View RDC's comment letter

Deadline for Comment was May 31, 2012

Overview:
The public comment period for the proposed Sussitna-Watana Hydroelectric Project has been extended to May 31, 2012. The Federal Energy Regulatory Commission (FERC) held public “scoping meetings” in March for the proposed project. The current “scoping” process is the first step in a required federal Environmental Impact Statement for the project. FERC is the lead agency on the EIS and is the agency collecting public comments. The public scoping process allows for public input so that all pertinent issues, concerns, and opportunities are identified as the environmental review is undertaken. Following the current public comment period, the next step would be preparation of a draft EIS, followed by a final EIS and Record of Decision. The EIS determines whether, and under what conditions, to issue a license for the project.

On a separate regulatory track, FERC must also issue a federal certificate for the project. The Alaska Energy Authority (AEA) filed a Preliminary Application Document in December and anticipates filing a full license application by 2015 with hopes that the agency can issue the license in 2016 or 2017.

In 2010, the Alaska State Legislature passed legislation outlining a State energy policy. The bill directs the State to receive 50 percent of its electrical generation from renewable and alternative energy sources by 2025. Hydropower, the lowest cost energy for Alaska consumers, currently provides approximately 24 percent of the electrical energy used in Alaska. The only way to achieve the new goal of deriving 50 percent of our electricity from renewable and alternative sources is for a new, large hydroelectric project to be built in the Railbelt region.

The 2010 Legislature provided funding to AEA for the preliminary planning, design, permitting and field work for the Susitna-Watana Project. AEA recommends that the Lower Watana site on the Susitna River should be the primary hydroelectric project for Alaska’s Railbelt. Of the projects examined, Susitna not only has the best chance of being built; AEA believes it will provide cost-effective, reliable, power for the Railbelt at a constant price for decades, and it will help the State meet its recently established long-range goal.

The proposed project would be located approximately halfway between Anchorage and Fairbanks on the upper Susitna River. The Susitna-Watana dam would be located within a steep-sided valley of the Susitna River at 184 miles above the mouth. The single dam would be at the same location below Watana Creek as in the much larger two-dam Susitna project proposed in the 1980s.

The project would have a capacity of 600 megawatts and meet half of the electricity requirements expected in the future for communities now connected to the regional power grid. Construction would get underway in 2017 and under the present schedule it could be in operation by 2023. At its peak, about 1,000 people would be employed in construction, with an additional 2,000 support jobs. The most recent cost estimate is $4.34 billion.

Action requested:
RDC members are encouraged to provide comments to FERC in support of the project. It is important to communicate your support for the EIS to reinforce the multiple environmental studies that have been completed, and the need for a sustainable and reliable energy source for Railbelt communities and businesses. Written comments are accepted online or by mail.

Submit comments to:
Online Submittal:
http://www.ferc.gov/docs-filing/efiling.asp

Mail:
Federal Energy Regulatory Commission
888 First Street NE
Washington, D.C., 20426
Reference: Susitna-Watana Hydroelectric Project, Docket Number P-14241

Additional information on the project is available at:
http://www.susitna-watanahydro.org/

Points to consider in your comments:

• FERC and all permitting agencies should not delay the completion of the environmental review and approval for this sustainable energy infrastructure project. The FERC process provides five years for studies and analysis. Considering the studies performed in the 1980s, this is more than ample time for completing environmental work and monitoring. It is also important to recognize that data analysis for modifying or improving upon environmental enhancement can continue during the five-year construction period. Railbelt energy consumers may be at risk if the project is needlessly delayed.
• The Susitna-Watana Hydroelectric Project will address Railbelt energy uncertainty by providing stable, reliable, long-term power for generations to Alaskans. The benefit of stable energy prices will become more pronounced over time because the fuel that drives hydropower – water – is free.
• The project will diversify the Railbelt’s energy portfolio and provide needed security to help our economy resist disruptions caused by potential interruptions in fuel supplies and market fluctuations in energy prices. Price volatility and high cost of electricity is a limiting factor in economic development.
• Alaska cannot achieve the 50 percent renewable energy goal without a project like Susitna-Watana.
• The proposed project is important to economic growth and resource development in Alaska.
• The project will lead to economic benefits, including new business and jobs. Project construction will produce an estimated 1,000 jobs, with an additional 2,000 support jobs. Moreover, it has the potential to expand the economy by attracting new business to the region.
• The certainty of achieving the intended outcome of stable, predictable, lower cost energy is relatively high, considering the abundance of success with hydropower in Alaska, the U.S., and globally. In Alaska, Bradley Lake is now one of the cheapest sources of electricity on the Railbelt, costing about a third less than natural gas. When built in 1991, Bradley Lake hydropower was about twice the cost of natural gas, but gas prices have risen while the cost of Bradley Lake water has not.
• In the US, recent studies by the National Hydropower Association show that hydropower offers the lowest levelized cost of electricity of all major energy sources and costs less than energy efficiency options.
• Once built, hydro projects can last 50-100 years with very low operating costs and without needing major replacement or repairs.
• The Susitna-Watana Project is compatible with, and complimentary to, other forms of energy. The need for natural gas, renewables, and other forms of generation to fill Alaska’s energy demand will not go away. For example, natural gas is likely a better source for heating than electricity.
• Multiple studies have demonstrated that once built, hydropower’s carbon footprint drops virtually to nothing, and the infrastructure lasts for decades.
• Resource industries in Alaska will benefit from stable, and long-term electrical energy that can be the baseload for economic growth and diversification.
• The project can be safely built in our seismically-active state, just like other major infrastructure and dam projects that are built in earthquake zones around the world.
• The project will include mitigation measures to stabilize Susitna River salmon runs, as well as moose and caribou abundance. In fact, there are opportunities for improvement. At a minimum, the project has the ability to help manage river flows that are favorable to fisheries. The Bradley Lake Hydro Project on the Kenai Peninsula is a model for fish and wildlife abundance and good public policy.
• A recent Hellenthal survey of Alaskan voters showed 60 percent support for the project.

Deadline for Comment was May 31, 2012