20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM Whitewater Creek Hydroelectric Project WHITEWATER GREEN ENERGY, LLC Revised Study Plans April 15, 2014

April 15, 2014

Kimberly Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, D.C. 20426

Subject: Whitewater Creek Hydroelectric Project Revised Study Plans (FERC Project No. 14383)

Dear Secretary Bose:

Whitewater Green Energy LLC is submitting our Revised Study Plans (RSP) for the Whitewater Creek Hydro Project (FERC No. 14383). Whitewater Green Energy, LLC hosted the Proposed Study Plan Meeting on January 28, 2014 in Salem, Oregon with assistance from Environmental Resources Management (ERM). PSP comments from stakeholders filed with FERC by March 29, 2014 have been incorporated into the RSP.

Sincerely,

David G. Harmon, P.E. Whitewater Green Power, LLC ELECTRONIC FILING

2532 Santiam Hwy SE, Albany, Oregon 97322 541-405-5236 Page 1

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Whitewater Creek Hydroelectric Project Revised Study Plan FERC No. 14383

Prepared by Whitewater Green Energy, LLC with support from ERM

April 2014

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TABLE OF CONTENTS

LIST OF FIGURES V

LIST OF ACRONYMS VI

1.0 INTRODUCTION 1

2.0 REVISED STUDIES 4

2.1 WATER QUALITY STUDY 4 2.1.1 Goals and Objectives § 5.11(d)(1) 4 2.1.2 Study Area 5 2.1.3 Resource Management Goals §5.11(d)(2) 5 2.1.4 Existing Information §5.11(d)(3) 5 2.1.5 Nexus to Project §5.11(d)(4) 5 2.1.6 Study Methods §5.11(b)(1) & (d)(5) 6 2.1.7 Study Results §5.11(b)(3) 8 2.1.8 Schedules §5.11(b)(2) 8 2.1.9 Level of Effort and Cost §5.11(d)(6) 8

2.2 HYDROLOGY STUDY 9

2.2.1 HYDROLOGY STUDY 9 2.2.10 References 18

2.3 WETLANDS AND WATERS OF THE US DELINEATION 18 2.3.1 Goals and Objectives § 5.11(d)(1) 18 2.3.2 Study Area 18 2.3.3 Resource Management Goals §5.11(d)(2) 19 2.3.4 Existing Information §5.11(d)(3) 19 2.3.5 Nexus to Project §5.11(d)(4) 19 2.3.6 Study Methods §5.11(b)(1) & (d)(5) 19 2.3.7 Study Results §5.11(b)(3) 22 2.3.8 Schedules §5.11(b)(2) 22 2.3.9 Level of Effort and Cost §5.11(d)(6) 22 2.3.10 References 23

2.4 CULTURAL RESOURCES SURVEY 23 2.4.1 Goals and Objectives § 5.11(d)(1) 23 2.4.2 Study Area 23

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2.4.3 Resource Management Goals §5.11(d)(2) 23 2.4.4 Existing Information §5.11(d)(3) 24 2.4.5 Nexus to Project §5.11(d)(4) 24 2.4.6 Study Methods §5.11(b)(1) & (d)(5) 24 2.4.7 Study Results §5.11(b)(3) 25 2.4.8 Schedules §5.11(b)(2) 25 2.4.9 Level of Effort and Cost §5.11(d)(6) 25

2.5 AESTHETIC RESOURCES STUDY 25 2.5.1 Goals and Objectives § 5.11(d)(1) 25 2.5.2 Study Area 26 2.5.3 Resource Management Goals §5.11(d)(2) 26 2.5.4 Existing Information §5.11(d)(3) 26 2.5.5 Nexus to Project §5.11(d)(4) 27 2.5.6 Study Methods §5.11(b)(1) & (d)(5) 28 2.5.7 Study Results §5.11(b)(3) 31 2.5.8 Schedules §5.11(b)(2) 31 2.5.9 Level of Effort and Cost §5.11(d)(6) 31

2.6 BYPASS REACH INSTREAM FLOW AND AQUATIC HABITAT STUDY32 2.6.1 Goals and Objectives § 5.11(d)(1) 32 2.6.2 Study Area 32 2.6.3 Resource Management Goals §5.11(d)(2) 32 2.6.4 Existing Information §5.11(d)(3) 33 2.6.5 Nexus to Project §5.11(d)(4) 33 2.6.6 Study Methods §5.11(b)(1) & (d)(5) 34 2.6.7 Study Results §5.11(b)(3) 47 2.6.8 Schedules §5.11(b)(2) 47 2.6.9 Level of Effort and Cost §5.11(d)(6) 48 2.6.10 References 48

2.7 BOTANICAL RESOURCES AND WILDLIFE HABITAT STUDY 49 2.7.1 Goals and Objectives §5.11(d)(1) 49 2.7.2 Study Area 50 2.7.3 Resource Management Goals §5.11(d)(2) 50 2.7.4 Existing Information §5.11(d)(3) 50 2.7.5 Nexus to Project §5.11(d)(4) 52 2.7.6 Study Methods §5.11(b)(1) & (d)(5) 53 2.7.7 Study Results §5.11(b)(3) 56 2.7.8 Schedules §5.11(b)(2) 57 2.7.9 Level of Effort and Cost §5.11(d)(6) 58 2.7.10 References 58

2.8 SOILS AND GEOLOGY RESOURCES STUDY 58 2.8.1 Goals and Objectives § 5.11(d)(1) 58 2.8.9 Level of Effort and Cost §5.11(d)(6) 63

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2.8.10 References 63

2.9 RECREATION RESOURCES STUDY 63 2.9.1 Goals and Objectives § 5.11(d)(1) 63 2.9.2 Study Area 64 2.9.3 Resource Management Goals §5.11(d)(2) 64 2.9.4 Existing Information §5.11(d)(3) 65 2.9.5 Nexus to Project §5.11(d)(4) 66 2.9.6 Study Methods §5.11(b)(1) & (d)(5) 67 2.9.7 Study Results §5.11(b)(3) 70 2.9.8 Schedules §5.11(b)(2) 70 2.9.9 Level of Effort and Cost §5.11(d)(6) 70

2.11 BEDLOAD STUDY 82 2.11.1 Goals and Objectives § 5.11(d)(1) 82 2.11.2 Study Area 82 2.11.3 Resource Management Goals §5.11(d)(2) 82 2.11.4 Existing Information §5.11(d)(3) 83 2.11.5 Nexus to Project §5.11(d)(4) 83 2.11.6 Study Methods §5.11(b)(1) & (d)(5) 84 2.11.7 Study Results §5.11(b)(3) 85 2.11.8 Schedules §5.11(b)(2) 85 2.11.9 Level of Effort and Cost §5.11(d)(6) 85 2.11.10 References 86

3.0 STUDY REQUESTS NOT ADOPTED 87

3.1 FISH SCREENING AND UPSTREAM PASSAGE ALTERNATIVES 87

3.2 EFFECTS TO ESA SPECIES AND DESIGNATED CRITICAL HABITAT 87

3.3 WILDLIFE OBSERVATIONS 87

3.4 STREAM MACROINVERTEBRATES 88

3.5 HARLEQUIN DUCK STUDY 88

3.6 BALD EAGLE STUDY 89

3.7 LAND USE STUDY 90

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APPENDICES

APPENDIX A — STUDY REQUEST LETTERS

APPENDIX B — SUMMARY OF STAKEHOLDER COMMENTS ON THE NINE PROPOSED STUDY PLANS (PSP) AND APPLICANT RESPONSES

APPENDIX C — SUMMARY OF INFORMAL CONSULTATION BETWEEN THE FORMAL PSP MEETING (28 JANUARY 2014) AND THE PSP COMMENT DEADLINE (29 MARCH 2014)

APPENDIX D —PSP MEETING ATTENDANCE LIST

APPENDIX E —WHITEWATER IFS WORKPLAN

APPENDIX F —WETLAND DETERMINATION DATA FORMS

APPENDIX G —WILLAMETTE NATIONAL FOREST T/E OR SENSITIVE SPECIES FROM RFSSS LIST 2011

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LIST OF FIGURES

(Figures immediately follow the text)

1 Site Location

2 Wetlands and Waters of the U.S. Study Area

3 Cultural Resource Survey Areas

4 Aesthetics Study Area

5 Botanical Study Area

6 Recreation Study Area

7 Northern Spotted Owl Study Area

8 Osprey Study Area

9 Amphibian Study Area

10 Terrestrial Mollusks Study Area

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LIST OF ACRONYMS

APE Area of Potential Effect AWS Area weighted suitability BAGS Bedload Assessment for Gravel-Bed Streams BMPs Best Management Practices Ca Calcium CFR Code of Federal Regulations cfs Cubic feet per second Cl Chlorine CO32 Carbonate CSI Combined suitability index DO Dissolved oxygen DTM Digital terrain model ESA Endangered Species Act FERC Federal Energy Regulatory Commission FPA Federal Power Act GIS Geographic Information System HCO3 Bicarbonate HPMP Historic Properties Management Plan HSI Habitat suitability index IDP Inadvertent Discovery Plan IFIM Instream Flow Incremental Methodology IFS Instream flow study ILP Integrated Licensing Process ISR Initial Study Report K Potassium KOPs Key observation points kV Kilovolt Mg Magnesium msl Means sea level MW Megawatt NA Sodium Native American Graves Protection and Repatriation NAGPRA Act NEPA National Environmental Policy Act NH4 Ammoniuum NHPA National Historic Preservation Act NI No regional indicator NO No known occurrence

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NO2 Nitrogen dioxide NO3 Nitrate NOI Notice of Intent NRCS Natural Resources Conservation Service NWFP Northwest Forest Plan ODEQ Oregon Department of Environmental Quality ODFW Oregon Department of Fish and Wildlife PAD Preliminary Application Document PLP Preliminary Licensing Proposal PO43 Phosphate PSP Proposed Study Plan QAPP Quality Assurance Project Plan RFSSS Regional Forester’s Special Status Species RSP Revised Study Plan fSD1 Scoping Document 1 SEFA System of Environmental Flow Analysis SHPO State Historic Preservation Office SO42 Sulfate SPD Study plan determination TES Threatened and endangered, or sensitive TKN Total kjeldahl nitrogen USACE US Army Corps of Engineers USC United States Code USEPA United States Environmental Protection Agency USFS US Forest Service USFWS US Fish and Wildlife Service WNF Willamette National Forest WUA weighted usable area

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1.0 INTRODUCTION

On 8 July 2013 Whitewater Green Hydro, LLC (the applicant) filed a revised Notice of Intent (NOI) to submit a license application and an associated Preliminary Application Document (PAD) for the Whitewater Creek Hydroelectric Project Federal Energy Regulatory Commission (FERC) No. 14383 (Project). The proposed Project would consist of:  A 36.6-foot wide, 113.4-foot-long diversion structure on Russell Creek that would impound a 2,838-square-foot reservoir at a normal maximum water surface elevation of 3,580 means sea level (msl);  A 19,500-foot-long, 36 to 48 inch-in-diameter high-density polyethylene and steel penstock;  An 80-foot-wide by 50-foot-long powerhouse containing one 9-megawatt (MW) Pelton turbine/generator unit;  A 320-foot-long tailrace that would discharge flows into Whitewater Creek;  A 2.5-mile-long, 12.4-kilovolt (kV) buried transmission line extending from the powerhouse to an existing transmission line along Oregon Highway 22;  Three new access roads, including: o A 2,660-foot-long road that would be used to access the powerhouse; and o A 3,580-foot-long road that would be used to access the diversion structure o A 3,000-foot-long road that would be used to connect Forest Service Roads 45 and 441; and  Appurtenant facilities.

The Project would have an estimated average annual generation of 50,567,654-kilowatt-hour.

The proposed diversion would create a small reservoir at river mile 1.5 on Russell Creek. The applicant proposes to divert between 5.75 and 138 cubic feet per second (cfs) via the penstock to its proposed powerhouse on Whitewater Creek. These flows would enter the powerhouse and flow through the Pelton turbine/generator unit before

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discharging to Whitewater Creek, approximately 2.2 river miles upstream of its confluence with Russell Creek (Figure 1).

On 30 August 2013 FERC issued Scoping Document 1 (SD1) for the Whitewater Creek Hydroelectric Project with a preliminary scope of potential environmental issues associated with the project. FERC held two scoping meetings on 18-19 September 2013 in Detroit, Oregon, to solicit additional information and study requests necessary to prepare their Environmental Assessment for the Project. In accordance with the process plan and schedule established by FERC in SD1, resource agencies, Non- governmental organizations, tribes, and other stakeholders had until 29 October 2013 to file written comments on the PAD and SD1, as well as request studies pursuant to 18 Code of Federal Regulations (CFR) § 5.9(b). On 25 October 2013 FERC granted a 2 week extension until 14 November 2013 to file written study requests as well as comments on the PAD and SDI, due to the federal government shutdown that occurred from 1 October 2013 through 16 October 2013. Written comments and study requests were filed by the US Fish and Wildlife Service (USFWS), US Forest Service (USFS), Oregon Department of Fish and Wildlife (ODFW), Oregon Department of Environmental Quality (ODEQ), Oregon Wild, and the Portland District of the US Army Corps of Engineers (USACE).

On 27 December 2013, Whitewater filed its Proposed Study Plan (PSP). The PSP included the applicant’s study plans for filling data gaps identified in the PAD, during scoping, in stakeholder comments, and additional information necessary for preparing a comprehensive Preliminary Licensing Proposal (PLP). Whitewater’s PSP included nine studies to be completed over the course of 12 months, as described in the proposed schedule in Appendix B of the PSP. In accordance with 18 CFR§5.11 each study in the PSP included a description of the Project objectives, study area, resource management goals relevant to the study, study nexus, study methodology/products, level of effort/cost, and a schedule.

A formal PSP meeting was held on 28 January 2014 in Salem, Oregon. Additional informal meetings and correspondence between the Applicant and stakeholders were held subsequent to the formal meeting and prior to the PSP comment deadline. Stakeholder comments on the PSP were due to be filed with FERC no later than 29 March 2014. Many of the original nine studies in the PSP have been modified in the Revised Study Plan (RSP) in response to stakeholder comments filed by the 29 March 2014 deadline. In addition, two additional studies have been added in response to comments. Section 2.0 includes the applicants revised study plans for 11

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studies. Section 3.0 includes explanations for specific study requests that were not adopted.

Pertinent formal and informal consultation post filing of the PSP has been included in Appendices A-E:  Appendix A: PSP comments filed with FERC by 29 March 2014.  Appendix B: Comment matrix with Whitewater’s responses to specific comments on the nine studies included in the PSP.  Appendix C: Summary of informal consultation between the formal PSP meeting (January 28 2014) and the PSP comment deadline (29 March 2014).  Appendix D: Copy of the list of attendees at the 28 January 2014 PSP meeting.  Appendix E: Copy of the Draft Revised Bypass Reach Instream Flow and Aquatic Habitat Study circulated to the study specific subgroup to assist with PSP comments.

In accordance with the ILP schedule, FERC will issue a formal study plan determination in May 2014. Upon issuance of this determination the applicant will proceed with the FERC approved studies according to the schedules provided in the individual study plans.

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2.0 REVISED STUDIES

The studies included in the RSP are a combination of studies in the PSP as well as additional studies added in response to stakeholder comments. The RSP studies are as follows  2.1 Water Quality Study  2.2 Hydrology Study  2.3 Wetlands and Waters of the US Delineation  2.4 Cultural Resources Survey  2.5 Aesthetic Resources Study  2.6 Bypass Reach Instream Flow and Aquatic Habitat Study  2.7 Botanical Resources Study  2.8 Soils and Geology Resources Study  2.9 Recreation Resources Study  2.10 Wildlife Resources Study  2.11 Bedload Study

In accordance with 18 CFR§5.11 each study in the RSP includes a description of the project objectives; study area; resource management goals relevant to the study; study nexus; study methodology/products; level of effort/cost; and a schedule. The applicant intends to complete all eleven studies in 1-year and file the individual study results in a comprehensive Initial Study Report (ISR) in June of 2015 (18 CFR §5.15[c][1]).

2.1 WATER QUALITY STUDY

2.1.1 Goals and Objectives § 5.11(d)(1)

The goal of this study is to characterize the existing water quality conditions for areas of Russell and Whitewater creeks (18 CFR § 5.18[b][5][A]) and establish a baseline for comparison of potential project effects in Russell and Whitewater creeks. Specific objectives of this study include:

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(1) Characterization of baseline water quality conditions in the affected reaches of Russell and Whitewater creeks; and (2) Evaluation of the potential effects of project construction and operation on water quality in the affected reaches of Russell and Whitewater creeks.

2.1.2 Study Area

Monitoring of baseline water quality conditions will occur at three locations in the project area. Monitoring will occur at the diversion location on Russell Creek, the tailrace location on Whitewater Creek, and immediately downstream of the confluence of Russell and Whitewater creeks.

2.1.3 Resource Management Goals §5.11(d)(2)

ODEQ administers the state’s water quality laws, ORS chapter 468B, including the assurance that operation of a hydroelectric project is consistent with water quality standards and the protection of beneficial uses. ODEQ approves or denies water quality certification for purposes of Section 401 of the Clean Water Act. Any license issued by the Commission must incorporate any conditions accompanying the state’s water quality certification (33 USC Sec. 1341[d]).

2.1.4 Existing Information §5.11(d)(3)

There is no information on existing water quality in either Russell or Whitewater creeks beyond data collected by the applicant in 2012. This data is insufficient to properly assess existing water quality conditions in Russell and Whitewater creeks, or predict future project effects on water quality. Additional water quality monitoring is needed to conduct the required analysis of potential project effects (e.g., streamflow diversions) on water quality and aquatic resources in the project area.

2.1.5 Nexus to Project §5.11(d)(4)

Project diversions for power generation have the potential to modify the existing flow regime in Russell and Whitewater Creeks These modifications have the potential to adversely affect water temperature and dissolved oxygen concentrations in these creeks

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The study would establish a baseline condition for the potentially affected stream reaches and provide data to be used to predict water temperatures and dissolved oxygen concentrations in Russell and Whitewater creeks. Results of this water quality monitoring study would inform potential license articles pertaining to water quality. Characterizing the existing environment for potentially affected water quality parameters and describing the project’s potential effects on these resources is necessary for FERC to carry out their responsibilities under the National Environmental Policy Act (NEPA), the Clean Water Act, the Endangered Species Act (ESA), and the Magnuson-Stevens Fishery Conservation and Management Act.

2.1.6 Study Methods §5.11(b)(1) & (d)(5)

To characterize the temporal variability of temperature in the project area, the applicant will continuously monitor water temperature at hourly intervals from May 2014-April 2015 at: (a) at the diversion location on Russell Creek; (b) at the tailrace location on Whitewater Creek; and (c) immediately downstream of the confluence of Russell and Whitewater creeks. Onset Hobo Temperature Loggers (or similar) will be used to continuously monitor temperature. Loggers will be anchored in the streambed well below the surface ensure they remain underwater during low flow periods. Loggers will be downloaded monthly May-October and as weather and site conditions allow during the winter months of 2014/2015. Exact logger locations will be recorded with a handheld GPS and location information will be included in the ISR.

The applicant proposes to continuously monitor dissolved oxygen (DO), pH, conductivity, and turbidity with a multi-parameter water quality probe(s) (Hydrolab DS5X or similar) at hourly intervals during one 24- hour sampling event/month from May 2014-October 2014 and This monitoring effort will occur at: (a) the diversion location on Russell Creek; (b) the tailrace location on Whitewater Creek; and (c) immediately downstream of the confluence of Russell and Whitewater creeks. The August sampling event for DO and pH will be extended from 24 to 72 hours in order to address ODEQ’s concerns specific to the project’s potential impacts on algal respiration. Probes will be anchored in the streambed and monitored to ensure that the sensors remain underwater during sudden changes in flow. Probes will be downloaded after each May-October sampling event. Monitoring locations will be recorded with a handheld GPS and location information will be included in the ISR.

ODEQ commented that the buffering capacity of freshwater systems is influenced by the composition of certain common major ions. Reduced

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flows in the bypassed reaches may impair water quality parameters including pH which may cause stressful aquatic conditions. Establishing baseline water chemistry conditions will help understand how aquatic systems resist changes in pH caused by project-related effects. In response the applicant will collect spring, summer, fall, grab samples for laboratory analysis of the principle ion group (bicarbonate [HCO3-], carbonate [CO32-], sodium [Na-], chlorine [Cl-], magnesium [Mg2+], calcium [Ca2+], potassium [K+], sulfate [SO42-]). Grab samples will be collected at the proposed project intake and tailrace locations.

The Project proposes to alter the hydrologic regime of Russell and Whitewater Creeks which may directly influence primary productivity. In response, the applicant will collect spring, summer, and fall grab samples for laboratory analysis of nutrients (ammonium [NH4+], total kjeldahl nitrogen [TKN], nitrate [NO3-] + nitrogen dioxide [NO2-]; phosphate [PO43-], TP ). Grab samples will be collected at the proposed project intake and tailrace locations. Also in response to ODEQ’s comments, the applicant will collect spring, summer, and fall grab samples for laboratory analysis of chlorophyll-a and ecoli.

Mercury is present in Oregon through naturally occurring mineral sources and atmospheric deposition. Mercury is bioaccumulative in fish tissue in the form of methylmercury. ODEQ recently developed a mercury water quality standard based on the concentration of methylmercury in fish tissue. Mercury methylation is caused, in part, by the metabolism of anaerobic bacteria. Because reduced flow in bypassed reaches may lower DO concentrations, ODEQ recommended initial screening for mercury through water samples collected at the three principle sampling locations. In response, the applicant will collect spring, summer, and fall surface water grab samples for laboratory analysis of mercury at the proposed intake and tailrace locations as well as the Highway 22 bridge near the confluence of Whitewater Creek and the North Santiam River.

A combination of temperature data loggers, multi-parameter probes, and collection of grab samples are commonly used methods to assess baseline water quality. In addition, the methods are consistent with previous studies of water quality for other applications for hydropower license and 401 certifications.

The Water Quality Study will be conducted under a Quality Assurance Project Plan (QAPP). The QAPP will be developed once the study plan determination has been issued by FERC and will address both field and laboratory procedures. The QAPP will be developed in consultation with

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the Oregon Department of Environmental Quality (ODEQ). ODEQ will have at least 30 days to comment on the QAPP. Any comments made by ODEQ will be incorporated into a revised QAPP and the final plan will be filed with FERC. Any project staff working on the Water Quality Study will be familiar with both the study plan and QAPP.

2.1.7 Study Results §5.11(b)(3)

A report describing the results of the 2014/2015 water quality monitoring effort will be prepared at the end of the first study season and included in the ISR filed in May of 2015. The report will summarize the data and discuss the results in the context of relevant water quality standards and study objectives. In addition, the results of the Water Quality Study will be used to determine potential impacts, as well as prepare protection, mitigation, and enhancement plans.

2.1.8 Schedules §5.11(b)(2)

The Water Quality Study would be completed during the first study season of the Integrated Licensing Process (ILP) with an individual report prepared as part of the ISR. Field monitoring efforts will begin in June of 2014 and end in May 2015. The applicant is aware that FERC, ODEQ, and other stakeholders may request further monitoring if additional data collection is warranted after the 2014/2015 study effort.

A draft report including the results of the water quality study will be available for comment by all stakeholders at least 60 days prior to the 27 May 2015 initial study report meeting. The applicant will allow 30 days for stakeholders to comment and incorporate comments into the final report, currently scheduled to be filed with FERC on 12 May 2015.

2.1.9 Level of Effort and Cost §5.11(d)(6)

The applicant estimates that the costs of the sampling equipment and labor associated with monitoring, data analysis, and reporting for the Water Quality Study will be $50,000.

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2.2 HYDROLOGY STUDY

2.2.1 HYDROLOGY STUDY

2.2.1 Goals and Objectives § 5.11(d)(1)

The goal of this study is to quantify the frequency, magnitude, and duration of flows in Russell and Whitewater creeks. The specific objectives of this study include:  Determine stream flow availability in Russell Creek for project operations;  Conduct monthly stage-discharge measurements at hydrometric stations in Russell and Whitewater creeks;  Survey channel geometry at each hydrometric station;  Characterize the existing flow regime and develop stage-discharge relationships and related rating curves and hydrographs for each site;  Develop monthly flow-duration curves for Russell and Whitewater creeks, as required by section 4.41(c)(4)(i) of the Commission’s regulations;  Evaluate potential project effects on stream flows in the bypassed reach of Russell Creek, and in Whitewater Creek downstream of the project tailrace; and  Support the decision-making process in regards to instream flow needs for the bypassed reach in Russell and Whitewater creeks.

2.1.2 Study Area

Russell and Whitewater creeks are located on the west slope of Mt. Jefferson. Russell Creek is a small lake headed tributary to Whitewater Creek with the confluence of the two at 3,500 feet in elevation. Whitewater Creek begins in the alpine, has a glaciated headwater, and is a direct tributary to the North Santiam River.

In order to quantify flows in Russell and Whitewater Creeks in the project area, a continuous hydrometric monitoring station will be installed at the diversion location on Russell Creek and at the tailrace location on Whitewater Creek.

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2.2.3 Resource Management Goals §5.11(d)(2)

ODEQ administers the state’s water quality laws, ORS chapter 468B, including the assurance that operation of a hydroelectric project is consistent with water quality standards and the protection of beneficial uses. ODEQ approves or denies water quality certification for the purpose of Section 401 of the Clean Water Act. ODFW is the state agency with jurisdiction over fish and wildlife in Oregon (ORS 496.012; the Fish and Wildlife Coordination Act at 16 USC § 661 and 662; the Federal Power Act at 16 United States Code [USC] § 803 & 811). Reduced instream flows could stress water quality parameters and reduced support for aquatic resources in Russell and Whitewater Creeks. Modification of the flow regime in Russell and Whitewater Creeks could result in aquatic habitat alteration and complexity.

Sections 4(e) and 10(a) of the Federal Power Act (FPA) require FERC to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued. Providing an accurate description of the available stream flow for Project operations in the Project bypassed reach would provide information necessary to conduct the required analysis of water availability for power generation and instream flow needs to support aquatic, riparian, and terrestrial resources necessary to fulfill FERC’s responsibilities under the NEPA. Also, providing an accurate description of the existing stream flow in Whitewater Creek at the location of the proposed tailrace would provide information necessary to conduct an analysis of the effects of Project discharge and associated ramping rates on aquatic, riparian, and terrestrial resources necessary to fulfill FERC’s responsibilities under the NEPA.

2.2.4 Existing Information §5.11(d)(3)

Hydrology information for Russell and Whitewater Creeks is limited. The applicant collected preliminary flow data in 2012 and 2013 as well as periodic depth and velocity measurements at 1-foot intervals across a single transect located at the proposed diversion site. In 2012, Campbell Scientific continuous stage measurement and recording equipment was anchored in stable features at the project’s intake location on Russell Creek. The specific equipment was chosen by the applicant due to its reputation for being able to withstand freezing conditions and peak flows expected in Russell Creek. The equipment was programmed to continuously record at 6-minute intervals and the elevation of the equipment was surveyed. The applicant continued to collect depth and

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velocity measurements at 1-foot intervals along a single transect in close proximity to gaging equipment during the summer months of 2013. Additional hydrology data is needed to fully describe potential Project effects on stream flows in the bypassed reach of Russell Creek and Whitewater Creeks.

2.2.5 Nexus to Project §5.11(d)(4)

Stream flow diversion for power generation would affect the amount of water available in the Project bypassed reach to support aquatic, riparian, and terrestrial resources. Furthermore, flows from the proposed Project would discharge into Whitewater Creek, potentially to altering stream morphology downstream of the Project tailrace. Stream morphology, in turn, is linked to the health of fish and fish habitat (e.g., spawning, rearing, and migration). Habitat in both Whitewater and Russell Creeks could be affected by the intended and unintended (i.e., emergency) ramping of stream flows during project startup and shutdown events. The requested information is necessary to evaluate the amount of water available for power generation and for the protection of environmental flow needs.

Results of the hydrology study would inform potential license articles pertaining to project operations, such as minimum instream flow needs within the bypassed reach of Russell Creek, flushing flows downstream of the diversion on Russell Creek, and ramping rates within both Russell and Whitewater Creeks downstream of the proposed diversion and tailrace, respectively.

The hydrology study would establish a baseline condition for the potentially affected stream reaches and provide data to be used to predict stream flows in Russell and Whitewater Creeks. Results of this hydrology study would inform potential license articles pertaining to water quality, fish, wildlife, and other resources. Characterizing the existing environment for potentially affected water quality parameters and describing the project’s potential effects on these resources is necessary for FERC to carry out their responsibilities under the NEPA, the Clean Water Act, the Endangered Species Act (ESA), and the Magnuson-Stevens Fishery Conservation and Management Act.

2.2.6 Study Methods §5.11(b)(1) & (d)(5)

The hydrology study would include:

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 Installation and service of pressure transducers for water level measurement at the intake location on Russell Creek and the tailrace location on Whitewater Creek;

 Measurement of stream discharge at hydrometric stations on Russell and Whitewater Creeks;

 Construction of a rating curve from which continuous stage data may be used to construct a stream flow hydrograph;

 Development of monthly flow duration curves based on the first year data collection; and

 Preparation of a report describing Russell and Whitewater Creeks hydrology including modeled long-term hydrological period for comparison to records from regional stream gages.

Installation of Gages and Recording Equipment

A Campbell Scientific (or similar) pressure transducer for water level measurement will be installed on Whitewater Creek downstream of the proposed tailrace. The pressure transducer will meet at the US Geological Survey (USGS) recommended accuracy requirements and will record at 15 minute intervals. This record interval is standard for documenting short-term flow fluctuations.

The applicant will establish a second hydrometric station capable of withstanding peak flows and debris on Whitewater Creek. This station will have direct read cables and power sources housed in a secure location sufficiently far back from contact with stream flows. An analog staff gage will be anchored adjacent to the hydrometric station to develop a manual stage record.

The pressure transducer and staff gage will be surveyed using a total station. By surveying these to a common datum the manual staff gage measurement will be used to calibrate the continuous stage record. The location of the sensor and data exchange interface will be clearly flagged and located in the field with GPS coordinates for ease of data retrieval on subsequent site visits.

Stream Discharge Measurement Sites

A professional hydrologist will lead the selection of discharge measurement sites during the Field Reconnaissance. Discharge measurement sites will be co-located with the hydrometric station to

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provide an accurate stage-discharge relationship. The hydrologist will select cross sections with uniform channel characteristics and within proximity to the hydrometric station. These are typically areas with exposed bedrock or pool tail-outs with fairly uniform, laminar flow. Cross section selection will adhere to the general principals and guidelines provided by the USGS (Rantz et al, 1982).

Conduct Discharge Measurements

The applicant proposes to conduct five discharge measurements over the course of the calendar year. Discharge measurements will span a wide range of stage heights so as to capture stage-discharge data throughout the low, middle, and top of the rating curve. All field methods will follow those guidelines provided by the USGS (Rantz et al., 1982). The discharge measurements will coincide with download of the data from hydrometric stations, as well as station maintenance and battery replacement. During the instream flow study the applicant’s contractors will conduct three to five discharge measurements throughout the summer. Every effort will be made to co-locate instream flow study transects with the hydrometric stations so these flow measurements can also contribute to the hydrology program.

Three potential methods will be used for obtaining stage-discharge data from Russell and Whitewater Creeks. These may include the velocity-area method (wadable stream; USGS 1983), the tracer dilution method (non- wadable stream; USGS) and the slope-area method (non-wadable; USGS 1985). Each is described in detail below.

The USGS midsection method (velocity-area) will be used when conditions are such that the entire channel can be safely waded. The method is based on protocols developed by the USGS (Rantz et al., 1982). The midsection method divides the stream into a number of vertical panels across the channel, and assumes that the velocity measured in each panel represents the mean velocity. Using the depth, width, and mean velocity, discharge is calculated for each panel. The summation of the panels is the total discharge for the stream.

Velocity will be measured using a Marsh-McBirney (or similar) current meter mounted on a top-setting wading rod. To complete a velocity measurement, the width of the active channel will be measured using the tagline installed previously to define the cross section. Stations on the left and right edge of water will be noted. The spacing of the panels along the tagline will be calculated based on the wetted width of the active channel

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divided by 25. Measurements will be spaced so no panel contains more than 10 percent of the total discharge. The ideal measurement will have less than five percent flow in any one panel, thus the cross section will typically be divided into 25 to 30 panels (Rantz et al., 1982). Flow depth and velocity will be measured with the March-McBirney top-set wading rod. If water depth is less than or equal to 2.5 feet, the mean velocity of the panel will be measured at 0.6-depth below the surface. If the water depth is greater than 2.5 feet, the mean velocity of the panel will be measured at 0.2-depth and 0.8-depth below the surface. The average of the two will be the mean velocity for that panel. Discharge notes for each panel will be recorded in the field on standardized USGS discharge forms.

Seasonal flows in Russell and Whitewater Creeks may occasionally make the streams unwadeable. Capturing discharges at these high flows is highly desirable, and accordingly, two methods of discharge measurement may be used depending on access and safety considerations. These may be either the tracer dilution or slope-area methods.

The tracer dilution method is well documented in Kilpatrick and Cobb (1985). This method involved injecting a known mass of salt or fluorescent dye into the stream at an upstream location. Then, at a downstream location, the ‘slug’ of salt or dye is measured by sensors located on each stream bank. Some assumptions of this method are that the stream reach chosen is sufficiently turbulent enough to fully mix the slug both laterally and vertically within the stream. The degree of dilution is proportional to the stream discharge. This method is very common and equally robust as the velocity area method. If the stream was both unwadable and contained smooth, laminar flow then the tracer dilution method would not be appropriate.

In the circumstance where neither the velocity-area nor the tracer dilution methods are able to be employed the third option is the slope-area method. This method requires physically surveying an adequate amount of cross section to develop a hydraulic model. The hydraulic model will be developed using previously collected topographic data of the channel and floodplain surveyed during the low flows. A one-dimensional model such as HEC-RAS (or similar) will be used to generate stage-discharge data based on the cross section and stream data.

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Quality Control

Quality assurance and quality control protocols will be carried out by professional field staff in order to obtain the most accurate discharge value. Proper selection of a good cross section and careful measurements of depth and velocity will produce accurate, reproducible discharge measurements.

All instrumentation will be calibrated prior to use and the calibration will be checked regularly during the course of the study. A record of all factory and field calibration of the current meter will be maintained. Field staff will “zero” the Marsh-McBirney current meter daily, according to manufacturer’s recommendations.

Topographic Survey

A topographic survey of the channel bed profile at each hydrometric station will be completed using a Nikon total station (or similar equipment). Topographic surveying and benchmark methods will follow those described by the USGS (1983). Survey data will enable staff to observe physical changes in the channel bed profile over time. The survey data also enables staff perform quality assurance checks of the discharge calculations.

Preparation and Evaluation of a Discharge Rating Curve

Two independent methods may be used to develop rating curves for Russell and Whitewater Creeks. The first will be a standard, mathematical regression. This traditional method correlates field discharge measurements to water level sensor height and/or staff gage readings, creating a regression formula of stage versus discharge. Data analysis functions in Microsoft Excel will be used to create a regression formula for stage-discharge data. Continuous stage data will be multiplied by the rating curve equation (regression formula) to convert the stage data into discharge.

The integrity of the regression formula will be assessed using a correlation coefficient (R2 value). A correlation coefficient close to 1.00 is an indicator of a regression formula with a ‘perfect fit.’ Employing detailed and methodical field methods while collecting stream discharge data, coupled with sound installation and selection of a stable geomorphic site location, will minimize errors during generation of a regression formula.

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In addition to the analytical methods outlined above, a professional hydrologist may employ the slope-area method to create a secondary rating curve for a quality assurance/quality control check of discharge measures using standard USGS field methods. Slope information, along with cross-sectional elevation surveys and discharge measurements, will be used to create precise discharge rating tables with the slope-area method.

By employing the abovementioned methods to generate robust rating curves the applicant will be able to accurately correlate instantaneous stage level recordings to a field-verifiable discharge. This type of survey effort is consistent with hydrology surveys completed for other hydroelectric projects.

Monthly Flow-Duration Curves

Using the data collected from the gages on Russell and Whitewater Creeks, a professional hydrologist will develop synthetic hydrographs (regionalization) using stream gage(s) from elsewhere in the region (e.g., USGS stream gages). Mean daily discharge will be used for the regionalization. Synthetic hydrographs of the mean daily discharge will be developed for the length of the regional data (e.g. 20 to 30 years). The applicant will solicit feedback from the resource agencies on appropriate gages for comparison during the study planning process and, if possible, obtain 20 to 30 years of stream flow data from the comparison gage(s).

The regionalization will use a regression approach in Microsoft Excel; whereby mean daily flow from each regional station are compared to mean daily flows from Russell and Whitewater Creeks. This process will identify the appropriate regional stations to be used and provide the regression equation to be used for the historic record.

Using the extended record of mean daily flows, the applicant will characterize the year-long stream flow measurements within the context of the range of historic flow conditions, and provide an estimate of the historic flow regimes of Russell and Whitewater Creeks during wet, dry, and baseline scenarios.

Once the regionalization is complete, two sets of monthly flow duration curves will be developed using the data from each gage: (a) one set generated by the recorded gage data at the diversion on Russell Creek; and (b) one set generated from the extended record of mean daily flows derived from other stream gage(s) in the region (18 CFR § 4.41[c][4][i]).

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The process will be repeated for the gage data in the location of the Project tailrace.

In the event that representative USGS hydrometric stations are not available for regional comparisons, a rainfall-runoff approach will be adopted. This uses local streamflow and regional precipitation data will be used to develop a runoff coefficient (rainfall/streamflow) for the watershed. The runoff coefficient can then be applied to regional historic precipitation data to determine the historic day, wet, and baseline flows.

The results of this effort will be used to compare pre-Project and post- Project conditions in Russell and Whitewater Creeks during wet, dry, and baseline scenarios.

2.2.7 Study Results §5.11(b)(3)

A report describing the results of the 2014/2015 study will be prepared at the end of the first study season and included in the ISR filed May 2015. The report will summarize the data and discuss the results in the context of the goals and objectives of the study plan. In addition, the results of the hydrology study will be used in concert with the results of the water quality and instream flow studies to prepare protection, mitigation, and enhancement plans.

2.2.8 Schedules §5.11(b)(2)

The hydrology study would be completed during the first study season of the ILP with an individual report prepared as part of the ISR. Field monitoring efforts will begin May 2014 and end April 2015. The applicant is aware that FERC, ODEQ, ODFW, and other stakeholders may request additional monitoring if additional data collection is warranted after the 2014/2015 study effort.

A draft report including the results of the hydrology study will be available for comment by all stakeholders at least 60 days prior to the 27 May 2015 initial study report meeting. The applicant will allow 30 days for stakeholders to comment and incorporate comments into the final report which is currently scheduled to be filed with FERC 12 May 2015.

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2.2.9 Level of Effort and Cost §5.11(d)(6)

The applicant estimates that the costs of the sampling equipment and labor associated with monitoring, data analysis, and reporting for the hydrology study will be $48,000.

2.2.10 References

Dalrymple, T., and Benson, M. A., 1984. Measurement of Peak Discharge by the Slope-Area Method. U.S. Geological Survey Techniques of Water- Resources Investigations, book 3, chap. A2, 19 p.

Kilpatrick, F.A., and Cobb, E.D., 1985, Measurement of discharge using tracers: U.S. Geological Survey Techniques of Water-Resources Investigations, book 3, chap. A16, 52 p.

Rantz, S.E. and others, 1982. Measurement and Computation of Streamflow: Volume 1. Measurement of Stage and Discharge. U.S. Geological Survey Water Supply Paper 2175. 313 p.

2.3 WETLANDS AND WATERS OF THE US DELINEATION

2.3.1 Goals and Objectives § 5.11(d)(1)

The objective of this study is to document the location and extent of jurisdictional wetlands/waters of the United States within the Project area.

2.3.2 Study Area

The wetlands and waters of the United States survey area will include:

 A 300-foot buffer on either side of the following proposed Project infrastructure: intake, powerhouse, tailrace, penstock route, and proposed new roads;

 A 150-foot buffer on either side of the proposed transmission line, and all existing roads that access the Project area off of Highway 22, including Forest Road 440 from Highway 22 to the powerhouse; the area along Highway 22 itself is excluded from the study area; and

 Along Whitewater Creek from the impoundment area downstream to the North Santiam River (total survey area of approximately 452 acres).

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2.3.3 Resource Management Goals §5.11(d)(2)

All jurisdictional wetlands within the United States are regulated by the USACE and the United States Environmental Protection Agency (USEPA). Completion of wetland surveys will aid the applicant in designing Project features that will minimize impacts on jurisdictional wetlands/waters of the United States and inform the design of appropriate mitigation if necessary.

2.3.4 Existing Information §5.11(d)(3)

The applicant is not aware if any formal wetland or waters of the United States delineation have been completed in the Whitewater Project Area.

2.3.5 Nexus to Project §5.11(d)(4)

The Project has the potential to affect jurisdictional wetlands and waters of the United State within the Project boundary. A wetland determination will identify the boundaries of jurisdictional wetlands, aid the applicant in expediting the 404 permitting process, and aid the design of subsequent mitigation measures if necessary.

2.3.6 Study Methods §5.11(b)(1) & (d)(5)

Routine wetland determination methods described in the 1987 Corps of Engineers Wetland Delineation Manual (1987 Manual) and the Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coastal Coast Region (Regional Supplement) will be applied throughout the survey area. Surveys will occur in concert with vegetation and wildlife habitat surveys. Circular plots with a 30-foot radius will be placed within representative areas to characterize vegetation, record hydrology indicators, and describe local soils. The 1987 Manual recommends using a 5-foot radius for herbs and saplings/shrubs, and a 30-foot radius for trees and woody vines (when present). The applicant has proposed the more conservative plot size and assumes trees will be present in the majority of the wetland/waters of the United States study area. In addition, 1-inch or 2-inch diameter hand augers may be used to take additional soil samples in the upper 18 inches of soil along the boundary of the wetlands in order to more accurately determine fine scale edges. Soil samples will be tested for the presence of reducing conditions with the aid of a ferrous iron test kit.

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The 1987 Manual has comprehensive field protocol for completing wetland delineations, including guidance on the number of transects and plots that would be established in the Whitewater Wetlands and Waters of the United States Delineation Study Area. The applicant assumes that “normal environmental conditions”, as defined in the 1987 Manual, occur within the project area and subsequently will follow the field protocol guidance for delineations greater than 5 acres.

The National List of Vascular Plant Species that Occur in Wetlands, and the United States Department of Agriculture Natural Resources Conservation Services Wetland Plants Database will be used to determine the wetland indicator status of each plant species. Five levels of wetland indicator statuses are applicable in the regional manual, (i.e., OBL, FACW, FAC, FACU, and UPL). Plus (+) and minus (–) modifiers are not appropriate under guidance of the regional supplement (e.g., FAC–, FAC, and FAC+ plants are all considered to be FAC). For species listed as NI (reviewed but given no regional indicator) or NO (no known occurrence in the region at the time the list was compiled), the indicator status assigned to the species in the nearest adjacent region will be recorded as part of the study. Evaluation of the vegetation will include but not be limited to a rapid field test for hydrophytic vegetation. The procedure as outlined in the regional supplement is as follows: (1) Apply Indicator 1 (Rapid Test for Hydrophytic Vegetation).

a) If the plant community passes the rapid test for hydrophytic vegetation, then the vegetation is hydrophytic and no further vegetation analysis is required.

b) If the rapid test for hydrophytic vegetation is not met, then proceed to step 2.

(2) Apply Indicator 2 (Dominance Test).

a) If the plant community passes the dominance test, then the vegetation is hydrophytic and no further vegetation analysis is required.

b) If the plant community fails the dominance test, and indicators of hydric soil and/or wetland hydrology are absent, then hydrophytic vegetation is absent unless the site meets requirements for a problematic wetland situation.

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c) If the plant community fails the dominance test, but indicators of hydric soil and wetland hydrology are both present, proceed to step 3.

(3) Apply Indicator 3 (Prevalence Index). This and the following step assume that at least one indicator of hydric soil and one primary or two secondary indicators of wetland hydrology are present.

a) If the plant community satisfies the prevalence index, then the vegetation is hydrophytic. No further vegetation analysis is required.

b) If the plant community fails the prevalence index, proceed to step 4.

(4) Apply Indicators 4 (Morphological Adaptations) and/or 5 (Wetland Non- Vascular Plants).

a) If either indicator is satisfied, then the vegetation is hydrophytic.

b) If none of the indicators is satisfied, then hydrophytic vegetation is absent unless indicators of hydric soil and wetland hydrology are present and the site meets the requirements for a problematic wetland situation.

Local soil survey information from the Natural Resources Conservation Service (NRCS) will be used in concert with information from the soils and geology study to determine whether listed hydric soils are present within the Project boundary. Detailed aerial photographs will be used to further discern vegetation patterns throughout the Project area. The boundaries of the wetland sites will be flagged and then mapped using survey data recorded with a GPS (accurate to within 3 meters), and superimposed on aerial photographs of the property. A wetland delineation report will be submitted to a regulatory specialist at the Portland District offices. The USACE is responsible for determining jurisdiction over wetland sites and the authority for issuing permits rests with them.

Other waters of the United States shall be determined and mapped based on the location of the ordinary high water mark, which generally leaves a physical mark on the landscape such as changes in vegetation from primarily aquatic to terrestrial, shelving, changes in soil types, and in many cases can correspond with the 2-year flood elevation.

The wetlands and waters of the United States study will be completed by professional environmental scientists with experience completing

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wetlands and waters of the United States delineations in Oregon. Additional information and justification for the delineation methods prescribed in the 1987 Manual as well as the regional supplement are on line at: http://www.usace.army.mil/missions/civilworks/regulatoryprograman dpermits/reg_supp.aspx. Copies of the field data sheets required for the wetlands and waters of the United States delineation can be found in Appendix F

2.3.7 Study Results §5.11(b)(3)

A report describing the results of the 2014/2015 wetlands and waters of the United States delineation effort will be included in the ISR filed May 2015. The report will summarize the data and discuss the results in the context of relevant study goals and objectives. The results of this study will be used to determine potential impacts and prepare protection, mitigation, and enhancement plans.

2.3.8 Schedules §5.11(b)(2)

The wetlands and waters of the United States study would be completed during the first study season of the ILP. The fieldwork portion of the study would be completed during the growing season in the summer of 2014. The applicant intends to coordinate sharing of relevant field information between contractors completing the botanical and wetlands and waters of the United Sates delineation studies.

A draft report including the results of the wetlands and waters of the United States delineation study will be available for comment by all stakeholders at least 60 days prior to the 27 May 2015 initial study report meeting. The applicant will allow 30 days for stakeholders to comment and incorporate comments into the final report, currently scheduled to be filed with FERC on 12 May 2015.

2.3.9 Level of Effort and Cost §5.11(d)(6)

The applicant estimates that the costs of the sampling equipment and labor associated with surveying, and reporting for the wetlands and waters of the United States study will be $20,000.

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2.3.10 References

Environmental Laboratory. 1987. Corps of Engineers Wetland Delineation Manual, Technical Report Y–87–1. U.S. Army Engineers Waterways Experiment Station, Vicksburg, MS.

Environmental Laboratory. 2010. U.S. Army Corps of Engineers Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys and Coast Region. Vicksburg, MS: U.S. Army Engineer Research and Development Center.

2.4 CULTURAL RESOURCES SURVEY

2.4.1 Goals and Objectives § 5.11(d)(1)

The objective of this study is to identify and protect the location of archaeological sites or traditional cultural properties that would be negatively impacted by the hydroelectric project.

2.4.2 Study Area

Section 106 compliance will begin with the applicant, Oregon State Historic Preservation Office (SHPO), the tribes, and the USFS working together to establish an agreed on Area of Potential Effect (APE). During the initial study season, on-site cultural resource field surveys will be completed by an Oregon SHPO approved consulting archaeologist within areas that will be permanently or temporarily displaced by Project features (Figure 3).

2.4.3 Resource Management Goals §5.11(d)(2)

Cultural resource surveys are designed to assist in implementing Section 106 of the National Historic Preservation Act (NHPA) 1966 (amended in 1976, 1980, and 1992). Implementing NHPA regulations requires federal agencies to consider the effects of their actions on historic properties. The Native American Graves Protection and Repatriation Act (NAGPRA) prohibits unauthorized excavation, destruction, or collection of Native American burials, graves, and affiliated cultural goods. The Archeological Protection Act prevents unauthorized excavation, removal, or damage of archaeological resources on federal land. The applicant has a responsibility to protect cultural resources and traditional cultural

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properties located on federal lands that may be affected by the construction and operation of the Whitewater Hydroelectric Project.

2.4.4 Existing Information §5.11(d)(3)

Existing information on archeological or traditional cultural sites or properties in the Project area has not been provided to the applicant. Upon FERC’s issuance of the study plan determination (SPD) a desktop review of existing sites and/or properties in the project area will be completed by an Oregon SHPO approved consulting archaeologist in cooperation with the USFS.

2.4.5 Nexus to Project §5.11(d)(4)

The information provided by the cultural resource survey will assist the USFS and other stakeholders in identifying and recommended appropriate protection measures for cultural resources and traditional cultural properties impacted by the project.

2.4.6 Study Methods §5.11(b)(1) & (d)(5)

The “Section 106 process” of the NHPA is being followed for this survey effort. Section 106 compliance will begin with the applicant, Oregon SHPO, the tribes, and the USFS working together to establish an agreed on APE.

A desktop review of existing sites and/or properties in the Project area, followed by an on-site comprehensive cultural resource assessment survey will be completed by an Oregon SHPO approved consulting archaeologist in cooperation with the USFS.

Research design and methodology shall be developed in accordance with the Willamette National Forest updated Cultural Resource Inventory Plan and SHPO’s Inventory guidelines. The research design and methodology will detail the survey methods that the Applicant will use to conduct the cultural resources inventory of the proposed Project APE, site recording procedures, the NRHP evaluation strategy, and methods for analyzing collected information. A discussion of the theoretical orientation of pre- contact and historic resources, research domains, and associated research questions shall also be included.

The survey effort and subsequent reporting will be completed to document archaeological sites or traditional cultural properties that could

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be directly impacted by the hydroelectric project. This type of cultural resource survey effort is consistent with other cultural resource survey efforts completed during the licensing proceedings for hydroelectric projects that include ground disturbance on federal land.

2.4.7 Study Results §5.11(b)(3)

A report describing the results of the 2014 cultural resources survey effort will be prepared at the end of the first study season and included in the ISR filed May 2015. The report will summarize the results of the APE efforts as well as the desktop review and subsequent field surveys in the context of the study goals and objectives. In addition, the results of the cultural resource survey effort will be used to prepare a draft Historic Properties Management Plan (HPMP) and an Inadvertent Discovery Plan (IDP).

2.4.8 Schedules §5.11(b)(2)

The cultural resource survey would be completed during the first study season of the ILP with an individual report prepared as part of the ISR. APE designation; review of existing information; and associated consultation with the Oregon SHPO, USFS, and tribes will begin in late May 2014 and the field surveys will be completed during the summer of 2014. The applicant is aware that additional pre-construction cultural resource surveys may be necessary if an APE is not agreed on by all parties during the first study season.

2.4.9 Level of Effort and Cost §5.11(d)(6)

The applicant estimates that the cost of defining the APE, completion of field surveys, data analysis, and reporting will be approximately $30,000.

2.5 AESTHETIC RESOURCES STUDY

2.5.1 Goals and Objectives § 5.11(d)(1)

The goals for the aesthetic resources study are to inventory and document baseline visual resource conditions within the project area and evaluate the potential effects to visual resources that may result from the construction and operation of the Whitewater Hydroelectric Project. Specific objectives include:

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 Evaluation of existing visual resource conditions in the vicinity of the Project;  Evaluation of the effect of project features on visual resources; and  Identification of design modifications and protection, mitigation, and enhancement measures to help reduce visual resource impacts.

2.5.2 Study Area

The study area includes areas from which reasonable views of Project infrastructure (temporary and permanent) are possible. The final Project viewshed and study area may be revised after consultation with USFS in the third quarter of 2014, after reviewing the most up to date design information in combination with the results of the completed seen area analysis. At the request of the USFS, the aesthetic resources study area has been expanded to include all lands bounded by Highway 22; Forest Roads 2242 and 040; Trails #2000, #3429, #3442; and 0.25 miles on each side of Highway 22 for the projects new transmission line.

2.5.3 Resource Management Goals §5.11(d)(2)

The Willamette National Forest Land and Resource Management Plan provides management direction for aesthetic resources in the Project area (USDA Forest Service 1990, as amended by the Northwest Forest Plan; USDA Forest Service and USDI Bureau of Land Management 1994). Chapter IV of the Northwest Forest Plan sets forth the Forest-wide Standards and Guidelines for a variety of resources and activities, including scenic resources. Scenic quality and recreation setting protection are addressed in the Willamette Forest Plan section FW-001 to FW-078 and management allocations MA-11d, MA-12b, MA-1, MA-1a-d, MA-6c, MA-11c, and 11f. The West Cascades National Scenic Byway Corridor Development Plan provides a current assessment of the byway as well as management recommendations for improvements along the byway.

2.5.4 Existing Information §5.11(d)(3)

The USFS provided the following Description of Existing Scenic Resources as part of their comprehensive Scenic Resources Study Request:

Russell and Whitewater Creek are glacier fed streams originating from Mt. Jefferson (10, 495’) within the Mt. Jefferson Wilderness. Geographic and scenic features include contiguous forest canopy, steep talus slopes, rock outcrops, alpine meadows and lakes. The Pacific Crest National Scenic Trail between

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Mexico and Canada winds along the spine of the High Cascades in this area. The Mt. Jefferson Wilderness and Inventoried Roadless Area is characterized by a continuous forest canopy in an undeveloped natural setting that offers recreational opportunities in a pristine and semi-primitive setting respectively.

Most visitors find the area outside of the Wilderness and Inventoried Roadless Areas a natural appearing with minor evidence of management activities within travel way viewsheds along Forest Service Road 2243 and State Highway 22. These roads meander through a continuous corridor of trees that presents occasional views of features (e.g. Mt. Jefferson, North Santiam River). Natural stands of mature trees with pockets of old growth and older managed stands are interspersed along these roadways. Past regeneration harvests (clearcuts) are no longer in a “disturbed condition” as they have grown and recovered for over a decade. These travelways are managed to meet “Retention” Visual Quality Objectives or a “High” scenic integrity under SMS. The desired landscape character under this management objective appears unaltered and intact, where management activities are not evident. Deviations to landscape character (e.g., form, line, texture, color, and pattern) may be present but in such a way that is completely subordinate to the unaltered character of the landscape and is not evident to the viewer. Late Successional Reserve with management objectives to protect and enhance conditions of late successional and old-growth forest ecosystems would be the landscape character expressed within the Project area through time.

The West Cascades National Scenic Byway is a 220-mile route that includes the Cascade Mountains, several rivers, old growth forests, waterfalls, lava flow and lakes such as nearby popular Detroit Lake. The Project area transmission line and ancillary facilities is along a 6-mile segment of the scenic byway and the North Santiam River, an agency identified (5d) eligible (study) Wild and Scenic River with a scenic Visual Quality Objective of “Retention.” The byway is a highly traveled Scenic route with 1.28 million vehicles a year. Its national status and tourism marketing efforts attract people to travel the corridor to experience the West Cascades. Three trailheads for trails (Whitewater #3429, Woodpecker #3442 and Cheat Creek #3441) originate near the Project that access Mt. Jefferson Wilderness, and key scenic features including Jefferson Park, Mt. Jefferson and The Pacific Crest National Scenic Trail (No. 2000). There is a need to collect additional information in order to determine impacts on aesthetic resources and compliance Forest Plan standards and guidelines.

2.5.5 Nexus to Project §5.11(d)(4)

The Whitewater Hydroelectric Project has potential to affect aesthetic resources within and adjacent to the Project boundary that may include

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designated viewsheds, recreation areas, wilderness, inventoried roadless areas, a scenic byway, a national recreation trail, and an eligible wild and scenic river.

2.5.6 Study Methods §5.11(b)(1) & (d)(5)

The applicant proposes a two phase approach beginning with a project visibility determination followed by a viewshed analysis within the study area.

Seen Area Analysis

A preliminary project visibility determination “seen area” analysis will be completed by using a combination of Geographic Information System (GIS), bare-earth digital elevation models, 3D models of Project infrastructure, and site-specific data for canopy height (if available). A viewshed map will be prepared based on a line-of-sight analysis of visible project infrastructure before mitigation measures (such as vegetation barriers, architectural alteration, etc.) are incorporated into the project design. The viewshed map will be used to verify the size of the aesthetic resources study area in consultation with the USFS, as well as the full scope of the second phase of the aesthetic resources study.

Viewshed Analysis

The results of the seen area analysis will be used in concert with stakeholder input to determine sensitive viewing areas where project features may be able to be seen by individuals. A preliminary list of sensitive viewing areas provided by the USFS includes:  Travel routes such as Road 2243 and designated scenic byways (Highway 22);  Wild and scenic rivers corridor where recreation sites/activities take place;  Wilderness and inventoried roadless areas; and  Recreation sites, cabins, and trails, including the Pacific Crest National Scenic Trail.

Sensitive areas would be field verified by professionals with experience completing hydropower viewshed analyses to determine if temporary or permanent Project features could actually be viewed from these locations. Key observation points (KOPs) will be established in consultation with the

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USFS representing sensitive areas with views of the project features. Final KOP locations will be based in part on the following characteristics:  Provides the most representative view of the Project for a given area and portion of the Project.  Provides the greatest potential number of receptors (i.e., potential viewers) that will be able to actually see the Project.  Is a relatively common and/or sensitive view within the aesthetic resources study area that could be affected by the Project.  Is a relatively good location that can be used to measure anticipated change in visual resources resulting from the Project.  Provides new opportunities for views, based on potentially new public access from roads/corridors.

Analysis locations will differ by landscape analysis factors (i.e., distance from the Project, predominant angle of observation, dominant use, common or sensitive receptors). Once the KOPs are selected, still photographs to document existing visual conditions will be collected using a digital camera with an integrated GPS unit. Photo documentation will be completed by setting a tripod up at the designated location, lining up the camera at the same position as previously recorded, and taking photographs in a sweeping panorama from left to right to cover the complete view of Project features from a specific KOP.

Project infrastructure photomontages will be prepared using a panorama of digital still-photos of existing baseline conditions, rendered with simulated project infrastructure from 3D models. Photomontages are high-resolution still-images of an existing view taken from a KOP. They are then digitally edited (rendered) to illustrate Project components in a realistic manner depicting the structures, textures, colors, and finishes that appear realistic to the human eye. The photomontages will be prepared to document Project infrastructure from KOPs. Field locations will be recorded using a hand-held GPS unit and a GPS enabled digital camera to ensure that photographs can be taken in the exact same location during follow-up efforts.

A digital terrain model (DTM or model) will be constructed for the Project area using topographical surveying data collected for the Project. Once the DTM is complete, the 3D models of the project infrastructure will be placed on the DTM according to exact geographic coordinates, along with the photographs taken from known KOP locations. The photographs and

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3D models will be superimposed on top of each other to produce photomontages showing the project components accurately simulated within the existing landscape.

Field data and photographs from KOPs within the project viewshed will be used to characterize the existing visual conditions and landscape character in the study area using the USFS’s Scenery Management System. Common factors considered when evaluating the character of the existing landscape will include visual quality, viewer concern, and viewer exposure. Visual quality measures the overall scenic value or attractiveness of the landscape by considering the landform, vegetation, rock form, water features, cultural features, and built structures of the area. Viewer concern accounts for the relative importance placed on visual resources by viewers of an area, based on management goals, existing land uses, and available information about viewer interests and concerns. Viewer exposure assesses the visibility of the landscape or project infrastructure relative distance from the observer, number of viewers, and duration of view of the landscape and project infrastructure by viewers in the area. These three factors will be evaluated based on available information and professional judgment to make a determination about the sensitivity of the existing landscape to visual change, as well as project effects on scenic integrity and visual quality objectives. A landscape with a low degree of visual sensitivity can accommodate a higher degree of visual change before significant visual impacts are encountered.

Once the existing visual conditions have been evaluated, an assessment will be completed that evaluates the visual changes resulting from the proposed project and the significance of the changes to the existing visual conditions. Impacts of the project during both construction (temporary impacts) and operation (permanent impacts) will be evaluated. Details of the Project used to complete this evaluation will include Project plans, schedules, maps, and drawings, as well as renderings of the completed project within the existing landscape. Simulations of the Project will be developed using photographs from select KOPs that provide good vantage points of the Project or are of particular viewer concern. The photographs will be modified to include simulations of completed project components, including project infrastructure and/or other Project features, to evaluate the effect that the Project would have on the visual resources within the Project viewshed following Project development.

The factors considered when evaluating the visual change as a result of the Project will include visual contrast (form, line, color, and texture) of the Project relative to existing conditions, Project dominance relative to

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existing landscapes and features (natural and built environment), extent of blockage or impairment of existing views, and overall disruption of the Project on existing visual conditions. These factors will be combined into an overall rating to evaluate the degree of change resulting from the Project. The significance of the changes at a particular KOP will then be evaluated by comparing the visual sensitivity of the view from the particular KOP with the degree of visual change created by the Project. This type of aesthetic resources study is consistent with other aesthetic resource studies completed during the licensing proceedings for other FERC regulated hydroelectric projects.

2.5.7 Study Results §5.11(b)(3)

A report describing the results of the 2014/2015 aesthetic resources study effort will be prepared at the end of the first study season and included in the ISR filed May 2015. The report will summarize the data and discuss the results in the context of relevant study goals and objectives. The results of this study will be used to determine potential impacts, as well as prepare protection, mitigation, and enhancement plans.

2.5.8 Schedules §5.11(b)(2)

The applicant proposes to complete the “seen area analysis” and define the aesthetics study area in cooperation with the USFS in June and July 2014. Establishment of KOPs and associated field activities would occur in August 2014 with the subsequent analysis and reporting efforts completed during the fourth quarter of 2014 and the first quarter of 2015.

A draft report of the aesthetic resources study will be available for comment by all stakeholders at least 60 days prior to the 27 May 2015 initial study report meeting. The applicant will allow 30 days for stakeholders to comment and incorporate comments into the final report currently scheduled to be filed with FERC on 12 May 2015.

2.5.9 Level of Effort and Cost §5.11(d)(6)

The applicant estimates that the costs of completing the “seen area analysis” and the subsequent study area determination will be approximately $25,000. An accurate cost assessment for the viewshed analysis cannot be determined until the completion of the “seen area analysis” and subsequent consultation with the USFS.

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2.6 BYPASS REACH INSTREAM FLOW AND AQUATIC HABITAT STUDY

2.6.1 Goals and Objectives § 5.11(d)(1)

The Whitewater Hydropower Project is a proposed run-of-river hydropower project in Whitewater and Russell Creeks, Oregon. The goal of this study is to gather information that can be used to analyze Project effects on aquatic habitat in the bypass reach and to determine a flow regime that would protect existing aquatic resources including habitat and fish species in the project bypass reach (18 CFR § 5.18[b]).

Water demands for project development propose flow reductions in the bypass reach. Given the complexity of habitat changes with flow levels, a conventional instream flow study (IFS), using a modified Instream Flow Incremental Methodology (IFIM) (Bovee 1982; Bovee et al. 1998), is proposed for the Project.

This work plan outlines the proposed methods and rationale for the instream flow needs assessment on the Project. The proposed methods were selected to provide federal and state regulators with sufficient detail to assess potential effects resulting from Project development. The IFS will be used to quantify incremental changes to flow levels and, in turn, incremental changes to fish habitat. The IFS will provide direct insight into potential project effects within the bypass reach as associated with flow reductions. In addition to this, the IFS will provide the flexibility of assessing potential flow-related mitigation options that may be considered for the Project.

2.6.2 Study Area

The study area for the instream flow and aquatic habitat study includes the bypass reach(es) of Russell and Whitewater Creeks that could potentially be impacted from the Project.

2.6.3 Resource Management Goals §5.11(d)(2)

Sections 4(e) and 10(a) of the FPA require FERC to give equal consideration to all uses of the waterway on which a project is located. When reviewing a proposed action, FERC must consider the environmental, recreational, fish and wildlife, and other non-developmental values of the Project, as well as power and developmental values. The requested information is needed to characterize the fishery resources and aquatic habitat in Project waters and would help inform the appropriateness of protection and enhancement

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measures at the Project, necessary to fulfill FERC’s responsibilities under the NEPA. This evaluation is relevant to FERC’s public interest determination.

The Oregon Department of Fish and Wildlife (ODFW) is the state agency with jurisdiction over fish and wildlife in Oregon (ORS 496.012; the Fish and Wildlife Coordination Act at 16 USC § 661 and 662; the Federal Power Act at 16 USC § 803 & 811). The ODFW will file recommendations with FERC to protect, mitigate damages to, and enhance fish and wildlife affected by the operation and management of the project.

2.6.4 Existing Information §5.11(d)(3)

Coastal Cutthroat Trout (Oncorhynchus clarkii clarkii) are confirmed present in the bypass reach based upon recent USFS assessments. The USFS also stated that Brook Trout (Salvelinus fontinalis) are possibly present in the bypass reach.

The National Marine Fisheries Service has provided a letter to the applicant stating that the location of the proposed project is upstream of the documented extent of anadromous fish use within the North Santiam Basin.

2.6.5 Nexus to Project §5.11(d)(4)

The proposed Project has the potential to affect fish and aquatic habitat of both Russell and Whitewater Creeks during construction and operation. Information describing aquatic habitat in Russell Creek from the upstream most point of the Project impoundment downstream to its confluence with Whitewater Creek is necessary to assist in determining the potential extent of Project effects in the bypassed reach, and the appropriateness of protection and enhancement measures, such as construction timing and minimum flows.

The applicant proposes to divert up to 138 cfs from lower Russell Creek into Whitewater Creek for the purpose of power generation and subsequently create a 3.7-mile-long bypass reach. An instream flow habitat-based study for the bypass reach is necessary to assess the effects of Project operation on the availability of aquatic habitat. Specifically, the study would allow for an assessment of the effects of a range of potential bypass reach flow releases, including the minimum instream flow proposed in the preliminary application document, on aquatic habitat in the bypass.

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2.6.6 Study Methods §5.11(b)(1) & (d)(5)

Instream Flow Model Selection Rationale

The most widely accepted methodology for characterizing the effects of flow alterations on fish habitat is the IFIM. The IFIM was designed to aid scientists and resource managers in evaluating stream flows at small incremental changes in order to identify a ‘desired’ resource state. The IFIM is a comprehensive methodology within which there are a number of options that can be used to provide instream flow recommendations on the trade-offs between habitat protection and water demands of the Project. IFIM links traditional hydraulic engineering models to fish habitat suitability curves based on water depth, velocity, and bed particle size.

System of Environmental Flow Analysis (SEFA), an IFIM, is proposed for the Project (Jowett et al. 2013). SEFA contains one-dimensional hydraulic- habitat analysis, habitat suitability criteria development, water temperature modeling, sediment transport analysis, riparian modeling, time-series analysis, and externally references to legal-institutional analysis and two-dimensional hydraulic modeling. This is followed by hydraulic simulations to estimate habitat availability at different flow rates, for each species, and each life stage (Milhous, Wegner, and Waddle 1984). Field measurements of depth, velocity, substrate, and cover are taken along stream transects at different flow rates to adequately calibrate the model. The models are then used to predict incremental changes to available habitat, at different flow rates.

SEFA was designed to measure the amount of microhabitat available for fish at different life stages, and at different flow levels. Weighted usable area (WUA) is the model output and the metric used to determine minimum instream flow needs for specific species and life-stages. The WUA would be generated for both pre-development and operational conditions. To that end, SEFA provides sophisticated, incremental results by using the field data generated following the field procedures described below. The model results from SEFA are then able to be used to form an understanding of the trade-offs between flow reductions and instream flow needs. It is for this reason that ERM proposes to use SEFA and a modified IFIM approach to quantify the instream flow needs on the Project.

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Pre-Field Tasks

Fisheries Resources

Relevant fish and fish habitat reports specific to the study area will be obtained from regulatory agencies. These include the 1994 Whitewater Creek Level 2 fish habitat assessment, and a 1976 Russell and Whitewater Creeks fish assessment (D. Neff, pers. comm.). Relevant fish and fish habitat information from a regional perspective will be reviewed from a variety of sources including regulatory agencies and consultant reports. This information will be reviewed prior to selecting appropriate Coastal Cutthroat Trout HSI curve. This review will commence prior to initiating fieldwork to assist in determining fish presence/absence, life history timing, fish habitat distribution, and quality.

Stream Habitat and Hydrology

Prior to initiating any field work, it will be important to have a general understanding of physical stream features present within Whitewater and Russell Creeks. To assess the physical stream features, a number of data sources will be obtained. This includes historic physiographic data, hydrology and geology data, aerial photos, topographic information, 1994 Whitewater Creek Level 2 fish habitat, and any other source that will support this understanding.

As per the USFS Level 1 habitat assessment in the Stream Inventory Handbook (USFS 2010), preliminary reaches will be determined and mapped for Whitewater Creek (North Santiam River confluence to reach upstream of Russell Creek confluence), and Russell Creek (Whitewater Creek confluence to lake). This will be done with information gleaned from GIS layers, topographic maps, or thophotographs, and aerial photographs for Whitewater and Russell Creeks.

The following forms will be completed for the Level 1 habitat assessment:  Preliminary reach form (Form R6-2500/2600-20); and  Map of the target stream reaches showing preliminary reach breaks, access points, road crossings (culverts, bridges, etc.), and other points of interest that will help orient the field assessment.

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Hydrological Methods

Objectives

The program will provide information on hydrology and geomorphology within the bypass reach(es) that may be affected by the proposed Project. The overall objectives of the hydrology component are to:  Assess the hydrogeomorphic units present within the Russell and Whitewater Creeks;  Characterize stream hydraulics within Russell and Whitewater Creeks with a detailed emphasis on quantifying mesohabitats within the bypass reach(s); and  Develop a robust instream flow model capable of providing detailed insight on incremental changes in fish habitat commensurate with incremental changes in flow.

A hydrologist and fisheries biologist will establish stream transects for the purposes of instream flow habitat modeling after completion of the Level 1 and Level 2 habitat assessment. These transects will be stratified by mesohabitat units (e.g., pools, riffles and glides) present within the bypass reach(es). Selection will be based on the habitat preferences of Coastal Cutthroat Trout life history stages (e.g., adult, juvenile) likely to utilize the bypass reach(es). The instream flow assessment will also consider side channel, off-channel, and wetland morphological features within the bypass reach(es).

Each selected mesohabitat unit within the bypass reach(es) will require adequate field data to characterize its natural range of variability. The field program will include the collection of topographic, hydraulic, and geomorphic field data to support modeling incremental changes to flow and subsequent changes to depth, velocity, and substrate availability.

Hydrogeomorphic Units

Over the last two decades significant focus has been paid to the linkages between ecology and the physical stream environment, where abiotic stream processes have been internationally recognized as key components of aquatic ecosystem structure and function (Zavadil and Stewardon 2013). One of the fundamental focal points of eco-geomorphology has been to refine the conceptual understanding of spatial organization in riverine ecosystems. This body of research has identified three important

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scales to consider in riverine ecosystems; these include: the meso, reach and segment scales.

Segment scale units are generally defined from broad-scale changes in topography, geology, hydrology, and subsequently, stream character; thus being referred to as hydrogeomorphic units. Prior to the installation of transects it will be necessary to implement a segment break assessment to determine the stream character and presence of hydrogeomorphic units. The Level 1 and 2 habitat assessment will be a key tool to inform this process.

Transect Locations

A representative study reach will be selected for the instream flow assessment. The location of the representative reach will be determined by results from the Level 1 and 2 fish habitat assessments, segment break analysis (hydrogeomorphic units), background fisheries information, and proposed infrastructure locations. Where more than one hydrogeomorphic unit exists, it will be necessary to find agreement between agencies on the scope of the IFS; such that, ERM recommends that a representative reach for the IFS does not span multiple hydrogeomorphic units. Should agencies be interested in performing an IFS on mesohabitats from more than one hydrogeomorphic unit, ERM recommends that:  Each hydrogeomorphic unit be characterized separately;  A representative reach be selected from each hydrogeomorphic unit of interest;  Life stages/mesohabitat are separated and not aggregated between hydrogeomorphic units; and  Each life stage/mesohabitat to be characterized, within each hydrogeomorphic unit, be given no less than five transects.

Specific transect locations will be determined in consultation with regulatory agencies. ERM recommends the installation of five transects to characterize each life stage/mesohabitat of Costal Cutthroat Trout, within each hydrogeomorphic unit selected. In general, each life stage will correspond to a specific mesohabitat (pool, riffle, and glide). To adequately characterize each mesohabitat/life stage it is necessary to install enough transects to represent the range of natural variability observed for that mesohabitat. It is generally accepted that five transects are adequate to represent the range of natural physiographic variation for

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a single mesohabitat, within a single hydrogeomorphic unit. The total number of transects for this study will be determined after the Level 2 habitat assessment is complete, as the habitat assessment will provide information on mesohabitat presence, abundance, and distribution.

In addition to accurately characterizing the range of natural variation within the mesohabitats, it will also be necessary to characterize the range of water levels that can be expected for the Project. A total of five flow measurements will be conducted at each transect to develop rating curves and habitat-flow relationships (Table 1). This will further provide an opportunity to develop validation data (measured vs. modeled) at strategic flow levels.

Benchmarks

Three benchmarks will be established for each mesohabitat transect (USGS 1982). In some cases a series of three benchmarks may be able to be used for more than one transect, when longitudinal spacing and riparian visibility allowed. During the initial survey all benchmarks will be surveyed three times, systematically back sighting on each of the three benchmarks, one at a time, in order to calculate survey error. Survey error will be < 1/16” for each mesohabitat transect.

Staff Gauges

Staff gauges will be installed and surveyed for all transects. Rebar (3/8 inch) will be used for the staff gauges and, where possible, installed near the stream bank in a protected location (USGS 1982). Some staff gauges will be installed in the center of the stream to allow for low flow measurements. Staff gauges will be specifically located along all transects with the offset distance recorded. Subsequent water surface elevations will be measured relative to the top of the staff gauge which will be surveyed to a local site datum, as all benchmarks and channel cross- sections.

Channel Cross-Section Survey

During the initial establishment of each transect a channel cross section will be surveyed to a local datum. Rebar (3/8 inch) or spikes in trees will be used as transect end points to mark the left and right banks. In every case these end points will be located outside of the bankfull width. The spatial resolution of the cross section surveys will be proportional to the

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channel width, but in most cases there will be approximately 1 or 2-foot spacing between survey points. This approach will provide detailed cross sections built from 30 to 50 points for each transect.

Water Surface Elevations and Stream Gradient

Water surface elevations will be surveyed along the stream cross section, on the right and left sides of the wetted width, during the initial survey of each transect (USGS 1982). Additional water surface elevations will be surveyed at two points 65 feet upstream (left and right sides of wetted width) and two points 65 feet downstream, where riparian visibility and channel form permit. Where the wetted edge is not visible, 65 feet upstream or downstream, modifications will be made. Stream and bed gradients will then be calculated over a 130-foot stretch, using the upstream and downstream distance and water surface elevations for this calculation.

Stream Hydraulics

Water depth and velocity measurement will be conducted following the USGS Hydrometric Standards (1982). During the initial setup of each transect the channel cross section will be surveyed such that no less than 25 survey points (offsets) are located within the wetted width, along with enough points outside of the wetted width to characterize the un-wetted portion of the cross section. This will ensure that:  Discharge data collected for the IFS meet those requirements laid out by the USGS;  Hydraulic data for the velocity distribution factors are based on greater than 25 vertical panels across the streams; and  Survey flow data will be collected at a strategic water level to ensure successful model calibration.

Information on stream substrates will be collected during the initial setup and survey. Substrate data will be collected following appropriate state methods. At all offsets within the bankfull points substrate data will be collect and recorded in percent. Size classes will be consistent with the Stream Inventory Handbook (USFS 2010).

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Overall, the hydraulic data to be collected at each stream panel will include:  Cross section distance (feet);  Offset distance (feet);  Water depth (inches);  Substrate (percent composition);  Transect width (feet);  Stream bed elevation (feet);  Mean water velocity (feet/second); and  Cover (presence/absence)

Calibration Flows

To attain high quality flow measurements during subsequent calibration flows, stream discharge will be measured at glides (tailouts) and will not be measured at riffles and pools. The reason for this is that glides produce laminar flow, which is absent of turbulence, and meets the operating guidelines of common velocity instruments. In practice, each hydrogeomorphic unit, of each stream, may have five or more glides. Thus, discharge for each specific mesohabitat transect can be based on either the nearest glide or the average of all five glides in that hydrogeomorphic unit. This approach provides the flexibility of averaging five discharge measurements per hydrogeomorphic section, in addition to providing microhabitat data (depth and velocity) at additional calibration flows. Micro-habitat data from these two calibration flows will be used to validate model results by comparing the modeled depth and velocity data against the measured depth and velocity data.

Biological Methods

Objectives

The baseline program will provide information on fish and fish habitat within the bypass reach(es) that may be affected by the proposed Project. The objectives of the fish and fish habitat program are as follows:  Assess fish habitat within Russell and Whitewater Creeks, with a detailed emphasis on quantifying mesohabitat availability specific to

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life stages of Coastal Cutthroat Trout present within the bypass reach(es);  Determine fish presence, community composition, population demography, distribution and barriers to fish movement within the bypass reach(es) of Russell and Whitewater Creeks;  Select appropriate Coastal Cutthroat Trout habitat suitability index (HSI) curves, and validate the HSI curves with empirical site specific data (if achievable); and  Determine mean density of fish within the within the bypass reach(es) of Russell and Whitewater Creeks using single pass electrofishing surveys.

Fish Habitat

Fish habitat within Whitewater and Russell Creeks bypass reach(es) will be assessed according to the USFS Level 2 habitat assessment in the Stream Inventory Handbook (USFS 2010). In 1994, a USFS Level 2 habitat assessment was conducted for Whitewater Creek. This previous assessment is useful for characterizing habitat presence, habitat extent, mesohabitat composition, and distribution. However, the horizontal and vertical shifts typical of alluvial channels have likely changed the exact locations of mesohabitat features. Therefore, it is necessary to resurvey the Whitewater Creek bypass reach(es).

The bypass reach(es) will be ground-truthed and mapped with a differential GPS unit during June to characterize existing habitat conditions. The completion of the USFS Level 2 habitat assessment will serve as a basis for selecting appropriate transects for the instream flow assessment.

The field crew will comprise of two people with each member responsible for specific tasks. The "Estimator" will focus on the identification of channel unit characteristics. The "Numerator" will focus on the counts and relative distribution of several unit attributes and will verify the length and width estimates for a subset of units. The "Estimator" and "Numerator" share the responsibility for describing reach characteristics, riparian conditions, identifying habitat unit types, and for quantifying the amount of large woody debris. The following forms will be completed for the Level 2 habitat assessment:  Final reach form (Form R6-2500/2600-21)

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 Channel unit form (Form R6-2500/2600-22)  Special cases form, if applicable (Form R6-2500/2600-23)  Wolman pebble count form (Form R6-2500/2600-32)

The stream habitat data discharge form (Form R6-2500/2600-31) will not be completed as discharge at the time of the survey can be obtained from the existing hydrometric station.

Stream temperature data loggers will be mounted to rebar within the following sections of Russell and Whitewater Creeks:  Russell Creek, at the intake diversion;  Whitewater Creek, downstream of the Russell Creek confluence;  Whitewater Creek, between Sentinel Creek and Cheat Creek confluences; and  Whitewater Creek, downstream of the penstock tailrace.

Backup temperature data loggers will be installed at each of the above locations. Continuous hourly stream temperature will be collected during the open water period from the June to October 2014 and April to May 2015.

Fish

Habitat Suitability Index Curve Selection

Peer reviewed Coastal Cutthroat Trout depth, velocity, and substrate HSI curves will be collated and reviewed. Based upon this review, the most relevant Coastal Cutthroat Trout depth and velocity HSI curves will be selected for the habitat model. This is an acceptable approach and is classified as a Category I criteria curve in the Development and Evaluation of Habitat Suitability Criteria for use in the Instream Flow Incremental Methodology (Bovee 1986). This approach has been applied in numerous instream flow projects (e.g., City and Borough of Sitka Electric Department 2005; Sutton and Morris 2004; R2 Resource Consultants 2004). Following the identification of suitable HSI curves, selection of the most appropriate curves will be done in consultation with resource agencies.

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Fish Distribution and Average Density

The core of the fish study will:  Determine fish distribution and habitat utilization; and  Analysis of fish average density by determining ratios of habitat utilization to habitat availability.

Juvenile and adult rearing electrofishing surveys will occur during September and October within the bypass reach(es). The months of September and October, precipitation freezing at higher levels, was selected based upon communication with USFS District Fisheries Biologist (D. Neff, pers. comm.) because discharge is typically lower and water clarity is greater compared to summer months. The effectiveness of electrofishing surveys will be influenced by weather and its effect on discharge and water clarity. To mitigate weather effects, the following guidelines will be adopted for field assessments:  Review the weather forecast to avoid sampling during predicted periods of warm air temperatures and high rainfall events as these factors increase glacial melt.  Review freezing elevation data as higher freezing elevation forecasts increase glacial melt.  Review USGS hydrometric data to plan for sampling during lower discharge periods.  Conduct sampling during the morning and periods of high cloud cover (if possible).

The number of sampling sites to be sampled will depend on the results of the Level 2 habitat assessment. However, sample sites will be stratified by mesohabitat type and the sampling distribution will be throughout the bypass reach(es). The field methods will typically follow those presented within Salmonid Field Protocols Handbook (Johnson et al. 2007), and are outlined as follows:  Prior to each survey, a turbidity reading will be taken to determine the visibility for sampling.  The weather conditions and water temperature will be recorded at the start and end of the survey.

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 Given the small creek size, one electofisher and one netter will be used, and proceed in an upstream direction making observations of all microhabitat types within their line of sight.  When a fish is captured the following information will be recorded: o Fish species; o Fish length (millimeter); o Substrate use classification; o Proximity/affinity to habitat structure/cover features (e.g., boulder, undercut bank, overhanging vegetation, large woody debris); o Relevant comments pertaining to cover associations; o Mesohabitat type; o SO unit number; o Area electrofished per mesohabitat type (feet2); and o UTM location.  Subsequent to capturing a fish, the field crew will proceed to the fish location and collect the following information: o Water depth – measured to the nearest 0.1 feet using a top setting rod; o Mean column velocity – measured using a Swoffer Model 2100 current meter; and o Substrate classification.

The field data will be checked for data entry accuracy, collated, and analyzed. Fish rearing distribution will be mapped within the bypass reach(es). Fish rearing distribution data will be calculated and presented as:  Number of sites per habitat type/stratum (i.e., mesohabitat) electrofished; and  Percent fish occupancy per habitat type/stratum (i.e., mesohabitat).

Single pass electrofishing mean fish density will be calculated by species, mesohabitat type, and life history stage, according to the objective based recommendations within Salmonid Field Protocols Handbook (Johnson et al. 2007). Fish rearing distribution data will be calculated and presented as

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density of fish per square feet per electrofished habitat type/stratum (i.e., mesohabitat).

Standard error of the mean is a descriptive statistic related to the precision of the data. Standard errors will be reported, since we are primarily concerned with precision of the mean (Guy and Brown 2007). Catch and abundance data is typically not normally distributed (i.e., negative binomial distribution; Guy and Brown 2007). Therefore, bootstrapping techniques will be used to derive means and percentile bootstrap +/-95 percent confidence intervals for the density data. Bootstrapping is accomplished using 10,000 resamples from original density dataset (Guy and Brown 2007).

HSI Curve Validation

Sufficient sample size of fish observations for each Coastal Cutthroat Trout life history stage, are required to validate the previously selected HSI curve. A target of 25 to 50 fish observations per life history stage are typically required for instream flow studies, which is based upon IFIM recommendations (Bovee 1986). However, it is recognized that field conditions (low water clarity, low water temperatures) and habitat (high gradient, high velocity, cascade mesohabitats) will have an influence on fish abundance in the bypass reach(es), which dictate the ability to validate the HSI curve.

Depth, velocity, and substrate data will be collected for captured juvenile rearing and adult rearing Coastal Cutthroat Trout (see above). However, the adult and juvenile rearing HSI curve may not be validated depending on the number of fish captured. The Coastal Cutthroat Trout adult spawning HSI curve will not be validated, because of difficulties in determining spawning timing (D. Neff, pers. comm.).

If determined to be appropriate (based on sample size), field validation data will be analyzed and compared to the selected HSI curves. Data will be sorted according to species type and life-history stage. Frequency distributions will be generated for mean velocity, depth, and substrate type for each species and life history stage. An appropriate frequency bin width will be determined based on the field data to evaluate the mean velocity and depth utilization distributions. Histogram plots of depth and mean column velocity utilization will be produced. The frequency distribution of the field observations will be converted into HSI curves by scaling the distribution between 0 and 1 (utilization values divided by the maximum value observed). Based on this cross-validation analysis, the

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Coastal Cutthroat Trout HSI curves will be adjusted using an abbreviated convergence method approach (Bovee 1986), if required, in consultation with resource agencies.

Modelling Approach

Model

ERM will use SEFA to characterize habitat-flow relationships in the mesohabitats required to support each life-stage of Coastal Cutthroat Trout. Surveyed water surface elevations and flow measurements will be used to calibrate the model, in addition to channel conveyance parameters, and roughness factors. Water depth and velocities will then be fitted to the calibrated model; once calibrated, the model will be validated against measured water depths and velocities (calibration flows).

The SEFA model will combine hydraulic data (depth, velocity, and substrate) with HSI curves to generate an area weighted index of available habitat quality and quantity. Habitat mapping results, combined with the area weighted values will then be used to generate the WUA for each flow scenario.

Flow Scenarios

Various flow scenarios will be selected to model incremental changes to fish habitat. The flow scenarios to be selected will depend on a number of factors such as, species life history timing and operational regimes of the Project. To that end, flow scenarios to be modeled will be developed in consultation with resource agencies. These may include, but will not be limited to: mean annual discharge; mean monthly discharge; the regulated instream flow release; the 50 percent naturalized exceedence flow, the 80% naturalized exceedence flow; flushing flows and maintenance flows; and extreme low and high flows.

Quantifying Incremental Habitat Change

Each selected flow scenario will be used to quantify change in available Coastal Cutthroat Trout habitat. Naturalized and operational flows on habitat availability will also be compared for all months. A habitat index will be generated for each flow scenario and expressed either as area weighted suitability (AWS), WUA, and/or combined suitability index (CSI).

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Large Woody Debris Recruitment

Large woody debris is an important component of aquatic ecosystems, contributing to the geomorphic processes such as streambank stabilization, sediment storage, fluvial processes and the development of habitat for freshwater fish (Thevenet 1998). The role and recruitment of large woody debris will be considered in the Whitewater Creek instream flow needs assessment.

2.6.7 Study Results §5.11(b)(3)

Instream flow needs data will be analyzed, compiled, and communicated in a formal technical report. Level 1 and 2 habitat assessment forms will be included as an appendix to the report. The detailed results of the instream flow modeling will be organized to aid the development and permitting of the Project. These details will specifically include interpretation of the habitat-flow relationship of Coastal Cutthroat Trout in the bypass reach. Recommendations will be made on flushing and maintenance flows required to sustain the riverine health required to sustain Coastal Cutthroat Trout.

2.6.8 Schedules §5.11(b)(2)

Table 1 details the schedule of the Whitewater Project instream flow study activities. The bypass reach instream flow and aquatic habitat study would be completed during the ILP with an individual report prepared as part of the ISR. Desktop review and analysis will begin spring 2014 followed by field efforts from June 2014 to May 2015. Modeling efforts and reporting would occur winter 2014/2015.

Regulatory agencies will be consulted during the following phases:  Site visit to select representative reach(es) and transects – 1 June to 30 June;  Consultation with agencies regarding HSI to be applied – 1 November to 30 November;  Consultation with agencies (life stages and modelled scenarios) – 1 November to 30 November; and  Run preliminary WUA for agency review – 1 February to 15 February.

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2.6.9 Level of Effort and Cost §5.11(d)(6)

The applicant estimates that the costs to complete the bypass reach instream flow and aquatic habitat study would be approximately $180,000.

2.6.10 References

Bovee, K.D. 1982. A guide to stream habitat analysis using the instream flow incremental methodology. U.S. Fish and Wildlife Service FWS/OBS- 82/26.

Bovee, K.D. 1986. Development and evaluation of habitat suitability criteria for use in the instream flow incremental methodology. Washington, DC: USDI Fish and Wildlife Service Instream Flow Information Paper #21 FWS/OBS-86/7.

Bovee, K. D., B. L. Lamb, J. M. Bartholow, C. B. Stalnaker, J. Taylor and J. Henriksen. 1998. Stream habitat analysis using the instream flow incremental methodology. U.S. Geologicial Survey, Biological Resources Division Information and Technology Report USGS/BRD-1998-0004.

City and Borough of Sitka Electric Department. 2005. Revised draft habitat suitability curves: Coho Salmon and Steelhead Trout, Sawmill Creek Alaska. Blue Lake Hydroelectric Project.

Guy, C.S. and M.L. Brown. 2007. Analysis and interpretation of freshwater fisheries data. American Fisheries Society. Bethesda, Maryland.

Johnson, D. H., Shrier, B.M., O’Neal, J.S., Knutzen, J.A., Augerot, X., O’Neil, T.A., and T. N. Pearsons. 2007. Salmonid field protocols handbook: Techniques for assessing status and trends in salmon and trout populations. Maryland: American Fisheries Society.

Jowett, I.G., T.R. Payne and R. Milhouse. 2012. System for environmental flow analysis (SEFA). Software Manual.

Milhous, R., Wegner, D., and Waddle, T. 1984. User's guide to the physical habitat simulation system. Instream Flow Information Paper 11, United States Fish and Wildlife Service FWS/OBS-81/43.

R2 Resource Consultants. 2004. WRIA 44 and 50 watershed instream flow study. Prepared for the Foster Creek Conservation District and WRIAs 44 and 50 Planning Unit. Redmond, Washington.

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Sutton, R. and C. Morris. 2004. Flow characterization study instream flow assessment: Big Timber Creek, Idaho. Prepared for U.S. Department of the Interior Bureau of Reclamation. Boise, Idaho.

Thevenet, A., Citterio, A., and Piegay, H. 1998. A new methodology for the assessment of large woody debris accumulations on highly modified rivers. Regul. Rivers: Res. Mgmt. 14: 467-483.

USFS. 2010. Stream Inventory Handbook, Level I and II. Pacific Northwest Region: Region 6. Version 2.10.

USGS. 1982. Measurement and computation of streamflow: Volume 1. Measurement of stage and discharge. United States Geological Survey. Geological Survey Water-Supply Paper 2175.

Zavadil, E. and M. Stewardson. 2013. The role of geomorphology and hydrology in determining spatial-scale units for ecohydaulics. In Ecohydraulics: An integrated approach, First Edition. Edited by Ian Maddock, Atle Harby, Paul Kemp and Paul Wood. Published 2013 by John Wiley & Sons, Ltd.

Personal Communication

Neff, D. 2014. Fish Biologist, United States Department of Agriculture: Forest Service, Detroit Ranger District, Salem. Personal Communication: January 28, 2014.

Neff, D. 2014. Fish Biologist, United States Department of Agriculture: Forest Service, Detroit Ranger District, Salem. Personal Communication: March 3, 2014.

2.7 BOTANICAL RESOURCES AND WILDLIFE HABITAT STUDY

2.7.1 Goals and Objectives §5.11(d)(1)

The goal of this study is to evaluate the effects of project activities on the botanical resources in the project area. This version of the botanical resources study plan incorporates the following USFS document: Study Request for Botanical Resources: Sensitive and Survey and Manage Botanical Species, Invasive Species, and Special Habitats, prepared by Jennifer Lippert and Chris Wagner on 17 October 2013 (USDA 2013), referred to in this section as “USFS study request” (USFS 2013).

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The objectives of the botanical resources study are as follows: 1. Map and/or confirm vegetation types and special habitats within the affected project areas. 2. Identify of any threatened, endangered, or sensitive (TES) vascular and non-vascular plants and fungi; “survey and manage” species locations within the proposed Project area; and assess all Project-related effects to these species. 3. Inventory invasive weed species in the Project area.

2.7.2 Study Area

The study area will encompass all areas that would be directly and indirectly affected by Project construction and operation, as follows (Figure 5):  A 300-foot buffer on either side of the following proposed Project infrastructure: intake, powerhouse, tailrace, penstock route, and proposed new roads.  A 150-foot buffer on either side of the proposed transmission line, and all existing roads that access the Project area off of Highway 22, including Forest Road 440 from Highway 22 to the powerhouse. The area along Highway 22 itself is excluded from the study area.  Along Russell and Whitewater Creek from the impoundment area downstream to the North Santiam River;

2.7.3 Resource Management Goals §5.11(d)(2)

This study will provide information needed to support the general vegetation, special habitats, sensitive plant species, and invasive species study goals. This study will provide information relevant to USFWS, USFS, and ODFW management goals of protecting federal and state-listed species, sensitive plant species, survey and manage species, as well as priority habitats and species and special habitat areas. In addition, the USFS will use this information to issue a special use permit for the Project.

2.7.4 Existing Information §5.11(d)(3)

Existing information for general vegetation cover, special habitats, sensitive species, and invasive species for the Project area is described in the individual sections below. Existing digital spatial for each of these four elements will be obtained from the Willamette National Forest (WNF)

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Data Library (http://www.fs.fed.us/r6/data-library/gis/willamette/), as well as from other publically accessible GIS data portal web sites (e.g., Natural Resource Information Service), and from the existing Project geodatabase. Relevant existing spatial data to be reviewed includes vegetation cover, soils, hydrography, topography, and fire history data. This information is also being collected to complete a biological evaluation on effects to USFS sensitive species, and to meet required protocols for USFS survey and manage species.

General Vegetation Information

Vegetation type data for the Project are described in the ‘vegetation stand’ data layer of the WNF Data Library. For each mapped polygon in this layer, relevant attributes include plant associations, dominant and subdominant tree species for each polygon, land cover class, as well as several additional attributes. ERM will also reference the Field Guide to the Forested Plant Associations of the Westside Central Cascades of Northwest Oregon (USDA 2002). ERM will communicate with the WNF Detroit Ranger District botanist to determine what additional hard copy or digital vegetation type data (e.g. reports, maps, vegetation classifications, GIS layers) might also be available for reference.

Special Habitats Information

Special habitat types for the WNF are described in the Willamette National Forest Special Habitat Management Guide (USDA 2010). Special habitats are defined as any naturally non-forested habitat, as non-forested habitats represent only five percent of the land cover on the WNF. Within the Project area, special habitats include any non-forested wetland and riparian habitats, ponds, meadows, and other mesic and dry non-forested habitats.

Sensitive Species Information

Three types of species are included in the sensitive species survey: USFWS Threatened or Endangered species, USFS special status species, and the Northwest Forest Plan (NWFP) “survey and manage” species. These three designations are collectively referred to as “sensitive species” in this study plan.

No species on the USFWS’s Threatened or Endangered Plant list are found within the Project vicinity, or on the WNF. Documented or suspected USFS special status species for the WNF are listed on the Regional

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Forester’s Special Status Species list for Region 6 (RFSSS; found at www.fs.fed.us/r6/sfpnw/issssp); survey and manage species for the Project area are listed on the NWFP Survey and Manage Species list (Attachment 2 of the USFS study request, [USDA 2013]).

There are 98 vascular, lichen, bryophyte and fungal botanical species listed on the latest RFSSS list that are either documented or suspected on the WNF (listed in Appendix G). These species will need to be evaluated to determine if they or their habitat would be impacted by the Project. The following species from the RFSSS list have been documented in this portion of the North Santiam watershed: two vascular plants, Thompson’s mistmaiden (Romanzoffia thompsonii) and Gorman’s aster, (Eucephalus gormanii); one epiphytic lichen (Pseudocyphellaria rainierensis); and one fungi species. The latest RFSSS list is from December 2011. Prior to conducting the botanical field surveys ERM will confirm whether any updates have been made to the potential species listed for the Project area.

Seventeen NWFP Survey and Manage Category A and C species (species requiring predisturbance surveys) will also need to be evaluated. These species are listed in Appendix A, Attachment 2, of the USFS study request (USFS 2013) and consist of six vascular plants, two bryophytes, eight

lichens, and one fungi species.

Invasive Species Information

The following existing invasive species information is adapted from the USFS study request (USDA 2013). Several invasive species have been documented on the WNF, listed in Appendix A, Attachment 1 of the USFS study request (USFS 2013). Of these, many have been documented within the Project area. Documented species include scotch broom (Cytisius scoparius), Armanian blackberry (Rubus armeniacus), Canada thistle (Circium arvense), St John’s wort (Hypericum perforatum), and ox-eye daisy (Leucanthemum vulgare). In addition, one early detection and rapid response invasive species, spotted knapweed (Centaurea stoebe), has been documented at three known sites within the Project area.

2.7.5 Nexus to Project §5.11(d)(4)

Project construction will modify existing soils, vegetation, and habitat along the project corridor. These activities (e.g., removal of vegetation at Project facilities during construction, and brushing along access roads) would result in changes to vegetation, including causing potential impacts to sensitive species, or introduction of invasive species. Information obtained

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during this study will be used to analyze project effects, assist in designing the Project to avoid or minimize any adverse effects, identify best management practices (BMPs) to be employed during construction, and develop avoidance and mitigation measures to be included within the proposed terrestrial and habitat resource management plan. The surveys will also aid the applicant in prescribing appropriate rehabilitation and revegetation efforts following ground disturbance. The general vegetation and special habitats mapping will also be used as part of the wildlife resources study to describe wildlife habitats within the Project area (as described in Section 2.10).

The study would provide better information on the current habitat condition of the potentially affected areas in the Project construction area. Results of this study would inform potential license articles pertaining to the regulations of the NWFP, WNF Land and Resource Management Plan, and the ESA. Characterizing the existing habitat and resources is necessary for FERC to carry out their responsibilities under the NEPA.

2.7.6 Study Methods §5.11(b)(1) & (d)(5)

The study will consist of a pre-field desktop assessment and mapping, field surveys for general vegetation, special habitats, sensitive species, invasive species, post-field refining of the pre-field mapping, and production of a botanical study report. All surveys will be conducted by a qualified professional botanist, following the USFS study request provided by the WNF Detroit Ranger District botanist (USDA 2013). The study plan is summarized below.

Pre-Field Assessment

A pre-field assessment will be performed prior to conducting the botanical surveys. This assessment will consist of a comprehensive review of all available botanical information for the Project area, including reports, existing digital spatial data in GIS, vegetation type classifications, special habitat descriptions, and potential habitat and known occurrence data for sensitive and invasive species. ERM will communicate with the WNF Detroit Ranger District Botanist, as well as review the most up to date USFWS, Oregon Department of Fish and Game, Oregon Natural Heritage Program, Oregon Department of Agriculture, and USFS sensitive and invasive species data to confirm that the target species and status are current as of the 2014 field season, as well to obtain locations (coordinates) of any known occurrences of sensitive or invasive species within the Project area.

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ERM will produce a GIS-based draft field map using aerial imagery, terrain data, existing vegetation cover type maps, and other pertinent features (e.g., hydrography, soils). The field map will allow identification of potential habitat areas to be surveyed for sensitive and invasive species. These potential habitat areas, as well as any visible special habitat areas (non-forested habitats), will be digitized on the field map. This preliminary field map will be used to focus survey efforts in the field.

Based on the information gathered during the pre-field assessment, ERM will prepare a detailed field study design for conducting the special habitat, and sensitive and invasive species surveys within the Project area. Methods for study implementation are summarized below. In addition, methods specific to the sensitive and invasive species surveys are detailed in the USFS study request (USDA 2013).

General Vegetation Mapping

Vegetation types will be mapped within the entire study area. Assuming that the ‘vegetation stand’ layer from the WNF data library is of sufficient spatial resolution, ERM will use this layer to edit/update the existing mapping using field groundtruthed plant associations within the study area. Vegetation types will be confirmed and/or mapped in the field using established WNF plant species associations (e.g. USDA 2002). Vegetation type polygons will be included in the final GIS geodatabase.

Special Habitats Survey

Special habitats will be mapped within the entire study area. Special habitat types for the WNF are described in the Willamette National Forest Special Habitat Management Guide (USDA 2010). Potential locations of special habitat (non-forested) areas will be identified on the preliminary draft field map. These locations will be groundtruthed during the 2014 field effort, and the preliminary mapping will be updated based on field efforts. Survey protocol will follow the method described in USDA 2010; special habitats will be documented on the WNF Special Habitat Inventory Form, presented in Appendix B of USDA (2010). Per the special habitats survey protocol, locations of special habitats will be documented using a GPS, with habitats less than one acre documented using a single point, and habitats greater than one acre documented using a series of boundary points for later desktop polygon digitization. Special habitat locations will be included in the final GIS geodatabase.

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Sensitive Species Survey

Surveys for sensitive plants will be conducted by a professional botanist, and will occur in conjunction with vegetation type mapping. Target sensitive species will be identified during the pre-field assessment effort described above, using the updated lists described in the Existing Information, Section 2.7.4 above.

Sensitive species surveys will be conducted using the methods described in the USDA’s Threatened, Endangered, and Sensitive Plants Survey Field Guide (USDA 2005), using the “Focused” (Intuitive Controlled) survey type, as described in USDA (2005). This method focusses survey efforts on potential sensitive species habitat. High probability sensitive species habitat is identified within the study area using aerial imagery and existing field knowledge, and the identified habitat areas are surveyed on the ground in their entirety.

NWFP survey and manage species will be surveyed using the most up to date survey protocols published by the Survey and Manage Program of the NWFP. The current protocol is included in the document titled Record of Decision for Amendments to the Survey and Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines, January 2001 (USDA and USDI 2001). However, these protocols are subject to periodic changes, thus the latest version will be obtained prior to the field season from the BLM Oregon/Washington Planning Survey and Manage Protocols web site, http://www.blm.gov/or/plans/surveyandmanage/protocols/.

All survey efforts, whether a sensitive, or survey and manage species was encountered or not, will be documented on the USDA Forest Service TES Plant Survey Field Form (Appendix C of USDA 2005). If a new sensitive species occurrence is encountered, population extent, size, habitat characteristics, potential threats, and location relative to Project features, will be documented on the data form. New occurrences of rare lichens and bryophytes will also be vouchered using the envelope included as Attachment 6 in Appendix A of the USFS study request (USDA 2013).

All areas intensively examined will be GPS’d, and documented on field maps. The location of all sensitive plants identified during surveys will be GPS’d, and sensitive species locations will be included in the final GIS geodatabase. Photographs of each plant, its diagnostic characteristics, and habitat will be taken. Surveys will be scheduled during the appropriate phenological stage for identification of each target plant, which will occur over three survey periods during the growing season. In addition, within

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habitats where trees are 180 years or older, two fungal surveys (spring and fall) will be conducted.

This type of sensitive species survey effort is consistent with other sensitive species survey efforts completed during the licensing proceedings for hydroelectric projects that include ground disturbance.

Invasive Species Survey

Invasive species surveys will be conducted by a professional botanist and will occur in conjunction with vegetation and sensitive plant surveys. Target invasive species will be identified during the pre-field assessment effort described above, using the updated lists described in the Existing Information section (Section 2.7.4). Potential habitat areas for target invasive species within the study area will be identified during the pre- field assessment effort described above. These potential habitat areas will be surveyed in their entirety as described for the sensitive species surveys, recognizing that the invasive species surveys may occur within the same or different potential habitat areas. New occurrences of invasive species will be documented on the WNF Noxious Weed Siting Forms (Appendix A, Attachment 5 of the USFS study request [USDA 2013]). Invasive species locations will be included in the final GIS geodatabase.

This type of invasive species survey effort is consistent with other invasive species survey efforts completed during the licensing proceedings for hydroelectric projects that include ground disturbance.

Documentation

General vegetation, special habitat, sensitive species, and invasive species surveys will be documented as described in their respective section above. After the field effort, the preliminary field map will be updated using all field data, for each survey element. The final GIS deliverable will be a geodatabase of all field data, including vegetation type polygons, point location points of any sensitive or invasive species that were identified, confirmation points of vegetation types, and polygon boundaries, or point locations, of special habitats.

2.7.7 Study Results §5.11(b)(3)

Deliverables for the botanical study include the following:  A comprehensive botanical report, including:

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o Description of methods used for the surveys, including schedule and map; o Updated target list of sensitive and invasive species, with source lists and target species habitat information; o Results of the botanical survey: general vegetation types/plant associations; new and previously documented sensitive and invasive species; species descriptions; representative species and habitat photos; how species were identified; and special habitat descriptions and locations; o Maps of general vegetation types, special habitat locations, and sensitive and invasive species occurrences; and o Completed field forms; and  GIS geodatabase of all spatial data produced for the botanical study, including vegetation types, special habitats, and sensitive and invasive species habitats and occurrences (new and previous) data.

2.7.8 Schedules §5.11(b)(2)

The botanical study will be completed during the first study season of the Integrated Licensing Process (2014), with the schedule as follows (adapted from the USFS study request [USFS 2013]):  April-May 2014: Finalize the study plan and update the target botanical species list.  May-August 2014: Field work (plants, lichens, bryophytes)  May-June, October-November 2014: Field work (“survey and manage” fungi species)  September-October 2014: Data analysis

 November 2014: Prepare Draft Botanical Study Report  December 2014: Submit Draft Botanical Study Report for stakeholder review; the applicant will allow a minimum of 30 days for stakeholders to comment on the draft report.  January 2015: Revise and finalize Botanical Study Report based on stakeholder comments.

A second season of surveys is not anticipated, but it is possible that weather conditions or unresolved taxonomic issues may require some additional field work in 2015.

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2.7.9 Level of Effort and Cost §5.11(d)(6)

The applicant estimates that the costs of the sampling equipment and labor associated with monitoring, data analysis, and reporting for the Botanical Study will be $60,000.

2.7.10 References

USDA 2002. McCain, C. and Diaz, N., USDA Forest Service. Field Guide to the Forested Plant Associations of the Westside Central Cascades of Northwest Oregon. June 2002. Available at http://ecoshare.info/2009/12/16/plant- associations-of-the-west-central-cascades/

USDA, 2005. USDA Forest Service. Threatened, Endangered, and Sensitive Plants Survey Field Guide. Prepared by USFS Rangeland Management Staff, March 2005.

USDA, 2010. USDA Forest Service, Willamette National Forest. Willamette National Forest Special Habitat Management Guide. Prepared by J. Lippert, C. McCain, and A. Smith. May 2010.

USDA, 2013. USDA Forest Service, Willamette National Forest. Whitewater Hydroelectric Project FERC Project No.-P-14383-005 Study Request for Botanical Resources: Sensitive and Survey and Manage Botanical Species, Invasive Species, and Special Habitats. Prepared by J. Lippert and C. Wagner. October 17, 2013.

USDA and USDI, 2001. USDA Forest Service and USDI Bureau of Land Management. Record of Decision for Amendments to the Survey and Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines. In Forest Service and Bureau of Land Management Planning Documents within the range of the Northern Spotted Owl. January 2001.

2.8 SOILS AND GEOLOGY RESOURCES STUDY

2.8.1 Goals and Objectives § 5.11(d)(1)

The goal of this study is to collect additional information on soil and geology resources in the study area to ensure project facilities will support long term slope stability and productive information necessary for preparing comprehensive soil erosion control plans and other appurtenant design exhibits.

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2.8.2 Study Area

The soils and geology study area includes all surface areas that will be temporarily or permanently altered during Project construction including but not limited to (Figure 4):  Intake;  Penstock and 100 meters on each side of the proposed penstock route;  New roads; and  Proposed transmission line corridor areas surrounding the powerhouse and the tailrace.

A topographic map showing soils and geologic investigation results will be prepared for the site and surrounding area (Figure 6).

2.8.3 Resource Management Goals §5.11(d)(2)

The USDA Forest Service resource management goals for this project are identified in the laws, regulations, Forest Service direction, and the Willamette Forest Plan. 36 CFR 219.28(a) directs the USDA Forest Service to classify lands under its jurisdiction as not suited for timber production if they fall into the following categories: (1) Legislatively or administratively withdrawn (2) Irreversible soil or watershed damage (NFMA 6[g][3][E][i]) (3) No assurance of reforestation within 5 years

Element B relates in part to slope instability. The maintenance of long term slope stability is the primary concern for this Project. Though timber production is not part of hydropower development, the relationship with 36 CFR 219 is still twofold: 1) the USFS’s lesser concern is that some land will need to be cleared of timber for the development of this project; and 2) the USFS’s greater concern relates to access. Timber production in the Northwest requires a road system be developed and maintained. The roads required for hydropower construction and long term maintenance are essentially identical to those needed for timber management.

Forest Service Manual 2500 –Watershed and Air Management discusses the laws, executive orders, regulations, and Office of Management and Budget Circulars applicable to direct or otherwise authorize watershed and soil management on lands of the NFS. The National Best Management Practices for Water Quality Management on National Forest System Lands

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(April 2012) provides substantive direction to manage water quality and protect soil resources. Though many sections of this document apply, project specific core BMPs are discussed in Section Fac-9 Pipelines, Transmission Facilities and Rights-of-Way.

Forest Service Manual R-6 Supplement No. 2500.98-1 (Title 2520 Watershed Protection and Management) clarifies direction for planning and implementing activities in areas where soil quality standards are exceeded from prior activities, redefines oil displacement, and provides guidance for managing soil organic matter and moisture regimes. In addition, the USDA Forest Service Pacific Northwest Region Handbook on General Water Quality BMPs (November 1988) provides guide on practices applicable in conducting land management activities to achieve water quality standards to ensure compliance with the Clean Water Act, as amended, and Oregon Administrative Rules. Chapter IV of the Willamette Forest Plan sets forth the Forest-wide Standards and Guidelines for a variety of resources and activities, including soil and geology. Soil and water quality protection are addressed in the Willamette Forest Plan section FW-079 to FW-114.

2.8.4 Existing Information §5.11(d)(3)

The USFS provided the following existing information in their formal study requests for the Whitewater Creek Hydroelectric Project:

The Project is proposed to be constructed in the Cascade Mountain Range, which has a variety of soil and rock types. Extensive experience with timber management over several decades shows that maintenance of long term slope stability can be adversely affected where timber harvest or access development are implemented. As was discussed previously, road access for hydropower development is essentially identical to access for timber management. All aspects of this Project need to be investigated for soil, slope, seepage/drainage, and geologic conditions to insure that long term slope stability is maintained.

Located entirely within the Cascade Mountain physiographic region, the study area is principally found in the younger High Cascade portion of this volcanic range. Basalt flows, tuffs and ashflows form the foundation of the High Cascade volcanic episode, though basalts dominate (Orr and Orr, 2000). In the last several million years, these rock formations have been extensively modified by stream erosion and mountain glaciation. This complex geological history has produced a diverse landscape in the watershed. The landforms include the highly glaciated uplands with extensive ground moraine, long alluvial terraces of outwash, and steep rocky peaks (Legard and Meyer, 1973).

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The Forest Soils Resource Inventory (Legard and Meyer, 1973) and applicable geologic information (Orr, Elizabeth L., and Orr, Wiliam N., 2000, Geology) are general in nature and not intended to evaluate specific projects at the site level. As the Project to this point is relatively conceptual, additional substantive information is necessary at the site specific level to determine existing soil and slope conditions throughout the Project and sufficient design work to measure the magnitude of Project effects on the various slide slopes. With that information, Project integrity and long-term slope stability can be achieved.

2.8.5 Nexus to Project §5.11(d)(4)

Additional review of site-specific soils and geology information is needed to further advance project design and associated BMPs on steep or potentially unstable side slopes, or how subsurface seepage and drainage conditions will be determined, monitored, or designed for, or how long term slope stability will be maintained once construction is complete.

2.8.6 Study Methods §5.11(b)(1) & (d)(5)

Project design efforts are ongoing and will be subject to change based on the results or studies described in the PSP and other development analyses being completed by the applicant. Given that physical features could shift as a result of the study process, the applicant suggests a phased approach to studying general geology, soils, and geotechnical information in the proposed Project area. The first phase, or site screening phase, will include a thorough review of specific information about area geology, soils, and geotechnical properties that will allow for a preliminary assessment of soil erosion and slope stability. Once the applicant has refined the final location of project structures, a focused and detailed investigation (Phase 2) will be conducted according to the criteria, objectives, and goals set forth in the USFS Study Request prepared by Douglas Shank and dated 31 October 2013.

Phase 1 – Site Screening

A professional geologist will gather available literature in the Project area. Geologic and soils maps of the area will be reviewed. Geotechnical information associated with existing structures and logging roads and other linear features (transmission lines, pipelines, and telecommunications equipment) on slopes and soils in similar subsurface conditions will also be gathered and reviewed. Geologic, soils, and geotechnical information will be mapped using a GIS.

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From the information reviewed above, a report will be prepared illustrating the relationship between geology/soil types to slope steepness and to failure or erosion potential. Results will allow for rapid assessment of possible route alterations as problematic soils/slopes are identified. A site visit to the area will be conducted once the preliminary review is complete to confirm accuracy of the findings. The results of the site screening process will allow the applicant to potentially adjust Project features that will be best suited to prevent soil erosion or slope instability. In addition, a site screening analysis will allow the applicant to determine whether enough information exists to prepare soil erosion control plans and other design exhibits necessary for the FERC license application.

Based on the Phase 1 results, it may be necessary or prudent to perform more in depth investigations (Phase 2). Triggers for additional investigations will depend on the location and nature (weight, size, foundation requirements, permit requirements, etc.) of facilities and infrastructure; and soil and geologic conditions. Steep unstable slopes, erosive geologic and soil units, liquefiable sediments, or compressible soils could require detailed investigations (Phase2).

As mentioned earlier, the Phase 2 or detailed site geologic investigation will begin once the location of critical features, facilities, and roads are identified and if there is a need, as described above. Specific activities associated with Phase 2 could include detailed geologic mapping, test pits or borings, and/or geophysical investigations. Samples could be analyzed for geotechnical properties that include, strength, compressibility, cohesiveness, and/or liquefaction potential.

2.8.7 Study Results §5.11(b)(3)

A report describing the results of the site screening analysis will be prepared at the end of the first study season and included in the ISR filed May 2015. The report will summarize the data and discuss the results in the context of relevant study goals and objectives. At this time the applicant assumes that the Phase 2 detailed analysis will only occur after a thorough agency review of the Phase 1 report and that Phase 2 will likely occur after the first ILP study season.

2.8.8 Schedules §5.11(b)(2)

The Phase 1 site screening desktop and field analysis will occur in the summer and/or fall of 2014 with the report prepared during the first quarter of 2015. Phase 1 data collection would likely take 6 to 8 weeks to

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collect and analyze, and will be followed up with a 2 to 3 day site visit. A preliminary report would be prepared following the site visit. The report should take 3 to 6 weeks to prepare.

Threshold events include:  Office data collection completion;  Field site visit; and  Report.

Following the Phase 1, the final location of Project structures, and agency meetings a decision will be made as to the need and extent of Phase 2 Studies. A plan of work will be developed and implemented over a 2 to 3 month period. A schedule for Phase 2 will be included in the draft and final reports. A draft report including the results of the soils and geology resources study will be available for comment by all stakeholders at least 60 days prior to the 27 May 2015 initial study report meeting. The applicant will allow 30 days for stakeholders to comment and incorporate comments into the final report which is currently scheduled to be filed with FERC on 12 May 2015.

2.8.9 Level of Effort and Cost §5.11(d)(6)

The applicant estimates that the costs of the Phase 1 site screening desktop and field analysis, and reporting will be approximately $30,000.

2.8.10 References

Legard, Harold A. and Meyer, LeRoy C. 1973. Willamette National Forest Soil Resource Inventory, Pacific Northwest Region. 167p.

Orr, Elizabeth L. and Orr, William N. 2000. Geology of Oregon. Iowa: Kendall Hunt Publishing Company 6. 254p.

2.9 RECREATION RESOURCES STUDY

2.9.1 Goals and Objectives § 5.11(d)(1)

There are three primary goals of the recreation resources study:  Provide an account of existing recreation inventory within the immediate Project area and greater project vicinity.

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 Describe existing recreation use in the immediate Project area.  Analyze potential effects Project construction and operation could have on local recreation.

2.9.2 Study Area

The study area referred to as the immediate project area includes all areas with Project features, or areas that will be temporarily or permanently used during Project construction and/or operation (Figure 6). The applicant has not incorporated USFS Road 2243 into its project boundary as it will not be used during construction and/or operation. However, for the purpose of the recreation study, the area described as the immediate Project area includes USFS Road 2243 from its intersection with USFS Road 302 to its eastern intersection with an un-marked user created trail that leads to a location near the proposed Project intake on Russell Creek. The study area referred to as the greater Project vicinity is a much larger area that will extend beyond the applicant’s proposed Project boundary. This area will include numerous existing recreation facilities a majority of which are outside of the immediate Project area (see Section 2.9.6).

2.9.3 Resource Management Goals §5.11(d)(2)

The Willamette National Forest Land and Resource Management Plan provides management direction for recreation resources in the Project area (USDA Forest Service 1990, as amended by the Northwest Forest Plan [USDA Forest Service and USDI Bureau of Land Management 1994]). Chapter IV of the Forest Plan sets for the Forest-wide Standards and Guidelines for a variety of resources and activities, including recreation resources. Scenic quality (Study 2.5) and recreation setting protection are addressed in the Willamette Forest Plan section FW-001 to FW-078 and management allocations MA-11d, MA-12b. The West Cascades National Scenic Byway Corridor Development Plan provides a current assessment of the byway as well as management recommendations for improvements along the byway.

FERC must equally consider the environmental, recreational, fish and wildlife, and other non-developmental values of the Project, as well as power and developmental values when making a decision regarding the license issuance for the Whitewater Hydroelectric Project. FERC must also determine what conditions should be placed on any license that may be issued. Any license issued shall be best adapted to a comprehensive plan for improving or developing a waterway or waterways for all beneficial

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public uses. Construction of the Whitewater Project may temporarily displace recreation users on Forest Service Road 040 and 440. Reasonable consideration of the effects of Project construction and/or operation pertaining to recreational access and opportunities within the Project area is in the public interest.

2.9.4 Existing Information §5.11(d)(3)

There is limited information on existing recreation use or recreation amenities for project areas that have the potential to be temporarily or be permanently displaced by project specific features or construction access.

Specific to USFS Roads 040 and 440, the USFS has provided the following information in their formal ILP study requests:

Whitewater rock pit is within the Project area off Forest Road 040 and is popular for winter sledding and target shooting. There are numerous dispersed (undeveloped) campsites (indicated by fire rings, turnouts, compacted ground) within and adjacent to the Project area that have not been inventoried (mapped and evaluated) that could be affected by the Project. The trailhead at the end of the Road 040, Woodpecker Trail #3442, also accesses the Pacific Crest National Scenic Trail and Jefferson Park with Mt. Jefferson Wilderness.

The applicant has not observed any camping areas, other recreation sites, (or active recreation users) beyond a few dispersed turnouts along Forest Service Roads 040 and 440 during their preliminary surveying efforts at the intake, powerhouse, tailrace, and along the penstock alignment. In addition, the current road alignment and access plan for construction and operation is designed to eliminate impacts to recreation users using Forest Service Road 2243.

The USFS provided a great deal of existing recreation information as part of their formal ILP study requests for the greater project vicinity:

Recreation areas include those that are both formally designated and those areas used more informally (i.e., dispersed areas). Dispersed recreation is defined as passive outdoor recreation that occurs throughout the forest outside of developed sites with facilities (e.g., campgrounds, day use areas). Hiking, hunting, fishing, scenic driving, and camping are some of the primary dispersed recreational activities that occur in the Project vicinity, however, other activities include sightseeing, nature study, mushroom and huckleberry picking, sledding (Whitewater rock pit), cross country skiing, off highway vehicle use, kayaking, etc. Non-motorized trails provide hiking and equestrian use opportunities within

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the Mt. Jefferson Wilderness and along the Pacific Crest National Recreation Trail, and access to climbing Mt. Jefferson. Overnight lodging occurs at nearby cabins, one along Whitewater Creek, and Whispering Falls Campground on Highway 22.

The trailhead at the end of Road 2243 (Whitewater Trail #3429) accesses the Pacific Crest National Scenic Trail (trail from Mexico to Canada) and is the most popular access point into Jefferson Park in the Mt. Jefferson Wilderness. Weekend observations range from 45-75+ vehicles parked at this trailhead and between 2500- 4300 visitor days annually with most of the use occurring July through September. Cheat Creek Trail #3441 and trailhead is also located along Road 2243 which accesses the Mt. Jefferson Wilderness. The trailhead at the end of Road 040, Woodpecker Trail #3442, also accesses the Pacific Crest National Scenic Trail and Jefferson Park within Mt. Jefferson Wilderness.

There is occasional winter use in the wilderness by the more expert cross country skier. Wilderness permit data obtained by the Forest Service is available.

West Cascades National Scenic Byway was federally designated, traversing the western cascades for approximately 220 miles from Estacada to Westfir, Oregon. A 6-mile portion of the Project is along Highway 22 which is on the scenic byway and receives 1.28 million vehicles annually. Detroit Lake is located downstream and is a designated as a Federal Lake. Recreation and scenery resources in the area are very important to the local tourism-dependent economy.

A recreation special use permit exists for the Chemeketan hiking club’s cabin located off the Road 2243 located on the National Forest along Whitewater Creek, downstream of the proposed tailrace and powerhouse. Whitewater rock pit is within the Project area.

2.9.5 Nexus to Project §5.11(d)(4)

The Project has the potential to impact recreation use, activities, settings, access, and facilities during construction and operation. Specifically, preliminary Project designs for construction and operation could temporarily impact vehicle traffic and possible permanently impact undocumented recreation sites on Forest Service Roads 040 and 440.

Use of these roads for access during construction may impede recreation access and visitation along this corridor. This study will establish a baseline of recreation use. This will form the basis for a recreation plan and potential license articles to provide for scheduling construction activities in a manner to minimize conflicts with recreationists or any

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other actions deemed necessary to protect the recreational resources in the Project area.

2.9.6 Study Methods §5.11(b)(1) & (d)(5)

Existing Recreation Inventory

USFS existing recreation inventory information will be reviewed and compiled in the ISR. Existing information sources will include but not be limited to the sources identified in the USFS’s study requests and study plan comments. These include: available land and resource management plans/maps, GIS shapefiles, and existing Recreation Opportunity Spectrum classifications in the greater project vicinity. Existing recreation information will be described and, where applicable, delineated on maps along with the proposed hydroelectric Project facilities. Recreation information that would be described and mapped will include:  Open, publically-accessible roads by vehicle type as depicted on the Willamette;  National Forest Motor Vehicle Use Map;  -Designated scenic byways;  -Developed recreation sites (e.g., nearby campgrounds, trailheads, day use areas, cabins, etc.);  National scenic trails and all other trails, and trailheads;  Lakes, creeks, and rivers;  Dispersed campsites inventoried by the Forest Service;  Wilderness campsites inventoried by the Forest Service;  Wild and scenic rivers, wilderness areas, inventoried roadless areas, and potential wilderness areas; and  -Communities and nearby cabins.

The existing recreation inventory would be completed in concert with the “seen area analysis “described in RSP 2.5 to further assist with USFS consultation on the aesthetic resources study.

Use Analysis

The applicant will gather readily available existing use information for the greater project vicinity including: direct USFS knowledge, wilderness

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permit data, watershed analysis reports, and other available data from resource agencies. This information will be used to prepare a desktop assessment of recreation use and opportunities for spring, summer, fall, and winter recreation both in the immediate Project area and greater Project vicinity.

In addition, the applicant will inventory dispersed recreation sites within the immediate Project area (Figure 6). The presence of rock fire-rings, compacted or eroded soil, trampled vegetation and litter/sanitary problems, and user-created trails in the immediate Project area will be documented as evidence of dispersed recreational use. Locations of dispersed sites will be recorded with a handheld GPS. Visual observations will be recorded including the type of site, activities available, physical setting, human use condition, site facilities, and site access.

Field investigations will be conducted in August and October 2014 to document existing recreation sites along Forest Service Roads 040, 2443, and 440 in the immediate Project area. The timing of these visits is intended to coincide with warm weather and hunting related use of the Project area and will include at least one weekend day. The field investigation will be completed by resource professionals with experience documenting recreation sites on public lands in semi-remote locations. Still photographs will be taken to document/verify the location and condition of the recreation sites. Photos will be collected using a digital camera with an integrated GPS unit. Observations of use or other unique characteristics including the dimensions of campsites will be recorded and included in the study report. These types of recreation study methods are consistent with methods used to document recreation sites and vehicle use at other hydroelectric projects on federal land.

An estimate of usage for each site will be prepared based on visual observations and frequency of use definitions provide by the USFS in the study plan requests and comments:  Regularly: Site is used every weekend during the summer. These are the more popular sites and may be used during the week and are often the ones filled first by the weekend.  Often: Site is used one or two weekends a month during the summer.  Occasionally: Site is used a few times a year. Many hunter camps may start to fit in this category.  Infrequently: Site is used only once or twice a year.

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 Never: Site has not been used in the last couple years.

In addition to visual observations the applicant will use a digital sound level meter to record background noise conditions at recorded recreation sites in the immediate Project area. Monitoring will include recording the average ambient sound levels in dBA for 10 minutes at each recorded site.

Pressure sensitive traffic counters will be placed at the beginning of Forest Service Road 040 and 2443 just after its intersection with Forest Service Road 308, and Forest Service Road 440 where it initially intersects the Project area (Figure 6). The traffic counter data will be used to document existing vehicle access within the immediate project area. Traffic counters will provide daily use information, which will allow evaluation of recreator access use with respect to day of the week and time of the year during snow free periods. Routine visits made by the applicant, the applicant’s contractors, or USFS personnel will not be counted toward the overall traffic count.

Effects Analysis

The applicant proposes to utilize the existing use information as well as traffic and dispersed site information collected in the field to identify demand for recreation activities in the immediate project area. The applicant proposes to utilize existing sources of information recommended by the USFS pertinent to recreation demand including the Comprehensive Outdoor Recreation Plan and the National Visitor Use Monitoring Study to assist in determining predicated changes in anticipated demand for outdoor recreation in the immediate Project vicinity and impacts the Project may have on these demands. The effects analysis will incorporate the initial results of the other Whitewater resource studies to determine if there are any additional impacts on recreation due to Project impacts on other resources. The analysis will describe:  Direct impacts to recorded recreation sites due to Project construction and operation, including any reduction in public access.  How recreation setting and experiences could be affected by the Project using Recreational Opportunity Spectrum.  Potential noise effects on recorded recreation sites during construction and operation of the proposed facilities

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2.9.7 Study Results §5.11(b)(3)

A report describing the results of the 2014/2015 recreation resources study effort will be prepared at the end of the first study season and included in the ISR filed May 2015. The report will summarize the data and discuss the results in the context of relevant study goals and objectives. The results of this study will be used to determine potential impacts, as well as prepare protection, mitigation, and enhancement plans.

2.9.8 Schedules §5.11(b)(2)

The recreation resources study would be completed during the first study season of the ILP with an individual report prepared as part of the ISR. The applicant proposes to complete the existing recreation inventory work in cooperation with the USFS in June and July of 2014. Traffic counters will be installed late May 2014 and downloaded before permanent snow cover in mid-November 2014. Field investigations will be conducted in August and October 2014 with effects analysis and subsequent report prepared during the first quarter of 2015. A draft report of the recreation resources study will be available for comment by all stakeholders at least 60 days prior to the 27 May 2015 initial study report meeting. The applicant will allow 30 days for stakeholders to comment and incorporate comments into the final report which is currently scheduled to be filed with FERC on 12 May 2015.

2.9.9 Level of Effort and Cost §5.11(d)(6)

The applicant estimates that the costs of equipment, field work, and reporting will be approximately $30,000-50,000.

2.10 WILDLIFE RESOURCES STUDY

2.10.1 Goals and Objectives § 5.11(d)(1)

The goal of the wildlife resources study is to evaluate the effects of Project activities on the wildlife resources in the Project area. The study consists of two components: 1) wildlife habitat mapping; and 2) TES species survey and habitat assessment.

The objectives of the wildlife resources study are as follows:  Map and classify wildlife habitat types within the Project area.

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 Develop a list of TES, and “survey and manage” species that may occur within the proposed Project area, based on the mapped wildlife habitat.  Document the distribution and abundance of the following TES and “survey and manage” species (referred to as the “targeted sensitive species”) within the proposed Project area, and assess all Project- related effects to these species: northern spotted owl, red tree vole, amphibians, and terrestrial mollusks (Crater Lake tightcoil snail, Oregon megomphix, and Cascade axetail slug).

2.10.2 Study Area

Wildlife Habitat Study

The wildlife habitat mapping study area will be concurrent with the botanical resources study area, and will encompass the following areas that would be directly and indirectly affected by Project construction and operation (Figure 5):  A 300-foot buffer on either side of the following proposed Project infrastructure: intake, powerhouse, tailrace, penstock route, and proposed new roads.  A 150-foot buffer on either side of the proposed transmission line, and all existing roads that access the Project area off of Highway 22, including Forest Road 440 from Highway 22 to the powerhouse; the area along Highway 22 itself is excluded from the study area.

Northern Spotted Owl Study

The northern spotted owl study area includes all lands that within a 1.2 mile radius of suitable habitat that will be directly impacted by the proposed project (Figure 7). Based on the USFS’s March 28, 2014 PSP comments, field surveys for the Northern Spotted Owl Study will be completed in all suitable habitat areas within 300 meters of Project features that will require surface disturbing activities (Figure 7).

Red Tree Vole Study

The red tree vole study area includes all suitable red tree vole habitats that would be directly impacted by the proposed Project features. The Project is in the northern mesic zone. As such, red tree vole habitat would include conifer forest areas up to 3,500 feet in elevation where the quadratic mean

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tree diameter of the stand at breast height is greater or equal to 16 inches, or the average mean diameter of the stand is greater or equal to 15 inches, and where the stand is either multi-layered or has at least 60 percent canopy and two or more super dominant conifer trees/acre.

Terrestrial Mollusks Study

The terrestrial mollusks study area includes all suitable habitats for the Crater Lake tightcoil snail, Oregon megomphix, and Cascade axetail slug where road construction, tree falling, vegetation clearing or other Project related construction disturbance activities would occur (Figure 10)

Amphibian Study

The amphibian study area includes all suitable habitats that would be directly impacted by the proposed Project features, as well as the study areas along Whitewater and Russell Creeks included in the Wetland and Waters of the US delineation Study (Figure 9).

Osprey Study

Based on the USFS’s 28 March 2014 PSP comments, field surveys for the Osprey Study will be completed along Russell Creek within 0.25 miles of the proposed diversion structure construction area (Figure 8).

2.10.3 Resource Management Goals §5.11(d)(2)

This study will provide information needed to support the wildlife resource study goals previously defined. This study will provide information relevant to USFWS for ESA Section 7 Consultation, USFS, and ODFW management goals of protecting federal and state-listed wildlife species, as well as priority habitats. In addition, the USFS will use this information to issue a special use permit for the Project.

2.10.4 Existing Information §5.11(d)(3)

Wildlife Habitat Information

Existing digital spatial for TES wildlife species and wildlife habitat within the Project area will be obtained from the WNF Data Library (http://www.fs.fed.us/r6/data-library/gis/willamette/), as well as from other publically accessible GIS data portal websites (e.g., Natural Resource Information Service), and from the existing Project geodatabase.

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Wildlife habitat mapping will rely primarily on the general vegetation mapping and the special habitats mapping completed for the botanical resources study described in Section 2.7. The existing information for general vegetation and special habitats is described in the botanical resources study. The wildlife habitat mapping will also use information from the wetlands and waters of the U.S. study (Section 2.3), and the soils and geology resources study (Section 2.8). Information on habitat requirements for wildlife species includes data collected by the WNF and ODFW, the Northwest Forest Plan, USFWS, and other applicable agencies.

Northern Spotted Owl Study

The USFS has provided the following existing information:

Suitable northern spotted owl habitat consists of stands used by owls for nesting, roosting, and foraging. Generally these stands are conifer-dominated, 80 years old or older and multi-storied in structure, and have sufficient snags and downed wood to provide opportunities for owl nesting, roosting, and foraging. The canopy closure generally exceeds 60 percent. Thomas et al. (1990:164) defined suitable habitat as “multi-layered, multispecies canopy dominated by large (greater than 30 inches diameter at breast height) conifer overstory trees, and an understory of shade-tolerant conifers or hardwoods; a moderate to high (60 to 80 percent) canopy closure; substantial decadence in the form of large, live conifer trees with deformities—such as cavities, broken tops, and dwarf mistletoe infections; numerous large snags; ground cover characterized by large accumulations of logs and other woody debris; and a canopy that is open enough to allow owls to fly within and beneath it.” Although subsequent research has refined this definition, it remains valid (Courtney et al. 2004:).

Dispersal habitat for northern spotted owls includes conifer and mixed mature conifer-alder habitats with a canopy cover greater than or equal to 40 percent and conifer trees greater than or equal to 11 inches average dbh. Generally, northern spotted owls use dispersal habitat to move between blocks of suitable habitat, roost, forage, and survive until they can establish a nest territory. Juvenile owls also use dispersal habitat to move from natal areas. Dispersal habitat lacks the optimal structural characteristics needed for nesting.

Northern Spotted Owl Study: If the Applicant is implementing seasonal restrictions during the critical breeding season (March 1-July 15) for construction activities and during the entire breeding period (March 1-September 30), if Type 1 helicopters or blasting occurs, then potential take of spotted owls from disruption will not be an issue. The remaining concern will be that road construction in suitable habitat would harm nesting spotted owls by the falling of

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a nest tree or impacting habitat close (within 300 meters) to a nest which could result in ESA defined take of spotted owls. The Project will impact suitable nesting habitat when constructing a new road to the diversion structure and perhaps elsewhere.

Due to recent litigation, a solid basis for estimating harm to owls which USFWS uses to help determine take under the Endangered Species Act (ESA), relies on knowledge of where owls are nesting when projects directly affect nesting habitat.

Thus, the Applicant should conduct protocol owl nest surveys where suitable habitat is going to be directly impacted by road construction or other habitat removal impacts. As this is a two year six visit protocol, the Applicant should consider starting these surveys this year in order to complete the environmental analysis and consultation in a timely manner.

Northern spotted owl habitat must also be mapped by the Applicant to identify suitable nesting/roosting, suitable foraging, dispersal only, and non-habitat. The Applicant can use the available Forest Service or USFWS mapping and refine that based on the field habitat data they intend to collect.

The applicant received formal study requests to determine the extent of current habitat and use of the Project area by northern spotted owls from FERC (October 29, 2013) and the USFS (November 14, 2013). Information on the presence of both habitat and owls in the Project area has been provided by the USFS and additional information was provided to the applicant from the Oregon Biodiversity Information Center on 4 December 2013. Efforts associated with project design, construction techniques, and construction scheduling are ongoing. However, the type of temporary and permanent impacts and construction techniques associated with a run-of-river facility like Whitewater are not unique. Similar hydropower projects have been constructed on federal lands in the presence of northern spotted owls and other sensitive raptors with appropriate construction and operational management plans in place.

Red Tree Vole Study

The USFS has provided the following existing information:

The red tree vole is an important northern spotted owl prey species. It is primarily associated with mature and old-growth forests where Douglas fir is the dominant tree species. Project construction could adversely affect this species on both federal and private lands. It is possible those private lands may provide suitable habitat for the red tree vole, and that these lands could be affected by Project activities

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(section 5.9[b][5]). At this time, the record contains no detailed information about vegetative cover types in the Project area; therefore, the additional effort and cost, if any that would be required to survey all suitable habitat in the Project area is unknown.

Because of its importance as a primary prey species for northern spotted owls and potential occupancy of the Project area, red tree vole surveys will need to be conducted for this species to determine the effects and impacts the Project may have from construction, implementation, and operation and maintenance.

Terrestrial Mollusks Study

The USFS has provided the following existing information:

Crater Lake tightcoil snail (Pristiloma arcticum crateris) is found within 10 meters of open water in wetlands, springs, seeps, and riparian areas in “perennially wet situations in mature conifer forest, among rushes, mosses and other surface vegetation or under rocks and woody debris.” Where road construction, tree falling, vegetation clearing, or other construction occurs in this habitat, including streams crossing, protocol mollusk surveys will be needed (Version 3.0, 2003). The second survey and manage mollusk is Oregon Megomphix (Megomphix hemphilli) which inhabits mature to late seral conifer/hardwood forests often in association with big leaf maple up to 3,000’ elevation. Currently surveys are required for this species where habitat-disturbing activities are proposed.

Cascade axetail slug (Carinacauda stormi), a newly described monotypic species, that is a Forest Service sensitive species. This species is found in conifer needle litter in Douglas fir/western hemlock forests often in association with vine maple in forests from about 25 years of age to old-growth. This endemic species has a restricted range in the northern part of the western Oregon Cascades but seems to be relatively abundant in suitable habitat within that range with about 394 detections recorded on the Willamette National Forest to date in our Wildlife NRIS database.

Amphibian Study

The USFS and ODFW have provided the following existing information:

USFS: The project area includes potential breeding habitat for various amphibian species including (spotted frog, western toad, northern leopardfrog).

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ODFW: The following amphibians are known or likely to occur in the project area and could be negatively affected by the proposed project: Cascades frog, Western toad, Red-legged frog, Coastal tailed frog, Cascades torrent salamander, Clouded salamander, and the Oregon slender salamander.

Osprey Study

The USFS has provided the following existing information:

Ospreys were observed in the project vicinity in spring 2013 (Daryl Whitmore, Personal Communication, and November 2013). There is no existing survey data or information related to osprey use or occupancy in the vicinity of the Project

area.

2.10.5 Nexus to Project §5.11(d)(4)

Project construction will modify existing soils, vegetation, and wildlife habitat along the Project corridor. These activities (e.g., removal of vegetation at Project facilities during construction, and brushing along access roads) would result in changes to vegetation and soils, including causing potential impacts to wildlife habitat, including sensitive species habitat. Information obtained during this study will be used to analyze project effects, assist in designing the project to avoid or minimize any adverse effects, identify BMPs to be employed during construction, and develop avoidance and mitigation measures to be included within the proposed terrestrial and habitat resource management plan. The surveys will also aid the applicant in prescribing appropriate habitat rehabilitation and revegetation efforts following ground disturbance.

The study would provide better information on the current habitat condition of the potentially affected areas in the Project construction area. Results of this study would inform potential license articles pertaining to the regulations of the NWFP, WNF Land and Resource Management Plan, and the ESA. Characterizing the existing habitat and resources is necessary for FERC to carry out their responsibilities under the NEPA. This information is also being collected to complete a biological evaluation on effects to USFS sensitive species, and to meet required protocols for USFS survey and manage species.

2.10.6 Study Methods §5.11(b)(1) & (d)(5)

The study methods described below are divided into the two study components, wildlife habitat mapping, and TES studies, with

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comprehensive methods provided for each individual TES target species. A comprehensive data review will be performed prior to performing the wildlife habitat mapping or TES study. This will consist of a review of all available wildlife information for the Project area, including the results of the vegetation and special habitats mapping completed for the botanical study, reports, existing digital spatial data in GIS, and potential habitat and known occurrence data for TES wildlife species. ERM will also communicate with the WNF Detroit Ranger District wildlife biologist, and the ODFW biologist for the Project area, as well as review the most up to date USFWS, Oregon Department of Fish and Game, Oregon Natural Heritage Program, Oregon Department of Agriculture, and USFS sensitive species data to confirm the target species and status are current as of the 2014 field season, as well to obtain locations of any known occurrences of sensitive species within the Project area.

The wildlife habitat mapping will be completed by a professional wildlife biologist. All sensitive wildlife species surveys will be conducted by a wildlife biologist, following the protocol described in each section below.

Wildlife Habitat Type Mapping

The wildlife habitat type mapping will employ a desktop-based approach, using existing data collected by agencies, as well as other Project resources studies, including data collected by the botanical resources study, wetlands and riparian study, and soils and geology study. All existing wildlife data for the Project area will be reviewed as part of the wildlife habitat study, including agency reports, existing digital spatial data in GIS, potential habitat information, as well as potential methods for integrating the existing environmental data into wildlife habitat types. The primary data resource for mapping wildlife habitat types will be the general vegetation type mapping and special habitats mapping developed as part of the botanical resources study. These two base mapping layers will exist as individual feature classes as part of the botanical resources GIS geodatabase. Please refer to Section 2.7 for vegetation mapping and special habitats mapping methods.

The vegetation type and special habitats locations will be integrated with other existing data (e.g. wetlands, riparian, soils, geology, geomorphic position, relative landscape position, location of special habitats e.g. cliffs, talus slopes, wetlands, seeps, and springs), resulting in unique wildlife habitat types. For example, the mixed conifer forest vegetation type likely exists both in riparian and non-riparian environments, resulting in two separate wildlife habitat types. The specific method of integrating the

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environmental data into wildlife habitat types will be determined as part of the initial data review, as well as discussion with agencies including ODFW. The resulting wildlife habitat types will be classified in the wildlife habitat type feature class attribute table in the GIS geodatabase.

ERM will also use the wildlife habitat type map to develop a list of potential sensitive species in the Project area using the RSFFF list; survey and manage species lists; and the 2013 Rare, Threatened, and Endangered Species Oregon Biodiversity Information Center at Portland State University wildlife species data by county, along with a review of habitat requirements and those habitats found within the project area, as described in the Existing Information section above. The mapping would also be used to identify potential wildlife habitat areas to be surveyed for the targeted TES species, as described below. The final GIS deliverable for the wildlife habitat study will be feature classes of classified wildlife habitat type polygons, and polygon boundaries, or point locations, of special habitats (as described in Section 2.7, botanical resources study).

This type of wildlife habitat assessment effort is consistent with other wildlife habitat assessment efforts completed during the licensing proceedings for hydroelectric projects that include ground disturbance.

Northern Spotted Owl

The applicant will follow the Protocol for Surveying Proposed Management Activities that May Impact Northern Spotted Owls in Appendix C of the USFS’s 2013 Study Requests for Whitewater Hydroelectric Project. This protocol is an accepted method of inventory and survey in the general scientific community and follows direction in the Record of Decision and Standards and Guidelines for Amendment to the Survey and Manage, Protection Buffer, and other Mitigation Measures, specifically the Standards and Guidelines for Management of Habitat for Late-Successional and Old-Growth Forest Related Species Within the Range of the Northern Spotted Owl in Attachment A to the Record of Decision for amendments to Forest Service and Bureau of Land Management Planning Documents Within the Range of the Northern Spotted Owl (USDA 1994). Following this survey protocol will assure consistent, standardized surveys. The applicant’s biological contractors will have a least one meeting with USFS wildlife biologists prior to administering surveys to ensure the suitability and accuracy of the methods and procedures.

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Red Tree Vole Study

The applicant will follow the November 2012 (Version 3.0) Survey Protocol for the Red Tree Vole as recommended in the USFS’s 28 March 2014 PSP comments. Following this survey protocol will assure consistent, standardized surveys.

Terrestrial Mollusks Study

The applicant will follow the terrestrial mollusk survey protocol described in Appendix E of the USFS’s 2013 Study Requests. These survey protocols are designed for terrestrial mollusk species that require pre-disturbance surveys, as amended, of the Record of Decision and Standards and Guides for Amendments to the Survey and Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines.

The survey protocols have been accepted for use under the Northwest Forest Plan, Version 3.0. October 2003. This survey protocol is used to determine whether the species is present in the Project area. An intended objective of this survey protocol is to provide standard survey methodology, which can be used by field personnel to determine presence/lack-of-detection for target species, and to document species locations and habitats in a consistent format. These methodologies can be used during Project design to collect information about what species are present and may be affected by this Project. Following this survey protocol will assure consistent, standardized surveys.

Amphibian Study

The applicant will follow the survey protocols for amphibians under the Survey & Manage Provision of the Northwest Forest included in Appendix F of the USFS’s 2013 Study Requests for the Whitewater Hydroelectric Project. These protocols have been used and accepted by the Forest Service to screen proposed projects on federal lands to provide guidance on the compatibility of a project to the LRMP and federally mandated protection measures associated with amphibians and reptiles on federally managed lands. These protocols have undergone more than two years of field testing, and several rounds of peer, field-user, and manager reviews.

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Osprey Study

The applicant’s biological contractors will conduct a walk through search for osprey nests along Russell Creek within 0.24 miles of the proposed diversion structure construction area.

2.10.7 Study Results §5.11(b)(3)

Deliverables for the wildlife resources study include the following:  A comprehensive wildlife resources report, including: o Description of methods used for the wildlife habitat mapping and TES surveys, including schedule and map; o List of potential sensitive species within the Project area, based on mapped wildlife habitat, with source lists and target species habitat information; o Results of the wildlife habitat mapping in a GIS geodatabase and figure format; o Results of the TES survey efforts for each target species, including maps of potential habitat for each species; o Identification of any downstream riparian areas potentially impacted by the water diversion; and o Completed field forms.  GIS geodatabase of all spatial data produced for the wildlife resources study, including wildlife habitat type mapping and TES species occurrences (new and previous) data.

2.10.8 Schedule §5.11(b)(2)

The wildlife resources study will be completed during the first study season of the ILP (2014), with the schedule as follows:  April-May 2014: Finalize the study plans  May-August 2014: Field work (TES species surveys)  September-October 2014: Wildlife habitat mapping; TES species data analysis.  November 2014-February 2015: Prepare Draft Wildlife Resources Study Report.

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 A draft report of the study will be available for comment by all stakeholders at least 60 days prior to the 27 May 2015 initial study report meeting. The applicant will allow 30 days for stakeholders to comment and incorporate comments into the final report, currently scheduled to be filed with FERC on 12 May 2015.

2.10.9 Level of Effort and Cost §5.11(d)(6)

Wildlife Habitat Study

The applicant estimates that the costs of completing the wildlife habitat study will be $15,000.

Northern Spotted Owl

The applicant estimates that the costs of Northern Spotted Owl Study will be $12,000 to $20,000

Red Tree Vole Study

The applicant estimates that the costs of the red tree vole study will be $10,000 to 15,000.

Terrestrial Mollusks Study

The applicant estimates that the costs of the terrestrial mollusks study will be $8,000 to 10,000.

Amphibians Study

The applicant estimates that the costs of the amphibians study will be $8,000 to10,000.

Osprey Study

The applicant estimates that the costs of the Osprey study will be $5,000.

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2.11 BEDLOAD STUDY

2.11.1 Goals and Objectives § 5.11(d)(1)

A study and subsequent analysis should be completed to ensure that an operation plan can be developed and implemented for the facility that will not change the timing, magnitude, duration, or spatial distribution of peak, high and low flows in the reach of Russell and Whitewater Creeks between the diversion dam and the tailrace. The specific objectives of this study include:  Implement a field program to conduct pebble counts and collect bulk samples from Russell and Whitewater Creeks;  Characterize the annual sediment load and calculate sediment budgets for Russell and Whitewater Creeks; and  Estimate quantities of gravel extraction or augmentation.

2.11.2 Study Area

The study area includes the reach of Russell and Whitewater Creeks between the diversion structure and the tailrace, and the reach immediately downstream of the tailrace in Whitewater Creek.

2.11.3 Resource Management Goals §5.11(d)(2)

This will confirm compliance with regulations in the Northwest Forest Plan (ACS Objective 6, LH-1 and LH-2), and thus support a FERC license and special use permit for the proposed facilities.

ODEQ administers the state’s water quality laws, ORS chapter 468B, including the assurance that operation of a hydroelectric project is consistent with water quality standards and the protection of beneficial uses. ODEQ approves or denies water quality certification for the purpose of Section 401 of the Clean Water Act. ODFW is the state agency with jurisdiction over fish and wildlife in Oregon (ORS 496.012; the Fish and Wildlife Coordination Act at 16 USC § 661 and 662; the Federal Power Act at 16 USC § 803 & 811). Reduced instream flows could stress water quality parameters and reduce support for aquatic resources in Russell and Whitewater Creeks. Modification of the flow regime in Russell and Whitewater Creeks could result in aquatic habitat alteration and complexity.

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Sections 4(e) and 10(a) of the FPA require FERC to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued. Providing an accurate description of the bedload and continued recruitment of sediment for Project operations in the Project bypassed reach would provide information necessary to conduct the required analysis of water availability for power generation and instream flow needs to support aquatic, riparian, and terrestrial resources necessary to fulfill FERC’s responsibilities under the NEPA. Also, providing an accurate description of the existing stream flow in Whitewater Creek at the location of the proposed tailrace would provide information necessary to conduct an analysis of the effects of Project discharge and associated ramping rates on aquatic, riparian, and terrestrial resources necessary to fulfill FERC’s responsibilities under the NEPA.

2.11.4 Existing Information §5.11(d)(3)

There is no existing information for bedload and sediment transport in Whitewater and Russell Creeks. Estimates of sediment transport rate are needed to determine the annual sediment load, calculate sediment budgets, and estimate quantities of gravel extraction or augmentation. These estimates are needed to assess stream response to changes in water and sediment supply; and to determine the impact of these changes on receiving waters (for example, reservoir filling and downstream water quality impacts).

In addition to this, rates of sediment transport are required in order to predict channel change. Stream channel change depends on both water and sediment supply. Changes in sediment transport rate along a channel are balanced by bed aggradation/degradation and bank erosion.

2.11.5 Nexus to Project §5.11(d)(4)

Changes in bedload and sediment transport due to flow diversion at the intake structure could result in a change in channel morphology in the bypass reach and long term spawning gravel recruitment to the lower reaches of Whitewater Creek and the North Fork Santiam River. Loss of spawning gravel recruitment would affect native cutthroat trout and eventually ESA listed Upper Willamette winter steelhead trout. The proportion of the bed entrained is relevant for defining the extent of benthic disturbance and the effectiveness of flows in accessing the bed substrate needed for flushing fine sediment from spawning and rearing gravels.

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2.11.6 Study Methods §5.11(b)(1) & (d)(5)

Pebble count and substrate sampling will occur in several locations to characterize the variability of conditions in the bypassed reach. Sampling will occur both in the bypassed reach and below the proposed tailrace outflow. Relevant resource agencies (e.g., Forest Service, ODEQ, and ODFW) will be consulted prior to data collection to approve sampling locations. Sampling procedures and protocols will be consistent with those recognized by the scientific community and will be sufficient to determine an operational plan for the facility that is consistent with regulations (Pitlick et al., 2009). Appropriate agencies will review the study plan and make recommendations to alter the plan if needed. Using procedures similar to the Manual for Computing Bedload Transport using Bedload Assessment for Gravel-Bed Streams (BAGS) software and Sediment transport primer: estimating bed-material transport in gravel- bed channels.

The BAGS software uses six well-known bed load transport equations developed specifically for gravel-bed rivers: • The surface-based equation of Parker (1990). • The substrate-based equation of Parker- Klingeman-McLean (Parker and others 1982). • The substrate-based equation of Parker and Klingeman (1982). • The surface-based two-fraction equation of Wilcock (2001). • The surface-based equation of Wilcock and Crowe (2003). • The procedure of Bakke and others (1999).

Each of the six equations requires the input of a measured channel cross section, an estimate of the reach averaged water-surface slope, range of discharges, and varying types of sediment data from the bed surface, substrate and/or bed subsurface. Channel cross sections will be conducted via the instream flow study. Pebble counts and bulk samples will be co-located with the instream flow study to provide continuity with results from the instream flow study.

Estimating sediment transport and annual sediment load in coarse gravel- bed rivers can present many challenges. To aid with field sampling and making accurate inferences from the BAGS software results, the USDA has published a complimentary publication to the BAGS manual (Wilcock et al., 2009). Guidance and techniques provided in both the BAGS manual

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(Pitlick et al., 2009) as well as the Sediment Transport Primer (Wilcock et al., 2009) will be followed to ensure successful results from the bedload- sediment transport study.

2.11.7 Study Results §5.11(b)(3)

A report describing the results of the 2014/2015 bedload-sediment transport study will be prepared at the end of the first study season and included in the ISR filed May 2015. The report will summarize the data and discuss the results in the context of the goals and objectives of the study plan. In addition, the results of the bedload-sediment transport study will be used in concert with the results of the water quality and instream flow studies to prepare protection, mitigation, and enhancement plans.

2.11.8 Schedules §5.11(b)(2)

The bedload-sediment transport study will be completed for a full year during the first study season of the ILP with an individual report prepared as part of the ISR. Field sampling will occur during August and September under flow conditions which sediment / substrate are able to be sampled in Russell and Whitewater Creeks.

2.11.9 Level of Effort and Cost §5.11(d)(6)

Pebble counts will be coordinated to occur during one of the instream flow study field trips to reduce the effort required for sediment and substrate sampling. For substrate sampling, approximately three square feet of bed material will be collected and field sieved (down to 16 millimeters) for each site. The remainder of bed material will be removed from the field and sent to a lab. The lab will follow standard protocols to sieve the bed material at ½ phi intervals.

The estimates for sampling equipment and labor associated with monitoring, data analysis, and reporting for the bedload-sediment transport study will depend on the number of sites agreed upon with the relevant agencies. However, in brief, each pebble count and each substrate sampling site will take approximately 4 hours of field work.

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2.11.10 References

Pitlick, J., Cui, Y., and Wilcock, P., 2009. Manual for Computing Bed Load Transport Using BAGS (Bedload Assessment for Gravel-bed Streams) Software. U.S. Department of Agriculture, Rocky Mountain Research Center, General Technical Report, RMRS-GTR-223. 45 p.

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3.0 STUDY REQUESTS NOT ADOPTED

3.1 FISH SCREENING AND UPSTREAM PASSAGE ALTERNATIVES

On 14 November 2013 the applicant received an informal written study request from the USFWS to study fish screen and upstream fish passage alternatives. The request lacked the information in FERC’s formal study request criteria including methodology, level of effort, and cost. The project design and engineering process is ongoing. Whitewater will consider the USFWS’s and other stakeholders’ comments on design features throughout the FERC licensing process.

3.2 EFFECTS TO ESA SPECIES AND DESIGNATED CRITICAL HABITAT

On 14 November 2013 the applicant received an informal written study request from the USFWS to study impacts to ESA species and designated critical habitat. The request lacked the information in FERC’s formal study request criteria including methodology, level of effort, and cost. However, the applicant appreciates the request and has prescribed four comprehensive studies to determine project related impacts on vegetation and both aquatic and terrestrial wildlife habitat (studies 2.3, 2.6, 2.7 and 2.10).

3.3 WILDLIFE OBSERVATIONS

On 12 November 2013 and 27 March 2014 the applicant received a written study request from ODFW to complete a wildlife observation study in the Project area. Neither request fully addressed the Commission’s study request criteria (18 CFR §5.9[b]). However, ODFW did provide a general outline of survey protocol timing and the lack of existing wildlife resource information.

Although the applicant is not proposing a wildlife observation study as suggested by ODFW, the applicant is proposing to complete a wildlife resources study that includes comprehensive wildlife habitat delineation and physical surveys for TES and survey and manage wildlife species.

The results of these studies will provide the information necessary to determine potential impacts to wildlife including TES and survey and manage species in the Project area.

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3.4 STREAM MACROINVERTEBRATES

On 12 November 2013, the applicant received a written study request from ODFW to complete a stream macroinvertebrates study in the Project area. The applicant received similar study requests in response to the PSP from ODFW, ODEQ, and USFS. Only the USFS addressed the Commission’s formal criteria for study request criteria (18 CFR §5.9[b]). However, all three agencies reasoning for the requested studies were nearly identical.

The agencies provided comments describing how macroinvertebrate communities are an indicator of water quality and aquatic habitat health, and no specific macroinvertebrate information is currently available for Whitewater and Russell Creeks. Specifically the USFS requested the study to determine consistency with Forest Plan and ACX objectives 1, 2, 4, and 9 (as described in the USFS RSP comments).

The applicant agrees that macroinvertebrate communities are an indicator of water quality and aquatic habitat health. However, this indirect measure of water quality and indicator of aquatic habitat health is unnecessary to determine consistency with Forest Plan and ACX objectives 1, 2, 4, and 9. The applicant is already proposing comprehensive direct measurements of baseline water quality and aquatic habitat in RSP studies 2.1, 2.2, 2.3, 2.6, and 2.11. Aquatic habitat and water quality requirements for stream macroinvertebrates are well documented in western Oregon. Finally, the results of a macroinvertebrate study in addition to comprehensive water quality and aquatic habitat surveys will not aid in the development of Protection Mitigation and Enhancement measures for the proposed run-of-river hydroelectric Project.

3.5 HARLEQUIN DUCK STUDY

The applicant received a formal study request from the USFS to determine the extent of current habitat and use of the Project area by harlequin ducks on 14 November 2013. The USFS has documented both suitable habitat and the presence of harlequin ducks in the project vicinity. Data provided to the applicant on 4 December 2013 includes confirmed observations of harlequin ducks on the North Santiam River in the vicinity of Highway 22. The applicant believes that physical harlequin duck surveys in the Project area in the absence of detailed habitat information would be premature. The results of studies 2.3, 2.6, 2.7, and 2.10 will be used to quantify actual harlequin duck habitat that could be impacted by the

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project and will also be used to make adjustments to the project design, and prepare appropriate protection mitigation and enhancement plans. The plans could include but would not be limited to: seasonal construction restrictions during the sensitive nesting season, daily timing restrictions for certain heavy equipment and decibel levels, and physical surveys during construction.

The USFS’s 28 March 2014 PSP comments stated the following:

Harlequin Duck Study: Harlequin ducks nest adjacent to mountain streams like Whitewater and Russell Creeks. The Forest Service concern is that, if harlequin ducks are nesting or have newly-fledged young when construction activities occur at the diversion structure, this sensitive species may be harmed by the activities. If the Applicant can implement seasonal restrictions on these activities during the nesting period (mid-April to June 20), then the Forest Service can concur that specific harlequin duck surveys are not needed.

3.6 BALD EAGLE STUDY

The applicant received a formal study request from the USFS to determine the extent of current bald eagle habitat, presence, and use of the Project area on 14 November 2013. The USFS has documented the bald eagles in the greater project vicinity. Efforts associated with project design, construction techniques, and construction scheduling are ongoing. However, the type of temporary and permanent impacts and construction techniques associated with a run-of-river facility like Whitewater are not unique. Similar hydropower projects have been constructed on federal lands in the presence of bald eagles with appropriate construction and operational management plans in place. The applicant proposes to use the results of Study 2.10 as well as existing bald eagle information in the Project area to prepare bald eagle and northern spotted owl management plans to avoid construction related impacts to these species. The plan would be prepared in cooperation with the USFS, USFWS, and ODFW and filed as part of the PLP. The plan could include but would not be limited to: seasonal construction restrictions during the sensitive nesting season, daily timing restrictions for certain heavy equipment and decibel levels, and physical surveys during construction.

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The USFS’s 28 March 2014 PSP comments stated the following:

On further review, it is extremely unlikely that any bald eagle nesting occurs in the areas of proposed activities. Consequently, the Forest Service is not suggesting any specific surveys for nesting eagles.

3.7 LAND USE STUDY

The applicant received a formal study request from the USFS to complete a land use study in the greater Project vicinity on 14 November 2013. The study requested that the applicant provide the USFS information to ensure that National Forest Service resources are appropriately managed by the USFS consistent with applicable laws, regulations, and directives as they apply to the proposed hydroelectric Project.

The USFS provided additional clarification in their 28 March 2014 RSP comments including goals, objectives, and specifically that the information is necessary to ensure that NFS resources are appropriately managed by the USFS consistent with applicable laws, regulations, directives, and policy.

The applicant finds no nexus for endorsing a separate land use study for the Project, but will analyze land use effects based on the results of the 11 resource studies proposed and subsequent revisions to the Project design. This approach will provide the applicant the information needed for a comprehensive assessment of project related impacts to land use and applicable laws, regulations, directives and policy as well as preparation of any related Protection Mitigation and Enhancements, as required in Exhibit E of the application (18CFR§5.18)

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Environmental Resources Management Figure 5 1001 SW 5th St, Suite 1010 Botanical Study Area Portland, Oregon 97204 Whitewater Hydropower Revised Study Plan 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

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Environmental Resources Management Figure 10 1001 SW 5th St, Suite 1010 Terrestrial Mollusks Study Area Portland, Oregon 97204 Whitewater Hydropower Revised Study Plan 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Appendix A Study Request Letters

20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

FEDERAL ENERGY REGULATORY COMMISSION WASHINGTON, D. C. 20426

OFFICE OF ENERGY PROJECTS Project No. 14383-005 - Oregon Whitewater Creek Hydroelectric Project Whitewater Green Energy, LLC

Mr. David Harmon March 28, 2014 Whitewater Green Energy, LLC 601 7th Avenue P.O. Box 44 Sweet Home, OR 97386

Reference: Staff Comments on the Proposed Study Plan for the Whitewater Creek Hydroelectric Project

Dear Mr. Harmon:

We have reviewed your proposed study plan for the Whitewater Creek Hydroelectric Project filed on December 27, 2013. In addition to our verbal comments provided during the proposed study plan meeting on January 28, 2014, we are providing written comments pursuant to section 5.12 of the Commission’s regulations. Please note that your revised study plan is due to be filed with the Commission by April 28, 2014.

In your revised study plan, the methods for all studies should describe: (1) what information will be collected during the study; (2) why the information will be collected; (3) how the information will be collected; (4) when and for how long sampling will be conducted; (5) where sampling will occur; and (6) how collected data will be analyzed and reported. Staff encourages you to work with stakeholders to develop specific methodologies for all studies, in advance of the filing of your revised study plan. We recommend that you consult with the relevant resource agencies, tribes, and individuals to resolve these study details as soon as possible, particularly those regarding the following studies: bypass reach instream flow and aquatic habitat study, botanical resources and wildlife study, and soils and geology resources study. Please inform Commission staff of the date and time of any such meetings. Remember, if you do not integrate specific stakeholder recommendations for methodologies, length of study season, or data analysis into your revised study plan, you must provide your justification in sufficient detail to allow Commission staff to evaluate the validity of your study proposal.

Section 5.11(b)(3) of the Commission’s regulations requires the proposed study plan to include provisions for periodic progress reports, including the manner and extent 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Project No. 14383-005 2

to which information will be shared, and sufficient time for technical review of the analysis and results. Your proposed study plan includes provisions to provide the results from each study as part of the Initial Study Report, required by section 5.11(c) of the Commission’s regulations; however, most of your proposed studies do not include specific provisions for periodic progress reports or technical review of the analysis and study results prior to the Initial Study Report. As appropriate, please incorporate this information into each study in your revised study plan.1

Lastly, please include in your revised study plan a master schedule that includes the estimated start and completion dates of field studies, when each progress report will be filed, who will receive the reports and in what format, and the date of the initial study report. For each proposed study, please provide justification for the length of study season chosen (e.g., one year). If you propose in a study to provide a map showing your results as part of your initial or final study report, those results should also be provided as a GIS layer to assist Commission staff and resource agency personnel with analyzing the data.

Detailed comments on proposed studies are provided in the attached Schedule A. If you have any questions, please contact Aaron Liberty at (202) 502-6862, or via email at [email protected]. Sincerely,

Timothy Konnert, Chief Midwest Branch Division of Hydropower Licensing

Enclosure: Schedule A

cc: Mailing List Public Files

1 For additional guidance, see Chapter 5 of the Commission’s “Ideas for Implementing and Participating in the Integrated Licensing Process (ILP): Tools for Industry, Agencies, Tribes, Non-Governmental Organizations, Citizens, and FERC Staff” at http://www.ferc.gov/industries/hydropower/gen-info/licensing/ilp/ilp-tutorial.asp. 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

SCHEDULE A Comments on the Proposed Study Plan

Introduction (Section 1.0)

1. On page 2 of your proposed study plan, you state that all nine proposed studies would be completed within one year, suggesting a second year of studies under the Integrated Licensing Process (ILP) would not be necessary. However, as part of your proposed soils and geology resources study, you state that Phase 2 of this study would likely occur after the first ILP study season. Please revise your statement on page 2 of your proposed study plan to indicate that a second year of studies may be necessary as part of your proposed soil and geology resources study. Otherwise, please explain in your revised study plan how you propose to complete Phase 2 of this study during the first year of studies.

Water Quality Study (Section 2.1)

2. Nexus to Project (Section 2.1.5) - On page 7 of your proposed study plan, you provide details on potentially affected stream reaches in the project area; however, the distances provided for the affected stream reaches do not concur with those distances provided on page 3 of your additional information responses, included as part of your proposed study plan. In your revised study plan, please ensure the distances for the affected stream reaches, as well as the locations (i.e., river miles) of proposed project facilities on Russell and Whitewater creeks, are accurate.

3. Study Methods (Section 2.1.6) - On pages 7 and 8 of your proposed study plan, you describe the proposed methods for your water quality study. In your revised study plan, please provide the following additional information in regards to the proposed methods for this water quality study:

 the manufacturer, model, and number of all water quality sampling probes and temperature data loggers to be used during all proposed water quality monitoring events;

 a more detailed description of where each water quality sampling probe and temperature data logger would be located within the water column (i.e., depth in the water column and distance from shoreline) and a corresponding map that shows the GPS coordinates of each probe or logger in relation to proposed project facilities (e.g., diversion dam, powerhouse, etc.); and

 a description of the frequency with which data from any water quality sampling probes and temperature data loggers would be downloaded. 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

4. Study Methods (Section 2.1.6) - On page 8 of your proposed study plan, you propose to develop a quality assurance project plan (QAPP) after the study plan determination has been issued by the Commission to address both field and laboratory procedures related to your proposed water quality study. In your revised study plan, please include provisions for the QAPP to be developed in consultation with the Oregon Department of Environmental Quality (Oregon DEQ) and filed with the Commission upon completion. Additionally, please include a provision within the revised study plan that provides Oregon DEQ with a 30-day comment period prior to the QAPP being filed with the Commission.

Hydrology Study (Section 2.2)

5. Study Methods (Section 2.2.6) - On pages 11 through 15 of your proposed study plan, you describe the proposed methods for your hydrology study. In your revised study plan, please provide the following additional information in regards to the proposed methods for this hydrology study:

 the manufacturer and model of all continuous stage measurement and recording devices to be used during the implementation of this study;

 clarification as to whether an analog staff gage will be installed on Russell Creek, in addition to the analog staff gage proposed for installation on Whitewater Creek;

 a more detailed description of where each continuous stage measurement and recording device would be located on Russell and Whitewater creeks and a corresponding map that shows the GPS coordinates of each device in relation to proposed project facilities (e.g., diversion dam, powerhouse, etc.) (see comment no. 6);

 a description of when the five discharge measurements would be taken or how the five sampling dates would be decided upon to ensure they coincide with a wide range of water surface elevations and flow rates;

 a detailed description of the standard guidelines (referenced on page 13 of your proposed study plan) that would be used for cross section selection and placement (see comment no. 6);

 a detailed description of the “other pertinent parameters” (referenced on page 13 of your proposed study plan) that you propose to calculate upon completion of your discharge measurements; 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

 a detailed description of the hydraulic model (referenced on page 13 of your proposed study plan) that would be used during high flow events to calculate stream discharge;

 a detailed description of the model that would be used to model the hydrological period of record (referenced on page 15 of your proposed study plan);

 a schedule for soliciting feedback from the resource agencies on selecting the appropriate representative U.S. Geological Survey (USGS) stream gages in the region to generate a historical period of record for streamflows in Russell and Whitewater creeks; and

 any contingency plans (and corresponding methods) that would be implemented if representative USGS stream gages are not available for modeling a longer hydrological period of record, as proposed.2

6. Study Methods (Section 2.2.6) - As discussed during the proposed study plan meeting, selecting appropriate transects for continuous stage measurements and discharge measurements are necessary to collect accurate hydrology data. To ensure the collection of the most accurate data, prior to the initiation of field data collection efforts, staff recommends that the revised study plan provide an opportunity for the resource agencies to participate in selecting the specific transect locations to be used for collecting all stage and discharge measurement data. Incorporating stakeholder involvement, including those knowledgeable about local field conditions in the project area, would ensure that transects are located in the most appropriate areas, such that accurate data can be collected to meet the goals and objectives of this hydrology study.

Wetlands and Waters of the U.S. Delineation (Section 2.3)

7. Study Area (Section 2.3.2) - On page 16 of your proposed study plan, you state that the study area for the wetlands and waters of the U.S. delineation study would include Russell and Whitewater creeks within the project boundary, and all areas that could be displaced by project construction or operation. In your revised study plan, please describe the study area in terms of the distance (e.g., 100 feet from the bank) on either side of the aforementioned creeks, and the estimated size of the

2 During the proposed study plan meeting, stakeholders indicated that representative USGS stream gages on streams with hydrology similar to Russell and Whitewater creeks, which are dominated by glacial runoff, may not be available. 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

project-affected land areas3 (e.g., in square feet or acres) that would be surveyed. Additionally, please provide an updated map, as necessary.

8. Study Methods (Section 2.3.6) - On page 17 of your proposed study plan, you state that circular plots within a 30-foot radius would be placed within representative areas to characterize vegetation, hydrology and soils. In your revised study plan please provide more detailed information, per section 5.11(b) of the Commission’s regulations, about your proposed study methods. This information should include but not be limited to:

 the plot size for tree stratum, sapling stratum, herb stratum, and woody vine stratum vegetative layers (as applicable);

 a description of which tests/indices would be used to determine the presence of hydrophytic vegetation, as well as how data would be recorded (e.g., wetland determination data forms);

 an estimate of the number of plots that would be established within the study area;

 the schedule for conducting this study, including the field season and duration; and

 the personnel tasked to conduct this study, including a description of their qualifications.

Aesthetic Resources Study (Section 2.5)

9. Study Area (Section 2.5.2) - On page 21 of your proposed study plan, you state that the study area for the aesthetic resources study would be defined in cooperation with the U.S. Forest Service (Forest Service) in “Q3 of 2013.” Though “Q3” is not defined, section 5.11(b) of the Commission’s regulations clearly states that your proposed study plan must provide a detailed description of the study, which includes providing the necessary details with respect to the study area. We recommend that you consult with the relevant resource agencies to determine the appropriate study area, and include this information in your revised study plan.

10. Study Methods (Section 2.5.6) - On pages 26 and 27 of your proposed study plan,

3 Please note, that project-affected lands could extend beyond an established project boundary, and should include areas of temporary disturbance like storage and/or staging areas. 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

you state that you plan to establish key observation points (KOP’s) and associated field activities in August (summer) and September (fall) of 2014; however, it is unclear if you intend to assess how these KOP’s and activities could be impacted during the winter or spring months, given the seasonal variation throughout the year. Please include this information as part of your revised study plan.

Bypass Reach Instream Flow and Aquatic Habitat Study (Section 2.6)

11. Study Methods (Section 2.6.6) - On pages 29 through 33 of your proposed study plan, you describe the proposed methods for your bypass reach instream flow and aquatic habitat study. In many instances, you do not provide sufficient detail regarding the proposed methodologies for this study, and in other instances, you state suitable models/sampling techniques will be utilized to collect data. Section 5.11(b) of the Commission’s regulations clearly states that your proposed study plan must provide a detailed description of the study and the methodology to be used. This information must be provided as part of your revised study plan and cannot be deferred until a later date. Therefore, in your revised study plan, please provide the following information:

 a detailed description of the model that would be used to evaluate the relationship between stream flow and aquatic habitat availability;

 a detailed description of the rationale for choosing cutthroat trout, and any other species of interest, during habitat suitability index curve selection;

 a description of the life stages (for each selected species of interest) to be used during habitat suitability curve selection;

 the proposed number of transects, the aquatic mesohabitat each transect represents, and the location, including identification on a map and photo documentation, of each transect in the proposed bypassed reach (see comment no. 9 in regards to transect selection);

 a detailed description of the specific topographic, hydraulic, and geomorphic data that would be used to support modeling incremental changes to flow and subsequent changes to bedload, depth, water velocity, and substrate availability (as referenced on pages 31 and 32 of your proposed study plan);

 a detailed description of the methods that would be used to assess the various physical habitat attributes (e.g., substrate composition, fish 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

cover, etc.), including fish barriers, discussed on page 32 of your proposed study plan;

 a description of the number of mesohabitat units that will be selected for detailed assessment of physical habitat attributes and fish relative abundance and/or density;

 a detailed description of the fisheries sampling techniques that would be employed as part of this study, including a description of the specific reaches within Russell and Whitewater creeks to be sampled;

 a description of how many depth, velocity, and substrate measurements will be made for habitat suitability index curve validation and how many fish will be selected for your aging analysis; and

 a description of the various flow scenarios that would be used to model incremental changes to fish habitat.

12. Study Methods (Section 2.6.6) - To not only ensure the collection of the most accurate data, but to also ensure the results of this study achieve the stated goals and objectives, staff recommends that prior to filing your revised study plan, you consult with the resource agencies in selecting the model that will be used to evaluate the relationship between stream flow and aquatic habitat availability. We also recommend that you consult with the resource agencies when choosing the number and placement of transects to be used for the purposes of instream flow habitat modeling. Lastly, during the implementation of this study, we recommend that you consult with the resource agencies during the selection of the habitat suitability index curves.

Botanical Resources and Wildlife Habitat Study (Section 2.7)

13. Based on staff review of this plan, and as indicated during the study plan meeting, your botanical resources and wildlife habitat study combines elements from various requested studies. However, the study methods (Section 2.7.6), listed on pages 37 through 39 of your proposed study plan, are difficult to follow and moreover do not include sufficient detail to determine the effectiveness of the study in acquiring data to assess project-related impacts on habitat4, noxious weeds, or sensitive plants. The ground survey protocols, timing of data collection, and the number of sampling visits are too vague or undetermined, and the best season for sampling can vary

4 It is unclear whether the “habitat” sub-heading on page 37 of your proposed study plan refers to surveys for botanical habitat, wildlife habitat, or both. 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

considerably, depending on the target species. Further, the study does not include survey methods for acquiring wildlife data; though evaluating project effects on wildlife species is included as part of the goals and objectives for the study (as listed on page 35 - Section 2.7.1). Therefore, we recommend that you revise the study, in consultation with the relevant resource agencies, based on the issues stated above. Revisions may include, separating this single proposed study into two (or more) studies based on the target species, habitat type, or the type of surveys to be performed (e.g., a wildlife study, and botanical resources study). The revised plan(s) should include at a minimum:

 maps showing the area(s) that would be surveyed, including a preliminary characterization of the major habitat types;

 a detailed description of ground survey protocols/sampling methods, including but not limited to, the timing of data collection, plot sizes, the number of sampling visits, and a schedule for surveys;

 a detailed description of how wildlife use of the project area would be assessed;

 a list of any target species/habitat (i.e., special-status species, noxious plants, riparian habitat, critical habitat, etc.) and any specific characteristics that would influence how the data is collected (e.g., peak plant flowering period, wildlife activity);

 a detailed description of how data would be compiled and presented to stakeholders; and

 identification of the qualified professional(s) who would conduct these surveys, including a description of their qualifications.

Soils and Geology Resources Study (Section 2.8)

14. Study Methods (Section 2.8.6) – As part of your soils and geology resources study, you are proposing a phased approach to studying general geology, soils, and geotechnical information in the proposed project area. Currently, there is insufficient detail provided on Phase 2 of this study. So that staff can evaluate the study in full, please provide all components of a standard study plan (see section 5.11(d) of the Commission’s regulations) for each of the study phases, including a detailed methodology which addresses the six criteria detailed in the body of this letter. Also, for Phase 2 of this study, please ensure you provide the following, as appropriate: 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

 a topographic map indicating the study area for any geologic investigations;

 a schedule for conducting any proposed geologic investigations; and

 a preliminary indication of the number of subsurface samples you anticipate collecting, the properties you will test for, and under what conditions additional subsurface testing beyond the proposed samples will be conducted.

15. Please clearly identify the “triggers,” or thresholds that would be met during Phase 1 of the study to justify the implementation of Phase 2. If it is not possible to identify the triggers for Phase 2 of the study prior to conducting Phase 1, please describe a decision-making process that would be used when deciding whether to implement Phase 2 of the study.

16. Please note that for original major construction (greater than 1.5 megawatts of capacity), a Supporting Design Report consistent with section §4.41(g) of the Commission’s requirements will need to be filed with any final license application. Please take these requirements into account when developing your revised study plan.

Recreation Resources Study (Section 2.9)

17. Goals and Objectives (Section 2.9.1) – On page 44 of your proposed study plan, you state that the goal of the recreation resources study is to formally document campsites and dispersed recreation areas, as well as vehicular traffic along Forest Service Road 040 and Forest Service Road 440. However, your study does not provide specific methods for capturing recreational use data in the vicinity of the project. Therefore, you should conduct a recreation survey as part of your proposed study to establish a baseline of recreation usage and to determine future need at, and in the vicinity of, the proposed project. If you propose any recreation facilities based on the results of your recreation study, a recreation plan should be provided with your initial study report. The recreation survey, which should be conducted after consultation with the Forest Service and other relevant agencies, should include, at a minimum:

 on-site surveys at the proposed project and in adjacent areas to obtain the current usage data and to project future recreation needs.

 all formal and informal public recreation areas that allow public access to project lands or waters; 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

 the usage data should be reported in recreation days,5 for the average weekday, weekend, peak weekend averages, and annual number of total visits;

 assessment of the recreation opportunities for each season (i.e., winter, summer, spring and fall); and

 a description of the current and projected capacity of the existing recreation facilities and be representative of the entire recreation season.

18. Study Methods (Section 2.9.6) - On page 46 of your proposed study plan, you state that traffic counters would be used to document existing vehicle access within the project area. In your revised study plan, please clarify how long the traffic counters would remain on Forest Service Road 040 and Forest Service Road 440, and what protocol is being used to access the vehicular traffic data.

Studies Not Adopted (Section 3)

19. On pages 48 through 52 of your proposed study plan, you provide a discussion of those studies requested by various stakeholders which are not being adopted for inclusion within your proposed study plan. However, as required by section 5.11(b)(4) of the Commission’s regulations, you did not reference the criteria set forth in section 5.9(b) to explain why requested studies were not adopted. Therefore, for each requested study not adopted, please provide this required information in your revised study plan.

5 A recreation day is defined as each visit by a person to a development for recreational purposes during any portion of a 24-hour period. 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Western Region Eugene Office 165 East 7th Avenue, Suite 100 John A. Kitzhaber, M.D., Governor Eugene, OR 97401 (541) 686-7838 FAX (541) 686-7551 OTRS 1-800-735-2900

March 26, 2014

Kimberly D. Bose, Secretary VIA ELECTRONIC FILING Federal Energy Regulatory Commission 888 First Street, NE Washington D.C. 20426

RE: Whitewater Green Energy’s Whitewater Creek Hydroelectric Project, FERC No. 14383 Comments on Proposed Study Plan

Dear Ms. Bose:

On December 29, 2013, Whitewater Green Energy, LLC (“Whitewater”, “Applicant”) filed a Proposed Study Plan (PSP) with the Federal Energy Regulatory Commission (FERC) for their Whitewater Creek Hydroelectric Project (FERC No.14383). The Oregon Department of Environmental Quality (ODEQ) has reviewed the PSP and offers the our comments as attachments to this correspondence.

Sincerely,

Christopher Stine, PE Water Quality Engineer

cc: File ec: FERC service list, FERC Project No.14383 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY Whitewater Creek Hydroelectric Project, FERC No. 14383 PROPOSED STUDY PLAN COMMENTS

March 26, 2014

On July 8, 2013, Whitewater Green Energy, LLC (“Whitewater”, “Applicant”) filed a revised Preliminary Application Document (PAD) and Notice of Intent (NOI) to file for an original license for their proposed Whitewater Creek Hydroelectric Project (“Project”, FERC No.14383). On August 30, 2013, the Federal Energy Regulatory Commission (“Commission”, “FERC”) issued Scoping Document 1 (SD1) and commenced pre-filing procedures in accordance with the Integrated Licensing Process (ILP). On November 12, 2013, the Oregon Department of Environmental Quality (ODEQ) filed comments with FERC on the PAD and SD1 and offered studies deemed necessary to characterize project-related effects on water quality.

Whitewater proposes to site the Project on Whitewater and Russell Creeks near the town of Detroit, in Marion and Linn counties, Oregon. The Project would be located entirely on U.S. Forest Service (USFS) lands in the Willamette National Forest. On December 29, 2013, Whitewater filed a PSP with the Commission which proposes methods to investigate impacts which the Project may have on affected resources.

The Oregon Department of Environmental Quality (ODEQ) has reviewed the PSP and offers comments on the following proposed studies.

WATER QUALITY STUDY

Little water quality data are currently available to assess conditions in the streams potentially affected by Project operation. Because the Project proposes to divert a significant portion of instream flow from Russell and Whitewater Creeks, its operation may have a significant effect on water quality. Reduced flows can lead to water quality impairments such as higher temperature, lower dissolved oxygen (DO), pH excursions, and habitat alteration. Establishing a baseline water quality assessment is, therefore, deemed essential to evaluate project-related water quality effects.

The PSP adopted a modified version of water quality studies proposed by ODEQ. The principle components of PSP water quality study are presented in Table 1 below.

Table 1. PSP Water Quality Study Plan Location Parameter Frequency Duration a) Diversion (Russell) Temperature hourly May 2014 – April 2015 b) Tailrace (Whitewater) DO; pH; conductivity; hourly 24 hours per month: May c) Russell / Whitewater turbidity through October confluence DO; pH hourly August 2014

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ODEQ concurs with the studies presented in the proposed in the PSP but requests the following recommendations.

Parameters The final study plan determination issued by FERC should include monitoring for the following parameters:

Major Ions: 1 The buffering capacity of freshwater systems is influenced by the composition of certain common major ions. Reduced flows in the bypassed reaches may impair water quality parameters including pH which may cause stressful aquatic conditions. Establishing baseline water chemistry conditions will help understand how aquatic systems resist changes in pH caused by project-related effects. ODEQ recommends quarterly grab sample analysis for this principle ion group.

Nutrients:2 Organic and inorganic forms of nitrogen and phosphorus are principal nutrients which influence primary production. The Project proposes to alter the hydrologic regime of the watershed which may directly influence productivity in affected streams. ODEQ recommends spring, summer, and fall sampling for nutrients to characterize baseline water quality conditions.

Chlorophyll-a; e.coli: ODEQ recommends spring, summer, and fall grab sample analysis for these parameters.

Mercury: Mercury is present in Oregon through naturally occurring mineral sources and atmospheric deposition. Mercury is bioaccumulative in fish tissue in the form of methylmercury. ODEQ recently developed a mercury water quality standard based on the concentration of methylmercury in fish tissue. Mercury methylation is caused, in part, by the metabolism of anaerobic bacteria. Because reduced flow in bypassed reaches may lower DO concentrations, ODEQ recommends initial screening for mercury through quarterly water samples collected at the three principle sampling locations.

Benthic Macroinvertebrates: Reduced streamflow may degrade habitat through steam alteration and reduced sediment delivery. Macroinvertbrate communities are an indicator of water quality and aquatic habitat health. ODEQ recommends Whitewater conduct an assessment of macroinvertebrate communities present in the project area during the spring, summer, and fall using the assessment techniques and survey protocols developed by the Environmental Protection Agency and accepted by the US Forest Service.

1 Major ions include: HCO3-, CO32-, Na-, Cl-, Mg2+, Ca2+, K+, SO42- 2 + - - - Nutrients: NH4 , TKN, NO3 + NO2 ; PO43 , TP

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HYDROLOGICAL EVALUATION

The PSP adopted the principle recommendations of ODEQ and other stakeholders in developing a study plan to characterize the hydrological conditions in the Whitewater and Russell Creek watersheds. A final study plan determination issued by FERC should require sufficient detail to quantify the magnitude, duration, and frequency of flows in the affected watersheds. The study should also determine whether sources of groundwater accretion provide significant contribution to base flows.

In consultation with USDA Forest Service, the applicant should install one gage in the upper bypassed reach of Russell Creek near the proposed diversion and one gauge below the approximate location of the proposed powerhouse on Whitewater Creek. Gages should be installed at appropriate fixed locations using practices that ensure reliable operation and data availability. The applicant should develop rating curves to correlate streamflow with channel stage. Monitoring should be conducted continuously and continue for at least one year.

SOILS, GEOLOGY, AND GEOMORPHOLOGY

Project operation may directly reduce the delivery of critical substrate material below the proposed diversion structure. Managed flows in the bypassed reach may further alter geomorphology, habitat complexity, and sediment delivery. The Applicant should develop a study to evaluate the effect of Project operations on sediment transport between the diversion structure and the powerhouse tailrace. ODEQ supports recommendations by the USDA Forest Service to convene a technical advisory committee to guide development and implementation of plans to evaluate sediment dynamics in affected Project reaches.

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CERTIFICATE OF SERVICE

I certify that I have served the foregoing Oregon Department of Environmental Quality’s

COMMENTS ON PROPOSED STUDY PLAN for Whitewater Green Energy LLC’s

Whitewater Creek Hydroelectric Project by first-class mail or electronic mail upon each person

designated on the official service list compiled by the Secretary in this proceeding and by

electronic filing to FERC.

DATED: March 26, 2014

______Christopher Stine, PE Water Quality Engineer

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Whitewater Creek Hydroelectric project – FERC No. 14383 March 28, 2014

USDA Forest Service Comments to Whitewater Green Power LLC Proposed Study Plan For Whitewater Hydroelectric Project, FERC No. 14383

On December 27, 2013, Whitewater Green Energy filed a Proposed Study Plan (PSP) for the Whitewater Creek Hydroelectric Project (Project) with the Federal Energy Regulatory Commission (FERC). The enclosed comments are provided in addition to the oral comments provided at a Study Plan meeting held in Salem, Oregon, on January 28, 2014 where a review of the PSP was conducted with the Project applicant and interested parties.

In general the Forest Service finds the PSP lacks sufficient detail to adequately determine potential impacts to resources within the project area. Additionally, Whitewater Green Energy has not adopted a number of studies the Forest Service believes are necessary to evaluate direct, indirect, and cumulative effects of the Project and are required to meet Forest Service management direction.

The Forest Service has reviewed the PSP for the Project and offers the following comments on the proposed studies and studies not adopted.

2.1 Water Quality

2.1.4 Existing Information

The Applicant states in the Proposed Study plan on page 6: “There is limited information on existing water quality in either Russell or Whitewater creeks beyond data collected by the applicant in 2012. This data is insufficient to properly assess existing water quality conditions in Russell and Whitewater creeks, or predict future project effects on water quality. Additional water quality monitoring is needed to conduct the required analysis of potential project effects (e.g., streamflow diversions) on water quality and aquatic resources in the project area.”

Recommendation: The paragraph should be modified to reflect the lack of existing information on existing water quality.

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Whitewater Creek Hydroelectric project – FERC No. 14383 March 28, 2014

There is no information on existing water quality in in either Russell or Whitewater creeks. Water quality data is needed to predict future project effects on water quality. Additional water quality monitoring is needed to conduct the required analysis of potential project effects (e.g., streamflow diversions) on water quality and aquatic resources in the project area.

2.1.5 Nexus to Project §5.11(d)(4)

Project diversions for power generation have the potential to modify the existing flow regime of an approximately 3.7-mile-long bypassed reach of Russell Creek and a 1.5- mile-long reach of Whitewater Creek downstream of the project tailrace. These modifications have the potential to adversely affect water temperature and dissolved oxygen concentrations in these stream reaches, as well as in the 2.2-mile-long reach of Whitewater Creek between the confluence of Russell and Whitewater creeks to its confluence with the North Santiam River.

The Forest Service concurs with the water quality studies presented in the proposed study plan, which include temperature, DO, pH, conductivity and turbidity. The Forest Service recommends quarterly grab samples for major ions and mercury as well as spring, summer and fall sampling for nutrients and chlorophyll. The collection of this water quality data will provide valuable baseline water quality information.

Results of this water quality monitoring study would inform potential license articles pertaining to water quality. Characterizing the existing environment for potentially affected water quality parameters and describing the project’s potential effects on these resources is necessary for FERC to carry out their responsibilities under the National Environmental Policy Act (NEPA), the Clean Water Act, the Endangered Species Act (ESA), and the Magnuson-Stevens Fishery Conservation and Management Act.

The study would establish a baseline condition for the potentially affected stream reaches and provide data to be used to predict water temperatures and dissolved oxygen concentrations in Russell and Whitewater creeks Results of this water quality monitoring study would inform potential license articles pertaining to water quality. Characterizing the existing environment for potentially affected water quality parameters and describing the project’s potential effects on these resources is necessary for FERC to carry out their responsibilities under the National Environmental Policy Act (NEPA), the Clean Water Act, the Endangered Species Act (ESA), and the Magnuson-Stevens Fishery Conservation and Management Act.

2.1.6 Study Methods

The Applicant proposes to continuously monitor dissolved oxygen (DO), pH, conductivity, and turbidity with a multi-parameter water quality probe(s) at hourly intervals during one 24-hour sampling event/month from May 2014-October 2014. This monitoring effort will occur at: (a) the diversion location on Russell Creek; (b) the tailrace location on Whitewater Creek; and (c) immediately downstream of the

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Whitewater Creek Hydroelectric project – FERC No. 14383 March 28, 2014

confluence of Russell and Whitewater creeks. The August sampling event for DO and pH will be extended from 24 to 72 hours in order to address ODEQ’s concerns specific to the project’s potential impacts on algal respiration.

The Forest Service recommends quarterly grab samples for major ions and mercury and to conduct spring, summer and fall sampling for nutrients and chlorophyll. The collection of this water quality data will provide valuable baseline water quality information.

2.1.8 Schedules The dates cited in the Proposed Study Plan not correct (page 8).

The Applicant states: “Field monitoring efforts will begin in May 2013 and end in April 2013.”

Forest Service recommends deleting the dates and stating the Water Quality Study be completed during the first study season of the ILP.

2.4 Cultural Resources Survey

2.4.1 Goals and Objectives § 5.11(d)(1)

The Applicant wrote, “The objective of this study is to identify the location of archaeological sites or traditional cultural properties that would be negatively impacted by the hydroelectric project.”

Forest Service recommendation: Please add the wording …”and protect” after the wording “to identify.”

2.4.6 Study Methods §5.11(b)(1) & (d)(5)

The Applicant wrote, “A desktop review of existing sites and/or properties in the project area followed by an on-site comprehensive cultural resource assessment survey will be completed by an Oregon SHPO approved consulting archaeologist in cooperation with the USFS.”

Forest Service recommendation: After this paragraph, please add “a research design and methodology shall be developed in accordance with the Willamette National Forest updated Cultural Resource Inventory Plan and SHPO’s Inventory guidelines. The research design and methodology will detail the survey methods that the Applicant will use to conduct the cultural resources inventory of the proposed Project APE, site recording procedures, the NRHP evaluation strategy and methods for analyzing collected information. A discussion of the theoretical orientation of pre-contact and historic resources, research domains, and associated research questions shall also be included.”

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Whitewater Creek Hydroelectric project – FERC No. 14383 March 28, 2014

This information will be required prior to obtaining an Archaeological Resource Protection Act (ARPA) permit from the Forest Service. The ARPA permit is required prior to conducting cultural resource surveys or excavation on FS managed lands.

2.5 Aesthetic Resources Study

2.5.1 Goals and Objectives

Whitewater Green Power LLC (WGE) adequately described the goals and objectives.

Six miles of distribution (transmission) lines upgrades after the point of interconnection with the grid will not be discussed as part of FERC’s NEPA document since they do not have jurisdiction over these lines. FERC’s NEPA document analysis would be limited to the effects (direct, indirect, and cumulative) of the primary transmission line. WGE will need to work with the Forest Service on approval, including needed studies and NEPA analysis for the distribution line upgrades between the interconnection and Idanha. It would be beneficial for WGE to conduct this study concurrently with FERC studies for efficiency and to meet timelines. The Forest Service would require cost recovery to conduct the NEPA analysis and ultimately permitting, if approved. The Forest Service needs more specific information on the project of where ground disturbance would occur and if any above ground structures are being proposed especially since it is within the sensitive North Santiam Viewshed (Highway 22). The goals and objectives and studies needs as described below, will still apply to the distribution line upgrade and the effects (direct, indirect, and cumulative) to aesthetics will need to be analyzed.

2.5.1 Study Area

The study area as described in the Proposed Study Plan is focused around Russell and Whitewater Creeks, does not encompass the entire project area. On page 21 the Applicant states:

Project areas included in the viewshed analysis used to determine the study area will focus on the following areas. (1) Russell Creek, upstream of the proposed intake facility to the upriver extent of where project features are no longer visible (2) The Russell and Whitewater creek corridors from the proposed intake facility downstream to the proposed powerhouse facility (bypass reach) (3) The Whitewater Creek corridor, downstream of the proposed powerhouse facility, to the downriver extent of where project features are no longer visible (4) Upland areas along the river corridor or existing roads/trails with views of project features

The study area should be more clearly defined to include the entire project area.

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Whitewater Creek Hydroelectric project – FERC No. 14383 March 28, 2014

Forest Service recommendation: Expand the study area to be bounded by Highway 22, Forest Roads 2242 and 040, Trails #2000, #3429 and #3442 (also includes North Santiam Viewshed, Whitewater Viewshed, Inventoried Roadless Area, Potential Wilderness Areas, Wilderness, Wild and Scenic River, National Scenic Trail and National Scenic Byway). In addition, the Forest Service Project study area will also include an area of .25 mile on each side of Highway 22 for the length of the transmission line being considered for upgrade (Wild and Scenic River and National Scenic Byway).

2.5.3 Resource Management Goals

WGE’s proposed study plan captured all the management goals with the exception of those in Willamette National Forest Management Allocations MA-1, MA-1a-d, MA-6c which was omitted and needs to be added. In addition, MA-11c and 11f was inadvertently omitted from the Forest Service Study Plan Request and needs to be added as well.

Omitted in WGE’s proposed study plan, were the laws and regulations, USDA Forest Service direction, and other pertinent plans identified in the Forest Service Study Request. Please refer to Pages 1-3 of the USDA Forest Service Willamette National Forest Study Requests for Scenery Resources, Resource Management Goals and Public Interest Considerations: 18 CFR 5.9(b)(2).

2.5.5 Nexus to Project

The Forest Service inadvertently omitted the nexus with the West Cascades National Scenic Byway and Pacific Crest National Recreation Trail but is mentioned elsewhere in the study request.

2.5.6 Study Methods

In the Proposed Study Plan (on page 24) the Applicant provided “a preliminary list of sensitive view areas provided by the Forest Service”. The Forest Service included on their preliminary list of sensitive viewing areas “recreation sites, cabins and trails,” which was not included on the Proposed Study Plan list. There are two locations along the Pacific Crest National Scenic Trail from which the project area is visible.

Forest Service recommendation: The list of sensitive view areas should be modified to include “recreation sites, cabins and trails, including the Pacific Crest National Scenic Trail”.

As part of the study, describe, evaluate and map existing landscape character, scenic integrity, and landscape visibility using Scenery Management Systems. An evaluation of change to the existing character should include an examination of proposed Project features and operations with respect to the ability of the landscape to accept change and effect on Scenic Integrity and Visual Quality Objectives.

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Whitewater Creek Hydroelectric project – FERC No. 14383 March 28, 2014

2.6 Bypass Reach Instream Flow and Aquatic Habitat Study

2.6.6 Study Methods

In the Proposed Study Plan on page 32, last paragraph, the Applicant states “Techniques for fish relative abundance and/or density assessments will depend upon local site conditions, but will include snorkeling and/or electrofishing.” There is no description on how the snorkeling or electrofishing will be conducted.

Forest Service recommendation: describe methodology that will be used to conduct the snorkeling and electrofishing.

2.7 Botanical Resources and Wildlife Habitat Study

Botanical Resources Comments

1. The Botanical Resource and Wildlife Habitat Studies should be divided into two different sections.

Recommendation: The Botanical Resources and Wildlife Habitat Studies section should be divided into a Botany Resource Section and a Wildlife Resource Section because these are two different resources with unique complexities.

2. The “Goals and Objective” section (Section 2.7.1) of the Botanical Resource Study should be clarified to include additional goals related to the Willamette National Forest Land and Resource Management Plan.

In the Proposed Study Plan (on page 35), the Applicant states

(2) Evaluation of the effects of construction, operation, and maintenance of the diversion structure, penstock, powerhouse, tailrace, transmission line, access roads and any potential staging areas with respect to vegetation, including sensitive plants, riparian vegetation, and wetlands needed for wildlife habitat, and the spread of noxious weeds”

The above paragraph should be modified to include special habitats. Special habitats are non-forested plant communities. Clear direction for managing special habitats is given in several documents including the 1976 National Forest Management Act, the Northwest Forest Plan (USDA Forest Service/USDI Bureau of Land Management, 1994), and the Willamette National Forest Land and Resource Management Plan (USDA Forest Service, 1990). See the Forest Service Study Request for Botanical Resources filed on November 14, 2013, page 3.

If trees in the affected stands are 180 years old or older, the Northwest Forest Plan requires fungal surveys. If any of the proposed activities are in a stand over 180 years

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old, two years of fungal surveys will be required. This should be included in the proposed study plan.

Recommendation: Section 2.7.1 should be modified to include special habitats and the possible need for fungi surveys.

3. The Botanical Study Area should be more broadly described.

The Proposed Study Plan states in Section 2.7.2, page 36, that

The study area will encompass surface land within the project boundary (Figure 4) and areas that would be affected by project construction and operation. These areas include a 300-foot buffer around wetlands and riparian areas adjacent to the intake and powerhouse study area (Figure 4) and a 100-foot buffer along the edge of project access roads where the right-of-way (ROW) could be influenced by project construction or operation, including those roads within the powerhouse study area and Forest Road 440 from Highway 22 to the powerhouse, and a 300- foot buffer from the center line (150 feet on each side) along the transmission line route. The study area around the intake and powerhouse will be expanded to 0.5 miles to support an evaluation of potential noise disturbance associated with construction.”

The study area to be taken into consideration should include all features affected downstream, downhill and uphill regardless of limited feet distances as described. In most cases the limitations put forth would be sufficient but there may be some occasion where areas farther from the site may be affected. For instance, if a threatened, endangered or sensitive species is documented, it will be vital to know what the extent of that population is if it goes beyond the “buffered” survey area in order to determine the effects of the Project. Effects may go beyond 100 feet from the road.

Recommendation: The Study Plan should be amended to describe a study area that includes all features affected downstream, downhill and uphill.

4. Several important resource management goals were omitted from the Resource Management Goals Section in 2.7.3.

Special habitats and sensitive plant species were not included in the list of information needs and are essential for the Forest Service to make an informed decision on issuing a special use permit for this Project. Resource goals relating to them should be included as recommended below.

Recommendation: The following resource management goals (p. 36) (underlined below) should be added to Section 2.7.3.

This study will provide information needed to support the riparian vegetation and wetlands, sensitive plant species, special habitats and noxious weeds study goals.

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This study will provide information relevant to US Fish and Wildlife Service (USFWS), USFS, and ODFW management goals of protecting federal and state- listed species, sensitive plant species, survey and manage species, as well as priority habitats and species and special habitat areas. In addition, the USFS will use this information to issue a special use permit for the Project.

5. The Existing Information Section is incomplete.

The Existing Information section is missing information about the Forest Service Natural Resource Information System and additional justification regarding how the survey information will be used by the agencies.

Recommendation: The Existing Information Section (2.7.4) should be modified to include the Forest Service Natural Resource Information System (NRIS) botany database which contains location information on Forest Service sensitive species and survey and manage species found on the Willamette National Forest, and the Interagency Special Status Sensitive Species Program (ISSSP) website http://www.fs.fed.us/r6/sfpnw/issssp/.

The Forest Service agrees with the Applicant’s conclusion that “[a]dditional habitat, vegetation, and wildlife surveys are needed to conduct the required analysis of potential project effects on habitat and terrestrial resources in the project area.” Pg. 36. This paragraph should be modified to also include the following sentence:

This information is also being collected to a) complete a biological evaluation on effects to Forest Service sensitive species (see Forest Service 2670 Handbook), and b) meet required protocols for Forest Service survey and manage species (see Forest Service 2001 Survey & Manage Record of Decision and Standards and Guidelines available at http://www.blm.gov/or/plans/surveyandmanage/files/rd- rod_s_and_g-2001-01.pdf).

6. The Nexus to Project Section 2.7.5 is incomplete.

This Section does not reference some key Forest Service policies that are used to characterize existing habitat and botanical resources necessary for a complete resource analysis.

Recommendation: The following policies, standards and guidelines and guides should be added to the Nexus to Project Section: Northwest Forest Plan (USDA/USDI, 1994), and the Willamette National Forest Land and Resource Management Plan (USDA Forest Service, 1990), Field Guide to the Forested Plant Associations of the Westside Central Cascades of Northwest Oregon (USDA Forest Service, 2002) (available online at http://ecoshare.info/2009/12/16/plant-associations-of-the-west-central-cascades/) and Willamette National Forest Special Habitat management Guide (USDA Forest Service 2010), available from the Forest Service.

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7. “Complete surveys” is a more accurate term to use than “ground-truthing.”

On page 37 the Applicant states,

Field activities will focus on ground-truthing the draft map to verify and correct cover types and cover type boundaries for the terrestrial habitat study. Ground- truthing will be conducted by a qualified botanist, biologist, or forest ecologist, according to currently accepted methods.

The Forest Service would like the Applicant to change “ground-truthing the draft map” to “complete surveys.” It is unclear how the draft map would be created or where it originated. Completing surveys would be an efficient method of determining the botanical resources present in the project area.

Recommendation: Please change “ground-truthing the draft map” in the above paragraph to “completing surveys.”

8. Botanical surveys should be completed by a qualified botanist.

The Applicant states the “Ground-truthing will be conducted by a qualified botanist, biologist, or forest ecologist, according to currently accepted methods.”

The surveys for botanical resources are: Threatened, Endangered and Sensitive (TES) plants and their habitats, special habitats and noxious weeds. The botanical survey will be done by a journey level botanist. Please refer to the Willamette National Forest study request for survey methodology.

Recommendation: Please correct to state the surveys will be completed by a qualified botanist.

9. The Forest Service does not support use of plots for the botanical surveys.

The Applicant proposed

To characterize habitat in the project area, a minimum of eight 1-meter radius plots will be established representative of habitat that will be disturbed by construction activities. Section 2.7.6 , page 37.

The Forest Service recommends all botanical surveys be completed using the “intuitive control method” and cover the entire area beyond the directly affect area, allowing for documentation of species population extent. Knowing the extent will help in the effects analysis. Plots or transects are not needed for botanical surveys.

Recommendation: The Botanical Study Plan should be amended to use the “intuitive control method” instead of plots.

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10. Daubenmire’s cover classes do not apply to botanical resources.

Daubenmire’s cover classes as proposed in Section 2.7.6, page 37, do not apply to botanical resources as they cover a wide region whereas the plant association guide is distinct for our area.

Recommendation: For the appropriate study method, please refer to the Forest Service’s study request.

11. It is not necessary to submit findings to the Oregon Natural Heritage Program.

The Study Plan on page 38 states,

In addition, findings will be documented and submitted to the Oregon Natural Heritage Program. Any plants encountered during sensitive plant surveys that have not been recorded during vegetation characterization studies will be added to the list of species for the project area.

It is not necessary to submit to Oregon Natural Heritage Program (ONHP) because all data is input to a national database and ONHP has access to that data. The Forest Service should be the main depository of data collected for botanical resources.

Recommendation: All findings should be submitted to the Forest Service.

12. The Forest Service has some concerns with the content of the Study Results Report.

With regard to the Study Results Section 2.7.7, the Applicant states,

A report will be produced describing vegetation at potentially disturbed sites. It will contain a list of plants and the relative cover by each species. Total cover and the average cover in each of the vertical structure categories will also be reported. This document will include a vegetation map with plot locations, plant associations, important vegetation features, and photographs from the reference points.

It is not necessary to report total cover and average cover. Plant associations of the area as defined within the plant association guide will supply this as the guide describes percent cover of species. Use of the plant association guide as a tool will allow the Applicant to determine the plant associations of the area and will also assist with habitat enhancement strategies for mitigation needs if necessary.

The map provided in the study results report should include all mapped sensitive species, noxious weeds and special habitats.

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The Forest Service provided Survey Field Forms in the Botanical Study Request. We would like these completed forms returned to the Forest Service as part of the report.

Recommendation: In the Study Report, the Applicant does not need to report total cover and average cover. However, the map provided in the Study Report should include all mapped sensitive species, noxious weeds and special habitats. Finally, the Applicant should complete the Survey Field Forms and give them to the Forest Service. Wildlife Comments

1. The Botanical Resource and Wildlife Habitat Studies should be divided into two different sections.

The Botanical Resources and Wildlife Habitat Studies section (see Section 2.7) should be divided into a Botany Resource Section and a Wildlife Resource Section because these are two different resources with unique complexities.

2. The “Goals and Objective” section of the Wildlife Habitat Study should be clarified to include additional goals related to the Willamette National Forest Land and Resource Management Plan. See Section 2.7.1.

The Goals and Objectives Section (on pg. 35) should be modified as follows to clarify all the goals (proposed changes are underlined).

The goal of this study is to evaluate the effects of project activities on the terrestrial habitat in the Project area and gather sufficient species information to complete the biological assessment for the northern spotted owl and biological evaluations of Forest Service sensitive species. The goal of the study is also to conduct surveys needed to address the Survey and Management requirements of the Willamette National Forest Land Resource Management Plan for habitat disturbing activities. The terrestrial habitat study combines multiple wildlife habitat study requests made by the United States Forest Service (USFS) in order to most efficiently collect the necessary and relevant information on the project area.

The language proposed above is added to assure that the field studies will be sufficient to conduct the necessary information to complete Endangered Species Act (ESA) consultation and meet the National Environmental Policy Act (NEPA) requirements that the Forest Service will need to issue a special use permit.

3. The specific objectives of the study plan should include additional goals described below related to the ESA and United States Fish and Wildlife Service (USFWS) consultation. See Section 2.7.1, p. 35.

5) Completion of the Sec. 7 Endangered Species Act consultation with USFWS on effects of the Project to northern spotted owl, an endangered species.

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6) Completion of species-specific survey requirements of the Willamette National Forest for habitat disturbing activities.

4. The study area for suitable northern spotted owl habitat should be expanded to 1.2 miles around habitat that would be affected. See Section 2.7.2.

This expansion is necessary to evaluate the potential effects on spotted owl territories which are about 1.2 miles in radius. Initially, suitable spotted owl habitat can be estimated either using the Willamette National Forest mapping of spotted owl habitat or the USFWS mapping that is available at their web site.

5. The following resource management goals (p. 36) (underlined below) should be added to Section 2.7.3.

This study will provide information needed to support the riparian vegetation and wetlands, sensitive plant species, and noxious weeds study goals. This study will provide information relevant to US Fish and Wildlife Service (USFWS), USFS, and ODFW management goals of protecting federal and state-listed species, sensitive wildlife and plant species, survey and manage species, as well as priority habitats and species and special habitat areas. In addition, the USFS will use this information to issue a special use permit for the Project

These items were not included in the list of information needs and are essential for USFS to make an informed decision on issuing a special use permit for this Project.

6. The Existing Information Section (see 2.7.4) should be modified to include the additional sources described below.

Other information sources for wildlife are the Forest Service Natural Resource Information System (NRIS) wildlife database which contains location information on Forest Service sensitive species and survey and manage species found on the Willamette National Forest and the USFS GIS database which has records of peregrine falcon nest sites, known northern spotted owl territories, and forest-wide mapping of spotted owl habitat. Also the USFWS has a range-wide map of spotted owl habitat that can be downloaded from their website. A map of critical owl habitat is also available on the USFWS website. Additional information on Forest Service sensitive species found on the Willamette National Forest is available on the Interagency Special Status Sensitive Species Program (ISSSP) website http://www.fs.fed.us/r6/sfpnw/issssp/. Additional information of Forest Service Survey and Manage species, including survey protocol and management recommendations is available at the BLM Survey and Manage website http://www.blm.gov/or/plans/surveyandmanage/protocols/

The Forest Service agrees with the Applicant’s conclusion that “[a]dditional habitat, vegetation, and wildlife surveys are needed to conduct the required analysis of potential project effects on habitat and terrestrial resources in the project area.” Pg. 36. This paragraph should be modified to also add the following sentence:

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This information is also being collected to a) complete the biological assessment and ESA consultation on northern spotted owl, b) complete a biological evaluation on effects to Forest Service sensitive species (see Forest Service 2670 Handbook), and c) meet required protocols for Forest Service survey and manage species (see Forest Service 2001 Survey & Manage Record of Decision and Standards and Guidelines).

8. The study methods in Section 2.7.6 are incomplete and do not address many wildlife needs.

In the Forest Service wildlife study request filed with FERC on November 14, 2013 numerous surveys were requested that were not included in this proposed study plan. See pg. 48-52 of the applicant’s December 2013 Proposed Study Plan. In light of a better understanding of the Project activities the Forest Service revised recommendations for specific wildlife studies are described below. These recommendations should be included in the Applicant’s revised study plan. It should also be noted that some of the wildlife surveys identified below include two year surveys that must be completed prior to a Forest Service special use permit being issued.

a) Northern Spotted Owl Study: If the Applicant is implementing seasonal restrictions during the critical breeding season (March 1-July 15) for construction activities and during the entire breeding period (March 1-September 30) if Type 1 helicopters or blasting occurs, then potential take of spotted owls from disruption will not be an issue. The remaining concern will be that road construction in suitable habitat would harm nesting spotted owls by falling a nest tree or impacting habitat close (within 300 meters) to a nest which could result in ESA defined take of spotted owls. The Project will impact suitable nesting habitat when constructing a new road to the diversion structure and perhaps elsewhere.

Due to recent litigation, a solid basis for estimating harm to owls which USFWS uses to help determine take under the Endangered Species Act (ESA), relies on knowledge of where owls are nesting when projects directly affect nesting habitat. Thus, the Applicant should conduct protocol owl nest surveys where suitable habitat is going to be directly impacted by road construction or other habitat removal impacts. As this is a two year six visit protocol, the Applicant should consider starting these surveys this year in order to complete the environmental analysis and consultation in a timely manner.

Northern spotted owl habitat must also be mapped by the Applicant to identify suitable nesting/roosting, suitable foraging, dispersal only, and non-habitat. The Applicant can use the available Forest Service or USFWS mapping and refine that based on the field habitat data they intend to collect.

b) Harlequin Duck Study: Harlequin ducks nest adjacent to mountain streams like Whitewater and Russell Creek. The Forest Service concern is that, if harlequin

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ducks are nesting or have newly-fledged young when construction activities occur at the diversion structure, this sensitive species may be harmed by the activities. If the Applicant can implement seasonal restrictions on these activities during the nesting period (mid-April to June 20), then the Forest Service can concur that specific harlequin duck surveys are not needed.

c) Red Tree Vole (RTV) Study: It appears from the Applicant’s response (p. 50) that it does not understand the Forest Service requirements associated with the proposed activities. New road construction to the diversion site, and perhaps other construction activities, may impact RTV habitat and may require RTV vole surveys prior to the Forest Service accepting an environmental analysis for proposed activities on the land it manages. The applicant should replace the Survey Protocol for the Red Tree Vole, version 3.0, 2008 filed with the Forest Service study requests on November 14, 2013 with the current Survey Protocol for the Red Tree Vole, version 3.0, 2012. The Project is in the northern mesic zone. As such, RTV habitat would include conifer forest areas up to 3500’ elevation where the quadratic mean tree diameter of the stand at breast height is greater or equal to 16” or the average mean diameter of the stand is greater or equal to 15”, and where the stand is either multi-layered or has at least 60 percent canopy and two or more super dominant conifer trees/acre. The Forest Service will accept the Applicant mapping this RTV habitat in Year 1 of the study as long as the Applicant completes RTV surveys in Year 2 where such habitat will be affected by road building or other clearing and tree falling activities. In addition, Year 2 surveys must be completed prior to preparation of the EA.

d) Bald Eagle Study: On further review, it is extremely unlikely that any bald eagle nesting occurs in the areas of proposed activities. Consequently, the Forest Service is not suggesting any specific surveys for nesting eagles.

e) Terrestrial Mollusks: Similar to RTV, the Forest Service has a requirement to conduct protocol surveys and manage for two mollusk species. The first is the Crater Lake tightcoil snail (Pristiloma arcticum crateris) that is found within 10 meters of open water in wetlands, springs, seeps, and riparian areas in “perennially wet situations in mature conifer forest, among rushes, mosses and other surface vegetation or under rocks and woody debris.” Where road construction, tree falling, vegetation clearing or other construction occurs in this habitat, including streams crossing, protocol mollusk surveys will be needed (Version 3.0, 2003). The second survey and manage mollusk is Oregon Megomphix (Megomphix hemphilli) which inhabits mature to late seral conifer/hardwood forests often in association with big leaf maple up to 3000’ elevation. Currently surveys are required for this species where habitat-disturbing activities are proposed. Thus the Forest Service can agree to mollusk species surveys being completed in Year 2 prior to EA preparation as long as the Applicant maps the mollusk habitat that will be impacted in Year 1.

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f) We also recommend mollusk surveys where habitat will be affected for Cascade axetail slug (Carinacauda stormi), a newly described monotypic species, that is a Forest Service sensitive species. This species is found in conifer needle litter in Douglas fir/western hemlock forests often in association with vine maple in forests from about 25 years of age to old-growth. This endemic species has a restricted range in the northern part of the western Oregon Cascades but seems to be relatively abundant in suitable habitat within that range with about 394 detections recorded on the Willamette National Forest to date in our Wildlife NRIS database. Habitat evaluation needs to determine if suitable Carinacauda habitat is present. The Forest Service recommends mollusk surveys for this species in suitable habitat. If habitat is present, the Applicant will have to address in a Biological Evaluation why loss of habitat and potential occupied sites will not affect the viability of this species. Survey information would help inform this viability analysis. Biologists on the Willamette National Forest have been involved in the identification of this species and can provide reports on the species. The Applicant should also propose mitigation measures for this species such as depositing downed trees along newly constructed roads in suitable habitat.

g) Amphibian Study: The Applicant should survey for terrestrial amphibians where forest habitat is disturbed. These surveys can be done in conjunction with mollusk surveys with relatively little additional costs and help inform the evaluation of effects of the Project on terrestrial salamanders and other amphibians that are on the Oregon State list of sensitive vulnerable species.

The Applicant should also survey for amphibians in wetlands adjacent to the main stream channel and where construction activities cross perennial streams. The Forest Service believes these surveys should be done because amphibians could be affected if flooding that supports wetlands adjacent to the main stream channel is reduced by the Project. The amphibian surveys where streams are crossed could be done in conjunction with Pristiloma surveys discussed above. The Forest Service supports the Applicant’s desire to make adjustments to Project designs and implement protection, mitigation and enhancement measures for both terrestrial mollusks and amphibians (p. 51). The surveys will greatly inform the development of such designs and mitigation measures.

h) Osprey Study: The Willamette National Forest Land and Resource Management Plan requires protection of active nest sites of raptors. To meet this requirement, the Applicant should conduct a walk-thru search for osprey nests along Russell Creek within 0.25 miles of the proposed diversion structure construction area. Any other raptor nests found incidental to other field work should be identified as well. Effects of Project activities on osprey and other raptors must be addressed in the environmental analysis.

9. The Study Results Report Section should be modified to include the elements underlined below. See Section 2.7.7.

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a) a map of spotted owl habitat and results of spotted owl surveys; b) a map of red tree vole habitat and results of red tree vole surveys; c) a map of Pristiloma, Megomphix, and Carinacauda habitat and results of mollusk surveys; d) identification of any downstream riparian areas potentially impacted by the water diversion; e) results of amphibian surveys; and f) locations of any raptor nests found and areas where specific nest searches were conducted.

10. The study schedules outline in Section 2.7.8 (p. 39) do not take into account the need to survey for survey and manage species or for northern spotted owls.

The Applicant does not provide a road map for how ESA consultation will be completed without spotted owl surveys where suitable nesting habitat will be directly affected. It is notable that if the Applicant does not conduct survey and manage surveys in Year 1, the schedule should plan on conducting Year 2 surveys prior to the completion of the environmental assessment.

11. The costs shown in Section 2.7.0 (p. 39-40) do not account for the costs of spotted owl surveys, red tree vole surveys, mollusk surveys, and amphibian surveys and should be corrected.

The Red Tree Vole Survey Protocol should be revised from the version filed with FERC by the Forest Service on November 14, 2013 to the new Red Tree Vole Survey Protocol, Ver. 3.0, 2012.

2.9 Recreation Resources Study

2.9.1 Goals and Objectives

The goals and the objectives of Whitewater Green Energy’s, LLC (WGE) proposed study plan does not address what the study is intended to accomplish, which is to gather data and information to be able to analyze the short and long term effects of Project construction, operation and maintenance on recreation within the vicinity of the Project, including recreation use, opportunities, facilities, access, and visitor experience. Please refer to Page 1 of the USDA Forest Service Willamette National Forest Study Requests for Recreation Resources, Study Goals and Objectives: 18 CFR 5.9(b)(1).

As requested, the objectives of the Recreation Resources Study are to: 1. Provide a detailed description of recreation use, activities, facilities, access and opportunities that are present in general vicinity of the proposed. 2. Describe the effects of the Project on recreation use, opportunities, facilities, and access.

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3. Describe how recreation settings and experiences would be affected by the Project.

As this Project is proposed to be located on National Forest System (NFS) lands, this information is necessary to ensure that Project impacts to these NFS recreational resources are appropriately evaluated and mitigated or opportunities created by the project enhanced consistent with applicable laws, regulations, directives and policy.

Six miles of distribution (transmission) lines upgrades after the point of interconnection with the grid will not be discussed as part of FERC’s NEPA document since they do not have jurisdiction over these lines. FERC’s NEPA document analysis would be limited to the effects (direct, indirect, and cumulative) of the primary transmission line. WGE will need to work with the Forest Service on approval, including needed studies and NEPA analysis for the distribution line upgrades between the interconnection and Idanha. It would be beneficial for WGE to conduct this study concurrently with FERC studies for efficiency and to meet timelines. The Forest Service would require cost recovery to conduct the NEPA analysis and ultimately permitting, if approved. The Forest Service needs more specific information on the project of where ground disturbance would occur and if any above ground structures are being proposed. The goals and objectives and studies needs as described below, will still apply to the distribution line upgrade and the effects (direct, indirect, and cumulative) to recreation will need to be analyzed.

2.9.1 Study Area

The FERC Project study area should include more than Forest Roads 040 and 440. People use the forest surrounding Project area for recreational activities and the effects of the construction, operation and maintenance of the Project would go beyond just these two road systems. The Project area is defined as the area within the vicinity of the intake at the diversion structure in Russell Creek to the outflow of the tailrace in Whitewater Creek and associated roads, penstock, powerhouse, and transmission line and facilities along Highway 22. This Project study area should include the entire sub-watershed that the project is in (Whitewater drainage) as visitors move through the entire area on formal road networks (e.g. Roads 2242, 040, 440, 030) and trails off these roads (Trails #3441, #3429 and #3442) to the Pacific Crest Trail (#2000). The use is also dispersed in nature throughout the general forest off of roads and trails for hunting, fishing, gathering, hiking, winter sports, etc.

The FERC study area for recreation should include the area near the Project and the area bounded by Highway 22, Forest Roads 2242 and 040, Trails #2000, #3429 and #3442. In addition, the Forest Service Project study area will also include an area of .25 mile on each side of Highway 22 for the length of the transmission line being considered for upgrade.

Please refer to Page 5 paragraph 2, of the USDA Forest Service Willamette National Forest Study Requests for Recreation Resources, Proposed Study Methodology: 18 CFR 5.9(b)(6).

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2.9.3 Resource Management Goals

WGE’s proposed study plan captured all the management goals with the exception of those in Willamette National Forest Management Allocations MA-1, MA-1a-d, MA-6c which was omitted and needs to be added. In addition, MA-11c and 11f was inadvertently omitted from the Forest Service Study Plan Request and needs to be added as well.

Omitted in WGE’s proposed study plan, were the laws and regulations, USDA Forest Service direction, and other pertinent plans were identified. Please refer to Pages 2-3 of the USDA Forest Service Willamette National Forest Study Requests for Recreation Resources, Resource Management Goals and Public Interest Considerations: 18 CFR 5.9(b)(2).

2.9.4 Existing Information

WGE’s proposed study plan only captured a portion of the existing information that was provided by the Forest Service Study Request for Recreation Resources. Project impacts go beyond just temporary displacement of recreators on FS Roads 040 and 440 that was mentioned in 2.9.3 of WGE’s proposed study plan. Hiking, hunting, fishing, scenic driving and camping are some of the primary dispersed recreational activities that occur in the Project vicinity, however, other common activities include sightseeing, nature study, mushroom and huckleberry picking, sledding (Whitewater rock pit), cross country skiing (on roads into Wilderness), off highway vehicle use, kayaking, etc. Non- motorized trails provide hiking and equestrian use opportunities within the Mt. Jefferson Wilderness and along the Pacific Crest National Recreation Trail, and access to climbing Mt. Jefferson. Overnight lodging occurs at nearby cabins, one along Whitewater Creek, and Whispering Falls Campground on Highway 22. There are numerous dispersed (undeveloped) campsites (indicated by fire rings, turnouts, compacted ground) within and adjacent the Project area that have not been inventoried (mapped and evaluated) that could be affected by the Project. Please refer to Pages 3-5 of the USDA Forest Service Willamette National Forest Study Requests for Recreation Resources, Existing Information and Need for Additional Information: 18 CFR 5.9(b)(4).

As mentioned on the Forest Service study request on page 4, there is a need to describe the project and existing condition to be able to understand the short and long term effects of the Project on recreation use (levels), activities, settings, opportunities, access, facilities and subsequent effects to visitor experience.

Potential Project effects include: • noise disturbance (decibel levels at varying distances) that could affect recreation activities, opportunities or use; • physical alteration of recreation settings and sites; • changes in a recreation opportunities (and Recreation Opportunity Spectrum (ROS));

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• diminished public access to the project area including temporary or permanent area and road closures, and temporary trail closures; • increased access and subsequent use due to the development of Project facilities, and how use would be controlled and managed.

In addition, the Forest Service Project Study Area will also include an area along Highway 22 for the length of the transmission (distribution) line being considered for upgrade.

2.9.5 Nexus to Project

Project impacts go beyond just the “temporary displacement of recreators on FS Roads 040 and 440” that was mentioned in 2.9.3 of WGE’s proposed study plan. Construction of the Project could (temporarily or long term) close areas, roads and access to trails, cause noise and dust in the vicinity, alter recreation settings (ROS) and opportunities, affect visitor experiences, and displace visitors. Maintaining and operating the project could change recreation settings, opportunities and access, and subsequently potentially effect visitor experiences in the long term. Please refer to Pages 5 of the of the USDA Forest Service Willamette National Forest Study Requests for Recreation Resources, Nexus to Project Operations and Effects: 18 CFR 5.9(b)(5)

The information gathered will help identify appropriate protection, mitigation or enhancement measures to be identified to eliminate and minimize effects. Constructing the project in a manner that minimizes impacts to recreation opportunities through timing of activities or designing facilities to reduce affects to settings can offset impacts to visitors and their experiences.

2.9.6 Study Methods

Please refer to Pages 6-8 of the of the USDA Forest Service Willamette National Forest Study Requests for Recreation Resources, Proposed Study Methodology: 18 CFR 5.9(b)(6). The Forest Service requested that the existing recreation inventory information from a variety of sources be compiled, updated and synthesized in a written assessment including maps (as described on pages 6-8). This information was entirely omitted in WGE’s proposed study plan and needs to be added (see list of recreation inventory on Page 6). The existing information for this resource topic should be compiled and displayed on maps to include: • all Project facilities and work areas; • Recreation Opportunity Spectrum (ROS) classifications to describe setting and experiences in the project vicinity • open, publically-accessible roads by vehicle type as depicted on the Willamette National Forest Motor Vehicle Use Map (MVUM); • designated scenic byways; • developed recreation sites (e.g., nearby campgrounds, trailheads, day use areas, cabins, etc.); • National Scenic trails and all other trails, and trailheads;

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• Lakes, creeks and rivers (with eligible wild and scenic rivers and their classification labeled); • Inventoried dispersed campsites delineated by usage (not existing - to be collected by Applicant) • Wilderness campsites inventoried by the Forest Service • wild and scenic rivers, wilderness areas, inventoried roadless areas, and potential wilderness areas; • communities and nearby cabins.

The Forest Service concurs with the use of pressure sensitive traffic counters of Road 040, however, there shall also a counter installed along Road 2242 to get a more accurate measure of visitation in the project vicinity or study area described above. The counter should be used when clear of snow which varies year to year (typically April through the end of November). The Forest Service study request identified how recreation use can be compiled using existing sources (e.g. permit data, agency and stakeholder knowledge, maps, etc.) including site visits. WGE proposes to do a field investigation in August and October documenting recreation sites on Roads 040 and 440 including GPS location, dimensions, unique characteristics and photo documentation. The Forest Service requested that use levels based on observation be estimated for each dispersed sites as defined on page 6 and should be added. The Forest Service also requested that dispersed sites (and user-created trails, e.g. to the impoundment) along Road 2242 shall also get inventoried because it lies within the Project vicinity or study area described above (and is within sight and/or sound of the Project).

WGE’s states the timing of the investigative visits is intended to coincide with warm weather and hunting related use. To get a more accurate depiction of recreational use through observation or encounters, it is advised to have more sample visits on weekends. The proposed study plan did not indicate the sampling methodology, how often, when (e.g. days of the week) and omitted winter/spring use. There is also winter and spring use which is more intermittent and shall be sampled as well. Interviews of known users in the area, such as the Chemeketans hiking club who have a cabin in the project area along Whitewater Creek, could be conducted to evaluate use. Club members and general recreationists ski into the Mt. Jefferson Wilderness from Forest Roads 2242 and 040. Winter use, sledding, also occurs at Whitewater rockpit on Road 040-041. There is a popular recreation/dispersed site along Road 030 (along Whitewater Creek) which the Whitewater Creek Conservation Association has informally adopted and has interest in the Whitewater Creek watershed (i.e. Project area) and could also be interviewed. Forest Service Comments to the Preliminary Application Document, Page 18, Section 5.6(d)(5), Summary of Contacts has a list of stakeholders in the area that can be interviewed regarding evaluation of recreation use, e.g. Pacific Crest Trail Association (trail use, scenic concerns), Rocky Mountain Elk foundation, Oregon Hunters Association (hunting use), etc.

The study omitted and should identify the visitor demand for recreation activities that are pertinent to the Project area and how this demand could change in the future over the life of the Project. Information should be obtained from various sources, such as the

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Statewide Comprehensive Outdoor Recreation Plan (SCORP), National Visitor Use Monitoring Study, demand forecast publications etc. to help determine predicted changes in anticipated demand for the outdoor recreation activities associated with the Project.

2.9.7 Study Results

WGE proposes to draft a report describing the results of the 2014/2015 recreation resources study but appears to be limited to measuring dispersed sites along Roads 040 and 440. This is not complete. A report of the recreation inventory, recreation use, demand analysis and effects analysis shall be incorporated into the study results. Please refer to Pages 7-8 of the of the USDA Forest Service Willamette National Forest Study Requests for Recreation Resources, Proposed Study Methodology: 18 CFR 5.9(b)(6), Effects Analysis.

Once the existing recreation inventory and recreation use and demand information is gathered and described, an impact or effects analysis should be conducted and documented in a report. The effects analysis should include direct, indirect, and cumulative impacts to recreation from Project activities and whether or not the impacts would be short term, long term, or permanent. This study should make use of and integrate information resulting from other requested studies. For example, the Scenery Resources study should be used to determine effects on recreation setting and subsequently, the visitor experience relationship. The effects of distribution and abundance of fish and wildlife, and potential effects to anglers and hunters could be assessed using findings from these relevant wildlife and fish studies. Information on effects of the project on ROS would inform land use studies (Wilderness and Inventoried Roadless Area and affects to Wilderness values)

Items to address in the affects analysis report: • Direct impacts to recreation facilities or sites or their use including inventoried dispersed campsites. For example, will the project eliminate sites or cause temporary displacement of use elsewhere during Project construction, etc.? • Potential effects of the Projects on dispersed recreation opportunities and activities listed in the Existing Information section above. • How recreation setting and experiences would be affected by the Project using Recreational Opportunity Spectrum (ROS) classification to evaluate (e.g., Roaded Natural ROS along the roadways, Semi-primitive ROS in the Inventoried Roadless Area (IRA) and Pristine ROS in the Wilderness). For example, how does the project affect the natural setting/undeveloped character and opportunity for solitude or primitive and unconfined recreation quality in the area around the diversion structure and impoundment within Wilderness and IRA. • Potential noise effects during construction and operation of facilities by likely decibel levels at varying distances and potential impacts to recreation use, activities and experiences. • Diminished public access to the project area including temporary or permanent area and road closures, and temporary trail closures.

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• Increased access and subsequent use due to the development of Project facilities including cleared corridors, and how used would be controlled and managed. • Potential effects of the Project on travelers of West Cascades National Scenic Byway including any potential changes to the corridor setting, its intrinsic qualities and effects on experience. • Effects of the project on future recreation opportunities and use.

All data gathering, studies, surveys, analysis and reports should be performed by a person knowledgeable and experienced in outdoor recreation planning, forest landscape architecture, sociology or related fields in order to ensure policies, standard guides, methods, principles, and procedures in recreation planning and scenery management are adhered to.

3.0 Studies Requests Not Adopted

Bedload and Sediment Study

The Applicant did not adopt the Bedload and Sediment Study requested by the Forest Service. Russell Creek and Whitewater Creek are important contributors of bedload and sediment to the stream reaches in Whitewater Creek and the North Fork Santiam River below the proposed bypass reach. The Forest Service recommends the Bedload Study be expanded and adopted.

Goals and Objectives

A study and subsequent analysis should be completed to ensure that an operation plan can be developed and implemented for the facility that will not change the timing, magnitude, duration, and spatial distribution of peak, high and low flows in the reach of Russell Creek and Whitewater Creek between the diversion dam and the tailrace.

Study Area

The study area includes the reach of Russell Creek and Whitewater Creek between the diversion structure and the tailrace, and the reach immediately downstream of the tailrace in Whitewater Creek.

Resource Management Goals

This will confirm compliance with regulations in the Northwest Forest Plan (ACS Objective 6, LH-1 and LH-2), and thus support a FERC license and special use permit for the proposed facilities.

Existing Information

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There is no existing information for bedload and sediment transport in Whitewater Creek and Russell Creek. Estimates of sediment transport rate are needed to determine the annual sediment load, calculate sediment budgets, and estimate quantities of gravel extraction or augmentation. These estimates are also needed to assess stream response to changes in water and sediment supply (for example, from fires, landslides, forest harvest, urbanization, or reservoir flushing) and determine the impact of these changes on receiving waters (for example, reservoir filling and downstream water quality impacts).

We also need to know rates of sediment transport in order to predict channel change. Stream channel change depends on both water and sediment supply. Changes in sediment transport rate along a channel are balanced by bed aggradation/degradation and bank erosion.

Nexus to Project

Changes in bedload and sediment transport due to flow diversion at the intake structure could result in a change in channel morphology in the bypass reach and long term spawning gravel recruitment to the lower reaches of Whitewater Creek and the North Fork Santiam River. Loss of spawning gravel recruitment would affect native cutthroat trout and eventually ESA listed Upper Willamette winter steelhead trout.

The proportion of the bed entrained is relevant for defining the extent of benthic disturbance and the effectiveness of flows in accessing the bed substrate needed for flushing fine sediment from spawning and rearing gravels.

Study Methods

Directly measure bedload movement using a bedload trap as described in Bunte, K. and J. Potyondy (2004) available on the web at: http://www.stream.fs.fed.us/news/streamnt/pdf/oct04.pdf and Bunte, K. et al. (2004) available on the web at: http://www.fs.fed.us/rm/pubs_other/rmrs_2004_bunte_k001.pdf

Bedload sampling should occur in several locations because of the variability of conditions in the bypassed reach. Sampling should occur both in the bypassed reach and below the proposed tailrace outflow. Sampling should occur during high flows in the spring. Enough sampling stations should be established at each cross section to accurately characterize tributary bedload. Relevant resource agencies (e.g. Forest Service, ODEQ and ODFW) should be consulted prior to data collection to approve sampling frequency. The applicant is expected to develop a study plan that incorporates protocols recognized by the scientific community and sufficient to determine an operational plan for the facility that is consistent with regulations (see discussion above). We will review the study plan and make recommendations to alter the plan if needed.

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Sediment and bedload transport should be sampled and modeled in the bypass reach using procedures similar to the Manual for Computing Bedload Transport using Bedload Assessment for Gravel-Bed Streams (BAGS) software and Sediment transport primer: estimating bed-material transport in gravel-bed channels.

The BAGS software uses six well-known bed load transport equations developed specifically for gravel-bed rivers:

• the surface-based equation of Parker (1990); • the substrate-based equation of Parker- Klingeman-McLean (Parker and others 1982); • the substrate-based equation of Parker and Klingeman (1982); • the surface-based two-fraction equation of Wilcock (2001); • the surface-based equation of Wilcock and Crowe (2003); and • the procedure of Bakke and others (1999).

Each of the six equations requires the input of a measured channel cross section, an estimate of the reach averaged water-surface slope, range of discharges, and varying types of sediment data from the bed surface, substrate or bed subsurface, and/or bed load sample data. These input parameters for the equations are easily collected in the field or obtained from other resources.

The BAGS program, the BAGS user’s manual, and sediment transport primer can be downloaded from the STREAM website: http://www.stream.fs.fed.us/publications/software.html. BAGS may be updated as features and modeling capabilities are added to the program. Users are encouraged to periodically check the STREAM website for the latest updates to the BAGS program. Printed copies of Rocky Mountain Research Station General Technical Reports, GTR- 223 and GTR-226, can be obtained from the Rocky Mountain Research Station by submitting your mailing information by telephone: (970) 498-1392; facsimile: (970) 498-1122; e-mail : [email protected]; website: http://www.fs.fed.us/rm/publications; or mail: Publications Distribution, Rocky Mountain Research Station, 240 West Prospect Road, Fort Collins, CO 80526

Study Results

A report describing the results of the 2014/2015 bedload-sediment transport study should be prepared at the end of the first study season and included in the Initial Study Report (ISR) filed in May of 2015. The report will summarize the data and discuss the results in the context of the goals and objectives of the study plan. In addition, the results of the bedload-sediment transport study will be used in concert with the results of the water quality and instream flow studies to prepare protection, mitigation, and enhancement plans.

Schedules

The bedload-sediment transport study would be completed for a full year during the first study season of the Integrated Licensing Process with an individual report prepared as part of the ISR. Field monitoring efforts and sampling should occur during high flows in the spring, winter rain on snow events and in the hotter summer months during rapid glacial melt in Russell Creek. The applicant should be aware that FERC, ODEQ, ODFW,

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USFS and other stakeholders may request additional monitoring if additional data collection is warranted after the 2014/2015 study effort.

Level of Effort and Cost The estimates for sampling equipment and labor associated with monitoring, data analysis, and reporting for the bedload-sediment transport study is $28,000.

Macroinvertebrate Sampling

The Applicant did not adopt the Stream Macroinvertebrate Study requested by the Forest Service and ODFW. Marcoinvertebrate sampling should be included in the study plan for the Whitewater project. Sampling should be conducted in the proposed bypass reaches of Russell Creek and Whitewater Creek to collect base line macroinvertebrate information.

The USDA Forest Service and other stakeholders to the Whitewater Hydropower Project have interests and responsibilities associated with aquatic, riparian and other resources in Russell Creek and downstream in Whitewater Creek. These resources are not currently impacted by the operations of the project; and in its current form, the proposed project is expected to affect a multitude of geomorphic processes by altering the stream flows. Alteration of these processes will affect aquatic resources, both directly and indirectly. In particular, it will be important to quantify the hydrological processes that promote good habitat conditions for aquatic and riparian-dependent organisms to ensure compliance with regulations that protect these aquatic resources. A critical reference for good habitat conditions will be the inherent, natural capacity of Russell and Whitewater creeks hydrology, channel geomorphology, and ecology. Priority habitat conditions in Russell Creek and Whitewater Creek include those for Aquatic macroinvertebrates.

Alterations to the flow regime including diversion during peak and low flows has the potential to affect riparian vegetation, macroinvertebrate populations, and other important nutrient cycling related inputs to the stream system.

Nexus between project impacts & license conditions: The information provided by these studies will assist the stakeholders in the licensing of the Whitewater Hydroelectric Project in developing facilities and operational procedures necessary to meet regulatory requirements and protect aquatic resources of concern that could be impacted by altering the timing, magnitude, duration, and spatial distribution of peak, high, and low flows.

The Willamette National Forest Land and Resource Management Plan (LRMP) (Willamette National Forest, 1990) contains standards and guidelines that pertain to the management of soil and water resources, including specific references to in-stream flows and watershed enhancement. Forest-wide Standard FW-113 states “In-stream flow on National Forest System Lands shall be protected through environmental analysis of proposed water uses, diversions, transmission applications, and renewal of permits.”

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Standard MA-15-11 states “Stream-banks and channel stability shall be protected, rehabilitated, or enhanced to meet the water quality and aquatic habitat objectives.”

The Willamette LRMP was amended in 1994 by the “Northwest Forest Plan” (NWFP) (USDA/ USDI 1994). The NWFP Record of Decision (ROD) incorporated additional standards and guidelines, including the Aquatic Conservation Strategy (ACS) into the Willamette LRMP. The ACS is comprised of four components (riparian reserves, key watersheds, watershed analysis, and watershed restoration). There are nine ACS Objectives that outline requirements to maintain and restore ecosystem health in the aquatic ecosystems to protect habitat for fish and other riparian-dependent species and resources and restore currently degraded ecosystems. The project construction and operational effects to the NWFP Riparian Reserve land allocation will need to be evaluated against standards and guidelines and ACS objectives to ensure regulatory compliance.

The construction and operation of the Whitewater Project has the potential to affect aquatic biota, including Aquatic benthic macroinvertebrates (ACS Objectives 1, 2, 4, and 9).

The nature of the impacts of the diversions proposed on riparian plant communities, water quality, aquatic biota, and flow regimes in the Russell Creek bypassed reach and subsequent downstream effects on Whitewater Creek are unknown. Implementing studies including accurate collection of data should be included in the analysis in support of FERC license and conditional use permit for these facilities.

Stream Macroinvertebrates

Macroinvertebrate populations can be affected by rapid changes in streamflow, manipulations in streamflow, habitat degradation, and changes in water quality. There are currently three macroinvertebrates on the sensitive species list: Namamyia plutonis, Rhyacophila chandleri, and Rhyacophila leechi. The study requirement is to sample stream macroinvertebrates for one season (spring, summer and fall) using stream kick-net or Serber Sampler to quantify species composition and relative abundance. Study area should include upstream of the project, in the bypassed reach, and below the bypassed reach to compare the reaches above and below the project and evaluate any potential effects of the reduced bypass flows on aquatic macroinvertebrates. The applicant is expected to develop a study plan that incorporates protocols recognized by the scientific community and sufficient to determine an operational plan for the facility that is consistent with regulations (see discussion above). We will review the study plan proposed protocol for frequency and location of macroinvertebrate sampling and make recommendations to alter the plan if needed.

We agree with ODFW and ODEQ that no existing information is currently available so a complete study will be needed to establish baseline conditions. The study will be needed to determine consistency with the Forest Plan and ACS objectives 1, 2, 4, and 9 (see discussion on Basis for Study above).

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A report describing the results of the 2014 macroinvertebrate monitoring effort will be prepared at the end of the first study season and included in the Initial Study Report (ISR) filed in May of 2015. The report will summarize the data and discuss the results in the context of relevant baseline conditions. In addition, the results of the Macroinvertebrate Study will be used to determine potential impacts, as well as prepare protection, mitigation, and enhancement plans.

The Macroinvertebrate Study would be completed during the first study season of the Integrated Licensing Process with an individual report prepared as part of the ISR.

Land Uses

Whitewater Green Power LLC (WGE) did not adopt the “USDA Forest Service Willamette National Forest Study Requests for Land Uses,” which includes: • Wilderness • Potential Wilderness Areas (PWAs) • Inventoried Roadless Areas (IRAs) • River segments eligible for designation under the Wild and Scenic Rivers Act • Other Congressionally Designated Areas or features of interest, such as the Pacific Crest National Scenic Trail, West Cascades National Scenic Byway. • Other land uses including Forest Service permittees, and private and state property.

WGE states that the information will be addressed through other studies; however, there is no attention within any of the other resources studies (fish, wildlife, cultural, hydrology, geology, ecology/vegetation) about the special land designation needs (with the exception of aesthetics) and the necessity for a synthesized study. While data may be collected through various resource studies, a synthesized report for each of the above is necessary. For example, “Wilderness Character” encompasses all resources but needs to be described and analyzed in one synthesized interdisciplinary report specifically for Wilderness (see page 13 of the USDA Forest Service, Willamette National Forest, Study Request for Land Uses).

These specially designated land use areas are guided by law, regulations, directives and policy and cannot be omitted from study. The Forest Service is requesting that this analysis and study be completed to inform the environmental analysis and regulatory requirements. Please refer to the USDA Forest Service, Willamette National Forest, Study Request for Land Uses for specific information.

The goal of the study is to gather specific data and information in order to determine the short- and long-term effects of Project construction, operation, and maintenance on the following: • Mt. Jefferson Wilderness

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• Potential Wilderness Areas (PWAs) • Inventoried Roadless Areas (IRAs) • River segments eligible for designation under the Wild and Scenic Rivers Act • Other Congressionally Designated Areas or features of interest, such as the Pacific Crest National Scenic Trail, West Cascades National Scenic Byway. • Other land uses including Forest Service permittees, and private and state property.

The objectives of the study are to: 1. Determine how the Project may impact the wilderness resources, values, and character of the Mt. Jefferson Wilderness (methodology on Page 13 of the Forest Service Land Uses Study Request). 2. Determine how the Project may impact PWAs and their eligibility for potential future designation as wilderness (methodology on Page 13-14 of the Forest Service Land Uses Study Request). 3. Determine how the Project may impact the Mt. Jefferson IRA (methodology on Page 14-15 of the Forest Service Land Uses Study Request). 4. Determine how the project may impact the free-flow, water quality, and Outstandingly Remarkable Values of the North Santiam River, an agency- identified (5d) river eligible for designation under the Wild and Scenic River Act (methodology on Page 15 of the Forest Service Land Uses Study Request). 5. Determine how the project may impact other Congressionally Designated Areas or features of interest, including the Pacific Crest National Scenic Trail (methodology on Page 15-16 of the Forest Service Land Uses Study Request). 6. Determine how the Project would impact other land uses including Forest Service permittees, private and state property.

As this Project is proposed to be located on National Forest System (NFS) lands, this information is necessary to ensure that these NFS resources are appropriately managed by the USFS consistent with applicable laws, regulations, directives and policy.

The FERC study area for Land Uses should include the above listed congressionally designated areas or features of interest. The study area is generally bounded by Highway 22, Forest Roads 2242 and 040, Trails #2000, #3429 and #3442 (includes IRA, PWA, Wilderness, Wild and Scenic River, National Scenic Trail and National Scenic Byway). In addition, the Forest Service Project study area will also include an area of .25 mile on each side of Highway 22 for the length of the transmission line being considered for upgrade (Wild and Scenic River and National Scenic Byway).

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SURVEY PROTOCOL

FOR THE

RED TREE VOLE

Arborimus longicaudus (= Phenacomys longicaudus in the Record of Decision of the Northwest Forest Plan)

Photo by Nick Hatch

Version 3.0 November 2012

USDA Forest Service Region 6, Oregon and Washington USDA Forest Service Region 5, California USDI Bureau of Land Management, Oregon and Washington

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Authors

ROB HUFF, Conservation Planning Coordinator, Interagency Special Status/Sensitive Species Program, USDI Bureau of Land Management/USDA Region 6 Forest Service, Portland, Oregon.

KELLI VAN NORMAN, Inventory Coordinator, Interagency Special Status/Sensitive Species Program, USDI Bureau of Land Management/USDA Region 6 Forest Service, Portland, Oregon.

CAROL HUGHES, Special Status and Sensitive Species Specialist, Interagency Special Status/Sensitive Species Program, USDI Bureau of Land Management/USDA Region 6 Forest Service, Portland, Oregon.

RAY DAVIS, Old Forest and Spotted Owl Monitoring Lead, USDI Bureau of Land Management/USDA Region 6 Forest Service, Corvallis, Oregon.

KIM MELLEN-MCLEAN, Regional Wildlife Ecologist, USDA Region 6 Forest Service, Portland, Oregon.

Citation

Huff, R., K. Van Norman, C. Hughes, R. Davis and K. Mellen-Mclean. 2012. Survey Protocol for the Red Tree Vole, Version 3.0. Portland, OR. U.S. Department of the Interior, Bureau of Land Management, Oregon/Washington, and U.S. Department of Agriculture, Forest Service Regions 5 and 6. 52 p.

This protocol modifies and replaces the following documents:

Biswell, B., M. Blow, L. Finley, S. Madsen, and K. Schmidt. Undated. Survey Protocol for the Red Tree Vole, Version 2.0. Portland, OR. U.S. Department of the Interior, Bureau of Land Management, Oregon/Washington, and U.S. Department of Agriculture, Forest Service Regions 5 and 6. 32 p.

Biswell, B., M. Blow, R. Breckel, L. Finley, and J. Lint. 2002. Survey Protocol for the Red Tree Vole, Version 2.1. Portland, OR. U.S. Department of the Interior, Bureau of Land Management, Oregon/Washington, and U.S. Department of Agriculture, Forest Service Regions 5 and 6. 13 p.

USDA Forest Service, and USDI Bureau of Land Management. 2003. Red Tree Vole Protocol Revision, Version 2.2-Release of Pre-Disturbance Survey Requirements in Six Watersheds. BLM-Instruction Memorandum No. OR-2003-075. Portland, OR. U.S. Department of the Interior, Bureau of Land Management, Oregon/Washington, and U.S. Department of Agriculture, Forest Service Regions 5 and 6. 1 p. http://www.blm.gov/or/plans/surveyandmanage/files/12-red_tree_vole_v2-2.pdf

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TABLE OF CONTENTS

SUMMARY OF MODIFICATIONS TO PREVIOUS PROTOCOL VERSIONS 4

CRITERIA FOR DETERMINING THE NEED FOR PRE-DISTURBANCE SURVEYS 5

NATURAL HISTORY 11 Geographic Range of Tree Voles 12

NEST CATEGORIZATION 13 Categorizing Confirmed Red Tree Vole Nests 14

DETERMINATION OF RED TREE VOLE SITES AND HABITAT AREAS 18

SURVEY METHODOLOGY 20 Modified Line Transect Survey Method 21 Individual Tree Examination Survey Method 21 Additional Survey Guidelines for Stands with Large Trees 22 When Potential Nest Structures are Observed During Surveys 23 Survey Longevity 25 Surveyor Skills and Training 25 Data Management and Data Entry 25 Protocol Modifications 26

ACKNOWLEDGEMENTS 26

LITERATURE CITED 27

TABLES AND FIGURES TABLE 1: Nest Categorization Codes and Characteristics 17 TABLE 2: Definitions of Red Tree Vole Site Types 19 FIGURE 1: Northern Mesic, Mesic, and Xeric Survey Zones for the red tree vole 6 FIGURE 2: Watersheds exempted from red tree vole surveys in Matrix and Adaptive Management Areas 8 FIGURE 3: Example Transect Layout 32

APPENDICES APPENDIX I: How Line Transect Spacing was Calculated for Line Transect Surveys 30 APPENDIX II: Red Tree Vole Field Forms for Use by BLM in the GeoBOB Database 33 APPENDIX III: Red Tree Vole Field Forms for Use by Forest Service in the NRIS Wildlife Database 43

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SUMMARY OF MODIFICATIONS TO PREVIOUS PROTOCOL VERSIONS

This protocol combines Versions 2.0, 2.1, and 2.2 of the red tree vole survey protocol into one format and incorporates new direction regarding boundary lines and elevational limits for the Northern Mesic, Mesic, and Xeric Survey Zones (USDA and USDI 2000, 2001). The structure and organization of the document have been modified and new information added. The main changes in this updated protocol are a:

1. Modification of terminology, removing the term “Distribution Zone” and replacing it with “Survey Zone” to more accurately depict the intent of the delineated Northern Mesic, Mesic, and Xeric Zones,

2. Decrease in the upper elevation limit for surveys in portions of the Northern Mesic and Mesic Survey Zones,

3. Change in the eastern boundary and a decrease in the elevation limit for surveys in portions of the Xeric Survey Zone,

4. Modification of the time limitation before surveys must be repeated,

5. Focus on the need to conduct tree climbing to determine if a nest is a red tree vole nest and occupancy status of red tree vole nests,

6. Modification of the second set of conditions describing habitat under “General Habitat Descriptions,” replacing pre-dominant with superdominant when considering stands with large tree components,

7. Recommendation to conduct tree climbing sampling in stands containing larger (> 36″ dbh) trees, if visibility into the larger trees is poor and ground based surveys yield no vole nests,

8. Clarification of information about habitat and nests, and updates of pertinent literature,

9. Modification to data forms and data entry procedures, and

10. Refinement of the former system of categorizing red tree vole nests as “active” or “inactive” with finer categories that reflect nest occupancy based on observations of voles and nest materials.

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CRITERIA FOR DETERMINING THE NEED FOR PRE-DISTURBANCE SURVEYS

Pre-disturbance surveys for red tree voles are required if all three of the following criteria are met: 1) the proposed project is within the Northern Mesic, Mesic, or Xeric Survey Zones (Figure 1), 2) there is suitable habitat within the planning area that may potentially contribute to a reasonable assurance of persistence of tree voles, and 3) the project disturbance is likely to have a significant negative impact on the species’ habitat, its life cycle, microclimate, or life support requirements that affects persistence of red tree voles (USDA and USDI 2001: S&G 22). A detailed description of each criterion follows.

1. The proposed project is within the Northern Mesic, Mesic, or Xeric Survey Zones. The 2000 FSEIS for the Amendment to the Survey and Manage Mitigation Measures (USDA and USDI 2000) subdivided the range of the red tree vole into three zones, referred to as the Northern Mesic, Mesic, and Xeric Zones. New information on the species range and elevation limits has been gathered since then and is now incorporated into the Survey Zone delineations. These Survey Zones (Figure 1) encompass a large area and biologists should use more site-specific and fine-scale maps at the project scale when determining elevation limits and boundaries specific to each Survey Zone. A general description of the survey area boundaries in each of the three Survey Zones is as follows:

a. The Northern Mesic Zone is bounded to the north by the Columbia River, on the east by the 3,500 foot elevation contour along the west slope of the Cascade Mountains, on the west by the Pacific Ocean, and on the south by the Mesic Zone. Northeast of Mount Hood, the line delineating the eastern boundary of the Northern Mesic Zone extends east of the crest of the Cascades to include the headwaters of the Lake Branch watershed, where red tree voles are known to occur (Forsman et al. 2009a). Although the survey area goes up to the 3,500 foot elevation level in the Western Cascades portion of the zone, in the remainder of the zone there is no elevation limit. b. The Mesic Zone occurs south of the Northern Mesic Zone and is bounded on the south side by the Klamath River in California and on the southeastern side by the Xeric Zone. The northeastern limits follow the 4,500 foot elevation contour in the Western Cascades. The western boundary is the Pacific Ocean, except for the area in the extreme southern end of the zone, where the survey boundary moves inland along the Klamath River. In the Western Cascades portion of the zone, the survey area goes up to the 4,500 foot elevation level, while in the remainder of the zone there is no elevation limit. c. The Xeric Zone occurs east and southeast of the Mesic Zone. Based on recent surveys for tree voles and data from spotted owl (Strix occidentalis caurina) pellets (Forsman et al. 2004), the eastern edge of the Xeric Zone occurs from west of the Klamath County line north of the Middle Fork of the Rogue River and then north of the Rogue River to Grants Pass, then west of the Applegate River, to the Oregon/California border, then north of the border until Indian Creek (a tributary to the Klamath River), west of Indian Creek to its confluence with the Klamath River, then along the Klamath River, south of the China Peak HUC 5 watershed. In the Western Cascades portion of the zone, the survey area goes up to the 4,500 foot elevation level. In the Klamath Mountains portion of the zone the survey area goes up to the 5,000 foot elevation level.

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Figure 1—Northern Mesic, Mesic, and Xeric Survey Zones for the red tree vole (Arborimus longicaudus).

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It is important to note that these Survey Zones do not entirely capture the range of the red tree vole in the Cascades and Siskiyou Mountains where there may be a few red tree voles that occur at elevations above the upper limits of the Survey Zones. The elevation cutoffs for the Survey Zones are a compromise designed to keep surveyors from spending large amounts of time conducting surveys in places where the likelihood of finding red tree voles is low. Elevation limits and survey zone boundaries were determined through recommendations from Forsman and Swingle (pers. comm.) and were supported by analysis of Forest Service (FS) and Bureau of Land Management (BLM) database queries. For the elevation decrease, a disproportionate number of nests were found above the recommended elevation limits as compared to survey effort (FS/BLM unpublished data). The eastern survey zone boundaries incorporate all red tree vole nests (and spotted owl pellets with red tree vole remains) found to date. If red tree vole nests are found at elevations above the limits identified in any of the Survey Zones or in habitats not targeted by this survey protocol, then those areas would be managed as known sites in accordance with the current direction for this species.

Watersheds Exempted from Surveys in Matrix and Adaptive Management Areas (AMA) There are certain watersheds that are exempt from pre-disturbance surveys in Matrix and AMA or a combination of Matrix/AMA and Riparian Reserve allocations. On 22 April 2003, the “Supplemental Direction for Identification of Non-High Priority Sites for Red Tree Voles Within the Pilot Area” was transmitted to the field (Forest Service File Code 2630; Bureau of Land Management Instruction Memorandum No. OR-2003-062, http://www.blm.gov/or/efoia/fy2003/ib/im-or-2003-062.pdf). The supplemental direction established a programmatic process that allows field units to identify non-high priority sites. Application of the programmatic process allows for sites within Matrix and AMA or a combination of Matrix/AMA and Riparian Reserve land allocations in 5th field watersheds with high amounts of future red tree vole habitat in reserved land allocations, to be identified as non- high priority and thus released for other management priorities. This direction is still valid.

Sixteen watersheds within the pilot area were noted as having high amounts (83–100%) of red tree vole habitat in reserved land allocations. Within these 16 watersheds, any site in Matrix or AMA, or a combination of Matrix/AMA and Riparian Reserve land allocations can be identified as non-high priority, and hence pre-disturbance surveys within those allocations within these watersheds are not required. The 16 watersheds are: Lower Smith River, Lower Umpqua River, Wolf Creek, Fall Creek, Upper Umpqua River, Mill Creek (Lower Umpqua River), Canton Creek, Lower Siuslaw River, Upper Siuslaw River, Steamboat Creek, Boulder Creek (North Fork Umpqua River), Middle Fork Willamette River/Lookout Point, Deadwood Creek, North Fork Siuslaw River, Little Fall Creek, and Indian Creek/Lake Creek (Figure 2). Within these 16 watersheds, projects in land allocations other than Matrix, AMA, or a combination of Matrix/AMA and Riparian Reserves are not exempted from surveys by this direction.

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Figure 2—Watersheds exempted from red tree vole (Arborimus longicaudus) surveys within Matrix and Adaptive Management Area (AMA) or a combination of Matrix/AMA and Riparian Reserve land allocations.

2. Suitable habitat that may potentially contribute to a reasonable assurance of persistence occurs within the proposed project area (USDA and USDI 2001: S&G 23). Habitat descriptions listed below do not include all stand conditions where red tree vole nests occur. The differences in survey recommendations for stand conditions between Survey Zones are based on the following factors: number of known extant sites, detection rate of vole nests per survey effort, site quality, tree species, amount of late-successional forest, and land ownership patterns. The variation in these factors across their range takes into consideration the need to locate and identify a sufficient number of sites that may provide for a reasonable assurance of persistence of red tree voles.

For this criterion, either the Quadratic Mean Diameter (QMD) or Arithmetic Mean Diameter (AMD) size description and one of the two vole general habitat descriptions have to be met. Stands that meet both: 1) the QMD or AMD and 2) one of the two general habitat descriptions, are considered suitable habitat that may potentially contribute to a reasonable assurance of persistence, and would require surveys if Criteria 3 is met.

For more isolated stands that meet the minimum diameters (QMD or AMD) and one of the two general habitat descriptions, professional judgment should be used to evaluate the likelihood that

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the stand currently provides habitat for the red tree vole. For instance, a 2 acre stand meeting the habitat criteria but surrounded by clear-cuts may not provide habitat.

a. QMD or AMD Size Description by Survey Zone For purposes of deciding whether a stand is suitable habitat that may potentially contribute to a reasonable assurance of red tree vole persistence, determine the estimated QMD or AMD of the stand. Administrative units may use whichever method is more commonly used in their local forest management applications. If the estimated QMD or AMD is greater than or equal to the diameters for the survey zones listed below, the stand may be suitable habitat:

1. Northern Mesic Zone: QMD ≥ 16″ or AMD ≥ 15″. 2. Mesic Zone: QMD ≥ 18″ or AMD ≥ 16″. 3. Xeric Zone: QMD ≥ 16″ or AMD ≥ 14″.

If the stand does not meet the minimum mean diameters, then the stand is considered to not be composed of “suitable habitat that may potentially contribute to a reasonable assurance of persistence” and surveys are not required.

b. Red Tree Vole General Habitat Descriptions If the minimum QMD or AMD criterion for the stand has been met, then determine if one of the general habitat classes below applies:

1. Mature and old-growth conifer forests and older mixed-age conifer forests containing Douglas-fir (Pseudotsuga menziesii), grand fir (Abies grandis), Sitka spruce ( Picea sitchensis), or western hemlock (Tsuga heterophylla) with multi-layered canopies and branches capable of supporting nests. Mature forests are characterized by the onset of slowed height growth, crown expansion, heavier limbs, gaps, some mortality in larger trees, and appearance of more shade-tolerant species or additional crown layers (USDA and USDI 2001). Old-growth encompasses the later stages of stand development that typically differ from earlier stages in a variety of characteristics which may include tree size, accumulations of large dead woody material, number of canopy layers, species composition, and ecosystem function (USDA and USDI 2001). Typically, in Douglas-fir forests west of the Cascades, mature forests begin between 80–130 years, and old- growth forests at 180–220 years old. OR

2. Conifer or conifer-dominated mixed conifer-hardwood forests with canopy closure of intermediate, co-dominant and dominant trees ≥ 60%, and with two or more superdominant conifer trees per acre that have the following characteristics that provide foundations for vole nests: large limbs, palmate branch clusters, well developed crowns, cavities, broken tops, forked trunks, multiple leaders, or dwarf mistletoe (Arceuthobium spp.) brooms. Superdominant trees typically have crowns that extend above the general stand canopy and have large branches in the upper canopy of the dominant trees in the stand (Curtis et al. 1998). Superdominant trees may be remnant trees from an earlier cohort, or they may be trees from the dominant cohort that were more open grown and have become much larger than the rest of the trees in the stand.

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If the stand meets the minimum mean diameters described in a. above, but does not meet either one of these general habitat descriptions in b. then the stand is considered to not be composed of “suitable habitat that may potentially contribute to a reasonable assurance of persistence” and surveys are not required.

3. The proposed project is a habitat-disturbing activity that has the potential to cause a “significant negative effect on the species habitat or the persistence of the species at the site” (USDA and USDI 2001:S&G 22). “Habitat-disturbing activities are defined as those disturbances likely to have a significant negative impact on the habitat, life cycle, microclimate, or life support requirements of the species. The evaluation of the scale, scope, and intensity of the anticipated negative impact of the project on habitat or life requirements should include an assessment of the type, timing, and intensity of the disturbing activity. The line officer should seek the specialists’ recommendations to help determine the need for a survey based on site-specific information. In making such determinations, the line officer should consider the probability of the species being present on the project site, as well as the probability that the project would cause a significant negative effect on the species habitat or the persistence of the species at the site” (USDA and USDI 2001:22). “Site” is defined in the glossary section of the Survey and Manage Standards and Guidelines (USDA and USDI 2001:83). If the proposed activity is determined to not pose a potential significant negative effect at the site, then surveys are not required.

Activities that would remove or modify the intermediate, co-dominant, dominant, or pre- dominant/superdominant canopy within the stand may be considered habitat-disturbing to red tree voles. This includes activities that may cause a significant negative effect on red tree voles or habitat in the project area by isolating or damaging nests or nest trees.

Routine maintenance of improvements and existing structures is not considered a habitat-disturbing activity. Examples of routine maintenance include road maintenance, clearing encroaching vegetation, managing existing seed orchards, and falling hazard trees (USDA and USDI 2001:S&G 22).

Some other examples of projects that might not be considered habitat-disturbing and, therefore, not require pre-disturbance surveys include: brush and understory clearing, hand and machine piling of smaller diameter material, stream restoration, snag creation, tailholds, guylines, and lift trees.

In addition, there are survey exemptions that have been identified through settlement agreements associated with Survey and Manage litigation. A full listing of those exemptions may be found on the Survey and Manage General Guidance webpage http://www.blm.gov/or/plans/surveyandmanage/guidance.php.

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NATURAL HISTORY

The red tree vole (Arborimus longicaudus) is a small arboreal microtine that is endemic to the coniferous forests of western Oregon and northwestern California (Howell 1926, Maser 1966, Verts and Carraway 1998). Red tree voles are primarily arboreal but will come to the ground to move between trees if there are no branch pathways between trees (Swingle and Forsman 2009). Needles and twig bark of Douglas-fir, grand fir, western hemlock, and Sitka spruce are the only known foods eaten by red tree voles (Walker 1930, Maser 1966). Red tree voles are prey to many species of mammals and birds, including weasels (Mustela spp.) and the northern spotted owl (Forsman et al. 1984, 2004; Graham and Mires 2005; Swingle et al. 2010). In areas where they are particularly abundant they may provide 30–50% of the items consumed by spotted owls (Forsman et al. 1984).

Tree voles collect cuttings from tips of live conifer branches that they harvest by chewing through the stem, leaving a distinctive angled chisel-cut. Voles typically harvest 14–30 cuttings per night and store these on top of or inside their nests (Forsman et al. 2009b). Length of cuttings average 14 cm (range = 1–35 cm; Forsman et al. 2009b). Resin ducts are small tubules inside the needles of conifers that contain unpalatable chemicals that are the plant’s chemical defense against browsers (Kelsey et. al. 2009). When feeding on conifer needles, tree voles often (but not always) remove the portion of the needle containing the resin ducts before eating the palatable part of the needle (Howell 1926, Benson and Borell 1931). They use the discarded portion of the needle to line the tunnels and sleeping chamber inside their nests, which is why occupied or recently occupied nests often have a pleasant “Christmas Tree” odor. In Douglas-fir, the paired resin ducts are located along the edges of the needle, and tree voles remove the resin ducts by chewing along the edges of the needle before eating the rest of the needle. In western hemlock, the single resin duct is located in the center of the needle and tree voles eat the edges of the needle before discarding the midrib (Walker 1930, Clifton 1960). Voles that feed on Douglas-fir typically accumulate large amounts of resin ducts in their nests, whereas voles that feed on western hemlock accumulate smaller amounts of resin ducts. Because the resin ducts in Sitka spruce are discontinuous and located in the basal portion of the needle (Kelsey et al. 2009), voles feeding on these needles may have few or no resin ducts in their nests (Forsman and Swingle unpubl. data). No other species removes the resin ducts from conifer needles and uses them to build their nests, so it is usually easy to identify tree vole nests based on the presence of resin ducts.

After eating the needles, tree voles strip and eat the bark from many of the twigs that they harvest. These debarked twigs are often found in their nests and are typically 1–6 cm in length with a chisel-cut at each end. Fibrous tree vole fecal pellets that are slightly larger than mouse droppings are also found in their nests, often in copious amounts. Fresh tree vole fecal pellets are bright green and then gradually fade with age until they become dark brown or black. In nests that are occupied for long periods of time the old fecal pellets, resin ducts, debarked twigs, and uneaten cuttings gradually decompose, forming a brownish soil-like material inside the nest.

Red tree voles are solitary and build their nests in trees near their food. Although it is common to find multiple nests in the same tree, there have been only a few cases in which climbers visually observed more than one occupied vole nest in the same tree (Benson and Borell 1931, Maser 1966, Forsman and Swingle unpubl. data). Nests typically consist of a compact mass of conifer branch tips (cuttings), resin ducts, fecal pellets, dead twigs, debarked twigs, and lichens (Howell 1926, Benson and Borell 1931, Clifton 1960, Maser 1966, Gillesberg and Carey 1991, Forsman et al. 2009b).

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Stable platforms for tree vole nests in large trees are typically found on large branches, dwarf mistletoe brooms, epicormic branches (palmate branch clusters), and in cavities or hollow limbs. In young trees, nests are most commonly located in branch whorls, forked trunks, or broken tops with multiple leaders. Nests have been documented from 2–75 m above ground (Swingle 2005, Price et al. 2010). Old tree vole nests are sometimes found below the live crown of the nest tree, but most occupied nests are located in the live crown, where voles can easily reach their food (Swingle 2005). A small number of males have been found in nests on the ground (Howell 1926, Maser 1998, Thompson and Diller 2002), leading to speculation that many males nest on the ground, but this has never been proven and is highly unlikely in forests where the live canopy is high above ground.

Red tree voles were rated as highly vulnerable to local extirpation due to habitat fragmentation or loss (Huff et al. 1992). Several studies indicated tree voles are associated with old forests (Corn and Bury 1986, Dunk and Hawley 2009), but they also occur in younger forests (Jewett 1920, Howell 1926, Clifton 1960, Maser 1966, Thompson and Diller 2002, Swingle and Forsman 2009). Tree vole populations have probably declined in many parts of their range as a result of logging, fire, and forest conversion to agriculture and rural development. In Oregon, they are uncommon or absent in most of the northern Coast Ranges and northern Cascades, where large areas of old forest have been repeatedly logged or burned during the last century (Wimberly and Ohmann 2004). Although significant steps have been taken to protect tree vole habitat on federal lands, Huff et al. (1992) predicted that the tree vole population will continue to decline in the future as old forests are harvested or burned, and rural areas are converted to housing developments or agricultural crops.

Many biologists who have studied tree voles have noted that their nests tend to occur in clumps on the landscape (e.g., Howell 1926, Maser 1998). Signs of their presence range from areas with many nests in a single stand to stands in which only a few nests can be found (Forsman et al. 2009a).

Geographic Range of Tree Voles

There are two species of tree voles, the red tree vole that occurs in western Oregon and extreme northwestern California and the Sonoma tree vole (Arborimus pomo) that occurs in the coastal forests of California from the Klamath River south to Freestone in southern Sonoma County (Hayes 1996, Forsman and Swingle, unpubl. data). The only known ecological difference between the congeners is that the Sonoma tree vole will also feed on Bishop pine (Pinus muricata; Wooster and Town 2002) and Monterrey pine (P. radiata; Diller and Forsman unpubl. data). The most significant change regarding the range of the red tree vole since the implementation of the Northwest Forest Plan (NWFP) is clarification regarding the taxonomic relationship of populations in northern California. In the Final Supplemental Environmental Impact Statement (FSEIS) for the NWFP (USDA and USDI 1994a), the Oregon and California border was used as the dividing line between the red tree vole and Sonoma tree vole, as proposed by Johnson and George (1991). Subsequent DNA analyses suggested that a more appropriate dividing line between the congeners was the Klamath River in northwestern California (Murray 1995, Blois and Arbogast 2006). This protocol was developed for surveys within the range of the red tree vole and does not apply to the Sonoma tree vole, which mostly occurs on private lands (USDA and USDI 1994b, Forsman et al. in prep).

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NEST CATEGORIZATION

Arboreal nests found using this protocol must be classified into one of the following three categories: Confirmed red tree vole nest, Confirmed non-tree vole nest, or Unconfirmed species nest. Nests categorized as Confirmed red tree vole will be further categorized based on how recent the red tree vole activity was. From the ground, red tree vole nests generally appear as a compact mass. Close inspection by tree climbers will reveal diagnostic characteristics that differentiate tree vole nests from the nests of other arboreal rodents or birds. Finding or observing resin ducts, vole cuttings, debarked twigs, vole fecal pellets, or seeing a vole are the definitive indicators a nest has been or is occupied by a red tree vole.

Over time, individual nests may be used by squirrels, woodrats, or voles, but rarely at the same time (Maser 1966, Swingle 2005). There are six other mammals in the range of the red tree vole that build or use arboreal nests: white-footed voles (Arborimus albipes), Douglas’ squirrels (Tamiasciurus douglasii), northern flying squirrels (Glaucomys sabrinus), western gray squirrels (Sciurus griseus), and woodrats (Neotoma fuscipes and N. cinerea). Red tree voles may build their nests on top of or inside unoccupied nests of these species or other arboreal nests built by birds. Since tree voles will take over unoccupied nests of other species, tree climbing is the best method to determine if red tree voles have used the nest structure or not.

Many structures detected will be old and dilapidated rodent nests or natural accumulations of litter and broken branches, especially on dwarf mistletoe brooms. From the ground, these generally appear as dark haphazard accumulations of twigs, needles, moss, and/or lichens on the topside of a branch or in a crotch in a tree. Many of these structures are very compacted and do not contain any fresh material. Many will also have large holes through the nest, or the nest material will be falling off the structure. Samples of this fallen material can sometimes be seen on the ground under the nest.

The following describes general criteria to use to help make the appropriate determinations on nest classification. See also Table 1 for a summary of the key diagnostic characteristics.

1. Confirmed red tree vole nest This includes nests that are “active”, “inactive”, or the nest activity status is undetermined; data codes for confirmed red tree vole nests are included below under, “Categorizing Confirmed Red Tree Vole Nests”, as the activity or occupancy status of confirmed red tree vole nests must be further classified.

Below are typical signs that indicate a nest structure may be occupied or was used by a red tree vole. Some of these features may be present on the ground below the nest or they may be visible in the tree from the ground using binoculars:

a. Cuttings of Douglas-fir, grand fir, western hemlock, or Sitka spruce are piled on top of or pulled inside the nest entrances. Unlike the longer cuttings typically harvested by squirrels and woodrats, vole cuttings are shorter, typically only 5–20 cm long and not as thick, typically 2–3 mm (Forsman et al. 2009b). However, cuttings up to 35 cm long may occasionally be harvested by voles but not in large quantities. Tree voles also eat the bark off of the cuttings that they harvest, and tree vole nest chambers and tunnels typically contain many small

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white twigs with the bark removed that look like little pieces of toothpick. Cuttings and debarked twigs in vole nests have ends that are cut off at an angle (“chisel-cut”), whereas twigs that are broken off by wind have ends that are ragged. b. Clumps of resin ducts are incorporated into the nest. Resin ducts may be seen in the nest, sloughing off the edge of the nest, or on the ground, trunk, or limbs below the nest. c. Vole fecal pellets are located on top of or inside nests or on limbs below the nest. In rare cases, nests in riparian areas that look like tree vole nests and contain fecal pellets that look like tree vole fecal pellets may actually be white-footed vole nests. These nests do not contain resin ducts and are typically covered by leaves of red alder (Alnus rubra) or other deciduous plants, which are food for white-footed voles (Voth et al. 1983, Forsman and Swingle 2006).

2. Confirmed non-tree vole nest These nests are confirmed to a species other than tree vole or are a collection of debris. Nests in this category would not have any of the vole sign described above (under “Confirmed red tree vole nest”) from ground and tree climbing survey results.

Nests built by other arboreal rodents tend to be constructed of different and larger material or large amounts of moss. Nests of other arboreal rodents will have some of these characteristics:

a. The twigs and sticks that make up the base of the nest platform are larger diameter and longer than those added by red tree voles. For example, woodrats and squirrels may include twigs up to 1 cm in diameter in the nest platform. b. The nest chamber is constructed of moss, shredded bark, grasses, lichens, or leaves of deciduous trees and shrubs. If fresh cuttings of conifers are piled on top of the nest they will typically be 2–5 times longer than cuttings harvested by voles. c. Large quantities of cone scales or cone fragments piled on top of a nest or on the ground below a nest indicate usage by Douglas’ squirrels. Occupied or recently occupied woodrat nests typically smell strongly of urine and are often very large structures composed primarily of large twigs and branches.

3. Unconfirmed species nest The species using the nest is unknown, and may potentially be a red tree vole. In these cases, the species using the nest was not determined. This includes situations where the structure was not examined by a tree climber so that the builder of the nest was not determined, and therefore the structure could not be ruled out as an "active" red tree vole nest. Unconfirmed nests are to be managed as if they are “active” red tree vole nests.

Categorizing Confirmed Red Tree Vole Nests

To manage red tree vole sites and to assist in adaptive management processes, confirmed red tree vole nests should be further classified based on the occupancy status of the nest as “Active”, “Inactive”, or Activity “Status Undetermined”. “Active” nests should then be further classified based on how recent the red tree vole activity.

The following describes characteristics to examine in order to determine the appropriate occupancy status of confirmed red tree vole nests. See Table 1 for a comparison of key diagnostic characteristics.

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1. “Active” nests Diagnostic features that indicate occupancy status of red tree vole nests require close-up examination of the nest material (resin ducts, fecal pellets, cuttings) for freshness. Diagnostic features must be considered as a whole when determining occupancy or age of a nest. Most of the time tree climbers will not see the vole occupying a nest and will have to use contextual clues to make determinations.

The color of fecal pellets can be used to indicate how recently the nest was occupied. Bright green pellets indicate newer droppings and can indicate current or recent use of the nest. Older fecal pellets are dark brown to black and become compacted into the bottom of the nest as they become wet and compressed. Occupied or very recently occupied nests will usually have a combination of fresh green and old pellets.

Fresh, bright green to pale green resin ducts on or in the nest can indicate recent use, but ducts inside the nest can stay green for an extended time, so fresh cuttings are a better indicator of recent occupancy than are green resin ducts.

Active red tree vole nests are categorized into one of three categories:

a. Animal observed (noted as AC AO (Active, Animal Observed) for data management purposes): Vole seen—this is a rare event unless the nest is probed or torn apart, which is not recommended unless part of a research project. b. Likely or very recently occupied tree vole nest (noted as AC VR (Active Very Recently) for data management purposes): A red tree vole nest that is apparently occupied or has been used within the very recent past, but that is not disturbed by the tree climber to determine if it is actually occupied. These nests typically have fresh green cuttings piled on top of the nest or protruding from an entrance tunnel on the top or side of the nest. Green resin ducts are usually present inside or on top of the nest. Green cuttings can persist for weeks, maybe months, in a cool moist environment, but cuttings at likely or very recently occupied nests will be very fresh, with turgid needles, and will often form a plug that blocks the entrance to the nest. Fecal pellets are typically bright green. c. Moderately recently occupied tree vole nest (noted as AC MR (Active Moderately Recently) for data management purposes): A nest that was probably occupied by a vole within the recent past. May contain older resin ducts that have faded to a pale green. If cuttings are present, they are somewhat desiccated and the needles will often fall off the stem when touched.

2. “Inactive” nests (noted as INA for data management purposes) Typical signs of old vole nests with no recent use include:

a. Nest is compacted or falling apart and the fecal pellets are dark brown to black with no green resin ducts or cuttings. b. Nest material is comprised primarily of a composted layer of compressed fecal pellets, orange, tan or brown resin ducts, often with a layer of debris (conifer needles, sticks, lichens, etc.) that has fallen onto the nest. The vole nest material is often in various stages of decomposition, and can become difficult to identify in very old nests.

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3. “Status Undetermined” (noted as UND for data management purposes) A confirmed red tree vole nest where the occupancy status was not determined. For example, a nest with orange, brown, or tan resin ducts on the ground under the nest cannot be assumed to have an “inactive” occupancy status. The tree should be climbed and nest examined to determine occupancy status. If the nest is not examined by a climber, then the activity status is undetermined. (Nests classified as red tree vole, “status undetermined”, are to be managed as if they are “active”). It is important to note that tree climbers will be able to document if a nest is red tree vole or not, and the occupancy status of red tree vole nests. If the tree climbers are not able to make this identification, then they should take samples of the suspected tree vole nest material to the qualified surveyor (as defined on page 25) for proper determination.

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Table 1: Nest Categorization Codes and Characteristics NEST TREE CODE FECAL CUTTINGS RESIN OTHER TYPE PELLETS DUCTS 1. Confirmed RTV – On top of or Douglas fir, grand fir, western Clumps Arboreal nests confirmed as belonging to red inside nests, or hemlock, Sitka spruce cuttings incorporated into tree vole. Activity status of the nest is either on limbs below on top of nest or protruding nest; may be seen “Active” (and further defined as animal nest from an entrance tunnel; on the edge of observed, likely or very recently occupied, or typically 5-20 cm long and 2-3 the nest, on the moderately recently occupied), “Inactive”, or mm thick. Some will be ground, trunk, or Status Undetermined. debarked, look like little pieces limbs below the of toothpicks. Ends are often nest “chisel-cut”, cut at an angle. a. RTV Active – – – – Arboreal nests confirmed as red tree vole with recent red tree vole activity i. Animal AC AO – – – RTV is visually seen on or in the nest Observed ii. Likely or AC VR Bright green Fresh, green, turgid Green, inside or Very Recently on top of nest Occupied iii. Moderately AC MR Pale green to Somewhat desiccated, needles Pale green Recently light brown often fall off when touched Occupied b. RTV Inactive INA Dark brown to Desiccated or needleless Orange, tan, or Arboreal nests confirmed as red tree vole, but black branches brown with no sign of recent red tree vole activity c. RTV Activity UND Dark brown to Desiccated or needleless Orange, tan, or Tree has not been climbed, so activity status Status black on the branches on the ground under brown on the not assessed. Undetermined ground under the nest ground under the the nest nest 2. Confirmed non- – – Typically 2-5 times longer than – Nests are accumulations of twigs, needles, tree vole nest RTV cuttings. moss and/or lichens. Twigs and sticks comprising nest are longer and thicker. Nests do not contain any sign of RTV described above. 3.Unconfirmed – – – – Species using the nest has not been species nest determined, and tree has not been climbed. No sign of vole on the ground below nest; no sign of vole on nest from the ground. 17 20140331-506820140416-5027 FERC PDF (Unofficial) 3/28/20144/15/2014 7:42:429:29:06 PM

DETERMINATION OF RED TREE VOLE SITES AND HABITAT AREAS

Surveys completed to protocol may result in the identification of a red tree vole site. A site can be a single point representing a single nest tree or a polygon connecting the outer nest trees (all red tree vole or unconfirmed species nest trees within 100 m of one another). The identification of which nest trees to include in a site are incremental and cumulative and can result in a “linked chain” of trees that is ultimately used to define the total number of nest trees in the site and the site perimeter.

Sites can be categorized as “Biological” or “Managed” depending on nest categorization and occupancy. In general, sites with at least one confirmed red tree vole nest are considered “Biological sites” and are broken down into “Active”, “Inactive”, and “Undetermined Status” sites. “Active” and “Undetermined Status” sites require site management/protection following the Management Recommendations; “Inactive” sites do not. Sites with unconfirmed species nests or where managers assumed red tree vole occupancy are considered “Managed sites”; these sites are to be “Managed as Active Site” as red tree vole presence has not been documented due to incomplete survey efforts. Management Recommendations should be applied at these sites until adequate surveys are completed to determine the species using the nest, and if red tree vole, the activity status. For definitions of red tree vole site types, see Table 2 below, which was modified from the Red Tree Vole Survey Protocol, Version 2.1.

Application of the management recommendations for this species results in the creation of “Habitat Areas,” delineated to maintain habitat where red tree voles are known or assumed to occur. These Habitat Areas are designed to protect the physical integrity of the nests from both management activities and natural disturbances such as wind-throw, and to provide a short-term approach to maintaining habitat at red tree vole sites.

For direction on how to delineate and manage sites and Habitat Areas, see the following documents:

1. Management Recommendations for the Oregon Red Tree Vole Arborimus longicaudus, Version 2.0 http://www.blm.gov/or/plans/surveyandmanage/files/mr-rtv-v2-2000-09.pdf ,

2. Supplemental Direction for Identification of Non-High Priority Sites for Red Tree Vole Within the "Pilot" Area http://www.blm.gov/or/efoia/fy2003/ib/im-or-2003-062.pdf and

3. Amendments to Survey and Manage Management Recommendations Designed to Facilitate Certain National Fire Plan Activities - Second Group: Red Tree Vole, Certain Mollusks and Amphibians http://www.blm.gov/or/plans/surveyandmanage/files/mr-fire_amendment-rtv- ig-2003-02.pdf .

In addition, there are known site management exemptions and flexibilities that have been identified through settlement agreements associated with Survey and Manage litigation. A listing of those exemptions and flexibilities may be found on the Survey and Manage General Guidance webpage http://www.blm.gov/or/plans/surveyandmanage/guidance.php.

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Table 2: Definitions of Red Tree Vole Site Types Definitions of Red Tree Vole Site Types A red tree vole site is an individual red tree vole nest tree or a collection of red tree vole nest trees within a local area (all red tree vole nest trees in a stand and adjacent stands that are not isolated from other clumps of red tree vole nest trees by more than Red Tree Vole 100 m (330 ft)). Site “Red Tree Vole Site” is the term for the three specific site types described below (“Active” Site, “Inactive” Site, and “Undetermined Status” Site). Red tree vole sites are defined by any/all red tree vole nest tree/resin duct locations that are within 100 m of any other red tree vole nest tree/resin duct locations. Biological Site-confirmed red tree vole A location with one or more confirmed occupied red tree vole nests. These sites are known sites as defined on page 76 of the 2001 Survey and Manage Record of Decision “Active” Site and Standards and Guidelines: Includes nests that are http://www.blm.gov/or/plans/surveyandmanage/files/12-2001_record_decision.pdf classified as: These sites include any other type of red tree vole or “unconfirmed species” nests or “Animal Observed” resin duct location, as long as at least one tree in the site is active, thereby defining the “Likely or Very Recently site as an “Active” Site. All red tree vole nests and “unconfirmed species” nest types Occupied” and resin duct locations should be considered as part of the site as long as they are “Moderately Recently within 100 m of at least one other red tree vole nest/resin duct location or Occupied” “unconfirmed species” nest that is considered to be part of the site.

A location where all nests that are located within 100 m of any other nest are determined to be “inactive” red tree vole nests. (These sites could also include nests “Inactive” Site confirmed to other species, but those nests would not be used in determining the area of the site). These types of sites indicate historic red tree vole use at the site, not

current use, and they do not require site management/protection. The activity status of confirmed tree vole nests has not been determined for the nests in the site. The site is assumed to be currently occupied by the species for management purposes. Additional survey effort would identify these sites as either active or “Undetermined inactive sites. All “undetermined status”, “inactive”, and “unconfirmed species” nest Status” Site types and resin duct locations should be considered as part of the site as long as they are within 100m of at least one other nest/resin duct location that is considered to be part of the site. Managed Site Sites where the species using the nest has not been determined are assumed to be Managed as occupied for management purposes. Tree climbing did not occur and therefore the site is assumed to be currently occupied by red tree voles; tree climbing would identify “Active” Site these sites as either “active” or “inactive” sites, or not red tree vole. These sites may “Unconfirmed species include “inactive” nests, as long as at least one tree in the site is an “unconfirmed nests” species nest”, thereby defining the site as “Managed as Active”. All “unconfirmed “portions of stands species” nests and “inactive” red tree vole nests should be considered as part of the assumed occupied by red tree voles” site as long as they are within 100 m of at least one other nest that is considered to be part of the site.

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SURVEY METHODOLOGY

The main objective of this survey protocol is to provide a consistent, standardized approach for locating the nests of red tree voles and assessing the occupancy status of those nests. Tree voles cannot adequately be surveyed using conventional small mammal trapping techniques (Swingle et al. 2004). Data from radio-marked tree voles has indicated that ground-based tree vole surveys alone documented around half of the occupied nests in a stand, regardless of forest age (Swingle and Forsman 2009). Detecting 100% of the nests within a stand is not possible, because some nests would be missed even if tree climbers inspected every tree within the stand, which is impractical.

This red tree vole protocol utilizes a sampling methodology in which surveyors walk through management units and visually search trees for vole nests. Trees with nests discovered from the ground are then climbed to determine if the nest is a tree vole nest, and if so, the occupancy or activity status of that nest. (The terms, “occupancy” and “activity” are used interchangeably). The goal of this protocol is to assess presence or absence of red tree vole nests within the survey area and determine the occupancy status of those nests, not to discover every nest. The protocol requires the survey of large areas within each project area, and because many vole nests are visible from the ground, the protocol should result in few situations where vole nests are present but are completely undetected by the ground-based surveys.

Because red tree vole nests may occur in low numbers and in a clumped distribution at landscape and stand level scales, surveys need to cover a large percentage of the habitat to be disturbed to ensure detection of nests. Vole nests are an indicator of a possible population and are used to identify the red tree vole site. The actual survey methodology used will depend upon the type of project. Surveyors may use either Modified Line Transects (MLT), Individual Tree Examination (ITE), Additional Survey Guidelines for Stands with Large Trees (SLT) or a combination of methods depending on the scale and type of project under consideration.

The techniques included in this protocol emphasize approaches for locating potential vole nests from the ground and assessing their occupancy status through tree-climbing. It may be possible to determine occupancy status through ground-based surveys, if resin ducts are visible on the nest or fresh cuttings or resin ducts are located beneath the nest tree. However, in many cases tree climbing will be needed to determine the occupancy status. When tree climbing is conducted, all applicable Occupational Safety and Health Administration (OSHA) and agency standards must be followed (Davis 2005). Tree climbing information, Job Hazard Analysis examples, and certification are provided by the Forest Service’s National Tree Climbing Program which annually hosts a workshop at the Dorena Genetic Resource Center, Cottage Grove, Oregon (see http://www.fs.fed.us/treeclimbing/).

The ground-based observer should take advantage of steep slope positions (even if outside the project area) to look into tree crowns. Surveys can be conducted during all seasons of the year but should be planned to achieve the best visibility conditions within the project area. Conditions such as snow, rain, fog, or hardwood leaves may reduce visibility in some situations.

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Modified Line Transect (MLT) Survey Method

This method is appropriate for surveys that encompass stand level projects such as timber harvest. Unlike strip surveys, line transect methods do not assume 100% detection but use a detection function approach (Ramsey et al. 1987, Beavers and Ramsey 1998) to estimate detection probabilities and effective sampling area. The modified line transect method used in this protocol relies on estimated effective sampling width or sampling areas based on a sample set of transects to estimate the area sampled. Modified line transect survey results indicate that the average effective transect width ranges from 13 m in pole-sized stands to 26 m in old forest on each side of the transect line (Biswell unpubl. data). For purposes of standardizing this protocol, the effective strip width is considered to be 15 m on each side of the transect.

This protocol requires a minimum of 90 m (approximately 300 feet) of transect line per acre of survey area to be searched. Assuming an effective total survey strip width of 30 m, 90 m of transect line per acre will cover approximately 70% of the survey area on average. In general, this coverage can be achieved by placing transect lines parallel to one another, approximately 42.7 m (approximately 140 feet, range 130– 150 feet) apart. This length and width of transect should provide a good assessment of the presence or absence of voles within the stand. In addition, it is recommended that transects be placed perpendicular to the slope or whatever the prevailing aspect is (use the topography to determine the best way of viewing potential nests). Transects following the slope contour are acceptable, as long as the transects follow a distinct compass bearing, and maintain consistent spacing between adjacent transects. Transects can be placed closer than 130 feet apart, based on stand specifics, or a desire for greater coverage. For a more detailed assessment showing how the transect separation was calculated and an example on how to lay out transects see Appendix I.

Once transects have been established, conduct the ground surveys by:

1. Using a predetermined starting point, slowly walk along the straight-line transect using a pre- determined compass bearing.

2. While walking along the transect, visually search the tree canopy for likely nest structures on both sides of the transect line. Look for typical signs of red tree vole nests.

3. If nest structures are observed, follow the protocol methods described below under “When Potential Nest Structures are Observed During Surveys.”

4. Complete walking and visually searching all transects within the stand.

Individual Tree Examination (ITE) Survey Method

This method is used in situations where searching individual trees in a project area would be more efficient than surveying with the modified line transect method, typically in areas where the habitat- disturbing activity is fairly localized. When using this method, all potential nest trees in the project area should be surveyed regardless of size. A visual search of the live crown of all trees should be conducted from several viewpoints using binoculars. The project area can be defined as the area within one tree height of the actual potential habitat disturbance. If nest structures are observed, follow the protocol methods described below under “When Potential Nest Structures are Observed During Surveys.”

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Additional Survey Guidelines for Stands with Large Trees (SLT)

Some stands meeting the habitat descriptions described in “Criteria for Determining the need for Pre- Disturbance Surveys” have conditions that make it difficult to detect vole nests from the ground. For purposes of this protocol, these are defined as stands, or portions of a stand, greater than 2 acres in size, with 2 or more trees > 36" dbh per acre, with a well-established understory or midstory that makes it difficult to fully see into the larger trees, such that MLT surveys are likely not effective in determining whether red tree voles are present in the stand.

For these types of stands:

1. Since visibility into the tree canopy from the ground is very poor, ground surveys may be skipped in the portions of the stand with these conditions, and sampled by climbing larger trees instead. OR 2. If modified line transect or individual tree examination surveys have been conducted and no red tree vole nests were detected in the stand and based on professional judgment it is suspected that due to the habitat quality and/or visibility concerns red tree vole nests could have been missed, tree climbing should be considered to more fully evaluate whether voles are present. Only the portion of the stand that has these conditions would need to be sampled.

In both of these situations, consider the following:

1. On average sample at least two of the trees >36" dbh per 10 acres in the stand with the stand conditions as described above. Climb trees as near to the top as safety allows, searching for vole nests in cavities, dwarf mistletoe brooms, and on limbs in the tree crown. Only the portion of the stand that has the conditions described above would be sampled by climbing.

2. Sampled trees should include trees with large limbs with complex structure, cavities, broken tops, forked trunks, dwarf mistletoe brooms, epicormic branches, or other features that provide stable nest foundations. Trees selected for climbing are at the discretion of the biologist and the climber, but if possible should be well-distributed throughout the area being sampled. Also, consider selecting trees to climb that provide vantage points for viewing into nearby conifer crowns and viewing a range of canopy layers within the stand.

3. If no red tree vole nests are documented through the sampling, then red tree vole surveys to the stand (or portion of the stand) are considered complete.

4. If “inactive” red tree vole nests are documented through sampling, additional sampling should be conducted to determine if the stand is occupied. If an “active” red tree vole nest is documented through sampling, then for management purposes, surveys may be stopped for that particular 10 acres, and the site managed as an “active” red tree vole site. However, additional climbing should be considered to help determine the extent of the red tree vole site. In both situations, if additional sampling is conducted consider the following:

a. Climb additional (2) large trees within the stand (or portion of the stand) within 100 m of the nest.

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b. If additional red tree vole nest trees are found during this sampling, consider additional (2) sampling radiating out 100 m from those nest trees. c. Continue with this sampling approach until: i. no more red tree vole nests are found. ii. the search radius has taken the surveyor out of the stand where the attributes that make visibility difficult exist. In these cases, surveyors may return to a ground-based assessment (MLT or ITE surveys) for additional nest structures and not use the sampling methodology presented here. If nest structures are observed using ground-based surveys, follow the protocol methods described below under “When Potential Nest Structures are Observed During Surveys”.

5. Should tree climbing not be an option, line officers have the discretion to consider those portions of the stand meeting the above criteria as occupied by red tree vole, and to manage as an “active” red tree vole site.

When Potential Nest Structures are Observed During Surveys

1. When potential nest structures are located, assess the nest from the ground at various vantage points. Use the information presented in the “Nest Categorization” section above to help determine the species using the nest, and if red tree vole, the activity status of the nest. Search under the tree for nest material, particularly resin ducts. If cuttings located on the ground are the only characteristic used as a determinant for nest status, ensure that the cuttings are truly from a vole and not a sprig blown from a tree. If conducting MLT surveys, mark the location where you leave your transect with flagging or some other visible marker, so you can return to the spot along the transect where you stopped your surveys. Conduct an assessment of the nest from the ground:

a. If 1) no resin ducts, cuttings, or fecal pellets are observed either on the ground or on the nest, 2) the interior or top of the nest can clearly be seen, and 3) the nest is old, well below the live crown, and is falling apart, then the nest can be classified as Confirmed non-tree vole nest. Red tree voles are known to build nests inside unoccupied nests of other species, so a determination from the ground that a nest is not red tree vole is very difficult. Document your findings on your data form and if conducting MLT surveys, return to the transect to continue surveying. b. If green resin ducts or fresh green cuttings are found below the tree or seen on the nest, then the nest is considered a confirmed red tree vole nest, with occupancy status as: 1) likely or very recently occupied (AC VR) if the ducts or cuttings are fresh and bright green or 2) moderately recently occupied (AC MR) if the resin ducts or cuttings are green but starting to fade. c. If older resin ducts or cuttings are found below the tree or seen on the nest, the nest is considered a confirmed red tree vole nest, and is classified as status undetermined (UND) since the occupancy status is still unknown and fresher material may be present in the nest. d. If no resin ducts or cuttings are found below the tree or seen on the nest, and you cannot conclude that the nest is not red tree vole, then the nest is considered an unconfirmed species nest until climbing surveys are conducted.

2. Flag or tag all trees that contain a confirmed or possible red tree vole nest (items b, c, and d above). The flag or tag for an individual tree should be labeled with the date, surveyor initials, tree number, and nest categorization, such as 2011-03-04-JSH-1-AC VR. On the Red Tree Vole Transect Survey Form

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(Form #2) include a description that would help in re-locating the tree. Record the nest tree location using a GPS (NAD83 datum), and if conducting MLT surveys, the distance along transect, compass bearing off of transect, and distance off of transect. Also record tree species, tree diameter at breast height (dbh), and any notes that may help relocate the tree or nest such as approximate nest height, nest support, and number of nests.

3. For flagged trees with nests that were unconfirmed species nests or confirmed to red tree vole but activity status undetermined (UND), climb the trees to determine species using the nest, and if red tree vole, the activity status of the nest. After nests have been examined by tree climbers, the data and results should also be written on the tree tag. Potential results include: confirmed not red tree vole, animal observed (AC AO), likely or very recently occupied (AC VR), moderately recently occupied (AC MR), or inactive (INA). If tree climbing is not an option, for management purposes these trees should be considered “active” red tree vole nests. However, it is strongly encouraged that this be done only as a last resort, because correct assessment of species use and activity status will be essential for future annual species reviews, survey protocol updates, and modifications to management recommendations.

4. For flagged trees with nests that were identified as moderately recently occupied (AC MR), tree climbing is not required, but may be considered, as it would determine if the activity status of the nest is more recent. As above, if the tree is climbed, the data and results should also be written on the tree tag. Tree climbing is also not required for those trees identified from the ground as likely or very recently occupied (AC VR).

5. For any tree climbed, if a red tree vole is seen in or on the nest, that nest would be identified as a confirmed red tree vole nest, with occupancy status as animal observed (AC AO).

6. Consider photo documenting the nest for any tree climbed.

7. For trees with confirmed red tree vole nests (AC AO, AC VR, AC MR, UND, INA) or unconfirmed species nests, surveys should be conducted within a 100 m radius to determine the extent of the red tree vole site.

a. For nests found during MLT surveys, the transect surveys may be adequate to document additional nests within the 100 m radius. If the surveyor determines that, based on professional judgment, the MLT surveys likely do not provide an adequate determination of site size, the area between the transects can be walked and viewed for additional red tree vole nests, or the approach under ITE surveys (b., below) can be followed. b. For nests found during ITE surveys, the 100 m search can include a walk through the stand, looking into the canopy for additional nests. If additional red tree vole or unconfirmed species nests are found through these searches, additional searches out another 100 m could be completed to help fully determine the size of the red tree vole site. Continue this until no red tree vole nests are found, or a management decision is made that additional surveys are not necessary based on project size and/or red tree vole management recommendation applications.

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Survey Longevity

At the survey polygon scale, survey results which locate “active” red tree vole nests are considered valid for 10 years. Survey results where only “inactive” or no red tree vole nests were located will be considered valid for 5 years.

Surveyor Skills and Training

This protocol is designed for biologists who will be analyzing red tree vole habitat and survey results and overseeing field personnel or contractors executing red tree vole surveys on public lands managed by the BLM and Forest Service. Professional judgment is involved in analyzing habitat, conducting surveys, and interpreting red tree vole survey results. Knowledge of the biology and ecology of red tree voles and habitats will be essential for a reliable survey.

The minimum requirements for the biologist involved in supervision and interpretation of survey results are:

1. A bachelor's degree in wildlife biology or related field and/or qualification as a GS-486-9, and

2. A thorough understanding of all aspects of this protocol and a thorough understanding of the ecology and nest attributes of tree voles and nests of other arboreal species.

Field surveyors should:

1. Be familiar with techniques involved in project layout and establishing transect lines, and identification and interpretation of evidence of tree vole presence, including differentiation of their nests from those of other species and the ability to clearly describe nest characteristics on data sheets, and

2. Be trained by biologists who are knowledgeable about tree vole biology, sign, surveys, and interpretation of survey results.

Data Management and Data Entry

Data forms are provided in Appendix II for the BLM and Appendix III for the Forest Service. Field units should maintain hard copies of survey plans, data forms, maps, and aerial photos used during the survey for the project record. BLM and Forest Service field units will electronically enter the data into the Geographic Biotic Observations (GeoBOB) and National Resource Information System (NRIS) Wildlife database, respectively.

Tree vole survey data are collected and recorded in a nested design with two data forms. The first data form documents the area surveyed. The second form is used to document the transect surveys, potential nest trees found during ground-based surveys, and the tree climbing results.

Records should show the location, occupancy status, and species determination of all nests observed at each survey area. Surveys where no red tree vole nests are found (negative surveys) are just as

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important as positive surveys for assessing the status and distribution of red tree voles. Negative survey data are required to be entered into the appropriate agency database.

Red tree vole nests discovered incidentally are considered a known site (depending upon nest occupancy status) and will be entered into the GeoBOB or NRIS Wildlife database.

Protocol Modifications

The protocol was designed to ensure a high probability of finding at least some red tree vole nests in stands if red tree voles are present, and to provide consistency among management units in conducting surveys. But there may be site specific conditions that warrant some modification of the protocol. Biologists can make decisions concerning modifications of the protocol based on their professional judgment and sound biological reasoning. Where there is any deviation from the protocol, biologists must document the specific changes and the rationale for those changes and alert their line officers when changes or deviations from the protocol are made. In addition, the data sets collected using the modifications should be clearly identified.

ACKNOWLEDGEMENTS

Many thanks go to Eric Forsman and Jim Swingle who helped re-write the natural history section, provided thoughtful and thorough reviews and edits to this document, and answered a multitude of questions from the authors. Also thanks to Mike Blow for the creation of Appendix I, and to Brian Biswell with his assistance on effective sampling width information. Thanks go as well to the biologists who provided a thoughtful review of previous drafts of this document: Mike Blow, Brett Carré, Josh Chapman, Dick Davis, Brenda Devlin, Joe Doerr, Roli Espinosa, Eric Greenquist, Sue Livingston, Rex McGraw, Kary Schlick and Robin Snider. Thanks also go to Terri Stone and Steve Haney for development of the data entry guidance documents and assistance in developing the field forms.

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LITERATURE CITED

Beavers, S.C., and F.L. Ramsey. 1998. Detectability analysis in transect surveys. Journal of Wildlife Management 62:948–957.

Benson, S.B., and A.E. Borell. 1931. Notes on the life history of the red tree mouse, Phenacomys longicaudus. Journal of Mammalogy 12:226–233.

Blois, J.L., and B.S. Arbogast. 2006. Conservation genetics of the Sonoma tree vole (Arborimus pomo) based on mitochondrial and amplified fragment length polymorphism markers. Journal of Mammalogy 87:950–960. Clifton, P.L. 1960. Biology and life history of the dusky tree mouse Phenacomys silvicola (Howell). M.A. Thesis, Walla Walla College, Walla Walla, WA. 140 p. Corn, P.S., and R.B. Bury. 1986. Habitat use and terrestrial activity by red tree voles (Arborimus longicaudus) in Oregon. Journal of Mammalogy 67:404–406. Curtis, R.O., D.S. DeBell, C.A. Harrington, D.P. Lavender, J.B. St. Clair, J.C. Tappeiner, and J.D Walstad. 1998. Silviculture for multiple objectives in the Douglas-fir region. Gen. Tech. Rep. PNW-GTR-435. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 123 p. Davis, D. 2005. National tree climbing field guide 2005 edition. USDA Forest Service Technical & Development Report 0567-2819-MTDC, Missoula Technical and Development Center, Missoula, MT. 88 p. Dunk, J.R., and J.J.V.G. Hawley. 2009. Red-tree vole habitat suitability modeling: Implications for conservation and management. Forest Ecology and Management 258:626–634. Forsman, E.D., and J.K. Swingle. 2006. White-footed voles living in arboreal nests. Northwest Science 80:308–310. Forsman, E.D., E.C. Meslow, and H.M. Wight. 1984. Distribution and biology of the spotted owl in Oregon. Wildlife Monograph 87:1–64 (Supplement to Journal of Wildlife Management 48). Forsman, E.D., R.G. Anthony, and C.J. Zabel. 2004. Distribution and abundance of red tree voles based on occurrence in pellets of northern spotted owls. Northwest Science 78:294– 302. Forsman, E.D., J.K. Swingle, M.A. McDonald, S.A. Graham, and N.R. Hatch. 2009a. Red tree voles in the Columbia River Gorge and Hood River basin, Oregon. Northwestern Naturalist 90:227– 232. Forsman, E.D., J.K. Swingle, and N.R. Hatch. 2009b. Behavior of red tree voles (Arborimus longicaudus) based on continuous video monitoring of nests. Northwest Science 83:262–272. Forsman, E.D., J.K. Swingle, R.J. Davis, L.S. Andrews, and B.L. Biswell. In prep. Distribution and habitat of the red tree vole (Arborimus longicaudus) and Sonoma tree vole (A. pomo). Gillesberg, A-M., and A.B. Carey. 1991. Arboreal nests of Phenacomys longicaudus in Oregon. 27

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Journal of Mammalogy 72:784–787. Graham, S.A., and G.W. Mires. 2005. Predation on red tree voles by owls and diurnal raptors. Northwestern Naturalist 86:38–40. Hayes, J.P. 1996. Arborimus longicaudus. Mammalian Species 532:1–5. Howell, A.B. 1926. Voles of the genus Phenacomys, II. Life history of the red tree mouse (Phenacomys longicaudus). North American Fauna 48:39–66. Huff, M.H., R.S. Holthausen, and K.B. Aubry. 1992. Habitat management for red tree voles in Douglas-fir forests. Pages 1–16 in M.H. Huff, R.S. Holthausen, and K.B. Aubry, (technical coordinators), Biology and Management of Old-growth Forests. USDA Forest Service, Pacific Northwest Research Station, General Technical Report PNW-GTR-302. Portland, OR. Jewett, S.G. 1920. Notes on two species of Phenacomys in Oregon. Journal of Mammalogy 1:165– 168. Johnson, M.L., and S.B. George. 1991. Species limits within the Arborimus longicaudus species- complex (Mammalia: Rodentia) with a description of a new species in California. Natural History Museum of Los Angeles County Contributions in Science 429:1–16. Kelsey, R.G., E.D. Forsman, and J.K. Swingle. 2009. Terpenoid resin distribution in conifer needles with implications for red tree vole, Arborimus longicaudus, foraging. Canadian Field- Naturalist 123:12–18. Maser, C.O. 1966. Life histories and ecology of Phenacomys albipes, Phenacomys longicaudus, Phenacomys silvicola. M.S. Thesis, Oregon State University, Corvallis, OR. 221 p. Maser, C. 1998. Mammals of the Pacific Northwest: From the Coast to the High Cascades. Oregon State University Press, Corvallis. 406 p. Murray, M.A. 1995. Biochemical systematics of the genus Arborimus. M.A. Thesis, Humboldt State University, Arcata, CA. 46 p. Price, W.W., C.P. Landon, and E.D. Forsman. 2010. Aneides ferreus (clouded salamander): Arboreal activity. Herpetological Review 41:58–59. Ramsey, F.L., V. Wildman, and J. Engbring. 1987. Covariate adjustments to effective area in variable-area wildlife surveys. Biometrics 43:1–11. Swingle, J.K. 2005. Daily activity patterns, survival, and movements of red tree voles (Arborimus longicaudus) in western Oregon. M.S. Thesis, Department of Fisheries and Wildlife, Oregon State University, Corvallis. 118 p. Swingle, J.K., and E.D. Forsman. 2009. Home range areas and activity patterns of red tree voles (Arborimus longicaudus) in western Oregon. Northwest Science 83:273–286. Swingle, J.K., E.D. Forsman, and S.G. Sovern. 2004. A method for live-trapping tree voles. Northwestern Naturalist 85:134–135. Swingle, J.K., E.D. Forsman, and R.G. Anthony. 2010. Survival, mortality, and predators of red tree voles (Arborimus longicaudus). Northwest Science 84:255–265. Thompson, J.L., and L.V. Diller. 2002. Relative abundance, nest site characteristics, and nest

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dynamics of Sonoma tree vole on managed timberlands in coastal northwest California. Northwestern Naturalist 83:91–100. USDA Forest Service, and USDI Bureau of Land Management. 1994a. Final Supplemental Environmental Impact Statement on management of habitat for late-successional and old- growth forest related species within the range of the northern spotted owl (Northwest Forest Plan). Portland, OR. Irregular pagination. USDA Forest Service, and USDI Bureau of Land Management. 1994b. Record of Decision on management of habitat for late-successional and old-growth forest related species within the range of the northern spotted owl (Northwest Forest Plan). Portland, OR. Irregular pagination. USDA Forest Service, and USDI Bureau of Land Management. 2000. Final Supplemental Environmental Impact Statement for amendment to the Survey & Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines. Portland, OR. Irregular pagination. USDA Forest Service, and USDI Bureau of Land Management. 2001. Record of Decision and Standards and Guidelines for Amendments to the Survey and Manage, Protection Buffer, and Other Mitigation Measures Standard and Guidelines. Portland, OR. Irregular pagination. Verts, B.J., and L.N. Carraway. 1998. Land Mammals of Oregon. University of California Press, Berkeley, CA. 668 p. Voth, E.H., C. Maser, and M.L. Johnson. 1983. Food habits of Arborimus albipes, the white- footed vole, in Oregon. Northwest Science 57:1–7. Walker, A. 1930. Notes on the forest Phenacomys. Journal of Mammalogy 11:233–235.

Wimberly, M.C. and J. L. Ohmann. 2004. A multi-scale assessment of human and environmental constraints on forest land cover change on the Oregon (USA) coast range. Landscape Ecology 19: 631-646.

Wooster, T., and P. Town. 2002. Newly discovered food and habitat use by California red tree voles. California Fish and Game 88:181–185.

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Appendix I How Line Transect Spacing was Calculated for Line Transect Surveys

This documents how approximate spacing (130-150 feet) between line transects for red tree vole surveys was calculated. The example provided below (except where noted) delineates transects parallel to each other throughout the survey area and parallel to the longest dimension of the rectangle because it results in the fewest number of transects. Transects could also be delineated to be parallel to the shortest dimension of the rectangle but would result in a greater number of transects. Other methods that achieve a minimum transect length of 300 feet per acre of survey area and spacing of approximately 140 feet apart are acceptable but may be more difficult to delineate and achieve in the field. For survey areas that have more than one general topography, the survey area could be divided into two or more rectangles before applying the process described below.

1) Draw a rectangle (or square) around the project unit large enough to enclose the project area that will be habitat-disturbing for red tree voles (i.e., the survey area) with one side of the figure parallel to the desired direction the transects will run.

In figure 3: Rectangle is 1120 feet wide and 1310 long.

2) Measure each side of the rectangle and calculate its area in square feet (length feet x width feet = feet2).

In figure 3: (1120 feet wide) x (1310 feet long) = 1,467,200 feet2

3) Divide the resulting area in Step 2 by 43,560 feet2 (1 acre) to calculate the total acres of the survey rectangle.

In figure 3: ( 1,467,200 feet2 ) / (43,560 feet2) = 33.7 acres

4) Multiply these acres by 300 feet to get the number of transect footage needed for the rectangle.

In figure 3: ( 33.7 acres) x (300 feet ) = 10,110 feet of transect (minimum)

5) Divide the total transect footage by the length of the side of the rectangle which is parallel to the direction the transects will run. This result will be the approximate number of transect lines needed for the area within the project area. Round up to the next highest whole number to get the final minimum number of transects.

In figure 3: (10,110 feet of transect) / (1310 feet) = 7.7 transect lines. Round 7.7 up to a final answer of 8.0 transect lines needed for survey.

6) Divide the length of the other side of the rectangle that is perpendicular to the direction the transect lines will run by the number of transect lines calculated in step 5 to arrive at the approximate spacing

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between transect lines. Note: Use of the sample methods described in this Appendix will result in a transect spacing value of roughly 130-150 feet (if not, this sample method was not correctly implemented). Other methods of delineating transects that result in slightly different spacing between transects are also acceptable as long as they meet the three requirements of (a) 90 meters/300 feet of transect per acre; (b) transects well distributed in the survey area; and (c) transects far enough apart so their effective visual width does not overlap (a minimum of 15 meters/49 feet from the transect; therefore at least 30 meters / 98 feet between two transects).

In figure 3: (1120 feet) / (8 transect lines) = 140 feet of spacing between transects (approximate).

7) The total length of transects needed to survey a survey area can be divided into varying length segments and distributed throughout the stand (with the spacing guidelines calculated in Step 6) to accommodate stands of various shapes and sizes, and different topology.

8) Recommended to delineate transects across (perpendicular to) any environmental gradients (topography) where possible.

In figure 3: Transects are run roughly perpendicular to the topography lines

9) Delineate the first transect inside the survey area at a location approximately one half of the distance for between-transect spacing calculated in Step 6. Then space subsequent transects at approximately the between-transect spacing distance calculated in Step 6. As with the first transect, the last transect will be approximately one half of the distance for between-transect spacing from the edge of the survey area. See notes on Figure 3.

In figure 3: The between-transect spacing is 140 feet. Transect # 1 is begun approximately 70 feet from the west edge of the survey area (one half of the transect spacing distance of 140 feet). Subsequent transects are spaced approximately 140 feet apart. The last transect, #8, is approximately 70 feet from the east edge of the survey area.

10) To confirm calculations and that the transect layout effectively cover 300 feet of transect length per acre, delineate the transect lines on a project map and measure the total linear feet of transect lines within the area. It may be necessary (but unlikely) that the number of transect lines will need to be adjusted to achieve at least 300 feet of transect per acre of survey area.

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Figure 3: Example Transect Layout NOTE: In the map, transect lines are parallel to the survey rectangle length edge. Transects are approximately equally spaced 140 feet apart. Transects 1 and 8 are approximately 70 feet from the survey rectangle length edge/survey area edge. Initial surveys (not including any subsequent 100 meter searches) would only be required within the grey area (survey-project area).

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APPENDIX II Red Tree Vole Field Forms for Use by BLM in the Geographic Biotic Observations (GeoBOB) Database

Two types of red tree vole field forms are provided for BLM use. This appendix contains instructions on how to fill out the field forms. 1. Red Tree Vole – BLM GeoBOB Survey Form #1: This form is used to record the area surveyed and visits. Each survey area must have a survey form completed even if no voles are located (i.e., document negative surveys). The form contains general information about the survey polygon and visits. 2. Red Tree Vole – BLM GeoBOB Transect and Nest Tree Survey Form #2: This form is used to track ground observations of nests and other objects detected along each transect as well as the tree climbing results. Confirmed red tree vole nests are recorded here as well as nests confirmed to other species (only vole data are required to be entered into GeoBOB, but it does not preclude you from entering other species data). Data fields that are required in GeoBOB are bold on the field form and in these instructions. Additional data fields that are required by this survey protocol to be collected and entered into GeoBOB have an asterisk (*). Data fields that are required by this survey protocol, but have no specific field in the database have a plus sign (+). Instructions are provided on where to enter these data. There are additional data fields on these forms that are generally used while conducting surveys, but are not required in the database. A GeoBOB RTV Data Entry Guide is available with screenshots and instructions specific for GeoBOB RTV data entry. It is recommended that digital maps be printed and attached to the hardcopy field forms. Also scan the final field forms and attach to the GeoBOB record.

Red Tree Vole – BLM GeoBOB Survey Form #1

This form is used to record the area surveyed and visits. Each area surveyed must have a survey form completed even if no voles are located (i.e., document negative surveys). This form may be used to record multiple units (i.e., survey polgyons) in a single BLM project area. For example, a fuels treatment project in the Wildcat Creek watershed may be called Wildcat and have 10 separate units, which are essentially discrete survey polygons. This one form would be used to record visits to the 10 separate units. The project units are considered “Survey” polygon records in GeoBOB. The “Visits” in GeoBOB are non-spatial, tabular records.

Surveys & Visits Survey ID: User defined identification for the survey unit (unique for all surveys within the administrative unit). This field can be pre-filled by computer before printing the form to use in the field. Everyone should begin survey ID with “RTV— .”

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Admin Unit*: The BLM District on which the survey area is located. This field can be pre-filled by computer before printing the form to use in the field.

Sub Admin Unit*: The BLM District Resource Area on which the survey area is located. This field can be pre-filled by computer before printing the form to use in the field.

Location Accuracy: Describes the precision with which the recorded UTMs or lat/longs and the associated GIS digitized (electronic) point or polygon matches the actual ground site location. It is expected that a GPS unit will be used to record the survey polygon boundary. The full list of Location Accuracy values in GeoBOB are:  GENERATED - Generated by GeoBOB application. No map accuracy  GPS1 - GPS unit used; precision within 3 feet or less  GPS2 - GPS unit used; precision within 30 feet or less  GPS3 - GPS unit used; precision within 300 feet or less  MAN1 - Mapped to within 150 feet of actual location  MAN2 - Mapped to within 300 feet of actual location  MAN3 - Mapped to within 1/8 mile of actual location  MAN4 - Mapped to within 1/4 mile of actual location  MAN5 - Mapped to within 1/2 mile of actual location  MAN6 - Precision of mapped location cannot be determined  TR10 - Legal description to the 1/64 section (within 10 acres)  TR160 - Legal description to the 1/4 section (within 160 acres)  TR320 - Legal description to the 1/2 section (within 320 acres)  TR40 - Legal description to the 1/16 section (within 40 acres)  TR640 - Legal description to the section (within 640 acres)  VAGUE - Observation documented in vague descriptions

Project Name*: Project name that the survey is related to or was part of. This field can be pre- filled by computer before printing the form to use in the field.

Survey Type: The reason for doing the survey. Pre-filled with Project Clearance. The full list of Survey Types in GeoBOB are:  Follow-up - A visit done to confirm a species report  Incidental - Observation made while surveying for another species  Inventory - List of species recorded in a survey  Monitoring - Planned & repeated visits to existing observations/sites  Project Clearance - Surveys done prior to project implementation  Purposive - Surveys done in areas where the species is expected to occur  Research - Done for research purposes only

Survey Method: The method used to complete the survey. Check one of the four methods described in this protocol.  ITE - Individual Tree Exam  MLT- Modified Line Transect  SLT – Stands with Large Tree Survey

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 Combo MLT/SLT – Combination of Modified Line Transect and Stands with Large Trees

Protocol Name*: The name of the protocol used to complete the survey. Pre-filled with Survey Protocol for the RTV, v3.0.

Survey Notes: Text field for recording comments about the survey area, which may include a description of survey, location, management notes, general information, etc. It is not required to take notes, but if any are recorded, then enter them into GeoBOB.

Unit Visit Summary Project Unit*: Unit name or number within a project.

Start Date: Day, month, and year (DD/MM/YYYY) that the visit started.

End Date: Day, month, and year (DD/MM/YYYY) that the visit ended.

Observer 1: Primary surveyor for this survey. Write out the first and last name.

Observer 2: Secondary surveyor(s) for this survey. Write out the first and last name(s).

Total Area in Unit: The total area in the unit measured in acres (record unit of measurement if other than acres used). This is the number used to calculate the transect length as shown in Appendix 1 of this protocol. Show on the field form, but no need to enter into GeoBOB.

Total Transect Length: Total length of survey (feet) if the modified line transect survey method is used. Transect length is calculated from the steps outlined in Appendix 1 of this protocol. Show on the field form, but no need to enter into GeoBOB.

RTV Presence (Y/N/X)*: Record Y for yes or N for no depending on whether or not red tree voles were found in the project unit. Record X only if no red tree voles were found, but there is one or more sites in the project unit that have “assumed occupancy” meaning the species is “unconfirmed” and there are sites being managed as active red tree voles sites.

Visit Notes: Text field for recording comments about the survey area, which may include a description of survey, location, management notes, general information, etc. It is not required to take notes, but if any are recorded, then enter them into GeoBOB.

Red Tree Vole – BLM GeoBOB Transect and Nest Tree Survey Form #2

This form is used to track ground surveys conducted along transects and the subsequent tree climbing results. The form is designed to be used as one per project unit. Some data fields on this form are used while conducting surveys and are especially helpful to the tree climbers and project inspectors in relocating trees, but the data fields are not required in the database. Data fields that are required in GeoBOB are bold on the field form and in these instructions. Additional data fields that are required by this survey protocol to be collected and entered into GeoBOB have

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an asterisk (*). Data fields that are required by this survey protocol, but have no specific field in the database have a plus sign (+). Instructions are provided on where to enter these data. There are additional data fields on these forms that are generally used while conducting surveys, but are not required to be entered into the database. A separate document for BLM’s GeoBOB database, the RTV Data Entry Guide, provides instructions for how to enter actual red tree vole animals as “observation” points, red tree vole nests/trees as “feature points” including how to handle situations where the RTV activity status is “undetermined,” and points that are being managed as “active” red tree vole sites but where no red tree vole evidence was confirmed (i.e., “unconfirmed” species) as “assumed occupancy” feature points.

There will be cases where fresh green resin ducts are found on the ground and thus the tree not climbed and the nest examined. Clearly print in the Notes field when this occurs and what the red tree vole evidence was.

At other times, a nest may be spotted in a tree, but the tree not climbed. If confirmation to species cannot be determined from the ground and tree climbing is not considered a viable option, then this is called “unconfirmed” to species and for management purposes the nest is categorized as an “active” red tree vole nest and is managed as a red tree vole site. On the field form clearly indicate this type of point record by filling out the “Climbed Y/N” as No, “Unconfirmed Species Nest Y/N” as Yes, and “Feature Status” as “Assumed Occupancy.” This record will be entered into GeoBOB as an assumed occupied feature point (see RTV Data Entry Guide for data entry instructions).

General Information Admin Unit/Sub Admin Unit: The name of the BLM District and Resource Area. This field can be pre-filled by computer before printing the form to use in the field.

Project Name*: Project name that the survey is related to or was part of. This field can be pre- filled by computer before printing the form to use in the field.

Project Unit*: Unit name or number within a project.

Date: Day, month, and year (DD/MM/YYYY) that the survey visit started.

Transect Bearing: Direction of transect in degrees.

Ground Observers: Person(s) responsible for survey observations. Write out the first and last name.

Climber Observers: Name of the person(s) who climbed the nest tree. Write out the first and last name.

Ground Surveys Transect # or SLT or ITE: The transect line this record is associated with. Or if it is a Stand with Large Trees (SLT) being sampled as per the protocol, then write SLT. If it an Individual Tree Exam (ITE), then write ITE.

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Unique Feature ID/Tree ID: Unique user-defined code for each nest tree found during a project. The code cannot be repeated within a project. It will be entered into GeoBOB as the Feature ID.

Feature Type: A prominent or distinguishing characteristic of a species Observation that is being or may be used by the species of interest. Pre-filled with Tree.

Feature Species/Tree Code*: The species code of the feature, in this case the feature is the tree. The tree species code is unique and based on the species scientific name with the first two letters of the genus and the first two letters of the species plus a tie-breaking number. Use the codes provided by the USDA PLANTS database (http://plants.usda.gov).

Tree DBH*: The nest tree diameter-at-breast-height (inches).

Nest Height: The nest’s height above ground (feet). If more than one nest, record the height of the largest, freshest nest.

# Nests: The number of nests observed in the tree from the ground. Write “NNV” for no nests visible if RTV evidence such as resin ducts were found on the ground at the base of a tree.

Distance along Transect: Enter the distance (in feet) perpendicular to detected nest tree.

Azimuth off of Transect: Enter the direction (degrees) the detected nest is located from the transect.

Distance off of Transect: Enter the distance or estimated distance to the detected nest tree (in feet) from the transect line.

Location Accuracy: Check the appropriate box for whether the GPS precision is within 3 feet or less, 30 feet or less, or 300 feet or less.

UTM Easting: Universal Transverse Mercator (UTM) Easting (Zone 10 - NAD 83) coordinate of the nest tree (6 digits).

UTM Northing: Universal Transverse Mercator (UTM) Northing (Zone 10 - NAD 83) coordinate of the nest tree (7 digits).

Climbing Surveys Climbed (Y/N)+: Was the nest tree climbed? Yes or No.

Date Climbed: Day, month, and year (DD/MM/YYYY) that the survey started.

General Results Confirmed to other Species (Y/N): Was the nest confirmed to be that of another arboreal species? Yes or No.

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Unconfirmed Species Nest (Y/N): Is this a nest where the species is unconfirmed? Yes or No.

Feature Use (RTV Nest Y/N): A description of how the feature is being or could be used. For our specific purposes, record in this data field if this is a red tree vole nest. Yes or No. A new GeoBOB feature use has been added, “RTV nest.” This is the only place in the GeoBOB Features table where it is recorded that this is record is for red tree vole. Feature Use in combination with Feature Status, both mandatory fields in GeoBOB, will be used together to query red tree vole records and their activity and/or management status (see Feature Status).

Feature Status: A description of the feature occupancy status. Only the following Feature Status list of values will be used for red tree vole data. The additional meaning for red tree vole data is shown as italicized text.  Assumed occupancy - It is assumed that the feature is occupied. If confirmation of red tree vole occupancy cannot be determined from the ground and tree climbing is not considered a viable option, then for management purposes the nest is categorized as an “active” with “assumed occupancy” red tree vole nest and is managed as a red tree vole site.  In use - Feature is being used. A nest tree where red tree vole presence has been confirmed as “active.”  Not in use - Feature is not being used. An old vole nest with no sign of recent use. It is “inactive.”

RTV Occupancy Status+: If the nest is confirmed to be red tree vole, what is the activity and occupancy status?  AC AO – Occupied, animal observed, “active”. Vole seen—this is a rare event unless the nest is probed or torn apart, which is not recommended unless part of a research project.  AC VR – Very recently occupied, “active”. A red tree vole nest that is apparently occupied or has been used within the very recent past, but that is not disturbed by the tree climber to determine if it is actually occupied. These nests typically have fresh green cuttings piled on top of the nest or protruding from an entrance tunnel on the top or side of the nest. Green resin ducts are usually present inside or on top of the nest. Green cuttings can persist for weeks, maybe months, in a cool moist environment, but cuttings at likely or very recently occupied nests will be very fresh, with turgid needles, and will often form a plug that blocks the entrance to the nest. Fecal pellets are typically bright green.  AC MR – Moderately recently occupied, “active”. A nest that was probably occupied by a vole within the recent past. May contain older resin ducts that have faded to a pale green. If cuttings are present, they are somewhat desiccated and the needles will often fall off the stem when touched.  INA – “Inactive”. An old vole nest with no sign of recent use. Signs include the nest is compacted or falling apart and the fecal pellets are dark brown to black with no green resin ducts or cuttings. Or the nest material is comprised primarily of a composted layer of compressed fecal pellets, tan or brown resin ducts, and small debarked twigs, often with a layer of debris (conifer needles, cones, lichens, etc.) that has fallen onto the nest. The vole nest material is often in various stages of

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decomposition, and can become difficult to identify in very old nests.  UND – Undetermined. A confirmed red tree vole nest where the activity status and thus the occupancy status was not determined. (Nests classified as red tree vole, “status undetermined”, are to be managed as if they are “active”).

Notes: Text field for recording notes. It is strongly recommended that notes be recorded on the arboreal species, structures and nests (use other species codes and nest support codes). The Notes field is not required in GeoBOB, but if anything is recorded, then enter it into the database because it may be important in the future. The BLM RTV Data Entry Guide has specific instructions for entering the data fields required in the survey protocol for which there is no data field in GeoBOB so that these data can be more easily queried out of GeoBOB in the future.

Other Arboreal Nesting Species  ARAL – Arborimus albipes (White footed vole)  TADO – Tamiasciurus douglasii (Douglas’ squirrel)  GLSA – Glaucomys sabrinus (Northern flying squirrel)  SCGR – Sciurus griseus (Western gray squirrel)  NE – Neotoma spp. (Woodrat)

Nest Support  BW – Branch whorl  CAV – Tree cavity  FT – Forked top  MT – Mistletoe cluster  PBC – Palmate branch cluster  SB – Single large branch

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Red Tree Vole – BLM GeoBOB Survey Form #1 + Bold indicates GeoBOB mandatory data field (circle one, if options shown). Asterisk * and plus sign indicate mandatory RTV Survey Protocol data fields. Survey & Visits Attach Digital Maps

Location Accuracy: GPS1 / GPS2 / GPS3 Survey ID: RTV- Admin. Unit*: Sub Admin. Unit*: If other loc accuracy, describe: Project Name*: Survey Type: Survey Method: ☐Individual Tree Exam (ITE), ☐Modified Line Transect Protocol Name: Survey Protocol for the RTV, v3.0 Project Clearance (MLT), ☐Stands with Large Tree Survey (SLT), ☐Combo MLT/SLT Survey Notes:

Unit Visit Summary

Total Total RTV Project Start End Observer 1 Observer 2 Area in Transect Presence Visit Notes Unit* Date Date* Name Name + Unit (ac) Length (ft.) Y/N/X

GeoBOB Data Management Record Created By: Date: http://intra.or.blm.gov/geobob/Support/Documentation/default.asp Form dated June 22, 2012 RTV PRESENCE Y = Yes N = No X = Assumed Occupancy 40 20140331-506820140416-5027 FERC PDF (Unofficial) 3/28/20144/15/2014 7:42:429:29:06 PM

Red Tree Vole BLM GeoBOB Transect and Nest Tree Survey Form #2a Page __ of __ + Bold indicates GeoBOB mandatory data field. Asterisk * and plus sign indicate mandatory RTV Survey Protocol data fields.

Admin Unit/Sub Admin Unit*: Project*: Project Unit*: Visit Date: Transect Bearing: Ground Observers: Climber Observers:

Climbing Ground Surveys General Results Surveys

NAD 83, UTM zone 10

ID | ID | + Location Accuracy Notes on arboreal species,

Y/N)

(RTV (

Precision within +

structures and nests (use other (feet) ☐ 3 ft; ☐ 30 ft; ☐300 ft

species codes and nest support * (inches) Tree (feet) (feet)

/ (NNV=no

UTM (Y/N) UTM

codes). Enter data in GeoBOB

limbed

Northing

DBH Easting Feature Notes field. nests visible) nests +

e ID (generated (generated from GPS)

from GPS) Y/N) Nest Feature UseFeature Transect# or SLT ITE Unique Feature Tre Feature Type Feature Species Code* Tree Nest Height # Nests Distancealong Transect Azimuthoff of Transect Distance off of Transect Unconfirmed Species Nest Feature StatusFeature Climbed (Y/N) Date C Confirmed Other to Species RTV Occupancy

Status

Tree Tree Tree Tree Tree Tree Tree Tree Tree Tree

FEATURE STATUS: OTHER ARBOREAL NESTING SPECIES NEST SUPPORT: U – In Use (Active RTV) AS OC – Assumed Occupancy ARAL – Arborimus albipes (White footed vole) BW – Branch whorl MT – Mistletoe cluster NOT – Not in Use (Inactive RTV) (RTV not confirmed, managed as TADO – Tamiasciurus douglasii (Douglas’ squirrel) CAV – Tree cavity PBC – Palmate branch cluster Active RTV feature) GLSA – Glaucomys sabrinus (Northern flying squirrel) FT – Forked top SB – Single large branch RTV OCCUPANCY STATUS: SCQR – Sciurus griseus (Western gray squirrel) AC AO – Animal observed, active INA - Inactive NE – Neotoma spp. (Woodrat) AC VR – Very recently occupied, active UND – Undetermined AC MR – Moderately recently occupied, active

Please ensure all Transect and Nest Tree Survey Forms (form 2) and maps showing transect and tree locations remain attached to the Survey/Visit form (form 1) throughout the field and office processes. GeoBOB Data Management Record Created By: Date: http://intra.or.blm.gov/geobob/Support/Documentation/default.asp Form dated August 2, 2012 41 20140331-506820140416-5027 FERC PDF (Unofficial) 3/28/20144/15/2014 7:42:429:29:06 PM

Red Tree Vole BLM GeoBOB Transect and Nest Tree Survey Form #2b Page __ of __ + Bold indicates GeoBOB mandatory data field. Asterisk * and plus sign indicate mandatory RTV Survey Protocol data fields.

Admin Unit/Sub Admin Unit*: Project*: Project Unit*: Visit Date: Transect Bearing: Ground Observers: Climber Observers:

Climbing Ground Surveys General Results Surveys

NAD 83, UTM zone 10

ID +

Location Accuracy Notes on arboreal species, Y/N)

(

(Recorded from GPS) (RTV structures and nests (use other

* species codes and nest support Tree

/

UTM (Y/N) UTM

codes). Enter data in GeoBOB

Northing

DBH Easting

+ Feature Notes field. (generated (generated

Tree ID from GPS) from GPS) Transect# or SLT or ITE Unique Feature | Feature Type Feature Species Code* Tree Nest Height # Nests Distancealong Transect Azimuthoff of Transect Distance off of Transect Unconfirmed Species Nest Climbed (Y/N) Date Climbed Confirmed Other to Species Feature Use Feature Status RTV Occupancy

Nest Y/N) Status

Tree Tree Tree Tree Tree Tree Tree Tree Tree Tree Tree Tree Tree

Tree

GeoBOB Data Management Record Created By: Date: http://intra.or.blm.gov/geobob/Support/Documentation/default.asp Form dated August 2, 2012

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APPENDIX III Red Tree Vole Field Forms for Use by Forest Service in the NRIS (National Resource Information System) Wildlife Database

Two types of red tree vole field forms are provided for Forest Service use. This appendix contains instructions on how to fill out the field forms. 3. Red Tree Vole – USFS NRIS Wildlife Survey Form #1: This form is used to record the area surveyed and visits. Each survey area must have a survey form completed even if no voles are located (i.e., document negative surveys). The form contains general information about the survey “administrative site” and visits. 4. Red Tree Vole – USFS Transect and Nest Tree Survey Form #2: This form is used to track ground observations of nests and other objects detected along each transect as well as the tree climbing results. Confirmed red tree vole nests are recorded here as well as nests confirmed to other species (only vole data are required to be entered into NRIS, but it does not preclude you from entering other species data). Data fields that are required in NRIS Wildlife are bold on the field form and in these instructions. Additional data fields that are required by this survey protocol to be collected and entered into the NRIS Wildlife database, but have no specific field in the database have an asterisk (*). Instructions are provided on where to enter these data. There are additional data fields on these forms that are generally used while conducting surveys, but are not required in the database. An NRIS Wildlife RTV Data Entry Guide is available with screenshots and instructions specific for NRIS Wildlife RTV data entry. It is recommended that digital maps be printed and attached to the hardcopy field forms. Also scan the final field forms and attach to the NRIS Wildlife record.

Red Tree Vole – USFS NRIS Wildlife Survey Form #1

The first section on the survey form is labeled “Survey” and the second section is “Site & Visit.” These labels correspond to the different types of records in the NRIS Wildlife database. In the database, Surveys are non-spatial tabular records. The “Site” in this context is “administrative” rather than biological and refers to the polygon area being surveyed, thus it is essentially the survey area polygon. One Forest Service project may have multiple administrative survey “sites,” which we in the Forest Service often refer to as “units.” The Visits in NRIS Wildlife are non-spatial, tabular records.

Survey Forest/District: The name of the National Forest and the District. This field can be pre-filled by computer before printing the form to use in the field.

Survey Name (Project): The name of the survey, which is often referred to as a “project” in the Forest Service. The survey name must be unique by National Forest. This field can be pre-filled by computer before printing the form to use in the field.

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Target Species: Target species for this survey. Pre-filled with Arborimus longicaudus.

Detected: Circle either the Y for yes or N for no depending on whether or not red tree voles were found in the survey/project area.

Survey Status: Status of the survey.

Data Origin: Was the data collected by the Forest Service, including biologists under contract to the Forest Service, or a Non-Forest Service organization (e.g., State Heritage, BLM, Private Timber Companies, etc)?  Forest Service  Non-Forest Service

Start Date: Day, month, and year (DD/MM/YYYY) that the survey started.

End Date: Day, month, and year (DD/MM/YYYY) that the survey ended. In NRIS Wildlife, End Date is required for a “completed survey.”

Survey Protocol: The survey protocol followed. Pre-filled with Survey Protocol for the RTV, v3.0.

Primary Surveyor: Primary surveyor for this survey. Write out the first and last name.

Quals: The qualifications of the Primary Surveyor.  EXP – Experienced  L EXP – Limited experience  No EXP – No experience  UNKN – Unknown

Survey Steward: The steward (biologist) for this survey. Write out the first and last name.

Survey Method: The method used to complete the survey. Check one of the four methods described in this protocol.  ITE - Individual Tree Exam  MLT- Modified Line Transect  SLT – Stands with Large Trees  Combo MLT/SLT – Combination of methods using Modified Line Transect and Stands with Large Trees

Comments: Text field for recording comments about the survey area, which may include a description of survey, location, management notes, general information, etc. It is not a required field, but if any comments are recorded, then enter them into NRIS.

Sites & Visits Site Category: Category of the site. Pre-filled with Adminstrative since this site represents the survey area polygon and is not biologically derived.

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Site Type: Type of site, which in this case is the survey area polygon represented by a site/unit or multiple sites/units. Pre-filled with Sample Area.

Site Status: Status of the site at the time of the Visit. Pre-filled with Not Applicable because this is an administrative site record.

Site Condition: Condition of the site at the time of the Visit. Pre-filled with Not Applicable because this is an administrative site record.

Site Name: Unique local name of the site, which in the Forest Service we often refer to as a “unit.”

Start Date: Day, month, and year (DD/MM/YYYY) that the site was established or the visit started. In NRIS Wildlife, the start date goes in both the site and the visit record.

End Date: Day, month, and year (DD/MM/YYYY) that the visit ended.

Observer: The name of the person who performed this visit. In the NRIS site record it is called the “originator,” but in the NRIS visit record it is called the “visitor.” Write out the first and last name.

Quals: The qualifications of the person who makes the Visit. Education and field experience generally define the level.  EXP – Experienced  L EXP – Limited experience  No EXP – No experience  UNKN – Unknown

Total Area in Unit: The total area in the unit measured in acres (record unit of measurement if other than acres used). This is the number used to calculate the transect length as shown in Appendix 1 of this protocol. Show on the field form, but no need to enter into NRIS.

Total Transect Length: Total length of survey (feet) if the modified line transect survey method is used. Transect length is calculated from the steps outlined in Appendix 1 of this protocol. Show on the field form, but it is not required to enter into NRIS. If Transect Length is entered into NRIS, it goes in the Visits comments field.

Comments: Text field for recording comments about the site or the visit. It is not a required field, but if any comments are recorded, then enter them into NRIS.

Red Tree Vole – USFS Transect and Nest Tree Survey Form #2

This form is used to track ground surveys conducted along transects and the subsequent tree climbing results. Some data fields on this form are used while conducting surveys and are especially helpful to the tree climbers and project inspectors in relocating trees, but the data

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fields are not required in the database. Data fields that are required in NRIS Wildlife are bold on the field form and in these instructions. Data fields that are required by this survey protocol to be collected and entered into the NRIS Wildlife database, but have no specific field in the database have an asterisk (*). Instructions are provided on where to enter these data. The Data Entry Guide also provides instructions for how to enter actual red tree vole animals as “observation” points, red tree vole nests/trees as “site” points including how to handle situations where the RTV activity status is “undetermined,” and points that are being managed as “active” red tree vole sites but where no red tree vole evidence was confirmed as “administrative site” points.

There will be cases where fresh green resin ducts are found on the ground and thus the tree not climbed and the nest examined. Clearly note in the Comments field when this occurs and what the red tree vole evidence was.

At other times, a nest may be spotted in a tree, but the tree not climbed. If confirmation to species cannot be determined from the ground and tree climbing is not considered a viable option, then this is called “unconfirmed” to species and for management purposes the nest is categorized as an “active” red tree vole nest and is managed as a red tree vole site. On the field form clearly indicate this type of point record by filling out the “Climbed Y/N” as No, “Unconfirmed Species Nest Y/N” as Yes, and write in the Comments field “MANAGE AS ACTIVE SITE.” This record will be entered into NRIS Wildlife as an administrative site point (see RTV Data Entry Guide for data entry instructions).

General Information Forest/District: The name of the National Forest and the District. This field can be pre-filled by computer before printing the form to use in the field.

Survey Name (Project): The name of the survey, which is often referred to as a “project” in the Forest Service. The survey name must be unique by National Forest. This field can be pre-filled by computer before printing the form to use in the field.

Site Name (Unit): Unique local name of the site, which in the Forest Service we often refer to as a “unit.”

Date: Day, month, and year (DD/MM/YYYY) that the survey started.

Transect Bearing: Direction of transect in degrees.

Ground Observers: Person(s) responsible for survey observations. Write out the first and last name.

Climber Observers: Name of the person(s) who climbed the nest tree. Write out the first and last name.

Ground Survey Results Transect # or SLT or ITE: The transect line this record is associated with. Or if it is a Stand with Large Trees (SLT) being sampled as per the protocol, then write SLT. If it an Individual

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Tree Exam (ITE), then write ITE.

Unique Tree ID: Unique user-defined code for each nest tree found during a Survey. The code cannot be repeated within a Survey. This data will be entered into NRIS Wildlife Site form in the Local ID field.

Tree Species Code*: Unique code based on the species scientific name with the first two letters of the genus and the first two letters of the species plus a tie-breaking number. Use the codes provided by the USDA PLANTS database (http://plants.usda.gov). This data will be entered into the biological site comments field (see RTV Data Entry Guide for data entry instructions).

DBH*: The nest tree diameter-at-breast-height (inches). This data will be entered into the biological site comments field (see RTV Data Entry Guide for data entry instructions).

Nest Height: The nest’s height above ground (feet). If more than one nest, record the height of the largest, freshest nest.

# Nests: The number of nests visible in the tree from the ground. Record “NNV” if no nests are visible, but RTV evidence is found at the base of the tree.

Distance along Transect: Enter the distance (in feet) perpendicular to detected nest tree.

Azimuth off of Transect: Enter the direction (degrees) the detected nest is located from the transect.

Distance off of Transect: Enter the distance or estimated distance to the detected nest tree (in feet) from the transect line.

UTM Easting: Universal Transverse Mercator (UTM) Easting (Zone 10 - NAD 83) coordinate of the nest tree (6 digits).

UTM Northing: Universal Transverse Mercator (UTM) Northing (Zone 10 - NAD 83) coordinate of the nest tree (7 digits).

Climbing Survey Results Climbed (Y/N)*: Was the nest tree climbed? Yes or No.

Date Climbed: Day, month, and year (DD/MM/YYYY) that the survey started.

Confirmed to other Species (Y/N): Was the nest confirmed to be that of another arboreal species? Yes or No.

Unconfirmed Species Nest (Y/N): Is this a nest where the species is unconfirmed? Yes or No.

Confirmed RTV Nest Tree (Y/N): Is this a nest that is confirmed to be red tree vole? Yes or No.

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RTV Occupancy Status*: If the nest is confirmed to be red tree vole, what is the activity and occupancy status?  AC AO – Occupied, animal observed, “active”. Vole seen—this is a rare event unless the nest is probed or torn apart, which is not recommended unless part of a research project.  AC VR – Very recently occupied, “active”. A red tree vole nest that is apparently occupied or has been used within the very recent past, but that is not disturbed by the tree climber to determine if it is actually occupied. These nests typically have fresh green cuttings piled on top of the nest or protruding from an entrance tunnel on the top or side of the nest. Green resin ducts are usually present inside or on top of the nest. Green cuttings can persist for weeks, maybe months, in a cool moist environment, but cuttings at likely or very recently occupied nests will be very fresh, with turgid needles, and will often form a plug that blocks the entrance to the nest. Fecal pellets are typically bright green.  AC MR – Moderately recently occupied, “active”. A nest that was probably occupied by a vole within the recent past. May contain older resin ducts that have faded to a pale green. If cuttings are present, they are somewhat desiccated and the needles will often fall off the stem when touched.  INA – “Inactive”. An old vole nest with no sign of recent use. Signs include the nest is compacted or falling apart and the fecal pellets are dark brown to black with no green resin ducts or cuttings. Or the nest material is comprised primarily of a composted layer of compressed fecal pellets, tan or brown resin ducts, and small debarked twigs, often with a layer of debris (conifer needles, cones, lichens, etc.) that has fallen onto the nest. The vole nest material is often in various stages of decomposition, and can become difficult to identify in very old nests.  UND – Undetermined. A confirmed red tree vole nest where the activity status and thus the occupancy status was not determined. (Nests classified as red tree vole, “status undetermined”, are to be managed as if they are “active”).

Comments: Text field for recording notes. It is strongly recommended that notes be recorded on the arboreal species, structures and nests (use other species codes and nest support codes). If a tree was not climbed, no red tree vole evidence was found, but it is going to be managed as an “active” RTV point, write “MANAGE AS ACTIVE SITE” in the Comments so that it is clear how this point is being handled. The Comments field is not required in NRIS, but if any comments are recorded, then enter them into the database because they may be important in the future (see RTV Data Entry Guide for data entry instructions).

Other Arboreal Nesting Species  WFV – White footed vole  DSQ – Douglas’ squirrel  WRT – Woodrat  NFSQ – Northern flying squirrel  WGSQ – Western gray squirrel

Nest Support  BW – Branch whorl

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 CAV – Tree cavity  FT – Forked top  MT – Mistletoe cluster  PBC – Palmate branch cluster  SB – Single large branch

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Red Tree Vole – USFS NRIS Wildlife Survey Form #1 Bold indicates NRIS mandatory field (circle one, if options shown). Survey Attach Digital Maps

Forest/District: Survey Name: (Project)

Target Species Detected Survey Status: Active / Cancelled / Completed / Inactive / Pre-Survey Data Origin: FS / Non-FS Arborimus longicaudus Y / N Start Date: End Date: Survey Protocol: Survey Protocol for the RTV, v3.0 Survey Method: ☐Individual Tree Exam (ITE), ☐Modified Line Transect Primary Surveyor: Quals: Survey Steward: (MLT), ☐Stands with Large Tree Survey (SLT), ☐Combo MLT/SLT Comments:

Site (RTV Survey area polygon) & Visit

Site Category: Administrative Site Type: Sample Area Site Status: Not applicable Site Condition: Not applicable

Total Total Start End Observer 1 Name Observer 2 Name Observer 3 Name Site Name Area in Transect Comments (Unit Name) Date Date and Quals and Quals and Quals Unit (ac) Length (ft)

QUALS: EXP – Experienced No EXP – No Experience L EXP– Limited Experience UNKN - Unknown

http://fsweb.nris.fs.fed.us/products/Wildlife/documentation.shtml Form dated NRIS Wildlife Data Management Record Created By: Date: June 22, 2012

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Red Tree Vole – USFS Transect and Nest Tree Survey Form #2 Page __ of __ Bold indicates NRIS mandatory fields. Asterisk * indicates data field not available in NRIS Wildlife, but required data entry into NRIS nest tree SITE Comments field for nests confirmed as RTV or managed as RTV. Other data fields intended for project tracking and hardcopy permanent record.

Forest/District: Survey Name: (Project) Site Name: (Unit) Date: Transect Bearing: Ground Observers: Climber Observers:

Ground Survey Results Climbing Survey Results

NAD 83, UTM zone 10

LT

*

or S N)

(NNV=no UTM UTM Comments: Notes on arboreal species,

Easting Northing nests visible) nests structures and nests (use other species Tree (generated (generated codes and nest support codes) Unique Species from GPS) from GPS) Transect# or ITE DBH* Nest Height # Nests Distancealong Transect Azimuthoff of Transect Distance off of Transect Unconfirmed Species Nest (Y/N) Climbed (Y/N) Date Climbed Confirmed Other to Species (Y/ Tree ID Code* Tree (Y/N) Status* Confirmed RTV Nest RTV Occupancy

OCCUPANCY STATUS: OTHER ARBOREAL NESTING SPECIES NEST SUPPORT: AC AO – Animal observed, active INA - Inactive WFV – White footed vole NFSQ – Northern flying squirrel BW – Branch whorl MT – Mistletoe cluster AC VR – Very recently occupied, active UND – Undetermined DSQ – Douglas’ squirrel WGSQ – Western gray squirrel CAV – Tree cavity PBC – Palmate branch cluster AC MR – Moderately recently occupied, active WRT – Woodrat FT – Forked top SB – Single large branch http://fsweb.nris.fs.fed.us/products/Wildlife/documentation.shtml Form dated NRIS Wildlife Data Management Record Created By: Date: August 2, 2012

20140331-506820140416-5027 FERC PDF (Unofficial) 3/28/20144/15/2014 7:42:429:29:06 PM Document Content(s) USDA Forest Service PSP comments P-14383.PDF...... 1-30 USFSBLM_2012_RTVSurvey Protocol-V3 0.PDF...... 31-82 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Appendix B Summary of Stakeholder Comments on the Nine Proposed Study Plans (PSP) and Applicant Responses

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Appendix B: Summary of stakeholder comments on the nine proposed study plans (PSP) and applicant responses.

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation 3/28/2014 Timothy FERC Water Nexus to Project (Section 2.1.5) - On page 7 The applicant has included the most Konnert Quality Study of your proposed study plan, you provide up to date information project (Section 2.1) details on potentially affected stream features and distances in the RSP. reaches in the project area; however, the Design work and project refinements, distances provided for the affected stream will continue throughout the reaches do not concur with those distances licensing process provided on page 3 of your additional information responses, included as part of your proposed study plan. In your revised study plan, please ensure the distances for the affected stream reaches, as well as the locations (i.e., river miles) of proposed project facilities on Russell and Whitewater creeks, are accurate 3/28/2014 Timothy FERC 2.1.6 Study Methods (Section 2.1.6) - On pages 7 RSP Study 2.1 has been updated Konnert and 8 of your proposed study plan… accordingly.  the manufacturer, model, and number of all water quality sampling probes and temperature data loggers to be used during all proposed water quality monitoring events; 3/28/2014 Timothy FERC 2.1.6 Study Methods (Section 2.1.6) - On pages 7 RSP Study 2.1 has been updated Konnert and 8 of your proposed study plan… accordingly.  a more detailed description of where 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation each water quality sampling probe and temperature data logger would be located within the water column (i.e., depth in the water column and distance from shoreline) and a corresponding map that shows the GPS coordinates of each probe or logger in relation to proposed project facilities (e.g., diversion dam, powerhouse, etc.); and 3/28/2014 Timothy FERC 2.1.6 Study Methods (Section 2.1.6) - On pages 7 RSP Study 2.1 has been updated Konnert and 8 of your proposed study plan… accordingly.  a description of the frequency with which data from any water quality sampling probes and temperature data loggers would be downloaded. 3/28/2014 Timothy FERC 2.1.6 Study Methods (Section 2.1.6) - On page 8 RSP Study 2.1 has been updated Konnert of your proposed study plan, you propose accordingly. to develop a quality assurance project plan (QAPP) after the study plan determination 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation has been issued by the Commission to address both field and laboratory procedures related to your proposed water quality study. In your revised study plan, please include provisions for the QAPP to be developed in consultation with the Oregon Department of Environmental Quality (Oregon DEQ) and filed with the Commission upon completion. Additionally, please include a provision within the revised study plan that provides Oregon DEQ with a 30-day comment period prior to the QAPP being filed with the Commission. 3/28/2014 Timothy FERC Hydrology Study Methods (Section 2.2.6) - On pages The applicant proposes to use Konnert Study 11 through 15 of your proposed study industry standard equipment (Section 2.2) plan… please provide the following manufactured by Campbell Scientific. additional information: Final equipment selections, including  the manufacturer manufacturer and model numbers, and model of all will be included in the initial study continuous stage report for stakeholder review. measurement and recording devices to be used during the implementation of this study 3/28/2014 Timothy FERC Hydrology Study Methods (Section 2.2.6) - On pages Analog staff gages will be installed in Konnert Study 11 through 15 of your proposed study both locations. (Section 2.2) plan… please provide the following additional information: 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation  clarification as to whether an analog staff gage will be installed on Russell Creek, in addition to the analog staff gage proposed for installation on Whitewater Creek; 3/28/2014 Timothy FERC Hydrology Study Methods (Section 2.2.6) - On pages A Campbell Scientific (or similar) Konnert Study 11 through 15 of your proposed study pressure transducer for water level (Section 2.2) plan… please provide the following measurement will be installed on additional information: Whitewater Creek downstream of  a more detailed the proposed tailrace. The pressure description of where transducer will meet at the US each continuous stage Geological Survey (USGS) measurement and recommended accuracy recording device would requirements and will record stage at be located on Russell 15 minute intervals. This record and Whitewater creeks interval is standard for documenting and a corresponding short-term flow fluctuations. map that shows the The applicant will establish a second GPS coordinates of hydrometric station capable of each device in relation withstanding peak flows and debris to proposed project on Whitewater Creek. This station facilities (e.g., diversion will have direct read cables and dam, powerhouse, etc.) power sources housed in a secure (see comment no. 6); location sufficiently far back from contact with stream flows. An analog staff gage will be anchored adjacent to the hydrometric station to develop a manual stage record. 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation The pressure transducer and staff gage will be surveyed using a total station. By surveying these to a common datum the manual staff gage measurement will be used to calibrate the continuous stage record. The location of the sensor and data exchange interface will be clearly flagged and located in the field with GPS coordinates for ease of data retrieval on subsequent site visits. Maps of the locations will be included in the initial study report. 3/28/2014 Timothy FERC Hydrology Study Methods (Section 2.2.6) - On pages The hydrology study in the RSP has Konnert Study 11 through 15 of your proposed study been updated to include additional (Section 2.2) plan… please provide the following information on when flow additional information: measurements will be taken.  a description of when the five discharge measurements would be taken or how the five sampling dates would be decided upon to ensure they coincide with a wide range of water surface elevations and flow rates; 3/28/2014 Timothy FERC Hydrology Study Methods (Section 2.2.6) - On pages Agreed. The hydrology study in the Konnert Study 11 through 15 of your proposed study RSP has been updated accordingly. (Section 2.2) plan… please provide the following 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation additional information:  a detailed description of the standard guidelines (referenced on page 13 of your proposed study plan) that would be used for cross section selection and placement (see comment no. 6); 3/28/2014 Timothy FERC Hydrology Study Methods (Section 2.2.6) - On pages Agreed. The hydrology study in the Konnert Study 11 through 15 of your proposed study RSP has been updated accordingly. (Section 2.2) plan… please provide the following additional information:  a detailed description of the “other pertinent parameters” (referenced on page 13 of your proposed study plan) that you propose to calculate upon completion of your discharge measurements; 3/28/2014 Timothy FERC Hydrology Study Methods (Section 2.2.6) - On pages The hydrology study in the RSP has Konnert Study 11 through 15 of your proposed study been updated to provide additional (Section 2.2) plan… please provide the following clarification of methods for high additional information: flows.  a detailed description of the hydraulic model (referenced on page 13 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation of your proposed study plan) that would be used during high flow events to calculate stream discharge; 3/28/2014 Timothy FERC Hydrology Study Methods (Section 2.2.6) - On pages The hydrology study in the RSP has Konnert Study 11 through 15 of your proposed study been updated to describe the (Section 2.2) plan… please provide the following regression approach. additional information:  a detailed description of the model that would be used to model the hydrological period of record (referenced on page 15 of your proposed study plan); 3/28/2014 Timothy FERC Hydrology Study Methods (Section 2.2.6) - On pages The hydrology study in the RSP Konnert Study 11 through 15 of your proposed study includes a schedule for agency (Section 2.2) plan… please provide the following review. additional information:  a schedule for soliciting feedback from the resource agencies on selecting the appropriate representative U.S. Geological Survey (USGS) stream gages in the region to generate a historical period of 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation record for streamflows in Russell and Whitewater creeks; and 3/28/2014 Timothy FERC Hydrology Study Methods (Section 2.2.6) - On pages The hydrology study in the RSP has Konnert Study 11 through 15 of your proposed study been updated to include contingency (Section 2.2) plan… please provide the following plans and methods that would be additional information: implemented if representative USGS  any contingency plans stream gages are not available for (and corresponding modeling a longer hydrological methods) that would period of record, as proposed. be implemented if representative USGS stream gages are not available for modeling a longer hydrological period of record, as proposed. 3/28/2014 Timothy FERC Hydrology Study Methods (Section 2.2.6) - As Agreed. The applicant will ensure Konnert Study discussed during the proposed study plan that their contractors completing the (Section 2.2) meeting, selecting appropriate transects for study coordinate their transect continuous stage measurements and selection with the resource agencies. discharge measurements are necessary to collect accurate hydrology data. To ensure the collection of the most accurate data, prior to the initiation of field data collection efforts, staff recommends that the revised study plan provide an opportunity for the resource agencies to participate in selecting the specific transect locations to be used for collecting all stage and discharge 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation measurement data. Incorporating stakeholder involvement, including those knowledgeable about local field conditions in the project area, would ensure that transects are located in the most appropriate areas, such that accurate data can be collected to meet the goals and objectives of this hydrology study. 3/28/2014 Timothy FERC Wetlands Study Area (Section 2.3.2) - On page 16 of An updated study area description Konnert and Waters your proposed study plan, you state that including distances and associated of the US the study area for the wetlands and waters map has been included in the RSP. Delineation of the U.S. delineation study would include (Section 2.3) Russell and Whitewater creeks within the project boundary, and all areas that could be displaced by project construction or operation. In your revised study plan, please describe the study area in terms of the distance (e.g., 100 feet from the bank) on either side of the aforementioned creeks, and the estimated size of the project-affected land areas (e.g., in square feet or acres) that would be surveyed. Additionally, please provide an updated map, as necessary. 3/28/2014 Timothy FERC Wetlands Study Methods (Section 2.3.6) - On page 17 Additional details from the 1987 Konnert and Waters of your proposed study plan, you state that Corps of Engineers Wetland of the US circular plots within a 30-foot radius would Delineation Manual (1987 Manual) Delineation be placed within representative areas to and the Regional Supplement to the (Section 2.3) characterize vegetation, hydrology and Corps of Engineers Wetland soils. In your revised study plan please Delineation Manual: Western provide more detailed information, per Mountains, Valleys, and Coastal 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation section 5.11(b) of the Commission’s Coast Region (Regional Supplement) regulations, about your proposed study have been added to the RSP methods. This information should include Wetlands and Waters of the of the but not be limited to: US Delineation Study including:  the plot size for tree stratum, sapling The 1987 Manual recommends using stratum, herb stratum, a 5-foot radius for herbs and and woody vine saplings/shrubs, and a 30-foot radius stratum vegetative for trees and woody vines (when layers (as applicable); present). The applicant has proposed the more conservative plot size and  a description of which assumes that trees will be present in tests/indices would be the majority of the wetland/waters of used to determine the the US study area. presence of hydrophytic The 1987 Manual has comprehensive vegetation, as well as field protocol for completing wetland how data would be delineations including guidance on recorded (e.g., wetland the number of transects and plots determination data that would be established in the forms); Whitewater Wetlands and Waters of the US Delineation Study Area. The  an estimate of the applicant assumes that “normal number of plots that environmental conditions” as defined would be established in the 1987 Manual occur within the within the study area; project area and subsequently will follow the field protocol guidance for  the schedule for delineations greater than 5 acres. conducting this study, including the field Five levels of wetland indicator season and duration; statuses are applicable in the regional 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation and manual, (i.e., OBL, FACW, FAC, FACU, and UPL). Plus (+) and minus (–)  the personnel tasked to modifiers are not appropriate under conduct this study, guidance of the regional supplement including a description (e.g., FAC–, FAC, and FAC+ plants are of their qualifications. all considered to be FAC). For species listed as NI (reviewed but given no regional indicator) or NO (no known occurrence in the region at the time the list was compiled), the indicator status assigned to the species in the nearest adjacent region will be recorded as part of the study.

Evaluation of the vegetation will include but not be limited to a rapid field test for hydrophytic vegetation. The procedure as outlined in the regional supplement has been included in the RSP

The schedule for study completion, including field activities and the qualifications of individuals completing the study, have been incorporated into the RSP. 3/28/2014 Timothy FERC Aesthetic Study Area (Section 2.5.2) - On page 21 of The USFS provided additional study Konnert Resources your proposed study plan, you state that area comments in the 28 March 2014 Study the study area for the aesthetic resources Proposed Study Plan comments. The (Section 2.5) study would be defined in cooperation with applicant has incorporated their the U.S. Forest Service (Forest Service) in requested study area into the RSP. 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation “Q3 of 2013.” Though “Q3” is not defined, However, the applicant does feel that section 5.11(b) of the Commission’s the aesthetic resources study area regulations clearly states that your may change after completion of the proposed study plan must provide a seen area analysis and subsequent detailed description of the study, which review with the USFS. includes providing the necessary details with respect to the study area. We recommend that you consult with the relevant resource agencies to determine the appropriate study area, and include this information in your revised study plan. 3/28/2014 Timothy FERC Aesthetic Study Methods (Section 2.5.6) - On pages Additional clarification has been Konnert Resources 26 and 27 of your proposed study plan, you provided in Section 2.5.8 of the RSP Study state that you plan to establish key regarding the timing of the KOP field (Section 2.5) observation points (KOP’s) and associated activities. The initial reference to field activities in August (summer) and August and September was to September (fall) of 2014; however, it is provide flexibility as the PSP was unclear if you intend to assess how these prepared in 2013. The applicant KOP’s and activities could be impacted intends to complete all KOP related during the winter or spring months, given field efforts in August of 2014 and the seasonal variation throughout the year. use the results of this effort to Please include this information as part of complete the view shed analysis and your revised study plan. subsequent reporting efforts described in the RSP. 3/28/2014 Timothy FERC Bypass Reach Study Methods (Section 2.6.6) - On pages Comments addressed in Section Konnert Instream 29 through 33 of your proposed study plan, 2.6.6. Flow and you describe the proposed methods for Aquatic your bypass reach instream flow and Habitat Study aquatic habitat study… please provide the (Section 2.6) following information:  a detailed description 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation of the model that would be used to evaluate the relationship between stream flow and aquatic habitat availability; 3/28/2014 Timothy FERC Bypass Reach Study Methods (Section 2.6.6) - On pages Comments addressed in Section Konnert Instream 29 through 33 of your proposed study plan, 2.6.6. Flow and you describe the proposed methods for Aquatic your bypass reach instream flow and Habitat Study aquatic habitat study… please provide the (Section 2.6) following information:  a detailed description of the rationale for choosing cutthroat trout, and any other species of interest, during habitat suitability index curve selection; 3/28/2014 Timothy FERC Bypass Reach Study Methods (Section 2.6.6) - On pages Comments addressed in Section Konnert Instream 29 through 33 of your proposed study plan, 2.6.6. Flow and you describe the proposed methods for Aquatic your bypass reach instream flow and Habitat Study aquatic habitat study… please provide the (Section 2.6) following information:  a description of the life stages (for each selected species of interest) to be used 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation during habitat suitability curve selection; 3/28/2014 Timothy FERC Bypass Reach Study Methods (Section 2.6.6) - On pages ERM cannot provide the exact Konnert Instream 29 through 33 of your proposed study plan, location of transects at this time Flow and you describe the proposed methods for because the proposed Level 2 habitat Aquatic your bypass reach instream flow and mapping will inform where transects Habitat Study aquatic habitat study… please provide the will be placed. (Section 2.6) following information:  the proposed number of transects, the aquatic mesohabitat each transect represents, and the location, including identification on a map and photo documentation, of each transect in the proposed bypassed reach (see comment no. 9 in regards to transect selection); 3/28/2014 Timothy FERC Bypass Reach Study Methods (Section 2.6.6) - On pages Comments addressed in Section Konnert Instream 29 through 33 of your proposed study plan, 2.6.6. Flow and you describe the proposed methods for Aquatic your bypass reach instream flow and Habitat Study aquatic habitat study… please provide the (Section 2.6) following information:  a detailed description of the specific 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation topographic, hydraulic, and geomorphic data that would be used to support modeling incremental changes to flow and subsequent changes to bedload, depth, water velocity, and substrate availability (as referenced on pages 31 and 32 of your proposed study plan); 3/28/2014 Timothy FERC Bypass Reach Study Methods (Section 2.6.6) - On pages Comments addressed in Section Konnert Instream 29 through 33 of your proposed study plan, 2.6.6. Flow and you describe the proposed methods for Aquatic your bypass reach instream flow and Habitat Study aquatic habitat study… please provide the (Section 2.6) following information:  a detailed description of the methods that would be used to assess the various physical habitat attributes (e.g., substrate composition, fish cover, etc.), including fish barriers, discussed on page 32 of your proposed study plan; 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation 3/28/2014 Timothy FERC Bypass Reach Study Methods (Section 2.6.6) - On pages Comments addressed in Section Konnert Instream 29 through 33 of your proposed study plan, 2.6.6. Flow and you describe the proposed methods for Aquatic your bypass reach instream flow and Habitat Study aquatic habitat study… please provide the (Section 2.6) following information:  a description of the number of mesohabitat units that will be selected for detailed assessment of physical habitat attributes and fish relative abundance and/or density; 3/28/2014 Timothy FERC Bypass Reach Study Methods (Section 2.6.6) - On pages Comments addressed in Section Konnert Instream 29 through 33 of your proposed study plan, 2.6.6. Flow and you describe the proposed methods for Aquatic your bypass reach instream flow and Habitat Study aquatic habitat study… please provide the (Section 2.6) following information:  a detailed description of the fisheries sampling techniques that would be employed as part of this study, including a description of the specific reaches within Russell and Whitewater creeks to be sampled; 3/28/2014 Timothy FERC Bypass Reach Study Methods (Section 2.6.6) - On pages Comments addressed in Section 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation Konnert Instream 29 through 33 of your proposed study plan, 2.6.6. Flow and you describe the proposed methods for Aquatic your bypass reach instream flow and Habitat Study aquatic habitat study… please provide the (Section 2.6) following information:  a description of how many depth, velocity, and substrate measurements will be made for habitat suitability index curve validation and how many fish will be selected for your aging analysis; and 3/28/2014 Timothy FERC Bypass Reach Study Methods (Section 2.6.6) - On pages Comments addressed in Section Konnert Instream 29 through 33 of your proposed study plan, 2.6.6. Flow and you describe the proposed methods for Aquatic your bypass reach instream flow and Habitat Study aquatic habitat study… please provide the (Section 2.6) following information:  a description of the various flow scenarios that would be used to model incremental changes to fish habitat. 3/28/2014 Timothy FERC Bypass Reach Study Methods (Section 2.6.6) - To not only ERM provided a draft revised ISF Konnert Instream ensure the collection of the most accurate study plan to regulators on 18 Flow and data, but to also ensure the results of this February 2014. ERM consulted with Aquatic study achieve the stated goals and regulatory agencies, via Habitat Study objectives, staff recommends that prior to teleconference call, on 3 March 2014 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation (Section 2.6) filing your revised study plan, you consult to discuss the draft revised ISF study with the resource agencies in selecting the plan. model that will be used to evaluate the relationship between stream flow and Comments addressed in Section aquatic habitat availability. We also 2.6.8. recommend that you consult with the resource agencies when choosing the number and placement of transects to be used for the purposes of instream flow habitat modeling. Lastly, during the implementation of this study, we recommend that you consult with the resource agencies during the selection of the habitat suitability index curves. 3/28/2014 Timothy FERC Botanical Based on staff review of this plan, and as Botanical study plan has been Konnert Resources indicated during the study plan meeting, updated with detailed descriptions of and Wildlife your botanical resources and wildlife existing data, specific tasks (pre-field, Habitat Study habitat study combines elements from field, post-field), target species, study (Section 2.7) various requested studies. However, the area definition, methods protocols, study methods (Section 2.7.6), listed on timing, frequency, and deliverables. pages 37 through 39 of your proposed study plan, are difficult to follow and The wildlife resources study has been moreover do not include sufficient detail made a separate study (Section 2.10) to determine the effectiveness of the study apart from the botanical study. The in acquiring data to assess project-related study will have two components: 1) impacts on habitat noxious weeds, or general wildlife habitat assessment sensitive plants. The ground survey (using vegetation and special habitats protocols, timing of data collection and the data collected as part of the botanical number of sampling visits are too vague or resources study); and 2) T/E and undetermined, and the best season for sensitive wildlife species survey and sampling can vary considerably, depending habitat assessment. Detailed 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation on the target species. Further, the study methods for acquiring wildlife data does not include survey methods for for each of the requested TES species acquiring wildlife data; though evaluating has been added to the wildlife RSP. project effects on wildlife species is included as part of the goals and objectives for the study (as listed on page 35 - Section 2.7.1). Therefore, we recommend that you revise the study, in consultation with the relevant resource agencies, based on the issues stated above. Revisions may include, separating this single proposed study into two (or more) studies based on the target species, habitat type, or the type of surveys to be performed (e.g., a wildlife study, and botanical resources study). The revised plan(s) should include at a minimum: 3/28/2014 Timothy FERC Botanical the study methods (Section 2.7.6), listed on Botanical RSP and RSP figure (Figure Konnert Resources pages 37 through 39 of your proposed 5) has been updated to include areas and Wildlife study plan… to be surveyed. Habitat Study  maps showing the (Section 2.7) area(s) that would be A preliminary characterization of the surveyed, including a major habitat types is part of the preliminary botanical study (vegetation type characterization of the mapping), and is therefore not major habitat types included in the study plan. 3/28/2014 Timothy FERC Botanical the study methods (Section 2.7.6), listed on Botanical study plan has been Konnert Resources pages 37 through 39 of your proposed updated with detailed descriptions of and Wildlife study plan… existing data, specific tasks (pre-field, Habitat Study  a detailed description field, post-field), target species, study (Section 2.7) of ground survey area definition, methods protocols, protocols/sampling timing, frequency, and deliverables. 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation methods, including but not limited to, the timing of data collection, plot sizes, the number of sampling visits, and a schedule for surveys; 3/28/2014 Timothy FERC Botanical the study methods (Section 2.7.6), listed on The wildlife RSP was updated to Konnert Resources pages 37 through 39 of your proposed describe how wildlife use will be and Wildlife study plan… assessed (using vegetation mapping Habitat Study  a detailed description to determine wildlife habitat). (Section 2.7) of how wildlife use of the project area would be assessed; 3/28/2014 Timothy FERC Botanical the study methods (Section 2.7.6), listed on Lists of target botanical species to be Konnert Resources pages 37 through 39 of your proposed surveyed were added to the and Wildlife study plan… botanical resources. Habitat Study  a list of any target (Section 2.7) species/habitat (i.e., A list of target wildlife species for special-status species, which habitat will be assessed was noxious plants, riparian added to the wildlife RSP. habitat, critical habitat, etc.) and any specific Special habitats survey will follow the characteristics that USFS protocol; a description of the would influence how special habitats survey has been the data is collected added to the study plan. (e.g., peak plant flowering period, wildlife activity); 3/28/2014 Timothy FERC Botanical the study methods (Section 2.7.6), listed on Detailed methods and deliverables Konnert Resources pages 37 through 39 of your proposed list has been added to the botanical 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation and Wildlife study plan… resources and wildlife RSPs. Habitat Study  a detailed description (Section 2.7) of how data would be compiled and presented to stakeholders; and 3/28/2014 Timothy FERC Botanical the study methods (Section 2.7.6), listed on Identification of the staff to conduct Konnert Resources pages 37 through 39 of your proposed the surveys has been added to the and Wildlife study plan… botanical resources and wildlife RSPs. Habitat Study  identification of the (Section 2.7) qualified professional(s) who would conduct these surveys, including a description of their qualifications.

3/28/2014 Timothy FERC Soils and Study Methods (Section 2.8.6) – As part of Comments have been addressed in Konnert Geology your soils and geology resources study, you the section 2.8 of the RSP. Resources are proposing a phased approach to Study studying general geology, soils, and (Section 2.8) geotechnical information in the proposed project area. Currently, there is insufficient detail provided on Phase 2 of this study. So that staff can evaluate the study in full, please provide all components of a standard study plan (see section 5.11(d) of the Commission’s regulations) for each of the study phases, including a detailed methodology which addresses the six criteria detailed in the body of this letter. 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation Also, for Phase 2 of this study, please ensure you provide the following, as appropriate:

 a topographic map indicating the study area for any geologic investigations;

 a schedule for conducting any proposed geologic investigations; and

 a preliminary indication of the number of subsurface samples you anticipate collecting, the properties you will test for, and under what conditions additional subsurface testing beyond the proposed samples will be conducted. 3/28/2014 Timothy FERC Soils and Please clearly identify the “triggers,” or Additional clarification on “Triggers” Konnert Geology thresholds that would be met during Phase has been included in section 2.8.6 in Resources 1 of the study to justify the implementation the RSP. Study of Phase 2. If it is not possible to identify (Section 2.8) the triggers for Phase 2 of the study prior to conducting Phase 1, please describe a decision-making process that would be used when deciding whether to implement Phase 2 of the study. 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation 3/28/2014 Timothy FERC Soils and Please note that for original major The applicant is aware that a Konnert Geology construction (greater than 1.5 megawatts Supporting Design Report consistent Resources of capacity), a Supporting Design Report with section §4.41(g) of the Study consistent with section §4.41(g) of the Commission’s requirements will need (Section 2.8) Commission’s requirements will need to be to be filed with any final license filed with any final license application. application. Please take these requirements into account when developing your revised study plan. 3/28/2014 Timothy FERC Recreation Goals and Objectives (Section 2.9.1) – On The recreation resources study has Konnert Resources page 44 of your proposed study plan, you been revised to include methods for Study state that the goal of the recreation documenting existing sites, use, (Section 2.9) resources study is to formally document demand, and measures to assess campsites and dispersed recreation areas, project related impacts of recreation as well as vehicular traffic along Forest for appropriate P, M,&E measures. In Service Road 040 and Forest Service Road addition, the area of study has been 440. However, your study does not provide revised to include areas beyond specific methods for capturing recreational Forest Service Road 040 and 440. use data in the vicinity of the project. Therefore, you should conduct a recreation survey as part of your proposed study to establish a baseline of recreation usage and to determine future need at, and in the vicinity of, the proposed project. If you propose any recreation facilities based on the results of your recreation study, a recreation plan should be provided with your initial study report. The recreation survey, which should be conducted after consultation with the Forest Service and other relevant agencies, should include, at 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation a minimum:

 on-site surveys at the proposed project and in adjacent areas to obtain the current usage data and to project future recreation needs.

 all formal and informal public recreation areas that allow public access to project lands or waters;

 the usage data should be reported in recreation days, for the average weekday, weekend, peak 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation weekend averages, and annual number of total visits;

 assessment of the recreation opportunities for each season (i.e., winter, summer, spring and fall); and

 a description of the current and projected capacity of the existing recreation facilities and be representative of the entire recreation season. 3/28/2014 Timothy FERC Recreation Study Methods (Section 2.9.6) - On page 46 The Applicant contacted FERC on 9 Konnert Resources of your proposed study plan, you state that April 2014 to clarify their comment Study traffic counters would be used to regarding access to the vehicular (Section 2.9) document existing vehicle access within the traffic data. FERC clarified that they project area. In your revised study plan, were requesting information on how please clarify how long the traffic counters traffic counter data would be would remain on Forest Service Road 040 interpreted and used in the analysis. 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation and Forest Service Road 440, and what protocol is being used to access the The traffic counter data will be used vehicular traffic data. to document existing vehicle access within the immediate project area. Traffic counters will provide daily use information, which will allow evaluation of recreator access use with respect to day of the week and time of the year during snow free periods. This existing vehicle use information will assist in the preparation of the study’s effects analysis describing in part how project construction and/or operation could impact recreation sites and/or recreation use. 3/26/2014 Christopher ODEQ Water The final study plan determination issued RSP Study 2.1 has been updated to Stine Quality Study by FERC should include monitoring for the include sampling for major ions. following parameters: Major Ions: The buffering capacity of freshwater systems is influenced by the composition of certain common major ions. Reduced flows in the bypassed reaches may impair water quality parameters including pH which may cause stressful aquatic conditions. Establishing baseline water chemistry conditions will help understand how aquatic systems resist changes in pH caused by project-related effects. ODEQ recommends quarterly grab sample 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation analysis for this principle ion group. 3/26/2014 Christopher ODEQ Water The final study plan determination issued RSP Study 2.1 has been updated to Stine Quality Study by FERC should include monitoring for the include sampling for nutrients. following parameters: Nutrients:2 Organic and inorganic forms of nitrogen and phosphorus are principal nutrients which influence primary production. The Project proposes to alter the hydrologic regime of the watershed which may directly influence productivity in affected streams. ODEQ recommends spring, summer, and fall sampling for nutrients to characterize baseline water quality conditions. 3/26/2014 Christopher ODEQ Water The final study plan determination issued RSP Study 2.1 has been updated to Stine Quality Study by FERC should include monitoring for the include sampling for Chlorophyll-a following parameters: and ecoli. Chlorophyll-a; e.coli: ODEQ recommends spring, summer, and fall grab sample analysis for these parameters. 3/26/2014 Christopher ODEQ Water The final study plan determination issued RSP Study 2.1 has been updated to Stine Quality Study by FERC should include monitoring for the include surface water sampling for following parameters: Mercury at three principal locations Mercury: along Russell and Whitewater Creeks. Mercury is present in Oregon through naturally occurring mineral sources and atmospheric deposition. Mercury is bioaccumulative in fish tissue in the form of methylmercury. ODEQ recently developed 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation a mercury water quality standard based on the concentration of methylmercury in fish tissue. Mercury methylation is caused, in part, by the metabolism of anaerobic bacteria. Because reduced flow in bypassed reaches may lower DO concentrations, ODEQ recommends initial screening for mercury through quarterly water samples collected at the three principle sampling locations. 3/26/2014 Christopher ODEQ Water The final study plan determination issued Disagree. The applicant agrees that Stine Quality Study by FERC should include monitoring for the macroinvertebrate communities are following parameters: an indirect indicator of water quality Benthic Macroinvertebrates: and habitat health. However, this Reduced streamflow may degrade habitat indirect measure of water quality is through steam alteration and reduced unnecessary as the applicant is sediment delivery. Macroinvertbrate already proposing comprehensive communities are an indicator of water direct measurements of water quality and aquatic habitat health. ODEQ quality. Oregon Water Quality recommends Whitewater conduct an standards are already protective of assessment of macroinvertebrate macroinvertebrates. Adding a communities present in the project area macroinvertebrate study in addition during the spring, summer, and fall using to comprehensive water quality and the assessment techniques and survey aquatic habitat surveys will not protocols developed by the Environmental substantively aid in the development Protection Agency and accepted by the US of P,M,&E measures for water quality Forest Service. of aquatic habitat. 3/26/2014 Christopher ODEQ Hydrology The PSP adopted the principle The applicant has proposed a robust Stine Study recommendations of ODEQ and other hydrology study in order characterize stakeholders in developing a study plan to the hydrological conditions in the characterize the hydrological conditions in Whitewater and Russell Creek 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation the Whitewater and Russell Creek watersheds in the RSP. watersheds. A final study plan determination issued by FERC should require sufficient detail to quantify the magnitude, duration, and frequency of flows in the affected watersheds. The study should also determine whether sources of groundwater accretion provide significant contribution to base flows. 3/26/2014 Christopher ODEQ Hydrology In consultation with USDA Forest Service, The applicant has proposed a Stine Study the applicant should install one gage in the hydrology study in the RSP that upper bypassed reach of Russell Creek near includes gages and monitoring in the proposed diversion and one gauge these locations. below the approximate location of the proposed powerhouse on Whitewater Creek. Gages should be installed at appropriate fixed locations using practices that ensure reliable operation and data availability. The applicant should develop rating curves to correlate streamflow with channel stage. Monitoring should be conducted continuously and continue for at least one year. 3/26/2014 Christopher ODEQ Soils and Project operation may directly reduce the Agreed. The applicant has included a Stine Geology delivery of critical substrate material below bedload study in the RSP. Resources the proposed diversion structure. Managed Study flows in the bypassed reach may further alter geomorphology, habitat complexity, and sediment delivery. The Applicant should develop a study to evaluate the effect of Project operations on sediment 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation transport between the diversion structure and the powerhouse tailrace. ODEQ supports recommendations by the USDA Forest Service to convene a technical advisory committee to guide development and implementation of plans to evaluate sediment dynamics in affected Project reaches. 3/27/2014 John Zauner ODFW Bypass Reach The following are examples within the ERM provided a draft revised ISF Instream study plan where further discussion and study plan to regulators on 18 Flow and detail for the IFIM analysis, and the February 2014. ERM consulted with Aquatic evaluation of fish habitat, fish community regulatory agencies, via Habitat Study composition, distribution, relative teleconference call, on 3 March 2014 abundance and fish density within Russell to discuss the draft revised ISF study and Whitewater Creeks needs to be plan. The RSP has been updated provided in order to not only understand accordingly. what is being proposed, but also to approve the Proposed Study Plan: pg. 33 - "Various scenarios will be selected to model incremental changes to fish habitat. The flow scenarios to be selected will depend upon a number of factors such as species life history timing and operational regimes of the project", 3/27/2014 John Zauner ODFW Bypass Reach The following are examples within the ERM provided a draft revised ISF Instream study plan where further discussion and study plan to regulators on 18 Flow and detail for the IFIM analysis, and the February 2014. ERM consulted with Aquatic evaluation of fish habitat, fish community regulatory agencies, via Habitat Study composition, distribution, relative teleconference call, on 3 March 2014 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation abundance and fish density within Russell to discuss the draft revised ISF study and Whitewater Creeks needs to be plan. The RSP has been updated provided in order to not only understand accordingly. what is being proposed, but also to approve the Proposed Study Plan: pg. 32 - "Physical habitat attributes such as substrate composition, substrate embeddedness, substrate compaction, fish cover, pool residual depth, functional L WD, and distribution, etc. will assessed", 3/27/2014 John Zauner ODFW Bypass Reach The following are examples within the Electrofishing methods are provided Instream study plan where further discussion and in Section 2.6.6. Flow and detail for the IFIM analysis, and the Aquatic evaluation of fish habitat, fish community Based upon the 3vMarch 2014 Habitat Study composition, distribution, relative teleconference with regulatory abundance and fish density within Russell agencies, electrofishing was and Whitewater Creeks needs to be determined to be the most provided in order to not only understand appropriate method for the study what is being proposed, but also to area glacial streams because of low approve the Proposed Study water clarity (ability to visually Plan: observe fish underwater) and low pg. 32-"Techniques for fish relative water temperatures (human safety abundance and/or density assessments will concerns regarding snorkeling). depend upon local site conditions, but will include snorkeling and/or electrofishing". 3/27/2014 John Zauner ODFW Bypass Reach With a proposed diversion of this ERM provided a draft revised ISF Instream magnitude, it is likely that analysis of study plan to regulators on 18 Flow and rearing/spawning for February 2014. ERM consulted with Aquatic cutthroat trout with Physical Habitat regulatory agencies, via 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation Habitat Study Simulation (PHABSIM) will tell only part of teleconference call, on 3 March 2014 the story. A to discuss the draft revised ISF study large diversion of winter flows would be plan. The RSP has been updated expected to affect side channel/off accordingly. channel/wetland areas, and could also have effects on channel morphology. Therefore included within the Proposed Study Plan should be analysis of the potential effects on side channel/off channel/wetland area within the bypass reach. 3/27/2014 John Zauner ODFW Bypass Reach In addition, because IFIM incorporates ERM provided a draft revised ISF Instream many steps and decision points, project study plan to regulators on 18 Flow and scoping is critical for PHABSIM studies. February 2014. ERM consulted with Aquatic ODFW needs to have the opportunity to regulatory agencies, via Habitat Study advise, and comment at each step. This teleconference call, on 3March 2014 commitment to contact and coordinate to discuss the draft revised ISF study with ODFW at these critical steps should be plan. The RSP has been updated included within the text of the Study Plan accordingly. and within a detailed schedule developed for the study. In addition, ODFW recommends that PHABSIM data be collected and processed by people with prior PHABSIM experience 3/27/2014 John Zauner ODFW Bypass Reach Transect placement: ODFW will need to ERM provided a draft revised ISF Instream review the number of proposed transects, study plan to regulators on 18 Flow and the mesohabitats they represent, and their February 2014. ERM consulted with Aquatic locations in the stream. Study regulatory agencies, via Habitat Study measurements should not proceed without teleconference call, on 3 March 2014 prior ODFW approval of the transect to discuss the draft revised ISF study placement. plan. The RSP has been updated accordingly. 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation

3/27/2014 John Zauner ODFW Bypass Reach Target flows: Based on the results of ERM provided a draft revised ISF Instream hydrological studies, the Applicant will study plan to regulators on 18 Flow and produce estimated flow duration curves February 2014. ERM consulted with Aquatic and other flow statistics for Russell and regulatory agencies, via Habitat Study Whitewater Creeks. Using this information, teleconference call, on 3 March 2014 ODFW will advise on the range of flows for to discuss the draft revised ISF study PHABSIM data collection. The field work plan. The RSP has been updated should be timed so that high, medium, and accordingly. low flows can be measured on the descending limb of the hydrograph if at all possible. 3/27/2014 John Zauner ODFW Bypass Reach Hydraulic modeling: ODFW needs the ERM provided a draft revised ISF Instream opportunity to review the field data study plan to regulators on 18 Flow and collected, and offer comments and advice February 2014. ERM consulted with Aquatic on the hydraulic modeling process, regulatory agencies, via Habitat Study including the upper and lower limits of teleconference call, on 3 March 2014 extrapolation. The Applicant should provide to discuss the draft revised ISF study copies to ODFW of field notes, basic plan. The RSP has been updated computer input files (using PHABSIM or accordingly. RHABSIM software), and summaries of measured vs. simulated cell velocities. 3/27/2014 John Zauner ODFW Bypass Reach Habitat suitability criteria (HSC): Applicant ERM provided a draft revised ISF Instream should assemble data from relevant field study plan to regulators on 18 Flow and studies, and develop proposed HSC, along February 2014. ERM consulted with Aquatic with the rationale for cutthroat trout and regulatory agencies, via Habitat Study juvenile adult life stages. ODFW will need teleconference call, on 3 March 2014 to review the HSC and propose to discuss the draft revised ISF study adjustments. Final HSC will need ODFW plan. The RSP has been updated sign-off before the HABTAT phase of accordingly. modeling proceeds. 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation 3/27/2014 John Zauner ODFW Bypass Reach - Page 2-3 -The discussion of IFIM, SEF A, Comment addressed in Section 2.6.6. Instream and PHABSIM creates confusion. It would Flow and be clearer if it was simply stated that SEFA was referenced in the study Aquatic Whitewater Green Energy was going to use plan, and PHABSIM was not Habitat Study a PHABSIM-type model. It makes little referenced in the study plan to difference whether a SEFA version of reduce reader confusion. PHABSIM or standard PHABSIM is used. 3/27/2014 John Zauner ODFW Bypass Reach - ERM describes mesohabitat mapping, and Comment addressed in Section 2.6.6. Instream also suggests representative reaches. This Flow and needs to be clarified, as habitat mapping Mesohabitat mapping will be Aquatic and representative reach are often conducted for the defined study area Habitat Study described as two distinct methods. reaches, according to the USFS Level 2 habitat assessment in the Stream Inventory Handbook. All mesohabitats will be mapped within the defined study area reaches. The representative reach is for the purposes of the instream flow assessment, not habitat mapping. The location of the representative reach will be determined from the Level 1 and 2 fish habitat assessments, segment break analysis (hydrogeomorphic units), background fisheries information, and proposed infrastructure locations. The representative reach will then be used for the modeling exercise.

3/27/2014 John Zauner ODFW Bypass Reach Page 9- One of the key decisions in ERM cannot provide an estimate of Instream PHABSIM modeling is estimating the range the range of flows (in cfs) to be 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation Flow and of flows to model, and choosing the flow modeled because the watershed is Aquatic level (calibration flow) at which all of the not developed/operational. Section Habitat Study velocities at each transect will be 2.6.6 states that each selected flow measured. Usually this is a relatively high scenario will be used to quantify flow, since modeling downward is more change in available Coastal Cutthroat accurate than modeling up from a low Trout habitat. This will include a measured flow. Although flow conditions comparison of naturalized and are not precisely known at present, it operational habitat availability for all would be good for ERM to make an initial months. estimate of the range to be modeled, and also estimate a calibration flow of XX cfs. 3/27/2014 John Zauner ODFW Bypass Reach -Flow magnitude has been observed to vary For the purposes of fish and habitat Instream greatly and rapidly during a single day's sampling, an approach to deal with Flow and time within the bypass reach in response to daily/hourly changes in flow and Aquatic weather conditions and glacial melt. To water clarity is provided in Section Habitat Study ensure that reliable and accurate data is 2.6.6. collected Whitewater Green Energy should develop and include within the Study a plan For the purposes of hydrology to cope with rapidly changing discharge sampling, a total of five flow conditions. measurements will be conducted at each transect to develop rating curves and habitat-flow relationships (Section 2.6.6). Each transect is independent of each other; therefore, differences in flow between the morning and afternoon are acceptable and one transect measurement does not influence another. If the stream is dynamic, as suggested by regulators, than measurements during these flow 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation ranges will strengthen the model. 3/27/2014 John Zauner ODFW Bypass Reach - Included within the Study Plan should be a Comment addressed in Section 2.6.6. Instream section regarding how the potential effects Flow and on side channel/off channel/wetland area Aquatic within the bypass reach will analyzed. Habitat Study 3/27/2014 John Zauner ODFW Bypass Reach Validating cutthroat HSI information is Comment addressed in Section 2.6.6. Instream likely to be difficult. ODFW does not Flow and recommend the preference calculation As stated by ODFW and as per the Aquatic described on pp 12-13. Rather, Whitewater 3 March 2014 regulator Habitat Study Green Energy should sample all teleconference call, Coastal Cutthroat mesohabitats equally, and just analyze the Trout habitat preference may not be Utilization data. validated. It is recognized that there will be difficulty in obtaining sufficient sample size to validate the habitat preference curves due to high likelihood of low fish densities and low water clarity. 3/27/2014 John Zauner ODFW Bypass Reach -Page 13 - ODFW supports the use of Electrofishing methods are provided Instream juvenile and adult snorkel surveys as in Section 2.6.6. Flow and proposed. However, if glacial melt excludes Aquatic or limits the feasibility of snorkel surveys Based upon the 3 March 2014 Habitat Study during the timeframes provided, teleconference with regulatory Whitewater Green Energy should contact agencies, electrofishing was and coordinate with ODFW to develop the determined to be the most appropriate protocol to collect the same appropriate method for the study information as provided in the study plan; area glacial streams because of low which may include electrofishing survey. water clarity (ability to visually observe fish underwater) and low water temperatures (human safety concerns regarding snorkeling). 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation 3/27/2014 John Zauner ODFW Bypass Reach - Page 15 - Conducting spawning surveys Comment addressed in Section 2.6.6. Instream within the bypass reach will be difficult, Flow and and hit and miss clue to flow conditions as Based upon the 3 March 2014 Aquatic well as spawning timing. ODFW teleconference with regulatory Habitat Study recommends not pursuing spawning agencies, spawning surveys within ground surveys and that efforts the study area will excluded from the concentrate on the fish community field program. composition, distribution, relative abundance and fish density components of the Study Plan. 3/27/2014 John Zauner ODFW Bypass Reach -Page 17- Various flow scenarios are Section 2.6.6 states that each Instream mentioned. However, the most important selected flow scenario will be used to Flow and flow scenarios are the natural flow regime quantify change in available Coastal Aquatic and proposed project flows. Cutthroat Trout habitat. This will Habitat Study include a comparison of naturalized and operational habitat availability for all months. 3/27/2014 John Zauner ODFW Bypass Reach As discussed previously, ODFW must have Comment addressed in Section 2.6.8. Instream the opportunity to comment, advise, and Flow and agree at each of the following steps Aquatic associated with IFIM analysis: Transect Habitat Study Placement, Target Flows, Hydraulic modeling, and the development of the Habitat Suitability Criteria. This commitment to contact and coordinate with ODFW at these critical steps should be included within the text of the Study Plan and within the detailed schedule Table 1 provided at the end of the Plan. 3/27/2014 John Zauner ODFW Botanical Construction, operation and maintenance Wildlife habitat types will be Resources of the proposed project features such as identified using the vegetation 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation and Wildlife diversion structure, penstock, access roads, mapping and special habitats portion Habitat Study transmission corridor, powerhouse and of the botanical study, as well as tailrace will either directly or indirectly additional resource information, as affect wildlife by altering habitat through described in the wildlife resources soil disturbance, removal of vegetation, study plan. and modified stream flow. ODFW is the state agency with jurisdiction over fish and wildlife in Oregon: See ORS 496.01 2; the Fish and Wildlife Coordination Act at 16 U.S.C. § 661 and 662; the Federal Power Act at 16 U .S.C § 803 and 811. Evaluation of project impacts on wildlife species occurring within the proposed project area will require locating and identifying the various wildlife habitat types found within the proposed project area. 3/27/2014 John Zauner ODFW Botanical The Wildlife Habitat Study component of The wildlife resources study has been Resources the plan is incomplete and difficult to made a separate study (Section 2.10) and Wildlife follow. This is largely due to it being apart from the botanical study. The Habitat Study combined and interfused with the botanical study will have two components: 1) resource component. Wildlife and general wildlife habitat mapping Botanical Resources are two distinct (using vegetation and special habitats resources with unique complexities. To data collected as part of the botanical avoid confusion, the wildlife habitat study resources study); and 2) T/E and component of the study should be included sensitive species survey and habitat and discussed separately from the assessment. botanical resources component. 3/27/2014 John Zauner ODFW Botanical There are two specific goals to be included Wildlife habitat types will be Resources in the wildlife habitat study. The first is to identified using the vegetation and Wildlife identify the various wildlife habitats mapping and special habitats portion Habitat Study including special wildlife habitats such as of the botanical study, and additional 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation cliffs, talus slopes, wetlands, seeps, and resource information. This approach springs occurring within the proposed has been described and clarified in project area. The second is to utilize the the wildlife RSP. wildlife habitat data collected to assist in the development of a list for state endangered, threatened and sensitive wildlife species occurring within the proposed project area. 3/27/2014 John Zauner ODFW Botanical We agree that available wildlife habitat Agreed. Added this information to Resources data for the project area is lacking, making the Existing Information, and Study and Wildlife it difficult to evaluate project impacts as Methods sections of the wildlife Habitat Study well as to provide prescriptions that avoid, resources study. minimize or mitigate project impacts. This lack of available wildlife habitat data also makes the development of a state endangered, threatened and sensitive wildlife species list for the project area difficult to complete. However, once wildlife habitat surveys are conducted the development of a list for those wildlife species likely to occur within the project area becomes a desktop operation. Using the 2013 Rare, Threatened, and Endangered Species Oregon Biodiversity Information Center at Portland State University wildlife species data by county along with a review of habitat requirements and those habitats found within the project area will produce a list of state endangered, threatened and sensitive wildlife species that may occur within the 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation project area: allowing for development of study framework as well as assisting in the development of avoidance, minimization, and mitigation measures for project impacts. 3/27/2014 John Zauner ODFW Botanical The wildlife habitat study methods section The wildlife RSP is now separate from Resources should clarify that wildlife habitat surveys the botanical RSP, and has been and Wildlife will be conducted within the proposed area updated with objectives, descriptions Habitat Study and for all proposed project features - of existing data, specific tasks, target including wildlife habitat to be inundated species, study area definition, by the proposed diversion structure. methods protocols, timing, and Included through discussion should be how frequency, and deliverables, and and when the surveys will be conducted method of wildlife habitat and completed. In addition, the following assessment. two objectives should be included within this section: (1) the development of a map that depicts the various wildlife habitats within the proposed project area including special wildlife habitats such as cliffs, talus slopes, wetlands, seeps, and springs, and (2) the development of a list for state endangered, threatened, and sensitive species potentially occurring within the proposed project area. The steps and methods associated in achieving these two objectives should be provided and discussed in this section. 3/27/2014 John Zauner ODFW Botanical The Study Results section of the plan The wildlife RSP is now separate from Resources should reflect the completion and the botanical RSP, and has been and Wildlife distribution of the project area wildlife updated with objectives, descriptions 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation Habitat Study habitat map, state endangered, threatened of existing data, specific tasks, target and sensitive species list, and associated species, study area definition, completion and comment period time methods protocols, timing, and frames. frequency, and deliverables, and method of wildlife habitat assessment. 3/27/2014 John Zauner ODFW Botanical Under 2. 7.8 Schedules §5.11 (b )(2) its All surveys will be completed prior to Resources states that "additional surveys may be project construction. and Wildlife necessary after review of the results of the Habitat Study botanical and wildlife habitat study including surveys during project construction". ODFW agrees that additional surveys may be necessary after the review of the wildlife habitat study component; however, all additional survey needs to be completed prior to project construction. 3/28/2014 Meg Mitchell USFS Water The Applicant states in the Proposed Study RSP Study 2.1 has been updated Quality Study plan on page 6.. accordingly. 2.1.4 Recommendation: The paragraph should be modified to reflect the lack of existing information on existing water quality. 3/28/2014 Meg Mitchell USFS Water The Forest Service recommends quarterly RSP Study 2.1 has been updated to Quality Study grab samples for major ions and mercury as include sampling for major ions, 2.1.5 well as spring, summer and fall sampling for mercury, nutrients, and chlorophyll. nutrients and chlorophyll. The collection of this water quality data will provide valuable baseline water quality information 3/28/2014 Meg Mitchell USFS Water The dates cited in the Proposed Study Plan RSP Study 2.1 has been updated Quality Study not correct (page 8). accordingly. 2.1.8 Forest Service recommends deleting the dates and stating the Water Quality Study 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation be completed during the first study season of the ILP. 3/28/2014 Meg Mitchell USFS Cultural The Applicant wrote, “The objective of this RSP Study 2.4 has been updated Resources study is to identify the location of accordingly. Study 2.4.1 archaeological sites or traditional cultural properties that would be negatively impacted by the hydroelectric project.” Forest Service recommendation: Please add the wording …”and protect” after the wording “to identify.” 3/28/2014 Meg Mitchell USFS Cultural The Applicant wrote, “A desktop review of RSP Study 2.4 has been updated Resources existing sites and/or properties in the accordingly. Study 2.4.6 project area followed by an on-site comprehensive cultural resource assessment survey will be completed by an Oregon SHPO approved consulting archaeologist in cooperation with the USFS.” Forest Service recommendation: After this paragraph, please add “a research design and methodology shall be developed in accordance with the Willamette National Forest updated Cultural Resource Inventory Plan and SHPO’s Inventory guidelines. The research design and methodology will detail the survey methods that the Applicant will use to conduct the cultural resources inventory of the proposed Project APE, site recording procedures, the NRHP evaluation strategy and methods for analyzing collected information. A 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation discussion of the theoretical orientation of pre-contact and historic resources, research domains, and associated research questions shall also be included.” This information will be required prior to obtaining an Archaeological Resource Protection Act (ARPA) permit from the Forest Service. The ARPA permit is required prior to conducting cultural resource surveys or excavation on FS managed lands 3/28/2014 Meg Mitchell USFS Aesthetic In the Proposed Study Plan (on page 24)… RSP Study 2.5 has been updated Resources The list of sensitive view areas should be accordingly. Study 2.5.6 modified to include “recreation sites, cabins and trails, including the Pacific Crest National Scenic Trail”. As part of the study, describe, evaluate and map existing landscape character, scenic integrity, and landscape visibility using Scenery Management Systems. An evaluation of change to the existing character should include an examination of proposed Project features and operations with respect to the ability of the landscape to accept change and effect on Scenic Integrity and Visual Quality Objectives. 3/28/2014 Meg Mitchell USFS Bypass Reach In the Proposed Study Plan on page 32, last Electrofishing methods are provided Instream paragraph… in Section 2.6.6. Flow and Forest Service recommendation: describe Aquatic methodology that will be used to conduct Based upon the 3 March 2014 Habitat Study the snorkeling and electrofishing. teleconference with regulatory 2.6.6 agencies, electrofishing was 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation determined to be the most appropriate method for the study area glacial streams because of low water clarity (ability to visually observe fish underwater) and low water temperatures (human safety concerns regarding snorkeling). 3/28/2014 Meg Mitchell USFS Botanical Recommendation: The Botanical Resources The wildlife RSP has been made a Resources and Wildlife Habitat Studies section should separate study (Section 2.10) apart and Wildlife be divided into a Botany Resource Section from the botanical study. The study Habitat Study and a Wildlife Resource Section because will have two components: 1) general 2.7 these are two different resources with wildlife habitat assessment (using unique complexities. vegetation and special habitats data collected as part of the botanical resources study); and 2) T/E and sensitive species survey and habitat assessment. 3/28/2014 Meg Mitchell USFS Botanical The “Goals and Objective” section (Section Section 2.7.1 of the botanical study Resources 2.7.1) of the Botanical Resource plan was updated to include the and Wildlife Study should be clarified to include mapping of USFS special habitats and Habitat Study additional goals related to the Willamette fungal surveys, as needed. 2.7.1 National Forest Land and Resource Management Plan. Recommendation: Section 2.7.1 should be modified to include special habitats and the possible need for fungi surveys. 3/28/2014 Meg Mitchell USFS Botanical The Proposed Study Plan states in Section The botanical resources study area Resources 2.7.2, page 36… (Section 2.7.2) and wildlife resources and Wildlife Recommendation: The Study Plan should study areas (Section 2.10.2) were Habitat Study be amended to describe a study area that edited to include all areas that will 2.7.2 includes all features affected downstream, potentially be impacted (direct or 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation downhill and uphill. indirect impacts) by proposed Project infrastructure and proposed and existing roads. 3/28/2014 Meg Mitchell USFS Botanical Special habitats and sensitive plant species The recommended text was added to Resources were not included in the list of information section 2.7.3 of the botanical study and Wildlife needs and are essential for the Forest plan, with the exception that Habitat Study Service to make an informed decision on “riparian vegetation and wetlands” 2.7.3 issuing a special use permit for this Project. was not included. These habitats are Resource goals relating to them should be specifically addressed in the wetlands included as recommended below. section. Recommendation: The following resource management goals (p. 36) (underlined below) should be added to Section 2.7.3. This study will provide information needed to support the riparian vegetation and wetlands, sensitive plant species; special habitats and noxious weeds study goals. This study will provide information relevant to US Fish and Wildlife Service (USFWS), USFS, and ODFW management goals of protecting federal and state listed species, sensitive plant species, survey and manage species, as well as priority habitats and species and special habitat areas. In addition, the USFS will use this information to issue a special use permit for the Project. 3/28/2014 Meg Mitchell USFS Botanical The Existing Information section is missing Section 2.7.4 was updated to include Resources information about the Forest Service detailed information on the existing and Wildlife Natural botanical information for the Project Habitat Study Resource Information System and area and the Willamette National 2.7.4 additional justification regarding how the Forest. 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation survey information will be used by the agencies. The recommended text was added to Recommendation: The Existing Information Section 2.7.4 Section (2.7.4) should be modified to include the Forest Service Natural Resource Information System (NRIS) botany database which contains location information on Forest Service sensitive species and survey and manage species found on the Willamette National Forest, and the Interagency Special Status Sensitive Species Program (ISSSP) website http://www.fs.fed.us/r6/sfpnw/issssp/. The Forest Service agrees with the Applicant’s conclusion that “[a]dditional habitat, vegetation, and wildlife surveys are needed to conduct the required analysis of potential project effects on habitat and terrestrial resources in the project area.” Pg. 36. This paragraph should be modified to also include the following sentence: This information is also being collected to a) complete a biological evaluation on effects to Forest Service sensitive species (see Forest Service 2670 Handbook), and b) meet required protocols for Forest Service survey and manage species (see Forest Service 2001 Survey & Manage Record of Decision and Standards and Guidelines available at http://www.blm.gov/or/plans/surveyandm 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation anage/files/rd-rod_s_and_g-2001-01.pdf). 3/28/2014 Meg Mitchell USFS Botanical The Nexus to Project Section 2.7.5 is The recommended policies were Resources incomplete. added to Section 2.7.5. The and Wildlife This Section does not reference some key recommended guides were added to Habitat Study Forest Service policies that are used to the Existing Information Section 2.7.5 characterize existing habitat and botanical 2.7.4, where it seemed more resources necessary for a complete appropriate. resource analysis. Recommendation: The following policies, standards and guidelines and guides should be added to the Nexus to Project Section: Northwest Forest Plan (USDA/USDI, 1994), and the Willamette National Forest Land and Resource Management Plan (USDA Forest Service, 1990), Field Guide to the Forested Plant Associations of the Westside Central Cascades of Northwest Oregon (USDA Forest Service, 2002) (available online at http://ecoshare.info/2009/12/16/plant- associations-of-the-west-central-cascades/) and Willamette National Forest Special Habitat management Guide (USDA Forest Service 2010), available from the Forest Service. 3/28/2014 Meg Mitchell USFS Botanical “Complete surveys” is a more accurate Section 2.7.6, Study Methods, has Resources term to use than “ground-truthing.” been completely updated to include and Wildlife On page 37 the Applicant states, details on survey protocol, which Habitat Study Field activities will focus on ground-truthing includes “complete surveys” within 2.7.6 the draft map to verify and correct cover the defined study area. types and cover type boundaries for the 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation terrestrial habitat study. Groundtruthing will be conducted by a qualified botanist, biologist, or forest ecologist, according to currently accepted methods. The Forest Service would like the Applicant to change “ground-truthing the draft map” to “complete surveys.” It is unclear how the draft map would be created or where it originated. Completing surveys would be an efficient method of determining the botanical resources present in the project area. Recommendation: Please change “ground- truthing the draft map” in the above paragraph to “completing surveys.” 3/28/2014 Meg Mitchell USFS Botanical Botanical surveys should be completed by Edited text in Section 2.7.6 that Resources a qualified botanist. botanical surveys will be completed and Wildlife The Applicant states the “Ground-truthing by a qualified botanist using the Habitat Study will be conducted by a qualified botanist, methods requested in the USFS study 2.7.6 biologist, or forest ecologist, according to request. currently accepted methods.” The surveys for botanical resources are: Threatened, Endangered and Sensitive (TES) plants and their habitats, special habitats and noxious weeds. The botanical survey will be done by a journey level botanist. Please refer to the Willamette National Forest study request for survey methodology. Recommendation: Please correct to state the surveys will be completed by a qualified 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation botanist. 3/28/2014 Meg Mitchell USFS Botanical The Forest Service does not support use of Edited Section 2.7.6 to detail the Resources plots for the botanical surveys. methods requested in the USFS study and Wildlife Recommendation: The Botanical Study request, including the use of the Habitat Study Plan should be amended to use the “intuitive control methods” instead 2.7.6 “intuitive control method” instead of plots. of plots. 3/28/2014 Meg Mitchell USFS Botanical Daubenmire’s cover classes do not apply Edited Section 2.7.6 to detail the Resources to botanical resources. methods requested in the USFS study and Wildlife Daubenmire’s cover classes as proposed in request to include the use of the Habitat Study Section 2.7.6, page 37, do not apply to plant association guide for vegetation 2.7.6 botanical resources as they cover a wide type mapping. region whereas the plant association guide is distinct for our area. Recommendation: For the appropriate study method, please refer to the Forest Service’s study request 3/28/2014 Meg Mitchell USFS Botanical It is not necessary to submit findings to Edited Section 2.7.6 to state that all Resources the Oregon Natural Heritage Program. findings will be submitted to the and Wildlife The Study Plan on page 38 states, USFS. Habitat Study In addition, findings will be documented 2.7.6 and submitted to the Oregon Natural Heritage Program. Any plants encountered during sensitive plant surveys that have not been recorded during vegetation characterization studies will be added to the list of species for the project area. It is not necessary to submit to Oregon Natural Heritage Program (ONHP) because all data is input to a national database and ONHP has access to that data. The Forest Service should be the main depository of 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation data collected for botanical resources. Recommendation: All findings should be submitted to the Forest Service. 3/28/2014 Meg Mitchell USFS Botanical Recommendation: In the Study Report, the Edited Section 2.7.6 to detail the Resources Applicant does not need to report total methods requested in the USFS study and Wildlife cover and average cover. However, the request, including a deliverable of a Habitat Study map provided in the Study Report should map of study results (locations), and 2.7.7 include all mapped sensitive species, the use of the specified data forms. noxious weeds and special habitats. Finally, the Applicant should complete the Survey Field Forms and give them to the Forest Service. 3/28/2014 Meg Mitchell USFS Botanical The Botanical Resource and Wildlife The studies were divided into Resources Habitat Studies should be divided into two separate “botanical resource” and and Wildlife different sections. “wildlife resource” study plans. Habitat Study 2.7 3/28/2014 Meg Mitchell USFS Botanical The “Goals and Objective” section of the Section 2.10.1 of the wildlife study Resources Wildlife Habitat Study should be clarified plan was updated to include the and Wildlife to include additional goals related to the mapping of wildlife habitats, and TES Habitat Study Willamette National Forest Land and species surveys. 2.7.1 Resource Management Plan. See Section 2.7.1. 3/28/2014 Meg Mitchell USFS Botanical The specific objectives of the study plan Section 2.10.1 of the wildlife study Resources should include additional goals plan was updated to include the and Wildlife described below related to the ESA and mapping of wildlife habitats, and TES Habitat Study United States Fish and Wildlife Service species surveys. 2.7.1 (USFWS) consultation. See Section 2.7.1, p. 35. 3/28/2014 Meg Mitchell USFS Botanical The study area for suitable northern Section 2.10.2 of the wildlife study Resources spotted owl habitat should be expanded plan has been updated accordingly. 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation and Wildlife to 1.2 miles around habitat that would be Habitat Study affected. See Section 2.7.2. 2.7.2 3/28/2014 Meg Mitchell USFS Botanical The following resource management goals This text was added to Sections 2.7.3 Resources (p. 36) (underlined below) should be (botanical) and 2.10.3 (wildlife). and Wildlife added to Section 2.7.3. Habitat Study This study will provide information needed 2.7.3 to support the riparian vegetation and wetlands, sensitive plant species, and noxious weeds study goals. This study will provide information relevant to US Fish and Wildlife Service (USFWS), USFS, and ODFW management goals of protecting federal and state-listed species, sensitive wildlife and plant species, survey and manage species, as well as priority habitats and species and special habitat areas. In addition, the USFS will use this information to issue a special use permit for the Project 3/28/2014 Meg Mitchell USFS Botanical The Existing Information Section (see This information was added to Resources 2.7.4) should be modified to include the sections 2.7.4 (botanical) and 2.10.4 and Wildlife additional sources described below. (wildlife). Habitat Study Other information sources for wildlife are 2.7.4 the Forest Service Natural Resource Information System (NRIS) wildlife database which contains location information on Forest Service sensitive species and survey and manage species found on the Willamette National Forest and the USFS GIS database which has 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation records of peregrine falcon nest sites, known northern spotted owl territories, and forest-wide mapping of spotted owl habitat. Also the USFWS has a range-wide map of spotted owl habitat that can be downloaded from their website. A map of critical owl habitat is also available on the USFWS website. Additional information on Forest Service sensitive species found on the Willamette National Forest is available on the Interagency Special Status Sensitive Species Program (ISSSP) website http://www.fs.fed.us/r6/sfpnw/issssp/. Additional information of Forest Service Survey and Manage species, including survey protocol and management recommendations is available at the BLM Survey and Manage website http://www.blm.gov/or/plans/surveyandm anage/protocols/ The Forest Service agrees with the Applicant’s conclusion that “[a]dditional habitat, vegetation, and wildlife surveys are needed to conduct the required analysis of potential project effects on habitat and terrestrial resources in the project area.” Pg. 36. This paragraph should be modified to also add the following sentence: This information is also being collected to a) complete the biological assessment and ESA consultation on northern spotted 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation owl, b) complete a biological evaluation on effects to Forest Service sensitive species (see Forest Service 2670 Handbook), and c) meet required protocols for Forest Service survey and manage species (see Forest Service 2001 Survey & Manage Record of Decision and Standards and Guidelines). 3/28/2014 Meg Mitchell USFS Botanical The study methods in Section 2.7.6 are A detailed northern spotted owl Resources incomplete and do not address many study was added to the wildlife and Wildlife wildlife needs. resources study (section 2.10). Habitat Study Northern Spotted Owl Study: If the 2.7.6 Applicant is implementing seasonal restrictions during the critical breeding season (March 1-July 15) for construction activities and during the entire breeding period (March 1-September 30) if Type 1 helicopters or blasting occurs, then potential take of spotted owls from disruption will not be an issue. The remaining concern will be that road construction in suitable habitat would harm nesting spotted owls by falling a nest tree or impacting habitat close (within 300 meters) to a nest which could result in ESA defined take of spotted owls. The Project will impact suitable nesting habitat when constructing a new road to the diversion structure and perhaps elsewhere. Due to recent litigation, a solid basis for estimating harm to owls which USFWS 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation uses to help determine take under the Endangered Species Act (ESA), relies on knowledge of where owls are nesting when projects directly affect nesting habitat. Thus, the Applicant should conduct protocol owl nest surveys where suitable habitat is going to be directly impacted by road construction or other habitat removal impacts. As this is a two year six visit protocol, the Applicant should consider starting these surveys this year in order to complete the environmental analysis and consultation in a timely manner. Northern spotted owl habitat must also be mapped by the Applicant to identify suitable nesting/roosting, suitable foraging, dispersal only, and non-habitat. The Applicant can use the available Forest Service or USFWS mapping and refine that based on the field habitat data they intend to collect. 3/28/2014 Meg Mitchell USFS Botanical The study methods in Section 2.7.6 are A specific harlequin duck study will Resources incomplete and do not address many not be conducted. and Wildlife wildlife needs. Habitat Study Harlequin Duck Study: Harlequin ducks nest 2.7.6 adjacent to mountain streams like Whitewater and Russell Creek. The Forest Service concern is that, if harlequin ducks are nesting or have newly-fledged young when construction activities occur at the diversion structure, this sensitive species 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation may be harmed by the activities. If the Applicant can implement seasonal restrictions on these activities during the nesting period (mid-April to June 20), then the Forest Service can concur that specific harlequin duck surveys are not needed. 3/28/2014 Meg Mitchell USFS Botanical The study methods in Section 2.7.6 are A detailed red tree vole study was Resources incomplete and do not address many added to the wildlife resources study and Wildlife wildlife needs. (Section 2.10). Habitat Study Red Tree Vole (RTV) Study: It appears from 2.7.6 the Applicant’s response (p. 50) that it does not understand the Forest Service requirements associated with the proposed activities. New road construction to the diversion site, and perhaps other construction activities, may impact RTV habitat and may require RTV vole surveys prior to the Forest Service accepting an environmental analysis for proposed activities on the land it manages. The applicant should replace the Survey Protocol for the Red Tree Vole, version 3.0, 2008 filed with the Forest Service study requests on November 14, 2013 with the current Survey Protocol for the Red Tree Vole, version 3.0, 2012. The Project is in the northern mesic zone. As such, RTV habitat would include conifer forest areas up to 3500’ elevation where the quadratic mean tree diameter of the stand at breast height is 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation greater or equal to 16” or the average mean diameter of the stand is greater or equal to 15”, and where the stand is either multi-layered or has at least 60 percent canopy and two or more super dominant conifer trees/acre. The Forest Service will accept the Applicant mapping this RTV habitat in Year 1 of the study as long as the Applicant completes RTV surveys in Year 2 where such habitat will be affected by road building or other clearing and tree falling activities. In addition, Year 2 surveys must be completed prior to preparation of the EA. 3/28/2014 Meg Mitchell USFS Botanical The study methods in Section 2.7.6 are A specific bald eagle study will not be Resources incomplete and do not address many conducted. and Wildlife wildlife needs. Habitat Study Bald Eagle Study: On further review, it is 2.7.6 extremely unlikely that any bald eagle nesting occurs in the areas of proposed activities. Consequently, the Forest Service is not suggesting any specific surveys for nesting eagles. 3/28/2014 Meg Mitchell USFS Botanical The study methods in Section 2.7.6 are A detailed terrestrial mollusks study Resources incomplete and do not address many was added to the wildlife resources and Wildlife wildlife needs. study (section 2.10). Habitat Study Terrestrial Mollusks: Similar to RTV, the 2.7.6 Forest Service has a requirement to conduct protocol surveys and manage for two mollusk species. The first is the Crater Lake tightcoil snail (Pristiloma 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation arcticum crateris) that is found within 10 meters of open water in wetlands, springs, seeps, and riparian areas in “perennially wet situations in mature conifer forest, among rushes, mosses and other surface vegetation or under rocks and woody debris.” Where road construction, tree falling, vegetation clearing or other construction occurs in this habitat, including streams crossing, protocol mollusk surveys will be needed (Version 3.0, 2003). The second survey and manage mollusk is Oregon Megomphix (Megomphix hemphilli) which inhabits mature to late seral conifer/hardwood forests often in association with big leaf maple up to 3000’ elevation. Currently surveys are required for this species where habitat-disturbing activities are proposed. Thus the Forest Service can agree to mollusk species surveys being completed in Year 2 prior to EA preparation as long as the Applicant maps the mollusk habitat that will be impacted in Year 1. 3/28/2014 Meg Mitchell USFS Botanical The study methods in Section 2.7.6 are A detailed terrestrial mollusks study Resources incomplete and do not address many was added to the wildlife resources and Wildlife wildlife needs. study (section 2.10). Habitat Study We also recommend mollusk surveys 2.7.6 where habitat will be affected for Cascade axetail slug (Carinacauda stormi), a newly 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation described monotypic species, that is a Forest Service sensitive species. This species is found in conifer needle litter in Douglas fir/western hemlock forests often in association with vine maple in forests from about 25 years of age to old- growth. This endemic species has a restricted range in the northern part of the western Oregon Cascades but seems to be relatively abundant in suitable habitat within that range with about 394 detections recorded on the Willamette National Forest to date in our Wildlife NRIS database. Habitat evaluation needs to determine if suitable Carinacauda habitat is present. The Forest Service recommends mollusk surveys for this species in suitable habitat. If habitat is present, the Applicant will have to address in a Biological Evaluation why loss of habitat and potential occupied sites will not affect the viability of this species. Survey information would help inform this viability analysis. Biologists on the Willamette National Forest have been involved in the identification of this species and can provide reports on the species. The Applicant should also propose mitigation measures for this species such as depositing downed trees along newly constructed roads in suitable habitat. 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation 3/28/2014 Meg Mitchell USFS Botanical The study methods in Section 2.7.6 are A detailed terrestrial amphibian Resources incomplete and do not address many study was added to the wildlife and Wildlife wildlife needs. resources study (section 2.10). Habitat Study Amphibian Study: The Applicant should 2.7.6 survey for terrestrial amphibians where forest habitat is disturbed. These surveys can be done in conjunction with mollusk surveys with relatively little additional costs and help inform the evaluation of effects of the Project on terrestrial salamanders and other amphibians that are on the Oregon State list of sensitive vulnerable species. The Applicant should also survey for amphibians in wetlands adjacent to the main stream channel and where construction activities cross perennial streams. The Forest Service believes these surveys should be done because amphibians could be affected if flooding that supports wetlands adjacent to the main stream channel is reduced by the Project. The amphibian surveys where streams are crossed could be done in conjunction with Pristiloma surveys discussed above. The Forest Service supports the Applicant’s desire to make adjustments to Project designs and implement protection, mitigation and enhancement measures for 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation both terrestrial mollusks and amphibians (p. 51). The surveys will greatly inform the development of such designs and mitigation measures. 3/28/2014 Meg Mitchell USFS Botanical The study methods in Section 2.7.6 are A detailed osprey study was added to Resources incomplete and do not address many the wildlife resources study (section and Wildlife wildlife needs. 2.10). Habitat Study Osprey Study: The Willamette National 2.7.6 Forest Land and Resource Management Plan requires protection of active nest sites of raptors. To meet this requirement, the Applicant should conduct a walk-thru search for osprey nests along Russell Creek within 0.25 miles of the proposed diversion structure construction area. Any other raptor nests found incidental to other field work should be identified as well. Effects of Project activities on osprey and other raptors must be addressed in the environmental analysis. 3/28/2014 Meg Mitchell USFS Botanical The Study Results Report Section should These deliverables were added to the Resources be modified to include the elements wildlife resources study. and Wildlife underlined below. See Section 2.7.7. Habitat Study a) a map of spotted owl habitat and results 2.7.7 of spotted owl surveys; b) a map of red tree vole habitat and results of red tree vole surveys; c) a map of Pristiloma, Megomphix, and Carinacauda habitat and results of mollusk surveys; d) identification of any downstream 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation riparian areas potentially impacted by the water diversion; e) results of amphibian surveys; and f) locations of any raptor nests found and areas where specific nest searches were conducted. 3/28/2014 Meg Mitchell USFS Botanical The study schedules outline in Section The schedule was updated in the Resources 2.7.8 (p. 39) does not take into account wildlife resources study. and Wildlife the need to survey for survey and manage Habitat Study species or for northern spotted owls. 2.7.8 3/28/2014 Meg Mitchell USFS Botanical The costs shown in Section 2.7.0 (p. 39-40) The Costs have been updated Resources do not account for the costs of spotted accordingly in section 2.10.9. and Wildlife owl surveys, red tree vole surveys, mollusk Habitat Study surveys, and amphibian surveys and 2.7.9 should be corrected. 3/28/2014 Meg Mitchell USFS Recreation The goals and the objectives of Whitewater The goals and objectives of the Resources Green Energy’s, LLC (WGE) proposed study recreation resources have been Survey 2.9.1 plan does not address what the study is updated in the RSP and include: intended to accomplish, which is to gather 1. Provide an accounting of existing data recreation inventory within the and information to be able to analyze the immediate project area and greater short and long term effects of Project project vicinity. construction, operation and maintenance 2. Describe existing recreation use in on recreation within the vicinity of the the immediate project area. Project, including recreation use, 3. An analysis of potential effects opportunities, facilities, access, and visitor project construction operation could experience. Please refer to Page 1 of the have on local recreation. USDA Forest Service Willamette National Forest Study Requests for Recreation Resources, Study Goals and 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation Objectives: 18 CFR 5.9(b)(1). 3/28/2014 Meg Mitchell USFS Recreation As requested, the objectives of the The goals and objectives of the Resources Recreation Resources Study are to: recreation resources study have been Survey 2.9.1 1. Provide a detailed description of updated in the RSP and include: recreation use, activities, facilities, access 1. Provide an accounting of existing and opportunities that are present in recreation inventory within the general vicinity of the proposed. immediate project area and greater 2. Describe the effects of the Project on project vicinity. recreation use, opportunities, facilities, and 2. Describe existing recreation use in access. the immediate project area. 3. Describe how recreation settings and 3. An analysis of potential effects experiences would be affected by the project construction operation could Project. have on local recreation. 3/28/2014 Meg Mitchell USFS Recreation As this Project is proposed to be located on The applicant has expanded the Resources National Forest System (NFS) lands, this scope of the recreation resources Survey 2.9.1 information is necessary to ensure that study in the RSP. Project impacts to these NFS recreational resources are appropriately evaluated and mitigated or opportunities created by the project enhanced consistent with applicable laws, regulations, directives and policy. 3/28/2014 Meg Mitchell USFS Recreation Six miles of distribution (transmission) lines The applicant has expanded the Resources upgrades after the point of interconnection scope of the recreation resources Survey 2.9.1 with the grid will not be discussed as part study in the RSP. of FERC’s NEPA document since they do not have jurisdiction over these lines. FERC’s NEPA document analysis would be limited to the effects (direct, indirect, and cumulative) of the primary transmission line. WGE will need to work with the Forest 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation Service on approval, including needed studies and NEPA analysis for the distribution line upgrades between the interconnection and Idanha. It would be beneficial for WGE to conduct this study concurrently with FERC studies for efficiency and to meet timelines. The Forest Service would require cost recovery to conduct the NEPA analysis and ultimately permitting, if approved. The Forest Service needs more specific information on the project of where ground disturbance would occur and if any above ground structures are being proposed. The goals and objectives and studies needs as described below, will still apply to the distribution line upgrade and the effects (direct, indirect, and cumulative) to recreation will need to be analyzed. 3/28/2014 Meg Mitchell USFS Recreation The FERC Project study area should include The applicant has expanded the Resources more than Forest Roads 040 and 440. scope of the recreation resources Survey 2.9.1 People use the forest surrounding Project study in the RSP. area for recreational activities and the effects of the construction, operation and maintenance of the Project would go beyond just these two road systems. The Project area is defined as the area within the vicinity of the intake at the diversion structure in Russell Creek to the outflow of the tailrace in Whitewater Creek and 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation associated roads, penstock, powerhouse, and transmission line and facilities along Highway 22. This Project study area should include the entire sub-watershed that the project is in (Whitewater drainage) as visitors move through the entire area on formal road networks (e.g. Roads 2242, 040, 440, 030) and trails off these roads (Trails #3441, #3429 and #3442) to the Pacific Crest Trail (#2000). The use is also dispersed in nature throughout the general forest off of roads and trails for hunting, fishing, gathering, hiking, winter sports, etc. 3/28/2014 Meg Mitchell USFS Recreation The FERC study area for recreation should The applicant has expanded the Resources include the area near the Project and the scope of the recreation resources Survey 2.9.1 area bounded by Highway 22, Forest Roads study in the RSP. 2242 and 040, Trails #2000, #3429 and #3442. In addition, the Forest Service Project study area will also include an area of .25 mile on each side of Highway 22 for the length of the transmission line being considered for upgrade. Please refer to Page 5 paragraph 2, of the USDA Forest Service Willamette National Forest Study Requests for Recreation Resources, Proposed Study Methodology: 18 CFR 5.9(b)(6). 3/28/2014 Meg Mitchell USFS Recreation WGE’s proposed study plan captured all the The recreation resources RSP has 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation Resources management goals with the exception of been updated accordingly. Survey 2.9.3 those in Willamette National Forest Management Allocations MA-1, MA-1a-d, MA-6c which was omitted and needs to be added. In addition, MA-11c and 11f was inadvertently omitted from the Forest Service Study Plan Request and needs to be added as well.

3/28/2014 Meg Mitchell USFS Recreation Omitted in WGE’s proposed study plan, The applicant acknowledges that Resources were the laws and regulations, USDA Forest these laws and regulations were Survey 2.9.3 Service direction, and other pertinent plans present in the Study Plan Request were identified. Please refer to Pages 2-3 of and has reviewed them along with the USDA Forest Service Willamette the other information provided by National Forest Study Requests for USFS for preparation of the RSP. Recreation Resources, Resource Management Goals and Public Interest Considerations: 18 CFR 5.9(b)(2). 3/28/2014 Meg Mitchell USFS Recreation WGE’s proposed study plan only captured a The applicant has expanded the Resources portion of the existing information that was scope of the recreation resources Survey 2.9.4 provided by the Forest Service Study study in the RSP. Request for Recreation Resources. Project impacts go beyond just temporary displacement of recreators on FS Roads 040 and 440 that was mentioned in 2.9.3 of WGE’s proposed study plan. Hiking, hunting, fishing, scenic driving and camping are some of the primary dispersed recreational activities 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation that occur in the Project vicinity, however, other common activities include sightseeing, nature study, mushroom and huckleberry picking, sledding (Whitewater rock pit), cross country skiing (on roads into Wilderness), off highway vehicle use, kayaking, etc. Non- motorized trails provide hiking and equestrian use opportunities within the Mt. Jefferson Wilderness and along the Pacific Crest National Recreation Trail, and access to climbing Mt. Jefferson. Overnight lodging occurs at nearby cabins, one along Whitewater Creek, and Whispering Falls Campground on Highway 22. There are numerous dispersed (undeveloped) campsites (indicated by fire rings, turnouts, compacted ground) within and adjacent the Project area that have not been inventoried (mapped and evaluated) that could be affected by the Project. Please refer to Pages 3-5 of the USDA Forest Service Willamette National Forest Study Requests for Recreation Resources, Existing Information and Need for Additional 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation Information: 18 CFR 5.9(b)(4). 3/28/2014 Meg Mitchell USFS Recreation As mentioned on the Forest Service study The applicant has expanded the Resources request on page 4, there is a need to scope of the recreation resources Survey 2.9.4 describe study in the RSP to include a review the project and existing condition to be and analysis of existing recreation able to understand the short and long term sites and facilities in the greater effects project vicinity. of the Project on recreation use (levels), activities, settings, opportunities, access, facilities and subsequent effects to visitor experience. 3/28/2014 Meg Mitchell USFS Recreation Potential Project effects include: The applicant generally agrees that Resources • noise disturbance (decibel levels at these are potential project effects Survey 2.9.4 varying distances) that could affect and has updated the RSP accordingly. recreation activities, opportunities or use; • physical alteration of recreation settings and sites; • changes in a recreation opportunities (and Recreation Opportunity Spectrum (ROS)); • diminished public access to the project area including temporary or permanent area and road closures, and temporary trail closures; • increased access and subsequent use due to the development of Project facilities, and how use would be controlled and managed. 3/28/2014 Meg Mitchell USFS Recreation In addition, the Forest Service Project Study The applicant has expanded the Resources Area will also include an area along scope of the recreation resources Survey 2.9.4 Highway 22 for the length of the study in the RSP. 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation transmission (distribution) line being considered for upgrade. 3/28/2014 Meg Mitchell USFS Recreation Project impacts go beyond just the The applicant is an agreement that Resources “temporary displacement of recreators on the project may have the potential to Survey 2.9.5 FS Roads impact recreators beyond FS 040 and 040 and 440” that was mentioned in 2.9.3 440 and has expanded the scope of of WGE’s proposed study plan. the recreation resources study in the Construction RSP. of the Project could (temporarily or long term) close areas, roads and access to trails, cause noise and dust in the vicinity, alter recreation settings (ROS) and opportunities, affect visitor experiences, and displace visitors. Maintaining and operating the project could change recreation settings, opportunities and access, and subsequently potentially effect visitor experiences in the long term. Please refer to Pages 5 of the of the USDA Forest Service Willamette National Forest Study Requests for Recreation Resources, Nexus to Project Operations and Effects: 18 CFR 5.9(b)(5) 3/28/2014 Meg Mitchell USFS Recreation The information gathered will help identify The applicant is an agreement that Resources appropriate protection, mitigation or the project may have the potential to Survey 2.9.5 enhancement measures to be identified to impact recreators beyond FS 040 and eliminate and minimize effects. 440 and has expanded the scope of Constructing the recreation resources study in the 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation the project in a manner that minimizes RSP. impacts to recreation opportunities through timing of activities or designing facilities to reduce affects to settings can offset impacts to visitors and their experiences. 3/28/2014 Meg Mitchell USFS Recreation Please refer to Pages 6-8 of the of the USDA The applicant has reviewed pages 6-8 Resources Forest Service Willamette National Forest of the of the USDA Forest Service Survey 2.9.6 Study Requests for Recreation Resources, Willamette National Forest Proposed Study Methodology: 18 CFR Study Requests for Recreation 5.9(b)(6). The Forest Service requested that Resources, Proposed Study the existing recreation inventory Methodology: 18 CFR information 5.9(b)(6). Completion of an existing from a variety of sources be compiled, recreation inventory has been added updated and synthesized in a written to the RSP for the recreation assessment resources study. including maps (as described on pages 6-8). This information was entirely omitted in WGE’s proposed study plan and needs to be added (see list of recreation inventory on Page 6). The existing information for this resource topic should be compiled and displayed on maps to include: • all Project facilities and work areas; • Recreation Opportunity Spectrum (ROS) classifications to describe setting and experiences in the project vicinity • open, publically-accessible roads by vehicle type as depicted on the Willamette National Forest Motor Vehicle Use Map 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation (MVUM); • designated scenic byways; • developed recreation sites (e.g., nearby campgrounds, trailheads, day use areas, cabins, etc.); • National Scenic trails and all other trails, and trailheads; • Lakes, creeks and rivers (with eligible wild and scenic rivers and their classification labeled); • Inventoried dispersed campsites delineated by usage (not existing - to be collected by Applicant) • Wilderness campsites inventoried by the Forest Service • wild and scenic rivers, wilderness areas, inventoried roadless areas, and potential wilderness areas; • communities and nearby cabins. 3/28/2014 Meg Mitchell USFS Recreation The Forest Service concurs with the use of The applicant has incorporated 2242 Resources pressure sensitive traffic counters of Road into the area delineated as the Survey 2.9.6 040, however, there shall also a counter “immediate project area” in the RSP installed along Road 2242 to get a more and has included the addition of a accurate traffic counter on Road 2242. The measure of visitation in the project vicinity applicant has also included a Use or study area described above. The counter Analysis as part of the RSP and should be used when clear of snow which generally described the period of varies year to year (typically April through time and day(s) of the week the inventory efforts will be completed. end of November). The Forest Service study 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation request identified how recreation use can be compiled using existing sources (e.g. permit data, agency and stakeholder knowledge, maps, etc.) including site visits. WGE proposes to do a field investigation in August and October documenting recreation sites on Roads 040 and 440 including GPS location, dimensions, unique characteristics and photo documentation. The Forest Service requested that use levels based on observation be estimated for each dispersed sites as defined on page 6 and should be added. The Forest Service also requested that dispersed sites (and user-created trails, e.g. to the impoundment) along Road 2242 shall also get inventoried because it lies within the Project vicinity or study area described above (and is within sight and/or sound of the Project). 3/28/2014 Meg Mitchell USFS Recreation WGE’s states the timing of the investigative Resources visits is intended to coincide with warm Survey 2.9.6 weather and hunting related use. To get a more accurate depiction of recreational use through observation or encounters, it is advised to have more sample visits on weekends. 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation The proposed study plan did not indicate the sampling methodology, how often, when (e.g. days of the week) and omitted winter/spring use. There is also winter and spring use which is more intermittent and shall be sampled as well. Interviews of known users in the area, such as the Chemeketans hiking club who have a cabin in the project area along Whitewater Creek, could be conducted to evaluate use. Club members and general recreationists ski into the Mt. Jefferson Wilderness from Forest Roads 2242 and 040. Winter use, sledding, also occurs at Whitewater rockpit on Road 040-041. There is a popular recreation/dispersed site along Road 030 (along Whitewater Creek) which the Whitewater Creek Conservation Association has informally adopted and has interest in the Whitewater Creek watershed (i.e. Project area) and could also be interviewed. Forest Service Comments to the Preliminary Application Document, Page 18, Section 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation 5.6(d)(5), Summary of Contacts has a list of stakeholders in the area that can be interviewed regarding evaluation of recreation use, e.g. Pacific Crest Trail Association (trail use, scenic concerns), Rocky Mountain Elk foundation, Oregon Hunters Association (hunting use), etc. 3/28/2014 Meg Mitchell USFS Recreation The study omitted and should identify the Applicant has added a recreation Resources visitor demand for recreation activities that demand analysis to the RSP for the Survey 2.9.6 are recreation resources study pertinent to the Project area and how this demand could change in the future over the life of the Project. Information should be obtained from various sources, such as the Statewide Comprehensive Outdoor Recreation Plan (SCORP), National Visitor Use Monitoring Study, demand forecast publications etc. to help determine predicted changes in anticipated demand for the outdoor recreation activities associated with the Project 3/28/2014 Meg Mitchell USFS Recreation WGE proposes to draft a report describing The applicant has expanded the Resources the results of the 2014/2015 recreation scope of the recreation resources Survey 2.9.7 resources study but appears to be limited study in the RSP. to measuring dispersed sites along Roads 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation 040 and 440. This is not complete. A report of the recreation inventory, recreation use, demand analysis and effects analysis shall be incorporated into the study results. Please refer to Pages 7-8 of the of the USDA Forest Service Willamette National Forest Study Requests for Recreation Resources, Proposed Study Methodology: 18 CFR 5.9(b)(6), Effects Analysis. 3/28/2014 Meg Mitchell USFS Recreation Once the existing recreation inventory and Applicant has added a recreation Resources recreation use and demand information is impact effects analysis to the RSP for Survey 2.9.7 gathered and described, an impact or the recreation resources study. effects analysis should be conducted and documented in a report. The effects analysis should include direct, indirect, and cumulative impacts to recreation from Project activities and whether or not the impacts would be short term, long term, or permanent. This study should make use of and integrate information resulting from other requested studies. For example, the Scenery Resources study should be used to determine effects on recreation setting and subsequently, the visitor experience relationship. The effects of distribution and 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation abundance of fish and wildlife, and potential effects to anglers and hunters could be assessed using findings from these relevant wildlife and fish studies. Information on effects of the project on ROS would inform land use studies (Wilderness and Inventoried Roadless Area and affects to Wilderness values) 3/28/2014 Meg Mitchell USFS Recreation Items to address in the affects analysis Applicant has added a recreation Resources report: impact effects analysis to the RSP for Survey 2.9.7 • Direct impacts to recreation facilities or the recreation resources study. sites or their use including inventoried dispersed campsites. For example, will the project eliminate sites or cause temporary displacement of use elsewhere during Project construction, etc.? • Potential effects of the Projects on dispersed recreation opportunities and activities listed in the Existing Information section above. • How recreation setting and experiences would be affected by the Project using Recreational Opportunity Spectrum (ROS) classification to evaluate (e.g., Roaded Natural ROS along the roadways, Semi- primitive ROS in the Inventoried Roadless Area (IRA) and Pristine ROS in the Wilderness). For example, how does the project affect the natural 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation setting/undeveloped character and opportunity for solitude or primitive and unconfined recreation quality in the area around the diversion structure and impoundment within Wilderness and IRA. • Potential noise effects during construction and operation of facilities by likely decibel levels at varying distances and potential impacts to recreation use, activities and experiences. • Diminished public access to the project area including temporary or permanent area and road closures, and temporary trail closures. • Increased access and subsequent use due to the development of Project facilities including cleared corridors, and how used would be controlled and managed. • Potential effects of the Project on travelers of West Cascades National Scenic Byway including any potential changes to the corridor setting, its intrinsic qualities and effects on experience. • Effects of the project on future recreation opportunities and use. 3/28/2014 Meg Mitchell USFS Recreation All data gathering, studies, surveys, analysis The applicant intends have the Resources and reports should be performed by a recreation resources study Survey 2.9.7 person completed by resource professionals knowledgeable and experienced in outdoor with experience with recreation and 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Licensing Licensing Comment Participant Participant Study Comment Response Date Name Affiliation recreation planning, forest landscape aesthetic impact studies for FERC architecture, sociology or related fields in regulated hydropower or other order to ensure policies, standard guides, infrastructure development on public methods, principles, and procedures in lands. recreation planning and scenery management are adhered to.

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Appendix C Summary of Informal Consultation Between the Formal PSP Meeting (28 January 2014) and the PSP Comment Deadline (29 March 2014)

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Appendix C: Summary of informal consultation between the formal PSP meeting (28 January 2014) and the PSP comment deadline (29 March 2014).

Date Comment Oregon Department of Fish and Wildlife (ODFW) and US Forest Service (USFS) requested that additional detailed information and discussions were needed for them to provide detailed comments on 28 January 2014 the Bypass Reach Instream Flow and Aquatic Habitat Study. An IFS subgroup of agency experts was formed at the Proposed Study Plan (PSP) meeting including: Darrin Neff (USFS), Al Johnson (USFS), John Zauner (ODFW), and Douglass Fitting (ODFW). Whitewater Green Energy, LLC had ERM-West, Inc. (ERM) provide 18 February 2014 the IFS subgroup with a detailed instream flow work plan to further assist with their study plan comments (Appendix E). Whitewater Green Energy, LLC had ERM host a teleconference and 3 March 2014 WebEx call with the IFS subgroup to discuss the instream flow work plan and address any questions or comments. Whitewater Green Energy, LLC had a teleconference call with the USFS to discuss updates on the study plan process and the forest 2 April 2014 service special use permit. Associated email correspondence with Mr. Dave Harmon (WGE) and Penny Keen (USFS) occurred in February and March of 2014. Whitewater Green Energy, LLC had ERM ask some clarifying questions (via phone, Chris Stine) regarding Oregon Department of 7 April 2014 Environmental Quality’s (ODEQ’s) 26 March 2014 comments on the PSP for the Whitewater Creek Hydroelectric Project. Whitewater Green Energy, LLC had ERM host a teleconference call with the Federal Energy Regulatory Commission (FERC) to ask 9 April 2014 some clarifying questions regarding FERC’s 28 March 2014 staff comments on the PSP for the Whitewater Creek Hydroelectric Project. Whitewater Green Energy, LLC had ERM ask some clarifying questions (via phone, Al Johnson) regarding the USFS’s 28 March 10 April 2014 2014 comments on the PSP for the Whitewater Creek Hydroelectric Project. Whitewater Green Energy, LLC had ERM ask some clarifying questions (via phone, Joe Doerr) regarding the USFS’s 28 March 11 April 2014 2014 comments on the PSP for the Whitewater Creek Hydroelectric Project.

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Appendix D PSP Meeting Attendance List

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Appendix E Whitewater IFS Workplan

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Whitewater Hydropower Instream Flow Work Plan

February 2014

Prepared for: www.erm.com Whitewater Hydropower and ISF Subgroup

The world’s leading sustainability consultancy

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Whitewater Hydropower Whitewater Hydropower Instream Flow Work Plan

February 2014

Project No. 0219974-03

DRAFT Erik Steimle, CEP Project Manager

DRAFT John Gangemi, Partner-in-Charge

Environmental Resources Management 1001 SW 5th Avenue, Suite 1010 Portland, Oregon 97204 T: 503-488-5282 F: 503-488-5142

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TABLE OF CONTENTS

LIST OF TABLES III

LIST OF ACRONYMS IV

1.0 INTRODUCTION AND BACKGROUND 1

1.1 INSTREAM FLOW MODELS 1

1.2 MODEL SELECTION RATIONALE 2

2. METHODS 4

2.1 PRE-FIELD TASKS 4 2.1.1 Fisheries Resources 4 2.1.2 Stream Habitat and Hydrology 4

2.2 HYDROLOGICAL METHODS 5 2.2.1 Objectives 5 2.2.2 Hydrogeomorphic Units 5 2.2.3 Transect Locations 6 2.2.4 Benchmarks 7 2.2.5 Staff Gauges 7 2.2.6 Channel Cross-Section Survey 8 2.2.7 Water Surface Elevations and Stream Gradient 8 2.2.8 Stream Hydraulics 8 2.2.9 Calibration Flows 9

2.3 BIOLOGICAL METHODS 10 2.3.1 Objectives 10 2.3.2 Fish Habitat 10 2.3.3 Fish 12

2.4 MODELLING APPROACH 16 2.4.1 Model 16 2.4.2 Flow Scenarios 17 2.4.3 Quantifying Incremental Habitat Change 17 2.4.4 Large Woody Debris Recruitment 17

2.5 REPORTING 17

2.6 LIMITATIONS AND ASSUMPTIONS 18

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3. SCHEDULE 19

REFERENCES 20

APPENDIX A — NORTH SANTIAM RIVER HYDROGRAPH

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LIST OF TABLES

(Tables immediately follow the text)

1 Detailed Schedule of the Whitewater Project Instream Flow Study Activities

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LIST OF ACRONYMS

AWS Area weighted suitability

CSI Combined suitability index

HSI Habitat suitability index

IFIM Instream Flow Incremental Methodology

IFS Instream flow study

MAD Mean annual discharge

MMD Mean monthly discharge

PHABSIM Physical Habitat Simulation

SEFA System of Environmental Flow Analysis

USFS United States Department of Agriculture Forest Service

WUA Weighted usable area

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1.0 INTRODUCTION AND BACKGROUND

Whitewater Hydropower (the Project) is a proposed run-of-river hydropower project in Whitewater and Russell Creeks, Oregon. Coastal Cutthroat Trout (Oncorhynchus clarkii clarkii) are confirmed present in the bypass reach based upon recent United States Department of Agriculture Forest Service (USFS) assessments. The USFS also stated that Brook Trout (Salvelinus fontinalis) are possibly present in the bypass reach.

Water demands for project development propose flow reductions in the bypass reach. Given the complexity of habitat changes with flow levels, a conventional instream flow study (IFS), using a modified Instream Flow Incremental Methodology (IFIM) (Bovee 1982; Bovee et al. 1998), is proposed for the Project.

This work plan outlines the proposed methods and rationale for the instream flow needs assessment on the Whitewater Hydropower Project. The proposed methods were selected to provide federal and state regulators with sufficient detail to assess potential effects resulting from project development. The IFS will be used to quantify incremental changes to flow levels and, in turn, incremental changes to fish habitat. The IFS will provide direct insight into potential project effects within the bypass reach as associated with flow reductions. In addition to this, the IFS will provide the flexibility of assessing potential flow-related mitigation options that may be considered for the Project.

1.1 INSTREAM FLOW MODELS

A number of one-dimensional and two-dimensional models exist to characterize instream flow needs. The most suitable IFS model is selected based upon the overall physiography of the area, reach geomorphology and hydraulics, and physical requirements (depth, velocity, and substrate) of fish life history stages within a bypass reach.

Annear et al. (2002) discuss 29 different instream flow methods used in the United States and Canada; each relating to hydrology, biology, geomorphology, water quality, and connectivity. These computer models provide a mechanism to quantify usable fish habitat, per unit length of stream, by linking stream channel hydraulics with habitat suitability criteria (depth, velocity, and substrate). An output of hydraulic-habitat

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modeling is an index referred to as weighted usable area (WUA), which is a measure of potential suitable habitat available, for specific life stages, at specific flow rates. Some examples of these models are discussed below.

Physical Habitat Simulation (PHABSIM) is one of the most commonly used instream flow models. It requires the collection of habitat data (typically depth, velocity, substrate, and cover) along stream transects. This is followed by hydraulic simulations to estimate habitat availability at different flow rates, for each species, and each life stage (Milhous, Wegner, and Waddle 1984). Field measurements of depth, velocity, substrate, and cover are taken along stream transects at different flow rates to adequately calibrate the model. The models are then used to predict incremental changes to available habitat, at different flow rates.

System of Environmental Flow Analysis (SEFA) builds upon IFIM and PHABSIM (Jowett et al. 2013). SEFA contains one-dimensional hydraulic- habitat analysis, habitat suitability criteria development, water temperature modeling, sediment transport analysis, riparian modeling, time-series analysis, and externally references to legal-institutional analysis and two-dimensional hydraulic modeling. Similar to PHABSIM, SEFA is an incremental approach used to predict available habitat at the ‘desired’ resource state.

Many other habitat simulation models are available to link stream hydraulics with habitat suitability information for specific fish species. For example, River2D was developed at the University of Alberta (Steffler and Blackburn 2002) and is a two-dimensional depth averaged hydrodynamic model that has been customized for fish habitat evaluation studies. As with PHABSIM and SEFA, the model uses depth, velocity, and substrate data in addition to a topographic mesh to quantify incremental changes to available habitat at different flow rates.

1.2 MODEL SELECTION RATIONALE

The most widely accepted methodology for characterizing the effects of flow alterations on fish habitat is the IFIM. The IFIM was designed to aid scientists and resource managers in evaluating stream flows at small incremental changes in order to identify a ‘desired’ resource state. The IFIM is a comprehensive methodology within which there are a number of options that can be used to provide instream flow recommendations on the trade-offs between habitat protection and water demands of the

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project. IFIM links traditional hydraulic engineering models to fish habitat suitability curves based on water depth, velocity and bed particle size. SEFA, an IFIM and a variation of PHABSIM, is proposed for the Project.

SEFA was designed to measure the amount of microhabitat available for fish at different life stages, and at different flow levels. SEFA is a hydraulic-habitat model that is a simplified and more current version of PHABSIM. It has limited the number of variable inputs and field time required. This simplification has made IFIMs less intensive to apply. WUA is the model output and the metric used to determine minimum instream flow needs for specific species and life-stages. WUA would be generated for both pre-development and operational conditions. To that end, SEFA provides sophisticated, incremental results by using the field data generated following the field procedures described below. The model results from SEFA are then able to be used to form an understanding of the trade-offs between flow reductions and instream flow needs. It is for this reason that ERM proposes to use SEFA and a modified IFIM approach to quantify the instream flow needs on the Project.

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2. METHODS

2.1 PRE-FIELD TASKS

2.1.1 Fisheries Resources

Relevant fish and fish habitat reports specific to the study area will be obtained from regulatory agencies. These include the 1994 Whitewater Creek Level 2 fish habitat assessment, and a 1976 Russell and Whitewater Creek’s fish assessment (D. Neff, pers. comm.). Relevant fish and fish habitat information from a regional perspective will be reviewed from a variety of sources including regulatory agencies and consultant reports. This information will be reviewed prior to selecting appropriate Coastal Cutthroat Trout HSI curve (Section 2.3.3.1). This review will commence prior to initiating fieldwork to assist in determining fish presence/absence, life history timing, fish habitat distribution and quality.

2.1.2 Stream Habitat and Hydrology

Prior to initiating any field work, it will be important to have a general understanding of physical stream features present within Whitewater and Russell Creeks. To assess the physical stream features, and number of data sources will be obtained, including: historic physiographic data, hydrology and geology data, aerial photos, topographic information, 1994 Whitewater Creek Level 2 fish habitat, and any other source that will support this understanding.

As per the USFS Level 1 habitat assessment in the Stream Inventory Handbook (USFS 2010), preliminary reaches will be determined and mapped for Whitewater Creek (North Santiam River confluence to reach upstream of Russell Creek confluence), and Russell Creek (Whitewater Creek confluence to lake). This will be done with information gleaned from GIS layers, topographic maps, orthophotographs, and aerial photographs for Whitewater and Russell Creeks.

The following forms will be completed for the Level 1 habitat assessment:

• preliminary reach form (Form R6-2500/2600-20); and

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• map of the target stream reaches showing preliminary reach breaks, access points, road crossings (culverts, bridges, etc.), and other points of interest that will help orient the field assessment.

2.2 HYDROLOGICAL METHODS

2.2.1 Objectives

The program will provide information on hydrology and geomorphology within the bypass reach(s) that may be affected by the proposed Project. The overall objectives of the hydrology component are to:

• assess the hydrogeomorphic units present within the Russell and Whitewater Creeks;

• characterize stream hydraulics within Russell and Whitewater Creeks, with a detailed emphasis on quantifying mesohabitats within the bypass reach(s); and

• develop a robust instream flow model capable of providing detailed insight on incremental changes in fish habitat commensurate with incremental changes in flow.

A Hydrologist and Fisheries Biologist will establish stream transects for the purposes of instream flow habitat modeling after completion of the Level 1 (Section 2.1.2) and Level 2 (Section 2.3.2) habitat assessment. These transects will be stratified by mesohabitat units (pools, riffles and glides) and selection will be based upon the habitat preferences of Coastal Cutthroat Trout life history stages.

Each mesohabitat unit within the bypass reach(s), which are critical to life stage of Coastal Cutthroat Trout, will require adequate field data to characterize its natural range of variability. The field program will include the collection of topographic, hydraulic and geomorphic field data to support modeling incremental changes to flow and subsequent changes to depth, velocity, and substrate availability.

2.2.2 Hydrogeomorphic Units

Over the last two decades significant focus has been paid to the linkages between ecology and the physical stream environment, where abiotic

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stream processes have been internationally recognized as key components of aquatic ecosystem structure and function (Zavadil and Stewardon 2013). One of the fundamental focal points of eco-geomorphology has been to refine the conceptual understanding of spatial organization in riverine ecosystems. This body of research has identified three important scales to consider in riverine ecosystems; these include: the meso, reach and segment scales.

Segment scale units are generally defined from broad-scale changes in topography, geology, hydrology, and subsequently, stream character; thus being referred to as hydrogeomorphic units. Prior to the installation of transects it will be necessary to implement a segment break assessment to determine the stream character and presence of hydrogeomorphic units. The Level 1 and 2 habitat assessment will be a key tool to inform this process, which is described in Sections 2.1.2 and 2.3.2, respectively.

2.2.3 Transect Locations

A representative study reach will be selected for the instream flow assessment. The location of the representative reach will be determined by results from the Level 1 and 2 fish habitat assessments, segment break analysis (hydrogeomorphic units), background fisheries information, and proposed infrastructure locations. Where more than one hydrogeomorphic unit exists, it will be necessary to find agreement between agencies on the scope of the IFS; such that, ERM recommends that a representative reach for the IFS does not span multiple hydrogeomorphic units. Should agencies be interested in performing an IFS on mesohabitats from more than one hydrogeomorphic unit, ERM recommends that: (1) each hydrogeomorphic unit be characterized separately; (2) a representative reach be selected from each hydrogeomorphic unit of interest; (3) life stages / mesohabitat are separated and not aggregated between hydrogeomorphic units; and (4) each life stage/mesohabitat to be characterized, within each hydrogeomorphic unit, be given no less than five transects.

Specific transect locations will be determined in consultation with regulatory agencies. ERM recommends that five to eight transects are installed to characterize each life stage/mesohabitat of Costal Cutthroat Trout, within each hydrogeomorphic unit selected. In general, each life stage will correspond to a specific mesohabitat (pool, riffle, and glide). To adequately characterize each mesohabitat/life stage it is necessary to install enough transects to represent the range of natural variability

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observed for that mesohabitat. It is generally accepted that five to eight transects are adequate to represent the range of natural physiographic variation for a single mesohabitat, within a single hydrogeomorphic unit.

Assuming that one representative reach is selected, within the most representative hydrogeomorphic unit, and three mesohabitats (pool, riffle, and glide) are critical to the life stages of Coastal Cutthroat Trout, ERM would recommend that 18 transects (six transects per mesohabitat) would be installed to adequately characterize the natural variation of the representative reach.

In addition to accurately characterizing the range of natural variation within the mesohabitats, it will also be necessary to characterize the range of water levels that can be expected for the Project. A total of five flow measurements will be conducted at each transect to develop rating curves and habitat-flow relationships (Table 1). This will further provide an opportunity to develop validation data (measured vs. modeled) at strategic flow levels.

2.2.4 Benchmarks

Three benchmarks will be established for each mesohabitat transect (USGS 1982). In some cases a series of three benchmarks may be able to be used for more than one transect, when longitudinal spacing and riparian visibility allowed. During the initial survey all benchmarks will be surveyed three times, systematically back sighting on each of the three benchmarks, one at a time, in order to calculate survey error. Survey error will be < 1/16” for each mesohabitat transect.

2.2.5 Staff Gauges

Staff gauges will be installed and surveyed for all transects. Rebar (3/8”) will be used for the staff gauges and, where possible, installed near the stream bank in a protected location (USGS 1982). Some staff gauges will be installed in the center of the stream to allow for low flow measurements. Staff gauges will be specifically located along all transects with the offset distance recorded. Subsequent water surface elevations will be measured relative to the top of the staff gauge which will be surveyed to a local site datum, as all benchmarks and channel cross- sections.

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2.2.6 Channel Cross-Section Survey

During the initial establishment of each transect a channel cross-section will be surveyed to a local datum. Rebar (3/8”) or spikes in trees will be used as transect end points to mark the left and right banks. In every case these end points will be located outside of the bankfull width. The spatial resolution of the cross-section surveys will be proportional to the channel width, but in most cases there will be approximately one to two foot spacing between survey points. This approach will provide detailed cross- sections built from 30-50 points for each transect.

2.2.7 Water Surface Elevations and Stream Gradient

Water surface elevations will be surveyed along the stream cross-section, on the right and left sides of the wetted width, during the initial survey of each transect (USGS 1982). Additional water surface elevations will be surveyed at two points 65 feet upstream (left and right sides of wetted width) and two points 65 feet downstream, where riparian visibility and channel form permit. Where the wetted edge is not visible, 65 feet upstream or downstream, modifications will be made. Stream and bed gradients will then be calculated over a 130 feet stretch, using the upstream and downstream distance and water surface elevations for this calculation.

2.2.8 Stream Hydraulics

Water depth and velocity measurement will be conducted following the USGS Hydrometric Standards (1982). During the initial setup of each transect the channel cross-section will be surveyed such that no less than 25 survey points (offsets) are located within the wetted width, along with enough points outside of the wetted width to characterize the un-wetted portion of the cross-section. This will ensure that: (1) discharge data collected for the IFS meet those requirements laid out by the USGS; (2) hydraulic data for the velocity distribution factors (VDFs) are based on greater than 25 vertical panels across the streams; and, (3) survey flow data will be collected at a strategic water level to ensure successful model calibration.

Information on stream substrates will be collected during the initial setup and survey. Substrate data will be collected following appropriate state methods. At all offsets within the bankfull points substrate data will be

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collect and recorded in percent. Size classes will be consistent with the Stream Inventory Handbook (USFS 2010).

Overall, the hydraulic data to be collected at each stream panel will include:

• cross section distance (feet);

• offset distance (feet);

• water depth (inches);

• substrate (% composition);

• transect width (feet);

• stream bed elevation (feet);

• mean water velocity (feet/sec); and

• cover (presence/absence)

2.2.9 Calibration Flows

To attain high quality flow measurements during subsequent calibration flows, stream discharge will be measured at glides (tailouts) and will not be measured at riffles and pools. The reason for this is that glides produce laminar flow, which is absent of turbulence, and meets the operating guidelines of common velocity instruments. In practice, each hydrogeomorphic unit, of each stream, may have five or more glides; thus, discharge for each specific mesohabitat transect can be based on either the nearest glide or the average of all five glides in that hydrogeomorphic unit. This approach provides the flexibility of averaging five discharge measurements per hydrogeomorphic section, in addition to providing microhabitat data (depth and velocity) at additional calibration flows. Micro-habitat data from these two calibration flows will be used to validate model results by comparing the modeled depth and velocity data against the measured depth and velocity data.

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2.3 BIOLOGICAL METHODS

2.3.1 Objectives

The baseline program will provide information on fish and fish habitat within the bypass reach(s) that may be affected by the proposed Project. The objectives of the fish and fish habitat program are as follows:

• assess fish habitat within Russell and Whitewater Creeks, with a detailed emphasis on quantifying mesohabitat availability specific to life stages of Coastal Cutthroat Trout present within the bypass reach(s);

• determine fish presence, community composition, population demography, distribution and barriers to fish movement within the bypass reach(s) of Russell and Whitewater creeks;

• select appropriate Coastal Cutthroat Trout HSI curves, and validate the HSI curves with empirical site specific data; and

• determine mean density of fish within the within the bypass reach(s) of Russell and Whitewater Creeks using single pass snorkel surveys

2.3.2 Fish Habitat

Fish habitat within Whitewater and Russell Creek bypass reach(s) will be assessed according to the USFS Level 2 habitat assessment in the Stream Inventory Handbook (USFS 2010). In 1994, a USFS Level 2 habitat assessment was conducted for Whitewater Creek. This previous assessment is useful for characterizing habitat presence, habitat extent, mesohabitat composition and distribution; however the horizontal and vertical shifts typical of alluvial channels have likely changed the exact locations of mesohabitat features. It is therefore necessary to resurvey the Whitewater Creek bypass reach(s).

The bypass reach(s) will be ground-truthed and mapped with a differential GPS unit during April-May to characterize existing habitat conditions. The month of May, prior to freshet, was selected based upon communication with USFS District Fisheries Biologist (D. Neff, pers. comm.) because discharge is typically lower and water clarity is greater compared to summer months. Furthermore, the completion of the USFS

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Level 2 habitat assessment will serve as a basis for selecting appropriate transects for the instream flow assessment.

The field crew will comprise of two people with each member responsible for specific tasks. The "Estimator" will focus on the identification of channel unit characteristics. The "Numerator" will focus on the counts and relative distribution of several unit attributes and will verify the length and width estimates for a subset of units. The "Estimator" and "Numerator" share the responsibility for describing reach characteristics, riparian conditions, identifying habitat unit types, and for quantifying the amount of large woody debris. The following forms will be completed for the Level 2 habitat assessment:

• final reach form (Form R6-2500/2600-21);

• channel unit form (Form R6-2500/2600-22);

• special cases form, if applicable (Form R6-2500/2600-23); and

• Wolman pebble count form (Form R6-2500/2600-32).

The stream habitat data discharge form (Form R6-2500/2600-31) will not be completed as discharge at the time of the survey can be obtained from the existing hydrometric station.

Stream temperature data loggers will be mounted to rebar within the following sections of Russell and Whitewater creeks:

• Russell Creek, between the intake diversion and the lake;

• Whitewater Creek, downstream of the Russell Creek confluence;

• Whitewater Creek, between Sentinel Creek and Cheat Creek confluences; and

• Whitewater Creek, downstream of the penstock tailrace.

Backup temperature data loggers will be installed at each of the above locations. Continuous hourly stream temperature will be collected during the open water period from the April-May to October.

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2.3.3 Fish

2.3.3.1 Habitat Suitability Index Curve Selection

Peer reviewed Coastal Cutthroat Trout depth, velocity, and substrate habitat suitability index (HSI) curves will be collated and reviewed. Based upon this review, the most relevant Coastal Cutthroat Trout depth and velocity HSI curves will be selected for the habitat model. This is an acceptable approach and is classified as Category I criteria curve in Development and Evaluation of Habitat Suitability Criteria for use in the Instream Flow Incremental Methodology (Bovee 1986). This approach has been applied in numerous instream flow projects (e.g., City and Borough of Sitka Electric Department 2005; Sutton and Morris 2004; R2 Resource Consultants 2004). Following the identification of suitable HSI curves, selection of the most appropriate curves will be done in consultation with resource agencies.

2.3.3.2 HSI Curve Validation, Fish Distribution and Average Density

Sufficient sample size of fish observations for each Coastal Cutthroat Trout life history stage, are required to validate the previously selected HSI curve (Section 2.3.3.1). A target of 25-50 fish observations per life history stage, are proposed for this instream flow study, which is based upon IFIM recommendations (Bovee 1986). However, it is recognized that field conditions, habitat, and fish abundance dictate the ability to realistically achieve the target sample size. The Coastal Cutthroat Trout life history stages identified for the Project are: juvenile rearing, adult rearing, and adult spawning.

The preference curve verification study will consist of three parts:

• determine proportional habitat availability – This will be determined by the Level 2 habitat assessment. It is known that Coastal Cutthroat Trout rear in Whitewater and Russell Creeks and have particular habitat preferences based upon primary literature sources. The habitat preferences of Coastal Cutthroat Trout will be compared to available habitat. It is unknown if Coastal Cutthroat Trout spawn in these creeks. The Level 2 habitat assessment will inform whether spawning habitat is present and the amount of habitat available for spawning.

• determine fish distribution and habitat utilization; and

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• analysis of fish preferences and average density by determining ratios of habitat utilization to habitat availability

Juvenile and adult rearing snorkel surveys will occur during May within the bypass reach(s). The month of April to early May, prior to peak freshet, was selected based upon communication with USFS District Fisheries Biologist (D. Neff, pers. comm.) because discharge is typically lower and water clarity is greater compared to summer months. The snorkel surveys maybe repeated in late-September to October if insufficient number of fish observations are obtained during the May survey. The month of October, precipitation freezing at higher levels, was selected based upon communication with USFS District Fisheries Biologist (D. Neff, pers. comm.) because discharge is typically lower and water clarity is greater compared to summer months. The field methods will typically follow those presented within Salmonid Field Protocols Handbook (Johnson et al. 2007), and are outlined as follows:

• Prior to each survey, a secchi disk reading will be taken to determine the visibility corridor for sampling. A secchi disk will be held underwater by the data recorder, and a tape measure extended by the snorkeler from the secchi disk outward to a point where the disk is no longer clearly visible.

• The weather conditions and water temperature will be recorded at the start and end of the survey.

• To ensure accurate estimation of fish size underwater, the snorkeler will calibrate their sight to a ruler prior to beginning each survey. Rulers and objects of know length (e.g., fingers, marks on diving gloves) will be used during the survey to maintain accuracy in the estimation of fish length.

• Given the small creek size, one snorkeler and a data recorder will be used, and proceed in an upstream direction making observations of all microhabitat types within their line of sight.

• When a fish is observed the snorkeler will verbally transmitted the following information to the data recorder:

o fish species;

o fish length (mm);

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o location in water column (distance from the bottom to the nearest 0.1 feet);

o substrate use classification;

o proximity/affinity to habitat structure/cover features (e.g., boulder, undercut bank, overhanging vegetation, large woody debris);

o relevant comments pertaining to cover associations and/or behavioral characteristics of the fish observed;

o mesohabitat type;

o SO unit number;

o area snorkeled per mesohabitat type (feet2); and

o UTM location.

• Only fish holding over a fixed position will be included in the microhabitat survey. However, moving fish will also be enumerated for mean density calculations.

• Subsequent to locating a fish observation, the data recorder will proceed to the fish location and collected the following information:

o water depth – measured to the nearest 0.1 feet using a top setting rod;

o mean column velocity (fps) – measured using a Swoffer Model 2100 current meter; and

o substrate classification

If the Level 2 habitat assessment indicates that Coastal Cutthroat Trout spawning habitat is present within the bypass reach(s) then the timing of spawning surveys will be conducted in consultation with regulatory agencies. The field methods will typically follow those presented within Salmonid Field Protocols Handbook (Johnson et al. 2007), and are outlined as follows:

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• The weather conditions, water clarity, and water temperature will be recorded at the start and end of the survey. • Walk the stream channel in an upstream direction in high potential habitat areas identified from the Level 2 habitat assessment. • Identify the location of constructed redds and record: o mesohabitat type; o SO unit number; and o UTM location. • For each identified redd, the following measurements will be made: o redd dimensions (length and width [to nearest 0.5 feet] to allow computation of area); o water depth to the nearest 0.1 feet at the upstream end of each redd measured using a top setting wading rod; o mean water column velocity (fps) at the upstream end of each redd measured to the nearest 0.01 fps using a Swoffer Model 2100 current meter; and o substrate size (dominant, sub-dominant, and percent dominant) characterized in accordance with the size classification standards (USFS 2010)

The field data will be checked for data entry accuracy, collated, and analyzed. Fish rearing and spawning distribution will be mapped within the bypass reach(s). Fish rearing distribution data will be calculated and presented as:

• no. of sites per habitat type/stratum (i.e., mesohabitat) snorkeled; and • percent fish occupancy per habitat type/stratum (i.e., mesohabitat)

Single pass snorkel mean fish density will be calculated by species, mesohabitat type, and life history stage, according to the objective based recommendations within Salmonid Field Protocols Handbook (Johnson et al. 2007). Fish rearing distribution data will be calculated and presented as:

• density of fish per square feet per snorkeled habitat type/stratum (i.e., mesohabitat)

Standard error of the mean is a descriptive statistic related to the precision of the data. Standards error will be reported, since we are primarily concerned with precision of the mean (Guy and Brown 2007). Catch and abundance data is typically not normal normally distributed (i.e., negative binomial distribution; Guy and Brown 2007). Therefore, bootstrapping

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techniques will be used to derive means and percentile bootstrap +/-95% confidence intervals for the density data. Bootstrapping is accomplished using 10,000 resamples from original density dataset (Guy and Brown 2007).

Field validation data will be analyzed and compared to the selected HSI curves. Data will be sorted according to species type and life-history stage. Frequency distributions will be generated for mean velocity, depth, and substrate type for each species and life history stage. An appropriate frequency bin width will be determined based upon the field data to evaluate the mean velocity and depth utilization distributions. Histogram plots of depth and mean column velocity utilization will be produced. The frequency distribution of the field observations will be converted into HSI curves by scaling the distribution between 0 and 1 (utilization values divided by the maximum value observed). Based upon this cross- validation analysis, the Coastal Cutthroat Trout HSI curves will be adjusted using an abbreviated convergence method approach (Bovee 1986), if required, in consultation with resource agencies.

2.4 MODELLING APPROACH

ERM feels that a one dimensional IFIM approach suites the Project needs.

2.4.1 Model

ERM will use SEFA to characterize habitat-flow relationships in the mesohabitats required to support each life-stage of Coastal Cutthroat Trout. Surveyed water surface elevations and flow measurements will be used to calibrate the model, in addition to channel conveyance parameters, and roughness factors. Water depth and velocities will then be fitted to the calibrated model; once calibrated, the model will be validated against measured water depths and velocities (calibration flows).

The SEFA model will combine hydraulic data (depth, velocity and substrate) with HSI curves to generate an area weighted index of available habitat quality and quantity. Habitat mapping results, combined with the area weighted values will then be used to generate the WUA for each flow scenario.

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2.4.2 Flow Scenarios

Various flow scenarios will be selected to model incremental changes to fish habitat. The flow scenarios to be selected will depend upon a number of factors such as, species life history timing and operational regimes of the Project. To that end, flow scenarios to be modeled will be developed in consultation with resource agencies. These may include, but will not be limited to: mean annual discharge (MAD); mean monthly discharge (MMD); the regulated instream flow release; the 50% naturalized exceedence flow, the 80% naturalized exceedence flow; flushing flows and maintenance flows; extreme low and high flows.

2.4.3 Quantifying Incremental Habitat Change

Each selected flow scenario will be used to quantify change in available Coastal Cutthroat Trout habitat. A habitat index will be generated for each flow scenario and expressed either as area weighted suitability (AWS), weighted usable area (WUA), and/or combined suitability index (CSI).

2.4.4 Large Woody Debris Recruitment

Large woody debris is an important component of aquatic ecosystems, contributing to the geomorphic processes such as streambank stabilization, sediment storage, fluvial processes and the development of habitat for freshwater fish (Thevenet 1998). The role and recruitment of large woody debris will be considered in the Whitewater Creek instream flow needs assessment.

2.5 REPORTING

Instream flow needs data will be analyzed, compiled, and communicated in a formal technical report. Level 1 and 2 habitat assessment forms will be included as an appendix to the report. The detailed results of the instream flow modeling will be organized to aid the development and permitting of the Project. These details will specifically include interpretation of the habitat-flow relationship of Coastal Cutthroat Trout in the bypass reach. And make recommendations on flushing and maintenance flows required to sustain the riverine health required to sustain Coastal Cutthroat Trout.

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2.6 LIMITATIONS AND ASSUMPTIONS

The instream flow study for the Project makes the following assumptions:

• It is assumed the sediment recruitment and transport will remain unaltered through mitigation techniques, thus a separate study will therefore address bedload transport at the intake; and • It is assumed that Coastal Cutthroat trout are the target fish species.

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3. SCHEDULE

Table 1 details the schedule of the Whitewater Project instream flow study activities.

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REFERENCES

Annear, T., I. Chisholm, H. Beecher, A. Locke, and 12 other authors. 2004. Instream flow for riverine resource stewardship, revised edition. Instream Flow Council, Cheyenne, WY.

Bovee, K.D. 1982. A guide to stream habitat analysis using the instream flow incremental methodology. U.S. Fish and Wildlife Service FWS/OBS- 82/26.

Bovee, K.D. 1986. Development and evaluation of habitat suitability criteria for use in the instream flow incremental methodology. Washington, DC: USDI Fish and Wildlife Service Instream Flow Information Paper #21 FWS/OBS-86/7.

Bovee, K. D., B. L. Lamb, J. M. Bartholow, C. B. Stalnaker, J. Taylor and J. Henriksen. 1998. Stream habitat analysis using the instream flow incremental methodology. U.S. Geologicial Survey, Biological Resources Division Information and Technology ReportUSGS/BRD-1998-0004.

City and Borough of Sitka Electric Department. 2005. Revised draft habitat suitability curves: Coho Salmon and Steelhead Trout, Sawmill Creek Alaska. Blue Lake Hydroelectric Project.

Guy, C.S. and M.L. Brown. 2007. Analysis and interpretation of freshwater fisheries data. American Fisheries Society. Bethesda, Maryland.

Johnson, D. H., Shrier, B.M., O’Neal, J.S., Knutzen, J.A., Augerot, X., O’Neil, T.A., and T. N. Pearsons. 2007. Salmonid field protocols handbook: Techniques for assessing status and trends in salmon and trout populations. Maryland: American Fisheries Society.

Jowett, I.G., T.R. Payne and R. Milhouse. 2012. System for environmental flow analysis (SEFA). Software Manual.

Milhous, R., Wegner, D., and Waddle, T. 1984. User's guide to the physical habitat simulation system (PHABSIM). Instream Flow Information Paper 11, United States Fish and Wildlife Service FWS/OBS-81/43.

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R2 Resource Consultants. 2004. WRIA 44 and 50 watershed instream flow study. Prepared for the Foster Creek Conservation District and WRIAs 44 and 50 Planning Unit. Redmond, Washington.

Steffler, P., and J. Blackburn. 2002. River2D. Two-dimensional depth averaged model of river hydrodynamics and fish habitat. User’s manual. University of Alberta.

Sutton, R. and C. Morris. 2004. Flow characterization study instream flow assessment: Big Timber Creek, Idaho. Prepared for U.S. Department of the Interior Bureau of Reclamation. Boise, Idaho.

Thevenet, A., Citterio, A., and Piegay, H. 1998. A new methodology for the assessment of large woody debris accumulations on highly modified rivers. Regul. Rivers: Res. Mgmt. 14: 467-483.

USFS. 2010. Stream Inventory Handbook, Level I and II. Pacific Northwest Region: Region 6. Version 2.10.

USGS. 1982. Measurement and computation of streamflow: Volume 1. Measurement of stage and discharge. United States Geological Survey. Geological Survey Water-Supply Paper 2175.

Zavadil, E. and M. Stewardson. 2013. The role of geomorphology and hydrology in determining spatial-scale units for ecohydaulics. In Ecohydraulics: An integrated approach, First Edition. Edited by Ian Maddock, Atle Harby, Paul Kemp and Paul Wood. Published 2013 by John Wiley & Sons, Ltd.

Personal Communication

Neff, D. 2014. Fish Biologist, United States Department of Agriculture: Forest Service, Detroit Ranger District, Salem. Personal Communication: January 28, 2014.

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Table

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Table 1. Detailed Schedule of the Whitewater Project Instream Flow Study Activities

2014 2015 Task Jan Feb March April May Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar Finalize IFS work plan Consultation with working group regarding HSI to be applied Level 1 habitat assessment Level 2 habitat assessment and HSI validation snorkel assessment Site visit to select representative reach(s) and survey transects Install and survey transects Collect IFS data for all transects Large woody debris assessment Calbration measurements for all transects Calbration measurements for all transects Calbration measurements for all transects HSI validation snorkel assessment Data QA/QC Develop SEFA model Calibrate SEFA model Senior review on SEFA model Large woody debris framework Work up HSI validation data Consultation with working group (life stage and HSI agreement) Run preliminary WUA for working group review Model WUA for each life stage and scenario Senior review of results Reporting Senior review of report Review by client 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

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Appendix A North Santiam River Hydrograph

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Appendix A. North Santiam River Hydrograph

North Santiam River - Above Detroit 2007-2013 Average Daily Flow 2500

2000

1500

Discharge (cfs) Discharge 1000

500

0 1-Jan 1-Feb 1-Mar 1-Apr 1-May 1-Jun 1-Jul 1-Aug 1-Sep 1-Oct 1-Nov 1-Dec

*NOTE: Daily flow data from 2007-2013 has been averaged to produce one hydrograph inclusive of all seven years. 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

Appendix F Wetland Determination Data Forms

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DATA FORM ROUTINE WETLAND DETERMINATION (1987 COE Wetlands Delineation Manual)

Project/Site: ______Date: ______Applicant/Owner: ______County: ______Investigator: ______State: ______

Do Normal Circumstances exist on the site? Yes No Community ID: ______Is the site significantly disturbed (Atypical Situation)? Yes No Transect ID: ______Is the area a potential Problem Area? Yes No Plot ID: ______(If needed, explain on reverse.)

VEGETATION

Dominant Plant Species Stratum Indicator Dominant Plant Species Stratum Indicator 1.______9.______2.______10.______3.______11.______4.______12.______5.______13.______6.______14.______7.______15.______8.______16.______

Percent of Dominant Species that are OBL, FACW or FAC (excluding FAC-). ______

Remarks:

HYDROLOGY

___ Recorded Data (Describe in Remarks): Wetland Hydrology Indicators: ___ Stream, Lake, or Tide Gauge Primary Indicators: ___ Aerial Photographs ___ Inundated ___ Other ___ Saturated in Upper 12 Inches ___ No Recorded Data Available ___ Water Marks ___ Drift Lines ___ Sediment Deposits Field Observations: ___ Drainage Patterns in Wetlands Secondary Indicators (2 or more required): Depth of Surface Water: ______(in.) ___ Oxidized Root Channels in Upper 12 Inches ___ Water-Stained Leaves Depth to Free Water in Pit: ______(in.) ___ Local Soil Survey Data ___ FAC-Neutral Test Depth to Saturated Soil: ______(in.) ___ Other (Explain in Remarks)

Remarks:

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SOILS

Map Unit Name (Series and Phase): ______Drainage Class: ______Field Observations Taxonomy (Subgroup): ______Confirm Mapped Type? Yes No

Profile Description: Depth Matrix Color Mottle Colors Mottle Abundance/ Texture, Concretions, (inches) Horizon (Munsell Moist) (Munsell Moist) Size/Contrast Structure, etc. ______

______

______

______

______

______

Hydric Soil Indicators:

___ Histosol ___ Concretions ___ Histic Epipedon ___ High Organic Content in Surface Layer in Sandy Soils ___ Sulfidic Odor ___ Organic Streaking in Sandy Soils ___ Aquic Moisture Regime ___ Listed on Local Hydric Soils List ___ Reducing Conditions ___ Listed on National Hydric Soils List ___ Gleyed or Low-Chroma Colors ___ Other (Explain in Remarks)

Remarks:

WETLAND DETERMINATION

Hydrophytic Vegetation Present? Yes No (Circle) (Circle) Wetland Hydrology Present? Yes No Hydric Soils Present? Yes No Is this Sampling Point Within a Wetland? Yes No

Remarks:

Approved by HQUSACE 3/92

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WETLAND DETERMINATION DATA FORM – Western Mountains, Valleys, and Coast Region

Project/Site: City/County: Sampling Date: Applicant/Owner: State: Sampling Point: Investigator(s): Section, Township, Range: Landform (hillslope, terrace, etc.): Local relief (concave, convex, none): Slope (%): Subregion (LRR): Lat: Long: Datum: Soil Map Unit Name: NWI classification: Are climatic / hydrologic conditions on the site typical for this time of year? Yes No (If no, explain in Remarks.) Are Vegetation , Soil , or Hydrology significantly disturbed? Are “Normal Circumstances” present? Yes No Are Vegetation , Soil , or Hydrology naturally problematic? (If needed, explain any answers in Remarks.) SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc.

Hydrophytic Vegetation Present? Yes No Hydric Soil Present? Yes No Is the Sampled Area within a Wetland? Yes No Wetland Hydrology Present? Yes No Remarks:

VEGETATION – Use scientific names of plants. Absolute Dominant Indicator Dominance Test worksheet: Tree Stratum (Plot size: ) % Cover Species? Status Number of Dominant Species 1. That Are OBL, FACW, or FAC: (A) 2. Total Number of Dominant 3. Species Across All Strata: (B) 4. Percent of Dominant Species = Total Cover That Are OBL, FACW, or FAC: (A/B) Sapling/Shrub Stratum (Plot size: ) Prevalence Index worksheet: 1. Total % Cover of: Multiply by: 2. OBL species x 1 = 3. FACW species x 2 = 4. FAC species x 3 = 5. FACU species x 4 = = Total Cover Herb Stratum (Plot size: ) UPL species x 5 = 1. Column Totals: (A) (B)

2. Prevalence Index = B/A = 3. Hydrophytic Vegetation Indicators: 4. 1 - Rapid Test for Hydrophytic Vegetation 5. 2 - Dominance Test is >50% 6. 3 - Prevalence Index is ≤3.01 7. 4 - Morphological Adaptations1 (Provide supporting 8. data in Remarks or on a separate sheet) 1 9. 5 - Wetland Non-Vascular Plants 1 10. Problematic Hydrophytic Vegetation (Explain) 1 11. Indicators of hydric soil and wetland hydrology must be present, unless disturbed or problematic. = Total Cover Woody Vine Stratum (Plot size: ) 1. Hydrophytic 2. Vegetation Present? Yes No = Total Cover % Bare Ground in Herb Stratum Remarks:

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SOIL Sampling Point: Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) Depth Matrix Redox Features (inches) Color (moist) % Color (moist) % Type1 Loc2 Texture Remarks

1Type: C=Concentration, D=Depletion, RM=Reduced Matrix, CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix. Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils3: Histosol (A1) Sandy Redox (S5) 2 cm Muck (A10) Histic Epipedon (A2) Stripped Matrix (S6) Red Parent Material (TF2) Black Histic (A3) Loamy Mucky Mineral (F1) (except MLRA 1) Very Shallow Dark Surface (TF12) Hydrogen Sulfide (A4) Loamy Gleyed Matrix (F2) Other (Explain in Remarks) Depleted Below Dark Surface (A11) Depleted Matrix (F3) Thick Dark Surface (A12) Redox Dark Surface (F6) 3Indicators of hydrophytic vegetation and Sandy Mucky Mineral (S1) Depleted Dark Surface (F7) wetland hydrology must be present, Sandy Gleyed Matrix (S4) Redox Depressions (F8) unless disturbed or problematic. Restrictive Layer (if present): Type: Depth (inches): Hydric Soil Present? Yes No Remarks:

HYDROLOGY Wetland Hydrology Indicators: Primary Indicators (minimum of one required; check all that apply) Secondary Indicators (2 or more required) Surface Water (A1) Water-Stained Leaves (B9) (except Water-Stained Leaves (B9) (MLRA 1, 2, High Water Table (A2) MLRA 1, 2, 4A, and 4B) 4A, and 4B) Saturation (A3) Salt Crust (B11) Drainage Patterns (B10) Water Marks (B1) Aquatic Invertebrates (B13) Dry-Season Water Table (C2) Sediment Deposits (B2) Hydrogen Sulfide Odor (C1) Saturation Visible on Aerial Imagery (C9) Drift Deposits (B3) Oxidized Rhizospheres along Living Roots (C3) Geomorphic Position (D2) Algal Mat or Crust (B4) Presence of Reduced Iron (C4) Shallow Aquitard (D3) Iron Deposits (B5) Recent Iron Reduction in Tilled Soils (C6) FAC-Neutral Test (D5) Surface Soil Cracks (B6) Stunted or Stressed Plants (D1) (LRR A) Raised Ant Mounds (D6) (LRR A) Inundation Visible on Aerial Imagery (B7) Other (Explain in Remarks) Frost-Heave Hummocks (D7) Sparsely Vegetated Concave Surface (B8) Field Observations: Surface Water Present? Yes No Depth (inches): Water Table Present? Yes No Depth (inches): Saturation Present? Yes No Depth (inches): Wetland Hydrology Present? Yes No (includes capillary fringe) Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:

Remarks:

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Appendix G Willamette National Forest T/E or Sensitive Species from RFSSS List 2011

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Willamette National Forest T/E or Sensitive Species from RFSSS List 2011 or ScientificName CommonName Suspected ALPOVA ALEXSMITHII FUNGUS D BOLETUS PULCHERRIMUS FUNGUS D BRIDGEOPORUS NOBILISSIMUS FUNGUS D CORTINARIUS BARLOWENSIS FUNGUS D CYSTANGIUM IDAHOENSIS FUNGUS D GASTROBOLETUS VIVIDUS FUNGUS D GYMNOMYCES FRAGRANS FUNGUS D HELVELLA CRASSITUNICATA FUNGUS D MYTHICOMYCES CORNEIPES FUNGUS D PSEUDORHIZINA CALIFORNICA FUNGUS D RAMARIA AMYLOIDEA FUNGUS D RHIZOPOGON INQUINATUS FUNGUS D BRYORIA SUBCANA LICHEN D LOBARIA LINITA LICHEN D MICROCALICIUM ARENARIUM LICHEN D PILOPHORUS NIGRICAULIS LICHEN D PSEUDOCYPHELLARIA MALLOTA LICHEN D RAMALINA POLLINARIA LICHEN D STEREOCAULON SPATHULIFERUM LICHEN D THOLURNA DISSIMILIS LICHEN D ANASTROPHYLLUM MINUTUM LIVERWORT D BARBILOPHOZIA LYCOPODIOIDES LIVERWORT D CALYPOGEIA SPHAGNICOLA LIVERWORT D HAPLOMITRIUM HOOKERI LIVERWORT D HARPANTHUS FLOTOVIANUS LIVERWORT D JUNGERMANNIA POLARIS LIVERWORT D LOPHOZIA LAXA LIVERWORT D MARSUPELLA EMARGINATA VAR. AQUATICA LIVERWORT D SCHOFIELDIA MONTICOLA LIVERWORT D TRITOMARIA EXSECTIFORMIS LIVERWORT D BRYUM CALOBRYOIDES MOSS D SCHISTOSTEGA PENNATA MOSS D TOMENTYPNUM NITENS MOSS D TREMATODON ASANOI MOSS D Documented Species OPHIOGLOSSUM PUSILLUM ADDER'S-TONGUE D CAREX SCIRPOIDEA SSP. STENOCHLAENA ALASKAN SINGLE-SPIKED SEDGE D LYCOPODIELLA INUNDATA BOG CLUB-MOSS D CALAMAGROSTIS BREWERI BREWER'S REEDGRASS D ILIAMNA LATIBRACTEATA CALIFORNIA GLOBE-MALLOW D POLYSTICHUM CALIFORNICUM CALIFORNIA SWORD-FERN D CORYDALIS AQUAE-GELIDAE COLD-WATER CORYDALIS D LEWISIA COLUMBIANA VAR. COLUMBIANA COLUMBIA LEWISIA D EUCEPHALUS GORMANII GORMAN'S ASTER D LYCOPODIUM COMPLANATUM GROUND CEDAR D ARABIS HASTATULA HELLS CANYON ROCKCRESS D UTRICULARIA MINOR LESSER BLADDERWORT D CAREX DIANDRA LESSER PANICLED SEDGE D BOTRYCHIUM MONTANUM MOUNTAIN GRAPE-FERN D GENTIANA NEWBERRYI VAR. NEWBERRYI NEWBERRY'S GENTIAN D UTRICULARIA OCHROLEUCA NORTHERN BLADDERWORT D CAREX LIVIDA PALE SEDGE D SCHEUCHZERIA PALUSTRIS SSP. AMERICANA SCHEUCHZERIA D 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM

HIERACIUM HORRIDUM SHAGGY HAWKWEED D LATHYRUS HOLOCHLORUS THIN-LEAVED PEAVINE D ROMANZOFFIA THOMPSONII THOMPSON'S MISTMAIDEN D POA RHIZOMATA TIMBER BLUEGRASS D CICENDIA QUADRANGULARIS TIMWORT D FRASERA UMPQUAENSIS UMPQUA SWERTIA D POTENTILLA VILLOSA VILLOUS CINQUEFOIL D SCHOENOPLECTUS SUBTERMINALIS WATER CLUBRUSH D RHYNCHOSPORA ALBA WHITE BEAKRUSH D PINUS ALBICAULIS WHITEBARK PINE D CHOIROMYCES VENOSUS FUNGUS S RAMARIA SPINULOSA VAR. DIMINUTIVA FUNGUS S RHIZOPOGON EXIGUUS FUNGUS S STAGNICOLA PERPLEXA FUNGUS S ANTHELIA JULACEA LIVERWORT S BLEPHAROSTOMA ARACHNOIDEUM LIVERWORT S CEPHALOZIELLA SPINIGERA LIVERWORT S GYMNOMITRION CONCINNATUM LIVERWORT S HERBERTUS ADUNCUS LIVERWORT S MARSUPELLA CONDENSATA LIVERWORT S MARSUPELLA SPARSIFOLIA LIVERWORT S NARDIA JAPONICA LIVERWORT S ANDREAEA SCHOFIELDIANA MOSS S CONOSTOMUM TETRAGONUM MOSS S ENCALYPTA BREVICOLLIS MOSS S ENCALYPTA BREVIPES MOSS S ENTOSTHODON FASCICULARIS MOSS S HELODIUM BLANDOWII MOSS S POLYTRICHUM SPHAEROTHECIUM MOSS S SPLACHNUM AMPULLACEUM MOSS S TETRAPHIS GENICULATA MOSS S

Suspected Species AGOSERIS ELATA TALL AGOSERIS S ARNICA VISCOSA SHASTA ARNICA S ASPLENIUM SEPTENTRIONALE GRASS-FERN S BOTRYCHIUM PUMICOLA PUMICE GRAPE-FERN S CAREX CAPITATA CAPITATE SEDGE S CAREX LASIOCARPA VAR. AMERICANA SLENDER SEDGE S CAREX VERNACULA NATIVE SEDGE S COPTIS TRIFOLIA THREE-LEAF GOLDTHREAD S ELATINE BRACHYSPERMA SHORT SEEDED WATERWORT S EUCEPHALUS VIALIS WAYSIDE ASTER S PELLAEA ANDROMEDIFOLIA COFFEE FERN S ROTALA RAMOSIOR LOWLAND TOOTHCUP S SISYRINCHIUM SARMENTOSUM PALE BLUE-EYED GRASS S WOLFFIA BOREALIS DOTTED WATER-MEAL S WOLFFIA COLUMBIANA COLUMBIA WATER-MEAL S Notes: Species documented in the North Santiam watershed are bolded 20140416-5027 FERC PDF (Unofficial) 4/15/2014 9:29:06 PM Document Content(s) WhitewaterHydroRSP.PDF...... 1-351