FERC refuses to force Alaska hydro project applicant to perform climate change studies

Susitna Watana

The Federal Energy Regulatory Commission has rejected an attempt by a federal fisheries agency to force the Alaska Energy Authority to perform speculative climate change studies as part of licensing the 600-MW Susitna-Watana hydroelectric project on Alaska's upper Susitna River.

The National Marine Fisheries Service had appealed an April ruling in which FERC approved 14 remaining environmental studies for the Susitna-Watana project (No. 14241). In making that ruling, FERC Energy Projects Director Jeff Wright had turned down applicant Alaska Energy Authority's plan for climate change studies, which were proposed at NMFS' request. Wright said the studies would be costly -- an estimated $1 million -- and likely to produce uncertain results.

After that ruling, NMFS initiated a study dispute resolution procedure in which it did not prevail, then requested FERC rehearing of the rejection of the climate change studies. In a July 18 order, the full commission upheld its action.

"The commission agrees with NMFS that the effects of climate change on streamflow conditions and any corresponding adverse effects on environmental resources are important issues, and any substantial information regarding these matters will be given due consideration in the commission's environmental analysis and in any subsequent license order," FERC said. "However, the commission does not agree that the climate change studies proposed by AEA and requested by NMFS are likely to yield reliable data that can be used in the development of license requirements, particularly when balanced against the cost of such assessments."

Instead, FERC said, effects of the project on environmental resources can be studied effectively and evaluated using conventional hydrologic studies, monitoring techniques, and predictive models, as has been done in other hydroelectric licensing cases. FERC added its standard license reopener article would permit the license to be changed later if unanticipated adverse environmental effects occur during the course of the license.

FERC did approve two components of the climate change studies. One calls for AEA to analyze potential changes to sediment delivery from the upper Susitna watershed into the reservoir from glacial surges. Also, saying it would be low cost, FERC approved a requirement that AEA review existing literature relevant to glacial retreat in south central Alaska and the upper Susitna watershed and summarize the understanding of potential future changes in runoff associated with glacier wastage and retreat.

It rejected a request that AEA develop a hydrologic modeling framework that utilizes a glacier melt and runoff model and a water balance simulation model to predict changes in glacier wastage and retreat on runoff in the Susitna Basin resulting from climate change. It also rejected a request that AEA simulate the inflow of water to the proposed reservoir and predict changes to available inflow using downscaled climate projections up to the year 2100.

Norris: "Climate change ... firmly before us in this order"

In a concurring opinion, Commissioner John Norris noted, "The issue of whether the commission needs to consider climate change when evaluating the potential environmental effects of a commission-licensed hydroelectric facility is firmly before us in this order."

"Based upon the currently available climate change models, I agree that some of the climate change studies proposed here would impose additional significant costs while being unlikely to yield data that can be sufficiently relied upon for use in the development of license requirements," Norris said. "However, as climate change modeling continues to advance, it may eventually yield data and knowledge that can and should be used to formulate license requirements that respond to environmental effects caused by climate change."

While not mandating the additional studies, the commission did add that AEA was free to conduct the $1 million in studies voluntarily.

In 2012, NMFS requested proposals from contractors to study the vulnerability of Alaska hydropower production to climate variability and change, using as a case study the proposed Susitna-Watana project. In June, President Obama announced a climate change plan aimed at reducing carbon dioxide emissions.


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