TOLEDO BEND PROJECT FERC NO DRAFT LICENSE APPLICATION EXHIBIT E - ENVIRONMENTAL EXHIBIT 2.0 PROPOSED ACTION AND ALTERNATIVES

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1 TOLEDO BEND PROJECT FERC NO DRAFT LICENSE APPLICATION EXHIBIT E - ENVIRONMENTAL EXHIBIT 2.0 PROPOSED ACTION AND ALTERNATIVES May 2011 Copyright 2011.Sabine River Authority of Texas and Sabine River Authority, State of Louisiana. All Rights Reserved.

2 Table of Contents 2.0 PROPOSED ACTION AND ALTERNATIVES NO-ACTION ALTERNATIVE Existing Project Boundary Existing Project Facilities Existing Project Operations and Maintenance Activities Project Operations Project Maintenance Activities Existing Environmental Measures Proposed Action Proposed Project Boundary Proposed Project Facilities Proposed Project Operations and Maintenance Summary of Applicant-Proposed Environmental Measures Alternatives Considered But Eliminated From Further Analysis Nonpower License Project Decommissioning...8 Page i Toledo Bend Project No. 2305

3 List of Tables Table Operating characteristics of the existing Project....3 Table Current Toledo Bend Project Operating Guide Rule Curve....3 Table Operating characteristics of the proposed minimum flow unit...6 Page ii Toledo Bend Project No. 2305

4 List of Figures Figure Toledo Bend Project facilities...2 Page iii Toledo Bend Project No. 2305

5 EXHIBIT E - ENVIRONMENTAL EXHIBIT 2.0 PROPOSED ACTION AND ALTERNATIVES 2.1 NO-ACTION ALTERNATIVE The no-action alternative would allow the Authorities to continue Project operations under the terms of the current license, including maintaining the current Project Boundary, facilities, and operation and maintenance procedures Existing Project Boundary The Project Boundary encompasses an area of approximately 204,090 acres, with the reservoir covering approximately 185,000 acres at full pool. The full pool has an active storage capacity of 4,477,000 acre-feet (ac-ft) at 172 feet. Figure shows the Project Boundary below the dam. The Project Boundary includes the tailrace and spillway channel, and extends north encompassing the reservoir up to Murvaul Bayou at river mile (RM) 279. In the reservoir area, the Project Boundary generally includes the area up to elevation 175 feet Existing Project Facilities The existing facilities of the Project include a dam, powerhouse and excavated tailrace, three dikes, gated spillway, and excavated spillway channel, switchyard, and a 394-foot primary transmission line. The Project also includes public recreation facilities and use areas.. The location of major Project facilities is shown in Figure Detailed descriptions of these facilities are provided in Exhibit A of this application. The principal Project facilities as currently licensed are summarized below. A rolled earth-fill dam with a maximum height of 112 feet and a length of 11,250 feet (including saddle dikes). A reservoir with a surface area of 185,000 acres and 1,200 miles of shoreline with an active storage capacity of 4,477,000 ac-ft. A concrete-gravity spillway located on the left abutment (in Louisiana) with a gated-ogee section and a concrete chute and stilling basin. The spillway has a maximum length of 838 feet with eleven 40-foot-by-28-foot Tainter gates. The top of the gates is at elevation 173 feet and the top of the spillway ogee is at elevation 145 feet. A continuous flow of 144 cubic feet per second (cfs) is provided at the spillway from a low-flow sluiceway with an invert elevation of 100 feet. A powerhouse located at the right abutment (in Texas) containing two 58,500 horsepower vertical Kaplan turbines with direct-drive generators, an excavated tailrace channel, and appurtenant electrical and mechanical facilities. Page 1 Toledo Bend Project No. 2305

6 Figure Toledo Bend Project facilities. Page 2 Toledo Bend Project No. 2305

7 2.1.3 Existing Project Operations and Maintenance Activities Project Operations A summary of the operating characteristics of the existing Project is presented in Table Table Operating characteristics of the existing Project. Normal maximum water surface area (at 172 ft) 185,000 acres Normal maximum water surface elevation 172 ft Gross storage capacity of reservoir 4,477,000 ac-ft Number of turbines 2 Turbine type Kaplan Minimum hydraulic capacity 1,350 cfs/unit Maximum hydraulic capacity 8,500 cfs/unit Installed (rated) capacity 81 MW (40.5 MW/turbine) Dependable capacity 80 MW Average annual energy production (since 1972) 239,635 MWh Since 2007 amendments to the Power Sales Agreement, the Project is operated in accordance with an Operating Guide Rule Curve (Table ) that governs the production of both primary and secondary power as defined by the Power Sales Agreement. Primary power is produced from May through September and can be generated at any time the water surface elevation is above 168 feet. Secondary power is produced throughout the year when the reservoir is above the seasonal elevations indicated in the Operating Guide Rule Curve. Table Current Toledo Bend Project Operating Guide Rule Curve. Month Reservoir Elevation (feet msl) Plant Operation October thru December Below 168 Above 168 No power generated. Operate plant up to full capacity based on available water January Below Above No power generated. Operate plant up to full capacity based on available water February Below 169 Above 169 No power generated. Operate plant up to full capacity based on available water March Below Above No power generated. Operate plant up to full capacity based on available water April 1-15 Below 170 Above 170 No power generated. Operate plant up to full capacity based on available water April Below 171 Above 171 No power generated. Operate plant up to full capacity based on available water May Any stage Above 168 Above 172 Use Volume necessary to meet Prime Power Schedule (see Note 2) Operate plant up to full capacity June Any stage Above 168 Above 172 Use Volume necessary to meet Prime Power Schedule (see Note 2) Operate plant up to full capacity July Any stage Above 168 Above 172 Use Volume necessary to meet Prime Power Schedule (see Note 2) Operate plant up to full capacity August Any stage Above 168 Above 172 Use Volume necessary to meet Prime Power Schedule (see Note 2) Operate plant up to full capacity September Any stage Above 168 Use Volume necessary to meet Prime Power Schedule (see Note 2) Notes: 1. Maximum turbine discharge capacity 30,000 ac-ft/day. Page 3 Toledo Bend Project No. 2305

8 2. In accordance with Section 5.05 of the Power Sales Agreement, no more than 30,000,000 kwh of prime power shall be scheduled during any one month of the Peaking Period (May through September), except with prior written consent of the SRAs. 3. Releases for downstream flows shall be in accordance with Section 5.10 of the Power Sales Agreement. 4. When pool stage is at or above feet and inflow is greater than power plant capacity, operate spillway in accordance with Guide on Spillway Gate Operation. 5. During prime power season when stage of reservoir is near upper limit, inflow is monitored and releases for secondary power generation are made to avoid spillway releases if possible. The Authorities historically operated the reservoir with a normal maximum reservoir elevation of 172 feet and until 2007, a normal minimum reservoir elevation of feet. Under the current terms of the operating protocols, reservoir levels for power generation purposes typically vary during the year from a normal maximum pool level of 172 feet to a lower pool level of 168 feet. Once the 168-foot reservoir level is reached, power generation below that level may only occur under certain conditions, as follows: 1. FERC, or successor agency, orders or requires a reduction in the water level of the reservoir for purposes of inspecting or repairing the dam; 2. An insufficient supply of electric power to the Power Companies firm or non-interruptible power users will result; 3. Non-use of the waters of the reservoir for the generation of hydroelectric power will result in the failure to satisfy minimum downstream flow requirements necessary to meet water sales from the diversion canals of the Authorities; 4. Non-use of the waters of the reservoir for the generation of hydroelectric power will result in the failure to deter saltwater encroachment into Sabine River estuaries; or 5. The Authorities fail to make all credits owed to the Power Companies or fail to make full reimbursements as required in Sections 3.02A and 3.07 of the Power Sales Agreement within the time identified in the current agreement. Typically, the reservoir is at its highest during the late winter and early spring months and, beginning in May, the Authorities gradually draw the reservoir to reach its lowest level in the fall, completing the peak power season on September 30 each year. During the summer season (May through September) when water is available for power production between reservoir elevations 168 and 172 feet, the Project typically generates and releases either 7,000 or 14,000 cfs to the lower Sabine River (i.e., one- or two-unit operation, respectively) for six to eight hours to meet the afternoon and evening peak electrical demand. Typically, the units move from off-line to full load in less than 10 minutes. In addition to the releases for generation, there is also a minimum continuous release of 144 cfs from the spillway to the spillway channel. Examples of typical operations during the three operational seasons of January through April, May through September, and October through December are provided in Exhibit B Project Maintenance Activities Routine activities required for the administration, operation, and maintenance of Project facilities are conducted by the Authorities within the Project Boundary. These activities include, but are not limited to: Page 4 Toledo Bend Project No. 2305

9 Maintenance of all recreation facilities owned by the Authorities, including maintaining parking areas, docks, lawns, restrooms, lights, water, power, trash removal, sewer/septic systems, shelters, fishing piers, cabins, pavilions, and recreational vehicle and tent camping sites. Maintenance of boat ramps, including dredging of boat ramps and channels during low reservoir level (approximately every five years, generally scheduled to coincide with dam safety inspections during low water) and periodic concrete repair or replacement. Annual spring maintenance of sand beaches at Cypress Bend and Pleasure Point, with replacement of sand (approximately 100 cubic yards) approximately every three years, as needed. Maintenance of approximately 300 miles of marked boat lanes with buoys. Buoys are replaced as needed. Gravel road maintenance at three recreation sites in Louisiana (1 mile at Cow Bayou site entrance), less than 0.25 miles at Oak Ridge, and approximately 0.25 mile at Converse Bay, and up to 3 miles adjacent to the spillway and tailrace channels. Vegetation management surrounding Project facilities, including use of lightweight mowing equipment on embankment slopes and targeted herbicide applications. Management of invasive aquatic vegetation (e.g., giant salvinia and water hyacinth) according to Louisiana and Texas management plans. Removal of dead and hazardous trees at the parks maintained by the Authorities, typically fewer than 20 trees annually Existing Environmental Measures The Authorities currently implement several measures that contribute to the protection and enhancement of environmental resources: A continuous minimum flow of 144 cfs released at the spillway provides for protection and enhancement of resources downstream of the Project. SRA-TX and SRA-LA each have permitting programs to monitor and permit shoreline activities on Project lands designed to protect water quality, wetlands, and wildlife resources, promote reservoir safety, and protect Project operations. The Authorities maintain a series of public recreation sites (described in Section 3.8). The Authorities participate in cooperative efforts with TPWD and LDWF on the management of invasive aquatic plants and provide educational materials on the prevention of the spread of giant salvinia and water hyacinth. 2.2 Proposed Action The Authorities propose to continue current Project operations for the term of the new license, including all current operations and maintenance activities and existing environmental measures. In addition, the Authorities propose certain modifications to the Project Boundary configuration and Project facilities, as well as a series of new environmental measures. Each of these is summarized below. Page 5 Toledo Bend Project No. 2305

10 2.2.1 Proposed Project Boundary The proposed Project Boundary contains all of the lands necessary and appropriate to operate and maintain the Project, including implementation of the proposed protection, mitigation, and enhancement (PM&E) measures. The proposed Project Boundary differs slightly from the current Project Boundary, reflecting the Authorities efforts to correct past survey errors. The proposed Project Boundary will be reflected in Project maps to be filed as Exhibit G in the final license application Proposed Project Facilities In addition to maintaining existing facilities described in Section 2.1.2, the Authorities propose the construction of a minimum-flow hydropower facility (min-flow unit) at the existing Project spillway. Operating characteristics of the min-flow unit are presented in Table and details of the proposed facility and operation are provided in Exhibits A and B. Table Operating characteristics of the proposed minimum flow unit. Normal maximum water surface elevation 172 ft Number of turbines 1 Turbine type Francis Minimum hydraulic capacity 60 cfs Maximum hydraulic capacity 150 cfs Installed (rated) capacity 0.8 MW Dependable capacity 0.8 MW Estimated average annual energy production 7,000 MWh Proposed Project Operations and Maintenance The Authorities propose to continue current Project operations as described in Section for the term of the new license, with the addition of the min-flow unit. Once online, the min-flow unit will utilize the existing continuous release of 144 cfs maintained at the spillway. The Authorities propose to continue routine maintenance activities necessary to the administration and maintenance of Project facilities, including, but not limited to, those described in Section Summary of Applicant-Proposed Environmental Measures The Authorities propose continuing existing environmental measures described in Section In addition, the Authorities propose a series of resource management plans to protect and enhance resources in the Project Boundary during the term of a new license. The proposed resource management plans are summarized below. Shoreline Management Plan, Including an Erosion Monitoring Plan The Authorities propose to develop and implement a Shoreline Management Plan (SMP) consistent with Guidance for Shoreline Management Planning at Hydropower Projects (FERC 2001). Although the Authorities do not anticipate new environmental effects to shoreline soils, the Authorities propose to continue monitoring shoreline erosion along the impoundment. The Page 6 Toledo Bend Project No. 2305

11 draft SMP, which will include an Erosion Monitoring Plan, will be filed with the final license application. Historic Properties Management Plan The Authorities propose to develop and implement a HPMP for the management of archaeological and historic resources throughout the term of the new license. The HPMP will be prepared in consultation with SHPOs, Forest Service, and federally recognized Indian tribes, and other stakeholders and in accordance with the Guidelines for the Development of Historic Properties Management Plans for FERC Hydroelectric Projects. The HPMP will address, among other things, a schedule and methodology for completing any additional recommended studies and implementing monitoring measures; management measures for identified historic properties; protection of historic properties threatened by Project-related activities, including Project operations, shoreline and aquatic recreation, shoreline development, routine Project maintenance, and other Project activities or operations; and public outreach, education, and signage for the purpose of reducing looting and vandalism of sites. The draft HPMP will be filed with the final license application. Recreation Management Plan The Authorities propose to develop and implement a Recreation Management Plan (RMP). The RMP will guide the operation and maintenance of the Authorities recreation facilities in a way that will continue to offer diverse, high-quality recreation experiences, and minimize environmental effects on the Project s reservoir, lands, and wildlife resources. The draft RMP will be filed with the final license application Alternatives Considered But Eliminated From Further Analysis In SD2, FERC proposed to eliminate consideration of a nonpower license and Project decommissioning from detailed and comprehensive analyses in its environmental assessment. FERC s statements regarding these potential alternatives are presented below in Sections and Nonpower License FERC s statement from SD2 regarding a nonpower license analysis follows: A non-power license is a temporary license which the Commission would terminate whenever it determines that another governmental agency will assume regulatory authority and supervision over the lands and facilities covered by the non-power license. Hence, issuing a non-power license for the project would not provide a long-term solution to the issues presented. To date, no party has sought a non-power license, and we have no basis for concluding that the project should no longer be used to produce power. Thus, we do not consider a non-power license to be a reasonable alternative to some form of new license with enhancement measures. Page 7 Toledo Bend Project No. 2305

12 Project Decommissioning FERC s statement from SD2 regarding consideration of Project decommissioning follows: The project decommissioning alternative would involve: (1) denial of the license application for the Toledo Bend Project; and (2) ceasing power generation at the project. At a minimum, project decommissioning would have the following effects: (1) the energy currently generated by the project would be lost (about 220,000 MWh annually); and (2) there would be significant costs associated with decommissioning the project powerhouse and appurtenant facilities. Because no agency, tribe, or stakeholder has suggested that project decommissioning would be an appropriate alternative for the Toledo Bend Project, we have no basis for recommending decommissioning. Therefore, we do not consider project decommissioning a reasonable alternative to relicensing the project with appropriate environmental enhancement measures. TBend_ExhE Sctn 2.0 PrpsdActn-Altntvs doc Page 8 Toledo Bend Project No. 2305