UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION. Energy Northwest Project No

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1 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION Energy Northwest Project No NOTICE OF AVAILABILITY OF DRAFT ENVIRONMENTAL ASSESSMENT (February 5, 2009) In accordance with the National Environmental Policy Act (NEPA) of 1969 and the Federal Energy Regulatory Commission's (Commission) regulations, 18 CFR Part 380 (Order No. 486, 52 F.R ), the Office of Energy Projects has reviewed the application for a new major license for the Packwood Lake Hydroelectric Project (project), located on Lake Creek in Lewis County, Washington, and has prepared a draft Environmental Assessment (EA). In the draft EA, Commission staff analyze the potential environmental effects of licensing the project and conclude that issuing a license for the project, with appropriate environmental measures, would not constitute a major federal action significantly affecting the quality of the human environment. A copy of the draft EA is on file with the Commission and is available for public inspection. The draft EA may also be viewed on the Commission s website at using the "elibrary" link. Enter the docket number excluding the last three digits in the docket number field to access the document. For assistance, contact FERC Online Support at FERCOnlineSupport@ferc.gov or toll-free at , or for TTY, (202) Any comments should be filed within 30 days from the issuance date of this notice, and should be addressed to the Secretary, Federal Energy Regulatory Commission, 888 First Street, N.E., Room 1-A, Washington, DC Please affix Packwood Lake Hydroelectric Project No to all comments. Comments may be filed electronically via Internet in lieu of paper. The Commission strongly encourages electronic filings (See 18 CFR (a) (1) (iii) and the instructions on the Commission s website under the efiling link). For further information, contact Kenneth Hogan at (202) Kimberly D. Bose, Secretary.

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3 DRAFT ENVIRONMENTAL ASSESSMENT FOR HYDROPOWER LICENSE Packwood Hydroelectric Project FERC Project No Washington Federal Energy Regulatory Commission Office of Energy Projects Division of Environmental and Engineering Review 888 First Street, NE Washington, DC February 2009

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5 TABLE OF CONTENTS LIST OF FIGURES... v LIST OF TABLES... vi LIST OF TABLES... vi ACRONYMS AND ABBREVIATIONS... ix EXECUTIVE SUMMARY... xi 1.0 INTRODUCTION APPLICATION PURPOSE OF ACTION AND NEED FOR POWER Purpose of Action Need for Power STATUTORY AND REGULATORY REQUIREMENTS Federal Power Act Clean Water Act Endangered Species Act Coastal Zone Management Act National Historic Preservation Act Pacific Northwest Power Planning and Conservation Act Wild and Scenic Rivers Act Magnuson-Stevens Fishery Conservation and Management Act PUBLIC REVIEW AND CONSULTATION Scoping Interventions Comments on the License Application PROPOSED ACTION AND ALTERNATIVES NO-ACTION ALTERNATIVE Existing Project Facilities Project Safety Existing Project Operation Existing Environmental Measures APPLICANT S PROPOSAL Proposed Project Facilities Proposed Project Operation Proposed Environmental Measures Modifications to Applicant s Proposal Mandatory Conditions STAFF ALTERNATIVE ALTERNATIVES CONSIDERED BUT ELIMINATED FROM FURTHER ANALYSIS iii

6 3.0 ENVIRONMENTAL ANALYSIS GENERAL SETTING SCOPE OF CUMULATIVE EFFECTS ANALYSIS Geographic Scope Temporal Scope PROPOSED ACTION AND ACTION ALTERNATIVES Aquatic Resources Terrestrial Resources Threatened and Endangered Species Recreation, Land Use, and Aesthetics Aesthetic Resources Cultural Resources DEVELOPMENT ANALYSIS POWER AND ECONOMIC BENEFITS OF THE PROJECT COMPARISON OF ALTERNATIVES No-action Alternative Energy Northwest s Proposal Staff Alternative COST OF ENVIRONMENTAL MEASURES NEW PROJECT FACILITIES RECOMMENDED TO BE INCLUDED IN ANY NEW LICENSE CONCLUSIONS AND RECOMMENDATIONS COMPARISON OF ALTERNATIVES COMPREHENSIVE DEVELOPMENT AND RECOMMENDED ALTERNATIVE UNAVOIDABLE ADVERSE EFFECTS SUMMARY OF SECTION 10(J) RECOMMENDATIONS AND 4(E) CONDITIONS Recommendations of Fish and Wildlife Agencies Land Management Agencies Section 4(e) Conditions CONSISTENCY WITH COMPREHENSIVE PLANS FINDING OF NO SIGNIFICANT IMPACT LITERATURE CITED LIST OF PREPARERS I. MANDATORY CONDITIONS... 1 II. ADDITIONAL LICENSE ARTICLES RECOMMENDED BY COMMISSION STAFF... 1 Appendix A Draft License Articles...A-1 iv

7 LIST OF FIGURES Figure 1-1. Packwood Lake Hydroelectric Project location... 2 Figure 2-1. Packwood Lake Hydroelectric Project, detail of the outlet area Figure 2-2. Packwood Lake Hydroelectric Project, detail of the powerhouse area Figure 2-4. Packwood Lake minimum and maximum water levels restrictions under existing and proposed conditions Figure 3-1. Packwood Lake minimum and maximum monthly water levels Figure 3-2. Vertical temperature profiles for Packwood in the deepest area of the lake Figure 3-3. Hourly discharge and water temperature at the intake, and tailrace during Figure 3-4. mid-july to mid-september Water temperature in the end of the Packwood Project tailrace and the side channel of the Cowlitz River, October 2005 to October Figure 3-5. Packwood Lake tributary study sites Figure 3-6. Lower portion of Lake Creek (reaches 1 through 3) Figure 3-7. Lower portion of Lake Creek (reaches 4 and 5) Figure 3-8. Study site locations in Snyder Creek Figure 3-9. Monthly lake levels and inflow from January 1999 to December Figure Comparison of before and with project annual highest mean daily flow, Lake Creek near Packwood gage Figure Fish entrained on traveling screens at the Packwood Lake Hydroelectric Project during January through August Figure Packwood Lake area recreational access. (Source: Energy Northwest, 2008a) Figure Packwood Lake area recreational facilities. (Source: Energy Northwest, 2008a) Figure Land use designation within the Packwood Lake area Figure Packwood Lake area recreational access (detailed map). (Source: Energy Northwest, 2008a) v

8 LIST OF TABLES Table 1-1. Major statutory and regulatory requirements for the Packwood Lake Hydroelectric Project... 4 Table 3-1. Inflow (cfs) to Packwood Lake Table 3-2. Summary of Packwood overtopping events, 1967 to Table 3-3. Flow (cfs) at gages along Lake Creek and the Cowlitz River Table 3-4. Water quality parameters Table 3-5. Water temperature monitoring data for Table 3-6. Water temperature monitoring data for Table 3-7. Mean annual ph and turbidity levels Table 3-8. Lake Creek salmonid species periodicity Table 3-9. ESA-listed fish species in the Packwood Lake Hydroelectric Project area 49 Table The total number of rainbow trout and rainbow trout redds observed during the 2007 Packwood Lake tributaries spawning surveys Table Habitat type percentages for the five reaches surveyed on lower Lake Creek Table Comparison of measured water temperatures in Table Proposed instream flows (cfs) for lower Lake Creek as measured at the drop structure Table Summary of spawning weighted useable area by month for lower Lake Creek (current conditions and proposed flows with enhancements). (Source: Energy Northwest, 2008a as modified by staff) Table Summary of rearing weighted useable area by month for all sites in lower Lake Creek (current conditions and proposed flows with enhancement) Table Preferred, upper lethal, and lower lethal water temperatures (in C) for Chinook and coho salmon, steelhead/rainbow trout, and cutthroat trout Table Interim ramping rate guidelines for water diversions in Washington state. a Table Summary of approach velocity measurement at the Packwood Lake Hydroelectric Project fish screens Table Noxious weeds observed within study area Table Special status wildlife species that are known to occur or may occur in the Table project area Federally listed species and designated critical habitat in Lewis County and documented occurrences in the Packwood Lake Hydroelectric Project vicinity. (Source: FWS, 2007; NMFS, 2008; modified by staff) Table Average daily use of Pipeline Road/FS Trail 74 and FS Trail Table Summary of roads in project vicinity and Energy Northwest s usage Table Forest Service Visual Quality Objectives Table Archaeological sites within the Packwood Lake Hydroelectric Project area of potential effects vi

9 Table 4-1. Table 4-2. Table 4-3. Table 5-1. Table 5-2. Parameters for the economic analysis of the Packwood Lake Hydroelectric Project Summary of the annual cost, power benefits, and annual net benefits for the alternatives for the Packwood Lake Hydroelectric Project Costs of environmental mitigation and enhancement measures considered in assessing the environmental effects of continuing to operate the Packwood Lake Hydroelectric Project Fish and wildlife agency recommendations for the Packwood Lake Hydroelectric Project. (Source: Staff) Forest Service preliminary 4(e) conditions for the Packwood Lake Hydroelectric Project. (Source: Staff) vii

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11 ACRONYMS AND ABBREVIATIONS applicant Energy Northwest ATV all terrain vehicle ºC degrees Celsius cfs cubic feet per second Commission Federal Energy Regulatory Commission Council Northwest Power and Conservation Council 7-DADMax 7-day average of the daily maximum temperature DO dissolved oxygen EA environmental assessment EPA U.S. Environmental Protection Agency ESA Endangered Species Act FERC Federal Energy Regulatory Commission Forest Service U.S. Department of Agriculture, Forest Service mg/l milligrams per liter msl mean sea level MW megawatts MWh megawatt-hours NMFS U.S. Department of Commerce, National Marine Fisheries Service PHABSIM Physical Habitat Simulation Model project Packwood Lake Hydroelectric Project USGS U.S. Geological Survey Washington Fish and Wildlife Washington Department of Fish and Wildlife ix

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13 EXECUTIVE SUMMARY Energy Northwest proposed to continue to operate the existing megawatt (MW) Packwood Lake Hydroelectric Project (project) located on Lake Creek, near the town of Packwood in southwestern Washington. This project produces about 92,000 megawatt-hours (MWh) of generation annually. Parts of the project occupy acres of federal lands administered by the U.S. Department of Agriculture, Forest Service (Forest Service). The Forest Service lands are managed by the Cowlitz Valley Ranger District of the Gifford Pinchot National Forest. This draft environmental assessment (EA) evaluates the potential natural resource benefits, environmental impacts, and economic costs associated with relicensing the Packwood Lake Hydroelectric Project Proposed Action The project consists of a concrete drop structure (dam) on Packwood Lake, which creates a 452-acre reservoir at full pond and a network of concrete pipes, tunnels, and penstocks about 5.2 miles long leading to a powerhouse with a single turbine generator. The project is described in more detail in section 2.2. The project is operated depending upon license conditions, water availability, and power contracts. Energy Northwest proposes no capacity changes, but does propose operational changes and measures for the protection and enhancement of environmental resources, including (1) increasing minimum flows and other measures to protect aquatic resources in the 5.3-mile long bypassed reach of Lake Creek; (2) changing the date of the annual maintenance outage to August 15 until September 15; (3) implementing a monitoring plan to evaluate the effectiveness of project operation to meet water temperature standards; (4) improving fish passage on Snyder Creek where it crosses the tailrace canal; (5) developing and implementing plans to control weeds, (6) protecting threatened, endangered, and sensitive species; (7) providing measures to enhance and protect recreational use and trails in the project areas; and (8) implementing a Historic Properties Management Plan. These and other related measures are described in detail in section Alternatives Considered This EA analyzes the effects of continued project operation and recommends conditions for a new license for the project. In this EA, we consider three alternatives: (1) Energy Northwest s proposal; (2) Energy Northwest s proposal with staff modifications (staff alternative); and (3) a no-action alternative. Under Energy Northwest s proposal with staff modifications, the project would be operated as proposed, but would include the following additional measures. Implement ramping rates in lower Lake Creek during project-related flow changes. xi

14 Develop and implement a threatened, endangered, and sensitive species management plan which is consistent with the Forest Service condition and Washington Department of Fish and Wildlife recommendation, including conducting surveys for Oregon goldenaster prior to ground-disturbing activities in lower Lake Creek and consulting with resource management agencies regarding timing restrictions or other measures that may be needed to prevent adverse effects on amphibians during efforts to reroute Snyder Creek. Modify the Integrated Weed Management Plan to expand the list of target species for weed control at sites below the stilling basin, in order to protect the state-listed Oregon goldenaster and prevent the spread of noxious weeds as a result of implementing environmental measures in lower Lake Creek and Snyder and Hall creeks. Pursue formal National Register of Historic Places evaluation of the Packwood Lake facilities in 2014, when the facilities qualify. Public Involvement and Areas of Concern Before filing its license application, Energy Northwest conducted a pre-filing consultation process under the integrated licensing process. The intent of the Commission s pre-filing process is to initiate public involvement early in the project planning process and to encourage citizens, governmental entities, tribes, and other interested parties to identify and resolve issues during the process of completing its application. During the integrated licensing process, the Federal Energy Regulatory Commission (Commission or FERC) conducted scoping to determine what issues and alternatives should be addressed. A scoping document was distributed to interested parties on January 11, Scoping meetings were held in Packwood, Washington on February 3, Energy Northwest filed its preliminary licensing proposal on September 22, Energy Northwest filed its application on February 22, On June 19, 2008, the Commission issued the notice of ready for environmental analysis and requested comments, recommendations, terms and conditions, and prescriptions. On September 16, , the Commission issued the notice of application accepted for filing and soliciting motions to intervene. The primary issues associated with relicensing the project are the amount of flow released to Lake Creek, aquatic enhancement and protection for Lake Creek and the project tailrace area, changes in water level within Packwood Lake due to the change in the timing of the project shutdown, and recreational and land use issues on Forest Service land. 1 The September 16, 2008 notice was issued because the June 19, 2008, notice did not solicit interventions. xii

15 Project Effects Aquatic Resources Under the applicant s proposal, salmonid habitat in lower Lake Creek would improve in the 5.3 mile bypassed reach due to higher minimum flows, aquatic habitat forming flows, and recreation and enhancement plans. Potential degradation of anadromous habitat would be protected in the tailrace area due to the change in timing of the project maintenance shutdown. Slight increases in the water temperature in lower Lake Creek would occur, but would remain below critical levels for salmonids. Under the staff alternative, we recommend adopting ramping rates to protect aquatic resources in lower Lake Creek. Terrestrial Resources Under the applicant s proposal, an Integrated Weed Management Plan would help to limit the occurrence and distribution of invasive weeds. Under the staff alternative, we recommend modifying the plan to include potential ground disturbing activities along lower Lake Creek and Snyder/Hall Creeks. Threatened and Endangered Species The applicant proposes a threatened, endangered, and sensitive species management plan to address and protect such species and their habitat on project lands. Recreation, Land Use, and Aesthetics Under the applicant s proposal, the Recreation Management Plan, filed with the Commission on June 6, 2008, would be implemented to provide a framework for proposed recreational site improvements and management, and road management. The applicant also would implement a resource coordination plan to coordinate with various agencies the recommended management plans and associated requirements for the project. Cultural Resources The Historic Properties Management Plan filed with the Commission on August 30, 2007, would include site monitoring and protection of archaeological and historic sites. xiii

16 Conclusion Based on our analysis, we recommend licensing the project as proposed by Energy Northwest as modified by staff, as described on the previous page under Alternatives Considered. In section 4.1 of the EA, we estimate the annual net benefits of operating and maintaining the project under the three alternatives identified above. Our analysis shows that the annual net benefit would be $1,751,130 for Energy Northwest s proposed action; $1,745,420 for Energy Northwest s proposed action as modified by staff (staff alternative); and $2,445,610 for the no-action alternative. In addition, we estimate the annual net benefit for the staff alternative with mandatory condition as $1,743,720. On the basis of our independent analysis, we conclude that issuing a new license for the project, with the environmental measures that we recommend, would not be a major federal action significantly affecting the quality of the human environment. We chose the staff alternative as the preferred alternative because: (1) the project would provide a dependable source of electrical energy for the region (83,569 MWh annually); (2) the MW of electric energy generated from a renewable resource may offset the use of fossil-fueled, steam-electric generating plants, thereby conserving nonrenewable resources and reducing atmospheric pollution; (3) the recommended environmental measures proposed by Energy Northwest, as modified by staff would adequately protect and enhance environmental resources affected by the project. The overall benefits of the staff alternative would be worth the cost of the proposed and recommended environmental measures. xiv

17 1.1 APPLICATION 1.0 INTRODUCTION On February 25, 2008, Energy Northwest (applicant) filed an application for a new license for the Packwood Lake Hydroelectric Project (project) with the Federal Energy Regulatory Commission (Commission or FERC). The existing project is on Lake Creek, a tributary to Cowlitz River, in Lewis County in southwestern Washington near the unincorporated town of Packwood (figure 1-1). The upper portion of the lake lies within the Goat Rocks Wilderness Area. The project occupies acres of U.S. Department of Agriculture, Forest Service (Forest Service) land (administered by the Gifford Pinchot National Forest), acres of Energy Northwest-owned land, 8.78 acres of Washington state lands, and 1.52 acres of Lewis County Public Utility District lands. The megawatt (MW) project produces about 92,000 megawatt-hours (MWh) of generation annually. The applicant proposes no new capacity and no new construction. 1.2 PURPOSE OF ACTION AND NEED FOR POWER Purpose of Action The Commission must decide whether to issue a license to Energy Northwest for the Packwood Lake Hydroelectric Project and what conditions should be placed on any license issued. In deciding whether to issue a license for a hydroelectric project, the Commission must determine that the project will be best adapted to a comprehensive plan for improving or developing a waterway. In addition to the power and developmental purposes for which licenses are issued, such as irrigation, navigation, or water supply, the Commission must give equal consideration to the purposes of (1) energy conservation; (2) the protection, mitigation of, damage to, and enhancement of fish and wildlife resources; (3) the protection of recreational opportunities; and (4) the preservation of other aspects of environmental quality. Issuing a new license for the Packwood Lake Hydroelectric Project would allow Energy Northwest to generate electricity for the term of a new license, making electrical power from a renewable resource available to its customers. This draft environmental assessment (EA) assesses the environmental and economic effects associated with the operation of the project, alternatives to the proposed project, and makes recommendations to the Commission on whether to issue a new license, and if so, recommends terms and conditions to become a part of any license issued. In this draft EA, we assess the environmental and economic effects of continuing to operate the project (1) as proposed by Energy Northwest, (2) Energy Northwest s proposal with staff modifications (staff alternative), and (3) a staff alternative with 1

18 2 Figure 1-1. Packwood Lake Hydroelectric Project location. (Source: Energy Northwest, 2008a, as modified by staff)

19 mandatory conditions. We also consider the effects of the no-action alternative. Important issues that are addressed include the amount of flow released to Lake Creek, aquatic enhancement and protection for Lake Creek and the project tailrace area, changes in water level within Packwood Lake due to the change in the timing of the project shutdown, and recreational and land use issues on Forest Service land Need for Power The Packwood Lake Hydroelectric Project would provide hydroelectric generation to meet part of Washington s power requirements, resource diversity, and capacity needs. The project would have an installed capacity of MW and generate about 92,000 MWh per year. The North American Electric Reliability Council annually forecasts electrical supply and demand nationally and regionally for a 10-year period. The project is located in the Northwest Power Pool area of the Western Electricity Coordinating Council region of the North American Electric Reliability Council. According to North American Electric Reliability Council s 2008 forecast, average annual demand requirements for the U.S. portion of the Northwest Power Pool area are projected to grow at a rate of 1.86 percent from 2008 through North American Electric Reliability Council projects Northwest Power Pool winter resource capacity margins (generating capacity in excess of demand) will drop from 35 percent in 2008/2009 to 20 percent of firm peak demand by winter 2017/2018, including planned estimated new capacity additions of 3,820 MW (NERC, 2008). These new additions include 1,416 MW of hydro capacity, 1,902 MW of thermal capacity, 156 MW of geothermal capacity, 96 MW of biomass capacity, and 250 MW of wind capacity. We conclude that power from the Packwood Lake Hydroelectric Project would help meet a need for power in the Northwest Power Pool area in both the short- and longterm. The project provides low-cost power that displaces non-renewable, fossil-fired generation and contributes to a diversified generation mix. Displacing the operation of fossil-fueled facilities may avoid some power plant emissions and creates an environmental benefit. 1.3 STATUTORY AND REGULATORY REQUIREMENTS A license for the project is subject to numerous recommendations under the Federal Power Act and other applicable statutes. We summarize the major regulatory requirements in table 1-1 and describe them below. 3

20 Table 1-1. Major statutory and regulatory requirements for the Packwood Lake Hydroelectric Project. (Source: Staff) Requirement Agency Status Section 18 of the Federal Power Act (fishway prescriptions) National Marine Fisheries Service Prescription filed on August 19, 2008 Section 4(e) of the Federal Power Act (land management conditions) Section 10(j) of the Federal Power Act Clean Water Act 401 water quality certification Endangered Species Act Forest Service Washington Department of Fish and Wildlife Washington Department of Ecology National Marine Fisheries Service and U.S. Fish and Wildlife Service Preliminary terms and conditions filed August 16, 2008 Recommendations filed August 18, 2008 Request for water quality certification filed on August 14, Decision due by August 14, Biological Assessment pending. Biological Opinion (NMFS) and Concurrence (FWS) dates are dependent on the Biological Assessment issuance date Federal Power Act Section 18 Fishway Prescriptions Section 18 of the Federal Power Act 2 states that the Commission is to require construction, operation, and maintenance by a licensee of such fishways as may be prescribed by the Secretaries of Commerce or the U.S. Department of the Interior. By letter dated August 18, 2008, and filed on August 19, 2008, the U.S. Department of Commerce, National Marine Fisheries Service (NMFS) provided mandatory fishway prescriptions. These conditions are described further in section 2.2.4, Modifications to Applicant s Proposal Mandatory Conditions. In addition to its prescription, NMFS includes a general reservation of authority for NMFS to prescribe additional or modified fishways at such times and locations as NMFS may subsequently determine are necessary 2 16 U.S.C

21 to provide for safe, timely, and effective downstream and upstream passage of anadromous fish through the project facilities Section 4(e) Conditions Section 4(e) of the Federal Power Act 3 provides that any license issued by the Commission for a project within a federal reservation shall be subject to, and contain, such conditions as the Secretary of the responsible federal land management agency deems necessary for the adequate protections and use of the reservation. The Forest Service filed preliminary terms and conditions by letter dated August 16, These conditions are described further in section 2.2.4, Modifications to Applicant s Proposal Mandatory Conditions Section 10(j) Recommendations Under section 10(j) of the Federal Power Act 4, each hydroelectric license issued by the Commission must include conditions based on recommendations provided by federal and state fish and wildlife agencies for the protection, mitigation, or enhancement of fish and wildlife resources affected by the proposed project. The Commission is required to include these conditions unless it determines that they are inconsistent with the purposes and requirements of the Federal Power Act or other applicable law. Before rejecting or modifying an agency recommendation, the Commission is required to attempt to resolve any such inconsistency with the agency, giving due weight to the recommendations, expertise and statutory responsibilities of such agency. The Washington Department of Fish and Wildlife (Washington Fish and Wildlife) timely filed its recommendations, terms, and conditions by letter dated August 18, All of the Washington Fish and Wildlife recommendations were the same as Forest Service 4(e) conditions. By a letter dated August 18, 2008, which was filed on August 19, 2008, NMFS provided its 10(j) recommendations. The 10(j) conditions by NMFS and Washington Fish and Wildlife are summarized in table 5-1, in section 5.4.1, Recommendations of Fish and Wildlife Agencies. In section 5.4, we also discuss how we address agency recommendations and comply with section 10(j) Clean Water Act Under section 401 of the Clean Water Act, 5 a license applicant must obtain certification from the appropriate state pollution control agency verifying compliance 3 16 U.S.C. 797(e) U.S.C. 803(j) U.S.C

22 with the Clean Water Act. A section 401 water quality certification is waived if the certifying agency does not act on the request within 1 year. Energy Northwest filed its request for water quality certification on August 14, 2008, to the Washington Department of Ecology. That request is pending; however, a response from the Washington Department of Ecology is due on or before August 14, Endangered Species Act Section 7 of the Endangered Species Act (ESA) requires federal agencies to ensure that their actions are not likely to jeopardize the continued existence of endangered or threatened species of result in the destruction or adverse modification of the critical habitat of such species. NMFS and the U.S. Fish and Wildlife Service (FWS) identified the following listed and proposed to be listed fish species that may occur within the project area: Chinook salmon (Oncorhynchus tshawytscha), coho salmon (O. kisutch), chum salmon (O. keta), steelhead trout (O. mykiss), and bull trout (Salvelinus confluentus). Chum salmon and bull trout are not considered to be distributed in the upper Cowlitz River subbasin. Accordingly, we conclude that the project will have no effect on these listed species. Review of the FWS website in September 2008 indicated that five Endangered Species Act (ESA)-listed wildlife species may occur in Lewis County (FWS, 2007b). These include the Canada lynx (Lynx canadensis), gray wolf (Canis lupus), grizzly bear (Ursus arctos horribilis), marbled murrelet (Brachyramphus marmoratus) and northern spotted owl (Strix occidentalis caurina). We will issue a Biological Assessment for threatened and endangered species. We summarize our findings on Threatened and Endangered Species in section and below in table 1-2. Table 1-2 presents our findings for federally listed species that may occur in the project area, based on assessment of the species range, distribution, and habitat requirements; existing habitat conditions; and analysis of environmental effects. 6

23 Table 1-2. Determination of effect for listed species and findings regarding effects on critical habitat. (Source: Staff) Common Name Species Name Species Finding Critical Habitat Finding Fish Chinook Salmon Oncorhynchus Likely to adversely Likely to tshawytscha affect adversely affect Coho Salmon O. kisutch Likely to adversely affect None designated Steelhead Trout O. mykiss Likely to adversely Likely to affect adversely affect Chum Salmon O. keta No effect No effect Bull Trout Salvelinus confluentus No effect No effect Wildlife Canada Lynx Lynx canadensis No effect No effect Gray Wolf Canis lupus No effect None designated in Washington Grizzly Bear Ursus arctos horribilis No effect None designated in Washington Marbled Murrelet Brachyramphus marmoratus No effect No effect Northern Spotted Owl Strix occidentalis caurina Not likely to adversely affect Not likely to adversely affect Plants Howellia Howellia aquatilis No effect None designated Kincaid s Sulfur Lupinus sulphureus Lupine kincaidii No effect No effect Nelson s Checkermallow Sidalcea nelsoniana No effect None designated Based on these findings, we will request formal consultation with NMFS regarding our findings that relicensing the project would likely adversely affect Chinook and coho salmon and steelhead. We also will request concurrence from FWS regarding our finding that relicensing the project would be not likely to adversely affect the northern spotted owl Coastal Zone Management Act Under section 307(c)(3)(A) of the Coastal Zone Management Act, 6 the Commission cannot issue a license for a project within or affecting a state s coastal zone 6 16 U.S.C. 1456(3)(A). 7

24 unless the state s Coastal Zone Management Act agency concurs with the license applicant s certification of consistency with the state s Coastal Zone Management Act program, or the agency s concurrence is conclusively presumed by its failure to act within 180 days of its receipt of the applicant s certification. Washington State s Coastal Zone Management Program is managed by the Washington Department of Ecology and applies to the 15 coastal counties which front on salt water. The Packwood Lake Hydroelectric Project, located in Lewis County, does not front on salt water ( therefore, relicensing the project would not affect Washington s coastal resources. Our assessment is that the project is not subject to Washington coastal zone review and no coastal zone consistency certification is needed due to the lack of potential effects National Historic Preservation Act Section 106 of the National Historic Preservation Act 7 requires that every federal agency take into account how each of its undertakings could affect historic properties. Historic properties are districts, sites, buildings, structures, traditional cultural properties, and objects significant in American history, architecture, engineering, and culture that are eligible for inclusion in the National Register of Historic Places. To meet the requirements of section 106, the Commission intends to execute a Programmatic Agreement for the protection of historic properties from the effects of construction, operation, and maintenance of the project. The terms of the agreement would ensure that Energy Northwest addresses and treats all historic properties identified within the project s area of potential effects through implementation of the August 30, 2007, Historic Properties Management Plan. Additionally, an appendix to the Programmatic Agreement would contain a stipulation that Energy Northwest would evaluate the hydroelectric system for National Register of Historic Places eligibility once the facility reaches 50 years of age Pacific Northwest Power Planning and Conservation Act Under section 4(h) of the Pacific Northwest Power Planning and Conservation Act, the Northwest Power and Conservation Council (Council) developed the Columbia River Basin Fish and Wildlife Program to protect, mitigate, and enhance the operation of the hydroelectric projects within the Columbia River Basin. Section 4(h) states that responsible federal and state agencies should provide equitable treatment for fish and wildlife resources, in addition to other purposes for which hydropower is developed, and that these agencies shall take into account, to the fullest extent practicable, the program adopted under the Pacific Northwest Power Planning and Conservation Act U.S.C

25 The Columbia River Basin Fish and Wildlife Program directs agencies to consult with federal and state fish and wildlife agencies, appropriate Indian tribes, and the Council during the study, design, construction, and operation of any hydroelectric development in the basin (sections 12.1A. through 12.1A.2). When the application was filed, the regulations required the applicant to consult with the appropriate federal and state fish and wildlife agencies and tribes before filing, and after filing, to provide these groups with opportunities to review and comment on the application. Energy Northwest has followed this consultation process according to the Commission s regulations for the Integrated Licensing Process (18 CFR 5.18 and associated sections) and the relevant federal and state fish and wildlife agencies and tribes have reviewed and commented on the application. To mitigate harm to fish and wildlife resources, the Council has adopted specific provisions to be considered in the licensing or relicensing of non-federal hydropower projects (appendix B of the Columbia River Basin Fish and Wildlife Program). The provisions that apply to the project require: (1) specific plans for fish facilities prior to construction; (2) assurance that the project will not degrade fish habitat or reduce numbers of fish; (3) assurance that all fish protection measures are fully operational at the time the project begins operation; (4) timing construction activities, insofar as practical, to reduce adverse effects on wintering grounds; and (5) replacing vegetation if natural vegetation is disturbed. Staff recommendations are consistent with the provisions, listed above. A further condition of any license issued would reserve to the Commission the authority to require future alterations in project structures and operation to take into account, to the fullest extent practicable, the applicable provisions of the program. As part of the Columbia River Basin Fish and Wildlife Program, the Council has designated more than 40,000 miles of river in the Pacific Northwest region as unsuitable for hydroelectric development (protected area). The project is not affected by a designated protected area Wild and Scenic Rivers Act Section 7(a) of the Wild and Scenic Rivers Act 8 requires federal agencies to make a determination as to whether the operation of the project under a new license would invade the area or unreasonably diminish the scenic, recreational, and fish and wildlife values present in the designated river corridor. Currently, there are no congressionally designated wild, scenic, or recreational rivers in the Gifford Pinchot National Forest. As required under Section 5(d) of the act, the National Park Service maintains a Nationwide Rivers Inventory, which is a register of river segments that potentially qualify as national 8 16 U.S.C

26 wild, scenic, or recreational river areas. The Nationwide Rivers Inventory has more than 3,400 free-flowing river segments in the United States that are believed to possess one or more outstandingly remarkable natural or cultural values judged to be of more than local or regional significance. Segments of the Cowlitz River are listed in the Nationwide Rivers Inventory, including a 42-mile-long segment between Muddy Creek and Riffe Lake. Within this segment, Lake Creek and the project s tailrace waters enter the Cowlitz River. The Nationwide Rivers Inventory shows scenery and geology as outstandingly remarkable values in this segment of the Cowlitz River, and gives this segment a preliminary classification as a Recreation River; however, relicensing the project would not affect the identified values for the Cowlitz River or potential future listings Magnuson-Stevens Fishery Conservation and Management Act The Magnuson-Stevens Act, 9 as amended by the Sustainable Fisheries Act of 1996, requires federal agencies to consult with NMFS on all actions that may adversely affect Essential Fish Habitat. The objectives of this Essential Fish Habitat consultation are to determine whether the proposed action will adversely affect designated Essential Fish Habitat and to recommend conservation measures to avoid, minimize, or otherwise offset potential adverse effects on Essential Fish Habitat. In the case of the Packwood Lake Hydroelectric Project, Essential Fish Habitat for Chinook and coho salmon exists in the project area. In section we examine the existing condition of Chinook and coho salmon Essential Fish Habitat in the project area and those measures included in the proposed action that have the potential to affect these species and their Essential Fish Habitat. We conclude that those measures incorporated into the proposed action would likely be beneficial to Chinook and coho salmon and would improve or at least maintain the existing condition of this Essential Fish Habitat over the long-term. Therefore we conclude that licensing the project, as proposed by Energy Northwest, with staff s additional measures would not adversely affect designated Essential Fish Habitat for Chinook and coho salmon. With this draft EA, we are requesting NMFS concurrence with our conclusion on Essential Fish Habitat U.S.C

27 1.4 PUBLIC REVIEW AND CONSULTATION The Commission s regulations 10 require that applicants consult with appropriate resource agencies, tribes, and other entities before filing an application for a license. This consultation is the first step in complying with the Fish and Wildlife Coordination Act, the ESA, the National Historic Preservation Act, and other federal statutes. Pre-filing consultation must be complete and documented according to the Commission s regulations Scoping During the integrated licensing process, the Commission conducted scoping to determine what issues and alternatives should be addressed. A scoping document was distributed to interested agencies and others on January 11, Two scoping meetings were held in Packwood, Washington on February 3, 2005, to request oral comments on the project. A court reporter recorded all comments and statements made at the scoping meetings, and these comments are part of the Commission s public record for the project. In addition to comments provided at the scoping meetings, the following entities provided written comments: Commenting Entities Date of Filing Washington Fish and Wildlife March 9, 2005 Forest Service March 11, 2005 FWS March 11, A revised Scoping Document, addressing these comments, was issued on April 25, Interventions Organizations and individuals may petition to intervene and become a party to subsequent proceedings. On June 19, 2008, the Commission issued a notice accepting Energy Northwest s application and soliciting comments, recommendations, terms and conditions, and prescriptions. On September 16, 2008, the Commission issued a notice accepting Energy Northwest s application for filing and solicited motions to intervene. This notice set 60 days as a deadline for filing protests and motions to intervene. The following organizations filed motions to intervene C.F.R. sections

28 Intervenor Date of Filing Forest Service August 16, 2008 NMFS August 19, 2008 Washington Fish and Wildlife October 17, 2008 Washington Department of Ecology November 5, Comments on the License Application The Commission issued a Ready for Environmental Analysis Notice on June 19, 2008, requesting that terms, conditions, and recommendations be filed by August 18, The following entities provided comments. Commenting Entity Date of Filing Forest Service August 16, 2008 Washington Fish and Wildlife August 18, 2008 U.S. Department of the Interior, Office of Environmental Policy and Compliance August 18, 2008 NMFS August 19, 2008 Energy Northwest filed its reply comments on October 1,

29 2.0 PROPOSED ACTION AND ALTERNATIVES 2.1 NO-ACTION ALTERNATIVE Under the no-action alternative, the project would continue to operate under the terms and conditions of the current license, and no new environmental measures would be implemented. We use this alternative as the baseline environmental condition for comparison with other alternatives Existing Project Facilities The proposed project would consist of the following: (1) a 452-acre natural lake (Packwood Lake) at a normal full pool elevation of 2,857 feet above mean sea level (msl) with about 4,162 acre-feet of useable storage; (2) a trapezoidal intake canal that is about 424 feet long; (3) a concrete weir (drop structure) that is 15 feet high and 85 feet long with a stilling basin; (4) an intake building on Lake Creek located adjacent to the weir; (5) a 4.1-mile-long conveyance system of concrete pipe and tunnels; (6) a 1.1-mile-long concrete-encased steel penstock; (7) a concrete surge tank that is 5.5 feet in diameter and 191 feet high; (8) a concrete powerhouse with a megawatt turbine generator; (9) an excavated trapezoidal tailrace channel with an asphalt lining that is 29 feet wide at the top and 9 feet wide at the bottom; (10) a tailrace fish barrier; (11) a switchyard; and (12) a 1.5-mile-long, 69 kv transmission line. Average annual generation at the project is about 92,000 MWh. Figure 2-1 shows the Packwood Lake outlet and location of intake and drop structures. Figures 2-2 and 2-3 show the project layout and boundary (see also figure 1-1). 13

30 Figure 2-1. Packwood Lake Hydroelectric Project, detail of the outlet area. (Source: Energy Northwest, 2008a, as modified by staff) The 5.3-mile-long bypassed reach of Lake Creek is not included in the project boundary. The tailrace from the powerhouse and the 1.5-mile-long transmission line segment from the powerhouse to the Lewis County Public Utilities Department substation along Route 12 are included in the project boundary. The project boundary also includes about 1,400 linear feet in the tailrace which was washed out in a 1977 flood Project Safety The project has been operating for 44 years under the existing license, during which time Commission staff have conducted operational inspections focusing on the continued safety of the structures, identification of unauthorized modifications (if any), efficiency and safety of operations, compliance with the terms of the license, and proper maintenance. The project is exempted from requirements to have the project inspected and evaluated every 5 years by an independent consultant and from requirements to maintain an Emergency Action Plan for the project to be implemented in case of an emergency. As part of the relicensing process, Commission staff would evaluate the continued adequacy of the proposed project facilities under a new license. Special articles would be included in any license issued, as appropriate. Commission staff would continue to inspect the project during the new license term to assure continued adherence to Commission-approved plans and specifications, special license articles relating to 14

31 construction (if any), operation and maintenance, and accepted engineering practices and procedures Existing Project Operation The project is controlled from the project powerhouse and is operated in an automatic mode according to current license conditions, water availability, and power contracts. The project has a water right for 260 cubic feet per second (cfs) but does not operate at capacity at all times. The volume of water passing through the project varies with generator load and can range from a maximum of 225 cfs to a minimum of about 19 cfs. During the May 1 to September 15 period, the project s generation is dictated by article 37 of the existing license, which specifies a lake level requirement of 2,857 feet msl plus or minus 0.5 foot unless conditions occur which are beyond the control of the licensee. From May 1 to September 15, the project generation flow is adjusted to match lake inflow to hold the lake elevation relatively constant. After mid-september, the lake level may be drawn down as much as 8 feet to a level no lower than 2,849 feet msl. The 8 feet of vertical storage allows the project to store and utilize winter runoff for power generation. When seasonal high runoff exceeds the project capacity and the available lake storage capacity, as occasionally happens during fall and winter rain events and during snowmelt in the spring and early summer, the drop structure is overtopped (at elevation 2,858.5 feet msl) and excess runoff flows over the spillway and down Lake Creek. 11 Between 1967 and 2003 (the period of best available data), overtopping occurred or is suspected to have occurred on 504 days, averaging 13.7 days per year. However, in some years, no spill occurred. Article 37 of the license established the maximum operating water surface elevation for Packwood Lake as 2,858.5 feet msl. Article 14 of the existing project license requires Energy Northwest to release a year-round minimum instream flow of 3 cfs from Packwood Lake into lower Lake Creek to maintain aquatic habitat. Article 14 also requires a release of up to a maximum of 5 cfs during the period of May 15 to September 15 in order to facilitate a flow of 15 cfs at the gaging station identified as U.S. Geological Survey (USGS) gage no Lake Creek at Mouth. However, by a letter dated October 20, 1980, FERC authorized the discontinuance of the gage near the mouth of Lake Creek and also USGS gage no Lake Creek near Packwood, located immediately below Packwood Lake. 11 The nominal design capacity of the pipeline and penstock system is about 236 cfs. The volume of water passing through the project varies with generator load, and typically ranges from about 225 cfs (27 MW) to a minimum of about 19 cfs (1 MW). On average, it requires about 8 cfs per MW to operate the project. The project does not have the ability to control flows other than diverting the maximum amount to the powerhouse when flows reach the elevation of the drop structure (2,858.5 feet msl). 15

32 Energy Northwest has since been releasing about 3 cfs year as the minimum flow. Energy Northwest records water releases daily at the project drop structure. Energy Northwest has historically scheduled an annual project outage to perform equipment maintenance and inspection during the first 3 weeks of October. October was selected to minimize the economic impact of the scheduled outage, because it is typically a month with low inflows to the lake. In preparation for the scheduled outage, the lake is normally drawn down during the last 2 weeks in September. The resulting low lake level facilitates the work around the intake structure and minimizes the potential of an uncontrolled spill event down Lake Creek during the outage period. During the scheduled outage, the project s pipeline and penstock are normally dewatered to facilitate inspections and minor maintenance. The Commission is notified that the tunnels and penstock will be dewatered. According to Energy Northwest, under any water conditions, the priorities for plant operations are, from highest to lowest, to: (1) provide the required bypass flow down lower Lake Creek, (2) maintain the required lake levels specified in the license, and (3) to generate electricity with the balance of the water in accordance with Energy Northwest s power sales contracts. During dry periods with very low inflows, the project may be shut down in order to maintain the required lake level. Bypass flow releases to Lake Creek continue whether the project is operating or not. 16

33 17 Figure 2-2. Packwood Lake Hydroelectric Project, detail of the powerhouse area. (Source: Energy Northwest, 2008a, as modified by staff)

34 18 Figure 2-3. Packwood Lake Hydroelectric Project, detail of the tailrace area. (Source: Energy Northwest, 2008a, as modified by staff)

35 2.1.4 Existing Environmental Measures As indicated above, Article 14 of the existing license for the project requires Energy Northwest to release a year-round a minimum instream flow of 3 cfs from Packwood Lake into lower Lake Creek. Within lower Lake Creek, the normal natural accretion from runoff and groundwater inflow ranges from about 20 to 30 cfs during the winter and spring and about 10 cfs during the summer and early fall. Under the current license, Energy Northwest recently constructed and currently maintains a fish barrier (drum screens) at the downstream end of the project tailrace. 12 The design is based on two 14-foot long by 4-foot diameter drum screens fabricated by the Washington Fish and Wildlife Screen Shop in Yakima, Washington. The overall purpose of the tailrace barrier is to prevent fish (both anadromous and resident) from traveling up the project tailrace to the stilling basin, where they would be subject to potential delay in migration or mortality. In addition to these measures, Energy Northwest currently implements provisions for best management practices related to storm water pollution prevention; spill prevention, control and countermeasures; and noxious weed control. These provisions include a description of the personnel with primary responsibility for overseeing compliance with state and federal environmental regulations; spill prevention and response procedures; inspection procedures; personnel training; plan updates; and other applicable measures. Copies of these plans can be found in the final license application, appendices A and E, respectively (Energy Northwest, 2008a). 2.2 APPLICANT S PROPOSAL Proposed Project Facilities No new project development is proposed as part of relicensing this project Proposed Project Operation The existing license for the project requires a maximum Packwood Lake water surface elevation of 2,858.5 feet msl (the elevation of the drop structure crest) and a minimum water surface elevation of 2,849.0 feet msl. Under the proposed action, the existing maximum water surface elevation (2,858.5 feet msl) restriction would be dropped, because Energy Northwest does not have the ability to control flows during high inflow events other than diverting water to the powerhouse. In addition, the May 1 to September 15 maximum lake level requirement of 2,857.5 feet msl, would be eliminated to allow higher spring and summer lake levels to facilitate proposed annual aquatic 12 Energy Northwest, 120 FERC 62, 218 (2007). 19

36 habitat forming flows, support an August 15 to September 15 scheduled outage, and maintain continuous plant operations and lower Lake Creek instream flow releases in September and October. Energy Northwest would retain the existing minimum lake elevations of 2,856.5 feet msl between May 1 and September 15 and 2,849 feet msl between September 16 and April 30. The minimum lake level during the winter is needed to provide sufficient water for increased bypass flows in lower Lake Creek for project generation that provides continuous flows through the tailrace to the tailrace slough following the scheduled outage, and to allow cleaning and maintenance of the projects intake screens. Figure 2-4 shows the existing and proposed water levels for Packwood Lake, and table 2-1 shows proposed instream flows for Lake Creek Packwood Lake Existing and Proposed Reservoir Levels Elevation (feet msl) Jan 1-Feb 1-Mar 1-Apr 1-May 1-Jun 1-Jul 1-Aug 1-Sep 1-Oct 1-Nov 1-Dec Existing Maximum Level (2,858.5) None in Proposed Conditions Existing and Proposed Minimum Levels (2,849 and 2,856.5) Existing Summer Maximum Under Normal Operating Conditions (2,857.5) Figure 2-4. Packwood Lake minimum and maximum water levels restrictions under existing and proposed conditions. (Source: Energy Northwest, 2008a) 20

37 Table 2-1. Proposed instream flows (cfs) for Lake Creek, as measured at the drop structure. (Source: Energy Northwest, 2008a, appendix D) Month Instream Flow (cfs) January, February, March 4 April 7 May 15 June 10 July 15 August Aug 16 Sept September October 10 November 7 December 4 Energy Northwest has historically scheduled an annual project outage to perform equipment maintenance and inspection during the first 3 weeks of October. Under the proposed action, Energy Northwest would begin its scheduled outage on August 15 of each operating year and resume project operations on or before September 15. Completing the scheduled outage prior to September 15 would provide additional protection for spawning Chinook and coho salmon in the side channel of the Cowlitz River below the tailrace. Outage in this earlier period would also help avoid the discharge of naturally warmed Packwood Lake water into the Cowlitz River, when summer temperatures are at their highest; and help ensure adequate water is available in Packwood Lake to provide the proposed minimum flows for Lake Creek. Energy Northwest is not proposing to draw down Packwood Lake prior to the start of the outage, as it currently does under existing operations Proposed Environmental Measures Provide increased instream flows in Lake Creek according to the schedule above. Begin the annual outage for project maintenance on August 15 of each operating year, and resume operation by September 15, or earlier if all necessary work has been completed. Provide a spill event of greater than or equal to 285 cfs for as long as lake inflows can sustain that flow for a maximum of 24 hours, every other water year or 3 out of 6 water years. Provide documentation and reporting of the spill events and, if the frequencies of the spill events cannot be achieved, the agencies (including the Forest 21

38 Service and Washington Fish and Wildlife) will be consulted for an alternate plan. Implement a 3-phase adaptive plan to reduce entrainment at the project intake that would include as phase 1: replacing existing debris screens with better fitting screens, and monitoring results to determine if entrainment is less than targets established. If target numbers are met, this effort is deemed acceptable. If targets are not met, under phase 2, Northwest Energy would remove the debris screens, develop other means for cleaning debris from the trashracks, and monitor to determine if entrainment is less than the threshold targets. If targets are met at this point, this effort would be deemed acceptable. If impingement on the screens under Phase 2 exceeds threshold levels, Energy Northwest under phase 3 would consult with the natural resource agencies and tribes to determine an alternative means of protecting fish at the intake. Ensure a minimum of 30 adult resident rainbow trout are present in the upper 1,464 feet of Reach 5 of Lake Creek by monitoring abundance and age class and periodically moving Packwood Lake trout to Lake Creek downstream of the drop structure either by overtopping events (aquatic habitat flows) or by physically collecting and moving fish. Provide gravel and wood recruitment stations in Reach 5 below the drop structure. Wood and gravel located at these structures would be carried downstream during the channel-forming flows provided as part of the aquatic habitat spill events described above. Develop and implement a stream restoration and enhancement plan for the lowest 1.0 mile (river mile 0.0 to 1.0) of Lake Creek in the anadromous zone, after consultation with the natural resource agencies and tribes. Improve fish passage on Snyder Creek where its culvert crosses under the tailrace canal by rerouting Snyder Creek into Hall Creek on the downstream side (south) of the tailrace canal within 5 years of license issuance. Install flow measurement equipment at the Lake Creek Road bridge and begin recording data, within the first year of the issuance of any new license. 22

39 Maintain and monitor effectiveness of the tailrace fish barrier. Inspect the tailrace slough prior to the annual outage for adequate flows, and rescue fish, if necessary. Develop a monitoring plan after consultation with the Washington Department of Ecology, to evaluate the effectiveness of project operations, including the timing of the annual outage, and meet the applicable temperature standard at the confluence of the project tailrace with the Cowlitz River. If the tailrace temperature standard is not sufficiently resolved by changes in project operations, Energy Northwest will consult with the Washington Department of Ecology and other agencies on additional ways to address this issue. Develop and implement a threatened, endangered, and sensitive species management plan. Develop and implement a rare plant management plan, and incorporate it into the threatened, endangered, and sensitive species management plan after consultation with resource management agencies. Develop and implement an Integrated Weed Management Plan incorporating the current weed control plan. Provide for regular weed control and site-specific efforts. Implement the Recreation Management Plan as filed with the Commission on June 6, 2008, including: 1) install and maintain a composting toilet at Packwood Lake; 2) install and maintain a kiosk at the Packwood Lake Trailhead; 3) provide annual maintenance to the Pipeline Trail (FS Trail 74) and the Pipeline Bypass Trail (Dyson Pass) including drainage, trail clearing, and vegetation management; 4) provide operation and maintenance measures or annual funding of a seasonal employee to address effects of dispersed recreational use at the project; 5) continue providing power to the Forest Service guard station; 6) consult with the Forest Service on appropriate paint colors and materials as repairs and maintenance to the project intakerelated structures or facilities are performed to ensure the building blend in with the surrounding area; and 23

40 7) develop and implement a road maintenance plan for portions of Snyder Road (FS Road 1260), Pipeline Road (FS Road ), Powerhouse Road (FS Road ), and Latch Road (FS Road 1262), after consultation with the Forest Service. Implement the August 30, 2007, Historic Properties Management Plan including measures to install an interpretive sign at the ATV parking area along FS Trail 74. Ensure that the project transmission line conforms to Avian Power Line Interaction Committee standards for raptor protection. Develop and implement a road maintenance plan for Pipeline Road (FS Road ), Pipeline Trail (Trail No. 74), and Latch Road (FS Road 1262 above the gate), after consultation with the Forest Service. Develop and implement a resource coordination plan to coordinate the recommended management plans and associated requirements for the project with various agencies and include provisions for an annual coordination meeting. Develop and implement a fire prevention plan for the project as part of the resource coordination plan Modifications to Applicant s Proposal Mandatory Conditions The following mandatory conditions have been provided and are evaluated as part of Energy Northwest s proposal Section 18 Prescriptions On August 19, 2008, NMFS provided mandatory fishway prescriptions that would require Energy Northwest to: (1) continue the measures for maintenance, testing, and operation of the fish screen (post-construction) 13, as described in the incidental take statement (NMFS, 2007) and (2) develop and implement a plan (within 2 years of license issuance) to provide adequate passage that meets NMFS fish passage standards at the Snyder Creek tailrace crossing construction. 13 Energy Northwest constructed a fish screen facility to exclude fish from the project tailrace and stilling basin in the fall of

41 Section 4(e) Land Management Conditions The Forest Service filed preliminary terms and conditions under section 4(e) on August 16, These terms and conditions include the following: conditions 1 and 19 are administrative or legal in nature and not specific environmental measures; condition 15 is related to project safety and as such, monitoring is required regardless of the outcome of the relicensing procedure; condition 2 requires a resource coordination plan; condition 3 requires a fire prevention plan; condition 4 requires changes in the Packwood Lake elevations and timing of the annual project maintenance; condition 5 requires higher instream flows to lower Lake Creek; condition 6 requires releases for aquatic habitat enhancement in lower Lake Creek; condition 7 requires lower Lake Creek stream restoration and monitoring; condition 8 requires rainbow trout surveys and supplementation in the upper reach of lower Lake Creek; condition 9 requires methods to address entrainment at the project intake; condition 10 requires improved fish passage for Snyder Creek; condition 11 requires amphibian monitoring at site B near Packwood Lake; condition 12 requires the implementation of a threatened, endangered, and sensitive species management plan; condition 13 requires a Packwood Lake tributary headcutting monitoring program; condition 14 requires complying with provision of the Recreation Management Plan as filed with the Commission on June 6, 2008; condition 16 requires implementing the Integrated Weed Management Plan as filed with the Commission on June 6, 2008; condition 17 requires complying with the Avian Protection Plan filed with the Commission on June 6, 2008; and condition 18 requires complying with the Historic Properties Management Plan as filed with the Commission on August 30, As mentioned above, in its mandatory 4(e) condition 14, the Forest Service requires the licensee to completely and fully comply with all provisions of the Recreation Management Plan filed with the Commission on June 6, The Recreation Management Plan contains a provision for the licensee to continue to provide power to the Forest Service guard station, even though there is no nexus to the project. 14 However, in the absence of a statutory directive, it is not our policy to require specific allocation of power from licensed projects, but to leave those matters to private contract, and as 14 Because the guard station pre-existed the Packwood Lake Hydroelectric Project and Packwood Lake is a natural lake, the presence of the guard station is not a result of the Packwood Lake Hydroelectric Project; and therefore, has no nexus to the project. 25

42 appropriate, state regulation. 15 Therefore, it is against Commission policy to require the licensee to allocate power to the Forest Service guard station. As a result, we do not provide any further analysis in this draft EA of the provision to provide power to the Forest Service guard station. However, we recognize that the Commission is required to include valid section 4(e) conditions in any license issued for the project. 2.3 STAFF ALTERNATIVE Under Energy Northwest s proposal with staff modifications, the project would be operated as proposed, but would include the following: Implement ramping rates in lower Lake Creek during project-related flow changes. Develop and implement a threatened, endangered, and sensitive species management plan, including conducting surveys for Oregon goldenaster prior to ground-disturbing activities in lower Lake Creek and consulting with resource management agencies regarding timing restrictions or other measures that may be needed to prevent adverse effects on amphibians during efforts to reroute Snyder Creek. Modify the Integrated Weed Management Plan to expand the list of target species for weed control at sites below the stilling basin, in order to protect the state-listed Oregon goldenaster and prevent the spread of noxious weeds as a result of implementing environmental measures in lower Lake Creek and Snyder and Hall creeks. Pursue formal National Register of Historic Places evaluation of the Packwood Lake facilities in 2014, when the facilities qualify. 2.4 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM FURTHER ANALYSIS We considered several alternatives to the applicant s proposal, but eliminated them from further analysis because they are not reasonable in the circumstances of this 15 It has... been the practice of this Commission and the predecessor Federal Power Commission (FPC) since the issuance of licenses began in 1920 to leave the disposition of project power in the hands of the licensee, which is responsible for the construction, operation, and maintenance of the project, unless Congress has made a legislative directive to the contrary. Power Authority of the State of New York; Massachusetts Municipal Wholesale Electric Company v. Power Authority of the State of New York, 109 FERC 61,092 (2004). See New York Power Authority, 118 FERC 61,206 at P 73 n.73 (2007). 26

43 case. They are (1) issuing a non-power license, (2) federal government takeover of the project, and (3) retiring the project. A nonpower license is a temporary license that the Commission will terminate when it determines that another governmental agency will assume regulatory authority and supervision over the lands and facilities covered by the nonpower license. At this point, no agency has suggested a willingness or ability to do so. No party has sought a nonpower license and we have no basis for concluding that the project should no longer be used to produce power. Thus, we do not consider issuing a nonpower license a realistic alternative to relicensing in this circumstance. We do not consider federal takeover to be a reasonable alternative. Federal takeover of the Packwood Lake Hydroelectric Project would require Congressional approval. Although that fact alone would not preclude further consideration of this alternative, there is currently no evidence showing that a federal takeover should be recommended to Congress. No party has suggested that federal takeover would be appropriate, and no federal agency has expressed an interest in operating the project. Project retirement could be accomplished with or without dam removal. Either alternative would involve denial of the relicense application and surrender or termination of the existing license with appropriate conditions. No participant has suggested that dam removal would be appropriate in this case, and we have no basis for recommending it. Dam removal is often recommended by some parties to allow fish passage into areas that were formerly accessible by anadromous fish; however, Packwood is a natural lake and water falls in the lower part of Lake Creek have historically blocked fish access. Thus, dam removal is not a reasonable alternative to relicensing the project with appropriate environmental measures. 27

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45 3.1 GENERAL SETTING 3.0 ENVIRONMENTAL ANALYSIS 16 The Packwood Lake Hydroelectric Project is located near the town of Packwood in Lewis County, Washington, within the Gifford Pinchot National Forest (see figure 1-1). The project is located just west of the crest of the Cascade Mountains and south of Mt. Rainier in central Washington near the town of Packwood (elevation 1,050 feet msl). Packwood Lake (452 acres) is located in a mountainous region about 5 miles east of the town at an elevation of 2,857 feet msl. The lake is bounded on both the east and west by mountains with ridge top elevations of approximately 5,000 feet or higher. Snyder Mountain (elevation 5,011 feet msl) is located immediately west of the lake. The lake is located at the lower end of the upper Lake Creek valley midway between the Goat Rocks and the Cowlitz River. A number of small streams flow into the lake but the primary source of water is upper Lake Creek that originates from Packwood Glacier and other snowfields on the flanks of Old Snowy Mountain (Goat Rocks). Packwood Lake is drained by Lake Creek, a tributary of the Cowlitz River, and the Packwood Lake Hydroelectric Project. Upper Lake Creek and Lake Creek have a northwest - southeast trend in parallel with the other streams in the area. 3.2 SCOPE OF CUMULATIVE EFFECTS ANALYSIS According to the Council on Environmental Quality s regulations for implementing National Environmental Policy Act (40 C.F.R ), a cumulative effect is the impact on the environment that results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (federal or non-federal) or person undertakes such actions. Cumulative effects can result from individually minor but collectively significant actions taking place over time, including hydropower and other land and water development activities. Based on our review of the license application and agency and public comments, we identified water quality and fishery resources as having the potential to be cumulatively affected by the proposed project in combination with other past, present, and foreseeable future activities Geographic Scope The geographic scope of analysis for cumulatively affected resources defines the physical limits or boundaries of the effects of the proposed action on the resources. 16 Unless otherwise indicated, our information is taken from the license application for this project (Energy Northwest, 2008a). 29

46 Because the proposed action can affect resources differently, the geographic scope for each resource may vary but for water quality and fisheries includes the Lake Creek watershed and Cowlitz River downstream of the confluence with Lake Creek, downstream to the Columbia River Temporal Scope The temporal scope of analysis includes a discussion of the past, present, and future actions and their effects on water quality and fisheries resources. Based on the potential term of a license, the temporal scope looked 30 to 50 years into the future, concentrating on the effect on water quality and fisheries from reasonably foreseeable future actions. The historical discussion is limited, by necessity, to the amount of available information for each resource. We identified the present resource conditions based on the license application, agency comments on the draft license application, and comprehensive plans. 3.3 PROPOSED ACTION AND ACTION ALTERNATIVES In this section, we discuss the effect of the project alternatives on environmental resources. For each resource, we first describe the affected environment, which is the existing condition and baseline against which we measure effects. We then discuss and analyze the specific site-specific and cumulative environmental issues. Only the resources that would be affected, or about which comments have been received, are addressed in detail in this EA. We have not identified any substantive issues related to socioeconomics associated with the proposed action, and, therefore, this topic is not assessed in this EA. Discussion of geology and soils is included in section, 3.3.1, Aquatic Resources. We present our recommendations in section 5.2, Comprehensive Development and Recommended Alternative Aquatic Resources Affected Environment Water Resources Water Quantity Packwood Lake has a drainage area of about 19.2 square miles. Tributaries that drain into Packwood Lake include Upper Lake Creek, Osprey Creek, Trap Creek, Muller Creek, and Crawford Lake Creek. All of these tributaries are unregulated and ungaged. Based on lake levels and project discharge records for 1999 to 2007, Energy Northwest calculated the mean monthly inflow to Packwood Lake (table 3-1), and the highest mean inflows occur during the snowmelt months of May and June. 30

47 Table 3-1. Inflow (cfs) to Packwood Lake. (Sources: Energy Northwest, 2008a; USGS, 2008) Month Calculated Mean Inflow a October 43 November 84 December 71 January 82 February 95 March 96 April 76 May 138 June 172 July 105 August 51 September 35 a Estimated by Energy Northwest. Packwood Lake The normal surface area of Packwood Lake is 452 acres at a lake elevation 2,857 feet msl. From May 1 to September 15, the project is operated to maintain a lake elevation of 2,857 msl plus or minus 0.5 foot. During the summer period, project generation is generally adjusted to keep the lake level relatively constant. The existing license also specifies a maximum lake level of 2,858.5 feet msl, which is the top of the outlet control structure. From September 16 to April 30, the existing license specifies a minimum lake elevation of 2,849 msl, and Energy Northwest uses the storage to store and utilize winter runoff for power generation. Historically, Energy Northwest normally performs an annual generation plant shutdown to allow for maintenance and inspection during the first 3 weeks in October. Prior to this time period, the lake level is normally drawn down during the last 2 weeks in September. According to Energy Northwest, the project is operated using the following three priorities, from highest to lowest: 1. Provide the required bypass flow down lower Lake Creek; 2. Maintain the required lake levels specified in the license; and 31

48 3. Generate electricity with the balance of the water in accordance with Energy Northwest s power sales contracts. As a result of these project operations, during very low inflow periods, the project is shut down to maintain the required lake level and maintain flow releases to Lake Creek. Figure 3-1 provides a graph of the monthly minimum and maximum Packwood Lake levels from January 1999 to December This figure shows that the lake level has commonly exceeded the maximum lake surface elevation of 2,858.5 feet msl even as a monthly average and that the minimum monthly lake elevation does not normally remain near minimum elevation 2,849 feet for too long. Table 3-2 provides a summary of the number of days and maximum flows when Packwood Lake exceeded an elevation of 2,858.5 msl, the top of the outlet structure. 17 Table 3-2 also shows that, on a daily basis, Packwood Lake has exceeded elevation 2,858.5 feet msl 25 out of the 40 years between 1967 and Energy Northwest states that, prior to the construction of the Packwood Project, the water level of Packwood Lake normally ranged between elevation 2,856.5 and 2,857.5 feet msl. The result of these project operations is that during very low inflow periods, the Packwood Project is shut down to maintain the required lake level and continue the bypassed reach flow releases to Lake Creek. Figure 3-1 provides a graph of the monthly minimum and maximum Packwood Lake levels from January 1999 to December Table 3-2 provides a summary of the number of days and maximum flows when Packwood Lake exceeded an elevation of 2,858.5 feet msl, the top of the outlet structure. 5 Energy Northwest states that, prior to the construction of the Packwood Project, the water level of Packwood Lake normally ranged between elevation 2,856.5 and 2,857.5 feet msl. 17 Due to the lack of gates or other control devices, Energy Northwest does not have the ability to control flow at this elevation, other than diverting flow to the powerhouse. 32

49 2,862 2,861 2,860 2,859 2,858 Elevation (feet msl) 2,857 2,856 2,855 2,854 2,853 2,852 2,851 2,850 2,849 2,848 Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Jan-07 Jan-08 Historical minimum monthly level Existing maximum rule curve level Historical maximum monthly level Existing minimum rule curve level Figure 3-1. Table 3-2. Packwood Lake minimum and maximum monthly water levels. (Source: Energy Northwest, 2008a) Summary of Packwood overtopping events, 1967 to (Source: Energy Northwest, 2008a) Year Days Overtop Days Suspected Overtop Days Total Days Plant Down Days Adj. Total Max Flow (cfs)

50 Year Days Overtop Days Suspected Overtop Days Total Days Plant Down Days Adj. Total Max Flow (cfs) Total The intake structure is located about 424 feet downstream from the outlet of the lake and is connected to the lake by an excavated inlet canal. From Packwood Lake, flow is diverted at the intake structure to either Lake Creek or to the pipeline and tunnel leading to the powerhouse. Energy Northwest stated that the amount of water sent to the powerhouse typically ranges from a minimum of 19 cfs to a high of about 225 cfs. Energy Northwest has a water right of 260 cfs, but normally does not operate at that rate and the nominal design capacity of the pipeline and penstock is 236 cfs. The existing license requires a minimum flow of 3 cfs from Packwood Lake to Lake Creek. Furthermore, during May 15 to September 15, the project was originally required to release up to a maximum of 5 cfs, in order to facilitate a flow of 15 cfs at the 34

51 gaging station identified as Lake Creek at Mouth (USGS Station No ). The instream flow requirement was established as a result of studies conducted in the late 1960s and early 1970s in consultation with Washington Game Commission and Washington Department of Fisheries (now Washington Fish and Wildlife), the Bureau of Commercial Fisheries, the Bureau of Sport Fisheries and Wildlife, and the Forest Service. By letter dated October 20, 1980, the Commission authorized the discontinuance of the USGS gaging stations related to the project (i.e., Station Nos and ). Energy Northwest is not currently required to measure instream flows in Lake Creek near its confluence with the Cowlitz River; however, water releases are recorded daily at the project drop structure. Outlet flow data collected by Energy Northwest for January 1999 to the end of December 2007 indicate that the minimum flows averaged slightly more than 3 cfs from the outlet structure. Table 3-3 provides flow data from the two currently inactive flow gages on Lake Creek and the active gage on the Cowlitz River downstream of the mouth of Lake Creek, but upstream of the project tailrace. The Lake Creek gages show that flows from Packwood Lake were generally highest in the late spring and early summer and lowest during the late summer and early fall. From the gage along Lake Creek for the 1965 to 1977 period, representing post-project conditions, median flows were highest during the winter indicating the influence of inflow from small tributaries downstream of Packwood Lake. Downstream of Packwood Lake, Lake Creek flows about 5.3 miles to its confluence with the Cowlitz River at river mile The drainage area of lower Lake Creek, not counting Packwood Lake is about 7.3 square miles. Within this reach, the normal natural accretion from runoff and groundwater inflow ranges from about 20 to 30 cfs during the winter and spring and about 10 cfs during the summer and early fall. Flows from the Packwood powerhouse are returned to the Cowlitz River at about river mile about 4 miles downstream of the confluence of Lake Creek. As shown in table 3-3, flows in the Cowlitz are generally highest in May and June, with flood events occurring during the late fall and winter. 35

52 36 Table 3-3. Flow (cfs) at gages along Lake Creek and the Cowlitz River. (Source: USGS, 2008) Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep USGS gage no Lake Creek at Packwood Lake Outlet (October 1, 1912 to September 30, 1962 pre project) Mean Median Max , Min % Exceed % Exceed USGS gage no Lake Creek at Packwood Lake Outlet (October 1, 1965 to September 30, 1980 post project) Mean Median Max , Min % Exceed % Exceed USGS gage no Lake Creek at Mouth (October 1, 1965 to November 1977 post project) Mean Median Max , Min % Exceed % Exceed USGS gage no Cowlitz River at Packwood (October 1, 1965 to September 30, 2007) Mean 673 1,619 1,720 1,697 1,496 1,325 1,617 2,639 2,809 1, FERC PDF (Unofficial) 02/05/2009

53 37 Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Median 430 1,050 1,080 1, ,040 1,350 2,250 2,460 1, Max. 11,200 30,000 27,700 17,800 26,800 13,100 16,000 8,730 13,400 7,140 3,730 4,000 Min % Exceed. 1,340 3,173 3,530 3,586 2, % Exceed FERC PDF (Unofficial) 02/05/2009

54 Water Quality The water quality characteristics of tributaries to Packwood Lake are reflective of the relatively undisturbed nature of the drainage area. Based on the current state water quality standards, which became effective in December 2006, Packwood Lake has been designated by the state as a member of the lake class where the water quality must meet or exceed the requirements for all or substantially all uses. Under the state water quality standards, the Cowlitz River in the project area as well as Lake Creek has an aquatic life use of core summer habitat and extraordinary primary contact recreation. In addition, the Cowlitz River in the project area is designated as requiring supplemental spawning and incubation temperature protection such that the 7-day average of the maximum daily temperature for this reach may not exceed 13 degrees Celsius ( C) between September 1 and May 15. Table 3-4 provides the water quality criteria for key parameters. Table 3-4. Water quality parameters. (Source: Energy Northwest, 2008a) Parameter Temperature Requirements For waters designated core summer habitat, the highest 7-day average of the daily maximum temperature (7-DADMax) cannot exceed 16 C. When a water body s temperature is warmer than the criteria and that condition is due to natural conditions (as is the case at both the tailrace and in lower Lake Creek downstream of the outlet structure), then human actions cumulatively may not cause an increase in the 7-DADMax more than 0.3 C. Incremental temperature increases must not exceed 28/(T+7) where T represents the background temperature. For waters designated by Washington Department of Ecology as requiring supplemental spawning and incubation temperature protection; the 7-DADMax for this reach may not exceed 13 C between September 1 and May 15. Studies conducted during the relicensing process showed that the water temperature at both the tailrace and in lower Lake Creek downstream of the outlet structure sometimes exceed the 7-DADMax water temperature standard of 16 C. However, water temperature modeling determined the pre-project 7-DADMax water temperature at the mouth of Lake Creek to be C (EES Consulting, 2007a). Given this modeled, natural temperature, and applying the criteria for temperature in the Washington water quality standards, the maximum allowable temperature for water delivered by the project to the Cowlitz River via the tailrace and lower Lake Creek is C (WAC A). This criterion applies to lower Lake Creek yearround and to the tailrace from May 16 to August 31. Because the 38

55 Parameter Requirements Cowlitz River (including water delivered to the Cowlitz River via the tailrace) requires supplemental spawning and incubation temperature protection, the 7-DADMax for this reach may not exceed 13 C between September 1 and May 15. Dissolved Oxygen Turbidity Lowest 1-Day Minimum 9.5 milligrams per liter (mg/l) 5 nephelometric turbidity units over background when background is < 50 nephelometric turbidity units; or a 10% increase in turbidity when background > 50 nephelometric turbidity units ph 6.5 to 8.5 Total dissolved gas Fecal coliform Not to exceed 110% saturation for flows up to the seven day 10 year flood. Geometric mean value of 50 colonies/100 milliliters and not have more than 10 percent of all samples obtained for calculating the geometric mean value exceeding 100 colonies/100 milliliters Geometric mean value of exceeding 100 colonies/100 milliliters Packwood Lake has been classified as an oligotrophic lake by the Washington Department of Ecology in Oligotrophic lakes are low in both nutrient content and algal production and are general very clear with high water quality and are normally cold and well-oxygenated. The Cowlitz River in the area of the project as well as Packwood Lake and Lake Creek are not listed as impaired under the 303(d) list in the Clean Water Act. As part of the license application project, Energy Northwest conducted a 2-year water quality study and investigated the effects of the project operation on water quality. Most of the parameters collected included temperature, dissolved oxygen, ph, and nutrients for Packwood Lake, Lake Creek and the project tailrace. Maximum hourly inflow temperatures measured in three tributaries to Packwood Lake, Osprey and Muller Creeks, and the main inflow source Upper Lake Creek, measured during the summer of 2004 and 2005 remained below 12 C. Temperatures monitored during the same period on Crawford Creek, another tributary to Packwood Lake, approached 16 C in 2004, but remained below 15 C in

56 At the start of the water temperature monitoring in April 2004 and April 2005, Packwood Lake was unstratified with a very weak thermocline. Temperature profile data collected by Energy Northwest showed that as the summer progressed, a weak stratification of approximately 1.0 C per 1 meter of depth developed as shown in figure 3-2. This figure also shows that prior to the October drawdown, the surface water had already started to cool and the upper 11 meters of the lake were homothermous. While temperatures during the summer in the upper levels of Packwood Lake are above the 16 C water quality standard, the water temperatures in Packwood Lake are largely due to natural conditions such as those that would have existed in pre-project conditions. Therefore water temperature standards in Packwood Lake are in compliance with the water temperature standards. Figure 3-2. Vertical temperature profiles for Packwood in the deepest area of the lake. (Source: Energy Northwest, 2008a) Also during 2004 and 2005, temperatures were monitored in Packwood Lake near the outlet, Lake Creek, the tailrace, Cowlitz River, and Snyder Creek. Tables 3-5 and 3-6 provide a summary of these temperatures. These tables show that the maximum hourly temperatures were normally below 20 C, except near the surface of Packwood Lake and in areas directly influenced by the warm surface water such as the tailrace. 40

57 Table 3-5. Water temperature monitoring data for (Source: Energy Northwest, 2008a) Hottest 7 Days (Range) 7-DAD Max ( C) Max Hourly Temp. ( C) # of days exceeding 16 C Monitoring Site Packwood Lake near the surface at the deepest point of the lake 8/16-8/ NA Packwood Lake near outlet 8/16-8/ NA Lake Creek below diversion structure 8/15-8/ Lake creek 1,500 feet downstream of the drop structure 8/15-8/ Lake Creek near mouth 8/11-8/ Powerhouse tailrace upper end 8/14-8/ Powerhouse tailrace lower end 8/15-8/ Cowlitz River tailrace side channel 8/15-8/ Cowlitz River upstream of Lake Creek 7/29-8/ Snyder Creek upstream of ancillary water inflow 8/11-8/ Snyder Creek at confluence with Hall Creek 8/11-8/

58 Table 3-6. Water temperature monitoring data for (Source: Energy Northwest, 2008a) Hottest 7 Days (Range) 42 7-DAD Max ( C) Max Hourly Temp. ( C) # of days exceeding 16 C Monitoring Site Packwood Lake near the surface at the deepest point of the lake 7/14-7/ Packwood Lake near outlet 7/13-7/ Lake Creek below diversion structure 8/15-8/ Lake creek 1,500 feet downstream of the drop structure 8/9-8/ Lake Creek near mouth 7/30-8/ Powerhouse tailrace upper end 8/4-8/ Powerhouse tailrace lower end 8/4-8/ Cowlitz River tailrace side channel 7/25-7/ NA Cowlitz River upstream of Lake Creek 7/25-7/ Snyder Creek at confluence with Hall Creek 8/4-8/ Note: The project was not generating on August 6 and 7 th resulting in no water flowing out of the powerhouse into the tailrace. Data in tables 3-5 and 3-6 show a decline in the water temperature in Lake Creek downstream of the intake structure and the confluence of Lake Creek with the Cowlitz River. Energy Northwest states that this decline in water temperature is due to riparian shade and cold groundwater inflow. However, for flows diverted from the intake structure to the powerhouse, the collected water temperature data showed minimal changes in temperature between the intake area of the lake and the powerhouse outflow. However during the summer of 2005 when the project was shut down periodically for several 1- to 3-day periods due to low inflow to the lake, the water temperature at the upper end of the tailrace, near the stilling basin increased up to 3.5 C (figure 3-3). However, much cooler water temperatures were recorded in the lower end of the tailrace which empties into a side channel of the Cowlitz River, and Energy Northwest states this was the result of night time cooling of the shallow water. Figure 3-4 shows comparisons of the water temperature at the lower end of the tailrace to the side channel of the Cowlitz

59 River. This figure shows that the outflow from the powerhouse is slightly colder than the Cowlitz River flow in the winter and 2 to 3 C warmer during the summer but is very close to the water temperature of Packwood Lake when the project is operating. Note: POWT1: upper end of the powerhouse tailrace POWT2: lower end of the powerhouse tailrace LCDS: Packwood Lake near the outlet Figure 3-3. Hourly discharge and water temperature at the intake, and tailrace during mid-july to mid-september (Source: Energy Northwest, 2008a) 43

60 Note: CRTSC = Cowlitz River side channel Figure 3-4. Water temperature in the end of the Packwood Project tailrace and the side channel of the Cowlitz River, October 2005 to October (Source: Energy Northwest, 2008a) Dissolved Oxygen Within Packwood Lake, lower dissolved oxygen (DO) levels were found in the lower levels of the water column but remained well above anoxic conditions with a low of 4.93 mg/l during September 2005 at the deepest part of the lake. DO values near the surface ranged from between 8.3 and 10.6 mg/l during summer DO was the only water quality criteria below the standards in lower Lake Creek with levels below the 9.5 mg/l criteria recorded at all sites during summer 2004 and only once near the confluence with the Cowlitz River in Levels in Lake Creek were generally higher in lower sections of the creek probably due to turbulent flow and the 44

61 accretion of colder groundwater. In the tailrace area, measured DO levels were below the criteria during the summer months during both 2004 and Other Parameters Turbidity levels in most tributaries to Packwood Lake are low except during periods of high inflow. The exception is Upper Lake Creek which carries a higher sediment load and has higher turbidity levels especially during snowmelt in the spring and glacial meltwater during the summer. In 2005, Secchi depth measurements at Packwood Lake ranged from 3 to 4 meters during the spring to more than 8 meters during the summer. Table 3-7 shows measured mean annual turbidity levels and ph values in lower Lake Creek, the tailrace, and the Cowlitz River. Other than the turbidity level measured immediately below the diversion structure in the April 2004 to March 2005 period, turbidity and ph levels were within acceptable levels based on the water quality standards. Energy Northwest also measured total dissolved gas in tailrace and within Packwood Lake near the intake. All levels were below the 110 percent standard. Table 3-7. Mean annual ph and turbidity levels. (Source: Energy Northwest, 2008a) ph Turbidity (NTU) ph Turbidity (NTU) April March 2005 April March 2006 Lake Creek below diversion structure Lake Creek near mouth Cowlitz River upstream of Lake Creek Upper end of the tailrace Lower end of the tailrace Cowlitz River side channel NTU = nephelometric turbidity units Fishery Resources Historically, the upper Cowlitz River Basin supported large numbers of spring and fall Chinook salmon (Oncorhynchus tshawytscha), coho salmon (O. kisutch), steelhead (O. mykiss), and sea-run cutthroat trout (O. clarki clarki) (NPPC, 2004). The completion of Mayfield, Mossyrock, and Barrier dams in the 1960s 18 (Cowlitz River Hydroelectric 18 Construction of the first dam on the Cowlitz River, Mayfield dam, began in 1955, but was not completed until Mossyrock dam was completed in 1968 and Barrier dam (associated with Cowlitz Salmon Hatchery) was completed in

62 Project, FERC No. 2016) blocked the upstream migration of anadromous fish into the Cowlitz River above river mile 49.5, and thus, into the project area located near river mile 129. Although efforts to trap and haul adult Chinook and coho salmon and steelhead upstream of these dams continued into the late-1970s. The efforts were eventually abandoned in favor of increased hatchery production at the Cowlitz Salmon Hatchery. 19 Following the completion of Cowlitz Falls dam in 1994 (at river mile 88.5), Tacoma Power, Bonneville Power Administration, Lewis County Public Utility District, and various resource agencies engaged in a comprehensive anadromous fish reintroduction effort upstream of Cowlitz Falls dam (NPCC, 2004). As a component of the Cowlitz River Hydroelectric Project Settlement Agreement, large numbers of Chinook and coho salmon and steelhead are trapped at the Barrier dam adjacent to Tacoma Power s Cowlitz Salmon Hatchery and hauled to three release sites in the upper Cowlitz River Basin: Lake Scanewa, the Cispus River, and the mainstem Cowlitz River at Packwood (Franklin Bridge). 20 As a result, Chinook and coho salmon and steelhead now have access to the upper Cowlitz River and its tributaries, including Lake, Hall, and Snyder creeks. Anadromous fish no longer have access to the project tailrace or stilling basin following construction of the tailrace barrier in October Chinook salmon currently found in the project vicinity (spring Chinook) enter the Cowlitz River from March through June (NPCC, 2004). Natural spawning occurs between late August and early October (table 3-8), with most spawning occurring in the mainstem upper Cowlitz River above the town of Packwood and in the Cispus River between Iron and East Canyon creeks (NPCC, 2004). Fry emerge from the gravel between November and March. Spring Chinook fry typically spend 1 full year in fresh water and migrate to the ocean in their second spring as age-2 smolts. Juvenile Chinook salmon are typically associated with low gradient, meandering, unconstrained stream reaches with abundant instream cover (e.g., accumulations of large wood and overhanging vegetation) (Healey, 1991). 19 Downstream migrant traps in the project reservoirs were found to be ineffective once the surface water temperature became warm (approximately 16 C) (FERC, 2001). 20 All downstream migrants are collected at the Cowlitz Falls Project fish passage facility and trucked downstream to holding ponds at the Cowlitz Salmon Hatchery, where they are eventually released volitionally into the lower Cowlitz River. 46

63 Adult coho salmon in the project vicinity (late run) enter the Cowlitz River from August through February and typically spawn from late November to March (table 3-8). Natural spawning occurs in the mainstem and tributaries of the upper Cowlitz, Cispus, and Tilton rivers (NPCC, 2004). Juveniles rear for a full year before migrating as yearlings in the spring. Juvenile coho salmon are frequently associated with side channels, wetlands, and off-channel sloughs (Sandercock, 1991). Other important habitat features include large wood accumulations, undercut banks, and complex pools. Adult steelhead found in the project vicinity (winter steelhead) enter the Cowlitz River from December through April (NPCC, 2004). Known spawning areas included the mainstem Cowlitz River near Riffe and the reach between the Muddy Fork and the Clear Fork and the lower Ohanapecosh River. Spawning time is generally March to June (table 3-8). Juveniles generally rear in fresh water for 2 years and then migrate to the ocean from April to May (NPCC, 2004). In general, juvenile steelhead prefer relatively small, fast flowing streams with a high proportion of riffles and pools and abundant instream cover (Barnhart, 1991). 47

64 48 Table 3-8. Lake Creek salmonid species periodicity. (Source: Energy Northwest, 2008a) Species Lifestage Oct Nov Dec Jan Feb Mar April May June July Aug Sept Spring Chinook Coho Steelhead Cutthroat Trout Rainbow Trout Key: Spawning Incubation Rearing Spawning Incubation Rearing Spawning Incubation Rearing Spawning Incubation Rearing Spawning Incubation Rearing Black indicates periods of heaviest use Grey indicates periods of moderate use Blank areas indicate periods of little or no use FERC PDF (Unofficial) 02/05/2009

65 The naturally produced Lower Columbia River Chinook and coho salmon and Lower Columbia River steelhead present in the upper Cowlitz River Basin are listed as threatened under the ESA (table 3-9) and are considered Forest Service Special Status Species. Lower Columbia River Chinook salmon and Lower Columbia River steelhead are also designated Washington state species of concern (candidate species). 21 Table 3-9. ESA-listed fish species in the Packwood Lake Hydroelectric Project area. (Source: Energy Northwest, 2008a) Evolutionary Significant Unit/DPS ESA Listing Status ESA Critical Habitat Lower Columbia River Chinook Salmon Lower Columbia River Coho Salmon Lower Columbia River Steelhead Threatened June 28, 2005 (70 FR37160) Threatened June 28, 2005 (70 FR37160) Threatened January 5, 2006 (71 FR 834) Designated September 2, 2005 (70 FR52630), with an effective date of January 2, 2006 Under development Designated September 2, 2005 (70 FR52630), with an effective date of January 2, 2006 In addition to Chinook and coho salmon, and steelhead, the waters in the project vicinity support resident and anadromous coastal cutthroat trout (O. clarki clarki), westslope cutthroat trout (O. clarki lewisi), resident rainbow trout (O. mykiss), Pacific lamprey (Lampetra tridentata), sculpin (Cottus sp.), mountain whitefish (Prosopium williamsoni), northern pikeminnow (Ptychocheilus oregonensis), bridgelip sucker (Catostomus columbianus), mountain sucker (Catostomus platyrhynchus), longnose dace (Rhinichthys cataractae), speckled dace (Rhinichthys osculus), and eastern brook trout (Salvelinus fontinalis). Energy Northwest completed numerous studies designed to describe the current distribution of resident and anadromous species within project-area waterbodies and to evaluate the quality and quantity of available habitat potentially affected by project operations. In the following sections, we describe the physical features, aquatic habitat, and aquatic biota in six project area waterbodies, including: Packwood Lake, Packwood 21 Includes fish and wildlife species that Washington Fish and Wildlife would review for possible listing as state endangered, threatened, or sensitive. See 49

66 Lake tributaries, lower Lake Creek (below Packwood Lake), Hall and Snyder creeks, tailrace slough (Cowlitz River Side Channel), and Cowlitz River (see figure 1-1). Packwood Lake Packwood Lake existed as a natural lake prior to the construction of the Packwood Lake Hydroelectric Project. The lake was formed when a large mass of soil and rock slid off Snyder Mountain and dammed Lake Creek approximately 1,100 years ago. Water enters Packwood Lake via several tributaries, including Osprey, Trap, Muller, Upper Lake, and Crawford creeks and exits the lake via the project powerhouse and lower Lake Creek. The normal surface area of Packwood Lake is 452 acres at elevation 2,857 feet msl. The current license requires that Packwood Lake be maintained at a constant elevation of approximately 2,857 feet msl plus or minus 6 inches during the May 1 through September 15 recreational season. During the remainder of the year, under the current license, the lake level may be lowered not more than 8 feet below the summer lake level down to an elevation of 2,849 feet msl (422 acre minimum surface area). Packwood Lake and its major tributaries currently support a self-sustaining population of native adfluvial 22 rainbow trout, the only species of fish ever documented to exist in Packwood Lake. Genetic comparisons of Packwood Lake rainbow trout with inland and coastal populations found that Packwood Lake rainbow trout are more closely related to inland populations. Although five distinct populations of nonindigenous rainbow trout were stocked in Packwood Lake from 1954 through 1965, no fish have been stocked in the lake since As part of the relicensing process, Energy Northwest conducted a 2-year evaluation of the fishery resources in Packwood Lake using gill net and fyke net sets (EES, 2007b). All sampling was conducted between July 2006 and July Nets were set in the lake near the mouth of Osprey Creek and at the upstream end of the lake between the mouths of Muller and Upper Lake creeks. A total of 111 rainbow trout were captured during sampling in 2006 and 2007, ranging in size from 4.3 to 11.0 inches in length. No other species were observed or captured during sampling in the lake. Energy Northwest also conducted two hydroacoustic fish population surveys in Packwood Lake in May and August of The first survey took place on May 23, 2007, prior to adult rainbow trout migration into the tributaries for spawning. The second survey was conducted on August 8, 2007, after the adult rainbow trout migrated back to the lake. There were 96 and 211 rainbow trout detected during the May and August 2007, hydroacoustic surveys, respectively. After extrapolating the transect data to encompass the entire lake volume, a total of 21,127 rainbow trout were estimated to 22 Adfluvial refers to a life cycle that depends on the lake environment for adult holding and foraging, and the tributaries for spawning and early rearing habitat. 50

67 inhabit Packwood Lake in May Once adult rainbow spawners had returned to the lake in mid-august and juvenile outmigration had begun, the estimated number of rainbow trout inhabitants increased to 31,278. The majority of these were found to occupy the transition and deep portions of Packwood Lake. Packwood Lake Tributaries Since 1980, large numbers of rainbow trout have been documented spawning in six tributaries to Packwood Lake (Osprey, Trap, Muller, Upper Lake Creek, Beaver Bill, and Southeast Trap creeks). The two tributaries that have consistently supported the most spawning are Muller and Upper Lake creeks. However, spawning activity within these tributaries varies significantly from year to year. A typical year would see rainbow trout migrating from Packwood Lake into the tributaries in May and June. Peak spawning would occur in mid-june and the spawners typically would return to the lake by early July at the latest. The fry outmigration period would extend from July through to the latter part of August. As part of the relicensing process, Energy Northwest conducted aquatic habitat and fish population surveys in seven of the principle tributaries to Packwood Lake (figure 3-5). Field investigations included underwater observations (snorkeling), electrofishing, spawning surveys, and out-migrant trapping. In 2007, 76 percent of rainbow trout spawning in the tributaries to Packwood Lake were observed in Muller Creek (table 3-10); although a substantial number of spawners was also observed in Crawford and Osprey creeks. The abundance of fry in the tributaries to Packwood Lake correlated with the proportion of rainbow trout spawners observed in each creek, and as expected, the tributaries with the higher average water temperatures (Crawford and Trap creeks), had the shortest incubation periods. 51

68 Figure 3-5. Packwood Lake tributary study sites. (Source: Energy Northwest, 2008a) Table Number of Redds % of Total Redds Number of Fish % of Total Fish The total number of rainbow trout and rainbow trout redds observed during the 2007 Packwood Lake tributaries spawning surveys. (Source: EES, 2007b) Upper Lake Creek Beaver Bill Creek Crawford Creek Muller Creek Trap Creek SE Trap Creek Osprey Creek , ,

69 Reach 5 of lower Lake Creek extends approximately 0.4 miles from river mile 4.9 to the project drop structure. Aquatic habitat in this relatively high gradient reach (8.4 percent slope) consists primarily of glides, cascades, and plunge pools separated by a series of natural falls and chutes occasionally blocking upstream fish migration. Rainbow trout were the only species observed in the section of lower Lake Creek below the drop structure. The reach has very limited salmonid spawning and rearing habitat, resulting in the production of very few fish. While reach 5 was found to contain the most large woody debris per mile in the wetted channel of any reach in lower Lake Creek, only 6 percent of the reach contained spawning gravels with 5 percent the gravels being located in the area immediately below the drop structure. Lake Creek Lake Creek flows in a northwest direction from Packwood Lake approximately 5.3 miles to its confluence with the upper Cowlitz River, at river mile It has a drainage area of about 7.3 square miles below Packwood Lake, which supplements the 3 cfs minimum flow released at the project s diversion site. 23 Accretion from runoff and groundwater occurs along the 5.4-mile-stretch between the project drop structure and the confluence of Lake Creek with the Cowlitz River. The Lake Creek drainage is mostly within the Gifford Pinchot National Forest, with the lowest 0.7 miles of Lake Creek on private lands. The gradient of lower Lake Creek is relatively high, averaging about 6.3 percent from the lake to its confluence with the Cowlitz River. Reach gradients range from a low of about 2 percent immediately upstream of the Cowlitz River to 20 percent in the canyon reach. During studies conducted in July, August, and September 2006, Energy Northwest used snorkeling and electrofishing techniques to document fish species distribution and abundance in lower Lake Creek. Twenty-six sites were sampled in five distinct reaches between the creek s mouth (river mile 0.0) and the drop structure (river mile 5.4) (figures 3-6 and 3-7). A habitat analysis was conducted at each site prior to sampling. In addition to these studies, Energy Northwest conducted a lower Lake Creek barrier analysis and a lower Lake Creek gravel transport and large woody debris study. Glides and runs were the dominant habitat types in reach 1 of Lake Creek, comprising 86 percent of the total habitat (table 3-11). Pool habitat was extremely limited in reach 1. Runs were the dominant habitat type in reaches 2 through 5, comprising more than 30 percent of the habitat. Fish encountered in lower Lake Creek included adult and juvenile rainbow trout, juvenile coho salmon, and sculpin. All three species had a preference for runs and glides followed by pools and plunge pools. All 23 The existing project license requires a minimum instream flow of 3 cfs at the drop structure immediately downstream of the outlet of Packwood Lake. The license also requires a flow of 15 cfs at the confluence of Lake Creek with the Cowlitz River. 53

70 coho were observed below the chute at river mile The highest densities of rainbow trout were observed in reaches 3 and 4. Relatively few rainbow trout were observed in reach 5. An analysis of the natural barriers in lower Lake Creek indicated that the chute at river mile 1.03 was an upstream barrier for Chinook and coho salmon, while the falls at river mile 1.95 was documented as the barrier for steelhead (EES, 2007c). Figure 3-6. Lower portion of Lake Creek (reaches 1 through 3). (Source: Energy Northwest, 2008a) 54

71 Figure 3-7. Lower portion of Lake Creek (reaches 4 and 5). (Source: Energy Northwest, 2008a) Table Habitat type percentages for the five reaches surveyed on lower Lake Creek. (Source: Energy Northwest, 2008a) Reach Pools Glides Runs Riffles HGR PP Falls Cascades Note: HGR are high gradient riffles and PP are plunge pools. 55

72 The primary source of instream wood in Lake Creek, downstream of the drop structure, is local trees falling into the creek by wind throw, tree mortality, and mass wasting. Wood and log jams are abundant upstream of approximately river mile 2.1, with 90 to 130 pieces of countable wood/mile (more than 12 inches in diameter and 25 feet long) in the combined wetted and bankfull channel in reaches 3, 4, and 5. There is less wood in the lower 2.1 miles of Lake Creek. In 2005, 35 countable pieces of wood/mile were inventoried in reach 2, and 15 pieces of wood/mile in reach 1. There are few local sources of future large wood in reaches 1 or 2. Inventories of spawning-sized gravel in lower Lake Creek between the drop structure and the confluence with the Cowlitz River found a total of 42,660 square feet of gravel, with the highest concentrations in reaches 2, 3, and 4. The majority of instream gravel was located behind large-scale roughness elements such as large boulders or large woody debris. One hypothesis for the fewer amounts of gravel downstream of river mile 0.8 is that the project has reduced the frequency of flows capable of transporting gravel, so gravel is being retained in upstream reaches near its source. Another hypothesis is that channel conditions that favor gravel retention (log jams, large woody debris, large boulders) are not as frequent downstream of river mile 0.8, so that much of the gravel transported from upstream reaches during high flows is not retained downstream of river mile 0.8. It also should be noted that Packwood Lake acts as a natural gravel sink, limiting downstream movement of gravel originating from Packwood Lake tributaries. In addition to the fish habitat and fish population surveys described above, Energy Northwest conducted 2 years of adult salmonid spawner surveys in lower Lake Creek from it mouth to the anadromous fish migration barrier at river mile Surveys were conducted on a twice monthly basis from July 2004 to July Over the 2-year period, a total of 86 salmon and 56 redds were observed in the study area. Eighty-three of the salmon were coho and three were Chinook. No carcasses were observed during any of the surveys. No adult steelhead were documented during the surveys; however, a single steelhead redd was observed in lower Lake Creek at about river mile 0.3. Peak coho spawning in Lake Creek occurs between November 1 and January 31. The two Chinook salmon were observed in Lake Creek in August, Snyder and Hall Creeks Snyder Creek, the small outlet stream for Snyder Lake, is approximately 1-mile long and passes through a culvert under the project tailrace canal near its confluence with the Hall Creek wetland area (figure 3-8). Hall Creek is somewhat larger than Snyder Creek and drains much of the area to the northeast of the project powerhouse between the 24 The chute at river mile 1.03 subsequently was determined to be an upstream barrier for Chinook and coho salmon, while the falls at river mile 1.95 was determined to be the barrier for steelhead. 56

73 Snyder Creek and Lake Creek drainages. Hall Creek flows southwest along the mountain front and eventually reaches Johnson Creek and the Cowlitz River about 3 miles from the powerhouse. In the vicinity of the project powerhouse, Hall Creek consists of a large wetland area. The project tailrace passes over this wetland area in an elevated 356-footlong flume. In August 2006, Energy Northwest surveyed Snyder Creek from the Packwood tailrace crossing upstream 0.8 miles to the barrier falls (figure 3-8). Two 197 feet study sites were surveyed below a large culvert under a Forest Service road located approximately 1,800 feet upstream of the mouth of Snyder Creek and two 60 meter study sites were surveyed upstream of the culvert. A total of 24 coho salmon, 58 westslope cutthroat, 3 lamprey, and 16 sculpin were captured during sampling at the two study sites. No coho juveniles were captured above study site 1 (figure 3-8). A majority of the cutthroat were captured at study site 2 immediately below the Forest Service road and culvert. Two 30 meter (98 feet) study sites were snorkeled in Hall Creek and a 30 meter study site was snorkeled in Johnstone Creek (a tributary to Hall Creek). All three study sites were upstream of the Snyder Road (FS Road 1260). Ten rainbow trout and 18 westslope cutthroat trout were observed in the plunge pool immediately upstream of the confluence of Hall Creek with Johnstone Creek. No other fish were observed in Hall Creek. A single juvenile rainbow trout and one sculpin were observed in Johnstone Creek, just upstream from the confluence with Hall Creek. In addition to the surveys described above, Energy Northwest conducted twice monthly spawning surveys in Snyder and Hall creeks. Snyder Creek was surveyed from its confluence with Hall Creek to river mile 0.36 from April 12, 2005 through July 26, No adult salmon, steelhead, or redds were observed during the surveys. However, juvenile coho salmon and cutthroat trout were seen in the reach. Hall Creek was surveyed from the Snyder Road crossing to river mile 3.70 from May 10, 2005 through July 26, A total of 34 coho adults and 10 redds were observed during the surveys. All coho salmon and redds were documented between December 29, 2005 and January 26, No Chinook salmon or steelhead trout were observed during the Snyder Creek surveys. 57

74 Figure 3-8. Study site locations in Snyder Creek. (Source: Energy Northwest, 2008a) The Snyder Creek culvert under the project tailrace as currently configured does not meet Washington Fish and Wildlife criteria for fish passage. The culvert can also become blocked with large amounts of sediment which settles out in the culvert, at the culvert outlet, or near the drain. The blockage of the culvert can prevent spawning coho and cutthroat from accessing documented spawning and rearing habitat that extends up about 1,900 feet from the tailrace crossing. If the Snyder Creek culvert becomes blocked with sediment prior to downstream migration, juvenile coho and cutthroat can become stranded in Snyder Creek. Tailrace Slough (Cowlitz River Side Channel) The project tailrace slough is the point where the project tailrace discharges into a highly dynamic side channel in the Cowlitz River. 25 During some years, the volume of 25 Habitat characteristics in the slough can change on an annual basis depending on high flows and the relative contribution of the river and tailrace. 58

75 water in the tailrace slough during low flow periods is largely dependent upon flow levels in the mainstem Cowlitz River; however, in other years, a greater percentage of the flow in the tailrace slough comes from the project than from the river. Under its current condition, the tailrace slough has been dependant on tailrace flows to provide adequate habitat (depth and velocity) for anadromous salmonid spawning and rearing at certain times of the year. Chinook and coho salmon, steelhead, sea-run cutthroat trout, rainbow trout, resident cutthroat trout and mountain whitefish are known to inhabit the tailrace sloughside channel of the river at various life stages. From July 26, 2004 through July 26, 2006, Energy Northwest conducted twice monthly spawning surveys in the tailrace slough. A total of 34 coho salmon and 57 redds were observed over the 2-year survey period. All but one of the 34 coho adults and all 57 redds were observed during the 2004/2005 season. No Chinook salmon or steelhead were observed during the study. All coho salmon spawning activity in the tailrace slough took place between November 11 and December 21, In addition to spawning surveys described above, Energy Northwest conducted four seasonal fish population and habitat use surveys in the tailrace slough from July 2006 through January Habitat use information was gathered by a combination of visual, electrofishing, and snorkeling surveys. Approximately 2,200 coho juveniles and 5 Chinook juveniles were observed during the four surveys. Cowlitz River The mainstem Cowlitz River is formed at the confluence of the Ohanapecosh River and the Muddy and Clear Forks of the Cowlitz River, at approximately river mile 132. Outlet flows from the project are returned to the Cowlitz River at river mile 125.2, about 4 miles downstream from the confluence with Lake Creek. Energy Northwest conducted adult salmonids spawner surveys in a 2,000 foot-long reach of the Cowlitz River immediately downstream of Lake Creek (left bank, looking downstream) and in a 2,000 foot-long reach of the mainstem, downstream from the confluence with the tailrace slough. No adult salmonids or redds were observed during these mainstem spawner surveys Environmental Effects Monitoring of Flows and Water Levels and Reporting Currently, Energy Northwest maintains records of the water level in Packwood Lake, minimum flows released to lower Lake Creek, and powerhouse flow records to ensure compliance with existing license conditions. Energy Northwest proposes to continue its current flow and water level measurement operations and install a streamflow 59

76 gaging station on lower Lake Creek at Lake Creek Road bridge with regular downloading of data and periodic reporting of all measurements. Various Forest Service conditions specify measurement of water levels within Packwood Lake and measurement of flows within Lake Creek for compliance with proposed instream flows and aquatic habitat forming flows. Our Analysis Current operation of water level measurement of Packwood Lake and releases to Lake Creek allows Energy Northwest to manage its facility for hydroelectric generation and document environmental compliance with terms of its existing license. The configuration of future flow and water level monitoring gages would depend on the operating conditions that may be specified in a new license. Energy Northwest has stated that infrastructure changes to the outlet structure would not be required to release and monitor the proposed higher minimum flows or to continue monitoring the water level within Packwood Lake. Prior to November 1977, USGS operated gage no along lower Lake Creek about 0.5 mile from the confluence with the Cowlitz River. The proposed location of the new gage is along Lake Creek Road about 0.2 mile downstream of the location of the former gage. A gage in this location would ensure compliance with higher flow releases such as those proposed for aquatic habitat forming flows. Consultation with USGS for the development of this gage site would help ensure future compliance with USGS standards for flow measurement, if appropriate. Consultation with FWS, NMFS, and other fishery related agencies also would be appropriate to ensure that any structures such as a weir associated with this gage would not hinder salmonid fish passage. A streamflow and lake water level monitoring program and reporting program for the project would provide documentation of compliance with flows and lake water levels required by a new license. Project-Influenced Water Temperature Under current project operations, water discharged from the project causes periodic violations of applicable water temperature standards in the project tailrace and in the Cowlitz River at the confluence of the tailrace from May 16 through August 31. It is probable that violations of the more restrictive water temperature criteria from September 1 through May 15 in the Cowlitz River near the confluence of the tailrace (not to exceed 13 C) also occur under current operations. Warm surface water is withdrawn from Packwood Lake at the outlet structure and is diverted to the Packwood powerhouse and exits through the project tailrace. In addition, warm surface water from Packwood Lake also is released from the outlet structure to Lake Creek. Studies conducted during the relicensing process showed that the water temperature at both the tailrace and in lower Lake Creek downstream of the outlet structure sometimes exceed the 7-DADMax of 60

77 19.39 C water temperature standard. During both years (2004 and 2005) of water temperature monitoring in the tailrace, high temperatures ranged from C to C, with a 7-DADMax of C, which would exceed the maximum allowable temperature by 0.07 C. Because the tailrace water is likely to exceed the temperature standard in August, Energy Northwest proposes to implement a water temperature monitoring plan in consultation with the Washington Department of Ecology. The monitoring plan would evaluate the effectiveness of project operations, including the timing of the annual outage, in meeting the applicable temperature standard at the confluence of the project tailrace with the Cowlitz River. Specifically, Energy Northwest would monitor water temperatures at seven sites in four areas: (1) the tailrace, (2) Lake Creek, (3) Packwood Lake, and (4) the Cowlitz River. Monitoring would take place on an annual basis between June 25 and October 5 for the first 10 years of the new license (or until modified by the Washington Department of Ecology). If monitoring indicates the tailrace temperature standard is not met, and Washington Department of Ecology determines that Energy Northwest has employed all known, available, and reasonable methods of prevention, control, and treatment, and the temperature criteria still has not been met at the end of 10 years of monitoring, Energy Northwest would consult with Washington Department of Ecology to determine the next appropriate steps to be taken. These may include designating a mixing zone, determining whether the continued project temperature excursions are economically and socially acceptable, doing temperature mitigation (such as shade tree plantings) upstream on the Cowlitz River, or ramping power usage, if all other reasonable, feasible measures have been tried or investigated. Our Analysis The major influence of the temperature of water released by the powerhouse into the tailrace is the temperature of the source water in Packwood Lake near the outlet structure. In addition, during project shutdowns the water in the tailrace and the tailrace slough can be subjected to additional increases in temperatures during the summer due to warming from ambient air temperatures. However, in October of 2007 a permanent fish barrier was installed which prevents fish from entering the tailrace, effectively limiting the effects of the water temperature on fish to only the tailrace slough. The effect of discharged water from the project to the tailrace slough is also dependant on the volume of water flowing through the slough from the Cowlitz River. During the summer, the flow of water from the normally cooler Cowlitz River through the tailrace slough is dependant on the location of the migrating side channel of the Cowlitz River. The side channel of the Cowlitz River which supplies water to the tailrace slough tends to migrate during high flow events due to the mobile riverbed materials. During some summers, the majority of the water supplied to the tailrace slough is from project discharge, but in other years, there is also substantially cooler Cowlitz River flow in this location. In the past, 61

78 Energy Northwest scheduled their annual project shutdown during the first three weeks of October. Energy Northwest has proposed to move the timing of the annual project shutdown to August 15, to avoid providing flows that would attract salmonids to the tailrace slough area during their spawning and to insure that adequate water is available in Packwood Lake to provide for the large proposed minimum flows to Lake Creek. Energy Northwest monitored water temperature in the tailrace at the lower end of the lined tailrace, immediately downstream of the powerhouse, and in the side channel of the Cowlitz River into which the tailrace discharges. When the project is operating, flow in the tailrace slough can be partially from the Cowlitz River and partially from the project tailrace or mostly from the tailrace discharge. The side channel geometry and the amount of river flow in this area can be dramatically altered by flood events. Energy Northwest s monitoring shows that when the project is operating, there is only a minimal change in water temperature between the intake at Packwood Lake and the powerhouse outflow (see tables 3-3 and 3-4) as measured in the tailrace. Table 3-12 shows general comparisons of the water temperature data measured near the Packwood Lake intake area and the tailrace. On average, daily maximum water temperatures were slightly warmer at the lower end of the tailrace, compared to the upper end. On a few days when generation did not occur for 1 to 3 day periods (see figure 3-3) because of low inflows to the lake, the temperature at the Packwood Lake outlet and the tailrace differed by as much as 0.3 C. Table Comparison of measured water temperatures in (Source: Energy Northwest, 2008a) Immediately downstream of powerhouse minus Packwood Lake at intake End of tailrace minus immediate downstream of powerhouse Max Daily Temp ( C) Mean Daily Temp ( C) Max Daily Temp ( C) Mean Daily Temp ( C) Mean Max Mean Max Mean Max Mean Max May June July August September Note: Data for July, August, and September include data from dates without generation. 62

79 The amount of flow in the Cowlitz side channel that the tailrace discharges into varies by year depending on flow supplied to this location from the Cowlitz River. In 2005, most of the flow in this side channel was from the Cowlitz River, unlike the prior year when the majority of the flow was from the project tailrace. Figure 3-3 shows that, during the summer of 2005, the temperature in the tailrace was directly reflective of the water temperature in Packwood Lake, with the exceptions during periods when water was not being discharged to the tailrace from the powerhouse. Figures 3-3 and 3-4 show that in general the flow in the tailrace is 2 to 3 C warmer than flow in the Cowlitz River during most of July and August. Conducting water temperature monitoring as Energy Northwest proposes would evaluate the effectiveness of project operations including the planned annual shutdown starting in mid August to meet the temperature standards at the confluence of the tailrace and the Cowlitz River. While previous temperature monitoring by Energy Northwest showed a general slight increase in the water temperature in the tailrace during project shutdowns in October, the proposed August shutdowns substantially would decrease the overall volume of warm water discharged to the tailrace. Monitoring water temperature also would provide information to determine the effects of the project discharge compared to the dynamic location and flow associated with the tailrace slough. Monitoring water temperatures in these areas and consultation with the Washington Department of Ecology would provide valuable information to allow for the potential development of additional measures to decrease the effects of the project discharges on water temperatures in the Cowlitz River. In addition, because Washington Department of Ecology water quality standards are designed to protect salmonid spawning, emergence, adult holding, and summer rearing these measures would to the extent possible minimize potential adverse effects on Chinook and coho salmon, steelhead, sea-run cutthroat trout, rainbow trout, and resident cutthroat trout. Tributary Headcutting Monitoring Lake level drawdown may affect the headcutting in tributaries that drain to Packwood Lake. These tributaries are important for reproduction and rearing of a native strain of uniquely adapted Packwood rainbow trout (Oncorhynchus mykiss). If high flows occur during drawdown, erosion and headcutting into the tributaries upstream of the lake bed may occur. If low flows occur during the drawdown period, tributaries may incise into the deltas and lake bed. Both these processes may result in fish passage issues and habitat reduction. The Forest Service specifies that Energy Northwest develop a Packwood Lake Tributary Monitoring Program after consultation with the Forest Service within 5 years of license issuance. It specifies that the monitoring program should focus on two tributaries to Packwood Lake Mueller and Upper Lake Creeks and that the initial monitoring program would occur at year 10 of the new license (2020) and reoccur every 10 years thereafter. The monitoring program should employ the same data collection methods as 63

80 implemented in the Stream Connectivity in Packwood Lake Tributaries Study Plan (Energy Northwest, 2005) as summarized below: A survey of each tributary channel would be made from elevation 2,846 feet msl upstream until a permanent grade control or geologic structure is encountered, or in the case of Upper Lake Creek and Muller Creek, 300 feet upstream of the point where field evidence indicates the channel is not incised. Prior to the survey on Upper Lake and Muller creeks, a reconnaissance-level walk of the low gradient portion of the creek would be made, noting any indicators of incision, to determine how far upstream the survey would extend. The channel survey would include a profile surveyed with a stadia rod, tape, and level to establish a profile of the thalweg, water surface, bankfull, floodplain, and terrace would be collected to provide information on channel incision. At each thalweg profile station, water depth and channel width would be measured to provide information on hydraulic characteristics. The width and depth to thalweg of the wetted channel, bankfull channel, top of bank, and any recent terraces also would be measured. At each thalweg profile station, dominant and sub-dominant substrate size would be noted to provide information on channel substrate composition. Photos would be taken of each tributary to document the drawdown zone and any channel incision features noted. An assessment of channel incision would be made based on a description of the following field indicators that may indicate channel incision at various stages of channel evolution. The survey information would be used to assess the potential problems related to fish passage through the stream channels in the area affected by the lake level. In addition, the survey would provide for analysis of the potential for lost instream and terrestrial habitat, loss of riparian vegetation, downstream flooding, channel widening, increased turbidity and suspended sediments, mid-channel bar formation due to increased sediment load, deceased bank stability, and loss of wetlands. 64

81 Our Analysis Packwood Lake is fed by at least seven fish-bearing tributaries including Upper Lake, Beaver Bill (a tributary of Upper Lake), Muller, Crawford, Trap, Osprey, and unnamed tributary southeast of Trap creeks, with the glacial-fed Upper Lake Creek supplying most of the lake inflow. The other tributaries are typically small spring-fed drainages (400 to 700 acres) that descend in steep mountain headwall channels but with the lower 0.25 to 0.75 river miles transition to a moderate gradient (< 4 percent) and are accessible to fish. These small streams have a bankfull width typically < 10 feet, and low flow at an estimated volume of 3 to 6 cfs. Abundant overhanging vegetation, fallen logs, and undercut banks provide plentiful hiding habitat. Operation of the project results in fluctuations of the lake levels. Currently from May 1 to September 15 lake levels are held at the license-requirement of 2,857 feet msl plus or minus 6 inches. Also under current conditions, after mid-september, the lake level may be drawn down 8 feet to a level no lower than 2,849 feet msl. During times when the lake is drawn down, tributaries entering the lake temporarily experience a lower water level and the flow in these tributaries can incise into the deltas and lake bed, potentially limiting fish passage. In addition during higher flows especially under low lake levels, erosion and headcutting in the tributaries upstream of the lakeshore may occur, limiting fish passage in the tributaries during all flows. Figure 3-9 provides a graph of the monthly lake levels and the estimated inflow to Packwood Lake including an example of high inflows during relatively low lake level elevations during January and February Conducting geomorphologic monitoring as specified by the Forest Service would evaluate the effects of the water level management of Packwood Lake on two key tributaries of Packwood Lake. Prior monitoring conducted by Energy Northwest showed that water level of Packwood Lake does have an effect on tributary headcutting; the monitoring specified by the Forest Service also would provide information to determine the effects of the water levels of Packwood Lake on the continued trout access to these key spawning tributaries after the possible issuance of a new license. 65

82 2, , Packwood Lake Level (feet msl) 2,858 2,856 2,854 2, Inflow (cfs). 2, ,848 Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Jan-07 minimum monthly level maximum monthly level Inflow to Packwood Lake (cfs) 0 Figure 3-9. Monthly lake levels and inflow from January 1999 to December (Source: Energy Northwest, 2008a, modified by staff) Packwood Lake Elevation Restriction The lake level fluctuations resulting from project operations can potentially affect the quality and quantity of littoral habitat within the lake that is used by juvenile and adult rainbow trout for feeding and cover, the migration of rainbow trout into their spawning tributaries (due to the creation of upstream migration barriers in the drawdown zone), and the migration of juvenile rainbow trout into Packwood Lake. These fluctuations may also influence water quality (discussed in section 3.3.1, Aquatic Resources), wetland vegetation and native amphibians (discussed in section 3.3.2, Terrestrial Resources), recreation (discussed in section 3.3.4, Recreational Resources), and project generation (discussed in section 4.0, Developmental Analysis). Energy Northwest proposes to slightly change the rule curve for the operation of Packwood Lake. Its proposed rule curve would retain the lake elevation of 2,856.5 feet msl from May 1 to September 15. The proposed rule curve would eliminate both the May 1 to September 15 lake elevation restriction of 2,857.5 feet msl and the maximum operating water surface elevation of 2,858.5 feet msl. Consistent with Energy Northwest s proposed rule curve, the Forest Service specifies and Washington Fish and Wildlife recommends that Energy Northwest maintain a minimum Packwood Lake elevation of 2,856.5 feet msl between May 1 and September 66

83 15 of each year and a minimum lake elevation of 2,849 feet msl between September 16 and April 30 of each year. In addition, the Forest Service specifies and Washington Fish and Wildlife recommends that Energy Northwest not decrease lake elevation by more than 1 foot per day. According to Energy Northwest, the Forest Service, and Washington Fish and Wildlife, the May 1 to September 15 lake level restriction would ensure tributary stream connectivity with Packwood Lake for adult rainbow trout spawning and fry outmigration; provide stable water levels for wetland and amphibian productivity (see section 3.3.2, Terrestrial Resources); keep recreational activity on the west shore of Packwood Lake at a minimum (see section 3.3.4, Recreation, Land Use, and Aesthetics); and maintain Packwood Lake elevations that reflect the natural hydrology (see section 3.3.1, Aquatic Resources). The September 16 to April 30 minimum winter water surface elevation is intended to provide sufficient water for increased instream flows into lower Lake Creek, for uninterrupted tailrace flows after the project maintenance outage and continuous flows for project generation. Our Analysis Packwood Lake supports a relatively large, genetically distinct population of adfluvial rainbow trout that spawns in the tributaries to Packwood Lake in May and June when streamflows and lake levels are at their highest stages of the year. The adult spawners typically return to the lake shortly after spawning, leaving the tributaries by early July. Following emergence from the gravel, the resulting rainbow trout fry move out of the tributaries and into Packwood Lake by late August. Because Energy Northwest s proposed rule curve would retain the existing lower lake elevation of 2,856.5 feet msl from May 1 to September 15 and commence the fall drawdown after mid- September, the proposed rule curve would likely have no effect on the migration of rainbow trout into or out of the tributaries to Packwood Lake. The proposed drawdown (beginning on September 16) would occur after both the rainbow trout spawning period (May through June) and the fry outmigration period (prior to the latter part of August). As a result, connectivity between Packwood Lake and the pertinent tributaries would remain intact. While seasonal water level fluctuations in lakes and reservoirs are known to adversely affect the quantity and quality (complexity) of littoral habitat, alter the production of benthic macroinvertebrates, and disrupt the growth of native aquatic vegetation, rainbow trout in Packwood Lake appear to move into deeper water as near surface water temperatures increase during the summer. Very few trout likely use the littoral zone of Packwood Lake in mid-september when the proposed drawdown would be initiated due to relatively high summer water temperatures in the lake s epilimnion (see section 3.3.1, Aquatic Resources). In addition, the relatively distinct population of 67

84 rainbow trout in Packwood Lake has remained self-sustaining and relatively large 26 under the existing project rule curve for decades, despite fairly intensive recreational harvest. The current abundance in Packwood Lake suggests that the population is at very low risk of extirpation and would likely remain robust under Energy Northwest s modified rule curve. Within the lake level range between elevation of 2,849 and 2,858.5 feet msl, Packwood Lake has about 450 acre-feet of storage per foot of drawdown. The maximum normal flow to the powerhouse is about 225 cfs, which for 1 day is a volume of about 445 acre-feet. Therefore, Energy Northwest is unable to drawdown Packwood Lake by more than about 1 foot per day even under unrealistically dry conditions of negligible inflow or inflows equal to flows released to lower Lake Creek. Therefore, the Forest Service specification and Washington Fish and Wildlife recommendation of a limit in the decrease of the lake elevation of 1 foot per day will be met by normal project operations. Annual Project Maintenance Outage (Tailrace Slough) The project tailrace canal discharges into a side channel of the Cowlitz River (tailrace slough). Tailrace slough is a highly dynamic side channel with frequently changing morphology as a result of flood events. During some years (e.g., 2005) flood flows in the Cowlitz River can reconfigure this side channel so that it derives most of its inflow from the mainstem Cowlitz River. When the slough is connected to the mainstem Cowlitz River, project flows have little effect on water levels in the slough. During other years, like the present configuration, the tailrace slough is not connected to the mainstem Cowlitz River and water levels in the slough are almost entirely dependent on project flows. In this condition, flows and water levels in the tailrace slough are strongly affected by water releases from project operations. Chinook and coho salmon and 27 steelhead are known to reside the tailrace slough at various life stages, and the amount of flow entering the tailrace slough (either from the project or the mainstem Cowlitz River) greatly affects the quality and quantity of available spawning, rearing, and incubation habitat for these species. Under existing project operations, a project shutdown associated with annual maintenance occurs in late September and potentially runs through the third week in October. During this period, generation ceases and water from the project is not added to the tailrace slough. This loss of flow has the potential to dewater salmon eggs previously deposited in redds and adversely affect the quality and quantity of available rearing 26 The current lake population is estimated at about 30,000 fish. 27 Energy Northwest documented both adult and juvenile coho salmon and juvenile Chinook salmon in the tailrace slough during studies conducted from 2005 to

85 habitat. The timing of this shutdown coincides with the latter portion of the Chinook salmon spawning period (when eggs have already been deposited in the gravel) and with the year-round coho salmon and steelhead rearing period. To minimize potential adverse effects on Chinook salmon spawning, Energy Northwest proposes to commence its annual maintenance shut down on August 15 of each operating year. Operations would resume by September 15, or earlier, if all the necessary work has been completed. Currently the lake is drawn down to 2,849 feet msl prior to the outage. To avoid potential impacts to the Packwood Lake environment, Energy Northwest does not propose a pre-outage drawdown. Prior to the annual project shutdown, Energy Northwest also proposes to inspect the Cowlitz River side channel that flows into the tailrace slough. If the side channel is dry, Energy Northwest would initiate a fish rescue within 12 hours of cessation of flows through the project tailrace and move any captured fish into the mainstem Cowlitz River. If there is flow through the side channel, no fish rescue would be required. Energy Northwest would also inspect and electrofish the section of tailrace upstream of the fish barrier within 12 hours of the project s annual maintenance outage and seine the project s stilling basin within 72 hours of the outage. The total number of each species captured during the fish rescues would be recorded in the field and the information would be provided to the aquatics resource panel in the annual report. Consistent with Energy Northwest s proposed annual maintenance schedule, the Forest Service specifies and Washington Fish and Wildlife and NMFS recommend that Energy Northwest perform its annual project equipment maintenance (outage) starting on August 15 of each year and eliminate the pre-outage lake drawdown. The intent of the outage period is to complete all major maintenance, inspections, and testing within one month (i.e. prior to September 15). NMFS also recommends that Energy Northwest conduct, within 2 years of license issuance, a risk analysis based on the frequency and duration of unplanned shutdowns and develop plans for maintaining flow to redds dependent on project flows and rescue of stranded fish. Our Analysis As described above, the tailrace slough is a highly dynamic side channel with frequently changing morphology as a result of flood events. During some years (e.g., 2005) flood flows in the Cowlitz River can reconfigure this side channel (tailrace slough) so that it derives most of its inflow from the mainstem Cowlitz River. When the slough is connected to the mainstem Cowlitz River, project flows have little effect on water levels in the slough. During other years, like the present configuration, the tailrace slough is not connected to the mainstem Cowlitz River and water levels in the slough are almost entirely dependent on project flows. In this condition, flows and water levels in the tailrace slough are strongly affected by water releases from project operations. 69

86 Chinook and coho salmon, 28 steelhead, sea-run cutthroat trout, rainbow trout, resident cutthroat trout, and mountain whitefish are known to reside the tailrace slough at various life stages, and the amount of flow entering the tailrace slough (either from the project or the mainstem Cowlitz River) greatly affects the quality and quantity of available spawning, rearing, and incubation habitat for these species. Energy Northwest has historically scheduled an annual project shutdown to perform equipment maintenance and inspection during the first three weeks of October. According to Energy Northwest, October was selected to minimize the economic impact of the outage, because it is typically a month with low inflows to the lake (see section ). In preparation for the outage, Packwood Lake is normally drawn down during the last two weeks in September. The resulting low lake level facilitates the work around the intake structure and minimizes the potential of an uncontrolled spill event down Lake Creek during the outage period. As part of its relicensing studies, Energy Northwest conducted aquatic habitat and fish population surveys in the tailrace slough and mainstem Cowlitz River and determined that an annual project shutdown in October has the potential to adversely affect incubating spring Chinook salmon eggs deposited in the tailrace slough. 29 According to Energy Northwest, the highest likelihood for loss of spawning habitat and dewatering of redds in the slough occurs between October and February. This directly coincides with Chinook and coho salmon spawning and incubation in the Cowlitz River. By beginning the outage on August 15, rather than the current outage timing, the project would avoid providing attraction flows that would draw adult Chinook and coho salmon into the tailrace slough to spawn. Outage in this earlier period would also help avoid the discharge of naturally warmed Packwood Lake water into the Cowlitz River, when summer temperatures are at their highest; and help ensure adequate water is available in Packwood Lake to provide the proposed minimum flows for Lake Creek. In addition, eliminating the pre-outage drawdown would help ensure the project maintain continuous operation from the end of the outage in mid-september through the end of October and minimize any potential drawdown-related adverse effects on the migration of juvenile rainbow trout from the Packwood Lake tributaries. Conducting fish rescues in the tailrace slough (when the Cowlitz River side channel is dry), tailrace, and stilling basin following the cessation of project operation would minimize potential impacts to fish residing in these areas including federally listed 28 Energy Northwest documented both adult and juvenile coho salmon and juvenile Chinook salmon in the tailrace slough during studies conducted from 2005 to If the tailrace slough is receiving inadequate flow from the Cowlitz River to support spawning and is entirely dependent on water from the project tailrace. 70

87 species. Following standard NMFS and Washington Fish and Wildlife fish capture and handling guidelines and releasing the captured fish into the Cowlitz River would likely result in higher survival rates for all species captured. While NMFS recommends Energy Northwest conduct a risk analysis based on frequency and duration of unplanned shutdowns and develop plans for maintaining flow to redds dependent on project flows and rescue of stranded fish, the objectives of this risk analysis are not clearly defined in the agency s section 10(j) rationale. As a result, it is difficult for staff to evaluate the potential value of such an analysis. Nevertheless, we conclude that providing NMFS with an annual record of the timing and duration of all planned and unplanned project shutdowns and the results of all associated fish salvage efforts should present NMFS with enough information to evaluate any potential adverse effect on ESA-listed species. Lower Lake Creek Stream Restoration and Enhancement Plan Prior to project construction in 1964, lower Lake Creek naturally drained all runoff that entered Packwood Lake. Under existing license conditions, the project diverts water out of Packwood Lake and returns the diverted flow to the Cowlitz River approximately 4 miles downstream from the mouth of Lake Creek. Energy Northwest currently releases a minimum of 3 cfs into lower Lake Creek to protect resident and anadromous fish and other aquatic species. There is also an instream flow requirement of 15 cfs at the confluence of Lake Creek with the Cowlitz River. While additional accretion from runoff occurs along the 5.4 mile stretch of Lake Creek between the project intake and the confluence with the Cowlitz River, the reduction in natural flows has reduced the depths and velocities of habitats available to resident and anadromous fish and benthic macroinvertebrates, thereby reducing the amount of available habitat. The project s constant 3 cfs minimum instream flow release also has altered seasonal and inter-annual hydrologic variation in lower Lake Creek (see section 3.3.1, Aquatic Resources). Altering the timing, frequency, magnitude, or duration of naturally occurring flow events can reduce habitat diversity, cause river channels to degrade and disconnect from floodplains, disrupt migration and spawning cues for fish, affect the breeding and dispersal of amphibians, and alter the survival and distribution of juvenile fish and macroinvertebrates (ISG 2000, NRC 1996, Richter et al. 1996). To enhance aquatic habitat in lower Lake Creek, Energy Northwest proposes to increase instream flows to the levels presented in table Energy Northwest also proposes to increase the amount and quality of anadromous fish spawning and rearing habitat in lower Lake Creek (river mile 0-1.0) through the installation of wood and boulder stream structures to provide for additional pools, gravel retention, and other beneficial habitat features; add gravel to these structures to immediately improve habitat; monitor these stream enhancement measures to verify improvements to habitat; and 71

88 supplement the stream structures with gravel recruitment stations to provide adequate movement of gravel into the anadromous reach. Table Month Proposed instream flows (cfs) for lower Lake Creek as measured at the drop structure. (Source: Energy Northwest, 2008a) January 4 February 4 March 4 April 7 May 15 June 10 July 15 August August 16-September September October 10 November 7 December 4 Instream Flow Release (cfs) Energy Northwest anticipates using an adaptive management approach to develop the plan, and expects that goals, objectives, and evaluation metrics would be developed and modified or amended as discussions continue with the stakeholders. NMFS recommends that Energy Northwest develop, after consultation with NMFS, FWS, the Forest Service, Washington Fish and Wildlife, Washington Department of Ecology, and the tribes a plan of increased flows (as prescribed in table 3-12) and habitat enhancement to address degradation and loss of anadromous fish rearing habitat in lower Lake Creek due to the effects of project operations. The Forest Service specifies and Washington Fish and Wildlife recommends that Energy Northwest implement the instream flow releases presented in table In addition, the Forest Service specifies and Washington Fish and Wildlife recommends that Energy Northwest verify and adjust flow readings (at the bypass pipe discharge point) to meet the minimum instream flow at least twice each day from the powerhouse control 72

89 room, make available instream flow data upon request, and provide an annual report of daily instream flow at the Annual Resource Coordination meeting. In addition to the instream flow releases described above, the Forest Service specifies and Washington Fish and Wildlife recommends that Energy Northwest prepare a lower Lake Creek stream restoration, enhancement, and monitoring plan for the anadromous reach of lower Lake Creek up to river mile 1.0. The plan would be prepared within 2 years of license issuance, in coordination and consultation with the Forest Service, FWS, NMFS, Washington Fish and Wildlife, Washington Department of Ecology, and the tribes, and would be approved by the Forest Service and the Commission. According to the Forest Service and Washington Fish and Wildlife, the primary goal of the plan would be to restore and enhance anadromous and resident salmonid habitat in lower Lake Creek by increasing rearing and spawning habitats. The lower Lake Creek stream restoration, enhancement, and monitoring plan would use the following objectives and design criteria as the basis for plan development. 30 Rearing Habitat Objectives: Increase the number of pools in lower Lake Creek to represent about 30 percent of the available stream habitat. Improve the rearing habitat found in the remaining runs and glides by about 15,300 square feet. Spawning Habitat Objectives: Increase the number of pool and pool tail-outs. Place gravel into the pool tail-outs of appropriate size for salmon and trout spawning. Increase spawning habitat in the reach by about 1,700 square feet (+/- 10 percent). Restoring Geomorphic Functionality: Shape the channel to ensure that the 1.5 year recurrence interval flows (285 cfs) fills the channel to its morphological bankfull stage. 30 If reach specific assessment data indicate adjustments that would maximize the primary objectives, the objectives and design criteria may be modified after consultation with the natural resource agencies and the tribes. 73

90 Restore channel complexity and roughness factors (e.g., boulders and large wood). Add bed material that can be partially mobilized at bankfull flow. Geomorphic Objectives, Design Elements, and Structural Criteria: Convert a degraded plane-bed/step-pool system into a wood forced step-pool system; construct pool-forming bedforms (steps) using boulder and wood complexes; and increase instream habitat cover and complexity. Convert current glide habitat into high quality pool habitat. Increase residual pool depths to increase habitat capacity during low flow periods. Increase available spawning habitat through gravel augmentation. In addition, the Forest Service specifies and Washington Fish and Wildlife recommends that Energy Northwest consult with both agencies, to develop effective monitoring elements, as needed, to track the status of resource objectives, employ the principle of adaptive management to modify the environmental measures, and meet resource-specific objectives and/or desired conditions. Energy Northwest would update and/or revise as needed the lower Lake Creek stream restoration, enhancement, and monitoring plan every 5 years. The initial 5-year update to the plan would be completed 10 years after issuance of any new license and would be filed in Our Analysis The lower 1.0 mile of lower Lake Creek are accessible to Chinook and coho salmon, steelhead/rainbow trout, and coastal cutthroat trout with an additional 0.9 miles accessible to steelhead (the anadromous zone). Under existing conditions, there is a general lack of high quality spawning and rearing habitat in the anadromous zone of lower Lake Creek. Stream surveys conducted as a part of project relicensing documented very few pools and a very low density of large woody debris in this reach. Whereas the upper reaches of lower Lake Creek contain as many as 90 to 130 pieces of wood per mile, the lower reaches contain fewer than 30 pieces per mile. As a result of past logging activities along reach 1 of lower Lake Creek, it is unlikely that large trees would be present near the stream banks to furnish large woody debris in the near future. In addition, the numerous channel constrictions and large boulders make it nearly impossible for wood to be transported very far in the stream. Gravel quantity is also severely limited in the lower reaches of Lake Creek as the lack of large woody debris (and other roughness elements) causes spawning-sized gravels to be flushed through the 74

91 system or stored on the channel margins where it rarely functions as suitable spawning habitat. This lack of spawning and rearing habitat likely limits the productivity and carrying capacity of lower Lake Creek, reducing the distribution and abundance of native fish populations. Energy Northwest, working in close association with the resource agencies, conducted an instream flow study in lower Lake Creek using the Physical Habitat Simulation Model (PHABSIM). PHABSIM incorporates data on river channel characteristics, flow, and fish life-stage suitability to assess the relationship between streamflow and habitat availability. Thirty-four transects in four study sites were selected for lower Lake Creek. The basic unit of fish habitat calculated by PHABSIM is weighted useable area. Weighted useable area can be interpreted in the context of stream hydrology and species life history to evaluate project effects and serve as the basis for determining alternative flow regimes. Together, Energy Northwest and the resource agencies used the information collected during this study to derive the proposed minimum streamflows listed in table Energy Northwest also modified some of the pool and glide/run study transects in lower Lake Creek to reflect general physical habitat changes that would be made to lower Lake Creek as part of its proposed habitat enhancement plan. These changes included: Increasing the residual pool depth of two transects each in reaches 1 and 2; Decreasing the wetted width and increasing the depth of run transects in reaches 1 and 2; Improving the cover components of the pools and runs to increase rearing habitat; Improving the substrate component of pool tailouts to reflect improved spawning habitat; and Adjusting the transect weighting in these reaches to reflect decreased run/glide and increased pool and pool tailout habitat. Energy Northwest then used PHABSIM to predict weighted useable area at the proposed instream flows (table 3-12) (including accretion) with enhancement for each of the analysis species (Chinook and coho salmon, steelhead, rainbow trout, and sea-run cutthroat trout) and life-stages of interest. These predicted enhancement weighted useable area values were then compared with weighted useable area values present under and current conditions. 75

92 Results of this modeling exercise indicate that for each analysis species, spawning and rearing habitat area would substantially increase with Energy Northwest s proposed flow regime and habitat enhancements when compared to existing conditions. In lower Lake Creek (from its mouth to the drop structure), enhanced spawning habitat area (weighted useable area) would be on average 473 percent greater than what is present under existing conditions, ranging from 264 percent for steelhead spawning to 4,713 percent for Chinook spawning (table 3-14). Enhanced rearing habitat area (weighted useable area) would average 155 percent of existing conditions, ranging from 104 percent for winter trout to 205 percent for rainbow trout (table 3-15). 76

93 77 Table Summary of spawning weighted useable area by month for lower Lake Creek (current conditions and proposed flows with enhancements). (Source: Energy Northwest, 2008a as modified by staff) Spawning Weighted Useable Area (sq feet/1,000 feet) a Month Treatment Chinook Coho Steelhead Cutthroat Rainbow Mean % Increase Jan Current Cond Proposed Feb Current Cond Proposed Mar Current Cond Proposed April Current Cond Proposed May Current Cond Proposed June Current Cond Proposed July Current Cond Proposed Aug Current Cond Proposed ,789 Sept Current Cond Proposed , FERC PDF (Unofficial) 02/05/2009

94 78 Spawning Weighted Useable Area (sq feet/1,000 feet) a Month Treatment Chinook Coho Steelhead Cutthroat Rainbow Mean % Increase Oct Current Cond Proposed Nov Current Cond Proposed Dec Current Cond Proposed Mean Current Cond Proposed Mean % Increase 4, , a Based on 50 percent exceedance values FERC PDF (Unofficial) 02/05/2009

95 79 Table Summary of rearing weighted useable area by month for all sites in lower Lake Creek (current conditions and proposed flows with enhancement). (Source: Energy Northwest, 2008a) Rearing weighted useable area (sq feet/1,000 feet) a Month Treatment Chinook Coho Steelhead Cutthroat Rainbow Winter Trout Mean % Increase Jan Current Cond. 5,085 3, ,630 5,040 - Proposed 7,754 5, ,679 6, Feb Current Cond. 5,062 3, ,830 5,123 - Proposed 7,718 5, ,589 6, Mar Current Cond. 4,938 3, ,148 5,245 - Proposed 7,466 5, ,679 6, April Current Cond. 4,974 3,609 3,472 2,530 3,582-3,633 - Proposed 7,680 5,511 5,163 4,131 5,557-5, May Current Cond. 4,727 3,886 3,094 2,407 3,326-3,488 - Proposed 7,908 5,049 5,434 4,569 5,746-5, June Current Cond. 4,592 4,018 2,902 2,340 3,187-3,408 - Proposed 7,537 5,933 4,835 4,095 5,521-5, July Current Cond. 3,904 4,415 2,170 2,018 2,497-3,001 - Proposed 7,491 6,068 4,708 4,179 5,489-5, Aug Current Cond. 3,158 4,601 1,686 1,746 1,995-2,637 - Proposed 6,907 6,916 4,181 3,877 5,162-5, Sept Current Cond. 2,938 4,641 1,540 1,649 1,842-2, FERC PDF (Unofficial) 02/05/2009

96 80 Rearing weighted useable area (sq feet/1,000 feet) a Month Treatment Chinook Coho Steelhead Cutthroat Rainbow Winter Trout Mean % Increase Proposed 7,550 5,997 4,723 4,285 5,498-5, Oct Current Cond. 2,938 4,641 1,540 1,649 1,842-2,522 - Proposed 5,857 7,380 3,522 3,421 4,523-4, Nov Current Cond. 4,116 4, ,092 5,524 - Proposed 6,534 6, ,771 7, Dec Current Cond. 4,938 3, ,148 5,245 - Proposed 7,466 5, ,590 7, Mean Current Cond. 4,281 4,030 2,343 2,048 2,610 7,170 3,747 - Proposed 7,322 6,018 4,652 4,079 5,357 7,461 5,815 - Mean % Increase a Based on 50 percent exceedance values FERC PDF (Unofficial) 02/05/2009

97 Results of the large woody debris study found that nearly all of the limited large woody debris in lower Lake Creek is derived from local sources rather than from wood transport. The proposed stream structures and associated gravel placement in the lower mile of Lake Creek would likely compensate for both the lack of large woody debris caused by forest management practices, and for the lack of overall habitat complexity resulting from nearly 50 years of altered flows in lower Lake Creek. The placement of gravel-retaining structures would also help the aquatic habitat forming flows (described below) form desired features, such as scour pools, while helping to retain needed spawning gravel. The instream flows released to lower Lake Creek have a temperature equal to the water temperature of Packwood Lake, which is relatively warm in the summer. During the warmer months, the current instream flow of 3 cfs of relatively warm water is lowered by accretion of colder water in the 5.3 mile reach of lower Lake Creek. Because the maximum water temperature under the proposed 20 cfs flow release would be about 1.6 C cooler than pre-project (natural) conditions, the increase in water temperature associated with the proposed minimum flows would not cause exceedance of the Washington Department of Ecology water quality standard of C for temperature (i.e., the Washington Department of Ecology water temperature criteria states when a water body s temperature is warmer than the criteria [in this case 7-DADMax of 16.0 C] and that condition is due to natural conditions, then human actions cumulatively may not cause an increase in the 7-DADMax more than 0.3 C) (see table 3-4). The C standard is the modeled water temperature at the mouth of Lake Creek under natural conditions (19.09 C) plus the allowable increase of 0.3 C (19.39 C). While the proposed 15 and 20 cfs instream flow water temperatures would occasionally exceed the preferred temperatures for Chinook, steelhead/rainbow trout, and cutthroat trout rearing (table 3-16); they are well below the upper lethal temperatures for these species (table 3-16). Moreover, rearing anadromous salmonids are known to seek areas of cold water refugia (i.e., groundwater inflow locations, cold water tributaries, and in some cases mainstem river reaches) when water temperatures begin approach the upper end of their preferred range. Cold water refugia would be present in the mainstem Cowlitz River throughout the summer rearing period and may also be present in lower Lake Creek in the form of groundwater inflow. These areas would be easily accessible to rearing Chinook, coho and steelhead/rainbow trout, and cutthroat trout under the proposed flow regime and would allow salmon and steelhead to minimize their exposure to temperatures that might adversely affect their survival. Although the warm water temperatures in August and September would likely continue to limit spring Chinook spawning success in lower Lake Creek (as they likely did during pre-project and existing conditions), they would have no effect on steelhead or coho spawning success as these species spawn primarily in the late fall, winter, and early spring (see table 3-8). Overall, the increases in habitat area associated with the proposed instream flows and habitat enhancements would outweigh any negatives related to these warmer water temperatures. 81

98 Table Preferred, upper lethal, and lower lethal water temperatures (in C) for Chinook and coho salmon, steelhead/rainbow trout, and cutthroat trout. (Source: Bell, 1990) Life History Preferred Stage Species Lower Lethal Lower Upper Upper Lethal Rearing Chinook Coho Steelhead/Rainbow Cutthroat Spawning Chinook Coho Steelhead/Rainbow Cutthroat Taken as a whole, implementation of the recommended minimum instream flows and habitat restoration measures in lower Lake Creek would likely substantially increase the amount and quality of habitat available to anadromous and resident fish on lower Lake Creek. These improved habitat conditions, in conjunction with ongoing basin-wide anadromous fish reintroduction efforts, would likely increase wild salmon and trout production in the project vicinity that would in turn contribute to the recovery of ESAlisted fish species. While these measures would likely increase the production of native fish species in the basin, we are concerned that the Forest Service and Washington Fish and Wildlife may have identified specific design criteria that may not necessarily reflect what could be reasonably achieved in lower Lake Creek. Revisiting and/or refining these target values to allow some flexibility may be more appropriate during the development of the final enhancement plan. Aquatic Habitat Forming Flows in Lower Lake Creek As discussed in the previous section, operation of the project reduces the frequency and magnitude of high flow events in lower Lake Creek when compared to pre-project conditions. This altered flow regime affects the natural sediment and small woody debris transport characteristics of the stream channel downstream of the drop structure, and in turn, affects the quality of aquatic and riparian habitat (i.e. reduces habitat complexity). While overtopping events do occur periodically at the drop structure, the absence of frequent bankfull events and their associated channel forming processes is evident, in part, in the lack of gravel and overall habitat complexity in the lower mile of Lake Creek. Aquatic habitat forming flows (periodic controlled high-flow releases) are often implemented at hydroelectric projects and other water diversions to restore or improve aquatic and riparian habitat. 82

99 Energy Northwest proposes to provide aquatic habitat forming flows in lower Lake Creek greater than or equal to 285 cfs for as long as lake inflows can sustain the flow, or a maximum of 24 hours, every other water year or 3 out of 6 water years, starting in the first water year after issuance of the new license and continuing for the life of the new license. Energy Northwest would take the necessary measures to control Packwood Lake elevation and power generation to ensure that aquatic habitat forming flows are achieved and maintained for up to 24 hours. If the desired frequencies of the aquatic habitat forming flows cannot be achieved, the agencies would be consulted for an alternate plan. Energy Northwest would monitor aquatic habitat forming flows at the drop structure and record the bypass flow and spill flow over the drop structure at appropriate time intervals. In addition, Energy Northwest would provide the agencies with an annual report on aquatic habitat forming flow attempts and activities including the magnitude, duration, and frequency of these flows and associated power generation throughout the past year, 30 days prior to the annual Resource Coordination meeting. Energy Northwest would allow a minimum of 60 days for the agencies to comment and to make recommendations prior to filing the final report with the Commission for approval. The Forest Service specifies and Washington Fish and Wildlife recommends the same aquatic habitat forming flows as those proposed by Energy Northwest. According to Energy Northwest, the Forest Service, and Washington Fish and Wildlife, the objective of aquatic habitat forming flows is to provide flows of sufficient magnitude, duration, and frequency to sustain habitat forming, and maintaining processes in lower Lake Creek during the operation and maintenance of the project. Some of these processes include the recruitment, mobilization, and deposition of sediment, wood and other organic material. Our Analysis Energy Northwest conducted several studies to evaluate the pre and post-project hydrology, channel morphology, and sediment and large woody debris transport regime in lower Lake Creek. Energy Northwest also evaluated appropriate habitat forming flows and the effects of project operations on aquatic habitat. Results of these studies indicate that peak flows in lower Lake Creek (near the mouth) are altered by operation of the project. Prior to project construction, median monthly flows as measured at the Packwood Lake outlet ranged from 48 cfs in October to 193 cfs in June and 65 percent of highest annual flows were between 200 and 500 cfs (table 3-3 and figure 3-10). During the post-project period, median monthly flows at the outlet ranged from 5 to 6 cfs and only 24 percent of the high flows were between 200 and 500 cfs. Flows greater than about 600 cfs appear to have a similar frequency during the pre- and post-project periods. 83

100 Figure Comparison of before and with project annual highest mean daily flow, Lake Creek near Packwood gage. (Source: Watershed Geodynamics, 2007a) The primary source of gravel to lower Lake Creek is from tributaries, landslides, and erosion in the watershed below Packwood Lake. These gravels are transported during higher flow events. Higher flow events also expose and redistribute stored gravels in the lower gradient reaches with wide floodplains. The relatively small amount of spawning gravel currently found in the lower mile of Lake Creek is likely the combined result of a lack of structure to hold gravel, few sediment sources downstream of the drop structure, and reduced transport from upstream reaches. Movement of painted rocks (large gravel) placed at gravel study sites throughout lower Lake Creek suggest that high flows (on the order of 250 to 300+ cfs) would be needed to mobilize the largest sized spawning gravels (3 to 4 inch diameter) across the entire channel width (Watershed Geodynamics, 2007). Lower flows would likely mobilize smaller gravels if they occurred in the middle of the channel, but the majority of gravel is stored on the channel margins or behind boulders/logs, and would require higher flows to be mobilized. If it is assumed that flows between 200 and 300 cfs would be necessary to move the full range of spawning-sized gravel, gravel transport would likely occur in 70 to 92 percent of the years if the project were not in place, and has occurred in 30 to 40 percent of the years since the project has been operational. 84