State's angry letter defends Susitna dam salmon science

WASILLA -- The state entity pushing a contentious dam on the Susitna River fired off an outraged response this week to the federal contention that the project's salmon science is flawed.

The National Marine Fisheries Service last month filed a critical letter with federal regulators saying the Alaska Energy Authority's fish data was so unreliable it wasn't usable. The NMFS critiqued everything from juvenile coho salmon wrongly labeled chinook to shortcuts in field studies and problems with scientific models.

Wayne Dyok, the authority's dam project manager, dismissed the agency's flawed science claims as "untenable, bordering on the absurd" in an aggressive and at times abrasive letter filed Tuesday with the Federal Energy Regulatory Commission.

"We really needed a strong letter," Dyok said during an interview Thursday. "We felt that the professionalism and integrity of our team, particularly the fisheries team, was being questioned, and we really take that challenge very seriously."

The tone of Dyok's letter was unusual for a federal hydro filing, especially when compared to letters from agencies like the Alaska Department of Fish and Game or Department of Natural Resources, said Jan Konigsberg, an energy analyst and Susitna dam critic who has spent years evaluating projects going through the federal licensing process.

"They certainly don't take that sort of tone with any of the public filings," Konigsberg said.

The tension between the agencies reflects the fact that the Susitna's salmon -- and the dam's effect on them -- are at the heart of the dam debate.


The state's proposal to put a 735-foot, 600-megawatt-capacity dam on the Susitna is touted as a major influx of renewable energy to the Railbelt but also castigated as too great a threat to the river's world-famous salmon runs.

The project to date has cost more than $190 million. Current estimates put the cost of building the dam at more than $5 billion.

The state's salmon studies will form the basis of a much larger Federal Energy Regulatory Commission decision to license the project. The authority expects to file a license application with FERC in December 2016.

NMFS, the federal agency responsible for protecting anadromous fish like salmon and marine mammals, came out swinging last month in its critique of a June report summarizing the state's first-year dam studies.

The agency's top Alaska official in a Sept. 22 letter told the authority that the report contained "data issues" that undercut the state's ability to understand the health of Susitna salmon now and predict the effects of the massive project on fish in the future.

Among other things, the letter faulted data collection methods -- it describes a "very high percentage" of misidentified juvenile salmon -- and said problems getting access to Alaska Native corporation lands last year led to incomplete studies. The authority initially failed to get permission to conduct research at the dam site and project area from a number of Alaska Native village corporation landowners.

The agency also contends federally approved study plans aren't being correctly followed.

The problems should be fixed before the state does any more field work, Alaska region administrator James W. Balsiger wrote.

"NMFS recommends that the data issues be resolved as soon as possible," the letter states.

Dyok, in his response letter, says the authority was "largely successful" putting a FERC-approved study plan into place last year. That included 10 studies covering more than 200 sampling sites across more than 200 river miles.

Yes, land access problems and late breakup in the spring of 2013 stalled field work, but the state modified study plans in response, he said.

As for the misidentified salmon, Dyok writes, the state "takes exception to any suggestion that it has not implemented the FERC-approved study plan in a professional manner." He praises the qualifications of what he calls nationally renowned experts working for five contractors with highly qualified field technicians, many with advanced degrees from the University of Alaska system.

Identifying young salmon can be tricky, Dyok said. Photos the authority included with a press release this week show the same 10-centimeter juvenile salmon -- a chinoho? -- in different pictures facing different directions. Arrows pointing to markings indicate the fish in question could be either coho or chinook.

Dyok's letter also accuses NMFS of making "a number of outright errors and instances in which you ignore available information," specifying pink salmon counts, relative salmon abundance information and development of fish passage criteria. A table details authority responses to NMFS concerns.

NMFS officials this week said it would be counterproductive to issue a response before they join the authority and numerous other agencies at a series of technical meetings coming up next week in Anchorage.

Agencies and interested parties involved in the Susitna licensing process will meet for six days to talk about the state's studies.

"Any comments we were to make now would be detrimental to the meetings next week where we will be discussing these issues," said Doug Mecum, the agency's deputy administrator in Alaska.


It's not clear how FERC will view the skirmish between the agencies. A spokesperson didn't return a call for comment.

The federal agency comments at this stage are only preliminary, Konigsberg noted. FERC will look much more closely at formal comments filed in February.

"I don't think this is as critical," he said.

Contact Zaz Hollander at

Zaz Hollander

Zaz Hollander is a veteran journalist based in the Mat-Su and is currently an ADN local news editor and reporter. She covers breaking news, the Mat-Su region, aviation and general assignments. Contact her at