An understanding of future flows and stream temperatures is necessary to inform the design of project infrastructure, including fish passage protection measures, and project operations. The best available science indicates temperature, precipitation, and stream flows will increase in the Bristol Bay region, and much of south central Alaska (IPCC 2018; Walsh 2014; Walsh 2018). Thus, higher stream flows and volume are likely within the project area during the prospective license term. Peer-reviewed, publicly available downscaled climate model projections have been developed for this region. These model projections should be analyzed to support flow analysis for this project. We request that the existing peer reviewed climate model predictions be used to model future discharges and water temperatures for the Nuyakuk River, in accordance with peer-reviewed published methods and generally accepted practice as described below. This information will inform the development of license articles guiding operation and maintenance, including mitigation measures, as well as the development of a climate resilient project design. The Nuyakuk River supports a commercial, subsistence and recreational sockeye fishery, as well as the four other Pacific salmon species. These species rely on these riverine systems for refuge, spawning, rearing and nursery habitat. The Nuyakuk River and Tikchik Lake supports the second largest sockeye run in the world; second only to the Kvichak River and Lake Iliamna. Adult sockeye pass through the Nuyakuk cascade to spawn in the lakes above. Smolts pass back down the cascade on route to the ocean to mature. Furthermore, the timing of adult escapement and smolt outmigration is keyed to water temperature, which is strongly affected by air temperature (Mauger et al. 2016) and projected to change with increasing air temperature. Many of the climate change effects described below have likely impacts on salmonids (Leppi 2014; Wobus 2015). Given that increased flows are projected by the five member ensemble of global climate models (GCM) best fitted for Alaska, these increases provide opportunities to benefit both the hydropower generation and fish management and protection. Therefore, it is critical to have estimates of future flows and stream temperatures to assess the combined effects of the project and climate on these trust resources. This study is at the core of producing more evenly distributed year-around hydropower generation, while at the same time protecting and maintaining this salmon fishery. This is in line with recent literature that highlights opportunities to design and operate hydropower projects for sustainability of both power production and the riverine environment (Brown et al. 2015; Poff et al. 2016). Thus, our study request will identify forward looking, climate resilient outcomes for hydropower development and fisheries. Trends in the Region We included published literature and first hand observations from 2019 for the Bristol Bay Watershed. Documented trends include (Thoman 2019): • Increase of 3.7º F in air temperature in the Bristol Bay region, 1969-2018 • Increase of 13 percent increase in annual total precipitation in
Both infrastructure and the primary and secondary effects of climate change on river hydrology and water temperature can affect salmonid populations and other NOAA trust species. Management actions, including those proscribed in fish passage design and the design and operation of hydropower dams, provide the opportunity to build resilience to climate change for these populations and their habitat. For example, both more frequent heavy rainstorms and an increase in the proportion of precipitation falling as rain versus snow may result in increased frequency of peak flow events. Changes in snowpack, timing of snowmelt, and the spring pulse may result in altered hydrograph and reservoir storage. Both types of changes affect fisheries, habitat, and infrastructure. These, in turn, impact hydropower operations and mitigation measures. A key management implication is the need for considering these risks during infrastructure design and licensing. However, NOAA has not yet offered concrete guidance on how to incorporate climate change into a proposed action. This presentation will discuss efforts by NOAA Fisheries to develop guidance to incorporate climate change risks into these key infrastructure planning arenas, including appropriate choices of climate information and how to design a project to support NMFS’ statutory requirements.
This chapter presents three cases of providing climate science for water policy decisions and the tangible challenges and opportunities encountered by scientists. These challenges include (1) different timeframes typical to funding and implementing research projects versus the often short timeframes of policy and legal processes; (2) the implications of divergent incentive structures for academic research compared to applied science and services; (3) the need to translate, synthesize, and interpret scientific results to serve the context of the decision or policy at hand; and (4) meeting the “best available science” criteria for many federal policy decisions. An additional critical function of scientists working in boundary organizations is identified—the framing of relevant climate questions. Finally, the efforts to participate in coproduction of policy-relevant science have value beyond the report or synthesis product itself. The outcomes of these stakeholder engagement efforts are described, and the benefits reaped by the science organization from the resources invested beyond the usual research models. Finally, it is argued that meeting the demands for usable science for policy requires ongoing support for the participation of research scientists and institutions in service functions.
This report is an attachment to the comments of the NOAA National Marine Fisheries service on the Brookfield White Pine Hydro, LLC’s Notice of Intent to File a License Application to FERC and Filing of Pre-Application Document for the Hiram Project (P - 2530)
Abstract: This presentation focuses on linking climate knowledge to the complicated decision process for hydropower dam licensing, and the affected parties involved in that process. The U.S. Federal Energy Regulatory Commission issues licenses for nonfederal hydroelectric operations, typically 30-50 year licenses, and longer infrastructure lifespan, a similar time frame as the anticipated risks of changing climate and hydrology. Resources managed by other federal and state agencies such as the NOAA National Marine Fisheries Service may be affected by new or re-licensed projects. The federal Integrated Licensing Process gives the opportunity for affected parties to recommend issues for consultative investigation and possible mitigation, such as impacts to downstream fisheries. New or re-licensed projects have the potential to “pre-adapt” by considering and incorporating risks of climate change into their planned operations as license terms and conditions. Hundreds of hydropower facilities will be up for relicensing in the coming years (over 100 in the western Sierra Nevada alone), as well as proposals for new dams such as the Susitna project in Alaska. Therefore there is a need for comprehensive guidance on delivering climate analysis to support understanding of risks of hydropower projects to other affected resources, and decisions on licensing,. While each project will have a specific context, many of the questions will be similar. This presentation will discuss what have become best practices for the use of climate science in hydropower reservoir & other large-scale water projects (e.g. the proposed Lake Powell Pipeline in Nevada), how creating the best and most appropriate science is also still a developing art. We will discuss the potential reliability of that science for consideration in long term planning, licensing, and mitigation planning for those projects. For the science to be “actionable,” the science must be understood and accepted by the potential users. This process is a negotiation, with climate scientists needing to understand the concerns of users and respond, and users developing a better understanding of the state of climate science in order to make an informed choice. We will also discuss what is needed to streamline providing that analysis for the many re-licensing decisions expected in the upcoming years.
The Commission-approved Study Plan for the Project does not order evaluation of the Project's effects in the light of future climate change. NMFS proposes this new information collection or study according to the regulations implementing the ILP, 18 C.F.R. § 5.15 (e), for good cause. Significant new information, material to the study objectives has become available, in the form of climate change study methods and application developed since NMFS' initial study requests were submitted on July 22, 2014. Additionally, California has experienced record drought conditions from 2012 to 2015, culminating in snowpack levels in 2015 that are estimated to the be lowest in 500 years (Belmecheri et al., 2016). This information suggests that climate change is currently affecting the Project area and will continue to do so over the term of any new license issued to the Project. NMFS provides further explanation of good cause below, as required under the regulations. § 5.15 (e) (1): Any material changes in the law or regulations applicable to the information request; NMFS does not find this criterion applicable here. § 5.15 (e) (2): Why the goals and objectives of any approved study could not be met with the approved study methodology; The existing Commission-approved Study Plan does not order evaluation of the Project's effects in the light of future climate change. The existing Commission-approved Study Plan uses historical and static flow and water temperature conditions to evaluate the Project's effects. This approach limits the usefulness of assessments of Project effects on anadromous fishes and their
The Glacier and Runoff Changes (GRC) Study determination from the Federal Energy Regulatory Commission (FERC) Dispute Resolution (April 26, 2013) requires for the literature review as "described in Revised Study Plan (RSP) section 126.96.36.199." The RSP describes the literature review method: to summarize the current understanding of the rate and trend of glacier retreat and the contribution of glacial mass wasting to the overall flow of the Upper Susitna watershed, include trend analyses of glacier retreat, temperature, and precipitation." However, the implied objective, to understand potential future changes in runoff associated with glacier wastage and retreat, cannot be met through a literature review alone because no such literature exists for the region of the Susitna basin. While the Glacier and Runoff Changes Literature Review Study (7.7) provides a reasonable review of some of the ways temperature and precipitation variability may impact glaciers, the climate literature review within is brief (one page), inadequate, and does not refer to key literature relevant to Alaska. However, it does point to a range of potential temperature and precipitation changes, an unambiguous reduction in ice volume, and implications for water chemistry. A literature review is inadequate as a method to understand the future changes in glaciers and runoff with changing climate for infrastructure planning and determining project impacts from the combined and in some instances, synergetic effects of both the project construction and operations and changing climate on biota in the river. Climate change has become a key lens through which resource management decisions must be evaluated and addressed. The existing FERC-approved Study Plan does not order evaluation of the combined effects of the Project and climate change. Given that this large project will greatly alter natural flows which wild anadromous fish are adapted to in the Susitna River, and will alter habitats that anadromous fish depend upon for various stages in their life histories, and climate change will also continue to affect these same flows and habitats, the project's effects are likely to exacerbate the effects of the project. The existing FERC-approved Study Plan uses historical and static flows (high, low and average water years) and water temperature conditions to evaluate the proposed Susitna-Watana hydropower project's (Project) effects. The approved glacial and runoff changes study is limited to review of existing literature relevant to glacial retreat, and summarizing the understanding of potential future changes in runoff associated with glacier wastage and retreat (hereafter referred to as the Glacial and Runoff Changes (GRC) literature review, Wolken et al (2014)). This literature review approach is not adequate to assess the combined risks of climate change and 7.7 Glacier and Runoff Changes