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Before the FERC Application for New License for the Annex Creek ...

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United States Department of <strong>the</strong> Interior<br />

IN REPLY REi=E:M TO:<br />

~. i "',"J -<br />

• • ~ ! ,.:<br />

~'.'\J ~~ ,:~ 1'~:;5;.A<br />

~;',:t:.:n. 'W!mlt<br />

Sara Hunt<br />

400 Willoughby Avenue<br />

Suite 400<br />

Juneau, Alaska 99801<br />

FISH AND \VILDLIFE SERVIC=:<br />

p.o. Box 1287<br />

Juneau, Alaska 99802<br />

May 22, 1985<br />

Re: ADL 51675<br />

Certification No. 611<br />

Salmon <strong>Creek</strong><br />

Dear Ms. Hunt:<br />

We have reviewed your request <strong>for</strong> comments on <strong>the</strong> Alaska Electric Light and<br />

Power Company's (AEL&P) application <strong>for</strong> a chanqe of appropriation of water.<br />

The U.S. Fish and Wildlife Service (FWS) has met with Dave Hoopes of R.W. Beck<br />

and Associates, Inc., representing AEL&P in <strong>the</strong> relicensing coordination <strong>for</strong><br />

<strong>the</strong> Salmon <strong>Creek</strong> hydroelectric project. Mr. Hoopes has worked closely with<br />

<strong>the</strong> Alaska Department of Fish and Game (ADFG) in establishing a minimum<br />

acceptable flow <strong>for</strong> <strong>the</strong> creek.<br />

On April 29, 1985, biologists from <strong>the</strong> FWS and The National Marine Fisheries<br />

Service walked <strong>the</strong> lower portion of <strong>the</strong> creek up to <strong>the</strong> staff gauge. The<br />

staff gauge indicated a water depth of 1.5 feet. The staff gauge was in poor<br />

condition, but did not appear unstable. At a depth of 1.5 feet, all areas<br />

that we exaJnined which appeared to be of potential importance to anadromous<br />

fish were floooed. Previous field work by <strong>the</strong> Division of Commercial<br />

Fisheri.es indicates that <strong>the</strong> recorded low flows of 1985, corresponding to 1.4<br />

feet at <strong>the</strong> staff guage, were sufficient to protect all documented s-pawning<br />

habitat within accessible portions of <strong>the</strong> creek. Although this figure<br />

reflects a very low flow <strong>for</strong> this creek, we will concur with ADFG.<br />

Because changes in channel contours and elevations of natural drainages occur<br />

over time, we believe it is necessary to correlate <strong>the</strong> minimum acceptable<br />

depth with a value in cubic feet per second (cfs). He understand that AEL&P<br />

has obtained a range <strong>for</strong> this value using discharge data from <strong>the</strong> u.s.<br />

Geological Survey. The amount of discharge at 1.4 feet depth varies between 7<br />

and 9 cfs. Because of this variability and because of our concern that<br />

spawning beds remain inundated throughout <strong>the</strong> winter, it is appropriate that<br />

<strong>the</strong> higher figure serve as <strong>the</strong> standard. Should <strong>the</strong>re be changes in <strong>the</strong><br />

course or contour of <strong>the</strong> stream, a new staging gauge value should be selected<br />

which corresponds to a discharge of approximately 9 cfs.<br />

Of additional concern is <strong>the</strong> national record of fish loss which results when<br />

flow levels are not adequately monitored. Monitoring is absolutely critical<br />

if minimum flow standar.ds are to have any value. Monitor.ing and proper<br />

regulation must also insure that excessive water is not dumped from <strong>the</strong> Salmon<br />

<strong>Creek</strong> Dam.

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