golden, colorado 80403 november 1,2005 federal energy ...~ xcel energy'" 4653 table...

~ Xcel Energy'"

4653 Table Mountain DriveGolden, Colorado 80403

November 1,2005

Ms. Magalie Roman Salas

SecretaryFederal Energy Regulatory Commission

888 First Street NE

Washington DC 20426

Subject: Proposed Study Plan

Tacoma Hydroelectric Project

FERC No.12589

Dear Secretary Salas:

Enclosed is Xcel Energy's, d.b.a. Public Service Company of Colorado (PSCo), Proposed

Study Plan package for its Tacoma Hydroelectric Project located in La Plata and San

Juan counties in southwestern Colorado.

PSCo submitted its Notice of Intent (NO1) and Pre-Application Document (PAD) on May

20, 2005. FERC issued its Notice of Commencement of Proceeding and Scoping

Document Ion July 21,2005. The public Scoping Meeting was held on August 10,2005

and stakeholders' Request for Studies had to be submitted by September 20, 2005. In

total, seven comment letters were received containing 11 requests for studies, as

summarized below:

.U.S. Forest Service -10 Study Requests

.U.S. Fish & Wildlife Services -1 Study Requestl

.National Park Service -No Study Requests

.American Whitewater -No Study Requests

.Southwest Land Services -No Study Requests

.State of Colorado -No Study Requests

.Southwestern Water Conservation District -No Study Requests

BackJ!.round

Dating back to July of 2004, PSCo has undertaken a significant outreach program to

work with stakeholders to (1) develop a common understanding of the Integrated

Licensing Process (ILP) and the operation of the Project, (2) define relevant issues, and(3) identify and define needed studies. PSCo created four Resource Work Groups -

Water, Terrestrial, Recreation/Land Use, and Cultural -and met six times with each in

I The U.S. Fish & Wildlife Service letter did not contain any specifically enumerated study requests

meeting FERC's criteria under 18 CFR 5.9(b). We have included ESA compliance related issues as one

study request.

Ms. Magalie Roman Salas 2 November 1, 2005

the course of twelve months. Consensus was reached on all issues and study needs/studyplans (with one exception remaining) and PSCo believes the comments filed reflect thislevel of agreement. PSCo respectfully requests that FERC give considerable weight tothe fact that these Study Plans reflect the consensus of the many stakeholders whodedicated numerous hours to this cooperative effort.

The RWGs proceeded through a series of meetings covering in sequence issueidentification, issue description, relationship of issue to Project operations2, identificationof all applicable existing information, defining additional information needs, and studyplan development. Additionally, PSCo met with stakeholders in the last week ofSeptember 2005 following the filing of Study Requests to review and clarify theindividual request for studies.

List Qf ProlJosed StudiesAs a result of its outreach process, and in response to the Request for Studies, PSCoherewith submits the following Proposed Study Plans:

Water ResourcesIssue No.23 Instream Flows below Cascade Creek Diversion Dam; Instream

Flows in Little Cascade Creek

Issue No.3 Potential for Degradation of Water Quality in Electra Lake

Issue No.5 Survey of Federal and State Lands Occupied by the Project

Issue No.7 Project Effects on the Water Quantity and Quality of the AnimasRiver

Issue No.8 Project Effects on Riparian Habitat and Fish Habitat in the AnimasRiver

Issue No.10 Project Effects on Little Cascade Creek

Terrestrial ResourcesIssue No.1 Fuels Management

Issue No.2 Occurrence, Distribution, and Abundance of Amphibians at theTacoma Project

Issue No.3 Special Status Species and Habitats

Issue No.4 Invasive Plant Species

2 PSCo used a standardized document entitled Issue Assessment and Study Plan for each issue. The

relationship of an issue to Project operations (Project Nexus or Project Effects) was discussed early in themeeting sequence because if no nexus to operations existed, then no additional study was necessary.3 Issues are numbered in accordance with the original issues identified in the RWG meetings.

Ms. Magalie Roman Salas 3 November 1,2005

Issue No.5 Migratory Bird Treaty Act

Issue No.7 Wetland and Riparian Habitats

Issue No.14 Studies Related to Compliance with Section 7 of the EndangeredSpecies Act

CulturalIssue Nos. 1-2-3-4 Historic Properties Management Plan

Recreation, Land Use & AestheticsIssue No.2 ADA Compliance and Recreation Facility Assessment

Issue Nos. 419 Recreation and Shoreline Management Plans for Electra Lake

Issue No.5 Maintaining a Quality Fishing Experience on Electra Lake;Assessing Day-Use Fee Structure

Issue No.7 Condition of Project Facilities on Cascade Creek

PSCo Response to SIJec!fic Study Re{luests and CommentsSeveral stakeholders filed comment letters in support of draft Study Plans that had been ,

developed through the RWG process. Only two letters were filed with FERC containing

study requests.

The USDA Forest Service, Rocky Mountain Region, filed comments and ten ( 10) studyrequests. PSCo's response to these comments and study requests are provided below.For the most part, the Study Requests reflect PSCo's draft Study Plans at the time of theUSFS' submittal to FERC.

ResRonse to USFS Comments4(1) In USFS's Enclosure 2 of its filing, the USFS points out that while the PAD statesthat PSCo "plans no major change to existing facilities", PSCo has in fact stated onoccasion that it plans to add a fourth unit to the powerhouse and replace the woodenflume section of the Cascade Creek conveyance facilities. PSCo wishes to point out, forthe record, that as stated in the PAD (Section 4.10), PSCo is proposing to add a fourthunit (4 to 6 MW) to the powerhouse. This has been fully vetted in the RWG meetings.This is primarily an efficiency upgrade, but would increase maximum generation in wetyears. PSCo plans no significant change in Project operation as a result of the new unit.Peaking operations could change slightly on a daily basis during periods of high demand.The addition of the fourth unit will result in some ground-disturbing activity locatedpredominantly within the fence line of the existing switchyard at the powerhouse. A newsection of penstock will be added between the blind flange of the existing Penstock No.1

4 PSCo responds herein to a few select comments made by USFS, where such comments would affect

Study Plan content.

Ms. Magalie Roman Salas 4 November 1,2005

bifurcation and the powerhouse. PSCo has indicated to the RWG members that thewooden flume is quite old and may have to undergo major maintenance between now andlicense renewal, and that this would be handled under the terms of the existing license(see PAD, Section 4.10).

(2) In USFS' Enclosure 3, the USFS indicates that it is concerned about the proper scopeof fishery-related studies being planned for Little Cascade Creek. PSCo has modified itsapproach to this study to satisfy USFS concerns (see Water RWG Issue Assessment Nos.2 and 10).

(3) In USFS' Enclosure 3, the USFS indicates that draft Study Plans submitted by PSCodirectly to the RWGs prior to the comment due date of September 20 did not explicitlyaddress FERC's seven study plan criteria, especially the "project nexus" criteria. WhilePSCo can appreciate the USFS concern (because USFS requests for studies essentiallyadopt much of the PSCo draft Study Plans), PSCo must respectfully disagree with USFSon this point. The draft Study Plans address the seven criteria, although not in the exactsequence they are listed in Section 18 CFR 5.9(b) of the FERC regulations. Relatedespecially to "Project Nexus" (18 CFR 5.9(b)(5», PSCo adopted the term "ProjectEffects", but it was clear to all stakeholders that this section of the draft IssueAssessments and Study Plans was intended to describe the connection and linkagebetween an issue and Project operations. We would point out that FERC' s own languagein 18 CFR 5.9(b)(5) states "Explain any nexus between project operations and effects(emphasis added) on the resources to be studied ".

ResRonse to USFS Stud~ Reguests.USFS Study Request No.1 -Instream Flows below Cascade Creek Diversion Dam

In this study request, the USFS describes the need to perform instream flow studies onboth Cascade Creek and Little Cascade Creek using the PHABSIM analysis. PSCo hasnow included in its Proposed Study Plan an instream flow assessment in Little CascadeCreek as requested by the USFS. However, because of the cost of a full IncrementalFlow Instream Methodology (IFIM) PHABSIM analysis for what has become threeseparate stream reaches, PSCo is now proposing to use a Delphi-type assessment as alower cost approach that will still be both technically robust and fully defensible. USFSand CDOW staff have agreed to consider such an approach.

.USFS.Study Request No.6 -Project Effects on Special Status Species and Habitats

In its request, USFS suggests that work associated with the Migratory Bird Treaty Act(MBT A) be consolidated into this study plan. PSCo has elected, as explained to USFSstaff during its September 27 RWG meeting, to keep the MBT A study plan separatebecause the MBT A is a distinct and separate statute with unique compliance

requirements.

.USFS Study Request No.8 -Project Effects on Wetlands, Riparian Habitats, andOccurrence, Distribution, and Abundance of Amphibians

Ms. Magalie Roman Salas 5 November 1, 2005

In its request, the USFS has requested that the geographic scope of this study include apond located south of Terminal Dam adjacent to the access road from Electra Lake toForebay Lake. PSCo has explained to the USFS that this pond has no nexus with Projectoperations; therefore, it is not included in PSCo's Proposed Study Plan.

.All Other USFS Requests

The USFS had a number of more minor scope-related comments on individual studyplans. PSCo has addressed these comments in its Proposed Study Plan package.

Response to USFWS Study ReguestOn September 20, 2005, the USFWS filed comments with FERC on the Tacoma ProjectILP. The comments primarily deal with (1) studies related to species listed under theEndangered Species Act (ESA) and (2) general comments related to hydropower. Thecomment letter does not reference the FERC's ILP regulations, nor does the letter makeany attempt to systematically address the seven study plan criteria listed under 18 CFR5.9(b ). Despite this, PSCo has developed a Study Plan to address concerns related tocompliance with Section 7 of the ESA (see Terrestrial Issue Assessment No.14).

The USFWS letter also cites potential impacts of hydro projects in general related to suchissues as bypass reaches, fluctuating water levels, et al. No evidence was provided of anyspecific relationship between these issues and any effects on site-specific resources due toTacoma Project operations. The USFWS provides no Project-specific nexus between anyof the issues raised and site-specific Project effects, nor is there any description of thestudy methodology to be used or level of effort expected. PSCo believes that thesegeneral study requests do not meet the minimum requirements of 18 CFR 5.9(b). Despitethat, the Proposed Study Plans address the great majority of the areas raised by theUSFWS letter, but on a site-specific basis.

U1Jcomin2 Stakeholder MeetingsPSCo has scheduled meetings on November 30, 2005, in Durango, Colorado, to discussany differences between PSCo's Proposed Study Plan package and the study requests.Additional'rneetings may be scheduled as necessary .

We look forward to working with all parties to develop an agreed-upon set of study plansfor the Tacoma Project.

ver/£7 y~~

R~~y ~esWater CoordinatorPublic Service Company of Colorado4653 Table Mountain DriveGolden CO 80222Randy .rhodes @ xcelenergy .corn~

WATER RESOURCES STUDY PLANS

Tacoma Hydroelectric Project Instream Flows Below Cascade Creek Diversion Dam Water RWG Issue No. 2

1 November 1, 2005

PUBLIC SERVICE COMPANY OF COLORADO TACOMA HYDROELECTRIC PROJECT

FERC NO. 12589 WATER RESOURCE WORK GROUP

Issue Assessment No. 2 and Study Plan

Instream Flows Below Cascade Creek Diversion Dam Instream Flows at Little Cascade Creek1

1.0 Description of Issue (18 CFR 5.9(b)(1)) Flows from Cascade Creek are diverted by Public Service Company of Colorado (PSCo) at its Cascade Creek diversion dam for delivery to Electra Lake via Little Cascade Creek. The Cascade Creek diversion dam is located approximately 0.8 miles upstream of where U.S. Highway 550 crosses Cascade Creek. The top-of-spillway elevation at the diversion dam is approximately 8,900 feet. Currently, PSCo diverts Cascade Creek flows up to the capacity of the wooden flume which carries the diverted water downstream from the diversion dam. Cascade Creek continues for about 6 miles downstream of the diversion dam to the Animas River. Lime Creek enters Cascade Creek about three miles downstream of the diversion dam. The Project’s diversion of the flow of Cascade Creek has created an existing condition related to fisheries, macroinvertebrates, water quality, and riparian vegetation communities downstream of the diversion dam. If the diversion amount is changed, there is likely to be an effect on the existing conditions in Cascade Creek and Little Cascade Creek. The amount, location, and seasonal variability of flow accretions below the diversion dam are currently unknown. Sources of increased flows may include springs, seeps, deep groundwater, treated effluent, and tributary inflows. 2.0 Project Effects (18 CFR 5.9(b)(5)) The operation of the Tacoma Hydro Project affects the flow characteristics and flow regime in Cascade Creek below the Cascade Creek diversion dam and in Little Cascade Creek from the discharge point of the flowline adjacent to U.S. Highway 550 to Aspaas Lake. The Project operations, which have been occurring for 100 years, have resulted in establishing the existing conditions in Cascade Creek downstream of the Project diversion dam. The current habitats and aquatic populations reflect this existing flow regime. The Project also affects Little Cascade Creek by its increased flow regimes and now established riparian zones. In general, PSCo exercises its senior water right (400 cfs) to divert the entire flow of Cascade Creek up to the current capacity of the existing wood flume (~250 cfs). The diversion dam and diversion works are not water tight and a small, unknown amount of leakage occurs below the diversion dam when streamflow is less than the capacity of the flume. When Cascade Creek flows exceed the 1 This Study Plan consolidates flow related issues pertinent to Water RWG Issue Assessment No. 10 – Project Effects on Little Cascade Creek with this Issue Assessment No. 2.


2 November 1, 2005

flume capacity, water is spilled at the diversion dam. The diversion dam is approximately 10 feet high and has no usable storage capacity. During periods of flow less than 250 cfs, plant operations normally divert all flows into the flume, except for leakage. The Cascade Creek channel, from the diversion structure to Purgatory Flats, a total distance of 3.9 miles, is not dewatered. Leakage at the diversion dam combined with accretions from groundwater and tributary sources provide stream channel flows estimated during late summer to early fall (2004) field visits to be 2 to 4 cfs in the channel at the U.S. Highway 550 bridge (about 1 mile below the diversion point). Below U.S. Highway 550, channel flows gradually increase as they proceed downstream until nearing Purgatory Flats where significant tributary inflow occurs. During late summer 2004 field trips, total flow was roughly 25 cfs with approximately two-thirds of this flow being attributable to Lime Creek (which flows into Cascade Creek near the upper end of Purgatory Flats). The other one-third (8 to10 cfs) was attributable to Cascade Creek. The corresponding area of interest on Little Cascade Creek extends from the Cascade Flowline Gauging Station, located at the end of the flowline near the south boundary of the Durango Mountain Resort, downstream through Columbine Lake to the point where the diverted flow enters Aspaas Lake (near the upper end of Electra Lake), a total distance of 2.5 miles. Flows within Little Cascade Creek are essentially entirely made up of diversion flows from Cascade Creek. The total drainage area of Little Cascade Creek at Aspaas Lake is approximately 2.7 mi2. Altering the amount of diverted flow at Cascade Creek diversion dam to increase flows in Cascade Creek would remove an equal amount of flow from Little Cascade Creek. The current status of the aquatic resources in Cascade Creek and Little Cascade Creek is largely unknown. Cascade Creek is primarily confined to a steep gradient canyon below the diversion dam and is a pool and drop environment with numerous boulders. The pools generally are bordered by steep canyon walls with little change in lateral extent with increasing flows. Cascade Creek is characterized by high velocities during times of moderate to high flow. Little Cascade Creek is also steep, dropping roughly 450 feet in its 2.5 miles traversed from the outlet of the flowline to Aspaas Lake. Much of this drop occurs at a series of cascades and falls located roughly 1 mile upstream of Aspaas Lake. It is generally known that at least a portion of the lower part of Little Cascade Creek (just above Aspaas Lake) provides excellent spawning habitat for naturally reproducing trout species of Electra Lake, especially the fall-spawning brook and brown trout. Data on the aquatic resources of Cascade Creek prior to Project construction does not exist. Current conditions in Cascade Creek are also affected by discharges from the Cascade Wastewater Treatment Plant (Cascade WWTP). Direct observation of algae growth on rocks (Wanner 2004) in Cascade Creek has been reported. Cascade WWTP effluent discharge is limited by the current flow regime in Cascade Creek.


3 November 1, 2005

Enhancement opportunities in Cascade Creek, as well as degradation trade-offs in Little Cascade Creek, potentially exist for aquatic resources in these two linked systems. Increasing flows in Cascade Creek by reducing the flows into Little Cascade Creek will require PSCo to conduct an assessment of habitat changes from modified flow regimes on both tributaries. Naturally occurring low winter flows in Cascade Creek may be a significant factor in any such evaluation as these can drop to 1 to 2 cfs upstream of the Cascade Creek diversion dam. Significant fall spawning flows in Little Cascade Creek are also important for reproduction success of salmonids in Electra Lake. 3.0 Relevant Existing Information (18 CFR 5.9(b)(4)) Existing instream flow information is very limited for Cascade Creek. Diverted flows are estimated at the diversion dam through use of a staff gage and measured at the flowline gauging station. It is unknown what amounts of accretion flows enter Cascade Creek below the diversion. CDOW has done occasional random sampling of the fishery in Cascade Creek watershed during the last 30+ years (CDOW 1976, CDOW 1991, CDOW 1992, CDOW 2004). These surveys include Cascade Creek, Lime Creek and Mill Creek. Results indicated good numbers of brook trout (Salvelinus fontinalis) existed at sites sampled in all three creeks while low numbers of rainbow trout (Oncorhynchus mykiss) and cutthroat trout (Oncorhynchus clarki) were occasionally recorded. The drainage area of Cascade Creek at the Cascade Creek diversion dam is about 26.2 mi2. The drainage area of Cascade Creek at U.S. Highway 550 is about 28 mi2 and the drainage area of Mill Creek, which enters Cascade Creek about 3,000 feet below U.S. Highway 550, is 7.0 mi2. At Purgatory Flats, the drainage area of Cascade Creek is 36.9 mi2 and the drainage area of Lime Creek is 42.1 mi2. 4.0 Need for Additional Information (18 CFR 5.9(b)(4) Additional information concerning flow regimes in Cascade Creek is needed to determine to what extent Project operations may be affecting aquatic habitats in Cascade Creek and Little Cascade Creek. A flow regime assessment will provide an increased understanding of the trade-offs (both biologically and economically) between providing additional flows to Cascade Creek between the diversion dam and U.S. Highway 550 and reduced flows to Little Cascade Creek above Aspaas Lake. 5.0 Final Study Plan 5.1 Purpose of Study and Use of Study Results (18 CFR 5.9(b)(1) & 5.9(b)(5) in part) The purpose of the study will be to develop flow-based management objectives and associated attainment criteria that allow the evaluation of various streamflow scenarios and their affects on aquatic habitat for life history stages of target species. These species include resident brook, rainbow and cutthroat trout in specific sections of Cascade Creek and Little Cascade Creek. The


4 November 1, 2005

study will utilize the best professional judgment (BPJ) of a study team of Tacoma Water RWG members to determine appropriate seasonal flows for resident fishes in Cascade Creek from the diversion dam downstream to U.S. Highway 550; in upper Purgatory Flats upstream of Lime Creek approximately 1 mile; and in Little Cascade Creek from the upper end of Aspaas Lake upstream to the first barrier falls. The approach chosen to determine these recommended flows will be a Delphi-based flow assessment (Arnold et al. 1997). A Delphi flow assessment relies heavily on the efforts of a technically trained study team working jointly to identify site specific management objectives; establish attainment criteria that allow the study team to judge how well each observed flow is meeting each management objective; and ultimately determine flow recommendations for each reach. The demonstration flow assessments will provide information to participants in the relicensing process which, in combination with the water quality study (Tacoma Water RWG Issue Assessment No. 3 Study Plan – Potential for Degradation of Water Quality of Electra Lake), the Little Cascade Creek habitat inventory (Tacoma Water RWG Issue Assessment No. 10 Study Plan – Project Effects on Little Cascade Creek), and other resource and economic studies, will provide a basis for streamflow-related resource management decisions on sections of Cascade and Little Cascade Creeks. 5.2 Relevant Resource Management Goals (18 CFR 5.9(b)(2)) Cascade Creek is located on public lands managed by the U.S. Forest Service (USFS) in the San Juan National Forest. Current forest management plans primarily emphasize timber harvest and fuels reduction. Recent plan amendments have increased their emphasis on protecting riparian and aquatic habitats and the species that depend upon these habitats through maintenance, improvement and enhancement. The current USFS Land and Resources Management Plan, as amended, includes: Forest-Wide Direction

Wildlife and Fish Resource Management (03). Maintain habitat for viable populations of all existing vertebrate wildlife species (page III-26).

a. Habitat for each species on the forest will be maintained at least at 40 percent or more of potential (page III-26).

Wildlife and Fish Resource Management (05). Manage waters capable of supporting self-sustaining trout populations to provide for those populations (page III-26). Riparian Area Management (02). Design and implement activities in management areas to protect and manage the riparian ecosystem (page III-46). Water Uses Management (01). Determine and obtain rights to instream flow volumes to protect and maintain stream channel stability and capacity and to accomplish any proposed increase in use or resource activity (page III-47).


5 November 1, 2005

Water Uses Management (03). Special use Permits, easements, rights-of-way, and similar authorizations for use of NFS lands shall contain conditions and stipulations to maintain instream or bypass flows necessary to fulfill all National Forest uses and purposes (page III-47). Water Resource Improvement and Maintenance (01). Maintain instream flows and protect public property and resources (page III-47).

Management-Area Direction/Riparian Area Management (9A)

Wildlife Habitat Improvement and Maintenance (04). Manage riparian areas identified as essential habitat for indicator species by retaining suitable habitats (page III-254).

b. Cutthroat, Rainbow, Brown, and Brook Trout. Implement structural and non-structural improvements to maintain or improve fisheries habitat in aquatic ecosystems. In streams and rivers, develop habitat that will provide protective cover for trout during low water and escape and feeding cover during periods of low flow (page III-254).

Wildlife Habitat Improvement and Maintenance (07). Maintain instream flows in cooperation with state wildlife agencies to support a sustained yield of natural fisheries resources (page III-255).

The US Fish and Wildlife Service (USFWS) also has resource management plans that may be considered relevant to this resource. The San Juan River Basin Recovery Implementation Program (RIP), while primarily dealing with two endangered fish outside of the Project area, does pertain to drainages, including the Animas River, that are tributary to the San Juan River. The primary goal of the San Juan River RIP is the protection and enhancement of habitats and flows in the San Juan River determined to be critical to various life history stages of the two endangered fish species. 5.3 Relevant Public Interest Considerations (18 CFR 5.9(b)(3)) Cascade Creek provides opportunities to the general public for dispersed recreational activities (fishing, hiking, swimming, winter sports) and aesthetics. It is also important to providing the primary water supply to Little Cascade Creek and Electra Lake. Electra Lake is an important waterbody for associated recreational, aesthetic and economic benefits to the area. The Colorado Division of Natural Resources (CDNR), the Colorado Water Conservation Board (CWCB) and the United States Department of Agriculture – Forest Service have a current Memorandum of Understanding (MOU) relating to establishing a framework for the Forest Service and the CDNR to work cooperatively together on issues regarding the management of water and water uses on national forest system lands in Colorado. It should be noted that recommendations made from results associated with this study need to be completed in a timely


6 November 1, 2005

fashion to allow for discussions and negotiations by the above parties as required by the MOU relating to providing increased flows to bypassed reaches in any Project-related stream. 5.4 Study Methodology – Delphi Assessment (18 CFR 5.9(b)(6)) A Delphi-type demonstration flow assessment is based on a list of flow-dependent management objectives for the study sites and the criteria by which a study team will rate how well a given flow meets those management objectives. These management objectives in turn, along with study team attainment scoring, become the record keeping of the basis for flow recommendations. The process begins by developing a study team made up of Tacoma Water RWG members with the technical expertise to make site-specific decisions based on observed flows and their affects on aquatic habitats. The study team will include, at a minimum, representatives from the USFS, CDOW and PSCo, along with a study facilitator. Next, a list of flow-based management objectives derived from published resource agency management plans and RWG consultation discussions will be prepared. The list of management objectives should be reached through study team consensus and may require more than one round of review. A draft list of flow-based management objectives is presented in Table 1 as a first draft for the study team to begin its review. Each management objective also needs to have attainment criteria paired to it. Attainment criteria are the basis upon which each study team member judges how well each management objective is met by the demonstration flow they are viewing in the field. It should be noted that development of specific attainment criteria for each management objective will be a Tacoma Water RWG coordinated effort using accepted life history requirements ( i.e. habitat suitability indices) for indicated species. This will be achieved during the 90-day study plan review period which begins November 2, 2005. Table 1. Cascade/Little Cascade Creek study plan management objectives and attainment criteria

Priority

Objective Management Objective/Attainment Criteria Reach 1 Reach 2 Reach 3 Reach 4 subreach A subreach B

1 MO: Providing adequate overwintering depths in pools (Nov- March)

AC:

2 MO: Provide adequate access to brook trout spawning areas (Sept-Nov)

AC

3 MO: Protect/enhance brook/brown trout egg development and fry emergence (Nov - Mar)

AC

4 MO: Provide adequate flows for cutthroat/rainbow trout spawning/rearing (Mar-Jun)

AC

5 MO: Maintain or enhance resting/holding refuge waters (Jul-Sept)

AC


7 November 1, 2005

6 MO: Avoid flows which causes excessive economic impact to Project

AC

7 MO: Avoid flows causing excessive scour (Sept-Dec) AC

Next, prioritizing the list of flow-based management objectives for each study site is performed by the study team. Assigning a priority to each management objective serves two purposes. First, it allows study team members to reflect differences in management priorities between two or more sites. Second, it allows study team members to reflect the relative importance of one management objective versus the remaining objectives on the list. Priority ranking assignment is done by consensus opinion of the team before the field study begins, but after site visits and review of available information about the site is complete. The zero to three ranking scale used to assign priority is listed below: Prioritization Ranking 0 Not a concern at this location. 1 Important, but low priority at this location. 2 Important, but not a top priority at this location. 3 Top priority at this location. Also in consensus fashion, the study team will use a similar rating scale to record how well each management objective is attained by each demonstration flow. This scoring is performed on site, while observing the demonstration flow. This allows the team to make direct reference to actual field conditions while formulating a consensus opinion. The zero to three ranking scale used to score attainment of each management objective is listed below: Attainment Ranking 0 Management objective is not attained at any level. 1 Low attainment of management objective. 2 Medium attainment of management objective. 3 High attainment of management objective. In summary, priority ranking of flow based management objectives is performed once by the study team before going in the field to view the flows. Attainment ranking of each flow-based management objective is scored at each study site, each time a new demonstration flow is observed by the study team. The number and magnitude of demonstration flows evaluated may vary from site to site and will be decided by the study team based on the study objectives with the potential for modification in the field during a study via study team consensus. Evaluation locations are also site-specific and will be selected by the study team during a pre-study site visit.


8 November 1, 2005

The Delphi approach encourages the study team to reach a consensus opinion for each criteria with each flow in all reaches. In the uncommon event that a unanimous opinion may not be reached by the group for some or all of the flows, the Delphi process attempts to record those instances. Therefore, each study team member will fill out an individual assessment form at the end of each demonstration flow. These individual assessment forms will be appended to the final study report as a permanent record of how each individual study team member reached an assessment of each flow. The individual assessment forms will be useful to refer back to during the development of the study team flow recommendation. Individual assessment forms will include each study team members’ field notes and the answer to several general questions such as: ■ What are your comments on the overall aquatic environment or ecosystem values at this

site and flow? ■ Do you have any concerns that are not reflected in the study team consensus? ■ Would minor changes in flow (10 to 20 percent), either up or down, substantially change

(improve/degrade) habitat? Why? ■ Are there non-flow enhancement opportunities under these conditions? (Describe) Following completion of field work, priority-weighted attainment (PWA) scores will be calculated as one of the study’s primary statistics. PWAs at each site will be calculated for each individual management objective at each study flow by multiplying the management objective priority by the attainment score given by the study team at that flow. Summing these PWAs across all management objectives at a given flow, will produce the total PWA value — the single comprehensive value that reflects the success of achieving all management objectives with greater emphasis (weighting) on management objectives of highest priority. The PWAs may be subdivided into different sites or topical clusters to evaluate how an individual management objective or group of management objectives changes with flow. Attainment scores may also be evaluated for each individual management objective with or without priority weighting. Responsibilities PSCo will assume to assist the efforts of the study team include: ■ A study team facilitator, responsible for guiding the study team through the process from

scoping through final report, but does not participate in study team flow assessment. ■ A flow coordinator to ensure that each flow is delivered as scheduled and measured at each

site to obtain an accurate flow measurement. ■ A technical crew gathering data on depth and wetted perimeter at representative channel

transects at each study flow. This crew may also provide spot measurements of velocity, water surface elevations, and channel width as requested by the study team.

■ Ground level photography of representative and critical habitats at each study site and flow from fixed ground level stations.


9 November 1, 2005

5.4.1 Study Area The instream flow study area covers two reaches of Cascade Creek and one in Little Cascade Creek. In Cascade Creek, the reaches are from the diversion dam downstream to U.S. Highway 550; and a second area in upper Purgatory Flats extending from immediately above the Lime Creek confluence to the Boyce Lake tributary confluence. This area has an additional unregulated drainage area of about 14 mi2. The Little Cascade reach extends from Aspaas Lake upstream to the first barrier falls, approximately one mile. Figure 1 shows the location of each proposed reach in Cascade and Little Cascade creeks. Figure 1 is located in Attachment A. 5.4.2 Study Reaches A study reach is defined as a sub-section of the overall Project study area. For the purposes of this study, a reach is a segment of river where slope, hydrology, sinuosity (i.e., channel meandering), and channel type, width to depth ratio, and substrate are relatively homogenous throughout its defined length. Stratification of the overall study area into reaches permits a more precise treatment of flow characteristics and the resultant effects on aquatic habitat. For the Tacoma Project study area, PSCo, in consultation with RWG members, proposes using the Delphi flow demonstration method for three reaches. Table 2 lists the reaches and their location descriptions. The section of Cascade Creek from the diversion dam to Highway 550 (approximately 4400’) will consists of two subreaches based on significant accretion flows entering in the upper third of the bypass channel. The second Cascade Creek reach, in upper Purgatory Flats (approximately 4200’), will consist of only one reach. The final reach will be in Little Cascade Creek above Aspaas Lake. It should be noted that in all three reaches, all habitat types will be included in the Delphi assessment analyses including spawning gravel areas and potential overwintering habitat. Table 2. Reach Information for Delphi evaluation on Cascade/Little Cascade Creeks. Reach

# Location Subreaches Rivermiles

(approximate) Description

1 Cascade Crk Subreach A 5.8 to 6.0 From Diversion Dam downstream to first significant tributary

Subreach B 5.1 to 5.8 From first significant tributary below Diversion Dam downstream to Highway 550

2 Cascade Crk N/A 3.0 to 4.0 Upper Purgatory Flats area from Lime Creek upstream to Boyce Lake drainage

3 Little Cascade Crk

N/A 0.1 to 1.0 Aspaas Lake upstream to barrier falls


10 November 1, 2005

The upper reach of Cascade Creek (Reach 1) is a high gradient stream channel (>2%) with an average width of less than 20 feet. The substrate is mostly composed of larger sized cobbles and boulders. The habitat types are also primarily boulder runs, boulder cascades, and plunge pools. The reach in upper Purgatory Flats (Reach 2) is a moderate gradient (1.5%) stream channel with an average width of approximately 23 feet. The substrate is well graded with a combination of gravels, cobbles, boulders and bedrock. There is also a diverse mixture of habitat types including riffles, runs, glides, pools and cascades. The Little Cascade Creek reach (Reach 3) is a moderate gradient (1.5%) stream channel with an average width of approximately 16 feet. The substrate is a combination of gravels, cobbles, boulders and bedrock. 5.4.3 Habitat Typing and Mapping In November 2004 and July 2005, an on-foot video was made of all three study reaches. This video, along with field notes taken during the video and subsequent site visits, will be used to determine the different habitat (i.e., channel) types that occur in these reaches. Examples of different habitat types are riffles, runs, cascades, shallow pools, and deep pools. During the 2006 field season, habitat mapping will be done in all three reaches to quantify the amount, or percentage, of each habitat type found in each reach. The habitat mapping will be done such that the distribution, or order, of the habitat types is captured. Also, because habitat types can change as flow increases or decreases (for example, a riffle may become a run at a higher flow), the habitat mapping will be done under flow conditions that fall within the target flow range for each reach. Results of habitat mapping are used in Delphi flow studies to assist with study scope development and selection of representative transects that represent each habitat type. Habitat mapping information can also be used to assist the study team with interpretation of study results. 5.4.4 Transects Within the study reaches, transects may be selected that represent the predominant habitat types in each study reach as well as important biological features for up to three target aquatic species to be studied (resident rainbow trout, brook trout, and cutthroat trout). Transects, as part of the Delphi approach, provide quantification data to the study team’s observations. While the study team may be reviewing particular flows in an area of a reach, transect data can help show incremental changes to a specific site. A transect is a designated line across the river channel (from river bank to river bank), generally perpendicular to the direction of flow, where instream flow variables are measured (depth, velocity, and substrate/cover). It is usually marked with a steel headpin and tailpin on each respective bank to sight the transect line across the river. These transects will provide reference points in important habitats, allowing the study group to observe site specific changes based on various flow releases. Transects will be placed after coordination and consultation with the Water Resource Work Group–Delphi study team. PSCo proposes to place transects at cross-sections that represent typical available habitat types as well as habitats


11 November 1, 2005

that are significant biologically and are the most sensitive to changes in flow. An example of this type of transect would be a riffle that is important to resident fish species biologically and also exhibits significant changes in depth, velocity, and wetted perimeter as stream flow changes. The availability of over wintering habitat and fall spawning/winter incubation habitat are two examples of important habitat. 5.4.5 Field Data Collection Methods In all three reaches, PSCo proposes to provide three different flows (representing the desired flow range based on study objectives) that will allow a streamflow evaluation using the Delphi method. The proposed target flows for observation and field data collection are 2, 7, and 12 cfs. This will provide a range of flows that may typically occur during wet and dry years during periods that are critical to resident fish species. Streamflows during the study site visits will be regulated by PSCo to provide target flows in each study reach. Flows will be held as steady as possible while observations and measurements are being made. The proposed schedule is to conduct the Delphi assessments and field data collection in early- to mid-summer 2006, on the descending arm of the high flow season. This time period should allow the greatest flexibility in flow deliveries below the diversion dam. PSCo will use standard differential surveying techniques while conducting the Delphi evaluation for all three reaches. A total station instrument or a survey auto-level will be used to measure the cross-sectional profile of each transect and determine water surface elevations and wetted perimeter at each target flow. Water surface elevations will be accurate to the nearest 0.02 feet. At least one transect will be selected in each reach (or subreach) to provide an accurate flow measurement. To make field data collection more efficient, it is desired that this transect also serve as one of the study transects. Velocities will be measured using a calibrated digital, Swoffer® brand, propeller-type velocity meter mounted on a standard top-set USGS wading rod. Velocities will be taken at six-tenths of the depth when depths are less than 2.5 feet, at two-tenths and eight-tenths of the depth when depths equal or exceed 2.5 feet, and when the expected velocity profile is altered by an obstruction immediately upstream. These rules for placement of verticals (measured velocities) along each transect will be closely followed. If there is uncertainty about whether a vertical is warranted, the vertical will usually be placed at that point. In addition to stationing, notes will be taken regarding top set rod placement relative to upstream obstructions and substrate that may affect the velocity column. Temporary staff gage readings will be taken at the beginning and end of each of the study team’s assessments where flow observations and measurements are made. This information will be used to determine how stable flows were held during the site visit. In-situ, continuously recording water level-loggers may also be installed at some or all the study sites to monitor changes in stage during the site visits.


12 November 1, 2005

Substrate and cover will be measured visually and/or by tactile inspection at wadeable depths. Classification will be in accordance with the proposed coding system shown below in Tables 3 and 4. Some modifications may be made to the proposed substrate and cover coding system once the Habitat Suitability Curves (described in Section 5.4.6) are agreed to by the Delphi team.

TABLE 3 PROPOSED SUBSTRATE SIZE CLASSIFICATION AND CODES

Code Abbreviation Description Inches 0 ORG Organic Detritus N/A 1 SI Silt, Clay <0.1 2 SA Sand <0.1 3 SGR Small Gravel 0.1-0.5 4 MGR Medium Gravel 0.5-1.5 5 LGR Large Gravel 1.5-3.0 6 SCOB Small Cobble 3.0-6.0 7 LCOB Large Cobble 6.0-12.0 8 SBOL Small Boulder 12.0-36.0 9 LBOL Large Boulder >36.0

10 SBR Smooth Bedrock N/A 11 IBR Irregular Bedrock N/A

TABLE 4 PROPOSED COVER TYPE CLASSIFICATION AND CODES

Overhead Cover Code Abbreviation Description 0.0 NC No Cover 0.1 UCB Undercut Bank 0.2 OHV Overhanging Vegetation Touching Water 0.3 ROOT Root Wad (greatest width 1.5 feet)

(dropped) 0.5 SNAG Snags, stream wood 0.6 WEED Submerged Aquatic Vegetation 0.7 DEB Fine Organic Substrate 0.8 TV Terrestrial Grass and Bushes 0.9 ISC Instream Cover

5.4.6 Hydrology Analysis Using available gage data at reasonably nearby gages, PSCo will develop monthly flow duration curves applicable to Cascade Creek above Cascade Creek diversion dam, Cascade Creek at Purgatory Flats, and Little Cascade Creek at Aspaas Lake. This information will be useful in evaluating the overall seasonal frequency of habitat availability.


13 November 1, 2005

To assist in determining flows above the Cascade Creek Diversion Dam and in each study reach, PSCo proposes to develop a stage/discharge relationship at a suitable transect location in each of the following areas:

• Cascade Creek - Reach 1 – upper subreach A; • Cascade Creek - Reach 1 – lower subreach B; • Cascacde Creek - Reach 2 – upper Purgatory Flats; and • Little Cascade Creek - Reach 3 – above Aspaas Lake

The stage/discharge relationship will be determined at suitable flow measurement transects at each of these locations. At least three different flows will be measured. PSCo intends to install level-loggers in December 2005, prior to winter low flow conditions. In addition, continuously recording water level-loggers will be installed at each of these transects to assist in determining the magnitude, duration, and frequency of flows at all of the study sites. These recorders will be left in-situ for a period of at least one year in order to capture seasonal flow patterns (they will be downloaded periodically during their deployment). This information is critical to understanding flow and habitat tradeoffs between Cascade and Little Cascade Creeks. 5.5 Schedule (18 CFR 5.9(b)(7)) PSCo proposes to form the Delphi study team by January 2006. Establishment of reach specific management objectives and attainment criteria will be completed by March 1, 2006. Field flow evaluations and data collection will occur during July 2006. Data analysis, and report preparation will begin in fall 2006 after data collection is complete. 5.6 Discussion of Alternative Approaches (18 CFR 5.9(b)(7)) The Water RWG originally developed a preliminary study plan related to this Issue Assessment based on Instream Flow Incremental Methodology (IFIM) approach using PHABSIM analysis techniques. As the original study plan underwent review within the RWG, the scope of the instream flow assessment expanded to include Purgatory Flats and certain reaches of Little Cascade Creek. PSCo became concerned about both the cost and the suitability of a standard PHABSIM approach. Cost estimates were beginning to approach and exceed $200,000 for the full PHABSIM approach. For an 8-MW project, such a cost for just one study was unreasonable. This is especially so when one considers that conducting such an analysis does not guarantee that consensus would be reached on the results, or that the study would actually relate to real-time improvements in fishery resources.


14 November 1, 2005

High mountain streams can be subject to severe winter conditions limiting overall fish populations due to hydrology. PSCo’s own prior experience with IFIM techniques in Colorado on a prior relicensing were pointed to the need to consider other approaches. The Delphi approach appears more appropriate for this study because: (1) costs were estimated at less than one-half a PHABSIM approach; (2) PSCo’s own experience highlighted the shortcomings of PHABSIM for high mountain streams; (3) the Delphi approach offers a greater chance of biological consensus; and,

(4) a Delphi approach was more likely to assess factors which more specifically relate to actual fish populations and stream suitability.

5.7 Data Analysis and Reporting After fieldwork is complete, study results will be compiled, calculated, and summarized. Photographs, individual assessments, and all field data measurements will be summarized and reproduced for distribution to all study team members. Field data such as spot measurements of depth and velocity will be summarized to support the observations of habitat types and habitat suitability for individual species. Data summaries of relative change in aquatic habitat such as changes in transect wetted width and wetted perimeter will also be prepared. PWA scores at each site will be calculated for each individual management objective at each study flow and tabulated. Summing these PWAs across all sites and management objectives at a given flow produces the total PWA value — a single index value that reflects the cumulative achievement of all management objectives and priorities. PWAs will also be subdivided into different topical clusters (e.g., target fish species, habitat availability, or spawning season and overwintering objectives) and presented graphically to evaluate how individual management objectives or groups of management objectives change with flow. These scores may be evaluated with or without priority ranking applied. This information will be bundled into a data summary package and forwarded to each study team member for review. Individual study team members are welcome to prepare their own data analysis for presentation to the study team at the flow recommendation meeting. Following distribution of study results, the study team will meet to develop flow recommendations. Study results from each demonstration flow will be reviewed including PWA scores and graphics, photo/video documentation, individual assessments, and data summaries when considering whether a flow should be recommended as a year-round base flow or a limited seasonal flow. The study team should include seasonal variation in their flow recommendation to accommodate specific management objectives such as spawning, nursery habitat low flow season, and winter habitat. Once study team flow recommendations are determined, a draft report will be prepared and submitted to the study team for review and comment. If necessary, a team meeting will be called


15 November 1, 2005

to discuss comments on the draft report. The final report will be prepared with the study teams’ biologically based recommendation and forwarded on to the larger negotiating group. 5.8 Report Preparation Reporting requirements (initial and updated study reports and meetings) will be conducted within the timeframes set forth in 18 CFR § 5.15. Progress reports will be provided to the RWG Relicensing Participants semi-annually. At the conclusion of the study, a report will be produced containing a description of the methodology, documentation of assumptions and results including the study group’s recommendations. 5.9 Level of Effort and Study Cost The preliminary level of effort to conduct the field studies and reporting under this study plan will be approximately 20 person weeks. 6.0 References Armantrout, N.B., compiler. 1998. Glossary of aquatic habitat inventory terminology. American

Fisheries Society, Bethesda, Maryland. Arnold, S. H., D. W. Culligan, J. Homa Jr., and J. L. Sabattis, 1997. Collaborative instream flow

resolution utilizing an enhanced Delphi technique. In Proceedings of the International Conference on Hydropower, Volume 1, pp 500-509. D. J. Mahoney Editor. ASCE, New York, NY.

Bain, M. B., and N. J. Stevenson, editors. 1999. Aquatic habitat assessment: common methods. American Fisheries Society, Bethesda, Maryland.

CDOW. (Colorado Division of Wildlife). 1976. Fish Survey Summary for Cascade Creek. Durango, CO.

CDOW. 1976. Fish Survey Summary for Lime Creek. Durango, CO. CDOW. 1976. Fish Survey Summary for Mill Creek. Durango, CO. CDOW. 1991. Fish Survey Summary for Lime Creek. Durango, CO. CDOW 1992. Fish Survey Summary for Cascade Creek. Durango, CO. CDOW. 2004. Fish Survey Summary for Cascade Creek. Durnago, CO.


16 November 1, 2005

Hawkins, C. P., J. L Kershner, P. A. Bisson, M. D. Bryant, L. M. Decker, S. V. Gregory, D. A. McCullough, C. K. Overton, G. H .Reeves. R. J. Steedman, and M. K. Young. 1993. A hierarchical approach to classifying habitats in small streams. Fisheries. 18(6): 3-12.

Steitz, C.E. 1985. DeSabla-Centerville project, FERC 803. Revised instream flow study analysis for rainbow trout and brown trout. Appendix 3E to PG&E 1985 application for amendment, DeSabla-Centerville Project FERC 803.

United States Forest Service (USFS). 1992. Amended Land and Resource Management Plan for the San Juan National Forests. Durango, Colorado.


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Attachment A

Figure 1.

Tacoma Hydroelectric Project Potential for Degradation of Water Quality of Electra Lake Water RWG Issue No. 3

1 November 1, 2005

PUBLIC SERVICE COMPANY OF COLORADO

TACOMA HYDROELECTRIC PROJECT FERC NO. 12589

WATER RESOURCE WORK GROUP DRAFT

Issue Assessment No. 3 and Study Plan Potential for Degradation of Water Quality of Electra Lake

1.0 Description of Issue (18 CFR 5.9(b)(1)) The issue of increased nutrient loading in Electra Lake due to the discharge from upstream wastewater treatment plants (WWTP) is a concern to stakeholders due to the potential for these discharges to adversely affect the water quality of the lake. It is currently unknown (as of February 24, 2005) how many such WWTP discharges there are and what their permitted (NPDES) capacities are. It is believed that there are 3 WWTPs upstream of Electra Lake and 1 WWTP on Elbert Creek downstream of Electra Lake. The Water Resource Work Group (RWG) has indicated that there is a need for information (flows, water quality parameters) on all WWTP discharges affecting Electra Lake and Elbert Creek. The Water RWG raised concerns about the potential impact of continued development in the Elbert Creek drainage on the water quality of Electra Lake. Concerns centered on the potential for degradation of water quality due to increased nutrient loading and increased siltation. An increased inflow of pollutants could result in an increase in aquatic plant growth and algae blooms, lower dissolved oxygen levels, and increased surface foam. This issue extends to all watersheds which drain into Electra Lake, Cascade Creek via diversion into Little Cascade Creek being the largest of these. 2.0 Project Effects (18 CFR 5.9(b)(5)) The water quality of Electra Lake is a concern to Public Service Company of Colorado (PSCo). The primary potential impact to the water quality of Electra Lake comes from sources of pollution and nutrient loading outside of the Tacoma Project Boundary from sources that are beyond any control or influence of PSCo. In fact, there are two wastewater treatment plants that discharge into Cascade Creek downstream of PSCo’s Cascade Creek diversion dam (Cascade WWTP and Purgatory Metropolitan District WWTP) and one WWTP discharging to Elbert Creek, upstream of Electra Lake (Needles WWTP). The Project may be affected by WWTP inflows; however, Project operations do not control the water quality of inflow the Project receives from Elbert Creek. Project operations are not believed to have any deleterious effect on the water quality of the lake and current water quality conditions are good. This issue, while important, is less related to the relicensing of the Tacoma Project and more appropriately handled by jurisdictional actions from Federal, State and County governments that approve land development and wastewater discharges within the watershed. Temperature effects of discharges from Electra Lake to the Animas River are unknown. Any effect would likely be limited to the summer months and consist of a small amount of cooling


2 November 1, 2005

effect. There are no reports of, or evidence of, deleterious effects to the Animas River due to flow releases from Electra Lake. While the Tacoma Project’s potential impact on water quality is thought to be minimal, the effect of discharges from the surrounding watershed may lead to future problems. This indicates a need to begin a water quality data collection program at Electra Lake to monitor trends and changes over time. The San Juan Citizen’s Alliance (SJCA) has formed the Animas Nutrients Workgroup (ANW). The ANW has been collecting certain nutrient-related water quality data in the Cascade Creek and Animas River drainages since 2002. PSCo has requested copies of the data collected to date. 3.0 Relevant Existing Information (18 CFR 5.9(b)(4)) Current water quality information for Electra Lake is limited. There are data for WWTP point source discharges into Cascade Creek and Elbert Creek as part of the NPDES permit reporting requirements for the three WWTPs identified in Section 2.0 above. No WWTP discharges directly to Elbert Creek downstream of Terminal Dam; Tamarron Resort recycles its wastewater. Data from the existing WWTP permit records is primarily related to discharge water only and not a mixture of stream and effluent water. There is no known source of water quality data being systematically collected at Electra Lake. 4.0 Need for Additional Information (18 CFR 5.9(b)(4)) There is a need for additional information to document current water quality conditions within Electra Lake and to evaluate the potential effect to the Animas River of waters released from Electra Lake. Land use changes, increased recreation demands and increased development in the Elbert Creek and Little Cascade Creek watersheds, and adjacent to Electra Lake, have the potential to alter water quality within Electra Lake. Project operations result in the release of Cascade Creek water through Electra Lake to the Animas River. Documenting existing water quality conditions within Electra Lake and of waters released from the Tacoma powerhouse will provide water quality reference data for Electra Lake and the Project waters released to the Animas River. 5.0 Final Study Plan 5.1 Purpose of Study and Use of Study Results (18 CFR 5.9(b)(1) and 5.9(b)(5) in part) The purpose of this study will be to develop data sufficient to describe the current water quality characteristics, including water temperatures, of Project waters. The area of emphasis will include the inflow to Electra Lake from Little Cascade Creek, three locations within Electra Lake, Elbert Creek immediately above Electra Lake, the tailrace at Tacoma powerhouse and the Animas River immediately above and below the Tacoma tailrace. Parameters to be monitored are listed in Table 1.


3 November 1, 2005

Table 1. Proposed water quality sampling parameters and locations.

1As established by the Colorado Water Quality Control Commission (CWQCC), 2002. 2LCC=Little Cascade Creek; EC=Elbert Creek/Above Electra Lake; EL1-EL2-EL3=upper, middle and lower Electra Lake; TT = Tacoma powerhouse tailrace; AR1 – upstream of Tacoma tailrace; AR2=downstream of Tacoma tailrace. 5.2 Relevant Resource Management Goals (18 CFR 5.9(b)(2)) The Colorado Water Quality Control Commission (CWQCC) has adopted general water quality standards for tributaries, lakes, and reservoirs of the Animas River including Cascade Creek,

Parameter Units Water Quality Standards1

Sampling Locations2

Frequency

Temperature deg. C 20° All Monthly Hourly Temperature deg C 20° EC Weekly-

July thru August DO Mg/L 6.0 mg/l All Monthly- July

thru October DO % sat -- All Monthly- July

thru October pH 6.5 -9.0 All Monthly- July

thru October Total Phosphorus

mg/L LCC, EC, EL1, EL2, EL3, TT, AR1, AR22

Monthly- July thru October

NO2 mg/L 0.05 EL1, EL2, EL3


NO3 mg/L 10.0 EL1, EL2, EL3


F. Coliform #/ml 200/100 ml EL1, EL2, EL3, AR1, AR2


E. Coli #/ml 126/100 ml EL1, EL2, EL3, AR1, AR2


Light meters EL1, EL2, EL3


Chlorophyll a

mg/L EL1, EL2, EL3


Total K. Nitrogen

Mg/l

LCC, EC, EL1, EL2, EL3, TT, AR1, AR2



4 November 1, 2005

Little Cascade Creek, Elbert Creek, and Electra Lake (CWQCC, Reg. 34, Segment 12a, Animas and Florida River). The San Juan National Forest, as part of its Forest Management Plan, has identified water quality goals for USFS administered lands that border the Tacoma Project (USFS 2000). Much of the current forest management plan primarily emphasizes timber harvest and fuels reduction. Recent plan amendments have increased their emphasis on protecting riparian and aquatic habitats and the species that depend upon them. 5.3 Relevant Public Interest Considerations (18 CFR 5.9(b)(3)) Public interest considerations on this issue are primarily related to recreation. PSCo, the general public, and the Electra Sporting Club have a strong interest in maintaining good water quality within Electra Lake for recreation, aesthetics, property values and fish and wildlife habitats. The Animas Nutrient Workgroup is concerned about the water quality of the Animas River Watershed, especially related to nutrient loading due to increased development. 5.4 Study Methodology (18 CFR 5.9(b)(6)) The study methodology is designed to document current water quality conditions at various locations and depths within Electra Lake, at Electra Lake inflows and Electra Lake releases to the Animas River. Sampling will be done at various locations and times and will include different parameters depending upon the site (see Table 1). Final sampling site selection within Electra Lake and those areas above the lake will be done taking into account seasonally fluctuating lake levels and access issues. Water temperatures will be monitored for a one year period on Little Cascade Creek and Elbert Creek just upstream of Electra Lake, at the Tacoma powerhouse tailrace and in the Animas River immediately above and below the Tacoma tailrace. Hourly Celsius recordings will be taken using Onset Tidbit temperature thermaloggers. Hourly data will be used to develop daily average, daily minimum, daily maximum, and maximum weekly average temperatures for each site. Downloads will be conducted on a monthly basis when access is available by boat or snowmobile. During winter and spring months or until ice has left Electra Lake, downloads will only be conducted at accessible sites. Instantaneous water temperatures will also be measured once a week for two months during the summer (July and August) at multiple depths in Electra Lake. This will be done to determine lake stratification depths and temperatures. This sampling will be conducted at three locations within the lake with one in close proximity to the Tacoma penstock intake. Sampling will be conducted with either a YSI multiprobe or a Hydrolab DataSonde 4. Water quality parameters will be sampled once during each summer month (July, August, and September) and in October. Three locations in Electra Lake will be sampled, and at each location, sampling will be conducted at the surface, at the thermocline and within 1 meter of the bottom. The locations on the lake will be identified by GPS coordinates using a handheld unit. The sampling will be done using a Van Dorn style multi-depth sampler to collect samples at varying depths. Water samples will be labeled, placed on ice and transported to Durango for lab


5 November 1, 2005

analyses. In addition, a Hydrolab DataSonde 4 will be used to take instantaneous readings at the same three locations for pH, dissolved oxygen (DO mg/l and DO %sat), depth and temperature. Calibration, deployment, maintenance and data downloads will be done according to accepted manufacturer’s specifications and schedule for individual parameters (Electronic Data Solutions 2003). 5.5 Data Analysis and Reporting Data will be collected and recorded either electronically (for temperature and Hydrolab readings) or via hardcopies from the analyzing lab. Results of all samplings will be reviewed, compiled into monthly reports, and analyzed for overall water quality impacts, comparison to similar concurrent studies in the upper Animas basin and summarized in a final report to be included as part of the Final License Application. Samples analyses for total phosphorus, total nitrogen, NO2, NO3, E. coli, fecal coliform and chlorophyll a will be done by a certified analytical lab located in the Durango area. Sample collection and transport will be done according to accepted protocols. Sampling results for pH, and DO will be saved as field notes and in spreadsheet form. 5.6 Schedule and Level of Effort (18 CFR 5.9(b)(7)) The level of effort to conduct this water quality and temperature monitoring study is approximately 8 person-weeks. Water temperature monitoring will begin in October 2005 for the sites at Little Cascade Creek, Elbert Creek, Tacoma tailrace and the Animas River. Sampling will last for twelve months and end in October 2006. Downloads will be done bimonthly at a minimum and monthly when conditions allow. Downloads will be done by one person except during winter months when two persons will be present for safety purposes. Monitoring done at Electra Lake locations for both temperature and water quality parameters will done using a boat and a two person crew. Sampling will be conducted once a month during July through October 2006. Sampling will require the use of a boat, vehicle and various types of hand held sampling equipment. 5.7 Discussion of Alternative Approaches (18 CFR 5.9(b)(7)) There have been no alternative approaches proposed at this time. 6.0 References Colorado Department of Public Health and Environment. 2002. Water Quality Control

Commission. Regulation #34. Classifications and Numeric Standards for San Juan River and Dolores River Basins.


6 November 1, 2005

Electronic Data Solutions. 2003. Hydrolab Maintenance and Calibration Workshop Training Manual. Jerome, ID. 100ppg. United States Forest Service. 2000. Forest Management Plan for the San Juan National Forest.

Tacoma Hydroelectric Project What Federal and State Lands are Occupied by the Project Water RWG Issue No. 5

1 November 1, 2005



WATER RESOURCE WORK GROUP

Issue Assessment No. 5 and Study Plan What Federal and State Lands are Occupied by the Project?

1.0 Description of Issue (18 CFR 5.9(b)(1)) The Water Resource Work Group (RWG) requested a description of any federally administered and state-owned lands within the Tacoma Project Boundary. The Federal Energy Regulatory Commission (FERC) license sets out a specific boundary for the Project in its original license authorizing the construction and operation of the Project facilities. Parts of the Tacoma Project occupy National Forest system lands managed by the U.S. Forest Service (USFS). 2.0 Project Effects (18 CFR 5.9(b)(5)) Public Service Company of Colorado (PSCo) intends to identify, delineate, and quantify the amount of federally administered lands occupied by the Tacoma Project. There are no state-owned lands within the Project Boundary. 3.0 Relevant Existing Information (18 CFR 5.9(b)(4)) Information currently available from both PSCo and U.S. Forest Service maps may not be up to date on the actual amount of public lands administered by the U.S. Forest Service that are occupied by the Tacoma Project. Available databases include PSCo’s Exhibit G mapping and USFS’ GIS mapping for the San Juan National Forest. Recent federal land exchanges immediately adjacent to the Project may have altered the amount and location of federal lands occupied by the Project, especially along the flowline right-of-way. 4.0 Need for Additional Information (18 CFR 5.9(b)(4)) It is necessary to have an accurate accounting of the amount and location of federal lands that are occupied by the Project. FERC-licensed projects that occupy federal lands are subject to federal land charges and certain conditioning authorities under the Federal Power Act (FPA). 5.0 Final Study Plan The sections below provide a description of the work to be performed to acquire the information needed to adequately address the issues raised under the Water RWG Issue Assessment No. 5.


2 November 1, 2005

5.1 Purpose of Study and Use of Study Results (18 CFR 5.9(b)(1) & 5.9(b)(5) in part) The purpose of the work to be undertaken is to accurately define the amount and location of federal lands occupied by the Tacoma Project. This information will be used to determine payments owed to the federal government for use of the lands occupied by the Project, and the proper limits on the mandatory conditioning authority granted to the federal land administering authority (USFS in this case) under the FPA. 5.2 Relevant Resource Management Goals (18 CFR 5.9(b)(2)) Lands within the San Juan National Forest are managed under the founding statutes and the current and relevant USFS management plan, including in this case the Amended Land and Resource Management Plan, San Juan National Forest. 5.3 Relevant Public Interest Considerations (18 CFR 5.9(b)(3)) The issue of accurately defining the amount and location of federal lands within the Project Boundary is largely an issue of federal interest for the purpose of “rent” payments and authorities under the FPA. 5.4 Study Methodology (18 CFR 5.9(b)(6)) PSCo has commissioned a new land survey of the Project Boundary which will also include searches of the most recent files in the county land offices for land ownership. The survey will be done in accordance with standard metes and bounds methods for land surveys for determination of land boundaries and tract ownership. PSCo will share its findings with the USFS for their review and comparison with USFS’ records. 5.5 Schedule The aerial photogrammetry and supporting ground survey of the Project have been completed. Mapping of the Project Boundary and determination of land ownership within the Project Boundary is underway and expected to be ready for review by the USFS by the end of 2005. 5.6 Duration and Level of Effort (18 CFR 5.9(b)(7)) The duration of the work will likely extend up to the submittal of the Final License Application in order to accurately record any land ownership changes up to that point. 5.7 Discussion of Alternative Approaches (18 CFR 5.9(b)(7)) No alternative approaches have been proposed by others at this time.


3 November 1, 2005

5.8 Data Analysis and Reporting The study will result in the production of new Exhibit G maps to relevant FERC specifications. The maps will delineate the location and acreage of federal land ownership within the Project Boundary. 6.0 References United States Forest Service. Amended San Juan National Forest Land and Resource Management Plan, Rocky Mountain Region. 1992.

Tacoma Hydroelectric Project Project Effects on the Water Quantity & Quality of the Animas River Water RWG Issue No. 7

1 November 1, 2005


FERC NO. 12589 WATER RESOURCE WORK GROUP

DRAFT Issue Assessment No. 71 and Study Plan

Project Effects on the Water Quantity and Quality of the Animas River 1.0 Description of Issue (18 CFR 5.9(b)(1)) An issue was raised related to how Tacoma plant operations might potentially be affecting the water quantity and quality in the Animas River downstream of the confluence of Cascade Creek and the Animas River, and downstream of the Tacoma powerhouse. Of particular mention were the potential effects on organics, metals, nutrient loadings, and dilution. The uncertainty as to the potential for such water quality effects was more the issue than that there was knowledge or evidence of actual effects on water quality. 2.0 Project Effects (18 CFR 5.9(b)(5)) The Tacoma Project diverts flows from Cascade Creek into Little Cascade Creek, and thence into Electra Lake. The Project operations do not add measurable levels of metals, organics, or nutrients to the Animas River. However, because of the timing of the transfer of water from Cascade Creek to Electra Lake and then from Electra Lake to the Animas River, the potential exists for a change in dilution related to these water quality parameters in the Animas River downstream of Cascade Creek. Therefore, the Project effects associated with this issue would primarily be related to the timing of the flow into and out of Electra Lake, and thereby is primarily a question of water quantity. There is no evidence or indication that the Project is directly affecting water quality in the Animas River, other than the potential to do so due to the change in timing of water quantity. Accordingly, Public Service Company of Colorado (PSCo) intends to undertake a study of the hydrologic effects of the Cascade Creek diversions on flows in the Animas River. 3.0 Relevant Existing Information (18 CFR 5.9(b)(4)) To address the primary question of the affect of the Tacoma Project on the flows in the Animas River, PSCo will rely heavily on flow records maintained by the Colorado State Engineers’ Office and by streamflow gauge records recorded and maintained by the U.S. Geological Survey. Relevant hydrologic records include data from the following sources: • USGS gauge number 09361500: Animas River at Durango, Colorado • USGS gauge number 09359500: Animas River above Tacoma (discontinued) • Colorado Division of Water Resources Annual Water Diversion Reports: Elbert Creek • Colorado Division of Water Resources Annual Water Diversion Reports: Cascade Creek

1 Original Issue No. 8.


2 November 1, 2005

• PSCo Discharge Records from the Tacoma Powerhouse and PSCo’s Electra Lake Reservoir Elevations Other relevant information includes the size of the various drainage areas relevant to this issue. These are shown in Figure 14 of PSCo’s Pre-Application Document (PAD). 4.0 Need for Additional Information (18 CFR 5.9(b)(4)) To understand the nature of the seasonal changes in flow distribution in the Animas River due to the Tacoma Project, a substantial amount of additional information will be necessary. This information will be developed by hydrologic analysis. No additional data collection will be required. 5.0 Final Study Plan The sections below provide a description of the work to be performed to acquire the information needed to adequately address the issues raised under the Water RWG Issue Assessment No. 7. 5.1 Purpose of Study and Use of Study Results (18 CFR 5.9(b)(1) & 5.9(b)(5) in part) The purpose of this study plan is to develop a quantitative understanding of the effects of the operations of the Tacoma Project on flows in the Animas River, and by association, potential effects on water quality in the Animas River on parameters potentially affected by dilution (metals concentration, nutrient concentration, organics). The study results will be used to demonstrate the hydrologic flow regime of the Animas River with Project operations. This will improve informed decision-making related to the effects of any potential future change in Project operations on Animas River flow, and by extension, Animas River water quality. 5.2 Relevant Resource Management Goals (18 CFR 5.9(b)(2)) Jurisdiction over the water quality in the Animas River rests with the Colorado Water Quality Control Commission. Jurisdiction over the allocation of the use of water in Colorado lies with the State of Colorado’s Division of Water Resources which administers water rights in the state. The water resource management goals of these agencies are established by state statute. Other relevant resource management goals for Project lands and waters that occupy federal lands managed by the USFS are contained in the appropriate Forest Plan, in this case the 1992 Amended Land and Resource Management Plan (LRMP) of the San Juan National Forest. The LRMP includes protection of riparian habitats and protection of native flora and fauna, especially rare and sensitive plant and animal species.


3 November 1, 2005

Specific LRMP direction includes: Forest-Wide Direction

Wildlife and Fish Resource Management (01). Manage for habitat needs of indicator species. Wildlife and Fish Resource Management (02). Maintain habitat for viable populations of all existing vertebrate wildlife species.

a. Habitat for each species on the forest will be maintained at least at 40 percent or more of potential.

Wildlife and Fish Resource Management (03). Manage waters capable of supporting self-sustaining trout populations to provide for those populations.

a. Manage stream habitat to 90 percent of potential where existing self sustaining fishery occurs. Management activities which cause unfavorable conditions in existing fishery will include mitigation measures in project proposal.

Wildlife and Fish Resource Management (04). Manage and provide habitat for recovery of endangered and threatened species. Wildlife and Fish Resource Management (05). Manage and provide habitat for the sensitive species.


Wildlife Habitat Improvement and Maintenance (06). Maintain instream flows in cooperation with state wildlife agencies to support a sustained yield of natural fisheries resources.

5.3 Relevant Public Interest Considerations (18 CFR 5.9(b)(3)) Other parties with an interest in this issue include various public, NGO, and private entities, including the City of Durango, the San Juan Citizen’s Alliance (SJCA) and numerous private water users (Durango Mountain Resort and Tamarron Resort). Water quantity and quality in the Animas River has been a topic of interest and some research in the past. Primary water quality concerns historically had centered on metals loadings due to historical and current mining operations in the upper Animas River watershed. 5.4 Study Methodology (18 CFR 5.9(b)(6)) The study approach to establish the effects of Project operations on flows and, by extension, water quality in the Animas River will be quantitative in nature, primarily focused on developing an understanding of historical flows at various points in the Animas River and the magnitude of the Project’s effects on these flows.


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5.4.1 Qualitative Overview of Project Operations Qualitatively, a reasonable assessment of effects on Animas River water quality can be surmised by a basic understanding of how the Tacoma Project operates. The Project’s main reservoir, Electra Lake, fills during periods of high runoff (late April through early July). This indicates that the Project operation results in a reduction in flows when the Animas River is at its peak seasonal runoff. Electra Lake levels are normally kept fairly constant through the July through October recreation season, indicating that inflows are roughly equal to outflow over a daily to multi-day time frame during this period. From November to March, Electra Lake is drawn down, meaning that Project operations result in an increase in flows when the Animas River is at its lower flow period. The daily distribution of Project outflows is affected by the Project’s peaking operations. In general, metals concentrations in the Animas River are currently lowest during high flow conditions and highest during low flow conditions. This is understandable from the fact that mine drainage and tailings pond seepage will have proportionately greater effect on water quality during low flow conditions. Therefore, the Tacoma Project can generally be expected to reduce metals concentrations during naturally lower flow periods because it is generally releasing water from storage, or increasing flows over natural runoff levels. It is important to note that Cascade Creek is generally considered to have significantly better water quality than the Animas River because of the general lack of mine development and the fact that it is essentially 100 percent lands managed by the USFS. 5.4.2 Approach to Quantitative Assessment The sequence of the hydrologic analysis to be undertaken is outlined below. This may be adjusted as the analysis proceeds to refine the approach based on findings that are made as the work proceeds. Step 1: Compile and Evaluate Existing Data Sources

Obtain from the Animas River Task Force and the Colorado Department of Public Health and Environment information relative to water quality at various locations on the Animas River. Obtain from the Colorado Division of Water Resources and the USGS information on the quantity of flows in the Animas River. This step will serve to confirm the availability, reliability, and accuracy of the various data sources.

Step 2: Select Target Locations for Analysis

On a preliminary basis, the target locations on the Animas River appropriate to this issue are (1) above Cascade Creek; (2) below Cascade Creek; (3) above Tacoma powerhouse; (4) below Tacoma powerhouse; and (5) at Durango.

Step 3: Select an Appropriate Period of Record for Analysis


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By evaluating the available sources of data, and relevant changes in the watershed that have occurred over time, an appropriate and representative period of record for the analysis will be selected.

Step 4: Develop Hydrologic Relationships

By using statistical techniques, develop relationships as necessary between gauge records to enable the development of hydrologic data suitable to the target locations identified in Step 2. Identify low flow and drought years for analysis.

Step 5: Develop Hydrographs of Runoff in the Animas River to Assess Project Effects

on Animas River Flows Using the relationships developed in Step 4, develop synthetic hydrographs for the target locations of Step 2 for the time period identified in Step 3. Evaluate these differences and their likely effect on the dilution capability of the Animas River at the various target locations. Provide an analysis of a low-flow year and the low-flow months of August, September, and October. Combine hydrologic data with available Animas River water quality data to estimate effect on water quality parameters of Tacoma Project operations.

Using the following equations, Project effects on metals, organics, or nutrient concentrations can be estimated: QA = QN + QP TMA = QA x C1 C2 = TMA / QN Where QA = Animas River average daily flow below Tacoma powerhouse QN = Animas River average daily unimpaired flow below Tacoma powerhouse QP = Net Tacoma plant flow (QOut – QIn) TMA = Total metals loading in Animas below Tacoma powerhouse C1 = Metals concentration in Animas River below Tacoma powerhouse C2 = Metals concentration in Animas River under unimpaired flow conditions Assuming metals concentration in Cascade Creek is always much lower than Animas River, then: When: QA > QN; C1 < C2 QA < QN; C1 > C2

5.5 Schedule The study will extend from February 2006 to September 2006, at which time a report of the findings will be issued.


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5.6 Duration and Level of Effort (18 CFR 5.9(b)(7)) The duration of the study is provided in Section 5.5 above. It is estimated that the study will require about 12 person-weeks of effort including report writing. 5.7 Discussion of Alternative Approaches (18 CFR 5.9(b)(7)) No alternative approaches have been proposed by others at this time. 6.0 References Public Service Company of Colorado. Pre-Application Document Tacoma Project. May 2005.

Tacoma Hydroelectric Project Project’s Effects on Riparian Habitat and Fish Habitat in the Animas River Water RWG Issue No. 8

1 November 1, 2005




Issue Assessment No. 81 and Study Plan Project’s Effects on Riparian Habitat and Fish Habitat in the Animas River

1.0 Description of Issue (18 CFR 5.9(b)(1)) It was noted that the general consensus was that the cold-water fishery in the Animas River in the vicinity of the Tacoma Project had improved considerably in recent years due, at least in part, to the improvement of water quality (reduced metal concentrations). A question was raised concerning whether plant operations might be affecting Animas River channel characteristics (channel morphology) and fish habitat. It was questioned whether the withdrawal of water at Cascade Creek, its temporary storage, and its re-discharge into the Animas River in a peaking mode was possibly affecting the quantity and quality of habitat in the Animas River. 2.0 Project Effects (18 CFR 5.9(b)(5)) The Tacoma project tailrace is located approximately 4.5 miles downstream of the mouth of Cascade Creek. The diversion of flows by the Project affects the flow regime in the Animas River. These effects are expected to be minor as the drainage area of the Animas River below Cascade Creek is approximately 340 square miles, and the drainage area above the Cascade Creek diversion dam is 25 square miles, or about 7% of the total. Therefore, the effect of the diversion on Cascade Creek on flows in the Animas River (which relates directly to riparian habitat and fish habitat) would be expected to be minor. Below the Tacoma powerhouse, Project effects are primarily related to the amount and timing of peaking releases relative to river flows at the time of powerhouse operation. Public Service Company of Colorado (PSCo) will examine the likely effects of Tacoma peaking flows on the Animas River by reviewing actual discharge records from the powerhouse and the Animas River. 3.0 Relevant Existing Information (18 CFR 5.9(b)(4)) Information relevant to this issue will be the results of the studies to be completed as part of Water RWG Issue Assessment No. 7 and PSCo’s records of Tacoma powerhouse discharges.

1 Original Issue No. 9


2 November 1, 2005

4.0 Need for Additional Information (18 CFR 5.9(b)(4)) In addition to hydrographs developed in the study associated with Water RWG Issue Assessment No. 7, it will be necessary to develop a representative seasonally-adjusted daily operation schedule for the Tacoma plant. The specific concern raised in this issue was the affect of peaking operations on Animas River flows; and thereby, effects on riparian habitat and fish habitat. Therefore, representative peaking operations would be overlayed on to Animas River flows that occur above the Tacoma plant. The Tacoma plant does not operate in a peaking fashion during the reservoir fill period of April through June. Peaking operations normally commence sometime in July and extend through September, then reoccur during the winter months December through March. 5.0 Final Study Plan The sections below provide a description of the work to be performed to acquire the information needed to adequately address the issues raised under the Water RWG Issue Assessment No. 8. 5.1 Purpose of Study and Use of Study Results (18 CFR 5.9(b)(1) & 5.9(b)(5) in part) The purpose of this study is to determine the potential for Project peaking operations to impact riparian habitat and/or fish habitat in the Animas River below the Tacoma powerhouse. The study will assist in making informed decisions about the degree of environmental impact, if any, resulting from Project peaking operations. 5.2 Relevant Resource Management Goals (18 CFR 5.9(b)(2)) Jurisdiction over the water quality in the Animas River rests with the Colorado Water Quality Control Commission. Jurisdiction over the allocation of the use of water in Colorado lies with the State of Colorado’s Division of Water Resources which administers water rights in the state. The water resource management goals of these agencies are established by state statute. Other relevant water resource management goals for those lands and waters located within the boundaries of federal lands managed by the USFS are contained in the appropriate Forest Plan, in this case the 1992 Amended Land and Resource Management Plan of the San Juan National Forest. The LRMP includes protection of riparian habitats and protection of native flora and fauna, especially rare and sensitive plant and animal species. Specific LRMP direction includes: Forest-Wide Direction




3 November 1, 2005

Wildlife and Fish Resource Management (05). Manage waters capable of supporting self-sustaining trout populations to provide for those populations (page III-26). Riparian Area Management (02). Design and implement activities in management areas to protect and manage the riparian ecosystem (page III-46).


Wildlife Habitat Improvement and Maintenance (04). Manage riparian areas identified as essential habitat for indicator species by retaining suitable habitats (page III-254).

b. Cutthroat, Rainbow, Brown, and Brook Trout. Implement structural and non-structural improvements to maintain or improve fisheries habitat in aquatic ecosystems. In streams and rivers, develop habitat that will provide protective cover for trout during low water and escape and feeding cover during periods of low flow (page III-254).

5.3 Relevant Public Interest Considerations (18 CFR 5.9(b)(3)) Other parties with an interest in this issue include various public, NGOs and private entities, including the City of Durango, the San Juan Citizen’s Alliance (SJCA) and numerous private water users (Durango Mountain Resort and Tamarron Resort). 5.4 Study Methodology (18 CFR 5.9(b)(6)) The approach to this study will be to determine, as an essential first step, the nature, degree, and magnitude of changes in Animas River flows over a normal daily period due to Tacoma peaking operations. Potential impacts to riparian habitat and fish habitat are presumed to be closely related to the changes in flow in the Animas River from above to below the Tacoma powerhouse. The Animas River below Tacoma is a steep-gradient stream confined in a well-defined, narrow channel. The sequence and scope of the work are outlined below. Step 1: Develop representative peaking schedules for Project operations

PSCo will develop, based on a review of recent operating records, seasonally-based representative peaking schedules for the flow through the Tacoma powerhouse on an hourly basis for a typical day.

Step 2: Develop typical flows on a monthly basis for the Animas River above

Tacoma This data will be derived from the analysis conducted as part of the Water RWG Issue Assessment No. 7. Typical wet, dry, and normal year flows for each month of the year that peaking occurs will be developed.

Step 3: Apply Peaking Schedule to Monthly Flows


4 November 1, 2005

This step will consist of overlaying the results of Step 1 and Step 2 to develop an understanding of the potential changes to flow that occur as a result of Project operations.

Step 4: Identify Representative Transects of the Animas River below the Tacoma

Powerhouse and Record Actual Changes in Stage as a Result of Peaking This step will consist of recording actual changes in river stage at representative river transects downstream of the Tacoma powerhouse. These will be recorded by a water-level logger at pre-selected transects.

Step 5: Assess Likely Changes in Flow and Stage Due to Peaking Operations

By combining the results of Step 3 and Step 4, a reasoned assessment of the potential degree of impact can be identified.

Step 6: Prepare Summary Report

A study report will be prepared describing the methodology, data, analyses, and findings of the study.

5.5 Schedule This study will commence about April 1, 2006 and be complete in December 2006. 5.6 Duration and Level of Effort (18 CFR 5.9(b)(7)) The duration of the study is 8 months and the level of effort is estimated to be 10 person-weeks. 5.7 Discussion of Alternative Approaches (18 CFR 5.9(b)(7)) No alternative approaches have been proposed by others at this time. 5.8 Data Analysis and Reporting The analysis is summarized in Section 5.4 above. The results from this study will be combined with the findings from Tacoma Water RWG Issue Assessment No. 7 - Project Effects on the Water Quantity and Quality of the Animas River and summarized in a single report. A draft report will be completed in December, 2006. 6.0 References Public Service Company of Colorado. Pre-Application Document Tacoma Project. May 2005. United States Forest Service (USFS). 1992. Amended Land and Resource Management Plan for

the San Juan National Forests. Durango, Colorado.

Tacoma Hydroelectric Project Project Effects on Little Cascade Creek Water RWG Issue No. 10.

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WATER RESOURCE WORK GROUP DRAFT

Issue Assessment No. 101 and Study Plan Project Effects on Little Cascade Creek

1.0 Description of Issue (18 CFR 5.9(b)(1)) The water diverted from Cascade Creek travels by flume and pipe to a point of exit into the Little Cascade Creek watershed; it then flows via Little Cascade Creek into Aspaas Lake and Electra Lake. An issue was raised as to the effects of these diverted flows on the stream channel conditions, geomorphology, adjacent wetlands, and fishery habitat of Little Cascade Creek. All issues related to fishery habitat and use have been consolidated with Issue Assessment No. 2, Instream Flows Below Cascade Creek Diversion Dam. 2.0 Project Effects (18 CFR 5.9(b)95)) Current Tacoma Project operations can provide as much as 250 cfs (flume capacity) with the potential for 400 cfs (current PSCo water right) to be discharged to the Little Cascade Creek channel. The drainage area of Little Cascade Creek at U.S. Route 550 is less than 5 square miles, indicating that absent diverted flows, the channel would essentially be dry for much of the time. The discharges provided by the Tacoma Project operations likely cause Project-related effects to Little Cascade Creek. It is known that at least a portion of the lower part of Little Cascade Creek (just above Aspaas Lake) provides spawning habitat for the trout species of Electra Lake, especially the fall-spawning brook trout. Comments by area sportsmen, Electra Sporting Club (ESC) members and agency personnel have indicated healthy fish populations reside in the Little Cascade Creek channel immediately above Aspaas Lake. The wetland habitats along Little Cascade Creek are a result of the diversions from Cascade Creek. However, the condition and distribution of fish and macroinvertebrate species, stream channel stability, and riparian areas have not been evaluated. If flows to Little Cascade Creek were to change significantly, these resources could be impacted. Public Service Company of Colorado (PSCo) intends to conduct an inventory of riparian and wetland habitats, erosion, and fish spawning habitats on Little Cascade Creek from U.S. Highway 550 to Aspaas Lake.

1 Original Issue No. 11 identified by the Water RWG on September 28, 2004


2

3.0 Relevant Existing Information (18 CFR 5.9(b)(4)) Existing information on current habitat conditions within Little Cascade Creek and in associated riparian and wetland areas is limited, with much of it consisting of information provided by personal communications. Flows diverted from Cascade Creek to Little Cascade Creek and Electra Lake are well documented by the Colorado State Engineers’ Office of Water Resources. Diverted flows are gauged at the exit of the Project flowline prior to entering Little Cascade Creek. Limited natural resource data is available from scattered Colorado Division of Wildlife (CDOW) surveys conducted over the last 30 years at specific sites within the watershed. CDOW conducted fish surveys in 1975, 1978, 1993 and 2004 in the area but none specifically on Little Cascade Creek. In addition, statements from CDOW staff, members of ESC and local residents have indicated the importance of Little Cascade Creek to natural reproduction of trout species, particularly brook trout, in Electra Lake. According to the National Wetland Inventory (NWI), wetlands along Little Cascade Creek are associated with areas of low gradient and wide floodplain. Columbine Lake is lacustrine, but is fringed by patches of palustrine scrub-shrub wetlands. Between Columbine Lake and Aspaas Lake, the NWI database shows other wetlands classified as palustrine aquatic bed and scrub-shrub. Aspaas Lake is classified as palustrine aquatic bed with smaller emergent and scrub-shrub areas. The NWI information is based on aerial infrared imagery dated July 1986. Other sources of data may exist, but have either yet to be identified or have only just recently come into the possession of PSCo. Further data searches are taking place with the Colorado Natural Heritage Program, San Juan County, Durango Mountain Resort and the offices of the San Juan National Forest. 4.0 Need for Additional Information (18 CFR 5.9(b)(4)) Additional information about Little Cascade Creek is needed to more fully understand the current physical conditions in the reach just above Aspaas Lake where important spawning and rearing habitat for brook and brown trout reportedly exists. Habitat characteristics in this area are currently unknown and the need for documenting these conditions is relevant particularly if potential flow requirements in Cascade Creek demand the altering of flows in Little Cascade Creek. During the original defining of this issue, the need to address broad geomorphological characteristics was discussed. Subsequent RWG discussions determined the need was not general geomorphological information but rather to focus this study on addressing bank stability and erosion issues, including their relationship to possible sediment contributions and effects to spawning areas. Water diverted from Cascade Creek to Little Cascade Creek provides the majority of flow in Little Cascade Creek and has been maintaining this riparian corridor for almost 100 years. The continued diversion of Cascade Creek water and its delivery through Little Cascade Creek to Electra Lake may be important to maintaining the current spawning habitats, riparian areas and channel conditions. Additional data collection is needed to locate and generally estimate fish spawning habitat within Little Cascade Creek. The quality and distribution of these spawning areas, and subsequent incubation success of the eggs, are likely to be directly related to flows delivered to Little Cascade Creek from Cascade Creek. This requires additional information in order to understand this area as agencies in the past have indicated that


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natural recruitment and reproduction in fish populations is preferred over long term stocking programs. The regularity and stability of these flows likely have produced aquatic resources that would not exist in their current state without the continuation of flow diversions from Cascade Creek. Results from this study will provide a descriptive evaluation of current physical characteristics in Little Cascade Creek and expected potential seasonal changes to this reach if altered flow regimes are considered during relicensing. Results may also provide additional information relating to seasonal fish use and fish preferred habitat allowing for specified habitat enhancement projects or use restrictions to protect and promote natural recruitment for Electra Lake. 5.0 Final Study Plan PSCo has developed this Study Plan to obtain the additional information needed to support informed decision-making related to the resources associated with the Tacoma Project, as relates to current conditions and uses of Little Cascade Creek and the likely gross level of changes that would occur with changes in flow regime. After discussion with RWG members at RWG Meeting No. 7 on September 27, 2005, it was agreed that aspects of this Issue Assessment No. 10 that deal with fish habitat assessment would be consolidated with the Study Plan for Water RWG Issue Assessment No. 2, Instream Flows Below Cascade Creek Diversion Dam because of the direct linkage between Cascade Creek and Little Cascade Creek from a flow perspective. Therefore, the Study Plan described herein only deals with those issues and Project effects not related to fish habitat, specially condition of riparian and wetland habitats and bank and channel stability. 5.1 Purpose of Study and Use of Study Results (18 CFR 5.9(b)(1) & 5.9(b)(5) in part) The purpose of the study will be to provide descriptive data on a number of different physical characteristics of Little Cascade Creek. The primary objective is to determine current substrate and channel conditions within the Little Cascade Creek corridor related to diverted flows into Little Cascade Creek as a result of Project operations. The assessments will include the location and condition of riparian and wetland habitats, and bank and channel stability. This information will provide the context for interpreting current stream corridor and substrate conditions and assist in predicting future large scale channel responses to continued or altered flow regimes from the Project. 5.2 Relevant Resource Management Goals (18 CFR 5.9(b)(2)) Little Cascade Creek occupies and borders lands of the San Juan National Forest (see Figure 4 of the Tacoma PAD). Current forest management plans primarily emphasize timber harvest and fuels reduction. Recent plan amendments have placed increased emphasis on protecting riparian and aquatic habitats and the species that depend upon them through maintenance, improvement


4

and enhancement of these habitats. There are no site-specific USFS resource management goals for Little Cascade Creek. 5.3 Relevant Public Interest Considerations (18 CFR 5.9(b)(3)) Little Cascade Creek is considered by members of the public to be an important fish rearing stream providing natural salmonid reproduction for Electra Lake. In addition, the area along Little Cascade Creek may be encouraging providing diverse habitat for amphibian, avian and plant species. 5.4 Study Methodology (18 CFR 5.9(b)(6)) Study components include semi-quantitative reconnaissance-level assessments of riparian vegetation and wetland habitat distribution (see Terrestrial RWG Issue Assessment No. 7), and geomorphologic assessments of bank and channel conditions. These evaluations will be done to document existing conditions, identify unique resource features and habitats, and evaluate the effect of changes in flow regime on a qualitative scale (absence or presence of resource impacts, major or minor level of effect). 5.4.1 Study Area The study area is composed of riparian, wetland, and aquatic habitats physically or hydrologically associated with Little Cascade Creek between U.S. Highway 550 and Aspaas Lake, a reach approximately two miles in length.

5.4.2 Study Approach

Riparian, wetland and stream channel conditions will be documented. Riparian vegetation, wetland habitats and bank conditions will also provide context for quantifying spawning habitat. A reconnaissance-level effort will be conducted to characterize these resource values. The reconnaissance survey team will be comprised of a botanist and a scientist qualified to evaluate stream geomorphology. Observations of representative conditions and noteworthy atypical conditions (e.g., site-specific erosion) will be documented by photographs and GPS-determined locations will be recorded. Within riparian habitats and stream-associated wetlands, descriptive information will be collected on the extent, composition, and condition of vegetation communities. This will include (1) noting dominant and sub-dominant species; (2) characterizing evidence of periodic recruitment; (3) rating dominant and sub-dominant species for known association with moist soil conditions according to Reed (1997) and capability for maintaining bank stability against the erosive forces of moving water according to Winward (2000), other published sources, or by interpreting field observations of erosion or bank failures; and (4) assessing plant communities as a source of coarse and/or large wood material. The width of the riparian zone will also be measured in representative locations.


5

Streambank erosion can be a significant sediment source and can affect spawning gravel quantity and quality. Little is known about the amount of erosion and condition of the streambed. Streambank erosion will be quantified by totaling the amount of freshly exposed streambanks on both banks and dividing by the total length of stream times two (to convert length of both banks to total distance). Slides will be classified similar to those found in D. Hagerty’s Journal of Hydraulic Engineering (1991, Volume 117, Number 8). Triggering mechanism and dominant size class of bank material will be noted. Length, width, and depth of each slide “class” will be provided to show the types of slides that are contributing the greatest quantity of sediment. Results will be summarized as to types of bank failure, and the mechanisms of failure. There may be a link between sediments and spawning gravel. Size fraction and type of sediment contributed from bank erosion can be compared to spawning gravels to qualitatively assess the link. 5.5 Data Analysis and Reporting

The data will be analyzed and summarized with the results and findings documented in a final report. The report will assess the current condition of the riparian and wetland areas, including a description of existing bank and channel conditions in Little Cascade. The results of this study plan will be incorporated into a final document detailing Project operations and their effects on spawning gravel areas, riparian areas and bank and channel conditions of Little Cascade Creek. The final report will be incorporated into the Final License Application. The report will include study objectives, study area, methods, tabulated results, maps with riparian vegetation, and an assessment of Project effects on these areas at a qualitative, descriptive scale, such as absence or presence of resource or likelihood of significant impacts.

5.6 Schedule and Level of Effort (18 CFR 5.9(b)(7)) The schedule for completing this task will include two different seasonal activities, both to be completed by the fall of 2006. This work includes performing the riparian and wetland vegetation surveys and documenting of stream channel and bank conditions. The approximate number of work hours to complete this study will be approximately 6 person-weeks. The final report will be completed within six months of the completion of the field work. 5.7 Discussion of Alternative Approaches (18 CFR 5.9(b)(7)) No alternative approaches have been proposed at this time. 6.0 References Bjornn,T.C. and D.W. Reiser. 1991. Habitat requirements of salmonids in streams. Pages 41-82

In: W.R. Meechan (ed.) Influences of forest and rangeland management on salmonid fishes and their habitats. American Fisheries Society Special Publication 16. Bethesda.

Cable, T., V. Brack, Jr., and V.R. Holmes. 1989. Simplified method for wetland habitat

assessment. Environmental Management 13: 207-213.


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Carsey, K., D. Cooper, K. Decker, D. Culver, and G. Kittel. 2003. Statewide wetlands classification and characterization – wetland plant associations of Colorado. Colorado Natural Heritage Program, Fort Collins, Colorado.

Cowardin, L.M., V. Carter, F.C. Golet, and E.T.LaRoe. 1979. Classification of wetlands and

deepwater habitats of the United States. FWS/OBS-79/31, US Fish and Wildlife Service Office of Biological Services, Washington D.C.

Hagerty, D.J. Piping/Sapping Erosion. I: Basic Considerations

Member, ASCE, (Prof., Civ. Engrg. Dept., Univ. of Louisville, Louisville, KY 40292) Hagerty, D.J. Piping/Sapping Erosion. II: Identification-Diagnosis

Member, ASCE, (Prof., Civ. Engrg. Dept., Univ. of Louisville, Louisville, KY 40292) Hankin, D.G. and G.H. Reeves. 1988. Estimating total fish abundance and total habitat area in

small streams based on visual estimation methods. Canadian Journal of Fisheries and Aquatic Sciences. 45(5): 834-844.

Harrelson, C.C., C.L. Rawlins, and J.P. Potyondy. Stream Channel Reference Sites: An

Illustrated Guide to Field Technique. USDA Forest Service General Technical Report RM-245. 61 pages.

Journal of Hydraulic Engineering, Vol. 117, No. 8, August 1991, pp. 1009-1025 Kittel, G., E. VanWie, M. Damm, R. Rondeau, S. Kettler, A. McMullen, and J. Sanderson.

1999. A classification of riparian wetland plant associations of Colorado – a user’s guide to the classification project. Colorado Natural Heritage Program, Fort Collins, Colorado.

Kondolf, G.M., M.J. Sale and M.G. Wolman. 1993. Modification of fluvial gravel size by

spawning salmonids. Water Resources Research 29 (7): 2265-2274. July 1993. Lanigan, S.H., K Anderson, B. Baer, T. Mendenhall, K. Moynan, W. Paradis, P. Sidall, G.

Seloske and K. Thompson. 1990-91. Nez Perce National Forest Basinwide Survey Methodology - Updated and Modified Clearwater National Forest Stream Survey Methodology (Espinosa 1989). Nez Perce National Forest, Grangeville, Idaho.

Platts, W.S., W.F. Megahan, and G.W. Minshall. 1983. Methods for evaluating stream, riparian,

and biotic conditions. Gen. Tech. Rep. INT-138. USDA Forest Service, Intermountain Forest and Range Experiment Station, Ogden, UT. 70 pp.

Schuett-Hames, D.E. and A. Pleuss. 1996. Literature review and monitoring recommendations

for salmonid spawning habitat availability. TFW-AM-9-96-002. Northwest Indian Fisheries Commission. Olympia, WA.


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US Department of the Interior Bureau of Land Management (BLM). 1997. Colorado public land health standards. Montrose, Colorado.

Tacoma Hydroelectric Project Compliance with Endangered Species Act - Section 7 Water RWG Issue No. 14

1 November 1, 2005




Issue Assessment No. 14 and Study Plan Compliance with Endangered Species Act - Section 7(c)

1.0 Description of Issue (18 CFR 5.9(b)(1)) The Department of Interior – United States Fish and Wildlife Service (USFWS) has raised the issue of compliance with Section 7(c) of the Endangered Species Act of 1973 (ESA), as amended (16 U.S.C. §§1531 to 1543 et seq.). This section requires federal agencies to consult with the USFWS to ensure that their actions are not likely to jeopardize the continued existence of federally listed threatened and endangered species, or result in the destruction or adverse modification of designated critical habitat. 2.0 Project Effects (18 CFR 5.9(b)(5)) By regulation, FERC is required to comply with Section 7 of the ESA. Public Service Company of Colorado (PSCo) has been granted designation as FERC’s non-federal representative for purposes of conducting consultation under Section 7 of the ESA. No specific evidence of the Project having any known adverse effect on listed species has been provided or found to date. 3.0 Relevant Existing Information (18 CFR 5.9(b)(4)) Site-specific survey work of listed species within the Tacoma Project Boundary has not been conducted. In a letter dated March 10 2005, the USFWS indicated that the following listed or candidate species may be present in the Tacoma Project vicinity: Tacoma Project Federally Listed and Candidate Species Bald eagle Haliaeetus leucocephalus Razorback sucker Xyrauchen texanus Colorado pikeminnow Ptychocheilus lucius Canada lynx Lynx Canadensis Uncompahgre fritillary butterfly Boloria acrocnema Southwestern willow flycatcher Empidonax traillii extimus Yellow-billed cuckoo Coccyzus americanus (candidate species) The USFWS originally included the boreal toad (Bufo boreas boreas) as a candidate species in their September 20, 2005 letter to PSCo. However, on September 29, 2005 the USFWS declined to list the Southern Rocky Mountain Population of the boreal toad as Endangered, and removed it from the candidate list.


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The USFWS list contains two fish species—razorback sucker and Colorado pikeminnow—that do not reside in the Project area. Both fish reside in the San Juan River of which the Animas River is a tributary. In 1992, after extensive negotiations among federal and state agencies, environmental groups, and water users, the San Juan River Basin Recovery Implementation Program (RIP) was established. The purpose of the RIP is to protect and recover Colorado pikeminnow and razorback sucker in the San Juan River basin, while allowing additional water development. The USFWS approved basin-wide recovery goals in August, 2002. The recovery goals recognize and adhere to State and Federal laws related to the Colorado River System (“Law of the River”), including Colorado State water law, interstate river compacts, and Federal trust responsibilities. The RIP has been adopted by the USFWS as the Reasonable and Prudent Alternative (RPA) to avoid jeopardy and provide recovery under the ESA. In accordance with the San Juan River RIP, all water diversions and water depletions occurring in the basin, including the Animas River Basin and its tributaries, prior to 1992, are part of the “baseline depletions” from the San Juan River. This includes 32,800 acre-feet of depletions from the Animas and LaPlata Rivers based on watershed modeling conducted by the U.S. Bureau of Reclamation. PSCo has confirmed that the Tacoma Project operations were included in the baseline depletions and in the hydrologic model. (Personal communication, John Simons, USBR). Therefore, the effects of PSCo’s Tacoma Project on the listed fish species has been assessed and incorporated into the San Juan River Basin RIP. PSCo is proposing no changes to the operation of the Project, and therefore there are no additional depletions or significant changes in flow regime compared to the RIP’s baseline conditions. 4.0 Need for Additional Information (18 CFR 5.9(b)(4)) An assessment of the potential for the Tacoma Project to affect listed species will require a review of habitat needs and life history in relation to the habitats available within the Project Boundary. The potential for Project operations to affect species covered under the San Juan River RIP will require final confirmation that the Project was included in the “baseline depletions.” PSCo recognizes the need to understand how current Project operations may affect endangered or threatened species in Cascade Creek, Elbert Creek, Little Cascade Creek and the Animas River in La Plata and San Juan Counties, Colorado. Additional information needs to be obtained on whether or not these species exist within the Project Boundary and to what extent their critical habitats may be affected by current Project operations.


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5.0 Final Study Plan 5.1 Purpose of Study and Use of Study Results (18 CFR 5.9(b)(1) & 5.9(b)(5) in part) The purpose of this study is to assist FERC in meeting the requirements of ESA Section 7 by assessing the potential for the Tacoma Project to affect listed species. Field work in support of these assessments is described in other study plans that are part of this Proposed Study Plan package. These assessments will support PSCo’s preparation of a draft Biological Assessment (BA) for the Project, a document that will include determinations of effect. Informal consultation with the USFWS is also expected to be a major contributor to the information base supporting PSCo’s BA for the Tacoma Project. Although BA preparation is optional when major new construction is not proposed, PSCo believes a BA will assist in the timely resolution of ESA issues arising from Project licensing, a benefit for all Project stakeholders. Related to the two listed fish species located in the San Juan River, an RPA already exists and is being implemented which has considered the effects of Tacoma Project operations. 5.2 Relevant Resource Management Goals (18 CFR 5.9(b)(2)) Lands within the San Juan National Forest are managed under the Amended Land and Resource Management Plan for the San Juan National Forest (USFS 1992). In addition, the following federal acts pertain to protected, threatened and endangered species as administered by the Service. They include: the Federal Power Act (16 U.S.C. 791 et seq.), Fish and Wildlife Coordination Act (16 U.S.C. §§661 et seq.), Endangered Species Act of 1973, as amended (16 U.S.C. §§1531 to 1543 et seq. (ESA)), National Environmental Policy Act (42 U.S.C. 4321 et seq.), Migratory Bird Treaty Act of 1918, as amended (16 U.S.C. 703 et seq. (MBTA)), and the Bald Eagle Protection Act of 1940, as amended (16 U.S.C. 668 et seq., (BEPA)). The recovery goals issued in August, 2002, for the San Juan River Basin RIP are relevant to the protection and recovery of the razorback sucker and the Colorado pikeminnow. 5.3 Relevant Public Interest Considerations (18 CFR 5.9(b)(3)) The Tacoma Water RWG, which is comprised of public agencies, private entities, and other interested parties, has identified this issue as being significant. 5.4 Study Methodology (18 CFR 5.9(b)(6)) As FERC’s designated non-federal representative for section 7 consultation, PSCo intends to proceed with informal consultation with the USFWS so as to ensure that listed species are adequately addressed in the BA for the Tacoma Project. Currently, PSCo has proposed a suite of studies that will establish the nature and degree of Project effects on listed species. Included in these are flow assessments, accretion, and fish habitat assessment efforts on Cascade Creek and Little Cascade Creek. PSCo will also conduct streamflow and hydrograph assessments on the Animas River in the vicinity of the Tacoma powerhouse. Terrestrial species in the Project area are addressed through a habitat mapping and evaluation effort, as well as assessments of riparian


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and wetland habitats. In addition to these relicensing studies, PSCo will conduct directed habitat assessments and survey efforts in areas potentially affected by PM&E efforts or potential changes to Project operations. For all studies involving listed species, PSCo will solicit input from the USFS and USFWS as to final study methods. Following the completion of relevant studies, PSCo will consolidate existing information, study results, agency input, scientific literature, and other relevant sources in preparation of a draft BA for the Tacoma Project. PSCo plans to work cooperatively with the USFWS and the USFS to review the BA prior to its formal submission. PSCo’s BA will include, at a minimum, the following components: (1) Statement of the species under consideration; (2) Description of the proposed action and action area; (3) Species accounts and status within the action area (including habitats); (4) Analyses of effects (direct and indirect) of the proposed action, including prior studies; (5) Analysis of cumulative effects of future actions in the action area; (6) Analysis of the alternate actions considered; (7) Conclusions, stated as determinations of effect (e.g., no effect, not likely to adversely affect), along with the summarized rationale that leads to them. 5.5 Schedule, Duration, and Level of Effort (18 CFR 5.9(b)(7)) Field studies and analyses in support of this work will be conducted in the summer and fall of 2006 are described in other Study Plans in this submittal. Informal consultation with the USFWS is expected to be an on-going process. The BA will be prepared concurrently with PSCo’s draft application for a new license. 5.6 Discussion of Alternative Approaches (18 CFR 5.9(b)(7)) The USFWS appears to suggest that water depletion and flow regime assessments be completed by PSCo without regard to prior studies already conducted by others, and already made part of the San Juan River Basin RIP. PSCo believes this would be an unnecessary and wasteful expense and, more importantly, counter to the agreed-upon terms of the RIP wherein all active projects in the Animas River basin prior to 1992 have already been adequately accounted for within the RPA. 5.8 Data Analysis and Reporting Data analyses will be conducted as described in individual study plans for the various study efforts. Reporting for this effort will consist of a BA as outlined above. 6.0 References San Juan River Basin Recovery Implementation Program. Program Highlights, 2004-2005. www.mountain-prairie.fws.gov/ea/infopackets.


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USDA Forest Service. 1992. Amended Land and Resource Management Plan for the San Juan National Forest, Rocky Mountain Region. Durango, CO. USFWS. 2005. Letter by the USFWS in response to the January 24, 2005 inquiry by the

licensee requesting a list of threatened and endangered species for the Tacoma-Ames Hydroelectric Project (FERC Project No. 400).

TERRESTRIAL RESOURCES STUDY PLANS

Tacoma Hydroelectric Project Fuels Management Terrestrial RWG Issue No. 1

1 November 1, 2005



TERRESTRIAL RESOURCE WORK GROUP

Issue Assessment No. 1 and Study Plan Fuels Management

1.0 Description of Issue (18 CFR 5.9(b)(1)) Fuels management in the vicinity of the Tacoma Project has been identified as an issue. In many parts of southwestern Colorado, years of fire suppression in disturbance-dependent forests have resulted in high fuel loads that can increase the frequency and intensity of wildfire. In response, the U.S. Forest Service (USFS), Bureau of Land Management (BLM), and other land management agencies have coordinated their efforts under the auspices of the National Fire Plan to fund fire management at the wildland-urban interface, reduce fuel loads through forest management (which could include prescribed fire or mechanical treatments), and conduct other associated activities (Robison and Wilson 2003). There is a need to conduct fuels reduction activities within the Project Boundary. These activities need to be coordinated with local projects such as the Electra Sporting Club Fuels Reduction Project and the United States Forest Service Electra Lake Fuels Reduction Project (ELFRP), with the overall goal of enhancing the ecological integrity of forest resources and protection of existing and future residences, project facilities and structures. Fuels reduction topics addressed during the Tacoma relicensing will be led by the Recreation Land Use & Aesthetics Resource Work Group, working in consultation with the Terrestrial Resource Work Group (RWG). 2.0 Project Effects (18 CFR 5.9(b)(5)) The Tacoma Project is located within and adjacent to public lands administered by the USFS. The USFS is undertaking a program of fuels management in the immediate vicinity of the Project. It is recognized that high fuel loads are the result of ecological processes and forest management decisions unrelated to Project operations. However, land management activities within the Project Boundary could substantially affect the overall success of forest management activities on adjacent lands, as well as potentially impact Project facilities and structures and other beneficial uses of the Project area. As a result, a study of the need for a fuels reduction program within the Project Boundary is warranted. 3.0 Relevant Existing Information (18 CFR 5.9(b)(4)) General information regarding fuels management needs and goals in Colorado is widely available (e.g., Robison and Wilson 2003). In addition, the USFS Columbine Ranger District and San Juan Public Lands Center has prepared documentation for the Electra Lake Fuels Reduction Project (ELFRP), which would thin or mow approximately 890 acres of USFS managed lands near Electra and Haviland Lakes. The preliminary list of issues addressed by USFS related to the proposed ELFRP includes (1) access to U.S. Highway 550, (2) impacts to


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recreational use and visual corridors, and (3) the introduction and spread of noxious weeds (Ellis 2004). Biological Assessments (BA) and Biological Evaluations (BE) have been completed. The USFS’ ELFRP has been approved for implementation. An Environmental Impact Statement is presently underway for the proposed expansion of the Durango Mountain Resort. 4.0 Need for Additional Information (18 CFR 5.9(b)(4)) Assessment of fuels loading has not been performed within the Project Boundary. Such an assessment is warranted given the proximity of public lands requiring fuels management. In addition, coordination between the USFS, the Electra Sporting Club (ESC), and PSCo is needed to meet resource management goals on federal lands managed by the USFS adjacent to the Project. 5.0 Final Study Plan 5.1 Purpose of Study and Use of Study Results (18 CFR 5.9(b)(1) & 5.9(b)(5) in part) The goals of this effort are (1) to solicit the participation and advice of USFS and Colorado State Forest Service experts in assessing lands within the Project Boundary from a fuels management perspective, and (2) to coordinate with appropriate USFS personnel to ensure that the USFS and ESC have access to lands proposed for their fuels management activities. 5.2 Relevant Resource Management Goals (18 CFR 5.9(b)(2)) Management goals relevant to Project lands which occupy National Forest System lands are described in the current forest management plan for the San Juan National Forest, including the Amended Land and Resource Management Plan (USFS 1992). Specific direction includes:

Forest-Wide Direction

Fuel Treatment (01). Maintain fuel conditions which permit fire suppression forces to meet fire protection objectives for the area (page III-83).

a. Reduce or otherwise treat all fuels so the potential fireline intensity of an area will not exceed 400 BTU/sec/ft on 90% of the days during the regular fire season, or break up continuous fuel concentrations exceeding the above standard into manageable units with fuel breaks or fire lanes, or provide additional protection for areas exceeding the above standard when such protection will not be required for more than five years (page III-83).

Vegetation Treated by Burning (01). Use prescribed fire to accomplish resource management objectives, such as reducing fuel load buildup, wildlife habitat improvement, etc (page III-84).


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Vegetation Treated by Burning (02). Limit use of prescribed fires on areas adjacent to riparian areas to protect riparian and aquatic values (page III-84).

Management-Area Direction/Rural and Roaded-Natural Recreation (2B) Fuel Treatment (01). Maintain fuel conditions which permit fire suppression forces to meet fire protection objectives for the area (III-129).

a. Reduce or otherwise treat all fuels on areas where wildfires are likely to threaten lives or property so the potential fireline intensity of an area will not exceed 100 BTU’s/sec/ft (Burning Index 38) on 90% of the days during the regular fire season, or break up continuous fuel concentrations exceeding the above standards into manageable units with fuel breaks or fire lanes (III-129).

5.3 Relevant Public Interest Considerations (18 CFR 5.9(b)(3)) The Terrestrial RWG, which is comprised of public agencies, private entities, and other interested parties, has identified this issue as being of substantial public interest, affecting resources such as timber and wildlife. Fuels reduction may be warranted within the Project Boundary, and coordination between existing fuels reduction programs is needed. 5.4 Study Methodology (18 CFR 5.9(b)(6)) PSCo will undertake a review of its lands for the purpose of assessing the need for and the cost of implementing fuels reduction. PSCo will seek the active involvement of experts within the USFS and the Colorado State Forest Service experienced with fuels management issues and field indicators of fuels loading. The study area includes lands in the Project Boundary adjacent to Electra Lake and along access roads used primarily for Project purposes. Field investigations will be conducted during which these agency experts, PSCo staff, and other knowledgeable parties will tour lands within the Project Boundary. For each major land parcel or habitat type within the Project Boundary, the field team will describe current conditions and make recommendations for potential fuels management projects. Each recommendation will include a justification/statement of need, as well as a prioritization relative to other lands within the Project Boundary. PSCo will evaluate the cost of implementing any recommended fuels reduction efforts including the cost of environmental impact assessment, before adopting any specific Fuels Reduction Treatment Plan. The USFS’ Electra Lake Fuels Reduction Project is recognized as an important resource goal for the USFS in the Project vicinity. PSCo expects to provide coordination and cooperation (e.g., access to Tacoma Project access roads) as needed by the USFS to implement the ELFRP. 5.5 Schedule The study will be conducted during the summer of 2006. A draft report will be issued no later than six months after field efforts are completed.


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5.6 Level of Effort (18 CFR 5.9(b)(7)) Initial field investigations with agency personnel are estimated to require approximately 60 hours of effort. The level of additional effort required for this study will be determined after reviewing field findings and any specific recommendations of agency experts. 5.7 Discussion of Alternative Approaches (18 CFR 5.9(b)(7)) There have been no alternative approaches proposed at this time. 5.8 Data Analysis and Reporting Reporting for this study will be descriptive; no quantitative analyses are proposed. Tabular and text summaries of study results will be prepared for lands within the Project Boundary in the Electra Lake area. Findings from this study, including any implementation plan, will be integrated into the Final License Application for the Tacoma Project. Environmental surveys associated with any Fuels Reduction Treatment Plan to be proposed in the license application will be conducted prior to the submittal of the Final License Application. 6.0 References Ellis, P. 2004. Letter dated August 5, 2004 describing public scoping for the Electra Lake Fuels Reduction Project. US Forest Service Columbine Ranger District and San Juan Public Lands Center, Bayfield Colorado. Robison, L, and P. Wilson. 2003. Making southwest Colorado a safer place to live. Pages 1-2 in: Wilson, P (editor). Fire and fuels in southwest Colorado. Online document: http://www.southwestcoloradofires.org/default.asp. Accessed December 2004. USDA Forest Service. 1992. Amended Land and Resource Management Plan for the San Juan National Forest, Rocky Mountain Region. Durango, CO.

Tacoma Hydroelectric Project Occurrence, Distribution and Abundance of Amphibians Terrestrial RWG Issue No. 2

1 November 1, 2005




Issue Assessment No. 2 and Study Plan Occurrence, Distribution and Abundance of Amphibians at the Tacoma Project

1.0 Description of Issue (18 CFR 5.9(b)(1)) The occurrence, distribution, and/or abundance of amphibians in the immediate vicinity of the Tacoma Project have been identified as questions. Amphibians are an important component of many terrestrial systems and include numerous special-status species tracked by the U.S. Forest Service (USFS), U.S. Fish and Wildlife Service (USFWS), and Colorado Natural Heritage Program (CNHP). The occurrence of some amphibians in the Project is well known and documented to occur; however, there is minimal information on their distribution and abundance. Any potential future ground-disturbing activities may impact amphibians. 2.0 Project Effects (18 CFR 5.9(b)(5)) All the amphibians that might occur in the Project area are aquatic-breeding species and some could potentially breed in Electra Lake or other seasonally or permanently flooded aquatic habitats associated with the Project. Public Service Company of Colorado (PSCo) is proposing to continue to operate the Tacoma Project under the next license term in the same manner as it is currently operated; that is, there are no changes in Project operations currently planned that would result in ground-disturbing activities. Installation of the fourth unit at the Tacoma powerhouse will result in ground disturbance over a 100-foot long area extending from the end of the blind flange at the Penstock No. 1 bifurcation to the powerhouse in an area that is primarily within the current switchyard fence. There is currently no indication or documentation of adverse effects to amphibian populations as a result of existing Project operations. Therefore, there is no reasonable basis for attributing to the Project impacts to amphibian populations within the Project Boundary or associated with Project operations. There are wetland complexes and water bodies associated with the Project that are likely to support amphibian populations, including the Columbine Lake area, the Aspaas Lake area, and Elbert Creek downstream of Terminal dam. These areas may represent opportunities for enhancement of existing populations and/or opportunities for resource protection intended to preserve or improve current amphibian populations. Amphibians within the Project’s terrestrial habitats could potentially be affected by Project-related activities (e.g., vegetation clearing). Issue Assessment No. 1, Fuels Management, includes an assessment of potential fuels management activities that may be warranted to support USFS fuels management efforts. To the extent that specific fuels management activities are


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identified, the potential for these activities to affect existing amphibian populations will be evaluated. 3.0 Relevant Existing Information (18 CFR 5.9(b)(4)) Amphibian species known or possibly occurring in the vicinity of the Project are limited to five wide-ranging native species: tiger salamander (Ambystoma tigrinum), boreal toad (Bufo boreas), Woodhouse toad (Bufo woodhousii), boreal chorus frog (Pseudacris maculata), and northern leopard frog (Rana pipiens) (Schrupp et al. 2000) (Table 1). Bullfrog (Rana catesbeiana) has been introduced to Colorado and could potentially occur in permanent ponds or lakes associated with the Project. Bullfrogs are found in aquatic habitats during all life stages and are easily documented by their loud vocalizations. Amphibian site records for the Project vicinity are scarce. Juvenile northern leopard frogs have been found at Rainbow Lake (just south of Electra Lake) (Japhet 1999) and at a beaver pond 0.5 miles NW of Forebay Lake, where a tiger salamander was also found (Japhet 1997). Juvenile northern leopard frogs were also found at sites mentioned above as well as Forebay Lake by Forest Service biologists in 2004 (personal communication. Chris Schultz, San Juan National Forest, Columbine Ranger District and BLM Field Office Wildlife Biologist). Amphibian surveys for the proposed expansion of the Durango Mountain Resort in the vicinity of the Cascade flowline indicated the presence of tiger salamanders at seven of twelve wetland sites that were considered suitable for amphibians (Ecosphere Environmental Services 2000). Table 1. Amphibian species known to occur or potentially occurring in the vicinity of the Tacoma Project Species Breeding Habitats and Known Occurrences Tiger salamander Ambystoma tigrinum

Various habitats, including seasonal to permanent ponds, lakes, stock ponds, and farm ponds. Documented occurrences in project vicinity.

Boreal toad Bufo boreas1

Small pools, ponds, bogs, marshes, and the shallow margins of lakes; rarely breeds in streams.

Woodhouse toad Bufo woodhousii

Various shallow, quiet waters including ponds, lakes, reservoirs, marshes, river backwaters and floodwater pools, low gradient streams, and irrigation ditches.

Boreal chorus frog Pseudacris maculata

Seasonal pools, marshy ponds, and cattail swamps; not found where predatory fish occur.

Northern leopard frog Rana pipiens

Ponds (including glacial kettles and beaver ponds), marshes, lakes, reservoirs, stream backwaters, and irrigation ditches. Documented occurrences in project vicinity.

1Southern Rocky Mountain Population Because breeding habitats of the target species are known to be diverse, criteria for amphibian habitat suitability can only be broadly defined. Larvae of all of the target species are adapted for lentic (i.e., still or slow-moving water) habitats; fast-flowing streams are not breeding habitat for these species. Water must persist, uninterrupted, for a period sufficient for larvae to complete development (for boreal toad this period can sometimes be as brief as 45 days, but in most cases a longer period is required [Loeffler 2001]); thus, wetlands described by the National Wetland Inventory (NWI) as “seasonally saturated” (USFWS 1998) are unlikely to constitute breeding habitat, unless areas of standing water also occur. The presence of shallow water exposed to direct sunlight is frequently an attribute of occupied habitat (shallow, warmer water accelerates embryonic and larval development, and may also constitute a refuge from larger, aquatic


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predators). The presence of predatory fish tends to reduce habitat suitability, although not for toads (Loeffler 2001). Boreal toad (Southern Rocky Mountain Population) is a federal candidate species for listing under the Endangered Species Act (listing “warranted but precluded”) not documented to occur in San Juan or LaPlata counties, but considered possible in suitable areas (usually above 8,500 ft elevation). A variety of federal and state agencies, including USFWS, USFS, U.S. Bureau of Land Management (USBLM), and Colorado Division of Wildlife (CDOW) are represented on the Boreal Toad Recovery Team, and participate in survey, monitoring, and research activities for the conservation of the boreal toad. Survey protocols for boreal toad have been developed and are recommended for use in determining the presence of the species (Loeffler 2001). 4.0 Need for Additional Information (18 CFR 5.9(b)(4)) Additional information concerning the distribution of amphibian populations and suitability of existing wetland habitats for amphibians is needed to supplement existing information and to identify potential opportunities for enhancement and/or resource protection on Project lands. In the event that ground-disturbing activities are proposed (e.g., vegetation or fuels management, or new recreational developments), site-specific information on amphibian occurrence may be required in order to evaluate the effects of proposed activities. 5.0 Final Study Plan 5.1 Purpose of Study and Use of Study Results (18 CFR 5.9(b)(1) & 5.9(b)(5) in part) The purpose of the study is to provide baseline information on the suitability of existing wetland habitats for amphibians in the Project area. The proposed study will focus on an inventory of habitats within and immediately adjacent to the Project Boundary, but information on the occurrence of amphibian species will only be collected incidentally. For sites where ground-disturbing activities (including fuels management work) are proposed by PSCo, the potential for effects to amphibians will be assessed; if potential boreal toad breeding habitat is jeopardized by these activities, a protocol-level boreal toad survey will be conducted. The amphibian study will support and be integrated with the wetland/riparian assessment to be conducted in accordance with Terrestrial RWG Issue Assessment No. 7, Wetland and Riparian Habitats. 5.2 Relevant Resource Management Goals or Public Interest Considerations (18 CFR

5.9(b)(2) & 18 CFR 5.9(b)(3)) Management goals and objectives for wildlife species on National Forest System lands administered by the USDA Forest Service are derived from the Forest Plan (USFS 1992). The Forest Plan is developed from a variety of sources, including the National Forest Management Act, as amended; the Endangered Species Act of 1974; as amended, the Forest Service Manual (FSM); and local forest planning documents, including the Amended Land and Resource Management Plan for the San Juan National Forest. The FSM requires review of projects that may affect species listed as Sensitive, such as boreal toad, and preparation of a Biological Evaluation (BE) to ensure that activities do not increase the likelihood of a future listing under


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the Endangered Species Act. In general, if a proposed activity will adversely affect boreal toad habitat, resource agencies may recommend surveys to obtain site-specific information on occurrence (presence) and habitat suitability, and seek to minimize adverse effects. As related to USFS-administered lands, specific LRMP direction includes:



Riparian Area Management (02). Design and implement activities in management areas to protect and manage the riparian ecosystem (page III-46).

5.3 Study Methodology (18 CFR 5.9(b)(6)) A wetland inventory and habitat evaluation will be conducted for all wetlands within the Project Boundary as described in Terrestrial RWG Issue Assessment No. 7. Amphibian habitat suitability will be evaluated based on hydrologic characteristics (e.g., estimated duration of inundation, maximum water depth, near-shore water depth), the presence of aquatic and/or emergent vegetation, and the presence of fish. Site conditions will be documented with a pedestrian, reconnaissance-level survey, during which sites will be photographed and incidental observations of amphibians will be noted. If habitat meets the definition of suitability for Southwestern Willow Flycatcher, this will be noted as well. Opportunistic searches for amphibians will also be conducted at selected sites to confirm conclusions concerning habitat suitability. Amphibian search methods will consist of commonly accepted techniques described in Olson et al. (1997). These may include the use of dip-net or aquatic funnel traps to document larval amphibians (Thoms et al. 1997), visual encounter (Crump & Scott 1994), or cover object searches. Site-specific habitat evaluations for amphibians will be conducted for any ground-disturbing activity (including vegetation and fuels management work) that PSCo may propose. Proposed activities will be screened for potential affects on amphibians based on the likelihood that the activity could adversely affect an amphibian breeding habitat. Existing information (including information collected as described above) will be used to assess known or likely amphibian occurrences, with supplemental surveys where warranted. If proposed activities are deemed likely to adversely affect amphibian breeding habitat, protocol-level surveys for boreal toad (Loeffler 2001) will be conducted. These surveys would consist of daytime searches of potential breeding sites on multiple dates; the survey techniques are also likely to document other species of amphibians that may occur. Biologists engaged in surveys will follow precautionary measures outlined by the Declining Amphibian Population Task Force for cleaning field equipment and boots to avoid the spread of pathogens between sites (Loeffler 2001).


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5.4 Schedule and Level of Effort (18 CFR 5.9(b)(7)) Field work for wetland habitat evaluations will be conducted in July 2006. Because larvae of the target species are typically present at wetland sites for a longer period than other life stages (adult, eggs, or post-metamorphosed juvenile), the field schedule may be adjusted to maximize the likelihood of documenting amphibians incidentally or with opportunistic sampling of larvae at selected, representative sites. Habitat evaluations and surveys to assess effects of new ground-disturbing activities on amphibians will be conducted in the event that such activities are proposed. Amphibian habitat assessment efforts are incorporated into estimates of effort for Issue Assessment No. 7, Wetland & Riparian Habitats. The level of effort required for additional, site-specific assessments or surveys is a function of the scale of proposed actions, if any. This could range from one hour (for a Project change with no effects on amphibian habitats) to over 120 hours (for a larger Project change requiring field efforts or agency consultation). 5.5 Discussion of Alternative Approaches (18 CFR 5.9(b)(7)) No alternative approaches have been proposed at this time. 5.6 Data Analysis and Reporting

The habitat data collected for this Study Plan will be summarized and compared to known habitat criteria for the target species, and documented amphibian occurrences at similar sites. If site-specific ground-disturbing activities are proposed by PSCo, the results of habitat evaluations and amphibian surveys will also be presented. The study report will include descriptions, habitat data summaries, and photographs of each site, as well as documentation of amphibians found and conclusions regarding habitat suitability for species not documented. The draft report will be prepared for review and the final report will be incorporated in the Tacoma Project Final License Application. The report will include study objectives, study area, methods, tabulated results, maps of sites, and an assessment of opportunities to enhance and/or protect amphibians within the Project Boundary.

6.0 References

Crump, N. L and N. J. Scott, Jr. 1994. Visual encounter surveys. pp. 84-92 In: W.R. Heyer, M.A. Donnelly, R.W. McDiarmid, L.C. Hayek, and M.S. Foster (editors). Measuring and Monitoring Biological Diversity, Standard Methods for Amphibians. Smithsonian Institution Press, Washington. 364 pp.

Ecosphere Environmental Services. 2000. Amphibian survey report for the Durango Mountain Resort proposed expansion. 11 pp.


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Fellers, G.M. 1997. Design of amphibian surveys. pp. 23-34 In: Olson, D.H., W.P. Leonard, and R.B. Bury (editors). Sampling amphibians in lentic habitats. Society for Northwestern Vertebrate Biology, Northwest Fauna (4). Heyer, W. R., M. A. Donnelly, R. W. McDiarmid, L. C. Hayek, and M. S. Foster (eds.) 1994. Measuring and monitoring biological diversity: Standard methods for amphibians. Smithsonian Institution Press, Washington, D.C. 364 pp. Japhet, M. 1997. Amphibian survey at Forebay Lake and vicinity. Copy of Amphibian survey

data sheet dated 6/2/1997. Japhet, M. 1999. Amphibian survey at Rainbow Lake and vicinity. Copy of Amphibian survey

data sheet dated 7/2/1999. Loeffler, C. (editor). 2001. Conservation plan and agreement for the management and recovery of the southern Rocky Mountain population of the boreal toad (Bufo boreas boreas), Boreal Toad Recovery Team. 76 pp. + appendices.

Olson, D.H. and W.P. Leonard. 1997. Amphibian inventory and monitoring: a standardized approach for the PNW. pp. 1-21 In: Olson, D.H., W.P. Leonard, and R.B. Bury (editors). Sampling amphibians in lentic habitats. Society for Northwestern Vertebrate Biology, Northwest Fauna (4).

Olson, D.H., W.P. Leonard, and R.B. Bury (editors). 1997. Sampling amphibians in lentic habitats. Society for Northwestern Vertebrate Biology, Northwest Fauna (4). Schrupp, D.L., W.A. Reiners, T.G. Thompson, L.E. O’Brien, J.A. Kindler, M.B. Wunder, J.F Lowsky, J.C. Bouy, L. Satcowitz, A.L. Cade, J.D. Stark, K.L. Driese, T.W. Owens, S.J. Russo, and F. D’Erchia. 2000. Colorado Gap Analysis Program: A Geographic Approach to Planning for Biological Diversity – Final Report, USGS Biological Research Division, Gap Analysis Program and Colorado Division of Wildlife, Denver, Colorado.

Thoms, C., C. C, Corkran, and D. H. Olson. 1997. Basic amphibian survey for inventory and monitoring in lentic habitats. pp 35-46 In: Olson, D.H., W.P. Leonard, and R.B. Bury (editors). Sampling amphibians in lentic habitats. Society for Northwestern Vertebrate Biology, Northwest Fauna (4).

USDA Forest Service. 1992. Amended Land and Resource Management Plan for the San Juan National Forest, Rocky Mountain Region. Durango, CO.

U.S. Fish and Wildlife service (USFWS). 1998. National Wetland Inventory maps for Engineer Mountain and Electra Lake quadrangles.

Tacoma Hydroelectric Project Special-Status Species and Habitats Terrestrial RWG Issue No. 3

1 November 1, 2005


FERC NO. 12589 TERRESTRIAL RESOURCE WORK GROUP


Special-Status Species and Habitats 1.0 Description of Issue (18 CFR 5.9(b)(1)) The occurrence and distribution of special-status species and habitats in the immediate vicinity of the Tacoma Project has been identified as a potential issue. Categories defined as “special-status” include ESA-listed (endangered, threatened, and candidate) taxa, USFS/BLM sensitive and management indicator species (MIS), and all categories currently tracked by the Colorado Natural Heritage Program (CNHP), including plants, birds, mammals, fish, invertebrates, and natural communities. The Terrestrial Resources Work Group (Terrestrial RWG) issue related to special-status species includes the potential adverse affects associated with future ground-disturbing Project activities and the uncertainty of the species existence in the Project area. Although the USFS has indicated it will use FERC’s NEPA review as the basis for its assessment of the Tacoma Project, analyses of special-status species and habitats should be consistent with USFS, NEPA, and NFMA processes and standards. USFS indicates that general inventories of management indicator species may be needed to fulfill the requirements of NFMA. The standard for determining the need for on-the-ground studies consist of (1) defining the proposed action and (2) evaluating the potential for impact, and (3) tailoring any studies to the scope of potential impacts. 2.0 Project Effects (18 CFR 5.9(b)(5)) Public Service Company of Colorado (PSCo) is not proposing any changes in Project operations that are expected to result in ground-disturbing activities. There is currently no indication or documentation of adverse affects to terrestrial special status species and habitats as a result of existing Project operations. Therefore, there is no reasonable basis for attributing to the Project impacts to terrestrial special status species and habitats within the Project Boundary or associated with Project operations. Potential Project effects on special-status species and habitats could, as a result of relicensing outcomes, be associated with changes to instream flow levels below the Cascade Creek diversion, changes to the normal operations of Electra Lake, or management of flowline/penstocks and other terrestrial areas of the Project. The scope of any potential effects would be expected to be in proportion to the reliance of the individual species on a given habitat and the degree to which such habitats would change. Previous studies of the Project’s relationship to, or impacts upon, special-status species or habitats do not exist; nor is there any evidence of the effect of the Project on such species or habitats. However, it is understood that portions of the Project (e.g. Electra Lake, Little Cascade


2 November 1, 2005

Creek) include areas of relatively unique habitats that may be expected to support sensitive species. In addition, PSCo intends to identify occurrences of special status species that are potentially affected by any new ground disturbing activities associated with the Project (e.g., vegetation management or fuels management efforts). The evaluation of potential Project effects on fish will be covered in the Water RWG. The evaluation of potential Project effects on amphibians will be covered in the Terrestrial RWG Issue Assessment No. 2. 3.0 Relevant Existing Information (18 CFR 5.9(b)(4)) Numerous special-status species potentially occur in the Project area; however, most of the Project area has not been surveyed specifically for special-status species and few occurrences have been documented. Bald eagle is the only federally threatened or endangered species documented to occur at the Project, with intermittent breeding records at Electra Lake since 1974. Other special-status animal species documented in the Project vicinity are northern leopard frog (Rana pipiens) (USFS sensitive and Colorado species of concern), peregrine falcon (Falco peregrinus) (USFS sensitive species and Colorado species of concern)), and American three-toed woodpecker (Picoides tridactylus) (USFS sensitive species) (Japhet 1997, CNHP 2005). No federally listed endangered or threatened plant species are known to occur in the Project vicinity, and occurrence is unlikely (USFWS 2005). However, numerous plant taxa categorized as sensitive by USFS and/or BLM, or tracked by CNHP potentially occur. CNHP (2005) records indicate the documented occurrence of six of these species within or near the Project area at about the same elevation: American spikenard (Aralia racemosa), Canadian single-spike sedge (Carex scirpoidea), green sedge (Carex viridula), American yellow lady’s-slipper (Cypripedium calceolus spp. parviflorum), variegated scouring rush (Hippochaete [Equisetum] variegata), and New Mexico cliff fern (Woodsia neomexicana). One of the goals of managing National Forest System lands is to provide for healthy ecosystems capable of sustaining viable populations of all native and desired non-native wildlife species, consistent with the overall multiple-use objectives stated in each National Forest’s Land and Resource Management Plan (Forest Plan) (36 CFR 291.27-Planning, Management Requirements). It would not be practical to simultaneously evaluate the status of all native and desired non-native species that occur on a National Forest administrative unit as well as monitoring their trends over time. Therefore, a smaller subset of species is selected to represent larger groups of species which have similar habitat needs or similar population characteristics and whose populations can be monitored. This subset is collectively referred to as Management Indicator Species (MIS). MIS are species whose population changes are believed to indicate the effects of management activities on other species of selected major biological communities, or on water quality, and whose population changes are believed to indicate the effects of management activities on wildlife populations as a whole (36 CFR 219.19(a)(1)). The San Juan National Forest (SJNF) MIS list includes some uncommon species found on other special-status species lists. However, most of the species are common and are not tracked by occurrence by the agencies or CNHP.


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4.0 Need for Additional Information (18 CFR 5.9(b)(4)) Additional site-specific information is necessary to evaluate the effects of vegetation management on special status species and communities. In the event that any new ground-disturbing activities are proposed (e.g., fuels management or new recreational developments), additional information to evaluate the effects of those activities may also be required when existing site-specific information on the condition of habitats and the occurrence of special-status species is lacking or out-of-date. Evaluations of proposed ground-disturbing activities would address habitat suitability for special-status species, the scope of the proposed activity, and the degree to which special-status species rely on habitats affected by the proposed activity. The need for additional site-specific information will be contingent on the potential for significant adverse effects to special-status species and habitats. 5.0 Final Study Plan 5.1 Purpose of Study and Use of Study Results (18 CFR 5.9(b)(1) & 5.9(b)(5) in part) The purpose of the study is to assess the potential for effects to special-status species and habitats based on known occurrences or the likelihood of occurrence, and the scope of the activity. Assessments may include field evaluations of habitat suitability and surveys for species that could be affected by ground-disturbing activities. Study results will be used in review of ongoing vegetation management and any proposed ground-disturbing activities. A separate assessment of the effects of the Project on federally listed (i.e. under the ESA) species will be prepared for Tacoma Water RWG Issue Assessment No. 14. Results of this study may inform such an assessment. 5.2 Relevant Resource Management Goals and Public Interest Considerations (18 CFR

5.9(b)(2) and (18 CFR 5.9(b)(3)) Management goals and objectives for public lands administered by the USFS are derived from the Forest Plan (USFS 1992), itself developed from a variety of sources, including the National Forest Management Act (NFMA), as amended; the Endangered Species Act of 1974, as amended; the Forest Service Manual (FSM); and local forest planning documents, including the Amended Land and Resource Management Plan for the San Juan National Forest. The NFMA includes direction to preserve and enhance the diversity of plant and animal communities, including endemic and desirable naturalized plant and animal species, so that their diversity is at least as great as that which would be expected in a natural forest (36 CFR § 219.26 and § 219.27). In addition, the NFMA requires the maintenance of plant and animal diversity commensurate with the overall multiple-use objectives of the USFS. The FSM requires review of projects that may affect species listed as Sensitive, and preparation of a Biological Evaluation (BE) to ensure that activities do not increase the likelihood of future Endangered Species listing. The 1983/1992 SJNF Forest Plan identifies MIS and contains management goals, objectives, standards and guidelines, and monitoring requirements that are specific to MIS.


4 November 1, 2005

Related to public lands administered by the USFS, specific LRMP direction for special-status species includes: Forest-Wide Direction

Wildlife and Fish Resource Management (01). Where present, the following species are Management Indicator Species: deer, elk, and all Federally-listed endangered or threatened plant and animal species (page III-26).

The USDA Forest Service also has specific policy direction regarding sensitive species (USDA Forest Service Manual 2670.22), including:

• Develop and implement management practices to ensure that species do not become threatened or endangered.

• Maintain viable populations of all native and desired nonnative wildlife, fish, and plant species in habitats distributed throughout their geographic range.

• Develop and implement management objectives for populations and/or habitat of sensitive species (USDA Forest Service Manual 2670.22).

• Assist States in achieving their goals for conservation of endemic species. • As part of the National Environmental Policy Act process, review programs and activities,

through a biological evaluation, to determine their potential effect on sensitive species. • Avoid or minimize impacts to species whose viability has been identified as a concern. • If impacts cannot be avoided, analyze the significance of potential adverse effects on the

population or its habitat within the area of concern and on the species as a whole. • Establish management objectives in cooperation with the States when projects on National

Forest System lands may have a significant effect on sensitive species population numbers or distributions. Establish objectives for Federal candidate species, in cooperation with the FWS or NMFS and the States (USDA Forest Service Manual 2670.32).

In addition, the USFWS is required under the authority of the Endangered Species Act to review and provide comment on federally authorized projects that may affect listed or proposed species. USFWS, BLM, and USFS are signatories of the Lynx Conservation Agreement and Strategy (http://fsweb.r2.fs.fed.us/rr/tes/tes_listed spp.html) which outlines management goals, objectives, and strategies for lynx conservation. The USFWS Recovery Plan for the Southwestern Willow Flycatcher (http://ecos.fws.gov/docs/recovery_plans/2002/020830c_combined.pdf) is required to be implemented within existing laws and policy. 5.3 Study Methodology (18 CFR 5.9(b)(6)) All areas within the Project Boundary that are subject to ground-disturbing activities related to Project operations or maintenance will be surveyed for special-status plants and habitats and assessed for their potential to support special-status wildlife. Special-status species and habitats are defined as those listed by the CNHP, USFWS, USFS, and/or BLM. USFS MIS taxa not included on other lists will be considered common and not addressed by this study. Project-related ground-disturbing activities are currently restricted to areas subject to periodic vegetation


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management, e.g., penstock corridors; additional areas will be surveyed in the event new ground-disturbing activities are proposed. Botanical survey methods will follow guidelines established by the Washington Natural Heritage Program (WNHP 2005). (The CNHP has not yet developed survey guidelines, and endorses those of the WNHP [personal communication, Dave Anderson, CNHP Botany Team Leader, June 2005]). Surveys will be conducted by individuals with: (1) experience conducting floristic field surveys; (2) knowledge of plant taxonomy and plant community ecology and classification; (3) familiarity with the plants of the area; (4) familiarity with appropriate state and federal statutes related to plants and plant collecting; and (5) experience with analyzing impacts to plants and plant communities. Surveys will be floristic in nature and conducted during the time of year when these taxa are most easily identified (i.e., when any plants present should possess features, such as flowers or fruit, required for identification). Each study area will be surveyed two times in order to locate all potential special-status plant species during appropriate phenological periods and prepare an accurate inventory. Wildlife assessments will review the habitats present in the area subject to ground disturbance in relation to species distributions, habitat requirements and life history information. This information will be used to assess (1) the availability of appropriate habitat within the proposed or current activity area and (2) the potential for each species to be affected by the proposed or current activity. Wildlife assessments will be conducted by individuals with: (1) experience conducting wildlife field surveys; (2) knowledge of wildlife taxonomy and wildlife community ecology and classification; (3) familiarity with the wildlife of the area; (4) familiarity with appropriate state and federal statutes related to wildlife; and (5) experience with analyzing impacts to wildlife and wildlife communities. No directed field surveys are proposed. If special status species or habitats are documented or likely to occur in the study area, Project effects on each will be assessed with consideration of the size of the affected area, the timing and duration of disturbance, the type of activity, the reliance of the individual species on a given habitat and the degree to which such habitats are disturbed or otherwise affected. If warranted, these considerations will be incorporated into management or mitigation efforts developed in consultation with the resource agencies. 5.4 Schedule The study will be initiated in late 2005, and field studies to address this issue will be conducted in spring and summer of 2006. A draft report will be issued no later than six months after field efforts are completed. 5.5 Level of Effort (18 CFR 5.9(b)(7)) Initial field studies for this study are estimated to require approximately 50 hours of effort, not including report requirements. The level of effort required to evaluate future areas of ground disturbance will be evaluated at the time such activities are proposed.


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5.6 Discussion of Alternative Approaches (18 CFR 5.9(b)(7)) No alternative approaches have been proposed. 5.7 Data Analysis and Reporting Reporting for this study will be descriptive; no quantitative analyses are proposed. Study reporting will be incorporated into the Tacoma Project license application, and will include study objectives, study area, methods, survey results, assessment of Project-effects on special-status species and habitats, and recommendations for resource measures, if warranted. The report will also include species summaries (e.g., life history, habitat requirements, current status and threats) for special-status species actually documented to occur within the study area. 6.0 References Colorado Natural Heritage Program (CNHP). 2005. Locations and status of rare and/or imperiled species and natural communities known from or likely to occur within the general vicinity of the project area. Colorado State University, Fort Collins, Colorado. Report Generated 2 March 2005. Japhet, M. 1997. Amphibian survey at Forebay Lake and vicinity. Copy of amphibian survey data sheet dated 6/2/1997. USDA Forest Service. 1992. Amended Land and Resource Management Plan for the San Juan National Forest, Rocky Mountain Region. Durango, CO. US Fish and Wildlife Service (USFWS). 2005. Letter by the USFWS in response to the January 24, 2005 inquiry by the licensee requesting a list of threatened and endangered species for the Tacoma-Ames Hydroelectric Project.

Tacoma Hydroelectric Project Invasive Plant Species Terrestrial RWG Issue No. 4

1 November 1, 2005




Issue Assessment No. 4 and Study Plan Invasive Plant Species

1.0 Description of Issue (18 CFR 5.9(b)(1)) The occurrence and distribution of invasive species in the immediate vicinity of the Tacoma Project has been observed as being an issue. Invasive species can affect terrestrial, aquatic, recreational, and other resources by displacing native species, changing ecosystem processes, and undermining aesthetic values. Invasive species potentially occurring in the Tacoma Project vicinity include 85 plants classified as noxious weeds by the Colorado Department of Agriculture, especially the nine species currently known from La Plata County (CDA 2004). Data from San Juan County are not available. There is a clear need for the Project to have an invasive species management plan coordinated with adjacent land ownerships and fuels reduction projects. 2.0 Project Effects (18 CFR 5.9(b)(5)) Invasive species around Electra Lake and in the larger Project vicinity are most often associated with roads, grazing, and development, suggesting the role of Project operations in their distribution, if any, is small. Plant invasions require propagule availability, dispersal, and establishment in suitable habitats (most often disturbed areas). Each of these requirements are met in parts of the Project vicinity, but only the latter two are likely affected by Project operations. Propagule availability for most plants is a function of regional-scale invasions and land-use patterns, neither of which is associated with the Project. However, plant dispersal may be affected by the Project by way of maintenance and/or vegetation management along access roads or penstocks, or via introduction by recreational boating which may provide a potential dispersal vector for existing infestations of exotic plants. Vegetation management along access roads or penstocks also creates habitat for invasive plants that would be otherwise unlikely to succeed in more intact systems (e.g., forested areas). The hydrologic disturbance associated with the normal operation of Electra Lake may have the potential to support plant invasions, but empirical evidence for such an effect is quite limited, and few invasive plant populations occur within the normal operation zone of Electra Lake. Active vegetation management associated with the Project occurs along the flume, penstocks, flowline, recreation facilities, the dams, and the powerhouse. Public Service Company of Colorado (PSCo) intends to conduct a survey of invasive plants at these Project facilities.


2 November 1, 2005

3.0 Relevant Existing Information (18 CFR 5.9(b)(4)) The Colorado Department of Agriculture reports that nine noxious weeds are currently known to occur within La Plata County (CDA 2004). Data from San Juan County are not available. Noxious weeds reported for Tacoma Project USGS quadrangles (Electra Lake and Engineer Mountain), as well as those expected to occur in the Tacoma Project vicinity by the USFS, are listed in Table 10 of PSCo’s Pre-Application Document (PAD) which is repeated below.

NOXIOUS WEEDS REPORTED OR EXPECTED TO OCCUR IN THE TACOMA PROJECT VICINITY

Name Common Name

Colorado Weed Rating

Acres reported in Project Quads1

Expected in Project Vicinity2

Bromus tectorum Cheatgrass C 0 Yes

Carduus nutans musk thistle B 0 Yes

Centaurea biebersteinii spotted knapweed B 6 Yes

Cirsium arvense Canada thistle B 37 Yes

Cynoglossum officinale Hound’s-tongue B 0 Yes

Euphorbia esula leafy spurge B 1 No

Leucanthemum vulgare oxeye daisy B 124 Yes

Linaria vulgaris yellow toadflax B 2 Yes

Onopordum acanthium Scotch thistle B 0 Yes

1 Source: Colorado Department of Agriculture quarter-quad noxious weed surveys, 2002. Data available at http://www.ag.state.co.us/DPI/weeds/mapping/QuarterQuadSurvey.html.

2 Sources: personal communication, Rob Cook, La Plata County Weed Supervisor, March 2005; personal communication, Mark Tucker, San Juan National Forest Rangeland Management Program Leader, March 2005.

4.0 Need for Additional Information (18 CFR 5.9(b)(4)) No inventories of invasive plants have been conducted in areas subject to Project vegetation management or the larger Project area. Additional information is needed on the composition and distribution of invasive plant species in these areas to the degree they are subject to Project-related ground disturbing activities. In addition, Project vegetation management does not currently address invasive plants, and efforts are currently not coordinated with adjacent land owners and land managers.


3 November 1, 2005

5.0 Final Study Plan 5.1 Purpose of Study and Use of Study Results (18 CFR 5.9(b)(1) & 5.9(b)(5) in part) The study will describe the composition and distribution of invasive plant species in areas subject to Project vegetation management efforts (e.g., penstock rights-of-way). This information will support the development of a formalized vegetation management plan designed to (1) allow continued vegetation management as needed for Project operations, (2) affect the prevention, eradication, or containment (in order of preference) of invasive plants, and (3) ensure coordination of vegetation management efforts between PSCo and adjacent land owners and land managers. 5.2 Relevant Resource Management Goals (18 CFR 5.9(b)(2)) This study is consistent with relevant agency resource management goals. The 1992 San Juan National Forest Land and Resource Management Plan includes the directive to employ Integrated Pest Management methods on significant pests in the Forest, including noxious weeds. Noxious weeds are considered to “be increasing in population at a rate that would be a threat to resources and uses” of the Forest, thereby requiring management efforts (USFS 1992). Forest-Wide Direction:

Range Resource Management (05). Treat noxious farm weeds in the following priority (page III-34):

a. Leafy spurge and Russian and spotted knapweed; b. Invasion of new plant species classified as noxious farm weeds; c. Infestation in new areas; d. Expansion of existing infestations of Canada and musk thistle, and other

noxious farm weeds; and e. Reduce acreage of current infestation (page III-34).

In addition, the Colorado Noxious Weed Act §§35-5.5-101 – 119 C.R.S (2003) states that noxious weed management is in the public interest, finding that “certain undesirable plants constitute a present threat to the continued economic and environmental value of the lands of the state and if present in any area of the state must be managed.”


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5.3 Relevant Public Interest Considerations (18 CFR 5.9(b)(3)) The Terrestrial RWG, which is comprised of public agencies, private entities, and other interested parties, has identified this issue as being of substantial interest, potentially affecting resources such as wildlife habitat and aesthetic values. 5.4 Study Methodology (18 CFR 5.9(b)(6)) 5.4.1 Surveys All Project lands and facilities subject to vegetation management will be field surveyed for the presence of invasive plant populations. Plants defined as invasive will include all those listed as “A” or “B” noxious weeds in Colorado, as well as other species considered of particular concern by the Terrestrial RWG. Invasive plant populations located during survey efforts will be mapped using GPS or hand-sketched onto Project orthophotos and subsequently digitized for use in a GIS data base. Large or diffuse populations may be unwieldy to map in detail; these will be described more generally. Standard descriptive data (e.g., plant list, population size, estimated number of individuals, estimated size of weed patch in acres/hectares, qualitative assessment of potential trends in patch growth, flowering phenology, and suggested potential treatment applications) will be collected at each population. All invasive plants located during field surveys will be addressed by the vegetation management plan (see below). PSCo is not proposing any changes to Project infrastructure, operation, or use that would be expected to affect invasive species. In the event such changes are proposed, the affected lands will be surveyed for invasive plants and incorporated into the vegetation management plan. While conducting field surveys associated with this Study Plan, PSCo will also record observations of any Special Status Species survey as referenced in Terrestrial RWG Issue Assessment No. 3, Special-Status Species and Habitats. If rare plants are found, data collected will include estimated number of individuals, estimated size of plant patch in acres/hectares, qualitative assessment of potential trends in patch growth (expansion/contraction), flowering phenology, and potential protection measures. All botanical survey methods will follow guidelines established by the Washington Natural Heritage Program (WNHP 2005) (personal communication, Dave Anderson, CNHP Botany Team Leader, June 2005). Field surveys will be conducted during times most conducive to species identification (i.e., when any plants present should possess features, such as flowers or fruit, required for identification). On a preliminary basis, field work is expected to be conducted in late June and August; however, further consultation with USFS biologists and the LaPlata County Weed Supervisor will be undertaken prior to final schedule development. 5.4.2 Vegetation Management Plan Project vegetation management practices will be formalized into a vegetation management plan that integrates vegetation removal and invasive plant management. The plan will be developed with the following goals: (1) allow continued vegetation removal as needed for Project


5 November 1, 2005

operations, (2) effect the prevention, eradication, or containment (in order of preference) of invasive plants, and (3) ensure coordination of vegetation management efforts between PSCo and adjacent land owners and managers. The plan will be limited to those areas currently affected by vegetation management, but additional lands affected by any future changes to Project infrastructure, operation, or use will be added as such changes are proposed. 5.5 Data Analysis and Reporting All reporting for this study will be incorporated into the vegetation management plan, with survey results and mapping presented as an appendix. All areas surveyed will be shown on Project maps. The plan will describe current management practices and define overall vegetation management goals, with emphasis on continued Project operations and the prevention, eradication, and containment of invasive plant species. Reporting will include a discussion of all areas at which vegetation management associated with the Project occurs, including the flume, penstocks, flowline, recreation facilities, dams, powerhouse, and gated project roads located on USFS lands. 5.6 Schedule Surveys of areas subject to vegetation management are scheduled for completion in the summer of 2006. Survey results and mapping will be developed and integrated into an invasive plants management plan which will be available as a draft report within six months of the completion of all field surveys. 5.7 Level of Effort (18 CFR 5.9(b)(7)) Initial surveys and mapping for this study are estimated to require approximately three person-weeks of effort, plus approximately one person-week of GIS time. The drafting of a vegetation management plan will require an additional two person-weeks. 5.8 Discussion of Alternative Approaches (18 CFR 5.9(b)(7)) There have been no alternative approaches proposed at this time. 6.0 References Colorado Department of Agriculture (CDA). 2004. Division of Plant Industry noxious weed lists for Colorado and Colorado counties. Online data: http://www.ag.state.co.us/DPI/weeds/mapping.html. Accessed December 2004. Colorado Natural Diversity Information Source (CNDIS). 2004. Known or likely wildlife species occurrence lists. Online data: http://ndis.nrel.colostate.edu/wildlife.asp. Accessed December 2004. USDA Forest Service. 1992. Amended Land and Resource Management Plan for the San Juan National Forest, Rocky Mountain Region. Durango, CO.

Tacoma Hydroelectric Project Migratory Bird Treaty Act Terrestrial RWG Issue No. 5

1 November 1, 2005



TERRESTRIAL RESOURCES WORK GROUP

Issue Assessment No. 5 and Study Plan Migratory Bird Treaty Act

1.0 Description of Issue (18 CFR 5.9(b)(1)) The issue has been raised that the Tacoma Project relicensing efforts should include a review of the Project in relation to the terms of the Migratory Bird Treaty Act (MBTA). Specifically, the issue is the need to protect avian individuals from the potential effects of any future ground-disturbing activities, or changes in human activities within the Project Boundary. Such changes could include modifications to Project operating procedures or increased access or use of the Project area. The MBTA of 1918 as amended (16 U.S.C. 703 et seq.) implements treaties between the United States and Great Britain (for Canada), Mexico, Japan, and Russia. Each treaty designates protected bird species and contains a prohibition on taking (e.g., to hunt, take, capture, kill, or possess) birds, bird parts, nests, or eggs of these species The MBTA provides the Federal government with authority to establish regulations on hunting and managing protected birds. The majority of native bird species that occur in North America fall within the auspices of the MBTA. 2.0 Project Effects (18 CFR 5.9(b)(5)) Public Service Company of Colorado (PSCo) is not proposing any changes to the Project that would result in any ground-disturbing activities or changes in human activities at the Project. Absent substantive changes in Project infrastructure, operations, or use, no Project effects on species protected by the MBTA are expected. The addition of a 4th unit to the existing powerhouse would not change Project operations in any significant way related to potential effects on migratory birds. Potential effects on riparian and wetland habitats used by some of these species are addressed within Terrestrial RWG Issue Assessment No. 7, Wetlands and Riparian Habitats. Changes that may result from proposed environmental enhancements as a result of relicensing must demonstrate their compliance with the MBTA. 3.0 Relevant Existing Information (18 CFR 5.9(b)(4))

An Executive Order titled responsibilities of federal agencies to protect migratory birds was enacted in 2001 (EO 13186) (http://ceq.eh.doe.gov/nepa/regs/oes/eo13186.html). This Executive Order highlights the important role of cooperation and communication among federal agencies in implementing bird conservation activities. The order requires federal agencies to consider the effect on migratory birds of land management planning and project implementation on public lands, particularly for those species for which there may be conservation concern. Executive Order 13186 requires federal agencies to “support the conservation intent of the migratory bird


2 November 1, 2005

conventions by integrating bird conservation principles, measures, and practices into agency activities and by avoiding or minimizing, to the extent practicable, adverse impacts on migratory bird resources when conducting agency actions.” Agencies are to “restore and enhance the habitat of migratory birds, as practicable” and to “evaluate the effects of actions and agency plans on migratory birds, with emphasis on species of concern.” This direction is to be implemented “to the extent permitted by law and subject to the availability of appropriations and within administration budgetary limits, and in harmony with agency missions.”

The MBTA states that “Unless and except as permitted by regulations, it shall be unlawful at any time, by any means, or in any manner, to pursue, hunt, take, capture, kill, attempt to do these acts, [or] possess ...any migratory bird, [or] any part, nest, or eggs of any such bird ....” Because the terms used in the MBTA are not defined in the Act, application of the MBTA has been subject to sometimes conflicting legal interpretation. Section 6 (16 U.S.C. §707) makes “any person, association, partnership, or corporation” who violates the MBTA or regulations there under subject to penalties. In practice, the focus of the MBTA is the maintenance of populations, not the protection of individual birds, which is not feasible or reasonable, with the exception of federally threatened or endangered species.

As a criminal environmental statute, the MBTA applies both to intentional and unintentional prohibited acts: unintentional violations are misdemeanors, whereas felony provisions are reserved for knowingly killing a migratory bird with intent to sell, or selling such birds. Responsibility for hazardous conditions that unintentionally kill migratory birds may be a violation of the MBTA. For example, the MBTA has been used by USFWS to enforce upgrades to electric power lines determined to be an electrocution hazard to protected species even though the birds were not deliberately killed (USDA 2000). Actions that result in killing protected species may require USFWS take permits. These actions may include clearing or grubbing vegetation, or demolishing structures where migratory birds nest if undertaken during the nesting season. However, only direct harm to migratory birds is understood to be addressed under the MBTA. The courts have held that the MBTA does not prohibit indirect take, including destruction or damage to habitats (e.g., logging) used by protected bird species (Baldwin 2003). On April 19, 2002, PSCo entered into a Memorandum of Understanding (MOU) with the US Fish and Wildlife Service "to establish procedures and policies...in dealing with migratory birds that may be present, injured or killed" on PSCo property. As a result of this MOU, PSCo is required to report any dead or injured birds found on company property and to be "sincere in its efforts to proactively protect migratory birds." It is known that the Project Boundary is used by bird species included within the MBTA. These include bald eagle, peregrine falcon, migratory waterfowl, and migratory songbirds. The Grace’s warbler (Dendroica graciae), a species tracked by CNHP but not accorded special status by any of the agencies, has also been reported for the Project vicinity (CNHP 2005). 4.0 Need for Additional Information (18 CFR 5.9(b)(4)) Proposed changes to Project operations (the Tacoma 4th Unit) will not substantially change flow regimes or Project structures and therefore are not expected to affect migratory birds or their


3 November 1, 2005

habitat. In the event that other changes or enhancements are proposed, they will need to be reviewed to ensure consistency with the MBTA. 5.0 Final Study Plan 5.1 Purpose of Study and Use of Study Results (18 CFR 5.9(b)(1) & 5.9(b)(5) in part) This study addresses consistency with the MBTA, specifically that any proposed change in Project infrastructure, operations, or use does not violate MBTA prohibitions to “pursue, hunt, take, capture, kill, attempt to do these acts, [or] possess ...any migratory bird, [or] any part, nest, or eggs of any such bird” unless permitted by regulations. The results will be used to assess the effects and advisability of proposed changes, and to guide modification of proposed changes as warranted. 5.2 Relevant Resource Management Goals (18 CFR 5.9(b)(2)) The Federal government is obligated by the MBTA to enforce international conventions that protect migratory birds from unauthorized take. The MBTA also provides the Federal government with authority to establish regulations on hunting and managing protected birds. 5.3 Public Interest Considerations (18 CFR 5.9(b)(3)) The Terrestrial RWG, which is comprised of public agencies, private entities, and interested parties, have identified this issue as needing to be addressed during relicensing. 5.4 Study Methodology (18 CFR 5.9(b)(6)) Consistency with the MBTA will be reviewed by assessing Project operations and proposed changes for the likelihood that direct taking of protected species would result. The study will consider the location, scope, and timing of activities relative to areas where migratory birds are known or expected to be nesting. CDOW, USFWS, USFS, and other agencies and stakeholders will be consulted with regard to the use of the Project area by MBTA-protected taxa, especially raptors. Data collection, if required, will consist of descriptions of MBTA-protected resources potentially affected by the activity (e.g., number and location of known nests). Existing operations or proposed changes that are determined likely to result in significant take (e.g., destruction of a nesting colony or other nest loss that may jeopardize a population) will be assessed or modified in consultation with relevant agencies so to reduce adverse effects. 5.5 Schedule, Duration, and Level of Effort (18 CFR 5.9(b)(7)) The study will occur in 2006, and a draft report will be issued in December 2006.


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5.6 Discussion of Alternative Approaches (18 CFR 5.9(b)(7)) There have been no alternative approaches proposed at this time. 5.7 Data Analysis and Reporting Reports produced for an MBTA study will include a description of the proposed action as well as the location, if known, of substantial populations of species addressed by the MBTA. Analyses will include a geographic assessment of the proximity of the action to such populations and an evaluation of the action relative to nesting phenology, tolerance for disturbance, and similarly relevant ecological information. Detailed field efforts are not expected to be a part of the MBTA study. 6.0 References Baldwin, P. 2003. The Endangered Species Act (ESA), Migratory Bird Treaty Act (MBTA), and Department of Defense (DOD) readiness activities: current law and legislative proposals. Report for Congress (Order Code RL31415), Library of Congress Congressional Research Service. 18 pp. U.S. Department of Agriculture (USDA). 2000. Migratory Bird Treaty Act enforcement. Located at: http://www.usda.gov/rus/electric/engineering/2000/mbta.htm. Accessed May 31, 2005.

Tacoma Hydroelectric Project Wetlands & Riparian Habitats Terrestrial RWG Issue No. 7

1 November 1, 2005




Issue Assessment No. 7 and Study Plan Wetlands & Riparian Habitats1

1.0 Description of Issue (18 CFR 5.9(b)(1)) The occurrence and distribution of wetlands in the immediate vicinity of the Tacoma Project has been identified as an issue. The Terrestrial Resource Work Group (RWG) also asked about the relationship of project-dependent wetlands and project operations, indicating that the maintenance and/or enhancement of these habitats needed to be addressed. National wetland inventory (NWI) maps of the Project area indicate that wetlands are numerous at various locations within the Project area and in adjacent areas that could be affected by the Project. Wetlands are valuable ecosystem components that can provide important wildlife habitats, help maintain water quality, and serve as a link between terrestrial and aquatic systems. In addition, numerous special-status species potentially occurring in the Tacoma Project vicinity are known to use or require wetland habitats. Potential future ground-disturbing activities that may impact wetlands need to be evaluated for their impact to these habitats. Also, the occurrence and distribution of riparian habitats in the immediate vicinity of the Tacoma Project has been identified as an issue. This includes the request to delineate current conditions of riparian habitat along Elbert Creek. The Terrestrial RWG asked that the maintenance and/or enhancement of these habitats be addressed. Riparian areas are important ecosystem components that can provide important wildlife habitats, help maintain water quality, and serve as a link between terrestrial and aquatic systems (Nilsson and Svedmark 2002). Numerous special-status species potentially occurring in the Tacoma Project vicinity are known to use riparian habitats. In addition, riparian areas often support important economic and recreational uses such as grazing, mining, or swimming. Riparian plant associations for Colorado were defined by Kittel et al. (1999), who included ratings for riparian condition and overall site quality for over 1,880 riparian plots statewide, including some in San Juan and La Plata counties. 2.0 Project Effects (18 CFR 5.9(b)(5)) NWI maps indicate that a variety of palustrine wetlands occur in areas potentially associated with the Project, including along Project-influenced stream reaches, around Electra, Aspaas, and Columbine Lakes, and along the route of the Cascade Creek pipeline. Forebay Lake is also classified as a palustrine wetland. Direct effects of Project operation on these wetlands are not currently known. Reservoir water surface fluctuations during the growing season have the potential to affect wetland functions and values, if rapid or extreme water fluctuations inhibit 1 The original Issue Assessment No. 10, Riparian Habitats has been consolidated with this Issue Assessment No. 7, Wetlands by the Terrestrial RWG. In addition, this Issue Assessment study plan addresses Water RWG Issue Assessment No. 13, Effects of Leakage from the Cascade Flowline on Adjoining Land.


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vegetation development or deter wildlife use (e.g., use by nesting waterfowl or breeding amphibians). In addition, wetlands along pipeline routes might be indirectly affected by periodic maintenance of the pipeline (e.g., via vehicle use). In general, the extent of each these effects is influenced by topography, geomorphology, adjacent land management, and recreational use. The Tacoma Project has been in existence for 100 years and the wetland habitats associated with the Project have developed in conjunction with the Project operations over that period of time. Public Service Company of Colorado (PSCo) is proposing to continue to operate the Tacoma Project in the manner that it has operated the facilities in the past; therefore, there is not likely to be any changes to the existing wetland habitats. Opportunities for enhancing existing wetlands may exist. Riparian habitats are associated with the Tacoma Project. During normal operations, water is diverted from Cascade Creek into the Little Cascade Creek watershed, flowing into Electra Lake, and subsequently the Animas River. Electra Lake functions as a storage reservoir, releasing water for use at the Tacoma powerhouse. Each of these areas supports a degree of riparian vegetation associated with existing Project operations. Stream diversions can influence riparian habitats by modifying water availability downstream. . The effects of diversion are strongly influenced by geomorphology: low-gradient stream reaches with adjacent floodplains, for example, are often more affected by hydroelectric operations than are high-gradient systems subject to large variations in flow and flow velocities. In addition, diversion effects can be substantially modified or mitigated by downstream accretion or tributary inflows, which can allow essentially unregulated riparian conditions below diversion points. Below the Cascade Creek diversion dam, seepage and accretions from groundwater and tributary sources provide stream channel flows of 2–4 cfs in the bypassed channel at the U.S. Highway 550 tunnel (1 mile below the diversion point). Below U.S. Highway 550, channel flows have been observed during normal Project operations to gradually increase to approximately 25 cfs below Lime Creek. Approximately one-third (8 to10 cfs) of this flow is believed to reflect accretion in the bypassed channel. PSCo intends to locate existing wetland systems within the Project Boundary. PSCo also intends to map riparian habitats on Elbert Creek and Forebay Lake, downstream of Terminal dam.2

2 A small pond located approximately 0.5 miles northwest of Forebay Lake adjacent to USFS access road used by PSCo is a natural pond unaffected by Project Operations and not within the Project Boundary and is therefore not proposed to be mapped.


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3.0 Relevant Existing Information (18 CFR 5.9(b)(4)) Only limited information is available concerning riparian areas within the Project Boundary. A CDOW (2005) riparian vegetation map shows small areas of riparian vegetation adjacent to Electra Lake, including the following types: riparian deciduous tree – cottonwood; riparian shrub; and riparian evergreen tree – general. Descriptions of these vegetation types or accompanying species lists are not available. Wetlands are depicted on the “Electra Lake, Colorado” and “Engineer Mountain, Colorado” NWI maps. Both maps are based on color infrared aerial photography dated July 1986. The types of palustrine wetlands shown to occur are primarily PAB (aquatic bed), PSS (scrub-shrub) and PEM (emergent). Wetland hydrology is mostly depicted as saturated or intermittently exposed. Topography suggests that wetlands in the vicinity of the Cascade Creek flowline are supported by drainage from Hermosa Cliffs, forming the headwaters of Little Cascade Creek. A report discussing some of the wetlands in the vicinity of the flowline adjacent to Durango Mountain Resort are characterized as willow scrub-shrub, alder/willow scrub-shrub, sedge emergent, and aquatic bed (Ecosphere Environmental Services 2000). The latter report describes aquatic bed wetlands as dominated by yellow pond lily (Nuphar lutea). Wetlands within the Project Boundary around Electra Lake are mostly situated on the west shore of the lake and are classified by NWI as seasonally flooded. In the flow-supplemented reach of Little Cascade Creek and on Elbert Creek downstream of Electra Lake, wetlands are associated with stream reaches of low gradient and a relatively wide floodplain. 4.0 Need for Additional Information (18 CFR 5.9(b)(4)) Site-specific information on riparian and wetland habitats in the Project area is needed to assess their functional condition, and the degree to which protection, management or enhancement of these habitats is warranted. 5.0 Final Study Plan 5.1 Purpose of Study and Use of Study Results (18 CFR 5.9(b)(1) & 5.9(b)(5) in part) The purpose of the study is to provide an inventory of riparian and wetland conditions within the Project Boundary and elsewhere as defined in section 5.4.1. Riparian and wetland habitats and bank conditions will be documented based on a review of existing information and a reconnaissance-level survey of the study area. If feasible, these conditions will be compared to reference habitats described elsewhere (e.g., by the Colorado Natural Heritage Program). The collected information will be used to assess the functional condition of Project-affected riparian and wetland habitats and to document areas potentially suitable for protection or enhancement efforts.


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5.2 Relevant Resource Management Goals (18 CFR 5.9(b)(2)) This study is consistent with resource goals established by federal land management agencies with lands potentially affected by the Tacoma Project. The San Juan National Forest Land and Resource Land and Management Plan, for instance, includes the directive to “protect streams, lakes, riparian areas, and other bodies of water through management activities.” (USFS 1992) Specific LRMP direction includes:

Forest-Wide Direction

Wildlife and Fish Resource Management (03), Maintain habitat for viable populations of all existing vertebrate wildlife species (Page III-26). Riparian Area Management (02). Design and implement activities in management areas to protect and manage the riparian ecosystem (Page III-46).

In addition, Executive Order 11990 authorizes federal protection of wetlands. The order requires federal agencies to consider the potential effects of a proposed project on the survival and quality of wetlands including the conservation and long term productivity of existing faunal species and habitat diversity and stability. However, executive Order 11990 does not apply to the issuance by federal agencies of permits, licenses, or allocations to private parties for activities involving wetlands on non-federal lands. 5.3 Relevant Public Interest Considerations (18 CFR 5.9(b)(3)) The Terrestrial RWG, which is comprised of public agencies, private entities, and other interested parties, has identified this issue as being of substantial interest, involving potentially valuable ecosystem components that can provide important wildlife habitats, help maintain water quality, and serve as a link between terrestrial and aquatic systems 5.4 Study Methodology (18 CFR 5.9(b)(6)) 5.4.1 Study Area The study area encompasses wetlands and riparian areas within the Project Boundary, and along Elbert Creek in approximately the first mile downstream of Terminal dam. The latter is upstream of a steep reach (a setting in which riparian vegetation is characteristically limited in extent) and is also upstream of the point where Elbert Creek receives inflow from Haviland Lake. 5.4.2 Mapping and Classification Riparian and wetland habitats within the study area will be mapped and classified consistent with Kittel et al. (1999) for riparian areas and Carsey et al. (2003) for wetlands; wetlands will also be defined according to wetland types described by Cowardin et al. (1979). Base maps for field use


5 November 1, 2005

will be prepared using the most recent available digital orthophotos, with a minimum polygon size of one acre. Draft habitat polygons apparent on the photos will be identified prior to field studies, and verified and adjusted as necessary by a field team. 5.4.3 Field Assessment A descriptive inventory of representative wetland and riparian polygons in the study area will be performed and “Proper Functioning Condition” (PFC) (Prichard et al. 1998a, 1998b) will be assessed. PFC assessment considers a series of functional attributes of vegetation, hydrology, and erosion/deposition in wetland or riparian systems in identifying site-specific characteristics in riparian and wetland habitats. For riparian zones of the study area, the PFC standard checklist of 17 attributes will be completed in representative reaches (Prichard et al. 1998a) (Appendix 1). Observations of representative conditions and noteworthy atypical conditions (e.g., site-specific erosion) will also be documented by photographs and GPS-determined locations will be recorded. Recorded information will include noting dominant and sub-dominant species; characterizing evidence of periodic recruitment; and rating dominant and sub-dominant species for known association with moist soil conditions according to Reed (1997) and capability for maintaining bank stability against the erosive forces of moving water. The latter will be determined based on stability ratings for 200 riparian community types of the Intermountain Region (which includes Colorado) (Winward 2000), other published sources, or by interpreting field observations of erosion or bank failures. Lentic wetlands in the study area will be assessed for PFC based on the standard checklist of 22 attributes (Prichard et al. 1998b) (Appendix 2). The following supporting descriptive information will also be collected: (1) vegetation composition (dominant and sub-dominant species; the presence of aquatic and/or emergent vegetation); (2) hydrologic characteristics (sources of hydrology, estimated duration of inundation, maximum water depth, near-shore water depth); (3) observations of fish, amphibians, and other wildlife or wildlife signs; and (4) documentation of Southwestern Willow Flycatcher habitat as defined by USFWS.. Work undertaken as part of this study plan will also include documenting apparent leakage from the Cascade flowline and the effects of this leakage (addresses Water RWG Issue Assessment No. 13, Effects of Leakage from the Cascade Flowline on Adjoining Land). 5.5 Schedule The study will be initiated in late 2005, and field studies associated with this issue will be conducted in spring and summer of 2006. A draft report will be issued no later than six months after field efforts are completed. 5.6 Level of Effort (18 CFR 5.9(b)(7)) Field work for this study is estimated to require approximately 120 hours of effort by a two-person team.


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5.7 Discussion of Alternative Approaches (18 CFR 5.9(b)(7)) No alternative approaches have been proposed at this time. 5.8 Data Analysis and Reporting Reporting for this study will be descriptive; no quantitative analyses are proposed. Study results will include a PFC assessment for representative wetland and riparian habitats, classifying system attributes as either “in proper functioning condition,” “nonfunctional,” or “at risk.” Documentation and biological rationale for each assessment will be included and presented in tabular form. Opportunities for protection or enhancement of riparian systems and wetlands will be identified. The results of this study will be incorporated in the Tacoma Project Final License Application. 6.0 References Carsey, K, G. Kittel, K. Decker, D.J. Cooper, and D. Culver. 2003. Field Guide to the Wetland and Riparian Plant Associations of Colorado. Colorado Natural Heritage Program. Fort Collins, CO. Cowardin, L.M., V. Carter, F.C. Golet, and E.T. LaRoe. 1979. Classification of wetlands and deepwater habitats of the United States. FWS/OBS-79/31, US Fish and Wildlife Service Office of Biological Services, Washington D.C. Kittel, G., E. VanWie, M. Damm, R. Rondeau, S. Kettler, A. McMullen, and J. Sanderson. 1999. A classification of riparian wetland plant associations of Colorado: user guide to the classification project. Colorado Natural Heritage Program, Colorado State University, Fort Collins, Colorado. Platts, W.S., W.F. Megahan, and G.W. Minshall. 1983. Methods for evaluating stream, riparian, and biotic conditions. Gen. Tech. Rep. INT-138. USDA Forest Service, Intermountain Forest and Range Experiment Station, Ogden, Utah. 70 pp. Prichard, D., J. Anderson, C. Correll, J. Fogg, K. Gebhardt, R. Krapf, S. Leonard, B. Mitchell, and J. Staats. 1998. A user guide to assessing proper functioning condition and the supporting science for lotic areas. Technical Reference 1737-15. Bureau of Land Management, BLM/RS/ST-98/001+1737, Service Center, Denver, CO. 136 pp. Prichard, D., C. Bridges, W. Hagenbuck, R. Krapf, and S. Leonard. 1998. Process for assessing proper functioning condition for lentic riparian-wetland areas. Technical Reference 1737-9. Bureau of Land Management, BLM/RS/ST-98/001+1737, Service Center, Denver, CO. 46 pp. USDA Forest Service. 1992. Amended Land and Resource Management Plan for the San Juan National Forest, Rocky Mountain Region. Durango, CO.


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Appendix 1 Proper Functioning Condition Checklist for Riparian Areas

Date:__________________ ID Team Observers:___________________ Name of Riparian Area:________________________ Segment/Reach ID: and Location _______________________________________________ Yes No N/A HYDROLOGIC Floodplain inundated by relatively frequent events (1-3 years) Active/stable beaver dams Sinuosity, width/depth ratio, and gradient are in balance with the landscape setting Floodplain zone is widening Upland watershed not contributing to riparian degradation Yes No N/A VEGETATIVE Diverse age structure of vegetation Diverse composition of vegetation Species present indicate maintenance of riparian and moisture characteristics Streambank vegetation is comprised of those plants or plant communities that have

root masses capable of withstanding high streamflow events Riparian plants exhibit high vigor Adequate vegetative cover present to protect banks and dissipate energy during high

flows Plant communities in the riparian zone are an adequate source of coarse and/or large

woody debris Yes No N/A EROSION DEPOSITION Floodplain and channel characteristics (i.e., rocks, coarse and/or large woody debris)

adequate to dissipate energy Point bars are revegetating Lateral stream movement is associated with natural sinuosity System is vertically stable Stream is in balance with the water and sediment being supplied by the watershed (i.e.,

no excessive erosion or deposition). Appropriate Willow Flycatcher Habitat present (Y/N, describe below): Field Notes: Functional Rating: Proper Functioning Condition Functional – At Risk Nonfunctional Unknown


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Appendix 2 Proper Functioning Condition Checklist for Wetland Areas

Date:__________________ ID Team Observers:___________________ Name of Wetland and Location:______________________________________________ Yes No N/A HYDROLOGIC Wetland area is saturated at or near the surface or inundated in “relatively frequent”

events Fluctuation of water levels is not excessive Riparian/wetland area is enlarging or has achieved potential extent Upland watershed is not contributing to riparian-wetland degradation Water quality is sufficient to support riparian-wetland plants Natural surface or subsurface flow patterns are not altered by disturbance (i.e., hoof

action, dams, dikes, trails, roads, rills, gullies, drilling activities) Structure accommodates safe passage of flows (e.g., no headcut affecting dam or

spillway) Yes No N/A VEGETATIVE Diverse age-class distribution of vegetation (recruitment for maintenance/recovery) Diverse composition of vegetation Species present indicate maintenance of soil moisture characteristics Vegetation is comprised of those plants or plant communities that have root masses

capable of withstanding wind events, wave flow events, or overland flows (e.g., storm events, snow melt)

Plants exhibit high vigor Adequate vegetative cover present to protect shoreline/soil surface and dissipate energy

during high wind and wave events or overland flows Frost or abnormal hydrologic heaving is not present Favorable microsite condition (i.e., woody debris, water temperature. etc.) is

maintained by adjacent site characteristics Yes No N/A EROSION DEPOSITION Accumulation of chemicals affecting plant productivity/composition is not apparent Saturation of soils (e.g., ponding, flooding frequency and duration) is sufficient to

comprose and mainatain hydric soils Underlying geologic structure/soil material is capable of restricting water percolation Riparian-wetland is in balance with the water and sediment being supplied by the

watershed (i.e., no excessive erosion or deposition). Islands and shoreline characteristics (i.e., rocks, coarse and/or large woody debris)

adequate to dissipate wind and wave event energies Appropriate Willow Flycatcher Habitat present (Y/N, describe below): Field Notes:


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Functional Rating: Proper Functioning Condition Functional – At Risk Nonfunctional Unknown

CULTURAL RESOURCES STUDY PLAN

Tacoma Hydroelectric Project Historic Properties Management Plan Cultural RWG Issue Nos. 1,2,3,4

1 November 1, 2005



CULTURAL RESOURCE WORK GROUP

Issue Assessment Nos. 11, 2, 3, and 4 and Study Plan Section 106 of the National Historic Preservation Act

1.0 Description of Issues (18 CFR 5.9(b)(1)) Issue Assessment No. 1: An issue was raised concerning how the Section 106 review will be conducted in the context of the Tacoma Project relicensing. Many of the issues identified within the Cultural Resource Work Group (RWG) are essentially sub-issues of the overall Section 106 review process. Issue Assessment Nos. 2, 3, and 4 will be considered during the Section 106 review process. For descriptions of these Issue Assessments, see Attachment A. 2.0 Project Effects (18 CFR 5.9(b)(5)) As the lead Federal agency for hydropower relicensing, the Federal Energy Regulatory Commission (FERC) is responsible for satisfying Section 106 consultation requirements under the National Historic Preservation Act (NHPA). Implementation regulations for Section 106 have been published by the Secretary of the Interior in 36 CFR 800. To accomplish this, FERC needs to document consultation with interested parties on Project effects on historic properties eligible for protection under the NHPA. This consultation must document that FERC has considered the effects of the undertaking (the issuance of a new federal operating license) on historic properties eligible for listing on the National Register of Historic Places (NRHP) and allow the Advisory Council on Historic Preservation (ACHP) the opportunity to comment on its conclusions. FERC begins to address Section 106 requirements during relicensing by delegating day-to-day consultation and study authority to the Licensee (PSCo). Many Licensees of FERC-jurisdictional hydroelectric facilities have recently been implementing a program of conservation archeology as a core component of Section 106 consultation, particularly at relicensings where there are few operational changes or proposed ground disturbances as compared to original licensings where a new project is to be constructed. Licensees that choose to incorporate a strong program of conservation archeology design the historic properties studies to minimize disturbance of eligible or potentially-eligible sites in order to preserve as much of the data in place. This study approach generally includes background research (Class I overview) and inventory (Class III inventory) to identify cultural resources within the Area of Potential Effect (APE) and evaluate them for inclusion on the NRHP. With the overview and inventory data in hand, the Licensee is in a position to proceed directly to the

1This Issue Assessment No. 1 was a new issue raised in the January 19, 2005 Cultural RWG Meeting and was deemed to be a fundamental, overarching issue by the RWG.


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development of a Historic Properties Management Plan (HPMP) that considers all eligible or potentially-eligible sites in future management. For historic structures that are part of Project facilities located within the APE, a determination is made as to whether PSCo’s building or structure is NRHP eligible; and if so, what character-defining features need to be managed during the term of the next license. The HPMP will then include provisions to lessen impacts to these character-defining features during changes that will likely occur to these properties through upgrades, maintenance, and other changes that will need to be made to the properties. FERC and the ACHP issued guidelines on developing HPMPs that specifically recognize that hydroelectric projects are critical energy production facilities. These facilities will need to be upgraded to remain competitive and to continue to produce power in a cost-effective manner rather than museums that need to be maintained in their original constructed condition. FERC’s HPMP guidelines satisfy both historic preservation needs as well as the Licensee’s interests in keeping the project economically sound. The following general description outlines the steps that Public Service Company of Colorado (PSCo) will follow to satisfy Section 106 consultation during relicensing in order to provide FERC with the documentation it needs to comply with the NHPA, complete NEPA, and issue a new license.

• Stakeholders - Identify interested parties and stakeholders. PSCo will identify Section 106 consulting/interested parties following the development of the draft HPMP.

• APE - Consult with stakeholders on the project’s Area of Potential Effect (APE). This

largely defines the geographic study scope for Section 106 consultation and often is defined as the property within the FERC project boundary. This approach also recognizes the geographic area over which FERC has jurisdiction.

• Background Research – a qualified archeological/historic consultant conducts a search

of prior research on work done in the project area to obtain an understanding of what is known about historic use in the APE. This information is used to scope the field work and to provide context for the later HPMP (if needed). In Colorado, this literature review and site file search stage is referred to as a Class I cultural resource overview.

• Inventory – Field crews walk transects at pre-determined intervals, usually 15-m (50-

foot), and identify archaeological and historical sites within the APE. Sometimes limited archaeological testing is included to establish significance under the NRHP criteria. This is referred to as a Class III cultural resource inventory.

• Historic Properties Management Plan – if NRHP-eligible historic properties are

located within the Project APE, then FERC will require the Licensee to consult with the Section 106 parties to develop an appropriate HPMP. FERC developed and published HPMP guidelines in consultation with the ACHP recently that provide a framework for developing a project-specific management plan as appropriate. The HPMP will include distinction for and definitions of routine maintenance, major maintenance, and emergency operations.


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• Programmatic Agreement - FERC develops and distributes a Programmatic Agreement

(PA) for signature that commits the Licensee to complete all outstanding identified work related to historic properties. This documents FERC’s completion of the Section 106 consultation process and allows the ACHP to sign off on FERC’s assessment of the Project effects on NRHP-eligible historic properties.

Reports that include site forms are developed and distributed to the Section 106 consultation parties for review and comment as appropriate. A single report will be written that encompasses the work completed. Any reports that include site location information must be kept confidential to avoid disclosing this information to surface collectors, site looters, or vandals. 3.0 Relevant Existing Information (18 CFR 5.9(b)(4)) Existing information regarding cultural resource sites and previous inventories in the Project area is on file at the Office of Archaeology and Historic Preservation of the Colorado Historical Society in Denver and at the San Juan Public Lands Office of the San Juan National Forest in Durango. Historic information about land use, land ownership, and water rights in the Project area are available at the La Plata and San Juan County Clerk’s offices in Durango and Silverton and in the General Land Office records on file at the Bureau of Land Management in Durango, Montrose, and Denver. More detailed water rights files of historical importance are available at the State Engineer’s Office in Denver. Files pertaining to initial Homestead Patents now part of the Project area are at the National Archives in Washington, D.C. Additional historical information about the Project area can be gleaned from local newspapers and documents on file at local libraries and historical societies and at the Colorado Historical Society Library and the Western History Collection at the Denver Public Library. Historical information specific to the Tacoma Project is present in the Western Colorado Power Company Collection housed at the Center of Southwest Studies at Fort Lewis College in Durango. It is also likely that information of historical importance may be present in the files of PSCo. 4.0 Need for Additional Information (18 CFR 5.9(b)(4)) Some previous site recordings, Historic American Engineering Record (HAER) documentations, and cultural resource inventories have taken place in or near the Project. Recordation and HAER documentation of Terminal Dam, Aspaas Dam, and Power Flume No. 1 (Hawley 1980, 1983a and b), all integral parts of the Tacoma Hydroelectric Project, were conducted so that those elements could be replaced. Recordation of the Tacoma powerhouse was done in 1979 (Alexander and Conner 1979) and resulted in the plant being officially determined National Register eligible, but is a poor recording in need of updating. No systematic inventories of the existing facilities or the fluctuating shoreline of Electra Lake have been conducted. A few prehistoric sites and isolated finds are known in and near the Project, but comprehensive knowledge is lacking of whether prehistoric sites are present within the seasonally exposed Electra Lake basin or in close proximity to existing facilities. It is known that two historic wagon roads passed through the Project area and that other historic activities took place in the area prior to the construction of the Tacoma Project, but it is unknown if any evidence of these early activities remains in the Project area. In addition, the Tacoma Project is itself historic and


4 November 1, 2005

historic evidence of its construction and use are in need of identification and documentation. These would include not only constructed elements of the Project, including dams, flumes, and pipelines but work camps, sawmills, and employee housing. Synthesis of primary historical documentation of the Project, examination of state and federal agency site files, and review of regional prehistoric overviews for the Project area have not taken place and are necessary for a cultural resource context to be developed for the HPMP and proper treatment of sites under Section 106. Recordation and National Register evaluation of historic and prehistoric sites within the seasonally exposed pool area of Electra Lake, along or in close proximity to existing facilities, and the historic facilities themselves will enable significant cultural resources to be managed and considered under Section 106 of the NHPA and will facilitate ongoing operation of the Tacoma Project. PSCo is currently proposing to add a fourth unit to the existing powerhouse. This work will include extending the current underground penstock approximately 100 feet to the powerhouse. Sufficient space exists in the existing powerhouse to accommodate the new unit. Some floor and foundation demolition will be needed to install the new unit, but no demolition of the currently visible building will be needed. The current Project switchyard will be upgraded and relocated slightly to the south of its current location. The HPMP will include recommendations for the conduct of this work consistent with maintaining the historic significance of the structure and Project. 5.0 Final Study Plan 5.1 Purpose of Study and Use of Study Results (18 CFR 5.9(b)(1) and 5.9(b)(5) in part) The purpose of this study is to identify and evaluate cultural resources comprising the existing facility, in or near existing Project facilities, and potentially being impacted by current operations so that they can be considered under Section 106 of the NHPA and be managed appropriately. Additional data will be compiled with the survey data for the preparation of the HPMP, with the final goal of entering into a Programmatic Agreement (PA) for the management and treatment of cultural resources for the Project. 5.2 Relevant Resource Management Goals (18 CFR 5.9(b)(2)) The goals of the study will be that historic properties (i.e., significant cultural resources) comprising the Project, in close proximity to Project facilities, and potentially being impacted by current Project operations are known and their values understood so that they can be considered under Section 106 and managed in a manner that facilitates Project operation. By inventorying those portions of the Project in direct use that have not been previously been inventoried, continued operation and planning for maintenance, modification, upgrading, or expansion can take place with full knowledge of what historic properties are present, their nature, potential for avoidance, or likely mitigation needs will be. Such an approach is proactive and fully satisfies the goals of the Section 106 process, which is intended to prevent inadvertent disturbance or


5 November 1, 2005

destruction of historic properties for projects on federal land or under federal authorization and allows for consultation where historic properties are concerned. Areas within the Project Boundary not currently in use and not anticipated for ground disturbance under current or foreseen plans will not be included in the inventory effort, but will be inventoried on a project-specific and place-specific basis if future plans involving ground disturbance require it. Data from the inventory will be combined with a historic and prehistoric context derived from site file search, prehistoric overview, and synthesized primary historical data to prepare the HPMP. The HPMP will serve as a guide for cultural resource compliance for the license period for the Project. It is expected that the HPMP will result in a PA between PSCo, FERC, the Advisory Council on Historic Preservation (ACHP), and other interested parties that serves as a binding agreement for the treatment of cultural resources. Forest-Wide Direction

Cultural Resource Management (01). Protect, find an adaptive use for, or interpret all cultural resources on National Forest System (NFS) lands which are listed on the National Register of Historic Places, the National Register of Historic Landmarks, or have been determined to be eligible for the National Registers.

5.3 Relevant Public Interest Considerations (18 CFR 5.9(b)(3)) The guiding principle behind historic preservation legislation is that protection of important historic and archaeological sites is for the common good of the American people. The foremost and most relevant method for that to take place in the Project area is through the mandate of Section 106 of the NHPA. In addition to satisfying legal requirements, identification, evaluation, and management of cultural resources in the Project Area will benefit the public through the additional information acquired about prehistoric and historic use of the region and the importance of the Tacoma Project to the development of the San Juan Mountains and Durango area. The HPMP and PA for the management and treatment of cultural resources will ensure proper consideration of cultural resources for the life of the Project license. 5.4 Study Methodology (18 CFR 5.9(b)(6)) 5.4.1 Study Area and Sites Cultural resource inventories will take place in three specific areas. The first inventory will be the shoreline of Electra Lake (including adjacent Aspaas Lake), done at the time when the reservoir is near its low water level and the shoreline is clear of snow. This will be in the spring or fall of 2006. Because the reservoir is near its low point during the late winter or early spring and typically begins filling before the shoreline is free of snow, it is likely that the inventory will not be possible when the reservoir is at its absolute lowest level. Still, a considerable amount of the shoreline below the high water mark will be visible at the time of the inventory. Terminal Dam and Aspaas Dam were replaced in 1980 and they were the subject of


6 November 1, 2005

HAER documentation (Hawley 1980, 1983a). It is unknown if remnants of Stagecoach Dam still exist on the shoreline of Electra Lake. The second inventory will be of the Cascade diversion dam, wooden Cascade Flume, the inverted siphon over Cascade Creek, and previously uninventoried portions of the buried water pipeline to Columbine Lake. The diversion dam will be recorded as an individual site and the flume, siphon, and visible portions of the pipeline will be recorded as elements of a linear site. The diversion, flume, and siphon were constructed in 1924, and the pipeline was constructed from 1949 to 1952 to replace the original box flume. In addition to documenting these facilities, a survey of 50 feet on either side of the flume, siphon, and pipeline will be completed where previous inventories have not taken place. This 100-foot-wide corridor conforms to the Project boundary. The third inventory will be along the Little Cascade Creek drainage between Columbine Lake and Aspaas Lake. Historical information suggests that the drainage was modified to carry water for the Project and that the lower 1,500 feet may have been contained in a wooden box flume. Again, a 100-foot-wide corridor (50 feet on either side of the drainage) will be inventoried to conform to the Project boundary. A fourth inventory will be performed in areas within the Project Boundary that have a high potential for prehistoric cultural resources. These areas are defined as having relatively gentle slopes in close proximity to natural water sources. In addition, the recordation of the Tacoma power plant structure should be updated with the completion of a current site form. Much of the documentation of the plant is currently underway as a volunteer partial HAER project being overseen by the National Park Service. The second through fourth inventories will take place during the summer of 2006. Completion of a site form for the power plant should be done during the summer of 2006 to take advantage of the completed partial HAER documentation. No work is proposed at this time along the power flume portion of the Project below Electra Lake. It is expected that installation of a completely new pipeline and penstock system in this area in 1980, with HAER documentation of the Power Flume No. 1 at that time (Hawley 1983b), has resulted in a disturbed corridor with little or no potential for intact cultural resources to exist. 5.4.2 Methods A Class I cultural resource site file search and overview will take place prior to fieldwork commencing in the identified survey areas. A file search at the San Juan Public Lands office of the San Juan National Forest in Durango was conducted on July 13, 2005. This revealed that a number of cultural resource inventories of blocks of land have covered a large amount of the Cascade Creek pipeline, and inventories have taken place of a few linear and smaller block areas elsewhere within the Project Area, but have covered an inconsequential amount of land. An initial search of the Colorado Historical Society’s site files was conducted using the on-line COMPASS database, but finalization of the site file search will need to be completed at the


7 November 1, 2005

Colorado Historical Society’s Office of Archaeology and Historic Preservation in Denver. Background overview information has also begun to be gathered about the project area, but will need to be completed. Besides the site file information from the San Juan National Forest and the Colorado Historical Society, the most important information about the prehistory of the area will be gained through reference to the two pertinent Colorado prehistory contexts (Lipe et al. 1999; Reed and Metcalf 1999). The Western Colorado Power Company records on file at the Center of Southwest Studies at Fort Lewis College in Durango have been examined and information about the Tacoma Project obtained. Information has also been gathered through on-line historical newspapers of the area. Additional historical information will be gathered at the Colorado Historical Society’s library and at the Western History Collection of the Denver Public Library. Oral informants may be consulted to fill gaps in the historical record. The Class III cultural resource inventory of the specified areas in the project area will be carried out under the direction of a qualified archaeologist under the Secretary of Interior’s standards, permitted by the State of Colorado, and permitted by the US Forest Service for lands on the San Juan National Forest. Surveys will be conducted by linear pedestrian transects spaced at 15-m (50-foot) intervals so as to give complete coverage to the areas to be inventoried. When artifacts or cultural features are encountered, the crew will intensively inspect the surrounding area to determine whether a site or an isolated find is represented. Sites are defined as five or more artifacts, in relatively close proximity to one another, exceeding 50 years old. Locations with four or less artifacts will usually be classified as isolated finds. Sites may also be defined for features, structures, rock art, or facilities exceeding 50 years of age that lack artifacts. Site maps will be prepared with the aid of a GPS unit capable of submeter accuracy and locations will be plotted on USGS quadrangle maps using the same GPS units. Site maps will illustrate site boundaries, datums, and cultural and topographic features. Aside from the site maps, all sites will be photographed using black-and-white film to aid in the site relocation. Sites will be evaluated for significance in terms of their eligibility for inclusion on the National Register of Historic Places (NRHP). Recommendations of significance will be made using the NRHP criteria for eligibility, as published in the U.S. Government Code of Federal Regulations (36 CFR 60). These read as follows: National Register criteria for evaluation. The quality of significance in American history, architecture, archeology, engineering, and culture is present in districts, sites, buildings, structures, and objects that possess integrity of location, design, setting, materials, workmanship, feeling, and association and

(a) that are associated with events that have made a significant contribution to the broad patterns of our history; or

(b) that are associated with the lives of persons significant in our past; or

(c) that embody the distinctive characteristics of a type, period, or method of construction, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction; or


8 November 1, 2005

(d) that has yielded, or may be likely to yield, information important in prehistory or history.

Identification and evaluation of cultural resources at the Project permit formulation of management recommendations. Isolated finds, by definition, are not eligible for inclusion on the NRHP. Reports will be prepared that document the inventories and provide information about the discovered sites and their recommended National Register eligibility. These reports will be prepared to the standards of the Secretary of Interior, San Juan National Forest, and the Colorado Historical Society. The reports will serve as the basis for PSCo to conduct consultation under Section 106 of the NHPA. Data from the Class I site file search and overview and the Class III cultural resource inventories will form the basis for the preparation of the HPMP. The HPMP provides a state of knowledge of cultural resources and their management in the FERC license area by:

• outlining applicable federal and state laws • establishing a context for historic and prehistoric sites of the area • identifying known cultural resources that may be impacted by proposed Project

changes or Project operations and identifying their significance • predicting what other cultural resources may exist in the license area • identifying areas that have been previously inventoried for cultural resources • outlining measures for the management of cultural resources • establishing procedures for the implementation of cultural resource management

The HPMP will be prepared in accordance with the Guidelines for the Development of Historic Properties Management Plans for FERC Hydroelectric Projects (FERC 2002). A considerable focus of the document will be on existing project facilities because many are themselves historic, with several elements already officially determined to be eligible for inclusion on the National Register of Historic Places. Historic American Engineering Record documentation packages (HAER No. CO-15, CO-16, and CO-17) were prepared for Terminal Dam, Aspaas Dam, and Power Flume No. 1 by Colorado-Ute Electric Association, Inc. to allow removal or replacement of those elements of the project in 1980 (Hawley 1980, 1983a, 1983b). Other related or unrelated historic cultural resources may fall within the project boundaries, as may unidentified prehistoric sites or Traditional Cultural Properties. Another important element of the document is expected to be a plan for identifying and assessing the significance of currently unknown cultural resources within the Project Boundary for the purposes of Section 106 compliance related to future construction of new Project facilities or modification of existing facilities. 5.5 Schedule The inventory of the shoreline of Electra Lake and Aspaas Lake will be done as soon as snow has cleared from the shore early in the spring of 2006 so that as much of the shoreline as possible is available for viewing. Inventories of the Cascade Creek diversion, Cascade Flume, siphon and pipeline, the Little Cascade Creek drainage, and the areas of high prehistoric cultural resource potential will take place during the summer of 2006. Updating of the site form for the power


9 November 1, 2005

plant should take place after the partial HAER documentation is completed, probably during the summer of 2006. Preparation of the HPMP is currently underway. It is expected to be completed by at least June 2007 to conform to the Ames-Tacoma relicensing schedule. 5.6 Level of Effort (18 CFR 5.9(b)(7)) It is estimated that the inventory of the approximately 11 miles of shoreline around Electra Lake and the areas of high prehistoric cultural potential will take eight days time for a crew of three archaeologists. The inventory of 1.5 miles of 100-foot-wide strip along Little Cascade Creek is estimated to take two days for a crew of two archaeologists, the inventory of a 100-foot-wide strip centered on the Cascade Creek flume, siphon, and pipeline is expected to take three days for a crew of two archaeologists. An additional field day will be required to update the recordation of the power plant for two archaeologists. Collection of historical data, site file information, and prehistoric context data is expected to take four weeks of time, with three weeks required for synthesis and writing. An additional three weeks of time are expected to prepare a draft HPMP. 5.7 Discussion of Alternative Approaches (18 CFR 5.9(b)(7)) It would be possible to prepare the HPMP without the benefit of the proposed cultural resource inventories. However, few cultural resources are known in the Project area, existing facilities are either undocumented or poorly recorded, cultural resources potentially being impacted by fluctuations in Electra Lake would remain unknown, and cultural resources potentially present along Little Cascade Creek would be unknown. Inventories of these areas could be prescribed in the HPMP, but the resulting document would be less complete and would not promote a comprehensive approach to managing the Project’s cultural resources. 5.8 Data Analysis and Reporting The results of the cultural resource inventories would be reported upon in one or more cultural resource reports, depending upon the timing of the inventories. These reports would be prepared in accordance with the Secretary of Interior’s guidelines and to the standards of the US Forest Service and Colorado State Historic Preservation Office. Data from the inventories will be incorporated into the HPMP and will facilitate cultural resource management of the Project. 6.0 References Alexander, Robert K., and Carl E. Conner 1979 Cultural Resource Inventory Report of the Tacoma Project for Colorado-Ute

Electric Association, Inc. GRI/CRI Report 7914. Grand River Institute, Grand Junction, Colorado. On file at the Colorado Historical Society, Office of Archaeology and Historic Preservation, Denver. (USFS Project No. 13-142).

Hawley, Monica E. 1980 Historic American Engineering Record No. CO-15, Terminal Dam (Tacoma

Project). Colorado-Ute Electric Association, Inc., Montrose, Colorado. On file at the Colorado Historical Society, Office of Archaeology and Historic Preservation,


10 November 1, 2005

Denver. 1983a Historic American Engineering Record No. CO-16, Aspaas Dam (Tacoma Project).

Colorado-Ute Electric Association, Inc., Montrose, Colorado. On file at the Colorado Historical Society, Office of Archaeology and Historic Preservation, Denver.

1983b Historic American Engineering Record No. CO-17, Power Flume No. 1 (Tacoma

Project). Colorado-Ute Electric Association, Inc., Montrose, Colorado. On file at the Colorado Historical Society, Office of Archaeology and Historic Preservation, Denver.

Lipe, William D., Mark D. Varien, and Richard H. Wilshusen, editors 1999 Colorado Prehistory: A Context for the Southern Colorado River Basin. Colorado

Council of Professional Archaeologists, Denver. Reed, Alan D., and Michael D. Metcalf 1999 Colorado Prehistory: A Context for the Northern Colorado River Basin. Colorado

Council of Professional Archaeologists, Denver. USDA Forest Service. 1992. Amended Land and Resource Management Plan for the San Juan

National Forest, Rocky Mountain Region. Durango, CO.


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Attachment A Issue Assessment Nos. 2, 3, 4


12 November 1, 2005



CULTURAL RESOURCES WORKING GROUP

Issue Assessment No. 22 The Tacoma Project Has Considerable Historical Value. Therefore, How Can the Plant’s Historical and Cultural Value Be Acknowledged and Protected, Including Its Associated

Recreational Features

1.0 Description of Issue (18 CFR 5.9(b)(1)) It was pointed out that the Tacoma Project is comprised of numerous features with potentially significant historical and cultural value. Elements of these potentially significant historical and cultural values may include: the context of its significance as a state and national hydroelectric generation site; the relationship to the Silverton, Mayflower Mill, and Durango-Silverton Railroad National Historic Landmarks; and evaluating the powerhouse as a National Historic Landmark in its own right. These project facilities include water diversions, wooden flumes, pipelines, reservoirs, dams, powerhouse, and even the older recreation camps on Electra Lake. There also have been long-term recreational uses such as fishing, boating, and hiking associated with some of the features. The powerhouse, as it currently exists, was constructed in the first decade of the 1900s at a time when alternating current was still relatively new. The majority of these features and recreational uses are considered by many as having historical and cultural importance. An issue was identified as to how these potentially significant features would be identified and protected. This issue includes the question of which agency and/or organization will perform this function and which process will be utilized. These issues are considered in the overall Section 106 review process. 2.0 Project Effects (18 CFR 5.9(b)(5)) The Tacoma Project became operational in 1906 and constitutes one of the early economic developments in this region of Colorado. The Tacoma Project continues to be a valuable energy source providing electrical generation on-peak when most needed by electricity users. Public Service Company of Colorado (PSCo) is proposing to continue to operate the Tacoma Project as it has in the past and is not proposing any changes to Project facilities or operations. At the same time, PSCo recognizes the historic significance of the Project and intends to meet the requirements of Section 106 of the National Historic Preservation Act (NHPA) as outlined in the Cultural RWG Issue Assessment No. 1. This compliance also applies to any changes to Project facilities that may be considered as a result of relicensing (e.g. changes to recreation use). 2 Previously Issue Nos. 2 & 3.


13 November 1, 2005




Issue Assessment No. 33 Identifying And Protecting Known And Unknown Cultural Resources;

Not Just Project Facilities

1.0 Description of Issue (18 CFR 5.9(b)(1)) An issue was raised about the need to identify and protect known and, as of yet, unknown cultural and/or historical resources within the area controlled by the Tacoma Project. There may be known and unknown cultural and/or historical resources within these Project boundaries. It was questioned whether during the relicensing of the Project there would be the need to identify, protect, and preserve these cultural features. If so, it must also be determined which agency and/or organization will perform this function and which process will be utilized. It was indicated that portions of the Project may be located on private property not owned by Public Service Company of Colorado (PSCo). These sub-issues will be considered during the Section 106 review process. 2.0 Project Effects (18 CFR 5.9(b)(5)) The Tacoma Project facilities and operations will be evaluated as part of PSCo’s compliance with Section 106 of the National Historic Preservation Act (NHPA). A description of the relationship between the Project and historic properties is contained within Cultural RWG Issue Assessment No. 1.

3 Previously Issues Nos. 4, 5, & 7


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Issue Assessment No. 44 What Are The Effects Of Proposed Project Modifications As They Relate To Cultural Resources

1.0 Description of Issue (18 CFR 5.9(b)(1))_ A concern was identified related to the potential effects of any proposed project modifications, improvements, or changes in operations on the cultural resources in the Tacoma Project area. It was asked how any such impacts would be identified and addressed. These issues will be considered during the Section 106 review process. 2.0 Project Effects (18 CFR 5.9(b)(5)) Public Service Company of Colorado (PSCo) is not proposing any changes to the Tacoma Project facilities or operations at this time. However, changes over the next license term (30 to 50 years) may be necessary. By the process outlined in Cultural RWG Issue Assessment No. 1, PSCo will develop a management plan for identifying and implementing future project modifications that may affect historic and cultural resources.

4 Previously Issue No. 6

RECREATION, LAND USE & AESTHETICS RESOURCES

STUDY PLANS

Tacoma Hydroelectric Project ADA Compliance and Recreation Facility Assessment Recreation, Land Use & Aesthetics RWG Issue No. 2

1 November 1, 2005



RECREATION, LAND USE AND AESTHETICS RESOURCE WORK GROUP

Issue Assessment No. 2 and Study Plan ADA Compliance and Recreation Facility Assessment

1.0 Description of Issue (18 CFR 5.9(b)(1)) The Tacoma Project currently has three public recreation use areas at Electra Lake. An issue was raised as to whether the facilities associated with these recreation areas meet current guidelines for accessibility under the Americans with Disabilities Act (ADA). The ADA guidelines include design standards for both new and retrofit outdoor recreational facilities. 2.0 Project Effects (18 CFR 5.9(b)(5)) Public Service Company of Colorado (PSCo) maintains public recreation facilities at Electra Lake. According to the Recreation and Land Management Plan for Electra Lake (2000), two of the picnic tables at the largest of the recreation areas are designed to accommodate wheelchairs, as are the restrooms at the main recreation area (Nunn Recreation Area). Additionally, the Plan states that “handicap parking is available at the main recreation area (Nunn Recreation Area) and at the ESC Clubhouse and Restaurant.” All Project recreation facilities may not currently be ADA compliant and thus may limit access for public use. Project recreation facilities should be reviewed for ADA accessibility and compliance with ADA standards. 3.0 Relevant Existing Information (18 CFR 5.9(b)(4)) Existing information regarding recreation activities associated with the Project area is provided in PSCo’s Pre-Application Document (PAD) and in the References section of this Study Plan. Information regarding the current physical condition of facilities, compliance with ADA, or impacts from recreation is limited and is summarized in the PAD. Additionally, two management plans have been developed by PSCo in coordination with the Electra Sporting Club, the Recreation and Land Management Plan (October 2000) and the Shoreline Management Plan (August 2002). Existing information regarding recreation carrying capacity is focused primarily on facility capacities at developed recreation areas at Electra Lake. These are described in the PAD. 4.0 Need for Additional Information (18 CFR 5.9(b)(4)) The Project recreation facilities, including access routes to these facilities have not been evaluated for ADA compliance nor has the general physical condition of the recreation facilities been reviewed within the recent past. Therefore, PSCo will conduct an evaluation of the developed recreation sites located within the Project Boundary. Additionally, PSCo will identify


2 November 1, 2005

any informal recreation sites within the Project Boundary and record the apparent use and condition of these sites. 5.0 Final Study Plan 5.1 Purpose of Study and Use of Study Results (18 CFR 5.9(b)(1) & 5.9(b)(5) in part) The purpose of this study is to inventory and assess the physical condition of Project recreation facilities, to review their compliance with current ADA standards, and to assess the general effects of the use of these recreation facilities on Project resources. The key objectives of this study are to:

• Inventory and assess the physical condition and access to the Project recreation facilities, including boat launches, picnic areas, restrooms, parking areas, bank fishing and directional signs;

• Assess whether Project recreational facilities comply with current ADA regulations and provide persons with disabilities the opportunity to participate in the Project’s primary recreation activities; and,

• Assess the general effects of recreation use on Project resources in the immediate vicinity of the recreation facilities, including soils, vegetation, and aesthetics.

This study will assist the relicensing proceeding by identifying potential improvements needed at the existing recreation facilities at the Tacoma Project, especially related to ADA accessibility.

5.2 Relevant Resource Management Goals (18 CFR 5.9(b)(2)) Recreational resources in Colorado are managed under an interwoven system of federal, state, and local policies. These policies, in conjunction with regulations, comprehensive plans, and policy directives, provide resource agency staff and regional planning groups with management direction. Relevant resource management goals include the USFS goals within the San Juan National Forest Land and Resource Management Plan (1992). PSCo, in cooperation with the Electra Sporting Club, also has developed guidelines for recreation use as contained in the current Recreation and Land Management Plan for the Tacoma Project. In addition, the La Plata County Development Plan was amended in 2001 and provides general recreation goals and objectives for the county. La Plata County is expected to experience continued growth and consequently increased demand on recreation facilities. Other resource management plans that contain goals and objectives relevant to recreation within the Project vicinity include the following: (a) Federal Energy Regulatory Commission (FERC) Guidelines

FERC will evaluate the recreational resources of all projects under its jurisdiction and seek, within its authority, the appropriate development of these resources, consistent with the needs of the area and to the extent that such development is not inconsistent with the primary purpose of the project. Reasonable expenditures by the licensee for primary recreational


3 November 1, 2005

development, pursuant to an approved plan, including the purchase of land, will be included as part of the project cost. FERC allows the licensee and operators of recreational facilities within the boundaries of the Project to charge reasonable fees to users of such facilities in order to help defray the cost of operating and maintaining such facilities.

(b) 2003 Colorado State Comprehensive Outdoor Recreation Plan (SCORP)

The 2003 Colorado SCORP identifies recreation issues of statewide importance and issues to be addressed through Colorado’s share of the federal Land and Water Conservation Fund (LWCF) grants. The SCORP Local Government Survey was conducted as part of the 2003 SCORP update and includes regionalized recreation issues and needs identified by local agencies involved in outdoor recreation management.

5.3 Relevant Public Interest Considerations (18 CFR 5.9(b)(3)) During the Tacoma Project Recreation, Land Use and Aesthetics Resource Work Group meetings, stakeholders raised concerns that all Project recreation facilities may not currently be ADA compliant and thus may limit access for public use. Project recreation facilities should be evaluated for ADA accessibility and compliance with ADA standards. 5.4 Study Methodology (18 CFR 5.9(b)(6)) 5.4.1 Study Area and Sites The study area for the recreation facility condition assessment includes the area within the FERC Project Boundary. PSCo will conduct facility inventories, facility condition assessments, and an assessment of the adequacy of access to recreation facilities (including ADA compliance) at the Project. These facilities consist of three designated recreation areas at Electra Lake (Table 1). Table 1 Survey sites for the recreation facility assessment.

Recreation Resource Area Study Sites Nunn Recreation Area Nunn parking area Restroom Fish cleaning station Picnic tables and cooking grills Boat ramp ESC Club House ESC Club House parking area Floating dock Westinghouse Parking and Picnic Area Restroom Picnic table Shoreline Trail Access Parking area Bank fishing area Edison Parking and Picnic Area Restroom Picnic table


4 November 1, 2005

Recreation Resource Area Study Sites Shoreline Trail Access Parking area Bank fishing area

The study area for the Project recreation use impact assessment extends to the Project Boundary in most cases, but may be extended an additional 100 feet from the Project Boundary if impacts due to recreation use appear to be Project related. PSCo will perform a general assessment of resource impacts due to recreation use at the Electra Lake recreation facilities and within and adjacent to the FERC Project Boundary at Electra Lake, Aspaas Lake, Forebay Lake, and the Tacoma powerhouse whitewater boating take-out site, as summarized in Table 2 below. Table 2 Survey sites for the recreation use impact assessment.

Recreation Resource Area Study Sites ELECTRA LAKE Reservoir shoreline

a. Nunn Recreation Area Nunn parking area Restroom Fish cleaning station Picnic tables and cooking grills Boat ramp ESC Club House ESC Club House parking area Floating dock b. Westinghouse Parking and Picnic Area Restroom

Picnic table Shoreline Trail Access

Parking area c. Edison Parking and Picnic Area Restroom

Picnic table Shoreline Trail Access Parking area ASPAAS LAKE Reservoir shoreline FOREBAY LAKE Reservoir shoreline

TACOMA POWERHOUSE Lands within FERC Project Boundary specific to whitewater take-out

CASCADE CREEK DIVERSION DAM Area at the diversion dam access road Bridge over flume Review USFS road gates and hazard signage on gates

The study methods have two components: (1) facility inventory and assessment and (2) recreation use impact assessment.


5 November 1, 2005

5.4.2 Recreation Facilities Inventory and Condition Assessment This component will inventory and assess existing conditions at designated Project recreation facilities. Information will summarize facilities; describe maintenance levels; assess ADA compliance; and describe repair, replacement, or upgrade needs. Step 1 – Review Existing Information Existing facility inventory and maintenance information for Project recreation facilities will be reviewed and summarized. This information will be obtained from PSCo and its recreation concessionaire files, and may include counts of amenities (e.g., fire rings, picnic tables), types of sanitation and water system facilities, and maintenance or repair frequencies. Step 2 – Develop Inventory/Assessment and ADA Compliance Forms Inventory, condition, and access route assessment and ADA developed facilities compliance forms proposed to be used on Project recreation are attached (see Attachment A). These forms may be modified based on review of existing information and initial field reconnaissance. Step 3 – Conduct Field Inventory and Condition Assessment of Recreation Facilities Step 3 will include a: (1) facility inventory; (2) recreation facility condition assessment; and (3) an ADA compliance inventory. 5.4.2.1 Facility Inventory PSCo will inventory the number and type of recreation facilities at each Project recreation development at Electra Lake using the form in Attachment A. Photographs will be taken as appropriate. Types of facilities of interest include picnic sites, restrooms, parking spaces, boat launches, and recreation signs. If not currently available, site plans will be developed to locate facilities within each recreation development. All signs will be inventoried and located on maps, and each type of sign will be photographed and documented (e.g., type of sign, condition, text, etc.). The content of signage will be checked for clarity, consistency, and appropriate and understandable wording. 5.4.2.2 Facility Condition Assessment A qualitative assessment of the condition of Project recreation facilities and signs will be conducted using the form included in Attachment A. The four assessment categories are:

• N = Needs replacement (non-functional or has broken or missing components). • R = Needs repair (structural damage or in obvious disrepair). • M = Needs maintenance (primarily cleaning or painting). • G = Good condition (functional and well-maintained).

In addition, photographic documentation of facilities (e.g., picnic tables, fire rings) will illustrate the representative range of conditions at a site.


6 November 1, 2005

5.4.2.3 ADA Assessment Project recreation facilities and signs will be assessed for their compliance with current ADA regulations (ADAAG, 2002; USDA Forest Service Outdoor Recreation Accessibility Guidelines, 2005; UTAP Guidelines). An ADA compliance form developed for items found within developed facilities is contained in Attachment A. Similar forms will be developed for signs and day use facilities, such as picnic areas and boat launches. In addition, Project recreation facilities will be assessed for their ability to provide opportunities for persons with disabilities to participate in the Project’s primary recreation opportunities (including boating and shore fishing). 5.4.3 Recreation Use Impact Assessment This component will assess impacts caused by recreational use on lands within and immediately adjacent to the Project Boundary, including at developed and informal recreation sites. The assessment will be qualitative, focusing on easily observable parameters such as relative amounts of litter, evidence of larger-scale trash dumping, tree cutting, amount of bare ground, vegetation damage and soil erosion, moved access barriers, and proximity to reservoirs, wetlands and streams. Other parameters to be collected, such as shade, visual screening, and views of reservoirs, canyons, and scenic landscapes will help assess the existing type of recreation setting of the site (i.e., solitude versus social focus, boating oriented). The assessment will provide some limited quantitative information such as user-created road and trail lengths. For user created sites (informal sites), information on the available parking sites and number of informal fire rings will be collected. Representative photographs will be taken of each disperse site, trail, road and of areas of significant impact. Four types of information, summarized below, will be collected:

• Spatial information: location of sites and roads and trails. Includes quantitative information such as the number of different types of sites, the length of trails and roads, and the number of dispersed site fire rings. A site map of each will be developed;

• Observational or qualitative assessments (characteristics) of individual sites using

categorical criteria (most of the variables on the forms). These describe each site’s characteristics and provide summaries of the number of sites with certain features (or problems), such as number of informal site fire rings without sufficient vegetation clearing for fire prevention;

• Professional assessments of the number of vehicles or groups that can that can be

accommodated at informal sites; and,

• Professional assessment of the type of recreation opportunity setting an informal site is providing or can provide.

Impact and resource inventory forms are provided in Attachment A. This form may be modified based on reviews of existing information and field reconnaissance.


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5.5 Consistency with Generally Accepted Scientific Practice The proposed methods are adapted from Wildland Recreation: Ecology and Management (Hammitt and Cole, 1987). Methods are designed to address four characteristics of effective impact monitoring variables: (1) meaningful measures of impact; (2) measurement techniques that are reliable (repeatable) and sensitive (will reflect changes in conditions); (3) efficient and cost-effective techniques that can be applied to all sites, and trails regularly; and (4) sites and measurement benchmarks that can be relocated precisely. Variations on these impact assessment protocols have been used on previous relicensing studies (e.g., Upper North Fork Feather River; Pit 3, 4 and 5; Upper American River Project and Tri Dam in California; and Hells Canyon in Idaho). ADA compliance assessment is in accordance with the Architectural and Transportation Barriers Compliance Board’s Americans with Disabilities Act Accessibility Guidelines for Buildings and Facilities; and Architectural Barriers Act Accessibility Guidelines (2004). 5.6 Schedule Field work for the recreation facility and impact inventories and assessments will be conducted during the summer of 2006. 5.7 Level of Effort (18 CFR 5.9(b)(7)) The duration of this study is 4 to 6 days of field work and approximately 4 days of data compilation and report writing. 5.8 Discussion of Alternative Approaches (18 CFR 5.9(b)(7)) Guidelines for evaluating accessibility were suggested at the RWG meeting held on July 14, 2005: (1) The Universal Trail Access Process (UTAP); and (2) USDA Forest Service Outdoor Recreation Accessibility Guidelines. These approaches will be reviewed and the final evaluation forms to be utilized in the field will include aspects of these approaches where appropriate for the Tacoma facilities. 5.9 Data Analysis and Reporting Developed recreation sites, informal recreation sites, and trails will be numbered and mapped at suitable scale within the FERC Project Boundary and study area. Sites, facility conditions, ADA compliance, use impacts, and other resource information will be provided in tabular format. Analysis will highlight sites with specific characteristics or conditions, which will be summarized in tables and graphs. Study results will be presented in the Final License Application and will include data summary tabulation tables and maps that indicate site locations. Major study findings will also be included. Appendices will include final assessment forms and photographs.


8 November 1, 2005

5.10 Relationship to Other Studies The inventory of developed and informal recreation sites will be used to help identify recreation sites to be sampled as part of the Visitor and Resident Use Survey and will be used to understand recreational carrying capacity and demand (Issue Assessment No. 9). Recreation use impact data will also be utilized in several aspects of an evaluation of recreational resources within the Project area. In a broad sense, major findings from this study will be used to assist in developing an understanding of what kinds of changes are occurring on recreation resources and the level of change acceptable, which assists in understanding carrying capacity and needs assessment. The impact analysis (location and photographs) will also be used to assist PSCo in the development of resource management plans related to recreational use (Issue Assessment No. 4). 6.0 References Americans with Disabilities Act Accessibility Guidelines (1991). (Retrieved May 10, 2005. www.access-board.gov/adaag/html/adaag.htm) Architectural and Transportation Barriers Compliance Board (Part II). Americans with

Disabilities Act Accessibility Guidelines for Buildings and Facilities; Architectural Barriers Act (ABA) Accessibility Guidelines; Final Rule. July 23, 2004.

EDAW, Inc and California Department of Water Resources, November 2003. Final Report

Recreational Facility Inventory and Condition Report (R-10). Oroville Facilities Relicensing, FERC Project No. 2100.

Hammitt, W. and Cole, D. (1998). Wildland Recreation: Ecology and Management. New York:

Wiley, 2nd Edition. Hall, T. and Bird, E. (2001). Description of existing recreation areas in the Hells Canyon

Complex and Hells Canyon National Recreation Area. In: Technical appendices for new license application: Hells Canyon Hydroelectric Project. Idaho Power, Boise, ID. Technical Report E.5-9.

PLAE Inc. (1993). Universal Access to Outdoor Recreation: A Design Guide. MIG Communications, Berkeley, CA.

Recreation Supply Analysis Report (September 2002). PacifiCorp Hydro Relicensing Project.

(FERC Nos. 2111, 2213, 2071, and 935). (Retrieved February 2005, http://www.pacificorp.com/Article/Article1343.html).

Sacramento Municipal Utility District Upper American River Project (FERC No. 2101).

Recreation Supply Technical Report. (Retrieved April 15, 2005: http://hydrorelicensing.smud.org /docs/reports/rec supply /RecSupply_tts093004d1.pdf)


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U.S. Department of Transportation Federal Highway Administration: Designing Sidewalks and Trails for Access Part I of II: Review of Existing Guidelines and Practices http://www.fhwa.dot.gov/environment/bikeped/10-chap5.pdf

USDA Forest Service Outdoor Recreation Accessibility Guidelines (Draft) Submitted May 01,

2005. USDA, Director of Recreation, Heritage, and Wilderness Resource Management, Washington D.C. http://www.fs.fed.us/recreation/programs/accessibility/ (Accessed July 20, 2005)

Whittaker, D. and Shelby, B. (2001). Pit 3, 4, and 5 Hydroelectric Project (FERC 233):

Recreation Opportunities & Management Issues in Pit River Canyon and on Lake Britton. Technical Report prepared for PG&E; included in technical documents for license application.


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Attachment A Recreation Facility Condition Assessment Form

ADA Checklist Recreation Use Impact Assessment Form

1 November 1, 2005

Recreation Facility Condition Assessment Form KEY

(N) = Needs replacement (broken or missing components, or non-functional) (R) = Needs repair (structural damage or otherwise in obvious disrepair) (M) = Needs maintenance (primarily cleaning) (G) = Is in good condition (functional and well maintained) (NA)=Not applicable to this project/site

Recreation Facilities Service Facilities Access Facilities Picnicking Sanitary Water Disposal Vehicular Trails Angler Boating/PWC

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SOURCE: EDAW, Inc and California Department of Water Resources, 2003.

2 November 1, 2005

ADA Checklist Location: ________________________ Surveyed Date: ___________________ ADDITIONAL PARKING COMPLY Y N SUBJECT ADA REQUIREMENT ACTUAL COMMENT

Additional Parking 16.17.4

Parking space shall be 12’ minimum Exception: This section does not apply if add’l. parking is part of camp space

Access Aisle 16.17.4.2

Access aisle adjacent to parking space shall be 8’ wide minimum and extend the full length of the parking space

Slope 16.17.4.3

Slope shall not exceed 1:50 or 2% in any direction Exception: Where drainage is necessary, 1:33 or 3% is allowed.

Surface 16.3.1

The surface of the outdoor recreation access route shall be firm and stable. 1. Could a person riding a narrow-tired bicycle

cross the surface easily without wheels sinking into or disturbing the surface?

2. Could a heavy child in a folding umbrella stroller, with small plastic wheels, be pushed across the surface without those small wheels sinking into or distorting the surface?

Access Route Criteria to be developed specifically to reflect: Universal Trail Assessment Process Guidelines/ USDA Forest Service Outdoor Recreation Accessibility Guidelines

PICNIC TABLES COMPLY Y N SUBJECT ADA REQUIREMENT ACTUAL COMMENT

Knee Space 16.5.4

27”high x 30”wide x 19” deep minimum

Toe Clearance 16.5.4

9” h x 24” deep minimum

Clear Ground Space 16.5.4

Clear ground space around accessible seating area

Table Clearance 16.5.5

36” minimum clear ground space surround the useable portion of the table (measured from the seat)

Slope 16.6.6

Slope shall not exceed 1:50 or 2% in any direction. Exceptions: Can be up to 1:33 or 3% for drainage. Does not apply if one or more departure exists.

Surface 16.6.7




Access Routes Criteria to be developed specifically to reflect: Universal Trail Assessment Process Guidelines/ USDA Forest Service Outdoor Recreation Accessibility Guidelines

3 November 1, 2005

FIRERINGS COMPLY Y N SUBJECT ADA REQUIREMENT ACTUAL COMMENT

Clear Floor Space 16.6.3

Clear floor space shall be a minimum of 48” around the firering. Exception: Minimum depth may be reduced to not less than 36” if one or more departure exists.

Fire Surface Height 16.6.4

Fire building surface shall be a minimum of 9” above the ground.

Raised Edge 16.6.5

When using a firering with a raised edge, the combined distance over the edge to the fire-building surface shall be no more than 24”.

Slopes 16.6.6

Slope shall be no greater than 1:50 or 2%. Exceptions: Can be 1:33 max. for drainage purposes. Does not apply if one or more departures exist.

Ground Surface 16.6.7

Surface will be stable and firm.


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COOKING SURFACE, GRILLS, PEDESTAL GRILLS COMPLY Y N SUBJECT ADA REQUIREMENT ACTUAL COMMENT

Cooking Surface Height 16.7.3

15” to 34” Cooking surface shall be from 15” minimum to a maximum of 34” above the ground

Controls 16.7.5 (ADAAG 4.27.1-3) Clear Floor Space

30” by 48” Clear floor space size and approach is 30” x 48” minimum. May be forward or parallel to the object.

Controls 16.7.5 Forward Reach ADAAG 4.2.5

15” to 48” If the clear floor space only allows a forward approach, the forward reach shall be a minimum of 15” to 48” maximum. If high forward reach is over an obstruction, reach shall be as shown in Fig. 5(b).

Controls 16.7.5 Side Reach ADAAG 4.2.6

9” to 54” If the clear floor space allows a parallel approach by a person in a wheelchair, the max. high side reach allowed shall be a minimum of 9” to a maximum of 54”. Fig. 6(a) and 6(b). If the side reach is over an obstruction, it shall be as shown in Fig. 6(c).

Clear Ground Space 16.7.5

48”x 48” All usable portions of the cooking surface shall provide a clear ground space 48” x 48” minimum. Exception: If one or more departures exist, then clear ground space can be 36” minimum.

Clear Ground Space - Slopes 16.7.6

No slope shall be greater than 1:50 or 2%. Exception: For proper drainage slope may be 1:33 or 3% max. The provision does not apply if a departure exists.

Clear Ground Space - Surface 16.7.7





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TRASH & RECYCLING CONTAINERS COMPLY Y N SUBJECT ADA REQUIREMENT ACTUAL COMMENT

Access Routes 16.8.2

Each container shall be connected by an access route. Exception: 50% of the bins in multi-bin containers are exempt.

Clear Ground Space 16.8.2 ADAAG 4.2.4.1

Size and approach. 30” x 48” minimum. Can be forward or parallel approach to the object.

Passing 16.8.2 ADAAG 4.2.2.2

Minimum width for two chairs to pass is 60”

Surface 16.8.3

Surface shall be stable and firm

Slopes 16.8.4

Slopes no greater than 1:50 or 2% in any direction. Exceptions: For proper drainage 1:33 or 3% is allowed. Slope minimums do not apply if one or more departures exist.

Controls & Operating Mechanisms 16.8.5, Heights ADAG 4.27.3

15” to 34” Top of operable part shall be from 15” minimum to a maximum of 34” above the ground

Operation ADAAG 4.27.4

Shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. Force to operate shall be no greater than 5 pounds. Exception: Does not apply to hinged lids and controls designed for large animal exclusion.

Tacoma Hydroelectric Project ADA Compliance

6 November 1, 2005

Recreation Use Impact Assessment Form DEVELOPED AND INFORMAL SITES

VARIABLE NAME QUESTION RESPONSE CHOICES Number Identification number Assigned Name Name of the site Assigned Resource Area Which resource area is the site

located in? 1. Electra Lake 2. Aspaas Lake 3. Forebay Lake 4. Tacoma Powerhouse

Litter In general, how much litter is found at this site?

1. Trace amounts: less than a handful or none 2. Small: about a handful 3. Medium: about a bucketful 4. Large: about a 33 gallon garbage bag full 5. Excessive: over one garbage bag full

Dump Does this site get used as a dump (not just litter from camping)?

1. No, rarely 2. Yes, sometimes (large items such as cars, beds, etc. in evidence)

Tree cutting Does the site show signs of tree cutting for firewood?

1. Low: few signs 2. Medium: some signs, especially lower branches of live trees 3. High: many signs, including excessive cutting of live trees

Access Barriers Are there management- placed barriers to prevent vehicle access to parts of the site and have people moved those barriers?

1. No barriers placed there 2. Barriers there and have not been moved 3. Barriers have been moved

Fire rings and vegetation clearances

How many fires rings do not have appropriate vegetation clearing?

Report number of fire rings that to do not have 8 to 10 feet vertical and 5 feet horizontal vegetation clearance.

Vegetation What is the dominant vegetation type at the site?

Report the % of vegetation types: Forested_____Meadow____Riparian____Other_____

Soil What is the dominant soil type at the site?

Report the % of soil type: Sandy____Clay_____Rock_____Other____________ Comment on drainage:__________________________

Shade Does the site have good shade from rocks or trees?

1. Low: few trees or rocks with shade 2. Medium: some shade trees/rocks for some parts of the day


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3. High: many trees/rocks that offer shade through entire day

Screening Does the site screen groups from each other?

0. Not applicable: single site (not cluster) 1. Low: virtually no screening between sites 2. Medium: some screening 3. High: extensive screening

Reservoir views Does the site have views of the reservoir?

1. Poor or no views 2. Some views, but not high quality 3. High quality views.

Landscape views Does the site offer views of the surrounding landscape?

1. Poor or no views 2. Some views, but not high quality 3. High quality views.

Reservoir proximity Is the site on or off the reservoir? 1. < 100 feet 2. 100 to 200 feet 3. > 200 feet

Reservoir accessibility Is the reservoir easy to access from the site?

1. Criteria to be developed specifically to reflect: Universal Trail Assessment Process Guidelines;

USDA Forest Service Outdoor Recreation Accessibility Guidelines

Creeks Is the site close to other creeks or springs?

1. < 100 feet 2. 100 to 200 feet 3. > 200 feet

ORV Does the site show signs of nearby ORV use?

1. No 2. Yes

INFORMAL SITES ONLY Site Type What type of site is it? 1. Single site

2. Cluster site : Max. No. Groups________Typical No. Groups______

Use Is the site currently used? 1. Yes, but rarely 2. Commonly used

Access Is the site primarily accessible by the road, a trail, or by the reservoir?

1. Road (within 50 feet) 2. Trail from road (and reservoir) 3. From the reservoir


8 November 1, 2005

Existing parking spaces How many vehicle places are available at the site (or at access to the site)?

# Report the number of obviously used parking places if those are distinct.

97 Report 97 if there are indistinct areas that could accommodate less than 7 vehicles

98 Report 98 if an indistinct area could accommodate more than 7

99 Report 99 if there is no parking associated with the site or you don’t know.

Squatter Use Is the site used for long term camping (over 14 days at one time)?

1. Rarely or never used by squatters 2. Occasionally used by squatters 3. Commonly used by squatters

Existing camp use How many parties appear to be able to use the site at one time?

Report number of fire rings that appear separate but “active” in a cluster. Report 1 if the site is a single site.

Bare ground Does the site show signs of extensive use and loss of ground vegetation?

1. Low: small areas around fire rings and tent sites 2. Medium: large areas around fire rings and tent sites 3. Large: large contiguous areas and multiple trails to satellite use areas

Tent availability Does the site have good places for tents?

1. Poor: few, small, low quality 2. Fair: more than one, better quality 3. Good: more than two sites with flat, un-brushy

areas. Hiking Trail Lengths Length of trail in feet?

Comments (i.e., user impacts, sensitive areas, general observations, etc.):

Adapted from Whittaker & Shelby (2001).

Tacoma Hydroelectric Project Recreation and Shoreline Management Plans Recreation, Land Use & Aesthetics RWG Issue Nos. 4 and 9

1 November 1, 2005



RECREATION, LAND USE AND AESTHETICS RESOURCE WORK GROUP

Issue Assessment Nos. 41 and 92 and Study Plan Recreation and Shoreline Management Plans

1.0 Description of Issue (18 CFR 5.9(b)(1)) Electra Lake is a pristine body of water known for its fishing, its scenic setting, and the quality of the recreation experience. An issue was raised about the appropriate levels of use of and public access to Electra Lake under the next License. These issues relate to defining the proper overall future management of the lake related to public access and resource protection. An issue was raised as to the need for documenting the current peak recreational use of Electra Lake. 2.0 Project Effects (18 CFR 5.9(b)(5)) The Tacoma Project’s primary storage reservoir, Electra Lake, is a valuable and largely undisturbed body of water in a highly scenic setting, supporting an excellent cold water fishery. The Electra Sporting Club (ESC) and Public Service Company of Colorado (PSCo) developed a Recreation and Land Management Plan (2000) and Shoreline Plan (2002) in consultation with resource agencies to develop guidelines for the enhancement of the recreational, environmental, and aesthetic resources of Electra Lake. These plans are intended to guide daily and long-term management of recreation facilities and shoreline management within the Project. Additionally, these plans provide guidance for long-term use and monitoring of this use. Electra Lake will continue to be a highly valuable resource in the future and will require updated Recreation and Shoreline Management Plans to guide the management of the natural resources in the Project area. Another factor to be considered in these plans will be the development of procedures and appropriate level of enforcement necessary to control unauthorized access and use of Project facilities. 3.0 Relevant Existing Information (18 CFR 5.9(b)(4)) Existing information regarding recreation activities in the Project area is provided in PSCo’s Pre-Application Document (PAD) Volume 1, and listed in the References section of this Study Plan. Only a limited amount of information currently exists regarding recreation visitor characteristics, attitudes, and preferences. Recreation use levels at the Project are based on visitor and ESC records collected since 1996. These are summarized in the Pre-Application Document (PSCo, 2005). Additionally, two 1 Originally Issue Nos. 4 and 16 in the Unedited Issues List. 2 Issue No. 9 will be addressed within the context of this study plan; see Attachment A for complete Issue Description and Projects Effects description.


2 November 1, 2005

management plans have been developed by PSCo in coordination with ESC: the Recreation and Land Management Plan (October 2000) and the Shoreline Management Plan (August 2002). Existing information on carrying capacity is focused primarily on recreation facility capacities at developed recreation areas at Electra Lake. These are also described in the PAD (PSCo, 2005). 4.0 Need for Additional Information (18 CFR 5.9(b)(4)) Information collected within this study will be used to fill the gaps in the existing information about recreation user attitudes towards recreation opportunities at the Project and to develop additional data on carrying capacity, recreation needs, and potential recreational use impacts. This information will assist in the development of updated Recreation and Shoreline Management Plans for Electra Lake. 5.0 Final Study Plan 5.1 Purpose of Study and Use of Study Results (18 CFR 5.9(b)(1) & 5.9(b)(5) in part) The purpose of this study is to support and update the current Recreation and Shoreline Management Plans for Electra Lake. Specifically, this study will take a stepwise approach to defining a quality visitor experience and appropriate recreation opportunities, carrying capacity, and management options for future management of recreation resources at Electra Lake. This Study Plan will address Issue Assessment Nos. 4 and 9 developed by the Recreation, Land Use and Aesthetics Resource Work Group (RWG). This study will also make use of information developed as part of Issue Assessment No. 5. The study plan is divided into four components as follows: Component 1: Visitor and Resident Use Assessment The purpose of Component 1 is to describe the current use levels, preferences, attitudes, and characteristics of primary recreation user groups using Electra Lake. This component will make use of the results of the study developed as part of Issue Assessment No. 5, “Maintaining a Quality Fishing Experience on Electra Lake; Assessing Day Use Fee Structure” (refer to Issue Assessment No. 5 for a detailed description of that study plan approach and design). Component 2: Carrying Capacity Assessment The purpose of conducting a carrying capacity assessment is to determine the maximum level of sustained recreation use that can occur at Electra Lake while protecting the area’s ecological, cultural, and recreation resources, consistent with the safe and effective operation of the Tacoma Project. Specific objectives for this component of the study include:

a. Distinguishing between facility, ecological, and social carrying capacities and assessing which are likely to be “limiting factors” for recreation in different areas or seasons;

b. Selecting indicator variables for important social, ecological, or facility conditions;

c. Assessing relationships between use levels, appropriate use, and key indicators; for some impacts, this will integrate information from the recreation inventory, spot count, or user survey studies.


3 November 1, 2005

d. Developing standards for indicator variables based on user survey results, literature review, and PSCo’s management objectives;

e. Defining recreation capacities for Electra Lake considering ecological impacts and health, and/or experience quality; and,

f. Identifying advantages and disadvantages of future management options. Component 3: Recreation Demand Assessment The purpose of Component 3 is to incorporate the results of Issue Assessment No. 9, Development Pressure into recreation and shoreline management planning. The study plan associated with addressing Issue Assessment No. 9 has been combined into this study plan description. The results of the recreation demand assessment will inform the relicensing by: (1) describing existing recreation use in the Project area; (2) identifying Project recreation activities with high, existing unmet (or latent) demand; (3) identifying particular recreation activities that are expected to have significant growth in demand; and (4) identifying the relative regional significance and uniqueness of Project area recreation resources. Component 4: Needs Assessment The primary purpose of the Needs Assessment is to integrate findings from Component 3, the Recreation Demand Assessment; Issue Assessment No. 2 which includes an inventory and assessment of recreation facilities and use impacts; Issue Assessment No. 5, Recreation Visitor and Resident Use Surveys; and Recreation Carrying Capacity to systematically prioritize possible management actions that would protect or enhance Project recreation opportunities while minimizing potential recreation use impacts on natural resources and Project operations. Specific objectives of this component are to:

a. encapsulate and integrate all recreational study findings in order to characterize the existing condition of Project recreation opportunities and to identify important recreation issues, including those identified during the study development process;

b. develop a prioritized list of potential actions to address Project recreation issues.

This list will be based on criteria such as effectiveness, appropriateness, public acceptability, feasibility, and cost;

c. work with Relicensing participants to review a set of recreation management

options that would be appropriate to include as Project recreation enhancement measures for the new license.

5.2 Relevant Resource Management Goals (18 CFR 5.9(b)(2)) Recreational resources in Colorado are managed under an intricate system of federal, state, and local policies. These policies, in conjunction with regulations and comprehensive plans provide resource agency and regional planning groups with management guidance. Where relevant to specific sites at the Project, resource management goals would include the USFS goals within the


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San Juan National Forest Land and Resource Management Plan (1992). PSCo in cooperation with the Electra Sporting Club (ESC) has objectives described in its current plans and these will be incorporated into the revised plans where appropriate. In addition, the La Plata County Development Plan was amended in 2001 and provides general recreation goals and objectives for the county. La Plata County is expected to experience continued growth and consequently increased demand on recreation facilities and parks. Other relevant plans that contain goals and objectives relevant to recreation include the following: (a) Federal Energy Regulatory Commission (FERC) Guidelines

FERC will evaluate the recreation resources of all projects under its jurisdiction and seek, within its authority, the appropriate development of these resources, consistent with the needs of the area and to the extent that such development is not inconsistent with the primary purpose of the project. Reasonable expenditures by the licensee for primary recreational development, pursuant to an approved plan, including the purchase of land, will be included as part of the project cost. FERC allows the licensee and operators of recreational facilities within the boundaries of the Project to charge reasonable fees to users of such facilities in order to help defray the cost of operating and maintaining such facilities.

(b) 2003 Colorado State Comprehensive Outdoor Recreation Plan (SCORP) The 2003 Colorado SCORP identifies recreation issues of statewide importance and which of those issues will be addressed through Colorado’s share of the federal Land and Water Conservation Fund (LWCF) grants. The SCORP Local Government Survey was conducted as part of the 2003 SCORP update and includes regionalized recreation issues and needs from local agencies involved in outdoor recreation management.

5.3 Relevant Public Interest Considerations (18 CFR 5.9(b)(3)) The issue concerning the appropriate levels of use of and public access to Electra Lake for the next license term was raised in the Recreation, Land Use and Aesthetics Resource Work Group. This issue is relevant to defining the appropriate future management of the lake related to public access and resource protection. Updated shoreline and recreation use plans are intended to direct guide daily and long-term management of recreation facilities and shoreline management within the Project. Additionally, these updated plans will provide guidance for long-term use and monitoring of recreational visitor and resident use. 5.4 Study Methodology (18 CFR 5.9(b)(6)) This study plan encompasses four components: Visitor and Resident Use Assessment (see Issue Assessment No. 5), Carrying Capacity, Recreation Demand Assessment, and Needs Assessment. The methods to be used for each are described below: 5.4.1 Study Area For the Visitor and Resident Use Assessment (Component 1), the study area includes the recreation areas listed in Table 1. As noted, in addition to recreation visitors to Electra Lake, ESC residents will also be surveyed directly. The study area for assessing regional uniqueness


5 November 1, 2005

and significance of the Project’s recreation resource opportunities will be determined from specific questions on the visitor survey. Of particular significance for the Visitor Use Study will be the following two questions: (1) the visitor’s area of residence; and (2) alternate recreation resource areas within the region that recreation users visit for similar recreation experiences. Table 1. Study Sites for Resident and Visitor Surveys

Recreation Resource Area Study Sites ELECTRA LAKE Reservoir shoreline

a. Nunn Recreation Area Nunn parking area Electra Lake surface via boat Picnic area Boat ramp Floating dock b. Westinghouse Parking and Picnic Area Picnic area

Parking area Shoreline fishing access area c. Edison Parking and Picnic Area Picnic area

Parking area Shoreline fishing access area ASPAAS LAKE Reservoir shoreline FOREBAY LAKE Reservoir shoreline ELECTRA LAKE RESIDENTS Electra Sporting Club Members

The study area for the Carrying Capacity Assessment (Component 2) is the area within the FERC Project Boundary adjacent to Electra Lake. The study area for the Demand Assessment (Component 3, Issue Assessment No. 9) includes the area within the Project Boundary and the study sites in Table 1. Statewide or regional information about current unmet demand and potential future demand will be applied to these same areas. The Needs Assessment will synthesize results from Components 1, 2 and 3, thereby incorporating the study areas mentioned previously. 5.4.2 Study Sites PSCo proposes to conduct the recreation study Components 1 through 4 at the sites listed in Table 1. This list contains both developed and informal user created recreation sites. Researchers will conduct field reconnaissance, review available aerial photography, and consult with recreation users and stakeholders to determine if recreation sites should be added or deleted from this list.


6 November 1, 2005

5.4.3 Methodology 5.4.3.1 Component 1-Visitor and Resident Use Assessment This approach to obtaining the information for this assessment is described in Recreation Land Use and Aesthetics Issue Assessment No. 5, including methodology for conducting both the Visitor and Resident Use Surveys (Component 1), the development of the survey instruments, the survey approach, and target sample sizes from the survey populations (visitors and residents). 5.4.3.2 Component 2-Carrying Capacity Assessment Carrying capacity is an “umbrella” concept used to address overuse or visitor impact issues. It generally refers to the maximum use level that can occur in an area without degrading biophysical resources or recreation experiences. As with other resource management issues, capacity depends on management objectives and more specific standards that define impact acceptability, both requiring evaluative judgments (Shelby & Heberlein, 1986). Researchers distinguish four types of capacities in recreation settings:

• Physical capacity refers to the space needed to engage in a particular recreation activity. Assessing physical capacities conceivably make sense if there are spatial constraints (e.g., number of people on a wildlife viewing platform), but it is usually a hypothetical calculation that sets an upper bound by explaining how many users can “fit” in an area. Physical capacity will not be a focus of this study.

• Facility capacity refers to the number of people or groups that a developed site or facility

is designed to handle. For example, there are limits to the number of groups that can use a developed campground with distinct sites. Facility capacity is generally associated with site planning rather than larger areas as in this study. Facility capacities, however, can interact with other capacity issues, by attracting and concentrating use. This study will review existing facility capacities for adequacy and integrate that information with other capacities in the area.

• Ecological capacity refers to biophysical impact issues such as the amount of use that can

occur without unacceptable impacts on plants, wildlife, soil, water, air quality, and cultural resources. There is considerable research on many of these impacts, but they are often linked to types rather than amounts of use, and may often be addressed through site hardening, education, or regulations instead of use limits (Kuss et al., 1990; Cole, 1994). The study will broadly examine potential links between recreation uses and biophysical impacts at Electra Lake, Aspaas Lake, and Forebay Lake.

• Social carrying capacity refers to impacts that impair or alter human experiences in

recreation settings. Standards are required to define how much interaction, competition, conflict, or signs of use are acceptable for a given type of recreation experience. Potential impact indicators (relevant for this study) might include perceived crowding, groups or boats within view, or spacing between groups or boats. The study will broadly examine potential links between recreation uses and these social impacts at Electra Lake, Aspaas Lake, and Forebay Lake.


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Several recreation planning frameworks have been developed to integrate these types of capacities and address the range of impact issues, including Limits of Acceptable Change (LAC) (Stankey et al., 1985), Carrying Capacity Assessment Process (CCAP) (Shelby and Heberlein, 1986), Visitor Impact Management (VIM) (Graefe, Kuss, and Vaske, 1990), and Visitor Experience and Resource Protection (VERP) (NPS 1997). These frameworks share several common features, and they focus on the need to: (1) define management objectives for an area; (2) set standards for key indicators (variables that gauge the health of resources or the quality of experiences); and (3) link management actions as part of specifying an area’s recreation capacity These concepts form the basis for capacity determinations in this study. Facility Capacity Capacities will be assessed for Electra Lake, Aspaas Lake, and Forebay Lake. Major steps in the assessment include:

• Describe management goals for each facility based on existing information, reconnaissance, and facility design. These will be professional judgments that clarify the type of recreation uses each facility is designed to handle.

• Specify indicator variables related to important facility conditions. In most cases, the

relevant variable will be “percent occupancy” (e.g., the number of parking spaces, sites, or picnic tables that are being used divided by the total number that exist). However, other relevant indicators may be considered (e.g., waiting time at launch areas, people per restroom facility).

• Examine relationships between occupancy rates and perceived crowding scores (where

applicable for Electra Lake only) for specific facilities and consider other available information to help develop reasonable occupancy standards.

• Compare occupancy levels with standards to assess whether existing or projected use

levels are likely to be “below capacity,” “approaching capacity,” “at capacity,” or “over capacity.”

• Review facility improvements or other management actions that could be used to reduce

impacts or increase capacities. Ecological Capacity The study will review ecological or signs-of-use impact issues in reservoir areas and discuss management actions to address these issues. A separate study (see Issue Assessment No. 2) will document existing conditions regarding some of these impacts, and other resource studies are expected to address several other ecological issues (e.g., wildlife, existence of sensitive or endangered plants, vegetation impacts). Recreation survey questions may also ask users to comment on some signs-of-use impacts (e.g., litter, human waste).


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Ecological impacts to be noted include: • Soil compaction at non-hardened sites • Soil erosion at sites, along trails, or at shoreline access areas • Litter • Human waste • Vegetation damage/cut trees • Tramping of endangered or sensitive plants • Wildlife disturbance • Extent of user-created trails • Off Road Vehicle (ORV) impacts

Based on a review of literature (e.g., Cole 1994; Marion, 1991; 1994) and consultation with other resource specialists, this study will qualitatively assess whether current use is below, approaching, at, or over capacity relative to these issues at recreation sites. Discussion will also examine management actions for addressing these impacts, most of which are likely to modify types of use or behaviors rather than adjust the numbers of users. Social Capacity Social capacities will be assessed for Electra Lake and Forebay Lake, focusing on the water surface and shoreline. Capacity/conflict issues will also be assessed along associated roads/trails. Major steps in the assessments include:

• Describe management goals for Electra Lake and Forebay Lake, using existing information, reconnaissance, and facility design. These will be professional judgments that clarify the types of recreation opportunities provided at each area. Descriptions will apply the Recreation Opportunity Spectrum (ROS) framework commonly used in U.S. Forest Service planning.

• Specify indicator variables related to important social conditions. Key variables are

expected to include perceived crowding; groups, people and/or boats in view at one time at the lake and trail; spacing between groups, people, and/or boats at Electra Lake; type, location, and timing of conflicts.

• Develop reasonable standards for indicator variables. Standards will be based on

professional judgment after field reconnaissance, a review of relationships between use and crowding, or other relevant information.

• Compare the existing conditions of social capacity indicator variable with standards to

assess whether existing use levels are “below capacity,” “approaching capacity,” “at capacity,” or “over capacity.”

• For conflict issues on and near Electra Lake, information will describe the type, location,

and timing of conflicts. This effort will identify:

o Groups and types of use involved in the conflicts;


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o Apparent sources of conflict such as resource impacts, experiential impacts, or safety;

o Temporal elements (when conflicts occur); o Spatial elements (where conflicts occur); and, o Extent to which the conflict appears to be interaction-based or values-based.

• Consider management strategies that could be used to reduce impacts or conflicts, or increase capacities. This will include assessing support or opposition among recreation users and/or residents.

PSCo proposes the following indicator variables for social capacity assessments at Electra Lake and surrounding recreation facilities within the Project area. Perceived Crowding: Most recreation experts recognize a difference between density (i.e., contacts) and crowding. Density is a descriptive term that refers to the number of people per unit area. It is measured by counting the number of people and measuring the space they occupy, and it can be determined objectively. Crowding, on the other hand, is a negative evaluation of density or encounters; it involves a value judgment about the specified density number. To emphasize the evaluative nature of the concept, the term perceived crowding is often used. For the purpose of clarity, the term crowding should not be substituted for high density or large numbers of people. Using this term confuses the objective impacts of larger numbers of people with the subjective evaluation of those impacts. Perceived crowding combines descriptive information (the density or encounter level experienced by the individual) with evaluative information (the individual's negative evaluation of that density or encounter level). When people evaluate an area as crowded, they have at least implicitly compared the condition they experienced (the impacts) with their perception of what is acceptable (their standards). If they conclude that the area is crowded, the existing conditions exceed their definition of a standard (one criterion for an area being over capacity). Researchers have developed a relatively simple measure of perceived crowding (Heberlein & Vaske 1977). The question asks people to indicate how crowded the area was at the time of their visit on a 9-point scale:

Not at all crowded

Slightly crowded

Moderately crowded

Extremely crowded

Reservoir water surface 1 2 3 4 5 6 7 8 9 Two of the 9 points on the crowding scale label the situation as uncrowded, while the remaining 7 points label it as crowded to some degree. The scale will be analyzed from various perspectives but has traditionally been collapsed into a dichotomous variable that provides a meaningful break point between those who labeled the situation as not at all crowded (scale points 1 and 2, a positive evaluation) and those who labeled the situation as slightly, moderately, or extremely crowded (scale points 3 through 9, a negative evaluation).


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This item and analysis strategy has been used in over 200 evaluation contexts, and a comparative analysis of scores has led to the development of five general capacity assessment categories (Shelby et. al, 1989):

Under 35% No crowding: Relatively unique low-density experiences 36 to 50% Low normal: Unlikely to be a problem 51 to 65% High normal: experiences approaching capacity 66 to 80% Over capacity: management probably needed Over 80% Greatly over capacity: manage for high density or a sacrifice area

This study will ask lake and trail users (through the Visitor and Resident Use surveys, Component 1) to report perceived crowding at the facilities at Electra Lake (surface and shoreline), including parking lots, trails for shoreline fishing, picnic areas, shoreline access etc. These scores can be compared to each other, to other recreation settings where crowding has been studied, and to the “rule of thumb” standards identified above. Boats, people, and/or groups in view at one time at Electra Lake These indicators may be useful for the lake because most of the area can be viewed from key locations. Accordingly, users may be aware of (and able to evaluate) the number of boats at one time during the on-site user survey. Similarly, they may be able to evaluate number of people or groups in specific shoreline areas. Statistically comparing existing and tolerable numbers (e.g., via t-tests or ANOVA) can help determine if there is an “impact problem,” and tolerances can be used to assess whether there is agreement for different types of opportunities (settings) or different types of users. Item format and analysis strategies follow from established research traditions (Shelby et al, 1996), and will allow discussion of norm prevalence (the percent who specify a preference), type of norm (single versus multiple tolerance), and the extent of agreement. Based on these characteristics and other relevant information, professional judgments will be used to recommend standards for various opportunities, which will be compared with existing use levels to determine if the lake surface is under, approaching, at, or over capacity. Spacing of boats, people, and/or groups at Electra Lake Indicators may also focus on spacing requirements of boats on water surfaces or people/groups along Electra Lake shoreline. Standards for these indicators may be developed from other studies or resource agencies for similar activities and recreation settings. Different standards would also make different assumptions about the type of use and the type of experience provided. This method allows comparisons with actual use densities to help characterize whether the lake is below, at, or over capacity. Capacity/conflict indicators along shoreline and trails Based on comments by stakeholders, there are potential conflicts between different types of recreation users (e.g., hikers and mountain bikers, hikers and ORV users, people with and without dogs), or between landowners (residents) and recreation users. Indicator variables for resident-user conflicts will be developed by discussions with residents and visitors. Indicator variables for between-user conflicts will be developed from previous research or field reconnaissance, and related items may be included on the visitor surveys.


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5.4.3.3 Component 3-Demand Assessment (RWG Issue Assessment No. 9) This study has four components: (1) summary of existing recreation use; (2) existing unmet demand assessment; (3) future demand assessment; and (4) regional uniqueness and significance assessment. 5.4.3.3.1 Existing Use Assessment: The Existing Use Assessment will be undertaken in

conjunction with RWG Issue Assessment No. 5. The approach is summarized below. Step 1 – Data collection To estimate recreation use at identified recreation sites (Table 1), PSCo will conduct a roving use survey using a stratified two-stage (geographic and temporal) probability sampling approach (Mavestuto, 1996. Pollock et al. 1996). The sample will be stratified by recreation resource areas (Table 1), type of day (weekdays, non-holiday weekends, holiday weekends, and opening fishing weekends), and time of day (mornings from 8 am to noon; afternoon from noon to 4 pm; and evenings from 4 pm to 8 pm). Sampling frequencies for each stratum will be based on estimated existing use levels developed from existing use data in the Pre-Application Document (PSCo, 2005) and reconnaissance field visits. During the roving survey, at each site a surveyor will count the number of vehicles, trailers, boats, people, day groups, and the types of activities. The surveyor will also administer a recreation on-site visitor questionnaire survey to randomly selected recreation visitors (see Visitor and Resident Use Survey, Issue Assessment No. 5 for details about the survey protocol). Project visitation from the ESC members will be captured during the existing recreation use survey and from responses from the recreation visitor and resident surveys. Step 2 – Estimate of at-one-time (AOT) and Daily and Season recreation days (RDs) For each recreation site (or cluster of dispersed sites) researchers will calculate the average and maximum existing use levels for recreation parameters (e.g., people, vehicles, groups, facility occupancy) by day type (e.g., weekend, weekday, holiday) and time period (e.g., morning, afternoon, evening) during the surveyed recreation season. In addition for each recreation site or cluster of sites, researchers will calculate the frequency distribution of observed recreation activities during the surveyed recreation season. The analysis will include estimates of existing annual day visits to recreation resource areas in recreation-days (RDs). An RD, as defined by FERC, equals a visit to an area for recreation purposes for any portion of a 24 hour period. To estimate RDs, researchers will use information on group size, number people in vehicles, and length of stay developed from the visitor survey findings.

5.4.3.3.2 Existing Unmet Demand Assessment: Existing recreation use does not always represent the total existing recreation demand because there may be constraints that limit participation. While there are many potential constraints on


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recreation use (e.g., lack of free time, cost, geographic distance, lack of skills or equipment), a subset of participation constraints may be closely associated with site-specific management (e.g., limited access to lands or water, use limits or full occupancies at facilities, Project operations that eliminate or diminish the quality of opportunities, or the lack of information about available recreation opportunities). To assess the general level of unmet demand for Project recreation resources, PSCo will perform the three steps described below.

Step 1 – Assess statewide and regional unmet recreation demand information Review and summarize relevant information from the 2003 Colorado SCORP, which among other things, identifies recreation issues of statewide importance and which of those issues will be addressed through Colorado’s share of the federal Land and Water Conservation Fund (LWCF) grants. In addition, a review of the SCORP Local Government Survey results, which include regionalized recreation issues and needs from local agencies involved in outdoor recreation management, will be reviewed. If available, other sources of Project area and region information will be reviewed. The focus of this assessment will be to identify possible recreation activities with substantial unmet demand with a qualitative discussion of participation constraints. Step 2– Collect unmet Project recreation demand information from visitor and resident surveys Researchers will collect additional information on unmet recreation demand from Project visitors and residents in the proposed questionnaire surveys [see Visitor and Resident Use Survey Issue No. 5]. These surveys will ask visitors if there are reservoir or river recreation activities they are interested in participating in, but can’t because of some form of barrier. Step 3 – Identify potential activities with high unmet demand within the Project Based on the review of unmet demand information derived from Colorado SCORP and SCORA, the recreation visitor survey, and Project monitoring data, potential activities with high unmet demand at the Project will be identified. Analysis will also attempt to identify likely barriers or constraints to participation, and whether those are related to Project operations or recreation management decisions.

5.4.3.3.3 Future Recreation Demand Assessment This element of the study will project future recreation use at the Project over the estimated period of the new License (40 to 50 years). Obviously, projecting future use is a speculative activity, especially over a 40 to 50 year period. These projections, though, can be useful for general planning purposes to identify potential management issues that may occur in the future. This approach will include the following steps:

Step 1 – Review existing recreation use trends Past use often helps predict future use. Researchers will review trends of actual Project area recreation use from Project monitoring reports for Electra Lake, including issuance of fishing permits and turn-away days; Colorado fishing license sales; ORV green stickers and boating vessel registrations for the counties where the majority of Project visitors originate from; local fishing guide activity; and recreation equipment sales.


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Step 2 – Review existing population and recreation activity participation projections Researchers will summarize existing information on projections of future demand from the Colorado Division of Local Affairs on projected population growth rates of county where the majority of the Project visitors originate; and from the U.S. Forest Service (i.e. Cordell, et. al 1999; 2001) and other appropriate sources future projections. Step 3 – Review reasonably foreseeable events that may influence future use Reasonably foreseeable events in the watersheds may influence recreation use in the watershed over the license period. If an event is determined to be reasonably foreseeable, a qualitative assessment will be made of its potential affect on future recreation use.

Step 4 – Estimate future recreation use over the next License period Based on historical trends, future growth projections, and likely foreseeable actions in the watershed, professional judgment will be used to estimate recreation use and facility utilization over the expected term of the new license (i.e. 40 to 50 years). These estimates must be considered very speculative and will only provide a general indication of how recreation use is expected to change over the license period.

5.4.3.3.4 Regional Uniqueness and Significance Assessment: The final part of Component 3 is designed to assess the regional uniqueness of the Project‘s primary recreation opportunities in three steps.

Step 1 – Review results of visitor questionnaires Researchers will review the results of the recreation visitor and resident use survey to identify Project’s primary recreation activities. It is anticipated that fishing, boating, hiking and picnicking will likely be among the top recreation activities at the Project. Step 2 – Identify regional recreational opportunities Researchers will identify the geographic draw of the Project’s top primary recreation opportunities. This will be done by assessing the geographic extent of visitors’ origins and location of the alternative recreation resource areas where visitors participate in their primary recreation activities. Researchers will identify regional alternatives from guidebooks, on-line web resources, state and national park information, USFS information, and county magazines and tourism information. Step 3 - Assess uniqueness of the Project-related recreation opportunities For the Project’s most popular primary recreation activities, PSCo will identify if these recreation opportunities are of local, regional or state significance. In addition, text will describe what is unique and special about the most popular recreation opportunities based on information from focus groups and other regional resource information.

Assessing existing recreation use through a combination of observation and questionnaire surveys is a common practice for large geographic areas that contain multiple accesses to desired recreation use areas (Malvestuto 1996, Pollock et. al. 1994, Forest Service 2000, Forest Service 1995). In addition, assessing future recreation demand through an evaluation of existing use, demographic data and participation trends and projections in the region is common practice (Kelly & Warnick, 1999). In addition, this methodology has also been utilized in recent


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relicensing processes for the Upper American River, the South Feather Water & Power, and the DeSabla-Centerville projects. 5.4.3.4 Component 4-Needs Assessment The Recreation Needs Assessment study will provide a qualitative assessment, utilizing professional judgment of the recreation needs based on integrating the findings from the other components of this study and other related studies. The assessment will involve a four-step process in which relevant Project recreation opportunities are described, relevant Project recreation issues are identified, potential actions to address Project-related issues identified, and proposed License PM&E measures are proposed. These steps are discussed below. Step 1. Summarize Project-related recreation opportunities at recreation resource areas The first step in the needs assessment is to integrate recreation study findings into a summary of Project-related recreation opportunities at recreation resource areas. The existing condition of the recreation opportunity as well as the likely condition of the opportunity over the license term will be described. Parameters to be discussed include such items as activity participation rates, satisfaction levels, facility needs, regional significance, resource impacts, and existing and likely future capacity availability. Step 2. Summarize major recreation issues for each recreation resource area Based on the existing and projected license term and the conditions of recreation opportunities within recreation resource areas, the recreation issues within the recreation resource area will be identified. This may include such items such as crowding, conflicts between user groups, likely facility needs over the license term, or various types of impacts resulting from recreation use. Recreation needs issues will be assessed by comparing recreation supply and demand study results. Step 3. Develop a set of reasonable possible actions to address Project-related issues A reasonable set of prioritized actions that address Project-related recreation issues will be developed. In some cases, several alternative actions are likely to be developed to address the same issue. The following criteria will be used to identify reasonable proposal actions and to prioritize these actions (Whittaker, Vaske, and Manfredo, 2002):

• Effectiveness: How effective is the proposal at addressing issues? For example, will interpretive signage and visitor information concentrate use away from unauthorized access on private lands? Will the provision of hardening and vehicle barriers at Electra Lake minimize impacts from vehicles or unauthorized parking?

• Appropriateness: How appropriate is the proposal for the given management setting (i.e.

Recreation Opportunity Spectrum (ROS) class setting)? For example, fencing off an area closed to social trail and ORV access might address unauthorized access issues, but it might also change the area to a more developed setting.

• Public Acceptability: How likely is it that recreation users will support the actions? For

example, a ban on unauthorized access to the lake shoreline may diminish residents concerns and impacts, but might not find broad support from some user groups.


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• Feasibility and Cost: How feasible is it to implement the proposal given administrative policies, laws, land ownership, and costs?

Such actions could potentially fit into categories such as new development, improvements to existing developments, Project operation modifications, and public information (i.e. about project operations, interpretation, and/or education and regulations to reduce impacts or conflicts). Step 4. Identify appropriate PM&E measures The last step of the process is to identify a set of Project mitigation and enhancement measures, if appropriate, to be included with the new FERC license for the Tacoma Project. Integrating study results, comparing supply and demand study findings, and identifying resource impacts is a standard practice on many relicensing). The proposed methods are consistent with approaches utilizing visitor frameworks such as the Visitor Impact Management (VIM) (Graefe, Kuss, & Vaske, 1990) and Limits of Acceptable Change processes. In addition, the proposed methods incorporate concepts from the Recreation Opportunity Spectrum (ROS) (Clark and Stankey, 1979), and subsequent Water Recreation Opportunity Spectrum (WROS) frameworks (Haas, Aukerman, Lovejoy, & Welch, 2004). 5.5 Schedule Visitor spot counts will begin during the summer of 2005 to assist in identifying use conflicts, visitor counts, and survey locations. Field work for the recreation assessments will be conducted from May 2006 when sites are first accessible through December 2006 (Table 3). The carrying capacity assessment will begin in fall 2005 with the refinement of carrying capacity questions to be included in the recreation visitor survey. From May 2006 through December 2006, the general user (Visitor and Resident Use Survey Assessment), existing use (Recreation Demand Assessment), and various ecological field surveys will be conducted. Results from these recreation and natural resource studies will be used in the analysis of the carrying capacity assessment and report, which will occur from winter 2006 through spring 2007. Table 3: Components 1-4 Study Schedule

2005 2006 2007

Study Activity for Components W

inte

r

Sprin

g

Sum

mer

Fall

Win

ter

Sprin

g

Sum

mer

Fall

Win

ter

Sprin

g

Sum

mer

Fall

Field Reconnaissance Finalize Survey Instruments On-Site & Mail-back Visitor/Resident Use Surveys Analysis Report Preparation


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5.6 Level of Effort (18 CFR 5.9(b)(7)) 5.6.1 Component 1-Visitor and Resident Assessment: The duration of these assessments entails approximately 50 days of field work (May through December) and approximately 15 days of summary and report writing. The estimate considers the following approach:

• Recreation visitor and resident use survey field work is performed in conjunction with the existing use recreation survey proposed for the Recreation Demand Assessment Plan (Component 3).

• In low use recreation areas, one recreation surveyor likely can perform both the

recreation visitor surveys and the existing use recreation spot counts in the Recreation Demand Assessment (Component 3).

5.6.2 Component 2-Carrying Capacity Assessment The duration of this assessment entails approximately 21 days of analysis, which includes time for coordination with other resource areas and studies, 8 days of drafting a summary report, and 5 days for final draft and consultation. 5.6.3 Component 3-Recreational Demand Assessment The duration of this assessment entails approximately 14 days of research and analysis, 5 days of drafting a summary report, and 5 days for final draft and consultation. 5.6.4 Component 4-Needs Assessment The duration of this assessment entails approximately 10 days of research and analysis, 5 days of drafting a summary report, and 4 days for final draft and consultation. 5.7 Discussion of Alternative Approaches (18 CFR 5.9(b)(7)) No alternatives have been proposed by others at this time. 5.8 Data Analysis and Reporting The Visitor and Resident Use Surveys will provide a substantial source of information about visitor use patterns, characteristics, preferences, and perceptions at Electra Lake and surrounding recreation facilities within the Project. Visitor and Resident Use survey responses will be analyzed taking an “opportunity perspective” by grouping users who are doing similar activities in similar geographic areas. Information will be presented in tabular or graph format that indicates the number and percent frequency of visitor survey responses. The study objectives and issues will be addressed through analysis of the responses to visitor and resident use questionnaires. Survey responses will be coded, edited and entered for analysis in


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SPSS. For each resource area, survey analyses will depend on the nature of the recreation users, but will likely focus on the following perspectives:

• Day and resident users • Developed facility users • Dispersed users • User groups defined by recreation opportunity (i.e. anglers of various types, hikers, etc.)

PSCo’s proposed methodology for planning, implementing, and analyzing visitor surveys is consistent with professional practice (Salant & Dillman, 2000; Watson et. al., 2000). In addition, for the mail back portion of the survey, researchers will be implementing professional accepted mail survey practices for contacting, choosing sample sizes, and reminding visitors (Dillman, 1978). The overall approach to carrying capacity follows from research and management traditions related to carrying capacity, visitor impact management, and recreation planning. Facility and ecological capacity assessments will rely in part on a review of previous research, while social capacity assessments will apply several research techniques that have been used in previous studies. Specific survey questions or formats to measure perceived crowding, preferred numbers of boats in view, or similar indicators have been used in previous studies, and have standard analysis protocols associated with them. At the conclusion of the study, a report will be produced consisting of methods describes in Components 1 through 4 and inserted into PSCo’s application for new license, Exhibit E. This report will be an integration of existing monitoring information, new demand assessment information and relevant information from the visitor and resident use surveys. This report will contain summary tables and/or graphs and actual user count data. 5.8.1 Relationships to Other Studies Fieldwork for the visitor surveys will be coordinated with the field work for the Carrying Capacity and Demand Assessments (Components 2 & 3). In fact, in some resource areas, there may be one surveyor conducting the field work for both these surveys as she or he travels through a resource area. In addition, findings from the visitor surveys are important inputs into the Recreation Demand, Carrying Capacity, and Needs assessments. In particular, visitor zip code, group size, people per vehicle, and frequency of use information obtained from the visitor survey will also be used in the Recreation Demand Assessment to assess visitor origin and recreation resource significance and to develop estimates of recreation visits. In addition, information on visitors’ experiential preferences will be used in the Recreation Carrying Capacity Assessment. As with all recreation assessments, visitor and resident survey results will be used in the Recreation Needs Assessment (Component 4). Survey items necessary for assessing social carrying capacities (Component 2) need to be coordinated with the visitor recreation and resident use surveys as part of the Visitor and Resident Use Survey. Capacity-related items will be provided to survey researchers before April 2006 so they can be used during pre-testing and sampling in spring 2006.


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Descriptions of existing or potential recreation opportunities in the Carrying Capacity assessment will be consistent with those developed in the Recreation Demand, Visitor and Resident Use Study, and the Inventory and Assessment of Recreation Facilities and Use Impacts (Issue Assessment No. 2). Coordination between information collection for existing use and evaluations of use levels is critical for examining relationships between use and social impact variables such as perceived crowding or evaluations of boats, people, and/or groups “at one time.” Estimates of future use and demand are similarly important for assessing whether facility capacities are likely to be sufficient (or whether to consider additional development). Findings from this study will be integrated with other cultural, recreational, and biological resource assessments to help assess the costs and benefits of recreation management alternatives. 6.0 References

Baker River Project Relicensing. 2002. Recreational and Aesthetic Resources Working Group.

Recreation Needs Analysis (Study Request R-R16), Study Plan, Unpublished work Copyright 2002 Puget Sound Energy, Inc. Retrieved February 05, 2005, http://www.pse.com/hydro/baker/index.html.

Berg, B. (2004). Qualitative Research Methods for the Social Sciences, Fifth Edition. Pearson

Education. Boston, MA Clark, R., & Stankey, G. (1979). Determining the acceptability of recreational impacts: An

application of the outdoor Recreation Opportunity Spectrum. Recreational impact on wildlands conference proceedings. October, Seattle, Washington.

Cole, D. (1994). Backcountry impact management: lessons from research. Trends 31(3): 10-14. Cordell, K. (Ed) (2001). Outdoor Recreation for 21st Century America. Venture Publishing.

State College, PA. Cordell, K., Betz, C., Bowker, B., English, D., Mou, S., Bergstrom, J., Teasley, R., Tarrant, M.,

and Loomis, J. (1999). Outdoor Recreation in American Life: A National Assessment of Demand and Supply Trends. Sagamore Publishing, Champaign, IL

Dillman, D. (1978). Mail and Telephone Surveys: The Total Design Method. John Wiley &

Sons, New York, NY. Donnelly, M., Vaske, J., and Shelby, B. (1992). Measuring backcountry standards in visitor

surveys. In B. Shelby, G. Stankey, & B. Shindler (Eds.), Defining wilderness quality: The role of standards in wilderness management - A Workshop Proceedings (pp. 38-52). (General Technical Report PNW-GTR-305). Portland, Oregon: USDA Forest Service.

Driver, B., Brown, P., Stankey, G. and Gregoire, T. (1987). The Recreation Opportunity

Spectrum Planning System: Evolution, Basic Concepts, and Research Needed. Leisure Sciences: 9:201-212.

Graefe, A., Kuss, F., and Vaske, J. (1990). Visitor impact management: The planning


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framework. Washington, DC: National Parks and Conservation Association. 105 pp. Graefe, A., Kuss, F., & Vaske, J. (1990). Recreational impacts and carrying capacity: Visitor

impact management: The planning framework (Volume 2), Washington, D.C.: National Parks and Conservation Association.

Haas, G. (2001). Visitor Capacity on Public Lands and Waters: Making Better Decisions. Draft

report of the Federal Interagency Task Force on Visitor Capacity on Public Lands. Haas, G., Aukerman, R., Lovejoy, V., & Welch, D. (2004). Water Recreation Opportunity

Spectrum (WROS) User’s Guidebook. United States Department of the Interior, Bureau of Reclamation, Office of Program and Policy Services, Denver Federal Center, Lakewood Colorado. July 2004.

Kelly, J. and Warnick, R. (1999). Recreation Trends and Markets. Sagamore Publishing,

Champaign, IL. Krejcie, R. and Morgan, D. (1970). Determining sample size for research activities.

Educational and Psychological Measurement, 30, 607-610. Kuss, F., Graefe, A., and Vaske, J. (1990). Visitor impact management: A review of research.

Washington, DC: National Parks and Conservation Association. 256 pp. Malvestuto, S. (1996). Sampling the Recreational Creel Fisheries Techniques (Chapter 20), 2nd

edition. American Fisheries Society. Manning, R. (1999). Studies in Outdoor Recreation: Search and Research for Satisfaction.

Second edition. Oregon State University Press, Corvalis, OR. Manning, R., Lawson, S., Newman, P., Laven, D., and Valliere, W. (2002). Methodological

issues in measuring crowding-related norms in outdoor recreation. Leisure Sciences 24(3-4): 339-348.

Marion, J. (1991). Developing a Natural Resource Inventory and Monitoring Program for Visitor

Impacts on Recreation Sites: A Procedural Manual. U.S. Department of Interior, National Park Service, Natural Resources Report NPS/NRVT/NRR-91/06. 59 p.

Marion, J. (1994). Trail conditions and management practices in the National Park Service. Park

Science 14(2):16-17. McHarg, Ian L. (1992). Design With Nature. John Wiley and Sons, New York, NY. National Park Service. (1997). VERP: The visitor experience and resource protection (VERP)

framework, a handbook for planners and managers. Denver, CO: USDI, National Park Service, Denver Service Center.

Pollock, K., Jones, C., and Brown, T. (1994). Roving Creel Survey. Angler Survey Methods and

Their Applications in Fisheries Management (Chapter 11). American Fisheries Society.


20 November 1, 2005

PSCo Tacoma Hydroelectric FERC Project 12589 (2005). Pre Application Document. Filed May

20, 2005. Public Service Company of Colorado and The Electra Sporting Club (2000). Recreation and

Land Management Plan for Electra Lake. October, 2000.

Sugnet and Associates and The Electra Sporting Club (August 2002). Electra Sporting Club Shoreline Management Plan. Public Service Company of Colorado, Durango, CO.

Salant, P. and Dillman, D. (1994). How to Conduct Your Own Survey. John Wiley and Sons, Inc. New York, NY.

Shelby, B., and Heberlein, T. (1986). Social carrying capacity in recreation settings. Corvallis,

OR: Oregon State University Press. Shelby, B., Vaske, J., and Heberlein, T. (1989). Comparative analysis of crowding in multiple

locations: Results from fifteen years of research. Leisure Sciences, 11, 269-291. Shelby, B., Vaske, J., and Donnelly, M. (1996). Norms, standards and natural resources. Leisure

Sciences, 18, 103-123. Stankey, G., and Shindler, B. (Eds.), Defining wilderness quality: The role of standards in

wilderness management - A Workshop Proceeding (pp. 13-22). (General Technical Report PNW-GTR-305). Portland, Oregon: USDA Forest Service.

Stankey, G., Cole, D., Lucas, R., Peterson, M., Frissel, S. (1985). The limits of acceptable

change (LAC) system for wilderness planning. USDA Forest Service Gen. Tech. Rep. INT-176. Ogden, UT: Intermountain Forest and Range Experiment Station.

U.S. Department of Agriculture, Forest Service. 2000. Wilderness Recreation Use: A Handbook

of Methods and Systems, October 2000, Forest Service RMRS GTR-56 (page 57 -59, Field Sampling Strategy, Method J, The General Recreation Survey, and Method A: Mechanical Counters with Visual Calibration)

U.S. Department of Agriculture, Forest Service. Techniques and Equipment for Gathering

Visitor Use Data on Recreation Sites (Personal Observation, page 23 -25; Traffic Counters, page 19-23; and Visitor Surveys, page 35-37).

Vaske, J., and Donnelly, M.(2002). Generalizing the encounter-norm-crowding relationship.

Leisure Sciences, 24, 255-270. Watson, A., Cole, D., Turnery D., and Reynolds, P. (October 2000). Wilderness Recreation Use:

A Handbook of Methods and Systems, October 2000, United States Forest Service Rocky Mountain Research Station General Technical Report-56. Ogden, Utah.

Whittaker, D. (1992). Selecting indicators: Which impacts matter more? In B. Shelby,


21 November 1, 2005

Whittaker, D., and Shelby, B. (1988). Types of norms for recreation impacts: Extending the social norms concept. Journal of Leisure Research, 20, 261-273.

Whittaker, D, Vaske, J., and Manfredo, M. (2002). Choosing actions: Problem definition,

identifying strategies, and evaluation criteria. In Manfredo, M. (Ed.) Wildlife viewing: A management handbook. Oregon State University Press.


22 November 1, 2005

Attachment A

Issue Assessment No. 9


23 November 1, 2005


FERC NO. 400 RECREATION, LAND USE, AND AESTHETICS RESOURCES WORKING GROUP

Issue Assessment No. 93 Development Pressure

1.0 Description of Issue (18 CFR 5.9(b)(1)) The issue of the potential for future growth to impact recreational demand and thereby result in greater pressure on current recreation resources related to the Tacoma Project was raised. This issue primarily related to the need for retaining the aesthetic character of the area and providing view- shed protection. Future growth in the region will affect demand for various types of recreation. 2.0 Project Effects (18 CFR 5.9(b)(5)) The Project’s reservoir, roads and lands provide opportunities for the public to participate in various recreational activities. As an example, public recreation such as fishing and boating activities are available on Electra Lake. According to the Electra Lake Recreation and Land Management Plan (2000), approximately 80 percent of the public fishing is from the shoreline of the Lake, which is accessible by footpath from the Westinghouse, Nunn, and Edison parking and picnic areas. The management plan also indicates that 20 percent of the public use is from boating activities for fishing, pleasure boating, and water skiing. Other activities including hiking, wildlife viewing, and educational excursions occur within and near the Project. The Project’s recreation and shoreline management plans, to be updated as part of relicensing, will address meeting present and future demand. Additionally, information within the plans will address the social, ecological, and facility, and physical carrying capacity of Electra Lake, while considering the operational needs of the project and the potential for environmental impacts resulting from increased recreational use. Retaining the aesthetic character of the area and view-shed protection relative to Project facilities and within the Project Boundary will be a part of the updated Shoreline Management Plan (Recreation, Land Use, and Aesthetics RWG Issue Assessment No. 4).

3 Previously Issue No. 11 from Unedited Issues List; Issue No. 12 from Revised Issues List.

Tacoma Hydroelectric Project Maintaining a Quality Fishing Experience on Electra Lake; Assessing Day-Use Fee Structure

Recreation, Land & Aesthetics RWG Issue No. 5

1 November 1, 2005


FERC NO. 12589 RECREATION, LAND USE AND AESTHETICS RESOURCE WORK GROUP


Maintaining a Quality Fishing Experience on Electra Lake; Assessing Day Use Fee Structure

1.0 Description of Issue (18 CFR 5.9(b)(1)) Electra Lake is known for the quality of the fishing experience. A concern was raised that increased public access, or even the current level of public access, could seriously diminish this experience. The issue of understanding the social and environmental impact of current recreational use levels and the need to maintain a quality recreation experience was raised. A related issue was raised about the appropriateness of the current fee structure at Electra Lake for day use, how the fee is set, and what the process would be for establishing future fee increases. 2.0 Project Effects (18 CFR 5.9(b)(5)) Public recreation such as fishing and boating activities are available on Electra Lake. It is generally acknowledged that the fishing experience at Electra Lake is of high quality with the lake producing a high catch rate of medium and large brook, brown, and rainbow trout. According to the Electra Lake Recreation and Land Management Plan (2000), approximately 80 percent of the public fishing is from the shoreline of the Lake, which is accessible by footpath from the Westinghouse, Nunn, and Edison parking and picnic areas. The management plan also indicates that the remaining 20 percent of the public use is from boating activities for fishing, pleasure boating, and water skiing. Other activities including hiking, wildlife viewing, and educational excursions for botanical, geological, and historical field trips occur within and near the Project. With continued economic and residential growth in the vicinity of the Project, future demand for this experience will likely increase. However, the sustainability of the quality of the fishing experience is a primary concern. It will be essential to balance this increased demand with the need to maintain this unique experience. Related to the issue of fee structure, current day-use fees are $7/day with a limit of four fish. Use is limited to 50 persons per day on a first-come, first-serve basis. The potential effect of current and increased public access on the fishing experience at Electra Lake and appropriateness of the present and future fee structures will be considered fully within the work conducted under the development of updated Recreation and Shoreline Management Plans (Recreation, Land Use and Aesthetics RWG Issue Assessment No. 4). 1Originally Issue Nos. 5 & 6 on the Unedited Issues List.



2 November 1, 2005

3.0 Relevant Existing Information (18 CFR 5.9(b)(4)) Existing information regarding recreation activities in the Project area is provided in the Tacoma Pre-Application Document (PAD) and is cited in this Study Plan. Limited information regarding the characteristics, attitudes, and preferences of recreation visitors to the Project is available. Recreation use levels at the Project are based on visitor and Electra Sporting Club (ESC) records collected since 1996. These are summarized in the PAD (PSCo, 2005). Additionally, two management plans have been developed by PSCo in coordination with the Electra Sporting Club: the Recreation and Land Management Plan (October 2000) and the Shoreline Management Plan (August 2002). Existing information related to current recreation carrying capacity is based on facility capacities at developed recreation sites at Electra Lake. These sites and capacities are described in the PAD (PSCo, 2005). 4.0 Need for Additional Information (18 CFR 5.9(b)(4)) This study will be used to address the gaps in the existing information on recreation user opportunities at the Project, including but not limited to the fishing experience, value of the resource, and place attachment; and, to understand carrying capacity and recreational use impacts. This information will inform the development of updated Recreation and Shoreline Management Plans for Electra Lake. 5.0 Final Study Plan 5.1 Purpose of Study and Use of Study Results (18 CFR 5.9(b)(1) and 5.9(b)(5) in part) The purpose of this study is to define the preferences, attitudes, and characteristics of the Project’s primary recreation user groups. Information from a survey of users will provide an understanding of the preferences of various Project recreation user groups and area residents. The survey will also describe user preferences for various types of recreation opportunities, the level of acceptability of experiential impacts, and support for existing and alternative management options. Specific objectives are to:

• Describe recreation visitors and their trip characteristics by Project recreation resource area (see Table 1 below) and type of user (i.e. anglers, boaters, canoe/kayakers, etc.);

• Describe Electra Sporting Club residents and their recreation use of the Project; • Describe user and ESC resident preferences for the various recreation settings and

facilities and their tolerances for various conditions at Project recreation resource areas; • Identify recreation conflicts, crowding, or personal safety issues within each of the

Project’s recreation resource areas; • Describe user and ESC resident attitudes toward management actions that might be used

to improve experiences or address problems; • Describe recreation visitor activities at Project area recreation resource areas;



3 November 1, 2005

• Describe visitor and ESC resident perceptions of a quality recreation experience at Electra Lake; and,

• Evaluate current fee structure and potential future fee structures related to effects on recreation use.

5.2 Relevant Resource Management Goals (18 CFR 5.9(b)(2))

It is PSCo’s goal to maintain a quality recreation experience at the Project. Within the current Recreation and Land Management Plan (2000), objectives are identified and these will be incorporated as appropriate into the updated Recreation and Shoreline Management Plan. The United States Forest Service (USFS) utilizes the Water Recreation Opportunity Spectrum (WROS) and Recreation Opportunity Spectrum (ROS) to assist in identifying desired recreation opportunities for the resources under its management. These designations will be reviewed and incorporated where the Project occupies USFS managed lands.

5.3 Relevant Public Interest Considerations (18 CFR 5.9(b)(3))

With continued economic and residential growth in the vicinity of the Project, future demand for the recreation experience at Electra Lake will likely increase. However, the sustainability of the overall quality of recreation experiences (primarily fishing) is a primary concern of PSCo. It will be essential to balance increased demand with the need to maintain this unique experience.

5.4 Study Methodology (18 CFR 5.9(b)(6))

Preparation of the recreation visitor and resident use survey instrument is scheduled for 2005 for implementation of the user surveys to occur from spring 2006 through fall 2006. Analysis of survey results is scheduled for winter 2006 and the study report for spring of 2007.

5.4.1 Study Area and Sites The physical sites for the conduct of the surveys to be undertaken as part of this study are designated in Table 1. As noted, in addition to visitors to Electra Lake, ESC residents will also be surveyed.



4 November 1, 2005

Table 1. Study sites for resident and visitor surveys. Recreation Resource Area Study Sites ELECTRA LAKE Reservoir shoreline

a. Nunn Recreation Area Parking Area Electra Lake surface via boat Picnic Area Boat ramp Floating dock b. Westinghouse Parking and Picnic Area Picnic area

Parking area Shoreline Fishing access area c. Edison Parking and Picnic Area Picnic area

Parking area Shoreline Fishing access area ASPAAS LAKE Reservoir shoreline FOREBAY LAKE Reservoir shoreline ELECTRA LAKE RESIDENTS ESC members and guests via mail

5.4.2 Methods This section describes the methods to be employed to develop the survey instruments, to conduct the survey, and to choose the target sample sizes from the survey populations (visitors and residents). Survey Instrument Development: PSCo is planning to design the survey to address the topics listed below consistent with the study purpose. Survey topics will include:

• acceptability of boat launch facilities • other recreation locations in the area visited on the trip (to understand demand) • preferences and attitudes towards developed facilities and services (including interpretive

and education facilities). • acceptability of shoreline access and opportunities • comparison of their primary destination site to other places • satisfaction and relative importance of specific trip attributes • perceived personal safety • crowding and conflict (focused on recreational uses) • changed recreational use patterns • place attachment • angler recreation behavior and preferences • attitudes and/or preferences related to the quality of the Electra Lake sport fishery • access fees • other potential barriers to recreation



5 November 1, 2005

Specific survey content will be developed for each topic based on previous research and discussions within the Recreation, Land Use & Aesthetics RWG. Survey content may vary somewhat between visitor and resident use surveys. Before the recreation season opens and prior to implementation in the summer of 2006, survey instruments will be pre-tested with a sample of recreation users, and, refined if necessary. Survey Approaches: Two survey approaches -- on-site/mail-back visitor survey and direct mail resident use survey -- will be utilized in the study to reflect the different ways that Project recreation users can be reached. The on-site /mail-back visitor surveys will be implemented in conjunction with the existing use recreation survey and will use a roving, systematic stratified sampling method. The sample method is stratified by location (the resource areas listed in Table 1), type of day (weekday, weekend, and holiday weekend), and time of year (spring, summer, fall, winter) during recreation seasons. The direct mail resident survey will target members of the Electra Sporting Club (ESC). Target Sample Sizes: For the Project visitor surveys and the direct mail use survey to ESC members/residents, PSCo will obtain a sample size for target populations so that survey responses can be reported at a 95% confidence interval, with a +/- 10% sampling error. Estimated visitor and resident target sample sizes to achieve this goal are discussed and summarized in Table 2. During the study process, PSCo will be monitoring the response rate of completed surveys on a weekly basis and, if necessary, make appropriate adjustments to increase the rate in order to achieve the targets of completed surveys. For ESC members, PSCo plans to send direct mail surveys to the entire population (approximately 101). PSCo proposes the survey methods described below. Direct Mail ESC Member Survey A direct mail resident use survey will be sent to all members of Electra Sporting Club, residing part-time or full-time at the lake. Names and addresses for residents will be obtained by PSCo in cooperation with the Electra Sporting Club. Completed mail surveys will provide information on user characteristics, recreational activities, Project visitation, concerns, and overall recreational experiences. Surveys will be sent through the mail before Labor Day Weekend 2006 (the end of the season, October 31). The direct mail survey will be conducted in accordance with standard mail survey methodology (Dillman 1978), which includes the use of a mail survey packet. This packet will include a self-addressed, stamped envelope, instructions and cover letter, and mail survey form. Each survey will be numbered for tracking purposes, with a reminder follow-up postcard sent approximately one week after the first mailing, a second letter and survey two weeks and three weeks respectively depending on response. The number of refusals will be recorded. In addition, PSCo will offer an incentive to assist with the return of completed survey forms for both direct mail and mail-back surveys (e.g., opportunity in a drawing).



6 November 1, 2005

Visitor Surveys (On-Site and Mail-Back) The on-site/mail-back visitor survey will be administered at sites where recreation visitors are readily visible and willing to participate. This survey approach will include a short, one page on-site survey instrument that collects information about current resource conditions (i.e. users’ feelings towards current use levels), and visitors’ mailing address. Visitors will be asked to take a multi-page, mail-back survey instrument, which addresses other aspects of their recreation experience listed previously. Only individuals or members of a group who are18 years or older will be asked to complete a survey. Electra Sporting Club has been monitoring various recreation uses at the Project since 1990 as reported in the 2000 Electra Lake Recreation and Land Management plan. However, recreation visitation estimates to Electra Lake have varied by type of visitor and category from year to year; therefore it is unclear precisely how many recreation days are held by ESC members, the general public, and special groups. As a result, use estimates for survey sample size will be based on 2003 estimates at Electra Lake (see Table 2) which are anticipated to be relatively close to current use levels. In 2003, a total of nearly 16,000 visitor recreation-days (RD) occurred at the lake. Each survey will be numbered for tracking and follow-up purposes. Recreation researchers will train surveyors on random selection techniques for choosing groups at a site and participants within groups, introduction strategies, recording, and tracking refusals. Table 3. ESC Member, Guest, & Visitor Recreation Days (RD) in 2003.

Visitor Estimates Survey Target Month ESC RD ESC Guest Public ESC RD ESC Guest Public June 688 1028 1752 All

Members 88 92

July 937 1660 1996 92 92 August 855 1720 1562 92 92 September 533 831 947 88 88 October 386 590 475 83 83 Total

3, 399

5, 829

6, 732

443

447

Total RD 2003: 15, 960 Visitor Use Spot Counts To estimate existing recreation use at Electra Lake (water surfaces of the lake, shoreline use, and informal area use) the survey team will begin with standardizing gate (public use) and member (private use) counts during the summer, fall and winter of 2005. Due to a range of categories utilized and reported since 1990, a revised annual count of various user types will be initiated. This includes members completing a self-reporting use and fish catch log (see Appendix 1) for each month, with a primary focus on May-October, and the gate attendant keeping track of public visitors with a standardized log sheet (see Appendix 2). In addition, PSCo field staff will



7 November 1, 2005

spot count on two week days per month and two weekend days per month, selected at random. Members will log the date, their activity, and fish catch and release and submit those logs weekly. The Gate staff will log for each group the date, activity, fish catch and release, and group size and residence or origin for each group (see Appendix 2). Field staff will visit all resource areas, log activities, date, and type of visitor for each sample day. Field staff will stratify their observations by recreation resource areas (see Table 1), type of day (weekdays, non-holiday weekends, and holiday weekends), and time of day (mornings from 7 AM – 12 PM; afternoon from 12 PM to 3 PM; and evenings from 3 PM to 7 PM) during the season (May-October).

During 2006, a roving user survey will be completed using a stratified two-stage (geographic and temporal) probability sampling approach (Mavestuto, 1996; Pollock et al., 1996). The sample will be stratified by recreation resource areas (Table 1), type of day (weekdays, non-holiday weekends, holiday weekends, and opening fishing or event weekends), and time of day (mornings from 7 AM – 12 PM; afternoon from 12 PM to 3 PM; and evenings from 3 PM to 7 PM) during summer months (May-September). Sampling frequencies for each stratum will be based on estimated existing use levels developed from previous use data and will be adjusted, if necessary, during the summer. Two weekend days, two week days will be randomly selected each month, and each major holiday (Memorial Day, Independence Day, and Labor Day) for a total of 34 survey days total from Memorial Day through October 31, 2006.

During the roving survey, for each site, a surveyor will count the number of vehicles, vehicles with trailers, boats, people, groups, and the types of activities in which users are engaged. To estimate boating use that occurs on Electra Lake, field staff will count the number and type of watercraft from the water during a recreation survey day from a boat. 5.4.3 Estimate of At-One-Time (AOT) and Daily and Season Recreation Days (RDs) For each recreation site (or cluster of informal sites), the average and maximum use levels for recreation parameters (e.g., people, vehicles, groups, facility occupancy) by day type (e.g., weekend, weekday, holiday) and if necessary, time period (e.g., morning, afternoon, evening) during the surveyed recreation season will be calculated. In addition, for each recreation site or cluster of sites, the frequency distribution of observed recreation activities during the surveyed recreation season will be analyzed. The analysis will include estimates of existing annual day and overnight visits (members/members guests only) to recreation resource areas in recreation-days (RDs). An RD, as defined by FERC, equals a visit to an area for recreation purposes for any portion of a 24 hour period. To estimate RDs, the information on group size, number of people in vehicles, and length of stay developed from the survey findings will be used.

Assessing existing recreation use through a combination of visitor counts and questionnaire surveys is a common practice (Malvestuto, 1996, Pollock et al., 1994, US Department of Agriculture, Forest Service, 2000). In addition, assessing future recreation demand through an



8 November 1, 2005

evaluation of existing use, demographic data and participation trends and projections in the region is common practice (Kelly & Warnick, 1999). 5.5 Schedule The study schedule begins during summer 2005 with spot counts and resident logs tracking daily use. A survey of visitor use and additional spot counts will begin during the 2006 season as presented in Table 3.

Table 3. Study Schedule

2005 2006 2007

Study Activity Su

mm

er

Fall

Win

ter

Spri

ng

Sum

mer

Fall

Win

ter

Spri

ng

Sum

mer

Field Reconnaissance X X Spot Counts/Gate Counts X X X X X Finalize Survey Instruments X X On-Site & Mail-back Visitor Surveys X X X Direct Mail Resident Surveys X X X Analysis X X Report Preparation X X

5.6 Level of Effort (18 CFR 5.9(b)(7)) Spot counts and resident logs will begin during the 2005 visitor season; surveys of visitor use and spot counts will begin Memorial Day 2006 and continue through October 31, with 2 weekdays and 2 weekend days surveyed per month, and primary holiday days (Memorial Day, Independence Day, Labor Day). 5.7 Discussion of Alternative Approaches (18 CFR 5.9(b)(7)) No alternative approaches have been recommended to date. 5.8 Data Analysis and Reporting Survey responses should provide a rich source of information about visitor use patterns, characteristics, preferences, and perceptions of experiences at Electra Lake. Visitor survey responses will be analyzed taking an “opportunity perspective” by grouping users who are doing similar activities in similar geographic areas. Information will be presented in tabular and graph format that indicates the number and percent frequency of visitor survey responses. The study objectives will be addressed through analysis of the responses to questionnaires. Survey responses will be coded, edited and entered for analysis through a separate effort and



9 November 1, 2005

entered into SPSS. For each resource area, survey analyses will depend on the nature of the recreation users, but will likely focus on the following perspectives:

• Shoreline users • Lake surface users • User groups defined by recreation opportunity (i.e. boaters, anglers) • ESC members & guests, and non-members Fieldwork for the visitor surveys will be coordinated with other field work related to developing shoreline and recreation use management plans for Electra Lake (see Issue Assessments No. 2 & No. 7). In fact, in some resource areas, there may be one surveyor conducting the field work for all recreation surveys as she or he travels through a resource area. In addition, findings from the visitor surveys are important inputs into the Recreation Demand Study (Issue No. 9). In particular, visitor zip code, group size, people per vehicle, and length of stay information obtained from the visitor survey will also be used in the Recreation Demand Study (Issue Assessment No. 9) to assess visitor origin and recreation resource significance and to develop estimates of recreation visits. Visitor and resident survey results will be used to inform the development of updated Recreation and Shoreline Plans (Issue Assessment No. 4). 6.0 References Berg, B. (2004). Qualitative Research Methods for the Social Sciences, Fifth Edition. Boston:

Pearson Education. 336 p. Dillman, D. (1978). Mail and Telephone Surveys: The Total Design Method. John Wiley &

Sons.

Haas, G., Aukerman, R., Lovejoy, V., and Welch, D. (2004). Water Recreation Opportunity Spectrum User’s Guidebook. United States Department of the Interior, Bureau of Reclamation, Office of Program and Policy Services, Denver Federal Center, Lakewood, Colorado. July 2004.

Krejcie, R. V. & Morgan, D. W. (1970). Determining sample size for research activities. Educational and Psychological Measurement, 30, 607-610.

Manning, R. E. (1999). Studies in Outdoor Recreation: Search and Research for Satisfaction. Second edition. Oregon State University Press, Corvalis, OR.

Public Service Company of Colorado and The Electra Sporting Club (2000). Recreation and Land Management Plan for Electra Lake. October, 2000.

Sugnet and Associates and The Electra Sporting Club (August 2002). Electra Sporting Club Shoreline Management Plan. Public Service Company of Colorado, Durango, CO.



10 November 1, 2005

Salant, P. and Dillman, D. (1994). How to Conduct Your Own Survey. John Wiley and Sons, Inc., New York, NY.

Watson, A. E., Cole, D. N., Turnery D. L., and Reynolds, P. S. (October 2000). Wilderness Recreation Use: A Handbook of Methods and Systems, October 2000, United States Forest Service Rocky Mountain Research Station General Technical Report-56. Ogden, Utah.

Tacoma Hydroelectric Project Condition of Project Facilities on Cascade Creek Recreation, Land Use & Aesthetics RWG Issue No. 7

1 November 1, 2005


FERC NO. 12589 RECREATION, LAND USE AND AESTHETICS RESOURCE WORK GROUP


Condition of Project Facilities on Cascade Creek 1.0 Description of Issue (18 CFR 5.9(b)(1)) The issue of documenting the current condition and status of facilities on Cascade Creek and related current amount and type of use was raised. The documentation of the status and condition of Project facilities within the Cascade Creek drainage was requested. This would include documenting the status and condition of the bridge over the wooden flume, compliance with the special use permits for storage and facility areas, and fencing and equipment. Additionally, it is suggested that there is increased public use of the area and a determination of the appropriate manner to address the aesthetic character of the area may be warranted. 2.0 Project Effects (18 CFR 5.9(b)(5)) The Tacoma Project facilities include the Cascade Creek diversion dam and intake, elevated wooden flume, and siphon crossing Cascade Creek just upstream of U.S. Highway 550. Access to this part of the Project is via U.S. Forest Service (USFS) Cascade Creek Pack/4WD trail. Most of the Project facilities in this portion of the Project occupy National Forest System lands managed by the USFS. As part of its relicensing process, the Project will be reviewed as to its overall compliance with USFS policies and management plans to identify areas of non-compliance or areas for improvement. Emphasis will be placed on the area between Cascade Creek diversion dam and U.S. Highway 550. 3.0 Relevant Existing Information (18 CFR 5.9(b)(4)) Existing information regarding recreation and land use in the Project area is provided in PSCo’s Pre-Application Document (PAD) and is listed in the References section of this Issue Assessment. Information regarding the current physical condition of facilities at Cascade Creek is summarized in the PAD, Section 5. 4.0 Need for Additional Information (18 CFR 5.9(b)(4)) Information on the current compliance of the Project facilities with USFS policies and management plans do not currently exist. This study will be undertaken to obtain the information needed to evaluate Project facilities located between U.S. Highway 550 and the Cascade Creek diversion dam. 1 Originally Issue Nos. 8 & 9 on the Unedited Issues List; Issue Nos. 9 & 10 on the Revised Issues List.


2 November 1, 2005

5.0 Final Study Plan 5.1 Purpose of Study and Use of Study Results (18 CFR 5.9(b)(1) & 5.9(b)(5) in part) The purpose of this study is to identify Project components and associated recreation use impacts to the surrounding characteristic landscape in the area between Cascade Creek diversion dam and U.S. Highway 550. For the visual contrast assessment, the surrounding landscape would be evaluated for various characteristics, such as its scenic attractiveness, scenic integrity, visual absorption capacity, public visibility, visual distance zones, visual sensitivity and, where applicable, USFS and Bureau of Land Management (BLM) visual quality objectives. Information from this assessment would be used to identify potential measures to reduce Project-related visual contrast with the surrounding environment specific to the area between Cascade Creek diversion dam and U.S. Highway 550. This study will be used to document aesthetic resource conditions at the Project and identify the Project effects on aesthetic resources in the area of the Cascade Creek diversion dam as well as consistency with current land management plans and policies. 5.2 Relevant Resource Management Goals (18 CFR 5.9(b)(2)) The relevant resource management goals for those lands and waters located within the lands managed by the USFS are contained in the appropriate Forest Plan, in this case, the 1992 Amended Land and Resource Management Plan for the San Juan National Forest. Specific direction relevant to USFS actions includes: Forest-Wide Direction

Visual Resource Management (02). Rehabilitate all existing projects and areas which do not meet the adopted visual quality objective(s) (VQO) specified for each management area (page III-16). Set priorities for rehabilitation, considering the following (page III-16):

a. Relative importance of the area and the amount of deviation from the adopted VQO. Foreground areas have the highest priority;

b. Length of time it will take natural processes to reduce the visual impacts so that they meet the adopted VQO;

c. Length of time it will take rehabilitation measures to meet the adopted VQO; and,

d. Benefits to other resource management objectives to accomplish rehabilitation (page III-16).

Management-Area Direction/Rural and Roaded-Natural Recreation (2B) The Cascade Creek Diversion Dam and associated facilities are located within the 2B Management Prescription Area. Emphasis is for rural and roaded-natural recreation opportunities. Visual resources are managed so that management activities maintain or improve


3 November 1, 2005

the quality of recreation opportunities. Management activities should not be evident, remain visually subordinate, or may be dominant, but harmonize and blend with the natural setting.

Visual Resource Management (01). Design and implement management activities to provide a visually appealing landscape. Enhance or provide more viewing opportunities and increase vegetation diversity in selected areas (page III-120).

a. Do not exceed an Adopted Visual Quality Objective (VQO) of Partial Retention (page III-120).

b. Manage visual resources using the above standards in accordance with FSM 2380 and FSH 2309.16 through FSH 2309.25 (page III-120).

Management-Area Direction/Semi-Primitive Motorized Recreation (2A) The road to Forebay Lake and pipeline are located in a 2A Management Prescription Area. Emphasis is for semi-primitive motorized recreation opportunities. Visual resources are managed so that management activities are not evident or remain visually subordinate.

Visual Resource Management (01). Design and implement management activities to provide a visually appealing landscape. Enhance or provide more viewing opportunities and increase vegetation diversity in selected areas (page III-106).

a. Do not exceed an Adopted Visual Quality Objective (VQO) of Partial Retention (page III-106).

b. FS System travel routes are Sensitivity Level one (page III-106). c. Apply rehabilitation practices where the above objectives are not currently

being met (page III-106). d. Manage visual resources using the above standards in accordance with FSM

2380 and FSH 2309.16 through 2309.25 (page III-107). 5.3 Relevant Public Interest Considerations (18 CFR 5.9(b)(3)) The Recreation, Land Use and Aesthetics Resource Work Group requested that as part of the relicensing process, the Project where it occupies federal lands should be reviewed as to its overall compliance with USFS policies and management plans to identify areas of non-compliance or areas for improvement. The focus of this issue was the area between Cascade Creek diversion dam and U.S. Highway 550 with respect to aesthetics. 5.4 Study Methodology and Analysis (18 CFR 5.9(b)(6)) To address aesthetic impacts, a visual assessment study will be conducted consisting of three components: (1) an inventory and assessment of the area’s visual resources and landscape character; (2) a review of the visual management polices applicable to the specific area; (3) an assessment of any visual contrast between the Project’s components and surrounding landscape; and (4) a review of housekeeping practices and their compliance with visual resources.


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5.4.1 Inventory/Assessment of Visual Resources Building on information presented in section 5.9 of the PAD, an inventory of all Project facilities in the vicinity of the Cascade Creek diversion dam will be undertaken. The visual characteristics of the area and/or site will be evaluated and photographed. Unique and important visual resources as well as the characteristic landscapes within the area will be identified. Unique landscape units, key public view points, and key public viewing areas including distance zones for Project components will be identified and evaluated. The scenic attractiveness, scenic integrity, absorption capacity, and visual sensitivity of the landscapes in the area between Cascade Creek diversion dam and U.S. Highway 550 will be assessed. 5.4.2 Review of the Visual Management Polices USFS management plans relevant to visual resources in the study area will be identified. Land management plans, transportation plans, and other resource use plans will be evaluated to identify visual resource management considerations applicable to the area. On U.S. Forest system lands, the Project’s relationship to current Visual Quality Objectives (VQOs) will be assessed. Any highway and road scenery management regulations and policies as well as any trail or waterway designations that may be applicable will also be identified. 5.4.3 Assessment of Visual Contrast Within the area between Cascade Creek diversion dam and U.S. Highway 550, the visual compatibility of the Project features with the surrounding landscape, including linear features such as the wooden flume, siphon and all ancillary facilities will be evaluated. In addition, facilities at the gauging station at Elbert Creek and facilities at Forebay Lake will be reviewed. Visual contrast, compatibility of the Project components, potential recreation use impacts, and potential impacts on the surrounding landscape will be evaluated. The visual assessment methods to be used in this study will be consistent with the relevant Forest Service and Bureau of Land Management visual assessment methods (USDA Forest Service 1995 and 1974; BLM undated Handbook H-8400 series). This methodology as applied to the mix of federal and non-federal lands within a hydroelectric project area has been successfully used in the recent Pit 3, 4, 5 relicensing and Upper North Fork Feather River relicensing studies. The results of this study will be of use and consideration in the recreation, land management and historic resources study work as there is cross-over areas of interest in both structures and visual compatibility of Project components within the larger landscapes. 5.5 Schedule This study will be coordinated with field work for the recreation facility inventories and assessments to be conducted during the summer of 2006. The time estimated to complete the field review is approximately 4 days.


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5.6 Level of Effort (18 CFR 5.9(b)(7)) This effort will be coordinated with work proposed in Issue Assessment No. 2, ADA Compliance. Field work will be conducted during the same time period as Issue Assessment No. 2, as part of an overview of facilities and ADA compliance. 5.7 Discussion of Alternative Approaches (18 CFR 5.9(b)(7)) There have been no alternative approaches proposed at this time. 5.8 Reporting The study methods and results will be contained in a stand alone report that will be included in the Final License Application. 6.0 References Landscape Aesthetics: A Handbook for Scenery Management. USDA Forest Service,

Agriculture Handbook Number 701. December 1995 National Forest Landscape Management, series, USDA Forest Service, Agricultural Handbooks,

Number 462 (1974), 478 (1975), 666 (1987). Also referenced at their web site http://www.fs.fed.us/im/directives/fsm/2300/2380.doc

USDA Forest Service. 1992. Amended Land and Resource Management Plan for the San Juan

National Forest, Rocky Mountain Region. Durango, CO. Visual Resource Management, Manual H-8400, et. seq, Bureau of Land Management

(http://www.blm.gov/nstc/VRM/index.html)

golden, colorado 80403 november 1,2005 federal energy ...~ xcel energy'" 4653 table...

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