United States Department of the InteriorNATIONAL PARK SERVICE

Alaska Region240 West 5" Avenue, Room 114

Anchorage, Alaska 99501

IN REPLY REFER TO:

L7425 (AKRO-EPC)ER 12/0747

NOV 292012

VIA ELECTRONIC MAIL: NO HARD COPY TO FOLLOW (FERC eFile P-13563-001)

Kimberly D. BoseFederal Energy Regulatory Commission (FERC)888 First Street, N.E.Washington, D.C. 20426

Subject: NPS comments and preliminary license condition recommendations on DraftLicense Application and Preliminary Draft Environmental Assessment for FERC ProjectNo. 13563, Sweetheart Lake Hydroelectric Project

Dear Secretary Bose:

The National Park Service (NPS), Alaska Region, Hydropower Assistance Program offersthe following response to the Commission's October 10,2012 request for preliminaryterms, conditions, and recommendations on the Preliminary Draft EnvironmentalAssessment (PDEA) and comments on the Draft License Application (DLA). Ourresponse is based on review of the DLA and PDEA submitted on August 31, 2012, byJuneau Hydropower Incorporated (JHI). The NPS Hydropower Assistance programconsults with license applicants and stakeholders providing technical assistance inassessing impacts on public recreational resources during the FERC licensing process. Theprogram draws its authority from the Federal Power Act and technical assistanceprovisions of the Outdoor Recreation Act of 1962, the Wild and Scenic Rivers Act of1968, and the National Trails System Act of 1968.

The proposed Sweetheart Lake project would consist of: (1) the existing Lower SweetheartLake, raised from a surface water elevation of 551 feet and a surface area of 1,414 acres toa new surface water elevation of 576 feet and a new surface area of 1,702 acres; (2) a new,approximately 278-foot-Iong, 105-foot-high, 100 foot-thick (thickness at the base) rollercompact concrete dam, constructed at the outlet of Lower Sweetheart Lake; (3) an intakeon the dam connecting to a 12-foot-diameter, 9,593-foot-Iong unlined tunnel; (4) an8-foot-diameter, approximately 980-foot-Iong penstock installed within the lower portionof the tunnel, connecting to the powerhouse; (5) a powerhouse containing three newFrancis generating units (6.6 MW each) with a total installed capacity of 19.8 MW; (6) anew tailrace discharging flows to Sweetheart Creek; (7) a new approximately 4,400 footlong road from the powerhouse to the dock/landing site; (8) a new dock/landing site for

boat, seaplane, and/or helicopter access, located on the east shore of Gilbert Bay; (9) anew 138-kilovolt transmission line that would be a total of45,900 feet long (25,700 feetof submarine cable in two segments; 15,400 feet of overhead transmission line onSnettisham Peninsula; and 4,400 feet ofburied transmission line in two segments) ; and(10) appurtenant facilities.

Consultation with NPS

To date, JHI and NPS have consulted throughout the Alternative Licensing Process for thisproject on the Communications Protocol, Pre-application Document (PAD), ScopingDocuments, recreation and aesthetics study plans, and study plan results. JHI's studies anddocumentation of baseline conditions have generally yielded useful infonnation that willsupport the development oflicense tenns and conditions. NPS recognizes, however, thatas primary land manager of the proposed project area, the U.S. Forest Service's (FS)Section 4(e) conditions will supersede conflicting NPS recommendations. We alsorecognize that the project's compatibility with the FS Semi-Remote and Timber HarvestLand Use Designations for the area, along with the Roadless Rule, has not yet beendetennined.

Preliminary Draft Environmental Assessment

The PDEA includes much useful infonnation about the project's likely impacts, and, ingeneral, NPS finds this assessment to be accurate. However, we note several places in thedocument where the text is confusing, or where generic placeholders ("X") were used toreference figures or values, suggesting the PDEA was rushed with minimal editing prior tobeing filed. We also note that some statements in the PDEA do not appear to be supportedby infonnation included in the document. For these reasons it is not possible to providefinal recommendations for license tenns and conditions to protect recreation and aestheticsresources.

Our specific comments on the PDEA are as follows:

Recreational Resources

The conclusion that the users who would be most affected by the project are those visitingGilbert Bay and Lower Sweetheart Creek in summer appears accurate. However, thedetennination in Section 1 on page 207 ofminimal recreation impacts based on oneobserved helicopter landing over a four month field season misses the importance of suchlightly used areas. Recreational resources like Sweetheart Lake are not only characterizedby the number ofvisitors, but by the type of experience. Low likely encounter rates areoften the reason for the use, providing a higher degree of independence and self-reliance,as well as the sense of a completely undisturbed natural setting. Regardless of how fewvisitors were observed during the field seasons, it is quite likely that demand foropportunities like those currently provided by Sweetheart Lake will increase over the next50 years. For this reason, the environmental assessment of should consider the site's

proximity to Juneau and also to the Tracy Arm-Fords Terror Wilderness, and evaluatelikely impacts ofdam construction and project operation on the lake.

With respect to the proposed access road, the proposed location of the road appearsinconsistent with the FS preference for siting such facilities further from the shoreline.The draft environmental assessment (DEA) will need to address this basic issue.

With respect to new or improved recreational trails in the vicinity of the anadromous reach,the intent appears to be to construct or refurbish these trails using rock from the powertunnel (p. 26). However, the condition of these existing informal trails has not beenassessed and a plan for trail construction, maintenance, and management based on trailpurpose has not been presented. These objectives, along with the environmental impacts ofany proposed trail work, should be included in the DEA.

The recreational survey data depicted in Figure 57 is difficult to understand. If the bars areintended to represent the percentage of respondents who favored each of the possiblerecreational facilities along the x axis, it appears that some respondents contradictedthemselves, saying both that they didn't want any new facilities, and that they did want oneor more of the facilities listed. Also, if almost 60% of respondents do not want newfacilities, including recreational trails, why are they proposed? Clarification would behelpful.

On page 270, a new FS-maintained cabin to facilitate overnight visits to the area isproposed. It is unclear if this is part of the project, or is a separate FS project.

Aesthetics Resources

While many aspects of the proposed project design, such as use of a power tunnel, buriedtransmission lines, and a low-profile powerhouse, appear to mitigate the aesthetic impactsof the project, more detail would be helpful. For example, assessment of the projectimpacts on Sweetheart Lake or the cascades above the barrier falls, true photo renderingsofproposed facilities, and supporting information for baseline visual conditions used forthe visual resource management (VRM) analysis would be useful.

Specifically, while use of the lake and areas above the anadromous reach may be light,these areas are visible from the air. Although no demand projections were included, thenumber of overflights by recreational users, both private and guided, can be expected toincrease over the term of an original license. We recommend including an assessment ofhow the project would alter these aesthetic values, including the dam, scoured lakeshoreresulting from project operations, and the visual impact of reduced flows in the dewateredreach of the creek below the dam.

In applying the Bureau of Land Management (BLM) VRM methodology, JHI used a singlepoint of reference, Gilbert Bay. Given the concentration ofuse at the anadromous reach,we suggest using this location as a key observation point as well. Also, an inventory ofexisting viewsheds and a description of the visual resource objectives for the area would

enhance the outcome when applying the contrast rating criteria. More detail would behelpful in the assessment ofthe project's impacts on fonn, line, color or texture. Werecommend that the level of aesthetics analysis be augmented to allow for development oflicense conditions to mitigate likely impacts.

The DEA would benefit from including photos showing the likely appearance ofthe dam,penstock, power house, dock, etc. We suggest these be added. Figure 73, which shows thetwo access road alternatives, is not a true photo rendering. It shows a winter photo of ashort stretch of shoreline with two colored lines indicating routes. The preferred route isgreen and the upland route is red. A true photo rendering would more realistically showthe color and location of the road surface and changes in the landscape due to road grading,removal of vegetation, signs and guard rails, etc.

Preliminary Section 10Ca) Recommendations

Based on the infonnation in the PDEA, NPS has the following preliminaryrecommendations for license conditions that would partially mitigate impacts onrecreational resources. We are deferring recommendations on aesthetic resources pendingfurther detail and analysis of likely impacts as suggested above.

1) Area users should be provided notice of the project construction schedule well inadvance of the first season of construction, including closures and other restrictions with apoint of contact for more infonnation. A website and/or listserve could be used tocommunicate with potential visitors.

2) A recreational management plan should be developed for the project. This plan shouldinclude details on the construction and maintenance of new project facilities such as trails,docks and moorages used for recreational purposes. It should be developed in consultationwith the FS and with user groups, and should include provisions for adaptive management.

NPS appreciates the opportunity to review the Sweetheart Lake PDEA and to providepreliminary Section lO(a) recommended tenns and conditions. If you have questions,please contact Cassie Thomas, NPS Hydro Program coordinator for the Alaska Region, at(907) 350-4139 or <cassie_thomas@nps.gov>.

Sincerely,

/s/

Nancy SwantonInterim Team ManagerEnvironmental Planning and Compliance

cc:Duff Mitchell, Business ManagerJuneau Hydropower, Inc,