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UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

Energy Northwest Project No. 2244-022

NOTICE OF AVAILABILITY OF FINAL ENVIRONMENTAL ASSESSMENT

(July 1, 2009)

In accordance with the National Environmental Policy Act (NEPA) of 1969 and the Federal Energy Regulatory Commission's (Commission) regulations, 18 CFR Part 380 (Order No. 486, 52 FR 47879), the Office of Energy Projects has reviewed the application for a new major license for the Packwood Lake Hydroelectric Project (project), located on Lake Creek in Lewis County, Washington, and has prepared a final Environmental Assessment (EA). In the final EA, Commission staff analyze the potential environmental effects of licensing the project and conclude that issuing a license for the project, with appropriate environmental measures, would not constitute a major federal action significantly affecting the quality of the human environment.

A copy of the final EA is on file with the Commission and is available for public inspection. The final EA may also be viewed on the Commission’s website at http://www.ferc.gov using the “eLibrary” link. Enter the docket number excluding the last three digits in the docket number field to access the document. For assistance, contact FERC Online Support at [email protected] or toll-free at 1-866-208-3676, or for TTY, (202) 502-8659.

Kimberly D. Bose,Secretary.

PKWD-09-053

C.3.9.11.B (MPF)C.3.9.11.B (Pkwd)Letterbook (MPF)Licensing (eFile)

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FINAL ENVIRONMENTAL ASSESSMENT

FOR HYDROPOWER LICENSE

Packwood Hydroelectric Project—FERC Project No. 2244-022

Washington

Federal Energy Regulatory CommissionOffice of Energy Projects

Division of Environmental and Engineering Review888 First Street, NE

Washington, DC 20426

July 2009

TABLE OF CONTENTS

LIST OF FIGURES.............................................................................................................v

LIST OF TABLES.............................................................................................................vii

ACRONYMS AND ABBREVIATIONS...........................................................................ix

EXECUTIVE SUMMARY................................................................................................xi

1.0 INTRODUCTION....................................................................................................11.1 APPLICATION.............................................................................................11.2 PURPOSE OF ACTION AND NEED FOR POWER..................................1

1.2.1 Purpose of Action............................................................................11.2.2 Need for Power................................................................................3

1.3 STATUTORY AND REGULATORY REQUIREMENTS..........................31.3.1 Federal Power Act............................................................................51.3.2 Clean Water Act...............................................................................61.3.3 Endangered Species Act..................................................................61.3.4 Coastal Zone Management Act........................................................81.3.5 National Historic Preservation Act..................................................81.3.6 Pacific Northwest Power Planning and Conservation Act..............91.3.7 Wild and Scenic Rivers Act...........................................................101.3.8 Magnuson-Stevens Fishery Conservation and Management Act. .101.3.9 Wilderness Act...............................................................................11

1.4 PUBLIC REVIEW AND CONSULTATION.............................................121.4.1 Scoping..........................................................................................121.4.2 Interventions..................................................................................121.4.3 Comments on the License Application..........................................131.4.4 Comments on the Draft EA............................................................13

2.0 PROPOSED ACTION AND ALTERNATIVES...................................................152.1 NO-ACTION ALTERNATIVE..................................................................15

2.1.1 Existing Project Facilities..............................................................152.1.2 Project Safety.................................................................................182.1.3 Existing Project Operation.............................................................182.1.4 Existing Environmental Measures.................................................20

2.2 APPLICANT’S PROPOSAL......................................................................202.2.1 Proposed Project Facilities.............................................................202.2.2 Proposed Project Operation...........................................................202.2.3 Proposed Environmental Measures................................................222.2.4 Modifications to Applicant’s Proposal—Mandatory Conditions. .26

2.3 STAFF ALTERNATIVE.............................................................................292.4 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM

FURTHER ANALYSIS..............................................................................29iii

3.0 ENVIRONMENTAL ANALYSIS.........................................................................313.1 GENERAL SETTING.................................................................................313.2 SCOPE OF CUMULATIVE EFFECTS ANALYSIS.................................31

3.2.1 Geographic Scope..........................................................................323.2.2 Temporal Scope.............................................................................32

3.3 PROPOSED ACTION AND ACTION ALTERNATIVES........................323.3.1 Aquatic Resources.........................................................................323.3.2 Terrestrial Resources...................................................................1093.3.3 Threatened and Endangered Species...........................................1403.3.4 Recreation and Land Use Resources............................................1543.3.5 Aesthetic Resources.....................................................................1753.3.6 Cultural Resources.......................................................................179

4.0 DEVELOPMENT ANALYSIS............................................................................1874.1 POWER AND ECONOMIC BENEFITS OF THE PROJECT.................1874.2 COMPARISON OF ALTERNATIVES....................................................188

4.2.1 No-action Alternative...................................................................1894.2.2 Energy Northwest’s Proposal......................................................1894.2.3 Staff Alternative...........................................................................190

4.3 COST OF ENVIRONMENTAL MEASURES.........................................1904.4 NEW PROJECT FACILITIES RECOMMENDED TO BE

INCLUDED IN ANY NEW LICENSE....................................................190

5.0 CONCLUSIONS AND RECOMMENDATIONS...............................................2015.1 COMPARISON OF ALTERNATIVES....................................................2015.2 COMPREHENSIVE DEVELOPMENT AND RECOMMENDED

ALTERNATIVE........................................................................................2025.3 UNAVOIDABLE ADVERSE EFFECTS.................................................2235.4 SUMMARY OF SECTION 10(J) RECOMMENDATIONS AND 4(E)

CONDITIONS...........................................................................................2245.4.1 Recommendations of Fish and Wildlife Agencies.......................2245.4.2 Land Management Agencies’ Section 4(e) Conditions...............228

5.5 CONSISTENCY WITH COMPREHENSIVE PLANS............................230

6.0 FINDING OF NO SIGNIFICANT IMPACT.......................................................233

7.0 LITERATURE CITED.........................................................................................235

8.0 LIST OF PREPARERS........................................................................................245

Appendix A Draft License Articles................................................................................A-1Appendix B Comments on the Draft EA.......................................................................B-1

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LIST OF FIGURES

Figure 1-1. Packwood Lake Hydroelectric Project location....................................2Figure 2-1. Packwood Lake Hydroelectric Project, detail of the outlet area.........15Figure 2-2. Packwood Lake Hydroelectric Project, detail of the powerhouse area16Figure 2-4. Packwood Lake minimum and maximum water levels restrictions

under existing and proposed conditions..............................................21Figure 3-1. Packwood Lake minimum and maximum monthly water levels........35Figure 3-2. Vertical temperature profiles for Packwood in the deepest area of the

lake......................................................................................................42Figure 3-3. Hourly discharge and water temperature at the intake, and tailrace

during mid-July to mid-September 2005............................................45Figure 3-4. Water temperature in the end of the Packwood Project tailrace and the

side channel of the Cowlitz River, October 2005 to October 2005....46Figure 3-5. Packwood Lake tributary study sites..................................................53Figure 3-6. Lower portion of Lake Creek (reaches 1 through 3)...........................56Figure 3-7. Lower portion of Lake Creek (reaches 4 and 5).................................57Figure 3-8. Study site locations in Snyder Creek..................................................59Figure 3-9. Monthly lake levels and inflow from January 1999 to December 200769Figure 3-10. Comparison of before and with project annual highest mean daily

flow, Lake Creek near Packwood gage...............................................86Figure 3-11. Fish entrained on traveling screens at the Packwood Lake

Hydroelectric Project during January through August 2007..............99Figure 3-12. Packwood Lake area recreational access..........................................156Figure 3-13. Packwood Lake area recreational facilities.......................................157Figure 3-14. Land use designation within the Packwood Lake area.....................162Figure 3-15. Packwood Lake area recreational access (detailed map)..................167

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LIST OF TABLES

Table 1-1. Major statutory and regulatory requirements for the Packwood Lake Hydroelectric Project.....................................................................................4

Table 3-1. Inflow (cfs) to Packwood Lake...................................................................33Table 3-2. Summary of Packwood overtopping events, 1967 to 2006.........................35Table 3-3. Flow (cfs) at gages along Lake Creek and the Cowlitz River.....................38Table 3-4. Water quality parameters.............................................................................40Table 3-5. Water temperature monitoring data for 2004..............................................43Table 3-6. Water temperature monitoring data for 2005..............................................44Table 3-7. Mean annual pH and turbidity levels...........................................................47Table 3-8. Lake Creek salmonid species periodicity....................................................50Table 3-9. ESA-listed fish species in the Packwood Lake Hydroelectric Project

area...............................................................................................................51Table 3-10. The total number of O. mykiss spp. and O. mykiss spp. redds observed

during the 2007 Packwood Lake tributaries spawning surveys..................54Table 3-11. Habitat type percentages for the five reaches surveyed on lower

Lake Creek...................................................................................................57Table 3-12. Comparison of measured water temperatures in 2005................................65Table 3-13. Proposed instream flows (cfs) for lower Lake Creek as measured at the

drop structure...............................................................................................75Table 3-14. Summary of spawning weighted useable area by month for lower Lake

Creek (current conditions and proposed flows with enhancements)...........80Table 3-15. Summary of rearing weighted useable area by month for all sites in

lower Lake Creek (current conditions and proposed flows with enhancement)...............................................................................................82

Table 3-16. Preferred, upper lethal, and lower lethal water temperatures (in °C) for Chinook and coho salmon, steelhead/.........................................................84

Table 3-17. Interim ramping rate guidelines for water diversions in Washington state..............................................................................................................92

Table 3-18. Summary of approach velocity measurement at the Packwood Lake Hydroelectric Project fish screens.............................................................100

Table 3-19. Noxious weeds observed within study area...............................................112Table 3-20. Special status and MIS wildlife species that are known to occur or may

occur in the project area.............................................................................115Table 3-21. Federally listed species and designated critical habitat in Lewis

County and documented occurrences in the Packwood Lake Hydroelectric Project vicinity....................................................................141

Table 3-22. Average daily use of Pipeline Road/FS Trail 74 and FS Trail 78.............159Table 3-23. Summary of roads in project vicinity and Energy Northwest’s usage......165Table 3-24. Forest Service Visual Quality Objectives..................................................176Table 3-25. Archaeological sites within the Packwood Lake Hydroelectric

Project area of potential effects.................................................................181

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Table 4-1. Parameters for the economic analysis of the Packwood Lake Hydroelectric Project.................................................................................188

Table 4-2. Summary of the annual cost, power benefits, and annual net benefits for the alternatives for the Packwood Lake Hydroelectric Project............189

Table 4-3. Costs of environmental mitigation and enhancement measures considered in assessing the environmental effects of continuing to operate the Packwood Lake Hydroelectric Project....................................192

Table 5-1. Fish and wildlife agency recommendations for the Packwood Lake Hydroelectric Project.................................................................................226

Table 5-2. Forest Service preliminary 4(e) conditions for the Packwood Lake Hydroelectric Project.................................................................................229

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ACRONYMS AND ABBREVIATIONS

applicant Energy NorthwestATV all terrain vehicleºC degrees Celsiuscfs cubic feet per secondCommission Federal Energy Regulatory CommissionCouncil Northwest Power and Conservation Council7-DADMax 7-day average of the daily maximum temperatureDO dissolved oxygenEA environmental assessmentEPA U.S. Environmental Protection AgencyESA Endangered Species ActFERC Federal Energy Regulatory CommissionForest Service U.S. Department of Agriculture, Forest ServiceMIS Management Indicator Speciesmg/L milligrams per litermsl mean sea levelMW megawatts MWh megawatt-hoursNMFS U.S. Department of Commerce, National Marine Fisheries Service PHABSIM Physical Habitat Simulation Modelproject Packwood Lake Hydroelectric ProjectUSGS U.S. Geological SurveyWashington Fishand Wildlife Washington Department of Fish and Wildlife

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EXECUTIVE SUMMARY

Energy Northwest (applicant) proposes to continue to operate the existing 26.125-megawatt (MW) Packwood Lake Hydroelectric Project (project) located on Lake Creek near the town of Packwood in southwestern Washington. This project produces about 92,000 megawatt-hours (MWh) of generation annually. Parts of the project occupy 511.65 acres of federal lands administered by the U.S. Department of Agriculture, Forest Service (Forest Service). The Cowlitz Valley Ranger District of the Gifford Pinchot National Forest manages the Forest Service lands. This final environmental assessment (EA) evaluates the potential natural resource benefits, environmental impacts, and economic costs associated with relicensing the Packwood Lake Hydroelectric Project.

Proposed Action

The project consists of a concrete drop structure1 (dam) on Packwood Lake, which creates a 452-acre reservoir at full pond and a network of concrete pipes, tunnels, and penstocks about 5.2 miles long leading to a powerhouse with a single turbine generator. The project is described in more detail in section 2.2. The project is operated depending upon license conditions, water availability, and power contracts. Energy Northwest proposes no capacity changes, but does propose operational changes and measures for (1) the protection and enhancement of environmental resources in the 5.3-mile-long bypassed reach of Lake Creek; (2) implementing an adaptive management plan to reduce entrainment at the project intake; (3) changing the date of the annual maintenance outage to August 15 until September 15; (4) implementing a monitoring plan to evaluate the effectiveness of project operation to meet water temperature standards; (5) improving fish passage on Snyder Creek where it crosses the tailrace canal; (6) developing and implementing plans to control weeds, (7) protecting threatened, endangered, and sensitive species; (8) providing measures to enhance and protect recreational use and trails in the project area; and (9) implementing a Historic Properties Management Plan. These and other related measures are described in detail in section 2.2.4.

Alternatives Considered

This EA analyzes the effects of continued project operation and recommends conditions for a new license for the project. In this EA, we consider three alternatives: (1) Energy Northwest’s proposal; (2) Energy Northwest’s proposal with staff modifications (staff alternative); and (3) a no-action alternative.

Under Energy Northwest’s proposal with staff modifications, the project would be operated as proposed, but would include the following additional measures.

1 A drop structure, also known as a grade control, sill, or weir, is a manmade structure, typically small and built on minor streams, to pass water to a lower elevation while controlling the energy and velocity of the water as it passes over.

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Develop and implement measures consistent with the draft water quality certificate conditions associated with hazardous substance spill prevention and protection of surface and groundwater quality.

Develop and implement a threatened, endangered, and sensitive species management plan which is consistent with the Forest Service condition and Washington Department of Fish and Wildlife recommendation, including conducting surveys for Oregon goldenaster prior to ground-disturbing activities in lower Lake Creek and consulting with resource management agencies regarding timing restrictions or other measures that may be needed to prevent adverse effects on amphibians during efforts to reroute Snyder Creek.

Modify the Integrated Weed Management Plan to expand the list of target species for weed control at sites below the stilling basin, in order to protect the state-listed Oregon goldenaster and prevent the spread of noxious weeds as a result of implementing environmental measures in lower Lake Creek and Snyder and Hall creeks.

Modify the project boundary to ensure that lands and ongoing measures associated with project purposes are brought into the project boundary so the Commission has the authority to administer the required components of the new license.

Pursue formal National Register of Historic Places evaluation of the Packwood Lake facilities in 2014, when the facilities qualify.

Public Involvement and Areas of Concern

Before filing its license application, Energy Northwest conducted a pre-filing consultation process under the integrated licensing process. The intent of the Commission’s pre-filing process is to initiate public involvement early in the project planning process and to encourage citizens, governmental entities, tribes, and other interested parties to identify and resolve issues during the process of completing its application. During the integrated licensing process, the Federal Energy Regulatory Commission (Commission or FERC) conducted scoping to determine what issues and alternatives should be addressed. A scoping document was distributed to interested parties on January 11, 2005. Scoping meetings were held in Packwood, Washington on February 3, 2005. Energy Northwest filed its preliminary licensing proposal on September 22, 2008. Energy Northwest filed its application on February 22, 2008. On June 19, 2008, the Commission issued the notice of ready for environmental analysis and requested comments, recommendations, terms and conditions, and prescriptions. On September 16, 2008,2 the Commission issued the notice of application accepted for filing and soliciting motions to intervene. The Commission issued its draft environmental

2 The September 16, 2008, notice was issued because the June 19, 2008, notice did not solicit interventions.

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assessment (EA) for the proposed relicensing of the Packwood Lake Hydroelectric Project on February 5, 2009. Staff requested comments on the draft EA be filed within 30 days from the issuance date (March 7, 2009). On April 27, 2009, the Commission held a meeting in Olympia, Washington to discuss 10(j) issues and receive and discuss comments on the draft EA with Energy Northwest, resource agencies, and the public.

The primary issues associated with relicensing the project are the amount of flow released to Lake Creek, aquatic enhancement and protection for Lake Creek and the project tailrace area, changes in water level within Packwood Lake due to the change in the timing of the project shutdown, and recreational and land use issues.

Project Effects

Aquatic Resources

Under the applicant’s proposal, salmonid habitat in lower Lake Creek would improve in the 5.3-mile bypassed reach due to higher minimum flows, aquatic habitat forming flows,3 downramping limitations, and aquatic habitat restoration and enhancement plans. Degradation of anadromous habitat would be reduced in the tailrace due to the proposed change in timing of project maintenance shutdown. Slight increases in the water temperature in lower Lake Creek would occur, but would remain below critical levels for salmonids. Under the staff alternative, measures would be developed and implemented for hazardous substance spill prevention and for the protection of surface and groundwater quality as defined in the draft water quality certificate.

Terrestrial Resources

Under the applicant’s proposal, an Integrated Weed Management Plan would help to limit the occurrence and distribution of invasive weeds. Under the staff alternative, we recommend modifying the plan to include potential ground-disturbing activities along lower Lake Creek and Snyder/Hall creeks.

Threatened and Endangered Species

The applicant proposes a threatened, endangered, and sensitive species management plan to address and protect such species and their habitat on project lands. Under the staff alternative, we recommend modifying the plan to include surveys for Oregon goldenaster prior to ground-disturbing activities in lower Lake Creek and

3 The aquatic habitat forming flows are periodic high flows designed to mobilize spawning gravel and small woody debris, and contribute to the formation and maintenance of habitat features needed to sustain and enhance the habitat for resident and anadromous fish.

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consulting with resource management agencies for potential timing restrictions to protect amphibians during efforts to reroute Snyder Creek.

Recreation, Land Use, and Aesthetics

Under the applicant’s proposal, the Recreation Management Plan, filed with the Commission on June 6, 2008, would be implemented to provide a framework for proposed recreational site improvements and management, and road management. The applicant also would implement a resource coordination plan4 to coordinate with various agencies the recommended management plans and associated requirements for the project. Under the staff alternative, we recommend modifying the project boundary to ensure that lands and ongoing measures associated with project purposes are brought into the project boundary so the Commission has the authority to administer the required components of the new license.

Cultural Resources

The Historic Properties Management Plan filed with the Commission on August 30, 2007, would include site monitoring and protection of archaeological and historic sites. Under the staff alternative, we recommend pursuing formal National Register of Historic Places evaluation of the Packwood Lake facilities in 2014.

Conclusion

Based on our analysis, we recommend licensing the project as proposed by Energy Northwest as modified by staff, as described previously under Alternatives Considered.

In section 4.1 of the EA, we estimate the annual net benefits of operating and maintaining the project under the three alternatives identified above. Our analysis shows that the annual net benefit would be $1,745,370 for Energy Northwest’s proposed action; $1,713,620 for Energy Northwest’s proposed action as modified by staff (staff alternative); and $2,445,610 for the no-action alternative. In addition, we estimate the annual net benefit for the staff alternative with mandatory conditions5 as $1,711,920.

4 This plan would provide for coordination of the implementation of the various management plans for Forest Service lands affected by the project, such as, but not limited to, recreation resource management; cultural resource management; integrated weed management; road management; threatened, endangered, and sensitive species management; and other resource protection plans.

5 As discussed later in this document, we do not recommend adoption of a few mandatory conditions such as supplying electrical power to the Forest Service guard station.

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On the basis of our independent analysis, we conclude that issuing a new license for the project, with the environmental measures that we recommend, would not be a major federal action significantly affecting the quality of the human environment.

We chose the staff alternative as the preferred alternative because: (1) the project would provide a dependable source of electrical energy for the region (83,655 MWh annually); (2) the 26.125 MW of electric energy generated from a renewable resource may offset the use of fossil-fueled, steam-electric generating plants, thereby conserving nonrenewable resources and reducing atmospheric pollution; (3) the recommended environmental measures proposed by Energy Northwest, as modified by staff, would adequately protect and enhance environmental resources affected by the project. The overall benefits of the staff alternative would be worth the cost of the proposed and recommended environmental measures.

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1.0 INTRODUCTION

1.1 APPLICATION

On February 25, 2008, Energy Northwest (applicant) filed an application for a new license for the Packwood Lake Hydroelectric Project (project) with the Federal Energy Regulatory Commission (Commission or FERC). The existing project is on Lake Creek, a tributary to Cowlitz River, in Lewis County in southwestern Washington near the unincorporated town of Packwood (figure 1-1). The upper portion of the lake lies within the Goat Rocks Wilderness Area. The project occupies 511.65 acres of U.S. Department of Agriculture, Forest Service (Forest Service) land (administered by the Gifford Pinchot National Forest), 23.66 acres of Energy Northwest-owned land, 8.78 acres of Washington state lands, and 1.52 acres of Lewis County Public Utility District lands. The 26.125-megawatt (MW) project produces about 92,000 megawatt-hours (MWh) of generation annually. The applicant proposes no new capacity and no new construction.

1.2 PURPOSE OF ACTION AND NEED FOR POWER

1.2.1 Purpose of Action

The Commission must decide whether to issue a license to Energy Northwest for the Packwood Lake Hydroelectric Project and what conditions should be placed on any license issued. In deciding whether to issue a license for a hydroelectric project, the Commission must determine that the project will be best adapted to a comprehensive plan for improving or developing a waterway. In addition to the power and developmental purposes for which licenses are issued, such as irrigation, navigation, or water supply, the Commission must give equal consideration to the purposes of (1) energy conservation; (2) the protection, mitigation of, damage to, and enhancement of fish and wildlife resources; (3) the protection of recreational opportunities; and (4) the preservation of other aspects of environmental quality.

Issuing a new license for the Packwood Lake Hydroelectric Project would allow Energy Northwest to generate electricity for the term of a new license, making electrical power from a renewable resource available to its customers.

This final environmental assessment (EA) assesses the environmental and economic effects associated with operation of the project, alternatives to the proposed project, and makes recommendations to the Commission on whether to issue a new license, and if so, recommends terms and conditions that would become a part of any license issued.

In this final EA, we assess the environmental and economic effects of continuing to operate the project (1) as proposed by Energy Northwest and (2) Energy Northwest’s proposal with staff modifications (staff alternative).

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2

Figure 1-1. Packwood Lake Hydroelectric Project location. (Source: Energy Northwest, 2008a, as modified by staff)

We also consider the effects of the no-action alternative. Important issues that are addressed include the amount of flow released to Lake Creek, aquatic enhancement and protection for Lake Creek and the project tailrace area, changes in water level within Packwood Lake due to the change in the timing of the project shutdown, and recreational and land use issues on Forest Service land.

1.2.2 Need for Power

The Packwood Lake Hydroelectric Project would provide hydroelectric generation to meet part of Washington’s power requirements, resource diversity, and capacity needs. The project would have an installed capacity of 26.125 MW and generate about 92,000 MWh per year.

The North American Electric Reliability Council annually forecasts electrical supply and demand nationally and regionally for a 10-year period. The project is located in the Northwest Power Pool area of the Western Electricity Coordinating Council region of the North American Electric Reliability Council. According to North American Electric Reliability Council’s 2008 forecast, average annual demand requirements for the U.S. portion of the Northwest Power Pool area are projected to grow at a rate of 1.86 percent from 2008 through 2017. North American Electric Reliability Council projects Northwest Power Pool winter resource capacity margins (generating capacity in excess of demand) will drop from 35 percent in 2008/2009 to 20 percent of firm peak demand by winter 2017/2018, including planned estimated new capacity additions of 3,820 MW (NERC, 2008). These new additions include 1,416 MW of hydro capacity, 1,902 MW of thermal capacity, 156 MW of geothermal capacity, 96 MW of biomass capacity, and 250 MW of wind capacity.

We conclude that power from the Packwood Lake Hydroelectric Project would help meet a need for power in the Northwest Power Pool area in both the short- and long-term. The project provides low-cost power that displaces non-renewable, fossil-fired generation and contributes to a diversified generation mix. Displacing the operation of fossil-fueled facilities may avoid some power plant emissions and creates an environmental benefit.

1.3 STATUTORY AND REGULATORY REQUIREMENTS

A license for the project is subject to numerous recommendations under the Federal Power Act and other applicable statutes. We summarize the major regulatory requirements in table 1-1 and describe them below.

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Table 1-1. Major statutory and regulatory requirements for the Packwood Lake Hydroelectric Project. (Source: Staff)

Requirement Agency Status

Section 18 of the Federal Power Act (fishway prescriptions)

National Marine Fisheries Service

Prescription filed on August 19, 2008

Section 4(e) of the Federal Power Act (land management conditions)

Forest Service Preliminary terms and conditions filed August 16, 2008

Section 10(j) of the Federal Power Act

Washington Department of Fish and Wildlife

Recommendations filed August 18, 2008

Clean Water Act – 401 water quality certification

Washington Department of Ecology

Request for water quality certification filed on August 8, 2008. Draft water quality certification filed on May 29, 2009. Decision due by August 7, 2009.

Endangered Species Act National Marine Fisheries Service and U.S. Fish and Wildlife Service

Biological Assessment issued on February 5, 2009. Biological Opinion (NMFS) due on or by June 22, 2009. A Concurrence (FWS) is not expected since the FWS notified FERC on February 11, 2009 that under new regulations, a concurrence letter is not required if the action agency makes the determination of “not likely to adversely affect.”

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1.3.1 Federal Power Act

1.3.1.1 Section 18 Fishway Prescriptions

Section 18 of the Federal Power Act6 states that the Commission is to require construction, operation, and maintenance by a licensee of such fishways as may be prescribed by the Secretaries of Commerce or the U.S. Department of the Interior. By letter dated August 18, 2008, and filed on August 19, 2008, the U.S. Department of Commerce, National Marine Fisheries Service (NMFS) provided mandatory fishway prescriptions. These conditions are described further in section 2.2.4, Modifications to Applicant’s Proposal—Mandatory Conditions. In addition to its prescription, NMFS includes a general reservation of authority for NMFS to prescribe additional or modified fishways at such times and locations as NMFS may subsequently determine are necessary to provide for safe, timely, and effective downstream and upstream passage of anadromous fish through the project facilities.

1.3.1.2 Section 4(e) Conditions

Section 4(e) of the Federal Power Act7 provides that any license issued by the Commission for a project within a federal reservation shall be subject to, and contain, such conditions as the Secretary of the responsible federal land management agency deems necessary for the adequate protections and use of the reservation. The Forest Service filed preliminary terms and conditions by letter dated August 16, 2008. These conditions are described further in section 2.2.4, Modifications to Applicant’s Proposal—Mandatory Conditions.

1.3.1.3 Section 10(j) Recommendations

Under section 10(j) of the Federal Power Act8, each hydroelectric license issued by the Commission must include conditions based on recommendations provided by federal and state fish and wildlife agencies for the protection, mitigation, or enhancement of fish and wildlife resources affected by the proposed project. The Commission is required to include these conditions unless it determines that they are inconsistent with the purposes and requirements of the Federal Power Act or other applicable law. Before rejecting or modifying an agency recommendation, the Commission is required to attempt to resolve any such inconsistency with the agency, giving due weight to the recommendations, expertise, and statutory responsibilities of such agency.

The Washington Department of Fish and Wildlife (Washington Fish and Wildlife) timely filed its recommendations, terms, and conditions by letter dated August 18, 2008.

6 16 U.S.C. §811.7 16 U.S.C. §797(e).8 16 U.S.C. §803(j).

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All of the Washington Fish and Wildlife recommendations were the same as Forest Service 4(e) conditions. By a letter dated August 18, 2008, which was filed on August 19, 2008, NMFS provided its 10(j) recommendations. The 10(j) conditions by NMFS and Washington Fish and Wildlife are summarized in table 5-1, in section 5.4.1, Recommendations of Fish and Wildlife Agencies. In section 5.4, we also discuss how we address agency recommendations and comply with section 10(j).

1.3.2 Clean Water Act

Under section 401 of the Clean Water Act,9 a license applicant must obtain certification from the appropriate state pollution control agency verifying compliance with the Clean Water Act. A section 401 water quality certification is waived if the certifying agency does not act on the request within 1 year. Energy Northwest filed its request for water quality certification on August 8, 2008, to the Washington Department of Ecology. On May 29, 2009, Washington Department of Ecology filed a draft water quality certification10 for the project. Comments on the draft are due by July 8, 2009, and a final water quality certification is due on or before August 7, 2009.

1.3.3 Endangered Species Act

Section 7 of the Endangered Species Act (ESA) requires federal agencies to ensure that their actions are not likely to jeopardize the continued existence of endangered or threatened species or result in the destruction or adverse modification of the critical habitat of such species. NMFS and the U.S. Fish and Wildlife Service (FWS) identified the following listed and proposed to be listed fish species that may occur within the project area: Chinook salmon (Oncorhynchus tshawytscha), coho salmon (O. kisutch), chum salmon (O. keta), steelhead trout (O. mykiss), and bull trout (Salvelinus confluentus). Chum salmon and bull trout are not considered to be distributed in the upper Cowlitz River subbasin; therefore, we conclude that the project will have no effect on these two listed species.

Review of the FWS website in September 2008 indicated that five ESA-listed wildlife species may occur in Lewis County (FWS, 2007). These include the Canada lynx (Lynx canadensis), gray wolf (Canis lupus), grizzly bear (Ursus arctos horribilis), marbled murrelet (Brachyramphus marmoratus) and northern spotted owl (Strix occidentalis caurina).

Concurrently with issuance of the draft EA, we issued a Biological Assessment for threatened and endangered species, and requested formal consultation with NMFS

9 33 U.S.C. §1341.10 This document can be accessed using project number P-2244 at:

http://elibrary.ferc.gov/idmws/search/fercadvsearch.asp

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http://elibrary.ferc.gov/idmws/search/fercadvsearch.asp

regarding our findings that relicensing the project would likely adversely affect Chinook and coho salmon and steelhead. NMFS anticipates completion of its Biological Opinion by June 22, 2009.

With the Biological Assessment, we also requested concurrence from FWS regarding our finding that relicensing the project would not likely adversely affect the northern spotted owl. Concurrence is not expected since FWS notified FERC on February 11, 2009, that under new regulations, a concurrence letter is not required if the action agency makes the determination of “not likely to adversely affect” and that it does not plan to provide comments.

We summarize our findings on Threatened and Endangered Species in section 3.3.3. Table 1-2 presents our findings for federally listed species that may occur in the project area, based on assessment of the species’ range, distribution, and habitat requirements; existing habitat conditions; and analysis of environmental effects.

Table 1-2. Determination of effect for listed species and findings regarding effects on critical habitat. (Source: Staff)

Common Name Species Name Species FindingCritical Habitat

Finding

Fish

Chinook Salmon Oncorhynchus tshawytscha

Likely to adversely affect


Coho Salmon O. kisutch Likely to adversely affect None designated

Steelhead Trout O. mykiss Likely to adversely affect


Chum Salmon O. keta No effect No effectBull Trout Salvelinus confluentus No effect No effect

Wildlife Canada Lynx Lynx canadensis No effect No effect

Gray Wolf Canis lupus No effect None designated in Washington

Grizzly Bear Ursus arctos horribilis No effect None designated in Washington

Marbled Murrelet Brachyramphus marmoratus No effect No effect

7

Common Name Species Name Species FindingCritical Habitat

FindingNorthern Spotted Owl

Strix occidentalis caurina

Not likely to adversely affect

Not likely to adversely affect

Plants Howellia Howellia aquatilis No effect None designatedKincaid’s Sulfur Lupine

Lupinus sulphureus kincaidii No effect No effect

Nelson’s Checker-mallow Sidalcea nelsoniana No effect None designated

1.3.4 Coastal Zone Management Act

Under section 307(c)(3)(A) of the Coastal Zone Management Act,11 the Commission cannot issue a license for a project within or affecting a state’s coastal zone unless the state’s Coastal Zone Management Act agency concurs with the license applicant’s certification of consistency with the state’s Coastal Zone Management Act program, or the agency’s concurrence is conclusively presumed by its failure to act within 180 days of its receipt of the applicant’s certification.

Washington State’s Coastal Zone Management Program is managed by the Washington Department of Ecology and applies to the 15 coastal counties which front on salt water. The Packwood Lake Hydroelectric Project, located in Lewis County, does not front on salt water (http://www.ecy.wa.gov/programs/sea/czm/prgm.html); therefore, relicensing the project would not affect Washington’s coastal resources. Our assessment is that the project is not subject to Washington coastal zone review and no coastal zone consistency certification is needed due to the lack of potential effects.

1.3.5 National Historic Preservation Act

Section 106 of the National Historic Preservation Act12 requires that every federal agency take into account how each of its undertakings could affect historic properties. Historic properties are districts, sites, buildings, structures, traditional cultural properties, and objects significant in American history, architecture, engineering, and culture that are eligible for inclusion in the National Register of Historic Places.

To meet the requirements of section 106, the Commission intends to execute a Programmatic Agreement for the protection of historic properties from the effects of

11 16 U.S.C. §1456(3)(A).12 16 U.S.C. §470.

8

http://www.ecy.wa.gov/programs/sea/czm/prgm.html

construction, operation, and maintenance of the project. The terms of the agreement would ensure that Energy Northwest addresses and treats all historic properties identified within the project’s area of potential effects through implementation of the August 30, 2007, Historic Properties Management Plan. Additionally, an appendix to the Programmatic Agreement would contain a stipulation that Energy Northwest would evaluate the hydroelectric system for National Register of Historic Places eligibility once the facility reaches 50 years of age.

1.3.6 Pacific Northwest Power Planning and Conservation Act

Under section 4(h) of the Pacific Northwest Power Planning and Conservation Act, the Northwest Power and Conservation Council (Council) developed the Columbia River Basin Fish and Wildlife Program to protect, mitigate, and enhance the operation of the hydroelectric projects within the Columbia River Basin. Section 4(h) states that responsible federal and state agencies should provide equitable treatment for fish and wildlife resources, in addition to other purposes for which hydropower is developed, and that these agencies shall take into account, to the fullest extent practicable, the program adopted under the Pacific Northwest Power Planning and Conservation Act.

The Columbia River Basin Fish and Wildlife Program directs agencies to consult with federal and state fish and wildlife agencies, appropriate Indian tribes, and the Council during the study, design, construction, and operation of any hydroelectric development in the basin (sections 12.1A. through 12.1A.2). When the application was filed, the regulations required the applicant to consult with the appropriate federal and state fish and wildlife agencies and tribes before filing, and after filing, to provide these groups with opportunities to review and comment on the application. Energy Northwest has followed this consultation process according to the Commission’s regulations for the Integrated Licensing Process (18 CFR §5.18 and associated sections) and the relevant federal and state fish and wildlife agencies and tribes have reviewed and commented on the application.

To mitigate harm to fish and wildlife resources, the Council has adopted specific provisions to be considered in the licensing or relicensing of non-federal hydropower projects (appendix B of the Columbia River Basin Fish and Wildlife Program). The provisions that apply to the project require: (1) specific plans for fish facilities prior to construction; (2) assurance that the project will not degrade fish habitat or reduce numbers of fish; (3) assurance that all fish protection measures are fully operational at the time the project begins operation; (4) timing construction activities, insofar as practical, to reduce adverse effects on wintering grounds; and (5) replacing vegetation if natural vegetation is disturbed.

Staff recommendations are consistent with the provisions, listed above. A further condition of any license issued would reserve to the Commission the authority to require

9

future alterations in project structures and operation to take into account, to the fullest extent practicable, the applicable provisions of the program.

As part of the Columbia River Basin Fish and Wildlife Program, the Council has designated more than 40,000 miles of river in the Pacific Northwest region as unsuitable for hydroelectric development (protected area). The project is not affected by a designated protected area.

1.3.7 Wild and Scenic Rivers Act

Section 7(a) of the Wild and Scenic Rivers Act13 requires federal agencies to make a determination as to whether the operation of the project under a new license would invade the area or unreasonably diminish the scenic, recreational, and fish and wildlife values present in the designated river corridor. Currently, there are no congressionally designated wild, scenic, or recreational rivers in the Gifford Pinchot National Forest. As required under Section 5(d) of the act, the National Park Service maintains a Nationwide Rivers Inventory, which is a register of river segments that potentially qualify as national wild, scenic, or recreational river areas. The Nationwide Rivers Inventory has more than 3,400 free-flowing river segments in the United States that are believed to possess one or more “outstandingly remarkable” natural or cultural values judged to be of more than local or regional significance. Segments of the Cowlitz River listed in the Nationwide Rivers Inventory include a 42-mile-long segment between Muddy Creek and Riffe Lake. Within this segment, Lake Creek and the project’s tailrace waters enter the Cowlitz River. The Nationwide Rivers Inventory shows scenery and geology as outstandingly remarkable values in this segment of the Cowlitz River, and gives this segment a preliminary classification as a Recreation River; however, relicensing the project would not affect the identified values for the Cowlitz River or potential future listings.

1.3.8 Magnuson-Stevens Fishery Conservation and Management Act

The Magnuson-Stevens Act,14 as amended by the Sustainable Fisheries Act of 1996, requires federal agencies to consult with NMFS on all actions that may adversely affect Essential Fish Habitat. The objectives of this Essential Fish Habitat consultation are to determine whether the proposed action will adversely affect designated Essential Fish Habitat and to recommend conservation measures to avoid, minimize, or otherwise offset potential adverse effects on Essential Fish Habitat. For the Packwood Lake Hydroelectric Project, Essential Fish Habitat for Chinook and coho salmon exists in the project area.

In section 3.3.1 we examine the existing condition of Chinook and coho salmon Essential Fish Habitat in the project area and those measures included in the proposed

13 16 U.S.C. §1271.14 16 U.S.C. §1801.

10

action that have the potential to affect these species and their Essential Fish Habitat. We conclude that those measures incorporated into the proposed action would likely be beneficial to Chinook and coho salmon and would improve or at least maintain the existing condition of this Essential Fish Habitat over the long-term. Therefore we conclude that licensing the project, as proposed by Energy Northwest, with staff’s additional measures would not adversely affect designated Essential Fish Habitat for Chinook and coho salmon. With this final EA, we are requesting NMFS’ concurrence with our conclusion on Essential Fish Habitat.

1.3.9 Wilderness Act

Section 4(c) of the Wilderness Act, 16 U.S.C. §1133(c), states that there shall be no commercial enterprise and no permanent road within any wilderness area designated by the Act and no structure or installation within any such area. The Commission has held that it is prohibited by section 4(c) of the Wilderness Act from issuing a license for the construction of projects with works within a wilderness area.15

On September 3, 1964, Congress passed the Wilderness Act, which added the Goat Rocks Wilderness Area to the new National Wilderness Preservation System. The original Packwood Lake Project license and construction predates the Wilderness designation.16 About three quarters of the Packwood Lake shoreline is located within and adjacent to the designated Goat Rocks Wilderness Area. There are no existing project works, other than part of the pre-existing Packwood Lake, and Energy Northwest is not proposing any construction of project works within the wilderness area. Therefore, we conclude that licensing the project, as proposed by Energy Northwest, with staff’s additional measures would not adversely affect the designated wilderness area within the vicinity of the project.

1.4 PUBLIC REVIEW AND CONSULTATION

The Commission’s regulations17 require applicants to consult with appropriate resource agencies, tribes, and other entities before filing a license application. Consultation is the first step in complying with the Fish and Wildlife Coordination Act, ESA, National Historic Preservation Act, and other federal statutes. Pre-filing consultation must be complete and documented according to the Commission’s regulations.

15 Thornton Lake Resource Co., 50 FERC ¶61,086 (1990).16 The Packwood Lake Project license was issued on July 7, 1960, with an

effective date of March 1, 1960; project construction started in 1962 and commercial operation began in June 1964.

17 18 CFR §§5.1-5.16.

11

1.4.1 Scoping

During the integrated licensing process, the Commission conducted scoping to determine what issues and alternatives should be addressed. A scoping document was distributed to interested agencies and others on January 11, 2005. Two scoping meetings were held in Packwood, Washington on February 3, 2005, to request oral comments on the project. A court reporter recorded all comments and statements made at the scoping meetings, and these comments are part of the Commission’s public record for the project. In addition to comments provided at the scoping meetings, the following entities provided written comments:

Commenting Entities Date of Filing

Washington Fish and Wildlife March 9, 2005

Forest Service March 11, 2005

FWS March 11, 2005

The Commission issued a revised Scoping Document addressing these comments on April 25, 2005.

1.4.2 Interventions

Organizations and individuals may petition to intervene and become a party to subsequent proceedings. On June 19, 2008, the Commission issued a notice accepting Energy Northwest’s application and soliciting comments, recommendations, terms and conditions, and prescriptions. On September 16, 2008, the Commission issued a notice accepting Energy Northwest’s application for filing and solicited motions to intervene. This notice set 60 days as a deadline for filing protests and motions to intervene. The following organizations filed motions to intervene:

Intervenor Date of Filing

Forest Service August 16, 2008

NMFS August 19, 2008

Washington Fish and Wildlife October 17, 2008

Washington Department of Ecology November 5, 2008

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1.4.3 Comments on the License Application

The Commission issued a Ready for Environmental Analysis Notice on June 19, 2008, requesting that terms, conditions, and recommendations be filed by August 18, 2008. The following entities provided comments:

Commenting Entity Date of Filing

Forest Service August 16, 2008

Washington Fish and Wildlife August 18, 2008

U.S. Department of the Interior, Office of Environmental Policy and Compliance

August 18, 2008

NMFS August 19, 2008

Energy Northwest filed its reply comments on October 1, 2008.

1.4.4 Comments on the Draft EA

The Commission issued a draft EA for the proposed relicensing of the Packwood Lake Hydroelectric Project on February 5, 2009. Staff requested comments on the draft EA be filed within 30 days from the issuance date (March 7, 2009). A public meeting was held in Olympia, Washington, on April 27, 2009, to discuss 10(j) issues and receive and discuss comments on the draft EA. In addition to oral comments received during the public meeting, four letters representing four entities were filed with the Commission commenting on the draft EA. Energy Northwest has not filed a response to comments from others on the draft EA. To prepare this final EA, we modified the text of the draft EA, as necessary, in response to these comments. Appendix B summarizes the comments that were filed and provides responses to these comments.

Commenting Entity Date FiledWashington Department of Ecology February 27, 2009

Washington Fish and Wildlife March 4, 2009

Energy Northwest March 5, 2009

The Forest Service March 6, 2009

Appendix B summarizes the comments that were filed and provides responses to these comments.

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2.0 PROPOSED ACTION AND ALTERNATIVES

2.1 NO-ACTION ALTERNATIVE

Under the no-action alternative, the project would continue to operate under the terms and conditions of the current license, and no new environmental measures would be implemented. We use this alternative as the baseline environmental condition for comparison with other alternatives.

2.1.1 Existing Project Facilities

The proposed project would consist of the following: (1) a 452-acre natural lake (Packwood Lake) at a normal full pool elevation of 2,857 feet above mean sea level (msl) with about 4,162 acre-feet of useable storage; (2) a trapezoidal intake canal about 424 feet long; (3) a concrete weir (drop structure) that is 15-feet-high and 85-feet-long with a stilling basin; (4) an intake building on Lake Creek adjacent to the weir; (5) a 4.1-mile-long conveyance system of concrete pipe and tunnels; (6) a 1.1-mile-long concrete-encased steel penstock; (7) a concrete surge tank that is 5.5 feet in diameter and 191-feet-high; (8) a concrete powerhouse with a 26.125 MW turbine generator; (9) an excavated trapezoidal tailrace channel with an asphalt lining that is 29-feet-wide at the top and 9-feet-wide at the bottom; (10) a tailrace fish barrier; (11) a switchyard; and (12) a 1.5-mile-long, 69 kV transmission line. Average annual generation is about 92,000 MWh. Figure 2-1 shows the Packwood Lake outlet and the intake and drop structures, and figures 2-2 and 2-3 show the project layout and boundary (see also figure 1-1).

Figure 2-1. Packwood Lake Hydroelectric Project, detail of the outlet area. (Source: Energy Northwest, 2008a, as modified by staff)

15

Figure 2-2. Packwood Lake Hydroelectric Project, detail of the powerhouse area. (Source: Energy Northwest, 2008a, as modified by staff)

16

Figure 2-3. Packwood Lake Hydroelectric Project, detail of the tailrace area. (Source: Energy Northwest, 2008a, as modified by staff)

17

The 5.3-mile-long bypassed reach of Lake Creek is not included in the project boundary. The tailrace from the powerhouse and the 1.5-mile-long transmission line segment from the powerhouse to the Lewis County Public Utilities Department substation along Route 12 are included in the project boundary. The project boundary also includes about 1,400 linear feet in the tailrace which was washed out in a 1977 flood.

2.1.2 Project Safety

The project has been operating for 44 years under the existing license, during which time Commission staff have conducted operational inspections focusing on the continued safety of the structures, identification of unauthorized modifications (if any), efficiency and safety of operations, compliance with the terms of the license, and proper maintenance. The project is exempted from requirements to have the project inspected and evaluated every 5 years by an independent consultant and from requirements to maintain an Emergency Action Plan for the project to be implemented in case of an emergency. As part of the relicensing process, Commission staff would evaluate the continued adequacy of the proposed project facilities under a new license. Special articles would be included in any license issued, as appropriate. Commission staff would continue to inspect the project during the new license term to assure continued adherence to Commission-approved plans and specifications, license articles relating to construction (if any), operation and maintenance, and accepted engineering practices and procedures.

2.1.3 Existing Project Operation

The project is controlled from the project powerhouse and is operated in an automatic mode according to current license conditions, water availability, and power contracts. The project has a water right for 260 cubic feet per second (cfs) but does not operate at capacity at all times. The volume of water passing through the project varies with generator load and can range from a maximum of 225 cfs to a minimum of about 19 cfs. During the May 1 to September 15 period, the project’s generation is dictated by article 37 of the existing license, which specifies a lake level requirement of 2,857 feet msl plus or minus 0.5 foot unless conditions occur which are beyond the control of the licensee. From May 1 to September 15, the project generation flow is adjusted to match lake inflow to hold the lake elevation relatively constant. After mid-September, the lake level may be drawn down as much as 8 feet to a level no lower than 2,849 feet msl. The 8 feet of vertical storage allows the project to store and utilize winter runoff for power generation. When seasonal high runoff exceeds the project capacity and the available lake storage capacity, as occasionally happens during fall and winter rain events and during snowmelt in the spring and early summer, the drop structure is overtopped (at elevation 2,858.5 feet msl) and excess runoff flows over the spillway and down Lake

18

Creek.18 Between 1967 and 2003 (the period of best available data), overtopping occurred or is suspected to have occurred on 504 days, averaging 13.7 days per year. However, in some years, no spill occurred. Article 37 of the license established the maximum operating water surface elevation for Packwood Lake as 2,858.5 feet msl.

Article 14 of the existing project license requires Energy Northwest to release a year-round minimum instream flow of 3 cfs from Packwood Lake into lower Lake Creek (with the point of compliance at the drop structure) to maintain aquatic habitat. Article 14 also requires a release of up to a maximum of 5 cfs during the period of May 15 to September 15 in order to facilitate a flow of 15 cfs at the gaging station identified as U.S. Geological Survey (USGS) gage no.14226000 Lake Creek at Mouth. However, by a letter dated October 20, 1980, FERC authorized the discontinuance of the gage near the mouth of Lake Creek and also USGS gage no. 14225500 Lake Creek near Packwood, located immediately below Packwood Lake. Energy Northwest has since been releasing about 3 cfs year-round as the minimum flow. Energy Northwest records water releases daily at the project drop structure.

Energy Northwest has historically scheduled an annual project outage to perform equipment maintenance and inspection during the first 3 weeks of October. October was selected to minimize the economic impact of the scheduled outage, because it is typically a month with low inflows to the lake. In preparation for the scheduled outage, the lake is normally drawn down during the last 2 weeks in September. The resulting low lake level facilitates the work around the intake structure and minimizes the potential of an uncontrolled spill event down Lake Creek during the outage period. During the scheduled outage, the project’s pipeline and penstock are normally dewatered to facilitate inspections and minor maintenance. The Commission is notified that the tunnels and penstock will be dewatered.

According to Energy Northwest, under any water conditions, the priorities for plant operations are, from highest to lowest, to: (1) provide the required bypass flow down lower Lake Creek, (2) maintain the required lake levels specified in the license, and (3) generate electricity with the balance of the water in accordance with Energy Northwest’s power sales contracts. During dry periods with very low inflows, the project may be shut down in order to maintain the required lake level. Bypass flow releases to Lake Creek continue whether the project is operating or not.

18 The nominal design capacity of the pipeline and penstock system is about 236 cfs. The volume of water passing through the project varies with generator load, and typically ranges from about 225 cfs (27 MW) to a minimum of about 19 cfs (1 MW). On average, it requires about 8 cfs per MW to operate the project. The project does not have the ability to control flows other than diverting the maximum amount to the powerhouse when flows reach the elevation of the drop structure (2,858.5 feet msl).

19

2.1.4 Existing Environmental Measures

As indicated above, article 14 of the existing license for the project requires Energy Northwest to release a year-round minimum instream flow of 3 cfs from Packwood Lake into lower Lake Creek. Within lower Lake Creek, the normal natural accretion from runoff and groundwater inflow ranges from about 20 to 30 cfs during the winter and spring and about 10 cfs during the summer and early fall.

Under the current license, Energy Northwest recently constructed and currently maintains a fish barrier (drum screens) at the downstream end of the project tailrace.19 The design is based on two 14-foot-long by 4-foot-diameter drum screens fabricated by the Washington Fish and Wildlife Screen Shop in Yakima, Washington. The overall purpose of the tailrace barrier is to prevent fish (both anadromous and resident) from traveling up the project tailrace to the stilling basin, where they would be subject to potential delay in migration or mortality.

In addition to these measures, Energy Northwest currently implements provisions for best management practices related to storm water pollution prevention; spill prevention, control and countermeasures; and noxious weed control. These provisions include a description of the personnel with primary responsibility for overseeing compliance with state and federal environmental regulations; spill prevention and response procedures; inspection procedures; personnel training; plan updates; and other applicable measures. Copies of these plans can be found in the final license application, appendices A and E, respectively (Energy Northwest, 2008a).

2.2 APPLICANT’S PROPOSAL

2.2.1 Proposed Project Facilities

No new project development is proposed as part of relicensing this project. However, Energy Northwest proposes to add several project features including an informational kiosk, composting toilet, and stream gage, and proposes to reroute Snyder Creek under the project tailrace.

2.2.2 Proposed Project Operation

The existing license for the project requires a maximum Packwood Lake water surface elevation of 2,858.5 feet msl (the elevation of the drop structure crest) and a minimum water surface elevation of 2,849.0 feet msl. Under the proposed action, the existing maximum water surface elevation (2,858.5 feet msl) restriction would be dropped, because Energy Northwest does not have the ability to control flows during high inflow events other than diverting water to the powerhouse. In addition, the May 1 to

19 Energy Northwest, 120 FERC ¶62, 218 (2007).

20

September 15 maximum lake level requirement of 2,857.5 feet msl, would be eliminated to allow higher spring and summer lake levels to facilitate proposed annual aquatic habitat forming flows, support an August 15 to September 15 scheduled outage, and maintain continuous plant operations and lower Lake Creek instream flow releases in September and October. Energy Northwest would retain the existing minimum lake elevations of 2,856.5 feet msl between May 1 and September 15 and 2,849 feet msl between September 16 and April 30. The minimum lake level during the winter is needed to provide sufficient water for increased bypass flows in lower Lake Creek for project generation that provides continuous flows through the tailrace to the tailrace slough following the scheduled outage, and to allow cleaning and maintenance of the projects intake screens. Figure 2-4 shows the existing and proposed water levels for Packwood Lake, and table 2-1 shows proposed instream flows for Lake Creek.

Packwood Lake Existing and Proposed Reservoir Levels

2848

2849

2850

2851

2852

2853

2854

2855

2856

2857

2858

2859

2860

1-Jan 1-Feb 1-Mar 1-Apr 1-May 1-Jun 1-Jul 1-Aug 1-Sep 1-Oct 1-Nov 1-Dec

Elev

atio

n (fe

et m

sl)

.

Existing Maximum Level (2,858.5) None in Proposed Conditions

Existing and Proposed Minimum Levels (2,849 and 2,856.5)

Existing Summer Maximum Under Normal Operating Conditions (2,857.5)

Figure 2-4. Packwood Lake minimum and maximum water levels restrictions under existing and proposed conditions. (Source: Energy Northwest, 2008a)

21

Table 2-1. Proposed instream flows (cfs) for Lake Creek, as measured at the drop structure. (Source: Energy Northwest, 2008a, appendix D)

Month Instream Flow (cfs)

January, February, March 4April 7May 15June 10July 15August 1 – 15 15Aug 16 – Sept 15 20September 16 – 30 15October 10November 7December 4

Energy Northwest has historically scheduled an annual project outage to perform equipment maintenance and inspection during the first 3 weeks of October. Under the proposed action, Energy Northwest would begin its scheduled outage on August 15 of each operating year and resume project operations on or before September 15. Completing the scheduled outage prior to September 15 would provide additional protection for spawning Chinook and coho salmon in the side channel of the Cowlitz River below the tailrace. Outage in this earlier period would also help avoid the discharge of naturally warmed Packwood Lake surface water into the Cowlitz River, when summer temperatures are at their highest; and help ensure adequate water is available in Packwood Lake to provide the proposed minimum flows for Lake Creek. Energy Northwest is not proposing to draw down Packwood Lake prior to the start of the outage, as it currently does under existing operations.

2.2.3 Proposed Environmental Measures

Provide increased instream flows in Lake Creek in accordance with the schedule above.

Implement the Lake Creek Ramping Rate Plan for Reach 5 below the drop structure filed with the Commission on June 9, 2009. With this plan, Energy Northwest would to limit all instream flow reductions associated with the minimum instream flows to a maximum of 2.5 cfs per hour. One exception to this procedure is the June 1 reduction in flow, which would be completed in one hour during night-time hours.

22

Begin the annual outage for project maintenance on August 15 of each operating year, and resume operation by September 15, or earlier if all necessary work has been completed.

Provide a spill event of greater than or equal to 285 cfs for as long as lake inflows can sustain that flow for a target of 24 hours, every other water year or 3 out of 6 water years. Provide documentation and reporting of the spill events and, if the frequencies of the spill events cannot be achieved, the agencies (including the Forest Service and Washington Fish and Wildlife) will be consulted for an alternate plan.

Implement a 3-phase adaptive plan to reduce entrainment at the project intake that would include as phase 1: replacing existing debris screens with better fitting screens, and monitoring results to determine if entrainment is less than targets established. If target numbers are met, this effort is deemed acceptable. If targets are not met, under phase 2, Northwest Energy would remove the debris screens, develop other means for cleaning debris from the trashracks, and monitor to determine if entrainment is less than the threshold targets. If targets are met at this point, this effort would be deemed acceptable. If impingement on the screens under Phase 2 exceeds threshold levels, Energy Northwest under phase 3 would consult with the natural resource agencies and tribes to determine an alternative means of protecting fish at the intake. Following issuance of the draft EA, Energy Northwest, the Forest Service, NMFS, and Washington Department of Ecology developed an alternative approach to address entrainment at the project intake that involved biological monitoring (entrainment and fish population monitoring). This approach was subsequently incorporated into Forest Service modified 4(e) condition 9 which requires Energy Northwest to develop, in consultation and coordination with the Forest Service, a Packwood Lake Intake Fish Entrainment Monitoring Plan. Energy Northwest agreed to this modified 4(e) condition during the April 27, 2009, public meeting.20

Ensure a minimum of 30 adult O. mykiss spp. are present in the upper 1,464 feet of Reach 5 of Lake Creek by monitoring abundance and age class and periodically moving Packwood Lake trout to Lake Creek downstream of the drop structure either by overtopping events (aquatic habitat flows) or by physically collecting and moving fish.

20 On April 27, 2009, Commission staff conducted a publically-noticed meeting in Olympia, Washington, which served as a forum to discuss section 10(j) recommendations as well as other topics associated with the draft EA.

23

Provide gravel and wood recruitment stations in Reach 5 below the drop structure. Wood and gravel located at these structures would be carried downstream during the channel-forming flows provided as part of the aquatic habitat spill events described above.

Develop and implement a stream restoration and enhancement plan for the lowest 1.0 mile (river mile 0.0 to 1.0) of Lake Creek in the anadromous zone, after consultation with the natural resource agencies and tribes.

Improve fish passage on Snyder Creek where its culvert crosses under the tailrace canal by rerouting Snyder Creek into Hall Creek on the downstream side (south) of the tailrace canal within 5 years of license issuance.

Install flow measurement equipment at the Lake Creek Road bridge and begin recording data within the first year of the issuance of any new license.

Maintain and monitor effectiveness of the tailrace fish barrier.

Inspect the tailrace slough prior to the annual outage for adequate flows, and rescue fish, if necessary.

Develop a monitoring plan after consultation with the Washington Department of Ecology, to evaluate the effectiveness of project operations, including the timing of the annual outage, and meet the applicable temperature standard at the confluence of the project tailrace with the Cowlitz River. If the tailrace temperature standard is not sufficiently resolved by changes in project operations, Energy Northwest will consult with the Washington Department of Ecology and other agencies on additional ways to address this issue.

Develop and implement a threatened, endangered, and sensitive species management plan.

Implement the Rare Plant Management Plan, and incorporate it into the threatened, endangered, and sensitive species management plan after consultation with resource management agencies.

Develop and implement an Integrated Weed Management Plan incorporating the current weed control plan. Provide for regular weed control and site-specific efforts.

Implement the Recreation Management Plan as filed with the Commission on June 6, 2008, including:

24

1) install and maintain a composting toilet at Packwood Lake;

2) install and maintain an informational kiosk at the Packwood Lake Trailhead;

3) provide annual maintenance to the Pipeline Trail (FS Trail 74) and the Pipeline Bypass Trail (Dyson Pass) including drainage, trail clearing, and vegetation management;

4) provide operation and maintenance measures or annual funding of a seasonal employee to address effects of dispersed recreational use at the project;

5) continue providing power to the Forest Service guard station;

6) consult with the Forest Service on appropriate paint colors and materials as repairs and maintenance to the project intake-related structures or facilities are performed to ensure the building blend in with the surrounding area; and

7) develop and implement a road maintenance plan for portions of Snyder Road (FS Road 1260), Pipeline Road (FS Road 1260-066), Powerhouse Road (FS Road 1260-013), and Latch Road (FS Road 1262), after consultation with the Forest Service.

Implement the August 30, 2007, Historic Properties Management Plan including measures to install an interpretive sign at the all terrain vehicle (ATV) parking area along FS Trail 74.

Ensure that the project transmission line conforms to Avian Power Line Interaction Committee standards for raptor protection.

Develop and implement a road maintenance plan for Pipeline Road (FS Road 1260-066), Pipeline Trail (Trail No. 74), and Latch Road (FS Road 1262 above the gate), after consultation with the Forest Service.

Develop and implement a resource coordination plan to coordinate the recommended management plans and associated requirements for the project with various agencies and include provisions for an annual coordination meeting.

Develop and implement a fire prevention plan for the project as part of the resource coordination plan.

2.2.4 Modifications to Applicant’s Proposal—Mandatory Conditions

The following mandatory conditions have been provided and are evaluated as part of Energy Northwest’s proposal.

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2.2.4.1 Section 18 Prescriptions

On August 19, 2008, NMFS provided mandatory fishway prescriptions that would require Energy Northwest to: (1) continue the measures for maintenance, testing, and operation of the fish screen (post-construction),21 as described in the incidental take statement (NMFS, 2007) and (2) develop and implement a plan (within 2 years of license issuance) to provide adequate passage that meets NMFS fish passage standards at the Snyder Creek tailrace crossing construction.

2.2.4.2 Section 4(e) Land Management Conditions

The Forest Service filed preliminary terms and conditions under section 4(e) on August 16, 2008. These terms and conditions include the following: conditions 1 and 19 are administrative or legal in nature and not specific environmental measures; condition 15 is related to project safety and as such, monitoring is required regardless of the outcome of the relicensing procedure; condition 2 requires a resource coordination plan; condition 3 requires a fire prevention plan; condition 4 requires changes in the Packwood Lake elevations and timing of the annual project maintenance; condition 5 requires higher instream flows to lower Lake Creek; condition 6 requires releases for aquatic habitat enhancement in lower Lake Creek; condition 7 requires lower Lake Creek stream restoration and monitoring; condition 8 requires O. mykiss spp. surveys and supplementation in the upper reach of lower Lake Creek; condition 9 requires methods to address entrainment at the project intake; condition 10 requires improved fish passage for Snyder Creek; condition 11 requires amphibian monitoring at site B near Packwood Lake; condition 12 requires the implementation of a threatened, endangered, and sensitive species management plan; condition 13 requires a Packwood Lake tributary headcutting monitoring program; condition 14 requires complying with provision of the Recreation Management Plan as filed with the Commission on June 6, 2008; condition 16 requires implementing the Integrated Weed Management Plan as filed with the Commission on June 6, 2008; condition 17 requires complying with the Avian Protection Plan filed with the Commission on June 6, 2008; and condition 18 requires complying with the Historic Properties Management Plan as filed with the Commission on August 30, 2007.

In response to the Commission’s draft EA, issued on February 5, 2009, and a meeting between the Forest Service, Energy Northwest, and all other stakeholders on February 11, 2009, Forest Service 4(e) condition 9, addressing entrainment at the project intake, was modified and filed with the Commission on March 6, 2009. This modified condition now contains a biological monitoring element, so that if biological impingement criteria are not met at the project intake, or there is a decline in fish

21 Energy Northwest constructed a fish screen facility to exclude fish from the project tailrace and stilling basin in the fall of 2007.

26

populations within Packwood Lake due to project operations, a major screen modification would be required and designed to meet Washington DFW screen criteria.

As mentioned above, in its mandatory 4(e) condition 14, the Forest Service requires the licensee to completely and fully comply with all provisions of the Recreation Management Plan filed with the Commission on June 6, 2008. The Recreation Management Plan contains a provision for the licensee to continue to provide power to the Forest Service guard station, even though there is no nexus to the project.22 However, in the absence of a statutory directive, it is not our policy to require specific allocation of power from licensed projects, but to leave those matters to private contract, and as appropriate, state regulation.23 Therefore, it is against Commission policy to require the licensee to allocate power to the Forest Service guard station. As a result, we do not provide any further analysis in this final EA of the provision to provide power to the Forest Service guard station; however, we do provide costs associated with this provision in section 4, Developmental Analysis. However, we recognize that the Commission is required to include valid section 4(e) conditions in any license issued for the project.

2.2.4.3 Draft Water Quality Certification Conditions

We summarize the draft conditions of the water quality certification in the following bullets:

Compliance with Washington State’s water quality standards in Packwood Lake, Lake Creek, and the tailrace area of the Cowlitz River, based on the designated use categories including criteria for total dissolved gas, pH, dissolved oxygen, fecal coliform, turbidity, and temperature.

Monthly instream flows from Packwood Lake to lower Lake Creek as shown below:

22 Because the guard station pre-existed the Packwood Lake Hydroelectric Project and Packwood Lake is a natural lake, the presence of the guard station is not a result of the Packwood Lake Hydroelectric Project; and therefore, has no nexus to the project.

23 It has . . . been the practice of this Commission and the predecessor Federal Power Commission (FPC) since the issuance of licenses began in 1920 to leave the disposition of project power in the hands of the licensee, which is responsible for the construction, operation, and maintenance of the project, unless Congress has made a legislative directive to the contrary.” Power Authority of the State of New York; Massachusetts Municipal Wholesale Electric Company v. Power Authority of the State of New York, 109 FERC ¶ 61,092 (2004). See New York Power Authority, 118 FERC ¶ 61,206 at P 73 n.73 (2007).

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Month Instream Flow (cfs)

January, February, March 4April 7May 15June 10July 15August 1 – 15 15August 16 – September 15 20September 16 – 30 15October 10November 7December 4

Seasonal ramping rate limitation in the anadromous portion of Lake Creek to be measured at a stream gage located near the Lake Creek Road bridge as shown below:

Season Daylight Ratesa Night Rate

February 16 to June 15b No Ramping 2 inches/hour

June 16 to October 31c 1 inch/hour 1 inch/hour

November 1 to February 15 2 inches/hour 2 inches/houra Daylight is defined as 1 hour before sunrise to 1 hour after sunset

b Salmon fry are present c Steelhead fry are present

Habitat forming flows of greater than or equal to 285 cfs for as long as lake inflows can sustain the flow, and for a maximum of 24 hours, every other water year or 3 out of 6 water years.

Measures associated with hazardous substance spill prevention and control including protection of surface and groundwater quality during all over-water and near-water work related to the project.

2.3 STAFF ALTERNATIVEUnder Energy Northwest’s proposal with staff modifications, the project would be

operated as proposed, but would include the following:

Develop and implement a threatened, endangered, and sensitive species management plan, including conducting surveys for Oregon goldenaster prior to ground-disturbing activities in lower Lake Creek and consulting

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with resource management agencies regarding timing restrictions or other measures that may be needed to prevent adverse effects on amphibians during efforts to reroute Snyder Creek.

Modify the Integrated Weed Management Plan to expand the list of target species for weed control at sites below the stilling basin, in order to protect the state-listed Oregon goldenaster and prevent the spread of noxious weeds as a result of implementing environmental measures in lower Lake Creek and Snyder and Hall creeks.


Modify the project boundary to include: the composting toilet and historic interpretive sign at the existing ATV parking area at the end of FS Trail 74; the informational kiosk at the Packwood Lake Trailhead; FS Trail 74, Dyson Pass, and Latch Trail; the portion of Powerhouse Road, from the gate to project facilities; all of Pipeline Road (FS Forest Service Road 1260-066); the portion of Latch Road from the Forest Service gate to its termination at Latch Trail; and the portion of the lower 1 mile section of lower Lake Creek where monitoring and mitigation will occur on a regular basis, and encompassing the new stream gage.

2.4 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM FURTHER ANALYSIS

We considered several alternatives to the applicant’s proposal, but eliminated them from further analysis because they are not reasonable in the circumstances of this case. They are (1) issuing a non-power license, (2) federal government takeover of the project, and (3) retiring the project.

A nonpower license is a temporary license that the Commission will terminate when it determines that another governmental agency will assume regulatory authority and supervision over the lands and facilities covered by the nonpower license. At this point, no agency has suggested a willingness or ability to do so. No party has sought a nonpower license and we have no basis for concluding that the project should no longer be used to produce power. Thus, we do not consider issuing a nonpower license a realistic alternative to relicensing in this circumstance.

We do not consider federal takeover to be a reasonable alternative. Federal takeover of the Packwood Lake Hydroelectric Project would require Congressional approval. Although that fact alone would not preclude further consideration of this alternative, there is currently no evidence showing that a federal takeover should be

29

recommended to Congress. No party has suggested that federal takeover would be appropriate, and no federal agency has expressed an interest in operating the project.

Project retirement could be accomplished with or without dam removal. Either alternative would involve denial of the relicense application and surrender or termination of the existing license with appropriate conditions. No participant has suggested that dam removal would be appropriate in this case, and we have no basis for recommending it. Dam removal is often recommended by some parties to allow fish passage into areas that were formerly accessible by anadromous fish; however, Packwood is a natural lake and water falls in the lower part of Lake Creek have historically blocked fish access. Thus, dam removal is not a reasonable alternative to relicensing the project with appropriate environmental measures.

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3.0 ENVIRONMENTAL ANALYSIS24

3.1 GENERAL SETTING

The Packwood Lake Hydroelectric Project is located near the town of Packwood in Lewis County, Washington, within the Gifford Pinchot National Forest (see figure 1-1). The project is located just west of the crest of the Cascade Mountains and south of Mt. Rainier in central Washington near the town of Packwood (elevation 1,050 feet msl). Packwood Lake (452 acres) is located in a mountainous region about 5 miles east of the town at an elevation of 2,857 feet msl. The lake is bounded on both the east and west by mountains with ridge top elevations of approximately 5,000 feet or higher. Snyder Mountain (elevation 5,011 feet msl) is located immediately west of the lake. The lake is located at the lower end of the upper Lake Creek valley midway between the Goat Rocks and the Cowlitz River. A number of small streams flow into the lake but the primary source of water is upper Lake Creek that originates from Packwood Glacier and other snowfields on the flanks of Old Snowy Mountain (Goat Rocks). Packwood Lake is drained by Lake Creek, a tributary of the Cowlitz River, and the Packwood Lake Hydroelectric Project. Upper Lake Creek and Lake Creek have a northwest - southeast trend in parallel with the other streams in the area.

3.2 SCOPE OF CUMULATIVE EFFECTS ANALYSIS

According to the Council on Environmental Quality’s regulations for implementing the National Environmental Policy Act (40 C.F.R. §1508.7), a cumulative effect is the impact on the environment resulting from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (federal or non-federal) or person undertakes such actions. Cumulative effects can result from individually minor, but collectively significant, actions taking place over time, including hydropower and other land and water development activities.

Based on our review of the license application, agency and public comments summarized in the revised Scoping Document, and our independent analysis, we identified water quality, fishery resources, wildlife, and shorelines as having the potential to be cumulatively affected by the proposed project in combination with other past, present, and foreseeable future activities.

3.2.1 Geographic Scope

The geographic scope of analysis for cumulatively affected resources defines the physical limits or boundaries of the effects of the proposed action on resources. For the

24 Unless otherwise indicated, our information is taken from the license application for this project (Energy Northwest, 2008a).

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Packwood Lake Project, the geographic scope includes the Lake Creek watershed and the Cowlitz River downstream from the confluence with Lake Creek to the Columbia River.

3.2.2 Temporal Scope

The temporal scope of analysis includes a discussion of the past, present, and future actions and their effects on water quality and fisheries resources. Based on the potential term of a license, the temporal scope looked 30 to 50 years into the future, concentrating on the effect on water quality and fisheries from reasonably foreseeable future actions. The historical discussion is limited, by necessity, to the amount of available information for each resource. We identified the present resource conditions based on the license application, agency comments on the draft license application, and comprehensive plans.

3.3 PROPOSED ACTION AND ACTION ALTERNATIVES

In this section, we discuss the effect of the project alternatives on environmental resources. For each resource, we first describe the affected environment, which is the existing condition and baseline against which we measure effects. We then discuss and analyze the specific site-specific and cumulative environmental issues.

Only the resources that would be affected, or about which comments have been received, are addressed in detail in this EA. We have not identified any substantive issues related to socioeconomics associated with the proposed action, and, therefore, this topic is not assessed in this EA. Discussion of geology and soils is included in section, 3.3.1, Aquatic Resources. We present our recommendations in section 5.2, Comprehensive Development and Recommended Alternative.

3.3.1 Aquatic Resources

3.3.1.1 Affected Environment

Water Resources

Water Quantity

Packwood Lake has a drainage area of about 19.2 square miles. Tributaries that drain into Packwood Lake include Upper Lake Creek, Osprey Creek, Trap Creek, Muller Creek, Crawford Creek, and other small unnamed tributaries. All of these tributaries are unregulated and ungaged. Based on lake levels and project discharge records for 1999 to 2007, Energy Northwest calculated the mean monthly inflow to Packwood Lake (table 3-1), and the highest mean inflows occur during the snowmelt months of May and June.

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Table 3-1. Inflow (cfs) to Packwood Lake. (Sources: Energy Northwest, 2008a; USGS, 2008)

Month

1999-2007

Calculated Mean Inflowa

October 43

November 84

December 71

January 82

February 95

March 96

April 76

May 138

June 172

July 105

August 51

September 35a Estimated by Energy Northwest.

Packwood Lake

The normal surface area of Packwood Lake is 452 acres at a lake elevation 2,857 feet msl. From May 1 to September 15, the project is operated to maintain a lake elevation of 2,857 msl plus or minus 0.5 foot. During the summer period, project generation is generally adjusted to keep the lake level relatively constant. The existing license also specifies a maximum lake level of 2,858.5 feet msl, which is the top of the outlet control structure. From September 16 to April 30, the existing license specifies a minimum lake elevation of 2,849 msl, and Energy Northwest uses the storage to store and utilize winter runoff for power generation. Historically, Energy Northwest normally performs an annual generation plant shutdown to allow for maintenance and inspection during the first 3 weeks in October. Prior to this time period, the lake level is normally drawn down during the last 2 weeks in September. According to Energy Northwest, the project is operated using the following three priorities, from highest to lowest:

1. Provide the required bypass flow down lower Lake Creek;

2. Maintain the required lake levels specified in the license; and

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3. Generate electricity with the balance of the water in accordance with Energy Northwest’s power sales contracts.

As a result of these project operations, during very low inflow periods, the project is shut down to maintain the required lake level and maintain flow releases to Lake Creek. Figure 3-1 provides a graph of the monthly minimum and maximum Packwood Lake levels from January 1999 to December 2007. This figure shows that the lake level has commonly exceeded the maximum lake surface elevation of 2,858.5 feet msl even as a monthly average and that the minimum monthly lake elevation does not normally remain near minimum elevation 2,849 feet for too long. Table 3-2 provides a summary of the number of days and maximum flows when Packwood Lake exceeded an elevation of 2,858.5 msl, the top of the outlet structure.25 Table 3-2 also shows that, on a daily basis, Packwood Lake has exceeded elevation 2,858.5 feet msl 25 out of the 40 years between 1967 and 2006. Energy Northwest states that, prior to the construction of the Packwood Project, the water level of Packwood Lake normally ranged between elevation 2,856.5 and 2,857.5 feet msl.

The result of these project operations is that during very low inflow periods, the Packwood Project is shut down to maintain the required lake level and continue the bypassed reach flow releases to Lake Creek. Figure 3-1 provides a graph of the monthly minimum and maximum Packwood Lake levels from January 1999 to December 2007. Table 3-2 provides a summary of the number of days and maximum flows when Packwood Lake exceeded an elevation of 2,858.5 feet msl, the top of the outlet structure. Energy Northwest states that, prior to the construction of the Packwood Project, the water level of Packwood Lake normally ranged between elevation 2,856.5 and 2,857.5 feet msl.

The intake structure is located about 424 feet downstream from the outlet of the lake and is connected to the lake by an excavated inlet canal. From Packwood Lake, flow is diverted at the intake structure to either Lake Creek or to the pipeline and tunnel leading to the powerhouse. Energy Northwest stated that the amount of water sent to the powerhouse typically ranges from a minimum of 19 cfs to a high of about 225 cfs. Energy Northwest has a water right of 260 cfs, but normally does not operate at that rate and the nominal design capacity of the pipeline and penstock is 236 cfs.

25 Due to the lack of gates or other control devices, Energy Northwest does not have the ability to control flow at this elevation, other than diverting flow to the powerhouse.

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2,848

2,849

2,850

2,851

2,852

2,853

2,854

2,855

2,856

2,857

2,858

2,859

2,860

2,861

2,862

Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Jan-07 Jan-08

Ele

vatio

n (fe

et m

sl)

.

Historical minimum monthly level Historical maximum monthly levelExisting maximum rule curve level Existing minimum rule curve level

Figure 3-1. Packwood Lake minimum and maximum monthly water levels. (Source: Energy Northwest, 2008a)

Table 3-2. Summary of Packwood overtopping events, 1967 to 2006. (Source: Energy Northwest, 2008a)

YearDays

Overtop

Days Suspected Overtop

Days Total

Days Plant Down

Days Adj. Total

Max Flow (cfs)

1967 7 2 9 0 9 2121968 3 3 0 3 4071969 20 6 26 0 26 2251970 2 2 0 2 351971 8 2 10 0 10 1981972 29 4 33 0 33 501973 2 2 2 0 141974 29 4 33 0 33 3111975 11 9 20 9 11 8251976 0 0 0 01977 16 16 0 16 6241978 0 0 0 01979 0 0 0 01980 6 6 0 6 3101981 24 24 24 0 685

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YearDays

Overtop

Days Suspected Overtop

Days Total

Days Plant Down

Days Adj. Total

Max Flow (cfs)

1982 13 13 0 13 1601983 4 4 0 4 611984 0 0 0 01985 14 14 0 14 3301986 6 6 0 6 1541987 0 0 0 01988 0 0 0 01989 0 0 0 01990 4 4 0 4 3881991 0 0 0 01992 0 0 0 01993 10 10 0 10 1551994 7 59 66 59 7 3261995 10 55 65 55 10 6731996 4 4 0 4 4061997 14 22 36 22 14 4531998 0 0 0 01999 13 13 0 13 1612000 12 12 12 0 472001 33 33 33 0 2752002 35 35 0 35 1702003 5 5 0 5 2602004 5 5 442005 0 02006 40 40 889

Total 341 136 504 216 288

The existing license requires a minimum flow of 3 cfs from Packwood Lake to Lake Creek. Furthermore, during May 15 to September 15, the project was originally required to release up to a maximum of 5 cfs, in order to facilitate a flow of 15 cfs at the gaging station identified as “Lake Creek at Mouth” (USGS Station No. 14226000). The instream flow requirement was established as a result of studies conducted in the late 1960s and early 1970s in consultation with Washington Game Commission and Washington Department of Fisheries (now Washington Fish and Wildlife), the Bureau of Commercial Fisheries, the Bureau of Sport Fisheries and Wildlife, and the Forest Service. By letter dated October 20, 1980, the Commission authorized the discontinuance of the USGS gaging stations related to the project (i.e., Station Nos. 14225500 and 14226000). Energy Northwest is not currently required to measure instream flows in Lake Creek near its confluence with the Cowlitz River; however, water releases are recorded daily at the

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project drop structure. Outlet flow data collected by Energy Northwest for January 1999 to the end of December 2007 indicate that the minimum flows averaged slightly more than 3 cfs from the outlet structure. Table 3-3 provides flow data from the two currently inactive flow gages on Lake Creek and the active gage on the Cowlitz River downstream of the mouth of Lake Creek, but upstream of the project tailrace. The Lake Creek gages show that flows from Packwood Lake were generally highest in the late spring and early summer and lowest during the late summer and early fall. From the gage along Lake Creek for the 1965 to 1977 period, representing post-project conditions, median flows were highest during the winter indicating the influence of inflow from small tributaries downstream of Packwood Lake.

Downstream of Packwood Lake, Lake Creek flows about 5.3 miles to its confluence with the Cowlitz River at river mile 129.2. The drainage area of lower Lake Creek, not counting Packwood Lake is about 7.3 square miles. Within this reach, the normal natural accretion from runoff and groundwater inflow ranges from about 20 to 30 cfs during the winter and spring and about 10 cfs during the summer and early fall. Flows from the Packwood powerhouse are returned to the Cowlitz River at about river mile 125.2 about 4 miles downstream of the confluence of Lake Creek. As shown in table 3-3, flows in the Cowlitz are generally highest in May and June, with flood events occurring during the late fall and winter.

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Table 3-3. Flow (cfs) at gages along Lake Creek and the Cowlitz River. (Source: USGS, 2008)Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep

USGS gage no. 14225500 Lake Creek at Packwood Lake Outlet (October 1, 1912 to September 30, 1962 pre project)

Mean 62 87 103 90 75 63 84 151 209 153 77 56

Median 48 65 71 67 60 53 76 139 193 139 70 49

Max. 546 855 1,300 590 530 238 379 382 562 462 169 267

Min. 20 18 18 24 25 29 33 46 64 42 34 24

10% Exceed. 106 164 184 177 134 103 137 230 324 247 124 83

90% Exceed. 29 29 35 40 36 37 44 83 111 73 44 35

USGS gage no. 14225500 Lake Creek at Packwood Lake Outlet (October 1, 1965 to September 30, 1980 post project)

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Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep

Mean 8 7 21 6 5 5 5 11 28 12 7 5

Median 6 5 5 5 5 5 5 5 6 5 5 5

Max. 42 46 1,220 182 24 27 10 300 302 208 204 20

Min. 3 3 3 3 2 3 2 3 3 3 4 3

10% Exceed. 19 8 6 6 6 6 6 17 76 29 6 6

90% Exceed. 4 4 4 4 4 4 4 4 4 4 4 4

USGS gage no. 14226000 Lake Creek at Mouth (October 1, 1965 to November 1977 post project)

Mean 17 28 53 63 46 42 36 41 58 29 18 14

Median 14 22 35 46 41 35 34 31 31 19 15 13

Max. 82 87 1,130 365 256 214 80 380 393 205 214 35

Min. 8 10 15 17 16 21 17 18 16 13 11 10

10% Exceed. 29 49 80 114 76 66 54 61 127 62 20 17

90% Exceed. 10 14 17 23 22 24 21 19 18 14 12 11

USGS gage no. 14226500 Cowlitz River at Packwood (October 1, 1965 to September 30, 2007)

Mean 673 1,619 1,720 1,697 1,496 1,325 1,617 2,639 2,809 1,583 785 566

Median 430 1,050 1,080 1,100 982 1,040 1,350 2,250 2,460 1,270 642 470

Max. 11,200 30,000 27,700 17,800 26,800 13,100 16,000 8,730 13,400 7,140 3,730 4,000

Min. 166 155 237 343 350 362 465 681 700 450 347 213

Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep

10% Exceed. 1,340 3,173 3,530 3,586 2,825 2270 2815 4520 4720 3060 1290 876

90% Exceed. 258 379 512 530 520 600 737 1340 1360 693 457 320

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Water Quality

The water quality characteristics of tributaries to Packwood Lake are reflective of the relatively undisturbed nature of the drainage area. Based on the current state water quality standards, which became effective in December 2006, Packwood Lake has been designated by the state as a member of the lake class where the water quality must meet or exceed the requirements for all or substantially all uses. Under the state water quality standards, the Cowlitz River in the project area as well as Lake Creek has an aquatic life use of ‘core summer habitat’ and ‘extraordinary primary contact recreation.’ In addition, the Cowlitz River in the project area is designated as requiring supplemental spawning and incubation temperature protection such that the 7-day average of the maximum daily temperature for this reach may not exceed 13 degrees Celsius (°C) between September 1 and May 15. Table 3-4 provides the water quality criteria for key parameters.

Table 3-4. Water quality parameters. (Source: Energy Northwest, 2008a)

Parameter Requirements

Temperature For waters designated core summer habitat, the highest 7-day average of the daily maximum temperature (7-DADMax) cannot exceed 16°C. When a water body’s temperature is warmer than the criteria and that condition is due to natural conditions (as is the case at both the tailrace and in lower Lake Creek downstream of the outlet structure), then human actions cumulatively may not cause an increase in the 7-DADMax more than 0.3°C. Incremental temperature increases must not exceed 28/(T+7) where T represents the background temperature.

For waters designated by Washington Department of Ecology as requiring supplemental spawning and incubation temperature protection; the 7-DADMax for this reach may not exceed 13°C between September 1 and May 15.

Studies conducted during the relicensing process showed that the water temperature at both the tailrace and in lower Lake Creek downstream of the outlet structure sometimes exceed the 7-DADMax water temperature standard of 16°C. However, water temperature modeling determined the pre-project 7-DADMax water temperature at the mouth of Lake Creek to be 19.09°C (EES, 2007a). Given this modeled, “natural” temperature, and applying the criteria for temperature in the Washington water quality standards, the maximum allowable temperature for water delivered by the project to the Cowlitz River via the tailrace and lower Lake Creek is 19.39°C (WAC 173-201A). This criterion applies to lower Lake Creek year-round and to the tailrace from May 16 to August 31. Because the

41

Parameter Requirements

Cowlitz River (including water delivered to the Cowlitz River via the tailrace) requires supplemental spawning and incubation temperature protection, the 7-DADMax for this reach may not exceed 13°C between September 1 and May 15.

Dissolved Oxygen

Lowest 1-Day Minimum 9.5 milligrams per liter (mg/L)

Turbidity 5 nephelometric turbidity units over background when background is < 50 nephelometric turbidity units; or a 10% increase in turbidity when background > 50 nephelometric turbidity units

pH 6.5 to 8.5

Total dissolved gas

Not to exceed 110% saturation for flows up to the seven day 10 year flood.

Fecal coliform

Geometric mean value of 50 colonies/100 milliliters and not have more than 10 percent of all samples obtained for calculating the geometric mean value exceeding 100 colonies/100 milliliters Geometric mean value of exceeding 100 colonies/100 milliliters

Packwood Lake has been classified as an oligotrophic lake by the Washington Department of Ecology in 1991. Oligotrophic lakes are low in both nutrient content and algal production and are general very clear with high water quality and are normally cold and well-oxygenated. The Cowlitz River in the area of the project as well as Packwood Lake and Lake Creek are not listed as impaired under the 303(d) list in the Clean Water Act. As part of the license application project, Energy Northwest conducted a 2-year water quality study and investigated the effects of the project operation on water quality. Most of the parameters collected included temperature, dissolved oxygen, pH, and nutrients for Packwood Lake, Lake Creek and the project tailrace.

Maximum hourly inflow temperatures measured in three tributaries to Packwood Lake, Osprey and Muller Creeks, and the main inflow source Upper Lake Creek, measured during the summer of 2004 and 2005 remained below 12°C. Temperatures monitored during the same period on Crawford Creek, another tributary to Packwood Lake, approached 16°C in 2004, but remained below 15°C in 2005.

At the start of the water temperature monitoring in April 2004 and April 2005, Packwood Lake was unstratified with a very weak thermocline. Temperature profile data collected by Energy Northwest showed that as the summer progressed, a weak

42

stratification of approximately 1.0°C per 1 meter of depth developed as shown in figure 3-2. This figure also shows that prior to the October drawdown, the surface water had already started to cool and the upper 11 meters of the lake were homothermous. While temperatures during the summer in the upper levels of Packwood Lake are above the 16°C water quality standard, the water temperatures in Packwood Lake are largely due to natural conditions such as those that would have existed in pre-project conditions. Therefore water temperature standards in Packwood Lake are in compliance with the water temperature standards.

Figure 3-2. Vertical temperature profiles for Packwood in the deepest area of the lake. (Source: Energy Northwest, 2008a)

Also during 2004 and 2005, temperatures were monitored in Packwood Lake near the outlet, Lake Creek, the tailrace, Cowlitz River, and Snyder Creek. Tables 3-5 and 3-6 provide a summary of these temperatures. These tables show that the maximum hourly temperatures were normally below 20 °C, except near the surface of Packwood Lake and in areas directly influenced by the warm surface water such as the tailrace.

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Table 3-5. Water temperature monitoring data for 2004. (Source: Energy Northwest, 2008a)

Monitoring Site

Hottest 7 Days

(Range)

7-DAD Max (°C)

Max Hourly

Temp. (°C)

# of days exceeding

16°C

Packwood Lake near the surface at the deepest point of the lake 8/16-8/22 21.04 23.65 NAPackwood Lake near outlet 8/16-8/22 20.45 20.74 NALake Creek below diversion structure 8/15-8/21 20.95 21.42 73Lake creek 1,500 feet downstream of the drop structure 8/15-8/21 19.82 20.12 53Lake Creek near mouth 8/11-8/17 14.36 14.78 0Powerhouse tailrace upper end 8/14-8/20 20.67 21.07 74Powerhouse tailrace lower end 8/15-8/21 21.25 21.51 79Cowlitz River tailrace side channel 8/15-8/21 21.91 22.38 80Cowlitz River upstream of Lake Creek 7/29-8/4 14.90 15.33 0Snyder Creek upstream of ancillary water inflow 8/11-8/17 18.02 18.30 38Snyder Creek at confluence with Hall Creek 8/11-8/17 17.99 18.34 39

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Table 3-6. Water temperature monitoring data for 2005. (Source: Energy Northwest, 2008a)

Monitoring Site

Hottest 7 Days

(Range)

7-DAD Max (°C)

Max Hourly Temp. (°C)

# of days exceeding

16°C

Packwood Lake near the surface at the deepest point of the lake 7/14-7/20 18.63 19.31 35Packwood Lake near outlet 7/13-7/19 17.68 17.37 38Lake Creek below diversion structure 8/15-8/21 20.81 21.42 77Lake creek 1,500 feet downstream of the drop structure 8/9-8/15 19.46 20.03 62Lake Creek near mouth 7/30-8/05 13.51 13.74 0Powerhouse tailrace upper end 8/4-8/10 21.82 24.28 81Powerhouse tailrace lower end 8/4-8/10 20.83 21.34 82Cowlitz River tailrace side channel 7/25-7/31 18.41 19.16 NACowlitz River upstream of Lake Creek 7/25-7/31 15.10 15.92 0Snyder Creek at confluence with Hall Creek 8/4-8/10 16.98 17.86 36

Note: The project was not generating on August 6 and 7th resulting in no water flowing out of the powerhouse into the tailrace.

Data in tables 3-5 and 3-6 show a decline in the water temperature in Lake Creek downstream of the intake structure and the confluence of Lake Creek with the Cowlitz River. Energy Northwest states that this decline in water temperature is due to riparian shade and cold groundwater inflow. However, for flows diverted from the intake structure to the powerhouse, the collected water temperature data showed minimal changes in temperature between the intake area of the lake and the powerhouse outflow. However during the summer of 2005 when the project was shut down periodically for several 1- to 3-day periods due to low inflow to the lake, the water temperature at the upper end of the tailrace, near the stilling basin increased up to 3.5°C (figure 3-3). However, much cooler water temperatures were recorded in the lower end of the tailrace which empties into a side channel of the Cowlitz River, and Energy Northwest states this was the result of night time cooling of the shallow water. Figure 3-4 shows comparisons

45

of the water temperature at the lower end of the tailrace to the side channel of the Cowlitz River. This figure shows that the outflow from the powerhouse is slightly colder than the Cowlitz River flow in the winter and 2 to 3°C warmer during the summer but is very close to the water temperature of Packwood Lake when the project is operating.

Note: POWT1: upper end of the powerhouse tailracePOWT2: lower end of the powerhouse tailraceLCDS: Packwood Lake near the outlet

Figure 3-3. Hourly discharge and water temperature at the intake, and tailrace during mid-July to mid-September 2005. (Source: Energy Northwest, 2008a)

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Note: CRTSC = Cowlitz River side channel

Figure 3-4. Water temperature in the end of the Packwood Project tailrace and the side channel of the Cowlitz River, October 2005 to October 2005. (Source: Energy Northwest, 2008a)

Dissolved Oxygen

Within Packwood Lake, lower dissolved oxygen (DO) levels were found in the lower levels of the water column but remained well above anoxic conditions with a low of 4.93 mg/L during September 2005 at the deepest part of the lake. DO values near the surface ranged from between 8.3 and 10.6 mg/L during summer 2005.

DO was the only water quality criteria below the standards in lower Lake Creek with levels below the 9.5 mg/L criteria recorded at all sites during summer 2004 and only once near the confluence with the Cowlitz River in 2005. Levels in Lake Creek were generally higher in lower sections of the creek probably due to turbulent flow and the

47

accretion of colder groundwater. In the tailrace area, measured DO levels were below the criteria during the summer months during both 2004 and 2005.

Other Parameters

Turbidity levels in most tributaries to Packwood Lake are low except during periods of high inflow. The exception is Upper Lake Creek which carries a higher sediment load and has higher turbidity levels especially during snowmelt in the spring and glacial meltwater during the summer. In 2005, Secchi depth measurements at Packwood Lake ranged from 3 to 4 meters during the spring to more than 8 meters during the summer. Table 3-7 shows measured mean annual turbidity levels and pH values in lower Lake Creek, the tailrace, and the Cowlitz River. Other than the turbidity level measured immediately below the diversion structure in the April 2004 to March 2005 period, turbidity and pH levels were within acceptable levels based on the water quality standards. Energy Northwest also measured total dissolved gas in tailrace and within Packwood Lake near the intake. All levels were below the 110 percent standard.

Table 3-7. Mean annual pH and turbidity levels. (Source: Energy Northwest, 2008a)

pHTurbidity

(NTU) pHTurbidity

(NTU)

April 2004 - March 2005 April 2005 - March 2006

Lake Creek below diversion structure 7.52 5.46 7.58 1.38Lake Creek near mouth 7.44 3.12 7.3 1.74Cowlitz River upstream of Lake Creek 7.12 25.94 7.36 13.78

2004 2005Upper end of the tailrace 7.25 3.21 7.28 1.53Lower end of the tailrace 7.44 2.74 7.31 1.72Cowlitz River side channel 7.25 26.79 7.33 5.52NTU = nephelometric turbidity units

Fishery Resources

Historically, the upper Cowlitz River Basin supported large numbers of spring and fall Chinook salmon (Oncorhynchus tshawytscha), coho salmon (O. kisutch), steelhead (O. mykiss), and sea-run cutthroat trout (O. clarki clarki) (NPPC, 2004). The completion

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of Mayfield, Mossyrock, and Barrier dams in the 1960s26 (Cowlitz River Hydroelectric Project, FERC No. 2016) blocked the upstream migration of anadromous fish into the Cowlitz River above river mile 49.5, and thus, into the project area near river mile 129. Although efforts to trap and haul adult Chinook and coho salmon and steelhead upstream of these dams continued into the late-1970s. The efforts were eventually abandoned in favor of increased hatchery production at the Cowlitz Salmon Hatchery.27

Following the completion of Cowlitz Falls dam in 1994 (at river mile 88.5), Tacoma Power, Bonneville Power Administration, Lewis County Public Utility District, and various resource agencies engaged in a comprehensive anadromous fish reintroduction effort upstream of Cowlitz Falls dam (NPCC, 2004). As a component of the Cowlitz River Hydroelectric Project Settlement Agreement, large numbers of Chinook and coho salmon and steelhead are trapped at the Barrier dam adjacent to Tacoma Power’s Cowlitz Salmon Hatchery and hauled to three release sites in the upper Cowlitz River Basin: Lake Scanewa, the Cispus River, and the mainstem Cowlitz River at Packwood (Franklin Bridge).28 As a result, Chinook and coho salmon and steelhead now have access to the upper Cowlitz River and its tributaries, including Lake, Hall, and Snyder creeks. Anadromous fish no longer have access to the project tailrace or stilling basin following construction of the tailrace barrier in October 2007.

Chinook salmon currently found in the project vicinity (spring Chinook) enter the Cowlitz River from March through June (NPCC, 2004). Natural spawning occurs between late August and early October (table 3-8), with most spawning occurring in the mainstem upper Cowlitz River above the town of Packwood and in the Cispus River between Iron and East Canyon creeks (NPCC, 2004). Fry emerge from the gravel between November and March. Spring Chinook fry typically spend 1 full year in fresh water and migrate to the ocean in their second spring as age-2 smolts. Juvenile Chinook salmon are typically associated with low gradient, meandering, unconstrained stream reaches with abundant instream cover (e.g., accumulations of large wood and overhanging vegetation) (Healey, 1991).

26 Construction of the first dam on the Cowlitz River, Mayfield dam, began in 1955, but was not completed until 1962. Mossyrock dam was completed in 1968 and Barrier dam (associated with Cowlitz Salmon Hatchery) was completed in 1969.

27 Downstream migrant traps in the project reservoirs were found to be ineffective once the surface water temperature became warm (approximately 16°C) (FERC, 2001).

28 All downstream migrants are collected at the Cowlitz Falls Project fish passage facility and trucked downstream to holding ponds at the Cowlitz Salmon Hatchery, where they are eventually released volitionally into the lower Cowlitz River.

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Adult coho salmon in the project vicinity (late–run) enter the Cowlitz River from August through February and typically spawn from late November to March (table 3-8). Natural spawning occurs in the mainstem and tributaries of the upper Cowlitz, Cispus, and Tilton rivers (NPCC, 2004). Juveniles rear for a full year before migrating as yearlings in the spring. Juvenile coho salmon are frequently associated with side channels, wetlands, and off-channel sloughs (Sandercock, 1991). Other important habitat features include large wood accumulations, undercut banks, and complex pools.

Adult steelhead found in the project vicinity (winter steelhead) enter the Cowlitz River from December through April (NPCC, 2004). Known spawning areas included the mainstem Cowlitz River near Riffe and the reach between the Muddy Fork and the Clear Fork and the lower Ohanapecosh River. Spawning time is generally March to June (table 3-8). Juveniles generally rear in fresh water for 2 years and then migrate to the ocean from April to May (NPCC, 2004). In general, juvenile steelhead prefer relatively small, fast flowing streams with a high proportion of riffles and pools and abundant instream cover (Barnhart, 1991).

The naturally produced Lower Columbia River Chinook and coho salmon and Lower Columbia River steelhead present in the upper Cowlitz River Basin are listed as threatened under the ESA (table 3-9) and are considered Forest Service Special Status Species. Lower Columbia River Chinook salmon and Lower Columbia River steelhead are also designated Washington state species of concern (candidate species).29

In addition to Chinook and coho salmon, and steelhead, the waters in the project vicinity support resident and anadromous coastal cutthroat trout (O. clarki clarki), westslope cutthroat trout (O. clarki lewisi), O. mykiss spp.,30 Pacific lamprey (Lampetra tridentata), sculpin (Cottus sp.), mountain whitefish (Prosopium williamsoni), northern pikeminnow (Ptychocheilus oregonensis), bridgelip sucker (Catostomus columbianus), mountain sucker (Catostomus platyrhynchus), longnose dace (Rhinichthys cataractae), speckled dace (Rhinichthys osculus), and eastern brook trout (Salvelinus fontinalis).

29 Includes fish and wildlife species that Washington Fish and Wildlife would review for possible listing as state endangered, threatened, or sensitive. See http://wdfw.wa.gov/wlm/diversity/soc/candidat.htm.

30 The Forest Service requests that all references to “resident rainbow trout” be clarified. It suggests that Packwood Lake fish may be more accurately described as Oncorhynchus mykiss spp. until the subspecies is verified.

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http://wdfw.wa.gov/wlm/diversity/soc/candidat.htm

Table 3-8. Lake Creek salmonid species periodicity. (Source: Energy Northwest, 2008a)Species Lifestage Oct Nov Dec Jan Feb Mar April May June July Aug Sept

Spring Chinook

Spawning

Incubation

Rearing

Coho

Spawning

Incubation

Rearing

Steelhead

Spawning

Incubation

Rearing

Cutthroat Spawning

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Trout

Incubation

Rearing

O. mykiss,

Spawning

Incubation

Rearing

Key:

Black indicates periods of heaviest use

Grey indicates periods of moderate use

Blank areas indicate periods of little or no use

Table 3-9. ESA-listed fish species in the Packwood Lake Hydroelectric Project area. (Source: Energy Northwest, 2008a)

Evolutionary Significant Unit/DPS ESA Listing Status ESA Critical Habitat

Lower Columbia River Chinook Salmon

Threatened June 28, 2005 (70 FR37160)

Designated September 2, 2005 (70 FR52630), with an effective date of January 2, 2006

Lower Columbia River Coho Salmon

Threatened June 28, 2005 (70 FR37160)

Under development

Lower Columbia River Steelhead

Threatened January 5, 2006 (71 FR 834)

Designated September 2, 2005 (70 FR52630), with an effective date of January 2, 2006

Energy Northwest completed numerous studies designed to describe the current distribution of resident and anadromous species within project-area waterbodies and to evaluate the quality and quantity of available habitat potentially affected by project operations. In the following sections, we describe the physical features, aquatic habitat, and aquatic biota in six project area waterbodies, including: Packwood Lake, Packwood Lake tributaries, lower Lake Creek (below Packwood Lake), Hall and Snyder creeks, tailrace slough (Cowlitz River Side Channel), and Cowlitz River (see figure 1-1).

Packwood Lake

Packwood Lake existed as a natural lake prior to the construction of the Packwood Lake Hydroelectric Project. The lake was formed when a large mass of soil and rock slid off Snyder Mountain and dammed Lake Creek approximately 1,100 years ago. Water enters Packwood Lake via several tributaries, including Osprey, Trap, Muller, Upper Lake, and Crawford creeks and exits the lake via the project powerhouse and lower Lake Creek. The normal surface area of Packwood Lake is 452 acres at elevation 2,857 feet msl. The current license requires that Packwood Lake be maintained at a constant elevation of approximately 2,857 feet msl plus or minus 6 inches during the May 1 through September 15 recreational season. During the remainder of the year, under the current license, the lake level may be lowered not more than 8 feet below the summer lake level down to an elevation of 2,849 feet msl (422 acre minimum surface area).

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Packwood Lake and its major tributaries currently support a self-sustaining population of native adfluvial31 O. mykiss spp., the only species of fish ever documented to exist in Packwood Lake. Genetic comparisons of Packwood Lake O. mykiss spp. with “inland” and “coastal” populations found that Packwood Lake O. mykiss spp. are more closely related to inland populations. Although five distinct populations of non-indigenous rainbow trout were stocked in Packwood Lake from 1954 through 1965, no fish have been stocked in the lake since 1965 and there appears to have been no genetic introgression of hatchery stocks with natural resident fish in Packwood Lake.

As part of the relicensing process, Energy Northwest conducted a 2-year evaluation of the fishery resources in Packwood Lake using gill net and fyke net sets (EES, 2007b). All sampling was conducted between July 2006 and July 2007. Nets were set in the lake near the mouth of Osprey Creek and at the upstream end of the lake between the mouths of Muller and Upper Lake creeks. A total of 111 O. mykiss spp. were captured during sampling in 2006 and 2007, ranging in size from 4.3 to 11.0 inches in length. No other species were observed or captured during sampling in the lake.

Energy Northwest also conducted two hydroacoustic fish population surveys in Packwood Lake in May and August of 2007. The first survey took place on May 23, 2007, prior to adult O. mykiss spp. migration into the tributaries for spawning. The second survey was conducted on August 8, 2007, after the adult O. mykiss spp. migrated back to the lake. There were 96 and 211 O. mykiss spp. detected during the May and August 2007, hydroacoustic surveys, respectively. After extrapolating the transect data to encompass the entire lake volume, a total of 21,127 O. mykiss spp. were estimated to inhabit Packwood Lake in May 2007. Once adult rainbow spawners had returned to the lake in mid-August and juvenile outmigration had begun, the estimated number of O. mykiss spp. inhabitants increased to 31,278. The majority of these were found to occupy the “transition” and “deep” portions of Packwood Lake.

Packwood Lake Tributaries

Since 1980, large numbers of O. mykiss spp. have been documented spawning in six tributaries to Packwood Lake (Osprey, Trap, Muller, Upper Lake Creek, Beaver Bill, and Southeast Trap creeks). The two tributaries that have consistently supported the most spawning are Muller and Upper Lake creeks. However, spawning activity within these tributaries varies significantly from year to year. A typical year would see O. mykiss spp. migrating from Packwood Lake into the tributaries in May and June. Peak spawning would occur in mid-June and the spawners typically would return to the lake by early July at the latest. The fry outmigration period would extend from July through to the latter part of August.

31Adfluvial refers to a life cycle that depends on the lake environment for adult holding and foraging, and the tributaries for spawning and early rearing habitat.

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As part of the relicensing process, Energy Northwest conducted aquatic habitat and fish population surveys in seven of the principle tributaries to Packwood Lake (figure 3-5). Field investigations included underwater observations (snorkeling), electrofishing, and spawning surveys.

Figure 3-5. Packwood Lake tributary study sites. (Source: Energy Northwest, 2008a)

In 2007, 76 percent of O. mykiss spp. spawning in the tributaries to Packwood Lake were observed in Muller Creek (table 3-10); although a substantial number of spawners was also observed in Crawford and Osprey creeks. The abundance of fry in the tributaries to Packwood Lake correlated with the proportion of O. mykiss spp. spawners observed in each creek, and as expected, the tributaries with the higher average water temperatures (Crawford and Trap creeks), had the shortest incubation periods.

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Table 3-10. The total number of O. mykiss spp. and O. mykiss spp. redds observed during the 2007 Packwood Lake tributaries spawning surveys. (Source: EES, 2007b) Upper Lake Creek

Beaver Bill

CreekCrawford

CreekMuller Creek

Trap Creek

SE Trap Creek

Osprey Creek

Number of Redds 61 9 214 1,147 38 0 134

% of Total Redds

4 1 13 72 2 0 8

Number of Fish 112 2 502 3,665 86 0 441

% of Total Fish 2 1 10 76 2 0 9

Lake Creek

Lake Creek flows in a northwest direction from Packwood Lake approximately 5.3 miles to its confluence with the upper Cowlitz River, at river mile 129.2. It has a drainage area of about 7.3 square miles below Packwood Lake, which supplements the 3 cfs minimum flow released at the project’s diversion site.32 Accretion from runoff and groundwater occurs along the 5.3-mile-stretch between the project drop structure and the confluence of Lake Creek with the Cowlitz River. The Lake Creek drainage is mostly within the Gifford Pinchot National Forest, with the lowest 0.7 miles of Lake Creek on private lands. The gradient of lower Lake Creek is relatively high, averaging about 6.3 percent from the lake to its confluence with the Cowlitz River. Reach gradients range from a low of about 2 percent immediately upstream of the Cowlitz River to 20 percent in the canyon reach.

During studies conducted in July, August, and September 2006, Energy Northwest used snorkeling and electrofishing techniques to document fish species distribution and abundance in lower Lake Creek. Twenty-six sites were sampled in five distinct reaches between the creek’s mouth (river mile 0.0) and the drop structure (river mile 5.4)33

32 The existing project license requires a minimum instream flow of 3 cfs at the drop structure immediately downstream of the outlet of Packwood Lake.

33 Most documentation for the project uses 5.3 miles when referring to the length from the drop structure to the Cowlitz River; however, in the figures in the license application used for our figure 3-7, the length is referred to as 5.4 miles.

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(figures 3-6 and 3-7). A habitat analysis was conducted at each site prior to sampling. In addition to these studies, Energy Northwest conducted a lower Lake Creek barrier analysis and a lower Lake Creek gravel transport and large woody debris study.

Glides and runs were the dominant habitat types in reach 1 of Lake Creek, comprising 86 percent of the total habitat (table 3-11). Pool habitat was extremely limited in reach 1. Runs were the dominant habitat type in reaches 2 through 5, comprising more than 30 percent of the habitat. Fish encountered in lower Lake Creek included adult and juvenile rainbow trout, juvenile coho salmon, and sculpin. All three species had a preference for runs and glides followed by pools and plunge pools. All coho were observed below the chute at river mile 1.03. The highest densities of O. mykiss spp. were observed in reaches 3 and 4. Relatively few O. mykiss spp. were observed in reach 5. An analysis of the natural barriers in lower Lake Creek indicated that the chute at river mile 1.03 was an upstream barrier for Chinook and coho salmon, while the falls at river mile 1.95 was the barrier for steelhead (EES, 2007c).

Reach 5 of lower Lake Creek extends approximately 0.4 mile from river mile 4.9 to the project drop structure. Aquatic habitat in this relatively high gradient reach (8.4 percent slope) consists primarily of glides, cascades, and plunge pools separated by a series of natural falls and chutes, occasionally blocking upstream fish migration. Rainbow trout were the only species observed in the section of lower Lake Creek below the drop structure. The reach has very limited salmonid spawning and rearing habitat, resulting in the production of very few fish. While reach 5 was found to contain the most large woody debris per mile in the wetted channel of any reach in lower Lake Creek, only 6 percent of the reach contained spawning gravels with 5 percent the gravels being located in the area immediately below the drop structure.

The primary source of instream wood in Lake Creek, downstream of the drop structure, is local trees falling into the creek by wind throw, tree mortality, and mass wasting. Wood and log jams are abundant upstream of approximately river mile 2.1, with 90 to 130 pieces of countable wood/mile (more than 12 inches in diameter and 25 feet long) in the combined wetted and bankfull channel in reaches 3, 4, and 5. There is less wood in the lower 2.1 miles of Lake Creek. In 2005, 35 countable pieces of wood/mile were inventoried in reach 2, and 15 pieces of wood/mile in reach 1. There are few local sources of future large wood in reaches 1 or 2.

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Figure 3-6. Lower portion of Lake Creek (reaches 1 through 3). (Source: Energy Northwest, 2008a)

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Figure 3-7. Lower portion of Lake Creek (reaches 4 and 5). (Source: Energy Northwest, 2008a)

Table 3-11. Habitat type percentages for the five reaches surveyed on lower Lake Creek. (Source: Energy Northwest, 2008a)

Reach Pools Glides Runs Riffles HGR PP Falls Cascades

1 0 53 33 8 0 7 0 0

2 0 9 39 0 0 35 0 0

3 1 27 37 0 15 5 0.5 13

4 6 34 39 1 13 2 0 5

5 29 31 32 0 0 0 0 8

Note: HGR are high gradient riffles and PP are plunge pools.

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Inventories of spawning-sized gravel in lower Lake Creek between the drop structure and the confluence with the Cowlitz River found a total of 42,660 square feet of gravel, with the highest concentrations in reaches 2, 3, and 4. The majority of instream gravel was located behind large-scale roughness elements such as large boulders or large woody debris. One hypothesis for the fewer amounts of gravel downstream of river mile 0.8 is that the project has reduced the frequency of flows capable of transporting gravel, so gravel is being retained in upstream reaches near its source. Another hypothesis is that channel conditions that favor gravel retention (log jams, large woody debris, large boulders) are not as frequent downstream of river mile 0.8, so that much of the gravel transported from upstream reaches during high flows is not retained downstream of river mile 0.8. It also should be noted that Packwood Lake acts as a natural gravel sink, stopping downstream movement of gravel originating from Packwood Lake tributaries to Lower Lake Creek. Prior to project construction, sediment recruitment occurred from the outlet area of Packwood Lake as lower Lake Creek flowed over unconsolidated deposits of the landslide which formed Packwood Lake. However, the construction of the outlet structure and the diversion of water to the powerhouse has decreased both the sediment recruitment from the Packwood Lake outlet area and the sediment transport capacity of lower Lake Creek.

In addition to the fish habitat and fish population surveys described above, Energy Northwest conducted 2 years of adult salmonid spawner surveys in lower Lake Creek from it mouth to the anadromous fish migration barrier at river mile 1.95.34 Surveys were conducted on a twice monthly basis from July 2004 to July 2006. Over the 2-year period, a total of 86 salmon and 56 redds were observed in the study area. Eighty-three of the salmon were coho and three were Chinook. On one survey alone, nearly 20 coho carcasses were observed in lower Lake Creek at the site of the temporary gage. No adult steelhead were documented during the surveys; however, a single steelhead redd was observed in lower Lake Creek at about river mile 0.3. Peak coho spawning in Lake Creek occurs between November 1 and January 31. The two Chinook salmon were observed in Lake Creek in August, 2004.

Snyder and Hall Creeks

Snyder Creek, the small outlet stream for Snyder Lake, is approximately 1-mile long and passes through a culvert under the project tailrace canal near its confluence with the Hall Creek wetland area (figure 3-8). Hall Creek is somewhat larger than Snyder Creek and drains much of the area to the northeast of the project powerhouse between the Snyder Creek and Lake Creek drainages. Hall Creek flows southwest along the mountain front and eventually reaches Johnson Creek and the Cowlitz River about 3 miles from the powerhouse. In the vicinity of the project powerhouse, Hall Creek consists of a large

34 The chute at river mile 1.03 subsequently was determined to be an upstream barrier for Chinook and coho salmon, while the falls at river mile 1.95 was determined to be the barrier for steelhead.

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wetland area. The project tailrace passes over this wetland area in an elevated 356-foot-long flume.

In August 2006, Energy Northwest surveyed Snyder Creek from the Packwood tailrace crossing upstream 0.8 miles to the barrier falls (figure 3-8). Two 197 feet study sites were surveyed below a large culvert under a Forest Service road located approximately 1,800 feet upstream of the mouth of Snyder Creek and two 60 meter study sites were surveyed upstream of the culvert. A total of 24 coho salmon, 58 westslope cutthroat, 3 lamprey, and 16 sculpin were captured during sampling at the two study sites. No coho juveniles were captured above study site 1 (figure 3-8). A majority of the cutthroat were captured at study site 2 just below the Forest Service road and culvert.

Figure 3-8. Study site locations in Snyder Creek. (Source: Energy Northwest, 2008a)

Two 30 meter (98 feet) study sites were snorkeled in Hall Creek and a 30 meter study site was snorkeled in Johnstone Creek (a tributary to Hall Creek). All three study sites were upstream of the Snyder Road (FS Road 1260). Ten rainbow trout and 18 westslope cutthroat trout were observed in the plunge pool immediately upstream of the confluence of Hall Creek with Johnstone Creek. No other fish were observed in Hall

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Creek. A single juvenile rainbow trout and one sculpin were observed in Johnstone Creek, just upstream from the confluence with Hall Creek.

In addition to the surveys described above, Energy Northwest conducted twice monthly spawning surveys in Snyder and Hall creeks. Snyder Creek was surveyed from its confluence with Hall Creek to river mile 0.36 from April 12, 2005 through July 26, 2006. No adult salmon, steelhead, or redds were observed during the surveys. However, juvenile coho salmon and cutthroat trout were seen in the reach. Hall Creek was surveyed from the Snyder Road crossing to river mile 3.70 from May 10, 2005 through July 26, 2006. A total of 34 coho adults and 10 redds were observed during the surveys. All coho salmon and redds were documented between December 29, 2005 and January 26, 2006. Neither Chinook salmon nor steelhead trout were observed during the Snyder Creek surveys.

The Snyder Creek culvert under the project tailrace as currently configured does not meet Washington Fish and Wildlife criteria for fish passage. The culvert can also become blocked with large amounts of sediment which settles out in the culvert, at the culvert outlet, or near the drain. The blockage of the culvert can prevent spawning coho and cutthroat from accessing documented spawning and rearing habitat that extends up about 1,900 feet from the tailrace crossing. If the Snyder Creek culvert becomes blocked with sediment prior to downstream migration, juvenile coho and cutthroat can become stranded in Snyder Creek.

Tailrace Slough (Cowlitz River Side Channel)

The project tailrace slough is the point where the project tailrace discharges into a highly dynamic side channel in the Cowlitz River.35 During some years, the volume of water in the tailrace slough during low flow periods is largely dependent upon flow levels in the mainstem Cowlitz River; however, in other years, a greater percentage of the flow in the tailrace slough comes from the project than from the river. Under its current condition, the tailrace slough has been dependant on tailrace flows to provide adequate habitat (depth and velocity) for anadromous salmonid spawning and rearing at certain times of the year.

Chinook and coho salmon, steelhead, sea-run cutthroat trout, rainbow trout, resident cutthroat trout and mountain whitefish are known to inhabit the tailrace slough-side channel of the river at various life stages. From July 26, 2004 through July 26, 2006, Energy Northwest conducted twice monthly spawning surveys in the tailrace slough. A total of 34 coho salmon and 57 redds were observed over the 2-year survey period. All but one of the 34 coho adults and all 57 redds were observed during the 2004/2005 season. No Chinook salmon or steelhead were observed during the study. All coho

35 Habitat characteristics in the slough can change on an annual basis depending on high flows and the relative contribution of the river and tailrace.

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salmon spawning activity in the tailrace slough took place between November 11 and December 21, 2004.

In addition to spawning surveys described above, Energy Northwest conducted four seasonal fish population and habitat use surveys in the tailrace slough from July 2006 through January 2007. Habitat use information was gathered by a combination of visual, electrofishing, and snorkeling surveys. Approximately 2,200 coho juveniles and 5 Chinook juveniles were observed during the four surveys.

Cowlitz River

The mainstem Cowlitz River is formed at the confluence of the Ohanapecosh River and the Muddy and Clear Forks of the Cowlitz River, at approximately river mile 132. Outlet flows from the project are returned to the Cowlitz River at river mile 125.2, about 4 miles downstream from the confluence with Lake Creek. Energy Northwest conducted adult salmonids spawner surveys in a 2,000 foot-long reach of the Cowlitz River immediately downstream of Lake Creek (left bank, looking downstream) and in a 2,000 foot-long reach of the mainstem, downstream from the confluence with the tailrace slough. No adult salmonids or redds were observed during these spawner surveys.

3.3.1.2 Environmental Effects

Monitoring of Flows and Water Levels and Reporting

Currently, Energy Northwest maintains records of the water level in Packwood Lake, minimum flows released to lower Lake Creek, and powerhouse flow records to ensure compliance with existing license conditions. Energy Northwest proposes to continue its current flow and water level measurement operations, and install a streamflow gaging station on lower Lake Creek at Lake Creek Road bridge with regular downloading of data and periodic reporting of all measurements.

Various Forest Service conditions specify measurement of water levels within Packwood Lake and measurement of flows within Lake Creek for compliance with proposed instream flows and aquatic habitat forming flows.

Our Analysis

Current operation of water level measurement of Packwood Lake and releases to Lake Creek allows Energy Northwest to manage its facility for hydroelectric generation and document environmental compliance with terms of its existing license. The configuration of future flow and water level monitoring gages would depend on the operating conditions that may be specified in a new license. Energy Northwest has stated that infrastructure changes to the outlet structure would not be required to release and

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monitor the proposed higher minimum flows at the discharge end of the bypass pipe at the drop structure or to continue monitoring the water level within Packwood Lake.

Prior to November 1977, USGS operated gage no. 14226000 along lower Lake Creek about 0.5 mile from the confluence with the Cowlitz River. The proposed location of the new gage is along Lake Creek Road at the same location of the former gage. A gage in this location would ensure compliance with higher flow releases such as those proposed for aquatic habitat forming flows. Consultation with USGS for the development of this gage site would help ensure future compliance with USGS standards for flow measurement, if appropriate. Additionally, consultation with FWS, NMFS, and the WDFW would be appropriate as construction activities associated with the installation of the stream gage could result in some short term environmental impacts such as sediment discharges, temporarily increasing turbidity within lower Lake Creek and in the unlikely event that a weir structure is deemed necessary for this gage location, these agencies should be consulted on the design to ensure the facility does not hinder anadromous fish passage within lower Lake Creek.

A streamflow and lake water level monitoring program and reporting program for the project would provide documentation of compliance with flows and lake water levels required by a new license.

Project-Influenced Water Temperature

Under current project operations, water discharged from the project causes periodic violations of applicable water temperature standards in the project tailrace and in the Cowlitz River at the confluence of the tailrace from May 16 through August 31. It is probable that violations of the more restrictive water temperature criteria from September 1 through May 15 in the Cowlitz River near the confluence of the tailrace (not to exceed 13°C) also occur under current operations. Warm surface water is withdrawn from Packwood Lake at the outlet structure and is diverted to the Packwood powerhouse and exits through the project tailrace. In addition, warm surface water from Packwood Lake also is released from the outlet structure to Lake Creek. Studies conducted during the relicensing process showed that the water temperature at both the tailrace and in lower Lake Creek downstream of the outlet structure sometimes exceed the 7-DADMax of 19.39°C water temperature standard. During both years (2004 and 2005) of water temperature monitoring at the tailrace, 7-DADMax temperatures of 21.25°C in 2004 and 20.83°C in 2005 were recorded, which would exceed the maximum allowable temperature by more than 1.4°C.

Because the tailrace water is likely to exceed the temperature standard in August (similar to 2004 and 2005), Energy Northwest proposes to implement a Water Temperature Monitoring Plan, which it filed with the Commission on June 6, 2008, in consultation with the Washington Department of Ecology. The monitoring plan would evaluate the effectiveness of project operations, including the timing of the annual

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outage, in meeting the applicable temperature standard at the confluence of the project tailrace with the Cowlitz River. Specifically, Energy Northwest would monitor water temperatures at seven sites in four areas: (1) the tailrace, (2) Lake Creek, (3) Packwood Lake, and (4) the Cowlitz River. Monitoring would take place on an annual basis between June 25 and October 5 for the first 10 years of the new license (or until modified by the Washington Department of Ecology).

If monitoring indicates the tailrace temperature standard is not met, and Washington Department of Ecology determines that Energy Northwest has employed all known, available, and reasonable methods of prevention, control, and treatment, and the temperature criteria still has not been met at the end of 10 years of monitoring, Energy Northwest would consult with Washington Department of Ecology to determine the next appropriate steps to be taken. These may include designating a mixing zone, determining whether the continued project temperature excursions are economically and socially acceptable, doing temperature mitigation (such as shade tree plantings) along the tailrace canal, or ramping power usage, if all other reasonable, feasible measures have been tried or investigated.

A condition of the draft water quality certification, issued by Washington Department of Ecology on May 29, 2009, requires compliance with Washington State’s water quality standards in Packwood Lake, Lake Creek, and the tailrace area of the Cowlitz River based on the designated use categories including criteria for total dissolved gas, pH, dissolved oxygen, fecal coliform, turbidity, and temperature. However, Washington Department of Ecology also states that temperature is the only problematic parameter and requests general compliance with the Water Temperature Monitoring Plan filed by Energy Northwest. The key difference specified in the draft water quality certification is that, if temperature in the tailrace continues to exceed the identified standards following 3 years of monitoring, Energy Northwest would be required to identify adaptive management strategies to further improve the temperatures in accordance with schedules and criteria determined by Washington Department of Ecology. In addition, the draft water quality certification states that, if the temperature criteria are met throughout the outage period during the 3 years of water temperature data collection, Energy Northwest would not need to continue monitoring or further action.

Our Analysis

The major influence of the temperature of water released by the powerhouse into the tailrace is the temperature of the source water in Packwood Lake near the outlet structure. In addition, during project shutdowns the water in the tailrace and the tailrace slough can be subjected to additional increases in temperatures during the summer due to warming from ambient air temperatures. However, in October of 2007 a permanent fish barrier was installed which prevents fish from entering the tailrace, effectively limiting the effects of the water temperature on fish to only the tailrace slough. The effect of discharged water from the project to the tailrace slough is also dependant on the volume

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of water flowing through the slough from the Cowlitz River. During the summer, the flow of water from the normally cooler Cowlitz River through the tailrace slough is dependant on the location of the migrating side channel of the Cowlitz River. The side channel of the Cowlitz River which supplies water to the tailrace slough tends to migrate during high flow events due to the mobile riverbed materials. During some summers, the majority of the water supplied to the tailrace slough is from project discharge, but in other years, there is also substantially cooler Cowlitz River flow in this location. In the past, Energy Northwest scheduled their annual project shutdown during the first three weeks of October. Energy Northwest has proposed to move the timing of the annual project shutdown to August 15, to avoid providing flows that would attract salmonids to the tailrace slough area during their spawning and to insure that adequate water is available in Packwood Lake to provide for the large proposed minimum flows to Lake Creek. In addition, a project shutdown starting on August 15 would avoid the discharge of naturally warm surface water to the project tailrace during the Chinook salmon spawning period.

Energy Northwest monitored water temperature in the tailrace at the lower end of the lined tailrace, immediately downstream of the powerhouse, and in the side channel of the Cowlitz River into which the tailrace discharges. When the project is operating, flow in the tailrace slough can be partially from the Cowlitz River and partially from the project tailrace or mostly from the tailrace discharge. The side channel geometry and the amount of river flow in this area can be dramatically altered by flood events. Energy Northwest’s monitoring shows that when the project is operating, there is only a minimal change in water temperature between the intake at Packwood Lake and the powerhouse outflow (see tables 3-3 and 3-4) as measured in the tailrace.

Table 3-12 shows general comparisons of the water temperature data measured near the Packwood Lake intake area and the tailrace. On average, daily maximum water temperatures were slightly warmer at the lower end of the tailrace, compared to the upper end. On a few days when generation did not occur for 1 to 3 day periods (see figure 3-3) because of low inflows to the lake, the temperature at the Packwood Lake outlet and the tailrace differed by as much as 0.3 °C.

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Table 3-12. Comparison of measured water temperatures in 2005. (Source: Energy Northwest, 2008a)

Immediately downstream of powerhouse minus Packwood

Lake at intake

End of tailrace minus immediate downstream of

powerhouse

Max Daily Temp (°C)

Mean Daily Temp (°C)

Max Daily Temp (°C)

Mean Daily Temp (°C)

Mean Max Mean Max Mean Max Mean Max

May -0.09 -3.70 0.06 0.54 0.34 0.62 0.17 0.36

June -0.10 -0.53 0.30 0.12 0.36 1.10 0.17 0.39

July -0.10 -0.52 0.33 0.09 0.40 0.77 0.05 0.16

August -0.16 0.63 0.58 0.12 0.27 0.60 -0.10 -0.19

September 0.02 0.59 0.58 0.10 0.03 -0.51 -0.13 -0.26Note: Data for July, August, and September include data from dates without generation.

The amount of flow in the Cowlitz side channel that the tailrace discharges into varies by year depending on flow supplied to this location from the Cowlitz River. In 2005, most of the flow in this side channel was from the Cowlitz River, unlike the prior year when the majority of the flow was from the project tailrace. Figure 3-3 shows that, during the summer of 2005, the temperature in the tailrace was directly reflective of the water temperature in Packwood Lake, with the exceptions during periods when water was not being discharged to the tailrace from the powerhouse. Figures 3-3 and 3-4 show that in general the flow in the tailrace is 2 to 3°C warmer than flow in the Cowlitz River during most of July and August.

Conducting water temperature monitoring as Energy Northwest proposes would evaluate the effectiveness of project operations including the planned annual shutdown starting in mid August to meet the temperature standards at the confluence of the tailrace and the Cowlitz River. While previous temperature monitoring by Energy Northwest showed a general slight increase in the water temperature in the tailrace during project shutdowns in October, the proposed August shutdowns substantially would decrease the overall volume of warm water discharged to the tailrace. Monitoring water temperature also would provide information to determine the effects of the project discharge compared to the dynamic location and flow associated with the tailrace slough. Monitoring water temperatures in these areas and consultation with Washington Department of Ecology would provide valuable information to allow for the potential development of additional measures to decrease the effects of the project discharges on

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water temperatures in the Cowlitz River. In addition, because Washington Department of Ecology water quality standards are designed to protect salmonid spawning, emergence, adult holding, and summer rearing these measures would to the extent possible minimize potential adverse effects on Chinook and coho salmon, steelhead, sea-run cutthroat trout, O. mykiss, and resident cutthroat trout.

Hazardous Substance Spill Prevention and Protection of Surface and Groundwater Quality

Energy Northwest did not propose any measures directly related to hazardous substance spill prevention and prevention of contaminants from degrading surface and groundwater quality during normal project maintenance operations. In its May 29, 2009, filing of the draft water quality certification, Washington Department of Ecology specifies conditions that would involve spill prevention and control methods for hazardous substances and water quality protection for all over-water and near-water work related to the Packwood Project that can affect surface or groundwater quality. Washington Department of Ecology states that these activities include, but are not limited to, construction, operation, and maintenance of fish collection structures, generation turbines, penstocks, transportation facilities, portable toilets, transmission corridors, structures, and staging areas for all activities related to project operations. These conditions would involve the development of the following measures and plans: spill prevention and control; a water quality protection plan that has control measures to prevent contaminants from entering surface and groundwaters; a stormwater prevention plan that includes best management practices; an in-water work protection plan; and measures for monitoring, maintenance, and reporting water quality

Our Analysis

Relicensing studies have shown that the general water quality of the project area is very good and within the applicable standards other than occasionally for water temperature. These conditions are expected for an area with limited disturbances associated with the project and other human activities. Actions such as regular project maintenance have the potential to affect water quality because hazardous substances such as oil and chemicals are normally used in the powerhouse and other locations, and some proposed environmental measures involve ground disturbance. Energy Northwest is probably already in compliance with most of these conditions in the draft water quality certificate, but compliance with these measures and plans would be a requirement of a new license and would reduce the possibility of a spill and water quality degradation.

Tributary Headcutting Monitoring

Lake level drawdown may affect the headcutting in tributaries that drain to Packwood Lake. These tributaries are important for reproduction and rearing of a native strain of uniquely adapted Packwood O. mykiss spp. If high flows occur during

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drawdown, erosion and headcutting into the tributaries upstream of the lake bed may occur. If low flows occur during the drawdown period, tributaries may incise into the deltas and lake bed. Both these processes may result in issues with fish passage and habitat reduction.

The Forest Service specifies that Energy Northwest develop a Packwood Lake Tributary Monitoring Program after consultation with the Forest Service within 5 years of license issuance. It specifies that the monitoring program should focus on two tributaries to Packwood Lake—Muller and Upper Lake Creeks—and that the initial monitoring program would occur at year 10 of the new license (2020) and reoccur every 10 years thereafter. The monitoring program should employ the same data collection methods as implemented in the Stream Connectivity in Packwood Lake Tributaries Study Plan (Energy Northwest, 2005) as summarized below:

A survey of each tributary channel would be made from elevation 2,846 feet msl upstream until a permanent grade control or geologic structure is encountered, or in the case of Upper Lake Creek and Muller Creek, 300 feet upstream of the point where field evidence indicates the channel is not incised. Prior to the survey on Upper Lake and Muller creeks, a reconnaissance-level walk of the low gradient portion of the creek would be made, noting any indicators of incision, to determine how far upstream the survey would extend.

The channel survey would include a profile surveyed with a stadia rod, tape, and level to establish a profile of the thalweg, water surface, bankfull, floodplain, and terrace would be collected to provide information on channel incision.

At each thalweg profile station, water depth and channel width would be measured to provide information on hydraulic characteristics. The width and depth to thalweg of the wetted channel, bankfull channel, top of bank, and any recent terraces also would be measured.

At each thalweg profile station, dominant and sub-dominant substrate size would be noted to provide information on channel substrate composition.

Photos would be taken of each tributary to document the drawdown zone and any channel incision features noted.

An assessment of channel incision would be made based on a description of the following field indicators that may indicate channel incision at various stages of channel evolution.

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The survey information would be used to assess the potential problems related to fish passage through the stream channels in the area affected by the lake level. In addition, the survey would provide for analysis of the potential for lost instream and terrestrial habitat, loss of riparian vegetation, downstream flooding, channel widening, increased turbidity and suspended sediments, mid-channel bar formation due to increased sediment load, deceased bank stability, and loss of wetlands.

Our Analysis

Packwood Lake is fed by at least seven fish-bearing tributaries including Upper Lake, Beaver Bill (a tributary of Upper Lake), Muller, Crawford, Trap, Osprey, and unnamed tributary southeast of Trap creeks, with the glacial-fed Upper Lake Creek supplying most of the lake inflow. The other tributaries are typically small spring-fed drainages (400 to 700 acres) that descend in steep mountain headwall channels but with the lower 0.25 to 0.75 river miles transition to a moderate gradient (< 4 percent) and are accessible to fish. These small streams have a bankfull width typically < 10 feet, and low flow at an estimated volume of 3 to 6 cfs. Abundant overhanging vegetation, fallen logs, and undercut banks provide plentiful hiding habitat.

Operation of the project results in fluctuations of the lake levels. Currently from May 1 to September 15 lake levels are held at the license-requirement of 2,857 feet msl plus or minus 6 inches. Also under current conditions, after mid-September, the lake level may be drawn down 8 feet to a level no lower than 2,849 feet msl. During times when the lake is drawn down, tributaries entering the lake temporarily experience a lower water level and the flow in these tributaries can incise into the deltas and lake bed, potentially limiting fish passage. In addition during higher flows especially under low lake levels, erosion and headcutting in the tributaries upstream of the lakeshore may occur, limiting fish passage in the tributaries during all flows. Figure 3-9 provides a graph of the monthly lake levels and the estimated inflow to Packwood Lake including an example of high inflows during relatively low lake level elevations during January and February 2004.

Conducting geomorphologic monitoring as specified by the Forest Service would evaluate the effects of the water level management of Packwood Lake on two key tributaries of Packwood Lake. Prior monitoring conducted by Energy Northwest showed that water level of Packwood Lake does have an effect on tributary headcutting; the monitoring specified by the Forest Service also would provide information to determine the effects of the water levels of Packwood Lake on the continued trout access to these key spawning tributaries after the possible issuance of a new license.

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2,848

2,850

2,852

2,854

2,856

2,858

2,860

2,862

Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Jan-07

Pack

woo

d La

ke L

evel

(fee

t msl

) .

0

50

100

150

200

250

300

350

400

Inflo

w (c

fs)

.

minimum monthly level maximum monthly level Inflow to Packwood Lake (cfs)

Figure 3-9. Monthly lake levels and inflow from January 1999 to December 2007. (Source: Energy Northwest, 2008a, modified by staff)

Packwood Lake Elevation Restriction

The lake level fluctuations resulting from project operations can potentially affect the quality and quantity of littoral habitat within the lake that is used by juvenile and adult O. mykiss spp. for feeding and cover, the migration of O. mykiss spp. into their spawning tributaries (due to the creation of upstream migration barriers in the drawdown zone), and the migration of juvenile O. mykiss spp. into Packwood Lake. These fluctuations may also influence water quality (discussed in section 3.3.1, Aquatic Resources), wetland vegetation and native amphibians (discussed in section 3.3.2, Terrestrial Resources), recreation (discussed in section 3.3.4, Recreation and Land Use Resources), and project generation (discussed in section 4.0, Developmental Analysis).

Energy Northwest proposes to slightly change the rule curve for the operation of Packwood Lake. Its proposed rule curve would retain the lake elevation of 2,856.5 feet msl from May 1 to September 15. The proposed rule curve would eliminate both the May 1 to September 15 lake elevation restriction of 2,857.5 feet msl and the maximum operating water surface elevation of 2,858.5 feet msl.

Consistent with Energy Northwest’s proposed rule curve, the Forest Service specifies and Washington Fish and Wildlife recommends that Energy Northwest maintain a minimum Packwood Lake elevation of 2,856.5 feet msl between May 1 and September

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15 of each year and a minimum lake elevation of 2,849 feet msl between September 16 and April 30 of each year. In addition, the Forest Service specifies and Washington Fish and Wildlife recommends that Energy Northwest not decrease lake elevation by more than 1 foot per day.

According to Energy Northwest, the Forest Service, and Washington Fish and Wildlife, the May 1 to September 15 lake level restriction would ensure tributary stream connectivity with Packwood Lake for adult O. mykiss spp. spawning and fry out-migration; provide stable water levels for wetland and amphibian productivity (see section 3.3.2, Terrestrial Resources); keep recreational activity on the west shore of Packwood Lake at a minimum (see section 3.3.4, Recreation and Land Use Resources); and maintain Packwood Lake elevations that reflect the natural hydrology (see section 3.3.1, Aquatic Resources). The September 16 to April 30 minimum winter water surface elevation is intended to provide sufficient water for increased instream flows into lower Lake Creek, for uninterrupted tailrace flows after the project maintenance outage and continuous flows for project generation. According to Energy Northwest, the rapid drawdown, which starts in mid September under current conditions, would no longer occur due to the proposed change in timing of the project outage and the goal of continuous generation flows which would result in a much more gradual lake level drawdown in the fall.

Our Analysis

Packwood Lake supports a relatively large, genetically distinct population of adfluvial O. mykiss spp. that spawns in the tributaries to Packwood Lake in May and June when streamflows and lake levels are at their highest stages of the year. The adult spawners typically return to the lake shortly after spawning, leaving the tributaries by early July. Following emergence from the gravel, the resulting O. mykiss spp. fry move out of the tributaries and into Packwood Lake by late August. Because Energy Northwest’s proposed rule curve would retain the existing lower lake elevation of 2,856.5 feet msl from May 1 to September 15 and commence the fall drawdown after mid-September, the proposed rule curve would likely have no effect on the migration of O. mykiss spp. into or out of the tributaries to Packwood Lake. The proposed drawdown (beginning on September 16) would occur after both the O. mykiss spp. spawning period (May through June) and the fry outmigration period (prior to the latter part of August). As a result, connectivity between Packwood Lake and the pertinent tributaries would remain intact.

While seasonal water level fluctuations in lakes and reservoirs are known to adversely affect the quantity and quality (complexity) of littoral habitat, alter the production of benthic macroinvertebrates, and disrupt the growth of native aquatic vegetation, O. mykiss spp. in Packwood Lake appear to move into deeper water as near surface water temperatures increase during the summer. Energy Northwest contends that

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very few fish use the littoral zone in mid-September when the proposed drawdown would be initiated due to relatively high summer water temperatures in the lake’s epilimnion (see section 3.3.1, Aquatic Resources); however, there is little data to support this hypothesis. In addition, the relatively distinct population of O. mykiss spp. in Packwood Lake has remained self-sustaining and relatively large36 under the existing project rule curve for decades, despite fairly intensive recreational harvest. The current abundance in Packwood Lake suggests that the population is at very low risk of extirpation and would likely remain robust under Energy Northwest’s modified rule curve.

Within the lake level range between elevation of 2,849 and 2,858.5 feet msl, Packwood Lake has about 450 acre-feet of storage per foot of drawdown. The maximum normal flow to the powerhouse is about 225 cfs, which for 1 day is a volume of about 445 acre-feet. Therefore, Energy Northwest is unable to drawdown Packwood Lake by more than about 1 foot per day even under unrealistically dry conditions of negligible inflow or inflows equal to flows released to lower Lake Creek. Therefore, the Forest Service specification and Washington Fish and Wildlife recommendation of a limit in the decrease of the lake elevation of 1 foot per day will be met by normal project operations.

Annual Project Maintenance Outage (Tailrace Slough)

The project tailrace canal discharges into a side channel of the Cowlitz River (tailrace slough). Tailrace slough is a highly dynamic side channel with frequently changing morphology as a result of flood events. During some years (e.g., 2005) flood flows in the Cowlitz River can reconfigure this side channel so that it derives most of its inflow from the mainstem Cowlitz River. When the slough is connected to the mainstem Cowlitz River, project flows have little effect on water levels in the slough. During other years, like the present configuration, the tailrace slough is not connected to the mainstem Cowlitz River and water levels in the slough are almost entirely dependent on project flows. In this condition, flows and water levels in the tailrace slough are strongly affected by water releases from project operations. Chinook and coho salmon and37 steelhead are known to reside the tailrace slough at various life stages, and the amount of flow entering the tailrace slough (either from the project or the mainstem Cowlitz River) greatly affects the quality and quantity of available spawning, rearing, and incubation habitat for these species.

Under existing project operations, a project shutdown associated with annual maintenance occurs in late September and potentially runs through the third week in October. During this period, generation ceases and water from the project is not added to the tailrace slough. This loss of flow has the potential to dewater salmon eggs previously

36 The current lake population is estimated at about 30,000 fish.

37 Energy Northwest documented both adult and juvenile coho salmon and juvenile Chinook salmon in the tailrace slough during studies conducted from 2005 to 2007.

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deposited in redds and adversely affect the quality and quantity of available rearing habitat. The timing of this shutdown coincides with the latter portion of the Chinook salmon spawning period (when eggs have already been deposited in the gravel) and with the year-round coho salmon and steelhead rearing period.

To minimize potential adverse effects on Chinook salmon spawning, Energy Northwest proposes to commence its annual maintenance shut down on August 15 of each operating year. Operations would resume by September 15, or earlier, if all the necessary work has been completed. Currently the lake is drawn down to 2,849 feet msl prior to the outage. To avoid potential impacts to the Packwood Lake environment, Energy Northwest does not propose a pre-outage drawdown.

Prior to the annual project shutdown, Energy Northwest also proposes to inspect the Cowlitz River side channel that flows into the tailrace slough. If the side channel is dry, Energy Northwest would initiate a fish rescue within 12 hours of cessation of flows through the project tailrace and move any captured fish into the mainstem Cowlitz River. If there is flow through the side channel, no fish rescue would be required. Energy Northwest would also inspect and electrofish the section of tailrace upstream of the fish barrier within 12 hours of the project’s annual maintenance outage and seine the project’s stilling basin within 72 hours of the outage. The total number of each species captured during the fish rescues would be recorded in the field and the information would be provided to the aquatics resource panel in the annual report.

Consistent with Energy Northwest’s proposed annual maintenance schedule, the Forest Service specifies and Washington Fish and Wildlife and NMFS recommend that Energy Northwest perform its annual project equipment maintenance (outage) starting on August 15 of each year and eliminate the pre-outage lake drawdown. The intent of the outage period is to complete all major maintenance, inspections, and testing within one month (i.e., prior to September 15). NMFS also recommends that Energy Northwest conduct, within 2 years of license issuance, a risk analysis based on the frequency and duration of unplanned shutdowns and develop plans for maintaining flow to redds dependent on project flows and rescue of stranded fish.

Our Analysis

As described above, the tailrace slough is a highly dynamic side channel with frequently changing morphology as a result of flood events. During some years (e.g., 2005) flood flows in the Cowlitz River can reconfigure this side channel (tailrace slough) so that it derives most of its inflow from the mainstem Cowlitz River. When the slough is connected to the mainstem Cowlitz River, project flows have little effect on water levels in the slough. During other years, like the present configuration, the tailrace slough is not connected to the mainstem Cowlitz River and water levels in the slough are almost entirely dependent on project flows. In this condition, flows and water levels in

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the tailrace slough are strongly affected by water releases from project operations. Chinook and coho salmon,38 steelhead, sea-run cutthroat trout, rainbow trout, resident cutthroat trout, and mountain whitefish are known to reside the tailrace slough at various life stages, and the amount of flow entering the tailrace slough (either from the project or the mainstem Cowlitz River) greatly affects the quality and quantity of available spawning, rearing, and incubation habitat for these species.

Energy Northwest has historically scheduled an annual project shutdown to perform equipment maintenance and inspection during the first three weeks of October. According to Energy Northwest, October was selected to minimize the economic impact of the outage, because it is typically a month with low inflows to the lake (see section 3.3.1.1). In preparation for the outage, Packwood Lake is normally drawn down during the last two weeks in September. The resulting low lake level facilitates the work around the intake structure and minimizes the potential of an uncontrolled spill event down Lake Creek during the outage period.

As part of its relicensing studies, Energy Northwest conducted aquatic habitat and fish population surveys in the tailrace slough and mainstem Cowlitz River and determined that an annual project shutdown in October has the potential to adversely affect incubating spring Chinook salmon eggs deposited in the tailrace slough.39 According to Energy Northwest, the highest likelihood for loss of spawning habitat and dewatering of redds in the slough occurs between October and February. This directly coincides with Chinook and coho salmon spawning and incubation in the Cowlitz River. By beginning the outage on August 15, rather than the current outage timing, the project would avoid providing attraction flows that would draw adult Chinook and coho salmon into the tailrace slough to spawn. Outage in this earlier period would also help avoid the discharge of naturally warmed Packwood Lake surface water into the Cowlitz River, when summer temperatures are at their highest; and help ensure adequate water is available in Packwood Lake to provide the proposed minimum flows for Lake Creek. In addition, eliminating the pre-outage drawdown would help ensure the project maintain continuous operation from the end of the outage in mid-September through the end of October and minimize any potential drawdown-related adverse effects on the migration of juvenile O. mykiss spp. from the Packwood Lake tributaries.

Conducting fish rescues in the tailrace slough (when the Cowlitz River side channel is dry), tailrace, and stilling basin following the cessation of project operation would minimize potential impacts to fish residing in these areas including federally listed species. Following standard NMFS and Washington Fish and Wildlife fish capture and

38 Energy Northwest documented both adult and juvenile coho salmon and juvenile Chinook salmon in the tailrace slough during studies from 2005 to 2007.

39 If the tailrace slough is receiving inadequate flow from the Cowlitz River to support spawning and is entirely dependent on water from the project tailrace.

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handling guidelines and releasing the captured fish into the Cowlitz River would likely result in higher survival rates for all species captured.

While NMFS recommends Energy Northwest conduct a “risk analysis based on frequency and duration of unplanned shutdowns and develop plans for maintaining flow to redds dependent on project flows and rescue of stranded fish,” the objectives of this risk analysis are not clearly defined in the agency’s section 10(j) rationale. As a result, it is difficult for staff to evaluate the potential value of such an analysis. Nevertheless, we conclude that providing NMFS with an annual record of the timing and duration of all planned and unplanned project shutdowns and the results of all associated fish salvage efforts should present NMFS with enough information to evaluate any potential adverse effect on ESA-listed species.

Lower Lake Creek Stream Restoration and Enhancement Plan

Prior to project construction in 1964, lower Lake Creek naturally drained all runoff that entered Packwood Lake. Under existing license conditions, the project diverts water out of Packwood Lake and returns the diverted flow to the Cowlitz River approximately 4 miles downstream from the mouth of Lake Creek. Energy Northwest currently releases a minimum of 3 cfs into lower Lake Creek to protect resident and anadromous fish and other aquatic species. There is also an instream flow requirement of 15 cfs at the confluence of Lake Creek with the Cowlitz River. While additional accretion from runoff occurs along the 5.3 mile stretch of Lake Creek between the project intake and the confluence with the Cowlitz River, the reduction in natural flows has reduced the depths and velocities of habitats available to resident and anadromous fish and benthic macroinvertebrates, thereby reducing the amount of available habitat. The project’s constant 3 cfs minimum instream flow release also has altered seasonal and inter-annual hydrologic variation in lower Lake Creek (see section 3.3.1, Aquatic Resources). Altering the timing, frequency, magnitude, or duration of naturally occurring flow events can reduce habitat diversity, cause river channels to degrade and disconnect from floodplains, disrupt migration and spawning cues for fish, affect the breeding and dispersal of amphibians, and alter the survival and distribution of juvenile fish and macroinvertebrates (ISG 2000; NRC 1996; Richter et al., 1996).

To enhance aquatic habitat in lower Lake Creek, Energy Northwest proposes to increase instream flows to the levels presented in table 3-13. Energy Northwest also proposes to increase the amount and quality of anadromous fish spawning and rearing habitat in lower Lake Creek (river mile 0-1.0) through the installation of wood and boulder stream structures to provide for additional pools, gravel retention, and other beneficial habitat features; add gravel to these structures to immediately improve habitat; monitor these stream enhancement measures to verify improvements to habitat; and supplement the stream structures with gravel recruitment stations to provide adequate movement of gravel into the anadromous reach.

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Table 3-13. Proposed instream flows (cfs) for lower Lake Creek as measured at the drop structure. (Source: Energy Northwest, 2008a)

MonthInstream Flow

Release (cfs)

January 4

February 4

March 4

April 7

May 15

June 10

July 15

August 1-15 15

August 16-September 15 20

September 16-30 15

October 10

November 7

December 4

Energy Northwest anticipates using an adaptive management approach to develop the plan, and expects that goals, objectives, and evaluation metrics would be developed and modified or amended as discussions continue with the stakeholders.

NMFS’ recommends that Energy Northwest develop, after consultation with NMFS, FWS, the Forest Service, Washington Fish and Wildlife, Washington Department of Ecology, and the tribes a plan of increased flows (as prescribed in table 3-12) and habitat enhancement to address degradation and loss of anadromous fish rearing habitat in lower Lake Creek due to the effects of project operations.

The Forest Service specifies and Washington Fish and Wildlife recommends that Energy Northwest implement the instream flow releases presented in table 3-12. Washington Department of Ecology in its draft water quality certification has a condition that also specifies the same instream flows. In addition, the Forest Service specifies and Washington Fish and Wildlife recommends that Energy Northwest verify and adjust flow readings (at the bypass pipe discharge point) to meet the minimum instream flow at least twice each day from the powerhouse control room, make available instream flow data upon request, and provide an annual report of daily instream flow at the Annual Resource Coordination meeting.

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In addition to the instream flow releases described above, the Forest Service specifies and Washington Fish and Wildlife recommends that Energy Northwest prepare a lower Lake Creek stream restoration, enhancement, and monitoring plan for the anadromous reach of lower Lake Creek up to river mile 1.0. The plan would be prepared within 2 years of license issuance, in coordination and consultation with the Forest Service, FWS, NMFS, Washington Fish and Wildlife, Washington Department of Ecology, and the tribes, and would be approved by the Forest Service and the Commission. According to the Forest Service and Washington Fish and Wildlife, the primary goal of the plan would be to restore and enhance anadromous and resident salmonid habitat in lower Lake Creek by increasing rearing and spawning habitats. The lower Lake Creek stream restoration, enhancement, and monitoring plan would use the following objectives and design criteria as the basis for plan development.40

Rearing Habitat Objectives:

Increase the number of pools in lower Lake Creek to represent about 30 percent of the available stream habitat.

Improve the rearing habitat found in the remaining runs and glides by about 15,300 square feet.

Spawning Habitat Objectives:

Increase the number of pool and pool tail-outs.

Place gravel into the pool tail-outs of appropriate size for salmon and trout spawning.

Increase spawning habitat in the reach by about 1,700 square feet (about +/-10 percent).

Restoring Geomorphic Functionality:

Shape the channel to ensure that the 1.5 year recurrence interval flows (285 cfs) fills the channel to its morphological bankfull stage.

Restore channel complexity and roughness factors (e.g., boulders and large wood).

Add bed material that can be partially mobilized at bankfull flow.

40 If reach specific assessment data indicate adjustments that would maximize the primary objectives, the objectives and design criteria may be modified after consultation with the natural resource agencies and the tribes.

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Geomorphic Objectives, Design Elements, and Structural Criteria:

Convert a degraded plane-bed/step-pool system into a wood forced step-pool system; construct pool-forming bedforms (steps) using boulder and wood complexes; and increase instream habitat cover and complexity.

Convert current glide habitat into high quality pool habitat.

Increase residual pool depths to increase habitat capacity during low flow periods.

Increase available spawning habitat through gravel augmentation.

In addition, the Forest Service specifies and Washington Fish and Wildlife recommends that Energy Northwest consult with both agencies, to develop effective monitoring elements, as needed, to track the status of resource objectives, employ the principle of adaptive management to modify the environmental measures, and meet resource-specific objectives and/or desired conditions. Energy Northwest would update and/or revise as needed the lower Lake Creek stream restoration, enhancement, and monitoring plan every 5 years. The initial 5-year update to the plan would be completed 10 years after issuance of any new license and would be filed in 2020.

Our Analysis

The lower 1.0 mile of lower Lake Creek are accessible to Chinook and coho salmon, steelhead/rainbow trout, and coastal cutthroat trout with an additional 0.9 miles accessible to steelhead (the anadromous zone). Under existing conditions, there is a general lack of high quality spawning and rearing habitat in the anadromous zone of lower Lake Creek. Stream surveys conducted as a part of project relicensing documented very few pools and a very low density of large woody debris in this reach. Whereas the upper reaches of lower Lake Creek contain as many as 90 to 130 pieces of wood per mile, the lower reaches contain fewer than 30 pieces per mile. As a result of past logging activities along reach 1 of lower Lake Creek, it is unlikely that large trees would be present near the stream banks to furnish large woody debris in the near future. In addition, the numerous channel constrictions and large boulders make it nearly impossible for wood to be transported very far in the stream. Gravel quantity is also severely limited in the lower reaches of Lake Creek as the lack of large woody debris (and other roughness elements) causes spawning-sized gravels to be flushed through the system or stored on the channel margins where it rarely functions as suitable spawning habitat. This lack of spawning and rearing habitat likely limits the productivity and carrying capacity of lower Lake Creek, reducing the distribution and abundance of native fish populations.

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Energy Northwest, working in close association with the resource agencies, conducted an instream flow study in lower Lake Creek using the Physical Habitat Simulation Model (PHABSIM). PHABSIM incorporates data on river channel characteristics, flow, and fish life-stage suitability to assess the relationship between streamflow and habitat availability. Thirty-four transects in four study sites were selected for lower Lake Creek.

The basic unit of fish habitat calculated by PHABSIM is weighted useable area. Weighted useable area can be interpreted in the context of stream hydrology and species life history to evaluate project effects and serve as the basis for determining alternative flow regimes. Together, Energy Northwest and the resource agencies used the information collected during this study to derive the proposed minimum streamflows listed in table 3-12. Energy Northwest also modified some of the pool and glide/run study transects in lower Lake Creek to reflect general physical habitat changes that would be made to lower Lake Creek as part of its proposed habitat enhancement plan. These changes included:

Increasing the residual pool depth of two transects each in reaches 1 and 2;

Decreasing the wetted width and increasing the depth of run transects in reaches 1 and 2;

Improving the cover components of the pools and runs to increase rearing habitat;

Improving the substrate component of pool tailouts to reflect improved spawning habitat; and

Adjusting the transect weighting in these reaches to reflect decreased run/glide and increased pool and pool tailout habitat.

Energy Northwest then used PHABSIM to predict weighted useable area at the proposed instream flows (table 3-12) (including accretion) with enhancement for each of the analysis species (Chinook and coho salmon, steelhead, O. mykiss, and sea-run cutthroat trout) and life-stages of interest. These predicted “enhancement weighted useable area values” were then compared with weighted useable area values present under and current conditions.

Results of this modeling exercise indicate that for each analysis species, spawning and rearing habitat area would substantially increase with Energy Northwest’s proposed flow regime and habitat enhancements when compared to existing conditions. In lower Lake Creek (from its mouth to the drop structure), enhanced spawning habitat area (weighted useable area) would be on average 473 percent greater than what is present

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under existing conditions, ranging from 264 percent for steelhead spawning to 4,713 percent for Chinook spawning (table 3-14). Enhanced rearing habitat area (weighted useable area) would average 155 percent of existing conditions, ranging from 104 percent for winter trout to 205 percent for rainbow trout (table 3-15). In general, these dramatic increases in weighted useable area (compared to existing conditions) are a function of the poor habitat currently present in the lower 1.0-mile reach.

Results of the large woody debris study found that nearly all of the limited large woody debris in lower Lake Creek is derived from local sources rather than from wood transport. The proposed stream structures and associated gravel placement in the lower mile of Lake Creek would likely compensate for both the lack of large woody debris caused by forest management practices, and for the lack of overall habitat complexity resulting from nearly 50 years of altered flows in lower Lake Creek. The placement of gravel-retaining structures would also help the aquatic habitat forming flows (described below) form desired features, such as scour pools, while helping to retain needed spawning gravel.

The instream flows released to lower Lake Creek have a temperature equal to the water temperature of Packwood Lake, which has relatively warm surface water in the summer. During the warmer months, the current instream flow of 3 cfs of relatively warm water is lowered by accretion of colder water in the 5.3 mile reach of lower Lake Creek. Because the maximum water temperature under the proposed 20 cfs flow release would be about 1.6°C cooler than pre-project (natural) conditions, the increase in water temperature associated with the proposed minimum flows would not cause exceedance of the Washington Department of Ecology water quality standard of 19.39°C for temperature (i.e., the Washington Department of Ecology water temperature criteria states when a water body’s temperature is warmer than the criteria [in this case 7-DADMax of 16.0°C] and that condition is due to natural conditions, then human actions cumulatively may not cause an increase in the 7-DADMax more than 0.3°C) (see table 3-4). The 19.39°C standard is the modeled water temperature at the mouth of Lake Creek under natural conditions (19.09°C) plus the allowable increase of 0.3°C (19.39°C).

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Table 3-14. Summary of spawning weighted useable area by month for lower Lake Creek (current conditions and proposed flows with enhancements). (Source: Energy Northwest, 2008a as modified by staff)

Month

Spawning Weighted Useable Area (sq feet/1,000 feet)a

Treatment Chinook Coho Steelhead Cutthroat Rainbow Mean % Increase

Jan Current Cond. - 199 - 17 - 108 -

Proposed - 567 - 309 - 438 406

Feb Current Cond. - 207 - 17 - 112 -

Proposed - 558 - 318 - 438 391

Mar Current Cond. - - 91 19 - 55 -

Proposed - - 187 354 - 270 491

April Current Cond. - - 98 - - 98 -

Proposed - - 206 - - 206 210

May Current Cond. - - 63 - 72 67 -

Proposed - - 218 - 212 215 321

June Current Cond. - - 51 - 68 59 -

Proposed - - 181 - 163 172 292

July Current Cond. - - - - 51 51 -

Proposed - - - - 192 192 376

Aug Current Cond. 9 - - - - 9 -

Proposed 341 - - - - 341 3,789

Sept Current Cond. 7 - - - - 7 -

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Month

Spawning Weighted Useable Area (sq feet/1,000 feet)a

Treatment Chinook Coho Steelhead Cutthroat Rainbow Mean % IncreaseProposed 412 - - - - 412 5,886

Oct Current Cond. - 103 - - - 103 -

Proposed - 398 - - - 398 386

Nov Current Cond. - 175 - 40 - 107 -

Proposed - 441 - 365 - 403 377

Dec Current Cond. - 212 - 19 - 116 -

Proposed - 530 - 354 - 442 381

Mean Current Cond. 8 166 75 22 64 67 -

Proposed 377 482 198 340 189 317 -

Mean % Increase 4,713 290 264 1,545 295 473 -a Based on 50 percent exceedance values

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Table 3-15. Summary of rearing weighted useable area by month for all sites in lower Lake Creek (current conditions and proposed flows with enhancement). (Source: Energy Northwest, 2008a)

Month Treatment

Rearing weighted useable area (sq feet/1,000 feet)a

Chinook Coho Steelhead Cutthroat RainbowWinter Trout Mean

% Increase

Jan Current Cond. 5,085 3,405 - - - 6,630 5,040 -

Proposed 7,754 5,046 - - - 7,679 6,826 135

Feb Current Cond. 5,062 3,478 - - - 6,830 5,123 -

Proposed 7,718 5,363 - - - 7,589 6,890 134

Mar Current Cond. 4,938 3,650 - - - 7,148 5,245 -

Proposed 7,466 5,979 - - - 6,679 6,708 128

April Current Cond. 4,974 3,609 3,472 2,530 3,582 - 3,633 -

Proposed 7,680 5,511 5,163 4,131 5,557 - 5,608 154

May Current Cond. 4,727 3,886 3,094 2,407 3,326 - 3,488 -

Proposed 7,908 5,049 5,434 4,569 5,746 - 5,741 165

June Current Cond. 4,592 4,018 2,902 2,340 3,187 - 3,408 -

Proposed 7,537 5,933 4,835 4,095 5,521 - 5,584 164

July Current Cond. 3,904 4,415 2,170 2,018 2,497 - 3,001 -

Proposed 7,491 6,068 4,708 4,179 5,489 - 5,587 186

Aug Current Cond. 3,158 4,601 1,686 1,746 1,995 - 2,637 -

Proposed 6,907 6,916 4,181 3,877 5,162 - 5,409 205

Sept Current Cond. 2,938 4,641 1,540 1,649 1,842 - 2,522 -

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Month Treatment

Rearing weighted useable area (sq feet/1,000 feet)a

Chinook Coho Steelhead Cutthroat RainbowWinter Trout Mean

% Increase

Proposed 7,550 5,997 4,723 4,285 5,498 - 5,611 222

Oct Current Cond. 2,938 4,641 1,540 1,649 1,842 - 2,522 -

Proposed 5,857 7,380 3,522 3,421 4,523 - 4,941 196

Nov Current Cond. 4,116 4,364 - - - 8,092 5,524 -

Proposed 6,534 6,999 - - - 7,771 7,101 129

Dec Current Cond. 4,938 3,650 - - - 7,148 5,245 -

Proposed 7,466 5,979 - - - 7,590 7,012 134

Mean Current Cond. 4,281 4,030 2,343 2,048 2,610 7,170 3,747 -

Proposed 7,322 6,018 4,652 4,079 5,357 7,461 5,815 -

Mean % Increase 171 149 199 199 205 104 155 -a Based on 50 percent exceedance values

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While the proposed 15 and 20 cfs instream flow water temperatures would occasionally exceed the preferred temperatures for Chinook, steelhead/rainbow trout, and cutthroat trout rearing (table 3-16); they are well below the upper lethal temperatures for these species (table 3-16). Moreover, rearing anadromous salmonids are known to seek areas of cold water refugia (i.e., groundwater inflow locations, cold water tributaries, and in some cases mainstem river reaches) when water temperatures begin approach the upper end of their preferred range. Cold water refugia would be present in the mainstem Cowlitz River throughout the summer rearing period and may also be present in lower Lake Creek in the form of groundwater inflow. These areas would be easily accessible to rearing Chinook, coho and steelhead/rainbow trout, and cutthroat trout under the proposed flow regime and would allow salmon and steelhead to minimize their exposure to temperatures that might adversely affect their survival. Although the warm water temperatures in August and September would likely continue to limit spring Chinook spawning success in lower Lake Creek (as they likely did during pre-project and existing conditions), they would have no effect on steelhead or coho spawning success as these species spawn primarily in the late fall, winter, and early spring (see table 3-8). Overall, the increases in habitat area associated with the proposed instream flows and habitat enhancements would outweigh any negatives related to these warmer water temperatures.

Table 3-16. Preferred, upper lethal, and lower lethal water temperatures (in °C) for Chinook and coho salmon, steelhead/rainbow trout, and cutthroat trout. (Source: Bell, 1990)

Life History Stage

PreferredSpecies Lower Lethal Lower Upper Upper Lethal

Rearing Chinook 0.0 1.1 14.4 25.0Coho 0.0 3.3 20.6 25.6Steelhead/Rainbow 7.2 7.2 14.4 23.9Cutthroat 0.6 9.4 12.8 22.8

Spawning Chinook 0.0 5.6 10.6 -Coho - 4.4 9.4 -Steelhead/Rainbow - 3.9 9.4 -Cutthroat - 6.1 17.2 -

As a whole, implementation of the recommended minimum instream flows and habitat restoration measures in lower Lake Creek would likely substantially increase the amount and quality of habitat available to anadromous and resident fish on lower Lake Creek. These improved habitat conditions, along with ongoing basin-wide anadromous fish reintroduction efforts, would likely increase wild salmon and trout production in the project vicinity in turn contributing to the recovery of ESA-listed fish species.

While these measures would likely increase the production of native fish species in the basin, we are concerned that the Forest Service and Washington Fish and Wildlife may have identified specific design criteria that may not necessarily reflect what could be

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reasonably achieved in lower Lake Creek. Revisiting and/or refining these target values to allow some flexibility may be more appropriate during the development of the final enhancement plan.

Aquatic Habitat Forming Flows in Lower Lake Creek

As discussed in the previous section, operation of the project reduces the frequency and magnitude of high flow events in lower Lake Creek when compared to pre-project conditions. This altered flow regime affects the natural sediment and small woody debris transport characteristics of the stream channel downstream of the drop structure, and in turn, affects the quality of aquatic and riparian habitat (i.e., reduces habitat complexity). While overtopping events do occur periodically at the drop structure, the absence of frequent bankfull events and their associated channel forming processes is evident, in part, in the lack of gravel and overall habitat complexity in the lower mile of Lake Creek. Aquatic habitat forming flows (periodic controlled high-flow releases) are often implemented at hydroelectric projects and other water diversions to restore or improve aquatic and riparian habitat.

Energy Northwest proposes to provide aquatic habitat forming flows in lower Lake Creek greater than or equal to 285 cfs for as long as lake inflows can sustain the flow for a minimum of 24 hours, every other water year or 3 out of 6 water years, starting in the first water year after issuance of the new license and continuing for the life of the new license. Energy Northwest would take the necessary measures to control Packwood Lake elevation and power generation to ensure that aquatic habitat forming flows are achieved and maintained for up to 24 hours. If the desired frequencies of the aquatic habitat forming flows cannot be achieved, the agencies would be consulted for an alternate plan. Energy Northwest would monitor aquatic habitat forming flows at the drop structure and record the bypass flow and spill flow over the drop structure at appropriate time intervals.

In addition, Energy Northwest would provide the agencies with an annual report on aquatic habitat forming flow attempts and activities including the magnitude, duration, and frequency of these flows and associated power generation throughout the past year, 30 days prior to the annual Resource Coordination meeting. Energy Northwest would allow a minimum of 60 days for the agencies to comment and to make recommendations prior to filing the final report with the Commission for approval.

The Forest Service specifies and Washington Fish and Wildlife recommends the same aquatic habitat forming flows as those proposed by Energy Northwest. They note that sustaining flows for 24 hours is a minimum target established to meet the habitat forming objectives and that flows that persist for less than 24 hours are likely not to meet the desired future condition based on the gravel study. Energy Northwest’s proposal is consistent with the condition in the draft water quality certification.

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According to Energy Northwest, the Forest Service, Washington Fish and Wildlife, and Washington Department of Ecology, the objective of aquatic habitat forming flows is to provide flows of sufficient magnitude, duration, and frequency to sustain habitat forming, and maintaining processes in lower Lake Creek during the operation and maintenance of the project. Some of these processes include the recruitment, mobilization, and deposition of sediment, wood and other organic material.

Our Analysis

Energy Northwest conducted several studies to evaluate the pre and post-project hydrology, channel morphology, and sediment and large woody debris transport regime in lower Lake Creek. Energy Northwest also evaluated appropriate habitat forming flows and the effects of project operations on aquatic habitat. Results of these studies indicate that peak flows in lower Lake Creek (near the mouth) are altered by operation of the project. Prior to project construction, median monthly flows as measured at the Packwood Lake outlet ranged from 48 cfs in October to 193 cfs in June and 65 percent of highest annual flows were between 200 and 500 cfs (table 3-3 and figure 3-10). During the post-project period, median monthly flows at the outlet ranged from 5 to 6 cfs and only 24 percent of the high flows were between 200 and 500 cfs. Flows greater than about 600 cfs appear to have a similar frequency during the pre- and post-project periods.

Figure 3-10. Comparison of before and with project annual highest mean daily flow, Lake Creek near Packwood gage. (Source: Watershed Geodynamics, 2007a)

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The primary source of gravel to lower Lake Creek is from tributaries, landslides, and erosion in the watershed below Packwood Lake. These gravels are transported during higher flow events. Higher flow events also expose and redistribute stored gravels in the lower gradient reaches with wide floodplains. The relatively small amount of spawning gravel currently found in the lower mile of Lake Creek is likely the combined result of a lack of structure to hold gravel, few sediment sources downstream of the drop structure, and reduced transport from upstream reaches.

Movement of painted rocks (large gravel) placed at gravel study sites throughout lower Lake Creek suggest that high flows (on the order of 250 to 300+ cfs) would be needed to mobilize the largest sized spawning gravels (3 to 4 inch diameter) across the entire channel width (Watershed Geodynamics, 2007). Lower flows would likely mobilize smaller gravels if they occurred in the middle of the channel, but the majority of gravel is stored on the channel margins or behind boulders/logs, and would require higher flows to be mobilized. If it is assumed that flows between 200 and 300 cfs would be necessary to move the full range of spawning-sized gravel, gravel transport would likely occur in 70 to 92 percent of the years if the project were not in place, and has occurred in 30 to 40 percent of the years since the project has been operational.

While hydraulic modeling and monitoring of tagged wood at five study sites in lower Lake Creek suggests that flows of 1,200 to 1,600 cfs would be required to mobilize large pieces of wood in lower Lake Creek; it is likely that movement of small pieces of wood also would occur at flows ranging from 200 to 300 cfs due to their shorter lengths and lower weights.

Based on our review of the aquatic habitat in the project area and on the hydrology and geomorphology information presented in the final license application, it is apparent that habitat forming flows would enhance the salmonid habitat in lower Lake Creek. The magnitude, frequency, and duration of the aquatic habitat forming flows proposed by Energy Northwest, specified by the Forest Service, and recommended by Washington Fish and Wildlife would likely meet the flow requirements needed to mobilize spawning gravel and small woody debris, and contribute to the formation and maintenance of habitat features needed to sustain and enhance the habitat for resident and anadromous fish in lower Lake Creek.

Gravel and Wood Placement in Reach 5 of Lake Creek

Under existing project operations, wood and floating debris in Packwood Lake collect at the log boom just upstream of the project intake and drop structure. Some of the smaller wood (small enough for 2 people to carry) is moved over the drop structure and placed into Lake Creek. The larger logs do not enter the Lake Creek stream channel and either sink or float back into the lake. Due to its large size, Packwood Lake currently acts and acted in pre-project conditions, as a sink for all sand, gravel, cobble, and

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boulders originating from upstream sources. As a result, the only natural source of spawning gravel to lower Lake Creek is from tributaries, landslides, and erosion in the lower watershed (below the drop structure). A reduction in peak flows associated with current operations may also limit the amount of streambank scour in lower Lake Creek, affecting the quantity of spawning gravel recruitment downstream of Packwood Lake.

Energy Northwest proposes to establish small woody debris and gravel recruitment stations in the upper portion of reach 5 to enhance aquatic habitat in lower Lake Creek. The wood and gravel would then be transported downstream by the required 285 cfs spill events that would take place every other water year, or 3 out of every 6 years. Energy Northwest would collect wood from the project intake and wind throw from along FS Trail 74 (in excess of 6-feet long and 4 inches in diameter), and place it in the upper portion of reach 5. Energy Northwest would also place 10 cubic yards of variable diameter gravel (between 0.5 and 3.0 inches diameter), onto an exposed bank within the bankfull channel within the first year of license issuance. Energy Northwest would conduct a baseline survey of spawning and rearing habitat in reach 5 prior to gravel or wood supplementation and then monitor the amount of spawning and rearing habitat present in the reach every 4 years thereafter (adding gravel as necessary to replace that lost by stream transport). Upon the completion of the second 4 year survey, Energy Northwest would meet with agency representatives to discuss the survey findings. Collaborative decisions would then be made as to the quantity and duration of gravel and wood placement in lower Lake Creek and whether continued surveys are warranted.

The Forest Service specifies and Washington Fish and Wildlife recommends that Energy Northwest implement the same wood and gravel enhancement and monitoring measures as those proposed by Energy Northwest. However, they suggest that Energy Northwest monitor the amount of spawning and rearing habitat present once every 2 years for 10 years after issuance of any new license.

Our Analysis

Energy Northwest conducted several studies to evaluate aquatic habitat and fish populations in reach 5 of lower Lake Creek. Results of these studies indicate that gravel for O. mykiss spp. spawning is scarce below the drop structure and that this condition likely existed prior to project construction (as would be expected as a result of Packwood Lake intercepting the gravel deposited from the tributaries upstream). These studies also determined that this limited amount of spawning habitat has a direct relationship to the small resident population of O. mykiss spp. present in the area. Although spawning gravel was limited in the reach, Energy Northwest’s large woody debris studies indicate that reaches 4 and 5 of Lake Creek contain approximately 60 to 70 pieces of large woody debris per mile. Large woody debris surveys also indicate that the primary source of instream wood in lower Lake Creek is local trees falling into the creek by wind throw, tree mortality, and mass wasting, and that logs are transported out of the stream

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infrequently.41 Packwood Lake is not a major source of wood for Lake Creek. Wood that has been fluvially transported to its position in the stream accounted for only 12 percent of small logs, 6 percent of medium logs, and none of the large logs. Fluvially transported wood was also either old or very old, further reinforcing the hypothesis that large woody debris is transported very infrequently in lower Lake Creek. It was also determined that flows of 1,200 to 1,600 cfs would be required to initiate transport of small-sized wood but would not initiate transport of many medium or large sized pieces. The highest recorded flow at the Lake Creek gage downstream of Packwood Lake was 1,690 cfs in December 1977.

Although recruitment of gravel and wood throughout the lower Lake Creek system has the ability to increase the amount of spawning and rearing habitat for O. mykiss spp., the amount of gravel in lower Lake Creek appears to be naturally limited due to the presence of Packwood Lake. Under existing operations, large woody debris is abundant in reach 5 of Lake Creek, and it would be likely that future operation of the project would not have a pronounced effect on the supply of local large woody debris in any of the stream reaches.

While moving wood around the drop structure would not likely produce a noticeable change in the wood profile for lower Lake Creek, gravel and small wood placement in reach 5 would likely serve to improve spawning habitat for O. mykiss spp. in this isolated reach, helping to mitigate for the ongoing reduction in habitat resulting from continued water diversion, continued interruption of habitat connectivity, and the continued reduction in the magnitude and duration of peak flow events in the system.

Placing 10 cubic yards of gravel in the stream channel below the drop structure in year 1 of a new license and adding gravel as necessary to replace that lost by stream transport, represents a reasonable approach to enhance aquatic habitat. Coordination with the resource agencies would help determine whether the intended enhancement objectives are being met. Monitoring, according to the schedule proposed by Energy Northwest, although not as frequent as that specified and recommended by the resource agencies, would ensure that enhancement objectives are being met, and facilitate the planning for future gravel augmentation in the reach.

O. mykiss spp. in Reach 5 of Lake CreekPackwood Lake currently supports a large self sustaining population of genetically

unique O. mykiss spp. Historically, fish from this population likely migrated downstream from the lake into lower Lake Creek when the population reached or exceeded the lake’s carrying capacity. Under existing project operations, downstream passage of fish from above the project drop structure to lower Lake Creek occurs only when the drop structure

41 The undisturbed riparian forest in these reaches and riparian protections under the Forest Service’s Forest Plan should result in a continued wood supply in these reaches in the future.

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is overtopped, since the bypass flows pass through the traveling screens prior to reaching lower Lake Creek. Between 1967 and 2003 (the period of best available data), overtopping occurred or is suspected to have occurred on 504 days, averaging 13.7 days per year. However, in some years, no spill occurred.

The Forest Service is concerned with the sustainability and genetic integrity of the resident fish population in lower Lake Creek below the drop structure. As the project drop structure only provides partial downstream passage, there is a lack of free interchange between the lake and creek populations. Washington Fish and Wildlife indicates that supplementation and monitoring of O. mykiss spp. in reach 5 would insure that this habitat is fully utilized by fish for recreational fishing and aesthetics.

To address these concerns that a self-sustaining O. mykiss spp. population exist in reach 5 of lower Lake Creek, Energy Northwest proposes to conduct fish population surveys in the upper 1,464 feet of reach 5 once every 2 years for 8 years, to confirm a population of at least 30 O. mykiss spp. The first survey would be conducted within 1 year of license issuance, before the first aquatic habitat forming flow event, to provide baseline information on the O. mykiss spp. population. If 30 adult O. mykiss spp. are not observed during a survey, Energy Northwest proposes to collect and move 30 healthy, adult O. mykiss spp. from Packwood Lake to reach 5. If 30 or more adult O. mykiss spp. are observed during a survey, Energy Northwest would not do anything. Upon the completion of the first four surveys, Energy Northwest would meet with agency representatives to discuss the findings of the surveys and make collaborative decisions regarding the need to continue fish supplementation and monitoring. If three consecutive surveys of the reach have documented the presence of 30 adult O. mykiss, spp. monitoring of the reach would be discontinued for the remainder of the license period. After the first four surveys, if three consecutive surveys have not confirmed the presence of 30 adult O. mykiss spp. Energy Northwest would continue to monitor reach 5 at a reduced frequency of once every 4 years or until 3 consecutive surveys document the presence of 30 adult O. mykiss spp. Scale samples would be collected during electrofishing surveys to monitor trends of fish age class variability within the reach. Energy Northwest would provide the agencies with a report every 2 years documenting the O. mykiss spp. population monitoring and supplementation efforts in the upper portion of reach 5.

The Forest Service specifies and Washington Fish and Wildlife recommends the same measures as those proposed by Energy Northwest; however, they also indicate that Energy Northwest conduct a survey study in reaches 3 and 4 if three consecutive bi-annual surveys in reach 5 have confirmed the presence of 30 adult O. mykiss spp. If a self-sustaining resident population is also found in these two reaches then monitoring and supplementation in reach 5 would be discontinued for the remainder of the license period.

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Our Analysis

Lake Creek below the project drop structure consists of a series of naturally isolated reaches with numerous barriers prohibiting the upstream migration of fish. The uppermost reach (reach 5) has limited spawning and rearing habitat, resulting in the production of few O. mykiss spp. the only species present in this reach. This lack of available spawning habitat may cue O. mykiss spp. to migrate downstream over a series of natural barriers in search of higher quality habitat.

While the project drop structure is considered a total barrier to upstream and downstream fish migration during the majority of the year, O. mykiss spp. appear to enter reach 5 of Lake Creek from Packwood Lake during periodic spill events. For example, during Energy Northwest’s fisheries studies on lower Lake Creek, biologists observed numerous O. mykiss, spp. approximately 8 to 12 inches long, immediately below the drop structure orienting directly into the current from the outflow pipe (Energy Northwest, 2008a). It is hypothesized that many of these large fish were residents of Packwood Lake that passed over the drop structure during high flow events in 2006.

Although man-made barriers to fish migration can cause population fragmentation which can lead to reduced genetic diversity, increased inbreeding, and elevated risk of extirpation from a stream system, the existing O. mykiss spp. population in lower Lake Creek has remained self-sustaining for nearly 50 years and is still relatively abundant in reaches 3 and 4. While the downstream migration of some O. mykiss spp. residing in Packwood Lake during spill events has likely contributed to this viability, the natural movement of O. mykiss spp. into Lake Creek would continue to be blocked by the project drop structure during the vast majority of the year. The occasional introduction of a limited number of O. mykiss spp. from the healthy Packwood Lake population (combined with other proposed enhancement measures) could potentially assist in increasing the population numbers and overall health of the naturally isolated population. Monitoring the abundance of trout in this reach for a period of 8 years following license issuance, and supplementing this population as recommended by Energy Northwest and the resource agencies, would ensure the downstream and subsequent genetic exchange between the O. mykiss spp. population in Packwood Lake and lower Lake Creek. Supplementation would also likely improve recreational fishing in this portion of Lake Creek.

Ramping RatesAlthough the proposed instream flows and aquatic habitat forming flows described

above would likely benefit aquatic resources in lower Lake Creek, rapid changes in streamflow have the potential to adversely affect aquatic resources. As water recedes during a rapid reduction in flow, potential effects can include the stranding of fish in shallow areas and off-channel habitat, resulting in immediate or delayed mortality; temporary loss of habitat or loss of habitat access; and the dewatering of fish redds (spawning nests), aquatic insects, and plant life (Hunter, 1992). The faster the reduction

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in water surface elevation (or stage), the more likely fish and/or other aquatic organisms are to be stranded or adversely affected. Numerous studies have shown that juvenile salmonids are particularly vulnerable to stranding because they are relatively poor swimmers, settle along shallow margins of rivers, and often occupy interstitial spaces in cobble and large gravel substrates. Limits governing the rate, timing, frequency, and amplitude of project-induced river stage changes (ramping rate restrictions) are often implemented at hydroelectric projects to protect fish from these effects (Hunter, 1992). In general, ramping rates (usually measured in inches per hour) need to be gradual enough to allow fish and other aquatic organisms to move out of shallow areas without becoming stranded when flows decrease (Hunter, 1992).

Energy Northwest’s final license application did not include any measures to address ramping rates at the project. No such measures were recommended by the resource agencies either.

In the draft water quality certification, Washington Department of Ecology has a condition that specifies the ramping rates shown in table 3-17. These ramping rate restrictions are based on the interim ramping rate criteria recommended by Washington Fish and Wildlife (table 3-17) (Hunter, 1992).

Table 3-17. Interim ramping rate guidelines for water diversions in Washington state.a (Source: Hunter, 1992)

Season Daylight Rates Night rates

February 16 – June 15 (salmon fry) No ramping 2 inches/hour

June 16 – October 31 (steelhead and trout fry) 1 inch/hour 1 inch/hour

November 1 – February 15 2 inches/hour 2 inches/hour

a Washington Fish and Wildlife did not make a specific recommendation for ramping rates at the Packwood Project.

Our Analysis

Because rapid decreases in streamflow associated with minimum instream flow releases or aquatic habitat forming flows included in a new license for the project would have the potential to adversely affect fish and other aquatic biota, staff recommended a downramping rate restriction in the draft EA for lower Lake Creek shown in table 3-17. These criteria have been applied to numerous hydroelectric projects located throughout the Pacific Northwest and are designed to mitigate potential adverse effects associated with project-induced flow reductions.

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As proposed, a change in minimum flow releases from 15 to 10 cfs (June 1) would occur when no ramping is allowed during daylight hours; while 2 inches/hour is allowed at night. Changes in flow from 20 to 15 cfs (September 16) and 15 to 10 cfs (October 1) would occur during the June 16 – October 31 period, when changes in stage are limited to 1 inch/hour during both daylight hours and at night. Decreases in flow from 10 to 7 cfs and from 7 to 4 cfs would occur in November and December, when ramping rates of 2 inches/hour are acceptable during all hours of the day and night.

Following issuance of the draft EA, Energy Northwest presented preliminary data at a public meeting on April 27, 2009, in Olympia, Washington, describing anticipated changes in stage associated with instream flow reduction ranging from 20 to 15 cfs and from 15 to 10 cfs. Based on this analysis, the mean hourly change in stage in Reach 5 (the reach closest to the drop structure) was about 1.5 inches from 20 to 15 cfs and just a little under 2 inches from 15 to 10 cfs. Energy Northwest also indicated that these downramping rates would be moderated in a downstream direction as a result of natural accretion flows.42

At this same public meeting, Commission staff requested that Energy Northwest more closely examine the effect of flow reductions associated with the lowering of instream flows on the habitat in lower Lake Creek and file this information with the Commission. In response to this request, on June 9, 2009, Energy Northwest filed the Lake Creek Ramping Rate Plan for Reach 5 below the Drop Structure (Energy Northwest, 2009). In this ramping rate plan, Energy Northwest examines changes in flow need to meet the Washington Fish and Wildlife ramping rate criteria at all 11 transects used for the instream flow study at Study Site 4, which represent habitat found within Reach 5, immediately below the drop structure at the intake.

Based on these findings, Energy Northwest proposes to limit all instream flow reductions described above to a maximum of 2.5 cfs per hour, with the exception of the June 1 reduction in flow, which could be completed in one hour during the night-time hours, to comply with Washington Fish and Wildlife’s seasonal downramping rates referenced in table 3-17. Limiting flows reductions according to this plan through the term of any new license would ensure compliance with these ramping rate criteria and would prevent the sudden discontinuation of minimum flow releases which could lead to fish stranding and other negative effects on aquatic biota.

Entrainment at the Project IntakeExcept during periodic overtopping events at the project drop structure, all of the

water exiting Packwood Lake passes through the project’s two trashracks (and outer debris screens), fills the entire intake well to the lake elevation, and then enters the traveling fish screens located in the project’s intake building. The traveling screens (4

42 Downramping events associated with the proposed aquatic habitat forming flows would not likely exceed 1.0 inches per hour given the project’s existing capacity.

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mm x 4 mm mesh screen) prevent debris and fish from entering the intake tunnel, which transports the water for instream flows to lower Lake Creek, as well as to the powerhouse for power production. The volume of water passing through the fish screens (plant flow and bypass flow) typically ranges from 44 to 190 cfs depending upon project generation. If the outer debris screens are not seated or cleaned correctly, O. mykiss spp. in the lake can become entrained between the trashracks and the traveling screens, resulting in mortalities. O. mykiss may also be subject to relatively high water velocities along the face of the fish screens that may lead to impingement-related injury or mortality. Small fish, especially newly emerged fry, have the greatest potential for entrainment or impingement because of their poor swimming ability, whereas adult salmonids have a much greater swimming ability and generally can avoid entrainment, unless fish desire to migrate downstream. Fish that are entrained or impinged are removed from the lake population and no longer available for recruitment to the lake fishery.

In its license application Energy Northwest proposed to reduce entrainment/impingement at the project intake through a 3-phase adaptive plan. In phase 1, Energy Northwest indicated it would replace existing debris screens with better fitting screens (in 2009), and monitor these screens to determine if entrainment was less than the recommended threshold level. Energy Northwest proposed setting a threshold level of 400 fish mortalities on the “outer” debris screens and 50 on the “inner” traveling screens, recorded during any 1-year time period (1 calendar year). If target numbers were met, this effort would be deemed acceptable. If fish mortalities exceeded this level on both screens, for 2 consecutive years, Energy Northwest would inform the natural resource agencies and tribes and proceed to phase 2. During phase 2 (if required), Energy Northwest would remove the debris screens from the exterior surface of the trashracks, develop other means for cleaning debris from the trashracks, and would monitor for a period of 2 years to determine if entrainment was less than the threshold targets. If project-related impingement fell below the threshold level of 400 fish per year on the traveling screens for 2 consecutive years, the measures taken would be deemed effective and no further actions would be required. If the project exceeded the impingement thresholds for 2 consecutive years, Phase 3 consultation would be initiated. During phase 3 (if required), Energy Northwest would consult with the natural resource agencies and tribes to determine an alternative means of protecting fish at the intake.

In its preliminary 4(e) condition and 10(j) recommendations, the Forest Service specified and Washington Fish and Wildlife recommended that Energy Northwest consult with the Forest Service, Washington Fish and Wildlife, and other interested stakeholders to test and evaluate whether the existing traveling fish screens at the project intake meet current state of Washington approach velocity criteria. According to the Forest Service and Washington Fish and Wildlife, the current measurable objective for fish screen approach velocities at the intake screens are the state of Washington maximum velocity criteria of ≤ 0.80 foot/second over 95 percent of the screen area, and ≤ 0.88 foot/second over 99 percent of the screen area for all intake flows and lake elevations. If testing and

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verification data indicate the traveling fish screens do not meet state criteria then Energy Northwest would modify the existing fish screens and/or evaluate whether administrative controls (restricting operational flows) could provide a means of complying with the criteria or install new fish screens at the project intake. At a minimum, the process would include the test and verification procedures described below, a schedule for implementation, and if necessary as described below, provide for the modification or redesign procedures for the traveling fish screens:

1. Energy Northwest would evaluate the condition and sealing of the existing traveling fish screen with resource agency personnel. If screen condition or sealing problems are found, Energy Northwest, after consultation with the resource agencies, would determine whether to modify the existing traveling screens and/or evaluate the use of administrative controls, or pursue a major screen redesign (see no. 5 below).

2. If the current traveling screens are adequately sealed or, after modifying the screens to be adequately sealed, Energy Northwest would test and verify the screen approach velocity over a range of lake elevations and intake flows (with the trashrack screens removed).

3. If the state screen approach velocity criteria are satisfied, Energy Northwest would retain the existing traveling screen as the primary fish exclusion device, and prepare an intake structure operation manual for agency approval (see no. 6 below).

4. If the state screen approach velocity criteria are not satisfied, Energy Northwest, after consultation with the resource agencies, would determine whether to experiment with a baffling system and other minor modifications (including limiting inflow at certain lake elevations), or pursue a major screen redesign (see no. 5 below). If the screen approach velocity criteria are satisfied, Energy Northwest would develop an intake structure operation manual (see no. 6 below). If the state screen approach velocity criteria are not satisfied, Energy Northwest would complete major redesign of the traveling fish screens (see no. 5 below).

5. If a major fish screen redesign should be warranted, Energy Northwest would consult with qualified engineers to explore options for screening that would satisfy state approach velocity criteria, and then after consultation with the resource agencies, determine the new screen design. A major screen redesign may mean significant changes to the existing screens or replacement of the existing screens. Proposed conceptual designs would be made available to resource agencies by the end of the third year of the new license, final design decision would be made by the end of the fourth year

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of the new license, and construction would be completed by the end of the seventh year of the new license.

6. Energy Northwest would prepare an intake structure operation manual for approval by the resource agencies. The manual would be provided to the resource agencies within 2 years of time the final intake structure configuration is completed.

In the draft EA, staff evaluated both Energy Northwest’s and the resource agency’s recommendations to address entrainment at the project intake and concluded that Energy Northwest’s proposal, and its associated biological monitoring component, would adequately protect trout residing in Packwood Lake. We also acknowledged that meeting the state’s criteria would likely protect trout at the intake; however, we concluded the costs associated with a major fish screen design (the worst case scenario), would likely outweigh the incremental benefit to the lake’s trout population over that anticipated under Energy Northwest’s proposal.

Following issuance of the draft EA, Energy Northwest, the Forest Service, NMFS, and Washington Department of Ecology developed an alternative approach to address entrainment at the project intake that involved biological monitoring (entrainment and fish population monitoring). This approach was subsequently incorporated into Forest Service modified 4(e) condition 9. Forest Service modified 4(e) condition 9 requires Energy Northwest to develop, in consultation and coordination with the Forest Service, a Packwood Lake Intake Fish Entrainment Monitoring Plan (within 3 months of issuance of a new license). The goal of the monitoring plan is to determine whether the intake traveling screen approach velocities in excess of the state of Washington criteria (see Our Analysis below) cause detrimental impacts on the O. mykiss spp. population in Packwood Lake. The objectives of the monitoring plan are to accurately describe and enumerate the O. mykiss spp. population size distribution in Packwood Lake; identify and record all fish impingement and mortality on project traveling screens; determine impingement decay rates; and to examine fish behavior in the intake wells and the forebay immediately in front of the intake. The monitoring plan would be implemented annually for the first 5 years of a new license. Subsequent monitoring frequency and actions would depend on the results of the initial monitoring period, and be collectively agreed upon between Energy Northwest, the Forest Service, and other interested parties.

A key element of the Packwood Lake Intake Fish Entrainment Monitoring Plan includes the development of impingement criteria including, but not limited to: estimates of the total population of O. mykiss spp. in the lake, the total number fry in each monitored cohort, and the identification of a threshold level of allowable mortality associated with the intake screen. For the initial 5-year sampling period, no more than 1.5 percent of the total Packwood Lake O. mykiss spp. population in the lake shall be injured or killed as a result of impingement on the intake screen.

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Each year’s monitoring results would be reported to the Forest Service and other interested parties for review and comment and discussed at the Annual Resource Coordination meeting. The 1.5 percent threshold for project related impingement mortality would be re-evaluated (and potentially reduced) if the Packwood Lake O. mykiss spp. population was affected by an uncommon event not related to project operations (e.g., a natural high inflow event that results in turbid water quality conditions in Packwood Lake between monitoring periods).

If the impingement criteria identified in the monitoring plan are satisfied after the initial 5-year monitoring period, then Energy Northwest would retain the existing traveling screen facility and operational mode as the primary fish exclusion device for a period to be determined collectively between Energy Northwest, the Forest Service, and other interested parties based on the initial 5-year monitoring program results. At this time, a revised monitoring plan would be developed cooperatively among the parties identifying appropriate methods, monitoring schedules, and impingement thresholds. At the commencement of the next monitoring period, this revised monitoring plan would be implemented for 1 or more years (to be determined by the parties) to examine whether the traveling screens are continuing to meet identified impingement criteria.

If the impingement criteria are met, then Energy Northwest would prepare an intake structure operation manual for Forest Service approval within 1 year after filing the final monitoring report. If the monitoring data indicate the modifications made at the intake structure do not meet the impingement criteria identified in the monitoring plan, then Energy Northwest would modify the existing fish screens and/or evaluate implementing administrative controls (restricting operational flows through the screens) to meet state criteria prior to subsequent monitoring years.

If a baffling system or other minor modification is selected in years 4 or 5 of the initial monitoring program (or any year thereafter), then the monitoring plan would be extended for at least 2 more years to test the modifications and would be completed by the end of the second year from modification completion. If the impingement criteria are satisfied by a baffling system or other modification, then Energy Northwest would prepare an intake structure operation manual. If the impingement criteria are not satisfied after one modification to the screens, then Energy Northwest would provide for a major redesign of the traveling fish screens to meet Washington State Fish Screen Criteria.

Energy Northwest endorses Forest Service modified 4(e) condition 9 and requests approval of this measure. Washington Fish and Wildlife does not support condition 9 to test and modify the existing fish screens as needed to comply with the state’s approach velocity criteria, and continues to assert that the screens must comply with state standards as specified in its 10(j) recommendation. Washington Fish and Wildlife also objects to the notion that the costs of replacing intake screens at the facility (estimated at $1.6M) is

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excessive and notes that the problem might be solved at a fraction of the cost through modifications to the intake.

Our Analysis

Energy Northwest evaluated the potential for fish entrainment at the project intake structure in 2006, 2007, and 2008. The target species for the entrainment studies was O. mykiss spp. in the adult life stage (the only species present in Packwood Lake). The objectives of these studies were to:

determine species relative abundance, age/size, timing and composition at the intake structure;

evaluate the effectiveness of the project’s screens in protecting fish;

assess the potential effects of entrainment or impingement from the lake elevation and project flow fluctuations; and

develop a rule curve for lake level elevation and diversion rate, since approach velocities may exceed the state mean velocity criteria at some operating scenarios.

A total of 63 fish were collected on the traveling screens from May 23 through September 28, 2006. All fish found on the screens were O. mykiss spp. Thirty-six fish were collected on screen 1 and 27 fish were collected on screen 2. The size of fish entrained on the intake screens averaged 7.6 inches, ranging from a minimum of 2.5 to 12.7 inches. Nearly 60 percent of the fish were found on the screens during the two inspections in May. All of these fish exceeded 5.7 inches in length, averaging 8.1 inches.

A total of 357 O. mykiss spp. were entrained on the traveling screens from January through August 2007 (figure 3-11). One hundred and ninety eight fish were observed on screen 2 and 159 were observed on screen 1. The highest number of fish impinged at one time was 69 on March 15, 2007. No fish were impinged after July 6, although the screens were checked weekly into September 2007. The majority (72 percent) of the fish entrained on the screens in 2007 had fork lengths in the range of 7.9 to 9.8 inches and no fish were smaller than 2 inches. Although Energy Northwest documented that more fish were entrained at the higher project flows, other factors also appeared to affect entrainment on the traveling screens, including improper debris screen alignment and poor water quality (turbidity and low DO).

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Figure 3-11. Fish entrained on traveling screens at the Packwood Lake Hydroelectric Project during January through August 2007. (Source: Energy Northwest, 2008a)

Energy Northwest continued to monitor entrainment at the project intake in 2008 (EES, 2008a). In 2008, 60 trout were entrained on the screens, similar to the 63 trout found in 2006. Of these 60 trout, about 84 percent were entrained on the screens between June 12 and July 23, 2008, consistent with the late and post-spawning period for O. mykiss spp. in Packwood Lake. This low number (relative to the total lake population) is in contrast to the 357 fish that were entrained in 2007 when natural conditions combined to cause extremely high lake inflows and substantial erosion in the lake tributaries that created sustained high levels of turbidity. These natural factors coupled with possible debris screen misalignment likely resulted in higher recorded mortalities in 2007.

In addition to monitoring fish entrainment and impingement at the project intake, Energy Northwest used a Swoffer Velocity Current Meter to measure approach velocities at the project fish screens over the course of several months during 2007. Velocity measurements were taken every foot vertically and every 1.25 to 1.50 feet horizontally across both traveling screens. The measurements took place at lake elevations ranging from 2,856.80 to 2,858.15 feet msl, with project flows ranging from 44 to 190 cfs. Mean screen velocities across the range of project flows and lake elevations were then compared to the Washington Fish and Wildlife Screening Requirements for Packwood

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Lake (≤ 0.80 and 0.88 feet/second). The results of this study indicated that more than 92 percent of the time the mean screen velocities were less than 0.50 foot/second; however, the maximum approach velocities ranged from 0.33 to 2.85 feet/second (table 3-18).

Table 3-18. Summary of approach velocity measurement at the Packwood Lake Hydroelectric Project fish screens. (Source: Energy Northwest, 2008a)

Screen 1 Velocities (ft/sec)

Screen 2 Velocities (ft/sec)

DateLake

ElevationPlant Flow

(cfs) Min Mean Max Min Mean Max

6/20/07 2857.64 150 0.02 0.33 1.50 0.01 0.48 1.78

6/28/07 2857.72 115 0.02 0.37 1.78 0.01 0.32 1.45

7/5/07 2857.55 190 0.03 0.57 2.85 0.01 0.53 2.16

7/13/07 2858.15 116 0.01 0.29 1.46 0.01 0.29 0.99

7/18/07 2857.84 59 0.00 0.15 0.72 0.00 0.14 0.60

7/24/07 2857.71 55 0.00 0.15 0.64 0.00 0.11 0.42

8/2/07 2857.26 66 0.00 0.14 0.55 0.00 0.10 0.33

8/9/07 2857.08 44 0.00 0.14 0.58 0.00 0.11 0.40

8/16/07 2856.77 59 0.00 0.19 0.67 0.00 0.19 0.54

8/29/07 2856.80 73 0.01 0.24 0.89 0.00 0.20 0.54

In 2008, Energy Northwest agreed to conduct additional velocity flow tests on the permanently installed rotating screens with the outer debris screens removed (EES, 2008a). Project flows, combined with instream flows, resulted in test flows ranging from 219 to 86 cfs. Results of this evaluation showed that mean screen velocities at all test conditions were less than the Washington Fish and Wildlife recommended criteria of 0.80 foot/second. In general, mean velocities were slightly higher at screen 2 than at screen 1, averaging 0.46 foot/second and 0.35 foot/second, respectively.

Screen compliance criteria (e.g., 95 percent of the screen velocities to be ≤0.80 foot/second, with 99 percent of the screen velocities to be ≤0.88 foot/second) were also analyzed. At flows of 162 cfs or higher at a lake elevation of 2,857 feet msl, measured velocities did not meet these criteria at either screen. At a flow of 119 cfs and a lake elevation of 2,857 feet msl, screen 1 met the criteria while screen 2 was slightly out of compliance. Screen 1 met both velocity criteria on seven of the eleven tests, while screen

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2 met both velocity criteria on five of the tests. Overall, the screens as a whole met both velocity criteria on five of the 11 tests. Additionally, they only marginally missed compliance on another.

Although the approach velocities at these screens exceeded the Washington Fish and Wildlife Screening criteria during both the 2007 and 2008 tests, EES (2008a) indicated that fish observed in 2008 easily moved throughout the well at the highest velocities and no fish were impinged on the traveling screens.

While the results of Energy Northwest’s entrainment studies indicate that impingement is occurring at the project intake (in some years) and that the existing project fish screens do not fully comply with existing state approach velocity criteria, the population of O. mykiss spp. in Packwood Lake has remained relatively healthy for decades, exhibiting multiple age classes and relatively high densities (exceeding 31,000 fish in August 2007). In addition, the total proportion of the population exposed to entrainment risk in any given year is relatively small (representing less than 1 percent of the total lake population). The timing of their appearance at the intake screen in 2006, 2007, and 2008 closely mirrored the peak spawning period spawning in the Packwood Lake tributaries, and it is likely that many of these fish were entrained in weakened condition following the peak spawning period. High levels of entrainment documented during the winter and spring of 2007 also may be attributed to improper replacement of the debris screens over the trashracks after cleaning.

Under existing conditions, O. mykiss spp. are relatively abundant in Packwood Lake; however, the Forest Service and Washington Fish and Wildlife are concerned with maintaining the long-term viability of this genetically distinct population. They believe entrainment of wild trout from this lake represents a loss to an important and popular recreational fishery and that properly functioning fish screens would likely eliminate or substantially reduce entrainment related mortality at this site and its associated effects on the Packwood Lake fishery.

Although violations of the state’s approach velocity criteria were documented at several locations along the project’s existing traveling fish screens, we conclude that the existing screens are likely to provide adequate protection for fish. In addition, similar to our recommendation in the draft EA, modified Forest Service 4(e) condition 9 would incorporate extensive biological monitoring to determine whether the Packwood Lake population of O. mykiss spp. is being affected by the project intake and provide additional opportunities to further evaluate our conclusion. Therefore, based on our analysis; we find that it is not likely that a major fish screen redesign or modification is needed to protect the fishery resources of Packwood Lake. However, if biological monitoring demonstrates that O. mykiss spp. densities are affected by the project (i.e., at numbers greater than 1.5 percent of the total population), Energy Northwest would have to take action to remedy these effects. Implementing this approach with its associated biological

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monitoring and associated triggers, prior to making any decisions regarding physical modifications to the intake screens, is appropriate and would adequately protect O. mykiss spp. in Packwood Lake.

Washington Fish and Wildlife’s 10(j) recommendation is inconsistent with the plan developed by Energy Northwest, the Forest Service, NMFS, and Washington Department of Ecology and relies primarily on fish screen modifications needed to meet the state approach velocity criteria (with no biological monitoring or associated triggers). While this approach also would likely provide adequate protection for O. mykiss spp. residing in Packwood Lake, our analysis leads us to conclude that the total proportion of the O. mykiss spp. exposed to entrainment risk in any given year is relatively small, representing less than 1 percent of the total lake population. In addition, we conclude that this loss does not appear to be having an adverse effect on the lake’s rainbow trout population under current project operations.

Fish Passage on Snyder CreekSnyder Creek currently passes through a 75-foot-long culvert under the project

tailrace and joins Hall Creek immediately downstream of the tailrace crossing. The Snyder Creek culvert, as currently configured, does not meet Washington Fish and Wildlife criteria for fish passage and can become blocked with large amounts of sediment, further impeding upstream and downstream fish migration. Consequently, the culvert can prevent spawning coho salmon, westslope cutthroat, and O. mykiss spp. from accessing documented spawning and rearing habitat that extends about 1,900 feet in Snyder Creek upstream from the tailrace crossing. In addition, if the Snyder Creek culvert becomes blocked with sediment prior to downstream migration, juvenile coho salmon and cutthroat trout can become stranded in upper Snyder Creek.

Rather than replace or modify the existing Snyder Creek culvert to meet current agency fish passage criteria, Energy Northwest proposes to reroute Snyder Creek into the existing backwater channel of Hall Creek downstream of the project flume. Energy Northwest would retain stream restoration specialists and prepare a Snyder Creek restoration, enhancement, and monitoring plan for the rerouting of Snyder Creek. The plan would be developed in coordination and consultation with the Forest Service, FWS, NMFS, Washington Fish and Wildlife, and tribes. Because some fish currently pass through the culvert (although the percentage is not known), Energy Northwest proposes to continue to maintain the culvert in operating condition until 2015. By this time, Energy Northwest proposes to have Snyder Creek rerouted into Hall Creek downstream of the project tailrace to provide full passage to anadromous fish.

NMFS’ section 18 article 2 requires Energy Northwest develop and implement a plan (within 2 years of license issuance) to provide adequate passage, that meets NMFS fish passage standards at the Snyder Creek tailrace crossing. The Forest Service specifies and Washington Fish and Wildlife recommends that Energy Northwest retain a stream

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restoration specialist and prepare a Snyder Creek restoration, enhancement, and monitoring plan (within 2 years of license issuance) for the rerouting of Snyder Creek. The plan would be developed in coordination and consultation with the Forest Service, FWS, NMFS, Washington Fish and Wildlife, and tribes, and be subject to approval by the Forest Service. In addition, the Forest Service specifies and Washington Fish and Wildlife recommends that Energy Northwest:

apply for and secure permits by the end of the fourth year after license issuance and reroute Snyder Creek to join Hall Creek immediately downstream of the project tailrace flume within 5 years of license issuance;

maintain the existing culvert under the tailrace in operational condition to allow existing fish passage until Snyder Creek is redirected; and

monitor the rerouting of Snyder Creek for 2 years following the restoration to determine whether Snyder Creek allows for volitional passage of anadromous and resident trout species.43

All work on Snyder Creek would be completed in year 5 of a new license.

Our Analysis

Physical barriers to fish migration can include natural structures such as waterfalls, cascades, and debris dams, and artificial barriers such as dams, diversions, and improperly placed or designed culverts. Maintaining access to a greater range of habitat types, if blocked by project-related artificial barriers or obstructions, would benefit existing fish populations by enabling recolonization of unoccupied or underused habitats. Connectivity with other isolated fish populations also would maintain genetic diversity and dispersal among native fish species. As described in section 3.3.1.1, fish population surveys conducted during project relicensing, and prior surveys conducted by the Forest Service have documented juvenile coho salmon, steelhead/rainbow, and westslope cutthroat trout presence in Snyder Creek upstream of the Snyder Creek culvert. While the existing tailrace culvert appears to allow some level of fish passage into and out of upper Snyder Creek, it does not meet current agency passage criteria and does not allow for full passage of all species and life stages at all times. According to Energy Northwest, the culvert can also become clogged with sediment, blocking fish access into and out of 1,900 feet of documented salmonid spawning and rearing habitat in Snyder Creek upstream of the tailrace crossing.

43 If volitional passage of anadromous and resident trout species is documented, a collective decision would be made whether further monitoring is warranted. Conversely, if volitional passage does not occur, then a collective decision would be made as to what measures would be required to restore volitional passage the Snyder Creek reroute.

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While evaluating potential measures needed to successfully restore full fish passage in Snyder Creek, Energy Northwest surveyed a nearby backwater channel that runs parallel to the project tailrace, entering Hall Creek just downstream of the project flume. The drainage path is approximately 800 feet long with a bankfull width ranging from about 10 to 20 feet. There are no barriers to upstream anadromous migration within this reach. If properly designed, rerouting Snyder Creek into the existing backwater channel (downstream of the project flume), as proposed by Energy Northwest, would likely facilitate unimpeded migration into and out of upper Snyder Creek and create an additional 800 feet of useable salmonid spawning and rearing habitat. Since the culvert currently does pass some fish, maintaining it until the channel construction is complete would likely minimized potential adverse effects on migrating salmonids residing in Snyder Creek. Monitoring the reroute of Snyder Creek for 2 years following the channel restoration to determine whether Snyder Creek allows for volitional passage of anadromous and resident trout species would ensure the proposed measure is achieving it desired objectives.

Maintenance of the Tailrace Barrier

Resident and anadromous salmonids are known to spawn and rear in both lower Lake Creek and in the project tailrace slough where it enters the Cowlitz River. A tailrace barrier previously existed at the terminus of the tailrace before it was washed out by a flood in the 1970s. The state fish and game agencies agreed that the barrier did not need to be replaced at that time, but reserved the right to require replacement if anadromous fish were reintroduced to the upper Cowlitz River Basin.

As described in section 3.3.1.1, adult anadromous fish are currently being trapped and hauled into the upper Cowlitz River above Barrier, Mossyrock, and Cowlitz Falls dams. The target species under this agreement are Chinook and coho salmon and steelhead. As a result of this reintroduction program, anadromous salmonids now have access to the upper Cowlitz River, as well as Lake Creek and the project tailrace. During project relicensing studies, Energy Northwest recovered large numbers of juvenile salmonids (primarily coho salmon with smaller numbers of Chinook salmon and steelhead) and smaller numbers of adult salmonids from the project stilling basin and lined tailrace. These fish were at risk of injury or mortality from contact with project equipment and facilities and were also potentially subject to stranding and degraded water quality when the project was shutdown during annual maintenance.

After consultation with NMFS, the other resource agencies, the tribes, and the Commission, Energy Northwest obtained authorization and installed a permanent fish barrier drum screen near the end of the lined tailrace in October 2007. The design is based on two 14-foot long by 4-foot diameter drum screens fabricated by the Washington Fish and Wildlife Screen Shop in Yakima, Washington.

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To ensure that this screen remains functional for the duration of the proposed license, NMFS’ section 18 article 1 requires Energy Northwest to continue the measures for maintenance, testing, and operation of the screen (post-construction), as described in the incidental take statement (NMFS, 2007). Specifically, the incidental take statement requires Energy Northwest to:

Minimize take from fish handling during monitoring/evaluation studies and fish salvage operations by applying permit conditions that avoid or minimize adverse effects.

Conduct monitoring to determine if the screen is effectively excluding fish from the project tailrace and stilling basin without causing delay, injury, or mortality of listed species.

Develop procedures and schedules for maintenance of screens that ensures their continued efficacy and minimizes risk of water quality impairment and disturbance of listed fish within the tailrace.

The Biological Opinion issued by NMFS also requires Energy Northwest to file an annual monitoring report with NMFS describing the results of the biological monitoring, maintenance activities, inspections, fish mortalities, and any proposed major repair or modifications to the facility.

Currently, Energy Northwest and the resource agencies are using an adaptive approach to determine the efficacy of the new tailrace barrier. The stilling basin is seined following the project’s annual maintenance shutdown period to determine if fish are bypassing the barrier. If two consecutive years of seining during this period document few (<50) fish are captured (total of all salmonid species and life stages), then the program would go to every 3rd year and termination of the program would occur in year 8. If adult salmonids are captured during this annual seining program or more than 50 fish (total of all salmonid species and life stages) are captured, then seining would be conducted again the following year. The tailrace would also be checked at these times and any fish would be rescued.

The one exception to this schedule is when Cowlitz River flooding results in water backing up in the lower terminus of the project tailrace to an elevation of 1,044 feet msl or greater. If water surface elevations meet or exceed the height of the fish exclusion racks on the barrier (1,044 feet msl) or water is observed to be flowing into the tailrace canal upstream of the barrier, a seining operation would be conducted in the project stilling basin during the next annual shutdown. In this one instance, fish captured in the seining effort would be considered displaced by the flood event. The tailrace would also be checked for fish at this time and any fish would be rescued.

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Our Analysis

Commission staff observed Energy Northwest’s new fish screen in operation during an informal site visit in July 2008. The screen was generally free of debris and appeared to be functioning as designed. Staff also observed several juvenile salmonids immediately downstream of the fish screen attempting to migrate into the tailrace above the screen site.

Monitoring and maintaining the effectiveness of this screen and reporting the results of monitoring in an annual report, as required by NMFS in its Biological Opinion (NMFS, 2007), would likely continue to prevent the upstream migration of resident and anadromous fish into the project tailrace and stilling basin and thus, minimize any potential adverse affects on these species associated with project operations and maintenance. If Energy Northwest’s adaptive monitoring program indicates that the goal of the barrier is not being met, then Energy Northwest would make the necessary adjustments or modifications to the facility as directed by NMFS and Washington Fish and Wildlife in an effort to achieve the goal. Following the successful termination of the screen efficiency tests, fish rescue above the fish barrier would not be necessary.

Threatened, Endangered, and Sensitive Species PlanThe Forest Service specifies and Washington Fish and Wildlife recommends that

Energy Northwest prepare, within 1 year of license issuance, in coordination and consultation with the Forest Service and Washington Fish and Wildlife a Threatened, Endangered (Federal listed) and Forest Service Regional Forester Special Status Species Management Plan. The goal of this plan would be to provide protection, mitigation, enhancement, and monitoring of threatened, endangered, and sensitive species and their habitats that may be affected by project operation or project-related activities over the life of any new license. At a minimum, the plan would require Energy Northwest to prepare a list of threatened, endangered, and sensitive species that occur within the project boundary or on lands affected by project operation or project-related activities; annually update the list according to changes in species status or potential project effects; conduct baseline surveys at sites where project operations or project-related activities may affect them, if none have previously been conducted; and prepare Biological Evaluations, where needed, to evaluate potential project effects. Under this plan, Energy Northwest would monitor confirmed sensitive species sites every 2 years for 6 years following license issuance and at 3-year intervals thereafter, unless a determination can be made at year 6 that no additional monitoring is necessary. The plan would provide for implementation of protective measures, if monitoring results show project-related effects, and would also include monitoring to measure whether the measures are effective. The plan would provide for adaptive management, based on monitoring results. Finally, the plan calls for Energy to annually consult with the Forest Service and provide an annual report on plan activities, with the opportunity to update the plan, as needed.

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As discussed in the previous sections, Chinook and coho salmon, rainbow trout, and cutthroat trout have all been documented in lower Lake Creek. Two smaller creeks within the project boundary (Hall and Snyder creeks) also provide habitat. Hall Creek has 2.0 miles of accessible steelhead spawning habitat, and Snyder Creek provides coho salmon and cutthroat trout habitat in its lower reaches. Project operations within and near the tailrace slough also have the potential to affect these species in the Cowlitz River.

Our Analysis

We concur with the Forest Service and Washington Fish and Wildlife that a mechanism is needed to provide for protection of currently listed species and those that may be listed in the future. The Forest Service and Washington Fish and Wildlife Threatened, Endangered (Federal listed) and Forest Service Regional Forester Special Status Species Management Plan would provide an efficient mechanism for coordination between the Commission, Energy Northwest, the Forest Service, Washington Fish and Wildlife, and other agencies prior to any changes in project operation, ground-disturbing activities, or specific habitat enhancements that may be implemented within the new license period. The plan would also ensure that management of National Forest System lands is consistent with the Forest Plan (Forest Service and BLM, 1994).

Recreation Facility Construction and Maintenance MeasuresEnergy Northwest proposes as part of the Packwood Lake Recreation Plan to

install and maintain several new facilities, including a composting toilet at Packwood Lake and an informational kiosk at the Packwood Lake Trailhead (see also section 3.3.4, Recreation and Land Use Resources). In addition, as part of the proposed Historic Properties Management Plan Energy Northwest would install an interpretive sign at the ATV parking area near the end of FS Trail 74 (see section 3.3.6, Cultural Resources).

Our Analysis

Proposed construction associated with the recreational facilities and interpretive signage would have the potential for short-term land disturbance within the vicinity of the project. The areas that would be disturbed would only include a small area associated with the signs and toilet facility. There would be little ground-disturbing activity and with the implementation of best management practices soil erosion or any adverse effects on water quality as a result of construction of these facilities would likely be very minor and/or short-term. Additionally, the proposed toilet facility would have the beneficial effect of providing for the collection of human waste and associated reduction in the infiltration of dispersed areas of human waste that currently occur within the vicinity of Packwood Lake.

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3.3.1.3 Cumulative Effects

Actions within the geographic scope (defined in section 3.2.1) that may affect or have affected fisheries and aquatic resources in combination with the Packwood Lake Hydroelectric Project include: mainstem hydroelectric project development, fishery management (harvest and anadromous fish reintroduction), general recreation (camping, fishing, etc.), timber harvest, road building, agriculture, and rural development.

The project diverts flow from lower Lake Creek into the project powerhouse and discharges it into a side channel of the mainstem Cowlitz River. This diversion of water alters the natural hydrology, geomorphology, and water quality in lower Lake Creek, which in turn affects aquatic resources, including resident and anadromous fish species and the benthic macroinvertebrate community. Non-project related hydroelectric project development, agriculture, timber harvest, road construction, and rural development have also degraded habitat in the Cowlitz River Basin reducing the distribution and abundance of resident and anadromous fish populations. In addition to these impacts, commercial and recreational harvest have decreased the abundance of resident and anadromous fish in the Cowlitz River and its tributaries and changed fish community structure. Together, these impacts have contributed to the decline, and in some cases lack of recovery, of native fish species.

Implementation of our recommended minimum instream flows (above current levels), habitat forming flows, and other measures to restore habitat in lower Lake Creek would result in more natural flow conditions in lower Lake Creek and likely increase the amount and quality of habitat available to anadromous and resident fish. These improved habitat conditions, in conjunction with ongoing basin-wide anadromous fish reintroduction efforts, would likely increase wild salmon and trout production in the project vicinity that would in turn contribute to the recovery of ESA-listed fish species. It is also anticipated that these measures would slightly improve the recreational fisheries in both lower Lake Creek and the mainstem Cowlitz River.

Reducing entrainment/impingement at the project intake through the adaptive plan described in the Forest Service’s revised 4(e) condition 9 would increase the amount of protection for O. mykiss spp. residing in Packwood Lake, minimizing potential adverse effects on this unique fish population. Rerouting Snyder Creek would likely enhance fish passage and potentially increase the production of resident and anadromous fish in this small stream, and moving the annual project’s annual maintenance outage to begin on August 15 of each year would provide additional protection for spawning salmonids in the side channel of the Cowlitz River below the tailrace.

Overall, the protection and enhancement measures that would be included in a new license, combined with the recent anadromous fish reintroduction program (and passage improvement in the mainstem Cowlitz River) and improved fishery management would

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have an incremental beneficial cumulative effect on salmon and steelhead populations in the Cowlitz River Basin. However, ongoing urban development (in the lower Cowlitz River), rural development, agriculture, and flood control would continue to have an adverse cumulative effect on aquatic resources in the basin. Existing mainstem hydroelectric projects would also continue to alter the Cowlitz River’s natural hydrology and sediment transport regime, entrain fish, degrade water quality, and inundate historical spawning and rearing habitat.

3.3.1.4 Unavoidable Adverse Effects

Unavoidable adverse effects associated with the continued operation of the Packwood Lake Hydroelectric Project would include continued losses of relatively few O. mykiss spp. through entrainment/impingement at the project intake, the continued blockage of natural O. mykiss spp. migrations in lower Lake Creek at the drop structure, and the continued modification of natural flow and sediment transport regime in lower Lake Creek. The expected loss of fish through entrainment is not likely to have a population level effect on this resource, and we anticipate that the proposed enhancement measures for fish and aquatic resources included in the staff alternative would be more beneficial than under the current license.

3.3.2 Terrestrial Resources


The project is situated at elevations ranging from about 1,000 feet msl at the tailrace to 2,857 feet msl at Packwood Lake. The project area lies almost entirely within the western hemlock vegetation zone (Franklin and Dyrness, 1988). This zone is characterized by conifer forests dominated by Douglas-fir, western hemlock, and western red cedar.

Energy Northwest conducted several terrestrial resource studies to evaluate existing conditions and potential project effects on vegetation and wildlife. These included: vegetation cover type mapping; surveys for rare plants, noxious weeds, and amphibians; bald eagle and osprey nest surveys; and a study of the relationship between project operations and wetlands associated with Packwood Lake.

VegetationThe vegetation cover type mapping study area encompassed a total of 2,181 acres

of land and water, including 546 acres within the FERC project boundary and an additional 1,641 acres adjacent to the project boundary. Uplands account for about 62 percent of the study area. Wetlands and riparian habitat make up 9 percent; lakes and riverine habitat comprise 21 percent; and about 7 percent of the area is developed or is not vegetated.

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Western hemlock forest characterizes most (more than 1,000 acres) of the area mapped as uplands. In these forests, the dominant trees are western hemlock, Douglas fir, and western red cedar. Pacific silver fir forest, which comprises a total of 308 acres, occurs along the southwest shoreline of Packwood Lake and along Pipeline Road. Stand ages in areas mapped as conifer forest range from less than 10 years old to almost 350 years old, with most of the older forest occurring along Lake Creek and around Packwood Lake.

Energy Northwest mapped three wetland types. Palustrine emergent and palustrine forested wetlands account for 92 and 61 acres, respectively, while palustrine scrub-shrub wetlands cover only 1 acre. The two largest wetland complexes in the study area are associated with Hall Creek and the lower reaches of Upper Lake Creek and Muller Creek where they enter Packwood Lake. Slough sedge, small-fruited bulrush, manna grass, and reed canarygrass dominate the Hall Creek wetlands. A mix of red alder, black cottonwood, and western red cedar dominates the wetlands at the upper end of Packwood Lake, with a diverse understory of red elderberry, lady fern, skunk cabbage, cow-parsnip, Cooley’s hedge-nettle, monkey-flower, and other wetland-associated shrubs, ferns, forbs, and grasses.

Special Status Habitats

Washington Fish and Wildlife designated a number of cover types in Washington as priority habitats, based on their ability to support high densities or diversity of fish or wildlife species or dependent species; or to provide important breeding habitat, seasonal range, or movement corridors (Washington Fish and Wildlife, 2008a). Vegetation cover types may also be designated as priority habitats where they are limited in availability, or highly vulnerable to alteration. In the project area, priority habitats include freshwater wetlands, lakes, streams, and old-growth and mature forest stands.

Special Status Plants

Energy Northwest conducted rare plant surveys in 2005, 2006, and 2007 (Beck, 2008a). The rare plant survey area included lands within the project boundary and extending 100 feet from the centerline of linear project-associated features, such as roads and trails, and 200 feet from the shoreline of Packwood Lake.

Energy Northwest reviewed the FWS website and Washington Natural Heritage Program records to determine whether federal or state-listed species could occur in the study area (Beck, 2007a). Energy Northwest also reviewed lists of plants designated as sensitive in Forest Service Region 6 and either known or suspected to occur within the Gifford Pinchot National Forest. Based on this information, the list of target species for the field surveys included 20 plants with federal or state status, and 81 Forest Service sensitive species. We discuss the three federally listed plants that could occur in the project vicinity in section 3.3.3, Threatened and Endangered Species).

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The rare plant surveys documented six special status species in the study area. Two of these – the state threatened Oregon goldenaster (Heterotheca oregona) and the Forest Service sensitive lichen species Peltigera pacifica – occur within the project boundary. Oregon goldenaster grows on a gravel bar near the tailrace confluence with the Cowlitz River. Peltigera pacifica occurs as eight small subpopulations growing on mossy substrate in talus along a 1.25-mile stretch of Pipeline Road (FS Road 1260-066) in the vicinity of the surge tank.

Rare plants located outside the project boundary include an additional population of Oregon goldenaster growing near the confluence of Lake Creek with the Cowlitz River, and four Forest Service sensitive lichens – Nephroma bellum, Nephroma occultum, Platismatia lacunose, and Collema nigrescens – near FS Trail 74 along the northeast shoreline of Packwood Lake (Beck, 2008a).

Noxious Weeds and Invasive Non-native Plants

Along with rare plant surveys, Energy Northwest conducted surveys to locate, document, and map noxious weeds within the project boundary; 100 feet of linear project-associated features; and 200 feet of the Packwood Lake shoreline (Beck, 2007b). Weed surveys focused on species designated in Lewis County as Class A, Class B designate, Class B select, and Class C select weeds (Lewis County Noxious Weed Control Board, 2008),44 and species the Forest Service is tracking in the Gifford Pinchot National Forest. Surveys detected 18 noxious weeds in the study area (table 3-19). Lewis County considers eight of these as high priorities for monitoring and management because of their classification as B designates, B select, or C select species. These species and three others (shown with asterisks) are considered a high priority for management on National Forest System lands to ensure they do not spread into the Goat Rocks Wilderness.

44 “Class A” weeds are non-native species with a limited distribution in Washington. Preventing new infestations and eradicating existing infestations is the highest priority, and state law requires landowners to control these species. “Class B designates” are designated for control in regions where they are not yet widespread, but where they are already abundant, the primary goal is containment. “Class B select” species are those Lewis County has chosen for mandatory control in some parts of Lewis County. “Class C” weeds are non-native species that are widespread in the state. Class C weeds may be designated as “Class C select”, with mandatory control, depending on local threats and the feasibility of control.

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Table 3-19. Noxious weeds observed within study area. (Source: Energy Northwest, Exhibit E, Beck, 2007b, EES, 2008; Lewis County Noxious Weed Control Board, 2008; modified by staff)

Common Name (Scientific Name)

Weed Class General Locations of Occurrence

Bull thistle(Cirsium vulgare)

C Packwood Lake shoreline, Latch Road, Lake Creek/Cowlitz River confluence, Pipeline Road

Burdock(Arctium minus)

Gifford Pinchot National Forest species of concern

Location not noted

Butterfly bush (Buddleja davidii)

B select Small population on Cowlitz River gravel bar near tailrace on private land

Canada thistle (Cirsium arvense)

C select Medium/large population at southeast end of Packwood Lake, mouth of Osprey Creek, along the northeast shoreline, at the lower end of the lake, Latch Rd., Lake Creek/Cowlitz River confluence powerhouse, Hall Creek, Snyder Creek

Common cat’s ear (Hypochaeris radicata)

B Penstock, Latch Rd., Lake Creek/Cowlitz River confluence, FS Trail 78 parking lot, tailrace, tailrace/Cowlitz River confluence, Pipeline Rd.

Common groundsel (Senecio vulgaris)

C Pipeline Rd., Packwood Lake shoreline

Common St. John’s-wort(Hypericum performatum)*

C Latch Rd., penstock, tailrace, Cowlitz River gravel bar, Pipeline Rd., Packwood Lake shoreline

Common tansy (Tanacetum vulgare)

C Tailrace

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Weed Class General Locations of Occurrence

Diffuse knapweed (Centaurea diffusa)

B designate Tailrace

Herb Robert (Geranium robertianum)*

B Lake Creek from Packwood Lake to confluence with Cowlitz River, penstock near powerhouse, Cowlitz River gravel bar near tailrace slough

Japanese knotweed (Polygonum cuspidatum)

B select Small population on side channel of Cowlitz River

Meadow knapweed (Centaurea jacea x nigra (moncktonii)

B designate Latch Rd., Pipeline Rd.

Oxeye daisy (Leucanthemum vulgare)

B Latch Rd., Pipeline Rd., penstock, Lake Creek, FS Trail 78 parking lot

Reed canarygrass (Phalaris arundinacea)

C select Packwood Lake shoreline

Scotch broom(Cytisus scoparius)

B select Latch Rd., Pipeline Rd., penstock, tailrace, powerhouse, Cowlitz River gravel bar, Lake Creek/Cowlitz River confluence, FS Trail 78 parking lot

Sulfur cinquefoil (Potentilla recta)*

B Tailrace

Tansy ragwort (Senecio jacobaea)

B select Packwood Lake shoreline

Wild carrot(Daucus carota)

B Latch Rd., Lake Creek/Cowlitz River confluence, tailrace

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WildlifeThe project is situated within a mosaic of forest stands of different ages, but much

of it lies within a Late Successional Reserve in the Gifford Pinchot National Forest. Forest Service management of Late Successional Reserves is aimed at protecting or enhancing habitat for species associated with mature and old-growth forest, such as the northern spotted owl, northern goshawk, great gray owl, red tree vole, northern flying squirrel, and American marten.

Biologists conducting natural resource studies in the project area observed Douglas squirrels, pika, mountain cottontail, weasel, coyote, black-tailed deer, and black bear. Mountain goats likely use the rugged terrain near the upper end of Packwood Lake where it borders the Goat Rocks Wilderness. Elk are known to occur throughout the project area, and land at lower elevations along the Cowlitz River provides crucial winter range for the South Rainier elk herd (Washington Fish and Wildlife, 2002). Energy Northwest’s recreational surveys show very few visitors use the project area for hunting.

Packwood Lake does not provide substantial habitat for migratory waterfowl, but the Forest Service reports observations of common loon, common goldeneye, and Barrow’s goldeneye on the lake. American dippers use habitat along Lake Creek, and mallards and great blue heron are present in the Hall Creek wetland complex.

Bald eagles have been reported in the vicinity of Packwood Lake on several occasions, but no nests were documented during aerial surveys conducted by Energy Northwest in 2006. The survey documented four osprey nests along the shoreline of Packwood Lake. Biologists observed eggs or hatchlings at two of the nests; one osprey at the third nest; and no attendance at the fourth nest, which appeared to have been abandoned before 2006. A fifth nest, with a single osprey present, was documented along Lake Creek about 3 miles below Packwood Lake.

As many as 16 amphibian species are known to occur in the western Cascades of Washington. Energy Northwest conducted amphibian surveys in areas where project operations could affect amphibians or their habitat, including upper Lake Creek near Packwood Lake and Lake Creek from Packwood Lake to the confluence with the Cowlitz River (DTA, 2007). Opportunistic surveys were also conducted in the wetland complex associated with Hall and Snyder creeks. Results of the surveys confirmed the presence of nine species: northwestern salamander, western red-backed salamander, coastal giant salamander, rough-skinned newt, Pacific treefrog, Cascades frog, coastal tailed frog, northern red-legged frog, and western toad. The project area provides suitable habitat for Cascades torrent salamander and Vandyke’s salamander and these species may be present, although they were not observed during the surveys. The Larch Mountain salamander is known to occur near Packwood Lake, but because this species is entirely terrestrial, it was not included as a target species for survey.

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Only seven reptiles are known to occur in western Washington. In the project area, biologists observed northern alligator lizards and common garter snakes.

Special Status Wildlife and Management Indicator Species

The Forest Service provided a list of wildlife species designated as sensitive in Region 6 that are known or suspected to occur in the Gifford Pinchot National Forest, and several species with special status in the state may also be present (table 3-20). We discuss federally listed threatened and endangered species in more detail in section 3.3.3, Threatened and Endangered Species.

The Existing Conditions Analysis for Terrestrial Resources (Forest Service, 2004) lists 12 wildlife species that are identified as Management Indicator Species (MIS) on the Gifford Pinchot National Forest (table 3-20). The Forest Service selects MIS as a means of monitoring the effects of management activities on wildlife populations or habitats. MIS may represent a large number of species with similar habitat needs. All Gifford Pinchot MIS are likely to occur or have been documented in the project area.

Table 3-20. Special status and MIS wildlife species that are known to occur or may occur in the project area. (Source: Energy Northwest, 2008a; Washington Fish and Wildlife, 2008a and 2008b; modified by staff)


FWS Status

Forest Service Status

State Status

Habitat and Likelihood of Occurrence

Amphibians and ReptilesCascade torrent salamander (Rhyacotriton cascadae)

--- S C Possible; not documented during surveys. Semi-aquatic in rocky seeps and small streams.

Cope’s giant salamander (Dicamptodon copei)

--- S --- Possible; not documented during surveys. Usually aquatic in all stages, inhabiting small streams.

Larch Mountain salamander (Plethodon larsellii)

SoC S S Documented near trails along Packwood Lake. Terrestrial in all life stages.

Van Dyke’s salamander (Plethodon vandykei)

SoC S S Possible; not documented during surveys. Usually associated with seepages or splash zones.

Western toad (Bufo SoC --- C Documented; breeds in shallow

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FWS Status


State Status


boreas) wetlands and still water.

Cascades frog (Rana cascadae)

SoC Documented; breeds in shallow wetlands and still water.

Northwestern pond turtle (Clemmys marmorata marmorata)

SoC S E Unlikely; associated with ponds and wetlands that warm in the summer; typically at lower elevations (up to 1,000 feet in Washington).

BirdsBald eagle (Haliaeetus leucocephalus)

SoC S, MIS S Documented along Cowlitz River, especially during salmon runs, and observed at Packwood Lake. No nests documented during surveys in 2006.

Golden eagle (Aquila chrysaetos)

--- --- C Possible; associated with mountainous habitat, nesting on rock ledges on cliffs and canyon walls.

Common loon (Gavia immer)

--- S S Documented at Packwood Lake during migration, but no breeding records in Lewis County. Breeding typically occurs on remote lakes, with nesting on mats of aquatic vegetation in shallow water.

Wood duck (Aix sponsa)

--- MIS --- May occur at Packwood Lake year-round.

Common goldeneye (Bucephala clangula)

--- MIS --- Reported during migration, but breeding known only in northeastern Washington.

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FWS Status


State Status


Barrow’s goldeneye (Bucephala islandica)

--- MIS --- Reported during migration, nesting possible. Nests in tree cavities along the shorelines of lakes, streams, and wetlands near open water.

Northern goshawk (Accipiter gentilis)

SoC MIS C Possible; nests and forages in mature and old-growth forest with open understory.

Merlin (Falco columbarius)

--- --- C Possible; associated with open habitats, including lakes and large wetlands, but no nesting records from Lewis County.

Northern spotted owl (Strix occidentalis)

T S, MIS E Documented at several site centers in the project vicinity; strongly associated with old-growth forest and mature forest with old-growth characteristics.

Peregrine falcon (Falco peregrinus)

SoC S, MIS S Possible; wide ranging species that often nests on high cliffs. Might occur in project during migration.

Pileated woodpecker (Dryocopus pileatus)

--- MIS C Documented; strongly associated with mature and old-growth forest with abundant snags.

Vaux’s swift (Chaetura vauxi)

--- --- C Possible; associated with mature and old-growth forests; nests and roosts in colonies in large, hollow, broken-topped snags.

MammalsPacific townsend’s big-eared bat (Corynorhinus townsendii)

SoC S C Possible; no systematic surveys in the vicinity, but found opportunistically in the region.

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FWS Status


State Status


Fisher (Martes pennanti)

C S E Unlikely; old-growth and mature conifer forest, but thought to be extirpated from western Washington.

American marten (Martes americana)

--- MIS --- Possible; strongly associated with mature conifer forest.

Gray wolf (Canis lupus)

E S E Unlikely; range once extended throughout the state and habitat in the project area is suitable, but currently thought to occur primarily as a transient in northern and southeastern Washington. One pack documented in Okanogan County (more than 120 miles north of the project) in 2008.

Grizzly bear (Ursus arctos)

T S E Unlikely; range once extended through most of the state and habitat in the project area is suitable, but population currently low and limited to northern Cascades.

Lynx (Lynx canadensis)

T S T Unlikely; associated with forested habitat at elevations over 4,000 feet. Range once extended into Lewis County but population currently low and limited to north-central and northeastern Washington.

Wolverine (Gulo gulo)

SoC S C Possible; wide ranging species associated with undisturbed high elevation habitats.

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FWS Status


State Status


Roosevelt elk (Cervus elaphus roosevelti)

--- MIS --- Documented; migrates between winter range at low elevation and summer range at high elevation. Old-growth and late-successional forest provide high-quality forage and thermal cover, but often grazes in Cowlitz River valley pastures and grassy openings.

Black-tailed deer (Odocoileus hemionus)

--- MIS --- Documented; migrates between winter range at low elevation and summer range at high elevation. Prefers a mix of forest stand ages with abundant shrub cover, but often grazes in Cowlitz River valley pastures and grassy openings.

Mountain goat (Oreamnos americanus)

--- MIS --- Documented; strongly associated with steep, rocky cliffs, but occasionally seen in forested habitat at lower elevations, and reported near Packwood Lake.

MollusksPuget Oregonian (Cryptomastix devia)

--- S -- Possible; found in moist, mature and older forests, often associated with bigleaf maples.

Malone jumping slug (Hemphillia malonei)

--- S -- Possible; found in moist upland forests, often associated with swordfern and woody debris.

Blue gray tail-dropper (Prophysaon coeruleum)

--- S C Possible; found in moist microhabitats in upland forests.

Notes: T – threatened, E – endangered, SoC – species of concern, S – sensitive, and C – candidate, MIS – Management Indicator Species

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Several terrestrial resource issues were identified during the scoping process. In general, these issues encompass the effects of project facilities and ongoing project operations, and the potential effects of changes in these facilities or operations, on vegetation and wildlife resources. More specifically, the scoping process indicated a need to evaluate the effects of project operations on special status species; the establishment and spread of invasive plants; wetlands and wetland-dependant wildlife (amphibians in particular); and marine-derived nutrients.

VegetationA variety of project operations and project-related activities (e.g., facilities and

road maintenance; recreation; and implementation of some environmental measures) have the potential to adversely affect vegetation. Operations and activities that involve changes in hydrology, erosion, removal of existing vegetation, soil compaction, or soil disturbance may pose a risk to native plant communities and special status plants. They may also create conditions that promote the establishment and spread of noxious weeds and invasive non-native plants.

Special Status Plants

Energy Northwest’s rare plant surveys (Beck, 2008a) documented the presence of two special status species – the state-listed Oregon goldenaster and the Forest Service sensitive lichen Peltigera pacifica – within the project boundary that could be affected by project-related activities.

Energy Northwest consulted with the Forest Service to develop a Rare Plant Management Plan (Beck, 2008b) and filed the plan with the Commission on June 6, 2008. The Rare Plant Management Plan calls for Energy Northwest to conduct rare plant surveys in the project area, including Lake Creek, at 10-year intervals for the duration of the new license. Energy Northwest proposes to monitor known occurrences of Oregon goldenaster and Peltigera pacifica on National Forest System lands every 2 years for 6 years following license issuance, and every 5 years thereafter, to evaluate project effects. Energy Northwest would maintain an in-house rare plant occurrence database; annually update the list of rare plants to be covered in the plan; and prepare an annual rare plant management report. The annual report would document the results of surveys and any management activities, and describe coordination with other management plans (Integrated Weed Management Plan, Lower Lake Creek Stream Restoration Plan, and Road Maintenance Plan). The plan would be reviewed every 5 years, and updated if needed, after consultation with the agencies. In addition to these general requirements, the Rare Plant Management Plan identifies specific management activities intended to protect known occurrences of Oregon goldenaster and Peltigera pacifica.

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Forest Service 4(e) condition 12 specifies and Washington Fish and Wildlife 10(j) condition 12 recommends that Energy Northwest incorporate the Rare Plant Management Plan, as filed with the Commission, into the threatened, endangered, and sensitive species management plan described above in section 3.3.1.2. The threatened, endangered, and sensitive species management plan would provide for development of an initial species list, annual updates to the list, baseline surveys, preparation of biological evaluations, implementation of protective measures where needed, adaptive management, and annual reports and consultation. The monitoring interval for Forest Service sensitive species at confirmed sites would be every 2 years for 6 years and then at 3-year intervals, unless a determination can be made at year 6 that no additional monitoring is needed. For other threatened, endangered, and sensitive species, Energy Northwest would consult with the appropriate agencies to define an appropriate monitoring frequency.

Our Analysis

One Oregon goldenaster occurrence is located within the project boundary on a gravel bar along the Cowlitz River shoreline near the tailrace on Energy Northwest and private ownerships. Energy Northwest does not propose to implement any management activities at this site that would cause direct loss, disturbance, or habitat alteration. As mentioned above, Energy Northwest would consult with the resource management agencies regarding an appropriate monitoring frequency for this species. We conclude that monitoring this Oregon goldenaster population on the same schedule as proposed for rare plants on National Forest System lands would minimize the cost of surveys, while helping to protect this state-listed species.

Two noxious weeds selected for control in Lewis County have the potential to adversely affect the tailrace occurrence of Oregon goldenaster. Scotch broom is abundant at this site, and butterfly bush grows nearby. Common St. John’s-wort and herb Robert, noxious species that are not currently designated for control in Lewis County, are also present at this site.

Scotch broom is extremely common in a variety of habitats in Lewis County. Mature plants can produce about 10,000 seeds annually, and bursting seed pods can eject seeds as far as 20 feet (The Nature Conservancy, 2008). Seedlings can establish under mature plants, as well as colonizing open gravel and cobble bars, where high flows can wash seeds downstream to new sites.

Butterfly bush is a very aggressive non-native plant that forms dense thickets, especially along river banks and gravel bars, where it can crowd out native vegetation. Butterfly bush can produce hundreds of thousands of seeds per year that are lightweight and winged, and easily spread to new locations (The Nature Conservancy, 2008).

Energy Northwest would remove known populations of butterfly bush at the tailrace site by hand-pulling, and would monitor for new weed occurrences during the

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rare plant surveys. If weeds are present, Energy Northwest would consult with the Lewis County Noxious Weed Control Board regarding control methods, and would implement methods consistent with the Integrated Weed Management Plan (described below). However, review of the Integrated Weed Management Plan indicates that Energy Northwest’s preliminary management objectives for project lands below the stilling basin (identified as “Zone E” in the plan) do not include Scotch broom as a target species. Eradication would not be a realistic goal, because this species is abundant and widespread in the Cowlitz River valley. However, we conclude that control of Scotch broom at the Oregon goldenaster site may be necessary to protect this species, if it could be accomplished without damage to Oregon goldenaster.

The Oregon goldenaster population near the mouth of Lake Creek at the Cowlitz River is located outside the project boundary. Energy Northwest does not anticipate that implementation of the Lower Lake Creek Stream Restoration and Monitoring Plan (discussed in detail in section 3.3.1.2) would disturb this occurrence, but does not propose any specific measures that would ensure their protection. This site is not located on National Forest System lands, and preparation of a biological evaluation would not be required to meet Forest Service requirements. We conclude that clearance surveys may be needed prior to implementation of the stream restoration plan if ground-disturbance would occur within Oregon goldenaster habitat.

Beck (2007a) notes that Scotch broom is abundant at the Oregon goldenaster site at the mouth of Lake Creek at the Cowlitz River, and Japanese knotweed occurs nearby. Like butterfly bush, Japanese knotweed is an aggressive non-native that thrives in riparian habitat (The Nature Conservancy, 2008), but Japanese knotweed is even more difficult to eradicate. It spreads primarily by rhizomes, and can easily establish at new sites from stem or root fragments that may be washed downstream during flood events. Both Scotch broom (which is described as a co-dominant at the Oregon goldenaster site at the mouth of Lake Creek, as well as at the tailrace site) and Japanese knotweed have the potential to adversely affect habitat conditions for Oregon goldenaster, if Lake Creek enhancement measures cause soil disturbance. We conclude that implementation of best management practices for both species may be needed, if enhancement measures are proposed that could cause their spread.

The lichen Peltigera pacifica occurrence consists of eight small subpopulations on National Forest System lands within the project boundary. The subpopulations are found along a 1.25-mile stretch of Pipeline Road, Pipeline Trail (FS Trail 74), and above the buried pipeline. Within the last several years, Energy Northwest reports that maintenance activities along the road and trail have been minimal and none are planned at this time (Beck, 2008a). However, the proximity of the Peltigera occurrences to the road and trail would make them vulnerable to habitat loss if future maintenance activities involve ground disturbance or alteration of the forest canopy. If such activities are proposed, Energy Northwest would first prepare a biological evaluation to identify site-specific

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concerns and protective measures. Energy Northwest would consult with the Forest Service to develop a plan to avoid or minimize damage to Peltigera or its habitat, and would include provisions to monitor, mark, protect, or move affected subpopulations, with follow-up monitoring to determine whether transplanting is successful. If destruction of Peltigera subpopulations is unavoidable, Energy Northwest would survey for other populations outside the project area that could be protected and possibly provide opportunities for propagation. Energy Northwest would also train personnel, as needed, to identify Forest Service rare plant species that may occur in the project area. This approach would minimize the risk of adverse effects on Peltigera pacifica, and would provide options for mitigating any adverse effects that may be unavoidable.

The development and implementation of a threatened, endangered, and sensitive species plan would address occurrences of special status plants that may be identified in the future. The plan would provide an effective mechanism for tracking occurrences, evaluating project effects, and designing protective measures, where necessary. Modification of the Forest Service 4(e) condition and Washington Fish and Wildlife 10(j) recommendation to specify clearance surveys for Oregon goldenaster would minimize the risk of any adverse effects on this species due to lower Lake Creek restoration activities. In its comments on the draft EA, the Forest Service concurs with this recommendation.

Noxious Weeds and Invasive Non-Native Plants

Noxious weeds are a growing threat throughout the country, because of their potential to degrade native plant communities, outcompete rare species, and reduce wildlife habitat values. Most are highly adaptable to a range of soil and moisture conditions, and few have natural enemies; for these reasons, long-term control of noxious weeds can be extremely challenging.

Energy Northwest consulted with the Forest Service to develop an Integrated Weed Management Plan, and filed this plan on June 6, 2008, in response to the Commission’s AIR (EES, 2008). The Forest Service specifies that Energy Northwest should implement this plan, as submitted. The plan addresses four major areas: prevention, control and monitoring, revegetation, and reporting. The plan includes specific information detailing the frequency and methods for weed inventory and survey; implementation of best management practices; and annual consultation with the resource management agencies.

The plan covers the following areas:

The project boundary and 100 feet on each side of the project boundary, including project facilities, pipeline, penstock corridor, tailrace, and transmission line;

Pipeline Road (FS Road 1260-066);

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Snyder Road (FS Road 1260) from the surge tank to the junction with FS Road 1260-066;

Powerhouse Road (FS Road 1260-013) in the vicinity of the penstock crossing, raw water and constant head tanks;

Latch Road (FS Road 1262) from the gate to where the road ends;

FS Trail 74, including the Pipeline Bypass Trail (Dyson Pass) segment;

A 200-foot-wide margin around the perimeter of Packwood Lake (elevation 2,860 feet msl);

The mouths of all class 1, 2, and 3 streams (Osprey, Trap, Baker, Crawford, and Upper Lake creeks) that have a defined channel from the point where they enter Packwood Lake, upstream as far as weed species are present;

Where noxious weeds are present in populations outside the implementation area that are considered contiguous to populations inside the implementation area; and

Lower Lake Creek stream restoration areas (i.e., the sections of Lake Creek subject to restoration or enhancement as directed by other plans), as necessary.

The plan calls for Energy Northwest to conduct a weed inventory of all areas covered by the plan every 10 years, in conjunction with the rare plant surveys. Energy Northwest would conduct annual surveys in areas where there is a high probability of weed introduction, such as disturbed sites and high use recreation areas; and where monitoring is needed to evaluate the effectiveness of any control measures that have been implemented. The survey frequency could be reduced, if survey results and consultation with the agencies indicate that less frequent surveys would provide adequate information.

Best management practices identified in the plan address awareness training for personnel; methods for conducting work within existing weed infestations; equipment and vehicle cleaning; minimizing areas of ground disturbance; and use of weed-free sand, gravel, fill, or borrow material. To manage weed infestations, Energy Northwest would develop site-specific treatment plans, based on target species, infestation characteristics, location, site objectives, and likely effectiveness of available treatment methods. Treatment plans would be consistent with underlying land ownership and jurisdiction.

Energy Northwest would prepare an annual report updating the target weed list, documenting the results of surveys and any management activities, and describing coordination with other management plans (Rare Plant Management Plan, Lower Lake

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Creek Stream Restoration Plan, and Road Maintenance Plan). The plan would be reviewed every 5 years, and updated if needed, after consultation with the agencies.

Our Analysis

Energy Northwest would continue to manage project facilities, including road and transmission line rights-of-way, to maintain safe and efficient operating conditions. Energy Northwest also would continue to provide for recreational access to Packwood Lake. Implementation of Energy Northwest’s Integrated Weed Management Plan should be effective in minimizing the risk that routine maintenance or recreational access would introduce or contribute to the spread of noxious weeds. The Integrated Weed Management Plan indicates it would cover areas affected by enhancement measures at Lake Creek, but does not specifically address rerouting of Snyder Creek.

Energy Northwest proposes to work with stream restoration specialists as part of the plan to reroute Snyder Creek. The Integrated Weed Management Plan points out that Scotch broom, reed canarygrass, Himalayan blackberry, and cut-leaf blackberry are abundant and widespread in the Cowlitz River valley and does not propose any management measures to address them in project areas below the stilling pond. While we agree it would not be practical to attempt to control existing infestations at most project-related sites below the stilling basin, control at selected sites may be needed to protect high-value resources (e.g., Oregon goldenaster or wetlands) or where project-related activities, such as rerouting of Snyder Creek, could contribute to their spread. Energy Northwest’s proposal to revegetate disturbed soils using native plants would also be useful in preventing the spread of these lower priority – but still aggressive and undesirable – plants, provided Energy Northwest monitors the success of revegetation efforts and maintains the revegetated sites over the long-term.

Energy Northwest identified three noxious weeds selected for control in Lewis County growing along Lake Creek near its confluence with the Cowlitz River. These include Japanese knotweed, Scotch broom, and Canada thistle. Other noxious weeds not currently designated for control in Lewis County include herb Robert, common catsear, and wild carrot. The Integrated Weed Management Plan does not identify management priorities for weed control in the lower reach of Lake Creek, but implementation of best management practices regarding work at infested sites and revegetation using native plants would be important if the Lake Creek Stream Restoration and Monitoring Plan call for ground disturbance in this area. As mentioned above, including all existing occurrences of noxious weeds, including those not currently designated for control, would help prevent their spread as a result of project-related activities. In its comments on the draft EA, the Forest Service concurs with the benefits of these recommendations.

In addition to ongoing maintenance and recreational activities and implementation of proposed enhancement measures, lake level fluctuations may also adversely affect

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native plant communities. Under current and proposed operating conditions, reservoir fluctuations would continue to prevent the establishment of native plant communities along the Packwood Lake shoreline and promote the establishment and spread of invasive species that are more tolerant of a range of soil and hydrologic conditions.

Cover type mapping and results of the drawdown study show that no riparian plant communities have established along the Packwood Lake shoreline, and that palustrine wetlands are limited to the Upper Lake Creek/Muller Creek complex at the head of the lake, and Osprey Creek along the southwest shoreline. Weed surveys show that reed canarygrass is well-established at the Upper Lake Creek/Muller Creek wetland, and Canada thistle occurs at both these sites. Reed canarygrass and Canada thistle also occur near the Packwood Lake outlet and along the northeast shoreline.

Energy Northwest’s Integrated Weed Management Plan identifies reed canarygrass and Canada thistle as management priorities around Packwood Lake. Energy Northwest would also treat occurrences of tansy ragwort, bull thistle, and common groundsel when there is a practical opportunity to do so, i.e., in conjunction with annual surveys or when treatment is scheduled for reed canarygrass and Canada thistle. These species are not currently designated for control in Lewis County, but are recognized as a threat to native plant communities in the Goat Rocks Wilderness within and adjacent to the project boundary.

Wetlands and Littoral Zone Habitat

Fluctuation of lake levels and seasonal drawdowns may influence the size, characteristics and functions of wetlands around Packwood Lake, to the extent that the lake supplies wetland hydrology. Wetlands supported entirely by a connection with the lake would be at risk of losing hydrologic support as water levels drop.

Under current conditions, Energy Northwest maintains Packwood Lake at about 2,857 feet plus or minus 6 inches between May 1 and September 15, and draws it down to a minimum of 2,849 feet to allow for winter storage. Current operations also call for a two-week drawdown during the last 2 weeks of September, prior to shutting the project down for maintenance. When the project is shut down, lake levels increase in correspondence with inflows. When maintenance is complete (usually by the third week of October), the lake is drawn down for winter storage. The current pattern of operation results in fairly stable surface elevations during the summer and much greater variability during the fall and winter.

Energy Northwest proposes to modify project operations to minimize potential adverse effects on Chinook salmon spawning in the tailrace slough. Under proposed operations, the seasonal pattern of lake level fluctuations would be about the same, except that the maintenance shut down would occur between August 15 and September 14, instead of the last 2 weeks in September extending into mid October and there would

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be no pre-maintenance drawdown. Without the pre-maintenance drawdown, the lake levels would be higher in the later half of the August 15 and September 14 period than under current conditions. Energy Northwest has proposed to eliminate the pre-maintenance drawdown to limit effects on recreation and to ensure that enough water is available in Packwood Lake to supply the higher proposed minimum flows.

Our Analysis

As part of the drawdown study, Energy Northwest evaluated the hydrology of wetlands associated with Packwood Lake (EES, 2007a). Most of the lake’s shoreline above the drawdown zone is characterized by western hemlock or Pacific silver fir forest; only two wetland areas are present. These include a small wetland near Osprey Creek that supports both forested and emergent wetlands; and an extensive complex of forested and emergent wetlands between Upper Lake and Muller creeks at the head of the lake.

Based on a lack of correlation of piezometer readings with lake levels, Energy Northwest found that lake levels do not affect the hydrology of the Osprey Creek wetlands area. Groundwater hydrology was stable throughout the monitoring period, and the inflow from upslope areas is the likely controlling factor in this location.

Results of the drawdown study indicate that the influence of lake levels on hydrology in the Upper Lake Creek/Muller Creek wetland complex vary by season under current operating conditions. Lake levels strongly influence groundwater levels near the shoreline during the dry season (July through October). The effect diminishes with increasing distance from the shoreline, so that very little effect could be measured at a point 200 feet from the shoreline. The piezometer readings also show that precipitation and upslope drainage, surface flows, and run-off are the primary influences on wetland hydrology between November and June.

Under current conditions, the Upper Lake Creek/Muller Creek wetland complex supports a diverse native plant community. Holding water levels higher in the lake during late summer (mid-August through mid-September) would extend hydrologic support provided by the lake to much of this wetland longer into the growing season. This extended period would coincide with the hottest and driest time of the year. The existing plant community appears to be well-adapted to the current hydrologic regime, but a higher water table at this time of year would reduce the risk of drought stress, especially during dry years. The change in project operation may also enhance the functions of this wetland complex in terms of primary productivity, accumulation of organic matter, and nutrient cycling.

Recreation Facility Construction and Maintenance Measures

Energy Northwest proposes as part of the Packwood Lake Recreation Plan to install and maintain several new facilities, including a composting toilet at Packwood

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Lake and an informational kiosk at the Packwood Lake Trailhead (see section 3.3.4, Recreation and Land Use Resources). In addition, as part of the proposed Historic Properties Management Plan Energy Northwest would install an interpretive sign at the ATV parking area near the end of FS Trail 74 (see section 3.3.6, Cultural Resources).

Our Analysis

Materials for the construction of the proposed facilities would likely be brought in by existing roadways and trails and, therefore, no new trails or roadways would be constructed and there would be no adverse effects on terrestrial resources. Likewise, maintenance of the facilities would be conducted periodically, likely using existing trails and roadways. Construction activities and ground-disturbing activities associated with the installation of the proposed facilities would have the potential to affect vegetation in the area of the proposed facilities. However, the areas of disturbance would be small to accommodate only the locations of the signage and the toilet facility, and therefore, would have no long-term adverse effect on terrestrial resources in the vicinity of these proposed facilities.

WildlifeSpecial Status Wildlife and Management Indicator Species

As table 3-20 shows, the project area could support as many as 21 special status wildlife species. Nine of these – Larch Mountain salamander, Cascades frog, northern red-legged frog, western toad, bald eagle, common loon, northern spotted owl,45 and pileated woodpecker – have been documented within or near the project boundary. Through consultation with the resource management agencies, Energy Northwest identified bald eagle, osprey,46 and amphibians as species that could be affected by project operation or project-related activities. Bald eagles and osprey are strongly associated with lakes and rivers that support abundant fish. Project operations could affect the prey base for these raptors, and depending on timing and distance from nests, project maintenance activities or project-related recreational access could cause disturbance to nesting birds. Many amphibian species are dependent on wetlands and streams, and could be affected by lake level fluctuations and changes in instream flows.

Project effects on MIS were not identified as a resource concern during scoping, and the Forest Service’s Existing Information Analysis for Terrestrial Resources (Forest Service, 2004) concluded that the project would be unlikely to affect MIS (with the

45 We discuss federally listed threatened and endangered species in section 3.3.3, Threatened and Endangered Species.

46 Although osprey have no special status designation, they are an important raptor in western Washington, and are protected by the Migratory Bird Treaty Act.

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possible exception of the bald eagle), due to the absence of effects on upland forests that support most of these species.

Energy Northwest proposes to document any observations of bald eagles in the project vicinity and report sightings annually as part of the Resource Coordination Plan. The Forest Service specifies that Energy Northwest develop and implement a threatened, endangered, and sensitive species management plan. Washington Fish and Wildlife’s recommendations are consistent with the Forest Service condition, but would apply to non-National Forest System lands, as well. Section 3.3.1, Aquatic Resources, summarizes the requirements of the plan.

Our Analysis

As described above, Energy Northwest’s nesting surveys did not document any bald eagle nests at Packwood Lake, but noted that bald eagles forage along the Cowlitz River in the vicinity of the mouth of Lake Creek. Depending on the location of the nearest nest and the timing of stream restoration activities in lower Lake Creek, timing restrictions may be needed to prevent disturbance to nesting birds. Energy Northwest’s proposal to annually report bald eagle sightings would help to define bald eagle use of the project vicinity, but because it would not be conducted as a systematic survey, would not provide the basis for any protection measures that may be needed.

Energy Northwest’s surveys documented the presence of two active osprey nests at Packwood Lake in 2006. Based on priority habitats and species data (Washington Fish and Wildlife, 2008a), ospreys have nested at the lake since at least 1981, when periodic surveys were initiated. Energy Northwest notes that the continued presence of nesting pairs indicates that project operation and project-related activities, including recreation, are not adversely affecting this species. Energy Northwest does not propose implementation of any environmental measures at Packwood Lake, but like bald eagles, osprey may nest along the Cowlitz River near the mouth of Lake Creek. Also like bald eagles, osprey pairs are sensitive to disturbance during the nesting season. For this reason, timing restrictions may be needed to prevent disturbance, depending on the location and timing of stream restoration activities.

Energy Northwest documented the presence of several amphibian species in wetlands associated with Packwood Lake and in Lake Creek. With the exception of rerouting Snyder Creek, wetlands and streams that would be affected by changes in project operation or implementation of new environmental measures were included in the initial surveys and would be monitored as needed under the threatened, endangered, and sensitive species management plan. We discuss project effects on amphibians in more detail under a separate heading (Amphibians), below.

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Gifford Pinchot National Forest MIS are primarily associated with steep and rocky cliffs that do not occur within the project boundary, or with forested habitats that will not be removed or altered as a result of project operations or implementation of proposed environmental measures. However, project maintenance activities and implementation of new environmental measures would have the potential to cause localized and temporary noise disturbance to MIS in the vicinity of road repairs, pipeline maintenance, or stream enhancements on lower Lake Creek. MIS would likely avoid these areas during construction, but there would be no long-term effects.

Two MIS (wood duck and Barrow’s goldeneye) may nest at Packwood Lake. Nesting wood ducks appear to tolerate human activity without adverse effects (Hepp and Bellrose, 1995). Barrow’s goldeneyes are sensitive to disturbance during early incubation (Lewis and Kraege, 2004), which typically occurs between late April and late May (Eadie et al., 2000), but very little recreation occurs along the Packwood Lake shoreline until after Memorial Day. For these reasons, cavity-nesting ducks would be unlikely to experience adverse effects as a result of on-going project-related recreation.

We conclude that development and implementation of a threatened, endangered, and sensitive species management plan would provide an appropriate mechanism for ensuring that Energy Northwest has adequate information throughout any new license period to protect threatened, endangered, and sensitive species as they may be added to or removed from the list, as habitat conditions change, or as Energy Northwest implements environmental measures or new management activities. Implementation of the plan would provide a comprehensive and consistent approach to species protection on both National Forest System and non-National Forest System lands. It would assist Energy Northwest in meeting the requirements of the Bald and Golden Eagle Protection Act and Migratory Bird Treaty Act, and would be consistent with state and Forest Service goals and objectives for species conservation. Without such a plan, project-related ground disturbance or noise disturbance could adversely affect special status species (including MIS) and increase the risk of their listing as threatened or endangered in the future.

Avian Protection Plan

Avian injuries and fatalities associated with electrocution or collision with power lines have been reported since the late 1800s, and as power lines have proliferated across the country, bird losses have increased dramatically. A recent report estimated that fatalities in the United States range from 3.5 million to 1.05 billion birds every year (Hunting, 2002). Most electrocutions are associated with lines carrying 69 kV or less, because the spacing of hardware is often not sufficient to prevent birds from spanning between conductors or between a conductor and a ground (APLIC, 2006). The Packwood Lake transmission line carries 69 kV.

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Energy Northwest consulted with the Forest Service, FWS, and Washington Fish and Wildlife to develop an Avian Protection Plan, and filed the plan with the Commission on June 6, 2008. The Forest Service specifies that Energy Northwest should implement the plan, as filed. Washington Fish and Wildlife’s recommendation is consistent with Energy Northwest’s proposal and the Forest Service. It recommends a survey of project-related distribution lines; raptor-proofing of any power line or pole involved in a bird fatality or injury; and following the most current Avian Power Line Interaction Committee guidelines for avian protection.

Our Analysis

The 1.5-mile-long project transmission line begins at the powerhouse and terminates at the Packwood substation. The line follows the tailrace canal from the powerhouse before turning to follow Highway 12. There are 31 power poles. Spacing of conductors on all of the poles appear to conform to current standards to prevent electrocution, by providing adequate spacing (more than 60 inches) between phase conductors and between the phase conductors and grounding source lines. For this reason, the risk of electrocution would be low.

Most collision-related fatalities occur as a result of birds in flight striking the terminal ground wires (or static wires) that are installed on the lines to dissipate lightning (Hunting, 2002). A variety of factors contribute to the risk of collision, but risks are generally highest where power lines: (1) bisect flight paths for daily movement or seasonal migration across wetlands, waterways, or mountain passes; (2) are located in proximity to areas of bird concentration (wetlands, lakes, agricultural lands); or (3) are located above the tree line (APLIC, 2006). We conclude that the risk of avian collision with the project transmission line is low near the powerhouse and along Highway 12, but higher where it crosses an extensive palustrine emergent wetland as it follows the tailrace canal westward from the powerhouse. However, the Packwood transmission line is not equipped with overhead ground wires, which would help to reduce the risk of collision.

Implementation of Energy Northwest’s Avian Protection Plan addresses the need for surveys to identify any problems; identifies specific steps to address problems; and provides for ongoing consultation with the resource management agencies regarding project effects. We conclude that implementation of the plan would assist Energy Northwest in meeting the requirements of the Bald and Golden Eagle Protection Act and Migratory Bird Treaty Act, and would contribute to the conservation of all bird species likely to occur in the project vicinity.

Amphibians

Because many amphibian species breed in wetlands or shallow waters, lake level fluctuations that alter wetland hydrology could, in turn, affect amphibians. Amphibian species that breed in streams could be affected by flows (and associated temperatures) in

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Lake Creek, and by the timing, frequency, and magnitude of channel maintenance flows. The reconfiguration of Snyder Creek/Hall Creek could also affect amphibians that may breed in these streams or associated wetlands.

Lake Level Fluctuations

Three amphibian species occur in lake fringe wetlands at the head of the lake. These include the Pacific treefrog, Cascades frog, and northwestern salamander. These species typically breed in late April or May, depending on weather conditions. Pacific treefrog and Cascades frog tadpoles typically complete metamorphosis between June and late August, and would be able to exit the fringe wetlands and move into terrestrial habitats as the lake begins to drop for the fall/winter drawdown. Northwestern salamanders typically do not complete metamorphosis until their second year, and could be stranded by falling lake levels.

Based on the results of the drawdown study (EES, 2007a) and amphibian surveys (DTA, 2007), Energy Northwest proposes to further evaluate project effects on northwestern salamanders in the wetland complex located at the upper end of Packwood Lake. Energy Northwest would conduct a survey at “Site B” (the portion of the wetland nearest the edge of the lake) within this wetland complex before and after establishment of winter operating conditions to determine whether the annual drawdown prevents northwestern salamanders from moving into the lake, enabling them to survive the drawdown. If the surveys indicate that drawdown prevents their movement, Energy Northwest would conduct a survey for this species in areas along Upper Lake Creek and Muller Creek within 1 mile upstream of Site B. The purpose of the second survey would be to estimate the importance of Site B to local populations of northwestern salamanders. If the surveys indicate that Site B contributes a significant percentage (i.e., more than 10 percent) of the local population, Energy Northwest would consult with the agencies regarding appropriate habitat improvements that could be implemented at Site B to improve connectivity between Site B and Packwood Lake. The Forest Service and Washington Fish and Wildlife support this proposal.

Our Analysis

During surveys of large woody debris fringe wetlands at the head of Packwood Lake, biologists noted that large woody debris screens this wetland from the main body of the lake. The logs may pose a barrier to northwestern salamander larvae, preventing them from moving into shallow-water habitats around the margins of Packwood Lake as water levels decline during drawdown. Sediment accumulating behind the logs could also form a barrier.

Energy Northwest’s proposal would provide a reasonable means of first determining whether the present configuration of the wetland blocks the movement of northwestern salamander larvae; and then designing measures to improve connectivity, if

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surveys indicate that “Site B” larvae represent a significant proportion of the local population. Although northwestern salamanders are a common species in Washington, a recent assessment indicates that many populations have likely been lost to development and habitat fragmentation (Shaffer, 2005). Other factors that influence amphibian populations include climate change, UV-B radiation, and disease. These factors are not yet well-understood, but appear to be adversely affecting amphibian populations around the world. Global downward trends highlight the importance of conservation for amphibian species that are common, as well as those that are already in decline.

Instream Flows, Flushing Flows, and Water Temperatures

Instream flow is one of several factors that influence habitat suitability for amphibian species associated with flowing water. Energy Northwest surveys documented seven amphibian species in Lake Creek below the diversion dam that breed in aquatic habitats. These include Pacific treefrog, Cascades frog, coastal tailed frog, northern red-legged frog, western toad, rough-skinned newt, and coastal giant salamander47 (DTA, 2007). Energy Northwest identified coastal tailed frog and coastal giant salamander as being of particular concern in evaluating instream flows, because they are strongly associated with flowing water.

Energy Northwest proposes to increase minimum flow releases (see table 3-17, above). Energy Northwest also proposes (on average) to release channel forming flows every other year, or in 3 out of 6 years. Channel forming flows are intended to promote the development of instream structure by allowing for the transport of gravel and large woody debris. The Forest Service specifies and Washington Fish and Wildlife recommends the same approach to new instream flows and channel forming flows.

Our Analysis

Tailed frogs are typically found only in high gradient streams with high velocities, although adults tend to use microhabitats with slower flows more than larvae do (Welsh, Jr., 1993). Suitable habitat for this species is also characterized by cold water temperatures and coarse substrates (Welsh and Ollivier, 1998).

Coastal giant salamanders make use of a wider range of habitats than tailed frogs. They reach their highest abundance in stream reaches with intermediate gradients and a combination of pools, riffles, and runs, with little sediment deposition (Welsh, Jr., 1993).

A recent study (Welsh, Jr. and Hodgson, 2008) modeled habitat thresholds for these two species. The best predictors for tailed frog presence were water temperatures between 9.0 and 14.2°C; sand accounting for less than 9.0 percent of the substrate; embeddedness less than 76.8 percent; and large woody debris cover less than 2.0 percent.

47 The western red-backed salamander also occurs in Lake Creek, but because it is a terrestrial species, it would not be affected by flows in Lake Creek.

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The best predictors for coastal giant salamander presence were water temperatures between 10.5 and 17.0°C; less than 75.5 percent embeddedness; and large woody debris cover less than 5 percent. Substrate size was less important, but Welsh, Jr. (1993) found a negative correlation with small gravel and sandy substrate.

Lake Creek below the diversion dam is a boulder/cobble step/pool stream with a high gradient and relatively little gravel or finer material (Watershed Geodynamics, 2007a). Under current conditions, Energy Northwest releases a minimum of 3 cfs into Lake Creek. With the combination of releases and accretion flows over the 5.3-mile reach between the dam and the confluence, the annual mean flow was about 37 cfs at USGS gage no. 14226000 Lake Creek at mouth when between October 1, 1965, and November 1977 when this gage was deactivated. Low flows (25 to 35 cfs) occur during the drier months, and peak flows (as high as 1,600 cfs in November, 2006) occur during flood events. Project operation with the diversion of up to 260 cfs to the powerhouse reduces the frequency and magnitude of high flow events between 200 and 500 cfs, but has less of an effect on flows of more than 600 cfs.

Water temperatures under current conditions range from a minimum of about 3°C in the winter to more than 18°C in July and August. During Energy Northwest’s water quality study, the warmest water temperatures occurred in August in both 2004 and 2005, reaching maximum hourly temperatures as high as 21.42°C just below the drop structure in both years.

Coastal tailed frog and coastal giant salamander adults and larvae would be present in Lake Creek year-round. Coastal tailed frog eggs would be present from May through September, and coastal giant salamander eggs would be present from March through October. During macroinvertebrate surveys in 2005 and amphibian surveys in 2006 (DTA, 2007), biologists documented three larvae in Lake Creek, and three pairs of adult coastal tailed frogs under rocks in small tributaries to Lake Creek. Surveys conducted at ten representative sites detected 35 coastal giant salamanders, including both larvae and metamorphosed individuals. Survey notes indicate that 80 percent of the 35 amphibians observed in Lake Creek were observed at sample sites with low levels of embeddedness48 (four sites); 20 percent were observed at three of the five survey sites with moderate levels of embeddedness; and no amphibians were documented at the one survey site described as “highly embedded.”

Modeling predicts that the proposed minimum instream flow release to Lake Creek during August, the warmest month, would increase the temperature by about 3.1° at the mouth; and by more than 5° at a point 1,500 feet below the drop structure. Resulting temperatures would be well over 20°C in the upper reaches of the creek. Accretion flows between the drop structure and the mouth would provide a cooling

48 The degree to which sand and finer materials are mixed in or covered, larger substrate materials such as gravel and cobble.

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effect, but temperatures through most of the creek would exceed temperature preferences during the summer for both coastal tailed frog and coastal giant salamander to a greater extent than under current conditions, and could approach lethal temperatures during the summer. Bury (2008) gives the critical thermal maximum temperature for tailed frog larvae as 28.9-30.1°C, and 28.7-29.3°C for giant salamander larvae.

Embeddedness does not appear to be a concern for amphibians under existing conditions. However, provision of channel forming flows would help to maintain suitable conditions. Channel forming flows would flush fine sediments and prevent development of areas of sand or silt deposition that could fill rock interstices that provide cover for tailed frogs and giant salamanders.

Under current conditions, flood events likely flush some amphibian larvae downstream, and could flush them into less-preferred habitats. However, tailed frog and giant salamander larvae generally take cover under large rocks. Proposed channel forming flows of 285 cfs are intended to move gravel and finer materials, and would not be likely to affect the cobbles and boulders that offer protection for amphibians. We conclude that that flushing of larvae would be about the same as under current conditions that include flood events.

We assume that channel forming flows would be released during periods of high inflow to Packwood Lake, which would correspond to the timing of flood events that occur under natural conditions during spring snowmelt and fall rains. Water temperatures are low at this time of year, and for this reason, a release of 285 cfs for a 24-hour period would not increase water temperatures in Lake Creek to levels that would exceed tailed frog and giant salamander preferences.

Other amphibian species found along Lake Creek may breed in side channels, off-channel pools and slow backwaters of the creek. Proposed instream flows and channel forming flows may provide additional habitat for these species, and since they are not as strongly associated with cold water temperatures as tailed frogs and giant salamanders, higher temperatures associated with the proposed flow regime would not be likely to adversely affect them.

As discussed in section 3.3.1, Aquatic Resources, the mean downramping rates in lower Lake Creek associated with both the proposed habitat forming flows and minimum instream flows would not likely exceed 2.4 inches per hour, and would also be moderated by accretion flows. In addition, Energy Northwest would implement its proposed Lake Creek Ramping Rate Plan during downramping of the minimum instream flows released to lower Lake Creek. Given the relatively slow rate of decline and additional control, these ramping rates should be adequate to protect amphibian larvae from stranding during the normal flow regime and during channel forming flow releases.

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Rerouting of Snyder Creek

Several amphibian species found in the project area are associated with low-gradient streams and seasonal wetlands, such as those that occur along Snyder Creek, and could be adversely affected by ground disturbance and alteration of hydrologic support for streams and wetlands where they occur. The culvert that currently blocks fish passage in Snyder Creek may also block amphibian movement along Snyder Creek.

Energy Northwest proposes to improve fish passage in Snyder Creek by rerouting Snyder Creek to meet Hall Creek downstream of the tailrace. As a potential route, Energy Northwest is considering a drainage path that runs parallel to the tailrace for a distance of about 800 feet before entering Hall Creek. Energy Northwest would reroute Snyder Creek to connect to this backwater channel. It would retain stream restoration specialists and consult with the agencies and tribes in rerouting the creek.

Our Analysis

Most of the drainage path that Energy Northwest is considering as a path for Snyder Creek was dry at the time of Energy Northwest’s August 2007 inspection, but it includes a 300-foot length described as a backwater with a bankfull width of about 20 feet and no discernable flow. During the Commission staff’s informal site visit in July 2008 this portion of the backwater held standing water and supported abundant duckweed, an aquatic plant.

No amphibian surveys were conducted along Snyder or Hall creeks in the vicinity of the proposed realignment, but the two species documented during opportunistic surveys at the confluence of Snyder and Hall creeks (northwestern salamander and red-legged frog) may be present at this site, as well. Other amphibian species that were documented in the project area (Pacific treefrog, Cascades frog, [a federal species of concern], western toad [a federal species of concern and state candidate species], and rough-skinned newt) are often associated with wetlands and shallow water, and may also use this site.

Removal of the culvert and rerouting of Snyder Creek may ultimately benefit any amphibians that are present. However, construction would involve clearing of vegetation, soil excavation, and alteration of wetland hydrology, and could adversely affect amphibians. Construction during the dry season would minimize the risk of adverse effects on amphibians.

Marine-derived NutrientsThe return of Pacific salmon to freshwater streams can represent an important

source of nutrients for local biota, particularly in otherwise nutrient-poor systems. Native resident salmonids can benefit from marine-derived nutrients through increased primary

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production or direct consumption of eggs, fry, and carcasses (Cedarholm et al., 1999), and numerous studies over the past decade have shown that salmon contribute substantially to terrestrial systems through several pathways (Gende et al., 2002). Studies in western Washington indicate that salmon directly or indirectly affect more than 100 wildlife species (Cedarholm et al., 2001). At least 22 species of birds and mammals prey on salmon eggs or live salmon, or forage on salmon carcasses in freshwater systems. Salmon consumption may improve fitness (i.e., growth rate, litter size, reproductive success), suggesting that salmon play an important role in population dynamics of species such as river otters, black bears, and bald eagles.

Our Analysis

The lower 1.03 miles of Lake Creek are accessible to both salmon and steelhead, and an additional 0.92 miles (a total of 1.95 miles) are accessible to steelhead. Energy Northwest documented coho and Chinook salmon spawning in lower Lake Creek during surveys conducted between 2004 and 2006. No steelhead were observed during the surveys, but one steelhead redd was observed at about rive mile 0.3 during other field work in 2007.

The results of spawner surveys indicate that fish are using the extent of habitat that is available, but that habitat availability is restricted by low instream flows, a limited supply of gravel, and a lack of instream structure. As detailed in section 3.3.1, Aquatic Resources, Energy Northwest proposes and the agencies recommend several measures to improve habitat for anadromous fish in lower Lake Creek. These include increasing minimum flows to lower Lake Creek, releasing aquatic habitat forming flows, and developing and implementing a stream restoration and enhancement plan. In general, measures to improve habitat for anadromous fish would also improve conditions for fish-eating wildlife species, to the extent that such measures actually result in higher numbers of spawners in lower Lake Creek. Indirect benefits to riparian plant and animal communities may also occur, as nutrients are transported to terrestrial habitats along the river corridor (Gende et al., 2002).

Construction of the Stream Gage Energy Northwest proposes to construct a stream gage on lower Lake Creek at the

Lake Creek Road bridge (see also section 3.3.1, Aquatic Resources). This measure is also specified by the Forest Service and recommended by Washington Fish and Wildlife.

Our Analysis

Construction associated with the stream gage on lower Lake Creek would have the potential for short-term terrestrial and possible aquatic habitat disturbance. The land area that would be disturbed during the construction would probably consist of a very small footprint associated with the construction of the housing facility for the recording and

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transmission devices if this structure is not located on the bridge. Aquatic habitat disturbance could occur in the event that a weir is constructed in this location to aid in the stream gaging, but this possibility is very unlikely since this area is the location of a former USGS gage. There would be little ground-disturbing activity, and with the implementation of best management practices, soil erosion or any adverse effects on water quality as a result of construction of these facilities would likely be very minor and/or short-term.

3.3.2.3 Cumulative Effects

Scoping comments indicated concerns that wildlife species and shorelines (including shoreline wetlands) could be cumulatively affected by lake level drawdowns. The geographic scope selected for analysis of cumulative effects on these resources is the Cowlitz River Basin. At 2,480 square miles, the basin provides a landscape-level context for evaluating factors that affect the abundance and distribution of riparian habitat, shoreline wetlands, and associated wildlife species.

Past actions within the Cowlitz River Basin that have cumulatively affected these resources include timber harvest, agricultural practices, the development of towns, roads, and other infrastructure, and increasing levels of human activity. Development of three major hydroelectric projects (the 610-acre Lake Scanewa, 11,800-acre Riffe Lake, and 2,250-acre Mayfield Lake)49 in the Cowlitz River Basin has also resulted in the loss and fragmentation of large areas of riparian habitat due to inundation. Together, Riffe and Mayfield lakes account for 96 percent of the 23 square miles that are inundated by reservoirs in the Cowlitz River Basin.

On-going and future actions within the Cowlitz River Basin that may cumulatively affect riparian habitat and associated wildlife species are: continued timber harvesting, increasing development as a result of population growth, and continued hydropower project operation. Agriculture affects a relatively small portion (i.e., about 2 percent) of the basin (Dammers et al., 2002).

Timber harvest in Washington has dropped yearly since the late 1980s (Perez-Garcia and Barr, 2005). In 2006, harvest totaled less than 4 billion board feet (OFM 2007), with Lewis and Cowlitz counties (which encompass most of the Cowlitz River watershed) supplying a substantial portion (over 19 percent) of the statewide total. However, implementation of the Northwest Forest Plan on federal lands since 1990 and revised Washington Forest Practice Rules since 2001 provide increased protection for riparian habitat during forest management activities, and likely reduce cumulative effects of these activities.

49 Lake Scanewa is the reservoir impounded by the Cowlitz Falls Hydroelectric Project, FERC No. 2833. Riffe and Mayfield lakes are the impoundments for the Cowlitz River Hydroelectric Project, FERC No. 2016.

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The populations of both Lewis and Cowlitz counties are increasing at about the same rate as the statewide average, and grew by about 7.4 percent between 2000 and 2006 (Lewis County MapStats, 2007; Cowlitz County MapStats, 2007). As a result, the acreage of land being cleared for residential, commercial, and industrial development is also gradually increasing, but adoption of new regulations regarding critical areas in Lewis and Cowlitz counties (Lewis County Community Development, 2008; Cowlitz County, Department of Planning and Building, 2009) may help to prevent cumulative effects on riparian habitat and wetlands as development continues.

Current and future operation of hydropower projects in the Cowlitz River Basin will cumulatively affect riparian habitat and shorelines as a result of reservoir fluctuations and altered flows downstream of the dams. Riffe Lake is operated for power generation and flood storage. The reservoir is drawn down approximately 33 feet each fall to accommodate high winter and spring flows, which prevents development of a perennial riparian plant community along the 52-mile shoreline. Mayfield Lake is operated primarily as a run-of-river project, but operation does affect riparian vegetation within the 3-foot drawdown zone along the 33.5-mile shoreline. Effects of continued Packwood Lake Project operation would not substantially interact with the effects of timber harvest or increasing development in the Cowlitz River Basin. Energy Northwest does not propose any timber harvest or construction of major facilities, and increases in recreational activity are expected to be small. Cumulative interactions would center on reservoir level operations. Packwood Lake fluctuations would continue to affect the 4.3-mile-long shoreline and about 34 acres within the drawdown zone through the new license period. However, the small size of the Packwood Lake Project in relation to other hydropower projects in the basin would limit its contribution to cumulative effects. In addition, Energy Northwest’s proposed modifications to the drawdown schedule would provide increased hydrologic support for lake fringe wetlands.

Releases to lower Lake Creek from Packwood Lake which are related to both project generation fluctuations in the level of Packwood Lake would continue to affect the 5.3-mile reach of Lake Creek below the diversion dam. Proposed increases in minimum instream flows may help to restore riparian habitat along Lake Creek by removing vegetation that has encroached into the stream channel and increasing habitat availability for stream-associated amphibians. However, it would also increase water temperatures, making Lake Creek less suitable for amphibians that are adapted to cold-water systems.

Diversion of flows may have limited the abundance of spawning habitat for anadromous fish in the lower reach of Lake Creek, which would reduce the availability of marine-derived nutrients that help to support native riparian plant communities and associated wildlife species. Proposed flow increases and implementation of stream restoration measures would contribute to cumulative benefits for vegetation and wildlife, to the extent they contribute to increasing anadromous fish populations.

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In addition to increasing minimum instream flows and providing channel forming flows in Lake Creek, Energy Northwest proposes several measures that are intended to benefit terrestrial resources, including riparian habitat and shorelines and associated wildlife species. These include implementation of plans to (1) protect special status species; (2) manage noxious weeds; (3) monitor, and if needed, upgrade transmission line structures to minimize the risks of avian electrocution and collision; and (4) survey, and if needed, improve habitat connectivity for northwestern salamanders at the upper end of Packwood Lake. Each of these measures would contribute to cumulative benefits of other management activities that are on-going in the project area. These include the Gifford Pinchot National Forest’s protection of habitat within the Late Successional Reserve adjacent to lower Lake Creek and Goat Rocks Wilderness adjacent to Packwood Lake, and Lewis County Noxious Weed Control Board’s weed management programs.

3.3.2.4 Unavoidable Adverse Effects

Under proposed operations, lake level fluctuations would continue to prevent the establishment of riparian habitat along the Packwood Lake shoreline and development of an aquatic plant community within the littoral zone. Proposed increases in the minimum instream flows in Lake Creek would result in warmer temperatures, which would limit its suitability to support amphibians that are adapted to cold water streams.

3.3.3 Threatened and Endangered Species


Energy Northwest submitted its draft final Biological Assessment for the project addressing federally listed fish, wildlife, and plants that could occur in the project area as part of the license application filed in February 2008. Staff issued a Biological Assessment on February 5, 2009, and submitted it to NMFS and FWS as part of section 7(a) consultation on listed species that could be affected by project relicensing. Table 3-21 summarizes the information and analyses provided in the Biological Assessment for the species discussed in the following section.

Table 3-21. Federally listed species and designated critical habitat in Lewis County and documented occurrences in the Packwood Lake Hydroelectric Project vicinity. (Source: FWS, 2007; NMFS, 2008; modified by staff)

Common Name Species NameFederal Status

Found in Project Area

Critical Habitat in Lewis County

Fish Chinook Salmon O. tshawytscha Threatened Yes Yes

Coho Salmon O. kisutch Threatened Yes No

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Common Name Species NameFederal Status

Found in Project Area

Critical Habitat in Lewis County

Steelhead Trout O. mykiss Threatened Yes Yes

Chum Salmon O. keta Threatened No Yes

Bull Trout Salvelinus confluentus

Threatened No No

Wildlife Canada Lynx Lynx canadensis Threatened No No

Gray Wolf Canis lupus Endangered No No

Grizzly Bear Ursus arctos Threatened No No

Marbled Murrelet Brachyramphus marmoratus

Threatened No Yes

Northern Spotted Owl

Strix occidentalis caurina

Threatened Yes Yes

Plants

Kincaid’s Lupine Lupinus sulphureus kincaidii

Threatened No

Yes

Howellia Howellia aquatilis Threatened No No

Nelson’s checker-mallow

Sidalcea nelsoniana

Threatened No No

FishChinook Salmon

Chinook salmon, also referred to as king or Tyee salmon, is the largest of the Pacific salmon species. Spawning stocks are distributed from the Ventura River in central California to Kotzebue Sound, Alaska on the North American coast, and from northern Hokkaido, Japan to the Anadyr River, Russia on the Asian coast (Healey, 1991;

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Myers et al., 1998). Along the coast of North America, there are well in excess of 1,000 spawning Chinook salmon populations.

Based on the best available scientific and commercial information, NMFS has identified 15 evolutionary significant units of Chinook salmon from Washington, Oregon, Idaho, and California. The lower Columbia River Chinook evolutionary significant unit was listed as threatened on March 24, 1999, and that status was re-affirmed on June 28, 2005. The lower Columbia River Chinook evolutionary significant unit includes all naturally spawning populations of Chinook salmon from the Columbia River and its tributaries from the Pacific Ocean upstream to a transitional point between Washington and Oregon east of the Hood River and the White Salmon River, and includes the Willamette River to Willamette Falls, Oregon, exclusive of spring-run Chinook salmon in the Clackamas River (64 FR 14208). Seventeen artificial propagation programs are considered to be part of the evolutionary significant unit, including the Cowlitz River spring Chinook program. Critical habitat is found in the mainstem Cowlitz River, but does not include Lake Creek or other tributaries within the project area.

Lower Columbia River Chinook salmon exhibit three major life history types: fall run (tules), late-fall run (brights), and spring run. The fall-run Chinook salmon populations are currently dominated by large-scale hatchery production, relatively high harvest, and extensive habitat degradation (discussed in previous status reviews). The spring-run populations are largely extirpated as the result of dams, which block access to their high-elevation habitat. Abundances have largely declined since the last status review update (1998), and trend indicators for most populations are negative, especially if hatchery fish are assumed to have a reproductive success equivalent to that of natural-origin fish.

Spring Chinook salmon reside in freshwater for a year or more before migrating to sea and return to their natal river in spring or summer, several months prior to spawning. Fall Chinook salmon migrate to sea in their first year of life, usually only a few months after emergence, and return to their natal river in the fall, a few days or weeks before spawning (Healey 1991).

Historically, spring Chinook salmon were known to spawn and rear in the mainstem Cowlitz River above Tacoma Power’s Mayfield dam site and in the Cispus River. The historical upper Cowlitz River adult spawning population was estimated to range from 35,000 to 60,000 fish (NPPC, 2004). Fall Chinook salmon were also abundant in the Cowlitz River Basin and were distributed from its mouth to its upper tributaries, including the Ohanapecosh and Tilton rivers.

Lower Columbia River spring Chinook salmon have been observed in the upper Cowlitz River, lower Lake Creek and in the side channel of the Cowlitz River

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downstream of the project tailrace (known as the tailrace slough). A natural upstream migration barrier at river mile 1.03 prevents access above that point in Lake Creek.

Coho Salmon

Coho salmon is a widespread species of Pacific salmon, occurring in most major river basins around the Pacific Rim from Monterey Bay, California, north to Point Hope, Alaska, through the Aleutians, and from the Anadyr River south to Korea and northern Hokkaido, Japan (69 FR 33,109). Introductions have also occurred in most of the Great Lakes and in other cold temperate areas of North America (Scott and Crossman, 1973; Sandercock, 1991). All coho salmon stocks in the Columbia River Basin above Bonneville dam (except Hood River) are considered extinct (Nehlsen et al., 1991). All other lower Columbia River tributary stocks are at high risk of extinction (except the Clackamas River stock).

Lower Columbia River coho salmon were listed as threatened on June 28, 2005. The evolutionary significant unit includes all naturally spawned populations of coho salmon in the Columbia River and its tributaries in Washington and Oregon, from the mouth of the Columbia up to and including the Big White Salmon and Hood rivers, and includes the Willamette River to Willamette Falls, Oregon, as well as 25 artificial propagation programs including the Cowlitz Type-N Coho Program in the upper and lower Cowlitz rivers, Cowlitz Game and Anglers Coho Program, and the Friends of the Cowlitz Coho Program.

Coho salmon life histories are extremely variable, and coho examined in different years or from different locations or habitats within a basin may display different life history characteristics. The majority of coho salmon adults are 3-year-olds, having spent about 18 months in saltwater. The primary exception to this pattern are jacks, sexually mature males that return to freshwater to spawn after only 5 to 7 months in the ocean (Weitkamp et al., 1995). Coho juveniles in the Cowlitz River appear to reside in the river for 1 year before migrating downstream.

Coho salmon were historically the most abundant anadromous salmonid in the Cowlitz River Basin. The historical upper Cowlitz adult population is estimated to range from 20,000 to 70,000 fish, with the majority of returns being late stock which spawn from late November to March. Current natural spawning returns are part of an upper Cowlitz and Cispus rivers reintroduction program.

Coho salmon have been observed in the upper Cowlitz River, lower Lake Creek and in a side channel of the Cowlitz River adjoining the tailrace (tailrace slough). The natural upstream migration barrier at river mile 1.03 on Lake Creek prevents coho salmon access above that point in Lake Creek.

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Steelhead

The present distribution of steelhead, the anadromous form of O. mykiss, extends from Kamchatka in Asia, east to Alaska, and down to the U.S.-Mexico border (Busby et al., 1996). Historically, steelhead likely inhabited most coastal streams in Washington, Oregon, and California, as well as many inland streams in these states and Idaho. However, during this century, more than 23 indigenous, naturally reproducing stocks of steelhead are believed to have been extirpated, and more are thought to be in decline in numerous coastal and inland streams in Washington, Oregon, Idaho, and California.

Lower Columbia River steelhead populations were listed as a threatened species on March 19, 1998; threatened status was reaffirmed on January 5, 2006. The distinct population segment includes all naturally spawned anadromous steelhead populations below natural and manmade impassable barriers in streams and tributaries to the Columbia River between the Cowlitz and Wind rivers, Washington (inclusive), and the Willamette and Hood rivers, Oregon (inclusive), as well as 10 artificial propagation programs, including the Cowlitz Trout Hatchery (in the Cispus, upper Cowlitz, lower Cowlitz, and Tilton rivers). The Lower Columbia River steelhead Critical Habitat designation includes the mainstem Cowlitz River in the vicinity of the project, as well as Lake, Hall and Johnson creeks. Known spawning areas included the mainstem Cowlitz River near Riffe and the reach between the Muddy Fork and the Clear Fork and the lower Ohanapecosh River. Currently summer steelhead enter the Cowlitz River as immature fish from April through October, with spawning occurring from December through May. Fry emergence begins in March.

Historically, winter steelhead were distributed throughout the upper Cowlitz, Cispus, and Tilton rivers. The historical upper Cowlitz River Basin adult population is estimated from 2,000 to 17,000 fish. Current natural spawning returns are part of an upper Cowlitz and Cispus rivers reintroduction program (NPPC, 2004).

Spawner surveys associated with project relicensing have not documented the presence of steelhead in lower Lake Creek and in the tailrace slough below the project tailrace; however, a steelhead redd was noted in Lake Creek (about river mile 0.3) in May 2007. An analysis of the natural barriers in Lake Creek indicated that a steelhead in excellent condition would be able to successfully navigate the barrier at river mile 1.03. The next natural barrier, however, a falls at river mile 1.95 on Lake Creek prevents access to steelhead above that point.

Wildlife

Canada lynx

The Canada lynx is a medium-sized cat that is highly mobile and has a large home range. Its population and distribution is closely tied to its main prey, snowshoe hare

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(Ruediger et al., 2000). Populations in northern boreal regions fluctuate in response to snowshoe hare population level cycles; however, this cycling has not been found to occur in Washington (Stinson, 2001).

Canada lynx inhabit moist coniferous forests with cold, snowy winters. In Washington, the majority of lynx records and evidence of reproduction are from older lodgepole, subalpine fir, and spruce forests at elevations higher than 4,000 feet (McKelvey et al., 2000). Canada lynx survivorship, distribution, and population dynamics are closely tied to those of snowshoe hare. Den sites are commonly composed of large woody debris in older regenerating stands or mature forests.

The nearest designated critical habitat for the Canada lynx is located in north-central and northeastern Washington. Historic records (including three from Lewis County) indicate there was once a population of Canada lynx in the south Cascades, and Washington Fish and Wildlife considers high-elevation habitat east of Packwood Lake as a part of a potential recovery area that extends along the Cascade Crest from the vicinity of Stevens Pass southward to Indian Heaven Wilderness (Stinson, 2001). However, forests around Packwood Lake, the diversion dam, intake structure, and other project features closer to the Cowlitz River are located well below those typically occupied by Canada lynx, and are not characterized by the habitat types or prey populations that would be considered suitable for this species. For these reasons, the Canada lynx is unlikely to occur in the project area. No studies were requested or performed by Energy Northwest to investigate the presence or status of the Canada lynx in the project area. We conclude the Canada lynx is not likely to occur in the project area. The project would have no effect on the Canada lynx, and for this reason, we do not discuss this species further in this EA.

Gray wolf

Gray wolves use a wide range of habitats. The key components of gray wolf habitat are: (1) a sufficient, year-round prey base of ungulates (big-game) and alternate prey; (2) suitable and somewhat secluded den and rendezvous sites; and (3) sufficient space with minimal exposure to humans (FWS, 1987). Currently, there are more than 300 wolves in the Northern Rocky Mountain region which includes parts of Montana and Idaho (FWS, 2007). In Washington, sporadic occurrences may be the result of dispersal southward from Canada and westward from Idaho (Johnson and Cassidy, 1997; Smith, 2002; Forest Service, 2006a; Washington Fish and Wildlife, 2008c). Most of the reports involve single animals, but in July 2008, biologists documented a pack with pups in Okanogan County, about 120 miles north of Packwood Lake. This is the first fully documented breeding by wolves in the state since the 1930s (Washington Fish and Wildlife, 2008c).

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Several unconfirmed sightings of gray wolves were reported to Washington Fish and Wildlife from the Cowlitz and Cispus river drainages between 1981 and 1998 (Pacific Biodiversity Institute, 1999), but no sightings (confirmed or otherwise) have been reported from southwestern Washington since 2000 (WDFW, 2008c). The Forest Service notes that reports from the Goat Rocks Wilderness could be wolves, or could be misidentifications of wolf/dog hybrids or large coyotes (Forest Service, 2004). There are no reports or documented occurrences in the project area, and no studies were requested or performed by the licensee to investigate the presence or status of the gray wolf in the project area.

Grizzly bear

Preferred habitats of grizzly bears include sub-alpine meadows and open or semi-open forests, but individuals are very wide-ranging and can be found in diverse habitats. Dens are typically located far away from human activity on steep slopes where snow accumulation is deep and persistent. Seasonal movements often occur associated with patterns of newly sprouted vegetation, ripening berries, spawning salmon runs, and the availability of other prey, such as marmots.

FWS established several recovery zones throughout the western United States in 1993; the North Cascades Ecosystem Recovery Zone is the only zone in western Washington. Current population levels in this zone are unknown, but are believed to be very low, possibly fewer than 20 animals (FWS, 2004). Without augmentation, FWS concludes there is a low likelihood of recovery in the north Cascades (FWS, 2004). This species is probably not established south of Snoqualmie Pass, but individual grizzly bears are wide-ranging and occasional, possible detections have been reported as far south as the Mount St. Helens area (Johnson and Cassidy, 1997). These reports typically lack detailed documentation, and may often represent misidentified black bears. Grizzly bears are unlikely to occur in the project vicinity other than as a rare transient (Forest Service, 2004). Energy Northwest did not perform and the agencies did not request any studies to investigate the presence or status of the grizzly bear in the project area. The grizzly bear is unlikely to occur in the project area. The project would have no effect on the grizzly bear, and we do not discuss this species further in this EA.

Marbled murrelet

The marbled murrelet is a small diving seabird that ranges along the Pacific coast from Alaska to California. The primary food sources for this species are fish and invertebrates in nearshore marine environments (FWS, 1997). The marbled murrelet nests in primarily old-growth or mature conifer forests in trees with large branches, but nests also have been documented in younger, mixed stands where deformities are used as nest platforms (McShane et al., 2004).

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Nesting occurs in inland forests as far as 50 miles from saltwater. An interagency review of the status and trends of populations and nesting habitat found that all reports of marbled murrelet occupancy between 1994 and 2003 occurred within 37 miles of saltwater, within the band of habitat that was delineated as Zone 1 (habitat within 40 miles of saltwater) under the Northwest Forest Plan (Forest Service and BLM, 1994), while no occupancy was documented in Zone 2, which extended an additional 10 miles inland (Huff et al., 2006).

The marbled murrelet was originally listed as federally threatened in 1992 in Washington, Oregon, and California. FWS designated critical habitat for the marbled murrelet in 1996 and developed a recovery plan in 1997. The critical habitat designation encompasses a Late Successional Reserve about 1.5 miles west of the project area. This area would remain designated critical habitat under the proposed rule to revise the designation, issued on July 22, 2008.

No studies were requested by the resource management agencies or performed by the licensee to investigate the presence or status of the marbled murrelet in the project area. Marbled murrelets are unlikely to occur in the project area, due to its distance (more than 50 miles) from saltwater, just outside Zone 2. As of May 2008, the Priority Habitats and Species database shows no marbled murrelet occupancy detections in the project vicinity (Washington Fish and Wildlife, 2008a). For this reason, we conclude the marbled murrelet is unlikely to occur in the project area, and do not discuss this species further in this EA.

Northern spotted owl

Northern spotted owls inhabit temperate forests of the Pacific Coast region from southwestern British Columbia, through the Olympic and Cascade ranges in Washington and Oregon to north central California. The northern spotted owl is commonly associated with old-growth or mature conifer forest stands, especially during nesting, although younger stands that have late-successional stand remnant structures are also sometimes used, especially during times of dispersal (Thomas et al., 1990).

Nest sites are generally located in previously excavated cavities or on platforms in large trees and northern spotted owls may use nests built by other species (FWS, 1992). Established pairs normally remain in the same territories from year to year and foraging areas may reach nearly 2500 acres (FWS, 1992). Breeding behavior is generally initiated in March and continues into June, depending on elevation. Parental care continues into September and sometimes October, as fledglings learn to fly and hunt on their own. Although spotted owls are well-known for often continuing normal behaviors (including preening, feeding, caching of prey, and sleeping) within a few yards of observers, several studies of Mexican spotted owls have documented disturbance responses to a variety of disturbance sources, such as hikers, chainsaws, and helicopters (FWS, 2003). FWS

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considers the period between March 1 and July 15 to be the early breeding season, when birds are most vulnerable to disturbance. Birds may be less sensitive during the late breeding season (July 16 and September 30).

The northern spotted owl was listed as federally threatened on June 26, 1990. FWS issued a final recovery plan in May 2008 (FWS, 2008a). The plan identifies actions aimed at conserving and managing habitat and controlling barred owls, following a strategy designed for evaluation and adaptive management over the next 10 years. Based on Recovery Action 4 of the plan, FWS revised the designation of critical habitat in August 2008. The designated critical habitat provides for a network of managed owl conservation areas that are of sufficient size and spacing to achieve long-term recovery of spotted owls. The designation includes only federal lands. FWS designated seven managed owl conservation areas in southwestern Washington, including four in Lewis County, which are all part of Critical Habitat Unit 5. The boundaries of these conservation areas generally encompass areas managed as Late Successional Reserve lands under the Northwest Forest Plan (Forest Service and BLM, 1994).

Since the northern spotted owl was listed, 11 northern spotted owl nest sites have been recorded within the Packwood Lake Late Successional Reserve, which includes the recently designated managed owl conservation area. Based on Forest Service monitoring (Forest Service, 2004), two northern spotted owls were detected in the Lake Creek drainage in 2004. The Priority Habitats and Species database (Washington Fish and Wildlife, 2008a) shows one owl site center within 1 mile of the pipeline near Lake Creek, one within about 0.5 mile of Packwood Lake, and one about 1 mile from the penstock.

Conifer forest around Packwood Lake and along the pipeline, tunnels, penstock and access roads provides suitable habitat for nesting, roosting and foraging. Habitat conditions are considered good; however, the number of barred owls in the area is a negative feature. Barred owls may competitively exclude northern spotted owls from suitable habitat (Courtney et al., 2004; Forest Service, 2004).

No nests have been observed in the vicinity of the project, and Energy Northwest is unaware of the locations of any nests in the area designated as critical habitat. No studies were requested by FWS or other agencies participating in the relicensing, and none were performed by the licensee to investigate the presence or status of northern spotted owls in the project area.

Plants

Howellia

Howellia is a hydrophytic annual plant that is restricted to seasonally inundated, shallow water areas, and the edges of deep ponds that are partially bordered by deciduous

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trees. Seed germination for this species occurs only when ponds dry out and the seeds are exposed to air.

Howellia was placed on the federal list of threatened species in 1994. No critical habitat is designated, but FWS developed a recovery plan for the species in 1996 (FWS, 1996). It is listed as threatened in Washington. The nearest populations in Washington are located about 50 miles northwest of the project area (Mincemoyer, 2005). The wetland habitats in the project study area do not have the specific seasonal inundation and desiccation regime that is required to support howellia (Beck, 2007a). Howellia is unlikely to occur in the project area. We conclude that relicensing the project would have no effect on howellia, and we do not discuss this species further in this EA.

Kincaid’s sulfur lupine

Kincaid’s sulfur lupine is a perennial plant associated with native upland prairies and open oak woodlands that have a history of fire disturbance. Kincaid’s sulfur lupine is restricted to mesic to slightly xeric solids in native upland prairies. This species requires occasional burning to limit shading by trees, although it is found in association with fire-resistant Oregon white oak.

Kincaid’s sulfur lupine was placed on the federal list of threatened species on January 25, 2000. FWS designated critical habitat in 2006 and released a draft recovery plan for the prairie species of western Oregon and southwestern Washington, including Kincaid’s sulfur lupine, in August 2008 (FWS, 2008b). It is listed as threatened by the state of Washington.

Kincaid’s sulfur lupine is known to exist at three sites in Lewis County; the nearest of these is occurs within designated critical habitat about 60 miles west of the project area (FWS, 2008b). The project study area does not have undisturbed prairie and, thus lacks suitable habitat. Any existing grasslands in the lowland portions of the project study area have been subjected to repeated disturbances, including residential development, agriculture, grazing, mowing, and invasion by non-native species. Kincaid’s sulfur lupine is unlikely to occur in the project area. We conclude that relicensing the project would have no effect on Kincaid’s sulfur lupine, and we do not discuss this species further in this EA.

Nelson’s checker-mallow

Nelson’s checker-mallow is a perennial herb associated with streams, meadows, swales, wet depressions, riparian areas, and other open areas (WNHP, 1997). It occurs in areas of little or no shade and does not tolerate encroachment by woody species.

Nelson’s checker-mallow was placed on the federal list of threatened species in 1993. FWS issued a draft recovery plan for the prairie species of western Oregon and

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southwestern Washington, including Nelson’s checker-mallow, in August 2008 (FWS, 2008b). It is listed as threatened in Washington.

Nelson’s checker-mallow is known from several sites in Lewis County, although some sightings may be confused with Sidalcea hirtipes, a similar (and also rare) species (Caplow and Miller, 2004). The nearest known population of Nelson’s checker-mallow is located about 80 miles west of the project area (FWS, 2008b). Based on Caplow and Miller’s approach to evaluating potential habitat, there is a low likelihood that the project area would support Nelson’s checker-mallow. Marginal habitat for Nelson’s checker-mallow in the lowland portions of the project study area has been subjected to repeated disturbances, including residential development, agriculture, grazing, mowing, and invasion by non-native species (Beck, 2007a). Nelson’s checker-mallow is not likely to occur in the project area. We conclude that relicensing the project would have no effect on Nelson’s checker-mallow, and we do not discuss this species further in this EA.


As mentioned above, the Commission submitted a Biological Assessment to NMFS and FWS as part of formal consultation on Chinook and coho salmon, steelhead, and northern spotted owl. The following sections summarize our analyses for Chinook and coho salmon, steelhead, and northern spotted owl, which may be affected by project operation or project-related activities.

As discussed in section 3.3.1, Aquatic Resources and section 3.3.2, Terrestrial Resources, the Forest Service specifies and Washington Fish and Wildlife recommends that Energy Northwest to develop and implement a threatened, endangered, and sensitive species management plan. The plan would provide for implementation of protective measures, if monitoring results show project-related effects, and also would include monitoring to measure whether the measures are effective. The plan would provide for adaptive management, based on monitoring results. Finally, the plan calls for Energy Northwest to annually consult with the Forest Service and provide an annual report on plan activities, with the opportunity to update the plan, as needed.

FishWe evaluated the effects of Energy Northwest’s proposed measures and those

measures recommended or required by the resource agencies and the tribes in our Biological Assessment and in section 3.3.1.2, above. Based on this analysis, we conclude that all of those measures included under the proposed action would likely be beneficial to listed Chinook, coho, and steelhead and would likely improve or at least maintain the existing condition of this habitat. Implementation of the proposed action would (1) improve the quality of Chinook, coho and steelhead spawning and rearing habitat in lower Lake Creek (due to implementation of increased instream flows); (2) improve habitat quality (large woody debris, gravel, pool frequency and quality, off-channel

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habitat, and streambank/riparian condition) in lower Lake Creek through the implementation of habitat enhancement measures; (3) improve access to suitable spawning and rearing habitat in Snyder Creek; and (4) minimize the potential for fish or redd dewatering in the tailrace slough. Development and implementation of the threatened, endangered, and sensitive species management plan also would provide an efficient mechanism for coordination between the Commission, Energy Northwest, the Forest Service, Washington Fish and Wildlife, and other agencies to ensure the continued protection of currently listed species and those that may be listed in the future. Chum salmon and bull trout are not considered to be distributed in the upper Cowlitz River subbasin. Accordingly, the proposed action would have no effect on these species.

While all of the measures discussed above would likely improve aquatic habitat conditions for listed Chinook and coho salmon and steelhead, the risk of incidental adverse effects on individual fish cannot be entirely eliminated. For example, the potential for fish stranding cannot be completely eliminated during unplanned outages in the tailrace slough, and some small level of Chinook and coho salmon and steelhead handling mortality is unavoidable under any tailrace slough fish rescue scenario. Another take example may include juvenile harm or mortality caused by future habitat enhancement construction activities (i.e., disruption to lower Lake Creek and introduction of sediment and other materials). Although the proposed action of issuing a new license for up to a 50 year license term would have an overall net benefit compared to existing conditions, we conclude that the proposed action is likely to adversely affect listed Lower Columbia River Chinook salmon, Lower Columbia River coho salmon, and Columbia River steelhead and their designated Chinook salmon and steelhead critical habitat.

Based on these determinations, formal section 7 consultation with NMFS is required to ensure that the proposed action is not likely to jeopardize the continued existence of these listed species.

Gray WolfThere are no documented occurrences of gray wolves in the project area.

However, large blocks of contiguous forest on National Forest System lands in the project vicinity would provide suitable habitat, if wolf populations in the North Cascades and Idaho expand, and it is possible that wolves would use habitat around Packwood Lake in the future.

Our Analysis

No measures proposed or recommended for implementation as part of this relicensing would involve removal or alteration of habitat or the prey base for gray wolves, or increase the risk of disturbance. Wolves would likely avoid the lower Lake Creek watershed and habitat surrounding the powerhouse and tailrace, because of the lack of forest cover and high levels of human activity near the town of Packwood. Should gray wolves occur in the future, implementation of the threatened, endangered,

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and sensitive species management plan would provide a mechanism to evaluate and address potential project effects.

Northern Spotted OwlNorthern spotted owl populations appear to be declining throughout most of their

range as a result of habitat loss, predation, and competition with barred owls. Disturbance during the nesting season may impair reproductive success, and add to the rate of decline. Energy Northwest does not propose any activities that would remove or alter habitat for the northern spotted owl, but implementation of proposed environmental measures could cause disturbance.

Forest Service 4(e)-12 and Washington Fish and Wildlife 10(j)-12 call for Energy Northwest to develop and implement a threatened, endangered, and sensitive species management plan. As part of this plan, Energy Northwest would consult with the resource management agencies (Forest Service, FWS, and Washington Fish and Wildlife, depending on land ownership) to determine whether preparation of a Biological Evaluation is needed to evaluate potential impacts; whether owl surveys should be conducted; and if owls are present; identify timing restrictions or other mitigation measures that would minimize the risk of disturbance.

Our Analysis

There are no records of northern spotted owl nesting within the project boundary, but a review of the Priority Habitat Species database in May 2008 indicates two owl site centers within 1 mile of the penstock (Washington Fish and Wildlife, 2008a). Reproduction was documented at one of these sites in 1990, while at the other site, surveyors reported a single owl. Surveyors detected a pair of owls at a third owl site center in 1992, approximately 1.2 miles from the penstock, but did not document reproduction. No current survey data are available to determine whether these owl site centers are currently active, or whether new nesting territories have been established. No studies of spotted owls were requested for relicensing.

The Forest Service (2004) suggests there is the possibility that noise generated from Energy Northwest employees accessing project facilities might disturb northern spotted owls. In their comments on the draft biological assessment (Energy Northwest, 2007), FWS requested more information about any proposed activities that might cause noise disturbance to listed species (letter from K. Berg, Manager, Western Washington Fish and Wildlife Office, FWS, Olympia, WA, to K.D. Bose, Secretary, FERC, Washington, DC, dated December 17, 2007).

As described in section 3.3.3.1, spotted owls often continue normal behaviors (including preening, feeding, caching of prey, and sleeping) within a few yards of observers, but studies of Mexican spotted owls have documented flushing and interruption of care for young in response to disturbance sources, such as hikers,

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chainsaws, and helicopters (FWS, 2003). For this reason, timing restrictions are often implemented for activities that could cause noise or visual disturbance. Timing restrictions may vary, depending on the type of activity, and whether the activity is planned for early or late in the breeding season (FWS, 2003).

Under current conditions, Energy Northwest uses Pipeline Road to access the intake facilities at Packwood Lake and monitor the pipeline about once or twice a week during the summer, and uses Latch Road about once a week during winter and spring. We conclude it is unlikely that continuance of the same types of activities at the same levels of intensity would cause disturbance to northern spotted owls, if any are present in the project area.

The only project-related recreational facilities are located near Packwood Lake. Visitors have been traveling to Packwood Lake for recreational purposes since at least 1917. Under current conditions, recreation facilities are limited to a parking lot, a vault toilet, a Forest Service guard station, and Forest Service trails (FS Trails 78 and 81) that lead into the Goat Rocks Wilderness. Visitors use dispersed recreation sites around the lake for camping, swimming, bank fishing, hiking and picnicking.

Energy Northwest is proposing to install a new composting toilet, an informational kiosk, and an interpretive sign near the lake. Energy Northwest would also provide maintenance for FS Trail 74 and Dyson Pass segment. This work would involve removing hazards, litter and graffiti; ensuring proper drainage, functional surfacing, and signage; and educating the public and enforcing Forest Service management regulations. Equipment needed to install the toilet, kiosk, sign, and conduct trail maintenance would be limited to ATVs and hand-tools. Noise disturbance would be minor and localized. The proposed activities are expected to improve visitor safety and recreational quality, but are not anticipated to increase the level of public use, and would therefore not increase the potential for long-term noise disturbance to northern spotted owls, if any are present in the project area.

Public vehicle traffic is prohibited on Pipeline Road, but it is open to ATV and non-motorized use. Public vehicle traffic is discouraged on Latch Road up to the gate and prohibited beyond the gate. Energy Northwest shares road maintenance responsibilities with the Forest Service on Snyder Road, Powerhouse Road, Pipeline Road, and Latch Road. Maintenance is performed according to Forest Service standards. All are identified as maintenance level 2, i.e., the roads are passable by high-clearance vehicles, drainage structures are maintained, and the tread accommodates speeds of 15 miles per hour or less. Routine maintenance is conducted using conventional equipment for grading and brushing, and may cause temporary, localized noise disturbance to northern spotted owls, if any are present in the project area. Once specific plans are developed, major road repairs would require consultation with the Forest Service, FWS

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and Washington Fish and Wildlife to determine whether preparation of a biological evaluation would be warranted, or whether timing restrictions should be implemented.

Energy Northwest proposes to improve fish passage in Snyder Creek and/or realign Snyder Creek. Energy Northwest also proposes to improve instream habitat conditions for fish in the lower 1.0 mile of Lake Creek, by placing large woody debris and gravel at locations that will be determined in consultation with the resource management agencies. These activities would likely require the use of conventional construction equipment (e.g., excavator, front-end loader, pick-up truck, dump truck, hand tools). Energy Northwest also proposes to construct a stream gage on lower Lake Creek at the Lake Creek Road bridge. Once specific plans are developed, these activities would also require consultation with the Forest Service, FWS, and Washington Fish and Wildlife to determine whether preparation of a biological evaluation is needed or whether timing restrictions should be implemented.

None of the proposed environmental measures would involve removal or alteration of critical habitat or other suitable habitat, and implementation of the threatened, endangered, and sensitive species management plan would prevent noise disturbance. Thus, we conclude that relicensing of the project would be not likely to adversely affect the northern spotted owl, and would not adversely modify designated critical habitat for this species.

3.3.4 Recreation and Land Use Resources


Regional Recreation

The Packwood Lake Hydroelectric Project is within the Gifford Pinchot National Forest, in the Cascade Mountain range in southwestern Washington. Mt. Rainier National Park is about 9 miles north, and Mt. St. Helens National Monument is about 30 miles southwest from the project. The Gifford Pinchot National Forest offers more than 1,400 miles of trails, 44 developed campgrounds, 10 horse camps, 16 snow-parks and dispersed recreation throughout most of the forest. Recreational opportunities within the project vicinity include hiking, biking, backpacking, horseback riding, ATV riding, hunting, fishing, boating, wildlife viewing, skiing, snowboarding, snowmobiling, and camping. The forest also provides opportunities for canoeing, kayaking, and rafting. Goats Rock Wilderness, located within the Gifford Pinchot National Forest and close to the project is about 105,600 acres, including 18 primary trailheads with 134 miles of trails within the forest. The Pacific Crest National Scenic Trail crosses the forest to the east about 8 miles from the project.

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Project Area Recreational Facilities

Recreational facilities within the project boundary are located in the Cowlitz Valley Ranger District of the Gifford Pinchot National Forest, about three quarters of which is within Goats Rock Wilderness (figure 3-12). Existing facilities associated with the project include a paved parking lot for about 30 to 45 vehicles and the Packwood Lake Trailhead (FS Trail 78) at the end of Snyder Road (FS Road 1260), both of which are located outside of the project boundary. Also outside the project boundary, is a well maintained single vault toilet at the parking lot. At the end of FS Trail 74, located outside the project boundary, is a parking area for ATV/motorized vehicles. A Forest Service guard station and a historic ranger station are also located outside the project boundary along FS Trail 78. An old well is located about 100 feet west of the historic ranger station; however, due to unacceptable water tests the well has been dismantled to prevent public use. Three toilets/outhouses are located within the designated Wilderness area along Packwood Lake, but are in poor condition and have not been serviced or maintained in years.

At Packwood Lake during 2006, Energy Northwest identified 43 informal dispersed recreational sites, including 20 sites within the non-Wilderness area, and 23 sites within the designated Goat Rocks Wilderness area (see figure 3-13). Dispersed recreational sites are typically used for overnight camping and day use activities, such as visiting the beach, swimming, bank fishing, hiking, and picnicking. The majority of dispersed campsites around Packwood Lake do not conform to Forest Service standards, specifically those within the Goats Rock Wilderness. Twenty dispersed recreation sites are within 100 feet of the shoreline; and 16 are greater than 600 square feet of barren core, which violates Wilderness regulation, as discussed further in Recreation and Land Use Resources.

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Figure 3-12. Packwood Lake area recreational access. (Source: Energy Northwest, 2008a)

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Figure 3-13. Packwood Lake area recreational facilities. (Source: Energy Northwest, 2008a)

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Trails providing access to Packwood Lake and the project area are FS Trail 74, Dyson Pass, and FS Trail 78 (see figure 3-12). FS Trail 74 is a 4.5-mile ATV trail that begins at the parking lot at the end of Snyder Road and ends at the shoreline of Packwood Lake. This trail crosses the project boundary along the pipeline and is within the project boundary near the intake structure. Public access on foot, horseback, bicycles, or by ATV is provided around Energy Northwest’s locked vehicle gate on Pipeline Road (FS Road 1260-066) and connecting FS Trail 74 and Dyson Pass. FS Trail 74 is maintained by Energy Northwest and provides primary access for operation and maintenance of the project’s intake facilities during the summer, including manholes for access to the pipeline during the annual maintenance shutdown. About 1.42 miles from the end of Pipeline Road, FS Trail 74 splits into two trail segments to negotiate the steep topography in the area. The Dyson Pass trail segment follows the higher route along the original construction road, and functions as the primary public access route for ATV travel to the lake. Energy Northwest accesses the project area about once a week via Pipeline Road and FS Trail 74.

FS Trail 78 at Packwood Lake is a 4.5-mile non-motorized trail that runs southwest and parallel to FS Trail 74. The trail reaches the shoreline of Packwood Lake then continues across a footbridge at the lake outlet, where the trail is within the project boundary, and continues on to Mosquito and Lost lakes. Access is provided to Packwood Lake and Goat Rocks Wilderness; bicycles and ATVs are prohibited, but hiking and horseback riding are permitted. FS Trail 81 veers off from FS Trail 78 and continues along the lakeshore, providing access to some of the dispersed recreational sites on the eastern side of Packwood Lake, and then continues outside of the project boundary to Upper Lake Creek. Both trails are maintained by the Forest Service. There are no roads leading directly to Packwood Lake; however, several roads, as discussed further in Land Use, are associated with the project.

Lake Creek flows northwest from Packwood Lake to a confluence with the Cowlitz River. Below Packwood Lake, the Lake Creek drainage is mostly within the Gifford Pinchot National Forest and private lands. Fishing season along Lake Creek occurs between June 1 and October 31; however, recreation at Lake Creek is minimal because it is confined within a steep canyon making access difficult. During the 2006 fishing season, Energy Northwest observed no one recreating along Lake Creek. Lake Creek is only accessible to the public at the Old Highway 12 Bridge. There are no developed recreational facilities along Lake Creek.

Recreational Use and CapacityEnergy Northwest estimates 2,535 people visited Packwood Lake during the peak-

season (Memorial Day weekend to Labor Day). An estimated 114 people in the spring off-season (April-May) and 588 people in the fall off-season (September-November) went to Packwood Lake. Total estimated recreation days at Packwood Lake are 5,080 during the peak-season, 134 during the spring off-season, and 1,024 during the fall off-

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season. Very few people are known to visit Packwood Lake during the winter season (December through March) when a deep snowpack normally exists. Peak season weekends/holidays attract an average of 46 people per day, whereas peak season weekdays average about 14 people per day. The spring season draws fewer people on the weekends with an average of 3 people per day and about 4.5 people per day on the weekdays. During fall season, an average of 17.5 people per day recreate on weekends and about 2.5 people per day on weekdays.

Energy Northwest also estimates that at dispersed recreational sites, about 54 percent of peak-season visitors to Packwood Lake were day users and 46 percent were overnight users. Eighty-three percent of spring off-season visitors were day users and 17 percent were overnight users. In the fall off-season, 40 percent of visitors were day users and 60 percent were overnight users. Energy Northwest estimates that during peak season, the estimated average capacity for dispersed recreation sites within Wilderness areas near Packwood Lake is 47 percent, while use at non-Wilderness areas is at nearly 75 percent capacity. Energy Northwest predicts that by 2030 non-Wilderness dispersed recreation would be at more than 90 percent capacity near Packwood Lake during peak-season weekends.

Energy Northwest also estimates the current peak-season weekend use of Pipeline Road/FS Trail 74 at an average of 18 people per day. According to Energy Northwest, FS Trail 78 gets the most visitor use. Table 3-22 shows the average daily use numbers for Pipeline Road/FS Trails 74 and 78.

Table 3-22. Average daily use of Pipeline Road/FS Trail 74 and FS Trail 78. (Source: EES, 2007d)

Season/ Day

Average No. People/DayPipeline Road/FS Trail 74 FS Trail 78

ATVMotor-cycle Bike Hike Horse Total Hike

Horse/ Pack Total

Peak SeasonWeekend/ Holiday

3 3 1 11 0.2 18.2 26.5 3.5 30

Weekday 0.2 0.5 1.2 4 0 5.9 7 2.5 9.5Spring- SeasonWeekend 0 0.5 0.5 0 0 1 3 0 3Weekday 1 0 0 3.5 0 4.5 0 0 0Fall-SeasonWeekend 1 1.2 0 2.5 0 4.7 12.5 2 14.5Weekday 0 0 0 0 0 0 3 0.7 3.7

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Energy Northwest predicts that by 2030 the Pipeline Road/FS Trail 74 will have an average of nearly 24 people per day during the busiest times of the year (peak-season weekend/holiday), and that in 2030, FS Trail 78 will have an average of nearly 40 people per day using the trail during an average peak-season weekend.

According to Watershed Geodynamics (2007), in the peak-season, Energy Northwest personnel represent about 3 to 13 percent of FS Trail 74 total use. Energy Northwest’s use of FS Trail 74 is substantially higher during the off-season than during the peak recreational season due to fewer visitors to the area. During the spring off-season (late April to late May), Energy Northwest personnel represent between 17 to 71 percent of total trail use. During late April to early May, Energy Northwest personnel used mostly Latch Road/FS Trail 74 due to access issues related to snow. During the fall off-season (September – November), Energy Northwest personnel represent between 9 and 83 percent of total trail use for FS Trail 74.

Energy Northwest estimates, based on 2006 surveys (EES, 2007d) done at Packwood Lake, visitors participated in a number of activities including the most popular activities during all seasons: visiting the beach, hiking, picnicking, camping, and wading/swimming. Other activities in order of popularity were shoreline fishing, boat fishing, photography, other types of boating, and hunting.

According to the 2006 surveys, visitors identified the need for new toilets (39 percent) and trash receptacles (11 percent). Energy Northwest’s Recreation Needs Analysis Report (EES, 2007d) identified human waste and trash as problems during the peak-season around Packwood Lake, particularly in the non-wilderness portion of the lake where visitor use is the greatest. Accumulations of trash and horse and human waste have been documented within 100 feet of the shoreline. Human waste also occurs near toilet structures that are no longer maintained.

Recreational use along Lake Creek is minimal due to the creek’s location within a steep canyon and its limited access. Energy Northwest conducted observations in 2006 during the fishing season (June 1–October 31) at Lake Creek and observed no visitors.

Land Use and Management The Packwood Lake Hydroelectric Project is located in Lewis County,

Washington. The project boundary includes a total of about 546 acres, including 511.65 acres of Forest Service managed land, 23.66 acres of Energy Northwest-owned land, 8.78 acres of Washington state lands, and 1.52 acres of Lewis County Public Utility District land. A Forest Service guard station is located along FS Trail 78, near Packwood Lake (see figure 3-13). Land use within the project boundary consists of recreation (wilderness and non-wilderness), power generation, rural, residential, commercial, and industrial.

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Land and Resource Management Plan

The Gifford Pinchot National Forest Land Resource Management Plan establishes management areas for lands within the forest along with goals, objectives, standards, and guidelines. The project boundary is located within several management allocations addressed by the Land Resource Management Plan, including Wilderness, Unroaded Recreation, Roaded Recreation, Visual Emphasis, and General Late Successional Reserve (see figure 3-14).

More than three quarters of the Packwood Lake shoreline is located within and adjacent to the designated wilderness area. The goal of the wilderness designation is to preserve the wilderness character, allowing for natural processes and providing opportunities for solitude, challenge, and inspiration. Primitive or unconfined type of recreational, scenic, scientific, educational, and historical uses are allowed within the wilderness designated areas. In addition, within the designated wilderness area, no camping is permitted within 100 feet of the lake shoreline.

Under the Land Resource Management Plan, the wilderness area has additional designations under the Wilderness Recreation Opportunity Spectrum. The spectrum provides a way to describe the variations in the degree of isolation from the sounds and influences of people, and the amount of recreational visitor use. The wilderness area along the eastern side of Packwood Lake is designated as Transition in the Wilderness Recreation Opportunity Spectrum, and the wilderness along the western side of the Packwood Lake is designated as Pristine.

Transition Wilderness Recreation Opportunity Spectrum is generally characterized by an unmodified environment; however, the concentrations of visitors can be moderate to high at various times. The Wilderness Recreation Opportunity Spectrum management prescription for the transition class directs that the average number of people encountered each day should be 24 or fewer and that no more than two campsites should be visible from a given site. Transition Wilderness Recreation Opportunity Spectrum also requires that recreational sites not to exceed 600 square feet of vegetation loss.

Pristine Wilderness Recreation Opportunity Spectrum is characterized by an essentially unmodified, natural environment with low concentrations of visitors and minimal human use. These areas have a high opportunity for isolation, solitude, exploration, risk, and challenge. The Wilderness Recreation Opportunity Spectrum management prescription for the pristine class directs that the average number of people encountered each day should be limited to an average of three per day and that no other campsites should be visible from a given site.

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Figure 3-14. Land use designation within the Packwood Lake area. (Source: Energy Northwest, 2008a)

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Outside of the designated wilderness area, Packwood Lake’s northern shoreline and lands to the north of the lake, including the intake and upper pipeline route, are located within the Land Resource Management Plan designated Late-Successional Reserve and Unroaded Recreation without Timber Harvest management category. The management goal of the Late-Successional Reserve is to protect and enhance habitat for late-successional and old-growth related species, including any overlapping management designation with goals to provide dispersed recreational opportunities in a semi-primitive, undeveloped setting, and visually natural setting. Several management allocations overlap the Late-Successional Reserve designation, including Unroaded Recreation without Timber Harvest, Roaded Recreation without Timber Harvest, Visual Emphasis, and Utility. These four management categories are designated “administratively withdrawn areas.” Administratively withdrawn areas include wildlife, recreation, visual, and other areas not managed to provide timber outputs. Where administratively withdrawn areas overlap the Late-Successional Reserve, standards and guidelines from both designated areas may apply.

Under the Unroaded Recreation without Timber Harvest allocation, the resource management goal is to provide a variety of dispersed recreational opportunities in a semi-primitive or undeveloped setting, with an emphasis on maintaining a predominantly natural or naturally appearing environment. The Recreation Opportunity Spectrum class assigned to this management area is semi-primitive motorized. Under this class, as designated by the Land Resource Management Plan for non-wilderness lands, motorized use is permitted in a moderate to large area characterized by a predominantly natural environment, with low interaction, and little site modification. In this class, off road vehicle use is limited to designated trails. Semi-primitive motorized areas are managed for dispersed recreation and should produce no more than 15 encounters between groups of visitors (defined as no larger than 25 persons) per day for a total of no more than 400 individuals each day. Campsites should be located at least 100 feet away from lakeshores, streamsides, and trails and no more than three other campsites should be visible from a given campsite.

The middle section of the pipeline route is located within the Roaded Recreation without Timber Harvest management category. These management area lands provide a variety of dispersed recreational opportunities in areas conveniently reached by auto, and are managed to provide for interaction with a near-natural environment. The Recreation Opportunity Spectrum class for this management area is Roaded Natural. This class is characterized by predominantly natural appearing environment with evidence of humans, moderate site and resource modification, and conventional motorized use.

The lower section of the project pipeline route is within a Visual Emphasis management area. The management goal of this area is to provide visually natural or near-natural landscape as viewed from the designated travel route or use area. Relevant standards and guidelines for this category allow for enhancing viewing opportunities by

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opening views to such features as distant peaks, unique rock forms, and unusual vegetation. The Recreation Opportunity Spectrum class for the Visual Emphasis management area is Roaded Natural.

The powerhouse site is located within a Utility management category. The Recreation Opportunity Spectrum class for this management area is Rural, which is characterized by substantially modified site and natural environment. The management goal of the Utility area is to provide effective and economical utilities with the least impact on the various natural resources involved.

The Land Resource Management Plan also includes management strategies related to the Northwest Forest Plan Aquatic Conservation Strategy that designate watershed and riparian reserves. These riparian reserves are areas where special care is taken to assure protection of watershed and riparian processes and functions. For Packwood Lake, the riparian reserve consists of the lake itself and designated areas along the lake shoreline. Within riparian reserves, new facilities, including trails, and dispersed recreational sites would need to be designed to meet the Aquatic Conservation Strategy; whereas existing facilities would be examined to ensure the facilities do not prevent the attainment of Aquatic Conservation Objectives. Any facilities that retard or prevent attainment of Aquatic Conservation Objectives would be adjusted, and then eliminated if adjustment measures such as education, use limitation, traffic control devices, increased maintenance, relocation of facilities, and/or site closures are proven to be ineffective.

Wild and Scenic Rivers

There are two congressionally designated Wild and Scenic Rivers within the Gifford Pinchot National Forest: Klickitat and White Salmon. These rivers are tributaries of the Columbia River and located more than 50 miles outside the project boundary and the Cowlitz River Basin but within the regional area. The Klickitat River drains out of the Goat Rocks Wilderness and has 10 miles of wild and scenic designation between Wheeler Creek and the confluence with Columbia River. The White Salmon River is has 29 miles of designated waters and is located south of the project.

Lewis County Comprehensive Plan

Project lands located within rural Lewis County jurisdiction, including most of the tailrace from the project powerhouse site to the Cowlitz River and part of the transmission line, traverse through open rural, residential, commercial, and undeveloped and rural timbered lands and are under management guidelines of the Lewis County Comprehensive Plan.

Lewis County designates a Rural Development District that is located along the project tailrace and consists of a mixed-use zoning district that allows a number of different land uses such as single family residential, resource uses, and limited types of

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commercial activity. Also located along the tailrace is a designation of Small Town Mixed Use, which allows commercial and residential activities and is designed to ensure that development is consistent with the surrounding uses, existing public facilities, and character of the area.

As part of the Lewis County Comprehensive Plan, recreational policies and goals encourage opportunities for recreational and tourist activities that are well managed with respect to the preservation of natural resources. Lewis County encourages the multiple use of forest land, which acknowledges the primary use and provides for other compatible uses, including air and water quality; fauna, flora, and their habitats; viewsheds; watersheds; and dispersed recreation.

Roads

Roads within the vicinity of the project include Powerhouse Road (FS Road 1260-013), Snyder Road (FS Road 1260), Pipeline Road (FS Road 1260-066), and Latch Road (FS Road 1262) (see figures 2-2, 3-12, and 3-15). Table 3-23 summarizes Energy Northwest’s assessment of the portion of the roads used by Energy Northwest, the maintenance level, and Energy Northwest’s estimated share usage of the road.

Table 3-23. Summary of roads in project vicinity and Energy Northwest’s usage. (Source: Energy Northwest, 2008b, modified by staff)

Forest Service Road No. and Name

Maintenance Levela Licensee % Share Miles of Road

Road 1260 Snyder Road

2 1.3% 4.3

Road 1260-0 13Powerhouse Road

2 80% 0.25

Road 1260-066Pipeline Road

2 1.3% 1.3 (past gate)

Road 1262Latch Road

2 50% 2.2 (past gate)

a Maintenance levels define the level of service provided by, and maintenance required for, a specific road. Maintenance level 2 requires the road is passable by high-clearance vehicles, drainage structures are maintained, and the tread is maintained to accommodate speeds of 15 mph or less. Traffic is normally minor, usually consisting of one or a combination of administrative, permitted, dispersed recreation, or other specialized uses. Log haul may occur at this level. Appropriate traffic management strategies are either to (1) discourage or prohibit passenger cars, or (2) accept or discourage high clearance vehicles.

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Snyder Road (FS Road 1260) is a double-lane paved road that extends 5.8 miles from Highway 12 to the parking lot at FS Trail 78. Lewis County has jurisdiction for the road segment leading to the Forest Service boundary (mile post 0 to 0.83) and maintains the road to mile post 1.2. Snyder Road is designated and maintained by the Forest Service as a maintenance level 2 road from mile post 1.2 to the trailhead at mile post 5.8. The Forest Service maintains this section of Snyder Road. Maintenance level 2 means the road is passable by high-clearance vehicles, drainage structures are maintained, and the tread is maintained to accommodate speeds of 15 mph or less. The parking area at the end of Snyder Road is utilized by hikers, horseback riders, and ATVs. According to Watershed Geodynamics (2007), Energy Northwest use of Snyder Road, accounts for between 0.28 and 1.08 percent of total use in the peak-season, and between 0.69 and 6.1 percent of total use during the off-seasons. The highest percentage of Energy Northwest use of Snyder Road was in early spring when relatively fewer visitors use FS Road 1260.

Powerhouse Road (FS Road 1260-013) is gated where it begins just off the end of the county road and extends 2.5 miles. The only vehicular traffic is by Forest Service and Energy Northwest authorized personnel. Travel on this road is infrequent and Energy Northwest uses less than 0.5 mile of this road to access the penstock, raw water, and constant head tanks.

Pipeline Road (FS Road 1260-066) is a single-lane native surface road with wide spots, is gated at milepost 0.03 and is 1.3 miles long. This road is located near the end of Snyder Road beginning at milepost 5.55. Pipeline Road and FS Trail 74, including the Dyson Pass segment, are maintained by Energy Northwest and are used as primary access routes for operation and maintenance of the project’s intake facilities during the summer. Energy Northwest uses Pipeline Road and connecting FS Trail 74 about once a week, to check on intake facilities and perform needed maintenance. There are also several manhole sites for pipeline access that are used by Energy Northwest staff during the annual maintenance shutdown. Access is sometimes restricted during winter and spring months due to snow conditions. Public access on foot, horseback, bicycles or by all terrain vehicles (ATVs) is allowed by the Forest Service around Energy Northwest’s locked vehicle gate on the Pipeline Road.

Latch Road (FS Road 1262) is a single-lane gravel road with few turnouts. This road begins 1.66 miles up Snyder Road. Latch Road is gated and locked approximately 2.4 miles from the junction with Snyder Road. No public vehicular traffic is permitted behind the gate. From this gate, it is another 2.2 miles to where the road ends and a short 1 mile access trail connects to FS Trail 74. Energy Northwest primarily uses Latch Road and Latch Trail (the access trail connecting FS Trail 74), typically about once a week to access the intake facilities in months when snow makes access difficult on Pipeline Road and FS Trail 74 and Dyson Pass. Forest Service trail crews also use this road for working on trails in the Packwood Lake area.

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Figure 3-15. Packwood Lake area recreational access (detailed map). (Source: Energy Northwest, 2008a)

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Project Operations and Reservoir LevelsProposed changes in project operations, including drawdowns and instream flows,

affect reservoir levels, which could affect boat access, fishing, and the quality of recreational experiences at the project. These changes in project operation are described in section 3.3.1.2.

Under existing conditions Energy Northwest operates with a maximum reservoir level of 2,858.5 feet msl, at the top of the spillway, and a minimum reservoir elevation of 2,849 feet msl year round. Energy Northwest conducts an annual maintenance outage during the first 3 weeks in October with a 2-week-drawdown period occurring the last 2 weeks of September to achieve the minimum allowable lake level of 2,849 feet msl. Between May 1 and September 15, Energy Northwest maintains a reservoir level of 2,857 feet msl plus or minus 6 inches. During the remainder of the year, Energy Northwest allows lowering of the lake level not more than 8 feet below the summer lake level down to a minimum elevation of 2,849 feet msl.

Energy Northwest proposes to (1) eliminate the maximum surface elevation of 2,858.5 feet msl in the summer, which is at the crest of the spillway; (2) conduct the annual maintenance outage from August 15 through September 15 without the pre-outage drawdown; (3) maintain a minimum lake level of 2,856.5 feet msl from May 1 through September 15, without the summer limit of 2,857 feet msl plus or minus 6 inches; (4) maintain a minimum lake level of 2,849 feet msl from September 16 through April 30; and (5) increase instream flows in Lake Creek, as discussed in section 3.3.1, Aquatic Resources, including flows of between 10 to 20 cfs during May through October.

Consistent with Energy Northwest’s proposal, the Forest Service specifies Energy Northwest maintain a minimum elevation of 2,856.5 ft msl between May 1 – September 15; and 2,849 ft msl from September 16 – April 30 of each year, as well as conduct an annual maintenance outage without drawdown from August 15 – September 15, at the latest. In addition, the Forest Service specifies that Energy Northwest should not decrease lake levels by more than 1 foot per day.

Our Analysis

The elimination of the maximum surface elevation would not affect recreational resources including boating access, use, and fishing opportunities on the reservoir. Energy Northwest’s proposal to eliminate the summer upper elevation limit of 2,857 feet msl, which would allow for higher water levels, also would have no impact on boater access or recreation. At higher water levels, boat ramps still would be accessible and proposed conditions would not differ much from current conditions; therefore, we find that recreation would not be affected by the elimination of water elevation limits.

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As proposed, Energy Northwest would conduct the annual maintenance outage earlier in the season but without the pre-outage reservoir drawdown to 2,849 feet msl that occurred before the outage under existing conditions. The elimination of the pre-outage drawdown would allow the lake levels in August and September to remain higher than under existing conditions especially in September, which would benefit recreation and boater access. This change also would allow boaters to access certain areas of Packwood Lake later in the season for fishing or other recreational activities. Under current conditions, access may have been difficult because of shallow water and inaccessible boat ramps. According to the Forest Service, this also would allow for recreational access to the north and south shorelines of Packwood Lake.

As proposed, Energy Northwest would increase instream flows by 7 to 17 cfs during the primary recreational season (May through September) above the current minimum instream flow of 3 cfs. We conclude this would have a minimal effect on recreation at Lake Creek. Lake Creek is in a steep canyon, accessibility is nominal, and Energy Northwest does not propose to increase or improve accessibility to this area.

Recreation Management PlanEnergy Northwest proposes to implement the Recreation Management Plan

included in its June 6, 2008, response to the Commission’s request for additional information. The plan was developed in collaboration with the Forest Service and reviewed by stakeholders. The Forest Service filed the same preliminary 4(e) condition.

The Recreation Management Plan includes provisions for site improvements including a composting toilet and an informational kiosk, measures to conduct operation and maintenance measures or annual funding of a seasonal employee to address effects of dispersed recreational use, and trail and road maintenance measures (discussed in detail below). The Recreation Management Plan also includes (1) an annual internal meeting evaluating any operational changes, facility modifications, and resource protection plans that involve limiting public access, and implementing a monitoring program; (2) an implementation schedule that would start within 1 year of license issuance and continue over the term of the new license; (3) an annual meeting between Energy Northwest and the Forest Service to review the previous year’s achievements and discuss and approve a final work plan for the following year; (4) an annual implementation report filed each year to document the annual meeting between Energy Northwest and the Forest Service; and (5) a review and update of the Recreation Management Plan every 6 years, in coordination with the FERC Form 80. In addition, the Recreation Management Plan includes measures for yearly monitoring and adaptive management with the Forest Service, as discussed further in Resource Coordination. Energy Northwest would provide funding to implement all mitigation measures identified in the Recreation Management Plan.

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Our Analysis

Currently, management of Packwood’s recreational resources is guided by Forest Service management directions, not a recreation plan. As proposed, the Recreation Management Plan was developed to guide management requirements and maintenance responsibilities of dispersed recreational areas, develop coordination and implementation schedules, and comply with standards and regulations. The proposed plan would provide a framework for Energy Northwest to implement the recreational site improvements and coordinate management of recreational resources with the Forest Service. Communication and coordination between Energy Northwest and the Forest Service would ensure the achievement of resource goals and objectives set forth in the Recreation Management Plan. The annual review and updates every 6 years would be beneficial for future recreation by accommodating changes in demand and recreational preferences over the years.

Recreational Site ImprovementsAs part of the Recreation Management Plan, Energy Northwest proposes the

following improvements: (1) design and construct a composting toilet within 3 years of license issuance; (2) provide annual funding for monthly operation and maintenance, including aeration and the addition of organic material of the composting toilet; (3) provide for operation and maintenance measures or annual funding of a seasonal employee to address effects of dispersed recreational use, including providing an improved sense of security and safety for visitors, cleanliness of area, responsiveness to visitors’ needs, and improved implementation of Forest Service standards and guidelines; and (4) design and install an informational kiosk at the end of Snyder Road at the existing parking lot within 1 year of license issuance, with regular maintenance of the signage over the term of a new license. Figures 3-13 and 3-14 show the proposed location of the composting toilet and kiosk.

As part of its Historic Properties Management Plan (see section 3.3.6, Cultural Resources), Energy Northwest proposes to install an interpretive sign at the ATV parking area. This sign would relay information on prehistory and history to increase public awareness of the prehistoric and historic properties at Packwood Lake and the need to preserve these archaeological and historical resources.

Our Analysis

Currently, there is a single vault toilet at the Packwood Lake Trailhead. There are also three additional Forest Service toilets/outhouses along Packwood Lake, near the end of FS Trail 74, that are in poor condition and are no longer maintained. Energy Northwest’s proposed measure to install a composting toilet and provide annual operation and maintenance would replace old toilet facilities at the end of FS Trail 74 and benefit site users by improving sanitation in the project area.

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Energy Northwest proposes either to provide operation and maintenance measures or fund a seasonal employee to address effects of dispersed recreational use occurring at the project. The Commission’s policy on hydropower settlements50 states that the Commission has no way of ensuring that the hiring of personnel paid for by the licensee (in this case funding a seasonal employee), actually would accomplish a project purpose or ameliorate a project effect. However, the Commission can enforce specific measurable actions, such as operations and maintenance measures. Therefore, implementing Energy Northwest’s proposed operation and maintenance measures, such as maintenance of project lands and project recreational facilities to address litter and other associated potential effects of dispersed recreational use within the project boundary, would provide the means for a measureable action which the Commission could enforce. These operation and maintenance measures, such as litter control, would help to mitigate potential adverse effects of dispersed recreational use within the project boundary. If, as part of this operations and maintenance, there is an increased presence in the project area, this also would provide the opportunity for an improved sense of security and safety for recreational visitors at the project. While improved implementation of Forest Service standards and guidelines regarding dispersed recreational use would be beneficial, enforcement of the Forest Service regulations would be outside of the jurisdiction and responsibility of the licensee.

The proposed measure to install an informational kiosk at the Packwood Lake Trailhead and parking area would improve visitor understanding of Forest Service rules and regulations associated with dispersed recreation. The addition of a working and maintained toilet would help to address and improve sanitation problems at dispersed recreational sites.

The proposed measure to install an interpretive sign, as included in the Historic Properties Management Plan, at the ATV parking area along FS Trail 74, would improve visitor understanding and education of the historical values of the project area.

Currently, the proposed locations for the composting toilet, the historic interpretive sign at the ATV parking area, and the informational kiosk, are all located outside of the existing project boundary. These new facilities would provide project-related facilities and enhance the recreational experience at the project; therefore, we recommend these recreational facilities be brought into the project boundary to ensure installation, operation, and maintenance for the term of a new license.

Trail Maintenance Trails provide access to the Packwood Lake and a lack of trail maintenance could

affect public access and the overall experience to Packwood Lake and the vicinity of the project. As part of the its proposed Recreation Management Plan, Energy Northwest

50 Policy Statement on Hydropower Licensing Settlements, Docket No. PL06-5-000, issued September 21, 2006.

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proposes to maintain FS Trail 74 and the Pipeline Bypass Trail (Dyson Pass) including drainage, trail maintenance, and vegetation management over the term of a new license. As part of the trail maintenance measures, Energy Northwest would: remove litter and graffiti; identify, document, and remove hazards from the trails; enforce and educate the public regarding Forest Service management regulations; maintain signage; inspect trails and associated structures (i.e., culverts and retaining walls); and conduct necessary maintenance to maintain functionality of the trail.

Our Analysis

FS Trail 74 is used and maintained by Energy Northwest as primary access to the project intake facilities. This trail also provides recreational access to project-related recreational resources. Implementation of Energy Northwest’s proposed trail maintenance measures for FS Trail 74 and Dyson Pass would provide for ongoing maintenance and improvement of this access trail for people using the recreational facilities at the project reservoir, and for Energy Northwest’s access to project features.

Energy Northwest also uses the short Latch Trail segment, which provides access from the end of Latch Road to FS Trail 74, to access the project facilities during the winter and spring period (see Road Maintenance discussion below). Therefore, maintenance of Latch Trail by Energy Northwest also would help ensure that Energy Northwest would maintain access to project facilities.

While Energy Northwest’s proposed trail maintenance measures (such as removal of hazards and maintenance to maintain the functionality of the trail) would be necessary to maintain access to project facilities, Energy Northwest’s proposed enforcement and education of the public regarding Forest Service management regulations is not a project-related action or responsibility of a project licensee, and therefore, would not be necessary to maintain access to project facilities or for project purposes.

Road MaintenanceRoads provide access to the project area and dispersed recreation and a lack of

maintenance could affect public access and the overall experience. As part of the Recreation Management Plan, Energy Northwest proposes to develop and implement a road maintenance plan, in consultation with the Forest Service, for various roads within the vicinity of the project, including: Snyder Road (FS Road 1260), Powerhouse Road (FS Road 1260-013), Pipeline Road (FS Road 1260-066), and Latch Road (FS Road 1262 above the gate). Energy Northwest proposes to coordinate the road maintenance measures with the Integrated Weed Management Plan, as discussed in section 3.3.2, Terrestrial Resources.

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Our Analysis

Currently, road management and maintenance activities are shared by Energy Northwest, the Forest Service, and Lewis County. Energy Northwest’s proposed road maintenance plan and associated measures would improve road management within the project vicinity, protect natural resources, provide reasonable project and public access, define maintenance responsibilities, assess road conditions, and establish an opportunity for review of road maintenance measures. The road maintenance plan would establish a forum for coordination of road maintenance activities between Energy Northwest and the Forest Service and would identify Energy Northwest’s responsibilities for maintaining roads used for project operation and maintenance.

With respect to the roads to which the management measures should apply, we note that the project boundary does not currently enclose all of the roads. The roads cross the project boundary at different points but none of the four listed above are entirely within the boundary. Energy Northwest uses portions of some of these roads to access project facilities for operation and maintenance purposes; however, the roads are also used by the Forest Service and public recreational users. In the summer, Energy Northwest uses Pipeline Road to access project intake facilities and monitor the pipeline about once or twice a week. In the winter and spring, Energy Northwest uses Latch Road, including a short trail segment (Latch Trail) and FS Trail 74 and Dyson Pass about once a week to access the project facilities due to snow conditions limiting access to Pipeline Road. Energy Northwest uses about a half a mile of Powerhouse Road, from the gate to project facilities, to access the penstock, raw water, and constant head tanks. Energy Northwest’s maintenance responsibilities for roads used primarily for project purposes would help to ensure that access is maintained to project facilities over the term of a new license.

Resource CoordinationEnergy Northwest proposes to prepare and file a resource coordination plan, after

coordination with the Forest Service and other agencies, within 1 year of license issuance, as specified by the Forest Service.

As described by the Forest Service, the plan would include: (1) an annual resource coordination meeting; (2) a rolling 3-year annual report/work plan that includes a final annual report of all management activities and results in the preceding calendar year, a draft and final current year work plan for activities planned for the following year, and a consultation summary; (3) documentation of the requirements, tasks, methods, and reports related to monitoring the effects of project operations and facilities on natural and/or social resources and effectiveness of protection, mitigation, and enhancement measures; (4) a revision of implementation strategies and methods to reflect improvement in sampling procedures and/or changes in regulations or environmental conditions; (5) adaptive management measures when resources objectives are not met; (6) documenting

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and reporting any deviations from the approved plans or terms and conditions; (7) routine updates of the resource coordination plan; (8) the development of standard operating protocols and processes to resolve disagreements regarding the implementation process; and (9) a designated environmental coordinator to communicate implementation activities with Energy Northwest and the Forest Service.

Our Analysis

Energy Northwest proposes to provide an opportunity for the Forest Service and other agency involvement in ongoing resource planning and coordination through annual meetings for the project. A resource coordination plan would benefit all entities by establishing a process for exchanging information and coordinating efforts for operation and maintenance activities.

Energy Northwest’s proposed approach for periodic plan reviews and updates would enable the resource coordination plan to reflect changes in resource and recreational use patterns, and accommodate any changes in agency management direction that may occur during the term of a new license.

Fire Prevention Plan Dispersed recreational use at Packwood Lake and Lake Creek could potentially

pose a fire risk. In addition, hydroelectric operation and the presence of project facilities such as generators, construction equipment, and transmission lines could contribute to fire danger in the project area.

Energy Northwest proposes as part of the resource coordination plan to prepare and file within 1 year of license issuance a fire prevention plan after consultation with the Forest Service and other appropriate agencies for National Forest System lands adjacent to the project boundary that are affected by the project. The Forest Service specified an identical preliminary condition.

The fire prevention plan would require Energy Northwest to (1) analyze fire prevention needs to ensure that prevention equipment and personnel are available; (2) identify fire hazard reduction measures (e.g., eliminating ladder fuels, reducing fuel loading); and (3) provide the Forest Service a list of the location of available fire prevention equipment and the availability of project personnel.

Our Analysis

The development of a fire prevention plan, after consultation with the Forest Service, which incorporates both the measures proposed by Energy Northwest and specified by the Forest Service, would provide the means for effective fire prevention and management strategies. These strategies would include an evaluation of the location and

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availability of equipment and personnel for emergency situations. The fire prevention plan also would identify fire hazard reduction measures and public safety measures associated with project recreation and operation. It would identify and coordinate emergency response preparedness and reporting measures associated with fire management, as well as identify the cooperative roles and responsibilities of Energy Northwest and the Forest Service in managing fires.

3.3.5 Aesthetic Resources

3.3.5.1 Affected EnvironmentThe project is primarily located in the Gifford Pinchot National Forest within the

Lake Creek drainage. The project area is characterized by forested slopes and rugged and glaciated peaks in the upper elevations. Packwood Lake is about 1.5 miles long and 0.5 mile wide and is located at the end of a long glacially carved valley. Its main source of water is glacier-fed Upper Lake Creek. The forest above Packwood Lake harbors old-growth forest where Western hemlock, Western red cedar, and Douglas fir are the most common large varieties. Below Packwood Lake, Lake Creek flows through a steep canyon and through the Cowlitz River valley floodplain, where the community of Packwood is located. The combination of various landforms, vegetation, and rock and water features produces a distinctive and highly scenic landscape in the project area.

Aesthetic resource management in the Gifford Pinchot National Forest is guided by the Land Resource Management Plan Scenery Management System, which sets visual quality objectives designed to protect or enhance scenic recreational values. Table 3-24 shows the visual quality objectives associated with the project.

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Table 3-24. Forest Service Visual Quality Objectives. (Source: Energy Northwest, 2008a)

Visual Quality ObjectiveLocation Relative to the Project

Boundary/Project Features

Preservation – allows ecological changes only. Management activities, except for very low visual impact recreational activities, are prohibited. Applies to Wilderness and primitive areas. In general human activities are not detectable to the visitor.

Over three quarters of Packwood Lake shoreline (the project boundary) is adjacent to the Wilderness boundary (south side of the lake). Some dispersed recreational sites are located within the wilderness designation.

Retention - Human activities are not evident to the casual visitor. Activities may only repeat form, line, color, and texture which are frequently found in the characteristic landscape. Changes in their qualities of size, amount, intensity direction, pattern, etc., should not be evident.

Project specific standards and guidelines:

• Ground disturbance by any activity should be rehabilitated within 1 year to natural appearance.

• Buildings should be located and designed to blend with the natural character of the land.

• Revegetation for visual quality and erosion control should be completed within one season after construction.

• Roads may not dominate the natural form, line, color and texture.

• All utility rights-of-way should be located and designed to blend with natural appearances.

• Transmission towers will be screened or

Includes Packwood Lake and the intake canal, concrete drop structure (dam), and control building on Lake Creek and the upper portion of the pipeline route, which also provides motorized (ATV) access to Packwood Lake.

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Visual Quality ObjectiveLocation Relative to the Project

Boundary/Project Featuresdesigned to blend with their surroundings.

Partial Retention – Human activities remain visually subordinate to the characteristic landscape. Activities may repeat form, line, color, or texture common to the characteristic landscape, but changes in their qualities of size, amount, intensity, direction, pattern, etc., remain visually subordinate to the characteristic landscape.

Activities may also introduce form, line, color, or texture which are found infrequently or not at all in the characteristic landscape, but they should remain subordinate to the visual strength of the characteristic landscape.

Includes the majority of the project pipeline route (including the lower section of the access route to Packwood Lake), surge tank, and the penstock.

Modification – Human activities may visually dominate the original characteristic landscape. However, activities of vegetative and land form alteration must borrow from naturally established form, line, color, or texture so completely and at such a scale that its visual characteristics are those of natural occurrences within the surrounding area or character type.

Project specific standards and guidelines:

• Revegetation for visual quality and erosion control should be completed within one season after construction.

Powerhouse and associated facilities.

3.3.5.2 Environmental EffectsProject Operations and Reservoir Levels

Project operations related to reservoir levels, including drawdown and instream flows, could affect the visual quality of the reservoir and adjacent project lands.

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Energy Northwest proposes to eliminate the maximum surface elevation including the summer maximum elevation. Energy Northwest also proposes to conduct the annual maintenance outage from August 15 through September 15 without drawdown. A minimum surface elevation of 2,849 feet msl would be maintained, except between May 1 and September 14 when a minimum elevation of 2,856.5 feet msl would be maintained. Energy Northwest also proposes to increase instream flows in Lake Creek (see discussion in sections 3.3.1, Aquatic Resources, and 3.3.4, Recreation and Land Use Resources).

Our Analysis

Under current project operations, from May 1 through September 15, Energy Northwest maintains Packwood Lake at its approximate natural elevation (2,857 feet msl plus or minus 6 inches). During the remainder of the year, the lake level is at a minimum elevation of 2,849 feet msl. As proposed, reservoir levels would be maintained higher for longer and winter drawdown would occur more gradually than under current conditions. Maintenance of a higher reservoir elevation in the summer and a more gradual drawdown in the winter would enhance the aesthetic quality of the area by reducing the amount of shoreline that is visible around Packwood Lake.

An increase in instream flows in Lake Creek would have little affect on aesthetic resources considering the area is very remote and very few visitors visit this section of the project. However, increased flows typically would increase the aesthetic value of the area by decreasing the amount of shoreline visible.

Higher water levels for Packwood Lake and increased flows on Lake Creek would be in compliance with all Forest Service visual quality objectives.

Project Facilities and Maintenance

Project facilities and maintenance could affect aesthetic resources by introducing new elements into the viewshed.

As discussed in Recreation Resources, site improvements, including a composting toilet and an informational kiosk would be installed around Packwood Lake. As a provision of the Recreation Management Plan, Energy Northwest proposes to consult with the Forest Service about appropriate paint colors and materials to make the project developments blend with the surrounding environment to minimize the effects on aesthetic resources.

Our Analysis

Energy Northwest’s proposal to consult with the Forest Service, during repair and maintenance of project intake structures and facilities, about appropriate building materials and colors that would blend into the surrounding environment would benefit

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users in the area by maintaining the aesthetic Forest Service visual quality objectives. Colors and building materials that blend in with the surroundings would minimize the visual effect the project has on visitors in the area by making them less noticeable. The viewpoint would not be altered; therefore, any effect on aesthetic resources by project facilities would be minimal.

Also, as proposed and as part of the Recreation Management Plan, Energy Northwest would hire a seasonal employee to enforce rules and clean up at dispersed recreational sites. The seasonal employee would improve sanitation by cleaning up litter and educate visitors of the new vault toilet facility, thus improving the overall scenic quality of the area.

3.3.6 Cultural Resources


Cultural Background

The archaeological record demonstrates human use of the upper Cowlitz Watershed beginning about 7,000 years ago. The most important resources were deer and fish, but elk, mountain sheep, snowshoe hare, mountain beaver, and grouse also were taken. Plant resources included elderberries, huckleberries, and hazelnuts. Trade with other groups for materials such as clamshell and Olivella shell beads from coastal areas, obsidian from Oregon, and other types of tool stone from the crest of the Cascade Range also occurred.

Between 3,900 and 3,500 years ago, the eruption of Mount St. Helens resulted in human abandonment of the area. The eruptions may have decimated the landscape, killing trees and burying lower vegetation under as much as a meter of pumice, and choking streams with sediment.

People began to return to the area approximately 1,500 years ago. Settlement occurred in previously used sites and also in new locations. Subsistence strategies may have changed with an emphasis on the harvesting, processing, and storage of key resources during particular seasons at specific locations. Such a change in strategy may have resulted in the occupation of semi-permanent villages during the winter months and the use of temporary residential and procurement/processing sites during the milder seasons. This adaptation to environmental conditions supported larger groups of Native American inhabitants.

During the early nineteenth century, the project vicinity was located within the territory of the Taidnapam, or Upper Cowlitz Indians. Typical Taidnapam settlements were located along the upper Cowlitz River, and fishing locations were likely located near Packwood. Trade with the Yakima Indians occurred near Packwood. Jim Yoke, a

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Taidnapam elder who was born in the 1840s and living in the Packwood area, described the original name of the lake as Cuyu'ik. Packwood Lake was important to local native people for its resident trout known as ay'witcin or aytmín. Several seasonal residential locations are located at the lake.

In 1861, James Longmire and William Packwood were the first non-natives to visit the Packwood area. William Packwood is credited with the Euro-American discovery of Coal Creek and Lake Creek in 1869. By 1900, others were using the lake for fishing and other recreational activities. In 1906, the Portland Railway Light and Power Company (now Portland General Electric) initiated surveys for the construction of hydroelectric facilities at Packwood Lake. Additionally, the Valley Development Company planned to divert water from area streams for storage in Packwood Lake and to build a 100-foot-high dam near the outlet of the lake. In the Valley Development Company plan, a flume would transport water from the lake to a generating plant near the present-day community of Packwood. Construction of the facilities began in 1910, but was later suspended when the city of Tacoma determined that the project was not feasible. Construction undertaken at that time included a trail to the lake and a temporary power plant placed on Snyder Creek intended to provide electricity to the construction camp on the outskirts of Packwood, then called Lewis in honor of the Valley Development Company’s president. This plant was dismantled in 1920 and moved to Portland. Four log buildings also were constructed in 1910 near the outlet of Packwood Lake. These structures included a cookhouse, two bunkhouses, and an office building.

Until 1905, trails in the Packwood area were primarily Indian trails, although several were constructed by prospectors or surveyors. Between 1907 and 1911, the Valley Development Company constructed many miles of additional trails. Roads and a tramway also were constructed. The Forest Service established a public campground at Packwood Lake in 1917 and also obtained ownership of all Valley Development Company holdings. A former Valley Development Company cabin was used by the Forest Service for various activities.

In 1921, a tent camp resort was developed near the Packwood Lake outlet. In 1936, new owners built a large cedar lodge housing a store, kitchen, and dining area. The resort also included 11 rental cabins, a floating dock, and a boathouse. Following construction of the project, the Forest Service built a new guard station at the lake. The lodge and other buildings associated with the tent camp were damaged by fire in 1972, and most of the original cabins were removed in 1974. However, operation of the resort’s boat concession, with boathouse and dock, continued until 1991.

Archaeological and Historic-Era Resources

Gifford Pinchot National Forest and Historic Research Associates undertook pre-field archival research to identify previous studies, site locational data, and other

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information that would be helpful in developing the cultural history of the area. Using this information, they prepared sensitivity maps of the project’s area of potential effects based on existing predictability model criteria.

An intensive archaeological survey was undertaken using survey methods adopted by the Gifford Pinchot National Forest. These methods included shovel/trowel “scrapes” and shovel probes in most high probability areas to identify culturally modified sediments and underlying materials. All archaeological sites identified within the area of potential effects were evaluated for listing on the National Register of Historic Places. Table 3-25 lists all sites previously reported within or directly adjacent to the area of potential effects, whether or not the field survey identified them, newly discovered sites, and the National Register of Historic Places status of all resources.

Table 3-25. Archaeological sites within the Packwood Lake Hydroelectric Project area of potential effects. (Source: Energy Northwest, 2008a, as modified by staff)

Site (FS Number) Site Type

Proximity to Area of Potential Effects

National Register of Historic Places

Eligibility

13102115 Packwood Lake Archaeological Site (45LE285)

Inside Eligible

13102103 Big Sleep Peeled Cedar Outside Eligible

13092303 Valley Development Company telephone line

Inside but not encountered

Not applicable

13092304 Valley Development Company tramway hoist house

Just outside Not applicable

13092305 Valley Development Company road and flume bed

Outside Not applicable

13092401 Valley Development Company road/flume bridge


Not applicable

No number Valley Development Company Trail


Not applicable

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Site (FS Number) Site Type

Proximity to Area of Potential Effects

National Register of Historic Places

Eligibility13102803 Cuyu’ik Site (45LE296) Inside but not

encounteredRecommended not eligible

13102101 Packwood Lake Guard Cabin (Valley Development Company cabin remains)

Just outside Eligible

No number U.S. Geological Survey Gaging Station and Cableway Trolley

Inside Not individually eligible; Potentially eligible as part of a Multiple Property Submission

No number Packwood Lake Trail Inside Not eligible

13102102 Packwood Lake Resort Site

Only boat dock was inside; dock was removed and not encountered

Not eligible

13102804 Packwood Lake (Agnes) Island prehistoric isolated artifact


Not applicable

No number Lily Basin Trail (Hager Creek Trail)


Not applicable

No number Unknown trail fragment (possibly part of Hager Creek Trail)


13102801 Bear Creek Fishtrap Outside Not applicable

13102802 Game Department Cabin Site


13103301 Upper Lake Creek Fishtrap


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Energy Northwest identified only two archaeological or historic-era properties within the area of potential effects that are eligible for the National Register of Historic Places: the Packwood Lake Archaeological Site (FS 13102115 [45LE285]) and USGS Gaging Station/Cableway Trolley located on Lake Creek just below Packwood Lake. Management of these two resources is discussed in the proposed Historic Properties Management Plan.

Traditional Cultural Properties

The identification of potential Traditional Cultural Properties within the project area of potential effects took into consideration National Register of Historic Places Bulletin 38, Guidelines for Evaluating and Documenting Traditional Cultural Properties. The Cowlitz Indian Tribe and Yakima Nation did not identify any potential Traditional Cultural Properties associated with the project. However, Gifford Pinchot National Forest conducted a study between 1992 and 1995 for traditional uses locations located on National Forest System Lands. Packwood Lake was identified as a traditional use location in this study.


Energy Northwest anticipates that project-related erosion would have an effect upon archaeological site FS 13102115 (45LE285). Such erosion also could result in exposure of cultural materials leading to illicit artifact collection and site vandalism. Energy Northwest does not anticipate any project-related effects upon the USGS Gaging Station/Cableway Trolley, but acknowledges that deterioration and/or vandalism to this structure could take place in the future. Energy Northwest also states that future ground-disturbing activities have the potential to encounter and disturb archaeological materials.

Energy Northwest prepared an Historic Properties Management Plan designed to address potential project-related effects on site FS 13102115 and the USGS Gaging Station/Cableway Trolley. The Historic Properties Management Plan also includes procedures for site monitoring, staff training, curation of cultural artifacts, reporting, public education and interpretation, and inadvertent discoveries of archaeological materials and human remains. The Historic Properties Management Plan was prepared after consultation with the Cowlitz Indian Tribe, Yakima Nation, Gifford Pinchot National Forest, and the Washington Department of Archaeology and Historic Preservation and the State Historic Preservation Office. The Forest Service specified that the Historic Properties Management Plan should be implemented.

Our Analysis

While construction of the Packwood Lake Hydroelectric Project was completed in 1964 and the system and its individual components do not yet qualify for inclusion in the National Register of Historic Places as historic properties, they may meet eligibility

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requirements within the next 6 years (by 2014). Formal National Register of Historic Places evaluation of the system facilities when they reach 50 years of age should be undertaken as a condition of the new license.

Energy Northwest submitted a draft Historic Properties Management Plan to the Washington Department of Archaeology and Historic Preservation/State Historic Preservation Office for comment on July 10, 2007, and a final document was filed with the Commission on August 30, 2007. We agree that the measures identified in the final Historic Properties Management Plan are adequate to protect historic properties within the project area of potential effects. The Commission intends to execute a Programmatic Agreement with the Washington State Historic Preservation Office that would implement the Historic Properties Management Plan. However, an appendix to this agreement would contain stipulations calling for Energy Northwest to evaluate the project system for National Register of Historic Places eligibility once the facility reaches 50 years old (by 2014).

Recreational Facility Construction and Maintenance MeasuresEnergy Northwest proposes as part of the Packwood Lake Recreation Plan to

install and maintain several new facilities, including a composting toilet at Packwood Lake and an informational kiosk at the Packwood Lake Trailhead (see also section 3.3.4, Recreation and Land Use Resources). In addition, as part of the proposed Historic Properties Management Plan, Energy Northwest would install an interpretive sign at the ATV parking area along FS Trail 74 (see also section 3.3.6, Cultural Resources).

Our Analysis

Undocumented archeological materials could potentially be disturbed or uncovered during the construction and implementation of Energy Northwest’s proposed recreational and interpretive facilities. In addition, dispersed recreational use in the vicinity of the project would have the potential to cause erosion and potential disturbance of artifacts. Energy Northwest’s proposed Historic Properties Management Plan would provide measures for site monitoring, staff training, reporting, and inadvertent discoveries of archaeological materials and human remains. These measures would help to ensure there would be no adverse effects on archaeological materials within the potential area of effect as a result of the proposed recreational construction or dispersed recreational use at the project.

Construction of the Stream Gage and Aquatic Habitat Enhancement MeasuresEnergy Northwest proposes to construct a stream gage on lower Lake Creek,

provide for Snyder Creek fish passage rerouting under the project tailrace, provide gravel and wood augmentation to reach 5 of lower Lake Creek, and habitat enhancement as part of the Lower Lake Creek Stream Restoration and Enhancement Plan (see also section

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3.3.1, Aquatic Resources). These measures are also specified by the Forest Service and recommended by Washington Fish and Wildlife.

Our Analysis

Construction associated with the stream gage and aquatic habitat enhancement measures on lower Lake Creek and the rerouting of Snyder Creek would have the potential to disturb undocumented archeological materials. Energy Northwest’s proposed Historic Properties Management Plan would provide measures for site monitoring, staff training, reporting, and inadvertent discoveries of archaeological materials and human remains. These measures would help to ensure there would be no adverse effects on archaeological materials within the potential area of effect due to the proposed stream gage construction and implementation of the aquatic habitat enhancement measures.

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4.0 DEVELOPMENT ANALYSIS

In this section, we look at the project’s use of Lake Creek for hydropower purposes to see what effect various environmental measures would have on the project’s costs and power benefits. Consistent with the Commission’s approach to economic analysis, the power benefit of the project is determined by estimating the cost of obtaining the same amount of energy and capacity using the likely alternative generating resources available in the region. In keeping with the Commission policy as described in Mead, our economic analysis is based on current electric power cost conditions and does not consider future escalation of fuel prices in valuing the hydropower project’s power benefits.51

Our analysis includes (1) an estimate of the net power benefit of the project for each of our relicensing alternatives; and (2) an estimate of the cost of individual measures considered in the EA for the protection, mitigation, and enhancement of environmental resources affected by the project. To determine the net power benefit for each of the relicensing alternatives, we compare project costs to the value of the power output as represented by the cost of a likely alternative source of power in the region. For any alternative, the positive net annual power benefit indicates that the project power costs less than the current cost of alternative generation resources and a negative net annual benefit indicates that the project power costs more than the current cost of alternative generation resources. This estimate helps to support an informed decision concerning what is in the public interest with respect to a proposed license. However, project economics is only one of many public interest factors the Commission considers in determining whether, and under what conditions, to issue a license.

4.1 POWER AND ECONOMIC BENEFITS OF THE PROJECTTable 4-1 summarizes the assumptions and economic information we use in our

analysis. This information was provided by Energy Northwest in its license application. We find that the values provided by Energy Northwest are reasonable for the purposes of our analysis. Cost items common to all alternatives include: taxes and insurance costs; net investment (the total investment in power plant facilities remaining to be depreciated); estimated future capital investment required to maintain and extend the life of plant equipment and facilities; relicensing costs; normal operation and maintenance cost; and Commission fees.

51 See Mead Corporation, Publishing Paper Division, 72 FERC ¶ 61,027 (July 13, 1995). In most cases, electricity from hydropower would displace some form of fossil-fueled generation, in which fuel is the largest component of the cost of electricity.

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Table 4-1. Parameters for the economic analysis of the Packwood Lake Hydroelectric Project. (Source: Staff)

Assumption Value Source

Period of analysis (years) 30

Term of financing (years) 20

Book value, $a $606,000 Energy Northwest 2007 Annual Report, page 46 (net plant).

Relicensing cost, $b $3,800,000 license application

Operation and maintenance, $/yearc

$1,684,000 Energy Northwest Fiscal Year 2009 Packwood Annual Budget, Key Assumptions

Power value ($/MWh)d $48.10 Application for New License, exhibit D, section D.8/D.9

Interest rate 5 percent Energy Northwest 2007 Annual Report, page 54

Discount ratee 5 percenta Book value is the depreciated value of project facilities. b Relicensing costs include the administrative, legal/study, and other expenses to date.

Source: license application.c Existing plant operation and maintenance includes operation and maintenance related

to environmental measures associated with the current licensed Includes energy and capacity components.e Assumed by staff to be the same as the interest rate.

As currently operated, the 26.125-MW Packwood Lake Hydroelectric Project generates an average of 92,000 MWh annually and has a dependable capacity of 10.4 MW. Table 4-1 includes the secondary power sales cost that Energy Northwest would pay to replace project power. This cost reflects a mixture of generation resources available to Energy Northwest. We use this value for our analysis in order to estimate the cost (in lost energy) of minimum flows and other flow releases that affect the project’s ability to generate electricity. We discuss the effects of proposed operational changes on power benefits in section 4.2.2.

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4.2 COMPARISON OF ALTERNATIVESTable 4-2 compares the annual cost, power benefits, and annual net benefits for the

alternatives considered in this EA; no-action, Energy Northwest’s proposal, the staff, and the staff alternative with mandatory conditions.

Table 4-2. Summary of the annual cost, power benefits, and annual net benefits for the alternatives for the Packwood Lake Hydroelectric Project. (Source: Staff)

No action

Energy Northwest’s Proposal

Staff Alternative

Staff Alternative with Mandatory Conditions

Installed capacity (MW) 26.125 26.125 26.125 26.125

Annual generation (MWh) 92,000 83,655 83,655 83,655

Annual power value ($/MWh and mills/kWh)

$4,425,200

(48.10)

$4,023,800

(48.10)

$4,023,800

(48.10)

$4,023,800

(48.10)

Annual cost ($/MWh and mills/kWh)

$1,979,590

(21.52)

$2,278,430

(27.24)

$2,310,180

(27.62)

$2,311,880

(27.64)

Annual net benefit ($/MWh and mills/kWh)

$2,445,610

(26.58)

$1,745,370

(20.86)

$1,713,620

(20.48)

$1,711,920

(20.46)

4.2.1 No-action Alternative

Under the no-action alternative, the project would continue to operate as it does now. The project generates an average of 92,000 MWh of electricity annually. The average power value of the project under the no-action alternative would be $4,425,200 (about $48.10/MWh). The average annual cost of producing this power would be $1,979,590 (about $21.52/MWh), resulting in an average annual net benefit of $2,445,610 (about $26.58/MWh). In other words, the project produces energy at a cost that is less than that of currently available alternative generation by $26.58/MWh.

4.2.2 Energy Northwest’s Proposal

Energy Northwest proposes to implement increased minimum flows, and aquatic habitat flows, fish protection and passage measures, botanical and wildlife resource management plan implementation, avian protection, recreational resource management and enhancement, and cultural resource protection. The proposed project would have a total capacity of 26.125 MW, a dependable capacity of 10.4 MW and an average annual generation of 83,655 MWh. As proposed by Energy Northwest, the project would have

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an average annual power value of $4,023,800 ($48.10/MWh), and annual production cost (levelized over the 30-year period of analysis) of $2,278,430 ($27.24/MWh), and an annual net benefit of $1,745,370 ($20.86/MWh). In other words, the project would produce energy at a cost that is less than that of the currently available alternative generation by $20.86/MWh.

4.2.3 Staff Alternative

The staff alternative includes the same capacity and energy attributes as Energy Northwest’s proposal. Table 4-3 includes the staff’s recommended additions, deletions, and modifications to Energy Northwest’s proposed environmental protection and enhancement measures and the estimated cost of each. The difference between Energy Northwest’s proposed alternative and the staff alternative is the additional cost of: (a) the Forest Service’s modified 4(e) condition 9 measure to develop a Packwood Lake Intake Fish Entrainment Monitoring Plan; (b) the Forest Service’s section 4(e) measure to develop a Packwood Lake tributary headcutting monitoring plan; (c) developing and implementing a plan that includes measures associated with hazardous substance spill prevention and control including protection of surface and groundwater quality during all over-water and near-water work related to the project; and (d) modifying the Integrated Weed Management Plan to expand the target species list.

Based on a total capacity of 26.125 MW, a dependable capacity of 10.4 MW and an average annual generation of 83,655 MWh, the project would have an average annual power value of $4,023,800 ($48.10/MWh), an annual production cost (levelized over the 30-year period of our analysis) of $2,310,180 ($27.62/MWh), and an annual net benefit of $1,713,620 ($20.48/MWh) under the staff alternative. The staff alternative would reduce the net annual benefit by $31,750 ($0.38/MWh) compared to the project as proposed by Energy Northwest.

With the mandatory conditions, including requirements for Energy Northwest to implement Washington Department of Ecology’s draft water quality certification ramping rates and to provide electricity to the Forest Service guard station, the staff alternative would have a total capacity of 26.125 MW, a dependable capacity of 10.4 MW and an average annual generation of 83,655 MWh. The project would have an average annual power value of $4,023,800 ($48.10/MWh), an annual production cost (levelized over the 30-year period of our analysis) of $2,311,880 ($27.64/MWh), and an annual net benefit of $1,711,920 ($20.46/MWh) under the staff alternative with mandatory conditions. This would reduce the net annual benefit by $33,450 ($0.40/MWh) compared to the project as proposed by Energy Northwest.

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4.3 COST OF ENVIRONMENTAL MEASURESTable 4-3 gives the cost for each environmental enhancement measure considered

in our analysis. We convert all costs to equal annual (levelized) costs over a 30-year period of analysis for a uniform basis for comparing the benefits of a measure to its costs.

4.4 NEW PROJECT FACILITIES RECOMMENDED TO BE INCLUDED IN ANY NEW LICENSE We recommend expanding the project boundary by including several proposed

and existing facilities and several sections of access roads and trails. The purpose of our recommended expansion of the project boundary is to ensure that lands and ongoing measures associated with project purposes are brought into the project boundary so the Commission has the authority to administer the required components of the new license.

The proposed composting toilet and historic interpretive sign at the existing ATV parking area at the end of FS Trail 74, and the informational kiosk at the Packwood Lake Trailhead all would be located outside of the existing project boundary. These new facilities would be project-related and would enhance the recreational experience at the project; therefore, we recommend that they be included in the project boundary to ensure their installation, operation, and maintenance over the term of a new license.

Currently, only portions of FS Trail 74 and Dyson Pass are within the existing project boundary, and Latch Trail is located outside of the existing project boundary. Both trails, including the Dyson Pass segment, provide Energy Northwest primary access to project facilities. FS Trail 74 and Dyson Pass also provide recreational access to project recreational resources. Therefore, we recommend including FS Trail 74, Dyson Pass, and Latch Trail in the project boundary to ensure implementation of Energy Northwest’s maintenance measures for these trails and access to project facilities over the term of a new license.

Measures associated with the lower Lake Creek Restoration and Enhancement area, which is located outside of the existing project boundary, would involve annual monitoring and implementation of mitigation measures over the term of a new license. Therefore, we recommend inclusion of the Lake Creek Restoration and Enhancement area into the project boundary. We also recommend inclusion of the location of the proposed stream gage on lower Lake Creek into the project boundary since this facility would involve monitoring of project related streamflow over the term of the new license.

Powerhouse Road (FS Road 1260-013), Latch Road (FS Road 1262), and Pipeline Road (FS Road 1260-066) are used primarily for project purposes to access project facilities. Including these roads into the project boundary, (the portion of Powerhouse Road, from the gate to project facilities, all of Pipeline Road [FS Forest Service Road 1260-066], and the portion of Latch Road from the Forest Service gate to its termination

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at Latch Trail), is appropriate and would ensure Northwest Energy’s access to project facilities and that these roads are maintained over the term of a new license.

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Table 4-3. Costs of environmental mitigation and enhancement measures considered in assessing the environmental effects of continuing to operate the Packwood Lake Hydroelectric Project. (Source: Energy Northwest, 2008a, b).

Environmental Measures EntitiesCapital Cost (2008$)

Annual Cost (2008$)

Levelized Annual Cost (2008$) Notes

Aquatic Resources1. Provide increased instream flows in Lake Creek.

Energy Northwest, Forest Service, NMFS, Washington Fish and Wildlife, Washington Department of Ecology, Staff

$0 $359,020 $359,020 a

2. Eliminate the maximum summertime upper lake elevation limit

Energy Northwest, Forest Service, Staff

$0 $0 $0

3. Begin the annual outage for Project maintenance on August 15 of each operating year, and resume operation by September 15, or earlier if all necessary work has been completed.

Energy Northwest, Forest Service, NMFS, Staff

$0 $19,580 $19,580

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Annual Cost (2008$)


4. Provide a spill event of greater than or equal to 285 cfs for as long as lake inflows can sustain that flow or a maximum of 24 hours, every other water year or 3 out of 6 water years.

Energy Northwest, Forest Service, NMFS, Washington Fish and Wildlife, Washington Department of Ecology, Staff

$0 $42,380 $42,380 b

5. Implement a ramping rate plan to limit all instream flow reductions associated with the minimum instream flows to a maximum of 2.5 cfs per hour. One exception to this procedure is the June 1 reduction in flow, which would be completed in one hour during night-time hours.

Energy Northwest, and Staff

$0 $0 $0 c

6. Implement a seasonal ramping rate limitation in the anadromous portion of Lake Creek to be measured at a stream gage located near the Lake Creek Road bridge.

Washington Department of Ecology

$0 $0 $0 c

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Annual Cost (2008$)


7. Reduce entrainment at the project intake and monitor the trout population at Packwood Lake.


$37,930 $23,800 $26,360

8. Reduce entrainment at the project intake

Washington Fish and Wildlife

$1,600,000 $0 $108,080 d

9. Ensure a specified resident trout population in Reach 5 of Lake Creek by periodically moving Packwood Lake trout to Lake Creek downstream of the drop structure either by overtopping events (aquatic habitat flows) or by physically collecting and moving fish.


$12,300 $2,560 $3,390

10. Provide a gravel and wood recruitment station in Reach 5 below the drop structure.

Energy Northwest, Forest Service, Washington Fish and Wildlife, Staff

$68,270 $8,730 $13,340

11. Develop and implement a stream restoration and enhancement plan for lowest 1.0 mile of Lake Creek, in the anadromous zone, after consultation with the natural resource agencies and tribes.

Energy Northwest, Forest Service, NMFS, Washington Fish and Wildlife, Staff

$652,350 $7,220 $51,290

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Annual Cost (2008$)


12. Improve fish passage on Snyder Creek where it crosses the tailrace canal by rerouting Snyder Creek into Hall Creek on the downstream side (south) of the tailrace canal within 5 years of license issuance.

Energy Northwest, Forest Service, NMFS, Washington Fish and Wildlife, Staff

$223,670 $3,230 $18,340

13. Install flow measurement equipment, within the first year of the issuance of the new operating license and begin recording data at the Lake Creek Road Bridge.


$12,300 $26,240 $27,070

14. Maintain and monitor effectiveness of the tailrace fish barrier.

Energy Northwest, NMFS, Staff

$0 $35,900 $35,900

15. Monitor water temperature in the tailrace, Lake Creek, Packwood Lake, and the Cowlitz River on an annual basis between June 25 and October 5 for the first 10 years of the license.

Energy Northwest, Washington Department of Ecology, Staff

$0 $5,830 $5,830

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Annual Cost (2008$)


16. Within 5 years of license issuance, the licensee shall develop, after consultation with the Forest Service, a Packwood Lake tributary headcutting monitoring program.

Forest Service, Washington Fish and Wildlife, Staff

$0 $2,510 $2,510 e

17. Develop and implement a plan that includes measures associated with hazardous substance spill prevention and control including protection of surface and groundwater quality during all over-water and near-water work related to the project.

Washington Department of Ecology, Staff

$5,000 $15,000 $15,340

Terrestrial Resources18. Implement the Rare Plant Management Plan.

Energy Northwest, Staff

$10,250 $6,070 $6,760

19. Develop and implement an Integrated Weed Management Plan incorporating the current weed control plan. Provide for regular weed control and site-specific efforts.


$0 $13,530 $13,530

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Annual Cost (2008$)


20. Modify the Integrated Weed Management Plan to expand the list of target species for weed control at sites below the stilling basin, in order to protect the state-listed Oregon goldenaster and prevent the spread of noxious weeds as a result of implementing environmental measures in lower Lake Creek and Snyder and Hall creeks.

Staff $2,000 $630 $770 f

21. Develop and implement a threatened, endangered, and sensitive species management plan.


$14,150 $0 $960

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Annual Cost (2008$)


22. Within the first year after license issuance, monitor the lacustrine fringe wetland habitat at the head of Packwood Lake known as Site B for northwestern salamander larvae presence and to determine whether the larvae are able to move into the lake after the annual September 16 change in minimum lake elevation or if there is a physical barrier to their movement.


$15,380 $0 $1,040

23. Ensure that the project transmission line conforms to Avian Power Line Interaction Committee standards for raptor protection.


$4,920 $1,450 $1,780

24. Develop and implement a resource coordination plan


$61,930 $7,600 $11,780

Recreational, Land and Aesthetic Resources25. Implement the Recreation Management Plan as filed with the Commission on June 6, 2008


$200,670 $39,420 $52,980

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Annual Cost (2008$)


26. Continue providing power to the Forest Service guard station.

Energy Northwest, Forest Service

$0 $1,700 $1,700

27. Develop and implement a plan to monitor the project pipeline, surge tank, and penstock to protect National Forest Service lands from leakage or failure of the facilities


$0 $0 $0

28. Develop and implement a fire prevention plan for National Forest Service lands within the project boundary and National Forest Service lands adjacent to the project boundary that are impacted by the project


$0 $0 $0

29. Expand the project boundary.

Staff $200,000 $0 $13,510 g

Cultural Resources30. Implement the August 30, 2007 Historic Properties Management Plan.


$0 $7,220 $7,220

31. Evaluate the eligibility of the project for inclusion on the National Register of Historic Places in 2014.

Staff $19,590 $0 $1,320 h

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a Annual cost includes 7,464 MWh of lost energy.b Annual cost includes 881 MWh of lost energy.c We anticipate that this can be accomplished without reducing annual generation.d Cost estimated by staff for replacement of the existing intake screens.e Costs for this measure estimated by staff. Annual cost includes $5,000 per year for 10 years.f Costs for this measure estimated by staff. Costs include $2,000 for initial planning and an additional $1,000 per year for

control and monitoring, which would be needed annually for 5 years and then approximately every other year through any new license period.

g Costs for this measure was estimated by staff.h Costs for this measure were estimated by staff and consist of $25,000 in 2014.

5.0 CONCLUSIONS AND RECOMMENDATIONS

5.1 COMPARISON OF ALTERNATIVES

In this section we compare the developmental and non-developmental effects of Energy Northwest’s proposal, Energy Northwest’s proposal as modified by staff, and the no-action alternative.

We estimate the annual generation of the project under the three alternatives would be 83,655 MWh for Energy Northwest’s proposal; 83,655 MWh for Energy Northwest’s proposal as modified by staff; and 92,000 MWh for the no-action alternative. We summarize the environmental effects of the three alternatives below.

Aquatic Resources – Under Energy Northwest’s proposal anadromous and resident salmonid habitat would be enhanced by increasing rearing and spawning habitat in the bypassed reach, lower Lake Creek. Additional protection would be provided for spawning salmonids in the project tailrace on the Cowlitz River. Entrainment of small numbers of O. mykiss spp. at the project intake on Packwood Lake still would occur, but would probably be decreased from the current low levels as a result of improvements made to the existing fish screens. The ramping rate plan proposed by Energy Northwest would provide additional protection to aquatic species in lower Lake Creek during downramping of the minimum instream flows. Water temperature would increase slightly during some periods in lower Lake Creek due to the higher minimum flows proposed for lower Lake Creek.

Terrestrial Resources – Under the applicant’s proposal, implementing an Integrated Weed Management Plan would provide an effective and systematic approach to long-term weed monitoring and management. Implementing the Avian Protection Plan would help minimize the risk of avian electrocution along the transmission line. Annual reporting of bald eagle observations would determine whether timing restrictions or other protective measures should be implemented during construction activities associated with aquatic habitat enhancement projects. The results of additional amphibian surveys of “Site B” at the upper end of Packwood Lake would serve as the basis for identifying and designing any improvements in wetland connectivity that may be needed to protect northwestern salamanders. Changes in the instream flow regime in lower Lake Creek may provide additional habitat area for amphibians that are typically associated with off-channel pools, but may reduce habitat quality in terms of temperature for amphibians that are associated with flowing water. Lake level fluctuations would continue to limit the establishment of riparian habitat along the Packwood Lake shoreline and aquatic plant communities within the littoral zone, but holding the lake level higher during the late summer/early fall would provide additional hydrologic support for lake fringe wetlands.

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Staff’s modification of the applicant’s proposal would expand the list of target weed species to be addressed in the Integrated Weed Management Plan and would provide additional protection for rare plants and sensitive wetland and riparian habitats.

Threatened and Endangered Species – Under the applicant’s proposal and the staff alternative, implementation of a threatened, endangered, and sensitive species management plan would provide an effective strategy for long-term protection of special status plants and wildlife, and an effective coordination mechanism with the resource management agencies.

Recreation, Land Use, and Aesthetics – Under the applicant’s proposal and the staff alternative, the proposed Recreation Management Plan and associated proposed recreational enhancements, including new toilet facilities, an informational kiosk, measures to maintain trails, and operation and maintenance measures to address the effects of dispersed recreational use within the project boundary would enhance recreational opportunities at the project and help meet existing recreational needs and demand. In addition, Energy Northwest’s proposed annual recreation use monitoring and 6-year updates would help to ensure that adequate recreational opportunities to meet future recreational demand would be provided over the term of a new license.

Cultural Resources – Under the applicant’s proposal, project effects on historic properties would be taken into account through implementation of the HPMP.

The Commission intends to execute a Programmatic Agreement with the Washington State Historical Preservation Office that would implement the HPMP. Staff proposes stipulations to be included in the Programmatic Agreement that would require the applicant to evaluate the Packwood Lake Hydroelectric Project system for National Register eligibility once the facility reaches 50 years old (by 2014). Implementation of these additional stipulations would ensure that this potential historic property is adequately addressed under section 106.

Under the no-action alternative, environmental conditions would remain the same as under current conditions of the license for all affected resources and no enhancement of environmental resources would occur.

5.2 COMPREHENSIVE DEVELOPMENT AND RECOMMENDED ALTERNATIVE

Sections 4(e) and 10(a)(1) of the Federal Power Act require the Commission to give equal consideration to the power development purposes and to the purposes of energy conservation; the protection, mitigation of damage to, and enhancement of fish and wildlife; the protection of recreational opportunities; and the preservation of other aspects of environmental quality. Any license issued shall be such as in the Commission’s judgment will be best adapted to a comprehensive plan for improving or

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developing a waterway or waterways for all beneficial public uses. This section contains the basis for, and a summary of, our recommendations for relicensing the Packwood Lake Hydroelectric Project. We weigh the costs and benefits of our recommended alternative against other proposed measures.

Based on our independent review of agency and public comments filed on this project, and our review of the environmental and economic effects of the proposed action and its alternatives, we have selected the staff alternative as the preferred alternative. This alternative includes elements of the applicant’s proposal, section 4(e) conditions, resource agency recommendations, and some additional measures. We recommend this alternative because (1) issuance of a new hydropower license by the Commission would allow Energy Northwest to operate the project as an economically beneficial and dependable source of electric energy for its customers; (2) the 26.125-MW of electric energy generated from a renewable source may offset the use of fossil-fueled, steam-electric generating plants, thereby conserving nonrenewable resources and reducing atmospheric pollution; (3) the public benefits of this alternative would exceed those of the no-action alternative; and (4) the recommended environmental measures would protect or enhance fish and terrestrial resources, enhance public use of recreational facilities and resources, and maintain and protect historic and archaeological resources within the area affected by project operation.

In the following section, we make recommendations as to which environmental measures proposed by Energy Northwest or specified or recommended by agencies and other entities should be included in any license issued for the project. In addition to Energy Northwest’s proposed environmental measures, we recommend additional staff-recommended environmental measures to be included in any license issued for the project. We also discuss which measures we do not recommend including in the license; for example, we do not recommend continuing to supply power to the Forest Service guard station or to fund a seasonal employee to address the effects of recreational use, both of which are part of Forest Service 4(e) condition 14.

Measures Proposed by Energy Northwest Based on our environmental analysis of Energy Northwest’s proposal, we

recommend including the following measures proposed by Energy Northwest in any license issued for the Packwood Lake Hydroelectric Project.

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Provide the following increased minimum instream flows to lower Lake Creek:

MonthInstream Flow (cfs)

January, February, March 4April 7May 15June 10July 15August 1 – 15 15Aug 16 – Sept 15 20September 16 – 30 15October 10November 7December 4

Develop and implement a stream restoration and enhancement, and monitoring plan for the lowest 1.0 mile (river mile 0.0 to 1.0) of Lake Creek’s anadromous zone.

Implement the Lake Creek Ramping Rate Plan for Reach 5 below the Drop Structure filed with the Commission on June 9, 2009. With this plan, Energy Northwest would to limit all instream flow reductions associated with the minimum instream flows to a maximum of 2.5 cfs per hour. One exception to this procedure is the June 1 reduction in flow, which would be completed in one hour during night-time hours.

Conduct the annual project maintenance outage from August 15 through September 15, without a drawdown of Packwood Lake.

Maintain a minimum surface elevation of 2,849 feet msl on Packwood Lake, except between May 1 and September 14, when a minimum elevation of 2,856.5 feet msl would be maintained.

Provide a spill event for aquatic habitat enhancement from Packwood Lake to lower Lake Creek of greater than or equal to 285 cfs for as long as lake inflows can sustain that flow or for a maximum of 24 hours, every other water year or 3 out of 6 water years.

Improve fish passage on Snyder Creek where it crosses the tailrace canal by rerouting Snyder Creek into Hall Creek on the downstream side (south) of the tailrace canal.

Install flow measurement equipment at the Lake Creek Road bridge.

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Maintain and monitor effectiveness of the tailrace fish barrier.

Inspect the tailrace slough prior to the annual outage for adequate flows, and rescue fish, if necessary.

Implement the Tailrace Water Temperature Monitoring and Enhancement Plan filed with the Commission on June 6, 2008. The Tailrace Water Temperature Monitoring and Enhancement Plan calls for Energy Northwest to monitor water temperatures in the project’s lined tailrace, at the Packwood Lake outlet, the Cowlitz River, and the mouth of Lake Creek to determine the effect of the tailrace water on the Cowlitz River water temperature. Conduct the monitoring during the first 10 years following license issuance, unless the temperature criteria is met for 3 consecutive years, at which time Energy Northwest would consult with Washington Department of Ecology to suspend or modify the monitoring activities upon Commission approval. One exception for the previously stated monitoring would be to conduct monitoring associated with the project outage between August 15 and September 15 annually for the duration of the new license. If the tailrace temperature under the proposed operating regime does not meet applicable standards, Energy Northwest would consult with the Washington Department of Ecology and other agencies on additional ways to address this issue.

Implement the Rare Plant Management Plan filed with the Commission on June 6, 2008.

Develop and implement a threatened, endangered, and sensitive species management plan to address protection of special status species on all project lands and lands affected by project-related activities.

Document incidental bald eagle sightings in the project area, and provide an annual report on bald eagle observations to the Commission and resource management agencies.

Implement the Avian Protection Plan filed with the Commission on June 6, 2008.

Conduct northwestern salamander surveys at Site B, in the wetland complex at the upper end of Packwood Lake, and improve connectivity between Site B and the lake, if needed to allow amphibian movement during winter drawdown conditions.

Implement portions of the Recreation Management Plan as filed with the Commission on June 6, 2008. We recommend adopting the portions of the plan listed below:

1) install and maintain a composting toilet at Packwood Lake;

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2) install and maintain an informational kiosk at the Packwood Lake Trailhead and parking area, located at the end of Snyder Road;

3) provide annual maintenance to Pipeline Trail (FS Trail 74), including Dyson Pass, and Latch Trail including drainage, trail clearing, and vegetation management for portions of the trails primarily used for project purposes;

4) provide operation and maintenance measures to address the effects of dispersed recreational use within the project boundary;

5) consult with the Forest Service on appropriate paint colors and materials as repairs and maintenance to project intake-related structures or facilities are performed, to ensure the buildings blend in with the surrounding area; and

6) develop and implement a road maintenance plan for roads primarily used for project purposes, including portions of Powerhouse Road (FS Road 1260-013), Pipeline Road (FS Road 1260-066) and Latch Road (FS Road 1262), and include the road segments within the project boundary.

Implement (via a Programmatic Agreement with the Washington State Historic Preservation Office) the Historic Properties Management Plan that was filed with the Commission on August 30, 2007, including installation of an interpretive sign at the ATV parking area along the Pipeline Trail (FS Trail 74).

Develop and implement a resource coordination plan to coordinate the recommended management plans and associated requirements for the project with various agencies and provide for an annual coordination meeting.

Develop and implement as part of the resource coordination plan, a fire prevention plan for the project.

Additional Measures Recommended by Staff In addition to Energy Northwest’s proposed measures listed above, we

recommend including the following staff-recommended measures in any license issued for the Packwood Lake Hydroelectric Project:

Measures associated with the draft water quality certification for hazardous substance spill prevention and control including protection of surface and groundwater quality during all over-water and near-water work related to the project.

As part of the threatened, endangered, and sensitive species management plan, conduct surveys for Oregon goldenaster, bald eagles, and northern

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spotted owls prior to initiating any ground-disturbing activity in lower Lake Creek that could affect habitat for these species.

Consult with the resource management agencies regarding timing restrictions or other measures that may be needed to prevent adverse effects on amphibians during efforts to reroute Snyder Creek.

Modify the Integrated Weed Management Plan to: (1) expand the list of target species for weed control at sites below the stilling basin in order to protect the state-listed Oregon goldenaster; and (2) prevent the spread of noxious weeds as a result of implementing environmental measures in lower Lake, Snyder, and Hall creeks.


Modify the project boundary to include: the composting toilet and historic interpretive sign at the existing ATV parking area at the end of FS Trail 74; the proposed stream gage site at the Lake Creek Road bridge; the area along the anadromous reach of lower Lake Creek where restoration, enhancement, and monitoring would occur; the informational kiosk at the Packwood Lake Trailhead and parking area at the end of Snyder Road; FS Trail 74, Dyson Pass, and Latch Trail; the portion of Powerhouse Road, from the gate to project facilities; all of Pipeline Road (FS Forest Service Road 1260-066); and the portion of Latch Road from the Forest Service gate to its termination at Latch Trail.

Discussion of Recommended Measures Lower Lake Creek Stream Restoration and Enhancement

To enhance aquatic habitat in lower Lake Creek, Energy Northwest proposes and we recommend increasing the minimum instream flow releases in lower Lake Creek to levels ranging from 4 to 20 cfs, depending on season. Energy Northwest also proposes and we recommend increasing the amount and quality of anadromous fish spawning and rearing habitat in lower Lake Creek through the installation of wood and boulder stream structures, gravel, and other beneficial habitat features, and to monitor these enhancement measures to verify their effectiveness.

The Forest Service (condition 5) specifies and Washington Fish and Wildlife recommends the same instream flow releases as those proposed by Energy Northwest. In addition, the Forest Service specifies in condition 7 and Washington Fish and Wildlife recommends that Energy Northwest consult with both agencies, to develop and implement a lower Lake Creek stream restoration, enhancement, and monitoring plan for the anadromous reach of lower Lake Creek. According to the Forest Service and Washington Fish and Wildlife, the primary goal of the plan would be to restore and

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enhance anadromous and resident salmonid populations in lower Lake Creek by increasing rearing and spawning habitat. Consistent with Forest Service conditions 5 and 7, the NMFS recommends that Energy Northwest develop, after consultation with NMFS, FWS, the Forest Service, Washington Fish and Wildlife, Washington State Department of Ecology, and the tribes for increased minimum instream flows (as described above) and a habitat enhancement plan to mitigate for degradation and loss of anadromous fish rearing habitat in lower Lake Creek due to project effects.

In section 3.3.1, Aquatic Resources, we consider the condition of the habitat in lower Lake Creek and how flow releases affect available habitat for both resident and anadromous fish species. We also evaluate how approximately 50 years of flow diversion, in combination with other factors such as timber harvest, has altered aquatic habitat diversity in the anadromous reach of lower Lake Creek. Based on the results of studies conducted during project relicensing, we conclude that aquatic habitat quality and quantity in lower Lake Creek between the drop structure and its confluence with the Cowlitz River has been negatively affected by the project’s existing 3 cfs minimum flow release. We also consider what instream flows and other physical habitat enhancement measures would be needed to enhance aquatic habitat quality and quantity for both the resident and anadromous fish populations. We agree that Energy Northwest’s proposed 4 to 20 cfs flow release, plus accretion and tributary inflow, would substantially increase the amount of available spawning and rearing habitat area in lower Lake Creek compared to existing conditions. Energy Northwest’s proposed aquatic habitat enhancement measures in lower Lake Creek would also substantially improve the productivity and carrying capacity of lower Lake Creek, likely increasing the distribution and abundance of native fish populations, including ESA listed Chinook salmon and steelhead.

While it is apparent that both Energy Northwest and the resources agencies share the same general habitat enhancement objectives for the anadromous zone of lower Lake Creek, we are concerned that the Forest Service and Washington Fish and Wildlife may have identified specific design criteria that may not necessarily reflect what could be achieved in lower Lake Creek. An example is the goal to increase salmonid rearing habitat in the reach from river mile 0.3 to 1.0 by about 12,600 square feet. While we support utilizing the 12,600 square feet of habitat enhancement as a goal, we recognize that some flexibility in achieving this goal may be necessary and should be taken into consideration during the development of the final enhancement plan.

We estimate that the cost of developing and implementing the specified instream flows and habitat enhancement measures (including monitoring) would decrease the net annual benefit of the project by about $410,310. The higher instream flows would reduce generation of the project by about 7,464 MWh per year. We consider the expected benefits of providing increased instream flows and implementing habitat enhancements that would substantially increase the amount and quality of habitat (tables 3-14 and 3-15)

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in lower Lake Creek for several federally listed species, to be worth the cost of developing and implementing these measures.

Packwood Lake Elevations

Energy Northwest proposes, consistent with Forest Service and Washington Fish and Wildlife, to change the rule curve for the operation of Packwood Lake. Its proposed rule curve would retain the minimum lake elevation restrictions of 2,856.5 feet msl from May 1 to September 15 and elevation 2,849 feet msl from September 16 to April 30. The proposed rule curve would not have a maximum lake elevation restriction. However, the Forest Service specifies and Washington Fish and Wildlife recommends that Energy Northwest decrease lake elevation by no more than 1 foot per day.

As discussed in section 3.3.1, Aquatic Resources, not having a maximum reservoir elevation restriction as proposed by Energy Northwest would remove compliance issues currently experienced under the existing license that occur during flood flows and when Energy Northwest does not have the ability to control the level of Packwood Lake.52 In addition, the proposed reservoir levels would help to provide sufficient water for increased instream flows into lower Lake Creek, uninterrupted tailrace flows after the project maintenance outage, and continuous flows for project generation. The May 1 to September 15 minimum lake level restriction would ensure tributary stream connectivity with Packwood Lake for adult O. mykiss spp. spawning and fry out-migration and provide stable water levels for wetland and amphibian productivity (see section 3.3.2, Terrestrial Resources). The continuation of the September 16 to April 30 minimum lake level restriction would allow for storage of the spring runoff and allow for the maintenance of the outlet structure at a low water level. Due to a combination of factors such as the storage within Packwood Lake and the limited capacity of the powerhouse, Energy Northwest is not currently able to lower the level of Packwood Lake by more than a foot per day. We recommend adopting this measure and we estimate that there would not be a measurable annual cost associated with adopting this measure.

Annual Project Maintenance Outage (Tailrace Slough)

To minimize potential adverse effects on Chinook salmon spawning, Energy Northwest proposes, the Forest Service specifies, and Washington Fish and Wildlife and NMFS recommend that the annual outage for project maintenance commence on August 15 of each operating year and operations would resume by September 15. The current outage occurs during the first 3 weeks in October. The project tailrace canal discharges into a side channel of the Cowlitz River (tailrace slough). The tailrace slough is a highly dynamic side channel with frequently changing morphology as a result of flood events. During some years, flood flows in the Cowlitz River can reconfigure this side channel so

52 The current license provides that the maximum reservoir elevation of Packwood Lake shall not exceed 2,858.5 feet msl (article 37).

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that it derives most of its inflow from the mainstem Cowlitz River, in other years most of the flow in the side channel is derived from project outflows. Chinook and coho salmon and steelhead are known to reside in the tailrace slough at various life stages, and the amount of flow entering the tailrace slough (either from the project or the mainstem Cowlitz River) greatly affects the quality and quantity of available spawning, rearing, and incubation habitat for these species. Prior to the annual project shutdown, Energy Northwest also proposes to inspect the Cowlitz River side channel that flows into the tailrace slough and take appropriate actions to rescue fish, if needed.

As part of its relicensing studies, Energy Northwest conducted aquatic habitat and fish population surveys in the tailrace slough and mainstem Cowlitz River and determined that an annual project outage in October has the potential to adversely affect incubating spring Chinook salmon eggs deposited in the tailrace slough. According to Energy Northwest, the highest likelihood for loss of spawning habitat and dewatering of redds in the slough occurs between October and February. This directly coincides with Chinook and coho salmon spawning and incubation in the Cowlitz River. By beginning the outage on August 15, rather than the current outage timing, the project would avoid providing attraction flows that would draw adult Chinook and coho salmon into the tailrace slough to spawn. Outages in this earlier period also would help avoid the discharge of naturally warmed Packwood Lake surface water into the Cowlitz River, when summer temperatures are at their highest; and ensure adequate water is available in Packwood Lake to provide the proposed minimum flows for Lake Creek. In addition, eliminating the pre-outage drawdown would ensure that the project maintains continuous operation from the end of the outage in mid-September through the end of October and minimizes any potential drawdown-related adverse effects on the migration of juvenile O. mykiss spp. from the Packwood Lake tributaries. Conducting fish rescues in the tailrace slough (when the Cowlitz River side channel is dry) and tailrace following the cessation of project operation would minimize potential impacts on fish residing in these areas including federally listed species.

We estimate that the cost of changing the timing of the annual project outage including fish rescue would decrease the net annual benefit of the project by about $19,580. We consider the expected benefits of the change would: increase the suitability of the tailrace slough and lower Lake Creek for several federally listed species; benefit juvenile O. mykiss spp. migrating into Packwood Lake from its tributaries; and therefore, would be worth the cost of developing and implementing this measure.

Monitoring and Reporting of Stream Flows and Reservoir Elevations

Energy Northwest proposes to continue to record the water level in Packwood Lake and flows released to lower Lake Creek and to the powerhouse to ensure compliance with the conditions of a new license. In addition, Energy Northwest proposes to install a stream gage on lower Lake Creek at Lake Creek Road bridge to ensure

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compliance with the proposed aquatic habitat forming flows. This stream gage would be project-related, and we recommend that this facility be brought into the project boundary to ensure the installation, operation, and maintenance over the term of a new license. The stream flow and lake water level monitoring and reporting for the Packwood Lake Hydroelectric Project would provide documentation of compliance with flows and lake water levels required by a new license and worth the estimated annual cost of $27,070.

Water Temperature Monitoring

Energy Northwest proposes to implement the Tailrace Water Temperature Monitoring and Enhancement Plan to evaluate the effectiveness of project operation including the timing of the annual project outage, in achieving applicable water temperature objectives. In consultation with the Washington Department of Ecology, the monitoring plan would assess sites in the tailrace, lower Lake Creek, Packwood Lake, and the Cowlitz River. Our analysis of proposed project operations suggests that they would enhance the temperature regime for salmonids. However this monitoring could confirm the expected enhancement and would provide information regarding the potential need for additional measures to decrease the effects of project discharges on water temperature in lower Lake Creek and the Cowlitz River and minimize potential adverse effects on Chinook and coho salmon, steelhead, sea-run cutthroat trout, and resident rainbow and cutthroat trout. We estimate the annual cost of implementing this measure at $5,830, and we consider the expected benefits of identifying the need for potential additional temperature enhancement measures for salmonids to be worth the cost.

Tributary Headcutting Monitoring

The Forest Service specifies that Energy Northwest develop a Packwood Lake Tributary Monitoring Program within 5 years of license issuance. This monitoring program is to focus on two tributaries to Packwood Lake which are important to the reproduction and rearing of O. mykiss spp.: Muller and Upper Lake creeks. The initial monitoring program would occur at year 10 of the new license and reoccur every 10 years thereafter. Fish passage difficulties can occur between these tributaries and Packwood Lake during low lake levels and when the tributaries incise the deltas and lake bed. This monitoring program would provide a means to assess the effect of water level management on trout access to these key spawning tributaries, identify the need for corrective actions, if any, and would be worth the estimated annual cost of $2,510.

Maintenance of the Tailrace Fish Barrier

Resident and anadromous salmonids are known to spawn and rear in both lower Lake Creek and in the project tailrace slough where it enters the Cowlitz River. In October 2007, after consultation with NMFS, other resource agencies, tribes, and the Commission, Energy Northwest obtained authorization and installed a permanent fish barrier drum screen near the end of the lined tailrace. To ensure that this screen remains

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functional for the duration of the proposed license, the NMFS’ section 18 article 1 prescribes that Energy Northwest continue the measures for maintenance, testing, and operation of the screen. Monitoring and maintaining the effectiveness of this screen and reporting the results of monitoring in an annual report, as prescribed by NMFS, would identify the need for corrective actions regarding the drum screen operation to ensure that it continues to prevent the upstream migration of resident and anadromous fish into the project tailrace and stilling basin and thus, minimize any potential adverse affects on these species associated with project operations and maintenance. If annual monitoring shows that the goal of the barrier is not being met, then Energy Northwest would make necessary adjustments or modifications to the facility following Commission approval. We estimate that maintenance and monitoring of the tailrace fish barrier would be worth the estimated annual cost of $35,900 to protect resident and anadromous salmonids.

Fish Passage on Snyder Creek

Energy Northwest proposes and we recommend rerouting Snyder Creek from its existing culvert crossing under the tailrace into a backwater channel of Hall Creek located downstream of the project tailrace as part of a Snyder Creek restoration, enhancement and monitoring plan developed in coordination and consultation with the Forest Service, FWS, NMFS, Washington Fish and Wildlife, and tribes. NMFS’ section 18 article 2 prescribes that Energy Northwest develop and implement a plan within 2 years of license issuance to provide adequate salmonid passage at this crossing. The Forest Service specifies and Washington Fish and Wildlife recommends that Energy Northwest prepare a Snyder Creek restoration, enhancement, and monitoring plan for the rerouting of Snyder Creek. Snyder Creek currently passes through a culvert under the project tailrace and joins Hall Creek immediately downstream of the tailrace crossing. The culvert, as currently configured, does not meet Washington Fish and Wildlife criteria for fish passage and can become blocked with large amounts of sediment, further impeding upstream and downstream fish migration. There is about 1,900 feet of documented spawning and rearing habitat for coho salmon, westslope cutthroat, and O. mykiss upstream of this culvert. Rerouting the Snyder Creek tailrace crossing to bypass the culvert migration obstacle would facilitate year-round unimpeded migration into and out of Snyder Creek and create new, high quality spawning and rearing habitat for both resident and anadromous salmonids. Energy Northwest proposes to continue to maintain the existing culvert in operating condition until rerouting Snyder Creek in 2015 and then monitor the rerouted area for 2 years to determine if volitional fish passage of anadromous and resident trout species has been achieved. We estimate that the cost to improve and monitor fish passage on Snyder Creek would be worth the estimated annual cost of $18,340 to protect and enhance resident and anadromous salmonids.

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Entrainment at the Project Intake

In its license application, Energy Northwest originally proposed to reduce entrainment and impingement at the project intake through a 3-phase adaptive plan designed to limit intake-related mortality to less than 400 fish on the “outer” debris screens and 50 fish on the “inner” traveling screens, recorded during any 1-year period.

In its preliminary 4(e) condition 9 and 10(j) recommendation 9, the Forest Service specified and Washington Fish and Wildlife recommended, respectively, that Energy Northwest consult, test, and evaluate whether the existing traveling fish screens meet current state of Washington approach velocity criteria. If testing indicated the traveling fish screens do not meet state criteria, then Energy Northwest would modify the existing fish screens and/or evaluate whether administrative controls (restricting operational flows) could provide a means of complying with the criteria, or install new fish screens that would meet the state criteria at the project’s intake.

The results of Energy Northwest’s entrainment study indicate that entrainment/impingement is occurring at the project intake and that the approach velocity at the existing project fish screens exceeds Washington Fish and Wildlife’s approach velocity criteria as discussed in section 3.3.1.2. However, in the draft EA, our analysis led us to conclude that the total proportion of the rainbow trout population in Packwood Lake exposed to entrainment risk in any given year is relatively small, representing less than 1 percent of the total lake population. Based on this finding, we recommended in the draft EA that Energy Northwest consult with the Forest Service, NMFS, Washington Fish and Wildlife, and Washington Department of Ecology in the development of an alternative approach to address entrainment at the project intake that involved biological monitoring and the implementation of biological triggers that would be used to address approach velocity concerns (if warranted), rather than just modifying the screens to meet state’s approach velocity criteria. The goal of our recommended monitoring plan was to determine whether or not the existing screens cause detrimental effects on the O. mykiss spp. population residing in Packwood Lake.

Following issuance of the draft EA, Washington Department of Fish and Wildlife continued to recommend that the fish screens at the project intake be modified to meet state approach velocity criteria. However, Energy Northwest, the Forest Service, NMFS, and Washington Department of Ecology developed a new approach to address entrainment at the project intake that included biological monitoring coupled with an impingement mortality threshold (or biological trigger) that would have to be exceeded prior to making any decisions regarding physical modifications to the intake screens. This approach was subsequently incorporated into Forest Service modified 4(e) condition 9 that would require Energy Northwest to develop, in consultation and coordination with the Forest Service, a Packwood Lake Intake Fish Entrainment Monitoring Plan (within 3 months of issuance of a new license). The objectives of the monitoring plan would be to

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accurately describe and enumerate the yearly O. mykiss spp. population size distribution in Packwood Lake; identify and record all fish impingement and mortality on project traveling screens; determine impingement decay rates; and examine fish behavior in the intake wells and the forebay immediately in front of the intake. The monitoring plan would be implemented annually for the first 5 years of a new license. Subsequent monitoring frequency and actions would depend on the results of the initial monitoring period, and be collectively agreed on by Energy Northwest, the Forest Service, and other interested parties. For the initial 5-year sampling period, 1.5 percent of the total Packwood Lake O. mykiss spp. population would be the limit for fish injured or killed by impingement on the intake screen.

Each year’s monitoring results would be reported to the Forest Service and other interested parties for review and comment and discussed at the Annual Resource Coordination meeting. The 1.5 percent threshold for project-related impingement mortality would be re-evaluated (and potentially reduced) if the Packwood Lake O. mykiss spp. population suffers a random event such as high inflow event resulting in turbid conditions in Packwood Lake. Satisfaction of the impingement mortality threshold would allow Energy Northwest to retain the existing traveling screen facility and operational mode as the primary fish exclusion device for a period to be determined collectively by Energy Northwest, the Forest Service, and other interested parties based on the initial 5-year monitoring program results. At that time, a revised monitoring plan would be developed cooperatively among the parties identifying appropriate methods, monitoring schedules, and impingement thresholds. This revised monitoring plan would be implemented for 1 or more years (at the discretion of the parties) to determine if the traveling screens continue to meet the identified impingement criteria. If the impingement mortality threshold is met, then Energy Northwest would prepare an intake structure operation manual for Forest Service approval within 1 year after filing the final monitoring report. If the monitoring data indicated that the intake structure does not meet the impingement mortality threshold identified in the monitoring plan, then Energy Northwest would modify the existing fish screens and/or evaluate implementing administrative controls (restricting operational flows through the screens) to meet state criteria prior to subsequent monitoring years to protect the fish population.

In the event that modifications are made to the project intake in years 4 or 5 of the initial monitoring program (or any year thereafter), then the monitoring plan would be extended for at least 2 more years to test these modifications and would be completed by the end of the second year from the completion of the modification. If the impingement criteria are satisfied by a baffling system or other modification, then Energy Northwest would prepare an intake structure operation manual. If impingement criteria are not satisfied after one modification to the screens, Energy Northwest would provide for a major redesign of the traveling screens to meet Washington State Fish Screen Criteria.

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Washington Fish and Wildlife’s 10(j) recommendation is inconsistent with the plan developed by Energy Northwest, the Forest Service, NMFS, and Washington Department of Ecology. Its recommendation relies primarily on fish screen modifications to meet the state approach velocity criteria, with no associated biological monitoring to determine the overall level of effect on the O. mykiss spp. population. While this approach would also likely provide protection for O. mykiss spp. residing in Packwood Lake, our analysis of existing information leads us to conclude that the total proportion of the O. mykiss spp. exposed to entrainment risk in any given year is relatively small, representing less than 1 percent of the total lake population. We conclude that this loss does not appear to be having an adverse effect on the lake’s rainbow population under current project operations. We do not support Washington Fish and Wildlife’s 10(j) recommendation, because it is limited to meeting the state criteria regardless of the overall effect of the project on O. mykiss spp. population.

The conditions specified in the modified Forest Service 4(e) condition 9 would also provide adequate protection for fish at this site and, unlike Washington Fish and Wildlife’s 10(j) recommendation, would not necessarily result in a major fish screen redesign or modification without a supporting biological trigger. As recommended in the draft EA, modified Forest Service 4(e) condition 9 would incorporate extensive biological monitoring to confirm our conclusion that O. mykiss spp. populations are not harmed by the project intake. We recognize that, if monitoring demonstrates that O. mykiss spp. densities are being affected by the project, Energy Northwest would be required to take action to remedy the effects.

Although implementing a major fish screen redesign to meet state velocity criteria would likely protect the trout population residing in Packwood Lake, we consider its $1.6 million capital cost ($108,080 annualized cost) excessive, given the low level of impingement recently documented on the traveling screens. Because we do not expect implementing a major fish screen redesign will be necessary under the modified Forest Service 4(e) condition 9, we estimate the annual cost of implementing it to be $26,360. We consider the expected benefits to be worth the cost of implementing this modified 4(e) condition and that this would provide adequate protection of the O. mykiss spp. resource in Packwood Lake.

Aquatic Habitat Forming Flows in Lower Lake Creek

Energy Northwest proposes and we recommend providing aquatic habitat forming flows in lower Lake Creek greater than or equal to 285 cfs for as long as lake inflows can sustain the flow, or a maximum of 24 hours, every other water year or 3 out of 6 water years. The Forest Service specifies and Washington Fish and Wildlife recommends the same aquatic habitat forming flows as those proposed by Energy Northwest, and these flows would be consistent with the draft water quality certification conditions. The overall objective of these aquatic habitat forming flows is to provide flows of sufficient

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magnitude, duration, and frequency to sustain habitat forming, and maintaining processes in lower Lake Creek.

As discussed in section 3.3.1, Aquatic Resources, we base our analysis of the need for aquatic habitat forming flows in lower Lake Creek on information provided in Energy Northwest’s license application. Results of these relicensing studies indicate that spawning gravel is severely limited in portions of lower Lake Creek and that the frequency of flow events needed to transport gravel (in the range of 200 to 500 cfs) have been significantly reduced by operation of the project. The relatively small amount of spawning gravel currently found in the anadromous zone of Lake Creek is likely the combined result of a lack of structure to hold gravel, few sediment sources downstream of the drop structure, and reduced transport from upstream reaches. Based on our review of the aquatic habitat in the project area and on the hydrology and geomorphology information presented in the final license application, it is apparent that habitat forming flows would enhance the salmonid habitat in lower Lake Creek. The magnitude, frequency, and duration of the aquatic habitat forming flows proposed by Energy Northwest, specified by the Forest Service, and recommended by Washington Fish and Wildlife would likely meet the flow requirements needed to mobilize spawning gravel; contribute to the formation of physical habitat features such as riffles, pools, runs, and point bars; and support dynamic geomorphic processes over time as needed to sustain and enhance the habitat for resident and anadromous fish in lower Lake Creek.

Aquatic habitat flows would reduce generation of the project by about 881 MWh per year. We estimate that the cost of implementing the specified aquatic habitat forming flows would decrease the net annual benefit of the project by about $42,380 but the benefits of enhancing the salmonid habitat in lower Lake Creek would be worth the costs.

Ramping Rates

In its final license application, Energy Northwest did not propose any measures to address ramping rates at the project. However, because rapid decreases in streamflow associated with any aquatic habitat forming flows or downward adjustments to minimum instream flows included in a new license for the Packwood Lake Hydroelectric Project have the potential to strand fish and other aquatic biota in lower Lake Creek (causing immediate or delayed mortality), in the draft EA we recommend implementation of Washington Fish and Wildlife’s interim ramping rate criteria to protect aquatic resources downstream of the drop structure (Hunter, 1992) similar to the ramping rate condition in the draft water quality certification. These criteria range from 0 to 2 inches per hour depending of season and time of day and are generally designed to protect juvenile salmonids in low gradient alluvial river channels.

At an April 27, 2009, public meeting in Olympia, Washington, Commission staff requested that Energy Northwest more closely examine the flow reductions associated

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with the lowering of instream flows in lower Lake Creek and file this information with the Commission. In response to this request, Energy Northwest filed the Lake Creek Ramping Rate Plan for Reach 5 below the Drop Structure (Energy Northwest, 2009). In this ramping rate plan, Energy Northwest proposes to limit all instream flow reductions described above to a maximum of 2.5 cfs per hour, with the exception of the June 1 reduction in flow, which could be completed in one hour during night-time hours, to comply with the Washington Fish and Wildlife’s seasonal downramping rate criteria. These manual flow decreases would be implemented by adjusting the valve on the bypass pipe controlling the release of the flow at the drop structure.

Implementation of these ramping rates through the term of any new license would prevent the sudden discontinuation of spill flows or minimum flow releases in lower Lake Creek, minimizing potential negative effects on aquatic biota from stranding during sensitive time period for salmonids. The ramping rates would have minimal effects on generation and would have a very small and inconsequential cost to project operations.

Hazardous Substance Spill Prevention and Protection of Surface and Groundwater Quality

Energy Northwest did not propose any measures directly related to hazardous substance spill prevention and prevention of contaminants from degrading surface and groundwater quality during normal project maintenance operations. In its May 29, 2009, filing of the draft water quality certification, Washington Department of Ecology specifies conditions that would involve the development of the measures and plans for spill prevention and control; a water quality protection plan that has control measures to prevent contaminants from entering surface and groundwaters; a stormwater prevention plan that includes best management practices; an in-water work protection plan; and measures for monitoring, maintenance, and reporting water quality. Energy Northwest is probably already in compliance with most of these conditions in the draft water quality certification, but compliance with these measures and plans would be a requirement of a new license and would reduce the possibility of a spill and water quality degradation. We estimate that development of an overall plan, if one does not currently exist, would cost approximately $5,000, and any aspects that are not currently part of the plan (if any) might cost as much as $15,000 per year to implement, for a total levelized annual cost of $15,340. We estimate the possible additional cost is warranted to adequately protect water quality.

Expanded List of Target Species for Weed Control

The Integrated Weed Management Plan filed by Energy Northwest on June 6, 2008, identifies preliminary management priorities for different zones within the project area. The management priorities for each zone are based on a variety of factors, such as

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weed class; risk to sensitive resources; distribution and abundance; and potential for eradication, containment, or control.

The plan designates project features below the stilling basin as within “Zone E.” Weed occurrence and distribution in this zone is strongly influenced by river flows and land uses that are not related to project operations or project-related activities. The plan does not identify Scotch broom, butterfly bush, Japanese knotweed, reed canarygrass, Himalayan blackberry, or cutleaf blackberry as target species for control in this zone, presumably because they are so well established in the Cowlitz River valley on lands adjacent to project features, as well as on project lands. However, we are recommending that Energy Northwest modify the Integrated Weed Management Plan to include measures to address control of these species at three specific sites.

(1) Tailrace: The Revised Rare Plant Survey Report (Beck, 2008) identifies Scotch broom as a significant threat to the state listed Oregon goldenaster population that occurs near the tailrace. Based on this species’ status, we conclude that control efforts are warranted. We recommend Energy Northwest consult with the Lewis County Noxious Weed Board and Washington Natural Heritage Program to evaluate options for controlling Scotch broom. If options can be identified that would not pose a greater risk to Oregon goldenaster than the uncontrolled spread of Scotch broom, we recommend that Energy Northwest modify the Integrated Weed Management Plan to include long-term management, as well as monitoring of Scotch broom infestations at the tailrace site.

(2) Lower Lake Creek: The Revised Rare Plant Survey Report (Beck, 2008) identifies Scotch broom as a significant threat to the Oregon goldenaster site located outside the project boundary near the mouth of Lake Creek, and notes that Japanese knotweed grows nearby. If implementation of proposed stream enhancement measures in lower Lake Creek would cause ground disturbance near this site, we recommend Energy Northwest implement the same measures that would be implemented to control Scotch broom at the tailrace site, and control any other noxious weeds that would also be at risk of spreading as the result of stream enhancement activities.

(3) Snyder Creek/Hall Creek: Scotch broom, reed canarygrass, Himalayan blackberry, and cutleaf blackberry may be present at the site where Snyder Creek would be rerouted. We recommend that Energy Northwest modify the Integrated Weed Management Plan to include control of these species at the Snyder Creek site to minimize the risk that ground-disturbing activities associated with fish passage enhancement would contribute to their spread. We recommend that Energy Northwest specifically provide for control of these species prior to construction, implementation of best management practices during construction, revegetation with native plants following construction, and inclusion of the site in Energy Northwest’s regular monitoring program.

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We estimate that the total average annual cost of managing noxious weeds would be about $14,300, assuming that our recommendations would result in an additional $2,000 in capital costs for initial planning and an additional $1,000 for control and monitoring, which would be needed annually for 5 years and then approximately every other year through any new license period. However, we conclude that the environmental benefits warrant the increased cost, and note that, in its comments on the draft EA, the Forest Service concurs with our recommended modifications to the Integrated Weed Management Plan.

Threatened, Endangered, and Sensitive Species Management Plan

Energy Northwest proposes to develop and implement a threatened, endangered, and sensitive species management plan to address such species on all lands within the project boundary or lands affected by the project. The Forest Service specifies that with this measure, Energy Northwest should consult with the Forest Service to address threatened, endangered, and sensitive species and their habitat on National Forest System lands. Washington Fish and Wildlife mirrors the Forest Service condition, but would include consultation with FWS and Washington Fish and Wildlife to address species that occur on non-National Forest System lands within the project boundary or in areas affected by project operation or project-related activities.

We recommend implementation of this plan, because it would provide a comprehensive, consistent approach to the protection of threatened, endangered, and sensitive species on both National Forest System lands and non-National Forest System lands within the project boundary or on adjacent lands that may be affected by project-related activities that are conducted during the term of any new license. It would provide a means of protecting species which are state-listed or designated as sensitive by the Forest Service, but which are not listed under the ESA and would therefore not be protected through consultation with FWS or the NMFS. It would also provide a framework for specific management plans that have already been developed, such as the Rare Plant Management Plan, and others that may be needed in the future (e.g., a plan to manage northern spotted owls), as well as general best management practices that may be developed to protect fish, wildlife, and plants. We specifically recommend that the plan provide for an evaluation of potential effects of unanticipated project related activities on bald eagles and northern spotted owls. Both species are known to occur in the project’s vicinity and future nest sites may occur within proximity to these activities; and therefore, these activities could cause disturbance, depending on the distance of nest sites, the specific types of equipment that would be used, and the noise levels that would be expected. Surveys for the northern spotted owl should be conducted within 2 years of any such activity in order to be considered current, unless owl presence is assumed, and timing restrictions are implemented to prevent disturbance during the breeding season. Surveys for active bald eagle nests should be conducted prior to implementation of any ground-disturbing activities that are planned near potential habitat, unless activities are

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scheduled outside the breeding season. We also recommend the plan include timing restrictions or other measures to protect amphibians during construction activities associated with fish passage improvements at Snyder and Hall creeks. To protect Oregon goldenaster, we recommend the plan include clearance surveys prior to implementation of any ground-disturbing activity in lower Lake Creek that would affect habitat that supports this species.

We estimate the average annualized cost of developing the plan as the Forest Service specifies and Washington Fish and Wildlife recommends would be about $960. Our specific recommendations would not add cost to this estimate. Based on our independent analysis, we conclude that the benefits to listed species protection warrant the costs associated with developing and implementing the plan. We note that, in its comments on the draft EA, the Forest Service concurs with incorporating our specific recommendations regarding surveys and potential timing restrictions to protect Oregon goldenaster, bald eagle, northern spotted owls, and amphibians.

Recreational Facilities and Management

Currently, management of the project’s recreational resources is guided by Forest Service management directions, not a recreation plan. However, Energy Northwest’s proposed Recreation Management Plan, filed in June 2008, would provide a framework for Energy Northwest to implement the proposed recreational site improvements and coordinate management of the recreational resources with the Forest Service. Energy Northwest’s proposed recreational facility improvements would help meet existing recreational demand and enhance existing facilities. Future recreational use and demand at the project is likely to increase slightly, and the annual review and updates over the term of a new license would provide the means to monitor and ensure that future recreational demands are met and opportunities are provided, as appropriate.

Proposed measures to install a composting toilet and provide annual operation and maintenance would replace old toilet facilities at the end of FS Trail 74 and benefit site users and the environment by improving sanitation in the project area. Energy Northwest’s proposed measures to provide operation and maintenance measures, such as maintenance of project lands and project recreational facilities to address litter and other associated potential effects of dispersed recreational use within the project boundary, would help to mitigate potential adverse effects of dispersed recreational use within the project boundary. The proposed measure to install an informational kiosk at the Packwood Lake Trailhead and parking area at the end of Snyder Road would improve visitor understanding of Forest Service rules and regulations associated with dispersed recreation in the project area. The proposed measure to install an interpretive sign, as included in the Historic Properties Management Plan, at the ATV parking area at the end of FS Trail 74, would improve visitor understanding and education of the historical values of the project area.

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Currently, the proposed locations for the composting toilet and historic interpretive sign, the existing ATV parking area at the end of FS Trail 74, and the informational kiosk at the Packwood Lake Trailhead and parking area at the end of Snyder Road all are located outside of the existing project boundary. These new facilities would be project-related facilities and enhance the recreational experience at the project; therefore, we recommend these facilities be brought into the project boundary to ensure their installation, operation, and maintenance over the term of a new license.

Energy Northwest’s proposed trail maintenance measures for FS Trail 74 would provide for ongoing maintenance and improvement of the trail system for people using the recreational facilities at the project reservoir, and for Energy Northwest’s access to project features. Latch Trail also is used for primary project access; and therefore, measures by Energy Northwest to maintain this trail segment would ensure access to project facilities. Only portions of FS Trail 74 are currently within the project boundary and Latch Trail currently is located outside of the project boundary. Both of these trails provide primary access for Energy Northwest to project facilities and FS Trail 74 also provides recreational access to project recreational resources. Bringing FS Trail 74 and the Latch Trail into the project boundary would ensure implementation of Energy Northwest’s maintenance of these trails and access to project facilities over the term of the new license.

Energy Northwest’s proposed trail maintenance measures for FS Trail 74, including the Dyson Pass trail segment, would provide for ongoing maintenance and improvement of the trail system for people using the recreational facilities at the project reservoir, and for Energy Northwest’s access to project features. These trails are also used for primary project access; and therefore, measures by Energy Northwest to maintain this trail segment would ensure access to project facilities. Only portions of FS Trail 74 and the Dyson Pass segment are currently within the project boundary and Latch Trail currently is located outside of the project boundary. Bringing FS Trail 74, Dyson Pass, and the Latch Trail into the project boundary would ensure implementation of Energy Northwest’s maintenance of these trails and access to project facilities over the term of the new license. In the draft EA we incorrectly identified the Dyson Pass segment as a portion of trail that had been used to bypass a washed out portion of FS Trail 74 and that is no longer necessary for project access as a result of the trail improvements to FS Trail 74 in the washout area. In its comments on the draft EA, Energy Northwest clarified that Dyson Pass was a segment that branches off of FS Trail 74 and that is still used to access the project and is not the trail that was used as a bypass around the landslide on Latch Road (FS Road 1262).

As part of the proposed trail maintenance measures, Energy Northwest proposes to provide enforcement and education of the public regarding Forest Service management regulations. While this would help educate the public regarding Forest Service polices and regulations, it is not a project-related action or responsibility of a project licensee,

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and therefore, we do not recommend inclusion of this proposed measure as part of a new license requirement.

Including those roads used primarily for project purposes into the project boundary would be appropriate. Powerhouse Road (FS Road 1260-013), Latch Road (FS Road 1262), and Pipeline Road (FS Road 1260-066) are used primarily for project purposes to access project facilities. Energy Northwest has access beyond the Forest Service gates on these roads and is afforded vehicular access to sections of road not readily available to the general public. Therefore, including those roads used primarily for project purposes into the project boundary, including the portion of Powerhouse Road, from the gate to project facilities, all of Pipeline Road (FS Forest Service Road 1260-066), and the portion of Latch Road from the Forest Service gate to its termination at Latch Trail, is appropriate and would help to ensure licensee access to project facilities and that these roads are maintained over the term of a new license. Snyder Road (FS Road 1260) is not used primarily for project purposes and access; therefore, while Energy Northwest’s proposed maintenance measures may be beneficial, we do not recommend that these measures be included as a license requirement. For these reasons, we conclude that implementation of the provisions of the Recreation Management Plan, as modified, are worth the estimated annual cost of $52,980.

Resource Coordination Plan

Various management plans and actions are proposed and recommended as part of the future management and mitigation at the project. Energy Northwest proposes to develop and implement a resource coordination plan that would provide measures for the coordination and oversight of these various plans over the term of a new license. Specifically, the resource coordination plan would provide the means for an annual coordination meeting, measures for documenting and monitoring implementation measures and strategies associated with the various management plans, and provide the means for coordination of the various management measures with other agencies. This resource coordination plan is consistent with Forest Service condition 2, with the exception that Energy Northwest also proposes to include a fire prevention plan as a component to the resource coordination plan. Forest Service condition 3 specifies Energy Northwest develop a fire prevention plan consistent with Energy Northwest’s proposal. Energy Northwest’s proposed fire prevention plan would provide the means to identify and coordinate emergency response preparedness and reporting measures associated with fire management, as well as identify the cooperative roles and responsibilities of Energy Northwest and the Forest Service in managing fires. Accordingly, we recommend that Energy Northwest, in addition to the Forest Service, consult with the following entities, including: FWS, NMFS, Washington Department of Ecology, Washington Department of Fish and Wildlife, Washington State Department of Archaeology and Historic Preservation, the Cowlitz Tribe, and the Yakima Nation, and develop and implement a resource coordination plan including the fire prevention plan

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and conclude that the provisions of the resource coordination plan are worth the estimated cost of $11,780.

Historic Properties Management Plan and Programmatic Agreement

Continued project operations could affect archaeological sites and historic structures within the area of potential effects. While four resources were identified within the project area of potential effects, only two were recommended as eligible for listing on the National Register. Energy Northwest prepared and filed a final Historic Properties Management Plan designed to address potential project-related effects on site FS 13102115, which is recommended as individually eligible for listing on the National Register, and the USGS Gaging Station/Cableway Trolley, which is potentially eligible as part of a Multiple Property Submission. We concur with the Energy Northwest’s National Register recommendations and proposed management measures for these resources. The Historic Properties Management Plan also includes procedures for site monitoring, staff training, curation of cultural artifacts, reporting, public education and interpretation, and inadvertent discoveries of archaeological materials and human remains. The Historic Properties Management Plan was prepared after consultation with the Cowlitz Indian Tribe, Yakima Nation, Gifford Pinchot National Forest, and the Washington Department of Archaeology and Historic Preservation/State Historic Preservation Office. The Historic Properties Management Plan is consistent with Forest Service’s condition 18. We also recommend that the Packwood Lake Hydroelectric Project system should be evaluated for National Register of Historic Places eligibility once the facility reaches 50 years old (by 2014). The measures identified in the final Historic Properties Management Plan, along with our recommended evaluation of the project in 2014, would protect historic properties within the project area of potential effects. The estimated cost of $7,220 to implement the Historic Properties Management Plan and Programmatic Agreement would be worth the benefit of protecting the historic properties over the term of any new license. We estimate the cost to evaluate the project for inclusion on the National Register of Historic Places to be an additional $1,320 (based on a cost of $25,000 in 2014).

5.3 UNAVOIDABLE ADVERSE EFFECTS

Unavoidable adverse effects associated with the continued operation of the Packwood Lake Hydroelectric Project would include continued losses of relatively few O. mykiss spp. through entrainment and impingement at the project intake, the continued blockage of natural O. mykiss spp. migrations in lower Lake Creek at the drop structure, and the continued modification of natural flow and sediment transport regime in lower Lake Creek. Lake level fluctuations would continue to prevent the establishment of riparian habitat along the Packwood Lake shoreline and development of an aquatic plant community within the littoral zone. Proposed increases in the minimum instream flows

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in Lake Creek would result in warmer temperatures, which would limit its suitability to support amphibians that are adapted to cold water streams.

5.4 SUMMARY OF SECTION 10(j) RECOMMENDATIONS AND 4(e) CONDITIONS

5.4.1 Recommendations of Fish and Wildlife AgenciesUnder the provisions of section 10(j) of the Federal Power Act, each hydroelectric

license issued by the Commission shall include conditions based on recommendations provided by federal and state fish and wildlife agencies for the protection, mitigation, and enhancement of fish and wildlife resources affected by the project.

In response to our Ready for Environmental Analysis notice, Washington Fish and Wildlife (letter filed on August 18, 2008) and NMFS (letter filed on August 19, 2008) submitted recommendations for this project. Table 5-1 lists the federal and state recommendations filed subject to section 10(j), and whether the recommendations are adopted under the staff alternative. Environmental recommendations that we consider outside the scope of section 10(j) are considered under section 10(a) of the FPA and are addressed in the specific resource sections of this document and the previous section.

Section 10(j) of the Federal Power Act states that, whenever the Commission believes that any fish and wildlife agency recommendation is inconsistent with the purposes and the requirements of the Federal Power Act or other applicable law, the Commission and the agency shall attempt to resolve any such inconsistency, giving due weight to the recommendations, expertise, and statutory responsibilities of such agency. The Commission staff makes a preliminary determination that one section 10(j) recommendation by Washington Fish and Wildlife may be inconsistent with the purpose and requirements of the FPA or other applicable law.

We do not recommend adopting Washington Fish and Wildlife’s recommendation to reduce entrainment at the project intake. Our analyses in section 3.3.1 suggest that the Forest Service’s modified 4(e) condition 9 would provide adequate protection for fish at this site at a lower cost. The $1.6 million estimated capital costs associated with a major fish screen design, which Washington Fish and Wildlife stated was worth the cost since it would allow for assurance of adequate protection to the fish population and installation, would likely outweigh the small incremental benefit to the lake’s trout population over that anticipated under modified Forest Service 4(e) condition 9.

To resolve the inconsistency between the agencies’ recommendations and the purposes and requirements of the FPA and other applicable law, Commission staff conducted a meeting in Olympia, Washington, with representatives from Washington Fish and Wildlife and NMFS on April 27, 2009. In addition to addressing section 10(j) recommendations, this meeting (which was publicly noticed and open to all interested

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parties) also served as a forum to discuss other topics associated with the draft EA. Also in attendance were personnel from Energy Northwest, the Forest Service, Washington Department of Ecology, and the Yakima Nation.

During this meeting, participants discussed the one outstanding 10(j) inconsistency: measures to reduce entrainment at the project intake. The discussion centered around: (1) our recommendation in the draft EA to limit entrainment and impingement at the project intake through a 3-phase adaptive plan; (2) Washington Fish and Wildlife’s recommendation that the fish screen at the project intake be modified to meet state approach velocity criteria; and (3) the Forest Service modified 4(e) condition that would require Energy Northwest to develop a plan to address entrainment at the project intake, which also involved biological monitoring and the implementation of biological triggers that would be used to address approach velocity concerns (if warranted), rather than immediately modifying the screens to meet state approach velocity criteria.

Washington Department of Fish and Wildlife stated that its position is based on state law and specific engineering criteria that have been documented to protect various life stages of O. mykiss spp. Washington Fish and Wildlife rely on the state criteria, because of the high cost that would be involved in evaluating different site-specific circumstances for fish screens at projects across the state. Staff explained that the Commission is tasked with analyzing the degree of effects on a resource at each project and the cost associated with addressing those effects. Staff also noted that the O. mykiss spp. population within Packwood Lake appears very viable and healthy under existing conditions and that the existing screens (coupled with extensive biological monitoring) are likely to provide adequate protection for fish at a lower overall cost. Participants at the meeting also discussed methods of monitoring, such as hydroacoustics, to estimate the fish population. During this meeting, agreement was not reached with Washington Department of Fish and Wildlife on the section 10(j) inconsistency about entrainment at the project intake.

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Table 5-1. Fish and wildlife agency recommendations for the Packwood Lake Hydroelectric Project. (Source: Staff)

Recommendation Agency

Within scope of section

10(j)Annualized

cost Adopted?

Provide increased instream flows in Lake Creek.

Washington Fish and Wildlife, NMFS

Yes $359,020 Adopted

Revision of Packwood Lake water level management.


Yes $0 Adopted

Begin the annual outage for project maintenance on August 15 of each year.


Yes $19,580 Adopted

Release aquatic habitat forming flows to lower Lake Creek.


Yes $42,380 Adopted

Reduce entrainment at the project intake.


Yes $108,080 No, we recommend adopting the

Forest Service’s

modified 4(e) condition 9

Ensure a specified trout population in Reach 5 of lower Lake Creek, below the drop structure.


Yes $3,390 Adopted

Provide a gravel and wood recruitment station in Reach 5 below the drop structure.


Yes $13,340 Adopted

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10(j)Annualized

cost Adopted?

Develop and implement a stream restoration and enhancement plan for lowest 1.0 mile of Lake Creek.


Yes $51,290 Adopted

Improve fish passage on Snyder Creek where it crosses the tailrace canal.


Yes $18,340 Adopted

Develop and implement a threatened, endangered, and sensitive species management plan.


Yes $960 Adopted

Conduct amphibian monitoring in the wetland habitat at the head of Packwood Lake.


Yes $1,040 Adopted

Ensure that the project transmission line conforms to standards for raptor protection.


Yes $1,780 Adopted

Develop a Packwood Lake tributary headcutting monitoring plan.


Yes $2,510 Adopted

Develop and implement a resource coordination plan.


No.a Not a specific

measure to protect,

mitigate, or enhance fish and wildlife

resources

$11,780 Adopted

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10(j)Annualized

cost Adopted?

Conduct Pipeline Surge Tank and Penstock Monitoring.


No.b Not a specific

measure to protect,

mitigate, or enhance fish and wildlife

resources and more related to public safety.

$0 Adopted

a Although outside the scope of section 10(j), we considered it under section 10(a). Resource coordination will be addressed as part of Forest Service 4(e) condition 2 (table 5-2).

b Although outside the scope of section 10(j), we considered it under section 10(a). This will be addressed by the Division of Dam Safety and Inspection.

5.4.2 Land Management Agencies’ Section 4(e) ConditionsIn section 2.2.5, Modifications to Applicant’s Proposal—Mandatory Conditions,

we list the preliminary 4(e) conditions submitted by the Forest Service, and note that section 4(e) of the Federal Power Act provides that any license issued by the Commission “for a project within a federal reservation shall be subject to and contain such conditions as the Secretary of the responsible federal land management agency deems necessary for the adequate protection and use of the reservation.” Thus, any 4(e) condition that meets the requirements of the law must be included in any license issued by the Commission, regardless of whether we include the condition in our staff alternative.

Of the Forest Service’s 19 preliminary conditions, we consider two of the conditions (conditions 1 and 19) to be administrative or legal in nature and not specific environmental measures. The Forest Service’s condition 15 is more related to project safety than environmental protection and as such the Commission’s Division of Dam Safety and Inspection and the regional Commission offices are responsible for ensuring that proper monitoring of project features is implemented by Energy Northwest. We therefore, do not analyze these conditions in this EA. Table 5-2 summarizes our conclusions with respect to the 15 preliminary 4(e) conditions and one modified 4(e) condition that we consider to be environmental measures. We include in the staff alternative 12 of the environmental conditions specified by the Forest Service, we modify three conditions, and we recommend adopting the modified Forest Service 4(e) condition

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9 for entrainment in the project intake. The measures not adopted in total are discussed in detail in section 5.2, Comprehensive Development and Recommended Alternative.

Additionally, as discussed in section 2.2.4.2, the Forest Service’s condition 14, would require the licensee to provide power to the Forest Service guard station, even though we find no nexus to the project. However, we recognize that the Commission is required to include valid section 4(e) conditions in any license issued for the project.

Table 5-2. Forest Service preliminary 4(e) conditions for the Packwood Lake Hydroelectric Project. (Source: Staff)

Condition Annualized Cost Adopted

Nos. 2 and 3: Resource Coordination Plan and Fire Prevention Plan $11,870 Yes

No. 4: Packwood Lake elevations and annual project maintenance $19,580 Yes

No. 5: Lower Lake Creek instream flows $359,020 Yes

No. 6: Aquatic habitat forming flows $42,380 Yes

No. 7: Lower Lake Creek stream restoration and monitoring $51,290 Yes

No. 8: O. mykiss, surveys and supplementation in the upper reach of lower Lake Creek extending 1,464 ft below the drop structure

$3,390 Yes

Modified No. 9: Reduce entrainment at the project intake $26,360 Yes

No. 10: Fish passage at Snyder Creek $18,340 Yes

No. 11: Amphibian monitoring at site B $1,040 Yes

No. 12: Threatened , endangered and sensitive species $960 Yes

No. 13: Packwood Lake tributary headcutting monitoring $2,510 Yes

No. 14: Recreation management $52,980 Yes, in parta

No. 16: Exotic and invasive vegetative $13,530 Yes

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Condition Annualized Cost Adopted

management

No. 17: Raptor protection - primary distribution line $1,780 Yes

No. 18: Cultural resources $7,220 Yes

a We do not recommend inclusion of the requirement to supply electrical power to the Forest Service guard station or the funding of a seasonal employee to address recreational use at the project.

5.5 CONSISTENCY WITH COMPREHENSIVE PLANS

Section 10(a)(2) of the Federal Power Act, 16 U.S.C.§ 803(a)(2)(A), requires the Commission to consider the extent to which a project is consistent with the federal or state comprehensive plans for improving, developing, or conserving a waterway or waterways affected by the project. We reviewed 29 comprehensive plans (listed below) that are applicable to the Packwood Lake Hydroelectric Project, located in Washington. No inconsistencies were found.

Forest Service. Bureau of Land Management. 1994. Standards and guidelines for management of habitat for late-successional and old-growth forest related species within the range of the northern spotted owl. Department of Agriculture, Washington, DC. April 13, 1994. 144 pp.

Forest Service. 1990. Land and Resource Management Plan, Gifford Pinchot National Forest. Vancouver, Washington. June 1990.

Forest Service. 1995. Land and Resource Management Plan – Amendment 11, Gifford Pinchot National Forest. Vancouver, Washington. February 1995

Interagency Committee for Outdoor Recreation. 2002. An assessment of outdoor recreation in Washington State: A State Comprehensive Outdoor Recreation Planning (SCORP) Document 2002-2007. Olympia, Washington. October 2002.

Interagency Committee for Outdoor Recreation. 1995. Voices of Washington. November1995. 20 pp.

Interagency Committee for Outdoor Recreation. 1990. Washington outdoors: assessment and policy plan, 1990-1995. Tumwater, Washington. April 1990. 94 pp.

Interagency Committee for Outdoor Recreation. 1995. State of Washington outdoor recreation and habitat: Assessment and policy plan 1995-2001. November 1995. 28 pp. and appendices.

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Interagency Committee for Outdoor Recreation. 1991. Washington State trails plan: policy and action document. Tumwater, Washington. June 1991. 59 pp. and map.

National Marine Fisheries Service, Seattle, Washington; Pacific Fishery Management Council, Portland, Oregon. 1978. Final environmental impact statement and fishery management plan for commercial and recreational salmon fisheries off the coasts of Washington, Oregon, and California commencing in 1978. Department of Commerce. March 1978. 157 pp.

National Park Service. 1982. The nationwide rivers inventory. Department of the Interior, Washington, DC. January 1982.

Northwest Power Planning Council. 1984. Columbia River Basin fish and wildlife program. Portland, Oregon. October 1984. 138 pp., maps, and appendices.

Northwest Power Planning Council. 1986. Northwest conservation and electric power plan. Portland, Oregon. Two volumes.

Northwest Power Planning Council. 1987. Columbia River Basin fish and wildlife program. Portland, Oregon. February 1987. 246 pp.

Northwest Power Planning Council. 1994. Columbia River Basin fish and wildlife program. Portland, Oregon. December 14, 1994. 409 pp. and appendices.

Pacific Fishery Management Council. 1988. Eighth amendment to the fishery management plan for commercial and recreational salmon fisheries off the coasts of Washington, Oregon, and California commencing in 1978. Portland, Oregon. January 1988.

State of Washington. 1977. Statute establishing the State scenic river system, Chapter79.72 RCW. Olympia, Washington.

State of Washington. State of Oregon. State of Idaho. Confederated Tribes of the Warm Springs Reservation of Oregon. Confederated Tribes of the Umatilla Indian Reservation. Nez Perce Tribe. Confederated Tribes and Bands of the Yakima Indian Nation. Settlement Agreement pursuant to the September 1, 1983, Order of the U.S. District Court for the District of Oregon in Case No. 68-513. Columbia River fish management plan. Portland, Oregon. November 1987. A resource protection planning process identification of prehistoric archaeological resources in the lower Columbia study unit. Olympia, Washington. 50 pp.

Washington State Department of Community Development. Office of Archaeology and Historic Preservation. 1987. Resource protection planning process – mid-Columbia study unit. Olympia, Washington. 81 pp.

Washington State Department of Community Development. Office of Archaeology and Historic Preservation. 1988. Resource protection planning process – south Cascades study unit. Olympia, Washington. 79 pp.

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Washington State Department of Ecology. 1994. State wetlands integration strategy. Olympia, Washington. December 1994. 80 pp. and appendices.

Washington State Department of Ecology. 1986. Application of shoreline management to hydroelectric developments. Olympia, Washington. September 1986. 9 pp.

Washington State Department of Ecology. 1982. Instream resource protection program for the main stem Columbia River in Washington State. Olympia, Washington. 4pp.

Washington State Department of Fisheries. 1987. Hydroelectric project assessment guidelines. Olympia, Washington. 91 pp.

Washington State Department of Game. 1986. 1987 strategies for Washington’s wildlife. Olympia, Washington. December 1986. 300 pp.

Washington State Department of Natural Resources. 1987. State of Washington natural heritage plan. Olympia, Washington. 108 pp. and appendices.

Washington State Department of Natural Resources. 1997. Final habitat conservation plan. September 1997.

Washington State Energy Office. 1992. Washington State hydropower development/resource protection plan. Olympia, Washington. December 1992. 34 pp. and attachments.

Washington State Parks and Recreation Commission. 1988. Washington State scenic river assessment. Olympia, Washington. September 1988. 70 pp. and appendices.

Washington State Parks and Recreation Commission. 1988. Scenic rivers program- report. Olympia, Washington. January 29, 1988. 8 pp.

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6.0 FINDING OF NO SIGNIFICANT IMPACT

If the Packwood Lake Hydroelectric Project is relicensed with the staff-recommended measures, the project would continue to operate while providing protection and enhancements to aquatic, terrestrial, and wildlife resources; improvements to recreational facilities; and protection of cultural and historic resources in the project area.

Based on our independent analysis, issuance of the license with staff-recommended measures would not constitute a major federal action significantly affecting the quality of the human environment.

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7.0 LITERATURE CITED

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http://www.lewiscountywa.gov/files/departments/community%20development/docs/LewisCoCAOFINAL12-22-08.pdf

http://wdfw.wa.gov/hab/phs/vol4/cvtyduck.htm

http://www.energy.ca.gov/reports/2002-12-24_500-02-071F.PDF

McShane, C., T. Hamer, H. Carter, G. Swartzman, V. Friesen, D. Ainley, R. Tressler, K. Nelson, A. Burger, L. Spear, T. Mohagen, R. Martin, L. Henkel, K. Prindle, C. Strong, and J. Keany. 2004. Evaluation report for the 5-year status review of the marbled murrelet in Washington, Oregon, and California. Unpublished report. EDAW, Inc., Seattle, Washington. Prepared for the U.S. Fish and Wildlife Service, Region 1. Portland, OR.

Mincemoyer, S. 2005. Range-wide status assessment of Howellia aquatilis (water howellia) – revised December 2005. Report to the US Fish and Wildlife Service. Montana Natural Heritage Program, Helena, MT.

Myers, J. M., Kope, R.G., Bryant, G.J., Teel, D., Lierheimer, L.J., Wainwright, T.C., Grant, W. S., Waknitz, F.W., Neeley, K., Lindley, S.T., and Waples, R.S. 1998. Status Review of Chinook Salmon from Washington, Idaho, Oregon and California. National Marine Fisheries Service. Northwest Fisheries Science Center. Southwest Fisheries Science Center [Published as NMFS Technical Memorandum NMFS -NWFSC-35].

Nehlsen, W., J.E. Williams, and J.A. Lichatowich. 1991. Pacific salmon at the crossroads: Stocks at risk from California, Oregon, Idaho, and Washington. Fisheries 16(2):4-21.

NERC (North American Electricity Reliability Corporation). 2008. 2008 Long-term Reliability Assessment to ensure the reliability of the bulk power system. Princeton, NJ. October 2008.

NMFS (National Marine Fisheries Service). 2008. Endangered Species Act, Salmon Population Listings. http://www.nwr.noaa.gov/ESA-Salmon-Listings/Salmon-Populations/Index.cfm.

NMFS. 2007. Biological Opinion and Magnuson-Stevens Fishery Conservation and Management Act Consultation Construction, Post-construction Monitoring and Evaluation of a Tailrace Barrier at Packwood Lake Hydroelectric Project (FERC Project No. 2244), Cowlitz River, HUC 1708000501 Lewis County, WA.

NPPC (Northwest Power Planning Council). 2004. Cowlitz Subbasin – Upper Cowlitz. Lower Columbia Salmon and Steelhead Recovery and Subbasin Plan. Volume II, Chapter 9. Prepared by Lower Columbia Fish Recovery Board. Draft. May 28.

NRC (National Research Council). 1996. Upstream: Salmon and society in the Pacific Northwest. Committee on Protection and Management of Pacific Northwest Anadromous Salmonids. National Academy Press. Washington, DC.

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OFM (Office of Financial Management). 2007. 2007 Data Book: Timber Harvest by Ownership by County. Office of Financial Management, State of Washington. www.ofm.wa.gov/databook.

Pacific Biodiversity Institute. 1999. Gray Wolf Sightings, 1981-1998. Prepared by Pacific Biodiversity Institute, based on Washington Department of Fish and Wildlife data. www.pacificbio.org/ESIN/MapImages/graywolf.jpg. Accessed January 3, 2006.

Perez-Garcia, J. and J.K. Barr. 2005. Forest products export trends update for the Pacific Northwest Region. University of Washington College of Forest Resources, Northwest Environmental Forum, Seattle, WA. November 2005.

Richter, B.D., J.V. Baumgartner, J. Powell, and D.P. Braun. 1996. A method for assessing hydrologic alteration within ecosystems. Conservation Biology 10:1163-1174

Ruediger, Bill, Jim Claar, Steve Gniadek, Bryon Holt, Lyle Lewis, Steve Mighton, Bob Naney, Gary Patton, Tony Rinaldi, Joel Trick, Anne Vandehey, Fred Wahl, Nancy Warren, Dick Wenger, and Al Williamson. 2000. Canada lynx conservation assessment and strategy. USDA Forest Service, USDI Fish and Wildlife Service, USDI Bureau of Land Management, and USDI National Park Service. Forest Service Publication #R1-00-53, Missoula, MT. 142 pp.

Sandercock, F.K. 1991. Life History of Coho Salmon (Oncorhynchus kisutch). In C. Groot and L. Margolis (editors), Pacific Salmon Life Histories, p. 396-445. Univ. British Columbia Press, Vancouver.

Scott, W.B. and E.J. Crossman. 1973. Freshwater fishes of Canada. Bulletin 184, Fisheries Research Board of Canada. Ottawa.

Shaffer, H.B. 2005. Ambystoma gracile in M. Lannoo, ed. Amphibian Declines: The Conservation Status of United States Species. University of California Press, Berkeley, CA.

Smith, M.E. 2002. Western Washington Gray Wolf Distinct Population Segment. Certified letter to U.S. Fish and Wildlife Service. October 29. 34pp.

Stinson, D.W. 2001. Washington state recovery plan for the lynx. Washington Department of Fish and Wildlife, Olympia, WA. 78 pp. + 5 maps.

The Nature Conservancy. 2008. Global Invasive Species Team. Control Methods. http://tncinvasives.ucdavis.edu/esadocs.html. Accessed October 20, 2008.

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http://www.pacificbio.org/ESIN/MapImages/graywolf.jpg

http://www.ofm.wa.gov/databook

Thomas, J. W., E. D. Forsman, J. B. Lint, E. C. Meslow, B. R. Noon, and J. Verner. 1990. A conservation strategy for the northern spotted owl: a report to the Interagency Scientific Committee to address the conservation of the northern spotted owl. U.S. Forest Service, U.S. Fish and Wildlife Service, and National Park Service, Washington, DC. 427 pp.

USGS (U.S. Geological Survey). 2008. Daily streamflow for the nation. Washington web page. http://waterdata.usgs.gov/nwis accessed on October 27, 2008. Reston, VA.

Washington Fish and Wildlife (Washington Department of Fish and Wildlife). 2008a. Priority habitat and species list. Washington Department of Fish and Wildlife. Olympia, WA.

Washington Fish and Wildlife. 2008b. Sensitive habitat and species report. Quad Name: Packwood. Quadcode: 4612156. Washington Department of Fish and Wildlife, Priority Habitats and Species Section, Olympia, WA. Report Date: May 7, 2008.

Washington Fish and Wildlife. 2008c. Draft wolf conservation and management plan for Washington. Scientific peer review draft. Washington Department of Fish and Wildlife, Wildlife Program, Olympia, WA. August, 2008.

Washington Fish and Wildlife. 2002. Washington State elk herd plan: South Rainier elk herd. Washington Department of Fish and Wildlife, Wildlife Program, Olympia, WA. January, 2002.

Watershed Geodynamics. 2007. Engineering Needs for Access Routes Study Report. Prepared for Energy Northwest's Packwood Lake Hydroelectric Project. May.

Watershed Geodynamics. 2007a. Final Draft, Gravel Transport Study Report for Energy Northwest’s Packwood Lake Hydroelectric Project, FERC No. 2244, Lewis County, WA. July.

Weitkamp, L.A., T.C. Wainwright, and G.J. Bryant. 1995. Status review of coho from Washington, Oregon, and California. U.S. Department of Commerce. NOAA Technical Memo NMFS-NWFSC-24.

Welsh, Jr., H.H. 1993. A hierarchical analysis of the niche relationships of four amphibians from forested habitats of northwestern California. PhD dissertation submitted in partial satisfaction of requirements for degree of PhD in Wildland Resource Science in the Graduate Division of UC Berkeley.

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Welsh, Jr., H.H. and G.R. Hodgson. 2008. Amphibians as metrics of critical biological thresholds in forested headwater streams of the Pacific Northwest, USA. Freshwater Biology 53(7):1470-1488.

Welsh, Jr., H.H. and L.M. Ollivier. 1998. Stream amphibians as indicators of ecosystem stress: a case study from California’s redwoods. Ecological Application 8(4):1118-1132.

WNHP (Washington Natural Heritage Program). 2008. List of known occurrences of rare plants in Washington: Lewis County. February 2008. www1.dnr.wa.gov/nhp/refdesk/lists/plantsxco/lewis.html. Accessed September 24, 2008.

WNHP. 1997. Endangered, Threatened, and Sensitive Vascular Plants of Washington at: http://www.dnr.wa.gov/nhp/refdesk/fguide/pdf/hetore.pdf accessed on October 21, 2008.

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http://www.dnr.wa.gov/nhp/refdesk/fguide/pdf/hetore.pdf%20accessed%20on%20October%2021

8.0 LIST OF PREPARERS

Federal Energy Regulatory Commission Carolyn Templeton—Project Coordinator, Geology and Soil Resources, Recreation and

Land Use/Aesthetics, Terrestrial Resources and Threatened and Endangered Species (Environmental Biologist; B.S., Biology; M.S., GeoEnvironmental Science)

Jim Fargo—Need for Power, Developmental Analysis (Civil Engineer; M.S. Engineering)

Ken Hogan—Fisheries and Aquatic Resources and Water Resources, (Fishery Biologist; B.T., Fisheries Management and Aquaculture)

Frank Winchell—Cultural Resources (Archeologist; B.A., M.A., Ph.D., Anthropology)

Louis Berger GroupJohn Hart—Task Management, Water Resources (Hydrologist; B.A., Physics)

Marty Bowers—Cultural Resources (Principal Architectural Historian; M.A., American History)

George Gilmour—Fisheries and Aquatic Resources (Fisheries Biologist; B.A., Biology)

Kenneth Hodge—Need for Power and Developmental Analysis (Senior Engineer; B.S., Civil Engineering)

Karen Klosowski—Recreation and Land Use/Aesthetics (Senior Environmental Planner; B.S., Parks and Recreation; M.L.A., Landscape Architecture; M.U.R.P., Regional Planning)

Alison Macdougall—Cultural Resources (Senior Environmental Manager; B.A., Anthropology)

Deborah Mandell—Editorial Review (Technical Editor; B.A., Government; M.B.A., Finance and Marketing)

Eileen McLanahan—Terrestrial Resources and Threatened and Endangered Species (Wildlife Biologist; M.S., Biology)

Leslie Pomaville—Recreation and Land Use/Aesthetics (Scientist; B.S., Environmental and Natural Resources)

Denise Short—Editorial Review (Technical Editor; B.A., English; M.S., Agriculture, Food, and the Environment)

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APPENDIX A

DRAFT LICENSE ARTICLES

DRAFT LICENSE ARTICLES

I. MANDATORY CONDITIONS

On August 16, 2008, the U.S. Forest Service filed 19 preliminary 4(e) conditions, 16 of which we consider pertinent to environmental resources (described in section 2.2.4.2 of the EA). We include 1553 of these conditions in the staff alternative. On August 19, 2008, the National Marine Fisheries Service filed two section 18 prescriptions (described in section 2.2.4.1 of the EA). We include both of these prescriptions in the staff alternative. On March 6, 2009, the Forest Service filed a modified 4(e) condition 9 which is included in the staff alternative.

II. ADDITIONAL LICENSE ARTICLES RECOMMENDED BY COMMISSION STAFF

We recommend including the following license articles in any license issued for the project in addition to the mandatory conditions.

Draft Article 4xx. Downramping Adjustments Protocol. Upon license issuance, Energy Northwest shall implement a manual, downramping procedure during the decrease in the minimum flow released to the lower Lake Creek to limit the flow reduction to a maximum of 2.5 cfs per hour. The exception to this implementation is the May 31 to June 1 decrease of 15 to 10 cfs which shall occur during a one-hour period during the night-time hours. The downward ramping shall be implemented by the manual adjustment of the valve controlling the release to bypassed pipe to lower Lake Creek located at the outlet structure. Details of these adjustments shall be submitted with the Annual Submittal of Project Measurements.

Draft Article 4xx. Lake Creek Stream Gage, Flow Monitoring, and Recording. Within 180 days of license issuance, the licensee shall develop a plan to install a stream flow gage along lower Lake Creek in the vicinity of Lake Creek Road bridge. The plan shall specify a gage design in accordance with current U.S. Geological Survey standards for flow measurement accuracy, provide for the measurement of flow at intervals not greater than 15 minutes, and include a schedule for the installation of the gage within 18 months of license issuance. The gage design and supporting structures shall be constructed such that they will not hinder upstream salmonid passage into lower Lake Creek.

The plan shall be developed in consultation with the U.S. Geological Survey, U.S. Fish and Wildlife Service, National Marine Fisheries Service, the U.S. Forest Service,

53 As explained in section 5 of the EA, of the 15 conditions, we recommend modifying 3: (a) Lower Lake Creek stream restoration and monitoring (condition 7); (b) Recreation management (condition 14); and (c) Exotic and invasive vegetation management (condition 16).

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and the Washington Department of Fish and Wildlife. The licensee shall include with the plan submitted to the Commission, documentation of agency consultation, copies of comments and recommendations made in connection with the plan, and a description of how the plan accommodates the comments and recommendations of the consulted agencies. The licensee shall allow a minimum of 30 days for the consulted agencies to comment and make recommendations before filing the plan with the Commission. If the licensee does not adopt a recommendation, the filing shall include the licensee’s reasons, based on project-specific information.

The Commission reserves the right to require changes to the plan. The plan shall not be implemented until the licensee is notified that it has been approved by the Commission. Upon Commission approval, the licensee shall implement the plan, including any changes required by the Commission. Reporting of flow monitoring results shall be in accordance with the U.S. Forest Service condition 6 in Appendix X.

Draft Article 4xx. Water Temperature Monitoring Plan. Within 180 days of license issuance, the licensee shall file with the Commission for approval a Water Temperature Monitoring Plan. The plan shall provide for continuous monitoring of water temperatures in the project’s tailrace, lower Lake Creek, Packwood Lake, and the Cowlitz River annually from June 25 through October 5, for a period of 10 years. The monitoring plan shall: (1) identify specific water temperature monitoring locations within the four specified areas; (2) specify a 15 minute data recording interval for the June 25 through October 5 period; (3) specify timeframes and reasons to possibly revise the monitoring program after several years of data collection; and (4) specify monitoring equipment to be used and a monthly maintenance and inspection program for said equipment, for the period of deployment.

The plan shall be developed in consultation with the Washington Department of Ecology, Washington Department of Fish and Wildlife, the U.S. Forest Service, the National Marine Fisheries Service, and the U.S. Fish and Wildlife Service. The licensee shall include with the plan copies of comments and recommendations made on the completed plan after it has been prepared and provided to the agencies, and specific descriptions of how the agencies’ comments are accommodated by the plan. The licensee shall allow a minimum of 30 days for the consulted agencies to comment and make recommendations before filing the plan with the Commission. If the licensee does not adopt a recommendation, the filing shall include the licensee’s reasons, based on project-specific information.

The Commission reserves the right to require changes to the plan. The plan shall not be implemented until the licensee is notified that it has been approved by the Commission. Upon Commission approval, the licensee shall implement the plan, including any changes required by the Commission.

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The licensee shall prepare an annual report that summarizes the monitoring results, compares the results to applicable water temperature standards, determines whether temperatures that do not meet applicable state water quality standards are project-controllable factors, and if applicable makes recommendations for changes in project operations or facilities that may enable state water quality standards to be met, and specifies any changes to the monitoring program or project operations that are proposed for the following year based on the monitoring results.

The licensee shall provide a draft of the annual report to the Washington Department of Ecology, Washington Department of Fish and Wildlife, the U.S. Forest Service, National Marine Fisheries Service, and the U.S. Fish and Wildlife Service for review and comment prior to the annual resource coordination meeting specified in the U.S. Forest Service condition 2 in Appendix X. Within 30 days following the annual resource coordination meeting, the report shall be filed with the Commission, along with a summary of agency comments on the report, and how the final report addresses any comments received.

Draft Article 4xx. Fish Monitoring and Rescue After Annual Project Outages. Within 7 days prior to the onset of a scheduled project outage, the licensee shall inspect the Cowlitz River side channel and determine if Cowlitz River flows in this location are sufficient to support salmonids during the scheduled project outage. If not, the licensee shall capture salmonids within 12 hours of the cessation of flows resulting from the scheduled outage and place them at a location in the mainstem of the Cowlitz River where they will not be subject to stranding mortality. The number and species of salmonids captured and the gear used to collect fish shall be recorded.

In addition, within 12 hours of cessation of flow from a scheduled annual outage, the licensee shall collect salmonids by electrofishing in the tailrace upstream of the fish barrier, and within 72 hours of cessation of flow, collect salmonids by seining in the stilling basin unless alternative methods would result in more effective capture at specific locations. Captured fish shall be placed at a location in the mainstem of the Cowlitz River where they will not be subject to stranding mortality. The number and species of salmonids and gear used to collect fish at each location shall be recorded.

Methods used to capture and handle salmonids shall be in accordance with current National Marine Fisheries Service and Washington Department of Fish and Wildlife standard guidelines. Reports of the monitoring results including the methods used, number of salmonids by species successfully rescued, and recommendations for modifications of procedures for future fish rescue efforts, if needed, shall be included in the annual reports specified in the U.S. Forest Service condition 2 in Appendix X, for review and comment. Within 30 days of the annual resource coordination meeting, the reports shall be filed with the Commission, along with a summary of agency comments on the report, and how the final report addresses any comments received.

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Draft Article 4xx. Threatened, Endangered, and Sensitive Species Management Plan. The threatened, endangered, and sensitive species management plan required by U.S. Forest Service condition 12 in Appendix X shall be modified to include surveys for Oregon goldenaster prior to initiating any ground-disturbing activity along lower Lake Creek that could affect habitat for this state-listed species. It also should address whether timing restrictions would be appropriate to protect nesting bald eagles and northern spotted owls, if nests should occur in proximity to proposed stream enhancement measures along lower Lake Creek. Additionally, the plan shall address timing restrictions or other measures that may be needed to prevent adverse effects on amphibians with special status (i.e., Cascades frog and western toad) during efforts to reroute Snyder Creek. The geographic scope of the plan specified in the U.S. Forest Service condition 12 in Appendix X shall be expanded to include all lands within the project boundary.

In addition to the U. S. Forest Service, the plan shall be developed in consultation with the Washington Department of Ecology, Washington Department of Fish and Wildlife, the National Marine Fisheries Service, and the U.S. Fish and Wildlife Service. The licensee shall include with the plan copies of comments and recommendations made on the completed plan after it has been prepared and provided to the agencies, and specific descriptions of how the agencies’ comments are accommodated by the plan. The licensee shall allow a minimum of 30 days for the consulted agencies to comment and make recommendations before filing the plan with the Commission. If the licensee does not adopt a recommendation, the filing shall include the licensee’s reasons, based on project-specific information.

Draft Article 4xx. Exotic and Invasive Vegetation Management Plans. The Integrated Weed Management Plan filed with the Commission on June 6, 2008, and required by the U.S. Forest Service condition 16 shall be modified within 120 days of license issuance to include additional target species for weed control at sites downstream of the stilling basin. The revised plan shall include the area in proximity to the tailrace and areas where ground disturbance would occur at locations identified in the proposed lower Lake Creek stream restoration, enhancement, and monitoring plan specified in U.S. Forest Service condition 7 areas associated with the rerouting of Snyder Creek as required by U.S. Forest Service condition 10. The plan shall include the control of the following noxious weeds and non-native invasive plant species: Scotch broom (Cytisus scoparius); butterfly bush (Buddleja davidii); Japanese knotweed (Polygonum cuspidatum ); Himalayan blackberry (Rubus discolor); cut-leaf blackberry (Rubus laciniatus); reed canarygrass (Phalaris arundinacea); Canada thistle (Cirsium arvense); herb Robert (Geranium robertianum); common cat’s-ear (Hypochaeris radicata); and wild carrot (Daucus carota).

The revisions to the existing plan shall be developed in consultation with the Lewis County Noxious Weed Board, Washington Natural Heritage Program, and the U.S.

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Forest Service. The licensee shall include with the plan copies of comments and recommendations made on the completed plan after it has been prepared and provided to the agencies, and specific descriptions of how the agencies’ comments are accommodated by the plan. The licensee shall allow a minimum of 30 days for the consulted agencies to comment and make recommendations before filing the plan with the Commission. If the licensee does not adopt a recommendation, the filing shall include the licensee’s reasons, based on project-specific information.

The Commission reserves the right to require changes to the plan. The revised plan shall not be implemented until the licensee is notified that it has been approved by the Commission. Upon Commission approval, the licensee shall implement the plan, including any changes required by the Commission.

Draft Article 4xx. Bald Eagle Monitoring. Within 6 months of license issuance, the licensee shall begin documenting incidental bald eagle sightings in the project area with standardized forms and provide its project operators and other project personnel that work in the project area with written instructions for completing the forms. Forms shall include, at a minimum, the following information fields: date; time; observer name; locations of the observer and the bald eagle(s); number of adults or juveniles; behavior (e.g., in flight, perched, foraging); and any evidence of nesting activity. The forms shall be compiled, filed with the Commission, and provided to the resource management agencies as part of the Annual Report specified in U.S. Forest Service condition 2 in Appendix X.

If monitoring results confirm eagle nesting in the project area, the licensee shall file for Commission approval, a bald eagle nest management plan consistent with the current U.S. Fish and Wildlife Service, National Bald Eagle Management Guidelines. The plan shall be developed in consultation with the U.S. Forest Service, U.S. Fish and Wildlife Service, Washington Department of Fish and Wildlife, Washington Department of Ecology, the Cowlitz Tribe, and the Yakama Nation. The licensee shall include with the plan documentation of consultation with the tribes and agencies, copies of comments and recommendations made in connection with the plan, and a description of how the plan accommodates the comments and recommendations of the consulted entities. The licensee shall allow a minimum of 30 days for the consulted entities to comment and make recommendations before filing the plan with the Commission. If the licensee does not adopt a recommendation, the filing shall include the licensee’s reasons, based on project-specific information.

The Commission reserves the right to require changes to the plan. The plan shall not be implemented until the licensee is notified that it has been approved by the Commission. Upon Commission approval, the licensee shall implement the plan, including any changes required by the Commission.

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Draft Article 4xx. Programmatic Agreement and Historic Properties Management Plan. The licensee shall implement the “Programmatic Agreement among the Federal Energy Regulatory Commission and the Washington State Historic Preservation Officer for Managing Historic Properties that may be Affected by a License Issuing to Energy Northwest for the Continued Operation of the Packwood Lake Hydroelectric Project in Lewis County, Washington (FERC No. 2244),” executed on (future date), including but not limited to the Historic Properties Management Plan (HPMP) for the project filed with the Commission on August 30, 2007, as required by Forest Service condition 18.

In the event that the Programmatic Agreement is terminated, the licensee shall continue to implement the provisions of its approved HPMP. The Commission reserves the authority to require changes to the HPMP at any time during the term of the license. If the Programmatic Agreement is terminated, the licensee shall obtain approvals from or make modifications requested by the Commission and the Washington State Historic Preservation Office where the HPMP calls upon the licensee to do so.

Draft Article 4xx. Use and Occupancy. (a) In accordance with the provisions of this article, the licensee shall have the authority to grant permission for certain types of use and occupancy of project lands and waters and to convey certain interests in project lands and waters for certain types of use and occupancy, without prior Commission approval. The licensee may exercise the authority only if the proposed use and occupancy is consistent with the purposes of protecting and enhancing the scenic, recreational, and other environmental values of the project. For those purposes, the licensee also shall have continuing responsibility to supervise and control the use and occupancies for which it grants permission, and to monitor the use of, and ensure compliance with the covenants of the instrument of conveyance for any interests that it has conveyed under this article. If a permitted use and occupancy violates any condition of this article or any other condition imposed by the licensee for protection and enhancement of the project’s scenic, recreational, or other environmental values, or if a covenant or a conveyance made under the authority of this article is violated, the licensee shall take any lawful action necessary to correct the violation. For a permitted use or occupancy, that action includes, if necessary, canceling the permission to use and occupy the project lands and waters and requiring the removal of any non-complying structures and facilities.

(b) The types of use and occupancy of project lands and waters for which the licensee may grant permission without prior Commission approval are: (1) landscape plantings; (2) non-commercial piers, landings, boat docks, or similar structures and facilities that can accommodate no more than 10 watercraft at a time and where said facility is intended to serve single-family type dwellings; (3) embankments, bulkheads, retaining walls, or similar structures for erosion control to protect the existing shoreline; and (4) food plots and other wildlife enhancement. To the extent feasible and desirable to

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protect and enhance the project’s scenic, recreational, and other environmental values, the licensee shall require multiple use and occupancy of facilities for access to project lands or waters. The licensee shall also ensure to the satisfaction of the Commission’s authorized representative that the use and occupancies for which it grants permission are maintained in good repair and comply with applicable state and local health and safety requirements. Before granting permission for construction of bulkheads or retaining walls, the licensee shall: (1) inspect the site of the proposed construction, (2) consider whether the planting of vegetation or the use of riprap would be adequate to control erosion at the site, and (3) determine if the proposed construction is needed and would not change the basic contour of the impoundment shoreline. To implement this paragraph (b), the licensee may, among other things, establish a program for issuing permits for the specified types of use and occupancy of project lands and waters, which may be subject to the payment of a reasonable fee to cover the licensee’s costs of administering the permit program. The Commission reserves the right to require the licensee to file a description of its standards, guidelines, and procedures for implementing this paragraph (b) and to require modification of those standards, guidelines, or procedures.

(c) The licensee may convey easements or rights-of-way across, or leases of project lands for: (1) replacement, expansion, realignment, or maintenance of bridges or roads where all necessary state and federal approvals have been obtained; (2) storm drains and water mains; (3) sewers that do not discharge into project waters; (4) minor access roads; (5) telephone, gas, and electric utility distribution lines; (6) non-project overhead electric transmission lines that do not require erection of support structures within the project boundary; (7) submarine, overhead, or underground major telephone distribution cables or major electric distribution lines (69 kV or less); and (8) water intake or pumping facilities that do not extract more than one million gallons per day from a project impoundment. No later than January 31 of each year, the licensee shall file three copies of a report briefly describing for each conveyance made under this paragraph (c) during the prior calendar year, the type of interest conveyed, the location of the lands subject to the conveyance, and the nature of the use for which the interest was conveyed. If no conveyance was made during the prior calendar year, the licensee shall so inform the Commission in writing no later than January 31 of each year.

(d) The licensee may convey fee title to, easements or rights-of-way across, or leases of project lands for: (1) construction of new bridges or roads for which all necessary state and federal approvals have been obtained; (2) sewer or effluent lines that discharge into project waters for which all necessary federal and state water quality certification or permits have been obtained; (3) other pipelines that cross project lands or waters but do not discharge into project waters; (4) non-project overhead electric transmission lines that require erection of support structures within the project boundary for which all necessary federal and state approvals have been obtained; (5) private or public marinas that can accommodate no more than 10 watercraft at a time and are

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located at least one-half mile (measured over project waters) from any other private or public marina; (6) recreational development consistent with an approved report on recreational resources of an Exhibit E; and (7) other uses, if: (i) the amount of land conveyed for a particular use is 5 acres or less; (ii) all of the land conveyed is located at least 75 feet, measured horizontally, from project waters at normal surface elevation; and (iii) no more than 50 total acres of project lands for each project development are conveyed under this clause (d)(7) in any calendar year. At least 60 days before conveying any interest in project lands under this paragraph (d), the licensee must submit a letter to the Director, Office of Energy Projects, stating its intent to convey the interest and briefly describing the type of interest and location of the lands to be conveyed (a marked Exhibit G map may be used), the nature of the proposed use, the identity of any federal or state agency official consulted, and any federal or state approvals required for the proposed use. Unless the Director, within 45 days from the filing date, requires the licensee to file an application for prior approval, the licensee may convey the intended interest at the end of that period.

(e) The following additional conditions apply to any intended conveyance under paragraph (c) or (d) of this article:

(1) Before conveying the interest, the licensee shall consult with federal and state fish and wildlife or recreation agencies, as appropriate, and the State Historic Preservation Officer.

(2) Before conveying the interest, the licensee shall determine that the proposed use of the lands to be conveyed is not inconsistent with any approved report on recreational resources of an Exhibit E; or if the project does not have an approved report on recreational resources, that the lands to be conveyed do not have recreational value.

(3) The instrument of conveyance must include the following covenants running with the land: (i) the use of the lands conveyed shall not endanger health, create a nuisance, or otherwise be incompatible with overall project recreational use; and (ii) the grantee shall take all reasonable precautions to ensure that the construction, operation, and maintenance of structures or facilities on the conveyed lands will occur in a manner that will protect the scenic, recreational, and environmental values of the project.

(4) The Commission reserves the right to require the licensee to take reasonable remedial action to correct any violation of the terms and conditions of this article, for the protection and enhancement of the project’s scenic, recreational, and other environmental values.

(f) The conveyance of an interest in project lands under this article does not in itself change the project boundaries. The project boundaries may be changed to exclude land conveyed under this article only upon approval of revised Exhibit G drawings (project boundary maps) reflecting exclusion of that land. Lands conveyed under this

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article will be excluded from the project only upon a determination that the lands are not necessary for project purposes, such as operation and maintenance, flowage, recreation, public access, protection of environmental resources, and shoreline control, including shoreline aesthetic values. Absent extraordinary circumstances, proposals to exclude lands conveyed under this article from the project shall be consolidated for consideration when revised Exhibit G drawings would be filed for approval for other purposes.

(g) The authority granted to the licensee under this article shall not apply to any part of the public lands and reservations of the United States included within the project boundary.

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APPENDIX B

COMMENTS ON THE DRAFT ENVIRONMENTAL ASSESSMENTFOR HYDROPOWER LICENSE FOR THE

PACKWOOD LAKE HYDROELECTRIC PROJECT (FERC PROJECT NO. 2244)

The Federal Energy Regulatory Commission (Commission) issued its draft environmental assessment (EA) for the proposed relicensing of the Packwood Lake Hydroelectric Project on February 5, 2009. Staff requested comments on the draft EA be filed within 30 days from the issuance date (March 7, 2009).

In this appendix, we summarize the written comments received; provide responses to those comments; and indicate, where appropriate, how we modified the text in the final EA. We grouped the comment summaries and responses by topic for convenience. We did not summarize comments that point out minor edits to the draft EA; however, we have made these edits in the final EA. The following entities filed comments pertaining to the draft EA.

Commenting Entity Filing Date

Washington Department of Ecology February 27, 2009

State of Washington, Department of Fish and Wildlife March 4, 2009

Energy Northwest March 5, 2009

U.S. Department of Agriculture, Forest Service March 6, 2009

PROCEDURAL AND GENERAL

Comment 1: Energy Northwest and the U.S. Department of Agriculture, Forest Service (Forest Service) state that the draft EA is not consistent in its analysis of the alternative actions and does not clearly carry the analysis of each of the four distinct alternatives identified in section 1 throughout the document. In particular, the staff alternative with mandatory conditions is not analyzed in Chapter 5 and is difficult to recognize in the other chapters. The Forest Service has similar comments to Energy Northwest and notes that the draft EA in section 1 refers to the following alternatives: (1) No-Action Alternative, (2) Energy Northwest Proposal, (3) Energy Northwest’s proposal with staff modifications (Staff Alternative), and (4) Staff Alternative with Mandatory Conditions and that all alternatives are not fully assessed for their environmental and economic effects.

The Forest Service recommends the development of a Staff Alternative that includes Energy Northwest mitigation proposals, modified by the Mandatory Conditions and Staff additions, to bring the project into compliance with current environmental standards.

Response: The ‘Staff Alternative with Mandatory Conditions’ alternative was inadvertently referred to in chapter 1 of the draft EA. This alternative was considered in the early stages of the preparation of the draft EA, but we later decided that the ‘Energy Northwest’s proposal with staff modifications’ adequately covered the same issues. Chapter 1 in the final EA now clearly describes the three alternatives: (1) no-action alternative, (2) Energy Northwest’s proposal, and (3) Energy Northwest’s proposal with

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staff modifications (staff alternative). We note that in the draft EA, other than the one location in section 1 noted by the Forest Service, we referred to these three alternatives throughout the document except on page xv where we were summarized the estimated cost of the staff alternative with mandatory conditions, in table 4-2 where we had a column with the costs for the staff alternative with mandatory conditions, and in section 4.2.3, Staff Alternative. In the last paragraph of section 4.2.3, we discussed the cost differences associated with the mandatory conditions which we did not recommend such as supplying electrical power to the Forest Service guard station.

Comment 2: The Forest Service comments that The Wilderness Act of 1964 and 1984 be identified in section 1.3, Statutory and Regulatory Requirements.

Response: This change has been made in the final EA by the addition of section 1.3.9, Wilderness Act.

Comment 3: The Forest Service comments that the discussion in section 1.3.3, Endangered Species Act, should specify that the species under discussion are bull trout and chum salmon and that the narrative should be revised to consider critical habitat for these species.

Response: In the final EA, we revised section 1.3.3, Endangered Species Act, based on this comment and to update the consultation process and to indicate that habitat for these species is not anywhere near the project area..

Comment 4: The Forest Service comments that the analysis of the construction of the new composting toilet and the Heritage Interpretive Sign at Packwood Lake is insufficient to implement the measures without further National Environmental Policy Act analysis. The EA should include resource specialist review and analysis of any potential impacts of the construction on cultural, botanical, terrestrial and aquatic resources. The Forest Service notes that the analysis should also include discussions of access (bringing materials in for construction, servicing of the composting toilet and removal of the “product”), facility accommodation for winter conditions, and any timing restrictions for construction.

Response: In the final EA, we provide additional analysis of the potential effects of construction and maintenance of these proposed facilities on aquatic, terrestrial, and cultural resources.

PROJECT DESCRIPTION

Comment 5: The Forest Service comments that the discussion of instream flow requirements in section 2.1.3, Existing Project Operations of the draft EA, should be corrected to specify the point of compliance as “at the drop structure.” Energy Northwest similarly comments that the instream flows will be measured at the discharge end of the

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bypass pipe (just below the drop structure) using existing monitoring instrumentation and that the point of compliance for instream flows is the bypass flow in cfs measured at the drop structure by the licensee, not the flow measured at the Lake Creek gage located near the mouth.

Response: We revised section 2.1.3, Existing Project Operations, of the final EA to specify that the compliance point for the instream flow requirements is the drop structure.

Comment 6: The Forest Service disagrees with a sentence in section 2.2.1, Proposed Project Facilities, that no new project development is proposed as part of relicensing. It notes that several new project features should be considered in the context of the National Environmental Policy Act, including the kiosk and toilet construction, stream gauge installation, Snyder Creek fish passage channel rerouting, gravel and wood augmentation, and lower Lake Creek channel restoration.

Response: The wording of section 2.2.1, Proposed Project Facilities, has been changed to include the proposed project features mentioned by the Forest Service in its comment, and in the final EA we provide additional analysis of the potential effects of construction and maintenance of these proposed features in section 3, Environmental Analysis.

Comment 7: The Forest Service comments that, in section 2.2.3, Proposed Environmental Measures, in the bullet describing the spill event, the word “maximum” should be changed to “target” to reflect a modification agreed to by the parties.

Response: We revised section 2.2.3, Proposed Environmental Measures, and other areas, in the final EA to use the word ‘target’ instead of ‘maximum’ when describing the habitat enhancing spill events since changes beyond the control of the applicant could affect the length of the spill event.

Comment 8: The Forest Service comments that section 2.2.4.2 of the draft EA is inconsistent with section 4 and should be modified to acknowledge that an economic analysis for continuing to provide power to the guard station is provided in section 4 of the draft EA. In addition, the Forest Service disagrees with the Commission staff’s conclusion that continuing to provide power to the guard station has no nexus to the project. The Recreation Plan includes a measure that Energy Northwest provide annual operation and maintenance or annual funding for a seasonal employee to occupy the guard station during high visitation months.

Response: In the EA we provide cost information for providing power to the guard station because it is part of the Recreation Management Plan. In the final EA, we add a statement in section 2.2.4.2 that we provide cost estimates for this provision in section 4, Developmental Analysis. However, as stated, the guard station is not the result of the Packwood Lake Hydroelectric Project; and therefore has no nexus to the project. In

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addition, as summarized in the EA, it has been the policy of the Commission to leave the disposition of project power in hands of the licensee.

Comment 9: The Forest Service comments that the staff alternative should be clearly articulated in section 2.3 and that staff should enumerate which measures from Energy Northwest’s proposal are adopted and where staff has modified the proposal. In addition, staff should clearly identify if it adopts or modifies any Forest Service term and condition, Washington Department of Fish and Wildlife (Washington Fish and Wildlife) 10(j) recommendation or NMFS mandatory condition. The Forest Service specifically points to discrepancies in section 2.3 where the staff modifications include four additional measures and in the cost differences discussion in section 4.

Response: In section 2.3 Staff Alternative, we indicate the three added staff measures to Energy Northwest’s proposal. Sections 2.2.4.2, Section 4(e) Land Management Conditions, and 5.4.2, Land Management Agencies’ Section 4(e) Conditions, provide a listing of mandatory terms and conditions that we determined are specific environmental measures. Section 5.4.1, Recommendations of Fish and Wildlife Agencies, provides a summary of the 10(j) conditions that we recommend or do not recommend adopting. Based on the Forest Service comment and the revisions associated with the final EA, we have clarified the discrepancies between section 2.3 and section 4. In the final EA we recommend adopting all of the Forest Service 4(e) conditions that we determine to be specific environmental measures.

CUMULATIVELY AFFECTED RESOURCES

Comment 10: The Forest Service comments that the geographic scope in section 3.2.1 is described, without a rationale, for water quality and fisheries, but not for rare plants and weeds. The temporal scope is described (again only for water quality and fisheries, and without a rationale) only for the future time horizon, and not for the past time horizon. The scope of the project should include all proposed actions associated with this relicense including the restoration projects described in the Forest Service’s 4(e) terms and conditions and Washington Fish and Wildlife 10 (j) recommendations. In addition, the Forest Service comments that the geographic scope described in section 3.2.1 is considerably different than the planning area boundary.

Response: As summarized in SD2, participants in the scoping process identified the potential for cumulative effects on fish and aquatic resources in the Cowlitz River basin; on fish and aquatic resources in the Lake Creek watershed; and on wildlife species, shorelines, and wetlands (as a result of lake level drawdowns) as concerns that should be addressed in the EA. Based on scoping comments followed by our independent analysis, we determined that Project operation could also cumulatively affect water quality, but we did not identify cumulative effects on rare plants or weeds. In the final EA, we added

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text to section 3.2.1 to clarify the resources that we evaluated for cumulative effects, and the geographic scope of the analysis.

AQUATIC RESOURCES

Comment 11: Washington Fish and Wildlife comments that site-specific features should be considered when applying Hunter’s (1992) criteria for ramping rates. Washington Fish and Wildlife states that Energy Northwest only has the ability to artificially induce rapid decreases in flow during the aquatic habitat forming flows, which will occur normally only during the winter or spring and about every other year. Because the main potential for stranding of fish exists in the lower elevation and moderate gradient sections of Lake Creek where fall-spawning Chinook and coho salmon fry could be potentially vulnerable to stranding in the late winter and spring from the aquatic habitat forming flows, stranding for resident rainbow trout in the upper elevation and steeper sections should not be an issue. Therefore, Washington Fish and Wildlife suggests that ramping compliance should be measured at the proposed gage site in the lower/anadromous section of lower Lake Creek.

Energy Northwest recommends that FERC withdraw its recommended ramping rates for several reasons, including: (1) the project has limited ability to effect large changes in ramping rates due to the projects uncontrolled spillway; (2) flows in excess of bankfull (285 cfs) are rare and not a concern to Washington Fish and Wildlife; (3) flows released from the drop structure can take up to 5 hours to reach the lower reaches of Lake Creek; (4) the small step decreases in the instream flow releases (3 to 5 cfs increments) will result in minimal hourly changes in lower Lake Creek and will be moderated by natural accretion; (5) information provided in the Packwood Lake Drawdown and Lake Creek Ramping Rate Plans (2005) indicate that a ramping rate of 2 inches per hour would require a lake level change of 0.10 feet per hour which is beyond the capability of the project; (6) plant operations can only affect a lake level change of about 0.05 feet per hours which correlates to about 1 inch per hour in lower Lake Creek; (7) the only reasonable ramping rate restriction might be the zero ramping rate condition during daylight hours in the February 16 to June 15 time frame and would only apply to flows of 285 cfs or less; and (8) the monitoring station for ramping rate compliance should be the new lake Creek gage which will have 15 minute recording intervals.

Response: In the draft EA, our recommendation to implement Washington Fish and Wildlife’s interim ramping rate criteria in lower Lake Creek was based on a general concern that project operations (flow reductions associated with process flows and minimum flow adjustment) could potentially result in downramping conditions that would be detrimental to resident and potentially anadromous salmonids (particularity ESA-listed species in the anadromous zone of Lake Creek). Based on information filed in response to our draft EA, data presented at the April 27, 2009, public meeting in Olympia, Washington, indicating that downramping ramping rates would not likely

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exceed 2.4 inches per hour during both process flows and downward adjustments in minimum instream flows (under the 5 cfs per hour reduction scenario). Based on a filing of a Lake Creek Ramping Rate Plan by Energy Northwest on June 9, 2009, Energy Northwest is now proposing to limit all instream flow reductions associated with the minimum flows to a maximum of 2.5 cfs per hour, in order to comply with the Washington Fish and Wildlife’s seasonal downramping rate criteria. One exception to the 2.5 cfs per hour rate is the June 1 reduction in flow, which would be completed in one hour during night-time hours. These manual flow decreases would be implemented by adjusting the valve on the bypass pipe controlling the release of the flow at the drop structure. We recommend existing project-specific constraints on downramping and Energy Northwest’s proposed Lake Creek Ramping Rate Plan for minimum flows in the final EA since they would adequately protect aquatic resources in lower Lake Creek.

Comment 12: Energy Northwest and the Forest Service, commenting about the entrainment discussion in the draft EA, note that, during a project relicensing meeting on February 11, 2009, with NMFS, the Forest Service, Washington Fish and Wildlife, and Washington Department of Ecology, the Forest Service presented a modified 4(e) condition (no. 9) with a biological monitoring element, so that if biological impingement criteria is not met, or there is a decline in population due to project operations, a major screen modification would be required and designed to meet Washington Fish and Wildlife screen criteria. Both Energy Northwest and the Forest Service comment that the draft EA be revised to include and approve this revised 4(e) condition.

Response: In the final EA we now recommend the modified 4(e) condition 9 and its associated biological monitoring component. The conditions specified in the modified Forest Service 4(e) would provide adequate protection for fish at this site and based on our analysis; would not likely result in a major fish screen redesign or modification. In addition, as recommended in draft EA, modified Forest Service 4(e) condition 9 would incorporate extensive biological monitoring to determine whether O. mykiss spp. are significantly harmed by the project intake. If monitoring demonstrates that O. mykiss spp. densities are being affected by the project, Energy Northwest would be required to take action to remedy the effects.

Comment 13: Washington Fish and Wildlife and Energy Northwest both state that the recommended screen approach velocities at the Packwood Lake Project are <0.80 foot/second over 95 percent of the screen area, and 0.88 foot/second over 99 percent of the screen area for all intake flows and lake elevations to protect, mitigate, and enhance desirable native fish populations. In addition, Energy Northwest notes that the recommended approach velocities for the Packwood Lake Project, determined by Washington Fish and Wildlife, were changed from 0.33 foot/second to the <0.80 and 0.88 foot/second values. Washington Fish and Wildlife also objects to the notion that costs of replacing intake screens at the facility (estimated $1.6M) are excessive and other possibly cheaper options should be investigated to reduce velocity at the screen. Other options set

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forth by Washington Fish and Wildlife include: baffles to redistribute the flow and removal of part of a concrete wall located immediately upstream of the screen surface.

Washington Fish and Wildlife comments that preliminary indications are that the rainbow trout stock involved is ‘redband’ trout, or closely related to the redband trout which are candidates for ESA-listing. Even if this stock is not listed in the future, it is still a valuable genetic resource. Finally, Washington Fish and Wildlife states that 500 fish per year, not including fry, represent a potential mortality of 25,000 fish over a 50 year license. Washington Fish and Wildlife suggests that since the lake is on public land and is a popular recreational fishery, the worse case costs for screen replacement are not excessive. Washington Fish and Wildlife requests adherence to its previously listed approach screen criteria of ≥0.80 ft/sec over 95 percent of the screen surface, and ≥0.88 over 99 percent of the screen surface.

Response: We modified the referenced text to reflect that the recommended screen approach velocities are <0.80 foot/second over 95 percent of the screen area and <0.88 foot/second over 99 percent of the screen area for all intake flows and lake elevations. We also added text to indicate that these criteria were changed from the more restrictive 0.33 foot/second (fry criteria) value.

While baffles or other modifications to structures located immediately upstream of the project’s screens could eventually lead to lower approach velocities, based on the information we have, we doubt that relatively minor modifications to the intake would result in consistency with Washington Fish and Wildlife’s recommended criteria. As a result, we have developed our cost estimate associated with the recommended measure to reflect a worst case scenario (e.g., replacing the existing screens with new ones). Following issuance of the draft EA, we reviewed the Forest Service’s modified 4(e) condition 9 requiring the development of a Packwood Lake Intake Fish Entrainment Monitoring Plan that includes periodic fish population and entrainment monitoring with set impingement criteria. Under this revised 4(e) condition, we do not think the worst case scenario (rebuilding the screens to meet state criteria) is likely, and we have confidence in our modified 4(e) condition 9 cost estimate. Capturing all potential costs associated with a recommended measure ensures full public disclosure of potential project costs and helps to support an informed Commission decision concerning what is in the public interest with respect to a proposed license.

We agree with Washington Fish and Wildlife that the native rainbow trout population in Packwood Lake represents a valuable public resource and that the population should be protected from substantial entrainment-related losses. We also agree with Washington Fish and Wildlife that minor modifications to the screens and intake could result in a decrease in annual entrainment, even if approach velocities continue to exceed the state’s criteria. However, we note that the most recent entrainment data collected by Energy Northwest indicate that far fewer than Washington Fish and Wildlife’s example of 500

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fish are entrained at the project in a “typical” year (i.e., 60 fish in 2008) and that the timing of peak entrainment is consistent with the late post-spawning period for rainbow trout (i.e., many of these impinged fish were likely naturally weak or dead fish). As described above, we reviewed the Forest Service’s modified 4(e) condition 9 requiring the development of a Packwood Lake Intake Fish Entrainment Monitoring Plan. Under this condition, if monitoring data indicate the modifications made at the intake structure do not meet the pre-determined impingement criteria then Energy Northwest would modify the screens or evaluate other methods to meet the state approach velocity criteria. We recommend this measure and find that its implementation would adequately protect trout at the project intake.

Comment 14: Energy Northwest requests that the discussion of monitoring the intake screens for entrainment should be revised to include 2008 data from the Packwood Lake Intake Screen Velocity Test Report, November 2008.

Response: We updated the discussion in section 3.3.1.2 of the final EA to include information from the Packwood Lake Intake Screen Velocity Test Report. This report shows that maximum velocities at the existing screens continue to exceed the state’s velocity criteria. As a result, the data presented in this report did not affect our conclusions regarding project entrainment.

Comment 15: Energy Northwest disagrees with the Commission’s conclusion on page 96 of the draft EA that “Properly functioning fish screens would likely eliminate or substantially reduce entrainment related mortality at this site and its associated effects on the Packwood Lake fishery.” Energy Northwest states that it believes it is more likely that naturally weak or dead fish are being drawn into the intake and impinged on the screens rather than healthy fish being impinged solely as a result of screen velocity.

Response: We agree that many of the impinged fish were likely naturally weak or dead following spawning and have revised the final EA to reflect this. In our analysis, we note that it is likely that many of fish that were entrained in 2007 were in a weakened condition following the peak spawning period. These data support our conclusion regarding project entrainment.

Comment 16: Energy Northwest comments that the draft EA contains a condition requiring the submittal of a Water Temperature Monitoring Plan. Energy Northwest notes that this plan was filed with the Commission on June 6, 2008 and suggests that the discussion in the EA be expanded to include the plan’s proposed measures and approval, as appropriate.

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Response: We discuss and analyze the Water Temperature Monitoring Plan, which was filed on June 6, 2008, in section 3.3.1.2 of the final EA. Based on our analysis, we are recommending implementation of the Water Temperature Monitoring Plan. The draft license article for this requirement can be found in appendix A of the final EA

Comment 17: Energy Northwest comments on a reference in the draft EA to 19.46° Celsius (°C) as the 7-DADmax temperature for the end of the tailrace canal. Energy Northwest notes that this value and the associated range of temperatures cannot be verified. Further, it notes that the correct 7-DADmax temperatures for the end of the tailrace canal can be found in the draft EA in tables 3-5 and 3-6 and are 21.25°C for 2004 and 20.83°C for 2005.

Response: We made this correction in section 3.3.1.2 of the final EA.

Comment 18: The Forest Service comments that staff erroneously refers to Packwood Lake as naturally warm when in fact the lake temperature study depicted a pronounced thermocline at water temperature monitoring sites in Packwood Lake. The Forest Service comments that the lake surface may be warm but there is a natural strong temperature gradient in the lake. It requests that all references to lake temperatures should specify Packwood Lake “surface water temperatures.”

Response: Modifications to the final EA have been made to specify that, when discussing the warm lake water temperatures of Packwood Lake, we are referring to the surface water.

Comment 19: With regard to the rerouting of Snyder Creek as a fish passage corrective action, Energy Northwest comments that it, in consultation with the agencies, determined that a 5-year schedule was appropriate for rerouting Snyder Creek. The schedule included preparing a plan for stream restoration and relocation by year 2 and completing the physical work in year 5. Energy Northwest notes that this schedule conflicts with the schedule in the draft EA which calls for “developing and implementing a plan (within 2 years of license issuance).

Response: Our review indicates that your proposed schedule for rerouting Snyder Creek is reasonable; therefore, we revised the staff alternative in the final EA to concur with that schedule.

Comment 20: Energy Northwest comments that the collection of salmonids by electrofishing in the tailrace canal and seining of the stilling basin, as recommended in the draft EA, are not longer necessary due to the installation of a fish barrier in the fall of 2007. Energy Northwest is in its second year of testing the efficacy of the barrier and comments that the draft EA should reflect the limited seining and electrofishing schedule currently in place at the project.

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Response: We modified our recommendation in the final EA to support the existing multi-year barrier testing program. Monitoring and maintaining the effectiveness of this screen and reporting the results of monitoring in an annual report, as required by NMFS in its Biological Opinion (NMFS, 2007), would likely continue to prevent the upstream migration of resident and anadromous fish into the project tailrace and stilling basin and thus minimize any potential adverse effects on these species associated with project operations and maintenance.

Comment 21: Energy Northwest comments that consultation with USGS and the resource agencies regarding compliance with USGS standards and use of weirs to not hinder salmonid fish passage will not be necessary because the site of the proposed gage is the location of a previous USGS gage and there is no need for a weir or other stage control device at this site.

Response: We revised the wording in section 3.3.1.2 of the final EA slightly as a result of this comment. However, even though the location is the site of a previous USGS gage, we still recommend consultation with USGS and other agencies for the construction and maintenance of a new gage to ensure compliance with current USGS standards.

Comment 22: Energy Northwest requests that the language in the draft EA around temperature mitigation be clarified. It notes that shade tree plantings will be used along the tailrace canal and not the Cowlitz River.

Response: We clarified the text in section 3.3.1.2 of the final EA to reflect the possibility of tree planting along the tailrace canal.

Comment 23: Energy Northwest requests that in its discussion of why the maintenance outage was moved to August 15, that staff make mention of temperature mitigation, since moving the outage avoids the discharge of naturally warmed surface water from Packwood Lake. In addition, Energy Northwest notes that the rapid drawdown that occurs prior to the maintenance outage under the current license will no longer occur and that the fall drawdown under a new license would be gradual and would provide uninterrupted project operations to maintain an uninterrupted tailrace flow for spawning and incubating fish.

Response: We added clarification text in the final EA on these two topics throughout various sections of the final EA including in section 3.3.1.2.

Comment 24: Energy Northwest comments that page 56 of the draft EA includes the phrase “No carcasses were observed during any of the surveys.” Energy Northwest notes that this is incorrect and that coho carcasses were observed. On one survey alone, nearly 20 carcasses were observed in lower Lake Creek at the site of the temporary gage.

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Response: The sentence was developed using the information provided on page E.5.3-96 of the final license application. Based on your comment, we modified the final EA to indicate that coho carcasses were observed in lower Lake Creek at the site of the temporary gage.

Comment 25: Consistent with the staff recommendation, Energy Northwest endorses and recommends using hydroacoustic surveys to measure the Packwood Lake population of trout.

Response: We recommended using biological monitoring to estimate trout abundance in Packwood Lake and agree that hydroacoustic surveys are one of several methods that could be used to monitor trout populations in Packwood Lake.

Comment 26: The Forest Service requests that all references to “resident rainbow trout” be clarified. It suggests that Packwood Lake fish may be more accurately described as Oncorhynchus mykiss spp. until the subspecies is verified. In addition, since non-indigenous fish have not been stocked in the lake since 1965, the Forest Service requests that staff clarify that there has been no genetic introgression of hatchery stocks with natural resident fish in Packwood Lake based on existing electrophoretic assessment.

Response: We changed all references to “resident rainbow trout” in the final EA to Oncorhynchus mykiss spp. We also clarified that, based on existing electrophoretic assessment, there has been no genetic introgression of hatchery stocks with natural resident fish in Packwood Lake.

Comment 27: The Forest Service comments on the Commission’s conclusion that pipeline, surge tank, and penstock monitoring is related to project safety and is required regardless of the outcome of the relicensing procedure. The Forest Service included 4(e) condition 15 because the pipeline, surge tank, and penstock are located on National Forest Service (NFS) lands and failure of any of these features poses an environmental risk to NFS land and resources. Therefore, there is cost involved with plan preparation and cost due to any potential failures; and Forest Service 4(e) condition 15 should be included in the EA.

Response: In the draft EA and the final EA, we maintain that the pipeline, surge tank, and penstock monitoring are related to project safety and therefore fall under the jurisdiction of the Commission’s Division of Dam Safety and Inspections. During the term of a new license the Commission staff would continue to inspect the project to assure continued adherence to Commission-approved plans and specifications, operation and maintenance, and accepted engineering practices and procedures. We recognize the concern of the Forest Service on this issue, but a license article on this topic would result in a duplication of effort with the Division of Dam Safety and Inspections.

Comment 28: The Forest Service notes that the draft EA should drop or clarify the reference to out-migrant traps in section 3.3.1.1, Packwood Lake Tributaries, because no

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fish were captured. In addition, it recommends that staff clarify that Reach 5 is below the dam with distinct hydrology from upper Lake Creek. In section 3.3.1.1, Lake Creek, the Forest Service comments that staff should clarify its statement on sediment transport. It agrees that the current concrete dam structure does function as a physical hydrologic grade control and effectively prevents the natural downstream transport of sediment. Furthermore, it notes that current dam operations water control management (i.e., up to an 8 feet drop in forebay water elevation Oct – May) has moderated peak flows downstream of the lake. Consequently, it notes there is a considerable reduction in sediment transport function. However, the Forest Service states the pre-project channel form and function was far different from the current configuration; the natural earthen dam structure composed of unconsolidated slide material was commonly reworked by lake out-flowing water and subject to significant seasonal floods. Therefore, according to the Forest Service, the natural pre-project conditions provided lower Lake Creek with both an ample source of sediment and flow conditions highly conducive to transport bedload material.

Response: We deleted our reference to outmigrant traps in section 3.3.1.1 because no fish were captured, and we have added text to clarify that Reach 5 is below the dam with distinct hydrology from upper Lake Creek. Based on your comment, we have also added text indicating that the unconsolidated slide material at the lake’s outlet was likely reworked by flood flows and that the pre-project conditions likely provided lower Lake Creek with both an ample source of sediment and flow conditions more conducive to transport bedload material.

Comment 29: The Forest Service comments that the presentation of juvenile fish movement in Packwood Lake has been inconsistent and is disputed by the aquatics committee. Specifically it suggests that there are little data to support the statement in section 3.3.1.2, Packwood Lake Elevation Restriction, that “very few fish use the littoral zone” and that this statement should be qualified as inconclusive.

Response: We added text to the final EA stating that Energy Northwest asserts that very few fish use the littoral zone of Packwood Lake; however, there are little data to support that hypothesis, but this addition does not affect our conclusions.

Comment 30: The Forest Service comments that the discussion of planned/unplanned shutdowns in section 3.3.1.2, Annual Project Maintenance Outage (Tailrace Slough), requires more substance and analysis before a decision/biological opinion can be made.

Response: We respectively disagree and find that our level of analysis is appropriate for an EA since providing NMFS with a record of all planned and unplanned shutdowns and any fish salvage efforts will provide enough information to evaluate any adverse impact on ESA-listed species. Added enhancement and protection to ESA-listed species in this location would also be provided by the proposed water temperature monitoring, changes

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in the timing of the project shutdown, and the installation of the tailrace barrier in October 2007.

Comment 31: The Forest Service comments that the discussion of restoration benefits in section 3.3.1.2, Lower Lake Creek Stream Restoration and Enhancement Plan, and the discussion of ground-disturbing activities in section 3.3.2.2 (Noxious Weeds) should identify that the potential outcome is contingent upon landowner agreement allowing work on private land in the lower 1.0 mile of Lake Creek.

Response: The outcome of the Lower Lake Creek Stream Restoration and Enhancement Plan would depend on site-specific conditions, appropriate design, and successful implementation, rather than on landowner agreements. The extent of ground disturbance (and thus the extent of potential weed introduction) at each site that may be selected for stream enhancement projects would depend on the area that is needed to accomplish site-specific objectives. We anticipate that the enhancement projects could be accomplished through agreements with adjacent landowners, or that necessary land would be acquired through easements or in fee title.

Comment 32: The Forest Service comments that the EA should clarify that the very inflated numbers presented in the stream enhancement discussion are a function of modeled predictions on a very poor existing condition of the lower 1.0 mile reach. The Forest Service also comments that the discussion of habit forming flows in section 3.3.1.2, Aquatic Habitat Forming Flows in Lower Lake Creek, is confusing and that sustaining flows for 24 hours is a minimum target established to meet the habitat forming objectives. It notes that flows that persist less than 24 hours are likely not to meet the desired future condition based on the gravel study.

Response: We have added text clarifying that the inflated weighted useable area numbers presented in the stream enhancement discussion area a function of modeled predictions on a very poor existing condition of the lower 1.0 mile reach. We also added text clarifying our discussion of habitat forming flows in section 3.3.1.2.

TERRESTRIAL RESOURCES

Comment 33: The Forest Service comments that preliminary Forest Service 4(e) condition 16 has been modified since the draft EA. The draft EA includes measures to address control of Scotch broom, butterfly bush, Japanese knotwood, reed canarygrass, Himalayan blackberry, or cutleaf blackberry at three sites: tailrace, lower Lake Creek, and Snyder and Hall creeks. The Forest Service recommends that Commission staff adopt the modified 4(e) condition 16, concurring with the staff recommendation that the Integrated Weed Management Plan be amended to include control of the suggested weed species and locations.

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Response: The final EA recommends the adoption of Forest Service 4(e) condition 16, with the modification described in your comment.

Comment 34: The Forest Service notes that there is no mention of Management Indicator Species defined in the Gifford Pinchot National Forest Land and Resource Management Plan (as amended). Although the Forest Service expects effects on all of these species to be small or non-existent, it notes that these species should be mentioned and discussed.

Response: In the final EA, we added a brief assessment of Management Indicator Species to sections 3.3.2.1 and 3.3.2.2 to address these species.

Comment 35: The Forest Service comments that it would be useful to include a summary table listing all special status species and an effects determination by alternative for each one. The Forest Service also comments that it would be useful to include a summary table listing all threatened and endangered species and an effects determination by alternative for each one.

Response: Section 3.3.2.2 discusses current project effects (no action), effects of agency terms, conditions and recommendations, and effects of additional staff recommendations on the special status species (bald eagle, osprey, and amphibians) that were identified during scoping as being of concern. Effects determinations for federally listed species are shown in the summary table in section 1.3.3 (table 1-2), and would be the same under any of the alternatives.

Comment 36: The Forest Service comments that the cumulative effects analysis for Terrestrial Resources is vague and does not provide any indication or quantity, or any specific listing or description of projects or trends, past, present, or future that contribute to the cumulative effects outside of the Packwood Lake Hydroelectric development.

Response: In response to your comment, we added more specific information to define the geographic scope and focus the section on resources identified for cumulative effects analysis during scoping. We note that these changes do not alter our conclusion that relicensing the project, with the implementation of staff-recommended measures, would contribute to cumulative terrestrial resource benefits of other activities that are ongoing in the project area.

THREATENED AND ENDANGERED SPECIES

Comment 37: The Forest Service comments that Commission staff modified the monitoring schedule specified in preliminary Forest Service 4(e) condition 12, Threatened, Endangered, and Sensitive Species. The Forest Service condition specifies that monitoring will occur every 2 years for 6 years following license issuance and at 3-year intervals thereafter, unless a determination can be made at year 6 that no additional

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monitoring is necessary. The frequency in the draft EA is for monitoring every 2 years for 6 years, following license issuance and every 5 years thereafter to evaluate project effects. The Forest Service recommends that Commission staff adopt without modification the monitoring frequency identified in Forest Service 4(e) condition 12 as it provides greater frequency of monitoring.

Response: In the draft EA, we noted that Forest Service 4(e) condition 12 includes monitoring known occurrences of sensitive species every 2 years for 6 years following license issuance and then every 3 years unless it can be determined at year 6 that additional surveys are not warranted. The condition also recommends incorporating Energy Northwest’s Rare Plant Management Plan, as filed, into the threatened, endangered, and sensitive species plan. It was our understanding that Energy Northwest’s Rare Plant Management Plan called for monitoring known occurrences of sensitive plants species at 2-year intervals for 6 years following license issuance and then at 5-year intervals, but upon further review, we note that the slightly longer survey interval applies only to the Oregon goldenaster and Peltigera pacifica occurrences that have been documented to date. In the final EA, we clarify that we are adopting condition 12 without change to any survey schedules and that the only modification is the addition of surveys and/or potential timing restrictions for Oregon goldenaster, bald eagles, northern spotted owls, and amphibians in areas where ground disturbance could adversely affect them.

Comment 38: The Forest Service notes that although there have been no reports or documented occurrences of gray wolves in the project area, there have been many reports of them in the Cowlitz and Cispus river drainages. It recommends that the Commission assume that gray wolves are present in the project area, at least seasonally, and discuss and analyze potential effects on this species including the potential for noise disturbance.

Response: We modified the text in sections 3.3.3.1 and 3.3.3.2 to provide more information about the basis for our conclusion that gray wolves are not currently present in the project area. In addition, we note that Energy Northwest is not proposing, nor is staff recommending, implementation of any measures that would remove or alter habitat or the prey base for this species, or increase the risk of disturbance. If documented in the future, the gray wolf would be addressed as part of the threatened, endangered, and sensitive species management plan.

RECREATIONAL RESOURCES

Comment 39: The Forest Service comments that preliminary Forest Service 4(e) condition 14 has been modified in the draft EA. The draft EA eliminates the maintenance measures associated with Dyson Pass trail segment. It also eliminates the funding to be used for a seasonal employee who would help provide enforcement and education of the public regarding Forest Service management. The EA excludes Snyder Road (FS 1260) from the project boundary and eliminates the provision which would require Energy

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Northwest to supply the Forest Service guard station with electricity. The Forest Service recommends that Commission staff adopt without modification preliminary Forest Service 4(e) condition 14.

Response: As stated in the draft EA and maintained in the final EA, the measures associated with the funding for the seasonal employee, for the electricity at the guard station and for Snyder Road would all be actions not related to project purposes. The measures for the funding of the seasonal employee and the electricity at the guard station are not consistent with the Commission’s policy (Policy Statement on Hydropower Licensing Settlements, Docket No. PL06-5-000, issued September 21, 2006) on hydropower settlements which states that the Commission has no way of ensuring that the hiring of personnel paid for by the licensee or other non-project related measure, such as the electricity to the guard station, would actually accomplish a project purpose or ameliorate a project-related effect. As shown in the relicensing studies conducted by Energy Northwest and discussed in the EA, the use of Snyder Road by the public for general recreational access and other reasons is in excess of 98 percent of the total use; therefore, we continue to not recommend that these measures be included as a license requirement or that the road be included in the project boundary.

Comment 40: Energy Northwest comments that it opposes the expansion of the project boundary as described in the draft EA due to cost issues and lack of benefit. It notes that the three recreation installations (historic sign, trail kiosk, and toilet) are minor structures which it agreed to install and maintain for the Forest Service. They are not related to project operations and would be considered Forest Service property, since recreation is managed exclusively by the Forest Service. In addition, under the current license Energy Northwest has performed all the maintenance on Pipeline Road (FS 1260-066) and connecting Trail #74. All of this road and trail is not currently within the project boundary and inclusion of all would provide no benefit and would only increase project costs. The Dyson Pass segment of Trail #74 is still used to access the project and is not the trail that was used as a bypass around the landslide on Latch Road (FS 1262). Finally, Energy Northwest comments that inclusion of Latch Road (FS 1262) and Powerhouse Road (FS 1260-013) is unneeded and the existing maintenance agreement with the Forest Service is satisfactory to both parties.

Response: Energy Northwest proposes as part of the license application to implement and maintain the sign, trail kiosk, and toilet facilities over the term of a new license. Energy Northwest also proposes to maintain Pipeline Road and the connecting FS Trail No. 74. As noted by Energy Northwest, this road and trail are used by Energy Northwest to maintain access to the project facilities. The purpose of our recommended expansion of the project boundary is to ensure that lands and ongoing measures associated with project purposes are brought into the project boundary so the Commission has the authority to administer the required components over the term of a new license. We revised the final EA to correct the Dyson Pass segment for FS Trail 74 discussion as

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noted by Energy Northwest, and this trail section is shown on figure 3-15 in the final EA. We modified the final EA to include the Dyson Pass segment within the project boundary as it provides primary access to the project as stated by Energy Northwest.

Comment 41: Energy Northwest notes that the draft EA does not include any estimate regarding the cost associated with expanding the project boundary. It comments that a cost estimate including the cost of new land surveys and revisions to project-related maps should be included. In addition, any estimate should include the annual land fees that will be charged by the Commission and the Forest Service for occupation of the new land and the escalation of those costs over time.

Response: With any relicense alternative there would be some costs associated with surveying and modifying the project maps. In the preparation of an EA, we do not balance these administrative costs against the need to ensure that lands associated with project purposes are within the project boundary so the Commission has the authority to administer the required components of the new license.

Comment 42: The Forest Service comments that staff inconsistently applied designation of the project boundary for mitigation measures in sections 4.4 and 5.2. Staff did not include the lower Lake Creek Restoration and Enhancement area, the Dyson Pass segment, and the Snyder Road in the project boundary.

Response: Energy Northwest proposes to conduct ongoing monitoring and mitigation measures with the lower Lake Creek Restoration and Enhancement area and this is also part of the FS 4(e) condition 7. Energy Northwest states that the Dyson Pass segment is used as a key access route by Energy Northwest to the project. Therefore, in order to ensure ongoing monitoring and implementation of proposed mitigation measures for the Lake Creek Restoration and Enhancement area and to ensure project access over via the Dyson Pass segment, we recommend in the final EA that Energy Northwest include the lower Lake Creek Restoration and Enhancement area and the Dyson Pass segment into the project boundary. The purpose of our recommended expansion of the project boundary is to ensure that lands and ongoing measures associated with project purposes are brought into the project boundary so the Commission has the authority to administer the required components of the new license.

Comment 43: The Forest Service comments that staff incorrectly identifies an outhouse north of the trailhead in section 3.3.4.1, Project Area Recreational Facilities. The outhouse is not longer there.

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Response: We updated the final EA to delete reference to this outhouse.

DEVELOPMENTAL ANALYSIS

Comment 44: Energy Northwest comments that the draft EA does not include cost estimates for water conveyance monitoring or the fire prevention plan. Energy Northwest notes that it lumped the costs to develop these items in its estimate for the Resource Coordination Plan in the application.

Response: We presented the costs in the same manner as presented by Energy Northwest. Thus, as Energy Northwest points out, the costs to implement the water conveyance monitoring (item 24 in table 4-4) and fire prevention plan (item 25 in table 4-4) are not shown separately for items 24 and 25, but are included in the cost of the Resource Coordination Plan (item 21 in table 4-4). We determined that the combined cost was adequate for this measure.

Comment 45: Energy Northwest also comments that staff should prepare a cost estimate for evaluating project facilities for formal National Register eligibility in 2014.

Response: We added a separate measure for the evaluation of National Register eligibility to the developmental analysis section and estimate a cost of $25,000 in 2014.

Comment 46: The Forest Service notes that Commission staff excluded developmental analysis of preliminary Forest Service 4(e) condition 9 (Entrainment in Project Intake), filed with the Commission on August 16, 2008.

Response: In the draft EA, we recommended the implementation Energy Northwest’s 3-phase, adaptive management plan to reduce entrainment at the project intake. In the final EA, we now recommend the adoption of the modified Forest Section 4(e) condition 9, Entrainment at Project Intake, and the developmental analysis of that measure is included in section 4, Developmental Analysis.

Comment 47: The Forest Service recommends that the costs associated with plan preparation and cost due to any potential failures of the pipeline, surge tank, and penstock (4(e) condition 15) be included in the environmental analysis because the failure of any of these structures could affect Forest Service lands and resources.

Response: These costs are incorporated under item 22 in table 4-3. We presented the costs in the same manner as presented by Energy Northwest. Thus, the costs to implement the water conveyance monitoring as recommended by the Forest Service (item 25 in table 4-3) are not shown separately for item 25, but are included in the cost of the Resource Coordination Plan (item 22 in table 4-3). Energy Northwest states that the Resource Coordination Plan would include measures for pipeline, surge tank, and

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penstock monitoring; thus, the costs associated with the monitoring would be included under this line item.

Comment 48: The Forest Service comments that the proposed costs for the individual measures appear insufficient to fully fund the project and requests that staff describe its analysis process.

Response: We accepted the cost estimates provided by Energy Northwest for the measures it proposed as being reasonable estimates. Where costs were not provided by Energy Northwest, Commission staff estimated costs for those measures. Regardless of the estimated cost, Energy Northwest would be required to fulfill its obligations under the terms and conditions of a new license at whatever actual cost is required to fulfill those obligations. The costs estimates provided in the Developmental Analysis are not intended to be not-to-exceed costs for implementation of those measures.

Comment 49: The Forest Service recommends that the EA include a section 4.2.4, Staff Alternative with Mandatory Conditions to better display the cost of this alternative and to coordinate with the data displayed in table 4.2.

Response: The last paragraph of section 4.2.3, Staff Alternative, of the EA has a paragraph summarizing the cost of the Staff Alternative with Mandatory Conditions which includes providing power to the Forest Service Guard Station. With this information in section 4.2.3, and the very slight difference between two alternatives, we contend that there is no need for a section 4.2.4.

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