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HomeMy WebLinkAboutComments on the draft proposed study plan and request for studies and additional information - Federal Energy Regulatory Commission11:1 Recreation has been identified as a project purpose by the Commission. Applicants are encouraged to develop recreation resources in such a matter that is "consistent with the needs of the area to the extent that such development is not inconsistent with the primary purpose of the project" (18 C.F.R. §2.7). Identifying effects of project operations pertaining to this resource is relevant to the Commission's public interest determination. Background and Existing Infonnation §5.9(b)(4) — Describe existing information concerning the subject of the study proposal, and the need for additional information. Section 5.8 of the Pre - Application Document (PAD) provides a summary of activities and demand at the project. However, the PAD provides no project - specific information regarding visitor perceptions and identified needs at the projects or how project operations may affect the visitor experience. Further, much of the information provided in the PAD (while valid and valuable) is derived from studies prior to 2002. Infonnation on current use and whether existing access facilities in the area are meeting recreation demand would inform a decision on whether additional, designated public access at the project is necessary to meet existing and future recreation demand at the projects, and inform how project operations may affect recreational opportunities at the project. Proiect Nexus §5.9(b)(5) — Explain any nexus between project operations and effects (direct, indirect, and/or cumulative) on the resource to be studied, and how the study results would inform the development of license requirements. The project includes four reservoirs and two bypassed reaches with recreational opportunities. An analysis of existing recreation use and access at the projects would help form the basis for determining the projects' ability to enhance public recreation opportunities. Also, an assessment of the current level of recreation use and how project operation may affect use would provide information necessary to develop a Recreation Management Plan for efficient management of the recreational components of the project over the term of a new license. Proposed Methodology §5.8(b)(6) — Explain how any proposed study methodology (including any preferred data collection and analysis techniques, or objectively quantified information, and a schedule including appropriate field season(s) and the duration) is consistent with generally -9- accepted practice in the scientific community or, as appropriate, considers relevant tribal values and knowledge. The use and needs assessment should include all recreation activity types know to occur or potentially occurring at the project. Specific methods should include visitor observations and on -site visitor intercept surveys at formal and informal public recreation areas at the project reservoirs and riverine areas, including the Bucks Creek and Grizzly Creek bypassed reaches. Specific methods for each sampling approach in the use and needs assessment: • the visitor observations should capture information such as location, date, time, weather, number of vehicles, watercraft (if any), number of recreation users or party size, and recreation activity engaged in; and the visitor survey sampling should be based on a stratified random sample that includes all seasons, various locations, and various times of week and day to enable representative responses from the visitors, while ensuring interview coverage during key times (e.g., holiday and weekend days, shoulder seasons, hunting seasons). Annual recreation use by activity type and season should be quantified to include both formal and informal publicly accessible recreation sites including but not limited to: Mill Creek Campground, Haskins Valley Campground, Sundew Campground, Bucks Lake Boat -in Campground, Sandy Point Day Use Area, Indian Rocks Day Use Area, West End Cove, Bucks Lake Campground and RV Park, Bucks Lake Marina, Lakeshore Resort, Mill Creek Trail, Hutchins Campground, Lower Bucks Lake Campground, Grizzly Forebay Campground, Grizzly Forebay Access, Grizzly Forebay Trail, Grizzly Forebay Gaging Station Trail, and Three Lakes Trailhead. PG &E and the City of Santa Clara should also consult with the Forest Service to evaluate the need of including other Forest Service recreational developments that serve the project into the use assessment. The needs assessment should also include a future demand estimate from both current use and unmet demand based on guidance from Haas et al. (2007). Specifically, the following information should be integrated to 'Haas, G.E., M.D. Wells, V. Lovejoy, and D. Welch. January 2007. Estimating Future Recreation Demand: A Decision Guide for the Practitioner. U.S. Department of -10- provide an estimate of future recreation demand at the project: (1) prior and current project use data (e.g., 2002 recreation studies); (2) state, regional, and national recreation trend data; and (3) population growth data. Assess visitor perceptions of crowding, recreational conflict, the adequacy of recreation facilities and access to the project, and effects of project operations and management on recreation and recreation opportunities at the project (e.g., fluctuating reservoir levels and minimum flow releases). Identify potential measures to alleviate or reduce any negative effects of project operations, to enhance existing recreation opportunities, and (if appropriate) provide additional public access at the project reservoirs or riverine reaches (potential locations, type of facilities and access, and any associated costs). Develop a Recreation Management Plan as outlined in study # 1. Level of Effort and Cost §5.9(b)(7) — Describe considerations of level of effort and cost, as applicable, and why any proposed alternative studies would not be sufficient to meet the stated information needs. The estimated cost of the Use & Needs Assessment Study for the Bucks Creek project is about $65,000, including field studies, study report development, and drafting of a Recreation Management Plan. One field season should be sufficient to collect the required data and prepare the report. Study Request #3 — Whitewater Boating Flow Assessment Goals and Obiectives §5.9(b)(1) — Describe the goals and objectives of each study proposal and the information to be obtained. The goal of this study is to assess the effects of a range of bypassed reach flows on whitewater recreational opportunities on Bucks Creek and Lower Grizzly Creek. The objectives of the study are to: • Determine locations for accessing each bypassed reach for put -ins and take -outs. the Interior, Bureau of Reclamation, Office of Program and Policy Services, Denver Federal Center. Denver, Colorado. -7- Level of Effort and Cost §5.9(b)(7) — Describe considerations of level of effort and cost, as applicable, and why any proposed alternative studies would not be sufficient to meet the stated information needs. The estimated cost of the Recreation Facility Inventory and Impact Monitoring Study is about $25,000, including field studies, study report development, and drafting of a Recreation Management Plan. This figure may moderately increase if additional Forest Service recreation sites that serve the project are included. One field season should be sufficient to collect the required data and prepare the report. Study Request #2 - Use and Needs Assessment Goals and Objectives §5.9(b)(1) — Describe the goals and objectives of each study proposal and the information to be obtained. The goals of the Recreation Use & Needs Assessment Study are to: (1) obtain information about existing recreation use, access, and demand at the project; (2) conduct an assessment of the need to enhance recreation opportunities and access at the project; and (3) develop a Recreation Management Plan using information from all recreation studies. §5.9(b)(2) — If applicable, explain the relevant resource management goals of the agencies or Indian tribes with jurisdiction over the resource to be studied. Not applicable. §5.9(b)(3) —If the requester is not a resource agency, explain any relevant public interest considerations in regard to the proposed study. The Federal Energy Regulatory Commission must decide whether to issue a license to PG &E and the City of Santa Clara for the Bucks Creek Project. Sections 4(e) and 10(a) of the Federal Power Act require the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued. In making its license decision, the Commission must equally consider the environmental, recreational, fish and wildlife, and other non - developmental values of the project, as well as power and developmental values. Any license issued shall be best adapted to a comprehensive plan for improving or developing a waterway or waterways for all beneficial public uses. W Identify all informal and formal public and private recreational sites /facilities within the Buck Creek, Grizzly Creek, and Milk Ranch bypassed reaches. Develop and implement a site condition evaluation criterion of measurable and manageable indictors for facilities and dispersed recreation area conditions. Site condition assessments should be conducted at all formal and informal publicly accessible recreation sites including, but not limited to: Mill Creek Campground, Haskins Valley Campground, Sundew Campground, Bucks Lake Boat -in Campground, Sandy Point Day Use Area, Indian Rocks Day Use Area, West End Cove, Bucks Lake Campground and RV Park, Bucks Lake Marina, Lakeshore Resort, Mill Creek Trail, Hutchins Campground, Lower Bucks Lake Campground, Grizzly Forebay Campground, Grizzly Forebay Access, Grizzly Forebay Trail, Grizzly Forebay Gaging Station Trail, and Three Lakes Trailhead. PG &E and City of Santa Clara should also consult with the Forest Service to evaluate the need of including other Forest Service recreational developments that serve the project into the site condition assessment. Quantify the relationship between reservoir surface area and reservoir levels (i.e., reservoir elevation) for the range of operation (i.e., full pool to minimum reservoir level) at Bucks Creek reservoir. This relationship should also be mapped to visually assess the effects of reservoir levels on reservoir surface area and identify specifics areas that may become inaccessible at lower reservoir levels. Using the information from all recreation studies, develop a Recreation Management Plan for the project. This plan should be included in the license application and should include, at a minimum: (1) description of any proposed protection, mitigation, and enhancement measures, including: location of any proposed facilities and /or access areas (including description and figure depicting the relationship of any proposed facilities to the existing project boundaries), proposed ownership and management of any proposed facilities, associated capital, and operation and maintenance costs, and a timeline for implementation; (2) description of operation and management measures associated with project- related recreation access and facilities; and (3) an adaptive plan for future monitoring of recreation use, impacts, and adequacy of project - related facilities to meet demand over the term of the new license. M • Determine what whitewater boat -types (e.g., rafts, canoes, and kayaks) would be appropriate to utilize any potential whitewater flows in the bypassed reaches. • Determine the range of flows (minimum through optimal) needed to support various whitewater boating opportunities (by watercraft type) in the project bypassed reach. • Determine the number of days per month the minimum and optimum flows for whitewater boating would be available under the project's current and any. proposed mode of operation. • Identify any competing recreational uses (e.g., climbing or fishing) or other resource needs (e.g., aquatic habitat) that may be adversely affected by any scheduled releases. (Note: this objective may need information provided by other recommended studies) • Identify any significant or unique hazards. §5.9(b)(2) — If applicable, explain the relevant resource management goals of the agencies or Indian tribes with jurisdiction over the resource to be studied. Not applicable. §5.9(b)(3) —If the requester is not a resource agency, explain any relevant public interest considerations in regard to the proposed study. The Federal Energy Regulatory Commission must decide whether to issue a license to PG &E and City of Santa Clara for the Bucks Creek Project. Sections 4(e) and 10(a) of the Federal Power Act require the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued. In making its license decision, the Commission must equally consider the environmental, recreational, fish and wildlife, and other non - developmental values of the project, as well as power and developmental values. Any license issued shall be best adapted to a comprehensive plan for improving or developing a waterway or waterways for all beneficial public uses. Comments provided during scoping indicate an interest in studying flows for whitewater boating opportunities on the 7.2 -mile -long bypassed segment of Bucks Creek from Lower Bucks Lake to the North Fork Feather River and the 7.5- mile -long bypassed segment of Lower Grizzly Creek from Grizzly forebay to the North Fork Feather River. These comments suggested that releasing an appropriate amount of water into the bypassed reach could potentially provide whitewater boating opportunities for public use. -12- Background and Existing Information §5.9(b)(4) — Describe existing information concerning the subject of the study proposal, and the need for additional information. The Pre - Application Document (PAD) includes limited information on the bypassed reaches in Section 5.2, including draining area, minimum instream flow requirements, length, and gradient statistics. After reviewing this information and the comments provided during the February 11, 2014 scoping meetings, we have identified a gap between existing information and the information needed to analyze whether flows could be provided to enhance whitewater boating opportunities. We are unaware of any information on the characteristics or boatability of these bypassed reaches, or the range of boatable flows. Project Nexus §5.9(b)(5) — Explain any nexus between project operations and effects (direct, indirect, and/or cumulative) on the resource to be studied, and how the study results would inform the development of license requirements. Project operations divert flows from both the Bucks Creek and Lower Grizzly Creek that could possibly provide whitewater boating opportunities. While Table 5.2 -2 of the PAD states that the maximum flow in the bypassed reach (since the 2006 amendment) was 270.5 cubic feet per second (cfs) for Bucks Creek and 537 cfs for Lower Grizzly Creek, minimum instream flow requirements for Bucks Creek and Lower Grizzle Creek range from 4 cfs to 8 cfs. It is unclear whether these flows plus additional run -off can accommodate whitewater boating. An analysis of:project operation relative to a range of boatable flows would help form the basis for informing potential license articles pertaining to whitewater boating opportunities. Proposed Methodology §5.8(b)(6) — Explain how any proposed study methodology (including any preferred data collection and analysis techniques, or objectively quantified information, and a schedule including appropriate field season(s) and the duration) is consistent with generally accepted practice in the scientific community or, as appropriate, considers relevant tribal values and knowledge. Use accepted practices for a controlled flow study as described in Whittaker et al. (2005)? Due to the lack of information regarding each of these 2 Whittaker, D., B. Shelby, and J. Gangemi. 2005. Flows and Recreation: A -5- Background and Existing Information §5.9(b)(4) — Describe existing information concerning the subject of the study proposal, and the need for additional information. Section 5.8 of the Pre - Application Document (PAD) provides a general description of public recreation resources and facilities at the project. However, the PAD provides no detailed information regarding the condition of existing facilities or information regarding visitor perceptions and identified needs at the project. Information on current conditions at existing facilities and dispersed recreation areas at the project would inform a decision on whether current public access facilities and locations at the project are providing appropriate and safe recreation opportunities and if existing operational and management measures are adequate. Project Nexus §5.9(b)(5) — Explain any nexus between project operations and effects (direct, indirect, and/or cumulative) on the resource to be studied, and how the study results would inform the development of license requirements. The project includes four reservoirs and two bypassed reaches with recreational opportunities. An inventory and condition assessment of project recreation facilities, as well as an assessment of resource impacts at developed and dispersed recreational sites from recreational use would help form the basis for determining the project's ability to enhance public recreation access opportunities and would provide information necessary to develop a long -.term monitoring plan for recreation facilities over the term of a new license. Proposed Methodology §5.8(b)(6) — Explain how any proposed study methodology (including any preferred data collection and analysis techniques, or objectively quantified information, and a schedule including appropriate field season(s) and the duration) is consistent with generally accepted practice in the scientific community or, as appropriate, considers relevant tribal values and knowledge. Update existing data on recreation resources adjacent to and within the project through site assessment and consultation with public and private recreation providers. Update the inventory of informal and formal public and private waterfront recreational sites /facilities within and adjacent to the project boundary. -4- SCHEDULE B —STUDY REQUESTS Study Request #1– Recreation Facility Inventory, Impact Monitoring, and Reservoir Level Mapping Goals and Objectives §5.9(b)(1) – Describe the goals and objectives of each study proposal and the information to be obtained. The goals of the Recreation Facility Inventory and hnpact Monitoring Study are to: (1) obtain information about the condition of existing recreation facilities and access sites at the project; (2) conduct an assessment of the need to enhance recreation facilities and access at the project; (3) quantify and map the relationship between reservoir surface area and reservoir levels; and (4) develop a Recreation Management Plan for the implementation of any enhancement measures and long -term monitoring of the condition and adequacy of facilities at the project over the term of a new license in coordination with other recreation studies. §5.9(b)(2) – If applicable, explain the relevant resource management goals of the agencies or Indian tribes with jurisdiction over the resource to be studied. Not applicable. §5.9(b)(3) – If the requester is not a resource agency, explain any relevant public interest considerations in regard to the proposed study. The Federal Energy Regulatory Commission must decide whether to issue a license to PG &E and the City of Santa Clara for the Bucks Creek Project. Sections 4(e) and 10(a) of the Federal Power Act require the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued. In making its license decision, the Commission must equally consider the environmental, recreational, fish and wildlife, and other non - developmental values of the project, as well as power and developmental values. Any license issued shall be best adapted to a comprehensive plan for improving or developing a waterway or waterways for all beneficial public uses. Recreation has been identified as a project purpose by the Commission. Applicants are encouraged to develop recreation resources in such a matter that is "consistent with the needs of the area to the extent that such development is not inconsistent with the primary purpose of the project" (18 C.F.R. §2.7). Identifying effects of project operations pertaining to this resource is relevant to the Commission's public interest determination. -13- bypassed reaches, this study should use a sequential three- phased approach. • Phase I. Use a desktop analysis to identify access options to each bypassed reach, create a gradient profile for each bypassed reach, and identify any other flow- related information that may be pertinent to recreation in the bypassed reach. • Phase II. Use experienced whitewater boaters to conduct an on -land feasibility assessment by scouting each bypassed reach to examine the potential quality and characteristics of boating opportunities, estimate potential flow ranges, identify any obvious hazards, and determine whether an on -water controlled flow study is needed to evaluate whitewater recreational opportunities in the bypassed reach. • Phase III. If determined necessary by Phase II, use an on -water controlled flow evaluation to determine the acceptable minimum and optimal instream flow needed for whitewater boating in the bypassed reach. Prepare a study report for each phase of the study. The Phase I report should include a description of potential access options to each bypassed reach, a gradient profile for each bypassed reach, and any additionally pertinent information identified about flows and recreation in the bypassed reaches. The Phase II report should include an assessment of study participants evaluations for potential quality and characteristics of boating opportunities (e.g., difficulty, type of run, type of crafts likely suitable for the run), estimated potential flow ranges, obvious hazards (e.g., woody growth in the river bed), and recommendations for implementing Phase III. The Phase III report (if necessary) should include a description of the whitewater boating attributes of the range of flows examined (e.g., difficulty, unique features, portage requirements), determine the acceptable and optimal flows for each reach, the frequency of availability of the identified flows under current and any proposed project operation, and incorporate relevant results from other studies to identify any competing recreational uses (e.g., climbing or fishing) or other resource needs (e.g., aquatic habitat) that may be adversely affected by any scheduled releases. Level of Effort and Cost §5.9(b)(7) – Describe considerations of level of effort and cost, as applicable, and why any proposed alternative studies would not be sufficient to meet the stated information needs. Guide to Studies for River Professionals. -14- The detailed study protocol, logistics, and schedules of this study should be developed in consultation with interested stakeholders. The estimated cost of the whitewater boating flow assessment is approximately $50,000, depending upon the extent of fieldwork conducted. -3- SCHEDULE A-- ADDITIONAL INFORMATION REQUESTS Recreation and Land Use In the Pre - Application Document (PAD) you provide monthly mean, minimum, and maximum flows for project- affected streams downstream of project reservoirs (Table 5.2 -2). However, this table does not provide the duration of time these flows were provided to the bypassed reach or a median flow for each month. Therefore, so that we may fully understand flow conditions in the bypassed reaches of the project, please provide monthly flow duration curves and median flows for Bucks Creek, Grizzly Creek, and Milk Ranch Creek bypassed reaches since 2006. In the PAD you provide average and median monthly water surface elevations at the Bucks Creek reservoir (Figure F -1). However, you do not provide the duration of time these reservoir levels were present, the reservoir levels at peak recreation times of the day, nor do you stratify this data by wet and dry years. Therefore, so that we may fully understand the most recent conditions of reservoir level at the Bucks Creek reservoir, please provide monthly duration curves of Bucks Creek reservoir levels between the hours of 6:OOam- 9:OOpm from 2006 - present. Additionally, because current operations dictate that reservoir levels on June 1 serve as the baseline for summer reservoir level management, please provide a table with the reservoir elevation on June 1 from 2006 - present stratified by wet and dry year. In the PAD, tables 5.8 -1, 5.8 -5, 5.8 -7 list the name, type, capacity, amenities, and landownership /manager of each recreation site at the "project area." However, it is unclear whether or not these facilities are inside the project boundary and whether you as the licensee have ultimate responsibility for the use and conditions at each site. Please confirm which recreation sites listed in these tables are part of the current license requirements. -a- cc: Mailing List Public Files FEDERAL ENERGY REGULATORY COMMISSION WASHINGTON, D.C. 20426 APR, 9 2014 OFFICE OF ENERGY PROJECTS Project No. 619 -158– California Bucks Creek Project Pacific Gas & Electric Company and City of Santa Clara, California Alvin L. Thoma, Director —Hydro Licensing Pacific Gas & Electric Company Power Generation, Mail Code: NI IC PO Box 770000 San Francisco, CA 94177 Reference: Comments on the Draft Proposed Study Plan and Request for Studies and Additional Information Dear Mr. Livingston: After reviewing Pacific Gas & Electric Company (PG &E) and City of Santa Clara's Pre - Application Document (PAD) for the Bucks Creek Project and participating in the February 11, 2014, scoping meetings, Commission staff has additional information needs (attached in Schedule A), and study requests (attached in Schedule B). Please file your responses to schedules A and B with your proposed study plan that is due on May 29, 2014. As appropriate, we may request additional information or studies or provide input on proposed or requested studies after you file the proposed study plan. If you have any questions, please contact Alan Mitchnick at (202) 502 -6074 or alan.mitchnicknferc.gov. Sincerely, U T. thy J. Welch, Chief West Branch Division of Hydropower Licensing Attachments: Schedules A and B m m az a r C = M n �> 0 F c w o aw C N t N m tr•, °f o w 3 fsf Lo C Z r CTI C) o o D w. —I O m "u: cfl CD cn OC Cz z. GO < -, DO O O �0 <....... .w CD 4 + Cr MD