Fish and Aquatic Resources

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1 Fish and Aquatic Resources 1.0 General Description of this Study The Notice of Intent (NOI) and Preliminary Application Document (PAD) (GBEP 2013) for the Gordon Butte Pumped Storage Project (P , Project) identified the following issues associated with fish and aquatic resources for which the existing relevant and reasonably available information does not appear adequate. These issues are: Confirming how the Project will obtain water for the initial Project fill. This would include timing, magnitude and duration and the source(s) of water. Confirming how the Project will obtain water for routine maintenance filling. This would include timing, magnitude and duration and the source(s) of water. Initiating studies to determine if any proposed change in the timing, magnitude or duration of current diversion practices would impact the fish and aquatic resources in any potential water source. In conjunction with filing the Project s NOI, PAD, and request to use the Traditional Licensing Process (TLP) with FERC, GBEP also distributed these documents to all appropriate resource agencies, non- governmental organizations, tribes, members of the general public, and any other entities or interested parties for comments on the proposed Project. Formal comments regarding fish and aquatic resources were received from Montana Fish Wildlife and Parks (MTFWP), US Bureau of Land Management Lewistown Field Office (BLM) (submitted via US Department of the Interior [DOI]), and Montana Department of Environmental Quality (MTDEQ). These comments are summarized below. MTFWP comments focused primarily on cold- water fisheries and the resources on which they depend that may potentially be impacted by the Project. MTFWP recommended that entrainment and diversion screening studies, fish population studies, and benthic macroinvertebrate studies be conducted in proposed Project source waters in order to establish a better understanding of current baseline conditions for fish and aquatic resources in these areas. DOI comments regarding fish and aquatic resources largely echoed MTFWP s concerns regarding potential impacts to stream flow, particularly citing BLM s responsibility to manage downstream riparian and related resources that are dependent on instream flows originating from Cottonwood Creek and the South Fork and main- stem Musselshell River; hence their recommendation that existing flow conditions in these areas be preserved or improved as a result of the proposed Project. Comments received from MTDEQ were relevant to fish and aquatic resources in that several state bureaus under MTDEQ jurisdiction are responsible for protecting water quality and quantity (e.g., Environmental Management Bureau, Public Water Supply and Subdivisions Bureau, Water Protection Bureau [WPB], Water Quality Planning Bureau). MTDEQ comments specifically cited the WPB fact sheet detailing water- quality permits and authorizations that may be required for Project construction. 1

2 2.0 Project Nexus The timing, magnitude, location, and duration of water diversion to complete the initial fill of the Project, and maintenance fills thereafter, will be consistent with the historic water diversion operations of the 71 Ranch. Historically, the 71 Ranch has diverted substantial flows, up to the entire flow of Cottonwood Creek during certain times of the year, for irrigation. The Project will be diverting water, for the initial fill and annual make- up fills, to the lower reservoir, approximately 2.5 miles down the existing irrigation ditch after the 71 Ranch has diverted it from Cottonwood Creek. Therefore, there will be no nexus between the Project and Cottonwood Creek itself. The Project water will be taken from the historic amount diverted by the 71 Ranch. This agreement will be memorialized in the landowner lease agreement currently in development between the applicant and 71 Ranch. The 71 Ranch has notified GBEP that it intends to install a new irrigation diversion structure at its Cottonwood Creek diversion point. In addition, the applicant is working with 71 Ranch to install a new fish screen and Parshall flume in the existing irrigation ditch. The new diversion structure, fish screen and Parshall flume are anticipated to be installed prior to the Project diverting any water from the irrigation ditch. The 71 Ranch understands the desire to establish a baseline data collection on fish resources in Cottonwood Creek and the South Fork Musselshell River in conjunction with the new diversion structure, and an entrainment study in conjunction with the new fish screen. The 71 Ranch and GBEP will work with MTFWP to identify fish screening alternatives, and achieve agreement on the design of fish screens and associated works to be installed in the irrigation ditch, as well as, conduct the relevant suggested surveys. This agreement will be memorialized in a memorandum of understanding (MOU) between MTFWP, the 71 Ranch, and the applicant. The information obtained from the studies described herein will be used by the applicant and relevant resource agencies and stakeholders in combination with existing information to evaluate the potential effects on aquatic resources, and will be further used to evaluate various management options when balancing resource uses. The Project is anticipated to have no effect on aquatic resources because Project infrastructure will be constructed off any existing stream, water body, or other natural watercourse, and no new fisheries will be established within the two reservoirs of the closed- loop pumped storage system. 3.0 Goals and Objectives of Study The goals of this study are to develop the necessary additional information to determine any effects to aquatic resources in the Project area. Specifically, this study will characterize benthic macroinvertebrate communities in the source waters above the 71 Ranch diversion (in upper Cottonwood Creek) and below the 71 Ranch diversion (in lower Cottonwood Creek and the 2

3 South Fork Musselshell river) using standard survey methods. These goals and objectives will be addressed using a combination of existing and new information as described below. 4.0 Existing Information and Need for Additional Information The seminal effort to classify lotic ecosystems in the upper Missouri River Basin based on relationships between biological communities and their physical landscapes was undertaken by the Montana Natural Heritage Program (MTNHP), BLM, and the Nature Conservancy (Stagliano 2005). This classification system uses macroinvertebrate assemblages to predict the composition of aquatic communities within general ecosystem types and specific watersheds and/or sub- basins, including those in the Project area. Existing information regarding aquatic resources in the Project vicinity was also summarized in the PAD and the initial Fatal Flaw Analysis for the Project (GANDA 2010). As part of the FERC- licensing process, GBEP will continue to consult with MTDEQ regarding aquatic resources in order to identify additional information needs or protection measures may be required to address water quality issues. Existing information regarding BMIs in the Project area is generally lacking. The PAD reports that no site- specific information on the distribution of invertebrates in Cottonwood Creek exists, and only one limited invertebrate sampling effort in the South Fork Musselshell River is known from 1970 (Hill and Baldes 1971). However, as summarized in the PAD, the classification system developed by Stagliano (2005) can be used to predict general macroinvertebrate assemblages within given aquatic ecosystem classes, and furthermore, to identify community indicator species that should be present. As such, this classification can provide an accurate reference condition for streams within a given aquatic ecosystem class. The BMI in upper Cottonwood Creek are expected to be characterized by main- channel fast- current mayfly, stonefly, caddisfly, and dipteran species of the Traditional Trout Stream macroinvertebrate assemblage. While the community in lower Cottonwood Creek and the South Fork Musselshell River is expected to be characterized by mayfly, caddisfly, beetle, and dipteran species of the Medium Cool- Water Transitional Assemblage and Foothills Transitional Assemblage (sensu Stagliano 2005). Indicator species for these assemblages are listed in the PAD along with general life history summaries for most aquatic insect orders, and are discussed further in Stagliano (2005). The BMI surveys described in this Study Plan are designed to address the need for additional information in this resource area. The surveys will provide quantitative population information to fill critical data gaps and establish a better understanding of current baseline conditions for aquatic resources in the Project area. 5.0 Study Area The study area for aquatic resources will consist of three survey locations within the upper Musselshell River Basin: one site above the 71 Ranch diversion on upper Cottonwood Creek; one site below the 71 Ranch diversion on lower Cottonwood Creek; and another site below the 71 Ranch diversion at the Selkirk Fishing Access on the Musselshell River (below the 3

4 Cottonwood Creek confluence). Exact locations for these survey sites will be determined during initial field reconnaissance and will depend on the representativeness and suitability of each site for the sampling methods described below (see attached Project overview map). 6.0 Methods 6.1 Data Collection Benthic Macroinvertebrate Surveys Benthic macroinvertebrate (BMI) surveys will be conducted at three locations in the Project area following standardized sampling protocols in order to characterize community structure (in terms of richness, diversity, composition, tolerance, etc.) and to provide overall estimates of biological integrity in Project source waters. BMI surveys will be conducted at the same three fish population survey sites (one site above the 71 Ranch diversion on upper Cottonwood Creek, one site below the 71 Ranch diversion on lower Cottonwood Creek, and another site below the 71 Ranch diversion on the South Fork Musselshell River). Exact locations for these survey sites will be determined during initial field reconnaissance and will depend on the representativeness and suitability of each site for the proposed sampling methods. Each site will consist of a 150- meter survey reach, the exact boundaries of which will be determined in the field. Delineation of the survey reach at each site will follow procedures outlined in the Environmental Monitoring Assessment Program (EMAP) Field Operation Manual for Wadeable Streams (Peck et al. 2006). BMI samples will be collected at each site following the Montana DEQ s Sample Collection, Sorting, Taxonomic Identification, and Analysis of Benthic Macroinvertebrate Communities Standard Operating Procedure (MTDEQ 2012). The MTDEQ procedure is the statewide standard for BMI sampling based on the western EMAP protocol that employs a semi- quantitative reach- wide sampling technique in which kick samples are collected along each of 11 equally- spaced transects within the 150- meter survey reach. These transects (labeled A through K from downstream to upstream) span multiple habitat types throughout the survey reach such that the composited reach- wide benthos (RWB) sample (comprised of eleven 1- ft 2 kick samples) contains invertebrates representing all such habitat types. Each kick sample will be collected using a D- frame net fitted with a 500- micron mesh net moving from downstream to upstream and collecting samples from each successive transect. The resulting composite RWB sample will then be cleaned and elutriated, preserved in ethanol, placed in a leak- proof sample jar, labeled inside and out, and sent to an accredited laboratory for sorting and identification by a professional taxonomist. RWB samples will be collected before fish surveys and physical habitat measurements at each site to prevent bottom disturbance and excessive tramping. Physical Habitat Measurements The MTDEQ sampling protocol does not specify a field procedure for measuring physical habitat. However, the collection of such data is essential for correlating biological integrity with environmental conditions and identifying specific stressors. Other western states have adopted standardized physical habitat measurement procedures based on EMAP protocols such as the 4

5 Surface Water Ambient Monitoring Program (SWAMP) Standard Operating Procedures for Collecting Benthic Macroinvertebrate Samples and Associated Physical and Chemical Data for Ambient Bioassessments in California (SWAMP 2007). California s SWAMP protocol includes thorough physical habitat measurement procedures modeled after the EMAP approach and includes the most well- developed, comprehensive standardized field datasheets for recording the necessary suite of habitat measurements. Thus, for BMI surveys in the Project area, physical habitat parameters will be evaluated using the EMAP approach as outlined in the California SWAMP procedure and accompanying field data forms. The full suite of physical habitat characterizations (bankfull and wetted width, bankfull height, water depth, substrate composition, cobble embeddedness, algal cover, riparian vegetation, instream habitat complexity, canopy cover, human influence, bank stability, etc.) will be evaluated at a combination of 11 primary transects (A through K) and 10 secondary transects (inter- transects AB, BC, CD, etc.) located along the 150- meter survey reach at each site. Stream gradient will be surveyed using a transit and stadia rod positioned at water s surface at each transect, and compass bearings between transect mid- points will be measured to aid in aspect and sinuosity calculations. Discharge will be measured using the standard USGS velocity- area method at all sites where stream gage data is not available. All sites will be geo- referenced using GPS and thoroughly documented with digital photographs. Basic in situ water quality measurements will also be taken at each site (using a YSI Model 556 handheld multi- meter, or equivalent). Parameters will include water temperature, ph, specific conductance, total dissolved solids, salinity, and dissolved oxygen concentration. All water quality measurements will be collected prior to BMI sampling efforts. 6.2 Data Analysis BMI samples will be identified to the lowest practical level in the laboratory (typically genus/species for most taxa, or alternative Operational Taxonomic Units [OTUs] as defined in DEQ [2012]). All taxonomic data will be compiled into a master database. In general, BMI data will be analyzed by calculating standard community metrics (richness, composition tolerance, and functional feeding group measures), as well as Montana- specific tolerance indices, observed versus expected (O/E) ratios, Bray- Curtis similarity, and relevant aspects of data quality control as defined in DEQ (2012). Multi- metric tools (such as a regional Index of Biotic Integrity [IBI]) may also be calculated, as appropriate. 6.3 Consistency with Generally Accepted Scientific Practice The methods described in this Study Plan are widely accepted and commonly employed for sampling BMI populations and associated physical habitats. BMI and physical habitat sampling protocols developed as part of the EMAP Western Pilot Study (Peck et al. 2006) have become the basic scientific tools for evaluating ecological conditions. States across the west have adopted EMAP- based protocols as statewide standards for ambient bioassessments, including Montana (MTDEQ 2012). 5

6 Data analysis methods listed above and detailed in their respective sampling protocols are also standard analytical procedures. For BMI data, multi- variate (O/E) and multi- metric (IBI) approaches are common analytical methods for reducing the complexity of community data to provide more useful expressions of biological integrity. 7.0 Products Data and analyses from the aquatic resources surveys will be compiled into a Study Report. This Study Report will summarize survey methods and results, and discuss and interpret data. Supporting products such as maps, data forms, and site photographs will be included as an appendix to the Study Report. A summary of the information and findings, including any comments received on the Study Report, will also be included in the Final License Application, Exhibit E. 8.0 Relationship to Other Studies Information on aquatic resources will be also used to help evaluate water resources for the Project (refer to the Water Resources Study Plan). Information regarding existing water quantity and quality in the Project area gathered as part of surveys described in the Water Resources Study Plan will be used in conjunction with biological data collected as part of this Study Plan to better inform management decisions for both resource areas. 9.0 Schedule In general, field work for aquatic resources will be conducted under wadeable flow conditions following snowmelt runoff. BMI and associated physical habitat surveys will be conducted in summer or fall Data analysis and reporting will commence following the completion of all field work. The Study Report will be compiled in late 2014 and/or early 2015 and made available for review References Fish Wildlife and Parks (MTFWP). Undated. Musselshell River Physical Drainage Information. Montana Fish, Wildlife and Parks. 13 pages. [accessed ]. Fish Wildlife and Parks (MTFWP) Musselshell River Watershed Report. fwp.mt.gov/fwpdoc.html?id=56977 [accessed ]. Fish Wildlife and Parks (MTFWP) MFish Waterbody Report. Cottonwood Creek. [accessed ] 6

7 Garcia and Associates (GANDA) Fatal Flaw Analysis for the Proposed Gordon Butte Closed Loop Pumped Storage Hydro Project. Bozeman, MT. October 15, GB Energy Park, LLC (GBEP) Pre- Application Document Gordon Butte Pumped Storage Project (FERC Project No ). April Montana Department of Environmental Quality (MTDEQ) Sample Collection, Sorting, Taxonomic Identification, and Analysis of Benthic Macroinvertebrate Communities Standard Operating Procedure. March 15, Montana Natural Heritage Program (MTNHP) Animal Species of Concern. Montana Natural Heritage Program. Helena, MT. [accessed ]. National Marine Fisheries Service, Northwest Region Anadramous Salmonid Passage Facility Design. February, Peck, D. V. A. T. Herlihy B. H. Hill R. M. Hughes P. R. Kaufman D. J. Klemm J. M. Lazorchak F. H. McCormick S. A. Peterson P. L. Ringold T. Magee and M. Cappaert Environmental Monitoring and Assessment Program- Surface Waters Western Pilot Study: Field Operations Manual for Wadeable Streams. Operations Manual for Wadeable Streams. EPA/620/R- 06/003. Washington, D.C.: United States Environmental Protection Agency. Stagliano D. M Aquatic Community Classification and Ecosystem Diversity in Montana s Missouri River Watershed. Prepared for: Bureau of Land Management. Stagliano D Freshwater Mussels in Montana: Comprehensive Results from 3 years of SWG Funded Surveys. Prepared for: Montana Department Surface Water Ambient Monitoring Program (SWAMP) Standard Operating Procedures for Collecting Benthic Macroinvertebrate Samples and Associated Physical and Chemical Data for Ambient Bioassessments in California. February Prepared by the State Water Board and the CDFG Aquatic Bioassessment Laboratory. 7