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L A W O F F I C E S O F 1 5 0 0 K S T R E E T , N W ♦ S U I T E 3 3 0 ♦ W A S H I N G T O N , D C 2 0 0 0 5

GGG KKK RRR SSS EEE 202.408.5400 ♦ FAX: 202.408.5406 ♦ WEBSITE: www.gkrse-law.com

July 20, 2011

Ms. Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington D.C. 20426 RE: Public Utility District No. 1 of Okanogan County;

Enloe Hydroelectric Project, FERC Project No. 12569; Summary of PM&E Measures

Dear Ms. Bose:

Enclosed for filing in the docket for the pending application for license by the Public Utility District No. 1 of Okanogan County’s (“District”) for the Enloe Dam Hydroelectric Project (“Project”), Project No. 12569, is a summary of the District’s Protection, Mitigation, and Enhancement (“PM&E”) measures. On June 7, 2011, the District supplied comments on the Federal Energy Regulatory Commission’s draft environmental assessment, and indicated that it would produce a summary of the PM&E measures proposed for the project. This filing contains a comprehensive table of the PM&E measures.

Should you have any questions or comments, please contact the undersigned.

Sincerely,

Donald H. Clarke Counsel for the Public Utility District No. 1 of Okanogan County

Enclosure

CERTIFICATE OF SERVICE

I hereby certify that I have on this day served the foregoing document

by email or first class mail postage prepaid upon each person designated on the

official service list compiled by the Secretary of the Commission in this

proceeding.

Dated at Washington, DC this 20th day of July 2011.

Manuel Sandoval Legal Assistant Law Offices of GKRSE

1500 K Street, NW, Suite 330 Washington, DC 20005

Enloe Hydroelectric Project Summary of All PM&E Measures July 15, 2011

1

Proposed PM&E Measures Description Source WQ‐01: Temperature Monitoring

Water temperatures will be monitored at three locations for a period of 5 years to determine if the operation of crest gates causes an increase in the 7‐DADMax water temperatures compared to upstream of the reservoir.

FLA (August 2008)

WQ‐02: Location of the Powerplant Tailrace

To preserve water quality in this habitat, the powerplant tailrace was located such that the discharge circulates water to the pool preventing stagnation and consequent water quality degradation (i.e., high water temperatures and low dissolved oxygen) of the pool habitat.

FLA (August 2008)

WQ‐03: Provide Aeration in Flow Tubes

To minimize the loss of aeration by diverting water around the dam and to maximize DO concentrations during the critical summer season, aeration will be provided in the flow tubes of the turbines. The aeration vents will be blocked during high spring flows when high TDG is a concern and DO concentrations are not low. Adaptive management monitoring during the first five years of project operations will determine the optimal time to provide aeration in the flow tubes. The approach includes installing a small manifold around the perimeter of the draft tube and injecting air using a small blower.

FLA (August 2008)

WQ‐04: Dissolved Gas Monitoring (TDG and DO)

Dissolved gas concentrations will be monitored at the Project intake and in the pool below the falls to determine TDG under project operations.

FLA (August 2008)

WQ‐05: Headworks Design Project design incorporates a broad, shallow headworks to minimize sediment disturbance, as described in Exhibit A.

FLA (August 2008)

WQ‐06: Erosion and Sediment Control Plan

An Erosion and Sediment Control Plan (ESCP) will be prepared when designs have been finalized. The ESCP will address site‐specific mitigation measures to minimize effects of construction, repair and operation of the dam and intake, penstocks, powerhouse, tailrace, impoundment, access roads, powerline and construction camp. Critical areas within the project footprint identified as sensitive to erosion, slope failure and mass wasting will be identified and a plan will be developed to minimize effects from these areas. As described in Exhibit E.2.8, n Erosion and Sediment Control Plan (ESCP) will be prepared when designs have been finalized. Standard erosion and sediment control measures and site‐specific BMPs developed in the ESCP would also protect riparian and wetland habitats. No additional cost is assigned to this PM&E.

FLA (August 2008) License Application Amendment (September 2009)

WQ‐07: Spill Plan A spill prevention, containment, and clean‐up plan will be prepared and implemented at Project initiation, in order to reduce potential impacts from accidental spills when heavy machinery is operated near the river and reservoir. This PM&E includes development of the plan, training, and the provision of emergency spill containment kits to contain and remove spilled fuels and other fluids. One aspect of the Spill Plan identified in WQ 07 would be to minimize spills to the river and

FLA (August 2008) License Application


2

Proposed PM&E Measures Description Source reservoir by prohibiting fueling of heavy equipment within 500 feet of the river and reservoir during construction. This PM&E would also serve to protect riparian and wetland habitats. No cost additional is assigned to this PM&E.

Amendment (September 2009)

WQ‐08: Construction Sediment Management Program

Best Management Practices (BMPs) will be implemented that include preventative measures to minimize sediment disturbance and maximize sediment containment during construction. In addition, construction near water bodies will be planned to occur during the low flow season to reduce the opportunity for sediment to enter Project waters. Also, a storm water runoff plan and a sediment management plan will be prepared and implemented. A sampling program will be implemented to monitor compliance with water quality standards during construction. Monitoring also will be conducted during a gradual ramp‐up of water diversion at the intake structure. Standard erosion and sediment control measures will be used, and site‐specific BMPs will be developed, including: remove existing slide material; maintain the roadway with crushed rock; construct check dams; install filter fabric fences; grade roads and construction areas toward ditches and sediment traps; mulch and hydro seed in disturbed areas; minimize ground disturbance in or near wetland and riparian habitats.

FLA (August 2008)

BOTA‐01: Prepare a Mitigation and Monitoring Plan

The Vegetation Mitigation and Monitoring Plan (VMMP) for impacts to riparian and wetland vegetation has been developed in consultation with BLM, Ecology, and other stakeholders. The plan may be further developed with further consultation with these stakeholders following issuance of the license. This VMMP includes goals, the species to be used, methods, and benchmarks of success for botanical resources. Restoration of abandoned roadbeds is part of this VMMP, which will has details on surface preparation to deal with compaction issues, seeding, mulching, and planting. Details of cattle exclusion fencing to protect mitigation/restoration areas is also included in the VMMP and provided as Appendix E.3.7 of this document. Noxious weed control measures for the mitigation areas is included in the VMMP (see Appendix E.3.8 for the District’s BLM‐approved Noxious Weed Control Plans). The BLM will have approval authority for the elements of the plan that apply to BLM‐administered lands. Monitoring provisions in the VMMP include monitoring of sites that may convert from upland meadow to herbaceous wetland.

License Application Amendment (February 2009)

BOTA‐02: Plant Riparian Vegetation Along the Reservoir

BOTA‐02 proposes to plant riparian vegetation at previously identified sites along the west and east banks of the reservoir to mitigate for temporary loss of habitat while fringe riparian vegetation establishes along the new low water line. The cost associated with this restoration is expected to be $30,000.

FLA (August 2008)

BOTA‐03: Abandon Existing Shoreline Road

Under BOTA‐03, the existing access road that traverses the riparian zone at several points (Segment B) will be abandoned and restored to natural conditions. The cost of abandoning the Segment B is limited to weed control while natural vegetation

FLA (August 2008)


3

Proposed PM&E Measures Description Source reestablishes (estimated to be 3‐5 years) and is estimated to be $5,000. Costs for restoring the existing road in the riparian zone (Segment C) are included in the cost of riparian mitigation; and are estimated to be $350,000.

BOTA‐04: Plant Riparian Species Along the Corridor

BOTA‐04 proposes the planting of woody riparian species such as willow, alder, or black cottonwood, in the riparian areas of the abandoned road. Expected cost of $15,000.

FLA (August 2008)

BOTA‐05: Plant Riparian Species on East and West Banks Downstream of Shanker’s Bend

This PM&E will plant woody riparian species in the riparian area on the east bank, just downstream from Shanker’s Bend and on the west bank downstream of Shanker’s Bend. Estimated cost of $20,000.

FLA (August 2008)

BOTA‐06: Install Grazing Control Measures

Protective enclosures for individual plants will be used to protect the young plants from consumption by wildlife such as beaver or deer. These enclosures may consist of wire cages or rigid protection tubes at an estimated cost of $20,000. In addition, a temporary fence may be required to protect riparian areas on the west side of the river. The cost for this fence is estimated at $5,000.


BOTA‐07: Monitor Restored Areas and Replant if Necessary

Under BOTA‐07, the District will monitor restored areas annually for five years and provide an annual report of the monitoring results to the USACE and Ecology. The estimated annual cost for monitoring including report preparation, is $10,000; the total cost for 5 years would be $50,000. If the original plantings do not meet the performance criteria in the MMP, additional willows would be planted. Expected cost ranging from $5,000 to $15,000.

FLA (August 2008)

BOTA‐08: Employ BMPs to Protect Riparian and Wetland Vegetation

BOTA‐08 would employ the following BMPs as necessary to protect vegetation: • Flag and temporarily fence any wetland and riparian vegetation in the vicinity of Project

activities that can be avoided in order to prevent accidental impacts. This measure is estimated to cost $2,500.

• Limit construction‐related disturbance of native vegetation as much as possible. No cost is assigned to this BMP.

• Limit vegetation maintenance in sensitive habitats to the extent possible. No cost is assigned to this BMP.

FLA (August 2008)

BOTA‐09: Environmental Training Program

BOTA‐09 requires that the District provide environmental training to inform their employees, as well as employees of contractors and subcontractors who work on the Project Site or related facilities during construction and operation, regarding the sensitive biological resources associated with the Project Area.

FLA (August 2008)


4

Proposed PM&E Measures Description Source The training is estimated to cost approximately $5,000.

BOTA‐10: Provide a Biological Construction Monitor

Under BOTA‐10 the District would provide a biological construction monitor to check construction sites on a weekly schedule to ensure that protected areas are not disturbed and that fencing is intact. Estimated costs for this PM&E assume one monitor for 10 hrs a week at $100 per hour for the 18 months of construction, for a total of $72,000.

FLA (August 2008)

BOTA‐11: Implement a Noxious Weed Control Program

BOTA‐11 requires that the District implement a Noxious Weed Control Program to control noxious weeds along roads and construction sites, following the District’s approved Plan (Appendix E.3.8). Weeds likely to be subject to control measures include three Class B weeds; houndstongue (Cynoglossum officinale), diffuse knapweed (Centaurea diffusa), and sulfur cinquefoil (Potentilla recta), as well as one Class C weed; babysbreath (Gypsophila paniculata).

FLA (August 2008)

BOTA‐12: Survey Disposal Sites and Control Noxious Weeds

• Conduct a plant survey in the growing season preceding vegetation removal at the spoil sites.

• The spoil disposal areas will be surveyed for the noxious weeds addressed in the Vegetation

Mitigation and Monitoring Plan and control measures will be implemented to control any

infestations of those species prior to spoil disposal.

Costs for surveys at the sites are estimated to be approximately $3,000.

License Application Amendment (September 2009)

BOTA‐13: Hydroseed Disposal Sites

Following completion of the spoil disposal, the spoil disposal areas will be hydroseeded with native upland species. These areas will be included in subsequent weed survey and treatment efforts, as described in the Vegetation Mitigation and Monitoring Plan. Costs for hydroseeding areas are estimated to be approximately $13,200 (based on $.05 to $0.05.5 per square foot or about $2,400 per acre).


BOTA‐14: Conduct Surveys for Ute Ladies’ Tresses

• These surveys would be conducted in the summer/fall and can be timed to correlate with the

flowering period for the Ute ladies’ tresses. Surveys for Ute ladies’ tresses would be conducted

for an additional three years (in addition to two years of surveys already conducted).

Estimated cost for would be $10,000 for each of 3 years for Ute ladies’ tresses monitoring and reporting. Thereafter, Ute ladies’ tresses would be resurveyed only if site management changes occur that could affect the potential habitat for this species.



5

Proposed PM&E Measures Description Source FISH‐01: Blasting Plan and Best Management Practices

The following measures will be implemented to avoid and minimize the potential impacts associated with blasting to aquatic resources including federally listed or sensitive species: • The project is designed so that most facilities are located out of the present river channel so

that rock excavation will be carried out in dry conditions and that rock between the excavation and the river will attenuate vibration.

• Proven controlled blasting techniques will be employed for rock excavation. This involves careful planning of the timing of blasting operations, use of special drilling patterns, and use of small charges that are set off with time delays to minimize peak vibration and pressure waves.

• Blasting pressure waves that could coincide with occupation of area by fish will be monitored using hydro phones. Pressure wave criteria that are potentially harmful to fish will be established and a contingency plan for construction will be developed if pressure wave criteria are exceeded. It is estimated that creation of hydrostatic pressure waves in exceedance of 100 kilopascals (kPa or about 14.5 pounds per square inch) or noise levels exceeding 190 decibels (dB) should be avoided, as practical.

• Impacts will be minimized by timing near‐ and in‐water blasting to coincide with the lowest water levels (low flows) combined with lowest low potential for fish occupation in the area with a focus on avoiding periods where federally listed or sensitive salmonid species are present. Blasting adjacent to the stream will take place prior to spring high flow or during fall low flow.

• The amount of time that near or in water construction and blasting occurs will be minimized. The area of most concern is excavating the downstream end to the tailrace channel where construction activities will be expedited to reduce the amount of time fish may be exposed to effect of blasting activities.

• Impacts will be minimized or avoided by removing as many fish as practical from the area adjacent to the proposed blasting and installing an exclusion barrier downstream of the potentially affected area to prevent entry of additional fish into the affected area.

• Mechanical excavators with hydraulic rock hammer attachments will also be used in lieu of blasting to trim the excavation, excavate rock in areas unsuitable for blasting and to excavate loose rock. When removing materials from areas that are excavated through blasting, the District will remove residues from the blasting operation to the extent practical.

The expected costs associated with FISH‐01 are $100,000. Further breakdown of the costs include: Specialized controlled blasting consultant ‐ $15,000 Developing a controlled blasting specification ‐ $10,000 Contractor's controlled blasting plan ‐ $10,000 Acquire blast monitoring equipment ‐ $15,000 Monitoring blasting ‐ $35,000

FLA (August 2008)


6

Proposed PM&E Measures Description Source Temporary Downstream Barrier and Fish Relocation ‐ $5,000 Monthly Data Reports/correspondence ‐ $10,000

FISH‐02: Placement of Boulder Clusters

In the reach of river upstream of the impoundment, the habitat has very little diversity and habitat quality is most likely a limiting factor for resident fish. The District proposes to place two clusters of one ton to two ton boulders in riffles or in plane‐bed sections of the Similkameen River upstream of the reservoir. The PM&E will increase structural diversity and improve the quality of habitat. The objective of boulder cluster placement is to 1) alter patterns of scour to promote formation of small pools, 2) alter patterns of sediment deposition to trap spawning gravels for resident fish species, 3) increase cover for resident fish species and 4) increase hydraulic complexity including velocity refugia and feeding lanes. The costs of these habitat improvements are estimated to be $60,000. Approximately $10,000 would be needed to research the best location for the clusters, $25,000 would be used for construction of the clusters, and approximately $15,000 would be used in monitoring and reporting and $10,000 would be for permitting costs.

FLA (August 2008) License Application Amendment (February 2009)

FISH‐03: Transport of Large Woody Debris

LWD can be an important element of fish habitat. To prevent the loss of LWD from downstream habitats, logs and other LWD will be allowed to pass over the spillway during the annual flood and will continue downstream naturally. If needed, some LWD may be transported around the dam and placed in the river downstream of the dam. From there, the natural hydraulic force of the river will transport the LWD to downstream habitats. The annual cost of transporting LWD, including temporarily removing the log boom, is estimated to be $4,000 annually. The transport activity is expected to occur once during the recession of the high flow period.

FLA (August 2008)

FISH‐04: Modified Intake Trashrack

Several factors were considered in developing this PM&E to protect the existing fishery upstream of Enloe Dam including: • There are no state‐ or federally‐listed threatened or endangered species upstream of the Enloe

Dam. • The potential for the presence of salmonids in the area of the intake is minimal and therefore

the risk of entrainment is low. • Fish abundance in the reservoir is low, and the majority of the species present are cyprinids

(minnow species). • Turbine survival for smaller fish that might be incapable of avoiding entrainment if they come in

close proximity to the intake would be relatively high (Tables E.3‐7 and E.3‐8 and Appendix E.3.2).

Larger fish capable of swimming away from the intake should be discouraged or prevented from

FLA (August 2008)


7

Proposed PM&E Measures Description Source passing through the intake so that they remain in the upstream fishery. The proposed intake trashrack will have bars spaced such that smaller fish can pass safely through the racks without becoming impinged and larger fish will be discouraged or prevented from passing through the turbines. As described previously in this Exhibit, larger fish have a greater swimming ability and can easily move back upstream and avoid impingement on the rack. A description of the proposed trashrack is included in Exhibit A. The cost of reducing the trashrack bar spacing from that which would otherwise be required solely for protection of the turbine unit from large debris is estimated to be about $30,000.

FISH‐05: Entrainment Studies and Fish Monitoring

During the initial phase of project operation, the magnitude of entrainment impacts will be estimated with studies designed to 1) examine seasonal variation in entrainment susceptibility, 2) observe trauma and mortality associated with placement of fish species in the power canal, and 3) sample fish in the reservoir to relate the entrainment observations with the fish distribution and abundance in the reservoir. Potential losses will be mitigated through the habitat enhancement project described below. Entrainment susceptibility represents a potential loss of fish from the upstream fishery regardless of the survival rate through the turbine. Possible injury or mortality through the turbine represents a potential impact on the ability of the downstream fishery to recruit resident fish from the upstream fishery. These issues will be examined by placing nets in the tailrace discharge for the purpose of trapping fish that may pass through the turbines. Live fish captured in the nets will be examined for evidence of physical trauma and mortality, and results will be recorded. Entrainment into the power canal is a function of seasonal variation in fish density, seasonal variation in approach velocities (as a function of discharge), fish size, and species‐specific swimming capability. Surveys in the reservoir suggest that fish densities in nearshore environments vary substantially with season (Table E.3‐2). To gain an understanding of the magnitude of the potential impact, it will be necessary to seasonally examine fish entrainment. The District proposes to conduct quarterly fish sampling over a one‐year period. Sampling will occur at fixed intervals (e.g., every six hours) over two consecutive 24‐hour periods for each quarterly sampling period. Given the low fish densities observed in the reservoir, field crews may capture only small numbers of fish in the tailrace. In this event, the sampling crew will capture fish in the reservoir margins with a seine and place fish directly in the intake canal to observe actual mortality and trauma associated with passage through the turbine, given a known quantity and size of fish. This information will allow an estimate of mortality and injury of fish passing through the power plant, but not the number of fish entrained under normal operating conditions. If the number of fish entrained is low under normal conditions, then the loss of fish from the upstream fishery would be low, and the

FLA (August 2008)


8

Proposed PM&E Measures Description Source potential for recruitment of individuals to the downstream fishery would also be low, regardless of the injury or mortality rate. If the number of entrained fish is higher, at least for certain portions of the year, the mortality and injury estimates will assist in determining the magnitude of the reduction in potential recruitment of individuals to the downstream fishery. To relate the fish entrainment data with the fish distribution and relative abundance of fish in the reservoir, a fish monitoring program would be conducted in conjunction with the entrainment studies. The reservoir sampling efforts would be enacted using methods outlined in the ENTRIX technical fisheries report on Enloe Reservoir (ENTRIX 2007). The methods would involve minnow traps and seining in the margins of the reservoir and gill netting in the deeper portions. The expected costs associated with the study are $80,000 for entrainment sampling and $20,000 for the reservoir monitoring study.

FISH‐06: Tailrace Net Barriers The District proposes to make the tailrace a safe refuge for fish. The walls and floor of the tailrace will be excavated bedrock similar to the existing bedrock channel downstream of the falls. Conical net barriers are proposed for the draft tube exits to prevent fish in the tailrace from swimming upstream into the draft tubes during periods of low flows. The net barriers are described in Exhibit A; operation of the net barriers is described previously in this Exhibit. The initial cost of the net barriers including frames and guides is estimated to be about $20,000. Operation and maintenance of the barriers, including annual repair or replacement of the nets is estimated as an annual expense of $5,000.

FLA (August 2008)

FISH‐07: Tailrace Video Monitoring

Observations of the openings of the net barriers will be conducted using suspended underwater video cameras. The study will document that adult salmonids are not entering the nets at the downstream end of the barriers, or if some individuals do enter the nets, they are able to safely exit the barrier. Observations will be made during periods of peak presence in the tailrace for each of the three anadromous salmonid species during each of the first two years of operation. If fish are observed entering the openings, different materials could be attached to the downstream ends of the barriers to further discourage entry. The cost of this video monitoring study is estimated to be $20,000.

FLA (August 2008)

FISH‐08: Run‐of‐River Operations

During normal operations the Project will be true run‐of‐the‐river and there would be no detectable changes in flow below Similkameen Falls. Downstream flow impacts that might occur from operation of the crest gates will be prevented by operating the crest gates to maintain a constant predefined reservoir elevation. During an unexpected shutdown, the flows would switch from running through the powerhouse to spilling over the crest gates. There is no additional cost for implementation of the FISH‐08.

FLA (August 2008)


9

Proposed PM&E Measures Description Source FISH‐09: Relocation of Tailrace To avoid impacts to fish that use the holding area below Similkameen Falls, the original tailrace

location was changed. The original tailrace entrance was located downstream of the large pool that serves as a holding area for salmon and steelhead and would have not provided fresh water circulation to the pool. The new location of the tailrace was chosen to provide improved circulation and water exchange in the pool, therefore providing good water quality for fish. This is an important feature of the Project and was implemented to avoid impacts to pool habitat below the falls. The estimated cost of relocation of the tailrace was $112,000.

FLA (August 2008)

FISH‐10: Side Channel/Off Channel Development/Enhancement

This enhancement project would be feasible at several locations in the lower Similkameen River or nearby in the Okanogan River as described in the technical memo provided in Appendix E.3.3. Appendix E.3.3 provides criteria and conceptual design descriptions for several sites visited in the Project vicinity. A final enhancement project would be chosen by considering input from tribal, state and federal fisheries managers and available resources. The channel will be chosen to focus on addressing two of the most substantial limiting factors for salmonids in the system: high temperatures during low flow and the limited rearing habitat for salmon and steelhead in the system. A channel would need to be of the appropriate size, shape, and geomorphology to maintain suitable physical components during all flow conditions. A shallow well would be constructed to extract the cooler water flowing through the gravel of the streambed. This water would be pumped to perforated PVC pipe buried with spawning‐sized gravel in a modified (but existing) side channel. Water would be pumped through the PVC pipe during critical warm water periods and would provide upwelling of the cooler water. A “low‐technology” structure (e.g., boulders or log(s)) could be anchored at the head of the channel to allow water to enter the side channel during all flow conditions (low flow channel) while deflecting the larger flood flows back into the main channel. The channel would be approximately 300 feet in length and about 30 feet to 50 feet in average width. The side channel enhancement would be accomplished in three phases. The first phase would involve enhancement of the preliminary information including: 1) the use of existing data sources (LIDAR topography, aerial photographs) to evaluate candidate channel construction sites, 2) identification of sources of cold water and pump house locations, 3) examination and comparison of characteristics of known sites, and 4) the selection of one to three candidate project sites for further development and assessment. The second phase would include a more detailed examination of the channel stability, development of flow duration curves, choosing a site, and conducting preliminary design of the project. The last phase would be building, operating, and monitoring the project. It is assumed that monitoring would occur over a five‐year period and would be coordinated with other monitoring efforts in the basin. Fish distribution and relative abundance would be monitored in the enhanced side channel and at three other areas considered

FLA (August 2008)


10

Proposed PM&E Measures Description Source important spawning and rearing areas. Identified trends would be incorporated into the biological review process (see FISH‐12). The costs associated with this FISH‐10 are expected to range from $400,000 to $600,000. Phases one and two are estimated to cost about 15 to 20 percent of the budget, phase three would be distributed into about 60 percent of the total budget for design, building and operating, and 15 to 20 percent for monitoring.

FISH‐11: Gravel Supplementation

The Similkameen River is a gravel‐poor system. Gravels may be held behind Enloe Dam reducing the gravel supply to the lower river. Increasing the amount of gravel in the river downstream of Enloe Dam would improve spawning habitat and has the potential to increase the overall reproductive success of sensitive salmonid species. Spawning gravels (1 to 3 inches in size) will be placed in the active flood plain adjacent to the wetted area during the low flow period. Gravels will be place in areas that would facilitate the transport of gravel under winter and spring flows. The gravel would be distributed downstream by the hydraulic forces of the river. To be effective at replenishing gravels in existing spawning areas or in developing gravel bars or deposits that might be considered “new” habitat, it has been suggested that gravel be placed in the main channel of the Similkameen upstream of the bridge crossing in Oroville (J. Arterburn, pers. comm. 2008), which is also upstream of spawning habitat areas currently utilized in the Similkameen River (see Figure E.3‐1). Truck access to this site appears to be good, it is an area where gravel would be transported downstream by river flow, and it is located upstream of a 3‐mile long reach known to be utilized by spawning steelhead. The District would place a large volume of gravel in the active channel during the low flow season. The estimated volume of gravel to be placed would be 3,000 cubic yards. This amount would provide for approximately 5 percent coverage of the first mile of river channel downstream of the gravel stockpile. It may require 1 to 3 years to distribute the stockpiles. At an estimated cost of $15.00 per cubic yard, costs would be approximately $45,000 for a one‐time stockpiling of gravel in the transport zone. Gravel placement would begin post license at Year 3 when the Project is constructed. The subsequent stockpiles would be placed every 5 years for the next 20 years (e.g. Year 8, Year 13, Year 18, and Year 23).

FLA (August 2008)

FISH 12: Biological Review Process

To provide for ongoing refinement and measure of effectiveness of the PM&Es, the District plans to establish a Biological Resources Program, Technical Review Group (TRG). The TRG will be composed of specialists from the CCT, BLM, Ecology, WDNR, NOAA Fisheries, USFWS, and WDFW. The TRG will be formed to: a) consult with the agencies in the design of management and monitoring plans, b) review and evaluate data, and c) develop resource management proposals or other recommendations. The group’s meetings will be open to the public. The District will prepare the

FLA (August 2008)


11

Proposed PM&E Measures Description Source agendas, conduct the meeting, and maintain and make public all records of consultation. The District will provide these records with any recommendations to the appropriate agencies. The group will establish communication protocols to facilitate interaction among group members, which will allow for open participation, peer review, and communication among all parties. Data and information from these programs will be used to examine long‐term trends and make decisions regarding adapting the PM&Es to protect the aquatic resources. Development of the biological review process is expected to be $15,000. Implementation of the program on an annual basis is expected to be $10,000 a year.

FISH‐13: Development of a Fisheries Monitoring Database

As part of the biological review process, a central database will be developed by the District for organization and storage of the monitoring data related to aquatic resources. Database format and development will be consistent with other aquatic data gathered in the Okanogan River basin. The monitoring programs that would be included in the biological review process are: 1. Entrainment study including reservoir sampling, 2. Tailrace barrier monitoring 3. Monitoring the use of boulder clusters upstream of reservoir 4. Side Channel habitat monitoring program, and Data and information from these programs will be used to examine long‐term trends and make decisions regarding adapting the PM&Es to protect the aquatic resources. Development of the biological database is expected to be $45,000.

FLA (August 2008)

WILD‐01: Transmission Line Pole Relocation

The transmission line pole located within the FERC Boundary will be constructed or modified to prevent raptor electrocutions. This modification is estimated to cost $500.

FLA (August 2008)

WILD‐02: Construction Timing to Minimize Effects on Bald Eagles

WILD‐02 proposes to concentrate construction activities with the loudest noise to occur in summer and early fall to minimize effects to over wintering birds and bald eagles as much as possible. For planning purposes it is assumed that the contractor would be required to work 20 members of the construction crew an additional 10 hours of overtime per week for 20 weeks. Assuming that the average increased cost for overtime is $25 per hour and adding in a contractor markup of 25 percent, the total estimated cost for this PM&E is $125,000.

FLA (August 2008)

WILD‐03: • Conduct vegetation removal between September 1 and March 1 to avoid impacts to License Application


12

Proposed PM&E Measures Description Source breeding birds and whit‐tailed jackrabbit.

• If vegetation removal must be conducted during the breeding season, survey spoil disposal sites for wildlife use prior to vegetation clearance.

• If nesting birds or white‐tailed jackrabbits are present, vegetation removal within 100 feet of the birds or jackrabbits will be postponed until the young are able to leave the area.

Costs for surveys at the sites are estimated to be approximately $3,000. Follow‐up surveys would be as necessary to determine when nesting is completed.

Amendment (September 2009)

HIST‐01: Solicitation for Powerhouse Ownership

Upon receiving a license, the District will solicit interested parties to assume ownership and management of the powerhouse. This solicitation would provide the opportunity for community groups, qualified non‐profit groups, or state, federal, and local government agencies to find an alternative use for the building. The Programmatic Agreement (PA) will specify the period of time during which the District would solicit and review offers, selection criteria, and procedures for signing an agreement. Should a qualified owner not be identified within the specified period of time outlined in the PA, the powerhouse would be demolished as described in HIST‐02. The cost of HIST‐01 is estimated to be $5,000.

FLA (August 2008)

HIST‐02: Demolition and Site Closure

This PM&E would be implemented if a qualified owner is not identified under HIST‐01. The costs of the careful demolition of the powerhouse to create an interpretive site are $85,000. The cost of site closure of the historic powerhouse is anticipated to be $35,000. Implementation off the interpretive site is described below in HIST‐03.

FLA (August 2008)

HIST‐03: Install Interpretive Panels

To preserve information on the current powerhouse, the District will develop and install interpretive panels with information about the history of the powerhouse adjacent to its current site. The District will work with historical societies and community groups to incorporate information on the powerhouse into other resources such as interactive cd‐roms or websites on the role the dam played in community development. The District will retain copies of the HAER documentation for the powerhouse and dam which includes photographs of the dam and powerhouse. Because the condition of the powerhouse has deteriorated since this report was completed, additional photography documenting its current state will be taken. Interpretive materials would be developed and installed regardless of whether a new owner is identified. Development of the interpretive information and installation of the panels are estimated to cost

FLA (August 2008)


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Proposed PM&E Measures Description Source $25,000.

HIST‐04: Review and Agreement on the Draft HPMP

A draft HPMP has been prepared which stipulates specific mitigation measures for known adverse effects to historic resources. Some potential mitigation measures could include working with local historical societies, recreation, and preservation groups to develop and install interpretative panels about the penstock and powerplant; drafting of annotated measured drawings of the powerplant, or creating an interactive cd‐roms or website with historical information on Enloe Dam and Powerhouse. The HPMP also includes information about the ongoing treatment of historic resources within the APE and mitigation measures for archaeological resources. Discussions about the HPMP are continuing with the CRWG to agree upon specific mitigation measures. Review and agreement on the HPMP is not yet advanced sufficiently to have an accurate estimate the costs of these PM&Es.

FLA (August 2008)

ARCH‐01: Conduct Monitoring of Shoreline Areas

The District will conduct monitoring of shoreline areas to prevent damage to previously unrecorded archaeological sites and the NRHP‐eligible archaeological site due to water fluctuations. The HPMP will describe the proposed monitoring plan and the treatment plan for archaeological resources identified as at risk of exposure to avoid loss of important archaeological artifacts and sites. The HPMP will be developed for the filing of the License Application. The total cost of implementation of the plan has not been estimated, however, the costs of monitoring are anticipated to be $65,000.

FLA (August 2008)

ARCH‐02: Avoid Known Eligible Sites

Construction activities that have the potential to affect known eligible sites will be planned, and traffic patterns established, to avoid damage to these sites. The cost of avoiding these sites is estimated at $15,000.

FLA (August 2008)

ARCH‐03: Monitor Eligible Sites During Construction

The District will conduct monitoring of construction areas to prevent damage to NRHP‐eligible archaeological site(s). The HPMP will recommend strategies to minimize ground disturbance during construction. The HPMP will also describe the proposed monitoring plan and the treatment plan for archaeological resources identified as at risk of exposure to avoid loss of important archaeological artifacts and sites. The expected cost for developing the HPMP and monitoring are discussed above for archaeological resources along the reservoir shoreline.

FLA (August 2008)

ARCH‐04: Development of an Inadvertent Discovery Plan

The District has completed the identification and evaluation of the TCPs within the APE. Complete avoidance of all of these areas is not feasible due to their proximity to project facilities. Care will be taken in areas near TCPs. The development of an Inadvertent Discovery Plan that specifies required actions and procedure should a site be accidentally disturbed during construction activities. The District will provide information to its staff and construction workers about the potential for

FLA (August 2008)


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Proposed PM&E Measures Description Source archaeological deposits to be found. The expected costs development of the Inadvertent Discovery Plan is $15,000. The costs of implementation of the plan have not been estimated.

ARCH‐05: Determine Potential Recreational Impacts to Archaeological Sites

The District is discussing the proposed recreation plans with the CRWG to determine if there will be impacts to archaeological sites in the vicinity of the recreation facilities. HPMP will specify necessary mitigation and treatment measures to protect these prehistoric sites. The District will provide information to its staff and maintenance workers about the potential for archaeological deposits to be found. The costs of implementation of the plan have not been estimated.

FLA (August 2008)

REC‐01: Install Barricades and Fencing to Prevent Unauthorized Access

This PM&E measure is intended to protect public health and safety; safeguard the security of the hydropower generating facility; and protect wetlands and riparian areas (including mitigation sites). The proposed measures include a safety/security fence, riparian woodland protection, cattle fencing and barriers to restricted areas (see Fencing Plan provided as Appendix E.3.7). The cost of rock barricades, gates and safety/security fence, stock watering tank, pump enclosure, water line extension: $75,000. The cost of the permanent cattle fence is expected to be: $10,000.


REC‐02: Provide Recreation Access Below Enloe Dam

Options for providing access to the river corridor below Enloe Dam (including portage options) are limited by site factors (including steep, rocky terrain and a confined channel), the generation facility design program, and FERC security requirements. A new road will be built (using the existing road bed where feasible) to provide access to the generation facilities (Segment E on Figure E.7‐2). The District proposes to provide public access to the river below Enloe Dam by allowing foot access along the new road to connect with the old access road and existing trails. The new road will be gated at both ends to allow vehicle access only to authorized vehicles. However, visitors (including boaters hand‐carrying kayaks, canoes, and inflated rafts) would be able to walk down Segment E, past the power generation site; therefore, the road, even though gated, is expected to improve access to the water for these boaters. Foot access to areas below the new generation facilities would continue on the existing (abandoned) road and foot trails (see Exhibit G, Map 1). Currently there is no access to the area for people with physical disabilities, and no measures specifically intended to meet the needs of people with physical disabilities are proposed for access to areas below the dam. Due to natural topography and design constraints, the road to the new generating facility will be very steep, making it unsuitable for wheelchairs or other conveyance for people with physical disabilities. Vehicle access to the area below the dam via the new gravelled road would be allowed for authorized users only. Foot access to areas below the new generation facilities would continue on

FLA (August 2008)


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Proposed PM&E Measures Description Source the existing (abandoned) road. This PM&E is subject to federal requirements related to security of the generating facilities. The cost of constructing a new road is included in Exhibit E.3 Proposed PM&E BOTA‐03. There are no other costs associated with REC‐02. This PM&E measure addresses requests from BLM, NPS, the GCWTC and the WWTA, that the District maintain and improve access to the Similkameen River, including portage trails around dam facilities. The construction of the new power generation facilities would require upgrading or replacing portions of the abandoned road which currently provides foot access to areas below Enloe Dam, including the rocky area above Similkameen Falls and the lower reaches of the Similkameen River. The segment of the abandoned road from the proposed recreation site to the site of the 1906 power house would be upgraded for vehicular traffic during construction of the proposed new power generation facilities (Figure 17‐1). Options for providing access to the river corridor below Enloe Dam (including portage options) are limited by site factors (including steep, rocky terrain on both sides of the access corridor and a confined channel). Generation facility design and security requirements also limit options for improving access. During the RMP consultation process, the District agreed to designate and improve a single trail for public recreation access to the river below Enloe Dam. Foot access would be allowed along the upgraded access road. The old roadbed would be improved from the termination of the upgraded access road (in the vicinity of the old 1906 powerhouse) down to a terminus on the east bank of the Similkameen River below the dam as shown in Figure 17‐1. Below the dam, the District will examine the various trails that lead from the abandoned road down to the river’s edge and select one to improve, mark and maintain. The District will take measures to close and abandon other trails, as appropriate. Because the safety fence will be installed on the waterward side of the road leading to the generating facilities, visitors (including boaters hand‐carrying kayaks, canoes, and inflated rafts) will be able to walk down the improved access road, past the power generation site, and along the unimproved access trail to its terminus at the river. These enhancements will improve access to the water for boaters, fishers and other recreational users. Cultural resources interpretive signs will also be provided, as shown in Figure 17‐1.

AIR Responses (January 2009)


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Proposed PM&E Measures Description Source REC‐03: Transfer Ownership of the Trestle Bridge

This PM&E measure has been removed from the application. Transfer of ownership of the trestle bridge represents a side agreement previously concluded with Okanogan County. Documentation of the side agreement between the District and Okanogan County is included in Appendix E.7.2.


REC‐04: Improve Existing Informal Boat Ramp

To mitigate for the loss of these recreational sites, the District proposes to replace the existing informal hand‐launch/take‐out ramp with an improved ramp. These improvements will facilitate access to the river trail. Detailed plans will be developed following the FERC’s licensing decision. Changes in pool level would be accounted for in designing the ramp. The new ramp would be accessible to vehicles for loading; the proposed new parking area (described below under the heading “Potential changes in type and intensity of recreational use”) would be located a few yards away. To protect wetlands and riparian resources, fencing would be installed as described in Appendix E.3.7 to prevent vehicles and livestock from entering the riparian woodland (site of the existing informal ramp). The cost of replacing the boat ramp is estimated to be $75,000. Access to a riparian area on the east bank of the Similkameen River, just downstream from Shanker’s Bend, would also be restricted. The area is used as a boaters’ take‐out. Parts of the area would be permanently inundated due to the use of crest gates on the dam. In addition, the area will be fenced to prevent damage to wetlands by livestock. The District proposes to erect a sign facing the water advising boaters to use an alternative take‐out.


REC‐05: Clean Up and Restore Wooded Area on East Bank

Cleaning up and restoring the wooded area on the east bank of the reservoir would enhance visitor experience. Clean up would include removing trash, auto bodies, and other debris from the area. Restoration would include planting native vegetation appropriate to the site in areas that have been degraded by vehicle use and camping. The proposed changes are not expected to affect views of the area from Enloe Dam or to encourage visitors to enter the area. The area is expected to be more visually appealing after trash and debris have been removed. Initially, visual impact related to planting would be minimal; the appearance of the area would change as the plants mature. Currently, dense vegetation, including thick stands of poison ivy, covers much of the area, and the District does not plan changes that would make those heavily vegetated areas more accessible. A detailed clean up and restoration plan will be developed after the licensing decision. Expected costs for this would be $10,000.

FLA (August 2008)

REC‐06: Develop an Interpretive Publication

In collaboration with Okanogan County, the Greater Columbia Water Trail Steering Committee, and other interested parties, the Disrict will develop an interpretive publication, including a map of the Enloe Dam area that illustrates recreation sites and access. Topics to be addressed will be determined after the FERC’s licensing decision. Costs for this are anticipated to be $5,000.

FLA (August 2008)


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Proposed PM&E Measures Description Source REC‐07: Remove Existing Trash and Conduct Annual Cleanup

The District proposes to remove existing trash from the following areas: The wooded area on the east bank of the reservoir, just above Enloe Dam The OTID Ditch Road access leading from the Loomis‐Oroville Road to the dam site The District also proposes annual clean up to remove dumped materials. The initial effort is expected to cost approximately $5,000. Ongoing trash removal will likely cost an average between $500 and $1,000 annually.

FLA (August 2008)

REC‐08: Develop Parking Area This PM&E proposes to develop a parking area with a universally‐accessible vault toilet near Enloe Dam. Both the developed parking area and the accessible toilet would meet the needs of people with disabilities. Those measures would provide accessible recreational resources for a new user group as there are currently no facilities available for people with disabilities. The cost of these facilities is estimated at $100,000.


REC‐09: Install Picnic Tables REC‐09 would install picnic tables near the parking area. Shading will be provided by existing trees. The cost of these improvements is estimated at $15,000.

FLA (August 2008)

REC‐10: Develop Primitive Campsites

REC‐10 proposes to develop primitive campsites near the parking and picnic area described above. The campsites will also help to mitigate for closure of the riparian woodland to camping, described under the heading “Displacement of Uses Due to Increase in Inundated Area and Access Restrictions” above. The cost of the improvements is estimated at $25,000.


REC‐11: Interpretive Signs Under REC‐11 the District would place interpretive signs in the area near Enloe Dam that is accessible to visitors. Signs would include, at a minimum, one sign near the parking and picnic area and a second sign at or near the abutment of the old powerhouse access bridge, below Similkameen Falls at an estimated cost of $5,000. Contents of the signs will be determined following the licensing decision.

FLA (August 2008)

REC‐12: Information Board Place an information board in the area near Enloe Dam that is accessible to visitors. At a minimum, the information board will display a map showing river access points in the Project Area and information about visitor use of the Project Area. The District will consult with the BLM regarding design, placement, and any necessary environmental clearances related to the information board. The cost of erecting the information board is estimated to be $2,500.

FLA (August 2008)

REC‐13: Recreation Management Plan

The District has prepared a Recreation Management Plan (RMP) in consultation with the BLM, NPS, RCO, Washington Department of Natural Resources (DNR) and other federal, state, local and tribal agencies. In addition to public agencies and tribal representative, several grazing lessees that currently use project lands also participated in preparation of the RMP. The RMP was filed with FERC on February 27, 2009.



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Proposed PM&E Measures Description Source AES‐01: Use Visually Compatible Colors and Building Materials

Previously described PM&Es AES‐01, BOTA‐02, BOTA‐07, and BOTA‐08 will mitigate visual effects to recreational users below the dam. Under these PM&Es the District will use materials that are compatible with the site and are natural in appearance, appropriate in color and texture, and non‐reflective. Locations of facilities may be sought as a means to minimize visibility from KOPs. Grading, planting grasses, and repairing slopes damaged by erosion would be accomplished as the new facilities are constructed.


AES‐02: Consult with the CCT during Restoration Activities

This PM&E requires that the CCT be consulted during the restoration activities as there are known Traditional Cultural Properties within the APE. Coordination is estimated to cost $20,000.

FLA (August 2008)

AES‐03: Use Non‐Reflective Surfaces Where Possible During Construction

Non‐reflective surfaces will be used where possible during construction. There is no additional cost associated with AES‐03. Areas disturbed during construction will be protected as required by BOTA‐08, monitored (BOTA‐03), and restored (BOTA‐02).


AES‐04 The District plans to make trail improvements that will create closer and more intimate views of the falls from viewpoints that are not currently easily accessible to the public. The trail will be linked to the recreational improvements made above the dam and provide visitors with a trail with closer views of the falls and greater accessibility to the area below the dam. Interpretive signage, in concert with PM&E HIST‐03, will also be placed along the trail to highlight historical flows over the dam. This new trail will help to replace views partially blocked by the construction of new Project facilities and provide closer access to the falls for recreators during periods of high flows and high visitation.


SAFETY‐01 The District will continue to maintain the existing signs and system of safety cables and grab ropes above the dam. As recommended by FERC, the existing system of safety cables and grab ropes is located more than 300’ from Enloe Dam and the proposed intake channel at a narrow point in the river. The cables and grab ropes serve as a means of restraint and escape for people approaching the spillway that were not able to exit the water at the boat launch as directed by instructional signs and warnings. The District will also install canoe/kayak portage signs informing boaters and paddlers where to take out. Portage signs will be large enough to direct canoeists and kayakers to the take‐out location. As is currently the case, information on the signs will be printed in English and Spanish. The size of lettering, and the signs themselves, will be of sufficient size. Dam safety/warning signs will be designed so that when a boater is 300 feet away, the signs will be legible and easily noticed. Text on the signs will be worded to convey a message that clearly advises the boater of the real danger with statements such as: “Danger ‐ Dam Ahead”, “Danger of Drowning”, or “Stay Alive by Staying Out”. International symbols indicating “danger” or “hazard” will be included on the signs to alert boaters who cannot read English or Spanish.



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Proposed PM&E Measures Description Source The new boat launch ramp (which will also serve as a portage take‐out for canoeists and kayakers) will be more than 300’ from Enloe Dam and the intake channel. A log boom will be placed at the entrance to the intake channel to serve as a restraining barrier for any boaters or swimmers approaching the intake channel. The total cost of this PM&E measure is expected to be $10,000 initially, and $2,500 annually for ongoing maintenance.

SAFETY‐02: Allow Limited Public Access to the Project Area During Construction

Major construction activities are scheduled to occur at the Enloe site from mid‐2011 through 2013. The District will allow limited public access to the Project Area during the 2‐1/2 year construction period. Public access will be limited to areas upstream of the dam, outside of construction and staging areas. Access to the informal boat launch will be available during most of the construction period. Because of safety and liability concerns, the area along the east bank of the river (extending approximately 250 feet above the dam and 550 feet below the dam), including all areas of active construction and materials stockpiling, will be off‐limits to the public until major construction activities are completed. The off‐limits area will be completely enclosed by a temporary chain link security fence. Signs will be erected at the entrance to main access road alerting visitors that construction activities are taking place and that portions of the site may be closed to public use. The cost of this PM&E measure will be included in the cost of construction


SAFETY‐03: The District will coordinate with BLM and other land owners, as appropriate, to identify options for preventing public access to the old powerhouse. Options include installing fencing and/or gates at key access locations on the west bank of the river between the powerhouse and the old railroad. Warning signs with the words “Danger” and “No Entry” could also be installed at key locations. The fencing and signage could remain in place until another party assumed ownership and management of the powerhouse or until the powerhouse and penstock are demolished and removed. The District will allow 5 years to identify a potential entity to The total cost of this PM&E measure is expected to be $10,000.


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