UTBB hired technical experts* in the fields of cultural resources and archaeology, fisheries, and hydroelectric licensing to review Nushagak Cooperative’s application to help analyze potential impacts of the proposed project as stated in the draft application.
The topics they provided input on include:
Fisheries and aquatic resources
Tribal and public engagement
Cultural, Tribal, and subsistence resources
Climate change and hydrological analysis
Economics
Review their key concerns below to help inform and complete your own comment letter.
Fish Passage, Fisheries, and Aquatic Resources
No enforceable commitments to protect fish:
Though the Cooperative has expressed its intention to protect fish, the draft license application includes no enforceable commitments to actually protect salmon populations. Instead, the Cooperative relies on non-binding promises, future decisions, and unspecified post-license “adaptive management” to address salmon protection.
Need for more protective licensing conditions:
Section 6 of the Federal Power Act restricts amendments to licenses after issuance without the licensee’s consent. Because the Federal Energy Regulatory Commission rarely enforces major unilateral modifications post-license, the draft license application should not rely on future adaptive management and reopening of the license. Instead, the draft license application needs to include protective and enforceable default license conditions.
Absence of fish screens and entrainment risks:
Estimates show as much as half of all Nuyakuk River out-migrating smolts could interact with the project. The Cooperative proposes no fish screens, leaving juvenile salmon highly vulnerable to impingement and entrainment.
No commitment to a turbine type:
Turbine survival rate for fish ranges widely, from 0% to 98% based on turbine selection. The Cooperative suggests a Kaplan-type turbine but makes no binding commitment to a specific design. While the Cooperative relies on data from the largest types of Kaplan Turbines, small, high-RPM Kaplan units (the type likely to be used) cause severe mechanical strike and decompression trauma, yielding survival rates as low as 20%–40%. The applicants should either commit to fish screens or Natel’s FishSafe turbines (which claim a 98% turbine survival rate).
No consideration of avian predation:
Discharging concentrated volumes of potentially stressed or disoriented juvenile salmon into a confined tailrace area creates artificial “feeding stations” for birds and predatory fish. Avian predation is a major source of smolt mortality arising from hydro-systems in other river basins. The draft license application ignores this potential threat to fish.
Flaws in modeling and methodology for impacts on fish:
Conclusions on potential impact to salmon populations rely on an unverified model that lacks peer review. Models should be developed and conducted collaboratively with Bristol Bay Tribes and community members, and subjected to an open peer review process.
Tribal and Public Engagement
Inadequate Tribal and public engagement:
There have been significant barriers to Tribal and public engagement in the process, including the Cooperative holding in-person meetings only in Dillingham during the current and previous comment periods. During the current comment period on the draft license application, the Cooperative held a single townhall meeting that did not include detailed information about the application or adequate time for comment. Instead, the limited time resulted in participants being rushed in making comments or asking questions.
Exclusion of Indigenous Knowledge:
The draft license application omits Yup’ik knowledge for salmon, plants, and wildlife.
Cultural, Tribal, and Subsistence Resources
No attempt to document Traditional Cultural Places:
There is still no attempt by the Cooperative to document Traditional Cultural Places or other ethnographic places as required by the National Historical Preservation Act-Section 106 process. Meaningful consultation with Bristol Bay Tribes is needed to identify places of cultural importance and potential impacts. Cultural sites, ancestral locations, place names, and the Nuyakuk Falls portage trail are improperly evaluated as isolated, individual sites rather than a cohesive Historic District or Traditional Cultural Place.
Inadequate consideration of transmission lines:
The defined Area of Potential Effects excludes transmission lines. Further, the draft license application does not consider the potential impacts of increased access along transmission lines.
Changes to subsistence studies:
The Cooperative significantly changed the study methods from in-depth household surveys to superficial community workshops, diminishing the effectiveness of the analysis and results to assess potential impacts.
Subsistence data gaps:
Baseline subsistence data for Ekwok is severely lacking, and the applicant proposes monitoring biological resources without tracking shifts in actual community harvest patterns.
Climate Change and Hydrological Analysis
Lack of climate analysis or future flows analysis:
The application fails to meaningfully evaluate climate warming trends, ignoring documented flow changes. Crucial “Future Flows” analyses and Life Cycle Models for sockeye salmon are completely absent from impact evaluations. This analysis is critical to address the projected impact on salmon populations and economic viability of the project, depending on the amount of water diverted.
Overreliance on historic flow averages:
Estimates for the project’s potential power production rely solely on average flow conditions from recent record periods, failing to account for year-to-year variability or quantify the frequency of years where adequate power generation flows cannot be maintained. Further, there is little specification of how power will be generated during low flows or when migrating fish need to be protected. These analyses should explicitly account for the year-to-year variability in river flows under current conditions and climate-altered future scenarios.
Economic Issues
Economic feasibility and transparency:
Current estimated project costs exceed $500 million, well above previous estimates, yet economic viability remains unverified. Installing necessary fish screens and fish safe turbines could render the project uneconomic, which could explain the Cooperative’s reluctance to commit to protective measures.
How to Share Your Concerns:
Encourage your Tribe, City, or Village Corporation to submit an official comment
stating how this project would impact subsistence or other cultural activities. Interested entites can contact dlarson@utbb.org for assistance submitting their comment.
Submit a comment yourself.
We encourage you to add to your comment to share what concerns you most about the project. You may edit the template letter on this page.
All comments are due by November 16.
*Technical experts who contributed to this list include:
Dr. Daniel Schindler, Fisheries Research Institute
Steve Edmondson, Fisheries Biologist & retired Federal Energy Regulatory Commission leader
Monty Rogers & Peter Schnurr, Archaeologists, Cultural Alaska
