Read our comment on on the Chugach Electric Association, Matanuska Electric Association, and Municipality of Anchorage’s Eklutna Hydroelectric Project Draft Fish and Wildlife Program.
Since the Eklutna Hydroelectric Project became operational in 1955, it has caused the Eklutna River to run dry. The Project’s adverse effects on fish and wildlife in the Eklutna River were not evaluated for almost 70 years after project construction due, in part, to the existence of the lower diversion dam, which prevented salmon from ascending to Eklutna Lake and the upper reaches of the river. However, since the lower diversion dam was removed in 2018, the Project’s continued diversion of all controllable flow at Eklutna Lake to the Project’s powerhouse on Knik Arm and the complete disconnection of the river to the lake and upper tributaries are, and will continue to be under the Project Owners’ Program, the primary causes for ongoing degradation of fish and wildlife habitat in the Eklutna River system.
Eklutna Lake in 1944, courtesy of U.S. National Archives and Records Administration
Rather than fully evaluate alternatives that would avoid, minimize, or mitigate the project’s adverse effects, as would generally be required for the relicensing of any other similarly-sized non-federal hydropower project, the Project Owners have put forward a Draft Program that would maintain those adverse effects by continuing to dewater a portion of the lower Eklutna River and deny salmon access to the majority of the system’s salmon habitat for the next 35 years. The Draft Program shows that the Project Owners did not fully evaluate alternatives that would mitigate and enhance, let alone avoid or minimize the Project’s ongoing impacts to sockeye, Chinook, and coho salmon habitat even though the loss of the sockeye salmon run was one of the express reasons for the 1991 Eklutna Fish and Wildlife Agreement.
Impacts to Wildlife
Overall, the Plan recognizes that increasing the Eklutna River’s flow below the dam will “directly or indirectly benefit several ecologically and/or culturally important wildlife species” such as wolves, moose, raptors, and bears. Yet, because of the severe lack of adequate baseline data, it is impossible to truly analyze and understand how the different alternatives would impact and potentially benefit all wildlife and their habitat and to what degree.
For example, even though listed in the “observed or expected” wildlife list, the Draft Program fails to consider imperiled species like the Little brown bat (Myotis lucifugus) that rely on the Eklutna watershed and for which mitigation and enhancement of their foraging habitat in the lower Eklutna River valley, which is currently harmed by the Project, could be improved by increasing flows and rebuilding off channel habitat in the lower river. The Draft Program also fails to analyze why certain wildlife populations appear to be below normal levels. For example, the Summary of Study Results notes that “[w]aterfowl and shorebird numbers in the study area were moderate and low, respectively, during the field surveys” and that “[s]horebirds were noticeably absent during the spring surveys.” This may be an example of a system that is in depression from nearly a century of harms from hydroelectric dams. These examples, and many others, highlight the Draft Program’s inadequacies in considering and rigorously analyzing how the different alternatives would impact all non-salmonid fish and wildlife in the Eklutna system and whether the preferred alternative provides adequate mitigation and enhancement.
Endangered Cook Inlet beluga whales, photo by Paul Wade NOAA
Regarding marine mammals, the Draft Program fails to consider the protection, mitigation, and enhancement of Cook Inlet beluga whales (Delphinapterus leucas), one of the nation’s most critically endangered marine mammals. The best available science shows that Cook Inlet belugas could significantly benefit from increased salmon runs in the Upper Cook Inlet. Given the mouth of the Eklutna River is within designated critical habitat in upper Cook Inlet where the majority of the Cook Inlet beluga population forages during the summer, the critically endangered whales should be a primary concern for the Program.
The 2011 critical habitat designation for Cook Inlet belugas identified shallow intertidal and subtidal waters of Cook Inlet in close proximity to medium to high flow anadromous fish streams along with four species of Pacific salmon (Chinook, sockeye, chum, and coho) as essential to the beluga’s conservation (also known as Primary Constituent Elements). NOAA Fisheries’ 2016 Recovery Plan for the Cook Inlet Beluga Whale identifies prey availability as a threat of medium concern for their recovery. NOAA Fisheries acknowledges the heightened importance of prey availability, specifically Pacific salmon, for conserving Cook Inlet beluga whales. NOAA Fisheries has also identified Cook Inlet beluga whales as one of the species most at risk of extinction, and in their Species in the Spotlight, 2021-2025 Action Plan, state that, “[s]urvival and recovery of Cook Inlet beluga whales depend on an adequate quantity, quality, and accessibility of prey resources.”
In a recent notice to issue an Incidental Harassment Authorization (IHA) proposal from the Port of Alaska, NOAA Fisheries noted that, “Pacific salmon represent the highest percent frequency of occurrence of prey species in CIBW stomachs.” The notice highlighted that rich foraging areas to the north of the Port of Alaska, including the Eklutna River, are important to belugas and that the whales correlate their movements into Knik Arm around the timing of the salmon runs in those rivers. A recent 2023 study by Wild et al. delineated portions of Cook Inlet, including Knik Arm and the mouth of the Eklutna River, as a Biologically Important Area (BIA) for the small and resident population of Cook Inlet beluga whales based on scoring methods outlined by Harrison et al. in 2023.
The best available science shows that restoring abundant salmon runs may be one of the key strategies available for Cook Inlet beluga recovery by creating more foraging opportunities for belugas in upper Cook Inlet. The results of a 2020 study by Norman et al. suggest that “reproductive success in [Cook Inlet belugas] is tied to salmon abundance” in the Deshka River, which is also located in upper Cook Inlet near Knik Arm and the Eklutna River. That study showed that “if salmon runs remained at their current levels, the [Cook Inlet beluga] population would likely continue its current slow decline,” yet the study found that “if Chinook salmon increased 20% or more, the current decline would likely be reversed.” Furthermore, the study simulations found that “doubling the salmon abundance would be sufficient to allow recovery of the population regardless of impacts from other threats.” The study noted that while Chinook are the most nutritionally important salmon species for Cook Inlet belugas, belugas still rely on other salmon species as important prey. Moreover, a recent 2023 study by McHuron et al. found that if there is enough prey available for Cook Inlet belugas, the whales can withstand other intermittent stressors, concluding that increasing prey availability increases the beluga’s resiliency to threats.39 Another recent 2023 study by Warlick et al. stated that “aerial survey data suggest that the [Cook Inlet beluga] population continues to decline[, and the] leading hypotheses include reduced prey availability […].”
The proposed nominal flow releases from the AWWU Portal will only minimally enhance Chinook and coho salmon and their habitat in the lower Eklutna River. The AWWU Portal provides no solution for the complete blockage of salmon reaching the extensive lake spawning habitat required by sockeye salmon and miles of upper tributaries spawning habitat above the lake that is highly amenable to Chinook and coho salmon, both of which are primary forage species for Cook Inlet belugas. Without connection to Eklutna Lake, protecting, mitigating, and enhancing those key spawning grounds and habitat is impossible. In turn, the mitigation and enhancement for Cook Inlet beluga whales are likely to be minimal as well. Furthermore, no analysis was completed for how the other alternatives considered would benefit Cook Inlet belugas. The Draft Program’s severely inadequate analysis of non-salmonid fish and wildlife fails to meet the purposes of the Agreement and the standard of a similar federal process, and severely inhibits the Governor’s ability to make an informed decision.
Eklutna Project is the limiting factor preventing the restoration of the Eklutna River that flows from its headwaters to its confluence with the Knik Arm. Plainly, the Project Owners’ Draft Program to continue to promote lack of connectivity of the ecosystem is inadequate to mitigate the Project’s harms to fish and wildlife. Adequate and equitable fish and wildlife protection, mitigation, and enhancement, as required by the Agreement, requires the lake and upper tributary streams to be connected to the lower river and adequate flows for salmon to thrive. As such, we request that the Project Owners reconsider their proposed alternative, and instead promote methods which ensure a connected ecosystem.
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