A set of environmental, recreational, and engineering studies supporting the Grant Lake hydroelectric project is missing necessary information, according to comments made by the Federal Energy Regulatory Commission (FERC), the federal agency that licenses hydroelectric projects, and other state and federal agencies.

In March the Grant Lake project’s creator Kenai Hydro LLC, a wholly-owned subsidiary of Homer Electric Association, submitted a draft license application for its proposal to use water from the eastern peninsula’s Grant Lake — diverted to a powerhouse through an underwater opening and returned a half-mile down Grant Lake’s natural outlet, Grant Creek — to generate an estimated 5 megawatts of electricity.

In this document, a draft of a final license application that HEA plans to submit in December, HEA gave its assessment of the environmental and cultural effects of the project’s operation and construction. In FERC’s comments on the draft license application, released June 17, FERC’s Hydropower Licensing Project Coordinator Kenneth Hogan wrote that the research contains “potential deficiencies and some additional information needs.”

One issue requiring additional research, according to the FERC comments, is the effect on fisheries of reducing water flow in a portion of Grant Creek. Grant Lake and Grant Creek’s resident fish species include Dolly Varden, rainbow trout, whitefish, grayling, and sculpin. Anadromous species documented as breeding in Grant Creek are sockeye, cohoe, pink, and chinook salmon.

Although water taken from Grant Lake by the proposed project will bypass roughly half of its natural course in Grant Creek, HEA representatives have said in previous public presentations and documents that the decrease in flow will have a minimal effect on Grant Creek’s fish because the partially dewatered portion of the creek — referred to in HEA’s research as “Reach 6” — is naturally a steep area with waterfalls and fast current, making it a poor habitat and breeding ground.

In 2013, HEA conducted fishery studies in Grant Lake and Grant Creek, but in its draft license application wrote “since the waterfalls pose a barrier to upstream migration of fish, Reach 6 and Grant Lake have not been included in recent research efforts.”

The FERC comments noted that no research — present or past — was cited in the draft application regarding fish use of Reach 6.

Comments by the U.S. Fish and Wildlife Service also address issues in HEA’s 2013 fisheries research and analysis. Jeffry Anderson, supervisor of the Kenai Fish and Wildlife Field Office, wrote in his comments that environmental sampling done during a single year is insufficient to “differentiate potential impacts of the Project from natural background variation.”

Anderson wrote that the 2013 research was particularly inadequate for drawing conclusions about the project’s impact on chinook salmon. The Fish and Wildife comments state that HEA’s “current analyses of potential effects are based on the lowest abundance of chinook salmon ever recorded in the Kenai River.” Anderson wrote that in 2013 his agency observed a record low number of chinook salmon in the Kenai River — the watershed of which includes Grant Creek — and that using this chinook population as a basis for comparison may distort future data.

One indirect impact of the hydroelectric project will be the increased access it allows to Grant Lake, which is presently inaccessible to vehicles. HEA plans to build an access road to the project site, and has not yet decided whether to make the road publicly accessible.

The FERC comments noted a lack of analysis of effects this road may have, including a potential increase in erosion and an impact on wildlife through the increased human activity, such as hunting, that it would bring. The draft license application states that hunting in the Grant Lake area is open for “black bear, brown bear, caribou, Dall sheep, moose, mountain goat, wolf, and wolverine.”

In addition to environmental studies, HEA’s draft license application included studies of recreational use of the Grant Lake area, which were the subject of comments from individuals and agencies including the National Park Service. Comments by Joan Darnell, manager of the National Park Service’s Planning and Compliance team, stated that because tourism is a major economic contributor to the local community, “NPS thinks recreation and associated aesthetic resources deserve more attention than (Kenai Hydro LLC) has chosen to give them during the study process.”

The NPS comments state that HEA’s recreational use studies were flawed by insufficient data collection. HEA collected information on recreational use through four cameras at area trails and through summer and winter field observations. Darnell wrote in the NPS comments that “to our knowledge, the (draft license application’s) description of winter recreational use is based on a single day of observation: Saturday, March 3rd 2015.” According to the NPS comments, the summer recreational observations were also performed on a single day — July 12, 2013. Darnell wrote that single-day observations are inadequate because recreational use varies in response to weather patterns, time of the week, and hunting and fishing seasons.

One definite impact of the project will be on the proposed Iditarod National Historic Trail, a planned hiking path following the historic Iditarod mail route from Seward to Nome, which passes through the Grant Lake area. The path of the future trail in that area has been held as a state easement by Chugach National Forest since 2004.

The draft license agreement states that as the trail and the Grant Lake project are currently planned, the trail will have a single 90-degree crossing with the project’s access road. According to comments by the Alaska Department of Natural Resources, the easement as presently located runs through the project’s powerhouse, and the statement in the draft license application was based on an assumption that the trail easement will be moved.

Aside from the Iditarod mail route, the Grant Lake area has other artifacts and structural remains from the early settlement and gold-rush eras of Alaska history. These artifacts are discussed in a part of the draft license application kept confidential in order to prevent vandalism or other damage to the artifacts.

Mark Luttrell, an archeologist in the Grant Lake area, reviewed the draft license application’s assessment of historical resources and the accompanying management plan for those resources. Luttrell has previously opposed the Grant Lake Project as a member of the environmental group Resurrection Bay Conservation Alliance and also submitted comments against the project to FERC as an individual.

Although he was unable to talk about confidential details, Luttrell said that increased access to the area could threaten these artifacts, and that HEA’s plan to protect them was “insufficient to protect the cultural resources.”

“HEA’s proposal will have a negative impact on cultural resources,” Luttrell said, adding that the impacts were potentially irreversible. He said that HEA had recognized the adverse effects and was working to mitigate them.

A comment submitted to FERC from the Kenai River Special Management Area Advisory Board supported the project. The board unanimously voted to support the Grant Lake project at its meeting on May 14. In an interview following that meeting, board president Ted Wellman said that the hydropower project was “an opportunity to lower the carbon footprint on the Peninsula. By itself, it’s not going to mean a huge amount of energy. But what it will do is kind of incrementally add some energy that’s being wasted and lost.”

Wellman said that his group is generally against hydropower projects, but chose to support Grant Lake.

“We look at them on an individual basis and we saw a minimal impact on the resource and an opportunity to improve the energy situation,” Wellman said.

HEA began its studies of Grant Lake in 2008 after receiving a three-year study permit from FERC. The permit expired in 2012, but research continued during a second three-year permit that expired in February 2015. After FERC denied HEA’s March request for a 10-month extension of its preliminary study permit, HEA is able to continue research although FERC will no longer recognize its priority for potential licenses on the site.

Kenai Hydro, LLC Manager of Fuel Supply and Renewable Energy Development Mike Salzetti wrote in an email that HEA is in the process of reviewing the comments.

“HEA appreciates the proactive step FERC has taken in issuing these comments and we look forward to thoroughly reviewing the comments, discussing them with FERC and refining our Draft License Application into a Final License Application,” Salzetti wrote. “HEA is currently compiling and evaluating all comments received on the Draft License Application. HEA’s plan is to compile a response to all of the appropriate comments that we received and file those responses with FERC. Depending on the number of comments received, the format of the comments and the complexity of the comments, HEA expects this process to take from two to four months. Using input from the relevant comments, HEA will compile the Final License Application which we expect to file with FERC in December of this year.”

Reach Ben Boettger at ben.boettger@peninsulaclarion.com.