Download A. Project Background and Description

UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
PacifiCorp
)
)
Application For New Major License
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_______________________________________)
Project No. 1927-008
North Umpqua
Hydroelectric Project
AMERICAN RIVERS, OREGON NATURAL RESOURCES COUNCIL, UMPQUA
WATERSHEDS, UMPQUA VALLEY AUDUBON SOCIETY, STEAMBOATERS,
OREGON TROUT, PACIFIC RIVERS COUNCIL, AND WATERWATCH OF
OREGON’S COMMENTS AND RECOMMENDATIONS
I. INTRODUCTION
In January 1995, PacifiCorp filed an application for a new major license for the North
Umpqua Hydroelectric Project, No. 1927. This application was most recently amended by
PacifiCorp in February 2000. The original license expired in 1997. On November 15, 2000,
the Federal Energy Regulatory Commission (Commission) issued a Notice of Application
Ready for Environmental Analysis and Soliciting Comments, Recommendations, Terms and
Conditions, and Prescriptions. The Notice established a comment deadline of March 1, 2001.
American Rivers, Oregon Natural Resources Council, Umpqua Watersheds, Umpqua
Valley Audubon Society, Steamboaters, Oregon Trout, Pacific Rivers Council, and
WaterWatch of Oregon (collectively, the Conservation Groups) hereby submit the following
comments and recommendations pursuant to 18 C.F.R. § 4.34(b) and 18 C.F.R. §385.2010.
A.
Project Background and Description
The North Umpqua River is one of the most beautiful rivers in the Pacific Northwest.
Renowned for its excellent steelhead fly fishing, it provides a unique challenge to anglers
from all over the world. According to the North Umqpua Business Association, “[t]he
beautiful North Umpqua with a long history of angling, and a renowned reputation world
wide, in one of Southern Oregon’s most wild and scenic rivers.
The North Umpqua Hydroelectric Project was constructed between 1947 and 1956
near the headwaters of the North Umpqua River. The project is located almost entirely
within the Umpqua National Forest on the North Umpqua River, Fish Creek, and the
Clearwater River. The 185-megawatt hydroelectric project consists of eight hydroelectric
developments – Lemolo No.1, Lemolo No.2, Clearwater No.1, Clearwater No.2, Toketee,
Fish Creek, Slide Creek, and Soda Springs – which each consist of a dam, penstock, and
powerhouse. Additionally, the Project has created three reservoirs (Lemolo, Toketee and
Soda Springs), an impoundment at Stump Lake, four forebays (Lemolo No.2, Clearwater
Nos.1 and 2, and Fish Creek), 21.7 miles of canal, 9.8 miles of flume, 5.8 miles of penstock
and tunnels (total waterway length of 37.3 miles), 117.5 miles of transmission lines and 36
miles of access roads. The Project is operated to maximize peak power production with 68
percent of the energy being produced on peak on an annual basis. If the project were
operated as run of river, peak power would be produced 57 percent of the time. Total power
production would be the same in either case.
Various state and federal agencies have legal mandates and responsibilities
applicable to the licensing of the North Umpqua Hydroelectric Project. Because the Project
is located almost entirely within lands managed by the U.S. Forest Service, that agency has
substantial authority to develop conditions necessary for the adequate protection and
utilization of the land reservation affected by the Project. The primary sources of
management direction for the Forest Service related to this licensing are: the Umpqua Land
and Resource Management Plan or “Forest Plan”; the North Umpqua Wild and Scenic River
Management Plan; and the Northwest Forest Plan, particularly the Aquatic Conservation
Strategy (ACS) component of that plan. The management direction in these documents
necessary to adequately protect the land reservation affected by the Project focuses on the
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enhancement, preservation, and restoration of the structure and function of the aquatic and
related ecosystems, including, but not limited to, water quality, anadromous fish habitat,
aquatic and riparian dependent species habitat and connectivity, terrestrial habitat
connectivity, and watershed processes.
B.
Project Impacts
Due to the extent of project features across the landscape, for more than 50 years, the
North Umpqua Hydroelectric Project has adversely affected a variety of aquatic and
terrestrial ecosystems. Alteration of ecosystem functions has been substantial. Impacts to the
ecosystem include: 1) drastically reduced streamflows in bypassed reaches of streams; 2)
fluctuating flows and reservoir elevations; 3) blockage of upstream passage for both
anadromous and resident fish; 4) entrainment of fish, amphibians, and terrestrial animals at
unscreened diversions; 5) interruption of downstream transport of gravel and large woody
material; 6) increased erosion and sedimentation from construction, Project facilities, and
roads; 7) stranding and killing of fish downstream of the Project due to rapid changes in the
river levels during low summer flows; 8) disruption of terrestrial habitat connectivity; 9)
disruption of aquatic and riparian habitat and connectivity in small tributaries and headwater
streams; 10) inundation of unique stillwater, wetland, and riverine riparian habitats by
reservoirs and forebays; 11) reduction in water quality and progressive eutrophication of the
North Umpqua River.
As part of its 1995 license application, PacifiCorp initiated a comprehensive
watershed analysis that evaluated the ecological integrity of a 987 square mile area in the
upper North Umpqua watershed. The science based, multi-agency cooperative analysis,
carried out by a Science Team and a Resource Team, resulted in issuance of the “North
Umpqua Cooperative Watershed Analysis Synthesis Report” in 1998. The Watershed
Analysis identified six comprehensive issues for analysis. These include (1) fluvial
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geomorphic processes, channel morphology, and aquatic and riparian habitats, (2) aquatic and
riparian habitat connectivity, (3) instream flows, (4) reservoir and forebay management, (5)
water quality, (6) anadromous fish passage and offsite mitigation, and (7) terrestrial habitat
connectivity and wildlife entrapment. These issues were evaluated to get a better
understanding of the impacts of the hydroelectric project and to evaluate the biological
impacts of various potential operational and physical modifications of the project. The
Watershed Analysis was supplemented with additional studies and further analysis, primarily
in response to Additional Information Requests from the Commission.
1.
Flow Regime
The North Umpqua Hydroelectric Project has significantly affected the flow regime
in the basin. It has drastically reduced the minimum flows in the river by diverting between
50-95 percent of the river flow. The rate at which stream discharge and water surface
elevation changes occur has been altered due to peaking operations and project maintenance.
Flow releases have altered the natural hydrograph, with high flows occurring in the bypass
reached only infrequently and at a time of year when they do not naturally occur. Further, the
project, including canals and access roads, has intercepted and/or diverted numerous small,
perennial, and intermittent tributary streams and seeps.
The effects of such changes have been great. Existing minimum flows fail to
adequately protect the aquatic resources in the North Umpqua basin or to support a fully
functioning ecosystem. The quantity and quality of available habitat has been reduced,
stream temperatures and benthic invertebrate production have been adversely affected, and
natural geomorphological processes have been interrupted. Additionally, flow reductions
have contributed to channel narrowing in some areas, including the Clearwater No.1 and
Lemolo No.1 bypass reached. The existing flow regime does not represent a balanced use of
our public water resources.
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Furthermore, project induced fluctuations in bypass and, particularly, full flow
reaches have adversely affected aquatic ecosystems, fish populations, and non-fish aquatic
and riparian associated species within and below the Project area. The effects vary depending
on the particular facility and stream reach, however, fluctuations result in stranding and
mortality of juvenile salmonids and other aquatic wildlife; disruption of fish spawning
activity; temporary loss of and permanent alteration to aquatic and riparian habitat; reduced
fish, amphibian, and invertebrate production; and alteration of the substrate compromising
spawning conditions. Approximately 35 miles of stream are affected by project induced
ramping within the 8 bypass reaches. For example, daily flow fluctuations at the Lemolo
No.2 powerhouse adversely affect the low gradient, unconfined reach downstream. This
reach is a highly productive and diverse habitat type that is rare in the North Umpqua Basin.
However, macroinvertebrate scores are among the lowest within the project area and the
fluctuations substantially impact sensitive amphibians and mollusks in that reach. Ramping
below Soda Springs dam can be detected up to 32 miles below the dam in the designated
Wild and Scenic reach of the river.
Also, although it appears that the project has had a minimal effect on high flow
events, and only slightly more on two-year events, flow releases related to project
maintenance must be better managed. Such flows from Soda Springs dam have the capability
to scour salmonid eggs and maintenance-related high flows throughout the project can
adversely affect amphibian and macroinvertebrate communities. Scheduled project
maintenance should consider the natural flow timing and periods when sensitive life stages of
native aquatic species are at risk.
2.
Geomorphic Process, Channel Morphology
Fluvial geomorphic processes create the physical basis for aquatic and riparian
habitat conditions by delivering sediment and organic material to stream channels and
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transporting this material downstream. The quantity, quality, and timing of sediment and
large woody debris delivery and storage shape channel morphology. The Project (canals,
dams, diversions) has altered the geomorphic characteristics of the North Umpqua basin in a
number of ways, resulting in adverse impacts to aquatic species in the basin. It has modified
stream channels through interruption of large woody debris transport, water diversions,
sediment capture, inundation of limited unconfined stream reaches, and elimination of
wetland habitat. The dams reduce sediment supplies to and block coarse sediment delivery to
downstream reaches. They have trapped up to 100 percent of bedload and up to 80 percent of
suspended load. The North Umpqua below Soda Springs has experienced a reduction in
bedload supplies by 95 to 100 percent. Such alteration of the sediment regime have reduced
spawning gravel and made the river more susceptible to coarsening.
The North Umpqua Cooperative Watershed Analysis Synthesis, Volume 2, Table 22, outlines many of the site-specific impacts of the project on erosion and sedimentation.
Included are the inundation and continued occupation of unusual and complex aquatic
habitats at Stump Lake and Lemolo Lake, decreases in bedload supply and transport capacity
at many of the facilities, and channel narrowing due to low flows in several bypass reaches.
All of these effects illustrate the significant impact that the North Umpqua Hydroelectric
Project has on the river ecosystem.
3.
Anadromous Fish Resources
The North Umpqua River is world renowned for its anadromous fish resources and
historically supported large commercial fisheries for coho, chinook, and steelhead. Five
anadromous fish species known to occur in the North Umpqua River system have been
adversely affected by the Project. These include chinook salmon, steelhead, coastal cutthroat
trout, coho salmon, and Pacific lamprey. Although steelhead and spring chinook are
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considered stable, both are well below their historical abundance. Due to their different life
histories, they have been affected to varying degrees and from a range of impacts.
Since construction of the Project, Soda Springs and Slide Creek dams (the two most
downstream dams in the Project), have reduced the historical distribution of anadromous fish,
which used to migrate as far upstream as Toketee Falls and into the Fish Creek basin. Built
without fish passage, the two dams have eliminated access to potentially important spawning,
rearing, and holding habitat for anadromous fish. Additionally, they have adversely impacted
miles of habitat below the Project through altered flow regimes, trapped sediment and large
woody debris, and disrupted physical process. The quality of habitat in the Toketee bypass
reach, once accessible by anadromous fish, has also been greatly reduced due to diminished
sediment transport and low flows resultant from upstream dams.
Due to its design and location, Soda Springs dam causes a significant portion of the
adverse effects attributable to the hydropower project. As noted, it blocks upstream and
downstream passage of fish and has disconnected the majority of the North Umpqua
mainstem from Fish Creek. Fish Creek basin lies predominantly within the Western
Cascades geomorphic province, which is a major source of coarse sediment and large woody
debris to the North Umpqua River. These materials are important to the ecological integrity
of the Wild and Scenic reach of the river, but have not been transported to that area because
of the dam. The dam does not have any facilities for the effective handling and transport of
sediment or large woody debris into the North Umpqua River below the dam, and in fact, has
substantially reduced sediment and spawning gravels to downstream areas. Soda Springs
dam also inundates one of the largest and highest value mainstem spawning areas, adversely
affects water quality, and provides habitat for a large number of brown trout, an exotic
species that competes with and preys upon native species.
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4.
Aquatic and Riparian-dependent Species
In addition to adversely affecting anadromous salmonids, the Project also harms a
range of aquatic and riparian-dependent species including resident rainbow trout, amphibians,
small mammal, some bird, and macroinvertebrate populations throughout the project area.
The principal harm results from extensive habitat and population fragmentation, and
reduction in the quantity, quality, function, and processes of habitat. Habitat quantity and
quality has been reduced as a result of the creation of stillwater habitats, changes in sediment
delivery, insufficient stream flows, and flow and reservoir fluctuations.
Project dams prevent or restrict movement of fish and other aquatic organisms. Fish
Creek and Lemolo No.2 have fish ladders, although only the Fish Creek ladder is functional
and neither serves the needs of species other than fish. The project impoundments, including
Lemolo, Stump, and Toketee lakes, have inundated and eliminated floodplain and wetland
habitats, transformed free flowing streams into stillwater or low velocity habitats, and
increased predation. They are unsuitable habitat for many native aquatic species.
Further, the Project causes entrainment of fish and wildlife at all of the facilities of
the North Umpqua Hydroelectric Project. Due to the different facility configurations and
stream reach characteristics, varying levels of entrainment of fish and wildlife occur
throughout the Project and different mitigation measures are needed to address the impacts.
Entrainment at Lemolo No.1 coincides with low lake levels and rapid water withdrawal from
the lake, maintaining the lake at full stable pool provides the best means to mitigate for
entrainment at that facility. Entrainment at intercepted and diverted tributary streams would
be reduced through reconnection of stream and riparian reserves and modifications to the
canals.
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5.
Water Quality
As part of the licensing process, the proposed project must comply with applicable
water quality standards through state certification of water quality compliance under the
Clean Water Act section 401. These standards consist of three components: (1) existing or
potential beneficial uses, (2) numeric and narrative criteria to support the designated
beneficial uses, and (3) anti- degradation. The proposed protection, mitigation, and
enhancement measures must provide a reasonable assurance that the Project will comply with
the three water quality components for the relevant parameters.
Currently, numerous waters within the project area fail to meet Oregon water quality
standards. Standards for temperature, dissolved oxygen, pH, total dissolved gas, project
habitat modification, nuisance algae, and flow modification are exceeded in project affected
reaches. Although there is limited information on some project specific data, it is clear that
the existence and operation of the hydropower project have diminished water quality in the
North Umpqua basin.
Significant flow reductions in the bypass reaches have modified stream temperatures,
increasing temperatures over what they would be without the project in some instances (i.e.
Fish Creek during the summer months), and decreasing them in others (i.e. Toketee bypass
reach during the summer months). Temperature changes adversely affect concentrations of
dissolved oxygen and growth rates of aquatic organisms, which in turn, affect the abundance
and survival of aquatic organisms. Stream temperature is also altered due to the presence of
reservoirs. Outflow from Lemolo Lake is warmer than inflow from the North Umpqua River
during most of the summer; this change may extend as far downstream as the Wild and
Scenic stretch of the river. And, the daily and annual variation in water temperatures in the
North Umpqua and Clearwater rivers, and Fish Creek have been altered as a result of the
project.
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Although the North Umpqua system is nitrogen limited, it is undergoing progressive
eutrophication, due in part to the trapping of organic material in reservoirs and subsequent
decomposition and release of nutrients downstream. This is directly related to exceedences
of pH and dissolved oxygen criteria. Eutrophication also increases turbidity and disrupts
aquatic food webs. Such effects are detrimental to the health of fish in the project area.
Additionally, several powerhouses – Clearwater Nos.1 & 2, Lemolo Nos.1 & 2 –
contribute to total dissolved gas water quality limited conditions.
6.
Terrestrial Resources
The Project consists of 21.7 miles of canal, 9.8 miles of flume, 5.8 miles of penstock
and tunnels (total waterway length of 37.3 miles), 117.5 miles of transmission lines and 36
miles of access roads, all of which contribute to adverse affects on terrestrial habitat
connectivity and significant habitat fragmentation in the Project area. This habitat
fragmentation affects a number of at risk species. Species such as amphibians and small
mammals that have patchy population structures are affected to the greatest degree.
Terrestrial species also are subject to entrapment and resulting mortality in project
waterways. Although the effect of entrapment on population viability is not clear, species
with long generation times, limited dispersal abilities, and patchy distributions are adversely
impacted and are likely to have decreased wildlife population persistence and reduced
biological diversity when considering cumulative effects of all activities in the upper North
Umpqua watershed.
II. CONDITIONS AND RECOMMENDATIONS
To date, little mitigation, including changes in project operations, has been provided
for the longstanding impacts noted above. Unfortunately, the mitigation measures proposed
by PacifCorp in its license application fail to bring the Project up to current environmental
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standards. In the face of continuing impacts, PacifiCorp proposes to maintain the Project as a
peaking facility and is resistant to any substantial operational or structural modifications of
the Project, resulting in the continual decline of our public resources. Accordingly, the
Conservation Groups take this opportunity to set forth recommendations to partially remedy
the continuing damage to the North Umpqua ecosystem caused by the North Umpqua Project.
These recommendations are based primarily on the North Umpqua Cooperative Watershed
Analysis and supplemental studies and analysis. Our goal is to restore more fully functioning
aquatic and terrestrial ecosystems, which require diverse, complex, and connected habitats in
the project area. An alternative consistent with these recommendations strikes a better
balance between power production and “the protection, mitigation of damage to, and
enhancement of, fish and wildlife (including related spawning grounds and habitat), the
protection of recreational opportunities, and the preservation of other aspects of
environmental quality,” than the alternative proposed in PacifiCorp’s license application. 16
U.S.C. §797(e) Although the Project may experience some reduction in peaking potential, it
will still be an economically viable facility operated in a run of river manner.
A.
Term of the License
The Conservation Groups recommend that the Commission issue a hydropower
license for continued operation of the North Umpqua Hydroelectric Project for a term of 30
years.
Rationale:
Due to the ongoing adverse impacts from the Project and the relatively minimal
structural and capital investments, a 30 year license is in the public interest.
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B.
Instream Flows
For the protection, mitigation, and enhancement of aquatic resources, concurrent with
the issuance of any new license for the Project, PacifiCorp shall provide the following
minimum instream flows in the identified river reaches, consistent with Alternative F in
Existing Information Analysis (EIA) Module 8.1
1) Lemolo No.1 Bypass Reach
July 1 – April 30
Minimum flow releases shall be 130 cubic feet per second (cfs)
May 1 – June 30
Minimum flow releases shall be 150 cfs
2) Lemolo No.2 Bypass Reach
May 1 – June 30
Minimum flow releases shall be 170 cfs
July 1 – October 31
Minimum flow releases shall be 120 cfs
November 1 – April 30
Minimum flow releases shall be 170 cfs
3) Toketee Bypass Reach
a. Without passage at Slide Creek Dam
July1 – November 30
Minimum flow releases shall be 150 cfs
December 1 – June 30
Minimum flow releases shall be 200 cfs
b. If passage at Slide Creek Dam is provided
1
The instream flows must not be inconsistent with any state instream water rights within and below
the Project area.
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September 1 – October 31
Minimum flow releases shall be 200 cfs
November 1 – August 31
Minimum flow releases shall be 275 cfs
4) Clearwater No.1 Bypass Reach
Year round
Minimum flow releases shall be 120 cfs
5) Clearwater No.2 Bypass Reach
Year round
Minimum flow releases shall be 128 cfs
6) Fish Creek Bypass Reach
July 1 – October 31
Minimum flow releases shall be the entire flow of the river
November 1 – December 31
Minimum flow releases shall be 80 cfs
January 1 – June 30
Minimum flow releases shall be 160 cfs
7) Slide Creek Bypass Reach
a. Prior to Soda Springs dam removal in year five of the license
July1 – November 30
Minimum flow releases shall be 100 cfs
December 1 – June 30
Minimum flow releases shall be 125 cfs
b. After Soda Springs dam removal in year five of the license
Year round
Minimum flow releases of 400 cfs
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8) Soda Springs Bypass Reach
a. Prior to Soda Springs dam removal in year five of the license
September 1 – October 31
Minimum flow releases shall be 250 cfs
November 1 – August 31
Minimum flow releases shall be 300 cfs
b. After Soda Springs dam removal in year five of the license
The entire river flow
Within one year of license issuance, PacifiCorp shall develop and implement a
comprehensive monitoring and evaluation program to determine the sufficiency of the above
specified flows. Additionally, measuring gauges shall be installed and maintained at all
project developments to ensure instream flow levels are being met.
Rationale:
The hydroelectric Project has significantly altered base flows (the low flows that
occur between storm events), high flows that occur in response to snowmelt or rainfall runoff,
and ramping rates (the rate that stream discharge and water surface elevation changes)
throughout the Project area and downstream for more than 30 miles. The effect of the Project
on flows was identified as an area of particular concern due to the significant adverse
impacts. Adequate flows are necessary to address the effects that such hydraulic
modifications have had on aquatic ecosystems within the Project. The proposed flow regime
mimics the natural hydrograph, is within the natural range of variability, and is necessary to
maintain aquatic processes, provide properly functioning aquatic habitat for anadromous and
resident fish as well as macroinvertebrate communities, and further the goals of overall
ecosystem integrity. Sufficient flows also are necessary to address water quality problems
related to temperature, dissolved oxygen, and pH in numerous stream reaches in the Project
area.
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Conservation Groups’ Comments and Recommendations
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The flows proposed by the Conservation Groups are based on the North Umpqua
Cooperative Watershed Analysis and Existing Information Analysis (EIA) Module 8 –
Instream Flows attached hereto and are designed to provide functioning aquatic ecosystems.
They consider the needs of anadromous fish if present, resident native fish, amphibians and
other riparian dependent species, and macroinvertebrates, flows to address water quality
problems, and the timing and magnitude of reference flows.
C.
Ramping
For the protection, mitigation, and enhancement of all aquatic resources, PacifiCorp
shall operate the entire project in a run of river manner concurrent with issuance of a license.
The only exception to run of river operations shall be project maintenance, for which the
following ramp rates will apply, consistent with EIA Module 8 – Instream Flows attached
hereto.
Stream Reach
Upramping
Rate
Downramping Time of Year
Rate
Lemolo No. 2
0.1 ft/hr
0.1 ft/hr
mid October – June 30
Clearwater No.1
0.1 ft/hr
0.1 ft/hr
mid October – June 30
Clearwater No.2
0.17 ft/hr
0.1 ft/hr
mid October – June 30
Toketee and SlideCreek
0.25 ft/hr
0.1 ft/hr
mid October – June 30
Fish Creek
0.4 ft/hr
0.2 ft/hr
November 1 – June 30
Soda Springs
0.17 ft/hr
0.17 ft/hr
December 1 – March 31
Lemolo No. 1 and
Rationale:
An operational scenario that eliminates Project-induced fluctuations will minimize
the adverse effects on aquatic ecosystems and fish, amphibian, and other wildlife populations
in and below the Project area. Flow fluctuations caused by peaking operations are
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Conservation Groups’ Comments and Recommendations
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detrimental to aquatic, terrestrial, recreational, and aesthetic resources. They result in direct
mortality, stranding, disruption of spawning activity, displacement, temporary loss of habitat,
reduced production, and alteration of the substrate compromising spawning conditions for
early life stages of salmonids, amphibians, macroinvertebrates, and other wildlife such as
riparian ground nesting birds. A run of river operation with specified minimum flows would
maintain restore natural flow regimes and ecological integrity in the Project area, would
maintain the designated purposes of the Wild and Scenic River below the Project, and would
minimize mortality to anadromous salmonids and other wildlife.
D.
Restoration of Mainstem Connectivity at Soda Springs Dam
Within two years after the issuance of its license, PacifiCorp shall supplement the
existing study on the decommissioning of Soda Springs Dam for review by the public and
federal and state agencies. PacifiCorp shall complete the necessary permitting and complete
removal of Soda Springs dam and other associated facilities and developments within five
years after issuance of its license. Removal shall be in a manner designed to minimize the
downstream effects to the North Umpqua River. Concurrent with removal, PacifiCorp shall
construct a tailrace barrier at the Slide Creek powerhouse.
Rationale:
Soda Springs dam is responsible for a disproportionate amount of the adverse
impacts to aquatic resources attributable to the Project and is identified in the Watershed
Analysis as the highest priority for improvement to habitat connectivity. Removal of Soda
Springs dam provides the most effective means to provide fish passage and increase
anadromous fish and other wildlife populations, and has the highest likelihood of restoring
ecosystem processes in the North Umpqua River. As a result, numerous parties involved in
the relicensing recommended that the dam be removed in order to meet ecosystem, fish
passage and habitat, and production goals. Unimpeded upstream and downstream passage
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will allow anadromous fish, including Pacific lamprey, and other aquatic and ripariandependant species to access and utilize the upper reaches of the mainstem North Umpqua
River and Fish Creek, increasing the amount of available high quality habitat by at least about
seven miles. Pacific lamprey and potentially steelhead may also gain access to an additional
forty miles of habitat in Fish Creek above an existing boulder jam.
Currently, spring chinook production in the North Umpqua basin is limited by the
availability of high quality spawning habitat. Soda Springs dam and reservoir inundate one
of the four alluvial features that occur within the project area. Removal of the dam and
conversion of the reach now inundated by the reservoir from a reservoir to a river channel
will restore this alluvial feature and provide additional spawning habitat. It is estimated that
smolt production will increase by 1.6 percent for steelhead, 2.4 percent for chinook, and 2.2
percent for coho as a result of conversion of the reach. This increase is in addition to that
attributable to areas upstream of the reservoir, but will not be realized without removal of the
dam. Overall, removal will increase spawning habitat for the upper half of the Wild and
Scenic Reach by approximately 30 percent and represents a four fold increase in the upper
seven miles where most of the spring chinook spawn.
Fish passage alternatives would be of limited benefit to some anadromous fish
species, but of little or no benefit to Pacific lamprey and other aquatic and riparian-dependent
wildlife. Predation in the reservoir and entrainment at the dam will be eliminated with the
removal of Soda Springs dam, as will poor reservoir conditions that expose smolts to disease
risks.
Removal will also restore delivery of sediment and large woody debris from Fish,
Slide, and Medicine Creeks to the Wild and Scenic Reach of the North Umpqua River. The
coarse sediment and large woody material from Fish Creek, in the Western Cascades
geomorphic province, plays an important role in the ecological integrity of that reach.
Restoring these regimes in a high priority management objective.
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Conservation Groups’ Comments and Recommendations
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We recognize that removal of Soda Springs dam will have some short-term adverse
effects on downstream aquatic resources due to the release of sediments currently trapped
behind the dam. However, scientific analysis has concluded that the long-term benefits to be
gained by removal will outweigh the short-term effects such as increases in turbidity,
suspended sediment, and fine sediment deposition. Ultimately, removal is expected to
provide positive benefits to aquatic species and water quality and create sediment and
turbidity regimes in the mainstem North Umpqua River that more closely approximate
natural conditions.
At 11 megawatts, the Soda Springs powerhouse is the smallest unit in the project and
on average, it produces only about 7 percent of the total energy from the Project. The Soda
Springs dam also aids in reregulating flows so that the peak power production from the
project can be increased from 57 percent to 68 percent of the energy. The reregulation does
not change the total energy production and the economic value of the Project is still very
favorable without reregulation by Soda Springs Dam.
E.
Restoration of Mainstem Connectivity at Slide Creek Dam
Within five years of license issuance, a Technical Committee comprised of the
license holder, appropriate federal and state agencies, and non governmental organizations
shall determine whether effective upstream and downstream fish passage should be provided
at Slide Creek Dam, dependent upon an evaluation of and determination that there has been
sufficient recovery of habitat conditions in the Toketee bypass reach to warrant passage.
Within one year of a determination to provide passage, PacifiCorp shall complete all
necessary study and design work, permitting, and construction of passage facilities.
Concurrent with provision of passage, PacifiCorp shall construct tailrace barriers at Toketee
and Fish Creek powerhouses. If a determination is made that fish passage is not warranted,
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PacifiCorp shall contribute an additional $5million to the Habitat Restoration Fund outlined
below.
Rationale:
Passage at Slide Creek Dam will provide several species of anadromous fish access
to 1.4 miles of potentially very high quality mainstem spawning, adult holding, and juvenile
rearing habitat. In addition to increasing production, providing passage will fully restore
anadromous fish to their historic range. The absence of a reservoir behind this relatively low
dam, in conjunction with its engineering design, suggests that simply providing effective fish
passage would be of substantial benefit. This is in contrast to Soda Springs Dam where both
the dam and reservoir cause significant adverse impacts to water quality, anadromous fish
habitat, and watershed processes. Passage should not be restored until after the habitat
quality in the Toketee bypass reach has been restored and the Technical Committee has
determined that passage is warranted. Restoration of the presently degraded habitat will be
dependent on effective restoration of sediment and flow regimes in the that reach.
F.
Aquatic and Riparian Connectivity
1. PacifiCorp shall:
(a) reconnect the following areas such that upstream and downstream movement of
aquatic and riparian organisms is unimpaired and that flow, sediment, and large wood
regimes are fully restored: (1) Bear Creek to the Clearwater River; (2) the Clearwater River
to the North Umpqua River below Toketee Dam; (3) Warm Springs Creek and Riparian
Reserve corridor with the North Umpqua River
(b) modify the powerhouse and canal at Clearwater No.2 to functionally reconnect
Mowich Creek and the Riparian Reserve corridor to the Clearwater River
(c) remove the diversions on Mill, Helen, Karen, Spotted Owl, Thorn, White Mule,
Potter, and Deer Creeks.
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Conservation Groups’ Comments and Recommendations
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(d) restore riparian reserve habitat and connectivity in small tributaries and headwater
streams within the Project area
as more fully described in EIA Module 1A, 1B, and 7 attached hereto.
2. PacifiCorp shall:
(a) maintain the existing Fish Creek ladder to ensure its effectiveness
(b) develop and implement the appropriate measures, in consultation with federal and
state fish agencies, to reduce entrainment at the Fish Creek intake
(c) conduct a study to determine the appropriate modifications of the Fish Creek
facility to ensure that coarse sediment is delivered down Fish Creek as opposed to being
trapped behind the current structure and implement such modifications within two years of
license issuance
(d) conduct a study of entrainment of Pacific lamprey and other anadromous fish
concurrent with removal of Soda Springs dam and determine, in consultation with a
Technical Committee comprised of the license holder, appropriate federal and state agencies,
and non governmental organizations, what, if any, additional measures are required to reduce
entrainment.
Rationale:
Aquatic and riparian connectivity is important for maintaining healthy populations of
species across a landscape. Reconnection of tributary streams and restoration of riparian
reserve habitat and connectivity will provide increased flows, restoration of the sediment
regime, and improved mobility of aquatic and riparian species, mitigating for some of the
effects of the Project.
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Conservation Groups’ Comments and Recommendations
20
G.
Habitat Restoration and Enhancement
1.
Large Woody Debris Management Plan
Within nine months of license issuance, PacifiCorp shall file for Commission
approval a large woody debris management plan intended to restore the natural large wood
regime to the extent possible. This plan may be modified upon removal of Soda Springs
Dam, at which time it is anticipated that the restoration of the large wood regime in the lower
part of the river would occur. The plan shall include a monitoring program to determine the
effectiveness of the large woody debris transport program. PacifiCorp shall develop the plan
in coordination with an Aquatics Technical Team consisting of representatives from federal
and state agencies and non governmental organizations.
Rationale:
Project facilities have altered the delivery, transport, and retention of large wood
within and below the Project. Restoration of this important watershed process is needed.
2.
Mitigation for Inundated Wetland and Riverine Habitats
Within one year of license issuance, PacifiCorp shall file for Commission approval a
site plan for creation and improvement of at least eight wetlands within or in the immediate
vicinity of the Project areas as set forth as condition #7 in the attached EIA Module 2
(1/26/01 draft).
Rationale:
Lemolo reservoir, Toketee reservoir, Stump reservoir and Lemolo No.2 forebay
inundate and occupy about 3 miles of stream and riparian habitat and at least 30 to 50 acres of
what historically was unique wetland habitats. There is currently little, or no, stillwater
habitat associated with the reservoirs that is suitable and is isolated from predation by nonnative brown and brook trout. Habitat restoration and creation is an effective means of
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Conservation Groups’ Comments and Recommendations
21
mitigating a portion of the habitat losses and alterations due to the presence of the dams and
reservoirs. The creation and restoration of wetlands habitat will restore and maintain the
ecological health of the watershed and physical and biological processes necessary for
aquatic and riparian-dependent species.
H.
Water Quality
1. PacifiCorp shall implement the instream flow regime outlined above concurrent
with license issuance.
2. PacifiCorp shall make the necessary modifications and operational changes to
reduce total dissolved gas levels at the Lemolo No. 1, Lemolo No.2, Clearwater No. 1, and
Clearwater No. 2 powerhouses according to a schedule developed by the Oregon Department
of Environmental Quality. Changes will be accompanied by the appropriate monitoring to
demonstrate how the modifications have brought the Project into compliance with total
dissolved gas criteria.
3. PacifiCorp shall develop and implement a plan to address progressive
eutrophication in the North Umpqua basin according to a schedule developed by the Oregon
Department of Environmental Quality.
4. PacifiCorp shall implement all measures required pursuant to the Clean Water Act
section 401 certification process.
5. PacifiCorp shall develop and implement a long-term, comprehensive monitoring
program to ensure that water quality standards are being achieved and adverse trends in water
quality are being addressed through protection, mitigation, and enhancement measures.
PacifiCorp must establish permanent water quality monitoring sites above, below, and within
the Project
Rationale:
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Conservation Groups’ Comments and Recommendations
22
The existing project and operations contribute to exceedences of several water
quality standards within the Project area. These must be addressed to bring the Project into
compliance with applicable water quality standards. The existing flow regime contributes to
water quality problems throughout the project area and therefore, improving flows is a high
priority mitigation measure. Sufficient flows are necessary to address temperature, dissolved
oxygen, pH, and other related water quality problems in numerous stream reaches in the
Project area. Also, powerhouse operations contribute to exceedences of total dissolved gas
standards in several locations.
I.
Erosion Control Plan
PacifiCorp shall implement Alternative 3 – Partial Pipe Burial as described in the
August 14, 1998 Response to FERC Additional Information Request (AIR) Letter dated
March 16, 1998, Volume 2 of 4 (incorporated herein by reference).
Rationale:
Project induced mass wasting, particularly along the Fish Creek, Clearwater No.2,
and Lemolo No.2 waterways has significantly and adversely affected the ecological integrity
and functioning of the impacted watersheds. Studies were begun in 1992 and supplemented
in subsequent years to identify and prioritize existing and potential erosion sites within the
Project area. Each of the identified erosion sites were assigned to one of five categories
based on the risk they pose to environmentally sensitive areas. In response to a March 16,
1998 AIR from FERC, alternatives for stabilizing the prioritized sites were developed.
Alternative 3 (Partial Pipe Burial) as described in the August 14, 1998 response would
replace selected segments of Lemolo No.2, Clearwater No.2, and Fish Creek canals with
buried steel pipeline. Reconstructing these waterways using buried pipe would greatly
reduce, but not completely, eliminate, waterway failures.
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Conservation Groups’ Comments and Recommendations
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J.
Terrestrial Habitat Connectivity and Entrapment
1. Within 7 years of license issuance, PacifiCorp shall restore habitat connectivity in
the terrestrial habitat priority 1 area (areas 1 through 4 of Figure 6, EIA Module 1A) to allow
continuous unencumbered wildlife movement and other ecological processes by either
covering, burying, or elevating canals and flumes along the waterway system as more fully
described in Condition 1, page 26 of the EIA Module 1A attached hereto.
2. Within 7 years of license issuance, PacifiCorp shall restore 18 priority 1 Riparian
Reserves in terrestrial areas 5 through 10 to provide full corridor connectivity as more fully
described in Condition 2, page 26 and Condition 4, page 27 of EIA Module 1A attached
hereto.
3. Within 15 years of license issuance, PacifiCorp will place twelve foot wide
wildlife bridges over gunnite canals in between the restored priority 1 Riparian Reserves in
terrestrial areas 5 through 10 where needed to meet a frequency of crossings every 400 feet as
more fully described in Condition 5, page 27 of EIA Module 1A attached hereto.
4. Within 7 years of license issuance PacifiCorp shall reconnect stream channel and
bank habitat for those road/stream crossings identified as a connectivity problem (Table 2,
page 24) as more fully described in Condition 6, page 27 of the EIA Module 1A attached
hereto.
Rationale:
Wildlife habitats and connectivity have been extensively altered in the upper North
Umpqua watersheds due to hydroelectric project facilities and other activities. The main
features of the Project affecting connectivity, in order of impact, are: canals, flumes, dams,
and diversion structures; forebays and reservoirs; penstocks; transmission lines; projects
roads. The proposed actions chiefly address the first two categories of impacts, which have
the most dramatic effects, by restoring connectivity and ecological function in priority areas,
as more fully described in the EIA Module 1A attached hereto.
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Conservation Groups’ Comments and Recommendations
24
K.
Habitat Restoration/Mitigation Trust Fund
Within one year of license issuance, PacifiCorp should establish a mitigation trust
fund in the amount of $3 million for on site mitigation to address ongoing impacts that cannot
be mitigated for through other changes in the Project operation or structure. Funds shall be
directed to habitat enhancement and restoration efforts throughout the license term. These
funds should be managed by a Technical Committee comprised of the license holder, state
and federal agencies, and non-governmental organizations. Monies from this fund shall be
used solely for actual mitigation projects rather than to cover administrative and
organizational costs.
Rationale:
As noted above, PacifiCorp’s hydropower Project has significant impacts on fish and
wildlife, water quality, and numerous other resource areas in the North Umpqua basin.
Although implementation of the above recommended mitigation measures will decrease the
Projects impacts and increase protection of the affected resources, there are many impacts
that will continue as long as the Project is in place. These include juvenile mortality caused
by Project operation, entrainment of fish and other aquatic organisms at all the projects,
altered sediment and large wood regimes, and loss of wetland habitat.
The loss of quality habitat is one of the major factors for decline of native fish and
wildlife in the Northwest. Continued operation of the North Umpqua Hydroelectric Project
will result in ongoing loss, degradation, and fragmentation of habitat for the term of the next
license. Habitat restoration, protection, and enhancement measures provide an effective
means to mitigate for those adverse effects. Further, continued habitat restoration efforts are
essential to the success of the anadromous fish reintroduction program. An adequate
restoration and enhancement program is necessary to restore the biological integrity of the
North Umpqua system as well as improve the possibility for successful reintroduction.
PacifiCorp should fund mitigation that addresses these ongoing impacts.
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Conservation Groups’ Comments and Recommendations
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L.
Project Decommissioning Fund
PacifiCorp must establish a Project Decommissioning Fund to assist in the removal
of the Project in the event it is no longer in the public interest.
Rationale:
A dam decommissioning fund is an essential element of a new license issued for the
North Umpqua Hydroelectric Project. Due to a range of factors including increased
sedimentation and development of less damaging renewable energy sources, removal of some
or all of the Project may eventually become necessary. Given the inherently non-permanent
nature of hydropower projects, PacifiCorp must be financially capable of removing the dams
once they have outlived their purposes and/or lifespan. Such a fund could be established in a
number of ways. However it is created, it should be sufficient to cover the cost of
decommissioning/removal when the Project is no longer in the public interest and to restore
the impacted environment.
M.
License Reopener
The license should include a standard reopener clause to allow for changes to the
license should it prove inadequate to comply with legal obligations. In particular, there
should be a fish and wildlife reopener clause in the event that protection, mitigation, and
enhancement measures do not achieve performance criteria. It should allow the license to be
reopened in order to incorporate new protection, mitigation, and enhancement measures.
Rationale:
License reopeners are necessary to address a range of changed conditions, including
additional information, and provide a means to modify protection, mitigation, and
enhancement measures as necessary. A project as complex as the North Umpqua
Hydroelectric Project may require additional measures/modifications during the term of the
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Conservation Groups’ Comments and Recommendations
26
license to ensure that the substantial effects of the Project are adequately mitigated. A
mechanism must exist to allow such changes.
N.
Oversight/Management
Within one year of license issuance, PacifiCorp must submit for Commission
approval a monitoring plan that evaluates the status of the resources for which it is mitigating
as well as the progress and results of programs undertaken to mitigate environmental impacts
of the Project. PacifiCorp shall file annual reports with FERC on the results of the
monitoring program and the status of protection, mitigation, and enhancement measures.
Where a given program is determined to have insufficient success, current approached must
be reevaluated and alternatives implemented. Development of the plan, evaluation of results,
and subsequent modifications should be done through an Adaptive Management Committee
consisting of representatives from PacifiCorp, state and federal agencies, and non
governmental organizations.
Rationale:
The North Umpqua Hydroelectric Project is a complex project with numerous
impacts on environmental resources in the North Umpqua basin. Accordingly, there needs to
be a mechanism to ensure that efforts to mitigate the impacts of the Project and bring it into
compliance with current environmental standards are successful and will be sufficient for the
term of the license. If the measures are insufficient, changes must be implemented to meet
resource goals.
III. CONCLUSION
The Conservation Groups believe that the preceding conditions will help to restore
balanced operation of the North Umpqua Hydroelectric Project to benefit all aspects of the
public interest. We respectfully request that the FERC analyze these conditions in its
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Conservation Groups’ Comments and Recommendations
27
environmental analysis and incorporate them into any license issued for the North Umpqua
Hydroelectric Project, No. 1927.
Dated this ____ day of February 2001.
__________________________
Brett Swift
American Rivers
133 SW Second Ave., Suite 302
Portland, Oregon 97204
__________________________
Doug Heiken
Oregon Natural Resources Council
P.O. Box 11648
Eugene, Oregon 97440
__________________________
Penny Lind
Umpqua Watersheds
P.O. Box 101
Roseburg, Oregon 97470
__________________________
Diana Wales
Umpqua Valley Audubon Society
318 SE Jackson
Roseburg, Oregon 97470
__________________________
Ken Ferguson
Steamboaters
423 Winchester Street
Roseburg, Oregon 97470
__________________________
Jim Myron
Oregon Trout
117 SW Front Ave.
Portland, Oregon 97204
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Conservation Groups’ Comments and Recommendations
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__________________________
Karen Russell
WaterWatch of Oregon
213 SW Ash, Suite 208
Portland, Oregon 97204
___________________________
David Bayles
Pacific Rivers Council
PO Box 10798
Eugene, Oregon 97440
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