Department of Fish and Wildlife - · PDF filea bypass pipe to return fish to the ladder ... static head of 740 feet and ... upgrading thefish bypass screen to meet current ODFW fish

Department of Fish and Wildlife Umpqua Watershed District Office

4192 North Umpqua Highway Roseburg, OR 97470

(541) 440-3353 FAX (541) 673-0372 November, 14, 2013 Kimberly Bose, Secretary VIA ELECTRONIC FILING Federal Energy Regulatory Commission 888 First Street, NE Washington, D.C. 20426

Subject: Prospect 3 Hydroelectric Project (FERC 2337-076) Comments on Preliminary Application Document and Scoping Document; and Study Requests

Dear Secretary Bose:

The Oregon Department of Fish and Wildlife is filing the attached comments on the Preliminary Application Document, comments on the Scoping Document, and study requests in response to the Federal Energy Regulatory Commission’s Notice of Intent to File License Application, Filing of Pre-application Document (PAD), Commencement of Pre-filing Process, and Scoping: Request for Comments on the PAD and Scoping Document, and Identification of Issues and Study Requests, dated August 30, 2013 for the above reference project. Sincerely,

David A. Harris Southwest Hydropower Coordinator

Service List (P-308) C (electronic mail): Kristen Bonanno-USFS Ken Homolka-ODFW Salem Dan Van Dyke-ODFW Central Point Mark Vargas-ODFW Central Point Chris Stine- ODEQ Rob Burns- FWS Mary Grainey- OWRD

Oregon

John A. Kitzhaber, MD, Governor

1 Oregon Fish and Wildlife Comments and Study Requests (P-2337-076)

UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION

PacifiCorp Energy ) FERC Project 2337-076 ) Notice of Intent to File License Application, ) Filing of Pre-application Document (PAD), ) Commencement of Pre-filing Process, and ) Prospect 3 Scoping: Request for Comments on the PAD ) Hydroelectric Project and Scoping Document, and Identification ) of Issues and Study Requests

OREGON DEPARTMENT OF FISH AND WILDLIFE COMMENTS ON PRE-APPLICATION

DOCUMENT, COMMENTS ON SCOPING DOCUMENT 1, AND STUDY REQUESTS

INTRODUCTION

PacifiCorp Energy (“PacifiCorp” or “Applicant”) plans to file an application for a new license to

continue operating the Prospect No. 3 Hydroelectric Project (Project) FERC No P-2337, on the

South Fork Rogue River in Jackson County, Oregon. The current license will expire on

December 13, 2018. The Project has a generation capacity of 7,200 kilowatts (kW) and is

located on both private lands owned by PacifiCorp and federal lands managed by the Rogue

River-Siskiyou National Forest. The project consists of: (1) a 172-foot-long, 24-foot-high

concrete diversion dam with a 98-foot-long uncontrolled ogee on the South Fork Rogue River,

(2) a 1-acre impoundment at elevation 3,375 feet with a gross capacity of 10-acre-feet, (3) a fish

passage facility, including (a) an 86-foot long, 14-pool concrete ladder for upstream fish

passage over the diversion dam; and (b) a 0.25-inch wedge-wire, inclined-plane fish screen with

a surface area of 199 square feet located with the Project diversion facilities, which transitions to

a bypass pipe to return fish to the ladder and facilitate downstream passage: (4) a 15,894-foot-

long conduit system consisting of, in order, (a) 1 273-foot-long concrete-lined canal section; (b)

a 66-inch-diameter, 5,448-foot-long woodstave pipe; (c) a 5,805-foot-long concrete-lined canal


section; (d) a 5-foot-wide by 6.5-foot high, 698-foot-long, concrete-lined, horseshoe type tunnel;

(e) a 416-foot-long canal to penstock transition (i.e. forebay) with a 2,486-foot-long side channel

spillway; and (f) a 66-inch to 68-inch diameter, 3,254-foot-long, riveted steel penstock; (5) a

powerhouse containing one generating unit with a rated capacity of 7,200 kW operating under a

static head of 740 feet and producing an average annual energy output of 37,125 megawatt

hours (mW h); (6) a concrete tailrace structure approximately 20 feet by 20 feet by 5 feet with a

172-foot-long concrete lined overflow spillway; (7) a 66-inch, 887-foot-long woodstove siphon

that routes flows from the tailrace to the Middle Fork Canal of the Prospect Nos. 1,2 and 4

Project (FERC No. P-2630): and (8) a 6.97-mile-long, 69-kilovolt (kV) transmission line that

connects to Prospect Central substation.

The Oregon Department of Fish and Wildlife (ODFW) exercises statutory oversight and

possesses management expertise regarding the natural resources in the Rogue River Basin

that may be affected by this relicensing. ODFW is extensively involved in a variety of fish and

wildlife management issues in the Rogue watershed, including big game management, fish and

fishery management, and nongame protection at hydroelectric projects.

The Applicant filed its Notice of Intent to File License Application for a New License

and Commencing Pre-filing Process on August 30, 2013.

Staff from ODFW attended the Project site visit held on September 24, 2013 and the

Commission’s Daytime Scoping Meeting held on September 24, 2013 in Medford, Oregon.


COMMENTS ON PRE-APPLICATION DOCUMENT

The Pre-Application Document (PAD) provides the basic information that is relevant to the

Project proposal that is currently available, and it will assist ODFW to identify issues and

additional information needs. ODFW’s main interest in Project relicensing is to ensure that any

ongoing impacts are identified and mitigated, new impacts are avoided, and to ensure the

Project is consistent with Oregon’s Wildlife Policy (ORS496.012) and other statutes, rules,

guidelines, and plans.

Section 2.4 explains that the project is not operated with any specific daily or seasonal ramping

rates. ODFW believes it is important to understand the frequency and magnitude of ramping in

the tailrace and bypass reach from planned and unplanned project shutdowns. The frequency of

past shutdown events should be readily available for analysis. Information on the magnitude of

current ramping will need to be collected during relicensing when maintenance shutdowns or

other events are initiated. This information will assist in evaluating the effects of current project

operations on trout spawning, incubation, and rearing.

Section 2.5 describes the Project operations and existing license. Generating unit trips or

operational balancing infrequently (approximately 5 times per year) results in Project waters

discharging to the Middle Fork Rogue via the forebay spillway and tailrace overflow channel,

respectively. ODFW believes it is important to determine the month(s) these water discharges

are occurring. Information will assist in the evaluation of impacts (ramping and turbidity) to

spawning native trout in the Middle Fork Rogue below Daniel Creek. Egg incubation, fry

emergence and fry stranding all may be impacted by these events.


Section 2.6 The Applicant indicates in Section 2.6 that it is not planning to install new

facilities or implement capital upgrades; however, based on ODFW’s observations during

the scoping site visit it is likely that some fish and wildlife facilities will need to be modified or

replaced; such as: (1) upgrading the fish ladder to meet current upstream passage criteria,

(2) upgrading the fish bypass screen to meet current ODFW fish screening criteria, and 3)

widening the existing big game crossings.

Section 3.3.1 is a summary of the available habitat information from 1986. The summary states

that the 3.5 miles of the South Fork immediately below the dam represents the portion of the

bypass reach directly influenced by project operations. Of course, project influence is not

limited to the first 3.5 miles below the facility, and likely extends to the confluence with the North

Fork Rogue. ODFW feels that the distance analyzed in the current relicensing effort should at a

minimum include 6.3 miles (diversion dam downstream to the confluence of the Middle Fork of

Rogue River. Field work should confirm that accretion rates have not changed in amount per

month since the 1986 study.

ODFW agrees that there is minimal habitat data available between River Mile (RM) zero to RM

7.5. Ideally physical habitat data should be collected all the way to the mouth in order to fully

assess the potential native trout population. Native trout in the South Fork Rogue River are

migratory and must make lengthy instream movements in order to fulfill life history phases. This

additional information will be necessary to evaluate instream minimum flows that provide both

protection and enhancement.

This section refers to barriers to fish passage in the 3.5 miles below the dam, but ODFW has

records of anadromous fish in the vicinity of the projects (see below). It is important to note that


while debris jams and boulders reported in the habitat survey create jumps, they rarely create

barriers to fish migration because of gaps and even movement over time. In addition, the

habitat survey conducted in 1986 was conducted when flows below the dam were

approximately 4 cfs (see graph below). Flows this August were 13 cfs, and ambient flows even

in August would be around 100 cfs upstream of the project (according to the 1986 report). High

flows mean higher water levels and reduced jump heights. Fish passage should be expected

through this area.

ODFW agrees with FERC’s request for PacifiCorp to conduct a fish and aquatic habitat

survey; however, we disagree that the survey should only be conducted in the upper 3.5

miles of the bypass reach. ODFW recommends that the fish and aquatic habitat survey

cover a total of at least the upper 6.3 miles of the bypass reach, and as part of this

survey accretion rates be assessed.

Section 3.3.2 the PAD refers to a statement from a watershed analysis in stating that the

project area is outside the historic range of anadromous fish species. The “geologic landform

barriers near Prospect” actually refers to the Avenue of the Boulders, which is believed to have

blocked anadromous fish from entering the mainstem (or North Fork) of the Rogue River. The

South and Middle Forks are known to have been used by anadromous species.


The dam on the South Fork was built around 1932. Unfortunately the first biological

observations were not made until roughly ten years later. In his report “History and

Development of the Rogue River Basin as Related to its Fishery Prior to 1941”, Cole Rivers

(1963) wrote of the then Copco dams: “Occasionally there are a few steelhead found at the

base of the dams on the south and middle forks.”

ODFW observed large numbers of spawning spring chinook using the South Fork of the Rogue

River in October 1965. A total of 997 chinook and 420 redds were observed from the mouth of

the South Fork up to the confluence with the Middle Fork Rogue River. In October 1969, ODFW

observed 13 spring chinook and 8 redds on the Middle Fork under the Prospect-Butte Falls

Road Bridge. So while William Jess Dam (Lost Creek Reservoir) does block anadromous fish

today, ODFW emphasizes that historically this area supported a variety of native migratory fish

species. The presence of Chinook salmon implies that all other anadromous fish in the Rogue

could have been present historically.

Section 3.3.3 is a summary of the available information for the fish community in the Project

area. ODFW believes that native migratory fish species, primarily wild rainbow trout and

potentially cutthroat trout, migrate out of Lost Creek Reservoir and enter the lower South Fork

Rogue and the South Fork bypass reach, and must be able to pass the dam and diversion to

use habitat upstream of the project.

The Applicant states that since a 1986 study on downstream entrainment, considerable

improvements and updates to fish passage and screen facilities have been completed and

tested, so 1986 passage and entrainment figures are no longer applicable. ODFW agrees that

fish passage conditions were improved during the last relicensing, but believes it is important for


the Applicant to conduct an analysis of the design and operation of these facilities during this

relicensing to determine whether they meet current fish passage criteria, or can be upgraded to

meet current criteria.

The Applicant indicates that suitable spawning area in the bypass reach may be an important

limiting factor to rainbow trout population. The PAD states that immigrant additions to the

population from downstream rainbow trout communities are precluded by a number of natural

passage barriers in the bypass reach preventing additions to the population by upstream

movement. ODFW disagrees with this statement, and is not aware of any evidence that

confirms that the fish are blocked by the reported barriers listed in the 1986 study. As stated

above, anadromous fish were known historically in the project area. Flow reduction below the

project likely makes passage more difficult, but fish passage should be expected.

ODFW agrees with the Applicant that native trout in South Fork Rogue River are migratory and

need to safe upstream passage in order to reach suitable spawning areas. Based on

observations during the Scoping site visit ODFW is concerned that hydraulic conditions in the

fish ladder blocks, partially blocks, or delays upstream passage for trout. Also fish produced

above the South Fork Diversion dam, particularly young of the year, which migrate downstream

to contribute to the population, may be injured at the screen facility and at the exit pool of the

bypass pipe.

Section 3.3.5 describes that an environmental minimum flow of 10 cfs was established in the

last relicensing pursuant to License Article 402. Current minimum flows address juvenile fry in

the bypass reach. ODFW believes that fry survival in the bypass reach, although is important, is

not as critical as juvenile to adult survival. Juvenile to adult survival rate is higher than the fry to


adult survival rate. Fry production above the diversion dam will continue to produce fry that can

“seed” downstream bypass habitats, and improving the fish screen will likely provide a more

balanced benefit than focusing the bypass flow to increase fry habitat.

Section 4.1.2.1 ODFW believes that new information has been collected since the 1986

relicensing that will affect the results of the instream flow study. The Applicant should

incorporate updated habitat suitability criteria (HSC) to estimate weighted useable area at

various stream flows. ODFW recommends that the 1986 data be analyzed using the same HSC

used on the Prospect 1, 2, & 4 project. ODFW recommends that the Applicant provide

electronic files of the original 1986 instream flow data to the agencies and collaborate in

rerunning the flow analysis using the more recent HSC.

Section 4.1.3 ODFW agrees with the Applicant that the previous instream flow study was

coarse and supports an updated model to re-examine usable fish habitats at various life stages.

ODFW also believes that both upstream and downstream fish passage is outdated and needs to

be studied to determine suitable upgrades.

Section 4.1.4 ODFW believes that current wildlife crossings should be widened. Although

information suggest both small and big game animals are using the crossings, added width

ensures safe timely passage of herd animals that stack up and are forced to cross single file.

Section 4.1.6 ODFW with aid from federal agencies has radio collared several wolves in the

state of Oregon. Migration routes and locations of one particular wolf have been documented in

the South fork Rogue basin and Project area. ODFW believes that wolves should be added to

the survey and manage list.


Section 4.2.3 ODFW agrees with the Applicant’s proposed study to conduct a fine-scale habitat

duration analysis on existing habitat flow relationships for native trout in the South Fork bypass

reach, and ODFW recommends that the Applicant collaborate with the agencies to re-analyze

the existing 1986 instream flow data using updated HSC. ODFW also suggests re-examination

of the design and hydraulics of the fish ladder and screen facilities and development of a plan to

ensure they meet current ODFW fish passage criteria. The Applicant should consider ramping

study to assess impacts.

Section 4.3.1 ODFW has filed its Wolf Management Plan with the Commission to have it

considered as a comprehensive plan pursuant to Section 10(a)(2)(A) of the Federal Power Act

(FPA). We believe the Wolf Management Plan would be applicable to the Project area.

Appendix A: ODFW recommends that the siphon be considered a “feature” of the Prospect 3

project because in the event of a catastrophic failure of the loss of the siphon the loss of water

could damage the hillside under the powerhouse, and in the event of such a failure the project

should not be allowed to restart without a thorough evaluation of the environmental damage to

the Middle Fork Rogue River.

COMMENTS ON SCOPING DOCUMENT 1

Section 4.2.1 proposes to address effects of project operations and maintenance on soil

erosion. ODFW recommends that this section include analysis of the effects of penstock

failures, unit trips and maintenance outages on Daniels Creek and the Middle Fork Rogue River;

and the timing of forebay maintenance sluicing. ODFW has collected information from statewide


trout surveys that show erosion and fine sediment has a negative association with trout

presence.

ODFW recommends that the siphon be considered a “feature” of the Prospect 3 project

because in the event of a catastrophic failure of the loss of the siphon the loss of water could

damage the hillside under the powerhouse, and in the event of such a failure the project should

not be allowed to restart without a thorough evaluation of the environmental damage to the

Middle Fork Rogue River.

Section 4.2.3 proposes to address effects of minimum flow releases, Project effects on

upstream and downstream fish passage, and flow fluctuations in the bypassed reaches and

Daniel Creek. ODFW suggests that PacifiCorp re-analysis the existing 1986 instream flow data

using the same HSC used on the Prospect 1, 2, & 4 project. ODFW requests a copy of the

existing 1986 instream flow data in electronic format and will collaborate with the Applicant in

order to run flow analysis using the updated HSC. Effects on upstream passage should

include fish ladder entrance jump heights and attraction flows, in-ladder flows (including the fish

bypass pipe flow into the ladder), in-ladder jump heights, and flow though the submerged orifice

at the ladder exit. Downstream passage should include screen size, approach and sweeping

velocities, screen maintenance (cleaning), and bypass pipe flows.

Section 4.2.4 proposes to address effects of deer and elk movement and maintenance

activities. ODFW recommends that any analysis of the width of animal crossings be examined.

Other animal crossings in the Umpqua and Rogue watersheds have been increased in width to

accommodate “herd” animals. ODFW would also recommend that all transmission lines on the

Project be analyzed for risk of electrocution by avian species.


STUDY REQUEST

ODFW’s study requests are formatted to follow the requirements of 18 CFR Section 5.9(b)

1. Ramping

Recommended Study and Basis for Request ODFW recommends that PacifiCorp perform ramping studies in Project bypass reaches to

determine rates necessary to protect fish and aquatic resources from adverse effects resulting

from upramping and downramping.

Sudden flow changes in stream reaches due to Project operations can adversely impact fish

and aquatic resources. Significant rapid flow reduction in bypass reaches can affect fish

populations by dewatering redds and stranding fry or juvenile fish. Rapid flow increases in

bypass reaches can wash out existing redds, displace fry, displace macroinvertebrates, or

adversely impact amphibian populations in these reaches. One very significant ramping event

at a very unusual time can cause a significant limiting condition for one or more age classes of

fish, or a section of habitat to be impacted for a long period. The current FERC license does not

include conditions requiring PacifiCorp to apply specific ramping rates to operations.

ODFW believes that in order to form an adequate factual basis for complete analysis of the

application, information needed to achieve the study objectives must be included. For these

reasons, a ramp rate study at the South Fork Dam should be conducted.

Study Participants ODFW does not take a position on who should conduct the study. We are confident that

PacifiCorp can conduct the work in-house, though they may prefer to contract with a reputable


consultant. PacifiCorp needs to consult with the resource agencies during development of

study designs and analysis of data collected.

Study Methods and Objectives All the information below will need to be collected for the reach below the South Fork Dam.

1) Magnitude of ramping event (inches/hr);

2) Duration the event occurred (time in minutes);

3) Frequency of events (completed by reviewing production log books)*;

4) Ramp rate as measured on staff gages (nearest 0.01 inches);

5) Ramp rate estimates for maintenance activities (planned outages) based on mechanical

constraints.

ODFW recommends employing the methods proposed and implemented for relicensing studies

on the Prospect 1, 2, & 4 project. Use the same methods used at the Middle Fork and Red

Blanket bypass reaches) to obtain the information.

Study Objectives All objectives need to be achieved for the reach below the South Fork Dam.

1) Document the frequency and duration of scheduled and unscheduled ramping events*;

2) Categorize ramping events by month or hydrologically similar periods*;

3) Document magnitude and rate of ramping using current operational procedures*;

4) Assess the level of control Project works can impart on ramp rate measured at sites where

effects of changing flows on aquatic resources would be pronounced; and,

5) Determine the physical capabilities of the Project structures in controlling ramp rates.


How the Study will be useful in Furthering ODFW Resource Management Goals ODFW’s request is to ensure proposed studies are completed, that PacifiCorp collects all the

information that they have proposed, and that the information is made available for analysis.

ODFW will use the study results to assess the aquatic impacts of project ramping. This

information will also serve as the evidentiary basis to support recommendations for project

ramping rates that will avoid or minimize impacts to aquatic organisms.

ODFW’s overarching goal is to prevent or minimize project-caused flow fluctuations to protect

fish, wildlife, and other aquatic resources. The study results will further ODFW’s resource

management goals by providing information regarding the effect of the project on aquatic habitat

in the upper Rogue and what kinds and levels of mitigation measures would be most

appropriate to include in the new license to support protection and restoration of aquatic

organisms and their habitat.

Time Required for Study PacifiCorp should be able to conduct the field data collection as proposed for the areas below

the South Fork Dam with several weeks of effort. Field data collection should occur when spill

over the dam is minimal, but diversion into the South Fork power canal is near capacity.

Several weeks of effort will be needed to 1) collect records from log books to document the

frequency and duration of scheduled and unscheduled ramping events, 2) categorize ramping

events by month or hydrologically similar time periods, and 3) organize and analyze the data.

Existing Information and the Need for Additional Information PacifiCorp has conducted the field phase of a ramp rate study for bypass reaches below the

Middle Fork and Red Blanket Diversions, and the South Fork bypass below the confluence with


the Middle Fork as related to operation of the Prospect 1, 2, and 4 project, but areas affected by

the Prospect 3 project have not been assessed.

Additional information is needed to:

1) Document the frequency and duration of scheduled and unscheduled ramping events for the

bypass reach.

2) Categorize ramping events by month or hydrologically similar periods for all of the bypass

reach.

3) Document magnitude and rate of ramping using current operational procedures for all

bypass reach.

4) Assess the level of control Project works can impart on ramp rate measured at sites where

the effects of changing flows on aquatic resources would be pronounced in the South Fork

reach.

5) Determine the physical capabilities of the Project structures in controlling ramp rates in the

North Fork reach.

2. Wildlife Connectivity

Recommended Study and Basis for Request ODFW recommends that studies be conducted to determine the movements of animals in the

vicinity of Project facilities, entrapment into canals, and evaluation of the existing wildlife

crossings to determine whether the Project adversely impacts habitat connectivity for big game

and small animals. ODFW is interested in determining the effects of the existing canals on the

small vertebrates. While the fencing that surrounds the canals probably protects large

mammals from becoming entrapped, small animals are probably able to pass through the fence

mesh and become vulnerable to entrapment. Seasonal movements of reptiles and amphibians


are a well-documented aspect of their life history. The canals could represent an important

cause of mortality or block dispersion and genetic flow for some species. ODFW feels that the

current wildlife crossings are probably too narrow to provide adequate passage for big game

and may not be strategically located. ODFW recommends the use of the crossings by wildlife

be quantified and documented by monitoring with video cameras. In addition, PacifiCorp has

proposed a major maintenance event by replacing the wood stave flowline. Wildlife “underpass”

locations should be identified and implemented during replacement to ensure wildlife

connectivity.

The information gained from this study is essential for assessing wildlife connectivity in the

Project area and determining whether adverse impacts are occurring. ODFW’s basis for

obtaining this information is to assist in identifying project impacts on wildlife populations,

determine whether the project is consistent with ODFW’s resource goals, and provide

evidentiary fact for recommending measures for protection, mitigation, and enhancement.



wildlife consultant. PacifiCorp needs to consult with the resource agencies during development

of study designs and analysis of data collected.

Study Methods and Objectives Study methods should follow those described in Corn and Bury (1990). ODFW, other agencies,

and researchers have employed video cameras, still cameras, radio telemetry, and capture and

release methodology to monitor animal movements and behavior. Remote sensing with video


cameras can be used with bait stations to observe pine marten and fisher. Video cameras can

be used to record animal behavior at canal crossings. Radio telemetry and

capture/release/observation methods can be used to assess habitat connectivity, the avoidance

of canals to crossing, and an animal’s ability to cross canals to other Project features.

The objective of the study would be to provide information on the movements of large and small

animals near Project canals, to estimate the extent of entrainment mortality, and to determine

the efficiency of the existing canal crossings.

How the Study will be useful in Furthering ODFW Resource Management Goals Study information would be used to determine if the movements of small and large animals are

being restricted by Project facilities and whether project facilities or operations have affected

habitat conditions or connectivity. ODFW’s overarching goal for relicensing the Project is to

maintain terrestrial habitat connectivity so that dispersal, migration, and interbreeding among

subpopulations can occur and to create a waterway system that has insignificant effects on

populations. The study will further ODFW’s resource management goals by providing

information regarding the effect of the project on wildlife populations in the upper Rogue and

help to identify what kinds and levels of mitigation measures would be most appropriate to

include in the new license to support protection and restoration of wildlife populations.

ODFW’s goals and objectives for the fish and wildlife populations in the upper Rogue River

basin are found in the following statutes (ORS) and rules (OAR)

• Wildlife Policy (ORS 496.012) Establishes wildlife management policy to prevent serious depletion of any indigenous species and maintain all species of fish and wildlife at optimum levels.


• Fish and Wildlife Habitat Mitigation Policy (OAR 635-415-0000-0030) Require or recommend mitigation for losses of fish and wildlife habitat.

• Oregon’s Elk Management Plan

Protect and enhance elk populations in Oregon to provide optimum recreational benefits to the public and to be compatible with habitat capability and primary land uses.

• Oregon’s Black Bear Management Plan Maintain healthy populations of black bear consistent with public desires and state law.

• Oregon’s Cougar Management Plan Maintain healthy populations of cougar consistent with public desires and state law.

• Wildlife Diversity Plan (OARs 635-100-0001 through 0030) Maintain Oregon’s wildlife diversity by protecting and enhancing populations and habitats of native wildlife at self-sustaining levels throughout natural geographic ranges.

• Oregon Wolf Conservation and Management Plan (OAR 635-110-000) Ensure the conservation of gray wolves as required by Oregon law while protecting the social and economic interests of all Oregonians.

• Black-tailed Deer Management Plan Maintain healthy populations of Black-tailed Deer consistent with public desires and state law.

Time Required for Study The time required for collecting sufficient data on these species is not known. ODFW

recommends that the study schedule be prepared by PacifiCorp in cooperation with researchers

familiar with studies of these species.

Existing Information and the Need for Additional Information PacifiCorp conducted surveys on canals for the Prospect 1, 2, & 4 project relicensing.

PacifiCorp widened 6 foot wide crossings to 12 foot wide and observed usage by a number of

animal species. PacifiCorp’s North Umpqua Hydropower Project widened animal crossings

from 6 feet to 36 feet in width with small animal cover constructed on the edges. Information

collected by PacifiCorp suggests heavy usage of these larger width crossings by both large and

small animals.


ODFW has collected evidence to suggest that deer and other animals migrate from areas of the

Cascades above the Project to areas below the Project. There is uncertainty as to the extent

the canals and fencing effect migration, and whether the crossings are ameliorating possible

negative effects. ODFW again recommends evaluating use/non-use of the crossings by

monitoring animal behavior with video cameras.

Some data were collected at existing wildlife crossing structures. However, minimal information

was collected to examine the success of animal movement or the effects of canals and other

structures on dispersion of small animals.

3 Minimum Flows in Bypass Reaches Recommended Study and Basis for Request The current minimum flow requirement was established during the last Project relicensing in

1986. The current relicensing provides the opportunity to reassess the adequacy of the existing

mitigation measures for meeting the current and updated standards and criteria for fish and

wildlife mitigation and protection. Under the current license the minimum flow requirement in

the Project bypass reach is 10 cfs (License Article 402). Relicensing should result in ensuring

that minimum flows in the project bypass reach are consistent with fish management goals and

objectives to provide adequate stream habitat for fish production. ODFW’s goals and objectives

for the Prospect area fish populations of the Rogue River are found in the following statutes

(ORS) and rules (OAR):

• Wildlife Policy (ORS 496.102)

• Policy to Restore Native Stocks (ORS 496.435

• General Fish Management Goals (OAR 635-007-0510)


• Oregon Plan for Salmon and Watersheds (ORS 541.405)

• Native Fish Conservation Policy (OAR 635-007-0502-0509)

• Trout Management (OAR 635-500-0100-0120)

• Fish and Wildlife Habitat Mitigation Policy (OAR 635-415-0000-0030)


PacifiCorp can conduct the work in-house, though they may prefer to contract with a qualified

fisheries consultant. ODFW recommends that the Applicant consult with the resource agencies

to accomplish the reanalysis of the 1986 transect data using the HSC from the Prospect 1, 2,

and 4 relicensing.

Study Methods and Objectives This study will require PacifiCorp to acquire and provide to the resource agencies the existing

1986 IFIM data in electronic format. The Applicant should re-run the 1986 transect data using

the HSC for cutthroat and rainbow trout as agreed by the Applicant and the resource agencies

for the Prospect 1, 2, and 4 relicensing. The reanalysis of the existing transect data with the

more recent HSC will likely result in modification of the predicted weighted useable area and

habitat duration. (See ODFW caveat on habitat duration on page 23) The Applicant should use

stream hydrograph data from the last 20 years as available from USGS or a synthesized

hydrograph if necessary. ODFW recommends that the Applicant conduct field work to reassess

the contribution of accretion in the lower Project bypass reach to document any changes since

the last assessment for the 1986 IFIM study. The Applicant should collaborate with the

resource agencies on the IFIM/PHABSIM results to identify appropriate minimum bypass flows

for the species and life stages identified by the fish management agencies. The methods are


intended to be consistent with conducting a complete new IFIM/PHABSIM, however in this case

new transect data will not be collected.

How the Study will be useful in Furthering ODFW Resource Management Goals Study information would be used to determine what minimum flows will provide the greatest life

history stage protection and enhancement. Native trout life history stages include: spawning,

egg, fry, juvenile, and adult. Based on habitat measurements over a wide variety of flows, a

determination of monthly or seasonal minimum bypass flows will be recommended that may

overlap several life history stages but provide an “overall” protective/enhancement flow. These

minimum flow(s) will help maintain aquatic habitat connectivity so that dispersal, migration, and

interbreeding among subpopulations can occur. The study will further ODFW’s resource

management goals by providing information regarding the effect of the project on native trout

populations in the upper Rogue and help to identify what kinds and levels of mitigation

measures would be most appropriate to include in the new license to support protection and

restoration of trout populations.

Time Required for Study The time required for collecting sufficient data on these species is not known because ODFW is

uncertain of the availability of the 1986 IFIM/PHABSIM data files. If these are readily available

the rerun of the existing data with the more recent HSC could occur over a few weeks.

Obtaining the hydrograph information including documenting accretion, drafting a report of the

results, and collaboration and negotiation could potentially be completed within one year.

Existing Information and the Need for Additional Information

• Current license article allows PacifiCorp to divert up to 150 cfs and leave at least 10 cfs

to the bypass reach using the fish ladder as the conduit


• Establishing minimum flow in the project-affected reaches is related to ODFW’s

management goals and objectives in that adequate flow for juvenile and adult rearing

and spawning must be provided to meet goals and objectives of ODFW’s trout

management.

• Evaluating the relationship between stream flow and habitat in project affected reaches

is necessary to assist in developing minimum flow requirements in project bypass

reaches.

• PacifiCorp’s proposes a “fine scale habitat duration analysis on existing habitat-flow

relationships for native trout in the South Fork bypass reach (IFIM). ODFW will review

habitat duration analysis, but with the following caveats: WUA often reaches a peak at

some intermediate flow level, then decreases at higher flows. Habitat duration analysis

generally counts flow removal at these higher flows as a habitat benefit, since WUA is

increased. This computed benefit is then used to offset WUA losses that occur when

flow is reduced during the lower-flow times of the year. ODFW will not accept this type

of interpretation because:

a) Flows above the peak WUA flow provide many other functions to a healthy stream

ecosystem. The benefits of these elevated flows are not captured by standard WUA

output, but have been abundantly documented in the scientific literature.

b) Use of physical habitat space by fish at elevated flows is not well documented.

Higher velocity and increased depth does not necessarily decrease fish populations,

despite the WUA output.


• Any flow study conducted as part of relicensing for the Prospect 3 project must

incorporate all necessary life stages/needs of all species of concern in the project area.

The species of primary concern to ODFW are cutthroat trout and rainbow trout and the

life stages are juvenile and adult.

• Because IFIM involves a number of important subjective decisions, PacifiCorp should

involve ODFW and the other agencies in the study team to make decisions on

techniques of IFIM and interpretation of results. IFIM is a group decision-making

process, not simply a computer model, which requires input from all stakeholders

throughout the entire process.

• A final study plan needs to be developed and submitted to the agencies for review;

comment and approval before initiating the bypass reach flow studies. The study plan

will be necessary to document the agreed upon techniques and analytical procedures to

be used.

ODFW recommends the following be considered in developing and conducting the flow study:

Modeling incorporates a number of assumptions and uncertainties. These assumptions and

uncertainties should be addressed in the interpretation and report. In particular, the effects of

these uncertainties in determining instream flow requirements should be discussed, and

quantified if possible.

1. Develop WUA curves per individual transect to determine if a particular habitat type is more

impacted.


2. Make accurate representations of habitat the highest priority in the hydraulic modeling

3. Use the same spatial resolution for hydraulic simulation, habitat suitability index

development, and habitat criteria testing.

4. ODFW will provide additional comments when a detailed study plan is distributed for review.

4 Upstream Passage

Recommended Study and Basis for Request PacifiCorp was required to design and implement safe upstream passage per Article 404 of the

current license. In 1993 ODFW requested that PacifiCorp proceed with the design of the facility

utilizing interim design criteria to be provided by ODFW in the future. PacifiCorp filed the final

upstream and downstream fish passage designs along with monitoring plan on December 28,

1995. The plans and design were accepted by FERC order on May 21, 1996. The construction

of the upstream and downstream fish passage facilities was completed in November 1996.

According to ORS509.585, a fishway is required for artificial obstructions across any body of

water in the state. Fishways must be provided to maintain adequate upstream and downstream

passage of game fish. In addition, the policy goals of the Native Fish Conservation include;

prevent the serious depletion of any native fish species by protecting natural ecological

communities, conserving genetic resources, managing consumptive and non consumptive

fisheries; and maintain and restore naturally produced native fish species, taking full advantage

of the productive capacity of natural habitats, in order to provide substantial ecological,

economic, and cultural benefits.


ODFW’s main concern regarding fish passage is to bring the project into compliance with

present day statutes and standards for fish and wildlife mitigation measures. We will work with

PacifiCorp to identify the required fish passage criteria for the existing fishway. PacifiCorp

should include plans for evaluating the effectiveness of fish passage facilities.



fisheries consultant. PacifiCorp needs to consult with the resource agencies during

development of study designs and analysis of data collected

Study Methods and Objectives This study will require PacifiCorp conduct field sampling. Fish ladder hydraulics and steps will

need to be determined and compared to existing ODFW fish passage criteria. Those criteria

that do not meet current ODFW standards should be updated to ensure safe and timely

upstream passage. The energy dissipation factor EDF should be one component of the

hydraulic analysis, in addition to measuring operational flow, flow design range, jump heights,

and pool dimensions.

How the Study will be useful in Furthering ODFW Resource Management Goals Study information would be used to determine what flow will provide safe and timely upstream

passage. Also, jump heights at each fish ladder weir may need to be adjusted to allow

passage. Lastly, flows through the submerged orifice at the ladders exit may be preventing or

delaying trout movement out of the ladder into the reservoir. The goal is to maintain aquatic

habitat connectivity so that dispersal, migration, and an exchange of genetic material can occur.


The study will further ODFW’s resource management goals by providing information regarding

the effect of the project on native trout populations in the upper South Fork Rogue River.

Time Required for Study The time required for collecting sufficient data on these species should be complete during the

spring and fall months of 2015 and 2016. Two seasonal survey periods will cover migration

periods of trout species present in the South Fork Rogue River and check for a possible second

seasonal peak upstream migration. ODFW recommends that the study schedule be prepared

by PacifiCorp in cooperation with researchers familiar with studies of these species.

Existing Information and the Need for Additional Information

Current ladder at the South Fork diversion dam was designed and constructed using interim

design criteria. The ladder was evaluated with upstream fish passage observed, Since 1997,

information pertaining to correct step heights (6 inches), proper cfs though the ladder, energy

dissipation, and continued safe upstream passage has not be documented.

ODFW recommends the following be considered:

1. Updated fish ladder measurements to determine jump height

2. Accurate in ladder flow measurements (cfs) to determine if trout criteria are being met

3. Updated fish evaluation plan that outlines a study to determine safe upstream fish

passage

4. Updated information on the physical condition of the fish ladder (concrete cracks,

vegetation growth on ladder, etc.),


5 Fish Entrainment in the Power Canal

Recommended Study and Basis for Request In 1993 ODFW requested that PacifiCorp proceed with the design of the facility utilizing interim

design criteria to be provided by ODFW in the future. ODFW provided a “Fish Screen Policy”

with interim design standards to PacifiCorp on September 7, 1994. PacifiCorp filed the final

upstream and downstream fish passage designs along with monitoring plan on December 28,

1995. The plans and design were accepted by FERC order on May 21, 1996. The construction

of the upstream and downstream fish passage facilities was completed in November 1996.

ODFW has responsibility to protect downstream migrating fish through ORS 498.311 and

509.585. These statutes may require installation, operation, and maintenance of a fish screen

on any diversion of water in the state and downstream passage for native migratory fish.

ODFW will work with PacifiCorp to provide advice on conducting entrainment studies, to

determine if an updated fish screen criterion is being met. ODFW will help develop new

screening design and developing study plans for screen evaluation if determined that the

existing screen does not meet criterion.



fisheries consultant. PacifiCorp needs to consult with the resource agencies during

development of study designs and analysis of data collected

Study Methods and Objectives This study will require PacifiCorp conduct field sampling, and re-use existing fish passage

studies conducted in the 1980’ and 1990’s. Fish screen hydraulics and bypass pipe will need to


be studied then compared to existing ODFW fish passage criteria. Those criteria that do not

meet current ODFW standards should be updated or replaced to ensure safe and timely

downstream stream passage. Trout of various sizes should be placed at the entrance of the

fish screen (in the canal) to determine if: 1) screen approach and sweeping velocities meet

criteria, 2) passage through the screen is safe and completed in a timely matter, and 3) passage

through the bypass pipe and exit from the pipe does not delay or injure trout.

How the Study will be useful in Furthering ODFW Resource Management Goals Study information would be used to determine what if the current screen facility meets ODFW

criteria and provides safe and timely downstream passage. The goal is to maintain aquatic

habitat connectivity so that dispersal, migration, and an exchange of genetic material can occur

to downstream habitats below the diversion dam. The study will further ODFW’s resource

management goals by providing information regarding the effect of the project on native trout

populations in the upper South Fork Rogue River.


spring of 2015 and 2016. ODFW recommends that the study schedule be prepared by

PacifiCorp in cooperation with researchers familiar with studies of these species.

Existing Information and the Need for Additional Information Current fish screen at the South Fork diversion dam was designed and constructed using

interim design criteria. The screens were evaluated in the late 1990’s and did not meet criteria.

The screen was repaired and updated by PacifiCorp and met criteria standards for 2000-2001.

Since then no additional testing has been completed at the screening facility.


ODFW recommends the following be considered:

1. Updated approach and sweeping velocity studies

2. Updated screen spacing size

3. Updated fish screen evaluation plan that outlines a study to determine safe downstream

fish passage

4. Updated information on the physical condition of the fish screen facility (concrete cracks,

vegetation growth, screen condition, etc.),

6 Wildlife Species Composition Survey

ODFW proposes a study to characterize the existing wildlife and amphibian communities of the

project area in order to improve the understanding of the wildlife species currently inhabiting

project landscape during different times of the year, including their distribution, and relative

abundance.



wildlife consultant. PacifiCorp needs to consult with the resource agencies during development

of study designs and analysis of data collected

Study Methods and Objectives Study methods should be current acceptable to ODFW and other agencies. Studies may include

the use of video cameras, still cameras, radio telemetry, and capture and release methodology

to monitor animal movements and behavior. Remote sensing with video cameras can be used

with bait stations to observe species such as pine marten and fisher. Video cameras can be


used to record animal behavior at canal crossings. Radio telemetry and

capture/release/observation methods can be used to assess habitat connectivity, the avoidance

of canals to crossing, and an animal’s ability to cross canals to other Project features.

The objective of the study would be to provide information on the species composition of large

and small animals near Project.

How the Study will be useful in Furthering ODFW Resource Management Goals Study information would be used to determine what current and future project impacts may have

on wildlife resources in the area. The study will further ODFW’s resource management goals by

providing information regarding the effect of the project on native trout populations in the upper


spring of 2015 and 2016. ODFW recommends that the study schedule be prepared by

PacifiCorp in cooperation with researchers familiar with studies of these species.

Existing Information and the Need for Additional Information Species information gathered by other agencies appears to cover large landscapes and are not

specific to the Prospect 3 project area. In order to implement specific species management

plans, a detailed wildlife species composition list is needed.


UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION

PacifiCorp Energy ) FERC Project 2337-076 ) Notice of Intent to File License Application, ) Filing of Pre-application Document (PAD), ) Commencement of Pre-filing Process, and ) Prospect 3 Scoping: Request for Comments on the PAD ) Hydroelectric Project and Scoping Document, and Identification ) of Issues and Study Requests ______________________________________________________________________

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that I have made service of the foregoing OREGON DEPARTMENT OF

FISH AND WILDLIFE COMMENTS ON THE PREAPPLICATION DOCUMENT AND SCOPING

DOCUMENT NO. 1, AND STUDY REQUESTS – Prospect 3 Hydroelectric Project - Oregon -

FERC Project No. 2337-076 upon the parties designated on the official service list compiled by

the Secretary in this proceeding:

Dated _____November 14, 2013_______

David A. Harris Southwest Region Hydropower Coordinator

Documents

Department of Fish and Wildlife - · PDF filea bypass pipe to return fish to the ladder ... static head of 740 feet and ... upgrading thefish bypass screen to meet current ODFW fish