Eklutna Hydroelectric Project

1991 Fish & Wildlife Agreement Implementation

Initial Information Package

FINAL

September 2020

This page intentionally left blank.

Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Table of Contents

Terms, Acronyms, and Abbreviations ...... ix

1.0 Introduction...... 1 1.1 Background on 1991 Fish & Wildlife Agreement ...... 1 1.1.1 Early Hydropower Development and Anchorage’s Energy Needs ...... 1 1.1.2 Federal Hydropower Development ...... 2 1.1.3 Sale of the Federal Project to the Local Utilities ...... 4 1.2 Requirements of the 1991 Fish & Wildlife Agreement ...... 5 1.2.1 Procedural Requirements ...... 5 1.2.2 Schedule Requirements ...... 7 1.3 Early Consultation and Information Gathering ...... 8 1.3.1 Initial Consultation Meetings ...... 9 1.3.2 Technical Group Follow-up Meeting ...... 9 1.3.3 Site Reconnaissance ...... 10 1.4 Purpose of the Initial Information Package (IIP) ...... 10 1.5 References ...... 10

2.0 Schedule and Communication Protocols ...... 12 2.1 Process Plan and Schedule ...... 12 2.2 Communications and Distribution Protocols ...... 15 2.3 References ...... 15

3.0 History of Development in the Eklutna Basin and Project Tailrace Area ...... 16 3.1 Alaska Native Historical and Current Presence ...... 16 3.2 Alaska Railroad ...... 21 3.3 Glenn Highway ...... 22 3.4 Early Hydropower Development ...... 25 3.4.1 Planning ...... 25 3.4.2 Original Construction and Subsequent Improvements ...... 25 3.4.3 Old Project Sold to the City of Anchorage ...... 28 3.5 Federal Hydropower Development ...... 29 3.5.1 Planning and Authorization ...... 29 3.5.2 Initial Federal Project Construction ...... 31 3.5.3 1964 Earthquake and New Dam Construction ...... 33 3.6 Stream Diversions ...... 35 3.7 Military Use and Facilities ...... 36

McMillen Jacobs Associates i September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

3.8 Campgrounds and Picnic Areas ...... 36 3.9 Chugach State Park ...... 37 3.10 Eklutna Water Project ...... 37 3.11 Gravel Pits ...... 40 3.12 Eklutna Salmon Hatchery ...... 42 3.13 Eklutna Tailrace Day-Use Fishing Access Site...... 42 3.14 Eklutna River Canyon Illegal Dump Site ...... 43 3.15 Removal of the Old Diversion Dam ...... 44 3.16 Timeline...... 49 3.17 References ...... 51

4.0 Project Facilities and Operations ...... 55 4.1 Project Facilities ...... 55 4.1.1 Dam and Spillway ...... 55 4.1.2 Reservoir ...... 58 4.1.3 Intake ...... 58 4.1.4 Tunnel and Surge Tank ...... 58 4.1.5 Penstock ...... 59 4.1.6 Power Plant and Switchyard ...... 59 4.1.7 Tailrace ...... 60 4.2 Project Operations ...... 60 4.2.1 Reservoir Operations ...... 60 4.2.2 Water Usage, Energy Generation, and Cost of Power ...... 63 4.2.3 Flood Protection ...... 63 4.2.4 Spill Events ...... 64 4.2.5 Emergency Action Plan ...... 66 4.3 References ...... 66

5.0 Description of Existing Environment ...... 67 5.1 Climate ...... 67 5.1.1 Historical Climate ...... 67 5.1.2 Climate Change ...... 67 5.1.3 References ...... 69 5.2 Geology ...... 70 5.2.1 Glacial Influence ...... 70 5.2.2 Eklutna Lake ...... 71 5.2.3 Dam Site ...... 71 5.2.4 Eklutna River Valley and Canyon ...... 71

McMillen Jacobs Associates ii September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

5.2.5 Sediment Accumulation behind Lower Dam ...... 72 5.2.6 Thunderbird Creek and Falls ...... 73 5.2.7 Alluvial Fan ...... 73 5.2.8 Seismicity ...... 74 5.2.9 References ...... 75 5.3 Water Resources ...... 76 5.3.1 Watershed and Drainage Area ...... 76 5.3.2 Hydrology ...... 76 5.3.3 Water Quality ...... 90 5.3.4 Water Rights ...... 95 5.3.5 References ...... 96 5.4 Fish and Aquatic Resources ...... 98 5.4.1 Historic Salmon Runs...... 98 5.4.2 Habitat Degradation ...... 100 5.4.3 Current Fish Habitat and Assemblage ...... 104 5.4.4 Macroinvertebrates ...... 114 5.4.5 Beluga Whales ...... 114 5.4.6 References ...... 115 5.5 Wetlands, Riparian, and Littoral Habitat ...... 117 5.5.1 Floodplains ...... 123 5.5.2 Wetlands ...... 123 5.5.3 Riparian Habitat ...... 123 5.5.4 Littoral Habitat ...... 124 5.5.5 References ...... 124 5.6 Terrestrial Resources ...... 125 5.6.1 Terrestrial Habitat ...... 125 5.6.2 Plant and Animal Species ...... 125 5.6.3 References ...... 127 5.7 Land Ownership and Management ...... 128 5.7.1 Chugach State Park ...... 128 5.7.2 Eklutna Lake Management Area ...... 134 5.7.3 Eklutna River Estuary Conservation Easement ...... 135 5.7.4 References ...... 136 5.8 Recreational Use and Facilities ...... 137 5.8.1 Eklutna Valley ...... 137 5.8.2 Eklutna Tailrace Day-Use Fishing Access Site ...... 140 5.8.3 References ...... 143

McMillen Jacobs Associates iii September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

5.9 Cultural Resources ...... 144 5.9.1 National Register of Historic Properties Sites ...... 144 5.9.2 Historic Sites ...... 146 5.9.3 Prehistoric Sites ...... 149 5.9.4 References ...... 149

6.0 Project Effects, PMEs Suggested by Others, and Information Needs ...... 152 6.1 Impacts to Fish and Wildlife ...... 152 6.2 Identified Goals and PMEs Suggested by Others ...... 156 6.2.1 Flow Related ...... 156 6.2.2 Non-Flow Related ...... 160 6.3 Information Needs ...... 167 6.3.1 Information Matrix ...... 168 6.3.2 Ongoing Efforts by Other Agencies/Organizations ...... 170 6.3.3 Studies Conducted in 2020 ...... 170 6.4 References ...... 171

7.0 Next Steps ...... 172 7.1 Develop Study Plans ...... 172 7.2 Submittal of Comprehensive Study Plan and Schedule to Governor ...... 173 7.2.1 Timing and Duration of Study Efforts ...... 173 7.2.2 Study Efforts Beyond Year One ...... 173

List of Tables Table 2-1. Schedule for complying with the requirements of the 1991 Fish and Wildlife Agreement ...... 13 Table 3-1. Dena’ina names of various places in the Eklutna Valley (Kari and Fall, 2003) ...... 17 Table 4-1. Historic Annual Eklutna Hydroelectric Project Water Usage and Energy Generation ...... 63 Table 4-2. Summary of Spill Events at Eklutna Dam from 1965 to 2019 (MJA, 2020) ...... 65 Table 5-1. Annual Flow of Eklutna River in Acre-Feet from 1924 to 1928 (AL&P, 1929) ...... 77 Table 5-2. Monthly Mean Discharge of Eklutna River at Diversion Dam 1930-1946 (USGS, 1947) ...... 79 Table 5-3.Stream Gages in the Eklutna River Watershed ...... 80 Table 5-4. Mean monthly flow values for East Fork Eklutna Creek ...... 81 Table 5-5. Mean monthly flow values for West Fork Eklutna Creek ...... 82 Table 5-6. Mean monthly flow values for Eklutna River ...... 85 Table 5-7. Mean monthly flow values for the Eklutna River at the Old Glenn Highway ...... 87

McMillen Jacobs Associates iv September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Table 5-8. Thunderbird Creek Estimated Flows (cfs) from May 2002 to April 2004 (NVE, 2003a) ...... 88 Table 5-9. Available USGS water quality data within the Eklutna River watershed (1948-1981) ...... 91 Table 5-10. Physical Characteristics of Reaches in the Lower Eklutna River (USACE, 2007) ...... 105 Table 5-11. NVE estimated total number of salmon in 2002 and 2003 (NVE, unpublished) ...... 108 Table 5-12. Results of Sampling Eklutna Lake in 1973, 1980, and 1985 (ADNR, n.d.) ...... 111 Table 5-13. Stocking records for Eklutna Lake (ADNR, 2016) ...... 112 Table 5-14. Results of Sampling Eklutna Lake in 1993 (USACE, 2011) ...... 112 Table 5-15. Wetland Descriptions and Acreage in the Project vicinity ...... 117 Table 5-16. Birds that may occur in the Project vicinity that are listed as Birds of Conservation Concern (BCC) (USFWS, 2020) ...... 127 Table 5-17. Hunting regulations for the Eklutna Lake Management Area (ADFG, n.d.) ...... 134 Table 5-18. Historic Sites ...... 146 Table 6-1. Estimated range of flow required for spawning and incubation (USFWS, 2019) ...... 157 Table 6-2. Approximate acre-feet of water required for USFWS preliminary estimated flow regime ...... 157 Table 6-3. Habitat Components of USACE Alternatives 2-5 (USACE, 2011) ...... 162 Table 6-4. Information Matrix ...... 168

List of Figures Figure 3-1. Map showing places with Dena’ina names in the Eklutna Valley (Kari and Fall, 2003) ...... 16 Figure 3-2. Eklutna River railway bridge with tents in background ...... 21 Figure 3-3. Looking downstream at the Eklutna River railway bridge (MJA, 2019) ...... 22 Figure 3-4. Completed bridge, January 21, 1954 (ARC, 1954) ...... 23 Figure 3-5. Eklutna River looking upstream at the New Glenn Highway bridges (MJA, 2019) ...... 24 Figure 3-6. Eklutna River looking upstream at the current Old Glenn Highway bridge (MJA, 2019) ...... 24 Figure 3-7. Original hydropower development on the Eklutna River (CEMML, 2002)...... 26 Figure 3-8. Upstream face of diversion dam under construction (CEMML, 2002) ...... 27 Figure 3-9. Eklutna Lake spillway discharging 1,500 cfs, July 7, 1929 (CEMML, 2002) ...... 27 Figure 3-10. Eklutna dam, weir, headgates, and breakwater (CEMML, 2002) ...... 28 Figure 3-11. Eklutna Dam Gate Structure (USBR, 1948) ...... 28 Figure 3-12. Schematic of the Federal hydropower project (USBR, 1958) ...... 32 Figure 3-13. Eklutna dam gate structure showing lake level in September 1963 (USBR, 1963) ...... 32 Figure 3-14. Schematic plan and profile of Project features after rehabilitation (USBR, 1967) ...... 34

McMillen Jacobs Associates v September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 3-15. Spillway under construction, August 19, 1965 (USBR, 1965) ...... 34 Figure 3-16. Lach Q’atnu Creek in June 1941 (left) and on August 7, 1950 (right) ...... 35 Figure 3-17. Dynamiting channel for the diversion of a stream into Eklutna Lake (USBR, 1962) ...... 35 Figure 3-18. 60th Infantry Troops Skiing Across Whiteout Glacier and rappelling from a helicopter at Eklutna Glacier, 1963 ...... 36 Figure 3-19. Eklutna Water Treatment Plant (AWWU, 2020) ...... 39 Figure 3-20. AWWU access road bridge (left) and fording the Eklutna River (right) (MJA, 2019) ...... 40 Figure 3-21. Lower Eklutna River Gravel Mining and Historical Stream Centerlines (NWS, n.d.) ...... 41 Figure 3-22. Location of the three ponds created in the old gravel pit (Ward, 2010) ...... 41 Figure 3-23. Eklutna Power Plant and tailrace, Eklutna Salmon Hatchery, and Eklutna Tailrace Day- Use Fishing Access Site...... 43 Figure 3-24. Debris being hoisted out of the canyon (NVE, n.d.) ...... 44 Figure 3-25. Lower dam prior to removal (The Conservation Fund, 2016) ...... 44 Figure 3-26. Looking upstream into canyon from lower staging area; fill placed in 2016 for the construction of an access route and helicopter landing pad/work area (HDR, 2016) ...... 46 Figure 3-27. View of the construction site (The Conservation Fund, 2017) ...... 47 Figure 3-28. Incremental process of excavating sediment from behind the lower dam (HDR, 2016) ...... 47 Figure 3-29. Incremental process of demolishing the dam (HDR, 2016) ...... 48 Figure 3-30. Removal of lower dam (The Conservation Fund, 2017) ...... 48 Figure 3-31. Lower dam site post dam removal, August 2019 (MJA, 2019) ...... 49 Figure 3-32. Timeline showing History of Development in the Eklutna River Basin and Project Tailrace Area ...... 50 Figure 4-1. Dam crest and ungated overflow spillway, looking north (MJA, 2019) ...... 55 Figure 4-2. Project Location ...... 56 Figure 4-3. Natural glacial moraine and remnants of old storage dams (MJA, 2019) ...... 57 Figure 4-4. Pond between the natural glacial moraine and existing dam in May 2020 ...... 57 Figure 4-5. Eklutna Power Plant ...... 59 Figure 4-6. Eklutna Lake Rule Curve (USBR, 1967) ...... 61 Figure 4-7. Eklutna lake level from June 1, 2000 to June 21, 2020 ...... 62 Figure 4-8. Spillway on August 14, 1956, flow was 1,050 cfs (USBR, 1956) ...... 64 Figure 4-9. Lake Elevations during Spill Events at Eklutna Dam from 1965 to 2019 (MJA, 2020) ...... 65 Figure 5-1. Alaska annual temperatures in Fahrenheit relative to 1951-1980 average, 1900-2018 (Thoman, 2019) ...... 68 Figure 5-2. Extent of Eklutna Glacier in 1957, 2010, and 2015 (Sass et al, 2017)...... 69

McMillen Jacobs Associates vi September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 5-3. Profile of Eklutna Lake and River showing select points of interest (Loso, 2019) ...... 70 Figure 5-4. Eklutna River Valley (left) and Canyon (right) (MJA, 2019)...... 72 Figure 5-5. Debris avalanches on bluffs along the Eklutna River, December 3, 2018 (USGS, 2018) ...... 74 Figure 5-6. Run-off of Eklutna River at the mouth of the canyon from 1924 to 1928 (AL&P, 1929) ...... 78 Figure 5-7. Eklutna Lake and Eklutna River on September 10, 1939...... 80 Figure 5-8. Eklutna River Sub-basins and Stream Gage Locations (USFWS, 2019)...... 81 Figure 5-9. Mean daily flow values for East Fork Eklutna Creek ...... 82 Figure 5-10. Mean daily flow values for West Fork Eklutna Creek ...... 83 Figure 5-11. East and West Forks of Eklutna Creek on June 11, 1965 ...... 83 Figure 5-12. East and West Forks of Eklutna Creek on July 12, 1957 ...... 84 Figure 5-13. Mean daily flow values for Eklutna River from 1947-1954 and 1955-1962 ...... 86 Figure 5-14. Eklutna Lake Outlet Streamflow Normalized by Mean Annual Flow (TU, 2018) ...... 86 Figure 5-15. Mean daily flow values for the Eklutna River at the Old Glenn Highway ...... 87 Figure 5-16. Thunderbird Creek Estimated Flows (cfs) from May 2002 to April 2004 (NVE, 2003a) ...... 90 Figure 5-17. Preserving salmon for winter use (photo provided by The Conservation Fund) ...... 99 Figure 5-18. Fine sediment between cobble (left) & covering coarser substrate (right) (MJA, 2019b) .... 100 Figure 5-19. Eklutna River between railroad and New Glenn Highway bridges (MJA, 2019b) ...... 101 Figure 5-20. The remains of an electrical substation perched above existing ground level after approximately 20 vertical feet of aggregate was removed by mining operations (USACE, 2011) ... 102 Figure 5-21. Eklutna River Monitoring Site Map (ADFG, 2020) ...... 104 Figure 5-22. Map of Habitat Reaches in the Lower Eklutna River (USACE, 2007) ...... 105 Figure 5-23. Map of Habitat Reaches in the Eklutna River (NVE, 2020b) ...... 106 Figure 5-24. Timing of Life Stages for Coho, Chinook, and Sockeye (TU, 2018) ...... 107 Figure 5-25. Areas where salmon are known or suspected to spawn (USACE, 2011) ...... 109 Figure 5-26. Eklutna Lake Kokanee (ADFG, n.d.) ...... 111 Figure 5-27. Results of Sampling Eklutna Lake in 1988, 1989, and 1990 (ADNR, n.d.) ...... 113 Figure 5-28: The relative abundance of the most prevalent taxonomic groups for Thunderbird Creek and the Lower Eklutna River ...... 114 Figure 5-29. Location and Type of Wetlands in the Project Vicinity ...... 122 Figure 5-30. Moose and bear tracks, beaver dam, and porcupine in Eklutna basin (MJA, 2019) ...... 126 Figure 5-31. Land Ownership adjacent to Eklutna River ...... 129 Figure 5-32. Land ownership adjacent to Eklutna Lake ...... 130 Figure 5-33. Chugach State Park Land Use Designations (ADNR, 2016) ...... 132

McMillen Jacobs Associates vii September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 5-34. Eklutna Lake Management Area (ADFG, n.d.) ...... 135 Figure 5-35. Conservation Easements (NVE, 2014) ...... 136 Figure 5-36. Existing recreational facilities at the north end of Eklutna Lake (ADNR, n.d.) ...... 137 Figure 5-37. Erosion of Lakeside Trail, September 27, 2019 (Photo taken by Rick Sinnott) ...... 138 Figure 5-38. Existing recreational facilities around Eklutna Lake (ADNR, 2009) ...... 139 Figure 5-39. Proposed recreational facilities around Eklutna Lake (ADNR, 2016)...... 140 Figure 5-40. Angler Days at Eklutna Tailrace (ADFG, 2017) ...... 141 Figure 5-41. Sport Harvest of Coho and Sockeye at Eklutna Tailrace (ADFG, 2017)...... 141 Figure 5-42. Sport Harvest of Chinook at Eklutna Tailrace (ADFG, 2017) ...... 142 Figure 5-43. ADA Assessible Fishing Pads and Bridge at the Eklutna Tailrace (ADFG, 2020) ...... 142 Figure 5-44. Old Eklutna Power Plant, 1977 (NPS, 1980a) ...... 144 Figure 5-45. Old St. Nicholas Russian Orthodox Church in Eklutna, 1990 (HABS, 1990) ...... 145 Figure 5-46. Mike Alex Cabin (NPS, 1982) ...... 146 Figure 6-1. Aerial photo of the lower Eklutna River in August 1950 ...... 154 Figure 6-2. Aerial photo of the lower Eklutna River in July 1957 ...... 154 Figure 6-3. Aerial photo of the lower Eklutna River in July 1963 ...... 155 Figure 6-4. Aerial photo of the lower Eklutna River in September 1969 ...... 155 Figure 6-5. Aerial photo of the lower Eklutna River in April 2011 ...... 155 Figure 6-6. Eklutna PES Concept (ALICE, 2020) ...... 159 Figure 6-7. USACE Alternative 2: Constructed Channel with Large Woody Debris (USACE, 2011) ...... 163 Figure 6-8. USACE Alternative 3: Constructed Channel with Upstream Cross-Vane Weirs (USACE, 2011) ...... 164 Figure 6-9. USACE Alternative 4: Large Wood Debris, Boulder Clusters and Upstream Cross-Vane Weirs (USACE, 2011) ...... 165 Figure 6-10. USACE Alternative 5: Constructed Channel with Downstream Large Woody Debris and Boulder Clusters (USACE, 2011) ...... 166

Appendices Appendix A List of Studies Conducted to Date Appendix B Comment Response Table

McMillen Jacobs Associates viii September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Terms, Acronyms, and Abbreviations

1991 Agreement 1991 Fish and Wildlife Agreement

ADA Americans with Disabilities Act

ADEC Alaska Department of Environmental Conservation

ADFG Alaska Department of Fish and Game

ADL Alaska Division of Lands

ADNR Alaska Department of Natural Resources

ADOT&PF Alaska Department of Transportation and Public Facilities

AEA Alaska Energy Authority

AEC Alaska Engineering Commission

AF acre-feet

AGP Alaska Glacier Products

AHRS Alaska Heritage Resources Survey

AL&P Anchorage Light and Power

ALICE Alaska Institute for Climate and Energy

ANCSA Alaska Native Claims Settlement Act

ANILCA Alaska National Interest Lands Conservation Act

APA Alaska Power Administration

APU Alaska Pacific University

ARRC Alaska Railroad Commission

ATV all-terrain vehicle

AWC Anadromous Waters Catalog

AWWU Anchorage Water and Wastewater Utility

BCC Birds of Conservation Concern

BLM U.S. Bureau of Land Management

C celsius

CaCO3 calcium carbonate

cfs cubic feet per second

Chugach Chugach Electric Association, Inc.

CIAA Cook Inlet Aquaculture Association

CIRI Cook Inlet Regional, Inc.

McMillen Jacobs Associates ix September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

cm centimeters

CWA Clean Water Act

cy cubic yards

DO dissolved oxygen

DOE U.S. Department of Energy

DYRESM dynamic reservoir simulation model

EA Environmental Assessment

EAP Emergency Action Plan

Eklutna Purchasers ML&P, Chugach, and MEA

El elevation

EPA Environmental Protection Agency

ESA Endangered Species Act

Federal and State resource USFWS, NMFS, ADFG, ADEC, and ADNR management agencies

FERC Federal Energy Regulatory Commission

FONSI Finding of No Significant Impact

FPC Federal Power Commission

ft feet

GLT Great Land Trust

Governor Governor of Alaska

HEC-RAS Hydrologic Engineering Center's River Analysis System

ICC Indian Claims Commission

IDF Inflow Design Flood

IIP Initial Information Package

JTU Jackson Turbidity Units

km kilometers

kW kilowatt

kWh kilowatt-hour

L liters

LAS Land Administration System

LiDAR Light Detection and Ranging

m meters

McMillen Jacobs Associates x September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

MAUS Metropolitan Anchorage Urban Study

MDN marine-derived nutrients

MEA Matanuska Electric Association, Inc.

mg miligrams

mgd million gallons per day

mg/L milligrams per liter

mi miles

MJA McMillen Jacobs Associates

ML&P Municipal Light and Power

mm millimeters

MMPA Marine Mammal Protection Act

MOA Municipality of Anchorage

MW megawatt

NALA North Anchorage Land Agreement

NBA National Bank of Alaska

NEPA National Environmental Policy Act

NMFS National Marine Fisheries Service

NPS National Park Service

NRHP National Register of Historic Places

NTU Nephelometric Turbidity Units

NVE Native Village of Eklutna

NWI National Wetlands Inventory

NWS National Weather Service

OHA Office of History and Archaeology

OIA Office of Indian Affairs

PAD Pre-Application Document

PES Pumped Energy Storage

PME protection, mitigation, and enhancement

PMF Probable Maximum Flood

PMP Probable Maximum Precipitation

Project Eklutna Hydroelectric Project

McMillen Jacobs Associates xi September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Project Owners ML&P, Chugach, and MEA

PSI Periodic Safety Inspection

State State of Alaska

TEK Traditional Ecological Knowledge

Transaction Date October 2, 1997

TSS total suspended sediment

TU Trout Unlimited

TWG Technical Work Group

USACE U.S. Army Corps of Engineers

USBR U.S. Bureau of Reclamation

USFWS U.S. Fish and Wildlife Service

USGS U.S. Geological Survey

uS/cm microsiemens per centimeter

McMillen Jacobs Associates xii September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

1.0 Introduction

The Eklutna Hydroelectric Project (Project) is located in Southcentral Alaska approximately 30 miles northeast of downtown Anchorage near the Native Village of Eklutna (NVE). The Project was originally constructed by the Federal government in the 1950s but was later sold to and is currently owned by the Municipality of Anchorage (MOA) dba Municipal Light and Power (ML&P), Chugach Electric Association, Inc. (Chugach), and the Matanuska Electric Association, Inc. (MEA), collectively the “Project owners”. ML&P’s share of the Project is 53.33%, Chugach’s share is 30%, and MEA’s share is 16.67%.1 Both Chugach and MEA are non-profit cooperatives, formed to serve and provide affordable energy to their member-owners.

As part of the sale of the Project, the three utilities entered into the 1991 Fish and Wildlife Agreement (1991 Agreement) with the State of Alaska and multiple Federal agencies. The 1991 Agreement requires the Project owners to develop and propose to the Governor a program to protect, mitigate damages to, and enhance fish and wildlife impacted by the development of the Federal hydroelectric project.

The Project owners recognize that there is a high level of interest in the Project and are committed to meeting their obligations as outlined in the 1991 Agreement. The overarching goal of the owners is to develop the scientific information that will allow the Governor to make an informed decision. The Project owners have no pre-conception as to any particular outcome or what will be included in the Proposed Fish and Wildlife Program.

Interested members of the public can visit the Project website, www.eklutnahydro.com, to stay up to date on the efforts being undertaken by the Project owners to comply with the 1991 Agreement. All documents referenced in this Initial Information Package (IIP) are available on the Project website.

1.1 Background on 1991 Fish & Wildlife Agreement This section provides a brief overview of the historical events that ultimately led to the development of the 1991 Fish and Wildlife Agreement.

1.1.1 Early Hydropower Development and Anchorage’s Energy Needs Anchorage’s first electric power source was a steam power plant constructed by the Alaska Engineering Commission (AEC) in 1916. This 900-kilowatt (kW) power plant supported Anchorage’s power needs until 1929 when a private company, Anchorage Light and Power (AL&P), completed construction of a hydropower project at Eklutna. This project included a storage dam at the outlet of Eklutna Lake and a 61-foot-tall diversion dam on the Eklutna River approximately 7 miles downstream from the storage dam. Water was diverted from the river through an 1,800-foot-long tunnel and an 847-foot-long penstock to the power plant, and then discharged through the tailrace into the Knik Arm (CEMML, 2002). The power plant originally housed a 1,500 horsepower Pelton Wheel water turbine and a standard General Electric

1 MOA is currently in the process of selling ML&P to Chugach. However, MOA will retain its 53.33% share of the Project. Therefore, ownership shares of the Project will not change.

McMillen Jacobs Associates 1 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

1,250 kW generator. Identical turbine and generator units were installed in 1935, doubling the generating capacity of the power plant (AL&P, 1943).

In 1939 a new earth and rock fill dam was built at the lake outlet incorporating portions of the initial structure. This dam had 19 spillway gates to control discharge and thereby provide a more dependable water supply for the power plant. It also had 15 open bays which could be flash boarded to elevation 871 feet. The crest of the spillway gates, with the gates in the closed position, was at elevation 867.5 feet, the same as the crest of the ungated, open bay section (USBR, 1967). AL&P sold the hydropower project to the City of Anchorage in 1943 (FPC, 1944).

The City of Anchorage’s population increased dramatically in the 1940s due to the arrival of the military during World War II. The military immediately realized the Eklutna power plant could not meet its energy requirements and installed several diesel and steam plants around Fort Richardson. The rapid influx of people stretched city power sources to the absolute limit. As a result, the city leased and then purchased the stern half of an old oil tanker called Sackett’s Harbor which was equipped with a 3,000 kW coal generating power plant that was outfitted for connection to the municipal distribution system.

Even with the additional energy provided by Sackett’s Harbor, power shortages were critical. An old coal plant was intermittently brought back into service, and several diesel generating units were purchased. However, electrical demand still far exceeded the combined generating capacity of Anchorage power plants. Upgrades and expansions were no longer an option for the old Eklutna power plant. The city had simply outgrown the facilities (CEMML, 2002).

1.1.2 Federal Hydropower Development Recognizing the inevitable, the U.S. Bureau of Reclamation (USBR) began investigating the possibility of building a new, larger hydropower project at Eklutna (CEMML, 2002). In 1948 the USBR proposed replacing the then existing earth and rock fill dam with a concrete gravity type dam as well as constructing a tunnel through the mountain, a penstock down the mountain side, and a power plant at tidewater level. The proposed dam included an uncontrolled overflow spillway with a crest elevation at 870 feet, which would raise the maximum regulated lake level by approximately two feet. Unlike the hydropower project constructed by AL&P, the Federal project was not designed to release water from Eklutna Lake into Eklutna River, but to instead divert all outflow from Eklutna Lake through the new tunnel and power plant and into the Knik River (except if/when the lake elevation exceeded the elevation of the overflow spillway crest during a flood).

As part of their investigation, USBR consulted with several agencies including the City of Anchorage, Territorial Government of Alaska, Alaska Railroad, Alaska Road Commission, U.S. Bureau of Land Management (BLM), U.S. Bureau of Mines, U.S. Fish and Wildlife Service (USFWS), U.S Geological Survey (USGS), National Park Service (NPS), Office of Indian Affairs (OIA), U.S. Department of Agriculture, Civil Aeronautics Administration, Federal Power Commission (FPC), and the Department of National Defense.

At the time, the OIA operated and maintained the Eklutna Indian Reserve. In a letter to USBR, the General Superintendent of the OIA commented that “There is already a power shortage in the Anchorage area. We believe that the economical solution is the installation of a new Eklutna hydroelectric plant. This

McMillen Jacobs Associates 2 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package would not in any way, so far as we can see, conflict with the present Eklutna Indian Reserve.” However, it should be noted that there is no documentation that the Eklutna people were consulted with directly.

In a letter to USBR dated September 9, 1948 referring to USBR’s proposed plan at the time to raise the lake level by two feet, the USFWS stated that “…inasmuch as no salmon or game fish are involved, we can see no possibility of your proposal being harmful to wildlife interests.” The 1948 USBR report also stated that “Maintenance of a live stream for fish life is not necessary. There is so much suspended matter in the water that few if any fish inhabit the streams.” (USBR, 1948)

However, the project did require utilization of Eklutna Lake as a water storage reservoir, and impoundment and utilization of water theretofore utilized by the City of Anchorage for its existing hydropower project. On November 23, 1953, USBR and the City of Anchorage entered into a contractual agreement, No. 14-06-906(E)-1, entitled “Contract for Plant Purchase and Electric Service with the City of Anchorage, Alaska.” The contract reads in part:

“4. WHEREAS, completion and operation of the Eklutna project is dependent upon the United States acquiring all of the Contractor’s rights to water for the operation of the Contractor’s hydroelectric generating plant at Eklutna, Alaska (Federal Power Commission licensed Project No. 350), which will thereby render said generating plant useless to the Contractor; and

“5. WHEREAS, the Contractor is willing to transfer and deliver all its interest in and to said water rights, said generating plant, and associated facilities and properties to the United States if in return therefor Contractor is compensated by certain adjustments in rates and charges for the electric service furnished to it by the United States for the period of the remaining life of Contractor’s Federal Power Commission licensed Project No. 350, which license for Project No. 350 expires on October 12, 1978.”

The signing of the above contract removed the last remaining legal hurdle to construction of the Eklutna project (USBR, 1958). USBR paid the city $1,841,760 for the old project facilities (CEMML, 2002). It should be noted that the Federal government later transferred the lower diversion dam and any associated real property to Eklutna, Inc. and Cook Inlet Regional, Inc. (CIRI) in 1985 and 1986 pursuant to the Alaska Native Claims Settlement Act (ANCSA) (U.S. Patents, 1986a and 1986b).

The new Eklutna project was authorized on July 31, 1950 by Public Law 628, 81st Congress, 2nd Session, H.R. 940 (CEMML, 2002). The Law reads in part as follows:

“That in order to encourage and promote the economic development of the territory of Alaska, to foster the establishment of essential industries in said territory, and to further the self-sufficiency of national defense installations located therein, the Secretary of the Interior is authorized to construct, operate and maintain the Eklutna project in the vicinity of Anchorage, Alaska…”

It’s worth noting that because the new hydropower project was a Federal project, the first major development by USBR outside the continental United States, it did not require a license from the FPC.

McMillen Jacobs Associates 3 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

The Project was constructed between 1951 and 1955. It included an earthen dam at the outlet of Eklutna Lake with an uncontrolled overflow spillway, an intake structure on the north side of the lake approximately 1 mile east of the dam at the lake bottom, a 4.5-mile-long tunnel through Goat Mountain (now Twin Peaks), a 176-foot-tall surge tank, a 1,088-foot-long penstock, a power plant housing two vertical-shaft generating units, a switchyard located on the roof of the power plant, and a 209-foot-long tailrace that conveyed water under the Glenn Highway (now the Old Glenn Highway) and discharged it into the Knik River (USBR, 1958).

In 1964 the great Alaska earthquake caused considerable damage to the Eklutna project. Both a new intake structure and a new embankment dam were constructed in 1965. In 1967, the Alaska Power Administration (APA) was established and all responsibility for the operation and maintenance of the Eklutna project was transferred from USBR to the APA (USBR, 1967).

1.1.3 Sale of the Federal Project to the Local Utilities Besides the Eklutna project, the only other hydropower project to be constructed in Alaska by the Federal government was the Snettisham project near Juneau in 1973. Both projects were authorized to encourage economic and industrial development in Alaska. However, in the 1980s the APA concluded that it was no longer necessary to have a separate small Federal power program in Alaska, both projects were well suited to ownership and control within Alaska, and that the State and its electric utilities had excellent capability to manage the projects.

The divestiture of the projects was approached through a series of studies and public reports, interagency reviews, and consultation with interested parties. The process involved evaluation of issues, objectives, alternative approaches, an asset valuation, and consideration of public comments at three separate stages of the process. Formal invitation of proposals to purchase the projects were extended in the Spring of 1987 to the electric utilities served by the projects, municipalities in the project service areas, and the State of Alaska. In response to the solicitations, APA received one proposal for each project:

▪ A September 15, 1987 proposal from the Alaska Energy Authority (AEA) to purchase the Snettisham project. ▪ A November 9, 1987 joint proposal from the MOA dba ML&P, Chugach, and MEA to purchase the Eklutna project.

APA and the proposing parties negotiated purchase agreements which set forth specific terms and conditions for sale of the projects. The Eklutna Purchase Agreement was executed on August 2, 1989. The purchase agreement defined “Eklutna” as the Eklutna Hydroelectric Project authorized, constructed, and operated pursuant to the Eklutna Project Act of July 31, 1950, including any and all property and facilities acquired or used in connection with Eklutna. However, Section 4(e) of the Eklutna Purchase Agreement states that “The above description of assets is intended to be general and not precise or all inclusive. As part of the transition activities, the parties will jointly prepare a particularized listing of the assets to be sold and transferred.”

The APA then developed a legislative proposal to authorize the sale of the projects in accordance with the purchase agreements. Specific fish and wildlife measures were not contemplated in the earlier divestiture

McMillen Jacobs Associates 4 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package studies and reports or in negotiations for the purchase agreements because the projects were generally viewed as not involving fish and wildlife problems. However, the APA did submit the legislative proposal to various fish and wildlife agencies for review. Upon review of the legislative proposal, the loss of a sockeye salmon run that may have spawned in Eklutna Lake was identified by the National Marine Fisheries Service (NMFS). The loss would have been caused by AL&P’s development of the previous hydropower project in 1929. It was not identified in pre-authorization studies for the Federal project, and the Federal project did not include mitigation. This specific problem and the desires of the fish and wildlife agencies to provide appropriate consideration to fish and wildlife resources over the long run led to negotiation of a formal agreement between the purchasers, the State of Alaska, NMFS, and USFWS regarding protection, mitigation of damages to, and enhancement of fish and wildlife resources affected by hydroelectric development of the Federal Eklutna and Snettisham projects. The Fish and Wildlife Agreement was executed on August 7, 1991 (APA, 1992a).

The NMFS, USFWS, and the State agreed that the process outlined in the 1991 Agreement obviated the need for the purchasers to obtain a license from the Federal Energy Regulatory Commission (FERC) (Fish and Wildlife Agreement, 1991). The Divestiture Summary Report prepared by the APA in 1992 reads in part:

“Given the nature of the projects and the river basins affected, there is good reason to believe that the proposed arrangements will work at least as well as Federal regulation for the intended purpose of mitigation and enhancement of affected fish and wildlife resources. The August 7, 1991 Agreement affords fish and wildlife interests a stronger voice in project management than would be available under continued Federal ownership.”

The U.S. Department of Energy (DOE) prepared an Environmental Assessment (EA) to evaluate the proposed sale of the projects. Based on the analyses in the EA, the DOE determined that the proposed action did not constitute a major Federal action significantly affecting the quality of the human environment within the meaning of the National Environmental Policy Act (NEPA). Therefore, the DOE issued a Finding of No Significant Impact (FONSI) on March 27, 1992 (APA, 1992b).

In 1995, the U.S. Congress authorized and directed the Secretary of Energy to sell the Eklutna project to the MOA dba ML&P, Chugach, and MEA (Eklutna Purchasers). The Project was officially sold on October 2, 1997 (Transaction Date). It should be noted that the asset lists developed for the sale pursuant to the 1989 Eklutna Purchase Agreement did not include the lower diversion dam.

1.2 Requirements of the 1991 Fish & Wildlife Agreement

1.2.1 Procedural Requirements The 1991 Fish and Wildlife Agreement requires the Eklutna Purchasers to fund and conduct studies to examine, and quantify if possible, the impacts to fish and wildlife from the hydroelectric development of the Eklutna project. The studies must examine and develop proposed protection, mitigation, and enhancement (PME) measures for fish and wildlife affected by the Federal hydroelectric development. This examination must also consider the impact of fish and wildlife measures on electric rate payers,

McMillen Jacobs Associates 5 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package municipal water utilities, recreational users, and adjacent land use, as well as available means to mitigate these impacts.

The study plans must be developed by the Eklutna Purchasers in consultation with the USFWS, NMFS, the Alaska Department of Fish and Game (ADFG), the Alaska Department of Environmental Conservation (ADEC), and the Alaska Department of Natural Resources (ADNR), collectively the “Federal and State resource management agencies”. The study plans must include a schedule for the consultation, comment, and decision making required by the 1991 Agreement, which shall be adopted by the parties to the agreement in consultation with the Governor of Alaska (Governor). The Eklutna Purchasers must also receive concurrence on the scope of work from the Federal and State resource management agencies prior to implementation of the study program.

The Eklutna Purchasers are required to seek input from the Federal and State resource management agencies and other interested parties as the studies progress. The Eklutna Purchasers are also required to provide the Federal and State resource management agencies with an opportunity to comment on the draft study reports. All comments and responses must be included in the final study reports.

After final study reports are prepared, the Eklutna Purchasers are required to prepare a Draft Summary of Study Results and a Draft Fish and Wildlife Program. The Draft Fish and Wildlife Program must include the PME measures recommended by the Eklutna Purchasers and set a tentative schedule for their implementation. The Eklutna Purchasers are required to provide the Federal and State resource management agencies with an opportunity to comment on the draft Summary of Study Results and the Draft Fish and Wildlife Program and/or provide recommendations. If the Federal or State resource management agencies' comments or recommendations differ from those of the Eklutna Purchasers, the Eklutna Purchasers must attempt to resolve such differences giving due weight to the recommendations, expertise, and statutory responsibilities of the Federal and State resource management agencies.

Once comments and recommendations have been received, the Eklutna Purchasers are required to hold at least one public meeting each in Anchorage and the Matanuska Valley to receive public comment on the Draft Summary of Study Results, the Draft Fish and Wildlife Program, and the comments and recommendations of the Federal and State resource management agencies. The Eklutna Purchasers are required to prepare a summary and analysis of all comments received, develop a Proposed Fish and Wildlife Program, and prepare an explanatory statement describing the basis for the Proposed Fish and Wildlife Program. All of this information must be provided to the Federal and State resource management agencies and the Governor.

The Federal and State resource management agencies then have 60 days to submit to the Governor written comments on the Proposed Fish and Wildlife Program, as well as any recommendations for alternative PME measures. The Eklutna Purchasers then have 30 days to submit to the Governor written responses to any comments or recommendations from the Federal and State resource management agencies. The Governor is required to review the Proposed Fish and Wildlife Program as well as any comments or recommendations for alternative PME measures while giving equal consideration to:

1. Purposes of efficient and economical power production

McMillen Jacobs Associates 6 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

2. Energy conservation 3. Protection, mitigation of damage to, and enhancement of fish and wildlife (including related spawning grounds and habitat) 4. Protection of recreation opportunities 5. Municipal water supplies 6. Preservation of other aspects of environmental quality 7. Other beneficial public uses 8. Requirements of State law

Based on his/her review and consideration, the Governor is required to establish a Final Fish and Wildlife Program that adequately and equitably protects, mitigates damage to, and enhances fish and wildlife resources (including affected spawning grounds and habitat) affected by the Eklutna project. The Eklutna Purchasers are required to implement the Final Fish and Wildlife Program established by the Governor. However, the Governor’s decision and the provisions of the Final Fish and Wildlife Program are reviewable and enforceable in the U.S District Court for the District of Alaska, and the Court may order specific performance thereof (Fish and Wildlife Agreement, 1991).

1.2.2 Schedule Requirements The 1991 Fish and Wildlife Agreement gives deadlines for specific milestones in the consultation, program development, and implementation processes. These deadlines, listed below, are all relative to the date on which ownership of the Project was officially transferred from the Federal government to the Eklutna Purchasers (October 2, 1997). This date is referred to as the Transaction Date.

▪ Initiate the consultation process no later than 25 years after the Transaction Date (2022) ▪ Issuance of the Final Fish and Wildlife Program by the Governor at least 3 years prior to implementation (2024) ▪ Begin implementation of the Final Fish and Wildlife Program no later than 30 years after the Transaction Date (2027) ▪ Complete implementation of the Final Fish and Wildlife Program no later than 35 years after the Transaction Date (2032)

These timing provisions were designed primarily “to reduce uncertainties in financing and repayment of new debt by the Eklutna Purchasers, while recognizing that known fish and wildlife concerns were not of the type that would require near future action.” It should be noted that during informal consultation, the USFWS, NMFS, and ADFG judged the time frames within the agreement for assessing damages to the fish resources to be too far in the future and not realistic. They felt that by the time program implementation was initiated, loss to the salmon resources could not be adequately mitigated for. APA clarified that the time frames developed within the Fish and Wildlife Agreement were specifically done so for two reasons:

McMillen Jacobs Associates 7 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

1. The time frames defined within the agreement permit proper financing of the projects. It was expected that financial institutions would not provide financing if issues were outstanding and lacked resolution. By developing a binding and protective agreement, and putting off implementation dates, financing became an achievable goal.

2. Under continued Federal ownership, resolution of potential fisheries issues would not occur because the existing legislation and regulations did not prescribe natural resource damage type assessments, studies, or mitigation. Through the Fish and Wildlife Agreement, the fisheries resource agencies were able to attain and require the development of a fish and wildlife management planning process that would have oversight by a regional administrator and have implementation costs assumed by the new owners.

It should also be noted that upon review of the EA that was prepared for the proposed sale of the projects, ADFG recommended that the timeframes within the Fish and Wildlife Agreement be accelerated, and that the fish and wildlife mitigation analysis be initiated within three years. APA responded that “the time frames defined in the agreement were so designed to allow for proper financing of the projects. The agreement sets minimum limits for the implementation period but does not preclude the new owners from initiating the fish and wildlife agreement process at an early date. In addition, there is no identifiable or discernable difference in regard to resource degradation for utilization of either time frame.” (APA, 1992b)

The Eklutna Purchasers are required to repeat the process called for in the 1991 Agreement on a recurring basis every 35 years, beginning within 25 years of the time implementation of the Final Fish and Wildlife Program has been completed for the prior consultation process. In addition, the Eklutna Purchasers are required to repeat the process called for in the 1991 Agreement prior to undertaking any major structural or operational modifications substantially affecting water usage or fish and wildlife at the Project (Fish and Wildlife Agreement, 1991).

1.3 Early Consultation and Information Gathering Although the 1991 Agreement gives deadlines for specific milestones in the consultation, program development, and implementation processes, it does not preclude the Eklutna Purchasers (herein referred to as the Project owners) from initiating the fish and wildlife process early if the parties to the Agreement find that to be desirable.

In 2017 and 2018 the Anchorage Municipal Assembly, the Chugach Board of Directors, and the MEA Board of Directors all issued resolutions in support of their management working with the other parties to the agreement to advance the schedule and begin the study planning process consistent with the requirements set forth in the 1991 Agreement (Anchorage Municipal Assembly, 2017; Chugach, 2017; MEA, 2018). Therefore, in order to allow adequate time to meet the procedural requirements of the 1991 Agreement, the Project owners initiated the consultation process in 2019, more than three years earlier than the deadline specified in the 1991 Agreement.

McMillen Jacobs Associates 8 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

1.3.1 Initial Consultation Meetings In March and April of 2019, the Project owners conducted in-person initial consultation meetings with multiple agencies and interest parties. The 1991 Agreement only requires the Project owners to consult with the five Federal and State resource management agencies listed in the 1991 Agreement. However, because the Project owners recognize that there is a high level of interest in the Project from other entities for various reasons, the Project owners reached out to those entities for early consultation as well. In total the Project owners met with 14 agencies and interested parties as part of their initial consultation efforts. These entities are listed below.

▪ National Marine Fisheries Service (NMFS) ▪ U.S. Fish and Wildlife Service (USFWS) ▪ Alaska Department of Fish and Game (ADFG) ▪ Alaska Department of Environmental Conservation (ADEC) ▪ Alaska Department of Natural Resources (ADNR), including:  Division of Mining, Land, and Water  Division of Parks and Outdoor Recreation (Chugach State Park)  Office of History and Archaeology (OHA) ▪ Alaska Department of Transportation & Public Facilities (ADOT&PF) ▪ Alaska Railroad Corporation (ARRC) ▪ Anchorage Water and Wastewater Utility (AWWU) ▪ U.S. Army Corps of Engineers (USACE) ▪ Eklutna, Inc. ▪ Native Village of Eklutna (NVE) ▪ The Conservation Fund

Since the initial consultation meetings in March and April of 2019, the Project owners have identified additional interested parties and conducted initial consultation with those entities as appropriate. The Project owners will continue to reach out to new interested parties as they are identified.

1.3.2 Technical Group Follow-up Meeting During the initial consultation meetings, several entities requested a follow-up group meeting to promote technical discussion amongst the resource agencies and interested parties. In response to those requests, the Project owners conducted an in-person follow-up group meeting on July 16, 2019. Discussion topics included a review of the contact list and existing information gathered to date, updates on on-going data collection by others, an overview of current Project operations, discussion regarding the initial comments and concerns of agencies and interested parties, and next steps (MJA, 2019a).

McMillen Jacobs Associates 9 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

1.3.3 Site Reconnaissance In August 2019, the Project owners’ team conducted a site reconnaissance of the entire Eklutna River including the Project site. The primary goal of the site reconnaissance was to provide the Project owners’ technical and regulatory staff with the chance to review and observe site conditions and Project facilities. In addition, the site reconnaissance allowed technical staff to assess the potential scope of study efforts needed to provide the Governor with the information necessary to establish the Final Fish and Wildlife Program. The Project owners’ team was accompanied by AWWU staff during reconnaissance of the upper river and by NMFS staff during reconnaissance of both the upper and lower river (MJA, 2019b). The Project owners’ team conducted additional site visits in 2020 to support study planning and implementation.

1.4 Purpose of the Initial Information Package (IIP) The process outlined in the 1991 Agreement is very similar but not identical to a FERC licensing process. One notable difference is that a FERC licensing process requires the applicant to develop a Pre- Application Document (PAD), which is a summary of the existing or proposed project, a summary of existing information relevant to the environmental resources in the project area, a preliminary discussion about potential impacts of the project on known environmental resources, identification of information gaps, and identification of potential studies that might be needed to gather additional information. This document is then used to inform subsequent study planning discussions and decisions.

Therefore, although it is not required by the 1991 Agreement, the Project owners have developed this IIP to establish a baseline of existing information and to inform the study planning process that is required by the 1991 Agreement.

1.5 References AL&P (Anchorage Light and Power Company). 1943. Application for Amendment of License: Project No. 350, Exhibit M-1 Power Plant Equipment. October 26, 1943.

Anchorage Municipal Assembly. 2017. A Resolution of the Anchorage Municipal Assembly in Support of Efforts to Restore the Eklutna River. October 24, 2017.

APA (Alaska Power Administration), U.S. Department of Energy (DOE). 1992a. Divestiture Summary Report: Sale of Eklutna and Snettisham Hydroelectric Projects. April 1992.

APA, DOE. 1992b. Environmental Assessment: Submittal of a Legislative Proposal to Congress for the Sales of the Eklutna and the Snettisham Projects. Juneau, AK. March 27, 1992.

CEMML (Center for Environmental Management of Military Lands). 2002. The Early Electrification of Anchorage. Colorado State University, Fort Collins, CO. July 2002.

Chugach (Chugach Electric Association, Inc.). 2017. Resolution: Eklutna Project. November 29, 2017.

FPC (Federal Power Commission). 1944. Order Approving Transfer of License (Major): Project No. 350. March 1, 1944.

McMillen Jacobs Associates 10 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Fish and Wildlife Agreement: Snettisham and Eklutna Projects. 1991. Municipality of Anchorage dba Municipal Light & Power, Chugach Electric Association, Inc., Matanuska Electric Association, Inc., Alaska Energy Authority, National Marine Fisheries Services, U.S. Fish and Wildlife Service, and State of Alaska. August 7, 1991.

MEA (Matanuska Electric Association, Inc.). 2018. Resolution No. 2055: Eklutna Hydro Project Study Timeline. October 8, 2018.

MJA (McMillen Jacobs Associates). 2019a. Eklutna Hydroelectric Project: Fish & Wildlife Program Development: Technical Group Follow-up Meeting Minutes. July 16, 2019.

MJA. 2019b. Eklutna Hydroelectric Project: Fish & Wildlife Program Development: Site Reconnaissance Trip Report. August 2019.

USBR (U.S. Bureau of Reclamation). 1948. Eklutna Project to serve 25% of all Alaskans. Juneau, Alaska. October 1948.

USBR. 1958. Technical Record of Design and Construction: Eklutna Dam, Powerplant and Tunnel. Denver, CO. March 1958.

USBR. 1967. Rehabilitation of Eklutna Project Features Following Earthquake of March 1964. Denver, CO. June 1967.

U.S. Patent. 1986a. United States of America, Patent No. 50-86-0356. Surface transfer. Aug. 15, 1986.

U.S. Patent. 1986b. United States of America, Patent No. 50-86-0357. Subsurface transfer. Aug. 15, 1986.

McMillen Jacobs Associates 11 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

2.0 Schedule and Communication Protocols

2.1 Process Plan and Schedule Table 2-1 below shows the planned schedule for providing the Governor with a Proposed Fish and Wildlife Program and all supporting information needed for him/her to make a decision regarding the Final Fish and Wildlife Program before the October 2, 2024 deadline specified in the 1991 Agreement.

A meeting with agencies and interested parties was held on April 16, 2020 to review the Draft IIP and address any preliminary comments or questions (MJA, 2020b). The deadline for written comments on the Draft IIP was April 24, 2020. The Project owners’ technical team then reviewed each of the comment letters, finalized the IIP (this document) based on the comments received, and developed the comprehensive comment/response table included in Appendix B.

During the April meeting, the stakeholder group also discussed the need to establish a Technical Work Group (TWG) to engage in study planning and review of technical information developed by the study program. Since the primary interest of agencies and interested parties has been the restoration of flows to the Eklutna River, the intent of the Project owners is to start with one TWG focused initially on flow related study components, and then expand the TWG membership or establish separate TWGs as needed to cover other technical disciplines. Several entities with relevant expertise either agreed or volunteered to participate in the TWG (MJA, 2020b). After the April meeting, the Project owners coordinated with each of those entities to identify one or more representatives from each entity and establish the TWG. The TWG is comprised of technical experts and representatives from the following entities:

▪ Native Village of Eklutna (NVE) ▪ Alaska Department of Fish and Game (ADFG) ▪ U.S. Fish and Wildlife Service (USFWS) ▪ National Marine Fisheries Service (NMFS) ▪ Trout Unlimited (TU) ▪ Alaska Pacific University (APU) ▪ Alaska Institute for Climate and Energy (ALICE) ▪ Project Owners

In addition to finalizing the IIP, the Project owners’ team also revised the Information Matrix included in the Draft IIP based on the comments received from agencies and interested parties. The Project owners’ technical team then reviewed the revised Information Matrix with the stakeholder group during the quarterly update call held on June 2, 2020. Agencies and interested parties provided additional comments on the revised Information Matrix, and the group agreed to adopt the revised Information Matrix incorporating the additional comments (Table 6-4) as a provisional working document (MJA, 2020c).

The TWG met on July 15, 2020 to discuss the site reconnaissance scheduled for the following week (MJA, 2020d). The Project owners’ technical team conducted the site reconnaissance on July 20-22 to

McMillen Jacobs Associates 12 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package better familiarize their technical experts with the existing conditions in the Eklutna River (MJA, 2020e). The TWG met again on July 23, 2020 to review observations made during the site reconnaissance and kick-off the study planning process. This meeting included initial discussions regarding the planned instream flow study, potential methods, and associated challenges (MJA, 2020f). Based on that discussion and the revised Information Matrix, the Project owners’ technical team then developed a proposed Study Program Framework and presented it to the TWG on September 3, 2020. This meeting included discussion regarding how study efforts would occur over a two-year period, the study plan outline, and the study planning schedule (MJA, 2020g).

The remainder of 2020 will be used to develop and review the Draft Study Plans, revise and finalize the Study Plans based on comments from the TWG, obtain concurrence from the parties to the 1991 Agreement, and provide the Study Plans to the Governor. Next steps in early 2021 include briefing the Governor on the study schedule and supporting rationale for the study scope of work and starting the process of obtaining any permits or access permission that may be needed to conduct the agreed upon studies in 2021. Tentative dates for review and comment periods and meetings with the TWG for the remainder of 2020 are shown on the Project schedule so that individuals can plan ahead. However, these dates may change due to participant availability or unforeseeable circumstances. The Project owners will regularly update the schedule on the Project website as discussed in the following section.

The Project owners believe it is prudent to begin this substantial study effort by being somewhat conservative in terms of the overall schedule. The starting schedule includes time for a second study year for studies that will rely on the results of year one studies as well as should additional time be required to complete Year 1 studies. There may also be new Year 2 studies that are identified as being needed based on Year 1 study efforts that differ from Year 1 studies and thus would require additional study planning efforts. This may or may not be needed. The schedule also allows a full year for any necessary modeling, integration of study results, development of a decision matrix, and conducting a PME alternatives analysis in consultation with the agencies and interested parties. Again, a full year may not be needed. Accounting for future uncertainties, the starting schedule will still allow the Governor to meet the October 2, 2024 deadline for issuing the Final Fish and Wildlife Program.

Table 2-1. Schedule for complying with the requirements of the 1991 Fish and Wildlife Agreement

Activity Time Frame

IIP Development January 2020 – September 2020

Develop Draft IIP January 2020 – March 23, 2020

Draft IIP Uploaded to the Project Website for Review March 24, 2020 and Comment

Meeting with Agencies and Interested Parties to Review April 16, 2020 the Draft IIP and Address Preliminary Comments and Questions

Deadline for Written Comments on the Draft IIP April 24, 2020

Develop Comment/Response Table and Finalize IIP April 27, 2020 – September 2020

McMillen Jacobs Associates 13 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Activity Time Frame

Year 1 Study Plan Development July 2020 – March 2021

Establish TWG May – June 2020

TWG Meeting to Prep for Site Reconnaissance July 15, 2020

Site Reconnaissance July 20, 2020 – July 22, 2020

TWG Meeting to Kick-off Study Planning Process July 23, 2020

Develop Proposed Study Program Framework July 24, 2020 – August 2020

TWG Meeting to Discuss Draft Study Program September 3, 2020 Framework

Draft Year 1 Study Plans and Distribute to TWG September 2020 – October 23, 2020

Review and Comment Period October 23, 2020 – November 20, 2020

TWG Meeting to Review Comments on the Draft Year 1 Week of November 23, 2020 Study Plans

Prepare Comment/Response Table, Revise Year 1 November 30, 2020 – December 18, 2020 Study Plans, and Distribute to Parties of the 1991 Agreement

Review and Approve Revised Year 1 Study Plans December 18, 2020 – December 31, 2020

Submit Approved Year 1 Study Plans to the Governor January 1, 2021

Governor’s Review Period January 1, 2021 – January 29, 2021

Meeting with the Governor to discuss any Feedback on Week of February 1, 2021 the Approved Year 1 Study Plans

Discuss Governor’s Feedback with TWG, Revise Year 1 February 8, 2021 – February 26, 2021 Study Plans (if needed), and Post Final Year 1 Study Plans to Project Website

Obtain any Permits and/or Access Permission needed January 2021 – March 2021 for Year 1 Study Implementation

Year 1 Study Implementation and Reporting March 2021 – January 2022

Year 2 Study Plan Development November 2021 – March 2022

Year 2 Study Implementation and Reporting March 2022 – January 2023

Modeling, Decision Matrix, Alternatives Analysis January 2023 – December 2023

Fish and Wildlife Program Development January 2024 – September 2024

Deadline for the Governor to Issue the Final Fish October 2, 2024 and Wildlife Program

McMillen Jacobs Associates 14 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

2.2 Communications and Distribution Protocols In 2019 the Project owners developed and launched a Project website, www.eklutnahydro.com. The purpose of this website is to provide information on the efforts being undertaken by the Project owners to comply with the 1991 Fish and Wildlife Agreement, including background information, the Project schedule, Project updates, reference and final documents, frequently asked questions, and a contact form. Agencies and interested parties will be notified via email when new updates are posted on the website.

Draft documents will be distributed electronically to the appropriate entities for review and comment. For example, draft meeting minutes will be distributed to all meeting attendees, and draft technical documents will be distributed to the representatives on the TWG. All final documents will be made publicly available on the Project website for easy reference.

During the July 2019 Technical Group Follow-up Meeting, it was suggested that the Project owners conduct quarterly calls to update the agencies and interested parties on Project activities (MJA, 2019a). The Project owners conducted the first quarterly update call in November 2019 and subsequent quarterly update calls in February, June, and September of 2020 (MJA, 2019b; MJA, 2020a; MJA, 2020c; MJA, 2020h). The Project owners will continue to conduct quarterly update calls approximately every three months. Final meeting minutes for each call will be posted on the Project website.

2.3 References MJA (McMillen Jacobs Associates). 2019a. Eklutna Hydroelectric Project: Fish & Wildlife Program Development: Technical Group Follow-up Meeting Minutes. July 16, 2019.

MJA. 2019b. Eklutna F&W Agreement: Quarterly Update Call Meeting Minutes. November 15, 2019.

MJA. 2020a. Eklutna F&W Agreement: Quarterly Update Call Meeting Minutes. February 13, 2020.

MJA. 2020b. Eklutna F&W Agreement: Eklutna Hydroelectric Project: Fish & Wildlife Agreement Implementation: Stakeholder Meeting. April 16, 2020.

MJA. 2020c. Eklutna F&W Agreement: Quarterly Update Call Meeting Minutes. June 2, 2020.

MJA. 2020d. Eklutna F&W Agreement: TWG Meeting Minutes. July 15, 2020.

MJA. 2020e. Eklutna Hydroelectric Project: Fish & Wildlife Agreement Implementation: Site Reconnaissance Trip Report. July 2020.

MJA. 2020f. Eklutna F&W Agreement: TWG Meeting Minutes. July 23, 2020.

MJA. 2020g. Eklutna F&W Agreement: TWG Meeting Minutes. September 3, 2020.

MJA. 2020h. Eklutna F&W Agreement: Quarterly Update Call Meeting Minutes. September 10, 2020.

McMillen Jacobs Associates 15 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

3.0 History of Development in the Eklutna Basin and Project Tailrace Area

Eklutna Lake historically drained into the Eklutna River which extends approximately 12 miles northwest where it discharges into the Knik Arm. This section provides a chronology of historical use and development in the Eklutna River basin, including the Project tailrace.

3.1 Alaska Native Historical and Current Presence The Native Village of Eklutna (NVE), or Eklutna village, is located near the mouth of the Eklutna River in the Cook Inlet Region of Southcentral Alaska. The indigenous inhabitants of this area are the Dena’ina (or Tanaina), Athabaskan (or Athapaskan) speakers believed to have arrived in interior Alaska sometime between 1,000 and 1,500 years ago (Cook Inlet Historical Society, n.d.). According to some sources, the Dena’ina may have replaced or displaced earlier Yupik or Inuit residents in the Cook Inlet area (Lobdell, 1984; Chandonnet, 1979 and 1991; Dumon and Mace, 1968). Regarding the establishment of Eklutna village, Billy Pete, a former Eklutna elder, stated that “Eklutna is an old, old village. Nobody knows when they first moved there. People came down the Matanuska River then they returned to Cook Inlet after the Ice Age.” Johnny Shaginoff, another former elder, recalls “Eklutna was always an old village” (Kari and Fall, 2003). Figure 3-1 and Table 3-1 below show the Dena’ina names for various places within the Eklutna Valley.

Figure 3-1. Map showing places with Dena’ina names in the Eklutna Valley (Kari and Fall, 2003)

McMillen Jacobs Associates 16 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Table 3-1. Dena’ina names of various places in the Eklutna Valley (Kari and Fall, 2003)

No. Dena’ina Translation Also known as

21 Idlughet “By the Objects” Eklutna village

22 Idlishla “Small Plural Objects” North hill on Eklutna Flat

23 Idlika’a “Big Plural Objects” South hill with gravel quarry on Eklutna Flat

24 Idluytnu “Plural Objects River” Eklutna River

25 Chishkatnu “Big Ochre Creek” Thunderbird Creek

26 Kuy’inshla Betnu “Little Heart Creek” Creek into Thunderbird Creek

27 Kuy’inshla “Little Hear” Small peak 4009’ east of Mount Eklutna

28 Bentulik’elashi “The One That Dogs Are Driven Ridge extending west of Twin Peaks Up”

29 Ghetgge Daydlent “Where It Flows Between” Creek that crosses Eklutna Lake Road at Chugach State Park boundary

30 K’enan Qetni’unt “Where There Is a Face” On Eklutna Lake Trail, five to six miles from village

31 Benshla “Little Lake” Lake Barbara

32 Huch’iydelq’uht “Where We Build a Fire for Creek from West Twin Peak into Ourselves” Eklutna River

33 Lach Q’atnu “Clay Hole Creek” Lach Q’atnu Creek

34 Lach Q’a “Clay Hole” Twin Peaks

35 Dnasan “A Man Is Standing” Rock pinnacle between Twin Peaks

36 Idlu Bena “Plural Objects Lake” Eklutna Lake

37 Ben Q’estsiq’ “Lake Outlet” Outlet of Eklutna Lake

38 Lachda “Silt Place” Mineral lick south of Eklutna Lake outlet

39 Ts’inshla “Little --" Rocks on north shore of Eklutna Lake before Yuditnu

40 Yuditnu “Golden Eagle Creek” Creek at large point on north shore of Eklutna Lake

41 Yudi Qeneh “Golden Eagle House” Black Peak, mountain at head of Yuditnu

42 Sdaylent “Where Current Flows at the Creek into Eklutna Lake in the middle of Point” the north shore

McMillen Jacobs Associates 17 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

43 Qunsha Qeneh “Ground Squirrel House” Mountain, elevation 3000’, east of Sdaylent

44 Nuji Qeneh “Sheep House” Bold Peak

45 Nuhalch’k’eldelt “Where We Return with Packs” Site at start of East Fork trail at head of Eklutna Lake

46 Niltanikda Betnu “Creek of the One That Is East Fork of Eklutna Creek Leaning”

47 Niltani, Niltanikda “The One That Is Leaning” Hill elevation 3000’, north of East Fork trail

48 Bendilent “Creek from Eklutna Glacier” West Fork of Eklutna Creek

49 Idlu Bena Li’a “Glacier of Plural Objects Lake” Eklutna Glacier

50 Idlu Bena “Mountain of Plural Objects The Mitre Dghelaya Lake”

51 Nuhdaltunt “Ridge That Extends Across” Ridge on south shore of Eklutna Lake

52 Snutnadzeni “That Which Extends away Mount Eklutna Steeply”

53 Snutnadzeni T’ugh “Lakes Beneath That Which Mirror Lake and Edmonds Lake Daydliyi Ben Extends away Steeply”

The name Eklutna is derived from the Dena’ina name for the Eklutna River, Idluytnu, meaning “Plural Objects River”. The Dena’ina name for Eklutna village is Idlughet, meaning “By the Objects”. The “objects” referred to in both names are a unique granite formation (two hills) on the shore of the inlet just north of the village, often referred to by the Eklutna people as “The Knobs”. Both hills served as navigational aids for Dena’ina on the land and the water. Travelers used them to gauge travel time and determine their location. They marked a source of water, shelter, and hospitality. Both hills served as lookout sites to guard the Knik Arm Dena’ina villages against attack from the Ulchena (Alutiiq). They were also game lookouts and played a role in Dena’ina subsistence activities, such as hunting, harvesting edible wild plants, and gathering wood for fuel, smoking fish, construction, and manufacture of tools. The story about the formation of the hills, as told by former elder “Eklutna Alex” and translated by Billy Pete, is as follows:

“The Ahtna used to come out to Eklutna. Two sisters came out to the outlet of Eklutna Lake for trout, being without food, and they had gone up there for trout. A trout swam into their trap. It was a little trout, and they threw it back in the water upstream. The lake is seven miles long. It is large. Those Ahtna women threw the little fish back in with its head facing upstream and [they said to it] “You go back to your mother and father. We might have saved ourselves [from starvation] by [eating] you. You tell him that you are too small,” they told it. “You tell him that when you return to him.” They spoke to it there in the Ahtna language, and they threw it back in the water, and it swam back up the lake. When that little trout told that [giant] underwater creature [what they had said], it [a giant fish] swam downstream. It swam up from the bottom.

McMillen Jacobs Associates 18 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Only one creature stayed there. A noise was heard in the water. That creature under the water was starting to move around. The [the girls] ran to the mountain. That lake is between mountains, and then a [giant] fish swam up from below, and it swam out through the lake outlet. It floundered along the creek; downstream the cliffs form a big canyon. It swam into that canyon. The water level dropped there and it died. As it swam through the outlet, the water washed out the land, and all over Eklutna [pieces of] all of that land remained. That is why its name is ‘By the Plural Objects’. That is what they told me about it. That is the Eklutna story that I know.”

Since at least the 1940s, the Alaska Railroad has quarried rock from its property at the southern hill (Idlika’a). The remainder of the hill was owned by the National Bank of Alaska (NBA), which in the 1990s began developing plans to mine the rock as well. In 1996 and 1997, the Eklutna Tribal Council voiced objections to continued mining at the railroad quarry and further development of the bank property because of the importance of the hill as a landmark and symbol of identity for the people of Eklutna. On February 5, 2000, the Alaska Supreme Court ruled that the City of Anchorage had erred in issuing a permit to NBA to operate a quarry at this site because of inadequate consideration of the potential damage to archaeological and historical resources. It ordered the City’s planning commission to conduct a more thorough analysis and weigh the value of preserving the cultural values against the potential economic benefits of mining the rock. Several traditional semi-subterranean dwellings (nichilq’a in Dena’ina Athabascan) and storage caches were identified on the property. They are among the few remaining undisturbed Dena’ina habitations within the Municipality of Anchorage. In 2014 Wells Fargo Bank (who bought NBA) donated the 143-acre tract of land back to Eklutna village through a conservation easement for permanent land and habitat preservation (Kari and Fall, 2003).

The Eklutna River drainage was an important subsistence hunting area for Eklutna Natives up through the 1950’s. Eklutna Natives hunted sheep, moose, ground squirrels, and bear in the watershed. In addition, subsistence fishing has always played an important role in the lives of the Dena’ina (USACE, 2011). The Dena’ina maritime culture historically included utilizing ocean-run salmon streams, summer salmon traps, and fish camps. “During summer months the early villagers would move down along Knik Arm and Ship Creek to reach Fire Island. Here they would fish from their traditional subsistence fish camps. In the fall, they would return to Eklutna to spend the winters and spring. Then the Eklutnans would trap and hunt especially in the Eklutna Lake area near their village” (NPS, 1982).

According to Chandonnet (1979 and 1991), while Eklutna village may have served as a primary settlement for the Dena’ina beginning circa 1650 A.D., the site would have only been used in winter. However, NVE disagrees with this interpretation. It is NVE’s understanding that ancient Eklutna Dena’ina did consider themselves a village people. Although most of the Eklutna people would disperse during the summer months to fish and hunt at various locations, it is NVE’s understanding that some people would have remained at Eklutna village to hunt and harvest salmon there, including from Eklutna River, and lay in food supplies for overwintering at Eklutna from both local and dispersed sources (Leggett, 2020).

By the late 1700s, Russian explorers and traders began arriving in Southcentral Alaska, followed by missionaries. At that time, the Dena’ina lived in scattered villages, and Eklutna village was considered the most important of several villages in the Knik Arm vicinity (NPS, 1982). It is believed that there were 3,000 to 5,000 Dena’ina living in the area (Cook Inlet Historical Society, n.d.). The Russian Orthodox tradition brought by missionaries had a significant following in Eklutna: “Eklutna, unlike most early

McMillen Jacobs Associates 19 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Native Interior villages north of the Alaska Peninsula, was influenced strongly by Russian (18th and 19th century) Missionaries. By 1880, there were a recorded 100 Tanaina-Eklutna converts to the Russian Orthodox faith; the Tanaina being among the most dominant converts, except for the Aleuts, in all of Alaska” (NPS, 1982).

The United States purchased Alaska from the Russian Empire in 1867. This act was followed by a gradual influx of newcomers to the area such as miners and traders, construction of a railroad through Dena’ina lands beginning in 1915, an influenza outbreak that decimated the Dena’ina population, and the founding of the City of Anchorage in 1920 (Eklutna, Inc., n.d.). Other changes in the 1920s included development of the first hydropower facility in the Anchorage area and establishment of a government-run vocational school at Eklutna.

In 1946 the United States established the Indian Claims Commission (ICC) to hear claims of any Indian tribe, band, or other identifiable group of American Indians against the United States. Native American tribes and bands were given five years to register claims with the commission, claims relating to past injustices of federal Indian policy, including lands illegally taken, lands taken for "unconscionably low" compensation, and the government's misuse of Indian monies. Altogether, by the deadline, 176 tribes and bands lodged 370 claims, which were separated into 617 dockets. From 1951 to 1972 a group of Dena’ina in Palmer, through Chief William Ezi, Sr. and others who lived in the area, had a claim for lands before the ICC. This claim extended around the shores of Knik Arm to the headwaters of the Knik and Matanuska rivers (Kari and Fall, 2003).

The Palmer Land Claim was voided with the passage of the Alaska Native Claims Settlement Act (ANCSA) in 1971 (Kari and Fall, 2003). ANCSA allowed Alaska Natives to retain 44 million acres of land and a cash settlement. This act created 13 Regional Corporations and approximately 175 village corporations. Eklutna, Inc. was formed on October 17, 1972 as one of the village corporations. Today, Eklutna, Inc. represents more than 170 shareholders and is managed by a Board of Directors, Chief Executive Officer, and Corporate Officers, with headquarters in Eagle River. Eklutna, Inc. is the largest private landowner in Anchorage, owning 90,000 acres within the Municipality of Anchorage and managing a variety of investments including commercial properties and residential developments (Eklutna, Inc., n.d.).

The Dena’ina Athabaskan people continue to live in Eklutna village and in the surrounding area. Eklutna village is unincorporated and lies within the Municipality of Anchorage. NVE is a federally recognized tribe, with a government office organized in 1961 by the traditional people of Eklutna village. Governance is provided via a 7-member elected Tribal Council serving 3-year terms and operating under a constitution. A Tribal Administrator is in charge of day-to-day operations, and judicial matters are addressed by 5 traditional Rule Keepers chosen by each prominent clan family. NVE has established goals for economic development, community development, education and employment, family support, health and wellness, and land and the environment. The Tribal Office is located in Chugiak (NVE, n.d.).

Due to provisions enacted in the Alaska National Interest Lands Conservation Act (ANILCA) in 1980, the Knik Arm region does not qualify under Federal or State regulations as a subsistence use area. Despite such regulatory issues, the NVE residents and other Dena’ina in the Knik Arm region that are indigenous

McMillen Jacobs Associates 20 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package to the area continue to harvest local resources for cultural uses and subsistence as they have done for centuries, utilizing educational subsistence permits. These types of permits allow NVE to maintain salmon gillnet sites for the purpose of educating children on the traditional subsistence lifestyle. Hunting and trapping on the inlands and in the mountains are also important traditional subsistence activities that continue today, along with the gathering of berries, plants, trees, and stones (USACE, 2011).

3.2 Alaska Railroad In 1914 the U.S. Congress authorized President Woodrow Wilson to construct the Alaska Railroad, which would extend 470 miles from Seward to Fairbanks. In 1915 Anchorage was established as a “tent city” and selected as the new headquarters for the project. Upon completion of the railroad in 1923, offices and maintenance shops were permanently located in Anchorage, and many of the construction workers stayed to settle the townsite (USBR, 1948). The railbed at Eklutna was moved in 1968 due to shoreline erosion (Section 905b Study).

In 1983, the U.S. Congress passed the Alaska Railroad Transfer Act authorizing the transfer of the Alaska Railroad from the federal government to the State of Alaska. In 1984 the Alaska Railroad Corporation (ARRC) was established as a public corporation authorized to own and operate the Alaska Railroad. The federal government officially sold the Alaska Railroad to the State of Alaska in 1985 (ARRC, 2020).

The Alaska Railroad crosses the Eklutna River at rail mile 140.8 (USACE, 2011). Photos of the original railroad bridge and the current railroad bridge are shown in Figures 3-2 and 3-3 below. Historic aerial photos of the lower Eklutna River indicate that the current railroad bridge was constructed before 1950.

Figure 3-2. Eklutna River railway bridge with tents in background

McMillen Jacobs Associates 21 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 3-3. Looking downstream at the Eklutna River railway bridge (MJA, 2019)

3.3 Glenn Highway In 1935 and 1936 the Palmer Highway was constructed to transport agricultural products from the Matanuska Valley to the markets in Anchorage (Mead & Hunt, 2014). As part of the Palmer Highway, a one-lane bridge was constructed across the Eklutna River approximately half a mile upstream from the existing railroad bridge (R&M, 2015).

In 1941 during World War II the Alaska Road Commission received a one-million-dollar appropriation endorsed by the War Department to construct the Glenn Highway from Palmer to the existing Richardson Highway. A few years later the Palmer Highway was incorporated into the Glenn Highway designation (Mead & Hunt, 2014). The one-lane bridge at the Eklutna River was expanded to two lanes in 1952 by moving the original upstream truss further upstream, adding a new third arch between the original two, and placing a concrete deck (R&M, 2015). Figure 3-4 shows the completed bridge in 1954.

McMillen Jacobs Associates 22 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 3-4. Completed bridge, January 21, 1954 (ARC, 1954)

The New Glenn Highway was constructed in 1975. This included construction of two new bridges (one northbound and one southbound) across the Eklutna River just downstream from the existing highway bridge (Figure 3-5). The original highway was left open to vehicular use and is today known as the Old Glenn Highway.

In 2010, an inspection of the Old Glenn Highway bridge that crosses the Eklutna River near Thunderbird Falls recommended that the bridge be replaced due to widespread deterioration and cracks in the welds and truss members, missing connections, member damage and section loss, rust, poor deck condition, and paint failure. As a result, the bridge was closed to vehicular traffic in 2012, then replaced and reopened in 2016 as shown in Figure 3-6 (R&M, 2015).

As part of the bridge replacement effort, the 100-year flood was calculated to be 1330 cfs, and the 500- year flood was calculated to be 1800 cfs. The abutments of the replacement bridge are outside the floodplain of the river, and the hydraulic capacity of the replacement bridge well exceeds the 500-year flood (the 500-year flood water surface is approximately 36 feet below the low chord of the bridge). The pier piles for the replacement bridge are high enough on the left overbank that the 100-year flood water surface elevation results in water that is only about one foot deep flowing around the base of the pier. The long-term likelihood of large-scale bank migration at the replacement bridge site is expected to be extremely low under the current flow regime because field observations after two consecutive years of high magnitude flooding in 2012 and 2013 showed no evidence of any significant bank instability or bank migration at the bridge site. Pier scour depth for a 100-year flood was calculated to be 3 feet (R&M, 2015).

McMillen Jacobs Associates 23 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 3-5. Eklutna River looking upstream at the New Glenn Highway bridges (MJA, 2019)

Figure 3-6. Eklutna River looking upstream at the current Old Glenn Highway bridge (MJA, 2019)

McMillen Jacobs Associates 24 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

3.4 Early Hydropower Development

3.4.1 Planning In December of 1921, AEC engineers John Longacre and C.D. Pollock visited Eklutna Lake to gather preliminary feasibility information regarding a potential hydropower development. Their brief survey resulted in a highly favorable recommendation. As a result, a more intensive survey of the Eklutna River, was conducted in 1922. The survey party determined exact dimensions of the lake, established a weir to measure water discharge, and gathered data on basic characteristics of the lake, river and surrounding area.

In 1922 local businessman Frank Reed decided to team up with AEC engineer John Longacre to develop the hydropower project at Eklutna. On September 28, 1922 Frank Reed filed a preliminary permit application with the Federal Power Commission (FPC). On March 9, 1923 the FPC granted Frank Reed the preliminary permit under Project Number 350 (P-350). The same year the preliminary permit was issued, Frank Reed formed AL&P which was tasked with development of the hydropower project at Eklutna.

In 1924 Frank Reed hired Seattle engineer Robert Howes to conduct initial studies of the Eklutna undertaking. Howes examined the market for power, the environment and climate of the proposed site, transportation issues, lake characteristics, head conditions, cost projections and other aspects of the project. Ultimately Howes concluded that the project was “one of decided merit”.

AL&P’s assured market for power relied on three principle consumers: the City of Anchorage, the Alaska Railroad, and city water pumping. The Alaska Railroad agreed to purchase power from AL&P in 1924. However, at that time a contract with the city had yet to be approved. The delay in this agreement may have kept AL&P from an earlier development schedule. By the end of 1924, Frank Reed had realized that the project was going to take longer to develop than anticipated. Therefore, he applied to the FPC for an extension of the preliminary permit. The FPC granted the amendment to the original application on April 4, 1925.

On June 15, 1927, AL&P submitted a proposal to the municipal council that offered to provide the city with electricity for municipal use and for retail distribution within the city limits. The proposal, Ordinance No. 68, outlined the terms of the contract and set rates for power consumption. On June 20, 1927, the city council held a public meeting to familiarize people with AL&P’s proposal and to solicit opinions. Fifteen to twenty people expressed opinions during the meeting and only one was opposed to the arrangement. Several other meetings were held to acquaint interested parties to Proposed Ordinance No. 68. The ordinance was authorized during a city council meeting on July 18, 1927. It bound the city to a fifteen- year contract with AL&P for the purchase of electric power for industrial, commercial and domestic purposes (CEMML, 2002).

3.4.2 Original Construction and Subsequent Improvements On October 12, 1928 the FPC issued a 50-year license authorizing construction of the hydropower project at Eklutna as well as "the occupancy and/or use by the Licensee of said lands of the United States and of all riparian rights appurtenant thereto which are necessary or useful for the purposes of the project".

McMillen Jacobs Associates 25 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Construction of the project was initiated in 1928 and completed in 1929. The project included both a storage dam at the outlet of Eklutna Lake and a diversion dam on the Eklutna River approximately 7 miles downstream from the storage dam (Figure 3-7). Water was released from the storage dam into the Eklutna River, then diverted from the river at the diversion dam through an 1,800-foot-long tunnel and an 847-foot-long penstock to the power plant, and then discharged through the tailrace into the Knik Arm.

The diversion dam was a concrete arch structure 61 feet high and 98 feet wide at the crest (Figure 3-8). There was a spillway at the top of the dam that was designed to allow passage of 6,000 cubic feet of water per second, and a sluice gate was built into the bottom of the dam to allow gravel and debris deposits to be released downstream. The dam did not include any upstream or downstream fish passage facilities (CEMML, 2002).

Figure 3-7. Original hydropower development on the Eklutna River (CEMML, 2002)

The initial storage dam was constructed on top the natural moraine left behind by the retreating Eklutna glacier (Figure 3-9). Construction materials included brush, clay, moss, logs, lumber and rocks. However, this initial structure quickly proved to be unsound, and the dam was almost destroyed by flooding in 1929 before the power plant ever went online (CEMML, 2002). This is because when the lake level rose 4 or 5 feet above the elevation of the natural moraine, the slightest leak allowed water to escape. To solve this problem, wood piling was driven across the mouth of the overflow channel to permit storage of water to a depth of 3 or 4 feet above the natural lake level (USBR, 1967). As the lake capacity decreased during dry periods of the year, sections of the piling could be removed to allow water over the spillway (CEMML, 2002).

McMillen Jacobs Associates 26 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 3-8. Upstream face of diversion dam under construction (CEMML, 2002)

Figure 3-9. Eklutna Lake spillway discharging 1,500 cfs, July 7, 1929 (CEMML, 2002)

McMillen Jacobs Associates 27 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

In 1939 a new earth and rock fill dam was built at the lake outlet incorporating portions of the initial structure. This dam had 19 spillway gates to control discharge and thereby provide a more dependable water supply for the power plant. It also had 15 open bays which could be flash boarded to elevation 871 feet (Figures 3-10 and 3-11). The crest of the spillway gates, with the gates in the closed position, was at elevation 867.5 feet, the same as the crest of the ungated, open bay section (USBR, 1967).

Figure 3-10. Eklutna dam, weir, headgates, and breakwater (CEMML, 2002)

Figure 3-11. Eklutna Dam Gate Structure (USBR, 1948)

3.4.3 Old Project Sold to the City of Anchorage The population of the City of Anchorage increased dramatically in the 1940s due to the arrival of the military during World War II, and the power plant began operating at full capacity. Unfortunately, it was at this time that Reed’s health began to deteriorate. Reed was already blind in one eye due to an accident

McMillen Jacobs Associates 28 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package suffered during military service. Glaucoma rapidly claimed the vision of his other eye. Facing the prospect of total blindness, Reed knew he could not successfully continue operating the company. He also realized that major upgrades would soon be required to cope with the city’s increasing power demands. Reed’s son, Frank M. did not want his father to sell the company, but Reed did not feel his son had the necessary experience to undertake the major fund-raising that expansion necessitated. So, when the city indicated an interest in buying the power plant, Frank I. Reed was ready to negotiate.

It was largely through the personal efforts of longtime Alaskan, William (Bill) Stolt, that the city purchased the Eklutna power plant. Stolt, an electrician, had long felt that the city should own the production system since it already owned the electric distribution system. It took Stolt several years to convince the city council that purchasing the Eklutna power plant was good for the city. The council eventually called for a special election for the purpose of submitting to the electors the question of whether or not Anchorage should purchase AL&P. The election was held on August 17, 1943, and the proposition passed. Ultimately, the city paid $1,000,000 for the facilities (CEMML, 2002).

By a general conveyance and other instruments, the project property and the license were conveyed to the City of Anchorage on October 15, 1943. On November 3, 1943, AL&P and the City of Anchorage jointly filed a request to the FPC for a transfer of the license. The license transfer was approved on March 1, 1944 effective October 15, 1943 (FPC, 1944).

3.5 Federal Hydropower Development

3.5.1 Planning and Authorization The City of Anchorage’s population continued to increase, and soon Anchorage’s electrical demand far exceeded the combined generating capacity of its power plants. Recognizing the inevitable, USBR began investigating the possibility of building a new, larger hydropower project at Eklutna (CEMML, 2002).

Several plans were investigated and discarded for various reasons. For example, it was determined that the construction of a series of dams down the canyon to develop the Eklutna River below the lake would have been economically infeasible because of the distance to impervious material in the streambed and abutments. Another plan involved a conduit from the lake to a point down the river near the existing diversion dam. However, the conduit route would have been on unconsolidated material with steep slopes and cut by deep side ravines. Further, climatic conditions would have most likely precluded winter operations unless the conduit was buried deeply, which would have involved construction in highly unfavorable ground and through suspected underground pockets of permafrost. All such plans stemmed from a desire to salvage and continue operation of the small existing power plant. However, it was determined that rehabilitation and enlargement of the power plant to take the full regulated flow of Eklutna River would have been almost as costly as new construction and would have only developed 27% of the potential power between the lake and the sea (USBR, 1948).

Another plan investigated for comparison and discarded was the construction of a steam plant. The cost of production of power in a new steam plant, of capacities which would have been considered as alternative to the Eklutna plant, was conservatively estimated at approximately 12.0 mills per kWh plus transmission costs (USBR, 1948).

McMillen Jacobs Associates 29 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

In 1948 the USBR proposed replacing the then existing earth and rock fill dam with a concrete gravity type dam and constructing a tunnel through the mountain, a penstock down the mountain side, and a power plant at tidewater level. The proposed dam included an uncontrolled overflow spillway with a crest elevation at 870 feet, which would raise the maximum regulated lake level by approximately two feet. Unlike the hydropower project constructed by AL&P, the Federal project was not designed to release water from Eklutna Lake into Eklutna River, but to instead divert all outflow from Eklutna Lake through the proposed tunnel and power plant and into the Knik River (except if/when the lake elevation exceeded the elevation of the overflow spillway crest during a flood). As part of their investigation, USBR consulted with several agencies including the City of Anchorage, Territorial Government of Alaska, Alaska Railroad, Alaska Road Commission, BLM, U.S. Bureau of Mines, USFWS, USGS, NPS, OIA, U.S. Department of Agriculture, Civil Aeronautics Administration, FPC, and the Department of National Defense.

At the time, the OIA operated and maintained the Eklutna Indian Reserve. In a letter to USBR, the General Superintendent of the OIA commented that “There is already a power shortage in the Anchorage area. We believe that the economical solution is the installation of a new Eklutna hydroelectric plant. This would not in any way, so far as we can see, conflict with the present Eklutna Indian Reserve.” However, it should be noted that there is no documentation that the Eklutna people were consulted with directly.

In a letter to USBR dated September 9, 1948 referring to USBR’s proposed plan at the time to raise the lake level by two feet, the USFWS stated that “…inasmuch as no salmon or game fish are involved, we can see no possibility of your proposal being harmful to wildlife interests.” The 1948 USBR report also stated that “Maintenance of a live stream for fish life is not necessary. There is so much suspended matter in the water that few if any fish inhabit the streams.” In the same report, the USBR concluded that:

“The use of electric power in the power market area is expanding so rapidly that new installations of hydroelectric power plants are needed as quickly as possible to meet the emergency requirements of existing loads and to permit the establishment of new industries to support increases in population and economic development.”

The report also determined that the project was feasible from both an engineering and economic standpoint and recommended that construction be authorized (USBR, 1948). The new Eklutna project was authorized on July 31, 1950 by Public Law 628, 81st Congress, 2nd Session, H.R. 940 (CEMML, 2002). The Law reads in part as follows:

“That in order to encourage and promote the economic development of the territory of Alaska, to foster the establishment of essential industries in said territory, and to further the self-sufficiency of national defense installations located therin, the Secretary of the Interior is authorized to construct, operate and maintain the Eklutna project in the vicinity of Anchorage, Alaska…”

It’s worth noting that because the Eklutna project was a Federal project, it did not require a license from the FPC. However, the project did require utilization of Eklutna Lake as a water storage reservoir, and impoundment and utilization of water theretofore utilized by the City of Anchorage for its existing hydropower project. On November 23, 1953, USBR and the City of Anchorage entered into a contractual

McMillen Jacobs Associates 30 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package agreement, No. 14-06-906(E)-1, entitled “Contract for Plant Purchase and Electric Service with the City of Anchorage, Alaska.” The contract reads in part:

“4. WHEREAS, completion and operation of the Eklutna project is dependent upon the United States acquiring all of the Contractor’s rights to water for the operation of the Contractor’s hydroelectric generating plant at Eklutna, Alaska (Federal Power Commission licensed Project No. 350), which will thereby render said generating plant useless to the Contractor; and

“5. WHEREAS, the Contractor is willing to transfer and deliver all its interest in and to said water rights, said generating plant, and associated facilities and properties to the United States if in return therefor Contractor is compensated by certain adjustments in rates and charges for the electric service furnished to it by the United States for the period of the remaining life of Contractor’s Federal Power Commission licensed Project No. 350, which license for Project No. 350 expires on October 12, 1978.”

The signing of the above contract removed the last remaining legal hurdle to construction of the Eklutna project (USBR, 1958). USBR paid the city $1,841,760 for the old project facilities including the existing storage dam (CEMML, 2002). It should be noted that the Federal government later transferred the lower diversion dam and any associated real property to Eklutna, Inc. and CIRI in 1985 and 1986 pursuant to ANCSA (U.S. Patents, 1986a and 1986b).

3.5.2 Initial Federal Project Construction The Eklutna project, the first major development by USBR outside the continental United States, was constructed between 1951 and 1955 (Figure 3-12). It included an earthen dam at the outlet of Eklutna Lake with an uncontrolled overflow spillway, an intake structure on the north side of the lake approximately 1 mile east of the dam at the lake bottom, a 4.5-mile-long tunnel through Goat Mountain (now Twin Peaks), a 176-foot-tall surge tank, a 1,088-foot-long penstock, a power plant housing two vertical-shaft generating units, a switchyard located on the roof of the power plant, and a 209-foot-long tailrace conduit that conveyed water under the Glenn Highway (now the Old Glenn Highway) to a 2,000- foot-long open tailrace channel which discharged into the Knik River (USBR, 1958).

As part of construction of the new Eklutna project, USBR strengthened and reinforced the existing storage dam at the outlet of Eklutna Lake. Principal improvements consisted of placing additional earthfill embankment material on the existing embankment, driving and anchoring additional sheet piling, and placing riprap on the upstream and downstream faces. As modified in 1952, the dam had a crest length of 555 feet and a crest elevation of 875 feet. The 19 spillway gates (Figure 3-13) were considered to be in such poor condition due to aging that they were required to be left in the closed position at all times (USBR, 1967).

McMillen Jacobs Associates 31 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 3-12. Schematic of the Federal hydropower project (USBR, 1958)

Figure 3-13. Eklutna dam gate structure showing lake level in September 1963 (USBR, 1963)

McMillen Jacobs Associates 32 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

3.5.3 1964 Earthquake and New Dam Construction On March 27, 1964 a 9.2 magnitude earthquake occurred in the Prince William Sound region of Alaska, with its epicenter about 75 miles east of Anchorage. The earthquake was the second largest earthquake ever recorded and caused considerable damage to the Eklutna project including the dam and intake structure.

Inspections of the intake structure revealed that some of the conduit joints had been separated by as much as 10 inches and that some of the conduit sections had been laterally displaced. It was subsequently determined that the movement resulted from a consolidation of materials in Eklutna Lake induced by the earthquake. The intake structure had moved approximately 44 inches toward the lake, and tensional forces in the precast conduit produced by this horizontal shift had caused separation of 10 of the 15 joints in the conduit. The opening of these joints allowed approximately 1,200 cubic yards (cy) of rock, gravel, and debris to enter the conduit and be deposited throughout the pressure tunnel. The debris was cleaned from the tunnel and temporary repairs were made to the conduit sections. A new intake structure was constructed about 222 feet downstream from the original structure (Figure 3-14). The new intake structure was keyed into the more compact glacial till to deter any similar future movement.

The dam at the lake outlet was inspected immediately following the earthquake. This inspection and other subsequent early inspections revealed no apparent damage. The frozen ground near the surface apparently moved as a mass during the earthquake and no cracks were formed in the area of the dam and spillway. However, later inspections revealed that some consolidation of the alluvium beneath the frozen layer had occurred resulting in the development of a void. By July 1964, it became apparent that the upper layers of alluvium under the spillway gate structure had begun to subside into the void. Two cracks approximately 1 inch in width had developed (one in the base of the spillway slab and one in the sill of the gate structure). In addition, a large part of the base slab obviously did not have foundation support as a result of the void. Subsequent studies indicated that instead of repairing the existing dam and spillway, it would be less expensive to build a new replacement dam and spillway near the downstream toe of the existing structure. All gates were locked open throughout the spring run-off (USBR, 1967).

Explorations for a replacement dam near the location of the existing dam revealed highly plastic clay in the foundation which would not support the spillway structure. However, a suitable foundation for the spillway was found about 1,400 feet downstream. The replacement dam was built in 1965 with an ungated overflow spillway (Figure 3-15). The new spillway crest has an elevation of 871 feet and is 3.5 feet higher than the previous spillway. This increased the active storage capacity by about 10% from 160,000 acre-feet to 175,000 acre-feet. The crest of the new dam itself is at elevation 891 feet which is 16 feet higher than the previous dam. This had the benefit of greatly increasing the surcharge storage capacity in the event of a flood. Gates and excess timbers were removed from the old dam to make it inoperative (USBR, 1967).

McMillen Jacobs Associates 33 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 3-14. Schematic plan and profile of Project features after rehabilitation (USBR, 1967)

Figure 3-15. Spillway under construction, August 19, 1965 (USBR, 1965)

McMillen Jacobs Associates 34 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

3.6 Stream Diversions Today, Lach Q’atnu Creek flows into Eklutna Lake. However, it originally flowed into the Eklutna River below the lake outlet. Historic photos provide some clues about when the creek was diverted. Figure 3-16 below shows a picture of Lach Q’atnu Creek in 1941 (left). This picture clearly shows Lach Q’atnu Creek flowing into the Eklutna River. Figure 3-16 also shows a picture of Lach Q’atnu Creek in 1950 (right). This photo shows Lach Q’atnu Creek flowing into Eklutna Lake. Therefore, it is likely that Lach Q’atnu Creek was diverted into Eklutna Lake sometime between 1941 and 1950. Unfortunately, there is no clear documentation regarding who diverted Lach Q’atnu Creek or when.

Figure 3-16. Lach Q’atnu Creek in June 1941 (left) and on August 7, 1950 (right)

In 1962 USBR diverted a small stream into Eklutna Lake by digging a short ditch with ditching powder. However, it is unclear which stream was diverted. Figure 3-17 below shows dynamiting the channel for the diversion and the resulting new channel and water flow (USBR, 1962). In 1963 the ditch was extended a short distance to pick up another small intermittent stream (USBR, 1963).

Figure 3-17. Dynamiting channel for the diversion of a stream into Eklutna Lake (USBR, 1962)

McMillen Jacobs Associates 35 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

A number of people believe that the small unnamed tributary that currently flows into the “pond” between the existing dam and the natural glacial moraine at the lake outlet originally flowed into the Eklutna River just downstream of the existing dam, and that the stream was diverted into the pond as part of the dam’s construction in 1965 (Meiklejohn, 2020). However, there is no clear documentation regarding if/when this stream was diverted or by whom, and it is unlikely that this is the stream that was diverted by USBR in 1962 and 1963 since the pond didn’t exist at that time. Another theory is that the stream wasn’t necessarily diverted but was instead “captured” when the existing dam was constructed (Sinnott, 2020). However, there is no clear documentation that this was the case either.

3.7 Military Use and Facilities In 1961 the army constructed a road along the lake shore to the Eklutna Glacier and conducted glacier training exercises for most of the summer (USBR, 1961). In 1962 the army relocated a section of the road between the lake and Eklutna Glacier. This relocation crossed the east fork of Eklutna Creek at a narrow spot where they built a Bailey bridge (USBR, 1962). This road (currently called the Eklutna Lakeside Trail) is now located within Chugach State Park and is managed by ADNR.

In 1963 the Assistant Secretary of the Interior withdrew 68.68 acres of land located approximately 10 miles south of Eklutna Lake within the Chugach Mountains (Eklutna Glacier Area) for use by the Department of the Army for training purposes as shown below in Figure 3-18 (BLM, 1963). The Eklutna Glacier Training Site is currently designated as a light maneuver and training area, the primary mission of which is to provide a glacier and mountaineering training site for company-size elements. Training currently authorized at the Eklutna Glacier Training Site consists of glacial travel, ice climbing, rescue techniques, and glacial warfare (U.S. Army, 2008).

Figure 3-18. 60th Infantry Troops Skiing Across Whiteout Glacier and rappelling from a helicopter at Eklutna Glacier, 1963

3.8 Campgrounds and Picnic Areas The Bureau of Land Management (BLM) built four campgrounds and a number of picnic areas around the lake in 1963 and 1964 (USBR, 1963 and USBR, 1964). These sites are now located within Chugach State Park and are managed by ADNR.

McMillen Jacobs Associates 36 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

3.9 Chugach State Park On January 3, 1959, President Eisenhower signed a special proclamation admitting the territory of Alaska into the Union as the 49th state. Over the next decade, the proximity of the Chugach Mountains to Anchorage, Alaska’s most highly developed urban area, soon awakened interest in its recreational potential for a large number of city dwellers. Members of relatively small special interest groups such as the Nordic Ski Club and the Mountaineering Club of Alaska had already been using the area for some years. However, the explosive growth of Anchorage soon posed a variety of problems. Private acquisitions of lands blocked public access into the Chugach Mountains and the accumulation of garbage at various entrance points became an eyesore to many citizens. Despite pressures for wider recreational opportunities, little or no maintenance of foot paths and trails existed, nor were sorely needed camping places developed. In addition, haphazard use and development threatened the watershed.

The varying interests seeking to use the Chugach Mountains and surrounding areas encountered difficulties when trying to use what appeared to be available land. This led to the formation of the Chugach State Park Ad Hoc Committee. Despite the diversity of interests (conservation, hunting, hiking, equestrian use, historical preservation, wilderness, dog sledding and snowmobiling, among others) among this group, they built support for the formation of a state park that would protect the mountains they felt belonged to the people. A number of State legislators took an interest in 1970 and worked to pass SB 388, “an act creating Chugach State Park”, found in Chapter 112 of Alaska’s Session Laws (AS 41.20.200- 240). On August 6, 1970 the legislation establishing Chugach State Park became a reality when Governor Keith Miller signed it into law. The five primary purposes for establishing Chugach State Park as outlined in the legislation are as follows:

▪ To protect and supply a satisfactory water supply for the use of the people. ▪ To provide recreational opportunities for the people by providing areas for specified uses and constructing the necessary facilities in those areas. ▪ To protect areas of unique and exceptional scenic value. ▪ To provide areas for the public display of local wildlife. ▪ To protect the existing wilderness characteristics of the easterly interior area.

The park boundary includes Eklutna Lake and the upper Eklutna River. Management responsibility for the park is assigned to ADNR for control, development and maintenance (ADNR, 2016).

3.10 Eklutna Water Project During the 1970s Anchorage’s water demand was expected to exceed its water supply by 1988. Therefore, it was determined that a new water source must be obtained. Many alternative sources of supplemental water for the Anchorage water service area were examined. A 1973 report titled Anchorage Water Sources examined several potential water sources ranging from artificial recharge of Anchorage Bowl aquifers and Cook Inlet desalinization to tapping streams from Portage to Chickaloon. That study recommended off stream storage of Ship Creek water on Fort Richardson as the most feasible solution to Anchorage’s water problems. Military opposition this proposal eventually led to studies performed as part of the USACE’s Metropolitan Anchorage Urban Study (MAUS) in 1979. The MAUS study reexamined several of the alternatives studied previously and other Ship Creek, Eagle River, Eklutna Lake, and

McMillen Jacobs Associates 37 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Campbell Creek alternatives. In total, at least 28 alternative water sources were considered for an Anchorage area water supply. Many of these are listed below with summarized reasons for rejection.

▪ Use of a dam on Ship Creek, or off-stream storage there, was rejected because of military opposition, high capital costs, adverse environmental impacts, inadequate long-term supply and complex water and land rights problems. ▪ Use of Anchorage Bowl groundwater resources, with or without artificial recharge of the aquifers, was rejected mainly because of already near-capacity development of that source, energy requirements, unknown impacts on present groundwater supplies, and because it offered only a short-term solution. ▪ Desalination of Cook Inlet was not economically feasible, and reuse of the then current water sources was too costly. ▪ The following streams were rejected as sources primarily because of lack of a suitable storage site, inadequate discharge, high sediment loads, or long or difficult water transmission line requirements: Little Susitna River, Matanuska River, Knik River, Peters Creek, South Fork Eagle River, Campbell Creek, Chester Creek, Rabbit/Indian/McHugh Creeks, Bird Creek, Twenty-Mile River, Portage Lake, Placer River, Six-Mile Creek, Resurrection Creek, and Chickaloon River. ▪ Pt. MacKenzie surface and groundwater sources were found to be inadequate, as were Eagle River, Matanuska-Knik and Portage area groundwater sources.

Final MAUS recommendations included development of an Eklutna diversion or an Eagle River dam and reservoir. These two sources were examined in detail by CH2M Hill in their 1981-1982 Eagle River Water Resource Study. However, a dam on Eagle River was ultimately rejected because of extreme adverse environmental impacts, great capital cost, technical complexity and difficulty of land acquisition. Therefore, Eklutna Lake was determined to be the best solution to Anchorage’s long-term water supply problems. There would be minimal adverse environmental impacts, and no geotechnical problems were identified. The main disadvantages included the high capital cost, water treatment requirements, and the deprivation of power-generating water to the Eklutna powerhouse. However, although tapping the Eklutna water source would have a high capital cost, its unit cost over the life of the project was the lowest of any alternative examined.

CH2M Hill proposed three different alternatives for utilizing the Eklutna water source: tapping the Eklutna Power Plant tunnel upstream of the power plant, tapping the tailrace after water was used for power generation, or pumping water from Eklutna Lake into Eklutna River and then taking the water from the river near the lower end of the valley. The CH2M Hill studies recommended the alternative which would take water from the tailrace because of its relative technical simplicity, and because it would not impact power plant generation. The project team later examined a fourth alternative which involved diverting water directly from Eklutna Lake or the power plant tunnel near the lake. This alternative was found to be superior when environmental, permitting, right-of-way, geotechnical, energy, and cost aspects were considered and is the alternative that was finally selected and developed.

Construction of the Eklutna Water Project was completed in 1988. The project diverts Eklutna Lake water from the power tunnel to a 7-foot diameter diversion tunnel that connects to a buried 54-inch pipeline

McMillen Jacobs Associates 38 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package located downstream from the existing dam at the lake outlet. Water flows by gravity through the 1-mile- long diversion tunnel and the approximately 6-mile-long buried pipeline down the Eklutna River valley to a 750 kW energy recovery station at the Eklutna Water Treatment Plant (Figure 3-19) located on a bench above the river near the site of the old diversion dam.

Figure 3-19. Eklutna Water Treatment Plant (AWWU, 2020)

There is a portal valve at the intersection of the tunnel and pipeline that is used to drain the pipeline for maintenance when needed. There is also a drain valve located at the approximate location where the pipeline exits the canyon. AWWU maintains an access road that roughly parallels the pipeline and crosses the riverbed in a series of bridges and fords (Figure 3-20). After treatment, water flows by gravity through a 23-mile-long buried pipeline to the distribution system near the Ship Creek Water Treatment Plant. This system supplies water to the Anchorage service area, from Eklutna Village to Potter Marsh in South Anchorage (AWWU, 1984).

In addition to being the main source of drinking water for the Anchorage service area, Eklutna Lake water is also used for bottle water. Alaska Glacier Products (AGP) currently purchases treated water from AWWU at the Eklutna Water Treatment Plant and then transports it to their bottling facility near Eklutna village. In 2016, AGP’s production was approximately 250,000 gallons per month. However, to meet a growing international demand, AGP plans to double or triple its output capacity (Sinnott, 2016).

McMillen Jacobs Associates 39 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 3-20. AWWU access road bridge (left) and fording the Eklutna River (right) (MJA, 2019)

At the time the Eklutna Water Project was being developed, it was projected that the project would decrease the amount of energy generated by the Eklutna Power Plant by approximately 6% in 1988 and up to 21% by 2025. However, the energy recovery facilities constructed as part to the Eklutna Water Project were estimated to recover up to 45% of the deprived energy production. In 1984 AWWU reached an agreement with the APA for an equitable method of replacing energy taken from the Eklutna Power Plant by the Eklutna Water Project (AWWU, 1984). However, it was later determined that the compensation methods outlined in the 1984 agreement were inappropriate because water diversions for the Eklutna Water Project constitute a small fraction of the available water supply. Therefore, the agreement was supplemented in 1988 and then again in 1993. The 1993 supplemental agreement is effective until 2025, at which time it was predicted that water diversions for the Eklutna Water Project (over a 12-month period) would exceed 18,000 acre-feet. Under this agreement, AWWU is required to compensate ML&P for the calculated net reduction in generation, except during spill events when water diverted by AWWU is not considered as diminishing power production at the power plant (Agreement for Public Water Supply, 1984; Supplemental Agreements, 1988 and 1993).

Today, approximately 10% of the water diverted from Eklutna Lake provides up to 90% of the public water supply for the Municipality of Anchorage. The remaining 90% of water diverted from Eklutna Lake is used for power production. Additional information regarding water use and power generation is included in Section 4.2.2.

3.11 Gravel Pits Gravel mining has occurred at various times and locations in the Eklutna River. The most notable gravel mining operation was operated by the Alaska Railroad downstream of the railroad bridge between the years of 1970 and 1984. The area mined was approximately 150 acres (based on aerial photograph measurements). Figure 3-21 shows the maximum extents of the gravel mining operation and the location of the historical centerline of the lower Eklutna River. Several other smaller areas upstream of the railroad crossing on the north side of the river have been mined periodically for gravel (NWS, n.d.).

A large 40-acre gravel mine located on the north side of the Eklutna River between the New Glenn Highway and the Alaska Railroad was operated from 2007 to 2018. The mine is owned jointly by Eklutna, Inc., which owns the surface land, and Cook Inlet Regional Inc. (CIRI), who owns the gravel beneath. Up to 200 truckloads of gravel were extracted from the mine per day (USACE, 2011).

McMillen Jacobs Associates 40 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 3-21. Lower Eklutna River Gravel Mining and Historical Stream Centerlines (NWS, n.d.)

In an effort to increase salmon habitat and help restore the fishery for subsistence use by the Native Village of Eklutna, a series of three interconnected ponds were created in the 1980s in an old gravel pit located approximately 0.75 miles upstream from the mouth of the Eklutna River as shown in Figure 3-22. The gravel pit was connected to the main-stem Eklutna River via an artificial channel. While providing off-channel habitat, this project did not restore river processes (Ward, 2010).

Figure 3-22. Location of the three ponds created in the old gravel pit (Ward, 2010)

McMillen Jacobs Associates 41 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

3.12 Eklutna Salmon Hatchery Owned and operated by Cook Inlet Aquaculture Association (CIAA), the Eklutna Salmon Hatchery is located at the head of the Project tailrace that flows into the Knik River (see Figure 3-23) and was originally constructed in 1982 as a pink, chum, coho, and Chinook salmon hatchery (CIAA, 2019c).

In 1992 a majority of the facility was converted to sockeye salmon production; and the facility produced sockeye and coho smolts for release to Eklutna Tailrace and sockeye fry for release to several Cook Inlet lakes (CIAA, 2019c). The purpose of this project was to provide sockeye salmon to the Upper Cook Inlet drift and set gillnet commercial fisheries, and to provide for a cost-recovery harvest at the Eklutna Salmon Hatchery. Returns of adult fish from smolt releases were generally less than expected. Fish returning to the hatchery were available for cost-recovery harvest but were of poor quality (CIAA, 2019a).

In 1998 fish production at the Eklutna Salmon Hatchery was suspended. Since then the facility has been maintained as an emergency backup system for Trail Lakes Hatchery. The facility is also used by ADFG to imprint and release Chinook and coho salmon smolts prior to their release in the Eklutna Tailrace (CIAA, 2019c).

In November 2018, Southcentral Alaska experienced a magnitude 7.0 earthquake that caused significant structural damage to roads, homes, and facilities including the Eklutna Salmon Hatchery. CIAA is currently assessing the damage to the hatchery to determine the cost of repairing the facility and is investigating options for restoring fish production at the facility. Although CIAA owns the hatchery buildings, the property is leased from ADNR. Over the last few years, CIAA has been working with ADNR to establish conditions for a new lease and it is expected that this process will be complete in 2020 (CIAA, 2019b).

3.13 Eklutna Tailrace Day-Use Fishing Access Site There is a recreational fishery in the Project tailrace that was originally supported by salmon returning to the Eklutna Salmon Hatchery. Due to the very large returns of coho, chum and sockeye salmon to the hatchery, a large number of sport fisherman started frequenting the site (APA, 1996). For many years, APA would submit a request to the ADFG Sport Fishing Division to provide management of sport fishing activities at the Project tailrace during that fishing season, and each year ADFG would provide basic site maintenance services, install appropriate signage, place two fish cleaning tables on site, and install portable toilets and a dumpster at the end of May and service them until removal in early September (APA, 1997 and ADFG, 1997).

When operation of the hatchery was suspended in 1998, ADFG began stocking the tailrace annually with coho salmon smolts reared at the ADFG Fort Richardson Hatchery. In 2002 they also started stocking chinook salmon smolts, which has provided a popular chinook salmon fishery since 2004. Salmon originating from the drainages of the Knik and Matanuska rivers are also harvested at the confluence of the tailrace and the Knik River.

In 2005 ADFG completed several improvements at the tailrace site (Figure 3-23) including rerouting and improving the public access road to the mouth of the tailrace, increasing the size of the parking lot, and

McMillen Jacobs Associates 42 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package providing ADA accessible trails, fishing pads, a bridge (to provide convenient access to both sides of the tailrace), toilet screens and improved refuse receptacles (ADFG, 2020). ADFG currently provides dumpster pick-up, a fish cleaning table, vault latrines, and contracts out for patrols and litter pick-up. Sport fishing for chinook salmon at the tailrace continues to be a popular recreational activity, and a youth only fishery takes place each year in June (ADFG, 2019).

Figure 3-23. Eklutna Power Plant and tailrace, Eklutna Salmon Hatchery, and Eklutna Tailrace Day- Use Fishing Access Site

3.14 Eklutna River Canyon Illegal Dump Site An illegal dump pile was located near the lower dam site in the Eklutna River Canyon. In June 2002, NVE applied to the national Tribal Interagency Workgroup for a Tribal Open Dump Cleanup Project. NVE was awarded the funding and completed the project in 2004. Debris was hoisted out of the canyon using crane with a 200-foot boom (Figure-24). The dump pile consisted of: 45 vehicles (including an RV and a couple of motorcycles), 10 barrels (some originally with unknown contents, some were labeled as containing hydrofluorocarbons, but none contained much more than water), 8 newspaper vending machines, 5 bicycles, 3 propane canisters, 3 paint cans, 5+ laundry machines, 2 refrigerators, 2 ovens, 2 computer CPUs and 2 CRT monitors, a record player, 2 dead moose, 3 dead dogs, 1 dead bear, 1 dead porcupine, lots of logs (not removed), and various other debris (NVE, n.d.). An additional 30 tons of junk cars, refrigerators, tires, bicycles and other debris were removed from the canyon as part of the lower dam removal discussed in Section 3.15 (Meiklejohn, 2020).

McMillen Jacobs Associates 43 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 3-24. Debris being hoisted out of the canyon (NVE, n.d.)

3.15 Removal of the Old Diversion Dam Eklutna, Inc., in partnership with The Conservation Fund, recently removed the old diversion dam in the lower Eklutna River (lower dam) which had blocked fish passage since 1929 (Figure 3-25). The purpose of the project was to help restore some natural stream functions that were inhibited by the dam's presence (HDR, 2016).

Figure 3-25. Lower dam prior to removal (The Conservation Fund, 2016)

McMillen Jacobs Associates 44 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Eklutna, Inc. considered several alternatives to safely remove the lower dam. Most of the alternatives involved constructing a temporary diversion dam upstream, excavating the sediment immediately behind the dam in a series of layers to expose the face of the dam, and then demolishing the dam in 10-foot horizontal sections. However, given the lower dam site's topographical constraints and the large volume of sediment that had accumulated upstream of the dam (estimated at 230,000 cubic yards), safe management of that accumulated sediment was the primary challenge of the project. In summary, the accumulated sediment could either be removed from the canyon (Alternative 1) or remain in the canyon (Alternative 2). For Alternative 1, Eklutna, Inc. considered three primary options to haul the sediment out of the canyon:

▪ Option 1A would have involved improving the existing AWWU access road that extends from Eklutna Lake Road into the canyon at a point about 1.4 miles upstream of the lower dam and then hauling the sediment out of the canyon using trucks. Since no road route exists within the canyon between the lower dam site and the AWWU access road upstream, Eklutna, Inc. would have needed to construct a new access route along the banks of the Eklutna River. However, there is a pinch point about halfway between the lower dam site and the AWWU access road where the canyon is only about 12 feet wide. To use this route, Eklutna, Inc. would have needed to widen the canyon walls and install a temporary culvert to convey the river underneath the access road. It was estimated that 16,000 to 23,000 truckloads would have been required to haul the sediment out of the canyon. This option ultimately was not considered practical or feasible due to excessive cost as well as additional impacts within a larger project footprint in the Eklutna River canyon.

▪ Option 1B would have involved constructing a new road off Eklutna Lake Road to access the canyon near the lower dam site and then hauling the sediment out of the canyon using trucks. The route deemed most feasible was about 0.2 miles upstream from the lower dam site and downstream of the pinch point described in Option 1A. Like Option 1A, this option still would have required 16,000 to 23,000 truckloads to haul the sediment out of the canyon as well as construction of a new access route along the banks of the Eklutna River, although the new access route would have been much shorter. However, this option was considered infeasible primarily due to the challenging logistics of building a road to the dam side and the associated cost.

▪ Option 1C would have involved setting up a bucket conveyor system in the ravine to transport sediment out of the canyon. However, this option was ultimately considered to be unfeasible due to the cost.

Eklutna, Inc. also evaluated three options for Alternative 2 which involved leaving the accumulated sediment in the canyon, as opposed to hauling the sediment out of the canyon:

▪ Option 2A would have involved stockpiling the excavated sediment approximately 450 feet upstream of the dam as the dam was demolished in horizontal sections. This approach would have required placing the temporary diversion dam farther upstream on the Eklutna River in order to create enough space to maintain safe working conditions and to transport and stockpile the excavated sediment. However, this option was ultimately not selected primarily due to the safety concerns inherent to working downstream of a high volume of stockpiled sediment within a canyon. Further, given the limited area within the canyon, sediment stockpiled upstream of the

McMillen Jacobs Associates 45 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

lower dam site could have potentially been washed back into the excavation during a flood event, which would have created substantial delays and posed a financial risk.

▪ Option 2B involved casting the excavated sediment over the face of the dam as the dam was demolished in horizontal sections and then moving and redistributing the excavated sediment further downstream using a bulldozer. This option was considered to be the safest and most cost- effective option.

▪ Option 2C would have involved using explosives to deconstruct the dam by either full detonation or by blasting an arch in the bottom of the dam. While it would have been possible to deconstruct the dam using either method, the stability of the surrounding canyon wall was questioned. There was also concern that the dam debris and sediment would create an earthen dam downstream of the explosion and block the channel. The potential was also great for fractured or loose material in the canyon wall to contribute to the debris pile in an unknown quantity. Therefore, it was determined that this option posed too many safety risks.

Eklutna, Inc. ultimately chose Option 2B as the method for deconstructing the lower dam. In 2016 Eklutna, Inc. conducted site preparation activities including placing fill for the construction of an access route and a helicopter landing pad/work area as shown in Figure 3-26. In 2017 a crane was staged at the top of the canyon to lower heavy construction equipment to the canyon bottom as shown in Figure 3-27. In addition, an aluminum stairwell down the gully was constructed to provide safe worker access to the dam site. To divert flow around the construction area, an inflatable bladder type diversion dam was used to direct flow into an adjacent diversion pond, where a diversion pipe fitted with a slip gate conveyed water downstream (HDR, 2016).

Figure 3-26. Looking upstream into canyon from lower staging area; fill placed in 2016 for the construction of an access route and helicopter landing pad/work area (HDR, 2016)

McMillen Jacobs Associates 46 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 3-27. View of the construction site (The Conservation Fund, 2017)

To maintain safe working conditions, the sediment excavation and dam deconstruction were done incrementally. Excavated sediment was cast downstream over the dam so that the dam could be demolished in approximate 4 to 8-foot increments as shown in Figures 3-28 through 3-30. In this way, workers alternated between sediment excavation and relocation operations and concrete demolition activities. The contractor estimated that between 15,000 and 21,000 cubic yards (cy) of sediment was excavated from the upstream side of the dam and relocated over its face to establish a 6h:1v safety slope (HDR, 2016).

Figure 3-28. Incremental process of excavating sediment from behind the lower dam (HDR, 2016)

McMillen Jacobs Associates 47 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 3-29. Incremental process of demolishing the dam (HDR, 2016)

Figure 3-30. Removal of lower dam (The Conservation Fund, 2017)

McMillen Jacobs Associates 48 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

In October 2017, a large slope failure occurred in the sediment wedge above the lower dam. This failure may have been triggered by a minor seismic event. Ron Benkert with ADFG conducted a site visit a couple days after the slope failure to assess the situation. It was estimated that approximately 10,000 to 15,000 yards of material was conveyed over the dam and down the channel about 100 yards. At the time of the event, several pieces of equipment were staged on site and were swept downstream. This equipment included a backhoe, drill rig, two conex type trailers, and other small equipment. Additionally, a backhoe and dozer staged below the dam were partially buried. Since some of the equipment was buried too deeply to effectively be removed by the crane, Eklutna Inc. walked a backhoe and dozer up the Eklutna River from below the Old Glenn Highway Bridge to assist in removing the buried equipment. At the time of the slope failure, approximately 12 feet of the dam still needed to be removed. However, dam removal operations were suspended to let the site stabilize before continuing and completing the dam removal in 2018 (ADFG, 2017).

Upon completion of the dam removal, the crane pad area and upper work area were regraded to match the surrounding topography and then hydroseeded. The road approach and stairway access were removed. The entrance into the old penstock was blocked to minimize the potential for trespassing and related safety concerns. The contractor was required to remove metal and other debris from the canyon bottom and regrade the remaining sediment into a stable condition. The temporary diversion structures, bypass pipes, and culverts were removed, and the two diversion ponds were backfilled (HDR, 2016).

The Project owners’ team conducted a site reconnaissance of the Eklutna River in 2019. Figure 3-31 below shows post dam removal conditions. At that time there appeared to still be some construction debris on top of and embedded within the sediment (MJA, 2019).

Figure 3-31. Lower dam site post dam removal, August 2019 (MJA, 2019)

3.16 Timeline Figure 3-32 below is a timeline summarizing the history of development in the Eklutna River basin and Project tailrace area as describe in Section 3.2 to 3.15 above.

McMillen Jacobs Associates 49 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 3-32. Timeline showing History of Development in the Eklutna River Basin and Project Tailrace Area

McMillen Jacobs Associates 50 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

3.17 References ADFG (Alaska Department of Fish and Game). 1997. Letter RE: Eklutna Tailrace, fisheries maintenance plan. March 6, 1997.

ADFG. 2017. Division of Fish Habitat. Matanuska-Susitna Area Office. Memorandum, Eklutna Dam Removal Project, Emergency Action, Habitat Case No. FH-17-IV-0419. October 19, 2017.

ADFG Division of Sport Fish. 2019. Region II: Statewide Stocking Plan for Sport Fish 2019 – 2013, 2019 UPDATE.

ADFG. 2020. Southcentral Recreational Angler Access Projects: Eklutna Tailrace. http://www.adfg.alaska.gov/index.cfm?adfg=fishingSportAnglerAccessSouthcentral.eklutna. Accessed on February 21, 2020.

ADNR (Alaska Department of Natural Resources) Division of Parks and Outdoor Recreation. 2016. Chugach State Park Management Plan. February 2016.

Agreement for Public Water Supply. 1984. Agreement for Public Water Supply and Energy Generation from Eklutna Lake, Alaska between the Alaska Power Administration (APA) and the Municipality of Anchorage (MOA). February 17, 1984.

APA (Alaska Power Administration). 1996. Letter RE: Public Fishing Access at the Eklutna Power Plant. August 29, 1996.

APA. 1997. Letter RE: Approval to Provide Sport Fish Management at the Eklutna Project, U.S. Department of Energy. January 9, 1997.

ARC (Alaska Road Commission). 1954. Final Construction Report, Eklutna River Bridge, Mile 25.9, Glenn Highway. January 29, 1954.

ARRC (Alaska Railroad Commission). 2020. https://www.alaskarailroad.com/corporate/history. Accessed on February 27, 2020.

AWWU (Anchorage Water and Wastewater Utility). 1984. Eklutna Water Project Executive Summary. January 1984.

AWWU. 2020. AWWU Overview. https://www.awwu.biz/about-us/awwu-overview. Accessed on February 23, 2020.

BLM (U.S. Bureau of Land Management). 1963. Public Land Order 3162. July 31, 1963.

CEMML (Center for Environmental Management of Military Lands). 2002. The Early Electrification of Anchorage. Colorado State University, Fort Collins, CO. July 2002.

Chandonnet, Ann. 1979. The Once & Future Village of Ikluat/Eklutna (A History of a Tanaina Athapaskan Settlement). Chicago: Adams Press.

McMillen Jacobs Associates 51 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Chandonnet, Ann. 1991. On the Trail of Eklutna. Chicago: Adams Press.

CIAA (Cook Inlet Aquaculture Association). 2019a. 2019 Annual Management Plan, Eklutna Salmon Hatchery.

CIAA. 2019b. 2019 Annual Report.

CIAA. 2019c. Eklutna Salmon Hatchery. https://www.ciaanet.org/hatcheries/eklutna-salmon- hatchery.html. Accessed on May 1, 2019.

Cook Inlet Historical Society, n.d. Anchorage History. https://www.cookinlethistory.org/anchorage- history.html.

Dumond, D.E. and Robert L.A. Mace. 1968. An Archaeological Survey along Knik Arm. Anthropological Papers of the University of Alaska, Volume 14, Number 1.

Eklutna, Inc. n.d. Eklutna Dam Removal and Diversion Project. https://www.eklutnainc.com/eklutna- dam-project/. Accessed February 2020.

FPC (Federal Power Commission). 1944. Order Approving Transfer of License (Major): Project No. 350. March 1, 1944.

HDR. 2016. Project Description to support application Section 404 Individual Permit: 2017 Dam Deconstruction and Sediment Relocation – Lower Eklutna River Dam Removal Project. November 15, 2016.

Kari, James M. and James A. Fall. 2003. Shem Pete's Alaska: The Territory of the Upper Cook Inlet Dena'ina. Fairbanks, Alaska: Alaska Native Language Center, University of Alaska. August 1, 2003.

Leggett, Aaron. 2020. Comments on Draft Initial Information Package. April 24, 2020.

Lobdell, John E. 1984. An Archaeological Assessment of the Eklutna Water Project, Phase II: Staging Areas, Material Sources, and Route Modifications. Municipality of Anchorage Water and Wastewater Utility.

Mead & Hunt. 2014. Alaska Roads Historic Overview, Applied Historic Context of Alaska’s Roads. February 2014.

Meiklejohn, Brad. 2020. Comments on Draft Initial Information Package. April 17, 2020.

MJA. 2019. Eklutna Hydroelectric Project: Fish & Wildlife Program Development: Site Reconnaissance Trip Report. August 2019.

NVE (Native Village of Eklutna). n.d. Website: https://eklutna-nsn.gov/. Accessed February 2020.

NVE. n.d. Removal of Eklutna River Canyon Illegal Dump.

McMillen Jacobs Associates 52 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

NPS (National Park Service). 1982. Mike Alex Cabin. National Register of Historic Places. https://npgallery.nps.gov/NRHP/GetAsset/NRHP/82002071_text. Photos: https://npgallery.nps.gov/GetAsset/9c05ae4a-795f-4044-bed6-748bd13bebcf.

NWS (National Weather Service). Eklutna Hydrology – DRAFT.

R&M Consultants, Inc. 2015. Eklutna River Bridge Replacement Project, Hydrologic and Hydraulic Report. Anchorage, Alaska. March 2015.

Section 905(b) Eklutna Watershed Study

Sinnott, Rick. 2016. Anchorage Daily News. Let’s find a way to restore the Eklutna River and its salmon runs. June 25, 2016.

Sinnott, Rick. 2020. Comments on Draft Initial Information Package. April 2, 2020.

Supplemental Agreement No. 1. 1988. Agreement for Public Water Supply and Energy Generation from Eklutna Lake, Alaska, Supplemental Agreement No. 1, Interim Compensation, Allocation and Operating Procedures between APA and MOA. August 24, 1988.

Supplemental Agreement No. 2. 1993. Agreement for Public Water Supply and Energy Generation from Eklutna Lake, Alaska, Supplemental Agreement No. 2, Compensation, Allocation and Operating Procedure between APA and MOA. November 30, 1993.

USACE (U.S. Army Corps of Engineers). 2011. Eklutna River Aquatic Ecosystem Restoration Technical Report. Joint Base Elmendorf-Richardson, Alaska. November 2011.

U.S. Army. 2008. Operational Range Assessment Program, Phase I Qualitative Assessment Report, Eklutna Glacier Training Site, Alaska. July 2008.

USBR (U.S. Bureau of Reclamation). 1948. Eklutna Project, to serve 25% of all Alaskans. Juneau, Alaska. October 1948.

USBR. 1958. Technical Record of Design and Construction: Eklutna Dam, Powerplant and Tunnel. Denver, CO. March 1958.

USBR. 1961. Eklutna Project, Annual Project History, Calendar Year 1961, Volume XI.

USBR. 1962. Eklutna Project, Annual Project History, Calendar Year 1962, Volume XII.

USBR. 1963. Eklutna Project, Annual Project History, Calendar Year 1963. Volume XIII.

USBR. 1964. Eklutna Project, Annual Project History, Calendar Year 1964. Volume XIV.

USBR. 1965. Eklutna Project, Annual Project History, Calendar Year 1965. Volume XV.

USBR. 1967. Rehabilitation of Eklutna Project Features Following Earthquake of March 1964. Denver, CO. June 1967.

McMillen Jacobs Associates 53 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

U.S. Patent. 1986a. United States of America, Patent No. 50-86-0356. Surface transfer. Aug. 15, 1986.

U.S. Patent. 1986b. United States of America, Patent No. 50-86-0357. Subsurface transfer. Aug. 15, 1986.

Ward, Nicole A. 2010. Monitoring the efficacy of juvenile salmon (Oncorhynchus spp.) off-channel habitat restoration projects in south central, Alaska. December 2010.

McMillen Jacobs Associates 54 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

4.0 Project Facilities and Operations

The 40-megawatt (MW) Eklutna Hydroelectric Project is located in Southcentral Alaska approximately 30 miles northeast of downtown Anchorage near the Native Village of Eklutna. Figure 4-2 shows the location of Project as well as some of the other major developments in the Eklutna Basin previously discussed in Section 3.

4.1 Project Facilities

4.1.1 Dam and Spillway The current dam is located approximately 1,400 feet downstream of the natural outlet of Eklutna Lake. It is an earth and rock fill embankment dam with a crest length of 815 feet, a crest width of 30 feet, and a crest elevation of 891 feet (USBR, 1967). The structural height (maximum height above the deepest excavation) is 56 feet. However, the crest (Figure 4-1) is only 41 feet above the streambed. It has a 3 to 1 upstream slope, a 2 to 1 downstream slope, and a volume of 85,000 cy. The crest of the dam is finished with crushed rock material to form a stable road surface (MJA, 2018).

An ungated overflow spillway is incorporated into the dam. The spillway is located near the middle of the dam, and consists of a riprap-lined approach channel, concrete inlet structure, ungated ogee-type weir, rectangular concrete conduit through the embankment, concrete-lined chute, concrete stilling basin, and riprap-lined outlet channel. The spillway crest elevation is 871 feet, and the crest length is 18 feet. The hydraulic height (from the spillway crest to the streambed) is 21 feet (MJA, 2018).

Figure 4-1. Dam crest and ungated overflow spillway, looking north (MJA, 2019)

There is a natural glacial moraine at the outlet of Eklutna Lake on which the old storage dams were built (Figure 4-3). When the lake level is below the crest of the moraine, a pond is created between the moraine and the current dam (Figure 4-4). The water level in the pond is not monitored. However, upon visual inspection, the pond level routinely differs from the lake level by several feet. Therefore, it can be concluded that the pond is not entirely hydraulically connected to the lake at low lake levels. There is a 30-inch by 30-inch drainage outlet in the base of the spillway crest at El. 852 feet that was designed to drain the pond when water becomes trapped there during late fall or early winter. It was thought that this water would cause detrimental frost action against the toe of the current dam and at the spillway inlet. This is not a typical reservoir outlet and was supplied only for drainage (USBR, 1967).

McMillen Jacobs Associates 55 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 4-2. Project Location

McMillen Jacobs Associates 56 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 4-3. Natural glacial moraine and remnants of old storage dams (MJA, 2019)

Figure 4-4. Pond between the natural glacial moraine and existing dam in May 2020

McMillen Jacobs Associates 57 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

4.1.2 Reservoir Eklutna Lake is a natural lake formed by the retreating Eklutna glacier. It is approximately 7 miles long, 1 mile wide, and 200 feet deep at its deepest. The natural lake elevation is 850 feet.

The current dam raises the water level of Eklutna Lake by 21 feet to a maximum regulated lake level of El. 871 feet (the elevation of the spillway crest). At this elevation, the lake has a surface area of 3,420 acre-feet (AF). The minimum regulated lake level is El. 814 feet, which provides an active storage capacity of 174,800 acre-feet. Storage between the spillway crest (El. 871 feet) and the dam crest (El. 891 feet) is an additional 72,800 acre-feet (MJA, 2018).

In their 1948 report, the USBR stated that there is at least 200,000 acre-feet of space in the lake below El. 830 feet (the proposed invert elevation of the tunnel at that time) which would have been dead storage available for silt accumulation. Because the bed load is largely deposited on the alluvial flats above the lake and in the delta, and a high percentage of the suspended matter was carried on through the lake, the 200,000 acre-feet of available dead storage would have provided ample capacity to allow a useful reservoir life far in excess of 100 years, without encroachment on the proposed active storage space (USBR, 1948). As stated above, the active storage for the existing Project is between El. 814 feet and 871 feet. We are unaware of any assessment of the impacts of silt accumulation on the available dead storage space for the existing Project.

4.1.3 Intake The intake is located on the north shore of the lake approximately 1 mile east of the dam. Diversion from the lake is made through an inlet channel 100 feet wide and originally about 720 feet long excavated at the lake bottom (the original intake structure and portions of the original intake conduit damaged in the 1964 earthquake remain in the intake channel). The intake channel leads to the intake structure, which consists of a rectangular reinforced concrete box structure, open and protected by trashracks on its top, front, and both sides. The trashracked portion is about 23 feet wide, 20 feet high, and 22 feet long in the direction of conduit flow. Overall length of the structure is 42 feet 4 inches. Elevation of the invert is 793.6 feet, which is 77.4 feet below the dam spillway crest. A bulkhead gate is provided for emergency closure of the conduit if needed (USBR, 1967).

4.1.4 Tunnel and Surge Tank A 4.5-mile-long tunnel conveys water from the intake to the penstocks. The tunnel is a circular, concrete- lined pressure tunnel with an 9-foot inside diameter. The capacity of the tunnel is 640 cfs at a velocity of 10.06 feet per second. The tunnel terminates in a surge tank installed directly over the tunnel. The surge tank has an inside diameter of 30 feet and extends 176 feet above the tunnel.

The tunnel section beneath the surge tank contains one 9-foot-long round-to-square transition and a similar square-to-round transition spaced 4 feet 6 inches apart along the centerline. The 4-foot 6-inch rectangular separation serves as a gate slot for the fixed-wheel gate which is used for emergency closure of the tunnel in the event of damage to the penstock below or to the turbine in the power plant and for unwatering the penstock for inspection and maintenance.

McMillen Jacobs Associates 58 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

A tunnel adit is located at the outlet end of the tunnel near the surge tank. The adit is essentially the same size as the main tunnel and is approximately 300 feet long. The purpose of the adit is to provide one means of access to the tunnel for inspection and maintenance purposes. It also acts as a free-flow conduit in conveying drainage water from the tunnel when entrance into the tunnel is necessary. Access from the adit to the tunnel is by means of a watertight door (USBR, 1967).

4.1.5 Penstock Extending from the surge tank at the end of the tunnel is the penstock which conveys water to the power plant turbines. The overall length of the penstock is about 1,088 feet, installed in 30-foot sections. The penstock is a variable- diameter (91-, 83-, and 75-inch-outside-diameter) welded and coupled steel pipe encased in concrete in a tunnel extending from the surge tank to the power plant. In profile, the penstock roughly parallels the mountainside, descending for approximately 864 feet at an angle of 53°; it then levels off and continues through a horizontal section about 501 feet long.

The penstock bifurcates into two 51-inch-diameter 23-foot-long branches at the power plant which are connected to the spiral cases of the turbines. A 66-inch butterfly valve is installed in each penstock branch upstream from the turbines to provide means of unwatering the turbines for servicing or maintenance. These valves also serve as emergency shutoff valves in the event of damage to the turbines (USBR, 1967).

4.1.6 Power Plant and Switchyard The power plant (Figure 4-5) is located on the Old Glenn Highway. It houses two vertical-shaft generating units with an installed nameplate capacity of 44.4 MW. Actual capacity is less; the plant is rated at 41.9 MW at High Lake and 38.8 MW at Low Lake (MJA, 2018). The switchyard equipment, consisting of the power circuit breakers, disconnecting switches, and main buses, is on the roof of the power plant (USBR, 1967).

Figure 4-5. Eklutna Power Plant

McMillen Jacobs Associates 59 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

4.1.7 Tailrace Water discharged from the draft tubes of the turbines in the power plant enters a 209-foot-long tailrace conduit through which the water is conducted under the Old Glenn Highway to a 2,000-foot-long open tailrace channel which discharges into the Knik River. The banks of the open tailrace channel are built on a 2 to 1 slope. The channel has a top width of about 75 feet, a bottom width of 25 feet, and a depth of about 12 feet 6 inches. Stoplog slots at the outlet of the tailrace conduit can be used to dewater the conduit or to unwater both draft tubes at the same time (USBR, 1967).

4.2 Project Operations The Eklutna Hydroelectric Project falls under the jurisdiction of the Alaska Dam Safety Program administered by ADNR. Every three years the Project owners are required to perform a Periodic Safety Inspection (PSI) of the dam and appurtenant works. The PSI must be performed by a qualified engineer, and approval of the engineer and the scope of the inspection must be obtained from ADNR in advance of the inspection. ADNR then reviews the information contained in the PSI and issues a Certificate of Approval to Operate the Dam. The current certificate of approval for the Eklutna dam was issued by the State Dam Safety Engineer on February 12, 2019 (ADNR, 2019).

4.2.1 Reservoir Operations Typical operation of the Project is to fill the reservoir during the summer and drain it during the winter months (Figure 4-6). The Project operators try to refill the reservoir as much as possible without spilling, and the extent of winter draw down is based on power requirements and the operator’s estimates of the winter snowpack (Chugach, 2016b). The lake level is generally at its lowest elevation in May and then peaks in September. As shown in Figure 4-7, the lake level is drawn down below the natural lake level (El. 850 feet) for about six months out of the year, and below the crest of the natural glacial moraine for about 9 months out of the year.

The lake level increases as a result of inflows (mostly glacial melt) and is drawn down by operation of the tunnel/penstock system. Assuming no inflow, the lake can be drawn down by approximately 4 inches per day when the power plant is generating at max capacity (660 cfs). Water conveyance can be closed at the lake intake structure by closing the intake gate, by closing the main butterfly valve located at the beginning of the steel penstock system, and by closing the individual inlet valves at the inlet of each turbine in the powerhouse.

The Eklutna Power Plant is the primary means of making controlled releases from Eklutna Lake. The 30- inch by 30-inch drainage outlet in the base of the spillway crest is controlled by a manually operated slide gate conduit and can release up to 191 cfs (with reservoir at the spillway crest). However, this is not a typical reservoir outlet and was supplied only for draining water trapped against the dam in the winter when the reservoir is drawn below the glacial moraine. Operation of the spillway gate valve is checked on an annual basis and the operating mechanism lubricated (Chugach, 2016b).

McMillen Jacobs Associates 60 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 4-6. Eklutna Lake Rule Curve (USBR, 1967)

McMillen Jacobs Associates 61 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 4-7. Eklutna lake level from June 1, 2000 to June 21, 2020

McMillen Jacobs Associates 62 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

4.2.2 Water Usage, Energy Generation, and Cost of Power The Eklutna Hydroelectric Project produces nearly 6% of the Project owners combined generation. The annual water usage and energy generation of the Project for the past 10 years is summarized in Table 4-1.

Table 4-1. Historic Annual Eklutna Hydroelectric Project Water Usage and Energy Generation

Year Water Usage (AF) Energy Generation (kWh)

2010 196,205 129,822,200

2011 195,535 128,068,400

2012 221,396 145,240,600

2013 256,015 172,076,600

2014 233,335 157,291,000

2015 207,499 136,050,800

2016 249,111 169,525,600

2017 172,402 119,916,900

2018 248,795 168,757,000

2019 274,191 191,568,000

Average 225,448 151,831,710

Eklutna hydro is the lowest-cost resource for power in the Railbelt. The average cost of power produced by the Project is $0.013 per kWh. The next lowest-cost resource for power in the Railbelt is the Bradley Lake Hydroelectric Project with an average cost of power of $0.04 per kWh. One of the other major benefits of the Project is increased grid reliability through diversification of fuel for generation. With a weak natural gas system, hydro plays an important alternate fuel supply if there is an interruption to gas supply. In addition, Eklutna hydro generation offsets approximately 86,000 tons of carbon each year.

4.2.3 Flood Protection The dam has 20 feet of freeboard at the maximum normal storage pool (El. 871 feet). The Probable Maximum Flood (PMF) for the Project was most recently updated by USBR in 1987. USBR developed the Inflow Design Flood (IDF) for these analyses based on the probable maximum precipitation (PMP) calculated by the U.S. Weather Bureau in 1963. The resulting hydrograph has a peak inflow of 68,700 cfs and a 4-day volume of 60,600 acre-feet. The analyses concluded that the peak reservoir elevation was 885.7 ft, leaving approximately 5 ft of freeboard for this condition. The peak outflow through the spillway was determined to be 3,990 cfs.

USBR also noted that the entire volume of the PMF could be contained in the flood storage capacity of the reservoir (between the spillway crest and dam crest) with 3 feet of freeboard remaining even if the spillway was blocked (MJA, 2018).

McMillen Jacobs Associates 63 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

4.2.4 Spill Events There were four spill events at the dam from 1955 to 1963 (USBR, 1956; USBR, 1957; USBR, 1958; USBR, 1959). These spill events are summarized below. Figure 4-8 shows flow over the spillway during the 1956 spill event.

▪ 1956 – Spill occurred during August and September ▪ 1957 – 80,484.48 acre-feet of water was spilled during July, August, and September ▪ 1958 – 20,814.89 acre-feet of water was spilled during August and September ▪ 1959 – 1,504 acre-feet of water was spilled during August and September

Figure 4-8. Spillway on August 14, 1956, flow was 1,050 cfs (USBR, 1956)

After the earthquake in 1964, the spillway gates were kept open all spring and summer (USBR, 1967). USGS estimated that 42,630 acre-feet of water was spilled during this time (USBR, 1964). There have been 9 spill events since the current dam was constructed in 1965. These spill events are shown in Figure 4-9. Note that the 1967, 1977, and 1981 spill events are represented with a dotted line because the only data available for these spill events were the spill period, the maximum elevation, and the date the maximum elevation occurred. Table 4-2 summarizes the historical data and calculated values for each of these spill events (MJA, 2020).

McMillen Jacobs Associates 64 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Table 4-2. Summary of Spill Events at Eklutna Dam from 1965 to 2019 (MJA, 2020)

Peak Average Peak Average Total Duration Year Spill Period Lake Level Lake Level Spillway Spillway Volume (Days) Elevation (ft) Elevation (ft) Flow (cfs) Flow (cfs) Spilled (AF)

1967 9/20 – 10/11 22 872.99 - 160 - - 1977 8/15 – 9/26 43 874.60 - 396 - - 1981 8/15 – 9/23 40 873.50 - 226 - - 1989 9/5 – 10/7 33 873.73 872.40 259 107 7,018 1990 9/12 – 9/27 16 872.31 871.78 85 43 1,370 1995 9/21 – 10/20 30 877.62 874.40 1,022 426 25,356 1997 8/19 – 10/31 74 875.51 873.33 561 242 35,591 2012 9/23 – 10/19 27 874.52 873.10 383 188 10,055 2013 8/9 – 10/1 54 874.99 873.18 464 201 21,567

Eklutna Dam Spill Events 878

877

876

875

874

873

872

871 1-Aug 8-Aug 15-Aug 22-Aug 29-Aug 5-Sep 12-Sep 19-Sep 26-Sep 3-Oct 10-Oct 17-Oct 24-Oct 31-Oct

1967 1977 1981 1989 1990 1995 1997 2012 2013

Figure 4-9. Lake Elevations during Spill Events at Eklutna Dam from 1965 to 2019 (MJA, 2020)

The highest lake level elevation ever recorded in Eklutna Lake was 877.62 feet on September 25, 1995. At this elevation the flow through the spillway was calculated to be 1,022 cfs. The longest spill event at Eklutna Dam occurred in 1997 and lasted for a total of 74 days. The calculated total volume of water spilled during this time was 35,591 acre-feet (MJA, 2020).

McMillen Jacobs Associates 65 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

4.2.5 Emergency Action Plan The ADNR certificate of approval requires the Project owners to maintain an Emergency Action Plan (EAP) for the Eklutna dam. The EAP outlines notification and response procedures for Project personnel and public safety agencies to follow in the unlikely event of a failure or potential failure of the dam. The ADNR certificate of approval also requires the Project owners to review and update the plan annually and periodically conduct various training and drill exercises (Chugach, 2016a).

4.3 References ADNR (Alaska Department of Natural Resources). 2019. Certificate of Approval to Operate a Dam, Eklutna Dam. February 12, 2019.

Chugach (Chugach Electric Association, Inc.). 2016a. Emergency Action Plan, Eklutna Hydroelectric Project. February 2016.

Chugach. 2016b. Operations and Maintenance Plan for Eklutna Dam. July 2016.

MJA (McMillen Jacobs Associates). 2018. Periodic Safety Inspection, Eklutna Dam.

MJA. 2020. Technical Memorandum, Summary of Spill Events at Eklutna Dam. January 31, 2020.

USBR (U.S. Bureau of Reclamation). 1948. Eklutna Project, to serve 25% of all Alaskans. Juneau, Alaska. October 1948.

USBR. 1956. Eklutna Project, Annual Project History, Calendar Year 1956, Volume VI.

USBR. 1957. Eklutna Project, Annual Project History, Calendar Year 1957, Volume VII.

USBR. 1958. Eklutna Project, Annual Project History, Calendar Year 1958. Volume VIII.

USBR. 1959. Eklutna Project, Annual Project History, Calendar Year 1959. Volume IX.

USBR. 1964. Eklutna Project, Annual Project History, Calendar Year 1964. Volume XIV.

USBR. 1967. Rehabilitation of Eklutna Project Features Following Earthquake of March 1964. Denver, CO. June 1967.

McMillen Jacobs Associates 66 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

5.0 Description of Existing Environment

5.1 Climate

5.1.1 Historical Climate Eklutna is near the northern limit of Southcentral Alaska’s maritime temperate zone. Average temperatures range from 47 to 69°F in July and from 6 to 14°F in January. The average annual precipitation is about 18 inches, with 56 inches of snowfall. The wettest months are July through September, while the driest are January through May. Average snow cover is highest in March, at 13 inches. High winds are not uncommon in the area, due in part to its location along the front range of the Chugach Mountains (USACE, 2011).

The timing of freeze-up for Eklutna Lake is dependent on the sequence and magnitude of winds and air temperatures during November and December. From 1982 to 1984 freeze up occurred between the first and second weeks of December. Disappearance of ice on the lake occurred between the second and third weeks of May in 1983 to 1985 (R&M, 1986). Fresh surface water along Eklutna River typically begins to freeze in mid-November and break up in April. Ice forms on the brackish estuarine waters at the mouth of Eklutna River from December through April. The lower Eklutna River continues to flow throughout the winter. In this reach there appears to be adequate flow to prevent freezing within main channel gravels, although freezing of spawning gravels may occur in smaller channels (USACE, 2011).

5.1.2 Climate Change Alaska has recently experienced profound environmental change related to extreme weather events and deviations from the historical climate. Recent years have brought many temperature extremes to Alaska, including the warmest year (2016), the warmest month (July 2019), and in places like Anchorage, the warmest day (July 4, 2019). In fact, four of the past five years (2014–16 and 2018) were warmer than any year prior to 2014. Air temperatures in Alaska are rising twice as fast as in other parts of the United States. The typical annual average statewide temperature is now 3 to 4ºF warmer than during the early and mid-20th century (Figure 5-1). Factors contributing to this warming include decreases in sea ice and snow cover, warming ocean, and increasing greenhouse gases. Of course, there is considerable day-to-day and even year-to-year variability, but these trends are unmistakable (Thoman, 2019).

A major outbreak of spruce bark beetles has been spreading through Southcentral Alaska during the past several years. The area affected by the outbreak increased from 33,000 acres in 2015 to 593,000 acres in 2018. While small populations of the beetles are always present in spruce forests, sudden increases in their populations are favored by a dry summer, which reduces trees’ capacity to produce sap, a defense against the beetle. Longer and warmer summers also increase beetles’ reproductive capacity, while milder winters increase over-winter survival rates (Thoman, 2019).

By 2006, warmer springs and earlier snow melt had lengthened the wildfire season in Alaska to the point that Alaska’s interagency fire management organization changed the “start date” for wildfire response from May 1 to April 1. While the year-to-year variability of acreage burned has changed little, the frequency of large wildfire seasons has increased dramatically. Wildfire seasons with more than one million acres burned have increased by 50% since 1990, compared to 1950–1989 (Thoman, 2019).

McMillen Jacobs Associates 67 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 5-1. Alaska annual temperatures in Fahrenheit relative to 1951-1980 average, 1900-2018 (Thoman, 2019)

Each year the mass of glaciers increases due to snow in winter and then decreases during the summer melt season. Largely because of increasing air temperatures, summer melt has exceeded winter gain in recent years, resulting in the retreat and mass loss of Alaska glaciers. More than 90% of Alaska’s glaciers are retreating. Between 2002 and 2017, Alaska glaciers thinned on average by several feet per year. Overall mass loss during this period was nearly 60 billion tons of ice per year (Thoman, 2019). The Eklutna Glacier is one of the glaciers that is retreating as a result of climate change. Figure 5-2 below shows the extent of the glacier in 1957, 2010, and 2015. In 2017 the cumulative glacier-wide mass balance of Eklutna Glacier from 2010 to 2015 was determined to be −3.7 ± 0.2 m w.e. Balance-flux estimates suggest that over 6 km (3.7 miles) of terminus retreat is required to approach equilibrium with the present climate. With a continued altitude-mass-balance feedback the glacier could lose >80% of its present area, and possibly more with continued climate change (Sass et al, 2017). At the current rate of warming, scientists expect Eklutna Glacier to disappear in about 100 years, but this timeline could be cut in half with a higher warming rate (MOA, 2019).

The Project owners each have specific goals or initiatives related to climate change. In 2019 MOA adopted the Anchorage Climate Action Plan which puts Anchorage on a path to reduce greenhouse gas emissions 80% from 2008 levels by 2050, with an interim goal of 40% by 2030; Chugach’s 2020 Strategic Plan identifies Renewable Generation and Conservation as one of its five priority areas; and MEA is currently investigating a renewable energy and/or carbon reduction strategy either as a standalone utility or in conjunction with other Railbelt utilities. The Eklutna Hydroelectric Project is a valuable renewable energy resource that offsets approximately 86,000 tons of carbon each year.

McMillen Jacobs Associates 68 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 5-2. Extent of Eklutna Glacier in 1957, 2010, and 2015 (Sass et al, 2017)

5.1.3 References MOA (Municipality of Anchorage). 2019. Anchorage Climate Action Plan. Adopted May 21, 2019 by Anchorage Assembly Resolution 2019-158.

Sass, Louis et al. 2017. Journal of Glaciology. Geometry, mass balance and thinning at Eklutna Glacier, Alaska: an altitude-mass-balance feedback with implications for water resources.

Thoman, R. and J. E. Walsh. 2019. Alaska’s changing environment: documenting Alaska’s physical and biological changes through observations. H. R. McFarland, Ed. International Arctic Research Center, University of Alaska Fairbanks.

USACE (U.S. Army Corps of Engineers). 2011. Eklutna River Aquatic Ecosystem Restoration Technical Report. Joint Base Elmendorf-Richardson, Alaska. November 2011.

McMillen Jacobs Associates 69 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

5.2 Geology

5.2.1 Glacial Influence The Eklutna Valley is a “U-shaped” glacial valley approximately 27 miles long, trending northwest from the Chugach Mountains to the Knik Arm. Elevations in the area range from 8,000 feet at the peaks surrounding the valley to approximately 850 feet at Eklutna Lake (MJA, 2018). The valley was formed by the powerful abrasive action of the Eklutna Glacier, which formerly extended down the full length of the valley to its junction with the main valley of the Knik River (USBR, 1948).

The bedrock floor of the valley is completely hidden by Eklutna Glacier, Eklutna Lake, and thick deposits of silt, sand and gravel released as the glacier front melted back up the valley to its present position. The remnants of Eklutna Glacier are now restricted to the upper valley (USBR, 1948). The glacier itself is 10.2 km (6.3 miles) long, 29.5 km2 (11.4 mi2) in area, and ranges in elevation from 580 m (1,903 ft) to 2100 m (6,890 ft). It consists of two tributaries that converge 2.7 km (1.7 miles) above the terminus, but only 6% of the glacier area is located below the convergence. The longer, larger tributary (56% of the total glacier area) is referred to as the east branch or main branch, and the shorter, smaller tributary (44% of the area) is referred to as the west branch (Sass et al, 2017). Figure 5-3 below shows the profile of the Eklutna basin from the terminus of Eklutna Glacier all the way to the Knik Arm. The figure also indicates select points of interest including Eklutna Lake, the existing dam, the former lower dam site, and the downstream bridges.

Figure 5-3. Profile of Eklutna Lake and River showing select points of interest (Loso, 2019)

McMillen Jacobs Associates 70 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

The west fork of Eklutna Creek, supplied by meltwater from Eklutna Glacier, flows down the valley for about 5 miles to the head of Eklutna Lake. Through this distance, the creek flows in a mesh of braided channels over a wide deposit of material released by melting ice and carried down-valley by the creek (USBR, 1948).

5.2.2 Eklutna Lake Eklutna Lake, approximately 7 miles long and 1 mile wide, is naturally dammed at its northwest end by a recessional moraine from the Eklutna Glacier. The lake has two main basins reaching depths of approximately 200 and 165 feet, separated by a submerged end moraine at a depth of approximately 100 feet (Fortin, 2019).

Eklutna Lake is flanked on both sides by glacial deposits, alluvial fans, talus and the steep rock slopes of the valley. The actual shores of the lake consist of rock debris released by the glacier and in part transported by former side-glacial streams. The bulk of such deposits, locally terraced, exist chiefly on the northeast side of the lake. Alluvial fans and extensive talus slopes, representing the material derived by the normal weathering and erosion of bedrock at higher elevations, have been built out over the surface of the glacial deposits (USBR, 1948).

5.2.3 Dam Site The foundation at the dam site consists of firm glacial till with occasional thin, discontinuous lenses of sand and clay. The till is overlain on both abutments by a bed of gravelly clay ranging from 4 to 15 feet in thickness. This material has little stability when wet and numerous small slumps were evident in the area of the left abutment prior to construction of the dam. These slumps resulted from seasonal saturation of the gravelly clay by water from muskeg swamps on the gently sloping bench above the dam site. Much of this clay was removed and drains were provided to intercept water from the muskeg swamp. The clay was completely removed along the spillway alinement so this structure would rest on firm glacial till (USBR, 1967).

Bedrock was not encountered in any of the subsurface explorations advanced for the Project (advanced as deep as 165 ft); and based on the depositional environment and drilling program results, bedrock is likely several hundred feet below ground surface (MJA, 2018).

5.2.4 Eklutna River Valley and Canyon Below the lake, the bedrock trough gouged out by the glacier is filled with glacial debris to a general elevation of about 900 to 1,000 feet. The upper end of this unconsolidated glacial fill forms the natural dam which creates Eklutna Lake. Since the retreat of the glacier, the Eklutna River has excavated a valley through the fill of glacial debris (Figure 5-4). The valley ranges from a depth of about fifty feet or less adjacent to the lake to over five hundred feet about five miles downstream (USBR, 1948). There are several large alluvial fans within the valley that were created by runoff and erosion of the glacial and colluvial deposits that make up the valley walls. At many locations, these alluvial fans act as natural gravel and fine sediment sources for the Eklutna River. However, there are some areas where the AWWU access road acts as a barrier between the alluvial fan and the river itself.

McMillen Jacobs Associates 71 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Starting at about 6.75 miles below the lake outlet, the river has cut through the unconsolidated, glacial overburden into bedrock creating a narrow canyon. In the vicinity of the lower dam site, the canyon is approximately four hundred feet deep (USBR, 1948). Rock falls in the canyon have periodically created natural barriers to fish passage just below the lower dam site. The frequency of these rock fall events and how long they remain a barrier under various flow regimes is currently unknown.

Figure 5-4. Eklutna River Valley (left) and Canyon (right) (MJA, 2019)

5.2.5 Sediment Accumulation behind Lower Dam Sediment bedload in the Eklutna River is high. It is likely that a majority of the sediment comes from erosion of the glacial and colluvial deposits that make up the valley walls and floor. Studies through 1948 estimated that an average of 300,000 cubic yards of gravel accumulated behind the lower dam annually. This accumulation almost completely filled in the reservoir behind the lower dam to its crest most years and was routinely flushed through a sluice gate in the bottom of the dam (Section 905b Study).

Sediment accumulated behind the lower dam after the dam was abandoned in the 1950s and maintenance was discontinued. In 2016 HDR determined that the accumulated sediment (sediment plug) extended approximately 0.6 miles upstream and that the approximate volume of the sediment plug was 230,000 cubic yards (HDR, 2016b). In 2011 the USACE stated that removing the lower dam and releasing this accumulated sediment into the river without adequate flushing flows could do more physical and biological harm than good by degrading the existing fish habitat downstream even further (USACE, 2011).

As part of the alternatives analysis for the lower dam removal project, Eklutna, Inc. considered several options for removing the accumulated sediment from the canyon. Ultimately, Eklutna, Inc. determined that none of these options were practical and feasible due to excessive cost, challenging logistics, and additional impacts to the Eklutna River. Instead, Eklutna, Inc. proposed to leave a majority of the accumulated sediment in place and redistribute the sediment excavated to allow demolition of the dam

McMillen Jacobs Associates 72 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package downstream (HDR, 2016a). During the planning phase of the lower dam removal project, both the Alaska Railroad and the Alaska Department of Transportation and Public Facilities (ADOT&PF) expressed concern about potential impacts to the downstream bridges from the large amount of accumulated sediment that would be flushed downstream and potentially accumulate at the bridges, and requested that the accumulated sediment be removed from the canyon as part of the project (MJA, 2020). A sediment transport model was developed by HDR in 2016. The model concluded that generally all sediment gradations, other than the coarsest armor layer, would be transported out of the sediment plug within approximately one to two years under the current flow regime with the finer sediments generally conveyed through the Eklutna River reach and into the Knik Arm. However, limited historical data was available for the Eklutna River at the time of the study. Therefore, hydrologic, geotechnical, and physical assumptions were made for sediment modeling, and calibration of the model was not possible (HDR, 2016b).

The ADEC issued a Section 401 Certificate of Reasonable Assurance for the dam removal project on April 20, 2017, and the USACE issued a Section 404 Permit to Eklutna, Inc. on June 21, 2017. As conditioned by the Section 404 Permit, Eklutna, Inc. was required to entirely remove all temporary fill following completion of construction activities and to conduct three years of sediment transport monitoring at the downstream bridges (ADEC, 2017; USACE, 2017). Eklutna, Inc. has committed to providing the results when available.

5.2.6 Thunderbird Creek and Falls Thunderbird Creek, the Eklutna River’s largest tributary, enters the left bank of the Eklutna River about one mile downstream from the lower dam site. There is a 200-foot-tall waterfall on Thunderbird Creek about one-third of a mile upstream from its confluence with the Eklutna River (USACE, 2011). Additional information regarding flows in Thunderbird Creek is provided in Section 5.3.2.4.

5.2.7 Alluvial Fan About a half mile downstream from the confluence with Thunderbird Creek, the Eklutna River exits the canyon and forms an alluvial fan. The alluvial deposit, approximately 1 to 2 square miles in area, lies between the canyon mouth and the Knik Arm (USACE, 2011). The Old Glenn Highway bridge is at the upstream end of the alluvial deposit (HDR, 2016b). The alluvial deposit is composed of silt, sand, gravel, and cobble washed down from the Eklutna River canyon and glaciers. The deposit has been intermittently, but heavily mined for construction aggregate starting with construction of the Alaska Railroad at Eklutna in 1917. The alluvial fan is crossed in a northerly and southerly direction by the New Glenn Highway and the Alaska Railroad. Both crossings form channel constrictions. Excessive deposition of sediment occurs in the reach between the Alaska Railroad bridge and the New Glenn Highway bridges (USACE, 2011).

The Eklutna River flows into the Knik Arm, a marine intrusion along the west boundary of the Eklutna area. The intertidal portion of the alluvial deposit is covered by a thick layer of glacial silt (USACE, 2011). The Alaska Railroad speculates that the entrapment of sand and gravel behind the lower dam may have caused Knik Arm shoreline erosion that required the Alaska Railroad rail bed to be moved in 1968. Blockage of the sediment to the river delta may have caused a change in tidal currents that subsequently led to bank erosion along the shore of Knik Arm (Section 905b Study).

McMillen Jacobs Associates 73 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

5.2.8 Seismicity Eklutna Dam is located in one of the most seismically active regions in the United States. Seismic activity is dominated by the Aleutian–Alaska megathrust zone, which extends from the Aleutian Islands to Southcentral Alaska. The megathrust zone is the convergent plate boundary between the northwest- moving Pacific Plate, which is subducted below the North American Plate. The 9.2 magnitude 1964 earthquake was generated along this zone and was one of the largest earthquakes ever recorded (MJA, 2018). The Eklutna area subsided approximately 2 feet during the 1964 earthquake (USACE, 2011).

A number of active crustal faults are also located in Southcentral Alaska. Eklutna is almost directly on top of the Border Ranges Fault which formed the steep west face of the Chugach Mountain Range. This massive fault was active from the Cretaceous period to about 300 years ago. The Eklutna River crosses the Knik Fault (the local segment of the Border Ranges Fault) as well as other lesser tectonic faults. Other more active faults include the Castle Mountain Fault about 30 miles north of Eklutna (USACE, 2011).

A magnitude 7.0 earthquake struck north of Anchorage, Alaska on November 30, 2018. As of December 3, 2018, 170 aftershocks of magnitude 3 or above had occurred since the mainshock, including a magnitude 5.7 aftershock on November 30th, just 7 minutes after the magnitude 7.0 mainshock. Figure 5- 5 shows debris avalanches on bluffs along the Eklutna River after the earthquake (USGS, 2018). No significant damage to Eklutna dam was identified.

Figure 5-5. Debris avalanches on bluffs along the Eklutna River, December 3, 2018 (USGS, 2018)

McMillen Jacobs Associates 74 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

5.2.9 References ADEC (Alaska Department of Environmental Conservation) Division of Water. 2017. Section 401 Certificate of Reasonable Assurance. April 20, 2017.

Fortin, David et al. 2019. New approach to accessing age uncertainties – The 2,300-year varve chronology from Eklutna Lake, Alaska. Quaternary Science Reviews 203 (2019) 90-101.

HDR. 2016a. Project Description to support application Section 404 Individual Permit: 2017 Dam Deconstruction and Sediment Relocation – Lower Eklutna River Dam Removal Project. November 15, 2016.

HDR. 2016b. Sediment Transport Submittal, Draft Lower Eklutna Sediment Study. November 2016.

Loso, Michael et al. 2017. Evaluating Evidence for Historical Anadromous Salmon Runs in Eklutna Lake, Alaska. Arctic Institute of North America. Arctic, Vol. 70, No. 3 (September 2017), pp. 259-272.

MJA (McMillen Jacobs Associates). 2018. Periodic Safety Inspection, Eklutna Dam.

MJA. 2020. Quarterly Update Call Meeting Minutes. February 13, 2020.

Sass, Louis et al. 2017. Journal of Glaciology. Geometry, mass balance and thinning at Eklutna Glacier, Alaska: an altitude-mass-balance feedback with implications for water resources.

Section 905(b) Eklutna Watershed Study

USACE (U.S. Army Corps of Engineers). 2011. Eklutna River Aquatic Ecosystem Restoration Technical Report. Joint Base Elmendorf-Richardson, Alaska. November 2011.

USACE. 2017. Section 404 Permit POA-2016-248, Eklutna River. June 21, 2017.

USBR (U.S. Bureau of Reclamation). 1948. Eklutna Project, to serve 25% of all Alaskans. Juneau, Alaska. October 1948.

USBR. 1967. Rehabilitation of Eklutna Project Features Following Earthquake of March 1964. Denver, CO. June 1967.

USGS (U.S. Geological Survey). 2018. 2018 Anchorage Earthquake. https://www.usgs.gov/news/2018- anchorage-earthquake.

McMillen Jacobs Associates 75 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

5.3 Water Resources The Eklutna River watershed is located in Southcentral Alaska near Anchorage. The Eklutna River originates from two glaciated basins within the Chugach Mountains and drains into the Knik Arm of Cook Inlet. Prior to development within the basin to regulate and divert water as far back as 1929, the hydrology of the Eklutna basin was typical for the region with the lowest flow periods occurring in the winter and spring (December-May). As ambient temperatures warm, snow and glacial melt cause a rapid increase in flows that peak sometime in late July to early August. Flows will slowly and steadily decrease from August to November until the stable, low flow period from December to May begins again.

5.3.1 Watershed and Drainage Area The overall Eklutna watershed is 174 square miles (Section 905b Study). The east and west forks of Eklutna Creek are the two primary sub-basins above Eklutna Lake and account for about 80% of the lake’s inflow. The drainage areas of the east and west forks are 38.9 and 24.7 square miles respectively. The east fork has a few unnamed cirque glaciers within the watershed, accounting for approximately 12% of the drainage area. The west fork is dominated solely by the Eklutna Glacier, which occupies more than 46% of the drainage area (Larquier, 2010; USGS, 1993).

As previously noted, the Eklutna Glacier is retreating as a result of climate change. The mass lost from Eklutna Glacier has important consequences for runoff to a downstream reservoir that is used – in its entirety – to provide municipal water and hydropower for the city of Anchorage. The runoff from net- mass loss alone averaged 7 ± 1% of total inflow to the reservoir from 2010 to 2015, and in 2013 and 2015 reached ∼13%. The eventual diminishing deglaciation dividend will necessarily result in decreased water availability (Sass et al, 2017).

Eklutna Lake's total drainage comprises approximately 119 square miles, including the east and west fork sub-basins. The Eklutna River watershed downstream of Eklutna Lake is 55 square miles, including 38 square miles within the Thunderbird Creek sub-watershed (Section 905b Study). Thunderbird Creek represents the only major tributary to flow into the lower Eklutna River. Thunderbird Creek enters the lower Eklutna River approximately 3.3 miles from its confluence with Knik Arm (NWS, 2018; USGS 2006).

5.3.2 Hydrology

5.3.2.1 Natural Flows (Pre-1929) In 1924 Frank Reed with AL&P hired Seattle engineer Robert Howes to conduct initial studies regarding the hydropower potential at Eklutna. On March 4, 1924, Howes estimated the flow at the lake outlet to be 50-60 cfs. Howes also established a gage at the mouth of the canyon on March 12, 1924 and measured the flow to be 69.3 cfs at that time when the water was believed to be at a very low stage (Howes, 1924).

AL&P established a staff gage at the mouth of the canyon about half a mile above the railroad crossing. In the fall of 1928, when active preliminary construction work had commenced, a gaging station was installed at the mouth of the canyon. The gaging station was referenced to the original staff gage in order to calculate a continuous flow record, with the exception of the last three months of 1924 and December

McMillen Jacobs Associates 76 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

1927. The flow from January 1923 to December 1928 is shown in Figure 5-6. The two short gaps in the record were filled in by approximation. The computed total annual flow for each year is also shown on the figure and in Table 5-1 During that time period, there was a wide variation of streamflow throughout the year, the maximum occurring in July and August and the minimum in early spring. The minimum flow recorded in this period was 50 cfs and the average for the whole period was 640 cfs. The maximum discharge recorded was 2,930 cfs in September 1925.

Table 5-1. Annual Flow of Eklutna River in Acre-Feet from 1924 to 1928 (AL&P, 1929)

The flow of the Eklutna River was affected by Eklutna Lake. The lake had a narrow outlet with a well- established crest elevation, which restricted the natural flow during periods of high runoff, thereby reducing the peak flows. It was considered probable that the lake also had some effect of maintaining the low flow during the winter months by permitting the seepage of impounded water through the gravels that formed the natural dam at the lake outlet. Measurements at Eklutna Lake indicated roughly about the same discharge as what was measured at the outlet of the canyon (AL&P, 1929).

McMillen Jacobs Associates 77 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 5-6. Run-off of Eklutna River at the mouth of the canyon from 1924 to 1928 (AL&P, 1929)

McMillen Jacobs Associates 78 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

5.3.2.2 Flow at the Diversion Dam (1930-1946) The flow at the diversion dam in the lower river was recorded in connection with the operation of the power plant starting in October 1929. However, this was not a traditional gaging station record but was a compiled record made by totaling the flow through the powerhouse, the flow over the diversion dam, and at times leakage around the sluice gate in the dam. The flow through the powerhouse was based on the manufacturer’s rating of the turbines showing the theoretical relation between power generated and water required. The flow over the diversion dam was based on a theoretical rating curve that was never checked with meter measurements. The leakage around the sluice gate was estimated. The record was not a daily record but instead was based on observations about every third day (USGS, 1947). The flow record from 1930-1946 is shown in Table 5-2 below.

Table 5-2. Monthly Mean Discharge of Eklutna River at Diversion Dam 1930-1946 (USGS, 1947)

The annual means varied from a minimum of 239 cfs to a maximum of 514 cfs. The maximum value recorded was 3,098 cfs in August 1944. The date of the maximum discharge varied from the earliest on July 4, 1946 to the latest on September 14, 1938. The average date of maximum discharge was August 12th (USGS, 1947). Figure 5-7 below is a photo of Eklutna Lake and the Eklutna River in 1939.

McMillen Jacobs Associates 79 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 5-7. Eklutna Lake and Eklutna River on September 10, 1939

5.3.2.3 USGS Gage Stations (Post-1946) The USGS gage stations listed in Table 5-3 provide flow data for the Eklutna River watershed post-1946. All of the flow data for these gage stations can be accessed at http://waterdata.usgs.gov/ak/nwis/. Figure 5-8 shows the Eklutna River sub-basins and stream gage locations.

Table 5-3.Stream Gages in the Eklutna River Watershed

Gage Station Date Range Location Number 1960 – 1962 15277600 East Fork of Eklutna Creek 1985 – 1988 1960 – 1962 15277800 West Fork of Eklutna Creek 1985 – 1988 15280000 1946 – 1962 Eklutna River 200 feet downstream of Eklutna Lake 15280100 2002 – 2007 Eklutna River above Thunderbird Creek 1954 – 1956 15280200 Eklutna River at Old Glenn Highway 2002 – 2006

McMillen Jacobs Associates 80 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 5-8. Eklutna River Sub-basins and Stream Gage Locations (USFWS, 2019)

East and West Fork of Eklutna Creek Available mean monthly and daily flow statistics for East Fork Eklutna Creek from 1960-1962 and 1985- 1988 are provided in Table 5-4 and Figure 5-9 below. Mean daily flow ranges hover around 20-40 cfs from November-April, with flows rapidly rising in May with peak flows above 500 cfs from mid to late July. Mean monthly flows reflect a similar pattern with July representing the highest mean monthly flow volumes with an average of 461 cfs over the seven years of record.

Table 5-4. Mean monthly flow values for East Fork Eklutna Creek Monthly mean in ft3/s (Calculation Period: 1960-06-01 -> 1988-12-31) YEAR Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 1960 316 402 321 166 95 55 40 1961 37 34 30 30 127 327 450 443 205 89 40 27 1962 21 16 13 16 72 423 464 405 1985 160 469 326 186 59 26 23 1986 20 16 10 11 61 248 451 327 180 167 54 33 1987 23 23 21 13 65 235 444 426 227 86 39 28 1988 21 17 15 15 83 326 549 446 162 101 37 28 Mean of Monthly 24 21 18 17 81 291 461 385 188 99 42 30 Discharge ** No Incomplete data have been used for statistical calculation

McMillen Jacobs Associates 81 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

EF Eklutna Creek near Palmer, AK - USGS Gage No. 15277600 Mean of Daily Mean Values (Calculation Period: 5-7 Years of Data from 1960 -1988) 600

500

400

300 Discharge Discharge (cfs)

200

100

0 Jan-1 Feb-1 Mar-1 Apr-1 May-1 Jun-1 Jul-1 Aug-1 Sep-1 Oct-1 Nov-1 Dec-1 Date

Figure 5-9. Mean daily flow values for East Fork Eklutna Creek

Available mean monthly and daily flow statistics for West Fork Eklutna Creek from 1960-1962 and 1985- 1988 are provided Table 5-5 and Figure 5-10 below. Mean daily flows range between 0-8 cfs from November-April, with flows beginning to rise in May and peak flows above 600 cfs in late July. Mean monthly flows reflect a similar pattern with July and August representing the highest mean monthly flow volumes (473 cfs and 471 cfs respectively) over the seven years of record. Figures 5-11 and 5-12 below shows pictures of the East and West Forks of Eklutna Creek in June 1965 and July 1957 respectively.

Table 5-5. Mean monthly flow values for West Fork Eklutna Creek Monthly mean in ft3/s (Calculation Period: 1960-06-01 -> 1988-12-31) YEAR Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 1960 272 498 469 186 18 7.0 4.0 1961 2 1 0.00 0.67 32 186 492 493 229 23 3.0 1.0 1962 0.32 0 0.00 0.50 19 282 599 693 1985 65 360 343 197 29 5.8 2.4 1986 1.0 0.5 0.00 0.50 11 123 490 422 205 89 15.1 4.4 1987 1.3 0.607 0.00 1.5 9.8 84 379 437 197 27 9.6 3.2 1988 2.2 1.2 0.00 0.67 12 155 494 437 118 40 8.5 5.0 Mean of monthly 1.4 0.66 0.00 0.77 17 166 473 471 188 38 8.2 3.3 Discharge ** No Incomplete data have been used for statistical calculation

McMillen Jacobs Associates 82 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

WF Eklutna Creek near Palmer, AK - USGS Gage No. 15277800 Mean of Daily Mean Values (Calculation Period: 5-7 Years of Data from 1960 -1988) 700

600

500

400

Discharge Discharge (cfs) 300

200

100

0 Jan-1 Feb-1 Mar-1 Apr-1 May-1 Jun-1 Jul-1 Aug-1 Sep-1 Oct-1 Nov-1 Dec-1 Date

Figure 5-10. Mean daily flow values for West Fork Eklutna Creek

Figure 5-11. East and West Forks of Eklutna Creek on June 11, 1965

McMillen Jacobs Associates 83 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 5-12. East and West Forks of Eklutna Creek on July 12, 1957

Eklutna River Available mean monthly and daily flow statistics for the Eklutna River downstream of Eklutna Lake from 1947-1962 are provided in Table 5-6 and Figure 5-13 below. There are two distinct monitoring periods to describe. The eight-year record from 1947-1954 represents outflows from Eklutna Lake when the City of Anchorage controlled flow releases from the existing dam at the lake outlet. Mean daily flows from 1947- 1954 hold at approximately 130 cfs from mid-October through January. From early February through mid-May, flows slowly decrease from approximately 120 cfs to 80 cfs. Flows begin to rise in mid-May with peak flows of approximately 1,300 cfs in late-July. Mean monthly flows confirm this pattern with July representing the highest mean monthly flow volume of 1,098 cfs for the 8 years of record.

McMillen Jacobs Associates 84 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

The eight-year record from 1955-1962 represents outflows from Eklutna Lake after the Federal hydropower project was constructed and waters from Eklutna Lake were being diverted to the Knik River. Mean daily flows from 1955-1962 typically remain steady at a range of 15-20 cfs from mid-October through mid-February. From mid-February through late July, flows decrease to a range of 3.8 cfs to 0.0 cfs. Flows begin to rise in late-July with peak flows of approximately 450 cfs in mid-August. Mean monthly flows confirm this pattern with August representing the highest mean monthly flow volume of 308 cfs for the 8 years of record.

Participants of a workshop hosted by Trout Unlimited (TU) and NVE in 2018 created a hydrograph for streamflow at the Eklutna Lake outlet from 1947 to 1954 (Figure 5-14) by using the historic streamflow data from the Eklutna River, gauge data from the Eklutna Lake, and a comparison to the seasonal patterns exhibited by similar streams located throughout Alaska. This period predated completion of the Federal hydropower project. Therefore, participants agreed this hydrograph probably closely mimics the natural streamflow at the lake outlet and could serve as a helpful template for natural flows.

Table 5-6. Mean monthly flow values for Eklutna River

Monthly mean in ft3/s (Calculation Period: 1946-10-01 -> 1962-08-31) YEAR Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 1946 175 145.7 143.1 1947 99 86 90 86 77 462 1095 893 388 284 133 136 1948 123 149 128 120 144 508 958 871 157 133 131 134 1949 119 112 75 87 112 427 833 936 713 195 121 134 1950 133 125 120 111 93 501 979 898 410 73 126 125 1951 122 70 57 47 100 373 1301 989 1097 191 138 141 1952 162 122 125 81 46 296 960 831 365 354 201 120 1953 131 126 129 123 133 897 1672 1402 608 205 138 141 1954 140 115 94 99 139 550 985 1025 485 212 141 140 1955 120 69 0 0 0 0 190 705 252 2.7 0 0 1956 0 0 0 0 0 0 0 635 337 0.71 0 0 1957 0 0 0 0 0 0 10.4 779 524 11 0.20 0 1958 0 0 0 0 0 0 0 330 8.4 0 0 0 1959 0 0 0 0 0 0 0 13 12 0 0 0 1960 0 0 0 0 0 0 0 0 0 0 0 0 1961 0 0 0 0 0 0 0 0 0 0 0 0 1962 0 0 0 0 0 0 0 0 Mean of monthly Discharge 129 113 102 94 105 502 1098 980 528 202 142 135 (1947-1954) Mean of monthly Discharge 15 9 0 0 0 0 25 308 162 2 0 0 (1955-1962)

McMillen Jacobs Associates 85 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Eklutna River near Palmer, AK - USGS Gage No. 15280000 Mean of Daily Mean Values (Calculation Periods: 8 Years of Data from 1947 -1954; and 1955-1962) 1,400

1955-1962 1947-1954 1,200

1,000

800

Discharge Discharge (cfs) 600

400

200

0 Jan-1 Feb-1 Mar-1 Apr-1 May-1 Jun-1 Jul-1 Aug-1 Sep-1 Oct-1 Nov-1 Dec-1 Date

Figure 5-13. Mean daily flow values for Eklutna River from 1947-1954 and 1955-1962

Figure 5-14. Eklutna Lake Outlet Streamflow Normalized by Mean Annual Flow (TU, 2018)

McMillen Jacobs Associates 86 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Available mean monthly and daily flow statistics for the Eklutna River at the Old Glenn Highway (below Thunderbird Creek confluence) from 2002-2007 are provided in Table 5-7 and Figure 5-15 below. Mean daily flows range between 12 cfs to 20 cfs from mid-December through early April. Flows begin to rise in early April with peak flows of approximately 108 cfs in mid-June. Mean monthly flows confirm this pattern with June representing the highest mean monthly flow volume of 86 cfs over the six years of record.

Table 5-7. Mean monthly flow values for the Eklutna River at the Old Glenn Highway Monthly mean in ft3/s (Calculation Period: 2002-05-01 -> 2007-08-31) YEAR Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2002 53 78 53 63 64 66 43 24 2003 21 22 16 22 21 72 67 40 30 39 23 17 2004 16 13 12 18 50 80 42 29 43 74 30 26 2005 17 13 14 35 96 146 94 75 76 50 20 21 2006 11 13 11 17 29 78 61 90 58 49 18 18 2007 15 17 16 18 26 64 61 61 Mean of monthly 16 16 13 22 46 86 63 60 54 56 27 21 Discharge

Eklutana River at Old Glenn Highway at Eklutna, AK - USGS Gage No. 15280200 Mean of Daily Mean Values (Calculation Period: 5-6 Years of Data from 2002 -2007) 120

100

80

60 Discharge Discharge (cfs)

40

20

0 Jan-1 Feb-1 Mar-1 Apr-1 May-1 Jun-1 Jul-1 Aug-1 Sep-1 Oct-1 Nov-1 Dec-1 Date

Figure 5-15. Mean daily flow values for the Eklutna River at the Old Glenn Highway

McMillen Jacobs Associates 87 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Discharge measurements were taken for the Eklutna River above Thunderbird Creek (USGS 15280100) from 1954-1956 and 2002-2006. However, it should be noted that this is not a continuous data set, therefore all results are in situ and represent flow conditions at the time of each unique measurement. The 35 unique discharge measurements range from a high of 23.5 cfs to a low of 4.1 cfs.

5.3.2.4 Thunderbird Creek Estimated Flows There is no available gage data for Thunderbird Creek. However, NVE has estimated flows for Thunderbird Creek from May 2002 to April 2004 by subtracting the flow measured by NVE in the Eklutna River above the Thunderbird Creek confluence from the daily mean flow at USGS gage station 15280200 located in the Eklutna River below the Thunderbird Creek confluence (NVE, 2003a). This data is presented in Table 5-8 and Figure 5-16 below.

Table 5-8. Thunderbird Creek Estimated Flows (cfs) from May 2002 to April 2004 (NVE, 2003a)

Eklutna River Below Eklutna River Above Thunderbird Creek Date Confluence Confluence (By Subtraction) (USGS 15280200 Daily Mean) (NVE Measurement) 5/17/2002 42 12 30 5/24/2002 75 13 62 5/31/2002 87 11 76 6/7/2002 79 11 68 6/14/2002 74 11 63 6/21/2002 82 8 74 7/5/2002 58 8 50 7/11/2002 55 8 47 7/29/2002 48 7 41 8/13/2002 66 12 54 8/23/2002 70 9 61 8/30/2002 68 7 61 9/9/2002 76 11 65 9/13/2002 73 7 66 9/20/2002 59 7 52 9/27/2002 57 8 49 10/4/2002 63 10 53 10/15/2002 64 10 54 10/25/2002 69 9 60 11/1/2002 63 9 54 11/8/2002 48 8 40

McMillen Jacobs Associates 88 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

11/22/2002 37 9 28 11/30/2002 37 11 26 12/13/2002 29 9 20 1/17/2003* 22 7 15 4/7/2003* 14 7 7 5/2/2003 22 9 13 5/9/2003 19 8 11 5/30/2003 27 8 19 6/6/2003 35 8 27 6/13/2003 81 8 73 6/20/2003 101 9 92 6/27/2003 80 9 71 7/3/2003 88 9 79 7/12/2003 66 8 58 7/18/2003 62 7 55 7/25/2003 58 7 51 8/1/2003 49 7 42 8/8/2003 37 7 30 8/14/2003 38 6 32 8/22/2003 39 6 33 8/29/2003 39 6 33 9/5/2003 35 7 28 9/12/2003 30 6 24 9/19/2003 27 6 21 9/26/2003 26 7 19 10/3/2003 33 8 25 10/10/2003 47 6 41 10/24/2003 33 6 27 11/6/2003 27 5 22 1/26/2004* 16 5 11 2/25/2004* 13 4 9 4/25/2004* 21 8 13 *Winter discharges mostly under ice

McMillen Jacobs Associates 89 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Thunderbird Creek Estimated Flows 120

100

80

60

40

20

0

5/24/2002 6/24/2002 7/24/2002 8/24/2002 9/24/2002 1/24/2003 2/24/2003 3/24/2003 4/24/2003 5/24/2003 6/24/2003 7/24/2003 8/24/2003 9/24/2003 1/24/2004 2/24/2004 3/24/2004 4/24/2004

10/24/2002 11/24/2002 12/24/2002 10/24/2003 11/24/2003 12/24/2003 Eklutna River Below Confluence Eklutna River Above Confluence Thunderbird Creek (USGS 15280200 Daily Mean) (NVE Measurement) (By Subtraction)

Figure 5-16. Thunderbird Creek Estimated Flows (cfs) from May 2002 to April 2004 (NVE, 2003a)

5.3.3 Water Quality Alaska’s water quality standards are established under Administrative Code 18 AAC 70, amended as of April 6, 2018 and overseen by ADEC (ADEC, 2018). The standards established by ADEC must be approved by the U.S. Environmental Protection Agency (EPA) to comply with regulations under the federal Clean Water Act (CWA). Based on ADEC regulations, water quality within the Eklutna River watershed is protected by water quality criteria for the following fresh water designated water use classes and subclasses:

▪ Water supply (drinking water, agriculture, aquaculture, industrial) ▪ Water recreation (contact and secondary recreation) ▪ Growth and propagation of fish, shellfish, other aquatic life, and wildlife

Alaska Water Quality Standards identify acceptable levels for designated use for categories of pollutants, including pH, temperature, turbidity, fecal coliform bacteria; dissolved oxygen (DO); nutrients; sediment; metals; and toxic substances. Water quality criteria for designated water use classes are provided in two unique documents: 1) 18 AAC 70 Water Quality Standards, amended as of April 6, 2018; and 2) Alaska Water Quality Criteria Manual for Toxic and Other Deleterious Organic and Inorganic Substances (ADEC, 2008).

McMillen Jacobs Associates 90 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Available water quality data within the Project vicinity comes primarily from the USGS. Approximately 200 feet downstream of Eklutna Lake, the USGS analyzed water samples between 1948 to 1952. During a similar timeframe (1949-1952), the USGS collected water quality data on the middle segment of the Eklutna River downstream of the 1929 diversion dam (removed in 2018) and in the lower Eklutna River near the Old Glenn Highway crossing. Finally, the USGS collected water quality samples in the tailrace of the Eklutna power plant from 1972-1973. A summary of available water quality data from the USGS sampling efforts is provided in Table 5-9.

Table 5-9. Available USGS water quality data within the Eklutna River watershed (1948-1981)

Eklutna River Below Eklutna Lake -USGS Station 15280000 (1948-1952) Analyte Range Units No. of Samples ADEC Criteria 6.5-8.5. May not vary 0.5 pH pH 6.6-7.7 -- 41 units from ambient conditions Temperature 0-13.0 °C 8 20°C Specific Conductance 107-214 uS/cm 43 Carbon Dioxide 2-20 mg/L 41 Bicarbonate 46-110 mg/L 43 Nitrate 0.05-0.29 mg/L 43 10

Hardness as CaCo3 50-74 mg/L 42 Calcium 16-24 mg/L 42 Magnesium 2.4-3.9 mg/L 42 Sodium 1.8 mg/L 1 Potassium 0.9 mg/L 1 Chloride 0.4-3.5 mg/L 43 860 Sulfate 13-35 mg/L 43 Flouride 0-0.2 mg/L 26 1,000 Silica 2.6-6.4 mg/L 43 Iron 10-110 ug/L 31 1,000 Dissolved Solids 64-86 mg/L 42 1,000 Eklutna River Below Diversion Dam -USGS Station 612706149195000 (1949-1952) 6.5-8.5. May not vary 0.5 pH pH 7.0-7.8 -- 41 units from ambient conditions Temperature 11.5 °C 1 20°C Specific Conductance 49-73 uS/cm 42 Carbon Dioxide 1.6-12 mg/L 41 Bicarbonate 51-98 mg/L 42 Nitrate 0.09-0.23 mg/L 41 10

Hardness as CaCo3 51-93 mg/L 42 Calcium 16-24 mg/L 40 Magnesium 2.6-5.6 mg/L 40 Sodium 2.1-2.7 mg/L 2 Potassium 0.7 mg/L 2 Chloride 0.5-7 mg/L 41 860 Sulfate 14-20 mg/L 40 Flouride 0-0.3 mg/L 26 1,000 Silica 1.9-8.7 mg/L 41 Iron 10-110 ug/L 30 1,000 Dissolved Solids 71-100 mg/L 40 1,000

McMillen Jacobs Associates 91 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Eklutna River at Old Glenn Highway -USGS Station 15280200 (1949-1951) 6.5-8.5. May not vary 0.5 pH pH 6.8-6.9 -- 2 units from ambient conditions Temperature 8.5-11.5 °C 2 20°C Specific Conductance 161-167 uS/cm 2 Carbon Dioxide 15-20 mg/L 2 Bicarbonate 76-77 mg/L 2 Nitrate 0.16-0.27 mg/L 2 10

Hardness as CaCo3 77-79 mg/L 2 Calcium 23 mg/L 2 Magnesium 4.7-5.2 mg/L 2 Sodium + Potassim 2.5-3.4 mg/L 2 Chloride 1.0-1.4 mg/L 2 860 Sulfate 18-19 mg/L 2 Silica 4.3-4.9 mg/L 2 Iron 30 ug/L 1 1,000 Dissolved Solids 94 mg/L 2 1,000 Suspended Sediments 16-85 mg/L 5 Eklutna River Below Power Plant (tailrace) - USGS Station 612836149084800 (1972-1973) 6.5-8.5. May not vary 0.5 pH pH 7.5-8.1 -- 8 units from ambient conditions Temperature 0-12.5 °C 10 20°C Specific Conductance 120-144 uS/cm 10 Turbidity 4-40 JTU 8 Dissolved Oxygen 9.9-11 mg/L 5 >7 mg/L Carbon Dioxide 0.9-3.3 mg/L 8 Bicarbonate 54-69 mg/L 9 Nitrate 0.11 mg/L 1 10 Nitrate+Nitrite 0.4-0.18 mg/L 8 10 Phosphorus <0.01-0.01 mg/L 8

Hardness as CaCo3 57-74 mg/L 9 Calcium 18-25 mg/L 9 Magnesium 2.7-3.2 mg/L 9 Sodium 2.5-3.3 mg/L 9 Potassium 0.2-0.7 mg/L 9 Chloride 0.8-4.2 mg/L 9 860 Sulfate 13-20 mg/L 9 Flouride <0.1-1.0 mg/L 9 1,000 Silica 2.6-6.3 mg/L 9 Arsenic <1.0 ug/L 1 50 Barium <100 ug/L 1 2,000 Cadmium trace ug/L 1 5 Chromium n/d ug/L 1 100 Copper 10 ug/L 10 Iron <10-110 ug/L 8 1,000 Lead <2 ug/L 1 50 Manganese <10-110 ug/L 8 200 Silver n/d ug/L 1 0.5 Zinc 50 ug/L 1 60 Selenium <1 ug/L 1 20 Total Coliform 0-17 cfu/100ml 6 Dissolved Solids 2.2-98.2 mg/L 9 1,000 Suspended Sediments 3-20 mg/L 8

McMillen Jacobs Associates 92 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

5.3.3.1 Turbidity, Dissolved Solids, and Suspended Sediments The USGS data indicate relatively low turbidity levels ranging from 4-40 Jackson Turbidity Units (JTU) within the Project tailrace. Concentrations of dissolved solids range from 2.2-100 mg/L based on 92 sampling events at the four sampling sites. Dissolved solids in the Eklutna River are well below the ADEC criteria of 1,000 mg/L. The USGS also sampled for suspended sediments on 13 occasions in the lower Eklutna River (n=5) and in the Project tailrace (n=8). Suspended sediment concentrations ranged from 3-85 mg/L with the lower Eklutna River station having slightly higher suspended sediment concentrations in comparison to the tailrace sampling site.

Turbidity and total suspended sediment (TSS) data are available for Eklutna Lake from March 23- November 26, 1984 (R&M, 1985). Turbidity and TSS values ranged from 2.1-75 Nephelometric Turbidity Units (NTU) and 1.1-31 mg/L, respectively. Peak turbidity values occurred on August 18, 1984, while minimum measurements for turbidity occurred on June 6, 1984. August 18, 1984 represents the sampling event when both minimum and maximum TSS concentrations were detected. The peak TSS measurement was at a depth of 52 feet, while the minimum TSS concentration was at a depth of 144 feet. This result is not unusual as temperature profiles indicate Eklutna Lake is stratified in August, and therefore has unique water chemistry near the surface (epilimnion), at mid-depth (metalimnion), and near the bottom (hypolimnion). Although multiple sampling stations were established in Eklutna Lake, the data summarized above are from Station 9, a mid-lake location that was also in the deepest area of Eklutna Lake (about 200 feet).

It should be noted that there is no current turbidity, dissolved solids, or suspended sediments data for the Eklutna River.

5.3.3.2 Nutrients The USGS dataset contains nutrient data for various aqueous forms of nitrogen and phosphorus, with nitrate being the most frequently sampled analyte (n= 87) with orthophosphate being sampled exclusively at the tailrace site (n=8). Orthophosphate was recorded at concentrations of <0.01 - 0.01 mg/L and nitrate concentrations ranged from 0.05-0.29 mg/L, well below the 10 mg/L ADEC criteria for nitrate.

5.3.3.3 Trace Metals, Major Ions, Hardness and Conductivity The USGS provides data for a variety of trace metals and major ions. These data indicate that all of the analytes tested are in low concentrations and below ADEC criteria. The only metals or major ions detected at concentrations above detection limits include magnesium, manganese, sodium, calcium, copper, iron, and zinc.

Hardness as calcium carbonate (CaCO3) ranged from 50-93 mg/L (n = 93) at all of the USGS Eklutna River sampling stations. All of the Eklutna River sites had similar hardness values that did not exceed 79 mg/L CaCO3, with only the mid-reach of the Eklutna River having a slightly higher hardness concentration of 93 mg/L CaCO3. With a method detection limit of 20 mg/L, these data indicate the Eklutna River falls within the low range of water hardness.

McMillen Jacobs Associates 93 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Conductivity data confirms the relatively low ion concentration in the Eklutna River system. Ninety- seven USGS samples measured a specific conductance (conductivity at 25ºC) range of 49-214 uS/cm for the upper, middle, and lower reaches of the Eklutna River. The highest specific conductance values were measured in the upper reaches of the Eklutna River (just downstream of the lake outlet), while the lowest specific conductance values (range of 49-73 uS/cm) were measured in the mid-reach of the Eklutna River (downstream of the recently removed diversion dam).

Conductivity data are also available for Eklutna Lake from field sampling efforts in 1984 (R&M, 1985). Between May 17-November 26, 1984 specific conductance ranged from 106-157 uS/cm at Station 9. Station 9 served as the primary data collection station due to its mid-lake location and proximity to the deepest areas of Eklutna Lake.

5.3.3.4 Coliform Bacteria The USGS sampled for total coliform bacteria only at the tailrace site (n=6). Total coliform was detected in low concentrations (0-17 colony forming units/100 ml). The USGS data does not provide additional details or information on other common bacteria typically tested in surface waters (i.e. Escherichia and fecal coliform bacteria). Therefore, the majority of coliform bacteria present in these samples is most likely from non-pathogenic sources such as soil or vegetation.

5.3.3.5 pH, Dissolved Oxygen (DO), and Temperature At all of the USGS sampling sites in the Eklutna River, pH data range from 6.6 – 8.1 (n = 92) and meets ADEC criteria. However, the downstream site has slightly more acidic conditions with ADEC data showing a pH range of 5.8 to 6.9.

Spot DO data are only available at the tailrace sampling location (n=5). DO concentrations ranged from 9.9 – 11.0 mg/L. The average of the 5 readings was 10.6 mg/L, with the minimum DO concentration measured in mid-July of 1973. Overall, these 5 readings are well above the ADEC criteria of 7 mg/L.

Spot temperature readings within the Eklutna River ranged from 0 – 13ºC (n= 21). The 13ºC reading was measured in the upper reach of the Eklutna River in early August of 1951, while temperatures of 11.5ºC were found at the middle and lower reaches of the Eklutna River in mid-August of 1949 and early June of 1951, respectively. At the tailrace sampling site, a peak temperature of 12.5ºC was detected in late July of 1973.

Temperature profiles of Eklutna Lake were conducted in 1982 to validate the dynamic reservoir simulation model (DYRESM) and test its application to other lakes in Southcentral Alaska (APA, 1984). Lake profiles were collected at a station with a depth of approximately 200 feet from June 18 to November 4, 1982 (n=8). In mid-June, the difference between surface (8ºC) and bottom (5ºC) temperatures is only 3ºC. In mid-July through August 11th, Eklutna Lake appears to stratify with surface temperatures ranging from 13.0ºC to 14.0ºC and bottom temperatures from 5.2ºC to 5.4ºC. On September 9th the stratification diminishes with surface and bottom temperatures of 10.8 ºC and 5.7 ºC, respectively. By September 21st the stratification of Eklutna Lake ends (i.e. lake turnover) and temperatures at the surface (8.0ºC) and at depth (7.0ºC) differ by only 1.0ºC. The relatively uniform temperatures throughout

McMillen Jacobs Associates 94 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package the water column of Eklutna Lake continue in mid-October (7.1ºC and 6.8ºC) and early November (5.1ºC and 5.2ºC).

Additional spot temperature measurements of Eklutna Lake were made near the surface and at depth (> 144 feet) in 1984 (R&M, 1985). Surface temperatures ranged from 6.3ºC to 14.0ºC (n=11) between May 17, 1984 and October 15, 1984. Bottom temperatures ranged 5.2ºC to 6.3ºC (n=5) from August 18- October 15, 1984. The temperature data from both of these studies produced remarkably similar results with peak surface temperatures of 14ºC in early to mid-July and minimal bottom temperatures of 5.2ºC - 5.4ºC during the mid-summer period of lake stratification.

5.3.4 Water Rights In the federal legislation authorizing the construction of the Eklutna project in July 1950, Congress reserved the waters of Eklutna Lake and its tributaries required for operation of the Project. In 1977, pursuant to AS 46.15.060, the State of Alaska recognized this federal reservation and the APA’s primary water right in the Eklutna River watershed in its Certificate of Appropriation ADL 44944 (State of Alaska, 1977). The State of Alaska granted the water right a priority date of December 31, 1954 and allowed the APA to divert any and all of the natural inflow into Eklutna Lake for hydroelectric generation. The State of Alaska’s certificate limits the Eklutna project to a maximum diversion rate of 660 cubic feet per second (cfs) for power production. When the Project was sold to the three utilities on October 2, 1997, APA transferred “that certain federal reserved water right created by the Eklutna Project Act of 1950, and including State of Alaska Water Rights Certificate of Appropriation (Amended) ADDL 44944” to the current Project owners pursuant to a quitclaim deed.

On January 16, 1985, AWWU filed an application of Preferred Use Status with the Division of Land and Water Management to divert 41 million gallons of per day (mgd) for public water supply. In a memorandum dated November 19, 1985, the Division of Land and Water Management denied the AWWU request as the additional appropriation of 41 million gpd would deplete and eventually empty the Eklutna Lake Reservoir (ADNR, 1985a). However, based on the 1984 compensation agreement between AWWU and APA, ADNR did grant AWWU Permit 2569 to divert 41.0 mgd from the existing appropriation to APA under ADL 44944 provided the maximum daily AWWU diversion did not exceed 72 million gallons on any single day. In addition, the quantity of water associated with LAS 2569 is to be reevaluated after 9, 15, 20, 25, 30, and 35 years (ADNR, 1986b). APA’s water right, ADL 44944, was subsequently amended to address the diversion as follows:

“Utilizing any and all of the natural inflow to Eklutna Lake and stored in Eklutna Reservoir between the intake invert elevation of 793 feet and the normal maximum water surface elevation of 871 feet (230,521 acre feet of storage), except that quantity of water which may be diverted from Eklutna Reservoir for the purpose of public water supply under authority of Section 45 of Public Law 98-552 98 STAT.2824 (1984) and appropriated under state of Alaska water rights permit/certificate LAS 2569 issued to the municipality of Anchorage.”

In addition to the water rights for power production and municipal water supply, NVE has applied for three water rights to create instream flow reservations for the protection of fish and wildlife habitat,

McMillen Jacobs Associates 95 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package migration, and propagation (NVE, 2003a; NVE 2003b; and NVE, 2003c). Specifically, application LAS 24335 is for segment 1 of the Eklutna complex which starts at the exit of the AWWU aqueduct in the Eklutna River canyon and continues downstream approximately 3 miles to the confluence with Thunderbird Creek. Application LAS 24334 is for segment 2 of the Eklutna complex. Segment 2 is delineated as Thunderbird Creek from the first major tributary draining Mount Eklutna and Bear Mountain, downstream to the confluence with the Eklutna River. Application LAS 24336 is for segment 3 of the Eklutna complex which starts at the confluence of Thunderbird Creek and flows downstream approximately 3 miles its terminus at the Knik Arm of Cook Inlet. NVE is requesting 100% of the remaining instream flows for each river segment be reserved for Eklutna River salmonids. The 2003 applications have not been adjudicated.

5.3.5 References ADEC (Alaska Department of Environmental Conservation). 2013. Alaska Water Quality Criteria Manual for Toxic and Other Deleterious Organic and Inorganic Substances. As amended through May 15, 2013. Available at: https://www.epa.gov/sites/production/files/2014-12/documents/ak- toxics-manual.pdf

ADEC (Alaska Department of Environmental Conservation). 2018. 18 AAC 70 Water Quality Standards. Amended as of April 6, 2018. Register 226, July 2018. Available at: https://dec.alaska.gov/water/water-quality/standards/

ADNR (Alaska Department of Natural Resources). 1985a. State of Alaska Water Rights Certificate of Appropriation (Amended) ADL 44944. Alaska Division of Land and Water Management.

ADNR. 1985b. Permit to Appropriate Water (Preferred Use), LAS 2569. December 16, 1985.

Howes, Robert. 1924. To Frank I. Reed of Anchorage, Alaska RE: Eklutna Hydro Electric Project. May 8, 1924.

NVE (Native Village of Eklutna). 2003a. Application for Reservation of Water. LAS 24334. Alaska Division of Land and Water Management. Application received June 2, 2003.

NVE. 2003b. Application for Reservation of Water. LAS 24335. Alaska Division of Land and Water Management. Application received June 2, 2003.

NVE. 2003c. Application for Reservation of Water. LAS 24336. Alaska Division of Land and Water Management. Application received June 2, 2003.

APA (Alaska Power Authority). 1984. Susitna Hydroelectric Project Eklutna Lake Temperature and Ice Study. 16 pp with 39 Figures. Submitted January 1984.

R&M (R&M Consultants, Inc.). 1985. Eklutna Lake Suspended Sediment, Turbidity, and Temperature Data 1982-1984. Memorandum submitted 5/1/1985 to Aquatic Study Team Members in support of Project No. 452418. 27 pp.

Sass, Louis et al. 2017. Journal of Glaciology. Geometry, mass balance and thinning at Eklutna Glacier, Alaska: an altitude-mass-balance feedback with implications for water resources.

McMillen Jacobs Associates 96 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Tibbetts, Fred H. 1929. Report to Anchorage Light and Power Co. Eklutna Hydro-Electric Project Report, Report No. 5. San Francisco, California. February 1929.

USGS (U.S. Geological Survey). 1947. Preliminary Report on Water Power Resources of Eklutna Creek, Alaska. Tacoma, Washington. August 1947.

McMillen Jacobs Associates 97 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

5.4 Fish and Aquatic Resources

5.4.1 Historic Salmon Runs Salmon have historically spawned in many drainage systems of Knik Arm, including the Eklutna River (Fall, 1981). However, prior to 2000 the written record and systematic study of salmon returning to the Eklutna River is limited and inconclusive (NVE, n.d.). In their 1992 Divestiture Summary Report, the APA stated that “One fisheries manager suggested that overfishing might have wiped out or greatly depleted the anadromous fish run prior to construction of the 1929 dam. If so, this would substantiate the lack of commercial fisheries data going back as early as 1900 when commercial fisheries were being exploited throughout the region” (APA, 1992). Recent studies regarding historic salmon runs and the traditional ecological knowledge (TEK) of the Eklutna people are summarized below.

5.4.1.1 Recent Studies It has been speculated that the kokanee in Eklutna Lake could be descendants of a historic sockeye run that utilized Eklutna Lake. However, in their 2011 report the USACE stated that it’s doubtful that significant numbers of sockeye salmon ever spawned in the Eklutna River drainage because suitable spawning area upstream of the lake is limited and water quality in the lake would likely have limited opportunities for spawning in the littoral zone of the lake. Eighty percent of the water entering Eklutna Lake comes from two turbid glacial streams that would not be conducive to the consistent survival of sockeye salmon from egg to fry. The remaining available and suitable spawning area would not be sufficient to support large numbers of spawning anadromous salmon. In addition, the physical limnology studies of Eklutna Lake suggest that the turbidity in Eklutna Lake during much of the year is not conducive to significant primary production (USACE, 2011). However, many significant sockeye systems in Alaska are predominantly glacial fed similar to Eklutna Lake. In some instances, sockeye have been found to spawn and rear at great depths in glacial systems. While these systems are more turbid and not as conducive to significant primary production, they do support stable fish runs (Section 905b Study).

A recent study was conducted to try to determine “whether there was an anadromous salmon into Eklutna Lake prior to 1929” (when the earlier hydropower project was constructed by AL&P) by using marine- derived nutrients (MDN) as a biochemical marker in lake sediment. The technique relies on the nitrogen isotopic analysis of well-dated lacustrine sediments. The study found that there was no significant difference in the nitrogen composition of sediment layers from before and after 1929. However, a sensitivity test was conducted to assess the possibility that a small salmon run may have gone undetected by the isotopic analysis. It was determined that “a salmon run of up to 1,000 per year, and potentially as many as 15,000 per year, would be possible without noticeably altering the measured isotopic composition of the sediments in Eklutna Lake.” Therefore, the results “provide no evidence that such runs occurred, but do not preclude the possible existence of a relatively small sockeye fishery in Eklutna Lake before 1929” (Loso et al, 2019).

5.4.1.2 Traditional Ecological Knowledge According to several Eklutna village elders, most Eklutna residents spent summers at fish camps distributed along the shore of Knik Arm from Fire Island to the Knik River, preserving ocean-caught salmon for winter use (Figure 5-17). As the summer progressed, families moved back to the winter

McMillen Jacobs Associates 98 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package villages, which were traditionally “located along productive salmon streams, by the mouths of lakes, or on the high bluffs” above Knik Arm. Eklutna was one of these winter villages (Loso et al., 2017).

Figure 5-17. Preserving salmon for winter use (photo provided by The Conservation Fund)

Maria Coleman, current NVE Tribal Council Vice President, listened to the Eklutna elders in the early 1970s. Six elders, now deceased, told her that the Eklutna River used to be “overflowing” with “abundant” fish before the dams. Max Alex, a recent Eklutna elder, also noted that there were plentiful salmon in the Eklutna and all the streams in the area. He says all species of salmon ran in the Eklutna River before the dams (NVE, n.d.). Former NVE Chief Executive Officer, Lee Stephan, stated that his father, Leo Stephan, learned from his teachers and elders that before the lower dam was constructed in 1929, salmon went to Eklutna Lake and spawned in the Eklutna River inflow. Native elders (now deceased) also reported to Maria Coleman that there used to be several sheep-hunting cabins around Eklutna Lake, and that these seasonal subsistence camps were provisioned by fish caught from the lake. However, it was not specified that the fish were sockeye (Loso et al, 2017).

Regarding the time period after the diversion dam was built in 1929 and before the Federal hydropower project was constructed in 1955, Eklutna elders noted that in the 1940s and in the early 1950s salmon of all species were still abundant in Eklutna River. Just above the confluence with Thunderbird Creek there was a large beaver dam. Here people used pews to pitch to land as many fish of all species as they needed, including sockeye and Chinook salmon. One elder, Jim Ezi, also recalls taking Chinook salmon in the Eklutna River above Thunderbird Creek and below the old diversion dam in the 1940s.

Daniel Alex, born in 1939, wrote the following while he was Tribal Administrator for NVE: “At peak flow, the water level in the canyon portion was wall to wall at where the old Eklutna Bridge is presently. At the same time in the lower part of the river, it was bank to bank and even overflowing the banks. The overflow provided water to the wetland area down near the mouth and south of the river, which was habitat for salmon fry. Salmon and trout did migrate up to Eklutna Lake. My late brother, Herbert Alex once told me that as a boy, he was fishing at the old upper dam and was almost pulled into the water by a

McMillen Jacobs Associates 99 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package large rainbow trout. The regular flow of water cleaned out any vegetation that would try to grow in the stream bed. There was a clear water spring below the railroad tracks to the North of where the river was, that had a large flow of clear water, enough to make a stream that was at least 25 feet wide and at least 24 inches in depth. It was habitat for pink and chum salmon. The village used to get salmon for food until the salmon deteriorated. My mother would tell us that we needed salmon for dinner, and we would go to the stream and toss fish up onto the bank and pick a good one. The ones not acceptable were thrown back into the stream. That stream was a spawning area for the pink and chum salmon. Sockeye, coho and Chinook salmon did migrate up Thunderbird Creek. Where rainbow and other trout species are means that salmon are present. Different trout species feed on salmon eggs and likely salmon fry. The fact that trout migrated to the lake meant there was food present for them. A conclusion that salmon run was destroyed by the dams is a logical conclusion” (Leggett, 2020).

After the Federal hydropower project was constructed, Lee Stephan remembers an abundance of pink salmon and other species in the Eklutna River during his youth in the late 1960s and 1970s. NVE believes that Chinook salmon no longer run here because the water level is too low with the 100% flow diversions from Eklutna Lake (NVE, unpublished).

5.4.2 Habitat Degradation Development within the Eklutna River watershed, including hydropower development, construction of the railroad and highway bridges, and aggregate mining, has degraded channel morphology and salmonid habitat functionality (USACE, 2011).

Construction of the concrete diversion dam in the lower Eklutna river in 1929 blocked any fish passage into the upper watershed that may have occurred previously. After construction of the Federal hydropower project in 1955, all outflow from Eklutna Lake (except for spill events) was diverted through a 4.5-mile-long tunnel to the penstock, powerhouse, and tailrace that discharges into the Knik River. This diversion of water is the primary cause of the degradation of any fish habitat that may have existed in the upper river (USACE, 2011). Today, some sections of the upper Eklutna River are completely dry. In addition, certain areas of the upper river are so overwhelmed with fine sediment that the embedded coarser substrate that lies below cannot be observed (Figure 5-18) (MJA, 2019b).

Figure 5-18. Fine sediment between cobble (left) & covering coarser substrate (right) (MJA, 2019b)

McMillen Jacobs Associates 100 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

The relatively narrow railroad bridge and elevated railbed cause natural bedload to accumulate between the railroad and New Glenn Highway bridges. Much of the bedload deposited between the bridges appears to have been caused by a 100-year flood event on October 12, 19862. This event flooded the ecosystem behind the elevated railbed and caused a massive volume of bedload being carried down from the canyon to drop out and superimpose a fresh alluvial deposit on the existing deposits. This deposit and additional bedload transported in subsequent but smaller events has elevated the riverbed between the bridges to a point where it has become highly braided and subject to frequent channel changes.

While these areas provide quality rearing habitat when wetted, some of these channels de-water as they flow downstream. Conversely, when viewed from the downstream end of the reach, some of the channels braid into small and often impassable branches moving upstream. These small, shallow braided channels shown in Figure 5-19 often run through heavily wooded areas that can dewater, strand fish, and make passage for salmon difficult or impossible. In addition to sediment accumulation conditions between the bridges, the channel appears to be starved of smaller gravel and sediment for several hundred yards downstream of the railroad bridge (USACE, 2011).

Figure 5-19. Eklutna River between railroad and New Glenn Highway bridges (MJA, 2019b)

2 Note that there was no reported spill event at the dam in 1986.

McMillen Jacobs Associates 101 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Aggregate mining within the lower Eklutna River ecosystem has further degraded the channel and reduced its current salmonid production potential. Mining downstream of the railroad bridge lowered the ecosystem habitat adjacent to the river channel by approximately 20 feet (Figure 5-20) and removed most of the old growth riparian vegetation between the railroad bridge and the upper extent of the intertidal zone associated with Knik Arm. A 100-year flood event in 1986 changed the river course between the railroad bridge and Knik Arm. Prior to the 1986 flood, the river flowed along the northern edge of the alluvial deposit. After the 1986 flood, the river flowed through the degraded mined area that’s virtually devoid of old growth riparian vegetation, large woody debris, or other habitat that promotes optimum production of rearing salmonids during the summer. Some riparian vegetation and woody debris has naturally reestablished itself since 1986 (USACE, 2011).

Figure 5-20. The remains of an electrical substation perched above existing ground level after approximately 20 vertical feet of aggregate was removed by mining operations (USACE, 2011)

Further degradation results from human use of the ecosystem, which continues to degrade its structure and function. Vehicle trails through the riparian habitat parallel the river, and vehicles cross or drive on the riverbed for short distances at several locations. Vehicle crossings create barriers to and disrupt the passage of adult salmon, and vehicle use on the riverbed results in compaction of the riparian soils and the riverbed. Vehicles also break down riverbanks that, under the right soil conditions, result in degraded

McMillen Jacobs Associates 102 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package channel morphology that can strand juvenile salmon during periods of rapid fluctuation in water levels. Vehicle use in the ecosystem can also disturb wildlife and introduce pollutants (USACE, 2011).

In an effort to increase salmon habitat and help restore the fishery for subsistence use by NVE, a series of three, interconnected ponds were created in the 1980s in an old gravel pit located 1.2 river km from the river’s mouth on Cook Inlet. The gravel pit was connected to the main-stem Eklutna River via an artificial channel. While providing off-channel habitat, this project did not restore river processes. Beaver dams have since altered the configuration of the lower river ponds (Ward, 2010).

In 2018 Eklutna, Inc., in partnership with The Conservation Fund, removed the old diversion dam in the lower Eklutna River (lower dam) which had blocked fish passage since 1929. The purpose of the project was to help restore some natural stream functions that were inhibited by the lower dam's presence (HDR, 2016). However, there was concern regarding the large amount of sediment that had accumulated behind the lower dam and the potential negative impacts to existing downstream fish habitat that could occur as a result of flushing the sediment downstream. The Section 404 Permit issued by USACE requires Eklutna, Inc. to monitor the physical changes to channel geometry, substrate composition, water temperature and turbidity at three downstream transects (USACE, 2017).

In 2017 prior to completion of the dam removal project, seven monitoring sites were established in the Eklutna River (five downstream of the lower dam site and two above) and baseline data was collected. Only channel geometry and substrate composition were recorded during the initial 2017 sample event to represent pre-removal conditions. Three of the transects downstream of the lower dam site (two above the Thunderbird Creek confluence and once below) were used for the monitoring project. Year 1 (2018) of the monitoring project was completed by Eklutna, Inc. in collaboration with NMFS, NVE, and ADFG. In 2019, Eklutna, Inc. contracted with the ADFG to complete the final two years of USACE required monitoring. ADFG established an additional monitoring location above the sediment plug upstream from the lower dam site and conducted two sampling events during 2019 at all four established monitoring locations (Figure 5-21). At each of the three lower sites, a suite of variables including channel geometry, substrate composition, and water quality were recorded. Continuous water temperature monitoring sites were established at two of these three locations. At the one site upstream from the dam site, only water quality variables were recorded in addition to the establishment of a third continuous temperature monitoring location (ADFG, 2020).

In their 2019 Aquatic Habitat Monitoring Technical Report, ADFG reported that channel geometry measurements indicate that aggradation occurred following the lower dam deconstruction at the two monitoring sites upstream from the Thunderbird Creek confluence. Dominant substrates generally transitioned from silt/sand and cobble prior to dam deconstruction to mostly medium gravel dominance. Water quality at these two sites was generally within expected ranges; however, pH was consistently high, ranging from 8.44 to 8.70. All recorded variables from the monitoring site downstream from the Thunderbird Creek confluence generally remained unchanged. At the water quality sampling location upstream from the sediment plug, all variables were found to be within the expected range. Interestingly, pH was again high; however, it tracked closely to measurements taken at each of the other monitoring sites. Each site will be visited again twice in 2020 (ADFG, 2020).

McMillen Jacobs Associates 103 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 5-21. Eklutna River Monitoring Site Map (ADFG, 2020)

5.4.3 Current Fish Habitat and Assemblage The Eklutna River from the mouth of the river to just above the confluence with Thunderbird Creek is catalogued as an anadromous stream by ADFG. Four species of anadromous Pacific salmon return to the Eklutna River as adults: Chinook (Oncorhynchus tshawytscha), chum (Oncorhynchus keta), pink (Oncorhynchus gorbuscha), and coho (Oncorhynchus kisutch). A fifth species, sockeye (Oncorhynchus nerka), only occasionally stray into the Eklutna River (USACE, 2011).

In 2006 the USACE conducted a habitat assessment of the Lower Eklutna River and Thunderbird Creek to assess the existing habitat available to salmon. The survey began at the mouth of the Eklutna River in the Knik Arm of Upper Cook Inlet and continued to approximately a quarter mile above the Lower Eklutna Dam. It also included Thunderbird Creek from its confluence with Eklutna River to the falls. The USACE divided the Eklutna River into 6 distinct reaches (Figure 5-22) and then divided into 111 habitat units. The physical characteristics of each reach are summarized in Table 5-10 below (USACE, 2007).

McMillen Jacobs Associates 104 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 5-22. Map of Habitat Reaches in the Lower Eklutna River (USACE, 2007)

Table 5-10. Physical Characteristics of Reaches in the Lower Eklutna River (USACE, 2007)

The USACE summarized the results of the survey as follows: “The Eklutna River system changes from a single channel to a multichannel river and then back to a single channel as one moves from the mouth upstream. The entrenchment of the river remains consistent throughout with the exception of Reach 4. It contains the largest amount of flow in the most constrained area of the river. The width/depth ratio of the channel changes depending on how constrained the channel is within the reaches. Reach 1 and Thunderbird Creek Reach 1 show the lowest ratio values because of the constraints of the channel allowing for very little movement of the channel. Gradient of the entire system stays around 1 percent or less. The substrate of the river is directly influenced by the tides and obstructions found within the system. Reach 1 and 2 have a silt substrate from the tidal deposition of silt. Reaches 3, Reach 4, and Thunderbird Creek Reach 1 have a cobble substrate from the movement of materials down the canyon. Reach 5 and 6 have a silt and sand substrate because the Lower Eklutna Dam has inhibited the transportation of material to Reach 5 and the Upper Eklutna Dam stopped the natural flow regime which

McMillen Jacobs Associates 105 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package would deposit gravels in Reach 6. Sinuosity values are consistent throughout the Eklutna system with a small increase in the lower braided sections of the river.” (USACE, 2007)

In 2019 NVE conducted a habitat assessment of the entire Eklutna River from the Cook Inlet to Eklutna Lake utilizing the same methods that the USACE used in their 2006 survey. NVE identified 11 reaches total (Figure 5-23) and summarized the results of their survey as follows “This system is mainly a single channel system for the length of the lower river. Some braiding is present, influenced by beaver dams flooding areas and remains of historical gravel mining, rather than geomorphological features. The river is approximately 62,292.70 feet in length (11.8 miles) with only half of the river having continuous water flow (5.97 miles). The river is predominately a run ecosystem with 15% being completely dry. Sixteen percent of the river has instream shelter values, with the largest category of instream shelter provided by small woody debris and terrestrial vegetation (34.4% and 21.2% respectively). Almost three quarters of the river’s banks are vegetated with deciduous trees (45%), brush (28%), and grasses (11%). Roughly 12% of the bank substrate composition is bedrock, with the remainder split three ways between boulders (29%), cobble/gravel (31%), and silt/sand/clay (27%)” (NVE, 2020b)

Figure 5-23. Map of Habitat Reaches in the Eklutna River (NVE, 2020b)

NVE observed significant changes in substrate composition between the 2006 and 2019 surveys in Units 1-6. It’s likely that these changes are largely influenced by the lower dam removal. In summary, Reach 1 is improved with increased gravel, Reach 2 and 3 have accumulated significant silt, Reach 4 has more sand while Reach 5 and 6 have much less silt and Reach 6 has much more gravel. Improvements to salmon habitat for Reach 5 and 6 are significant. However, per NVE increased flow is required for salmon to use the improved habitat (NVE, 2020b).

NVE sport salmon fishers have noted that Eklutna River Chinook salmon “are the largest found in any area streams or rivers.” Marc Lamoreaux, NVE Land and Environment Director, measured a 56-inch dead king by the lower Eklutna River ponds in 2002. In addition, Dustin Lorah, Trustee on the NVE Village Council, has measured a 52-inch fish caught and released and reported seeing another Chinook salmon caught (released) that was, “even bigger”. However, the relative size of Eklutna Chinook salmon has not

McMillen Jacobs Associates 106 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package been researched quantitatively. It should also be noted that Chinook salmon have been listed by ADFG as a Stock of Concern for several drainages in the Upper Cook Inlet (NVE, 2020a).

In 2019 after the lower dam removal, the ADFG Habitat Section conducted a fish sampling effort from the Old Glenn Highway bridge upstream to the lower dam site. During a single day of sampling, 10 baited minnow traps were set along with many opportunistic dip net attempts. Concurrently, visual observations were made of any adult salmon visible in the turbid water. A total of 57 juvenile coho salmon, 58 juvenile Chinook salmon, and 26 Dolly Varden were captured ranging upstream to a natural fish passage barrier located 1.6 km (1 mile) upstream from the Thunderbird Creek confluence. Observations from this sampling effort have been nominated for inclusion in the Anadromous Waters Catalog (AWC) and are anticipated to be adopted into the catalog by June 2020 (ADFG, 2020).

In 2018 Trout Unlimited and NVE hosted a restoration workshop for the Eklutna River. Figure 5-24 shows the life cycle timing for coho, Chinook, and sockeye relative to historic stream gage data compiled based on the results of the workshop.

Figure 5-24. Timing of Life Stages for Coho, Chinook, and Sockeye (TU, 2018)

5.4.3.1 Escapement The run strength of adult salmon in Eklutna River is not well known as few escapement surveys have been conducted and a counting weir has never been operated. NVE conducted fish count surveys in the Eklutna River, including Thunderbird Creek, in 2002 and 2003. The estimated total number of salmon by species for each year is shown in Table 5-11 below. Thunderbird Creek contributed relatively few fish to the overall counts because fish passage is blocked approximately one-third of a mile upstream by Thunderbird Falls. Most of the salmon seen were counted in reaches of the Eklutna River above and below its confluence with Thunderbird Creek. NVE speculates that up to 60 Chinook salmon may have

McMillen Jacobs Associates 107 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package returned to the Eklutna River drainage in 2003, but about half of these were taken illegally before they spawned (USACE, 2011).

Table 5-11. NVE estimated total number of salmon in 2002 and 2003 (NVE, unpublished)

Year 2002 2003

Chum 1,100 275

Coho 131 60

King 36 44

Pink 45 18

Red 2 21

Total 1,314 418

5.4.3.2 Spawning The predominant spawning locations in the Eklutna River from the upper limit of tidal influence to the 1929 diversion dam and the accessible stretch of Thunderbird Creek have been documented via surveys. Some pink, chum and Chinook salmon spawn in the reach downstream from the railroad bridge. No salmon have been observed spawning in the braided section of the river upstream of the railroad bridge. Pink, chum and Chinook resume spawning in the single channel that begins at the highway bridge and continues upstream to the confluence with Thunderbird Creek (Figure 5-25). The majority of spawning currently takes place in this reach. Chinook also spawn in Thunderbird Creek. Coho typically spawn in the upper areas of their natal drainage. The areas where coho spawn in Eklutna River have not been documented by survey, but they are known to spawn in Thunderbird Creek and in a few areas between Thunderbird Creek and the 1929 diversion dam that are associated with upwelling (USACE, 2011).

Existing salmonid escapement numbers indicate an underutilization of available spawning habitat. While limited visual observations indicate the spawning quality of the gravel in these areas is higher quality than most of the rest of the watershed, its overall quantity and production potential is not known as no studies have been done to directly assess quantities and quality. In some areas of the Eklutna River the spawning gravel appears clean on the surface, but it is embedded with silt just under its surface. In some areas observations of female salmon digging their nest show there is a considerable amount of turbidity associated with digging activity (USACE, 2011).

McMillen Jacobs Associates 108 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 5-25. Areas where salmon are known or suspected to spawn (USACE, 2011)

5.4.3.3 Juvenile Usage

Pink and Chum Salmon Pink and chum salmon fry emerge at night and immediately begin a downstream migration toward the sea. In short coastal streams like the Eklutna River, pink and chum fry can complete this journey during the initial night after emergence. However, if they do not complete their journey during the first night, the fry will sometimes re-enter the substrate and re-emerge the second night to complete the journey. Those that do not or cannot seek protection during daylight hours are exposed to predators and can suffer a relatively high proportional rate of mortality. A high rate of fry mortality influences the abundance of adults returning to the ecosystem.

McMillen Jacobs Associates 109 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Free, unhindered downstream passage is important to the survival of pink and chum salmon fry. The braided section of the river upstream from the railroad bridge traps many out-migrating fry that emerge upstream of this reach due to this stretch being predisposed to stranding and de-watering associated with fluctuating water flows. Fry entering this reach can easily be shunted into one of several small rivulets that dead end in thick vegetation or a dewatered channel. Fry that become stranded in these dead-end rivulets fall victim to desiccation and predation by birds and small fish-eating mammals like mink and weasels (USACE, 2011).

Coho and Chinook Salmon Coho fry live in river systems for 1 to 2 years before they undergo physical and chemical changes and migrate to the marine environment. Compared with coho, few Chinook are trapped as smolt in the Eklutna River, and it is possible that most juveniles of this species do not spend their first winter in the Eklutna River at all, but out-migrate as age 0+ juveniles and spend their first winter in the Knik Arm estuary.

Both Chinook and coho fry require low velocity side or off-channel habitat during their early life history. Because of this, the braided reach of the Eklutna River upstream of the railroad bridge is particularly appealing and potentially dangerous for these species. Field observations indicate that coho fry become trapped and stranded in this reach during the summer months. As Chinook grow in size, they tend to leave habitat preferred by younger fry and other species and move into faster flowing, more turbulent water with quality instream structure (boulders, large wood, etc.).

Due to its aforementioned degraded condition, the Eklutna River has a substantial lack of both summer and winter rearing habitat for juvenile Chinook and coho. Summer rearing habitat is important to the freshwater survival of post-emergent fry because it provides the growth and conditioning necessary for successful overwintering under harsh environmental conditions (low flows, limited food sources, cold water temperatures, etc.). Existing overwintering habitat is currently limited to interstitial spaces between large cobbles in areas of the river that do not freeze to the bottom, deeper holes on the intertidal flats, and perhaps small areas in the ponds created from mining gravel. Yet, juvenile Chinook and coho seem to survive these conditions in relative abundance. Catches of rearing coho juveniles and outmigrant smolt during early summer can be as high as 55 fish per trap baited with salmon eggs, though such a large catch is uncommon. The winter survival strategy of juvenile Chinook and coho salmon overwintering in the degraded river is uncertain (USACE, 2011).

In 2010, the three ponds in the old gravel pit and the main-stem Eklutna River up to the Old Glenn Highway Bridge were examined to determine if and how off-channel and main-stem habitats are utilized by coho salmon seasonally. Coho salmon were caught in the Eklutna River ponds throughout the study. The lower Eklutna River pond was the most productive habitat evaluated, and it supported a large summer coho salmon population of 3,490 coho salmon larger than 60 mm fork length, with coho salmon densities of 57/ 100 m². Coho salmon distribution within the Eklutna ponds was influenced by water temperature, with the highest catches in traps with temperatures between 11 and 13.5ºC. Fish reared in the Eklutna ponds tended to be older, (predominately ages 1 and 2) than fish reared in the main stem (predominately age 0) (Ward 2010).

McMillen Jacobs Associates 110 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

5.4.3.4 Resident Fish in Eklutna Lake Resident fish found in Eklutna Lake include rainbow trout, Dolly Varden, and kokanee (landlocked sockeye). Male and female kokanee salmon from Eklutna Lake are shown in Figure 5-26.

Figure 5-26. Eklutna Lake Kokanee (ADFG, n.d.)

ADFG sampled Eklutna Lake using gill nets in 1973, 1980, and 1985. The results shown in Table 5-12, indicated stable Dolly Varden and kokanee populations. It was noted that the kokanee appeared to spawn then die in their third year of life, and that spawning occurred along the lake shoal areas (ADNR, n.d.).

Table 5-12. Results of Sampling Eklutna Lake in 1973, 1980, and 1985 (ADNR, n.d.)

Sample Date Number Sampled Average Length (inches) Length Range (inches) Dolly Varden July 1973 81 7.25 4.5 – 16.5 August 19801 199 7 2.5 – 14.5 October 1985 82 7.25 3 – 16 Kokanee July 1973 29 3.5 3.25 – 4.5 August 19802 239 4 3.5 – 5 October 1985 59 3.75 3.5 – 4.5 1Live trap sampling captured Dolly Varden from 1.75 – 9.75 inches in length 2Live trap sampling captured Kokanee from 1.5 – 4 inches in length

McMillen Jacobs Associates 111 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

ADFG stocked Eklutna Lake with excess rainbow trout fingerlings from 1987 through 1997 (Table 5-13) but stopped stocking the lake because of low catch rates and limited angler participation (USACE, 2011). Per the 2016 Chugach State Park Management Plan, chum and coho salmon were each stocked once in 1992 and 1996 respectively (ADNR, 2016). However, ADFG thinks that the records for chum or coho stocking into Eklutna Lake are incorrect. Because those are entries from the Eklutna Salmon Hatchery, ADFG believes they were most likely saying that the water source was Eklutna Lake. Hatchery staff (Diane Loopstra) agreed that is most likely what happened (Jay Baumer, personal communication). ADFG is not currently stocking Eklutna Lake and has no plans to stock the lake in the future.

Table 5-13. Stocking records for Eklutna Lake (ADNR, 2016)

ADFG sampled Eklutna Lake again in 1988, 1989, and 1990 by setting eight fyke nets and 12 minnow traps overnight. Results are shown in Figure 5-27 (ADNR, n.d.). Dolly Varden were the most abundant in both 1988 and 1989, followed closely by rainbow trout. However, rainbow trout numbers far exceeded Dolly Varden in 1990. Kokanee were by far the least abundant in all three years.

ADFG conducted test-net sampling in 1993. Results are shown in Table 5-14. Once again rainbow trout were by far the most abundant with 300 individuals, and Kokanee were the least abundant with only 7 individuals (USACE, 2011).

Table 5-14. Results of Sampling Eklutna Lake in 1993 (USACE, 2011)

McMillen Jacobs Associates 112 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 5-27. Results of Sampling Eklutna Lake in 1988, 1989, and 1990 (ADNR, n.d.)

McMillen Jacobs Associates 113 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

5.4.4 Macroinvertebrates In 2019 a study was conducted to determine how removal of the lower dam might influence macroinvertebrate communities in the Eklutna River downstream. Previous research has found that turbid, glacier fed streams tend to have less macroinvertebrate taxonomic diversity, while clear water streams tend to have greater macroinvertebrate taxonomic diversity. Therefore, the study compared the different taxonomic groups of macroinvertebrates found in the Eklutna River between the lower dam site and its confluence with Thunderbird Creek to the relatively undisturbed and clear Thunderbird Creek itself. The study results as shown in Figure 5-28 indicate that Thunderbird Creek is currently a more favorable habitat for a greater number of macroinvertebrates, and the large amount of suspended sediment traveling downstream following the removal of the dam makes for a poorer habitat for macroinvertebrates in the lower Eklutna River (McLallen, 2019).

Figure 5-28: The relative abundance of the most prevalent taxonomic groups for Thunderbird Creek and the Lower Eklutna River

5.4.5 Beluga Whales Beluga whales are known for their white color and range of vocal sounds, earning them the title of “canary of the sea.” They are very social animals, forming groups to hunt, migrate, and interact with each other. Beluga whales have a varied diet consisting of octopus, squid, crabs, shrimp, clams, snails, and sandworms. They also eat a variety of fishes, including salmon, cod, sole, herring, eulachon, smelt, and flounder. In the United States, NMFS has identified five stocks of beluga whales, all in Alaskan waters: the Beaufort Sea, Bristol Bay, Cook Inlet, eastern Bering Sea, and eastern Chukchi Sea stocks. Each stock is unique, isolated from one another genetically and/or physically by migration routes and preferred

McMillen Jacobs Associates 114 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package habitats. Of the five Alaskan stocks, the Cook Inlet beluga stock is the smallest and most isolated from other beluga whales.

All beluga whale populations are protected under the Marine Mammal Protection Act (MMPA). NMFS has designated the Cook Inlet beluga whale population in Alaska as depleted under the MMPA (i.e., they have fallen below their optimum sustainable population levels). In addition, the Cook Inlet distinct population segment has been listed as an endangered species under the Endangered Species Act (ESA). The endangered Cook Inlet beluga whale population has declined by nearly 80% since 1979, from about 1,300 whales to an estimated 279 whales in 2018. The rapid decline and dire status of the Cook Inlet beluga whale population makes it a priority for NMFS and its partners to prevent extinction and promote recovery.

The summer range of Cook Inlet belugas has changed significantly since the 1970s, contracting northward and eastward toward Anchorage in upper Cook Inlet. This range contraction coincided with the population’s rapid decline. The reason for the Cook Inlet beluga’s distribution change is unknown, but the Susitna River delta appears to be an important feeding area that continues to be occupied by large gatherings of belugas during the ice-free period. This puts a larger portion of the endangered population near the most densely populated area of the state during the busy summer season, when boating, construction, and other human activities all increase.

Cook Inlet belugas were once a valuable part of the regional Alaska Native subsistence diet. However, their rapid population decline is thought to have most likely been caused by unregulated subsistence harvest at a level that this small population could not sustain. Although the hunt has been suspended since 2005, the whale population has not recovered as expected. Threats that could potentially limit recovery of Cook Inlet beluga whales include: anthropogenic noise, catastrophic events (natural disasters, spills, and mass strandings), habitat loss or degradation, prey reduction (eulachon and salmon), disease agents (pathogens, parasites, and harmful algal blooms), unauthorized take and trauma, pollution, predation, hunting, poaching, or intentional harassment, and cumulative and synergistic effects of multiple stressors (NMFS, n.d.).

5.4.6 References ADFG (Alaska Department of Fish and Game) Habitat Section. 2020. Eklutna River Aquatic Habitat Monitoring, 2019. Technical Report No. 19-13. January 2020.

ADNR (Alaska Department of Natural Resources) Department of Parks and Outdoor Recreation. 2016. Chugach State Park Management Plan. February 2016.

ADNR Department of Parks and Outdoor Recreation. Nd. Chugach State Park Files, ADFG Lake Stocking.

APA (Alaska Power Administration), U.S. Department of Energy (DOE). 1992a. Divestiture Summary Report: Sale of Eklutna and Snettisham Hydroelectric Projects. April 1992.

McMillen Jacobs Associates 115 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

HDR. 2016a. Project Description to support application Section 404 Individual Permit: 2017 Dam Deconstruction and Sediment Relocation – Lower Eklutna River Dam Removal Project. November 15, 2016.

Loso, Michael et al. 2017. Evaluating Evidence for Historical Anadromous Salmon Runs in Eklutna Lake, Alaska. Arctic Institute of North America. Arctic, Vol. 70, No. 3 (September 2017), pp. 259-272.

McLallen, Kaitlan and Elaina Maddaloni. 2019. Macroinvertebrate Taxonomic Comparison Between Lower Eklutna River and Thunderbird Creek. Alaska Pacific University.

MJA (McMillen Jacobs Associates). 2019a. Eklutna Hydroelectric Project: Fish & Wildlife Program Development. Technical Group Follow-up Meeting Minutes.

MJA. 2019. Eklutna Hydroelectric Project: Fish & Wildlife Program Development: Site Reconnaissance Trip Report. August 2019.

NMFS (National Marine Fisheries Service). n.d. Species Directory, Beluga Whale. Website https://www.fisheries.noaa.gov/species/beluga-whale.

NVE (Native Village of Eklutna). Unpublished. Traditional Knowledge of Eklutna Fish Resources.

NVE. 2020a. Comments on Draft Initial Information Package. April 24, 2020.

NVE. 2020b. Eklutna River Salmon Habitat Assessment and Collaboration to Recommend Restoration Flows.

TU (Trout Unlimited). 2018. Eklutna River Workshop, Summary of Outcomes, Recommendations, and Future Needs. June 2018.

USACE (U.S. Army Corps of Engineers). 2007.

USACE. 2011. Eklutna River Aquatic Ecosystem Technical Report. USACE Alaska District. November 2011.

USACE. 2017. Section 404 Permit POA-2016-248, Eklutna River. June 21, 2017.

Ward, Nicole A. 2010. Monitoring the efficacy of juvenile salmon (Oncorhynchus spp.) off-channel habitat restoration projects in south central, Alaska. December 2010.

McMillen Jacobs Associates 116 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

5.5 Wetlands, Riparian, and Littoral Habitat Wetlands are transitional lands between terrestrial and aquatic systems where the water table is usually at or near the surface or the land is covered by shallow water (Cowardin et al., 1979). Wetlands must have one or more of the following three attributes: (1) at least periodically, the land supports predominantly hydrophytes (plants specifically adapted to live in wetlands); (2) the substrate is predominantly undrained hydric (wetland) soil; and (3) the substrate is nonsoil and is saturated with water or covered by shallow water at some time during the growing season of each year (Cowardin et al., 1979). Types of wetlands are classified according to their hydrologic, geomorphic, chemical, and biological characteristics.

In 2012 Eklutna, Inc., in partnership with the Great Land Trust (GLT), completed the Fire Creek and Eklutna River conservation easements covering eight miles of coastline totaling 1,355 acres. The establishment of these conservation easements resulted in a 35-mile long wildlife corridor of nearly continuous protected lands, mostly wetlands, bordering upper Knik Arm, from Palmer Hay Flats State Game Refuge, past Eklutna, and on to Fire Creek near Beach Lake. The lands protected by the Eklutna River Estuary Conservation Easement remain under Eklutna, Inc. ownership, and traditional uses such as subsistence fishing and hunting by shareholders continue under GLT conservation easements management (NVE, 2014).

Wetlands in the Project area were mapped using USFWS National Wetlands Inventory (NWI) (USFWS, 2020). In this analysis, wetlands within 250 feet of the centerline of the Eklutna River and within 500 feet of the shoreline of Eklutna Lake were mapped and quantified. The alluvial fan where the Eklutna River flows into the Knik Arm of Cook Inlet was also included in the analysis. Wetlands are classified according to the system presented in Cowardin et al. (1979). Types and location of wetlands in the Project vicinity are shown on Figure 5-29. A total of 3,783.9 acres of wetlands are present in the Project vicinity. The majority of these wetlands are classified as Lake, due to the presence of Eklutna Lake (3,182.3 acres; 84.1% of total wetlands), followed by Freshwater Forested/Shrub Wetlands (346.8 acres; 9.2% of total wetlands). Freshwater Forested/Shrub wetlands primarily occur near the outlet of Eklutna Lake and in the lower Eklutna River upstream of tidal influence, although some small forested/shrub wetlands exist along the Eklutna River. Estuarine and Marine Wetlands are found just upstream of the Eklutna River’s confluence with the Knik Arm (157.1 acres; 4.2% of total wetlands). Areas of Riverine Wetlands along the length of the Eklutna River and at the upstream end of Eklutna Lake are present in the Project vicinity (74.3 acres; 2.0% of total wetlands). Several Freshwater Ponds (23.4 acres; 0.6% of total wetlands) are present downstream of the railroad bridge. Table 5-15 contains detailed wetland classifications and total acreages.

Table 5-15. Wetland Descriptions and Acreage in the Project vicinity

Wetland Total Wetland Type Description Code Acres

E—Estuarine: The Estuarine System consists of deepwater tidal habitats and adjacent tidal wetlands that Estuarine and are usually semi-enclosed by land but have open, partly Marine E2EM1P 98.6 obstructed, or sporadic access to the open ocean, and in Wetland which ocean water is at least occasionally diluted by freshwater runoff from land.

McMillen Jacobs Associates 117 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Wetland Total Wetland Type Description Code Acres 2—Intertidal: The substrate in these habitats is flooded and exposed by tides; includes the associated splash zone. EM—Emergent: Characterized by erect, rooted, herbaceous hydrophytes, excluding mosses and lichens. This vegetation is present for most of the growing season in most years. These wetlands are usually dominated by perennial plants 1—Persistent Vegetation: Dominated by species that normally remain standing at least until the beginning of the next growing season. P—Irregularly Flooded: Tides flood the substrate less often than daily.

E—Estuarine: See above. 2—Intertidal: See above. US—Unconsolidated Shore: This type includes all wetland Estuarine and habitats having two characteristics: (1) unconsolidated Marine E2USN 58.5 substrates with less than 75% areal cover of stones, Wetland boulders, or bedrock and; (2) less than 30% areal cover of vegetation. Landforms such as beaches, bars, and flats are included in the Unconsolidated Shore class. N—Regularly Flooded: Tides alternately flood and expose the substrate at least once daily.

L—Lacustrine: This type includes wetlands and deepwater habitats with all of the following characteristics: (1) situated in a topographic depression or a dammed river channel; (2) lacking trees, shrubs, persistent emergents, emergent mosses or lichens with greater than 30% areal coverage; and (3) total area exceeds 8 ha (20 acres). 1— This Subsystem includes all deepwater habitats (i.e., areas > 2.5 m [8.2 ft] deep below low water) in the Lake L1UBH 3,182.3 Lacustrine System. Many small Lacustrine Systems have no Limnetic Subsystem. UB—Unconsolidated Bottom: This type includes all wetlands and deepwater habitats with at least 25% cover of particles smaller than stones (less than 2.4 to 2.8 inches), and a vegetative cover less than 30%. H—Permanently Flooded: Water covers the substrate throughout the year in all years.

Freshwater P—Palustrine: This type includes all nontidal wetlands Forested/Shrub PSS1/EM1B 62.2 dominated by trees, shrubs, persistent emergents, Wetland emergent mosses or lichens and all such wetlands that occur in tidal areas where salinity due to ocean-derived

McMillen Jacobs Associates 118 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Wetland Total Wetland Type Description Code Acres salts is below 0.5 part per thousand (ppt). It also includes wetlands lacking such vegetation but having all of the following four characteristics: (1) area less than 20 acres; (2) active wave-formed or bedrock shoreline features lacking; (3) water depth in the deepest part of basin less than 8.2 feet at low water; and (4) salinity due to ocean- derived salts less than 0.5 ppt. SS—Scrub-Shrub: This type includes areas dominated by woody vegetation less than 20 feet tall. The species include true shrubs, young trees (saplings), and trees or shrubs that are small or stunted because of environmental conditions. 1—Broad-leaved Deciduous: This type has woody angiosperms (trees or shrubs) with relatively wide, flat leaves that are shed during the cold or dry season; e.g., black ash (Fraxinus nigra).

P—Palustrine: See above. SS—Scrub-Shrub: See above. Freshwater 1—Broad-leaved Deciduous: See above. Forested/Shrub PSS1A 38.8 Wetland A—Temporarily Flooded: Surface water is present for brief periods (from a few days to a few weeks) during the growing season, but the water table usually lies well below the ground surface for most of the season.

P—Palustrine: See above. SS—Scrub-Shrub: See above.

Freshwater 1—Broad-leaved Deciduous: See above. Forested/Shrub PSS1B 193.8 B—Seasonally Saturated: The substrate is saturated at or Wetland near the surface for extended periods during the growing season, but unsaturated conditions prevail by the end of the season in most years. Surface water is typically absent but may occur for a few days after heavy rain.

P—Palustrine: See above. SS—Scrub-Shrub: See above. Freshwater 1—Broad-leaved Deciduous: See above. Forested/Shrub PSS1C 16.5 Wetland C—Seasonally Flooded: Surface water is present for extended periods especially early in the growing season but is absent by the end of the growing season in most years. The water table after flooding ceases is variable.

McMillen Jacobs Associates 119 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Wetland Total Wetland Type Description Code Acres

P—Palustrine: See above. SS—Scrub-Shrub: See above. Freshwater 1—Broad-leaved Deciduous: See above. Forested/Shrub PSS1R 33.6 Wetland R—Seasonally Flooded-Tidal: Tidal fresh surface water is present for extended periods (generally for more than a month) during the growing season but is absent by the end of the season in most years.

P—Palustrine: See above. SS—Scrub-Shrub: See above. 4—Needle-Leaved Evergreen: The dominant species in Freshwater Needle-leaved Evergreen wetlands are young or stunted Forested/Shrub PSS4B 1.9 trees such as black spruce or pond pine. Wetland B—Seasonally Saturated: The substrate is saturated at or near the surface for extended periods during the growing season, but unsaturated conditions prevail by the end of the season in most years. Surface water is typically absent but may occur for a few days after heavy rain.

P—Palustrine: See above. UB—Unconsolidated Bottom: See above. Freshwater PUBF 23.4 Pond F—Semi-permanently Flooded: Surface water persists throughout the growing season in most years. When surface water is absent, the water table is usually at or very near the land surface.

R—Riverine: This type includes all wetlands and deepwater habitats contained within a channel, with the exception of wetlands dominated by trees, shrubs, persistent emergent, emergent mosses, or lichens. 3—Upper Perennial: This type is characterized by a high gradient. There is no tidal influence, and some water flows all year, except during years of extreme drought. The substrate consists of rock, cobbles, or gravel with Riverine R3UBH 37.3 occasional patches of sand. The natural dissolved oxygen concentration is normally near saturation. The fauna is characteristic of running water, and there are few or no planktonic forms. The gradient is high compared with that of the Lower Perennial Subsystem, and very little floodplain development exists. UB—Unconsolidated Bottom: See above. H—Permanently Flooded: See above.

Riverine R3USC 4.6 R—Riverine: See above.

McMillen Jacobs Associates 120 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Wetland Total Wetland Type Description Code Acres 3—Upper Perennial: See above. US—Unconsolidated Shore: See above. C—Seasonally Flooded: See above.

R—Riverine: See above. 4—Intermittent: This type includes channels that contain flowing water only part of the year. When the water is not flowing, it may remain in isolated pools or surface water may be absent. Riverine R4SBC 19.2 SB—Streambed: This type includes all wetlands contained within the Intermittent Subsystem of the Riverine System and all channels of the Estuarine System or of the Tidal Subsystem of the Riverine System that are completely dewatered at low tide. C—Seasonally Flooded: See above.

R—Riverine: See above. 5—Unknown Perennial: This type was created specifically for use when the distinction between lower perennial, Riverine R5UBH 13.3 upper perennial, and tidal cannot be made from aerial photography and no data is available. UB—Unconsolidated Bottom: See above. H—Permanently Flooded: See above.

McMillen Jacobs Associates 121 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 5-29. Location and Type of Wetlands in the Project Vicinity

McMillen Jacobs Associates 122 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

The Project vicinity features a variety of habitat types adjacent to Eklutna Lake and Eklutna River, each of which are characterized by different vegetation species composition and hydrologic regimes. These habitats provide important foraging grounds, nesting areas, and migratory corridor for a variety of wildlife species.

5.5.1 Floodplains Floodplains near the Project consist of the coastal marsh area that occurs at the mouth of the Eklutna River (USFWS, 2020). These areas are characterized by poorly drained, salt marsh and tide flat substrates with vegetation such as lyngbye sedge (Carex lyngbyei), maritime arrowgrass (Triglochin maritima), alkali grass (Puccinellia spp.), and plantain (Plantago major). Higher elevation areas may contain bluegrass (Poa spp.), silverweed (Argentina anserina), and bluejoint grass (Calamagrostis canadensis) (USACE, 2011).

5.5.2 Wetlands Wetland habitat near the Project consists of areas characterized by the presence of forested, shrub, and emergent vegetation. Black spruce (Picea mariana) bogs, with an understory of Labrador tea (Rhododendron groenlandicum), low bush cranberry (Vaccinium vitis-idaea), horsetail (Elocharis spp.), cloudberry (Rubus chamaemorus), and sphagnum moss (Sphagnum spp.) comprise most of the forested wetlands in the Project area, especially where poor drainage occurs. Black cottonwood (Populus balsamifera ssp. trichocarpa) and balsam poplar (Populus balsamifera) may also be present in spruce- dominated stands and tend to occur where alluvial soils are dominant (Marvin, 1986; USACE, 2011). Broad-leaved deciduous shrub vegetation such as willow (Salix spp.), sweet gale (Myrica gale), thin-leaf alder (Alnus incana), and dwarf birch (Betula nana) may be present in the understory of forested wetlands (USACE, 2011).

Shrub wetlands in the Project vicinity generally consist of shrubby black spruce (less than 20 feet tall) with a dense deciduous understory. Shrub wetlands lacking black spruce as a canopy species are typically comprised of willow, sweet gale, thin-leaf alder, dwarf birch, Labrador tea, bog blueberry (Vaccinium uliginosum), low bush cranberry, and bog rosemary (Andromeda polifolia). Sphagnum moss usually covers the saturated soils in these wetlands (USACE, 2011). Marvin (1986) described several highly calcareous bogs along the northwest margin of Eklutna lake that support a large number of plant species but lack black spruce, potentially due to the high substrate pH.

Wetlands in the Project vicinity characterized by emergent vegetation typically consist of grasses, sedges (Carex spp.), horsetail, and cottongrass (Eriophorum angustifolium), and may occur in the lower areas near shrub or forested wetlands. These wetlands may be permanently or seasonally flooded (USACE, 2011).

5.5.3 Riparian Habitat Riparian wetlands occur in temporarily flooded areas along rivers, creeks, and streams. In the Project vicinity, these wetlands occur along the Eklutna River and at the headwaters of Eklutna Lake (USFWS, 2020). Riparian vegetation depends on the duration and magnitude of flooding experienced, as well as elevation above the stream. Riparian vegetation is also subject to succession and may change over time as

McMillen Jacobs Associates 123 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package the river shifts and flooding events occur. Along the Eklutna River, riparian vegetation typically consists of a mixture of broad-leaved deciduous shrubs, such as willow and alder, with an understory of emergent vegetation such as grasses. Black spruce-dominated shrub wetlands may be found in seasonally flooded areas, along with willow and alder. Forested wetlands comprised of larger specimens of the aforementioned shrub species may also occur along the Eklutna River. Other riparian vegetation species that may occur in lower elevation, wetter areas include sweet gale, tufted clubrush (Trichophorum caespitosum), bladderworts (Utricularia spp.), cottongrass, buckbean (Menyanthes trifoliata), sundew (Drosera rotundifolia), livid sedge (C. livida), rotund sedge (C. rotundata), maritime arrowgrass, bog cranberry, bog blueberry, cloudberry, bog willow (S. pedicellaris), bog rosemary, and moss species (USACE, 2011).

5.5.4 Littoral Habitat Littoral habitat occurs on the edge of Eklutna lake, where wetland zones may contain plants that provide habitat and food for various wildlife species. Marvin (1986) noted that along much of the Eklutna Lake shoreline, the beaches are steep and wetland communities are lacking. However, NWI mapping revealed that freshwater forested/shrub wetlands occur along the northwest shore of the lake, near the dam (see the description of these wetland communities in Section 5.5.2 above). Wetlands may also occur at the southern end of the lake, where several creeks flow into Eklutna lake (USFWS 2020).

5.5.5 References Cowardin, Lewis M., Virginia Carter, Francis C. Golet, and Edward T. LaRoe. 1979. Classification of Wetlands and Deepwater Habitats of the United States. U.S. Fish and Wildlife Service Report No. FWS/OBS/-79/31.Washington, D.C.

Marvin, LuDean C. 1986. A Floristic Study of the Eklutna Valley. Master of Science Thesis, Department of Botany and Range Sciences, Brigham Young University. April 1986.

Native Village of Eklutna (NVE). 2014. Wetland Program Plan.

USACE (U.S. Army Corps of Engineers). 2011. Eklutna River Aquatic Ecosystem Technical Report. USACE Alaska District. November 2011.

USFWS (U.S. Fish and Wildlife Service). 2020. National Wetlands Inventory Wetland Mapper. U.S. Department of the Interior, Fish and Wildlife Service, Washington, D.C. Available at: https://www.fws.gov/wetlands/data/Mapper.html. Accessed February 11, 2020.

McMillen Jacobs Associates 124 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

5.6 Terrestrial Resources The Project lies in the Eklutna Valley, which features Eklutna Lake, the Eklutna River Canyon, and the delta area where the Eklutna River flows into the Knik Arm. The topography around these features includes a number of high peaks at the southern end, ranging from elevations of about 7,000 to 8,000 feet. Due to the wide range in elevation throughout the drainage area, diverse terrestrial habitat and a variety of plant and animal species are known to occur in the Project vicinity (Marvin, 1986; USACE, 2011).

5.6.1 Terrestrial Habitat Terrestrial habitats in the Eklutna watershed include high alpine zones, subalpine zones with varying substrate moisture and light exposure, and riparian and wetland areas associated with lakes, rivers, and river deltas. The diversity in elevation, light exposure, and moisture availability supports multiple vegetation community types, varying from high alpine tundra to alpine meadows, as well as mixed coniferous/deciduous forests and mixed deciduous forests in the subalpine zone and lower elevations. The habitat and foraging opportunities provided by these vegetation types supports a variety of avian species, small mammals, and land mammals.

5.6.2 Plant and Animal Species

5.6.2.1 Plant Species A floristic study of the Eklutna Valley conducted in 1986 described the plant communities of the watershed according to the following vegetation types: interior forest zone, subalpine zone, alpine zone, spruce bogs, and treeless bogs (Marvin, 1986). Spruce bogs and treeless bogs were described in Section 5.5 above. The remaining three vegetation types are described below.

The dominant vegetation of the interior forest zone includes mixed or pure stands of white spruce (Picea glauca), balsam poplar, black poplar, quaking aspen (Populus tremuloides), and paper birch (Betula papyrifera). Forest consisting of mixed spruce-birch species tend to occur in moist valley bottoms and along the north- to northeast-facing slopes of the west side of the Eklutna Valley. The understory associated with this forest type is generally species poor, but some woody shrub species and emergent vegetation are usually present. A mixed deciduous forest type dominated by birch, aspen, poplars, and an understory of immature white spruce is found in the interior forest zone along lower south- to southwest- facing slopes. A variety of shrub and emergent vegetation species are associated with this forest type (Marvin, 1986).

The subalpine zone with the Eklutna Valley covers a relatively narrow band of elevation range, from 2,500 to 3,000 feet. Within this zone, different vegetation communities are present based on sun exposure and substrate moisture. The vegetation communities found in moister areas of this zone are characterized by bluejoint meadows and thickets of Sitka alder (Alnus crispa). Drier areas are composed of more diverse vegetation, containing numerous herbaceous species and low shrubs, including willows, woody species, and emergent vegetation (Marvin, 1986).

The vegetation of the higher alpine zone is sometimes sparse or nonexistent, due to the harsh conditions found there, namely extremely cold temperatures and short growing seasons. Where vegetation exists, it

McMillen Jacobs Associates 125 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package is typically comprised of mat-forming species such as crowberry (Empetrum nigrum), bearberries (Arotostaphylos spp.), blueberry, moss heaths (Cassiope spp.), clubmosses (Lycopodium spp.), and luetkea (Leatkea pectinata). Some low thickets of willow and dwarf birch may also be present. The highest altitudes may contain no vegetation at all, or sparse tundra growth consisting of species such as black oxytrope (Oxytropis nigrescens), draba (Draba atenopetala), fleabane (Erigeron humilis), long- podded sandwort (Arenaria macrocarpa), reddish sandwort (Arenaria rubra), moss campion (Silene acaulis), arctic willow (Salix arctica), and leatherleaf saxifrage (Saxifraga bronchialis) (Marvin, 1986).

5.6.2.2 Wildlife Species Avian species and mammals reside in and utilize the terrestrial habitat in the Project vicinity. Both large and small mammals are found in the Eklutna watershed. Large mammals include moose, black bears, brown bears, Dall sheep, and infrequently, mountain goats. Moose use the Eklutna River delta as winter refuge habitat and display a preference for the willow saplings that grow in the wetlands there. Dozens of moose have been observed congregating in this area in the winter, and sometimes migrate long distances (from the Susitna River) to reach this area. Smaller mammals found in the Eklutna watershed include coyotes, muskrats, beavers, shrews, voles, mink, fox, porcupine, and short-tail weasel (USACE, 2011).

Figure 5-30. Moose and bear tracks, beaver dam, and porcupine in Eklutna basin (MJA, 2019)

McMillen Jacobs Associates 126 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Birds commonly observed in the area include the common raven, willow and rock ptarmigan, and spruce grouse. Waterfowl are found near the Project, although fish-eating species are uncommon due to the general scarcity of fish in Eklutna Lake. Bald eagles are also common in the vicinity and multiple nests were previously located in the terrestrial habitat surrounding the lower reaches of the Eklutna River. Sandhill cranes have been observed nesting in the Eklutna River delta area. The tidal areas of the Eklutna River delta also support some species of waterfowl including mallards, greenwing teal, and widgeon. It is likely that shorebirds such as sandpipers and yellowlegs also utilize the Eklutna River delta area. Passerine species including the American dipper, magpie, and black-capped chickadee may also use the habitat near the Eklutna River and Eklutna Lake (USACE, 2011).

No species listed as threatened or endangered under the Endangered Species Act (ESA) occur in the Project vicinity (USFWS, 2020). Several bird species that are listed on the USFWS Birds of Conservation Concern (BCC) list may occur in the Project area (Table 5-16). Of these species, the Olive-sided Flycatcher is a BCC-listed species that may nest in the Project vicinity during the late spring and summer months.

Table 5-16. Birds that may occur in the Project vicinity that are listed as Birds of Conservation Concern (BCC) (USFWS, 2020)

Breeding Common Name Scientific Name Breeding Location Season Lesser Yellowlegs Tringa flavipes n/a Breeds elsewhere Olive-sided Flycatcher Contopus cooperi May 20 – May breed in the Project vicinity; August 31 nests high in evergreen trees near openings and edges in coniferous forests Semipalmated Sandpiper Calidris pusilla n/a Breeds elsewhere

5.6.3 References Marvin, LuDean C. 1986. A Floristic Study of the Eklutna Valley. Master of Science Thesis, Department of Botany and Range Sciences, Brigham Young University. April 1986.

MJA (McMillen Jacobs Associates). 2019. Eklutna River Site Reconnaissance Technical Memorandum.

USACE (U.S. Army Corps of Engineers). 2011. Eklutna River Aquatic Ecosystem Technical Report. USACE Alaska District. November 2011.

USFWS (U.S. Fish and Wildlife Service). 2020. IPaC Resource List. Available online at: https://ecos.fws.gov/ipac/. Accessed February 13, 2020.

McMillen Jacobs Associates 127 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

5.7 Land Ownership and Management Land ownership in the Project area is shown in Figures 5-31 and 5-32. A majority of the land adjacent to Eklutna River and Eklutna Lake is owned by Eklutna, Inc. Other landowners include the State of Alaska and U.S. Bureau of Land Management (BLM). Lands adjacent to the Eklutna River and Eklutna Lake are generally managed as part of Chugach State Park (managed by ADNR), the Eklutna Lake Management Area (managed by ADFG), and/or the Eklutna River Estuary Conservation Easement (managed by the Great Land Trust).

5.7.1 Chugach State Park All of the lands in the upper watershed of the Eklutna River are located within Chugach State Park. The park contains approximately 495,000 acres of land and is one of the four largest state parks in the United States. The five primary purposes for establishing Chugach State Park were:

▪ To protect and supply a satisfactory water supply for the use of the people. ▪ To provide recreational opportunities for the people by providing areas for specified uses and constructing the necessary facilities in those areas. ▪ To protect areas of unique and exceptional scenic value. ▪ To provide areas for the public display of local wildlife. ▪ To protect the existing wilderness characteristics of the easterly interior area.

The park’s westernmost boundary lies in the western foothills of the Chugach Mountain Range and is a mere seven miles to the east of downtown Anchorage. As the population of Anchorage and surrounding communities continues to grow, visitor counts indicate increasing use of the park. This use is increasing resource degradation, stressing park facilities and crowding established access points (ADNR, 2016).

5.7.1.1 Management Goals and Objectives Management responsibility for the park is assigned to ADNR for control, development and maintenance. The Chugach State Park Management Plan is the basis for the management and development of the state- owned land and water within the legislatively designated boundary of the park as well as for areas managed by the park under special agreement. The management goals and objectives for Chugach State Park are outlined below (ADNR, 2016).

Recreation Goal: Provide recreational opportunities and complimentary facilities to keep pace with the needs and diversity of Alaskans and visitors. ▪ Provide a variety of recreation facilities and opportunities equitably distributed for all capabilities. ▪ Foster community health by promoting outdoor exercise through the wise development and maintenance of trails and facilities that link the community with the park. ▪ Design and construct sustainable park facilities that are appropriate to the park setting and enrich the park experience.

McMillen Jacobs Associates 128 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 5-31. Land Ownership adjacent to Eklutna River

McMillen Jacobs Associates 129 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 5-32. Land ownership adjacent to Eklutna Lake

McMillen Jacobs Associates 130 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Resource Goal: Protect park resources to allow for diverse visitor experiences and the understanding of the unique features of Chugach State Park. ▪ Protect and encourage a better understanding of the park’s natural and cultural features. ▪ Protect and provide for a satisfactory water supply. ▪ Protect areas of unique and exceptional scenic value, existing wildlife habitat and encourage opportunities for wildlife viewing throughout the park. ▪ Minimize the impact of human presence and promote “leave no trace” principles, particularly in fragile and wilderness areas. ▪ Develop criteria for using land acquisitions, land trades, and management agreements to maintain the park’s integrity, natural values and processes and to expand the potential for outdoor recreation.

Access Goal: Enhance and secure public access to Chugach State Park for the benefit of all Alaskans and visitors. ▪ Designate a variety of well-defined access points along the park’s perimeter and provide appropriate facilities. ▪ Enhance the visitor experience through management of access points and promoting of access etiquette to ensure that there is a balance between the demand for an area and its capacity (ADNR, 2016).

However, ADNR Division of Parks and Outdoor Recreation’s budget has not kept pace with inflation. Increased use threatens to damage park resources and challenges the Division’s ability to sustain facilities and programs at acceptable levels. This trend is especially noticeable in parks that border large population centers like Chugach State Park that once had thirteen rangers on staff managing public safety and park resources and now only has four. Chugach State Park has the largest deferred maintenance backlog of any single park within the Division with approximately $7 million needed to address facility upkeep (ADNR, 2016).

5.7.1.2 North Anchorage Land Agreement Although most of the lands around Eklutna Lake are owned by Eklutna, Inc., the lands are managed by the State in accordance with the North Anchorage Land Agreement (NALA). NALA gave the State management authority in perpetuity to 27,000 acres of Eklutna, Inc. owned lands within the park boundary in exchange for sharing in the military development lands in the future. These lands are to be managed as part of the park and in the same manner as other park lands are managed (ADNR, 2016).

5.7.1.3 Land Use Designations The lands within the park have been classified using three different land use designations to define their long-term management direction. Those land use designations are 1) Recreational Development, 2) Natural, and 3) Wilderness. Figure 5-33 depicts the land use designations within the park. The Project area is located within both Recreational Development and Natural land use designations. These land use designations are described below (ADNR, 2016).

McMillen Jacobs Associates 131 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Recreation Development – Recreation development zones are established to meet the more intensive recreational needs of the public by providing easy and well-defined access points into the park, and by developing appropriate facilities. In the Project vicinity, this designation applies to areas adjacent to the Eklutna Lake Road and the developed areas adjacent to Eklutna Lake.

Natural – Natural environment zones are established to provide for moderate-to-low impact and dispersed forms of recreation and to act as buffers between the recreation development areas and the wilderness areas. Natural environment zones have high scenic qualities and are intended to provide an intrinsic natural outdoor setting for visitors to recreate. This designation applies to large areas between the recreation development and wilderness zones in all of the units of the park.

The Chugach State Park Management Plan also provides specific guidelines regarding fisheries restoration and fisheries enhancement actions within each land use designation as described below.

▪ Fisheries restoration is defined as actions taken to restore native fish access to spawning and rearing habitat or actions taken to restore population to historical levels. This may include fish ladders, fish passages, and fish stocking. Fisheries restoration actions may be authorized in limited circumstances in conjunction with ADFG in both Recreation Development and Natural land use designations.

▪ Fisheries enhancement is defined as action taken to increase fishery stocks above historical levels, such as building fish passages and artificially incubating or stocking fish in streams. Fisheries enhancement may be authorized in both Recreation Development and Natural land use designations only if it enhances recreation (ADNR, 2016).

Figure 5-33. Chugach State Park Land Use Designations (ADNR, 2016)

McMillen Jacobs Associates 132 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

5.7.1.4 Eklutna-Peters Creek Planning Unit Due to Chugach State Park’s large size and landscape diversity, the area has been divided into five geographical planning units to facilitate planning and management. The Project area is located within the Eklutna-Peters Creek Planning Unit. This northernmost area of the park contains approximately 193,100 acres and is composed of three major drainages including the Eklutna River and Thunderbird Creek watersheds. The valleys and towering mountains of this unit provide a striking visual setting for recreation enthusiasts (ANDR, 2016). The management intent of this unit includes:

▪ Protecting its watershed properties and drinking water sources. ▪ Protecting its scenic qualities and enhancing its diverse recreational opportunities. ▪ Increasing public understanding and appreciation through the interpretation of unique natural and cultural features. ▪ Maintaining the wildlife viewing area in the Eklutna Basin.

Watershed Management One of the reasons for establishing Chugach State Park was to protect and provide a satisfactory water supply for the use of the people of the State of Alaska. Eklutna Lake is the major source of drinking water for residents of the Municipality of Anchorage (MOA). Anchorage Water and Wastewater Utility (AWWU), the utility that manages the drinking water supply for the MOA, has a cooperative agreement with the park to facilitate management and protection of the important watersheds within the park that provide the bulk of the MOA water supply. Under this agreement, ADNR is required to manage the Eklutna watershed with watershed protection as the highest land and water resource management goal. Any development or other activities within the park shall be conducted in accordance with this cooperative agreement (ADNR, 2016).

Fish & Wildlife Management Another reason for establishing Chugach State Park was to provide areas for the public display of local wildlife. In a letter to USBR in 1948, the USFWS stated that the Eklutna Lake area “affords some of the most beautiful scenery and natural game habitat to be found anywhere in Alaska” (USBR, 1948). However, fish and wildlife management can be challenging within the park due to its proximity to Alaska’s largest population center, the heavy use the park receives, and the diverse understanding of wildlife behavior by park users (ADNR, 2016).

Negative wildlife-human interactions, while not common within the park, is a public safety concern as visitors seek to view wildlife and use park resources for recreational pursuits. At least half of the 12 people injured or killed by bears in Chugach State Park since its establishment were within 100 yards of salmon spawning streams. Salmon-spawning streams represent a minute portion of the entire park. However, the odds of surprising a brown bear near a salmon-spawning stream are relatively high. Temporary closures, signage, and other measures may be employed as needed to help protect public safety during certain times or in areas that are prone to increased wildlife activities that could lead to negative interactions with humans (ADNR, 2016).

McMillen Jacobs Associates 133 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Recognizing the desire for park users to view fish and wildlife, the park has had to react by building facilities commensurate with the demand and appropriate to the setting. This is especially evident in areas of the park such as Bird Creek where ADFG enhances the fishery through their stocking program. As a result, fishing has become popular and the potential for bear-human interaction has increased. In order to protect park resources from heavy use, facilities have had to be developed to help appropriately accommodate public use (ADNR, 2016).

Most visitors seem to be aware of the potential threats that come with recreating alongside wildlife, and the possibility of encountering bear or moose has not prevented the overwhelming majority of residents from using the parks and trails (ADNR, 2016).

Sport Fishery Enhancement ADFG stocked Eklutna Lake with excess rainbow trout fingerlings from 1987 through 1997 but stopped stocking the lake because of low catch rates and limited angler participation (USACE, 2011). Chum and coho salmon were each stocked once in 1992 and 1996 respectively (ADNR, 2016). ADFG is not currently stocking Eklutna Lake and has no plans to stock the lake in the future.

5.7.2 Eklutna Lake Management Area ADFG regulates hunting and trapping activities in the Project area. These regulations are summarized in Table 5-17. Most of the Eklutna drainage is within the Eklutna Lake Management Area (as shown in Figure 5-34) which closes the area to all hunting except by bow and arrow. The taking of moose, brown bear and sheep requires a permit, and the taking of black and brown bears requires completion of a hunter safety course. The Eklutna Lake Management Area is currently closed to trapping (ADFG, n.d.).

Table 5-17. Hunting regulations for the Eklutna Lake Management Area (ADFG, n.d.)

Game Permit Required Methods Season Small Game No Bow and arrow, falconry September 1 – April 30 Black Bear No, must complete a Bow and arrow September 1 – May 31 hunter safety course Brown Bear Yes, must complete a Bow and arrow September 1 – May 31 hunter safety course Sheep Yes Bow and arrow September 1 – October 31 Moose Yes Bow and arrow All year

McMillen Jacobs Associates 134 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 5-34. Eklutna Lake Management Area (ADFG, n.d.)

5.7.3 Eklutna River Estuary Conservation Easement In 2012 Eklutna, Inc., in partnership with the Great Land Trust (GLT), completed the Fire Creek and Eklutna River conservation easements covering eight miles of coastline totaling 1,355 acres (Figure 5- 35). The establishment of these conservation easements resulted in a 35-mile long wildlife corridor of nearly continuous protected lands, mostly wetlands, bordering upper Knik Arm, from Palmer Hay Flats State Game Refuge, past Eklutna, and on to Fire Creek near Beach Lake. The lands protected by the Eklutna River Estuary Conservation Easement remain under Eklutna, Inc. ownership, and traditional uses such as subsistence fishing and hunting by shareholders continue under GLT conservation easements management (NVE, 2014).

McMillen Jacobs Associates 135 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 5-35. Conservation Easements (NVE, 2014)

5.7.4 References ADFG. n.d. Unit 14C Eklutna Lake Management Area Map.

ADNR (Alaska Department of Natural Resources) Department of Parks and Outdoor Recreation. 2016. Chugach State Park Management Plan. February 2016.

USACE (U.S. Army Corps of Engineers). 2011. Eklutna River Aquatic Ecosystem Technical Report. USACE Alaska District. November 2011.

MOA (Municipality of Anchorage). n.d. Property Information. Web App Viewer. https://muniorg.maps.arcgis.com/apps/webappviewer/index.html?id=493d6c82574c43d981bd2aa a384b3d60.

NVE (Native Village of Eklutna). 2014. Wetland Program Plan.

McMillen Jacobs Associates 136 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

5.8 Recreational Use and Facilities

5.8.1 Eklutna Valley The Eklutna Valley is one of the heavily used areas of Chugach State Park and is known for its scenic qualities and diverse recreational opportunities. Summer visitors enjoy hiking, biking, horseback riding, climbing, picnicking, hunting, fishing, boating, and riding ATV's. Winter activities include cross-country skiing, dog mushing, and snowmobiling. Camping, wildlife viewing, and photography may be enjoyed in any season (ADNR, n.d).

Eklutna Lake Campground, the main campground in the area, is located at the north end of the lake (Figure 5-36). It includes 50 campsites, water, latrines, picnic tables and fire pits. An overflow camping area has an additional 15 campsites. There is a Day Use Area with a picnic shelter for group activities, as well as a large group picnic and camping area. The Dolly Varden Public Use Cabin is located near the Day Use Area, and the Rainbow Trout Public Use Cabin is located just south of the Dolly Varden Cabin near Eklutna Lake Dam (ADNR, n.d.).

Figure 5-36. Existing recreational facilities at the north end of Eklutna Lake (ADNR, n.d.)

McMillen Jacobs Associates 137 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Eklutna Lake is the park’s largest lake. Non-motorized boats and boats powered by an electric motor are allowed on the lake. However, alternating water levels (often exposing extensive mud flats) and frequent strong winds can make boating difficult. Although the surface freezes in winter, fluctuating water levels create variations in ice thickness and cause surface irregularities which can result in unsafe ice conditions. Down-canyon winds can rise in the basin with little notice and often have sufficient force to create white- capped waves on the lake. To the unprepared boater, they can represent a hazardous situation (ADNR, 2016).

There are several hiking trails and routes around Eklutna Lake including the Twin Peaks Trail and the Eklutna Lakeside Trail which consists of an old roadbed constructed by the army in the 1960s and some adjacent foot trails. It follows the northeast side of the lake and leads to the west fork of Eklutna Creek and then to the Eklutna Glacier. However, because the glacier has receded, it is more difficult now to reach the trail’s terminus. Summer off-road vehicles are allowed during certain times on the Eklutna Lakeside Trail, and snowmobiles are allowed in the lake area when snow conditions are adequate to protect the underlying vegetation (ADNR, 2016). Park staff and members of the public have expressed concern regarding erosion of the lakeside trail caused by high lake levels, as well as potential impacts to other existing park infrastructure such as culverts, bridges, signs, and access to Yuditnu Creek Public Use Cabin discussed below (Hensel personal communication). Figure 5-37 below shows erosion of the trail on September 27, 2019. The lake level elevation at this time was 780.85 (within 1 inch of the spillway crest).

Figure 5-37. Erosion of Lakeside Trail, September 27, 2019 (Photo taken by Rick Sinnott)

Lifetime Adventures operates a rental facility at the north end of the lake near the lakeside trailhead. They offer both bike and kayak rentals as well as guided tours of the Eklutna Valley area. Bold Airstrip is located at the south end of the lake. Aircraft are allowed to use the airstrip except for the purpose of practice landings (Lifetime Adventures, n.d.). Three smaller more primitive campgrounds are located at

McMillen Jacobs Associates 138 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package the south end of the lake. The Yuditnu Creek Public Use Cabin is located midway along the lakeside trail and the Serenity Falls Public Use Hut exists nearer the terminus of the trail and is one of a series of mountaineering huts along the historical Eklutna Traverse. The Kokanee Public Use Cabin is located on the southern side of the lake (ADNR, 2016). Existing and proposed recreational facilities around Eklutna Lake are shown in Figures 5-38 and 5-39 below.

Figure 5-38. Existing recreational facilities around Eklutna Lake (ADNR, 2009)

McMillen Jacobs Associates 139 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 5-39. Proposed recreational facilities around Eklutna Lake (ADNR, 2016)

The Thunderbird Creek drainage receives very heavy use due to the popular Thunderbird Falls Trail located just off the Glenn Highway. A parking lot and a one-mile trail lead to the Eklutna River Gorge overlook and the Thunderbird Falls overlook. Few people continue beyond the falls overlook due to rough terrain (ANDR, 2016).

5.8.2 Eklutna Tailrace Day-Use Fishing Access Site There is a recreational fishery in the Project tailrace. Figure 5-40 shows angler days of fishing effort at the Eklutna tailrace from 1984 to 2017. In 1998 ADFG began stocking the tailrace annually with coho salmon smolts. Figure 5-41 shows the sport harvest of coho and sockeye at the Eklutna tailrace from 1984 to 2017. In 2002 they also started stocking chinook salmon smolts, which has provided a very popular chinook salmon fishery since 2003. Figure 5-42 shows the sport fish harvest of Chinook at the Eklutna tailrace from 2003 to 2017. Salmon originating from the drainages of the Knik and Matanuska rivers are also harvested at the confluence of the tailrace and the Knik River.

McMillen Jacobs Associates 140 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Angler Days at Eklutna Tailrace 25000

20000

15000

10000

5000

0 1984 1986 1988 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010 2012 2014 2016

Figure 5-40. Angler Days at Eklutna Tailrace (ADFG, 2017)

Sport Harvest of Coho and Sockeye at Eklutna Tailrace

8000

7000

6000

5000

4000

3000

2000

1000

0 1984 1986 1988 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010 2012 2014 2016

Coho Sockeye

Figure 5-41. Sport Harvest of Coho and Sockeye at Eklutna Tailrace (ADFG, 2017)

McMillen Jacobs Associates 141 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Sport Harvest of Chinook at Eklutna Tailrace 1600

1400

1200

1000

800

600

400

200

0 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

Figure 5-42. Sport Harvest of Chinook at Eklutna Tailrace (ADFG, 2017)

Facilities at the tailrace include ADA accessible trails, fishing pads, a bridge that provides access to both sides of the tailrace, toilet screens and improved refuse receptacles (Figure 5-43) (ADFG, 2020). ADFG currently provides dumpster pick-up, a fish cleaning table, vault latrines, and contracts out for patrols and litter pick-up. Sport fishing for chinook salmon at the tailrace continues to be a very popular recreational fishery for local residents, and a youth only fishery takes place each year in June (ADFG, 2019).

Figure 5-43. ADA Assessible Fishing Pads and Bridge at the Eklutna Tailrace (ADFG, 2020)

McMillen Jacobs Associates 142 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

5.8.3 References ADFG (Alaska Department of Fish and Game) Division of Sport Fish. 2019. Region II: Statewide Stocking Plan for Sport Fish 2019 – 2013, 2019 UPDATE.

ADFG. 2020. Southcentral Recreational Angler Access Projects: Eklutna Tailrace. http://www.adfg.alaska.gov/index.cfm?adfg=fishingSportAnglerAccessSouthcentral.eklutna. Accessed on February 21, 2020.

ADNR (Alaska Department of Natural Resources) Department of Parks and Outdoor Recreation. 2016. Chugach State Park Management Plan. February 2016.

ADNR Department of Parks and Outdoor Recreation. n.d. Chugach State Park. http://dnr.alaska.gov/parks/aspunits/chugach/chugachindex.htm.

Lifetime Adventures. n.d. Eklutna Trips and Rentals. http://www.lifetimeadventure.net/eklutna-trips- rentals/.

McMillen Jacobs Associates 143 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

5.9 Cultural Resources According to the Alaska Heritage Resources Survey (AHRS) data repository, at least 30 to 40 sites have been recorded in the general area of Eklutna. These are predominantly historic period sites in the vicinity of the Native Village of Eklutna or sites associated with hydropower operations. Three Eklutna-area sites are listed on the National Register of Historic Places (NRHP). In addition, the trail system that traverses the Eklutna area is part of the Iditarod National Historic Trail, designated in 1978 (BLM, n.d.).

5.9.1 National Register of Historic Properties Sites Three properties in the Eklutna area are listed on NRHP, as described below.

5.9.1.1 Old Eklutna Power Plant The Old Eklutna Power Plant (Figure 5-44) provided the first hydroelectric power to Anchorage beginning in 1929, and served that purpose until 1956, when it was replaced by a newer facility that could help meet the city’s growing electrical demands (AHRS, n.d.; AHRS Number ANC-00118). Associated facilities included a diversion dam (ANC-01973, removed in 2017 [Eklutna, Inc., n.d.]), storage dam, tunnel (ANC-01991, now collapsed), tailrace (ANC-01993), and penstock (ANC-01992). The power plant structure, with reinforced concrete walls and a steel truss roof, was still being used by the Matanuska Electric Association in 1980 (ANC-00118) (AHRS, n.d.). The Eklutna Power Plant was listed on the NRHP in 1980 (NPS, 1980a).

Figure 5-44. Old Eklutna Power Plant, 1977 (NPS, 1980a)

McMillen Jacobs Associates 144 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

5.9.1.2 Old St. Nicholas Russian Orthodox Church Old St. Nicholas Russian Orthodox Church in the Village of Eklutna was listed on the NRHP in 1972 (NPS, 1972; 1980b). Believed to have been built about 1870 or earlier, the outside of the church is constructed from hand-hewn spruce logs and includes an enclosed porch with a Greek cross above (Figure 5-45). The church is “the physical manifestation of the influence of the Russian Orthodox Church on the lives of the Dena’ina in the area. The structure is a symbol of the historical activity of the Russian Orthodox Church in Alaska” (AHRS, n.d.; AHRS Number ANC-00004). The church was moved from the town of Knik to its present location prior to 1899, restored in 1977 (AHRS, n.d.; AHRS Number ANC-00004), and is now part of the Eklutna Historic Park. The park includes a new church built in 1962 (Eklutna Historic Park, n.d.) as well as grave sites, some with spirit houses (ANC-0047).

Figure 5-45. Old St. Nicholas Russian Orthodox Church in Eklutna, 1990 (HABS, 1990)

5.9.1.3 Mike Alex Cabin The Mike Alex Cabin (Figure 5-46) is located near the old and new Russian Orthodox churches in the Village of Eklutna. Mike Alex (1907 – 1977), the “last of a long line of traditional Dena’ina Chiefs” (AHRS, n.d.; AHRS Number ANC-00294), built the cabin in the 1920s.3 The son of “Eklutna Alex” (Leggett, n.d.; Mielke, n.d.), Mike Alex “was an important source of continuity in a time of extremely rapid change for the people of Eklutna, linking the traditional past with the adaptation to contemporary life styles. He was a devout layman of the Russian Orthodox Church and was the moving force behind the building of a new church and the preservation of the old church” (AHRS, n.d.; AHRS Number ANC-

3 AHRS data repository information states that the cabin was built in 1928. The NRHP Nomination Form states that the cabin was built in 1925.

McMillen Jacobs Associates 145 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

00294). In addition, Mike Alex was active in attempting to stem the migration of tribal members away from his village and in developing an economic tool to assist in its survival (McCollom, 1971; Kari and Fall, 2003). The cabin, which “represents the only extant, authentic Athabaskan cabin” (AHRS, n.d.; AHRS Number ANC-00294), was listed on the National Register in 19824 (NPS, 1982).

Figure 5-46. Mike Alex Cabin (NPS, 1982)

5.9.2 Historic Sites Table 5-18 lists historic sites in the Eklutna area based on information available in the AHRS data repository.

Table 5-18. Historic Sites

AHRS Description Number ANC-00004 Old St. Nicholas Russian Orthodox Church – See Section 5.9.1. ANC-00080 Eklutna River Railroad Bridge – The railroad bridge, built in 1927, consists of one 80- foot through-girder mounted on concrete abutments; located approximately 1 mile from the Native Village of Eklutna. ANC-00091 Eklutna Railroad Station – A 2-story dwelling and a water station are reported to have been constructed here in the early 1940s, located north of the Native Village of Eklutna. ANC-00118 Eklutna Power Plant – See Section 5.9.1.

4 The NRHP Nomination Form lists the AHRS site number as ANC-111.

McMillen Jacobs Associates 146 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

AHRS Description Number ANC-00275 A.C. Warehouse – An Alaska Central Railroad map dated November 1906 identifies the A.C. warehouse and George Palmer’s homestead adjacent to the warehouse on the shoreline north of the Native Village of Eklutna. AHRS information indicates that the site was probably associated with the Iditarod Trail. ANC-00276 Watson’s Roadhouse – A 1914 Alaska Engineering Commission map showing the preliminary route for the Alaska Railroad identifies two buildings at this location on the shoreline north of the Native Village of Eklutna. AHRS information indicates that the site was probably associated with the Iditarod Trail. ANC-00294 Mike Alex Cabin – See Section 5.9.1. ANC-00436 Old Knik Indian Village – An 1899 map shows this village site on the south bank of the Knik River. ANC-00437 Eklutna grave sites – See Section 5.9.1. ANC-00757 F. Hunt Cabin – A 1914 survey map shows land and structures belonging to Hunt along the shore of Knik Arm. The cabin is thought to have eroded into the water. ANC-00829 Spillway – This poured concrete structure was built in 1965 and is associated with the Eklutna Hydroelectric Project. ANC-00832 Eklutna Power Line, Reed to Anchorage – This 1950s-era section of power line is approximately 26 miles long and is associated with the Eklutna Hydroelectric Project. ANC-00907 FAA Radio Transmission Facility – The remains of this facility are located at the top of a small hill overlooking Knik Arm. This structure was associated with an Alaska-wide communications network that provided navigational and weather information to aircraft in the 1940s to 1970s. ANC-01162 Residence complex – This site consists of a 3-room house, surrounding activity areas, cache pits, and a larger storage pit located within the bounds of the Native Village of Eklutna. It may be associated with ANC-00852. ANC-01948 Eklutna Army site – The site, located just west of the Native Village of Eklutna, included a Quonset hut and Bureau of Indian Affairs (BIA) industrial school buildings. The site was determined not eligible for listing on the NRHP. ANC-01973 Eklutna Diversion Dam – See Section 5.9.1. ANC-01975 Conduit – The 1950’s-era conduit, repaired in 1965 after an earthquake, is part of the Power Tunnel Complex (ANC-01982) associated with the Eklutna Hydroelectric Project. The conduit consists of about 120 feet of precast concrete. ANC-01976 Power tunnel – The tunnel, extending underground for about 4.4 miles between Eklutna Lake and the Eklutna Hydroelectric Project powerhouse, dates to the 1950s. ANC-01977 Tunnel gate shaft – The tunnel gate shaft is a component of the power tunnel complex (ANC-01982) of the Eklutna Hydroelectric Project and was constructed in the 1950s. ANC-01980 Tailrace – Rebuilt after the 1964 earthquake, the tailrace in a concrete conduit that carries water from the Eklutna Hydroelectric Project power plant under the Old Glenn Highway to the tailrace channel. ANC-01982 Power tunnel complex – The complex consists of multiple structures that deliver water from Eklutna Lake to the Eklutna Hydroelectric Project power plant. Much of the complex remains unaltered since construction in the 1950s. ANC-01991 Eklutna power plant tunnel – See Section 5.9.1. ANC-01992 Eklutna power plant penstock – See Section 5.9.1.

McMillen Jacobs Associates 147 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

AHRS Description Number ANC-01993 Eklutna power plant tailrace – See Section 5.9.1. ANC-03419 Old Glenn Highway (Segment D, Glenn Highway junction to Palmer) – This approximately 18-mile-long stretch of highway was determined not eligible for listing on the NRHP. ANC-03653 Telegraph – telephone pole remains – This resource consists of 18 pole stumps and associated wire with an estimated date range of 1920 to 1945. A portion of the line has been determined not eligible for NRHP listing but the entire line has not been evaluated. ANC-03739 Collapsed building – This semi-subterranean building may be associated with the railroad and has wood skids made from railroad ties. ANC-04061 Grave marker – The wooden marker is located in the Native Village of Eklutna near the power line right-of-way, and dates to 1928. ANC-04068 Glenn Highway – The highway is approximately 180 miles long and dates from the 1920s to the present. It has been determined to be part of the Interstate Highway System and exempt from Section 106 review. ANC-04346 Old Glenn Highway (Segment C, Thunderbird Falls) –This segment of the highway provides access to the Thunderbird Falls trail parking lot and Eklutna Lake Road. Determined not eligible for listing on the NRHP.

5.9.2.1 Iditarod Trail The Iditarod Trail was once “an important artery of Alaska’s winter commerce, [and] served a string of mining camps, trading posts, and other settlements founded between 1880 and 1920, during Alaska’s Gold Rush Era” (King, n.d.). In many places the Iditarod Trail followed pre-existing Dena’ina and other Alaska Native trails. Roadhouses served travelers along the trail with various levels of accommodation and became mainstays as stops on the mail contractor’s run. From 1914 to 1918, “Colonel” Harry Revell “operated a winter mail service connecting Seward, Sunrise, Girdwood, Eklutna, Knik, and Susitna Station” (King, n.d.). After the mail runs ended, roadhouses began closing, and use of the trail further declined with the eventual development of the Alaska Railroad and use of airplanes.

5.9.2.2 Hydroelectric Facilities At the time of the APA divestiture of the Eklutna Hydroelectric Project in 1996, APA evaluated the 1950s-era and post-1964-era Eklutna hydroelectric facilities. APA determined that the Project was eligible for listing on the NRHP under Criterion A (i.e., Association with Events that have made a Significant Contribution to the Broad Patterns of our Past), and that divestiture could constitute an adverse effect to a historic property. A Mitigation Plan was prepared (Woodward Clyde, 1996), which defined appropriate treatment to avoid adverse effects of the transfer: (1) documentation of the Project features that reflect its significance, and (2) preservation and archiving of photographs, drawings, and plans that reflect the construction and operation of the Project throughout its period of federal ownership and operation. These appropriate treatments were formalized in a Memorandum of Agreement between APA and the Alaska Historic Preservation Officer (ACHP, 1996).

McMillen Jacobs Associates 148 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

5.9.3 Prehistoric Sites There are several known prehistoric sites in the general Project area. However, due to the sensitive nature of this information, and at the request of the NVE, information regarding these prehistoric sites has not been included in this public document.

5.9.4 References ACHP (Advisory Council on Historic Preservation). 1996. Memorandum of Agreement regarding the Transfer of Ownership of the Eklutna Hydroelectric Project, AK. October 10, 1996.

AHRS (Alaska Heritage Resources Survey). n.d. Data Repository. Office of History and Archaeology, Alaska Department of Natural Resources. http://dnr.alaska.gov/parks/oha/ahrs/ahrs.htm.

Alaska Power Administration. 1992. Environmental Assessment, Submittal of a Legislative Proposal to Congress for the Sales of the Eklutna and the Snettisham Projects. March 1992.

BLM (Bureau of Land Management). n.d. Iditarod National Historic Trail. U.S. Department of the Interior. https://www.blm.gov/programs/national-conservation-lands/national-scenic-and-historic- trails/iditarod.

Chandonnet, Ann. 1979. The Once & Future Village of Ikluat/Eklutna (A History of a Tanaina Athapaskan Settlement). Chicago: Adams Press.

Chandonnet, Ann. 1991. On the Trail of Eklutna. Chicago: Adams Press.

CIRI (Cook Inlet Region, Inc.). n.d. Website: https://www.ciri.com/. Accessed February 2020.

Cook Inlet Historical Society, n.d. Anchorage History. https://www.cookinlethistory.org/anchorage- history.html.

De Laguna, Frederica. 1934. The Archaeology of Cook Inlet, Alaska. University of Pennsylvania Press.

Dumond, D.E. and Robert L.A. Mace. 1968. An Archaeological Survey along Knik Arm. Anthropological Papers of the University of Alaska, Volume 14, Number 1. https://www.uaf.edu/apua/files/Dumond1968.pdf.

Eklutna Historic Park. Website: https://www.eklutnahistoricalpark.org/. Accessed February 2020.

Eklutna, Inc. n.d. Eklutna Dam Removal and Diversion Project. https://www.eklutnainc.com/eklutna- dam-project/. Accessed February 2020.

Fall, James A. 1981. Traditional Resource Uses in the Knik Arm Area: Historical and Contemporary Patterns. Alaska Department of Fish and Game, Division of Subsistence. Technical Paper Number 25. December 2, 1981.

Fall, James A. 1987. The Upper Inlet Tanaina, Patterns of Leadership Among an Alaska Athabaskan People, 1741 – 1918. Anthropological Papers of the University of Alaska 21.

McMillen Jacobs Associates 149 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Fall, J.A., R.T. Stanek, B. Davis, L. Williams, and R. Walker. 2004. Cook lnlet Customary and Traditional Subsistence Fisheries Assessment. Alaska Department of Fish and Game, Division of Subsistence. Technical Paper No. 285. July 30, 2004.

CEMML. 2010. Annual Report: Cultural Resources Survey, Fort Richardson, Alaska 2009. Center for Environmental Management of Military Lands, Colorado State University, Ft. Collins, Colorado.

HABS (Historic American Buildings Survey). 1990. Shrine to the Theotokos and Old Church, Looking Southeast – St. Nicholas Russian Orthodox Churches, Eklutna, Anchorage, AK. Library of Congress. https://www.loc.gov/pictures/item/ak0312.photos.033275p/.

Kari, J., A. Boraas, A. Leggett, and R.G. Dixon. 2012. Bibliography of Sources on Dena’ina and Cook Inlet Anthropology. Version 3.1. http://qenaga.org/denaina-bibliography-version-3-1-g.pdf.

Kari, James and James A. Fall. 2003. Shem Pete’s Alaska, The Territory of the Upper Cook Inlet Dena’ina. Fairbanks: University of Alaska Press. Second Edition.

BLM. n.d. Iditarod National Historic Trail, Historic Overview. U.S. Department of the Interior, Bureau of Land Management.

Leggett, Aaron. n.d. Bel K'ikghil'ishen (Eklutna Alex). Cook Inlet Historical Society, Legends & Legacies, Anchorage, 1910-1940. https://www.alaskahistory.org/biographies/bel-kikghilishen- eklutna-alex/.

Lobdell, John E. 1984. An Archaeological Assessment of the Eklutna Water Project, Phase II: Staging Areas, Material Sources, and Route Modifications. Municipality of Anchorage Water and Wastewater Utility.

McCollom, Pat. 1971. Will Eklutna Survive? Alaska magazine. July 1971.

Mielke, Coleen. n.d. The Alex Family of Eklutna Village, Alaska. RootsWeb. http://freepages.rootsweb.com/~coleen/genealogy/alex.html.

Native Village of Eklutna. n.d. Website: https://eklutna-nsn.gov/. Accessed February 2020.

NHG (NHG Alaska, LLC). 2012. Phase I Cultural Resource Assessment of Bryant Army Airfield. Prepared for Alaska Army National Guard. October 2012. https://aws.state.ak.us/OnlinePublicNotices/Notices/Attachment.aspx?id=89759.

NPS (National Park Service). 1972. Old St. Nicholas Russian Orthodox Church. National Register of Historic Places.

NPS (National Park Service). 1980a. Eklutna Power Plant. National Register of Historic Places. Photos: https://npgallery.nps.gov/GetAsset/a8840b12-5761-4f19-94cc-e6a2e1e36d9d/.

NPS (National Park Service). 1980b. Russian Orthodox Church Buildings and Sites in Alaska. National Register of Historic Places.

McMillen Jacobs Associates 150 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

NPS (National Park Service). 1982. Mike Alex Cabin. National Register of Historic Places. Photos: https://npgallery.nps.gov/GetAsset/9c05ae4a-795f-4044-bed6-748bd13bebcf.

Reger, Douglas R. 1998. Archaeology of the Northern Kenai Peninsula and Upper Cook Inlet. Arctic Anthropology, Volume 35, No. 1, North Pacific and Bering Sea. University of Wisconsin Press.

Steele, Julia L. 1980. Archaeological Survey and Cultural Resources Overview, Fort Richardson, Alaska. U.S. Army Corps of Engineers, Alaska District.

USACE (U.S. Army Corps of Engineers). 2011. Eklutna River Aquatic Ecosystem Restoration Technical Report; Eklutna River; Eklutna, Alaska. November 2011.

Woodward-Clyde. 1996. Eklutna Hydroelectric Project Mitigation Plan. Prepared for Western Area Power Administration. May 7, 1996.

McMillen Jacobs Associates 151 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

6.0 Project Effects, PMEs Suggested by Others, and Information Needs

The focus of the study efforts will be to develop information to allow the evaluation of effects of the Eklutna Hydroelectric Project, potential PME measures, or combinations of measures, to address those impacts, and also to address the effect of implementing potential PME measures on other resources and eight key considerations identified in the 1991 Fish and Wildlife Agreement. In this section we summarize the information related to Project effects developed in each resource category in Section 5 above and the eight specific considerations identified in the Fish and Wildlife Agreement that must be given consideration. The objective here, based on what we know about resource conditions and how possible PME measures to address Project effects might affect other resources and considerations, is to identify the information needed to confirm both Project effects and the effects of potential PME alternatives. In addition, we discuss any constraints that have been identified to acquiring the needed information and actions required to address those constraints.

The overall goal is to design an appropriate study program to ensure that the Project owners, parties, other stakeholders, and ultimately the Governor will have the appropriate information to support development of, and decision making regarding, the Fish and Wildlife Program. Study efforts are sequenced over a planned two-year study period, such as when modeling of a potential measure relies on information that must first be developed.

6.1 Impacts to Fish and Wildlife With regard to understanding the effects of the Eklutna Hydroelectric Project on fish and wildlife, it is important to compile and develop information that allows for the Project owners, parties to the 1991 agreement, stakeholders and the Governor to identify, and quantify where possible, the effects of the Project vs. the effects of other development in the basin, such as the earlier hydropower project, railroad and highway bridge construction, aggregate mining, and other anthropogenic effects.

It is difficult to quantify the effect of the earlier hydropower project on fish and wildlife resources in the Eklutna River since no fish or wildlife studies were conducted as part of the project planning process or post construction. Eklutna elders have stated that the Eklutna River used to be “overflowing” with “abundant” fish before the dams, and that all species of salmon ran in the Eklutna River. In addition, Lee Stephan, former NVE CEO, stated that his father learned from his teachers and elders that before the lower dam was constructed in 1929, salmon went to Eklutna Lake and spawned in the Eklutna River inflow. (NVE, n.d.). Specifically regarding sockeye salmon, the presence of kokanee in Eklutna Lake, and the absence of any stocking records for kokanee, appears to indicate the existence of a historic sockeye run that utilized the lake. However, the USACE stated in their 2011 report that it’s doubtful that significant numbers of sockeye ever spawned in the Eklutna River drainage due in part to the limited suitable spawning habitat in the lake and upper tributaries (USACE, 2011). In addition, a recent study that used marine-derived nutrients (MDN) as a biochemical marker in lake sediment provided no evidence that a sockeye run occurred, but did not preclude the possible existence of a relatively small sockeye fishery (up to 1,000 per year, and potentially as many as 15,000 per year) in Eklutna Lake before 1929 (Loso et al, 2019). When the earlier hydropower project was constructed in 1929, it blocked any fish passage into the upper watershed that may have occurred previously (APA, 1992). It also modified the

McMillen Jacobs Associates 152 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package natural hydrograph of the river by releasing stored water from the lake during winter low flow periods to maintain a desired minimum flow further downstream for power generation purposes (AL&P, 1929). However, after the 1929 project was constructed, Eklutna elders noted that salmon of all species were still abundant in the lower Eklutna River in the 1940s and early 1950s. Therefore, it can be concluded that the overall effect of the 1929 project on fish resources was to limit the available anadromous fish habitat in the Eklutna River to below the lower dam site. This likely also had an indirect impact on wildlife in the area that rely on salmon as a food source.

In 1955 the Federal hydropower project diverted all Eklutna Lake outflow (approximately 90% of pre- construction flows in the Eklutna River) north through the existing tunnel to the powerhouse on the Knik Arm. This has severely impacted the remaining salmon populations and resident fish in the Eklutna River. The resulting low flows have led to loss of winter rearing habitat, poor sediment transport, excessive siltation of stream channels, gravel starved stream channels, reduced water quality, and insufficient water depth for Chinook salmon spawning (USACE, 2011). However, it should be noted that Lee Stephan, an Eklutna elder, remembers an abundance of pink salmon and other species in the Eklutna River during his youth in the late 1960s and 1970s. In addition to impacts to fish resources, it’s also likely that the Federal hydropower project has impacted wetlands downstream of Eklutna Lake Dam, both riparian wetlands that likely existed in the upper river and estuarine wetlands below the railroad bridge. Impacts to these wetlands have likely had an indirect impact on the wildlife that utilize those wetlands. However, once again the effect of the Federal hydropower project on fish and wildlife resources is difficult to quantify since no fish or wildlife studies were conducted pre-construction.

The natural alluvial fan downstream of the canyon is crossed by the railroad bridge and New Glenn Highway5 bridges. Both crossings form channel constrictions which likely impacted downstream wetlands, and indirectly impacted the wildlife that utilize that habitat. However, this is difficult to quantify since no wetland or wildlife surveys were conducted pre-construction (that we are aware of). The relatively narrow railroad bridge and elevated railbed cause natural bedload to accumulate between the bridges. This has elevated the riverbed to a point where it has become perched above the ground water table, highly braided and subject to frequent channel changes. While these areas provide quality summer rearing habitat when wetted, the absence of upwelling ground water limits the available winter rearing habitat. In addition, some of these channels lead to “dead ends” that can strand fish and make passage for salmon difficult or impossible, and no salmon of any species have been observed spawning in the braided section of the river upstream of the railroad bridge (USACE, 2011). Therefore, it can be concluded that the overall effect of construction of the railroad bridge, and to some extent the New Glenn Highway bridges, on fish resources was to negatively impact upstream and downstream fish passage, spawning habitat, and winter rearing habitat between the bridges. However, this is difficult to quantify since no fish studies were conducted pre-construction.

Aggregate mining by the Alaska Railroad downstream of the railroad bridge lowered the ecosystem habitat adjacent to the river channel by approximately 20 feet and removed most of the old growth riparian vegetation between the railroad bridge and the upper extent of the intertidal zone associated with Knik Arm. Well established riparian vegetation and large woody debris promotes optimum production of

5 The Old Glenn Highway bridge does not cause a channel constriction since it is located just downstream of the canyon at the upstream end of the alluvial deposit.

McMillen Jacobs Associates 153 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package rearing salmonids during summer (USACE, 2011). Therefore, it can be concluded that the overall effect of aggregate mining on fish resources was to degrade summer rearing habitat in the Eklutna River below the railroad bridge. Aggregate mining also directly impacted the wildlife habitat in that area. However, once again this is difficult to quantify since no fish or wildlife studies were conducted at that time.

Historic aerial photos in Figures 6-1 to 6-5 below visually show the impacts to the lower Eklutna River and surrounding wetlands from 1950 to present. Figure 6-1 shows the lower Eklutna River in August 1950. At this time the existing railroad bridge had been constructed and the old hydropower project was in operation. Note that there are no aerial photos of the lower Eklutna River prior to construction of the Alaska Railroad and old hydropower project. Figures 6-2 and 6-3 show the lower Eklutna River in July 1957 and 1963 respectively. This time period is after the Federal hydropower project was constructed and started diverting all lake outflows north through the tunnel to the existing powerhouse on the Knik Arm. Figure 6-4 shows the lower Eklutna River in September 1969. This photo shows the early impacts of gravel mining by the Alaska Railroad below the railroad bridge. Figure 6-5 shows the lower Eklutna river in April 2011. This is after the Alaska Railroad ceased gravel mining and the New Glenn Highway bridges were constructed.

Figure 6-1. Aerial photo of the lower Eklutna River in August 1950

Figure 6-2. Aerial photo of the lower Eklutna River in July 1957

McMillen Jacobs Associates 154 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 6-3. Aerial photo of the lower Eklutna River in July 1963

Figure 6-4. Aerial photo of the lower Eklutna River in September 1969

Figure 6-5. Aerial photo of the lower Eklutna River in April 2011

McMillen Jacobs Associates 155 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

6.2 Identified Goals and PMEs Suggested by Others The 1991 Fish and Wildlife Agreement requires the Project owners to develop and propose protection, mitigation, and enhancement (PME) measures for fish and wildlife affected by development of the Eklutna Hydroelectric Project. Based on early outreach efforts, our understanding of the main goals of the agencies and interested parties is to find a new balance amongst the uses of water in the Eklutna River basin, including power production, potable water supply, and fish habitat. NVE wishes to restore the Eklutna River for fish and wildlife habitat, traditional subsistence uses, and sustainable natural resources development. Described below are PME measures that have been suggested thus far and will be given consideration during the development of the Eklutna Fish and Wildlife Program. Careful evaluation of potential PME measures will be a central focus of the study program to develop information on potential benefits and costs of individual and potential combinations of measures. The results of the studies and subsequent alternatives analysis will inform what PME measures are included in the Proposed Fish and Wildlife Program to be sent to the Governor.

6.2.1 Flow Related Potential flow related PME measures involve providing a flow regime into the Eklutna River that would accomplish habitat restoration and increase the anadromous fish assemblage of the river. A second flow related PME would be to create the opportunity for sockeye to travel into/out of Eklutna Lake.

In 2018, Trout Unlimited (TU) and NVE hosted a workshop to develop a vision for salmon recovery in the Eklutna River and to identify next steps to improve conditions for salmon in the near-term. Participants concluded that establishing and maintaining adequate streamflow was the most important consideration for restoring salmon runs to the Eklutna River. With that in mind, the workshop’s recommendations related to streamflow included the following:

▪ Future seasonal streamflow should be patterned after a natural hydrograph. ▪ Restoration and mitigation efforts should account for the unique hydrogeomorphic stream reaches of the Eklutna River watershed. ▪ Restoration and mitigation activities should focus on coho, Chinook, and sockeye salmon as indicator species because of their unique requirements. ▪ Future streamflow should account for each focal species’ unique needs and life histories.

Workshop participants also identified various research opportunities and information gaps. As a result of this workshop, the USFWS conducted a preliminary fish habitat flow assessment in 2019 in an effort to provide information that could guide future analysis of flow requirements for salmonids. The flow assessment used the channel characteristics of a reach just below the upper Eklutna Dam to estimate the discharge needed to provide fish habitat in the historical channel for salmonid spawning and incubation. Coho, Chinook and sockeye were selected as the target species for potential restoration efforts. Table 6-1 provides a preliminary estimate of the range of flows needed for the study reach.

McMillen Jacobs Associates 156 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Table 6-1. Estimated range of flow required for spawning and incubation (USFWS, 2019)

As shown in Table 6-2 below, this flow regime would require a total of approximately 80,000 acre-feet of water each year, roughly 35% of the average annual water usage of the hydropower Project (Table 4-1).

Table 6-2. Approximate acre-feet of water required for USFWS preliminary estimated flow regime

Spawning Incubation Migration Bankfull Totals

Average CFS 206 61 24 1402 n/a

AF per Day 408.5 121.0 47.6 2,780.2 n/a

No. of Days 120 214 30 1 365

Total AF 49,020 25,894 1,420 2,780.2 79,114.2

The USFWS clarified that the preliminary flows presented in the final report should not be construed as a final recommendation for flows needed to support salmon habitat in the Eklutna River. Instead, the USFWS recommended that a full hydraulic model (HEC-RAS or similar) should be developed for the full length of the Eklutna River as well as an overall habitat survey conducted prior to final recommendations concerning flow and that an adaptive management approach be taken.

Subject to further study, it appears initially that there are technical and legal challenges associated with providing instream flows from the reservoir into the Eklutna River that would need to be addressed. Currently, the only way to intentionally release the higher “spawning” and “bankfull” flows through the spillway would be to curtail generating power and let the reservoir fill up until the lake level exceeds the spillway crest. However, because of the way the reservoir is operated, this method would substantially reduce the storage capacity for the hydropower Project.

Intentional flow releases through the spillway could potentially be used for providing specified flushing flows by allowing the reservoir to fill up to a specific elevation for a specific amount of time to release a desired flow (volume, rate, duration) and then generating power again to draw the lake level back down. However, as an example, providing a one-day “bankfull” flow of 1402 cfs as presented by USFWS would require that the reservoir be raised to approximately El. 879 feet, eight feet above the spillway crest. This

McMillen Jacobs Associates 157 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package one-day flow would result in a substantial amount of water being released over the spillway from the time the lake elevation first exceeds the spillway crest (El. 871 feet) until it returns to below the spillway crest. Because of the way the reservoir is operated for the hydropower Project, this kind of intentional flow release would only be able to occur in the fall when the reservoir is at its peak elevation. In addition, this method would have the inherent safety risk of an unforeseen storm occurring while the reservoir level is high and the freeboard is reduced. This means that there would be a risk of higher flows being released than intended which could pose a significant safety hazard to downstream areas.

For regulated flow release at the dam, there is a 30-inch by 30-inch drainage outlet at the base of the spillway rated to release 191 cfs when the reservoir is at the spillway crest. However, this drainage gate is not a typical reservoir outlet intended for continuous use and was supplied only for drainage purposes. An engineering analysis is needed to verify that the outlet could be used in this way, and if it could, flows would be still be limited by the hydraulic capacity of the gate. Use of the drainage outlet would also have the same operational constraints regarding year-round instream flows and the same inherent safety risks as use of the spillway regarding some kind of flushing flow, although the safety risk might not be as great.

If it is determined that the drainage outlet as it currently exists could not be used to release either regulated instream or flushing flows, then the ability to provide instream flows at the dam (either year- round instream flows or short-term “bankfull” flows) would require the design, installation and operation of appropriate water release mechanisms.

An alternative that has been identified preliminarily for providing instream flows would be the modification of AWWU’s pipeline to release water into the river at either the portal valve where the water tunnel transitions to the pipeline or the pipeline drainage valve where the pipeline exits the canyon heading towards the treatment plant. Flow releases would likely be restricted by the hydraulic capacity of AWWU’s tunnel/pipeline, which might make this alternative feasible for providing smaller year-round instream flows. Again, this would require the design, installation and operation of water release mechanisms.

Another alternative that has been suggested to provide some additional flow into the river but not necessarily a regulated flow regime would be to divert Lach Q’atnu Creek back into the Eklutna River below the dam.

It should also be noted that the Alaska Institute for Climate and Energy (ALICE) has proposed converting the existing Eklutna Hydropower Project into a pumped storage project that could integrate other renewable energy sources such as wind. The Eklutna Pumped Energy Storage (PES) concept consists of five reservoirs: two in the Thunderbird watershed, two in the Knik River floodplain, and Eklutna Lake (Figure 6-6).

McMillen Jacobs Associates 158 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 6-6. Eklutna PES Concept (ALICE, 2020)

The Upper Thunderbird system (consisting of the 104-acre Upper Thunderbird reservoir, tunnel and powerhouse on Eklutna Lake and the converted pumped hydro at the 18.5-acre Salmon reservoir) would be designed as a couplet. They would have an equal maximum flow rate, so when they are both

McMillen Jacobs Associates 159 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package generating or storing energy at the maximum rate, one would be adding 725 cfs to Eklutna Lake while the other would be taking 725 cfs from the lake, thus maintaining the lake at an even level. By regulating the flow rate, the lake level could be raised or lowered at will, according to seasonal variations of inflow, theoretically allowing lake levels to be held high enough for salmon to return to Eklutna Lake and the drainage below without reducing Anchorage’s water usage from Eklutna Lake. The Lower Thunderbird and Beluga tunnels would also have equal maximum flow rates, thus making those two systems a similar couplet also capable of holding the lake at a given surface elevation level or adjusting the lake level as needed. All together, the Eklutna PES project would store 507 GWh, enough to meet average Railbelt demand for 30 days and deal with a high level of variability in wind output. The estimated capital cost for PES plus wind is about $4.7 billion. ALICE submitted their proposal to the Governor in February 2020, and the governor directed the Alaska Energy Authority to conduct a study of the Eklutna PES-wind idea which is expected to take 6-8 months to complete (ALICE, 2020).

6.2.2 Non-Flow Related Non-flow related measures discussed at the 2018 workshop included: 1) habitat reconstruction and restoration to support spawning habitat and off-channel rearing habitat, 2) fish passage at the upper Eklutna dam to allow migration into and out of the lake, 3) vegetation management to promote lateral habitat expansion and reconnection, 4) large woody debris management, and 5) restoration of historic tributary channels near the lake outlet to increase flow in the Eklutna River. Additional potential non-flow related PME measures identified thus far include modifying existing or providing new recreational access facilities and increasing utilization of the Project tailrace (e.g., fish hatchery).

In 2011, the USACE recommended several non-flow related alternatives for improving fish habitat in the lower Eklutna River. The alternatives primarily focused on improving the reach between the Alaska Railroad and the New Glenn Highway bridges. These alternatives are described below and summarized in Table 6-3. Note that Alternative 1 was a No Action alternative and is therefore not included here. It should also be noted that these alternatives were not developed as mitigation for the hydropower Project impacts and will be re-examined for feasibility and cost-benefit potential in combination with potential instream flow releases.

Alternative 2: Constructed Channel with Large Woody Debris. A stream channel would be constructed between the Alaska Railroad and New Glenn Highway bridge crossings. The new channel would allow for deeper average water depths and provide a single channel for flows. The new channel would maintain a slope of 0.12 ft/ft and would be excavated to an average bankfull depth of 1.5 feet. The cumulative cut and fill would be approximately 16,000 cubic yards and 1,200 cubic yards, respectively. A temporary access road would be built near the new channel for construction. In addition to the new stream channel, large woody debris would be placed and would be used to facilitate the development of small pools and increase the overall in‐stream shelter available for this section of river. The large woody debris would be placed at a rate of 80 pieces per 1,000 feet and be a minimum of 12 inches in diameter. The total reach length between the Alaska Railroad and Glenn Highway bridges is 2,380 feet, resulting in approximately 191 pieces of large woody debris. An additional 150 pieces of large woody debris could be placed near the constructed stream as additional riparian corridor protection from bank erosion and vehicle and foot traffic. Alternative 2 is presented in Figure 6-7.

McMillen Jacobs Associates 160 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Alternative 3: Constructed Channel with Upstream Cross-Vane Weirs. A stream channel would be constructed between the Alaska Railroad and New Glenn Highway bridge crossings. The new channel would allow for deeper average water depths and provide a single channel for flows. The new channel would maintain a slope of 0.12 ft/ft and will be excavated to an average bankfull depth of 1.5 feet. The cumulative cut and fill would be approximately 16,000 cubic yards and 1,200 cubic yards, respectively. A temporary access road would be built near the new channel for construction. In addition to the new stream channel, cross‐vane weirs would be placed upstream of the New Glenn Highway bridge crossing. The cross‐vane structures would be designed to create in‐stream holding water, decrease the stream width to depth ratio, and provide a natural sorting of gravel in the upwelling downstream of the structure. The structures would consist of a boulder weir that is shaped like a ‘V’ with the point oriented in the upstream direction. Each cross‐vane would have an average length of 51 feet using a minimum of 3-foot diameter boulders. The series of structures would be spaced at five to seven bankfull widths, resulting in three structures and approximately 50 boulders. The constructed stream channel with upstream cross‐vane weirs is presented in Figure 6-8.

Alternative 4: Large Woody Debris, Boulder Clusters, and Upstream Cross-Vane Weirs. Large woody debris and boulder clusters would be placed within the current stream corridor between the Alaska Railroad and New Glenn Highway bridge crossings to provide in‐stream cover and resting areas. A new channel would not be constructed, but large woody debris and boulder clusters would be added to encourage stream flow through a corridor. Increased velocities around the boulders would also provide small scour pools. The large woody debris would be placed at a rate of 80 pieces per 1,000 feet and be a minimum of 12 inches in diameter. The total reach length between the Alaska Railroad and highway bridges is 2,380 feet, resulting in approximately 191 pieces of large woody debris. An additional 150 pieces of large woody debris could be placed within the corridor as additional riparian protection from bank erosion and vehicle and foot traffic. Boulder clusters would be placed in areas that are easily accessible. Each boulder would measure a minimum of 2 feet in diameter. Approximately 120 boulders would be placed between the Alaska Railroad and New Glenn Highway bridge crossings. Additional larger boulders may be placed within the corridor as additional riparian protection from bank erosion and vehicle and foot traffic. The area between the Alaska Railroad and New Glenn highway bridges is not ideal for cross‐vane weirs because there is no defined channel and the slope is very flat. However, upstream of the New Glenn highway bridge, cross‐vanes could be added. The cross‐vane structures are designed to create in‐stream holding water, decrease the stream width to depth ratio, and provide a natural sorting of gravel in the upwelling downstream of the structure. The structures would consist of a boulder weir that is shaped like a ‘V’ with the point oriented in the upstream direction. Each cross‐vane would have an average length of 51 feet using a minimum of 3-foot diameter boulders. The series of structures would be spaced at five to seven bankfull widths, resulting in three structures and approximately 50 boulders. Alternative 4 is presented in Figure 6-9.

Alternative 5: Channel with Downstream Large Woody Debris and Boulder Clusters. A stream channel would be constructed between the Alaska Railroad and New Glenn Highway bridge crossings. The new channel would allow for deeper average water depths and provide a single channel for flows. The new channel would maintain a slope of 0.12 ft/ft and would be excavated to an average bankfull depth of 1.5 feet. The cumulative cut and fill would be approximately 16,000 cubic yards and 1,200 cubic yards, respectively. A temporary access road would be built near the new channel for construction. The large woody debris would be placed at a rate of 80 pieces per 1,000 feet and be a minimum of 12 inches

McMillen Jacobs Associates 161 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package in diameter. The total reach length downstream of the Alaska Railroad Bridge is 3,700 feet, resulting in approximately 296 pieces of large woody debris. An additional 100 pieces of large woody debris could be placed as additional riparian protection from bank erosion and vehicle and foot traffic. The large woody debris would be keyed into the riverbank to prevent movement downstream. Boulder clusters would be placed in areas that are easily accessible. Each boulder would measure a minimum of 2 feet in diameter. Approximately 185 boulders would be placed downstream of the Alaska Railroad bridge crossing. Additional larger boulders could be placed within the corridor as additional riparian protection from bank erosion and vehicle and foot traffic. Alternative 5 is presented in Figure 6-10.

Table 6-3. Habitat Components of USACE Alternatives 2-5 (USACE, 2011)

McMillen Jacobs Associates 162 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 6-7. USACE Alternative 2: Constructed Channel with Large Woody Debris (USACE, 2011)

McMillen Jacobs Associates 163 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 6-8. USACE Alternative 3: Constructed Channel with Upstream Cross-Vane Weirs (USACE, 2011)

McMillen Jacobs Associates 164 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 6-9. USACE Alternative 4: Large Wood Debris, Boulder Clusters and Upstream Cross-Vane Weirs (USACE, 2011)

McMillen Jacobs Associates 165 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Figure 6-10. USACE Alternative 5: Constructed Channel with Downstream Large Woody Debris and Boulder Clusters (USACE, 2011)

McMillen Jacobs Associates 166 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

6.3 Information Needs The study program will be designed, in part, based on what additional information, if any, is needed to confirm Project effects with regard to fish and wildlife resources as summarized in Section 6.1. The study program will also be designed, in part, to evaluate the potential benefits of potential PME measures as well as the potential costs of taking those measures. In addition, we need to understand any potential tradeoffs with respect to other resource values that might occur with the implementation of potential PME measures.

As listed in the 1991 Fish and Wildlife Agreement, the Purchasers must consider the potential impact of fish and wildlife measures, along with measures to mitigate those impacts, on:

▪ Electric rate payers ▪ Municipal water utilities ▪ Recreational users ▪ Adjacent land use

In addition, there are eight specific considerations included in the 1991 Fish and Wildlife Agreement that must be given consideration during the development of the Fish and Wildlife Program. In order to ensure that the Eklutna Hydroelectric Project is best adapted for power generation and other beneficial public uses, the Governor shall give equal consideration to:

▪ Efficient and economical power production ▪ Energy conservation ▪ The protection, mitigation of damage to, and enhancement of fish and wildlife (including related spawning grounds and habitat) ▪ The protection of recreation opportunities ▪ Municipal water supplies ▪ The preservation of other aspects of environmental quality ▪ Other beneficial public uses ▪ Requirements of state law

Initial concerns of agencies and interested parties regarding potential impacts that could result from implementation of some of the suggested PME measures thus far are listed below:

▪ Impacts to downstream infrastructure (AWWU facilities and bridges) ▪ Potential plans to restore fish production at the hatchery ▪ Water quality of public water supply ▪ Dam safety and flood protection ▪ Impacts to existing downstream fish habitat

McMillen Jacobs Associates 167 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

▪ Impacts to the tailrace fishery as a result of fish straying to the Eklutna River and reduced flows from the power plant ▪ Impacts to the native fish stocks in the Eklutna River as a result of fish straying from the tailrace ▪ Flooding and erosion of the lakeside trail ▪ Potential for increased bear/human interactions near the campground ▪ Impacts to historic and archaeological resources ▪ Potential need to modify current water rights ▪ Decreased water availability for power production ▪ Liability for sediment ▪ Reduction in carbon offset ▪ Cost for ratepayers

6.3.1 Information Matrix This section of the IIP contains an Information Matrix (Table 6-4) to assist discussions/decisions regarding key resource parameters for which information is needed to help guide the development of the Study Plan to evaluate Project effects and later for evaluating potential PME measures, the effects of those measures, and potential means for addressing the effects of those measures. It is essential to identify key resource parameters to ensure that the study program presented to the Governor includes existing information and new information along with the analytical tools, models, valuations, etc. to evaluate PME measures.

Based on this matrix, we have engaged with the TWG to develop proposed study scopes designed to utilize existing information and supplement with new information as necessary. Wherever possible information utilized in the evaluation of Project effects and potential PME measures should be quantitative in nature, however qualitative descriptions can be used where that is not possible. The matrix is designed to generate information needed to characterize existing (baseline) conditions to show how conditions attributable to PME measures and baseline differ from one another, through a measurement of change in the parameter from baseline.

Table 6-4. Information Matrix

Difference in Condition for each Evaluation Parameter Existing Conditions Alternative

Fish Habitat (Coho, Chinook, Sockeye) Barriers to Upstream Passage Existing Presence Difference in Presence Barriers to Downstream Passage Existing Presence Difference in Presence Channel Complexity and Shelter (side channels, pools, vegetative Existing Quantity and Quality Difference in Quantity and Quality cover, instream structures, etc.) Spawning and Incubation Habitat Existing Quantity and Quality Difference in Quantity and Quality

McMillen Jacobs Associates 168 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Summer Rearing Habitat Existing Quantity and Quality Difference in Quantity and Quality Winter Rearing Habitat Existing Quantity and Quality Difference in Quantity and Quality Estuary Habitat Existing Quantity and Quality Difference in Quantity and Quality Water Quality Temperature Existing Temperature Difference in Temperature Dissolved Oxygen Existing DO Difference in DO Existing Sediment Difference in Sediment Sediment Load/Turbidity Load/Turbidity Load/Turbidity Macroinvertebrates Quantity Existing Quantity Difference in Quantity Diversity Existing Diversity Difference in Diversity Wetlands Eklutna River Estuary Existing Quantity and Quality Difference in Quantity and Quality Riparian Zone Existing Quantity and Quality Difference in Quantity and Quality Littoral Zone Existing Quantity and Quality Difference in Quantity and Quality Wildlife Belugas Existing Food Source Difference in Food Source Bears Existing Food Source Difference in Food Source Moose Existing Habitat Difference in Habitat Migratory Waterfowl Existing Habitat Difference in Habitat Recreational Use and Facilities Lakeside Trail Existing Condition Difference in Condition Campgrounds, Cabins, Huts Existing Condition Difference in Condition Kayaking/Boating Existing Use Difference in Use Hunting (Bear, Moose, Sheep) Existing Use Difference in Use Tailrace Fishery (Chinook, Coho) Existing Use Difference in Use Eklutna River Fishery Existing Use Difference in Use Guided Fishing/Hunting Trips Existing Services Difference in Services Cultural Resources Historic Existing Condition Difference in Condition Current Existing Condition Difference in Condition Archaeological Existing Condition Difference in Condition Subsistence Existing Use Difference in Use Other Aspects of Environmental Quality Carbon Benefit Existing Carbon Benefit Difference in Carbon Benefit Safety Flood Protection Existing Flood Protection Difference in Flood Protection Bear/Human Interactions Existing Interactions Difference in Interactions

McMillen Jacobs Associates 169 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Municipal Water Supply Water Usage Existing Usage Difference in Usage Water Treatment Existing Methods Difference in Methods Pipeline and Access Road Existing Condition Difference in Condition Downstream Bridges and Property Railroad Bridge Existing Condition Difference in Condition New Glenn Highway Bridges Existing Condition Difference in Condition Old Glenn Highway Bridge Existing Condition Difference in Condition Eklutna, Inc.’s Property Existing Condition Difference in Condition Eklutna Salmon Hatchery ADFG Current Use (Acclamation) Existing Current Use Difference in Current Use CIAA Potential Use (Production) Existing Potential Use Difference in Potential Use Power Production Power Generation Existing Generation Difference in Generation Avoided Cost Existing Avoided Cost Difference in Avoided Cost Grid Reliability Existing Grid Reliability Difference in Grid Reliability Renewable Integration Existing Renewable Integration Difference in Renewable Integration Fish and Wildlife Program Costs Capital Improvements Existing Costs Difference in Costs Operations and Maintenance Existing Costs Difference in Costs

6.3.2 Ongoing Efforts by Other Agencies/Organizations There are several ongoing efforts by others including the post-dam removal sediment transport monitoring being conducted by Eklutna, Inc., the post-dam removal aquatic habitat monitoring being conducted by ADFG for Eklutna, Inc., minnow trapping in the lower river by NVE, macroinvertebrate studies and stream gaging in the lower river by APU, glacier related studies by APU, a formal Traditional Ecological Knowledge assessment of the historic and cultural importance of the Eklutna River by TU in partnership with NVE, and the Eklutna PES feasibility study by AEA. It should also be noted that TU is partnering with ADFG to continue and expand monitoring efforts in the river. TU also expects to undertake an off-channel habitat assessment upstream of the lower dam site to better understand necessary flows for habitat viability and use. In addition, NVE has applied for a grant to conduct a habitat assessment of the East and West Forks of Eklutna Creek. Each of these entities has committed to sharing their final results when available. The Project owners will review and utilize the results of each study to help inform the scope of the study program and the content of the Proposed Fish and Wildlife Program.

6.3.3 Studies Conducted in 2020 The Project owners obtained aerial photography, spherical videography, and LiDAR of the Eklutna River basin and Eklutna Lake shoreline, conducted an initial condition assessment of the spillway and 30”x30” drainage outlet gate, and established additional transects and installed scour monitors in the Eklutna River.

McMillen Jacobs Associates 170 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

6.4 References ADFG (Alaska Department of Fish and Game) Habitat Section. 2020. Eklutna River Aquatic Habitat Monitoring, 2019. Technical Report No. 19-13. January 2020.

ALICE (Alaska Institute for Climate and Energy). 2020. Pumped Energy Storage for Alaska, A path to lower energy costs for Alaska’s new energy future. February 3, 2020.

Fish and Wildlife Agreement: Snettisham and Eklutna Projects. 1991. Municipality of Anchorage dba Municipal Light & Power, Chugach Electric Association, Inc., Matanuska Electric Association, Inc., Alaska Energy Authority, National Marine Fisheries Services, U.S. Fish and Wildlife Service, and State of Alaska. August 7, 1991.

TU (Trout Unlimited). 2018. Eklutna River Workshop, Summary of Outcomes, Recommendations, and Future Needs. June 2018.

USACE (U.S. Army Corps of Engineers). 2011. Eklutna River Aquatic Ecosystem Restoration Technical Report. Joint Base Elmendorf-Richardson, Alaska. November 2011.

USFWS (U.S. Fish and Wildlife Service). 2019. Upper Eklutna River Survey, Preliminary Fish Habitat Flow Assessment. Anchorage Fish and Wildlife Conservation Office. July 14, 2019.

McMillen Jacobs Associates 171 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

7.0 Next Steps

The focus of activity in 2020 is to identify the information and analytical tools that are required, along with existing information, to evaluate Project effects, potential PME measures and the effects of implementing any PME measures on other resources and the eight considerations identified in the 1991 Fish and Wildlife Agreement. We have attempted in this IIP to compile and reference existing relevant information and to present an initial list of information needs for consideration by the parties and other stakeholders. We will continue to supplement the existing information repository as needed.

The Project owners have established a technical work group (TWG) initially focused on fish habitat, hydrology, geomorphology, sediment transport, and other related aquatic resources to specifically consult on the development of the Study Plans and Schedule for submittal to the Governor. In the interest of efficiency and deference to the time considerations of this effort on all parties and stakeholders, we plan to expand the technical expertise represented on the TWG as needs are identified (such as for 2021 infrastructure related studies).

The TWG kicked off the study planning process in July 2020. During this meeting, the TWG discussed the instream flow study and other potential studies to be included in the study program. The Project owners’ team then develop a proposed Study Program Framework and presented it to the TWG for review and input.

7.1 Develop Study Plans The general approach to developing the Study Plans is as follows. Starting with the information matrix and Study Program Framework, the Project owners’ technical team will prepare Draft Study Plans for review by the TWG. Each of the individual study components will generally include the following:

▪ Study objectives ▪ Summary of existing information relevant to the study topic ▪ Assessment of the quality of any existing information ▪ Study methods and data collection approaches ▪ Outline of the resulting study report ▪ How study information will be utilized in models and other analytical tools to quantify, where possible, or qualitatively describe Project effects and effects of potential PME measures ▪ Study schedule ▪ Preliminary cost estimate

As shown in the schedule, the TWG will be given the opportunity to review the Draft Study Plans, meet with the Project owners’ technical team to discuss the Draft Study Plans, and provide both verbal and written comments on the Draft Study Plans. Based on the consultation and information gathered, the Project owners will finalize the detailed 2021 study plan components, and concepts for the 2022 study components for submittal to the Parties to the 1991 Agreement for approval, and then to the Governor.

McMillen Jacobs Associates 172 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

The Project owners are committed to a second round of focused study planning after the completion of the 2021 studies to finalize the 2022 study efforts. The Project owners will work diligently to achieve agreement on all components of the Study Plans. Where total agreement is not achieved, the Project owners commit to documenting any areas of non-agreement and submitting the record of consultation as part of the Final Study Plans.

7.2 Submittal of Comprehensive Study Plan and Schedule to Governor To meet the consultation requirements of the 1991 Agreement, the current schedule shows submittal of the Final Study Plans and schedule to the Governor in January 2021. While there is some flexibility with regard to this target, in order to have sufficient time to finalize permitting, field logistics, access permission and staffing for field related study activities in study year one (2021), this flexibility is not unlimited. The Project owners will work diligently with the TWG to remain on schedule to the extent practicable.

7.2.1 Timing and Duration of Study Efforts We anticipate the likelihood that some of the information developed during the first study year (2021) will identify the need for supplemental effort in the subsequent year. In addition, we have identified specific study plan components for implementation in the second study year (2022) that will build on the year one study results. Similarly, there is likely to be the need to complete the development of certain information before certain analysis/modeling can be conducted. The Study Plans will distinguish work to be completed in the first study year versus subsequent study related efforts where appropriate.

7.2.2 Study Efforts Beyond Year One As shown in the Project schedule, we are currently reserving 2022 for continuing study efforts from 2021 and for follow-up study scopes to be finalized based on the review of the 2021 study results. The Project schedule will be adjusted as appropriate based on progress of the planned two-year study program. Regardless, once the study effort is complete, we anticipate a significant subsequent effort to evaluate and compare the benefits and costs of possible PME measures, and/or combinations of measures, in addressing impacts of the Eklutna Hydroelectric Project.

McMillen Jacobs Associates 173 September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Appendix A

List of Studies Conducted to Date

McMillen Jacobs Associates September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

List of Studies Conducted to Date Section 13(c) of the 1991 Fish and Wildlife Agreement states that the parties to the agreement have “the option of funding fish and wildlife studies before the process called for in Sections 2 and 3 of the agreement would otherwise require, whether such studies are conducted by the parties themselves, or by third parties.” Below is a list of studies that have already been conducted or are ongoing.

▪ Adult fish counts conducted by the Native Village of Eklutna (NVE) in 2002 and 2003 ▪ Habitat Assessment of the Lower Eklutna River conducted by the U.S. Army Corps of Engineers (USACE) in 2007 ▪ Eklutna River Aquatic Ecosystem Restoration Study conducted by USACE in 2011 ▪ Assessment of historical presence of sockeye salmon in Eklutna Lake using nitrogen stable isotopes, conducted by Alaska Pacific University (APU) et al. and published in 2017 ▪ Geometry, Mass Balance and Thinning at Eklutna Glacier study conducted by Sass et al in 2017 ▪ Upper Eklutna River Survey, Preliminary Fish Habitat Flow Assessment conducted by the U.S. Fish and Wildlife Service (USFWS) in 2019 ▪ Eklutna River Habitat Mapping Survey conducted by NVE in 2019 ▪ Lower Eklutna Sediment Transport Study conducted by HDR in 2016 for The Conservation Fund ▪ Aquatic Habitat Monitoring being conducted by the Alaska Department of Fish and Game (ADFG) for Eklutna, Inc. and in partnership with Trout Unlimited (TU) (ongoing) ▪ Sediment Transport Monitoring at the Highway and Railroad bridges being conducted by Eklutna, Inc. (ongoing) ▪ Minnow trapping in the lower Eklutna River being conducted by NVE (ongoing) ▪ Macroinvertebrate study and stream gaging being conducted by APU (ongoing) ▪ Glacier related study being conducted by APU (ongoing) ▪ Eklutna Pumped Energy Storage Feasibility Study being conducted by the Alaska Energy Authority (AEA) (ongoing) ▪ Formal Traditional Ecological Knowledge assessment of the historic and cultural importance of the Eklutna River being conducted by TU in partnership with NVE (ongoing)

McMillen Jacobs Associates September 2020 Eklutna Hydroelectric Project 1991 Fish & Wildlife Agreement Implementation FINAL Initial Information Package

Appendix B

Comment Response Table

McMillen Jacobs Associates September 2020 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Section 1: Introduction Brad Meiklejohn Section 1 Introduction (page 12) We are pleased to see [this statement]. We [have examined] the contents of the IIP in light of this statement. Comment noted. The Conservation Fund “The owners have no pre-conception as to any particular outcome or what will be included in the Proposed Fish and Wildlife Program.” Rick Sinnott Section 1.1.2 Federal Hydropower Development (page 13) This statement is misleading for several reasons. It appears to provide a reason – from an expert source (the USFWS) no less – The purpose of this statement is to show that the USBR consulted with several agencies, "the USFWS stated that '...inasmuch as no salmon or game for claiming that hydropower development had little to no effect on fish and wildlife resources in Eklutna Valley. But the including the USFWS, and that no objections were raised to the project at that time. fish are involved, we can see no possibility of your proposal incomplete USFWS quote shouldn't be allowed to stand alone. First, so-called “game” fish have long inhabited the lake and river. Additional information regarding USBR's consultation with various agencies has been being harmful to wildlife interests' (USBR, 1948)." Local Dena’ina claim that their ancestors used to fish in the lake during their annual fall hunting/gathering excursions into the included in the Final IIP, see page 2. Raising the lake level by 2 feet was part of the overall valley. Pilot Russ Merrill began flying fishing parties to Eklutna Lake in 1927 (Anchorage Daily Times, 10 Aug. 1927, p. 4) and as project proposal. This has been clarified in the Final IIP, see page 3. There is no *Also Section 3.5.1 Federal Hydropower Development, soon as a passable road was built in the mid-1930s anglers began flocking to the lake (e.g., Anchorage Daily Times, 19 July 1937, documentation that indicates the USFWS was unaware of how the project would be Planning (page 33) p. 8). Rainbow trout still inhabit the lower reaches of the river (above the former location of the diversion dam), which receive operated. water from several small tributaries. Second, the quote fails to acknowledge the possibility that the lower dam, built two decades earlier, blocked a historic run of salmon from entering most of the river and the lake. There is no record that the Dena'ina living in Eklutna Village or other local residents, who would have remembered salmon spawning in the lake and upper stretches of the river prior to 1928, were consulted at the time. In fact, in its 1992 environmental assessment for the submittal of a legislative proposal to Congress for the sale of the Eklutna project, the Alaska Power Administration concluded that “complete loss of the anadromous salmon run (Sockeye) undoubtedly occurred with the construction of the 1929 dam.” (p. 11) That conclusion was based on anecdotal information supplied by fisheries biologists and the local Dena’ina residents of the valley. Third, fish are not wildlife and the presumed absence of "game" fish (a term that references the value of a fish to humans) doesn't preclude the valley's importance to wildlife. In fact, the USFWS letter quoted above emphasized the incomparable wildlife resources in the valley and recommended maintaining an existing hunting closure in perpetuity. In the letter, the Alaska director of the USFWS wrote “That particular area affords some of the most beautiful scenery and natural game habitat to be found anywhere in Alaska.” Dewatering Eklutna River would surely have had a significant impact on the distribution and abundance of fish and wildlife in the valley. It's possible that the USFWS was not aware that the new development would be unlike the hydropower development in operation at the time, that all of the water that would have normally flowed out of the lake was going to be shunted into a tunnel. In fact, based on his full statement (which was not included in the draft IIP), Director Clarence Rhode was referring to the USBR’s proposal to raise the lake level two feet, not to cut off all flow to the river.

Rick Sinnott Section 1.1.2 Federal Hydropower Development (page 14) This statement isn't completely accurate, and it has bearing on the arguments I've raised in [other] comments. The USBR bought This has been reworded in the Final IIP, see page 3. "With no flow from Eklutna Lake into Eklutna River, the old the existing facility, which was still operational, because the City of Anchorage owned the facility and the right to the lake’s hydropower project was rendered useless and shutdown. water, and the facility could be a potential competitor. This presented a legal hurdle as well. The USBR planned to increase the USBR paid the city $1,841,760 for the old project facilities." storage capacity of the lake by building a higher dam, while the City of Anchorage owned the water rights. Alternatively, the USBR recognized that operating their proposed facility would put the existing facility out of business, which could lead to a legal *Also Section 3.5.2 Initial Federal Project Construction (page challenge. In Eklutna Project … to Serve 25% of All Alaskans the USBR observed that “Except for spills, which would be utilized at 33) the existing plant, no water would be released from the lake to Eklutna Creek. This plan would greatly reduce the generation capability of the existing plant, and in many months of the year, when there is a very little inflow below the lake, the present plant would not be able to generate any power.” (p. 33) Of course, this conundrum was solved when Anchorage chose to sell their facility (and water rights) to support and encourage the new project, which promised a much larger capacity. It is inconceivable that today’s hydropower facility would exist without the purchase of the original facilities built in 1928 and 1929. The 1953 contractual agreement between the City of Anchorage and the Bureau of Reclamation (No. 14-06-906) transferred the original power plant “and associated facilities and properties” to the federal government. According to the document, this agreement “removed the last remaining legal hurdle to construction of the Eklutna project.” What is misleading about the statements in the draft IIP is the existing facility was not “rendered useless and shut down” by the lack of water, it was deliberately purchased and decommissioned because otherwise it would have presented several insurmountable hurdles to the new project.

Page 1 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Brad Meiklejohn Section 1.1.3 Sale of the Federal Project to the Local Utilities It should be inserted that the sale from APA to the Eklutna Purchasers included “any and all property and facilities acquired or This definition has been included in the Final IIP, see page 4. However, please note that the The Conservation Fund (page 14) used in connection with Eklutna”. See the Eklutna Purchase Agreement. This will need expansion and reiteration at 3.5.2 to 1989 Eklutna Purchase Agreement also states that “The above description of assets is "APA and the proposing parties negotiated Purchase clarify that the Eklutna Purchasers assumed ownership of, and liability for, all infrastructure related to the 1929 Lower Diversion intended to be general and not precise or all inclusive. As part of the transition activities, Agreements which set forth specific terms and conditions for Dam. the parties will jointly prepare a particularized listing of the assets to be sold and sale of the projects. The Eklutna Purchase Agreement was transferred.” The subsequent asset lists did not include the lower diversion dam. Regarding executed on August 2, 1989." ownership of and liability for the 1929 lower diversion dam, the Federal government transferred the lower diversion dam and any associated real property to Eklutna, Inc. and CIRI in 1985 and 1986 pursuant to ANCSA, several years prior to the 1989 Eklutna Purchase Agreement. Furthermore, the Section 404 permit application materials for the lower dam removal project state that "The lower Eklutna River dam and surrounding property are owned by Eklutna, Inc."

Aaron Leggett Section 1.1.3 Sale of the Federal Project to the Local Utilities NVE is intrigued by [The Conservation Fund's] comment, as in this light, it seems the removal of the lower dam by TCF, Eklutna, The proposed instream flow study will evaluate existing barriers to fish passage, sediment Native Village of Eklutna (page 14) Inc. (EI) and partners were services to the fish and wildlife mitigation goals of the 1991 Agreement. It facilitates restoration of conditions, and what habitat changes might occur under future alternative flow regimes. salmon habitat in Eklutna River above Thunderbird Creek, provided sufficient flow can be restored. Certainly, there are now The results of this study will inform discussions about benefits and costs of various PMEs. ongoing impacts to Eklutna River salmon habitat there from dewatering in need of study and mitigation.

Brad Meiklejohn Section 1.1.3 Sale of the Federal Project to the Local Utilities This section needs expansion with additional language from the Environmental Assessment Report section of the Divestiture The word alleged as been deleted in the Final IIP, see page 5. Existing information The Conservation Fund (page 14) Report specific to the loss of sockeye salmon. On page 10 of the Environmental Assessment the language is clear and regarding historic salmon runs in the Eklutna River, including recent studies and Traditional "Upon review of the legislative proposal, the loss of a unambiguous: “During initial reviews of the legislative proposal, one significant problem was identified: namely, loss of a Sockeye Ecological Knowledge, are summarized in Section 5.4.1. sockeye salmon run that may have spawned in Eklutna Lake salmon run that once spawned in Eklutna Lake.” Further language from the Environmental Assessment is unambiguous: “Loss of was identified by the National Marine Fisheries Service the Sockeye run was most likely staged, initiating with the 1929 dam construction and including the construction of the Eklutna (NMFS). The alleged loss would have been caused by AL&P’s Project facilities…Complete loss of the anadromous salmon run (Sockeye) undoubtedly occurred with the construction of the development of the previous hydropower project in 1929." 1929 dam.” Use of the word “alleged” in the text of the IIP here is misleading and appears to be an attempt to cast doubt on the prior existence of a sockeye salmon run that used to reach Eklutna Lake.

Aaron Leggett Section 1.1.3 Sale of the Federal Project to the Local Utilities This section should include the following from page 10 of the Environmental Assessment Report section of the Divestiture Report A statement summarizing this information is included in Section 1.1.3. Other existing Native Village of Eklutna (page 14) specific to the loss of sockeye salmon: “During initial reviews of the legislative proposal, one significant problem was identified: information regarding historic salmon runs in the Eklutna River, including recent studies "Upon review of the legislative proposal, the loss of a namely, loss of a Sockeye salmon run that once spawned in Eklutna Lake.” NVE believes this definitive statement should be and Traditional Ecological Knowledge, are summarized in Section 5.4.1. sockeye salmon run that may have spawned in Eklutna Lake emphasized in discussion of whether a sockeye salmon run spawned in Eklutna Lake. The sockeye statement in the Divestiture was identified by the National Marine Fisheries Service Report is the best evidence, along with Traditional Ecological Knowledge. (NMFS)." Austin Williams Section 1.1.3 Sale of the Federal Project to the Local Utilities Regarding sockeye salmon, this section characterizes the loss of sockeye salmon as an “alleged” loss. This ignores the rich oral The word alleged has been deleted in the Final IIP, see page 5. Trout Unlimited (page 14) history, statements from the 1992 Divestiture Report, and the presence of sockeye salmon in the lower portions of the Eklutna "The alleged loss would have been caused by AL&P’s River today. As discussed above, the loss of sockeye salmon was one of the prime motivators for creating the 1991 Agreement. development of the previous hydropower project in 1929." Their loss should not be characterized as “alleged.”

Rick Sinnott Section 1.1.3 Sale of the Federal Project to the Local Utilities This statement follows naturally from the assertions made on page 13 of the draft IIP. It seems to be accurate; however, once It's our understanding that during the early stages of the divestiture, the Eklutna project (page 14) again, it is taken out of context. The "earlier" divestiture studies, reports and negotiations assessed the technical and financial was generally viewed as not having fish and wildlife problems because in 1948 when the "Specific fish and wildlife measures were not contemplated feasibility of the transfer. Politicians, engineers and accountants are not known for their fisheries or wildlife expertise. To the USBR consulted with several agencies, including the USFWS, as part of the initial planning in the earlier divestiture studies and reports or in best of my knowledge, the primary landowner – Eklutna, Inc. – and the Native Village of Eklutna were not consulted about fish or process for the Eklutna project, no objections were raised to the project at that time. The negotiations for the Purchase Agreements because the wildlife. Neither were the federal and state agencies responsible for fish and wildlife management. Substantive fish and wildlife timing of APA's consultation with fish and wildlife agencies has been clarified in the Final projects were generally viewed as not involving fish and concerns were raised as soon as the agencies and local people found out about the plan to transfer the project. The draft IIP IIP, see page 5. As stated in the IIP, APA solicited public comments at three separate stages wildlife problems." acknowledges this, as follows: "The APA developed a legislative proposal to authorize sale of the projects in accordance with the of the divestiture process. However, the project owners acknowledge that there is no Purchase Agreements. Upon review of the legislative proposal, the loss of a sockeye salmon run that may have spawned in record that NVE or Eklutna, Inc. were consulted with directly regarding the sale of the Eklutna Lake was identified by the National Marine Fisheries Service (NMFS)." (p. 14) The draft IIP should make it abundantly project to the three utilities. clear that fisheries experts and local residents were not initially apprised of the negotiations for the Purchase Agreement; however, as soon as the divestiture plan reached a broader audience the fisheries concerns were raised, initially by the NMFS, then others.

Page 2 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Rick Sinnott Section 1.1.3 Sale of the Federal Project to the Local Utilities In other words, the construction of the original dams in 1928-29, which took place without consulting the local people or federal As discussed in Section 3.4, Frank Reed filed a preliminary permit application with the FPC (page 14) fish and wildlife managers, eventually led to the 1991 fish and wildlife agreement. Thus, the 1991 agreement was intended to (now FERC) in 1922, and the FPC granted the preliminary permit under Project No. 350. "The alleged loss [of the sockeye run] would have been protect, mitigate damage to, and enhance fish and wildlife resources affected by all of the hydroelectric development in Eklutna Frank Reed/AL&P followed the process as required at the time, and the FPC issued a 50- caused by AL&P's development of the previous hydropower Valley, past and present, not just the federal project. year license for the project on October 12, 1928 authorizing construction of the original project in 1929. It was not identified in pre-authorization dams in 1928-29. In addition, the city council held a public meeting on June 20, 1927 to studies for the Federal project, and the Federal project did familiarize people and solicit opinions regarding AL&P's proposal to provided the city with not include mitigation. This specific problem and the desires electricity. Several other meetings were reportedly held to acquaint interest parties to of the fish and wildlife agencies to provide appropriate AL&P's proposal. However, the owners acknowledge that there is no record that NVE was consideration to fish and wildlife resources over the long run directly consulted with regarding AL&P's plan to construct the original hydroelectric led to negotiation of a formal agreement between the project. Purchasers, the State of Alaska, NMFS, and USFWS regarding protection, mitigation of damages to, and enhancement of fish and wildlife resources affected by hydroelectric development of the Federal Eklutna and Snettisham projects."

Austin Williams Section 1.1.3 Sale of the Federal Project to the Local Utilities Quoting the 1992 Divestiture Report provides important context. As discussed above, this quote stresses the intent of the parties The 1991 Fish and Wildlife Agreement is a procedural document that outlines a process of Trout Unlimited (page 15) to the 1991 Agreement at the time it was entered to ensure that impacts to fish and wildlife are thoroughly and comprehensively consultation, studies, and public involvement for development of a Fish and Wildlife “Given the nature of the projects and the river basins addressed. Program while giving "equal consideration to the purposes of efficient and economical affected, there is good reason to believe that the proposed power production, energy conservation, the protection, mitigation of damage to, and arrangements will work at least as well as Federal regulation enhancement of fish and wildlife (including related spawning grounds and habitat), the for the intended purpose of mitigation and enhancement of protection of recreation opportunities, municipal water supplies, the preservation of other affected fish and wildlife resources. The August 7, 1991 aspects of environmental quality, other beneficial public uses, and requirements of state Agreement affords fish and wildlife interests a stronger voice law." The goals and PME's suggested by others are described in Section 6.2 of the IIP. in project management than would be available under continued Federal ownership.”

Austin Williams Section 1.2 Requirements of the 1991 Fish & Wildlife This section discusses the procedural requirements of the 1991 Agreement while paying little attention to the substantive The 1991 Agreement is procedural in nature and intentionally did not specify any particular Trout Unlimited Agreement (page 15) requirements of the agreement. A greater effort should be made to describe the substantive requirements; the expected outcome. The Agreement sets up a process similar to the FERC licensing process, which outcomes and desired conditions that should prevail in the Eklutna watershed after implementation of protection, mitigation, also focuses on procedural requirements and not specific outcomes. The objective of the and enhancement efforts; and the collective expectations of the parties. The workshop TU and the Native Village of Eklutna Agreement is to evaluate impacts of the federal project, evaluate potential PMEs, and the hosted should serve as a guide to help identify desired conditions. effects of implementing those PMEs and to develop a fish and wildlife program for submittal to the Governor. The owners have no pre-conception as to any particular outcome or what will be included in the Proposed Fish and Wildlife Program. The goals and PME's suggested by others are described in Section 6.2 of the IIP.

Tom Barret Section 1.2.1 Procedural Requirements (page 15) Would be helpful to know if this meant prior to 1929, prior to 1950’s or which phase of the project. The Federal government transferred the lower diversion dam and any associated real ADNR - Water Resources “The 1991 Fish and Wildlife Agreement requires the Eklutna property to Eklutna, Inc. and CIRI in 1985 and 1986 pursuant to ANCSA, several years prior Purchasers to fund and conduct studies to examine, and to the 1989 Eklutna Purchase Agreement and 1991 Fish and Wildlife Agreement. quantify if possible, the impacts to fish and wildlife from the Therefore, since the lower diversion dam was not included in the sale of the Project to the hydroelectric development of the Eklutna project.” current owners, it is our understanding that this is related to the hydroelectric development of the Federal project in the 1950s.

Sean Eagan Section 1.2.1 Procedural Requirements (page 16) NMFS requests further clarification on the meanings of the first two stated purposes in the 1991 Settlement Agreement: The 1991 Agreement does not include definitions for these terms. As interpreted by the NMFS “efficient and economical energy production..." and "energy conservation". Please also state how these purposes will be applied project owners, "Efficient and economical energy production" includes two separate but to future decision-making. related important considerations. The owners interpret "efficient energy production" to mean the ability to operate the project in a manner where the most effective use of the water resource allows for the optimum production of energy and in a manner that minimizes operations and maintenance requirements. The owners interpret "economical energy production" to mean the ability to keep the cost of energy production low consistent with sound and safe utility practices. The owners interpret "energy conservation" to mean the decision and practice of using less energy, but acknowledge that it's unclear what the intent was for including this as a consideration for development of the Fish and Wildlife Program.

Page 3 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Rick Sinnott Section 1.2.2 Schedule Requirements (page 17) In its 1992 environmental assessment for the submittal of a legislative proposal to Congress for the sale of the Eklutna project, The owners acknowledge that they are responsible for any reasonable costs associated “These timing provisions were designed primarily to reduce the Alaska Power Administration explained just how the agreement helped finance the project. In its informal consultation with with complying with the 1991 Fish and Wildlife Agreement and implementing the final Fish uncertainties in financing and repayment of new debt by the local offices of the USFWS, NMFS, and Alaska Department of Fish and Game, the APA addressed the fisheries experts’ concerns and Wildlife Program. Because the 1991 Agreement states that the Governor must Eklutna Purchasers. It was expected that financial that the dates for implementing the 1991 fish and wildlife agreement were too far in the future and that loss of the salmon run consider impacts to efficient and economical power production, the costs of any proposed institutions would not provide financing if issues were would not be adequately mitigated. According to the APA, “It was expected that financial institutions would not provide PME measures will be evaluated as part of the planned alternatives analysis. outstanding and lacked resolution. By developing a binding financing if issues were outstanding and lacked resolution. By developing a binding and protective agreement, and putting off and protective agreement, and putting off implementation implementation dates, financing is an achievable goal.” (p. 10) Thus, it seems as though the 1991 fish and wildlife agreement was dates, financing became an achievable goal (APA, 1992b).” instrumental in achieving financing for the proposed development, which suggests that any reasonable costs to be incurred pursuant to the 1991 agreement are baked into the deal.

Brad Meiklejohn Section 1.2.2 Schedule Requirements (page 17) Additional discussion is needed on the financing of the Eklutna Project, as we are told that financing was the principal rationale As stated in the IIP, the delay in mitigation was determined to be necessary at the time in The Conservation Fund “These timing provisions were designed primarily to reduce for the lengthy delay in starting the mitigation process. How did the financing work out? How much did the Eklutna Purchasers order for the Purchasers to finance the project. The project owners have initiated and are uncertainties in financing and repayment of new debt by the pay for the project (~$6.7 million) How quickly did the Project pay for itself? Was the 22-year delay in mitigation financially moving forward with the consultation process required by the 1991 Agreement. Additional Eklutna Purchasers. It was expected that financial necessary? information regarding the actual project financing would not impact the current institutions would not provide financing if issues were consultation and planned study efforts. outstanding and lacked resolution. By developing a binding and protective agreement, and putting off implementation dates, financing became an achievable goal (APA, 1992b).”

Brad Meiklejohn Section 1.2.2 Schedule Requirements (page 17) Language from the Environmental Assessment section of the Divestiture Report should be included wherein concerns are raised This text has been included in the Final IIP, see page 7. The final EA also clarifies that The Conservation Fund about the lengthy timeframe for study and mitigation: “The time frames within the agreement for assessing damages to the fish "These timing provisions [were] designed primarily to reduce uncertainties in the financing resources were judged to be too far in the future and not realistic. It was felt that by the time program implementation was and repayment of new debt while recognizing that known fish and wildlife concerns [were] initiated, loss to the salmon resources could not be adequately mitigated for.” Elsewhere in the Environmental Assessment: “The not of the type that will require near future action." It also states that "there [were] no Region II Habitat Division of the Alaska Department of Fish and Game recommended that the timeframes within the Eklutna Fish identifiable impacts or no discernible difference in regard to resource degradation for and Wildlife Agreement be accelerated. ADF&G recommends that the fish and wildlife mitigation analysis be initiated within 3 utilization of either timeframe." Without the timing provisions, the utilities would not have years.” been able to purchase the project, the Fish and Wildlife Agreement would not have been executed, and resolution of any fisheries issues would most likely not have occurred because the existing legislation and regulations at the time did not prescribe natural resource damage type assessments, studies or mitigation under Federal ownership.

Aaron Leggett Section 1.2.2 Schedule Requirements (page 17) NVE agrees with TCF that language from the Environmental Assessment section of the Divestiture Report should be included This text has been included in the Final IIP, see page 7. The final EA also clarifies that Native Village of Eklutna wherein concerns are raised about the lengthy timeframe for study and mitigation: "The time frames within the agreement for "These timing provisions [were] designed primarily to reduce uncertainties in the financing assessing damages to the fish resources were judged to be too far in the future and not realistic. It was felt that by the time and repayment of new debt while recognizing that known fish and wildlife concerns [were] program implementation was initiated, loss to the salmon resources could not be adequately mitigated for." This seems obvious. not of the type that will require near future action." It also states that "there [were] no Baseline studies on Eklutna salmon should have been done before the 1929 lower dam. identifiable impacts or no discernible difference in regard to resource degradation for utilization of either timeframe." Without the timing provisions, the utilities would not have been able to purchase the project, the Fish and Wildlife Agreement would not have been executed, and resolution of any fisheries issues would most likely not have occurred because the existing legislation and regulations at the time did not prescribe natural resource damage type assessments, studies or mitigation under Federal ownership. The owners cannot change what was or was not done in 1929. However, the owners are committed to conducting the appropriate studies to support the development of a Fish and Wildlife Program for the Eklutna Hydroelectric Project as required by the 1991 Agreement.

Brad Meiklejohn Section 1.3 Early Consultation and Information Gathering We object to the phrase “…more than three years early” and ask that it be deleted. If the Eklutna Purchasers had started the Per the 1991 Agreement, the owners were required to initiate the consultation process by The Conservation Fund (page 18) mitigation process in year 1, rather than year 22, it might be warranted to say you started early. But waiting 22 years to start is October 2, 2022. However, the 1991 Agreement also required that the schedule call for the "Therefore, in order to allow adequate time to meet the like showing up for a baseball game in the 8th inning and bragging that you started early. Governor to issue the Final Fish and Wildlife Program by October 2, 2024. Therefore, procedural requirements of the 1991 Agreement, the owners initiating the process in 2022 would only allow 2 years for the owners to meet the initiated the consultation process in 2019, more than three procedural requirements outlined in the 1991 Agreement. The owners determined that 2 years early." years was insufficient. Therefore, the owners initiated the consultation process in March 2019, more than 3 years prior to the required start date, in order to allow adequate time to meet the procedural requirements of the 1991 Agreement.

Page 4 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Austin Williams Section 1.3.1 Initial Consultation Meetings (page 18) Of course, and without question, the most important stakeholder in this process is the Native Village of Eklutna, whose people Although the 1991 Agreement only requires the owners to consult with specific state and Trout Unlimited "In March and April of 2019, the owners conducted in-person are the ancestral residents of the Eklutna River watershed, and who too often have been left without a voice in important federal agencies, the owners’ team has expanded its consultation to included other initial consultation meetings with multiple agencies and decisions affecting the future of their homeland. Excluding the Native Village of Eklutna from the 1991 Agreement was an interested parties. NVE was one of the first entities that the owners' team consulted with, interest parties. The 1991 Agreement only requires the egregious oversight. We encourage all parties to the 1991 Agreement to work together to find a way to make the Native Village and it is the owners’ intent to fully engage with NVE throughout the process. NVE has since owners to consult with the five Federal and State resource of Eklutna a more meaningful and formal participant of this process. submitted a request for formal recognition as a consulting government with their Land and management agencies listed in the Agreement. However, Environment Department, their natural resource agency, analogous to other governmental because the owners recognize that there is a high level of signatories for purpose and processes of the 1991 Agreement applicable to the Eklutna interest in the project from other entities for various reasons, Project” to the project owners. The project owners have reviewed NVE's request and are the owners reached out to those entities for early actively coordinating with NVE on this topic. consultation as well. In total the owners met with 14 agencies and interested parties as part of their initial consultation efforts. These entities are listed below... [including the] Native Village of Eklutna"

Brad Meiklejohn Section 1.3.1 Initial Consultation Meetings (page 18) In reviewing the list of acronyms and participating parties, it is notable that the Cook Inlet Region Inc. (CIRI) is not listed and has Agreed. The owners' team will reach out to CIRI to confirm what interest they may have in The Conservation Fund not been participating in the process. Given that CIRI own’s the subsurface rights for all of the surface estate held by Eklutna participating in the consultation process required by the 1991 Agreement. Inc., it seems they should at least be notified and invited to participate. Section 2: Schedule and Communication Protocols

Nabi Qureshi Section 2.2 Communications and Distribution Protocols (page There is no information about if or how utility ratepayers will be notified of changes to their utility company’s energy source. The project owners are committed to complying with the 1991 Agreement which requires The Alaska Center 22) How will the owners’ utility customers be involved and communicated with in this process, if at all? The 1991 Fish and Wildlife impacts to "efficient and economical power production" be evaluated and considered Agreement requires the consideration and mitigation of effects to electric ratepayers. While the information is being made public during development of the Fish and Wildlife Program. The 1991 Agreement also requires on the website, will the information and the resources for the Eklutna Project be shared with them directly? the project owners to hold at least one public meeting each in Anchorage and the Matanuska Valley to receive public comment on the Draft Summary of Study Results, the Draft Fish and Wildlife Program, and the comments and recommendations of the Federal and State resource management agencies. As the study effort and alternatives analysis effort progresses the project owners will evaluate other methods for involving and communicating with the utilities' rate payers directly.

Section 3: History of Development in the Eklutna Basin and Project Tailrace Area

Nabi Qureshi Section 3.1 Alaska Native Historical and Current Presence First I would like to reiterate the point that Austin Williams and Marc Lamoreaux raised in the meeting. I believe that Alaskan NVE provided comments on the Draft IIP regarding the historical and cultural presence of The Alaska Center (page 24) Native voices and especially those of the Native Village of Eklutna Elders need to be given more weight. Section 3.1 beginning on the Alaska Native people. The owners' team has reviewed and addressed their comments page 24 is relatively thin and would benefit from having more information on the historical and cultural presence of the Alaska in this comment response table and in the Final IIP. TU also commented that they are Native people, as well as their connection to the land and water; this is not fully considered from the time the dam was installed, working with NVE to compile their Traditional Ecological Knowledge. We look forward to till now. There is little to no references to their oral histories and their roles are understated. having that information available in the future.

Brad Meiklejohn Section 3.1 Alaska Native Historical and Current Presence Much more information about the Eklutna Dena’ina exists in definitive book, Shem Pete’s Alaska (Kari and Fall, 2003), and this The map of the area showing the Dena’ina place names has been added to the Final IIP, The Conservation Fund (page 24) source describes the profusion of Dena’ina place names around the Eklutna Lake and the Eklutna Valley. It would be good to see page 16. include a map of the area that includes all the many Dena’ina place names. Aaron Leggett Section 3.1 Alaska Native Historical and Current Presence Much more information about the Eklutna Dena’ina exists. In the definitive book, Shem Pete’s Alaska (Kari and Fall, 2003). It Information from Shem Pete's Alaska has been added to the Final IIP, see page 16. Native Village of Eklutna (page 24) includes two highly valued quotes from former elders that: “Eklutna is an old, old village. Nobody knows when they first moved there.” And, “Eklutna was always an old village.” Shem Pete’s Alaska also describes the profusion of Dena’ina place names around the Eklutna Lake and the Eklutna Valley. Section 15.21 includes the following helpful information: “Idlughet (Dena’ina); Zdlaaygha (Ahtna), ‘By the Objects’; Eklutna village, ‘Old Knik,’ ‘Knik Village’ (AHRS ANC-00008). The earliest recording of this name is ‘Ixliueskoe’ in the Wrangell collection notes from the 1830s (Arndt 1985), based on the lower Cook Inlet Dena’ina pronunciation, Ezdlughet, for Idlughet; skoe is a Russian suffix ‘village’. This name is recorded as ‘Zdluiat’ and is mislocated several miles to the south on the 1884 Petroff map. The Mendenhall and Meiklejohn maps of 1900 label Eklutna as ‘Knik Village.’ Chandonnet (1979:11) and Fall (1981:396) trace the recordings of the names ‘Knik’ and ‘Old Knik’ for the village now known as Eklutna.”

Aaron Leggett Section 3.1 Alaska Native Historical and Current Presence Steve Braund and Associates studied Eklutna Village for Wells Fargo and reported evidence of a much older existence than the This information has been added to the Final IIP, see page 19. Native Village of Eklutna (page 24) 1887 Old Russian Orthodox Church. It was so much so that Wells Fargo ended up gifting the land back to Eklutna in 2014 through our non-profit, Ikluat, Inc.

Page 5 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Aaron Leggett Section 3.1.1.1 Native Village of Eklutna, Background (page NVE disagrees with the interpretation of Chandonnet (1979 and 1991) that Eklutna Village “was used only in winter” in early This has been clarified in the Final IIP, see page 19. Native Village of Eklutna 24) times. NVE suspects that Euro-American culture and world views taint the interpretation. Much of the misguided assumptions "Beginning circa 1650 A.D., Eklutna may have served as a can be avoided with respectful tribal consultations and inclusion of Traditional Knowledge, whether ecological, environmental, primary settlement for the Dena’ina, though the site was social, or historical. It is NVE’s understanding that ancient Eklutna Dena’ina did consider themselves a village people. During the used only in winter (Chandonnet, 1979 and 1991)." summer months they would disperse to fish and hunt at various locations up and down the Inlet, and inland, as to Eklutna Lake, up the Knik River, and further afield. However, some would have remained at Eklutna Village to hunt and harvest salmon there, including from Eklutna River, and lay in food supplies for overwintering at Eklutna from both local and dispersed sources. Villages were selected to have access to all needed resources, which prominently included salmon. As per Loso et al., 2017, quoted at 5.4.1.2: “villages were traditionally ‘located along productive salmon streams …” Eklutna was one of these villages. Excess preserved subsistence foods would also have been traded to others travelling between interior Alaska and farther down the Inlet, as Eklutna lay on a well-used trade route. Winter Camp is more of the “Hunker Down” place to survive the harsh environment, and Eklutna is strategically located to watch up and down the Knik for invaders, hunt or trap in the mountains or nearby forests, and to fish, one of the most important food sources that continues to exist today. Simple logic dictates that in any strategic thinking, one would not leave the home-base unguarded, and not everyone was able to or cut out to go fishing, they did other things. To give some insight in this philosophy of living, see the book written by Alberta Stephan of Eklutna, The First Athabascans of Alaska: Strawberries: “Each person had a job to do. Some women were good at tanning skins, some were good at sewing. The elder women did the cooking and took care of the young children. The men were good hunters or runners or scouts who would find animals to hunt. Men who were too old to hunt anymore cut wood for the home fires.” … “History was passed to the younger generations by stories.” Note that oral traditions continue to be an important part of Eklutna’s culture. Alberta continues with, “Most families migrated to the rivers and wherever there was fish in the summertime. In the fall, it was time to hunt for sheep and goat up in the mountains.” … “With all these preparations for winter, when the food ran out, they had to rely on rabbits and porcupine. Please read the first word again, Most. To live where there is access to good water and food is a characteristic of societies all around the world. It is no less true for Eklutna people. In an interview with George Ondola, conducted by Bonnie Morris and Maria Coleman for the Anchorage Port project, George stated, “that he only claimed the amount of land he needed for his Birchwood allotment. There were rabbits all over the place, that was all he needed (if food ran low).”

Aaron Leggett Section 3.1.1.2 Native Village of Eklutna, Current Presence Maria Coleman, current NVE Tribal Council Vice President listened to the elders in the early ‘70s, when she was in her 20s. Six Comment noted. The Eklutna people's desire to catch more salmon from the Eklutna River Native Village of Eklutna (page 25) elders, now deceased, told her that the Eklutna River used to be “overflowing” with “abundant” fish before the dams. They said will be taken into consideration during the alternatives analysis. NVE will also have the "Subsistence fishing has always played an important role in that “now” there are (relatively) barely any fish there, and they can’t use that river anymore (Traditional Knowledge of Eklutna opportunity or review and comment on the eventual Proposed Fish and Wildlife Program the lives of the Dena’ina. Due to provisions enacted in the Fish Resources, Native Village of Eklutna). Eklutna people would like to catch more salmon from the Eklutna River today, but the to be submitted to the Governor. Alaska National Interest Lands Conservation Act (ANILCA), salmon populations are too small to support more than a very limited take in the lower River. the Knik Arm region does not qualify under Federal or State regulations as a subsistence use area. Despite such regulatory issues, the NVE residents and other Dena’ina in the Knik Arm region that are indigenous to the area continue to harvest local resources for cultural uses and subsistence as they have done for centuries, utilizing educational subsistence permits. These types of permits allow NVE to maintain salmon gillnet sites for the purpose of educating children on the traditional subsistence lifestyle."

Brad Meiklejohn Section 3.1.1.2 Native Village of Eklutna, Current Presence The text at 3.1.1.2 seems to be implying that the Eklutna Dena’ina did not fish for salmon in the Eklutna River, and elsewhere The previous paragraph acknowledges that "Subsistence fishing has always played an The Conservation Fund (page 25) (e.g. 5.4) we find insinuations that the Eklutna was never a significant salmon river. The continued presence of all five species of important role in the lives of the Dena’ina." The purpose of this paragraph is to describe "The Eklutna River drainage was an important hunting and salmon in the Eklutna despite the severely degraded hydrologic conditions is sufficient evidence alone that salmon have long the other subsistence activities conducted by the Eklutna Dena'ina people, including subsistence area for Eklutna Natives up through the 1950’s. used the Eklutna and that the Eklutna Dena’ina took advantage of this food source close to their village. hunting, trapping, and gathering. This has been clarified in the Final IIP, see page 21. Eklutna Natives hunted sheep, moose, ground squirrels, and bear in the watershed. Hunting and trapping on the inlands and in the mountains are also important traditional subsistence activities that continues today, along with the gathering of berries, plants, trees, and stones (USACE, 2011)."

Page 6 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Aaron Leggett Section 3.1.1.2 Native Village of Eklutna, Current Presence NVE agrees that it should not be implied in the IIP (e.g. 5.4) that the Eklutna was never a significant salmon river. The continued The previous paragraph acknowledges that "Subsistence fishing has always played an Native Village of Eklutna (page 25) presence of all five species of salmon in the lower Eklutna where it is supplemented by Thunderbird Creek is evidence alone that important role in the lives of the Dena’ina." The purpose of this paragraph is to describe "The Eklutna River drainage was an important hunting and salmon have long used the Eklutna and that the Eklutna Dena’ina took advantage of this food source close to their village. Please the other subsistence activities conducted by the Eklutna Dena'ina people, including subsistence area for Eklutna Natives up through the 1950’s. see related references under 1.1.3. hunting, trapping, and gathering. This has been clarified in the Final IIP, see page 21. Eklutna Natives hunted sheep, moose, ground squirrels, and bear in the watershed. Hunting and trapping on the inlands and in the mountains are also important traditional subsistence activities that continues today, along with the gathering of berries, plants, trees, and stones (USACE, 2011)." Brad Meiklejohn Section 3.1.2 Eklutna, Inc. (page 25) Reference should be made to the extensive Palmer Land Claims made by William Ezi in 1953, well before ANCSA. See Kari and This information has been included in the Final IIP, see page 20. The Conservation Fund Fall, 2003 above. Aaron Leggett Section 3.1.2 Eklutna, Inc. (page 25) Reference should be made to the extensive Palmer Land Claims made by William Ezi in 1953, well before ANCSA. (See Kari and This information has been included in the Final IIP, see page 20. Native Village of Eklutna Fall, 2003 above.) Brad Meiklejohn Section 3.3 Glenn Highway (page 27) Information should be provided about the hydrologic design flow that was assumed for the construction of the Old and New Additional information regarding the replacement of the Old Glenn Highway bridge in 2015 The Conservation Fund Glenn Highway bridge. has been added to the Final IIP, see page 23. Further information regarding the hydraulic design flow of the New Glenn Highway bridges and railroad bridge will be gathered as part of the proposed downstream infrastructure component of the study program.

Aaron Leggett Section 3.3 Glenn Highway (page 27) Information should be provided about the hydrologic design flow that was assumed for the construction of the Old and New Additional information regarding the replacement of the Old Glenn Highway bridge in 2015 Native Village of Eklutna Glenn Highway bridge. The New Glenn bridge has not suffered from large emergency flow releases. Also, there are plans to has been added to the Final IIP, see page 23. Further research regarding the hydraulic reconstruct it to accommodate more lanes in each direction, and it could be designed to accommodate increased flows. design flow of the New Glenn Highway bridges and railroad bridge, as well as any plans to replace those bridges, will be considered for inclusion in the study program.

Tom Barret Section 3.4.1 Early Hydropower Development, Planning (page In 1924 initial studies of the project included environment and climate. Were any fish studies documented? We are unaware of any study documentation regarding fish prior to the 1929 project. ADNR - Water Resources 29) "In 1924 Frank Reed hired Seattle engineer Robert Howes to conduct initial studies of the Eklutna undertaking. Howes examined the market for power, the environment and climate of the proposed site, transportation issues, lake characteristics, head conditions, cost projections and other aspects of the project."

Sean Eagan Section 3.4.2 Early Hydropower Development, Original NMFS would like to emphasize that the initial 1928 license issued to AL&P by the Federal Power Commission (FERC predecessor) This has been clarified in the Final IIP, see page 26. NMFS Construction and Subsequent Improvements (page 29) did have a mechanism to release water into the river from the upper storage reservoir. NMFS requests this be made more clear "On October 12, 1928 the FPC issued a 50-year license in the IIP. authorizing construction of the hydropower project at Eklutna. Construction of the project was initiated in 1928 and completed in 1929. The project included both a storage dam at the outlet of Eklutna Lake and a diversion dam on the Eklutna River approximately 7 miles downstream from the storage dam (Figure 3-6). Water was diverted from the river through an 1,800-foot-long tunnel and an 847-foot- long penstock to the power plant, and then discharged through the tailrace into the Knik Arm (CEMML, 2002)."

Austin Williams Section 3.4.3 Early Hydropower Development, Project Sold to This section notes the City of Anchorage purchased the hydropower project in 1942, which at the time included an original Additional information regarding the sale of the early hydropower project to the City of Trout Unlimited the City of Anchorage (page 32) diversion dam. This is a very brief subsection and additional information on the Order Approving Transfer of License approved by Anchorage has been included in the Final IIP, see page 28. "AL&P sold the hydropower project to the City of Anchorage the Federal Power Commission would be helpful, if available, for tracking the ownership and responsibility for the lower Eklutna in 1943. On October 16, 1944 the FPC approved the transfer Dam. of the project license from AL&P to the City of Anchorage effective October 13, 1943 (FPC, 1944)."

Page 7 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Brad Meiklejohn Section 3.5.2 Initial Federal Project Construction (page 33) More detail should be provided on the disposition of assets of the old project subsequent to the sale from the city to the USBR. It The Federal government transferred the lower diversion dam and any associated real The Conservation Fund "With no flow from Eklutna Lake into Eklutna River, the old appears that these assets were transferred to the Eklutna Purchasers subject to the sale of the Eklutna Project. property to Eklutna, Inc. and CIRI in 1985 and 1986 pursuant to ANCSA, several years prior hydropower project was rendered useless and shutdown. to the 1989 Eklutna Purchase Agreement. This has been clarified in the Final IIP, see page USBR paid the city $1,841,760 for the old project facilities 31. including the existing storage dam (CEMML, 2002)."

Aaron Leggett Section 3.5.2 Initial Federal Project Construction (page 33) More detail should be provided on the disposition of assets of the old project subsequent to the sale from the city to the USBR. It The Federal government transferred the lower diversion dam and any associated real Native Village of Eklutna "With no flow from Eklutna Lake into Eklutna River, the old appears that these assets were transferred to the Eklutna Purchasers subject to the sale of the Eklutna Project. property to Eklutna, Inc. and CIRI in 1985 and 1986 pursuant to ANCSA, several years prior hydropower project was rendered useless and shutdown. to the 1989 Eklutna Purchase Agreement. This has been clarified in the Final IIP, see page USBR paid the city $1,841,760 for the old project facilities 31. including the existing storage dam (CEMML, 2002)."

Rick Sinnott Section 3.5.3 Stream Diversions (page 35) The U.S. Board on Geographic Names has changed the name of this creek to Łach Q'atnu Creek. I appreciate that you found and The name of the creek has been corrected in the Final IIP, see page 35. Historic photos of "Thachkatnu Creek" shared the reference to the rerouting of Łach Q'atnu Creek into Eklutna Lake. Neither that creek nor a small, unnamed creek Lach Q'atnu Creek from 1941 and 1950 have also been included in the Final IIP. These entering the south side of the small dam pond are natural sources for the lake. Water from the small, unnamed creek was photos indicate that Lach Q'atnu Creek was diverted prior to 1950. Information regarding *Also Section 6.2.1 Flow Related (page 136) captured in the 1950s when the storage dam was moved downstream to its present location. The Eklutna Project Act of July 31, the small, unnamed creek has also been included in the Final IIP. 1950 (as amended) reserved only “the water of Eklutna Lake and its tributaries which are required for the operation of the Eklutna project…” Łach Q'atnu Creek and the small, unnamed creek were not tributaries of Eklutna Lake when the Act was passed by Congress. Brad Meiklejohn Section 3.5.3 Stream Diversions (page 35) My understanding is that an additional creek on the south shore of Eklutna Lake was also diverted, and that this diversion Information regarding the small, unnamed creek has been included in the Final IIP, see The Conservation Fund rerouted the creek that now flows into the catchment basin upstream of the upper dam. On the ground inspections of this creek page 36. support this conclusion. If this creek is walked upstream from where it empties into the catchment basin, nothing about it seems normal or natural. The creek mouth is not well established and neither is there a definite channel upstream. Aerial photos of the area show what appear to be bulldozer lines to divert the creek to its current location, including what appears to be trenching that diverted the creek to the east from its original channel. Ground inspections indicate that this creek formerly entered the Eklutna River immediately downstream from the upper dam. It is possible that this creek was diverted not only to capture the water but to keep this creek from impairing the function of the upper dam.

Aaron Leggett Section 3.5.3 Stream Diversions (page 35) There is no mention of the stream that was diverted to flow into the ‘pond’ between the glacier moraine and the Lake Dam. Information regarding the small, unnamed creek has been included in the Final IIP, see Native Village of Eklutna Without the man-made diversion, this stream would flow into the river channel below the dam. This should be mentioned in page 36. flow related PMEs as well. Sean Eagan Section 3.5.3 Stream Diversions (page 35) NMFS requests that the IIP provide the drainage area for Thachatnu Creek and the intermittent stream captured in 1963. An This information will be developed as part of the study program. NMFS estimated artificial hydrograph for Thachatnu Creek would also be helpful, but we understand that is more difficult.

Sean Eagan Section 3.5.4 1964 Earthquake and New Dam Construction In 1965 the Bureau of Reclamation built a replacement dam 1,400 feet downstream of the previous structure. It was a federal Section 3.5.4 of the IIP accurately describes the 1964 earthquake, post-earthquake NMFS (page 36) project and therefore did not need a FERC license. This is really the 3rd dam built at the lake outlet as it was not at the same inspections, explorations for a new dam location, and construction of the replacement "Explorations for a replacement dam near the location of the location as the 1951 structure. NMFS requests that this is made clear in the IIP. dam in 1965. The previous dams at the lake outlet are described in Sections 3.4.2 and existing dam revealed highly plastic clay in the foundation 3.5.2. It has been clarified in the Final IIP that the Federal hydropower project did not which would not support the spillway structure. However, a require a license from the FPC, see page 30. suitable foundation for the spillway was found about 1,400 feet downstream. The replacement dam was built in 1965 with an ungated overflow spillway (Figures 3-15 and 3-16)."

Rick Sinnott Section 3.6 Military Use and Facilities (page 38) This is indeed what the Army claims. However, this assertion seems to be contradicted by Public Land Order 3162 from 1963 in Information regarding Public Land Order 3162 has been included in the Final IIP, see page “The range at the Eklutna Glacier Training Site has never which the Secretary of the Interior withdrew 68.88 acres of land located about 10 miles south of Eklutna Lake (presumably on or 36. The project owners acknowledge the apparent discrepancy regarding the historic use of been used for training involving military munitions (live-fire near the glacier) for use by the Department of the Army because those “lands have been used as an impact area for mortar fire, military munitions at the Eklutna Training Site. However, because this information is or non-live-fire) (U.S. Army, 2008).” and may be contaminated from unexploded ordnance.” The Army should be asked to clarify this discrepancy. unlikely to impact the development of the Fish and Wildlife Program, reference to the use (or non-use) of military munitions as the Eklutna Training Site has been deleted from the Final IIP. Sean Eagan Section 3.7 Campgrounds and Picnic Areas (page 38) National Park Service records may provide additional information on the original four BLM campgrounds and establishment of Comment noted. NMFS Chugach State Park. While NMFS is not suggesting that this information needs to be in the IIP, necessarily, we wanted to make note of other possible resources.

Page 8 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Brad Meiklejohn Section 3.9 Eklutna Water Project (page 40) It is worth noting that the recommended alternative would have taken water from the tailrace. This is still an option, as the water It's true that of the 3 different alternatives that CH2M proposed initially for utilizing the The Conservation Fund "The CH2M Hill studies recommended the alternative which discharged at the tailrace is perfectly potable yet it is lost to the Knik River. Eklutna water source, CH2M originally recommended the alternative which would take would take water from the tailrace because of its relative water from the tailrace. However, as explained in the Draft IIP, CH2M later examined a technical simplicity, and because it would not impact power fourth alternative which involved diverting water directly from Eklutna Lake or the power plant generation. The project team later examined a fourth plant tunnel near the lake. This alternative was found to be superior when environmental, alternative which involved diverting water directly from permitting, right-of-way, geotechnical, energy, and cost aspects were considered, which is Eklutna Lake or the power plant tunnel near the lake. This why it's the alternative that was selected and developed. alternative was found to be superior when environmental, permitting, right-of-way, geotechnical, energy, and cost aspects were considered and is the alternative that was finally selected and developed."

Aaron Leggett Section 3.9 Eklutna Water Project (page 40) It is worth noting that the recommended alternative would have taken water from the tailrace. This is still an option, as the water It's true that of the 3 different alternatives that CH2M proposed initially for utilizing the Native Village of Eklutna "The CH2M Hill studies recommended the alternative which discharged at the tailrace is perfectly potable yet it is lost to the Knik River. Eklutna water source, CH2M originally recommended the alternative which would take would take water from the tailrace because of its relative water from the tailrace. However, as explained in the Draft IIP, CH2M later examined a technical simplicity, and because it would not impact power fourth alternative which involved diverting water directly from Eklutna Lake or the power plant generation. The project team later examined a fourth plant tunnel near the lake. This alternative was found to be superior when environmental, alternative which involved diverting water directly from permitting, right-of-way, geotechnical, energy, and cost aspects were considered, which is Eklutna Lake or the power plant tunnel near the lake. This why it's the alternative that was selected and developed. alternative was found to be superior when environmental, permitting, right-of-way, geotechnical, energy, and cost aspects were considered and is the alternative that was finally selected and developed."

Brad Meiklejohn Section 3.9 Eklutna Water Project (page 40) At this section some discussion is needed that an overflow discharge system exists at the AWWU plant that causes released A more detailed review of AWWU's existing infrastructure, operations, and water use will The Conservation Fund "The project diverts Eklutna Lake water from the power water to flow into the Eklutna River canyon through the side drainage just upstream of the Lower Dam. During the course of the occur as part of the proposed existing infrastructure review study component. tunnel to a 7-foot diameter diversion tunnel that connects to lower dam removal, this side channel flooded once in an unannounced and surprisingly large discharge (estimated at ~300 cfs) a buried 54-inch pipeline located downstream from the due to an issue at the AWWU facility. The possibility has been raised that this discharge could be used to mobilize remaining existing dam at the lake outlet. Water flows by gravity sediment in the vicinity of the lower dam site. through the 1-milelong diversion tunnel and the approximately 6-mile-long buried pipeline down the Eklutna River valley to a 750 kW energy recovery station at the Eklutna Water Treatment Plant (Figure 3-19) located on a bench above the river near the site of the old diversion dam." Brad Meiklejohn Section 3.9 Eklutna Water Project (pages 40-41) Mention should be made of the existing arrangement with AWWU and Alaska Glacier Products whereby the latter purchases This information has been included in the Final IIP, see page 39. The Conservation Fund "After treatment, water flows by gravity through a 23-mile- Eklutna Lake water from AWWU and resells it as bottled water. (www.clearalaskan.com). long buried pipeline to the distribution system near the Ship Creek Water Treatment Plant. This system supplies water to the Anchorage service area, from Eklutna Village to Potter Marsh in South Anchorage."

Sean Eagan Section 3.9 Eklutna Water Project (page 41, Figure 3-18 Many fish habitat restoration ideas center on the ability to manage riparian vegetation, move sediment, and create off channel The existing AWWU access road is shown on the project location map as presented in NMFS AWWU access road bridge [left] and fording the Eklutna River habitat. These activities are facilitated by mechanized equipment like bobcats, backhoes, and small dozers. NMFS requests that Figure 4-2. It's our understanding that there are several additional dirt roads and/or ATV [right]) this Figure also include a detailed map showing current dirt roads and old road beds that could be easily put back into use. trails around the lower river. However, we do not currently have a detailed map showing these roads/trails. Development of an "access road map" will be considered as part of the study effort.

Page 9 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Brad Meiklejohn Section 3.9 Eklutna Water Project (page 39) Discussion is warranted [in this section or Section 5.3.4 Water Rights] on the relative proportional allocation of water between This information has been included in the Final IIP, see page 40. The Conservation Fund "In 1984 AWWU reached an agreement with the APA for an AWWU and the Eklutna Purchasers and a comparison of the relative importance of that allocation to the total of each resource equitable method of replacing energy taken from the (ie; AWWU gets 10% of Eklutna Lake water which that represents 85% of the supply of public water for the MOA vs. Eklutna Eklutna Power Plant by the Eklutna Water Project (AWWU, Purchasers use 90% of the Eklutna Lake water which represents <5% of the power supply for Southcentral Alaska. 1984). However, it was later determined that the compensation methods outlined in the 1984 agreement were inappropriate because water diversions for the Eklutna Water Project constitute a small fraction of the available water supply."

Sean Eagan Section 3.9 Eklutna Water Project (page 41) The IIP states: “(AWWU(sic) … will exceed 18,000 acre feet” by 2025. It would be helpful to know whether this 1993 prediction of A more detailed review of AWWU's existing infrastructure, operations, and water use will NMFS "The 1993 supplemental agreement is effective until 2025, Anchorage’s water need is still accurate. Table 4.1 provides similar information, but not the same. occur as part of the proposed existing infrastructure review study component. at which time it was predicted that water diversions for the Eklutna Water Project (over a 12-month period) will exceeded 18,000 acre-feet." Brad Meiklejohn Section 3.9 Eklutna Water Project (page 41) Some discussion is needed about the overall AWWU water system, what fraction of total water is provided by Eklutna, the A more detailed review of AWWU's existing infrastructure, operations, and water use will The Conservation Fund relative or absolute volume of water lost to leakage, how water is distributed and whether AWWU users are billed for volume occur as part of the proposed existing infrastructure review study component. and usage. Sean Eagan Section 3.11 Eklutna Salmon Hatchery (page 43) The Eklutna Salmon Hatchery has not produced fish since 1998. At this point, NMFS believes it should be considered a newly A more detailed review of CIAA's existing water rights and plans to rehabilitate the Eklutna NMFS "In 1998 fish production at the Eklutna Salmon Hatchery was requested water use, rather than an existing water use. Salmon Hatchery will occur as part of the study program. suspended. Since then the facility has been maintained as an emergency backup system for Trail Lakes Hatchery. The facility is also used by ADFG to imprint and release Chinook and coho salmon smolts prior to their release in the Eklutna Tailrace (CIAA, 2019c). In November 2018, Southcentral Alaska experienced a magnitude 7.0 earthquake that caused significant structural damage to roads, homes, and facilities including the Eklutna Salmon Hatchery. CIAA is currently assessing the damage to the hatchery to determine the cost of repairing the facility and is investigating options for restoring fish production at the facility."

Sean Eagan Section 3.12 Eklutna Tailrace Day-Use Fishing Access Site NMFS recognizes this tailrace fishery is socially important. It is difficult to imagine a scenario where this recreation site would The 1991 Agreement requires the owners to consider potential impacts to recreation NMFS (page 44) cease to exist as an artificial day-use fishery. Therefore, because this fishery would not change substantially under any likely opportunities and other beneficial public uses when developing the Fish and Wildlife scenario, NMFS believes that it should be given less weight than other factors. Program. Some of the flow-related PME measures suggested by others may require a decrease in power generation, which would result in a decrease in the amount of water that is discharged into the tailrace, which could potentially impact salmon in the tailrace and therefore the tailrace fishery. Similar impacts occur under current operations, for example when a generating unit is taken off-line for preventative maintenance. Anglers have complained to the owners about these kinds of impacts in the past. In addition, there is the possibility that releasing flows into the Eklutna River will cause fish that would have returned to the Eklutna tailrace to stray and return to the Eklutna River instead, which also may impact the tailrace fishery. Therefore, the owners' team plans to include the potential impacts to the tailrace fishery as part of the PME alternatives analysis.

Brad Meiklejohn Section 3.12 Eklutna Tailrace Day-Use Fishing Access Site The use of the adjective “very” in two places (“very large” and “very popular”) seems biased and unnecessary. The statement regarding the "very large returns of coho, chum and sockeye salmon" is a The Conservation Fund (page 44) direct quote from a letter from APA to MEA dated August 29, 1996. The statement "Due to the very large returns of coho, chum and sockeye regarding the "very popular Chinook salmon fishery" was meant to convey the relative salmon to the hatchery, a large number of sport fisherman popularity of the Chinook salmon fishery at the Eklutna tailrace relative to other started frequenting the site (APA, 1996)… In 2002 they also recreational fisheries in the Anchorage area. However, to address your comment, the text started stocking chinook salmon smolts, which has provided has been edited to just say "popular Chinook salmon fishery". Additional data regarding a very popular chinook salmon fishery since 2004." recreational use and sport fish harvest at the Eklutna tailrace are included in Section 5.

Page 10 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Brad Meiklejohn Somewhere in Section 3.0, perhaps in Section 3.13 Removal There needs to be discussion of the multiple efforts to remove junked cars and other debris from the Eklutna Canyon. I believe This information has been included in the Final IIP, see page 43. The Conservation Fund of the Old Diversion Dam (page 45) that NVE led the first effort in 2011(?) that led to the removal of most of this debris. In the course of removing the Lower Dam, an additional 30 tons of junked cars, refrigerators, tires, bicycles and other debris were taken out of the lower canyon.

Sean Eagan Section 3.13 Removal of the Old Diversion Dam (page 48, This illustration is just a schematic that was not based on physical measurement. NMFS requests more useful information, such The owners acquired LiDAR data of the entire Eklutna River in May 2020, which should NMFS Figure 3-26 Incremental process of excavating sediment from as a graphical representation of the sediment that remains there today, like “as deconstructed” drawings. show how much sediment remained behind the lower dam site at that time. Additional behind the lower dam) information regarding the remaining accumulated sediment will be obtained in the planned geomorphology/sediment transport study. Michael Knapp Section 3.13 Removal of the Old Diversion Dam (page 49) The metal and other debris observed by the Upper Dam owners are likely remnants of construction equipment and materials Information regarding the 2017 slope failure has been included in the Final IIP, see page ADOT&PF “The contractor was required to remove metal and other that were buried during a dangerous slope failure that occurred during the Lower Dam removal project. This slope failure 49. debris from the canyon bottom and regrade the remaining incident is not mentioned in the IIP report, yet it would seem a relevant topic from a habitat perspective given that additional sediment into a stable condition… The owners’ team construction-related debris could be unearthed over time by stream flows. conducted a site reconnaissance of the Eklutna River in 2019… At that time there appeared to still be some construction debris on top of and embedded within the sediment...”

Section 4: Project Facilities and Operations

Monica Keim Section 4.1.2 Reservoir (page 56) Has there been an updated storage capacity for Eklutna Lake, considering the amount of sediment that is trapped behind the The storage capacity information reported in the Draft IIP is the most current information Undergraduate - APU "The current dam raises the water level of Eklutna Lake by present dam? Any monitoring of sediment accruement? Loso et al., 2017. available and refers to the active storage capacity above the minimum regulated lake level 21 feet to a maximum regulated lake level of El. 871 feet at elevation 814 feet. In 1948 USBR reported that "There is at least 200,000 acre-feet of (the elevation of the spillway crest). At this elevation, the space in the lake below elevation 830 which is considered as dead storage and would be lake has a surface area of 3,420 acre-feet (AF). The minimum available for silt accumulation. Inasmuch as the bed load is being largely deposited on the regulated lake level is El. 814 feet, which provides an active alluvial flats above the lake and in the delta, and a high percentage of the suspended storage capacity of 174,800 acre-feet. Storage between the matter is carried on through the lake, the 200,000 acre-feet of available dead storage spillway crest (El. 871 feet) and the dam crest (El. 891 feet) is should provide ample capacity to allow a useful reservoir life far in excess of 100 years, an additional 72,800 acre-feet (MJA, 2018)." without encroachment on the active storage space." The owners are unaware of any ongoing monitoring of sediment accruement. This information has been included in the Final IIP, see page 58.

Sean Eagan Section 4.2.1 Reservoir Operations (page 61) The 30” by 30” drainage outlet could turn out to be a key tool to habitat restoration. Please provide more detail on when the The base of the drainage outlet is located at El. 852 feet. This information has been NMFS "The 30-inch by 30-inch drainage outlet in the base of the lake is full enough to use this outlet (e.g. which months), and why the utilities are hesitant to use it to provide instream water. Is included in the Final IIP, see page 55. However, the lake level needs to exceed the spillway crest is controlled by a manually operated slide gate there some reason to think releasing 25 cfs would be fine, but releasing the full 191 cfs could cause structural damage? Thank elevation of the natural glacial moraine at the lake outlet for the "pond" to become conduit and can release up to 191 cfs (with reservoir at the you for the information provided so far! connected to the lake. The elevation of the glacial moraine is unknown at this time. spillway crest). However, this is not a typical reservoir outlet Development of this information is planned as part of the study program. The utilities are and was supplied only for draining water trapped against hesitant to use the drainage outlet to provide instream flows because that's not what it the dam in the winter when the reservoir is drawn below the was designed for. The drainage outlet was supplied for draining water trapped against the glacial moraine. Operation of the spillway gate valve is dam in the winter when the reservoir is drawn below the glacial moraine. To the best of checked on an annual basis and the operating mechanism our knowledge the drainage outlet has never been used to release any sustained flows, lubricated (Chugach, 2016b)." much less its rated full capacity of 191 cfs. Currently, the drainage outlet is only operated once annually for maintenance purposes, and the plant operators have expressed apprehension about debris potentially getting stuck in the drainage outlet when they do open the gate and then not being able to close it again. An engineering analysis will be conducted to verify whether or not the outlet could be used to provide regulated flow releases.

Page 11 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Brad Meiklejohn Section 4.2.2 Water Usage, Energy Generation, and Cost of We need much more information here to verify this statement. In a presentation to the Anchorage Assembly on August 18, 2017, This statement refers to the owners actual power generation, not the installed capacity. The Conservation Fund Power (page 61) ML&P asserted that Eklutna hydro represents 5.8% of ML&P’s total power generation. The Alaska Energy Authority Report AEA The project owners acknowledge the importance of the requested information, and plan to “The Eklutna Hydroelectric Project produces nearly 6% of the 11-022 showed installed generation capacity for MEA, CEA and ML&P of 921 MW in 2009, with Eklutna hydro making up 4.3% of develop more detailed information as part of the study program. project owners’ combined generation.” installed generation capacity at that time. Additional installed capacity (ML&P Plant 2A and Eklutna Generating Station) has come online since 2009, so the percentage of installed generation capacity represented by Eklutna hydro must be even lower in 2020. Based on 2019 figures reported by the three utilities, current installed generation capacity of the three utilities totals 1,132 MW, of which Eklutna hydro represents 3.5%. After the discussion that ensued on this topic on 4/16/20, this topic needs further elaboration to draw out the distinction between owner’s combined generation, installed generation capacity, Railbelt generation, and Railbelt generation capacity, and the relative percentage of these figures that Eklutna hydro represents. Depending on which of these terms is used you can get different results that raise or lower the apparent significance of Eklutna hydro.

Austin Williams Section 4.2.2 Water Usage, Energy Generation, and Cost of The use of “nearly” in this statement means less than 6%, and in order to fully understand the contributions made by the Eklutna The project owners acknowledge the importance of the requested information, and plan to Trout Unlimited Power (page 61) Hydroelectric Project to the grid, a more accurate accounting for the project's contributions would be helpful. One remedy would develop more detailed information as part of the study program. “Eklutna Hydroelectric Project produces nearly 6% of the be to add a column to “Table 4-1 Historic Annual Eklutna Hydroelectric Project Water Usage and Energy Generation” displaying project owners combined generation.” the annual percentage of electricity provided to the owners’ energy portfolio by the Eklutna Hydroelectric Project.

Sean Eagan Section 4.2.2 Water Usage, Energy Generation, and Cost of NMFS requests the annual water use by AWWU be added to this table (or put it someplace else in the document). The project owners acknowledge the importance of the requested information, and plan to NMFS Power (page 61, Table 4-1 Historic Annual Eklutna develop more detailed information as part of the study program. Hydroelectric Project Water Usage and Energy Generation)

Austin Williams Section 4.2.2 Water Usage, Energy Generation, and Cost of This section is titled “Water Usage, Energy Generation, and Cost of Power”. However, it includes very little discussion of water This document is meant to be a summary of existing information, therefore the highly Trout Unlimited Power (page 61, Table 4-1 Historic Annual Eklutna usage. Table 4-1 includes yearly water usage for the past 10 years, but does not include any information about usage prior to detailed information regarding water usage was not included. However, this information is Hydroelectric Project Water Usage and Energy Generation) 2010, about when within each year water is used, how that usage relates to lake inflows, or how the use relates to energy available if/when needed for the study program and/or PME alternatives analysis. LAS production or municipal water uses. The Municipality of Anchorage holds a certificate for water from the Alaska Department of 2569 is for the municipal water supply, not for the hydropower project. The Eklutna Natural Resources for the water use from the outlet of the Eklutna Lake, LAS 2569. This certificate, which has a priority date in Hydroelectric Project operates pursuant to Certificate of Appropriation ADL 44944 with a 1985, allows for the use of 41 million gallons per day, with the quantity of water to be re-evaluated after 9, 15, 20, 25, 30 and 35 priority date of December 31, 1954. The reevaluation requirement only applies to LAS years. The IIP should include specific information about water usage for each year data exist, include as much precision as 2569, not ADL 44944. The information you provided regarding the reevaluation possible and be no coarser than a month-by-month basis, and include all other relevant information from the periodic re- requirement has been included in the Final IIP, see page 95. More information on water evaluations of LAS 2569. All information on water use should be clearly linked to how much power was generated, how much rights is provided in Section 5.3 Water Resources. went to municipal water uses, or how much went to whatever other use the water might have been put toward. If the Eklutna Hydroelectric Project operates pursuant to other water certificates, information for each of those other certificates should also be included in the IIP.

Brad Meiklejohn Section 4.2.2 Water Usage, Energy Generation, and Cost of It is appropriate to ask here why Eklutna hydro is the lowest cost resource? The answer, which should accompany the statement Information regarding the cost of generation will be developed as part of the study The Conservation Fund Power (page 61) above, is that Eklutna hydro is cheap for the following reasons: 1) the project was paid for by the Federal government; 2) the program. "Eklutna hydro is the lowest-cost resource for power in the Eklutna Project was purchased by the Eklutna Purchasers at a very steeply discounted price; and 3) environmental costs, such as Railbelt." the impact to the river, to fish and to the Eklutna Dena’ina, have been externalized and delayed.

Austin Williams Section 4.2.2 Water Usage, Energy Generation, and Cost of The Eklutna and Bradley Lake Hydroelectric Projects are just snapshot of the owners’ portfolio and additional info such as the The project owners acknowledge the importance of the requested information, and plan to Trout Unlimited Power (page 61) cost of power per kWh and the percentage power generated for Fire Island wind and natural gas would help better show the full develop more detailed information as part of the study program. "Eklutna hydro is the lowest-cost resource for power in the picture of the grid and various individual projects’ relative importance. Railbelt. The average cost of power produced by the project is $0.013 per kWh. The next lowest-cost resource for power in the Railbelt is the Bradley Lake Hydroelectric Project with an average cost of power of $0.04 per kWh."

Austin Williams Section 4.2.2 Water Usage, Energy Generation, and Cost of To better understand the significance of this offset it would be helpful to have something to compare it to, such as the annual The project owners acknowledge the importance of the requested information, and plan to Trout Unlimited Power (page 61) carbon emissions of the owners. develop more detailed information as part of the study program. "In addition, Eklutna hydro generation offsets approximately 86,000 tons of carbon each year."

Page 12 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Sean Eagan Section 4.2.3 Flood Protection (page 62) The probable maximum precipitation (PMP) event calculated in 1963 needs to be updated. The climate has changed as has our Per the 2018 PSI, "The methods used by USBR to develop the IDF are adequate. The NMFS "USBR developed the Inflow Design Flood (IDF) for these understanding of stationarity and predicting rainfall events. An updated PMP may change the Probable Maximum Flood (PMF). referenced documents represent the most recent general guidance on PMP estimates for analyses based on the probable maximum precipitation the Eklutna Dam area. A new PMF estimate would involve a site-specific meteorological (PMP) calculated by the U.S. Weather Bureau in 1963." study and could result in a somewhat greater flood. However, the reservoir outflow would probably not change appreciably because of the large flood capacity of the reservoir. We consider the IDF presented in the SEED report to be reasonable and adequate for Eklutna Dam; no further analysis is needed at this time."

Sean Eagan Section 4.2.4 Spill Events (page 63, Table 4-2 Summary of This is very useful information. Thank you for including it. Comment noted. NMFS Spill Events at Eklutna Dam from 1965 to 2019) Monica Keim Section 4.2.4 Spill Events (page 64) No mention of downstream sediment transport monitoring during peak spills (1995, 1,022 cfs) or during the longest spill (74 To the best of our knowledge, no sediment transport monitoring was conducted for either Undergraduate - APU "The highest lake level elevation ever recorded in Eklutna days, 1997). the 1995 or 1997 spill events. Lake was 877.62 feet on September 25, 1995. At this elevation the flow through the spillway was calculated to be 1,022 cfs. The longest spill event at Eklutna Dam occurred in 1997 and lasted for a total of 74 days. The calculated total volume of water spilled during this time was 35,591 acre- feet (MJA, 2020)." Michael Knapp Section 4.2.5 Emergency Action Plan (page 64) DOT&PF requests a copy of [the] Emergency Action Plan (EAP) for review. If the Owners proceed with intentional flow releases A copy of the EAP will be provided to ADOT&PF for review. ADOT&PF "The ADNR certificate of approval requires the project into the river from the Upper Dam, their future EAP updates should address sediment management in the vicinity of the Glenn owners to maintain an Emergency Action Plan (EAP) for the Highway bridges and who would be responsible for that work. Eklutna dam." Section 5: Description of Existing Environment

Section 5.1: Climate

Sean Eagan Section 5.1.1 Historical Climate (page 65) [This] is an oversimplification of weather and climate information in the Eklutna watershed. It seems the information in the IIP This is a direct quote from the 2011 USACE report. It appears they got their data from the NMFS "The average annual precipitation is about 18 inches…" was solely collected at the lake. NMFS requests a list of the years of data collection that the 18” average was based on. Total National Climatic Data Center; however, they do not list the years of data collection that precipitation is higher at higher elevations and perhaps lower at the old Eklutna town site. Therefore, NMFS requests that this the 18" average was based on. Development of more detailed precipitation information section be expanded to include more data about the areas above and below the lake. will be considered during the scoping of the proposed water availability component of the study program. Rick Sinnott Section 5.1.1 Historical Climate (page 65) This seems to be the only place in the draft IIP where freezing is mentioned. However, no data is presented on when the lake Information regarding when the lake freezes has been included in the Final IIP, see page "Fresh surface water along Eklutna River typically begins to freezes. This would be useful information if it exists. My anecdotal observations for the past nine years indicate that the lake is 67. freeze in mid-November and break up in April. Ice forms on typically ice-free beginning in late April or May and typically freezes completely between late November and late December. The the brackish estuarine waters at the mouth of Eklutna River actual dates (possibly plus or minus several days) are as follows: from December through April. The lower Eklutna River continues to flow throughout the winter. In this reach there Freeze 11/29/2011, Thaw 5/19/2012 appears to be adequate flow to prevent freezing within main Freeze 11/26/2012, Thaw 6/1/2013 channel gravels, although freezing of spawning gravels may Freeze 12/2/2013, Thaw 5/10/2014 occur in smaller channels (USACE, 2011)." Freeze 12/24/2014, Thaw 4/23/2015 Freeze 12/23/2015, Thaw 4/21/2016 Freeze 12/11/2016, Thaw 5/13/2017 Freeze 12/26/2017, Thaw 5/11/2018 Freeze 12/25/2018, Thaw 4/27/2019 Freeze 1/4/2020

Austin Williams Section 5.1.1 Historical Climate (page 65) What constitutes the lower Eklutna River in this statement? Is this limited to the area downstream of the confluence of This information is from the USACE's 2011 report. The USACE report did not provide any Trout Unlimited “The lower Eklutna River continues to flow throughout the Thunderbird Creek, where the overwhelming majority of the water in the Eklutna River is attributed to the Thunderbird Creek. more detailed information or specify which sections of the river continue to flow winter.” Does the lower Eklutna River flow throughout the winter because of Thunderbird Creek’s contribution, or does a portion of the throughout the winter or why. Developing this information will be considered as part of river upstream of the Thunder Bird Creek confluence still flow throughout the winter? If so, how much? the study effort. The owners' team will also work with the TWG to segment the river so we can use consistent terminology going forward.

Sean Eagan Section 5.1.2 Climate Change (page 65, Figure 5-1 Alaska Figure 5-1 is excellent, but please clarify if it is in Celsius or Fahrenheit. This figure is in Fahrenheit. This has been clarified in the Final IIP, see page 68. NMFS annual temperatures relative to 1951-1980 average, 1900- 2018)

Page 13 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Monica Keim Section 5.1.2 Climate Change (page 66) No mention of how the diversion of water away from the Lower Eklutna habitat may be affecting fire risk or risk of spruce bark- We are unaware of any existing information on this topic. Development of this information Undergraduate - APU beetle infestation. will be considered as part of the study scoping effort. Sean Eagan Section 5.1.2 Climate Change (page 66) NMFS requests that the IIP state that identifying the approximate percentage of total discharge provided by glacier melt (old ice) Additional information regarding the mass balance of Eklutna Glacier has been included in NMFS "The Eklutna Glacier is one of the glaciers that is retreating is a priority. This is not the same as melting snow that fell on the glacier the year before. If this glacier’s annual water the Final IIP, see page 68. Information regarding the percentage of total inflow to Eklutna as a result of climate change. At the current rate of contribution can be calculated, it would be helpful. Lake provided by the East and West Forks of Eklutna Creek is included in the Final IIP, see warming, scientists expect Eklutna Glacier to disappear in page 76. about 100 years, but this timeline could be cut in half with a higher warming rate (MOA, 2019)."

Rick Sinnott Section 5.1.2 Climate Change (page 66) This statement follows a discussion of the Anchorage Climate Action Plan... Hydropower is a relatively clean and cheap source of The word "alternative" was used because releasing instream flows for fish habitat would “The Eklutna Hydroelectric Project is a valuable renewable electricity, and the 1991 agreement requires that a variety of factors unrelated to fish and wildlife be included in the final be an alternative to the current project operations, and is one of the scenarios that will be energy resource that offsets approximately 86,000 tons of decision. Nonetheless, restoring fish habitat lost through hydroelectric development in Eklutna Valley is not simply one of many included in our alternatives analysis. However, to avoid the appearance of any bias, the carbon each year. The owners are therefore committed to “alternative uses” of Eklutna Lake water, it is one of the primary uses. Humans can live with a little more carbon in the second sentence has been deleted from the Final IIP, see page 68. ensuring continued compliance with the requirements of the atmosphere and we can afford to pay a little more for electricity, but fish can’t live in Eklutna River without an adequate flow of 1991 Fish and Wildlife Agreement and balancing renewable water. energy against alternative uses for Eklutna Lake water.”

Austin Williams Section 5.1.2 Climate Change (page 66) This statement shows a bias against the natural uses of the water and implies a belief, which TU emphatically does not share, As stated in Section 6 of the IIP, and based on early outreach efforts, our understanding of Trout Unlimited “The owners are therefore committed to ensuring continued that energy production and water use for fish and wildlife are incompatible. the main goals of the agencies and interested parties is to find a new balance amongst the compliance with the requirements of the 1991 Fish and uses of water in the Eklutna River basin, including power production, potable water supply, Wildlife Agreement and balancing renewable energy against and fish habitat. The purpose of this statement was to express the project owners' alternative uses for Eklutna Lake water." commitment to working with the agencies and interested parties to find that new balance by complying with the requirements of the 1991 Agreement, which requires the owners to evaluate potential PME measures and weigh the potential benefits against the potential costs/impacts to other resources and uses. However, to avoid the appearance of any bias, this sentence has been deleted from the Final IIP, see page 68.

Section 5.2 Geology

Brad Meiklejohn Section 5.2 Geology (page 67) This section is thin and should be supplemented with additional information about the geology. One recommended source is The IIP is meant to be a summary of existing information. Therefore this section presents The Conservation Fund Guidebook to the Quaternary Geology of Central and Southcentral Alaska, (Pewe, T.L., ed., 1977) an overview of the geology of the Eklutna Valley. If it is determined that more detailed information is needed to support the study effort, then compilation and review of this information will be considered for inclusion in the study program.

Brad Meiklejohn Section 5.2.1 Glacial Influence (page 67) It would be helpful to better establish the glacial history of the Eklutna Valley. See Geometry, mass balance, and thinning of the The IIP is meant to be a summary of existing information. Therefore this section presents The Conservation Fund "The valley was formed by the powerful abrasive action of Eklutna Glacier, Alaska, Journal of Glaciology 2017, Sass, Loso, Geck, Thomas and McGrath. an overview of glacial influence on the Eklutna Valley. If it is determined that more detailed the Eklutna Glacier, which formerly extended down the full information is needed to support the study effort, then compilation and review of this length of the valley to its junction with the main valley of the information will be considered as part of the study scoping effort. Knik River (USBR, 1948)." Sean Eagan Section 5.2.4 Eklutna River Canyon (page 68) NMFS does agree that there is an Eklutna River gorge or canyon as the river cuts through bedrock in the mile just above the old This has been clarified in the Final IIP, see page 71. NMFS "Since the retreat of the glacier, the Eklutna River has dam site. The six miles below the upper dam where the river is incising its way through ancient lake beds, is more of a river valley excavated a narrow, inner gorge through the fill of glacial than a canyon. NMFS requests that when referring to this six mile section the term “river valley” be used rather than “canyon”. debris (Figure 5-2). The gorge ranges from a depth of about fifty feet or less adjacent to the lake to over five hundred feet about five miles downstream." Sean Eagan Section 5.2.4 Eklutna River Canyon (page 68) The IIP should discuss the large alluvial fans which enter Eklutna River valley predominantly from the north side and push the Reference to these alluvial fans has been included in the Final IIP, see page 71. NMFS river channel South. How these fans/debris flow respond to a changing climate will be instrumental in whether salmon Development of additional geomorphology information will be considered by the TWG restoration succeeds. during the scoping of the geomorphology/sediment transport component of the study program. Sean Eagan Section 5.2.4 Eklutna River Canyon (page 68) Past rockfall in the canyon created two partial barriers to salmon passage just below the lower dam in 2017. Understanding the Reference to these rock falls has been included in the Final IIP, see page 72. Development NMFS frequency of these rockfall events and the likelihood of them creating new fish barriers would be helpful. It would also be helpful of additional information regarding the rockfalls will be considered as part of the study to understand how long a rockfall event remains a barrier with normal flushing flows frequency and without flushing flows. scoping effort. NMFS requests this information be included in the planned studies.

Page 14 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Michael Knapp Section 5.2.5 Sediment Accumulation behind Lower Dam The USACE concern about potential physical and biological harm is not well explained. How does the USACE define “adequate” The USACE did not define in their report what an adequate flushing flow would be. ADOT&PF (page 68) when it comes to flushing flows, and what does it view to be the objective of flushing flows? (100% removal of accumulated Consideration of flushing and channel maintenance flows will be considered as part of the "In 2011 the USACE stated that removing the lower dam and sediments from the Eklutna River system to the Knik River?) study scoping effort. releasing this accumulated sediment into the river without adequate flushing flows could do more physical and biological harm than good by degrading the existing fish habitat downstream even further (USACE, 2011).”

Brad Meiklejohn Section 5.2.5 Sediment Accumulation behind Lower Dam [This statement] is taken out of context. This report preceded the actual dam removal by six years. This statement seems to be The purpose of this statement is to document that the USACE had previously expressed The Conservation Fund (page 68) included to suggest that the removal of the lower dam caused more biological harm than good because of the absence of concern on this issue. The IIP accurately states that this statement is from a 2011 report, "In 2011 the USACE stated that removing the lower dam and flushing flows. There is no evidence that has turned out to be the case, despite the fact that the proponents of the lower dam several years prior to the actual dam removal project. The IIP subsequently states that a releasing this accumulated sediment into the river without removal have repeatedly requested that the Eklutna Purchasers provide flushing flows. USACE permitted the lower dam removal sediment transport model was developed by HDR in 2016 which concluded that generally adequate flushing flows could do more physical and and was satisfied that doing so in the absence of flushing flows would ultimately be beneficial, not detrimental, to the biology all sediment gradations would be transported out of the sediment plug within biological harm than good by degrading the existing fish and hydrology of the Eklutna River. We suggest that this sentence taken from the 2011 USACE report be deleted here. approximately 1-2 years under the current flow regime. The USACE permitted the dam habitat downstream even further (USACE, 2011)." removal project based on that sediment transport model and required Eklutna, Inc. to conduct sediment transport monitoring at the downstream bridges and aquatic habitat monitoring at 3 locations downstream of the lower dam for 3 years post-dam removal as stated in the IIP. It's our understanding that these monitoring efforts are still ongoing, and although we have seen some preliminary results for the aquatic habitat monitoring (which are included in the IIP), we have not seen any of the results of the sediment transport monitoring yet. Therefore, we cannot make any final conclusions yet regarding any impacts to downstream habitat that may have occurred as a result of the lower dam removal.

Aaron Leggett Section 5.2.5 Sediment Accumulation behind Lower Dam The statement is taken out of context, as this report preceded the actual dam removal by six years. This statement seems to be The purpose of this statement is to document that the USACE had previously expressed Native Village of Eklutna (page 68) included to suggest that the removal of the lower dam caused more biological harm than good because of the absence of concern on this issue. The IIP accurately states that this statement is from a 2011 report, "In 2011 the USACE stated that removing the lower dam and flushing flows. There is no evidence that has turned out to be the case, despite the fact that the proponents of the lower dam several years prior to the actual dam removal project. The IIP subsequently states that a releasing this accumulated sediment into the river without removal have repeatedly requested that the Eklutna Purchasers provide flushing flows. USACE permitted the lower dam removal sediment transport model was developed by HDR in 2016 which concluded that generally adequate flushing flows could do more physical and and was satisfied that doing so in the absence of flushing flows would ultimately be beneficial, not detrimental, to the biology all sediment gradations would be transported out of the sediment plug within biological harm than good by degrading the existing fish and hydrology of the Eklutna River. NVE agrees that this sentence taken from the 2011 USACE report be deleted here. approximately 1-2 years under the current flow regime. The USACE permitted the dam habitat downstream even further (USACE, 2011)." removal project based on that sediment transport model and required Eklutna, Inc. to conduct sediment transport monitoring at the downstream bridges and aquatic habitat monitoring at 3 locations downstream of the lower dam for 3 years post-dam removal as stated in the IIP. It's our understanding that these monitoring efforts are still ongoing, and although we have seen some preliminary results for the aquatic habitat monitoring (which are included in the IIP), we have not seen any of the results of the sediment transport monitoring yet. Therefore, we cannot make any final conclusions yet regarding any impacts to downstream habitat that may have occurred as a result of the lower dam removal.

Page 15 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Rick Sinnott Section 5.2.5 Sediment Accumulation behind Lower Dam This is another quote from an expert agency that should be put in context. Yes, there were and are serious concerns about The owners have identified a list of prerequisites that need to be addressed in order to (page 68) flushing the accumulated sediment downstream. But if the goal is to restore fish habitat in the river, the lower dam had to be consider the release of flushing and other flows as part of the study program. The owners “In 2011 the USACE stated that removing the lower dam and removed. In the short term, accumulated sediment is likely to degrade downstream fish habitat. But that concern doesn’t are committed to working through this list of prerequisites with the TWG and other releasing this accumulated sediment into the river without acknowledge the long-term benefit to fish habitat of removing the dam. The U.S. Corps of Engineers (USACE) concurred with the relevant agencies/entities. adequate flushing flows could do more physical and dam’s removal after reviewing the details describing how and when it was to be accomplished. With regard to flushing flows, it biological harm than good by degrading the existing fish should be noted that the Producers seem to be dragging their feet on releasing water from the lake to flush sediments. Pursuant habitat downstream even further (USACE, 2011).” to the 1991 agreement, agencies have requested the release of several flushing flows to better assess potential habitat in the river canyon. This information would be used to design the study plans that the agencies are tasked with. The 1991 agreement requires cooperation from the producers in conducting necessary fieldwork. Yet, in their February 2020 presentation to the Anchorage Assembly, the Producers insisted that flow releases were “not allowed” because “major change affecting water usage or fish and wildlife [was] expressly prohibited prior to following process prescribed in 1991 Agreement.” This is a disingenuous and egregious interpretation of the provisions of the 1991 agreement, which was a contractual agreement to cooperate on protection, mitigation and enhancement of fish and wildlife in Eklutna Valley... The authors of the draft IIP are not at fault here, as they are undoubtedly reporting the opinions of the Producers. The authors of the draft IIP should ask the Producers to identify the source of this opinion and, in all fairness, cite the reasons why the Producer’s opinion appears to be self-serving.

Michael Knapp Section 5.2.5 Sediment Accumulation behind Lower Dam My recollection is that The Conservation Fund was either unwilling to fund or lacked the funds to remove accumulated The IIP lists "excessive cost" as one of the reasons why Eklutna, Inc. determined that ADOT&PF (page 69) sediments from the canyon. Given that most of the material from behind the dam is embanked along the sides of the channel, removal of all the accumulated sediment from behind the lower dam was not practical or “As part of the alternatives analysis for the lower dam the HDR prediction highlighted above clearly did not come to pass. feasible. HDR developed a sediment transport model in 2016 which concluded that removal project, Eklutna, Inc. considered several options for generally all sediment gradations would be transported out of the sediment plug within removing the accumulated sediment from the canyon. approximately 1-2 years post dam removal under the current flow regime. The lower dam Ultimately, Eklutna, Inc. determined that none of these removal project was completed in 2018. The owners' team conducted a site options were practical and feasible due to excessive cost, reconnaissance in August 2019 and agrees that there still appears to be a large amount of challenging logistics, and additional impacts to the Eklutna sediment behind the lower dam site. However, to the best of our knowledge the amount River... A sediment transport model was developed by HDR of sediment still behind the lower dam site has not been quantified. Development of this in 2016. The model concluded that generally all sediment information will be considered by the TWG during the scoping of the gradations, other than the coarsest armor layer, would be geomorphology/sediment transport component of the study program. transported out of the sediment plug within approximately one to two years under the current flow regime with the finer sediments generally conveyed through the Eklutna River reach and into the Knik Arm.”

Sean Eagan Section 5.2.5 Sediment Accumulation behind Lower Dam NMFS requests clarity and further explanation on ADOT&PF’s concern that redistributing a portion of the 230,000 cy Since 1955 when the Federal hydro project was constructed, the New Glenn Highway has NMFS (page 69) downstream will drastically change the channel and undermine the bridge piles. 300,000 cubic yards of sediment accumulated been constructed (1975) and the Old Glenn Highway bridge at Eklutna has been replaced "During the planning phase of the lower dam removal behind the lower dam annually around 1948, and yet only 230,000 cubic yards (cy) existed there prior to dam removal. Large (2016). Therefore, the downstream infrastructure that existed prior to 1955 is different project, both the Alaska Railroad and the Alaska Department volumes of sediment must have passed over the full lower dam annually prior to 1955. It is the cessation of large river flow by than the downstream infrastructure that exists today. It's our understanding that ARRC's of Transportation and Public Facilities (ADOT&PF) expressed the 1955 structure that set the stage for the current sediment conundrum rather than the removal of the lower dam in 2018. and ADOT's concerns are related to large amounts of sediment being flushed down the concern about potential impacts to the downstream bridges There is likely a large “surplus” of sediment in the 6 miles above the gorge as the day-to-day work of moving sediment performed river at one time, and that HDR noted in their 2016 report that there was a lot of from the large amount of accumulated sediment that would by a typical river draining 123 square miles did not happen for the last 65 years. Please provide more information. uncertainty involved in the analysis of their sediment transport model. An evaluation of be flushed downstream and potentially accumulate at the potential impacts to downstream infrastructure is included in the study program. bridges..."

Brad Meiklejohn Section 5.2.5 Sediment Accumulation behind Lower Dam Eklutna Inc. should be asked to provide for inclusion here the results of the monitoring of the Glenn Hwy bridges that to date As stated in the IIP, Eklutna, Inc. has committed to providing the results of their monitoring The Conservation Fund (page 69) show no significant accumulation of sediment at the bridges nor scour of the bridge abutments. effort when available. We look forward to reviewing the results and will share the final "As conditioned by the Section 404 Permit, Eklutna, Inc. was report on the project website for easy access. required to entirely remove all temporary fill following completion of construction activities and to conduct three years of sediment transport monitoring at the downstream bridges (ADEC, 2017; USACE, 2017). Eklutna, Inc. has committed to providing the results when available."

Page 16 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Aaron Leggett Section 5.2.5 Sediment Accumulation behind Lower Dam [Eklutna, Inc.] should be asked to provide for inclusion here the results of the monitoring of the Glenn Hwy bridges that to date As stated in the IIP, Eklutna, Inc. has committed to providing the results of their monitoring Native Village of Eklutna (page 69) show no significant accumulation of sediment at the bridges nor scour of the bridge abutments. effort when available. We look forward to reviewing the results and will share the final "As conditioned by the Section 404 Permit, Eklutna, Inc. was report on the project website for easy access. required to entirely remove all temporary fill following completion of construction activities and to conduct three years of sediment transport monitoring at the downstream bridges (ADEC, 2017; USACE, 2017). Eklutna, Inc. has committed to providing the results when available."

Michael Knapp Section 5.2.5 Sediment Accumulation behind Lower Dam Without any flows of significance since the lower dam was removed, one should not expect to find significant geomorphic Comment noted. Additional sediment transport modeling will be considered by the TWG ADOT&PF (page 69) change or aggradation occurring near the bridges in these monitoring reports. Sediment transport rates will increase with flow during the scoping of the geomorphology/sediment transport component of the study “As conditioned by the Section 404 Permit, Eklutna, Inc. was increases. program. required to entirely remove all temporary fill following completion of construction activities and to conduct three years of sediment transport monitoring at the downstream bridges (ADEC, 2017; USACE, 2017). Eklutna, Inc. has committed to providing the results when available.”

Austin Williams Section 5.2.6 Thunderbird Creek and Falls (page 69) Thunderbird Creek and Thunderbird Falls are introduced with minimal information. At current, Thunderbird Creek is critical to The purpose of this subsection within the overall Geology section is to simply introduce Trout Unlimited "Thunderbird Creek, the Eklutna River’s largest tributary, the lower reaches and fish habitat of the Eklutna River since it is the largest reliable source of water. This section should be Thunderbird Creek and Falls as geologic features. Available flow data is summarized and enters the left bank of the Eklutna River about one mile expanded with more information quantifying Thunderbird Creek’s contributions, such as a new table displaying average flows of presented in Section 3.0 Water Resources, and discussion regarding Thunderbird Falls as a downstream from the lower dam site. There is a 200-foot-tall Thunderbird Creek, average flows of the Eklutna River upstream of the confluence, and average flows of the combined Eklutna fish barrier is presented in Section 4.0 Fish and Aquatic Resources. To the best of our waterfall on Thunderbird Creek about one-third of a mile River. knowledge there is no available gage data for Thunderbird Creek. However, NVE has upstream from its confluence with the Eklutna River (USACE, previously estimated flows for Thunderbird Creek by subtracting the flow measured in the 2011)." Eklutna River above the confluence with Thunderbird Creek from the flow measured in the Eklutna River below the confluence with Thunderbird Creek. This information has been included in the Final IIP, see page 88.

Brad Meiklejohn Section 5.2.6 Thunderbird Creek and Falls (page 69) It would be useful to have information about the volume of water contributed by Thunderbird Creek. The purpose of this subsection within the overall Geology section is to simply introduce The Conservation Fund Thunderbird Creek and Falls as geologic features. Available flow data is summarized and presented in Section 3.0 Water Resources, and discussion regarding Thunderbird Falls as a fish barrier is presented in Section 4.0 Fish and Aquatic Resources. To the best of our knowledge there is no available gage data for Thunderbird Creek. However, NVE has previously estimated flows for Thunderbird Creek by subtracting the flow measured in the Eklutna River above the confluence with Thunderbird Creek from the flow measured in the Eklutna River below the confluence with Thunderbird Creek. This information has been included in the Final IIP, see page 88.

Aaron Leggett Section 5.2.6 Thunderbird Creek and Falls (page 69) It would be useful to have information about the volume of water contributed by Thunderbird Creek. This can be found in the The purpose of this subsection within the overall Geology section is to simply introduce Native Village of Eklutna NVE Application for Reservation of Water, Thunderbird Creek. Thunderbird Creek and Falls as geologic features. Available flow data is summarized and presented in Section 3.0 Water Resources, and discussion regarding Thunderbird Falls as a fish barrier is presented in Section 4.0 Fish and Aquatic Resources. To the best of our knowledge there is no available gage data for Thunderbird Creek. However, NVE has previously estimated flows for Thunderbird Creek by subtracting the flow measured in the Eklutna River above the confluence with Thunderbird Creek from the flow measured in the Eklutna River below the confluence with Thunderbird Creek. This information has been included in the Final IIP, see page 88.

Sean Eagan Section 5.2.7 Alluvial Fan (page 70) The railroad’s speculation that the 230,000 cubic yards behind the old dam caused the shoreline erosion may be partially correct, Comment noted. A geomorphology and sediment transport study has been included in the NMFS "The Alaska Railroad speculates that the entrapment of sand but the IIP should also acknowledge that the entire nine miles has more sediment storage because the river has not had the proposed study program. and gravel behind the lower dam may have caused Knik Arm power to move much sediment for 65 years. Gravel mining is also a contributing factor. The six spills may partially “catch up” shoreline erosion that required the Alaska Railroad rail bed sediment movement. to be moved in 1968." Section 5.3: Water Resources

Page 17 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Brad Meiklejohn Section 5.3 Water Resources (page 72) It would be useful to have a more detailed map and description of the reaches of the Eklutna River and details about where Development of this information will be considered by the TWG during the review of The Conservation Fund seeps, springs and creeks contribute flow with an estimate of volume for each. proposed study plans. Brad Meiklejohn Section 5.3 Water Resources (page 72) More detail is needed on the significance of the Eklutna River as a major clear water river in Upper Cook Inlet. At normal flows, We are not aware currently of any documentation regarding the potential historic The Conservation Fund the Eklutna River is one of the largest (and is possibly the largest) clear water river in Upper Cook Inlet. significance of the Eklutna River as a major clear water river in the Upper Cook Inlet.

Tom Barret Section 5.3.1 Watershed and Drainage Area (page 72) Add discussion of forecasted glacial melt and possible effects on hydrologic contribution to the lake. An analysis of glacier retreat Additional information regarding the Eklutna Glacier has been added to the Final IIP, see ADNR - Water Resources "The east and west forks of Eklutna Creek are the two over 20+ years might be helpful in assessing potential future shortages. Incidents of river “piracy” have been noted in the upper page 68. primary sub-basins above Eklutna Lake and account for Yukon, where glaciers have retreated entirely from a watershed. about 80% of the lake’s inflow. The drainage areas of the east and west forks are 38.9 and 24.7 square miles respectively. The east fork has a few unnamed cirque glaciers within the watershed, accounting for approximately 12% of the drainage area. The west fork is dominated solely by the Eklutna Glacier, which occupies more than 46% of the drainage area (Larquier, 2010; USGS, 1993)."

Sean Eagan Section 5.3.1 Watershed and Drainage Area (page 72) The Eklutna Lake drainage area is listed both as 123 and 119 square miles in subsequent paragraphs. NMSF seeks clarity on This has been corrected and clarified in the Final IIP, see page 76. NMFS "Eklutna Lake has a length of 7 miles, a width of 1 mile, an which number is correct. average depth of 120 feet, and a drainage area of approximately 123 square miles to the outlet (NWS, undated; USGS, 2020)… Eklutna Lake's drainage comprises approximately 119 square miles of the total 174 square miles of the overall Eklutna watershed... (Section 905b Study)." Brad Meiklejohn Section 5.3.2 Hydrology (page 73) A number of historical photos exist of the Eklutna River and Eklutna Lake during the 1940’s and 1950’s. Many of these have been Additional historical photos of Eklutna River and Eklutna Lake have been included in the The Conservation Fund collected by Crane Johnson of NOAA, and a sample of these are attached here at the end of this comment letter. Some or all of Final IIP. However, please note that the lake level and flow regime in the 1940s and 1950s these should be included as they provide a rare glimpse of what natural conditions look like for this lake and river. was regulated to some extent by a storage dam at the lake outlet, and therefore do not represent the natural conditions. Sean Eagan Section 5.3.2 Hydrology (page 73, Table 5-1 Annual Flow of [These estimated flows] are about twice the water usage from 2010 to 2019 (Table 4-1). Is one set of numbers inaccurate or was It is unclear why the early estimates from 1924-1928 are almost double the water usage NMFS Eklutna River in Acre-Feet form 1924-1928) 1924 - 1928 a series of wet years? It is unclear if Thunderbird Creek’s contribution is included in the early estimates. NMFS from 2010 to 2019. However, as stated in the IIP, AL&P installed their staff gage at the requests clarity on this. mouth of the canyon about half a mile above the railroad crossing. Therefore, it can be assumed that Thunderbird Creek's contribution was included in the early estimates.

Sean Eagan Section 5.3.2 Hydrology (page 76, Figure 5-6 Eklutna River While this is an excellent figure, gage 1520100 seems to be missing from the map. Gage 1520100 has been added to the figure in the Final IIP, see page 81. NMFS Sub-basins and Stream Gage Locations) Sean Eagan Section 5.3.2 Hydrology (page 79) Does this indicate substantial seepage through the dam until the water level hits a certain level mid February and then the Further investigation to answer these questions will be considered for inclusion in the NMFS “Mean daily flows from 1955-1962 typically remain steady seepage mostly stops leaving the channel mostly dry? What are other explanations? study program. at a range of 15-20 cfs from mid-October through mid- February. From mid-February through late July, flows decrease to a range of 3.8 cfs to 0.0 cfs.”

Monica Keim Section 5.3.3 Water Quality (page 82) Should water chemistry of the lake be taken into account when allowing spill over for salmon? Yes, it is our opinion that water chemistry of the lake should be taken into account when Undergraduate - APU evaluating potential flow releases. Sean Eagan Section 5.3.3.1 Turbidity, Dissolved Solids, and Suspended The presented turbidity data and discussion is primarily from the lake and the tailrace; neither is where we are hoping to create An evaluation of turbidity in the Eklutna River as it might affect alternative PME measures NMFS Sediment (page 85) fish habitat. The Eklutna River is extremely turbid on certain days. This turbidity is acknowledged by others on pages 95 - 97 and will be considered by the TWG for inclusion in the study program and subsequent PME section 5.4.3.4. The source of this turbidity has not been determined. Whether or not we need to mitigate it to restore fish alternatives analysis. habitat, is not yet determined. However, we must acknowledge that the turbidity will create a challenge for creating quality fish habitat. NMFS requests this acknowledgement be in the IIP.

Sean Eagan Section 5.3.3.5 pH, Dissolved Oxygen (DO), and Temperature While water temperature data circa 1950 and from the early 1980’s is interesting, those temperatures are not something we can Acquiring current temperature data will be considered by the TWG for inclusion in the NMFS (page 86) or should strive to recreate. The climate has changed (page 65) and lake and stream temperature are likely warmer now and will study program. continue to increase. NMFS recommends the IIP acknowledge it is unlikely we can mimic old temperature data.

Page 18 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Brad Meiklejohn Section 5.3.4 Water Rights (page 87) More discussion is needed here on historical water rights that pertained to the operation of the Lower Eklutna Dam. Were water In 1928 the FPC issued a license to Frank Reed authorizing "the occupancy and/or use by The Conservation Fund rights an issue at the time the Lower Eklutna Dam was built? Did Frank Reed claim the water rights that allowed him to operate the Licensee of said lands of the United States and of all riparian rights appurtenant AL&P? Did these water rights get sold to the City of Anchorage? Did these water rights get sold by the City of Anchorage to the thereto which are necessary or useful for the purposes of the project". This text has been USBR? Was the Lower Eklutna power facility purchased by USBR to resolve the question of water rights? Water rights are a included in the Final IIP, see page 25. Because the early hydropower project was threshold question in this process, and probably warrant their own section of investigation in Section 7. constructed pre-statehood, it's our understanding that no additional water rights were needed at that time. Additional information regarding the transfer of the license to the City of Anchorage, and the contractual agreement between the City of Anchorage and USBR is included in Section 3 of the Final IIP.

Brad Meiklejohn Section 5.3.4 Water Rights (page 87) Early in the process, Dave Schade of the AKDNR water rights section raised the prospect that the Eklutna Purchaser’s water right The project owners acknowledge that coordination with ADNR regarding water rights The Conservation Fund did not allow them to release water down the river in an “unproductive manner.” We have also heard the Eklutna Purchasers say might be needed if changes to the current flow regime are included in the eventual Fish similar things in recent meeting of the parties to the 1991 Agreement. Does the Eklutna Purchaser’s water right need to be and Wildlife Program. amended? Is that possible? Sean Eagan Section 5.3.4 Water Rights (page 87) If the priority date on the water right is December 31, 1954, it seems that would have been based on the original dam location Review of historic aerial photos appears to indicate that Lach Q'atnu Creek was diverted NMFS "In 1977, pursuant to AS 46.15.060, the State of Alaska 1,400 feet up the lake. Were the water rights adjudicated more recently to include Thachkatnu Creek, which was captured in prior to 1950. Further research into the current status of the water rights for the project recognized this federal reservation and the APA’s primary 1962, and any intermittent streams captured when the new (3rd) dam was built post earthquake in 1965? will be considered in the study program. water right in the Eklutna River watershed in its Certificate of Appropriation ADL 44944 (State of Alaska, 1977). The State of Alaska granted the water right a priority date of December 31, 1954 and allowed the APA to divert any and all of the natural inflow into Eklutna Lake for hydroelectric generation." Tom Barret Section 5.3.4 Water Rights (page 87) Suggest changing third sentence to “However, based on a 1984 compensation agreement between AWWU and APA, ADNR did This has been edited in the Final IIP, see page 95. ADNR - Water Resources "However, ADNR did grant AWWU a 41.0 mgd water right grant AWWU Permit LAS 2569 to divert 41 mgd from the existing appropriation to APA under ADL 44944 provided the maximum through LAS 2569 if the AWWU and APA could share the daily AWWU diversion did not exceed 72 mgd on any single day. APA’s water right, ADL 44944, was subsequently amended to annual allocation of water from Eklutna Reservoir (ADNR, address the diversion as follows:” Start new Paragraph “Utilizing....” 1985b)." Sean Eagan Section 5.3.4 Water Rights (page 87) Has anyone filed a water right for the river segment and any tributaries that enter Eklutna below the upper dam but above Not that we are aware of. NMFS "NVE has applied for three water rights to create instream AWWU aqueduct exit? The three water rights filed by NVE in 2003 for the salmon seem to request water downstream from the flow reservations for the protection of fish and wildlife AWWU aqueduct outlet. habitat, migration, and propagation (ADNR, 2003a; ADNR 2003b; and ADNR, 2003c). Specifically, application LAS 24335 is for segment 1 of the Eklutna complex which starts at the exit of the AWWU aqueduct in the Eklutna River canyon and continues downstream approximately 3 miles to the confluence with Thunderbird Creek. Application LAS 24334 is for segment 2 of the Eklutna complex. Segment 2 is delineated as Thunderbird Creek from the first major tributary draining Mount Eklutna and Bear Mountain, downstream to the confluence with the Eklutna River. Application LAS 24336 is for segment 3 of the Eklutna complex which starts at the confluence of Thunderbird Creek and flows downstream approximately 3 miles its terminus at the Knik Arm of Cook Inlet."

Brad Meiklejohn Section 5.3.4 Water Rights (page 87) It would be useful to have more discussion of water rights as they relate to the Native Village of Eklutna (NVE), the timing of We are unaware of any existing documentation that would answer your specific questions. The Conservation Fund ANCSA and the federal recognition of NVE as a tribe. How is it that the people who have been living in the Eklutna Valley for However, the project owners are committed to consulting with NVE throughout the thousands of years, whose presence there is well documented, who own nearly all the land along the Eklutna River and around process outlined in the 1991 Fish and Wildlife Agreement. Eklutna Lake, were not consulted or considered when water rights were granted?

Aaron Leggett Section 5.3.4 Water Rights (page 87) It would be useful to have more discussion of water rights as they relate to the Native Village of Eklutna, the timing of ANCSA and We are unaware of any existing documentation that would answer your specific questions. Native Village of Eklutna the federal recognition of NVE as a tribe. How is it that the people who have been living in Eklutna for thousands of years, and However, the project owners are committed to consulting with NVE throughout the who own nearly all the land along the Eklutna River and around Eklutna Lake, were not consulted or considered when water process outlined in the 1991 Fish and Wildlife Agreement. rights were granted?

Page 19 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Section 5.4: Fish and Aquatic Resources

Brad Meiklejohn Section 5.4 Fish and Aquatic Resources (page 89) Some discussion is needed of the marine and estuarine environment of Knik Arm and Upper Cook Inlet, and the impacts the Information regarding Cook Inlet beluga whales has been included in the Final IIP, see page The Conservation Fund project may have had on marine species, including Beluga Whale, federally listed as an endangered species. Beluga whales are 114. regularly sited in upper Knik Arm in the vicinity of the mouth of the Eklutna River, apparently foraging on salmon. Surveys of Beluga whales in upper Knik Arm were conducted by the Eklutna Tribe. It is likely that Beluga whales are impacted by the decline of salmon populations in the Eklutna River. Aaron Leggett Section 5.4 Fish and Aquatic Resources (page 89) This might be the section in which to include discussion of impacts from Eklutna hydro project development as contributive to Information regarding Cook Inlet beluga whales has been included in the Final IIP, see page Native Village of Eklutna the cumulative impacts on the population of now endangered Cook Inlet Beluga whales. Knik Arm is CI Beluga critical habitat, 114. and with decreasing salmon runs in the area, restoring Eklutna runs would boost CI beluga recovery efforts.

Brad Meiklejohn Section 5.4.1 Historic Salmon Runs (page 89) Once again we find a biased statement that seems intended to cast doubt on the presence of a sockeye run in Eklutna Lake. This phrase is referring to the purpose of the study conducted by Loso et al., published in The Conservation Fund "Prior to 2000, the written record and systematic study of There is no reason to doubt the statements made at the time of the sale, nor is there an alternate explanation for the continued 2019. That report states "our question is whether there was an anadromous salmon run salmon returning to the Eklutna River is limited and presence of landlocked sockeye salmon (aka kokanee). Prior to the 1929 dam, there were no barriers to sockeye reaching the into Eklutna Lake prior to 1929." The text in the Final IIP reflects the exact quote, see page inconclusive. However, recent studies have been conducted lake. Despite the degraded condition of the river, sockeye salmon still return to the Eklutna River. The preponderance of 98. to try to answer the question about whether or not there evidence should be interpreted to support the historic presence of sockeye, rather than their absence. What is indisputable is was once a sockeye salmon run into Eklutna Lake prior to that current operations of the Eklutna Project are responsible for preventing sockeye, and any of the other four species of 1929 when the lower dam was constructed by AL&P. There salmon, as well as Dolly Varden, from moving upriver beyond the lower dam site. are also oral histories from Eklutna village elders regarding the historic presence of salmon in the Eklutna River and Eklutna Lake. Both the recent studies and oral histories are summarized below."

Aaron Leggett Section 5.4.1 Historic Salmon Runs (page 89) This statement could be interpreted as to cast doubt on the presence of a sockeye run in Eklutna Lake. There is no reason to This phrase is referring to the purpose of the study conducted by Loso et al., published in Native Village of Eklutna "Prior to 2000, the written record and systematic study of doubt the statements made at the time of the sale, nor is there an alternate explanation for the continued presence of 2019. That report states "our question is whether there was an anadromous salmon run salmon returning to the Eklutna River is limited and landlocked sockeye salmon (aka kokanee). Prior to the 1929 dam, there were no barriers to sockeye reaching the lake. Despite into Eklutna Lake prior to 1929." The text in the Final IIP reflects the exact quote, see page inconclusive. However, recent studies have been conducted lack of access to the lake, sockeye salmon still return to the Eklutna River. The preponderance of evidence should be interpreted 98. to try to answer the question about whether or not there to support the historic presence of sockeye, rather than their absence. And, current operations of the Eklutna Project are was once a sockeye salmon run into Eklutna Lake prior to responsible for preventing sockeye, and any of the other four species of salmon, upriver beyond the former lower dam site. 1929 when the lower dam was constructed by AL&P. There are also oral histories from Eklutna village elders regarding the historic presence of salmon in the Eklutna River and Eklutna Lake. Both the recent studies and oral histories are summarized below."

Aaron Leggett Section 5.4.1 Historic Salmon Runs (page 89) A 1931-1934 study by Cornelius Osgood, published in 1976 by Yale University reported that: Dena’ina (Tanaina) of Upper (Cook) Comment noted. We were unable to locate this study report. Native Village of Eklutna Inlet caught and ate Humpback salmon, Dog salmon, Silver salmon, Red salmon, King salmon, and Candlefish locally (Pg. 27). One of the primary informants who Osgood worked with was an Eklutna person. And, the Eklutna Village word for the month of June means “King Salmon Run” (Pg. 16). Aaron Leggett Section 5.4.1 Historic Salmon Runs (page 89) A study by the Alaska Department of Fish and Game, Division of Subsistence, Technical Paper Number 25 by James A. Fall, This information has been added to the Final IIP, see page 98. Native Village of Eklutna published in 1981 states: “Five species of salmon spawn in the drainage systems of Knik Arm.” And, “Salmon have historically spawned in many drainage systems of Knik Arm, including those of the Eagle River, Eklutna River, Knik River, Matanuska River, Wasilla Creek, Cottonwood Creek, and Fish Creek.” Aaron Leggett Section 5.4.1.1 Recent Studies (page 89) With regards to the sensitivity test, for how many salmon could have historically left nitrogen isotopes in the lake sediments that The text in the IIP is a direct quote from the study report, see page 98. Native Village of Eklutna "However, a sensitivity test was conducted to assess the were missed, up to 1,000 per year and potentially as many as 15,000 per year are two different statements, and the first number possibility that a small salmon run may have gone is superseded. One of the authors of the study wrote: “Employing a simple sensitivity test, Finney found that Eklutna Lake could undetected by the isotopic analysis. It was determined that a have hosted as many as 15,000 spawning sockeye salmon without being detected by the isotopic analysis, which has a margin of salmon run of up to 1,000 per year, and potentially as many error of plus/minus 0.2 percent. Our results do not demonstrate that such runs existed, but neither can our results be construed as 15,000 per year, would be possible without noticeably as evidence that they did not.” - Rick Sinnott, Anchorage Daily News, 12/3/2017. altering the measured isotopic composition of the sediments in Eklutna Lake. Therefore, the results provide no evidence that such runs occurred, but do not preclude the possible existence of a relatively small sockeye fishery in Eklutna Lake before 1929 (Loso et al, 2019)."

Page 20 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Brad Meiklejohn Section 5.4.1.1 Recent Studies (page 89) It is conceivable that Eklutna Lake in the 1920’s was just beginning to be hospitable to sockeye salmon as the Eklutna Glacier Comment noted. The 1941 photo of Eklutna Lake has been included in the Final IIP, see The Conservation Fund "In their 2011 report, the USACE stated that it’s doubtful that receded and sediment loads in the lake decreased. The aerial photo of Eklutna Lake from 1941 (attached) suggests the lake was page 35. significant numbers of sockeye salmon ever spawned in the much siltier than present, and the foreground of this photo shows a landscape that appears to only recently have been Eklutna River drainage because suitable spawning area deglaciated. Better establishing the glacial history of the Eklutna Valley would be helpful to include in the IIP. The 1941 aerial upstream of the lake is limited and water quality in the lake photo also shows that original drainage of Thachkatnu Creek before it was diverted. would likely have limited opportunities for spawning in the littoral zone of the lake."

Aaron Leggett Section 5.4.1.1 Recent Studies (page 89) [This] should not be cited as a recent study. Opportunities for spawning in the littoral zone of the Lake should be investigated. Information from the 2011 USACE report has been included in the IIP as existing Native Village of Eklutna "In their 2011 report, the USACE stated that it’s doubtful that The potential for successful spawning in the Eklutna River and its forks that feed Eklutna Lake also requires further investigation. information from a Federal regulatory agency. An assessment of potential spawning significant numbers of sockeye salmon ever spawned in the habitat in Eklutna Lake and its tributaries is included in the proposed lake aquatic habitat Eklutna River drainage because suitable spawning area and fish utilization study component of the study program. upstream of the lake is limited and water quality in the lake would likely have limited opportunities for spawning in the littoral zone of the lake."

Nabi Qureshi Section 5.4.1.1 Recent Studies (page 89) [This] expresses doubts of historical salmon, due to the limited availability of suitable salmon habitat because of the turbidity of The additional information from USACE's 2004 report has been included in the Final IIP, The Alaska Center "Eighty percent of the water entering Eklutna Lake comes the streams. While this is correct, I think it is worth noting that USACE’s 2004 Section 905(b) (WRDA 86) analysis on the Eklutna see page 98. from two turbid glacial streams that would not be conducive Watershed states: “Many significant sockeye systems in Alaska, however, are predominantly glacial fed similar to Eklutna Lake. to the consistent survival of sockeye salmon from egg to fry. Physical limnology studies of Eklutna Lake suggest that the turbidity in Eklutna Lake is not conducive to significant primary The remaining available and suitable spawning area would production during much of the year. However, in some instances, sockeye have been found to spawn and rear at great depths in not be sufficient to support large numbers of spawning glacial systems. While these systems are more turbid and not as conducive to significant primary production, they do support anadromous salmon. In addition, the physical limnology stable fish runs.” (USACE 2004, p.19). Furthermore, the context of which the USACE and Loso et al reports are addressed in studies of Eklutna Lake suggest that the turbidity in Eklutna comparison to one another is misleading. The USACE 2011 report doubts a significant primary production of salmon, but the Lake during much of the year is not conducive to significant salmon run of 1000 to 15000 that could have gone undetected in the Loso et al study would not necessarily be considered a primary production (USACE, 2011)." significant run (USACE, 2011; Loso et al, 2017). Regardless, the presence of historical salmon in the Eklutna River needs to be acknowledged properly.

Aaron Leggett Section 5.4.1.1 Recent Studies (page 89) Around 2001, an ADFG salmon Biologist looked at the turbid Eklutna River above Thunderbird Creek (where discharge under 10 Comment noted. Development of this information is included in the proposed water Native Village of Eklutna "In addition, the physical limnology studies of Eklutna Lake cfs is the norm) and said no salmonids could survive in it. However, NVE salmon count surveys found chum spawn there in quality study component of the study program. suggest that the turbidity in Eklutna Lake during much of the profusion and coho also spawn there. Salmon adapt to conditions in these Alaska rivers. Current primary productivity in Eklutna year is not conducive to significant primary production Lake could be inhibited by extreme lake level fluctuations to optimize the power generation schedule. Allowing water to flow (USACE, 2011)." more naturally through the lake and into the river might also decrease lake turbidity by allowing lighter suspended solids to flow through while heavier ones settle. However, Eklutna water at the tailrace and in the Lake appear pretty clear, as opposed to excessively turbid, so NVE questions whether this issue precludes a sockeye run to Eklutna Lake. Certainly, impacts to fish and wildlife from the lake level fluctuations should be studied, and mitigated if possible. AWWU operators say they often find salmonids, including kokanee in the water coming from the lake, and these existing populations are probably being impacted.

Aaron Leggett Section 5.4.1.2 Oral Histories (page 89) Replace "Oral Histories" with “Traditional Ecological Knowledge”. Traditional Ecological Knowledge is recognized in US cultural This has been edited in the Final IIP, see page 98. Native Village of Eklutna resources protection law as equally valid with western science derived information. Traditional Ecological Knowledge (“Oral Histories”) from Eklutna Elders and Cultural Bearers provides the best available information, besides the Divestiture Report on the abundance of salmon in the Eklutna River before the dams. Brad Meiklejohn Section 5.4.1.2 Oral Histories (page 89) The story in Shem Pete’s Alaska about How Eklutna Got Its Name is important to include here. This story recounts a giant fish in This information has been included in the Final IIP, see page 18. The Conservation Fund Eklutna Lake that came out of the depths and swam down the river. Aaron Leggett Section 5.4.1.2 Oral Histories (page 89) The story in Shem Pete’s Alaska about how Eklutna got its name is important to include here. This story recounts a giant fish in This information has been included in the Final IIP, see page 18. Native Village of Eklutna Eklutna Lake that came out of the depths and swam down the river.

Page 21 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Aaron Leggett Section 5.4.1.2 Oral Histories (page 89) Again: NVE disagrees with the implication that all Eklutna Residents spent summers away from the village, although some have This has been clarified in the Final IIP, see page 98. Native Village of Eklutna "According to several Eklutna village elders, Eklutna reported that they did. Historically, Eklutna Dena’ina did consider themselves a village people and still do no matter where they residents spent summers at fish camps distributed along the live at what time of year. During the summer months they would disperse to fish and hunt at various locations up and down the shore of Knik Arm from Fire Island to the Knik River, Inlet, and inland, as to Eklutna Lake and up the Knik River. However, some would have remained at Eklutna Village to hunt and preserving ocean-caught salmon for winter use (Figure 5- harvest salmon there, including from Eklutna River, and lay in food supplies for overwintering at Eklutna from both local and 12)." dispersed sources. Villages were selected to have access to all needed resources, which prominently included salmon as a staple. NVE would also like to point out a 1978 publication, The Heritage of Eklutna, Mike Alex 1908-1977, in which James Kari wrote: “Mike was also well known to many Alaska natives who attended the BIA Eklutna Vocational School in the 20’s and 30’s as Mike was regularly involved with the school’s projects. In addition to all his jobs and chores, Mike always put up lots of fish and hunted moose and kept a garden for his large family. He sometimes talked of hunting trip in 1933, when he and his father killed 18 sheep at Eklutna Lake and distributed the meat throughout the village.” Please note, that Mike’s work at the church and school, as well as working in the garden would have required his presence at Eklutna Village during the non-winter months.

Aaron Leggett Section 5.4.1.2 Oral Histories (page 89) Eklutna was one of these villages. Excess preserved subsistence foods would also have been traded to others travelling between Comment noted. The IIP states that Eklutna was one of these villages. Native Village of Eklutna "As the summer progressed, families moved back to the interior Alaska and farther down the Inlet, as Eklutna lay on a well-used trade route. Throughout the last 50 years, several winter villages, which were traditionally “located along villagers have stated at one time or another that their parents would send them to the river to get dinner. It is cultural, it is self- productive salmon streams, by the mouths of lakes, or on the sufficiency in action. high bluffs” above Knik Arm. Per reports, Eklutna was one of these winter villages (Loso et al., 2017)."

Aaron Leggett Section 5.4.1.2 Oral Histories (page 90) NVE would appreciate replacement of [this sentence] with: “Maria Coleman, current NVE Tribal Council Vice President listened to This sentence has been replaced in the Final IIP, see page 99. Native Village of Eklutna "Eklutna village elders claim that all five species of Alaska the elders in the early ‘70s, when she was in her 20s. Six elders, now deceased, told her that the Eklutna River used to be salmon were once abundant in the Eklutna River." “overflowing” with “abundant” fish before the dams. They said that “now” there are (relatively) barely any fish there, and they can’t use that river anymore,” (Traditional Knowledge of Eklutna Fish Resources, Native Village of Eklutna)”

Aaron Leggett Section 5.4.1.2 Oral Histories (page 90) Please add the following relevant quote from the NVE paper, Traditional Knowledge of Eklutna Fish Resources: “Max Alex, a This information has been included in the Final IIP, see page 99. Native Village of Eklutna "Regarding the time period after the diversion dam was built recent Eklutna elder, noted that there were plentiful salmon in the Eklutna and all the streams in the area. He says all species of in 1929 and before the Federal hydropower project was salmon ran in the Eklutna River before the dams. Eklutna elders note that in the 1940s, before that, and in the early ‘50s salmon constructed in 1955, one elder, Jim Ezi, recalls taking king of all species were abundant in Eklutna River. Relocation to villages elsewhere is partially responsible for a gap in first-hand salmon in the Eklutna River above Thunderbird Creek and accounts about Eklutna salmon before then. Just above the confluence with Thunderbird Creek there was a large beaver dam. below the old diversion dam in the 1940s. In addition, Lee (The ends of this dam are still present, now on dry land.) Here people used pews to pitch to land as many fish of all species as Stephan remembers an abundance of pink salmon and other they needed, including Red and King Salmon. One Elder, Jim Ezi, recalls taking king salmon in the Eklutna above Thunderbird species in the Eklutna River during his youth in the late Creek and below the old dam in the 1940’s. The King Salmon no longer run here because the water level is too low with the 100% 1960s and 1970s (NVE, unpublished)." flow diversions from Eklutna Lake.” This illustrates the vestiges of once abundant Eklutna salmon runs still holding on in sufficient numbers for village use after the lower dam blocked passage farther upriver, but before flows were completely discontinued from Eklutna Lake. Today, tribal members do not deploy the NVE educational fish net in the Eklutna River because salmon populations are too low to sustainably harvest subsistence quantities.

Aaron Leggett Section 5.4.1.2 Oral Histories (page 89) Daniel Alex, son of Mike Alex, wrote the following while he was Tribal Administrator for NVE: “At peak flow, the water level in This information has been included in the Final IIP, see page 99. Native Village of Eklutna the canyon portion was canyon wall to wall at where the old Eklutna Bridge is presently. At the same time in the lower part of the river, it was bank to bank and even overflowing the banks. The over flow provided water to the wetland area down near the mouth and south of the river, which was habitat for salmon fry. Salmon and trout did migrate up to Eklutna Lake. My late brother, Herbert Alex once told me that as a boy, he was fishing at the old upper dam and was almost pulled into the water by a large rainbow trout. The regular flow of water cleaned out any vegetation that would try to grow in the stream bead. There was a clear water spring below the railroad tracks to the North of where the river was, that had a large flow of clear water, enough to make a stream that was at least 25 feet wide and at least 24 inches in depth. It was habitat for pink and chum salmon. The village used to get salmon for food until the salmon deteriorated. My mother would tell us that we needed salmon for dinner, and we would go to the stream and toss fish up onto the bank and pick a good one. The ones not acceptable were thrown back into the stream. That stream was a spawning area for the pink and chum salmon. Sockeye and Coho and king salmon did migrate up Thunderbird Creek. Where rainbow and other trout species are means that salmon are present. Different trout species feed on salmon eggs and likely salmon fry. The fact that trout migrated to the lake meant there was food present for them. A conclusion that salmon run was destroyed by the dams is a logical conclusion.”

Page 22 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Michael Knapp Section 5.4.2 Habitat Degradation (pages 90-91) The IIP report identifies the highway bridges as having degraded channel morphology and salmon habitat functionality. This is a Comment noted. The USACE also identified "man-made channel/flow constrictions placed ADOT&PF "Development within the Eklutna River watershed, including dishonest appraisal of impact. The channel morphology of alluvial fans is often contrary to and unsupportive of salmon habitat in the river at two highway bridges and one railroad crossing" as one of the primary causes hydropower development, construction of the railroad and functionality, as noted in the second excerpt shown above from the IIP. In this particular alluvial system, the DOT&PF highway of degraded salmonid habitat within the Eklutna River. highway bridges, and aggregate mining, has degraded bridges are helping to concentrate flows into a single channel and, arguably, are helping to improve fish passage potential. In channel morphology and salmonid habitat functionality.” Section 6.2.2, USACE-recommended non-flow alternatives for improving fish habitat include provisions that would “…allow for And, “While these [alluvial fan] areas provide quality rearing deeper average water depths and provide a single channel for flows…” not unlike the DOT&PF bridges. (See pages 135-137) habitat when wetted, some of these channels de-water as they flow downstream. Conversely, when viewed from the downstream end of the reach, some of the channels braid into small and often impassable branches moving upstream. These small, shallow braided channels shown in Figure 5-14 often run through heavily wooded areas that can dewater, strand fish, and make passage for salmon difficult or impossible.”

Brad Meiklejohn Section 5.4.2 Habitat Degradation (page 90) Some discussion is warranted to the effect that the Eklutna River is entirely dry in sections in the first 3 miles downstream of the This has been clarified in the Final IIP, see page 100. The Conservation Fund "After construction of the Federal hydropower project in dam, one of the most egregious forms of habitat degradation. 1955, all outflow from Eklutna Lake was diverted through a 4.5-mile-long tunnel to the penstock, powerhouse, and tailrace that discharges into the Knik River. This diversion of water is the primary cause of the degradation of any fish habitat that may have existed in the upper river. Certain areas of the upper river are so overwhelmed with fine sediment that the embedded coarser substrate that lies below cannot be observed (Figure 13) (MJA, 2019b)."

Michael Knapp Section 5.4.2 Habitat Degradation (page 91) Thank you for highlighting the 1986 flood event in the IIP report, along with the resultant bedload deposition in the vicinity of the Comment noted. ADOT&PF “The relatively narrow railroad bridge and elevated railbed Glenn Highway. This is precisely the kind of event that has DOT&PF concerned about safety and potential damage to cause natural bedload to accumulate between the railroad infrastructure. As a result of the lower dam removal project, there is now roughly 230,000 cubic yards of sediment available for and New Glenn Highway bridges. Much of the bedload transport to the lower reaches of the river. deposited between the bridges appears to have been caused by a 100-year flood event on October 12, 1986. This event flooded the ecosystem behind the elevated railbed and caused a massive volume of bedload being carried down from the canyon to drop out and superimpose a fresh alluvial deposit on the existing deposits. This deposit and additional bedload transported in subsequent but smaller events has elevated the riverbed between the bridges to a point where it has become highly braided and subject to frequent channel changes.”

Sean Eagan Section 5.4.2 Habitat Degradation (page 91) Referring to the event of October 12, 1986 as a 100-year event is incorrect, if it did not cause the dam to spill. With a 123 mi2 Comment noted. The 1986 flood event is referred to as a 100-year event in the 2011 NMFS "Much of the bedload deposited between the bridges portion of the 174 mi2 watershed not contributing it could not have been a 100-year event at the New Glenn Highway Bridge. On USACE report. The IIP notes that there was no reported spill event from the project in appears to have been caused by a 100-year flood event on a broad alluvial fan like the Eklutna fan, it may not take a 100-year event to cause the main channel to move. 1986. October 12, 1986." Michael Knapp Section 5.4.2 Habitat Degradation (page 93) Without any flows of significance since the lower dam was removed, one should not expect to find significant geomorphic The 2016 sediment transport model by HDR concluded that generally all sediment ADOT&PF "The Section 404 Permit issued by USACE requires Eklutna, change or aggradation occurring near the bridges in these monitoring reports. Sediment transport rates will increase with flow gradations would be transported out of the sediment plug within approximately 1-2 years Inc. to monitor the physical changes to channel geometry, increases. under the current flow regime. However, as you've previously pointed out, the author(s) substrate composition, water temperature and turbidity at noted a lot of uncertainty was involved in the analysis. It's our understanding that the three downstream transects (USACE, 2017).” current sediment transport monitoring at the bridges is ongoing. We have not seen any results from this monitoring effort yet. Eklutna, Inc. has committed to sharing the results when available. The need for additional sediment transport analysis will be considered by the TWG during the scoping of the proposed geomorphology/sediment transport study.

Page 23 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Sean Eagan Section 5.4.2 Habitat Degradation (page 93) While there are 3 monitoring sites for fish, five cross sections were surveyed below the dam and two immediately above the dam This information has been included in the Final IIP, see page 103. NMFS "In 2017 prior to completion of the dam removal project, in 2017; substrate composition was recorded at each one. Three of the seven have been resurveyed 4 times, two have only been three monitoring sites were established in the Eklutna River resurveyed twice, and two only once. The four sites that were not required by the Army Corp permit and not paid for by Eklutna downstream of the lower dam site (two above the Inc. may not have been covered in the 2020 report. NMFS would like to highlight this omission. Thunderbird Creek confluence and one below) and baseline data was collected." Aaron Leggett Section 5.4.3 Current Fish Habitat and Assemblage (page 94) This research should be cited and explicated: USACE. Habitat Assessment of the Lower Eklutna River. United States Army Corps Information from the 2007 USACE report has been included in the Final IIP, see page 104. Native Village of Eklutna of Engineers Report. Haines: Prince of Wales Tribal NVE's Eklutna River Salmon Habitat Assessment will be utilized during the planning for the Enterprise Consortium, 2007 . Native Village of Eklutna is nearly finished writing up a 2019 study: Eklutna River Salmon Habitat proposed instream flow study. Assessment and Collaboration to Recommend Restoration Flows. This uses similar methods to the 2007 USACE Report cited above, re-assessing habitat in lower reaches and extending the habitat analysis of the River to the Eklutna Lake dam.

Aaron Leggett Section 5.4.3 Current Fish Habitat and Assemblage (page 94) It’s also worth noting here that Eklutna River King Salmon are the largest found in any area streams or rivers. We are not aware This information has been included in the Final IIP, see page 106. The TWG can consider Native Village of Eklutna that this has been researched quantitatively, but village sport salmon fishers who fish other southcentral Alaska streams are very how to address an evaluation of the current Chinook salmon presence in the Eklutna River clear on this point. NVE Land and Environment Director measured a 56” dead king by the lower Eklutna River ponds in 2002. as part of the scoping of the proposed fish species composition and distribution study. Dustin Lorah, Trustee on the NVE Village Council, can attest to this statement as he has measured a 52” fish caught and released and reported seeing another King Salmon caught (released) that was, “even bigger”. He also reports, that the only other King Salmon this large could have come from very large and faster moving rivers like the Susitna, Kenai and Copper Rivers. These statements indicate that the Eklutna King Salmon are from a genetically distinct stock of larger fish, that hold on in the Eklutna River from a time before the River was diverted and had an order of magnitude greater discharge. A large Eklutna River King Salmon fishery would be a very desirable mitigation outcome, given the upper Cook Inlet dwindling King runs and fisheries’ demand for these.

Brad Meiklejohn Section 5.4.3 Current Fish Habitat and Assemblage (page 94) More detail is needed on the status of Upper Cook Inlet Chinook Salmon as a stock of concern. Chinook salmon are doing poorly This has been noted in the Final IIP, see page 107. The Conservation Fund throughout Upper Cook Inlet. A significant number of Chinook use the lower Eklutna River and are undoubtedly impacted by abnormally low water levels caused by hydropower diversions. Monica Keim Section 5.4.3.1 Escapement (page 95, Table 5-9 NVE Are the fish that are currently returning, to the Lower Eklutna and to Thunderbird Creek, straying from the tail race hatchery? We are unaware of any existing genetic data comparing the salmon returning to the Undergraduate - APU estimated total number of salmon in 2002 and 2003) Eklutna River to the salmon returning to the Eklutna tailrace. The TWG can consider how to address this question as part of the scoping of the proposed fish species composition and distribution study. Austin Williams Section 5.4.3.2 Spawning (page 96) This section focuses on known spawning areas and potential for spawning on most sections of the river system, excluding habitat We are unaware of any existing information regarding potential spawning habitat in the Trout Unlimited upstream of the Lower Eklutna Dam. This section should also include discussion of historic and potential spawning habitat upper Eklutna River and around Eklutna Lake. The TWG can consider how to address this upstream of the lower dam site, including areas upstream of the Eklutna Hydropower Project in and around the lake or its feeder question as part of the scoping of the proposed lake aquatic habitat and fish utilization streams. study. Sean Eagan Section 5.4.3.2 Spawning (page 96) As the glacier retreats, the two forks of the Eklutna will become better spawning habitat, even if it is true they were not An assessment of spawning habitat in the East and West Forks of Eklutna Creek will be NMFS productive spawning habitat prior to 1929. NMFS requests that the potential for new spawning habitat in these forks be studied. considered by the TWG as part of the scoping of the proposed lake aquatic habitat and fish utilization study. Sean Eagan Section 5.4.3.3 Juvenile Usage, Coho and Chinook Salmon This section posits a number of conflicting hypotheses without providing data to back them up. NMFS recommends that juvenile Comment noted. This information is from the USACE's 2011 report. The TWG can consider NMFS (page 97) salmon occurrence would be better understood if the IIP simply stated what fish sampling has been completed in each river how to address this question as part of the scoping of the proposed fish species reach and in what years. composition and distribution study. Aaron Leggett Section 5.4.3.3 Juvenile Usage, Coho and Chinook Salmon Ward’s Thesis (2010) should be cited and results presented here as the author studied juvenile coho relative abundance and This information has been included in the Final IIP, see page 110. Native Village of Eklutna (page 97) habitat at four creek off-channel restoration locations in southcentral Alaska. She wrote: “The lower Eklutna River pond was the most productive habitat evaluated, and it supported a large summer coho salmon population of 3,490 coho salmon larger than 60 mm fork length, with coho salmon densities of 57/ 100 m².” (from her Abstract)

Aaron Leggett Section 5.4.3.3 Juvenile Usage, Coho and Chinook Salmon An ADFG fish Biologist, Dan Bosch also trapped and measured minnows here prior to 2010 and told us some of the juvenile coho Comment noted. Native Village of Eklutna (page 97) were the largest he has measured in this area. Aaron Leggett Section 5.4.3.3 Juvenile Usage, Coho and Chinook Salmon It might also be noted that beaver dams have now altered the configuration of the lower River ponds. This information has been included in the Final IIP, see page 103. Native Village of Eklutna (page 97) Brad Meiklejohn Section 5.4.3.5 Eklutna Lake (page 99) What is the effect of lake drawdown on shore spawning of kokanee? As sockeye are typically lake shore spawners, and kokanee We are unaware of any data regarding the effect of current reservoir operations on The Conservation Fund are landlocked sockeye, presumably kokanee are affected by the regular drawdown, exposure and desiccation of their spawning kokanee. The TWG can consider how to address this question as part of the scoping of the habitat. It is conceivable the kokanee in Eklutna Lake are stunted because of the lack of marine-derived nutrients that are no proposed lake aquatic habitat and fish utilization study. longer being brought into the lake by sockeye salmon. Sockeye have a tremendous ability to import marine-derived nutrients.

Section 5.5: Wetlands, Riparian, and Littoral Habitat

Page 24 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Brad Meiklejohn Section 5.5 Wetlands, Riparian, and Littoral Habitat (page Some discussion is needed of the extent of riparian wetlands that have been lost as a result of dewatering of the upper reaches This has been noted in Section 6 of the Final IIP, see page 153. However, we are unaware The Conservation Fund 102) of the Eklutna River. Perhaps this is an item for Section 6, to characterize the Project Effects on the loss of wetlands resulting of any data quantifying the project impacts to wetlands. The TWG can consider how to from the project. address this question as part of the scoping of the proposed wetland/riparian habitat study. Sean Eagan Section 5.5 Wetlands, Riparian, and Littoral Habitat (page 22.9 acres of estuarine wetlands for a watershed of 174 mi square is an unusually small estuary for a large watershed. If the Since the Draft IIP only showed the wetlands within 250 feet of the centerline of the NMFS 103) Settlement Agreement directs us to give equal consideration to purposes #3 and #6, NMFS recommends increasing the size of Eklutna River, the total estuarine wetlands shown in the Draft IIP likely did not include all "Estuarine and Marine Wetlands are found just upstream of this estuary. Increasing the water flow to the estuary would greatly increase the productivity of the Fire Creek and Eklutna River of the estuarine wetlands for the watershed. We have revised this section in the Final IIP, the Eklutna River’s confluence with the Knik Arm (22.9 acres; estuary easement created in 2012. see page 117. 0.7% of total wetlands)…" Section 5.6: Terrestrial Resources

Monica Keim Section 5.6.2.2 Wildlife Species (page 112) Are there no steelhead or even bald eagles? Steelhead populations in Alaska are not listed as threatened or endangered. Bald eagles Undergraduate - APU "No species listed as threatened or endangered under the were delisted in 2007. Endangered Species Act (ESA) occur in the Project vicinity (USFWS, 2020)." Section 5.7: Recreation and Land Use

Brad Meiklejohn Section 5.7 Recreation and Land Use (page 113) This section needs substantial re-arrangement or there needs to be an entirely new section titled “Land Status and Land Agreed. The land ownership subsection has been separated out from the Chugach State The Conservation Fund Ownership.” It is important to provide a clear and concise description of land ownership throughout the entireC170:C171 Eklutna Park section in the Final IIP, see page 128. watershed and the project zone of influence, including the tailrace, the Knik River valley, Eklutna Village and the Thunderbird subdivision. Placing a discussion of land ownership under the header of Chugach Park is inappropriate as Chugach Park itself falls within the broader category of land ownership, not the other way around.

Brad Meiklejohn Section 5.7.1.2 Land Ownership (page 114) [This section] needs discussion of surface and subsurface ownership, as well as discussion of ownership of the lake bed and the More detailed maps showing land ownership adjacent to the Eklutna River and Eklutna The Conservation Fund river bed, issues of navigability and jurisdiction (ie; what agencies have jurisdiction of what attributes throughout the Eklutna Lake have been developed in consultation with Eklutna, Inc. and included in the Final IIP, watershed and the entire region affected by the Eklutna Project.) see page 129. Issues regarding jurisdiction will be addressed during any permitting process that might be required for implementation of the study program and eventual Fish and Wildlife Program. Brad Meiklejohn Section 5.7.1.2 Land Ownership (page 116, Figure 5-25 A much better map of land ownership also needs to be provided than what is shown in Figure 5-25. Such a map would show in Agreed. More detailed maps showing land ownership have been developed in consultation The Conservation Fund Chugach State Park Land Ownership) great detail all the various tracts of private and public lands throughout the Affected Environment. This map may be put under with Eklutna, Inc. and included in the Final IIP, see page 129. the category of a “need” that should be filled as it will probably be a detailed GIS product that may not currently exist. Likewise, we need a comprehensive map of the Affected Environment, again something that doesn’t exist and will require GIS expertise to produce. Monica Keim Section 5.7.1.4 Eklutna-Peters Creek Planning Unit (page 117) Ice climbing and rock climbing were not reported as an activities that exist within the Eklutna watershed. Climbing has been included in the Final IIP as an existing recreational activity within the Undergraduate - APU Eklutna Watershed, see page 137. Kurt Hensel Section 5.7.1.4 Eklutna-Peters Creek Planning Unit (page 117) "Park staff and members of the public have expressed concern regarding erosion of the lakeside trail." Add risk of water This sentence has been edited and the additional information has been added to the Final ADNR, Division of Parks and "Members of the pubic have expressed concern regarding damaging park infrastructure such as culverts, access to Yuditnu cabin, signs, bridges. IIP, see page 138. Outdoor Recreation erosion of the lakeside trail"

Rick Sinnott Section 5.7.1.4 Eklutna-Peters Creek Planning Unit (page 117, I took this photo and noted the lake level relative to the dam spillway on September 27. The authors of the draft IIP couldn’t This has been acknowledged in the Final IIP, see page 138. Figure 5-26 Erosion of Lakeside Trail, September 27, 2019) have known that, but they can give me credit now.

Kurt Hensel Section 5.7.1.4 Eklutna-Peters Creek Planning Unit (page 117) I don’t think the rental facility operated by Lifetime Adventures would be considered a visitor center. This has been corrected in the Final IIP, see page 138. ADNR, Division of Parks and "Lifetime Adventures operates a visitor center at the north Outdoor Recreation end of the lake near the lakeside trailhead."

Kurt Hensel Section 5.7.1.4 Eklutna-Peters Creek Planning Unit (page 118, Add Dolly Varden and Rainbow Public Use Cabins (built within last five years) Information regarding the Dolly Varden and Rainbow Trout Public Use Cabins has been ADNR, Division of Parks and Figure 5-27 Existing Recreational Facilities around Eklutna added to the Final IIP, see page 137. Outdoor Recreation Lake)

Page 25 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Rick Sinnott Section 5.7.1.4 Eklutna-Peters Creek Planning Unit (page 120) The draft IIP provides no information on the value of wildlife to the people living in Eklutna Village or visiting Eklutna Valley or Additional discussion regarding the value of wildlife in the Eklutna Valley has been included “At least half of the 12 people injured or killed by bears in Chugach State Park; however, it describes “negative wildlife-human interactions” as a public safety concern. The source of the in the Final IIP, see page 133. The information provided in the Draft IIP regarding Chugach State Park since its establishment were within 100 data cited above should be included. According to a paper published in 2015 (J.A. Coltrane and R. Sinnott. 2015. Brown bear and bear/human interactions is from the 2016 Chugach State Park Management Plan. This yards of salmon spawning streams.” human recreational use of trails in Anchorage, Alaska. Human-Wildlife Interactions 9:132-147), brown bears alone have injured reference has bee included in the Final IIP, see page 133. 19 people and killed 2 people in the Anchorage area since 1991. The exact locations of three brown bear attacks that occurred before 1991 are unclear, but about half of the attacks since 1991 have occurred in Chugach State Park. The fact that half of the brown bear attacks in the municipality (not, as the draft IIP reported, in Chugach State Park) occurred within 100 meters of a salmon spawning stream was reported by Coltrane and Sinnott. No brown bear attacks are known to have taken place in Eklutna Valley. Black bears have injured additional people and killed one person in the park. Only two people are known to have received minor injuries from black bears in Eklutna Valley. One of these incidents occurred before the park was established. The fact that people are more likely to be attacked by brown bears (not black bears) when they are near salmon spawning streams (particularly if they are running or biking) may be relevant to the discussion; however, the information provided in the quote above should be confirmed and a reference provided. It would also be useful to provide information to help the draft IIP’s intended audience understand the value of the park’s fish and wildlife resources to people using Chugach State Park and specifically Eklutna Valley.

Section 5.8: Cultural Resources

Aaron Leggett Section 5.8.3 Prehistoric Sites (page 130, Table 5-7 The list of prehistoric sites in Table 5-7 does not include many of these cultural resources of which NVE is aware. Regarding ANC- Due to the sensitive nature of this information, and at the request of the NVE, information Native Village of Eklutna Prehistoric Sites) 02859, ANC-02878, and ANC-02879, the referenced sites appear to derive from reported sites documented in an NVE survey on prehistoric sites in the project area has been removed from the Final IIP, see page 149. report, authored by Dan Stone: “Taking the Trail Home”. There were many more features found at this complex of sites “near the Knik River Bridge”. (This report is currently confidential, and documented information on this archeological district is not for public distribution to the extent of the IIP.) In contrast to the 11 house pits and 26 cache pits noted in the IIP table, Dan Stone’s 2008 Report, Taking the Trail Home (confidential, may be available for review) describes at least 42 house pits and 210 cache pits. It is our understanding that these findings were entered to the AHRS database. NVE is aware of at least 5 house pits that remain on either side of the railroad tracks through Eklutna Village. Around 20 years ago ARRC covered over about 10 house pits to expand the tracks. They should have a survey report on this. And, there were likely more such cultural resources covered over with the initial installation of the railroad tracks. The tracks footprint is now quite wide, with curve straightening, side tracks and a former station house, grounds and facilities where an ancient village was likely to have been located. NVE knows of a larger number of cache pits, some of them unusually large, still remaining around Eklutna Village. The inclusion of much of this information in a public document is inappropriate.

Section 6: Project Effects, PMEs Suggested by Others, and Information Needs

Brad Meiklejohn Section 6.1 Project Effects (page 133) This would be an appropriate place for additional citations from the 2011 USACE report, to whit: “Permanent loss of 90 percent This section has been revised in the Final IIP, see page 152. The Conservation Fund "The effects of the federal hydropower development in the of the natural hydrograph due to upstream dam construction and diversion of 100 percent of Eklutna River flows, impacts to the mid-1950s can generally be described as changing the river resulting from highway and railroad bridge construction, and other anthropogenic effects have degraded channel hydrologic regime in the Eklutna River through the diversion morphology and salmonid habitat functionality in some river reaches…The over-riding limitation is the inability to restore the of most of the water entering Eklutna Lake through a tunnel natural hydrograph.. … True restoration of the Eklutna River ecosystem would require removal of both dams…” to the powerhouse located on the Knik Arm."

Aaron Leggett Section 6.1 Project Effects (page 133) This would be an appropriate place for additional citation from the 2011 USACE Report, to whit: “Permanent loss of 90 percent This section has been revised in the Final IIP, see page 152. Native Village of Eklutna "The effects of the federal hydropower development in the of the natural hydrograph due to upstream dam construction and diversion of 100 percent of Eklutna River flows, impacts to the mid-1950s can generally be described as changing the river resulting from highway and railroad bridge construction, and other anthropogenic effects have degraded channel hydrologic regime in the Eklutna River through the diversion morphology and salmonid habitat functionality in some river reaches…The over-riding limitation is the inability to restore the of most of the water entering Eklutna Lake through a tunnel natural hydrograph.. … True restoration of the Eklutna River ecosystem would require removal of both dams…” to the powerhouse located on the Knik Arm."

Page 26 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Brad Meiklejohn Section 6.1 Project Effects (pages 133-134) The Eklutna Purchasers are not absolved from effects on anadromous fish either above or below the lower diversion dam. The lower diversion dam was not included in the sale of the Federal project to the current The Conservation Fund "With regard to the fish assemblage in the Eklutna River, the Because the chain of custody of the lower dam passed through the city (which is still one of the Eklutna Purchasers) to the USBR, owners. The Federal government transferred the lower diversion dam and any associated construction of the historic lower diversion dam in 1929 which built the federal project, and apparently passed to the Eklutna Purchasers with the sale, the Eklutna Purchasers are fully real property to Eklutna, Inc. and CIRI in 1985 and 1986 pursuant to ANCSA, several years eliminated the opportunity for fish to pass above that dam responsible for all impacts to the hydrology and fisheries of the Eklutna River stretching back to 1928. Especially now that the prior to the 1989 Eklutna Purchase Agreement and 1991 Fish and Wildlife Agreement. site into the portion of the river upstream. There were no fish lower dam has been removed, the absence of salmon upstream of the lower dam site, and their inability to reach Eklutna Lake, Furthermore, the Section 404 permit application materials for the lower dam removal passage facilities included in the construction of the lower rests entirely with the Eklutna Purchasers. project state that "The lower Eklutna River dam and surrounding property are owned by diversion dam. This effectively eliminated any anadromous Eklutna, Inc." fish above the lower diversion dam." And, "However, with respect to effects on the anadromous fish of interest, those flow impacts only occurred below the historic lower diversion dam site since anadromous fish did not exist above the lower diversion dam after 1929."

Aaron Leggett Section 6.1 Project Effects (pages 133-134) The Eklutna Purchasers are not absolved from effects on anadromous fish either above or below the lower diversion dam. The lower diversion dam was not included in the sale of the Federal project to the current Native Village of Eklutna "With regard to the fish assemblage in the Eklutna River, the Because the chain of custody of the lower dam passed through the city (which is still one of the Eklutna Purchasers) to the USBR, owners. The Federal government transferred the lower diversion dam and any associated construction of the historic lower diversion dam in 1929 which built the federal project, and apparently passed to the Eklutna Purchasers with the sale, the Eklutna Purchasers are fully real property to Eklutna, Inc. and CIRI in 1985 and 1986 pursuant to ANCSA, several years eliminated the opportunity for fish to pass above that dam responsible for all impacts to the hydrology and fisheries of the Eklutna River stretching back to 1928. Especially now that the prior to the 1989 Eklutna Purchase Agreement and 1991 Fish and Wildlife Agreement. site into the portion of the river upstream. There were no fish lower dam has been removed, the absence of salmon upstream of the lower dam site, and their inability to reach Eklutna Lake, Furthermore, the Section 404 permit application materials for the lower dam removal passage facilities included in the construction of the lower rests entirely with the Eklutna Purchasers. project state that "The lower Eklutna River dam and surrounding property are owned by diversion dam. This effectively eliminated any anadromous Eklutna, Inc." fish above the lower diversion dam." And, "However, with respect to effects on the anadromous fish of interest, those flow impacts only occurred below the historic lower diversion dam site since anadromous fish did not exist above the lower diversion dam after 1929."

Austin Williams Section 6.1 Project Effects (page 133-134) This section dramatically understates the impacts of the Eklutna Hydropower Project and fails to capture the present and future Additional discussion regarding the impacts of the federal hydropower project has been Trout Unlimited "With regard to the fish assemblage in the Eklutna River, the impacts. As the 1992 Divestiture Report states, the lower dam blocked salmon migration so that when the upper project was included in the Final IIP, see page 152. Note that the owners' team is reliant upon any construction of the historic lower diversion dam in 1929 completed no salmon could migrate upstream past the lower dam. However, as discussed above, the impacts of the upper baseline data collected prior to the development of the federal project in order to quantify eliminated the opportunity for fish to pass above that dam project change over time such that impacts today are different than impacts experienced at the date the project was the impacts of the project on various resources/use. Where no baseline data exists, the site into the portion of the river upstream. There were no fish constructed, which might both vary compared to possible future impacts. The 1991 Agreement accounted for these changes over owners can only speculate about what the impacts might have been at that time. passage facilities included in the construction of the lower time, and so should the Fish and Wildlife Program. Likewise, the IIP should include a much more robust and comprehensive Development of additional information to quantify ongoing impacts will be considered by diversion dam. This effectively eliminated any anadromous discussion of the impacts from the Eklutna Hydroelectric Project. Even though the Study Plan is not complete and impacts of the the TWG for inclusion in the study program. fish above the lower diversion dam. The overall effect of the project may change over time, the IIP can and should provide a better accounting of the impacts. In addition to diminishing federal hydropower development was thus to diminish significantly the amount and timing of water, the project blocks salmon migration now that the lower dam has been removed, significantly the amount and timing of water in the Eklutna has changed the sedimentation regime in the river, affects the lake habitat and its usage by resident and anadromous fishes, River throughout the entire river by diverting most of the blocks habitat usage upstream of the lake, among other not-yet known impacts. Beyond the biological and ecological impacts, water to the federal project powerhouse located on the Knik the project also has significant cultural and subsistence impacts that need to be discussed. Arm. However, with respect to effects on the anadromous fish of interest, those flow impacts only occurred below the historic lower diversion dam site since anadromous fish did not exist above the lower diversion dam after 1929. Resident fish impacts from the change in flow regime would have occurred along the entire length of the river."

Brad Meiklejohn Section 6.1 Project Effects (page 134) Here “was” should be changed to “has been” to clarify that the impacts of the Eklutna Project are on-going and are not limited to This section has been revised in the Final IIP, see page 152. The Conservation Fund "The overall effect of the federal hydropower development the mere “footprint” impacts at the time of construction. was thus to diminish significantly the amount and timing of water in the Eklutna River throughout the entire river by diverting most of the water to the federal project powerhouse located on the Knik Arm."

Page 27 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Aaron Leggett Section 6.1 Project Effects (page 134) Here “was” should be changed to “has been”, to clarify that the impacts of the Eklutna Project are ongoing and are not limited to This section has been revised in the Final IIP, see page 152. Native Village of Eklutna "The overall effect of the federal hydropower development the mere “footprint” impacts at the time of construction. was thus to diminish significantly the amount and timing of water in the Eklutna River throughout the entire river by diverting most of the water to the federal project powerhouse located on the Knik Arm."

Brad Meiklejohn Section 6.1 Project Effects (page 134) [This sentence] needs to be deleted since, with the removal of the lower dam, the flow impacts now encompass the entire river. This section has been revised in the Final IIP, see page 152. The Conservation Fund "However, with respect to effects on the anadromous fish of interest, those flow impacts only occurred below the historic lower diversion dam site since anadromous fish did not exist above the lower diversion dam after 1929."

Aaron Leggett Section 6.1 Project Effects (page 134) This part of the sentence needs to be deleted since, with the removal of the lower dam, the flow impacts now encompass the This section has been revised in the Final IIP, see page 152. Native Village of Eklutna "However, with respect to effects on the anadromous fish of entire river. interest, those flow impacts only occurred below the historic lower diversion dam site since anadromous fish did not exist above the lower diversion dam after 1929."

Brad Meiklejohn Section 6.1 Project Effects (page 134) The tense of [this sentence] needs to reflect the fact that the effects of the federal project have extended over 65 years, continue This section has been revised in the Final IIP, see page 152. The Conservation Fund "Resident fish impacts from the change in flow regime would to the present and are likely to extend into the foreseeable future. This sentence should read “Resident fish impacts from the have occurred along the entire length of the river." change in flow regime are occurring along the entire length of the river.”

Aaron Leggett Section 6.1 Project Effects (page 134) This needs to reflect the fact that the effects of the federal project have extended over 65 years, continue to the present and are This section has been revised in the Final IIP, see page 152. Native Village of Eklutna "Resident fish impacts from the change in flow regime would likely to extend into the foreseeable future. This sentence should read: “Resident fish impacts from the change in flow regime are have occurred along the entire length of the river." occurring along the entire length of the river.”

Brad Meiklejohn Section 6.1 Project Effects (page 133) The Conservation Fund is one of the top providers of wetlands mitigation in the nation. Since 1998 we have operated a statewide The 1991 Agreement requires the owners to evaluate impacts to fish and wildlife that The Conservation Fund wetlands mitigation program in Alaska. One of the central concerns of wetlands mitigation is “temporal loss” which is the lag resulted from hydropower development of the Federal project. The owners acknowledge between the time of impact and the time that mitigation is implemented. Nowadays, wetlands mitigation typically must occur the importance of wetland habitat to both fish and wildlife, and therefore have included before the impact to wetlands happens, to avoid any temporal loss of wetlands function. If a project proponent sought to discussion regarding Project impacts to wetlands in the Final IIP, see page 153. dewater a salmon river, they would need to replace or restore an equivalent amount (and equivalent type) of riparian habitat before their project would be permitted to advance. In this case we are looking at 65 years of temporal loss associated with the complete dewatering of the Eklutna River. So, not only are the Eklutna Purchasers responsible for the “footprint” impact of the project, but they are responsible for 65 years of loss of services and functions of an anadromous river. Additionally, because of the inter-related nature of the Lower Dam and the Eklutna Project, we believe that the Eklutna Purchasers are responsible for all impacts to the Eklutna River that have resulted from hydropower development.

Aaron Leggett Section 6.1 Project Effects (page 133) The Conservation Fund is one of the top providers of wetlands mitigation in the nation. Since 1998 they have operated a The 1991 Agreement requires the owners to evaluate impacts to fish and wildlife that Native Village of Eklutna statewide wetlands mitigation program in Alaska. One of the central concerns of wetlands mitigation is “temporal loss” which is resulted from hydropower development of the Federal project. The owners acknowledge the lag between the time of impact and the time that mitigation is implemented. Nowadays, wetlands mitigation typically must the importance of wetland habitat to both fish and wildlife, and therefore have included occur before the impact to wetlands happens, to avoid any temporal loss of wetlands function. If a project proponent sought to discussion regarding Project impacts to wetlands in the Final IIP, see page 153. dewater a salmon river, they would need to replace or restore an equivalent amount (and equivalent type) of riparian habitat before their project would be permitted to advance. In this case we are looking at 65 years of temporal loss associated with the complete dewatering of the Eklutna River. So, not only are the Eklutna Purchasers responsible for the “footprint” impact of the project, they are responsible for 65 years of loss of services and functions of an anadromous river. Additionally, because of the inter-related nature of the Lower Dam and the Eklutna Project, we believe that the Eklutna Purchasers are responsible for all impacts to the Eklutna River that have resulted from hydropower development.

Page 28 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Aaron Leggett Section 6.2 Identified Goals and PMEs Suggested by Others The Eklutna River has provided nutritional and cultural benefit to Eklutna Dena’ina throughout time immemorial, but its This information has been included in the Final IIP, see page 156. Native Village of Eklutna (page 134) productivity has been degraded in recent years. Eklutna’s wish to restore the Eklutna River for fish and wildlife habitat, "Based on early outreach efforts, our understanding of the traditional subsistence uses, and sustainable natural resources development. main goals of the agencies and interested parties is to find a new balance amongst the uses of water in the Eklutna River basin, including power production, potable water supply, and fish habitat." Austin Williams Section 6.2 Identified Goals and PMEs Suggested by Others While TU and its members value reliable and economic sources of power for local communities, and recognize it is absolutely Comment noted. Trout Unlimited (page 134) essential to maintain a clean and plentiful water source for the City of Anchorage, we believe it is also possible to restore the "Based on early outreach efforts, our understanding of the Eklutna River and bring back its once-abundant runs of wild salmon. TU has enjoyed working with diverse stakeholders to find main goals of the agencies and interested parties is to find a long-term successes to complex water management and hydropower challenges in other parts of the country, and we see no new balance amongst the uses of water in the Eklutna River reason a similar success story can’t be told with the Eklutna. We are encouraged the utilities are accepting input, and that they basin, including power production, potable water supply, have invited TU and other stakeholders to participate in this process, which will determine the future of the Eklutna River. and fish habitat." Aaron Leggett Section 6.2.1 Flow Related (page 134) NVE is very pleased that flow restoration mitigation is being considered for study planning as the foremost mitigation alternative. The USFWS previously provided their 2019 report, and that information was included in Native Village of Eklutna "Potential flow related PME measures involve providing a The 2019 USFWS Study (cited below) recommending discharge and flushing flow release levels and schedules for salmon habitat the Draft IIP. Please note that the USFWS clarified that the preliminary flows presented in flow regime into the Eklutna River that would accomplish in Eklutna River below the lake dam is most relevant here. We trust USFWS will provide it and recommend its inclusion and their report should not be construed as a final recommendation for flows needed to habitat restoration and increase the anadromous fish interpretation here. The flow release levels recommended by this study should provide salmon habitat in the River below the support salmon habitat in the Eklutna River. Instead, the USFWS recommended that a full assemblage of the river. A second flow related PME would be Lake. However, they will not fully restore what was lost (Upper Eklutna River Survey, Preliminary Fish Habitat Flow Assessment. hydraulic model (HEC-RAS or similar) should be developed for the full length of the Eklutna to create the opportunity for sockeye to travel into/out of Field Report. Anchorage: USFWS, 2019)... Sufficient water is required for salmon habitat to support abundant populations. The River as well as an overall habitat survey conducted prior to final recommendations Eklutna Lake." pattern of flow, and its interaction with other variables are also important and complex. Adequate flows must be staged taking concerning flow and that an adaptive management approach be taken. Development of into account the life stages of the fish, from egg through smolt and returning adult. Periodic flushing flows are needed to clean this type of information will be considered by the TWG during the scoping of the proposed the gravels of fine sediments that occlude oxygenation of spawning beds. Connectivity to the lake would be necessary to restore instream flow study. a sockeye run that could be the largest Eklutna system fishery.

Michael Knapp Section 6.2.1 Flow Related (page 134) I recommend that the Owners evaluate the natural hydrograph streamflow plan in terms of potential downstream impacts, as The owners have committed to working with the TWG to develop additional information ADOT&PF "In 2018, Trout Unlimited (TU) and NVE hosted a workshop noted in the IIP. What would be the highest allowable peak discharge envisioned for this “natural hydrograph” scenario? to determine how potential flow regimes would affect fish habitat in the Eklutna River. to develop a vision for salmon recovery in the Eklutna River Once those flow regimes have been determined, the owners will work with the and to identify next steps to improve conditions for salmon appropriate agencies to assess the potential impacts to downstream infrastructure and in the near-term…the workshop’s recommendations related other factors as required by the 1991 Agreement, then weigh those potential to streamflow included the following: …Future seasonal impacts/costs against the potential benefits to fish habitat. streamflow should be patterned after a natural hydrograph…”

Page 29 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Brad Meiklejohn Section 6.2.1 Flow Related (pages 134-135) Why is this statement included here? How is this calculation completed? What assumptions are used to reach this conclusion? Additional information regarding how this value was calculated has been added to the The Conservation Fund “This flow regime would require a total of approximately Without further expansion, this statement appears to be an attempt cast doubt on the feasibility of restoring instream flow and Final IIP, see page 157. This statement was included to quantify the amount of water that 80,000 acre feet of water each year, roughly 35% of the is an example of implicit bias favorable to the owners. would be needed to provide the specified flow regime. In fact, the volume of water stated average annual water usage of the hydropower project.” is an underestimation as the desired annual single day "bankfull" flow cannot be provided instantaneously but rather would require water to exceed the spillway elevation until the water level rises to a level that provides the desired flow. The reservoir level must then recede to an elevation below the spillway elevation before flows to the river would cease. The 1991 Agreement requires the owners to consider impacts to efficient and economical power production when developing the Fish and Wildlife Program. Any water released into the Eklutna River to provide fish habitat will not be available for power generation. Therefore, one of the ways to quantify the cost of providing flow for fish habitat is to calculate the amount of water that would be released under a specified flow regime. This information can then be used to calculate what the reduction in power generation at Eklutna would be, which would have to be generated using alternative power sources. Since, every other power source available to the owners is significantly more expensive than Eklutna, this added cost would impact rate payers. The same calculation will be done for any other flow regimes that are recommended as a result of the eventual instream flow study. Other factors such as timing and any necessary infrastructure improvements would also contribute to the cost of providing a specified flow regime and will be evaluated as part of the alternatives analysis. The costs will then be weighed against the potential benefits to fish habitat to help inform the development of the Fish and Wildlife Program.

Michael Knapp Section 6.2.1 Flow Related (page 135) Agreed. DOT&PF concurs that an intentional reduction of reservoir storage capacity could introduce flood risks and potentially Comment noted. ADOT&PF “Currently, the only way to intentionally release flows impact downstream public interests. through the spillway would be to curtail generating power and let the reservoir fill up until the lake level exceeds the spillway crest. Because of the way the reservoir is operated, this method is not a viable alternative for providing instream flows year-round since it would effectively eliminate the storage capacity for the hydropower project….In addition, this method would have the inherent safety risk of an unforeseen storm occurring while the reservoir level is high and the freeboard is reduced. This means that there would be a risk of higher flows being released than intended which could pose a significant safety hazard to downstream areas.”

Brad Meiklejohn Section 6.2.1 Flow Related (page 135) We find a series of statements that defy the sentiment in 1.0 that “the owners have no pre-conception as to any particular This statement has been edited in the Final IIP, see page 157. We anticipate that modifying The Conservation Fund "Currently, the only way to intentionally release flows outcome or what will be included in the Proposed Fish and Wildlife Program.” The statement that “Because of the way the project operations to cause the spillway to overtop will be evaluated as part of the through the spillway would be to curtail generating power reservoir is operated, this method is not a viable alternative…” exposes a clear bias on the part of the owners. In fact, allowing operational alternatives analysis. and let the reservoir fill up until the lake level exceeds the the reservoir to fill and allowing the spillway to overflow is a perfectly viable alternative. It might actually be the simplest and spillway crest. Because of the way the reservoir is operated, easiest means to accomplish flow restoration. Doing so might result in reduced power production, but it is a perfectly viable this method is not a viable alternative for providing instream alternative that should be carefully considered. Likewise, an intentional flow release could be accomplished at other times of the flows year-round since it would effectively eliminate the year besides fall, but it would require a reduction in power generation. storage capacity for the hydropower project."

Page 30 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Aaron Leggett Section 6.2.1 Flow Related (page 135) Allowing the reservoir to fill and allowing the spillway to overflow is a viable alternative. It might actually be the simplest and This statement has been edited in the Final IIP, see page 157. We anticipate that modifying Native Village of Eklutna "Currently, the only way to intentionally release flows easiest method of flow restoration. Doing so could result in reduced power production, and less capacity to control the schedule project operations to cause the spillway to overtop will be evaluated as part of the through the spillway would be to curtail generating power of that production. However, it is a viable alternative that should be considered if a better release mechanism is not devised, operational alternatives analysis. and let the reservoir fill up until the lake level exceeds the although by itself it does not address salmon access to the lake. spillway crest. Because of the way the reservoir is operated, this method is not a viable alternative for providing instream flows year-round since it would effectively eliminate the storage capacity for the hydropower project."

Michael Knapp Section 6.2.1 Flow Related (pages 135-136) DOT&PF recommends more discussion about the “inherent safety risks” associated with “flushing flows” over the spillway The previous paragraph describes the inherent safety risk of an unforeseen storm ADOT&PF “For regulated flow release at the dam, there is a 30-inch by and/or the drainage outlet. Are there any structural or instability concerns? Please clarify what these safety risks are. occurring while the reservoir level is high and the freeboard is reduced. This means that 30-inch drainage outlet at the base of the spillway rated to there would be a risk of higher flows being released than intended which could pose a release 191 cfs when the reservoir is at the spillway crest. significant safety hazard to downstream areas. An assessment of the safety risks However, this drainage gate is not a typical reservoir outlet associated with each alternative will be included as part of the study program. intended for continuous use and was supplied only for drainage purposes. An engineering analysis would need to be conducted to verify that the outlet could be used in this way, and if it could, flows would be still be limited by the hydraulic capacity of the gate. Use of the drainage outlet would also have the same operational constraints regarding year-round instream flows and the same inherent safety risks as use of the spillway regarding some kind of flushing flow, although the safety risk might not be as great.”

Aaron Leggett Section 6.2.1 Flow Related (page 136) NVE agrees with [this statement]. And, NVE believes such measures should be taken. NVE questions whether the drainage outlet The cost of designing, constructing, maintaining and operating the appropriate water Native Village of Eklutna “If it is determined that the drainage outlet as it currently is large enough to convey sufficient water for optimal sustained and larger flushing flows recommended by USFWS. release mechanisms, if needed, will be assessed along with the potential benefits to fish exists could not be used to release either regulated instream habitat to help inform the development of the eventual Fish and Wildlife Program. or flushing flows, then the ability to provide instream flows at the dam (either year-round instream flows or short-term flushing flows) would require the design, installation and operation of appropriate water release mechanisms.”

Sean Eagan Section 6.2.1 Flow Related (page 136) AWWU pipeline is an option for releasing water into the river. While there might be two obvious release locations, there are Discussion regarding the potential use of AWWU's pipeline to provide instream flows was NMFS "An alternative that has been identified preliminarily for engineering fixes that could allow releases at many other locations. NMFS is wondering if any of these alternatives have been included in the Draft IIP. More detailed information regarding the feasibility and costs will providing instream flows would be the modification of considered and if the IIP could discuss those alternatives and/or add considering alternatives to the study plan. be developed in coordination with AWWU to help inform the alternatives analysis of AWWU’s pipeline to release water into the river at either the potential PME measures. portal valve where the water tunnel transitions to the pipeline or the pipeline drainage valve where the pipeline exits the canyon heading towards the treatment plant. Flow releases would likely be restricted by the hydraulic capacity of AWWU’s pipeline, which might make this alternative feasible for providing smaller year-round instream flows. Again, this would require the design, installation and operation of water release mechanisms."

Ceal Smith Section 6.2.1 Flow Related (page 134) The Eklutna Pumped Energy Storage (Eklutna PES) concept offers the potential to increase energy generation capacity, provide Information regarding the Eklutna PES concept has been included in the Final IIP, see page Alaska Institute for Climate low-cost storage for the integration of renewable energy resources and improve availability and management of water in Eklutna 158. and Energy (ALICE) Lake and lower Eklutna River, thus assisting ongoing salmon restoration efforts. We hope you will consider including an analysis of relevant components of the Eklutna PES as a means of solving problems identified in the Draft Initial Information Package (IIP) in Section 6, PME Suggestions By Others, as part of the ongoing Eklutna Fish and Wildlife Agreement Stakeholder process.

Page 31 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Brad Meiklejohn Section 6.2.1 Flow Related (page 134) Discussion is warranted here on the idea of converting Eklutna Lake over to a pumped storage battery system. In its simplest Information regarding the Eklutna PES concept has been included in the Final IIP, see page The Conservation Fund iteration, the water discharged at the tailrace could be recaptured, and pumped back up to Eklutna Lake, using Fire Island wind at 158. times of excess wind capacity. This would allow for the “firming up” of additional wind capacity at Fire Island, allow Eklutna Lake to function like a battery, and keep Eklutna Lake levels full and spilling into Eklutna River.

Aaron Leggett Section 6.2.1 Flow Related (page 134) Discussion is warranted here on the idea of Eklutna pumped hydro battery. In its simplest iteration, the water discharged at the Information regarding the Eklutna PES concept has been included in the Final IIP, see page Native Village of Eklutna tailrace could be recaptured, and pumped back up to Eklutna Lake, using Fire Island wind and other sources at times of excess 158. wind capacity. This would allow for the “firming up” of additional wind capacity at Fire Island, allow Eklutna Lake to function like a battery, and keep Eklutna Lake levels full and spilling into Eklutna River. Kerry Williams has developed this idea in a number of articles and presentations. Energy storage capacity could be increased by creating additional reservoirs in high elevation valleys above and around Eklutna Lake, including upper Thunderbird Creek. Knik River water could be pumped to fill these and essentially bypass Eklutna Lake for hydro power flows delivery. With existing renewable production this could supply 100% of Railbelt energy needs at substantial savings relative to current generation and proposed Watana hydropower (Williams, Smith and Higman, 2020). The “pumped hydro Eklutna battery” is a win-win solution that could allow fully restored Eklutna River flows for salmon habitat, reduce costs to electric rate payers and not impact municipal water utilities.

Brad Meiklejohn Section 6.2.1 Flow Related (page 135) Maintaining Eklutna Lake at bankfull and overflowing into the Eklutna River is an achievable and desirable outcome that would Alternative project operational scenarios can be evaluated as part of potential PME The Conservation Fund restore the natural functioning of an anadromous river that has been degraded by hydropower for 92 years. The objective here is alternatives. not to return to a prior condition that may have existed in 1928 or 1954. Rather, the focus should be to provide natural conditions so that the Eklutna River can function and evolve without manipulation or intervention.

Aaron Leggett Section 6.2.1 Flow Related (page 135) Maintaining Eklutna Lake at bankfull and overflowing into the Eklutna River is another achievable, and in some ways desirable Alternative project operational scenarios can be evaluated as part of potential PME Native Village of Eklutna option that would restore some of the natural functioning of an anadromous river that has been degraded by hydropower for 92 alternatives. years. This would not return the river to a condition that may have existed in 1928 or 1954. It would not allow access for adult salmon returning to the lake without fish ladders, water cannons, etc. And, it could impact the most profitable power production schedule. However, it could provide relatively natural conditions so that the Eklutna River below the lake can function and evolve without manipulation or intervention.

Aaron Leggett Section 6.2.2 Non-Flow Related (page 136) NVE sees little development of this restoration/mitigation option, which could restore a sockeye run to Eklutna Lake, potentially There is no existing information regarding the construction of fish passage facilities at the Native Village of Eklutna “Non-flow related measures discussed at the 2018 workshop the largest fishery of the Eklutna system. (see comments on 1.1.3 and 5.4.1.1) Ideally, this would be a flow-related analysis. upper dam, and therefore is not available for inclusion in the IIP. Providing flow for included… 2) fish passage at the upper Eklutna dam to allow Engineering solutions should be investigated that would allow continuous discharge from the lake to the river. This analysis sockeye to travel into and out of the lake is listed as a potential flow-related PME measure migration into and out of the lake…” should be conducted anyway, since current strategies and mechanisms to release flow all have limitations. Fish ladders and in the previous section. Developing information regarding engineering solutions and the water cannons to get salmon around the upper dam are possible secondary options to consider. necessary flow requirements to provide fish passage into and out of the lake will be considered by the TWG during the scoping of the engineering feasibility and cost assessment component of the study program.

Monica Keim Section 6.2.2 Non-Flow Related (page 136) Are there any plans to allow lamprey to access Eklutna Lake? Is there any historical presence? They require different fish-passage To the best of our knowledge, there is no historical presence of lamprey in the Eklutna Undergraduate - APU "Non-flow related measures discussed at the 2018 workshop needs than salmon (ex. rounded corners on fish-ladders). River. included… 2) fish passage at the upper Eklutna dam to allow migration into and out of the lake..."

Aaron Leggett Section 6.2.2 Non-Flow Related (page 136) The USACE recommendations for improving fish habitat in the lower river are detailed. It should be noted that these alternatives This has been clarified in the Final IIP, see page 160. Native Village of Eklutna were not developed as mitigation for the hydropower project impacts and should be re-examined for feasibility and cost-benefit potential with restored flows from Eklutna Lake. They do not restore what was lost, but substitute for it. Also, NVE worked with USDA NRCS to assess potential support for implementing some USACE habitat improvement measures. NRCS concluded that the stream morphology that has developed between the New Glenn and the railroad tracks is its natural configuration for a southcentral Alaska stream, given the geo-hydrological conditions present.

Michael Knapp Section 6.3 Information Needs (page 143) The proposed introduction of intentional flow releases into the Eklutna River from the Upper Dam could present risks to Comment noted. ADOT&PF downstream public interests. While not highlighted or underscored, these risks are acknowledged and identified in the IIP. Under Section 6.3 Information Needs, the impacts to downstream infrastructure is listed first, along with dam safety, flood protection, and liability for sediment further in the list. It is encouraging to see that new studies are underway to evaluate geomorphic changes in the basin. Aaron Leggett Section 6.3 Information Needs (page 144) Should be: “Impacts of straying fish from tailrace fishery to Eklutna River with restored flow” Impacts to the native fish stocks in the Eklutna River as a result of fish straying from the Native Village of Eklutna “Straying fish impacts to tailrace fishery” tailrace has been included as a concern in the Final IIP, see page 168.

Page 32 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Sean Eagan Section 6.3.1 Information Matrix (page 145, Table 6-3) Juvenile rearing is discussed in terms of winter and summer rearing in the IIP, however, in the table they are lumped. NMFS The Information Matrix has been updated based on consultation with the stakeholder NMFS suggests separating the seasonal data, as it involves different water allocations at different times of year and affects species group, see page 168. differently. Sean Eagan Section 6.3.1 Information Matrix (page 145 Table 6-3) Smolt habitat may include estuary habitat, however, it would be more clear to create a stand alone Evaluation Parameter called The Information Matrix has been updated based on consultation with the stakeholder NMFS “Eklutna River Estuary Habitat”. We don’t want the juveniles to simply arrive in the Cook Inlet, we need them to thrive once group, see page 168. they get there. Research shows the smolt who go out larger, have greater chance of survival, and smolt that spend time in the estuary usually increase in size. Sean Eagan Section 6.3.1 Information Matrix (page 145, Table 6-3) Does this apply to adults or juveniles or both? The Information Matrix has been updated based on consultation with the stakeholder NMFS "Difference in Abundance" group, see page 168. Austin Williams Section 6.3.2 Ongoing Efforts by Other TU has various studies underway in partnership with other stakeholders that could be referenced: (1) we are partnering with the These studies have been listed in the Final IIP, see page 170. We look forward to reviewing Trout Unlimited Agencies/Organizations (page 147) Native Village of Eklutna to conduct a formal Traditional Ecological Knowledge assessment of the historic and cultural the results when available. importance of the Eklutna River; (2) we are partnering with the Alaska Department of Fish and Game to continue and expand monitoring efforts in the River; and (3) we expect to undertake an off-channel habitat assessment upstream of the lower dam site to better understand necessary flows for habitat viability and use. We are happy to share more and will, of course, share any results once they are available. Section 7: Next Steps

No comments received on Section 7

General

Tom Barret General DNR DMLW appreciates preparation of the non-mandatory IIP document as it is a single comprehensive reference for the Comment noted. ADNR - Water Resources stakeholders. Brad Meiklejohn General In light of the statement in 1.0 Introduction that “the owners have no pre-conception as to any particular outcome or what will Draft documents prepared by the consultant team have been and will be distributed to the The Conservation Fund be included in the Proposed Fish and Wildlife Program”, we find throughout the Draft IIP a large number of statements that cast owners’ representatives first. The 1991 Fish and Wildlife Agreement puts the responsibility doubt on the [owners'] claims of impartiality. If the purpose of the IIP is to present the facts of the matter in an undistorted for developing documents (including the eventual Study Plans and Fish and Wildlife manner, this document falls short. The impression one gets is that the consultant provided the owners with the first chance to Program) on the project owners. Any draft documents prepared by the consultant team edit this document before it was circulated to the working group. It would appear that the owners used this opportunity to tilt are prepared on behalf of the owners. All drafts released for public review are “owners” the narrative in their favor: 1) to cast doubt on the historic presence of sockeye salmon in Eklutna Lake; 2) to cast doubt on the drafts, not “consultants” drafts. extent that Eklutna Dena’ina relied on fish from the Eklutna River; 3) to limit the liability of the owners for impacts throughout the Eklutna River system; 4) to bolster the significance of the Eklutna Project; and 5) to pre-empt discussion of viable alternatives that would restore instream flow to the Eklutna River. Thank you for considering our comments and incorporating them into the Draft IIP. We ask that you revise the Draft IIP to a provide a neutral rendering of the facts. We also request that all future draft documents be circulated simultaneously to all the relevant parties. Providing the drafts first to the owners provides an unfair opportunity to bias the text to their advantage.

Austin Williams General Mitigation Must be Comprehensive and Account for all Impacts to Fish, Wildlife, and Habitat... The 1991 Agreement’s specific The 1992 EA states that the process outlined in the 1991 Fish and Wildlife Agreement is Trout Unlimited and numerous references to spawning grounds and habitat, the 1992 Divestiture Report’s clear explanation that concern over similar to and should work "at least as well as" the FERC licensing and relicensing process. impacts to sockeye salmon helped drive the 1991 Agreement, and the belief at the time that the 1991 Agreement would provide The EA further clarified that because the project was originally constructed by the Federal stronger protections for fish and wildlife and their habitat than traditional FERC licensing, make clear that protection, mitigation government and therefore did not require a FERC license, there was no existing regulatory and enhancement efforts by the utilities must be comprehensive and account for all impacts to fish, wildlife, and habitat. mechanism or requirement to reevaluate the project's impacts to environmental resources under continued Federal ownership. Therefore, the process outlined in the 1991 Agreement to develop a Fish and Wildlife Program, and reevaluate it every 35 years, would provide better opportunity for the protection, mitigation of impacts to, and enhancement of fish and wildlife than if the project had stayed under Federal ownership. Note that the 1991 Agreement is a procedural document and does set any specific substantive expectations regarding the proposed PME measures or the content of the Fish and Wildlife Program.

Page 33 Author Draft IIP Section (Page) Comment Response Agency/Interested Party "Text"

Rick Sinnott Project Website, FAQ This statement is incorrect. Anchorage Light & Power sold all of its physical assets, including the diversion dam, to the City of During initial consultation meetings with stakeholders in March/April 2019, there was “The Eklutna Hydroelectric Project is unrelated to the historic Anchorage in 1944. In the Eklutna Project Act of July 31, 1950, Congress authorized the Secretary of the Interior to "perform any some general confusion regarding which hydropower project we were talking about due to diversion dam constructed in 1929 on the lower Eklutna and all acts and enter into such agreements as may be appropriate for the purpose of carrying out the provisions of this Act the recent lower dam removal project. The purpose of including this statement on the River and removed in 2017-2018.” [authorizing construction of the Eklutna hydro project] into full force and effect, including the acquisition of rights and property." website's FAQ page was to clarify that the lower diversion dam is not considered part of A contractual agreement (no. 14-06-906) between the City of Anchorage and the U.S. Bureau of Reclamation was signed in 1953. the existing Eklutna Hydropower Project. Additional information regarding the sale of the This agreement transferred the old power plant "and associated facilities and properties" (e.g., the diversion dam) to the USBR. 1929 project to the City of Anchorage, the sale of the old project facilities and water rights According to the contractual agreement, this "removed the last remaining legal hurdle to construction of the Eklutna project." to USBR, and the transfer of the lower diversion dam and associated property to Eklutna, The old power plant and diversion dam were still operational in 1953; however, the USBR chose to decommission the Inc. pursuant to ANCSA has been included in the Final IIP. hydroelectric facility so that it wouldn’t compete with the federal hydro development. In the 1989 Purchase Agreement (as amended) the federal government sold and transferred to the Producers “the power production, transmission, associated real property and all other facilities and assets provided or otherwise acquired for Eklutna under the Eklutna Project Act of July 31, 1950 (64 Stat. 382, as amended) including but not limited to …” [emphasis added]. Only one dam is included in the list because the diversion dam was no longer in use. However, it had been in use in 1950 when the act was passed and certainly falls under the “but not limited to” clause. This is further clarified by the definition of Eklutna in the Purchase Agreement, wherein Eklutna “means any and all property and facilities acquired or used in connection with Eklutna” [emphasis added]. As explained above, the federal government had acquired the existing hydro facilities built in 1928 and 1929 to eliminate competition for the lake’s water and to remove “the last remaining legal hurdle to construction of the Eklutna project.” You cannot deny that the decommissioned diversion dam was not part of the Eklutna project.

Page 34