Lake Clementine Hydro, Llc

LAKE CLEMENTINE HYDRO, LLC

October 17, 2014

Ms. Kimberly Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426

Subject: Lake Clementine Project (FERC Project No. 13432) Completion of First Stage Consultation and Study Plans to Prepare License Application

Dear Secretary Bose:

Lake Clementine Hydro, LLC (LCH) has completed First Stage Consultation for the Lake Clementine Hydroelectric Project, Federal Energy Regulatory Commission (FERC) Project No. 13432 (Project), as required by 18 CFR §4.38 for the Traditional Licensing Process. This filing contains: • Summarized comments and recommendations received during First Stage Consultation activities; • LCH’s responses to the comments and recommendations; and • Study plans for individual resources that LCH will implement to collect information necessary to prepare the Project license application. An initial Preliminary Permit for the Project was issued on October 29, 2009. On August 30, 2010, LCH filed a Pre-Application Document and a Notice of Intent to file a license application with a request to use the Traditional Licensing Process. FERC approved the Traditional Licensing Process on October 10, 2010. LCH held a site visit and joint agency and public meeting on December 12, 2010.

FERC issued a subsequent Preliminary Permit to LCH on March 21, 2013. On March 12, 2014, LCH held a site visit and joint agency and public meeting to update stakeholders on current Project plans. LCH distributed an applicant-prepared scoping document and a set of draft resource study plans to agencies and stakeholders for review and comment. LCH received comments on the study plans from the following entities: The Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission October 17, 2014 Page 2

Commenting Agency or Stakeholder Date of Letter State Water Resources Control Board May 30, 2014

National Marine Fisheries Service June 10, 2014 State Water Resources Control Board June 25, 2014 California Department of Fish and Wildlife June 26, 2014 California Department of Parks and Recreation June 27, 2014 Bureau of Reclamation June 28, 2014

Auburn Boat Club July 1, 2014

LCH addressed the comments received in the above letters, revised the study plans, and redistributed the study plans to agencies for an additional review and comment period. Comments were received from the following agencies and except comments transmitted via email from the California Department of Parks and Recreation to LCH, all of the comment letters were filed with the Conmiission.

Commenting Agency or Stakeholder Date of Letter

State Water Resources Control Board October 1, 2014

National Marine Fisheries Service October 1, 2014 California Department of Fish and Wildlife September 25, 2014 California Department of Parks and Recreation October 3, a2014 National Park Service October 6, 2014 a This comment letter was not filed with the Commission and is enclosed.

A summary of all comments and recommendations and LCH’s responses are attached.

In response to the comments received, LCH developed or revised the following study plans, which are attached:

Water Quality Study Plan (WR-S 1) Amphibian and Reptile Study Plan (TR-2) Water Quantity Study Plan (WR-S2) Wildlife Study Plan (TR-3) Sediment Transport Study Plan (WR-S3) Recreation Resources Study Plan (RR-1) Fisheries Study Plan (AQ-1) Visual and Aesthetic Resources Study Plan (RR-2) Fish Entrainment Study Plan (AQ-2) Socioeconomic Resources Study Plan (RR-3)

Special-Status and Invasive Plant Study Plan (TR- 1) Cultural and Historic Properties Study Plan (CR-i)

LCH is ready to begin collecting resource information for developing the Project license application. However, study plan implementation is contingent on receiving permits and

Lake Ctementine Hydro, LLC

46 PeninsuLaCenter, Suite E RoLLingHiLLsEstates I CA90274 I USA The Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission October 17, 2014 Page 3 permission for site access from the U.S. Army Corps of Engineers and Bureau of Reclamation. In spite of LCH’s efforts during the last 6 months to obtain permits and permission for site access, it does not appear that these items will be received in time to collect meaningful data in 2014. Assuming the needed permits and permission for site access are received in the near ftture, the studies will be implemented in 2015, allowing for only one study season for most resource studies.

If you have any questions or require additional information, please contact Mr. Daniel Parker, Project Manager at (315) 261-2158 or [email protected].

Sincerely,

Jean Roy Magnus Johannesson Vice President;dperations Director, Project Development Lake Clementine Hydro, LLC Lake Clementine Hydro, LLC

Guy J. Paquette Vice President, Corporate and Legal Affairs Lake Clementine Hydro, LLC

Enclosures: Revised Study Plans Comments on study plans from California Department of Parks and Recreation Responses to Study Plan Comments

Lake CLementine Hydro, LLC

46 PeninsuLaCenter, Suite EI RoLLingHilLsEstates I CA90274 I USA

Lake Clementine Project Revised Study Plans

Lake Clementine Hydroelectric Project, FERC No. 13432 Water Quality Study Plan

WR-1

WATER QUALITY STUDY PLAN

October 17, 2014

STUDY GOAL AND OBJECTIVE The Lake Clementine Hydroelectric Project (Project) Pre-Application Document (PAD), filed August 2010, identified issues associated with water quality for which the existing, relevant, and reasonably available information is insufficient to address the issues.

These issues are:

Issue: Project effects on reservoir water temperature and dissolved oxygen (DO) stratification.

Issue: Project effects on water temperature and DO in Lake Clementine and downstream of North Fork Dam.

Issue: Available water quality data are insufficient to describe water quality under existing conditions that may be influenced by the proposed Project.

Issue: Supersaturated levels of dissolved gases can have adverse effects on fish. Diverting water through the proposed powerhouse would reduce flows over the spillway and may reduce total dissolved gas (TDG) levels downstream of the dam. Without baseline data on TDG, it would be unclear if this could represent a beneficial Project effect.

Issue: Adequate information regarding ambient levels of water constituents is not available.

The goal of this study is to develop the essential information necessary to supplement existing information addressing the identified issues. In this case, the objectives of this study are to describe existing conditions and analyze the potential for change to the existing conditions as a result of Project construction and operation. This information would also be used to determine if the Project will comply with the water quality criteria described in The Water Quality Control Plan (Basin Plan) for the California Regional Water Quality Control Board Central Valley Region, Fourth Edition, The Sacramento River Basin and the San Joaquin River Basin (Basin Plan). The information will also be used to determine the need for mitigation measures to protect beneficial uses and aquatic resources of the North Fork of the American River (NFAR). Additionally, this information would be used in LCH’s application to the State Water Resources Control Board for water quality certification for the Project.

Specifically the study objectives are to:

 Characterize existing water quality in NFAR upstream of Lake Clementine, in Lake Clementine, and in NFAR downstream of North Fork dam.  Identify the DO and temperature profiles near the dam and the proposed intake structure.  Identify any seasonal or temporal variations in DO concentration and water temperature.  Identify and describe the timing of reservoir stratification.  Describe DO and water temperature in the NFAR immediately upstream of Lake Clementine and immediately downstream of the dam and powerhouse location.

EXISTING INFORMATION The Project would be located at Lake Clementine adjacent to North Fork Dam on the NFAR in Placer County, California. Lake Clementine, which was formed by the North Fork debris dam constructed in 1939, is now owned by the U.S. Army Corps of Engineers (USACE). Lake Clementine has a surface area of 280 acres, a capacity of 14,700 acre-feet, and is approximately 3.5 miles (mi) long. The dam rises 155 feet (ft) above the lowest foundation and has a spillway crest elevation of 715 ft. The dam crest length is 620 ft and the thickness varies from 22 ft at the base to 6.8 ft at the top.

The proposed Project would consist of an intake near the left abutment of North Fork Dam, an open canal, and one or two penstocks connecting to a powerhouse that would house two or three generating units, totaling a combined capacity of 16 megawatts. The powerhouse would be located between 200 and 600 ft downstream of the dam. Construction of the intake, canal, and penstock intakes would require excavating the slope on the south side of the canyon adjacent to the dam. A switchyard consisting of a station generator bus, station service transformer, a step-up transformer, and circuit breaker would be located at an elevation above the high flood flow elevation of the NFAR near the powerhouse or in a room of the powerhouse building. A 60- kilovolt transmission line would be constructed to connect the switchyard with Pacific Gas and Electric’s Halsey Substation. The exact location of the transmission line has not been determined at this time. Two alternative access routes are being considered for Project construction. One access route option would entail reconstructing a 2.5-mile-long access road on the south side of the NFAR between Old Foresthill Road and North Fork Dam. The route would follow the alignment of an abandoned dirt road that is currently used as a hiking and biking trail. After construction is completed, the road either could be removed and the site restored or could remain in place to serve another purpose, such as an emergency access or a recreation trail. The second access route under consideration would use the existing Lower Lake Clementine Road. This route would require making upgrades to accommodate construction equipment and traffic. In addition, improving and using this road for Project construction would likely require traffic controls to ensure public safety and facilitate construction activities. The proposed Project would operate in a run-of-river mode with flows coming into Lake Clementine being equal to flows going out of Lake Clementine.

Limited historical data about water quality related to the Project-affected Area are available. Available information for Lake Clementine is outdated (i.e., 1977 and 1979). Data reported for the NFAR downstream of North Fork Dam are for the period from late August to early September 2008. No TDG measurements have been collected downstream of North Fork Dam; however, at other projects with similar designs, higher TDG levels have been observed in spillway plunge pools. Additional information exists from Placer County Water Agency’s relicensing study reports for the Middle Fork of the American River Project (FERC Project No. 2079) (http://relicensing.pcwa.net/html/filings/filings_dla.php). Information is contained in the License Application, Volume 3, Exhibit E – Environmental Exhibit, Appendices, and Supporting Documents A, B, and C. This volume contains the final technical study reports for the aquatic- related licensing studies. The federally approved and state-approved Basin Plan designates the beneficial uses of waters to be protected and presents the water quality objectives necessary to protect those uses. The beneficial uses identified for the NFAR include municipal and domestic supply, irrigation, water contact recreation, non-contact water recreation, canoeing and rafting, cold-water habitat, cold- water spawning, and wildlife habitat. Warm freshwater habitat is listed as a potential beneficial use.

NEXUS BETWEEN PROJECT AND RESOURCE TO BE STUDIED AND HOW THE RESULTS WILL BE USED Project construction could temporarily affect water quality in the vicinity of the construction activities. Project operation is not expected to adversely affect water quality in Lake Clementine or the NFAR downstream of the powerhouse tailrace. Because the Project would divert a portion of the spillway flow, the reach between North Fork Dam and the powerhouse tailrace would have reduced flow and, therefore, Project operations may affect water quality in this reach. Without current baseline water quality data for Project-affected waters, it is not possible to determine whether or not waters would be affected by the Project. This study will report data to document baseline conditions; assess potential Project effects; and if necessary, determine protection, mitigation, and enhancement measures to address any such effects and post-construction monitoring requirements.

STUDY AREA AND STUDY SITES Location of project components has been selected. However, since study results may impact final location of project components the study area includes the maximum extent of Project effects.

The study area includes Lake Clementine and four locations on the NFAR including one station immediately upstream of Lake Clementine, one station in the spillway plunge pool, one station located downstream of the powerhouse tailrace location, and one location upstream of the confluence with the Middle Fork of the American River. Water quality data will also be collected at one location in Lake Clementine near the proposed location of the intake in the vicinity of the dam. Data collected will provide documentation of existing water quality conditions of water entering Lake Clementine, in Lake Clementine, and downstream of Lake Clementine. The State Water Resources Control Board, California Department of Fish and Wildlife (CDFW), and National Marine Fisheries Service will be invited to participate in study site selection.

METHODOLOGY Water Temperature and Dissolved Oxygen Consideration was given to placing in-situ temperature recorders at all monitoring locations to record water temperatures on 15-minute intervals and stored as hourly-average values. Based on comments received from agencies on April 25, 2014 and May 12, 2014, in-situ recorders will only be placed at the upstream and downstream river locations. Redundant recorders will be placed at the following sites: in the river upstream of the lake, downstream of the dam in the spillway plunge pool, downstream of the powerhouse tailrace location, and the location upstream of the confluence with the Middle Fork of the American River. Data will be recovered from recorders every 30 days or less. DO readings will be taken at the river locations each time temperature data are recovered. Additional DO data will be collected daily for two 1-week periods in 2 consecutive years. The first 1-week period will be in September 2014 during low flows. The second 1-week period will be in December 2014. Sampling in 2015 will take place at approximately the same dates as the 2014 sampling.

In Lake Clementine, water temperature and DO profiles will be taken every 30 days beginning in 2014 as soon as permits are received from USACE, and continue until reservoir temperature stratification breaks down. Study implementation in 2015 will depend on the timing and amount of spring runoff but will begin no later than June 1 and continue until reservoir temperature stratification breaks down. The profile will be measured beginning 3 ft below the surface, continuing at 3-ft intervals to 3 ft from the bottom of the reservoir. Appropriate quality control measures will be used to verify measurements, including taking measurements consistently within 1 hour of the same time on each day.

Because water temperature below the Project is expected to be similar to reservoir surface water temperatures, water temperature modeling is not necessary. Water temperature and DO measurements will be used to establish the baseline condition required for determining if the Project is in compliance with the Basin Plan criteria.

Water Quality Constituents In addition to water temperature LCH will collect grab samples for analytical laboratory testing at the reservoir sampling point at three depths: just below the water surface, at mid-depth of the proposed intake, and about 3 ft from the bottom of the reservoir using a standard depth-sampler deployed from a boat. Grab samples for analytical laboratory testing will be collected during the June, July, August, November, and December water temperature and DO profile measurements. Grab samples will also be collected at the one upstream and three downstream water quality monitoring stations in June, July, August, November, and December when water temperature data are being downloaded from the continuously recording water temperature units.

Analysis of the grab samples will include:  total organic carbon;  dissolved organic carbon;  total dissolved solids;

 total suspended solids;  pH;  specific conductance;  turbidity;

 total alkalinity (as CaCo3);  total hardness;  calcium;  magnesium;  potassium;  sodium;  chloride;  arsenic (total and dissolved);  cadmium (total and dissolved  iron (total and dissolved);  lead (total and dissolved);  mercury (total);  methylmercury (total and dissolved);  selenium;  silver (total and dissolved);  zinc (total and dissolved);  nitrate and nitrite;  total ammonia;  total Kjeldahl nitrogen;  total phosphorus  dissolved orthophosphorus; and  water clarity as measured by Secchi disc (at Lake Clementine station). All grab samples will be collected into laboratory-supplied clean containers. Water chemistry samples to be analyzed for metals will be taken using methods consistent with the U.S. Environmental Protection Agency’s (EPA’s) Method 1669 (EPA 1996). The most recent editions of the approved methods shall be used. Samples requiring filtration before metals analysis will be filtered in accordance with standard protocols. For quality assurance, two field blanks (one at a riverine and one at a reservoir sampling station) and one equipment blank will be collected and

submitted to the laboratory for analysis. A field blank is a sample of analyte-free water poured into the sampling device (if different than the sample container), then into a sample container in the field, preserved and shipped to the laboratory with samples; this field blank assesses the contamination from field conditions during sampling. An equipment blank is a sample of analyte-free water poured over or through decontaminated field sampling equipment prior to the collection of samples; this sample assesses the adequacy of the decontamination processes. In addition, two field replicates will be collected—one at a riverine sampling station and one at a reservoir sampling station. These samples provide a measure of the precision of the entire sampling and laboratory analysis process.

TDG will be measured at the two stations downstream of the dam using a TDG sensor such as those available from Hydolab or Eureka 2. TDG measurements will be taken when temperature data downloads occur in June, July, August, November, and December.

CDFW staff requested that field crews record incidental observations of didymo (Didymosphenia geminate) and collect samples for laboratory confirmation. In response to this request, field crews will be directed to record observations of suspected didymo populations and collect samples for laboratory confirmation by CDFW.

ANALYSIS Analysis of data to assess Project effects will also consider the results of the Water Quantity Study.

Temperature and DO data will be compiled into a Microsoft Excel spreadsheet with graphical summaries. A report will be prepared that describes the sampling activities, measurement locations, temperature profiles, DO profiles, and a summary of results. The results of the water quality analysis will be compared to applicable state and federal objectives and standards.

CONSISTENCY WITH GENERALLY ACCEPTED SCIENTIFIC PRACTICE The proposed study methods are consistent with standard methodologies for measuring water quality parameters in water bodies to determine Project effects on water quality.

PRODUCTS Technical memoranda will be prepared following each of the 3 water quality constituent sampling efforts, including all data collected up to that point. The technical memoranda will describe field conditions at the time and date of data collection, any problems encountered, and present raw data. Each report will be made available to stakeholders on the Project website.1

After completion of the study a final report will be prepared summarizing the technical memoranda and providing an analysis of the data collected. After review of the results and

1 www.lakeclementinehydro.com

consultation with the stakeholders, this study may be continued in 2015. The same schedule and effort employed in 2014 would be followed unless modified during stakeholder consultation.

Study results will be summarized in Exhibit E of the License Application.

RELATIONSHIP TO OTHER STUDIES (OPTIONAL) Results from the Water Quantity Study will provide the historical hydrology record and a flow duration curve needed to determine the approximate periods of Project operation. Results from the Sediment Transport Study will provide information regarding sediment deposits in the vicinity of the Project intake. Study results will also identify whether there are contaminants in the sediment that could affect downstream water quality if Project operation were to cause sediment mobilization.

SCHEDULE Water quality data collection will begin in spring 2015 and continue until the reservoir temperature stratification breaks down, which is expected to occur in late fall.

Implementation of studies is dependent on receiving required permissions and permits from the U.S. Army Corps of Engineers.

LEVEL OF EFFORT AND COST Costs are to be determined.

REFERENCES EPA (U.S. Environmental Protection Agency). 1996. Method 1669: Sampling Ambient Water for Trace Metals at EPA Water Quality Criteria Levels. U.S. Environmental Protection Agency, Office of Water, Engineering and Analysis Division, Washington, DC.

Map of the Project showing a 0.5-mi radius around the proposed powerhouse location, the alternative access (shown as dashed lines) routes under consideration, and the transmission line study corridor (shown as a shaded polygon).

WR-2

WATER QUANTITY STUDY PLAN

October 17, 2014

STUDY GOAL AND OBJECTIVE The Lake Clementine Hydroelectric Project (Project) Pre-Application Document (PAD), filed August 2010, identified issue(s) associated with water resources for which the existing, relevant, and reasonably available information is insufficient to address the issue(s) (America Renewable 2010). These issues are:

Issue The Project would be designed to operate in a run-of-river mode, requiring an understanding of historical flow patterns and magnitudes.

Issue Project operations would reduce the volume of flow over the spillway and pass it through the proposed powerhouse. Historic data would be used to evaluate the effects of this change in regard to aesthetic flow releases over the spillway (Visual and Aesthetic Resources Study Plan [RR-2]).

The goal of this study is to develop the essential additional information necessary to supplement the existing information to address the identified issue(s). In this case, the study is to compile historic data regarding river flows for use in assessing run-of-river operations and will also be used for the Visual and Aesthetic Resources Study Plan (RR-2).

EXISTING INFORMATION The Project would be located at Lake Clementine adjacent to North Fork Dam on the NFAR in Placer County, California. Lake Clementine, which was formed by the North Fork debris dam constructed in 1939, is now owned by the U.S. Army Corps of Engineers. Lake Clementine has a surface area of 280 acres and a capacity of 14,700 acre-feet. It rises 155 feet (ft) above the lowest foundation and has a spillway crest elevation of 715 ft. The dam crest length is 620 ft and the thickness varies from 22 ft at the base to 6.8 ft at the top.

Two alternative access routes are being considered for Project construction. One access route would entail reconstructing a 2.5-mile-long access road on the south side of the NFAR between the Old Foresthill Road and North Fork Dam. The route would follow the alignment of an abandoned dirt road that is currently used as a hiking and biking trail. After construction is completed, the road either could be removed and the site restored or could remain in place to serve another purpose, such as an emergency access or a recreation trail. The second access route would use the existing Lower Lake Clementine Road. This route would require making upgrades to accommodate construction equipment and traffic. In addition, improving and using this road for Project construction would likely require traffic controls to ensure public safety and to facilitate construction activities. The proposed Project would operate in a run-of-river mode with flows coming into Lake Clementine being equal to flows going out of Lake Clementine.

NEXUS BETWEEN PROJECT AND RESOURCE TO BE STUDIED AND HOW THE RESULTS WILL BE USED The NFAR passes through Lake Clementine and over the existing dam spillway. A portion of the natural flow would pass through the proposed Project powerhouse to generate electricity. The study would gather data for this river from the U.S. Geological Survey (USGS) website database. The information will be used to describe the baseline conditions of the NFAR downstream of North Fork Dam. This information will be used when assessing Project effects on water quality, beneficial uses of the river, and aesthetic resources. The information may also be used to assess Project effects on recreation.

STUDY AREA AND STUDY SITES The study would use data from the existing USGS gaging station located 50 feet upstream from North Fork Dam (No. 11427000, North Fork American River at North Fork Dam, CA) available on the USGS website.

METHODS Data will be downloaded from the USGS website and compiled for use in describing existing conditions and assessing Project effects. Data gathered will include average daily water stage and flow information for each day in the period of record from October 1, 1941, to September 30, 2013. Data obtained will also include select statistical average daily and monthly flow data for the period of record (mean flow, minimum flow and the date it occurred, maximum flow and the date it occurred) to provide an updated replacement to Table 3.2-1 of the PAD (America Renewables 2010). Also for the period of record, the average of the daily values will be provided (e.g., average of flows on January 1 for x years, January 2, and so forth). All data will be provided in tabular form and in Microsoft Excel files. Annual and monthly flow exceedance data will be provided for the period of record and new monthly flow duration curves for the gage to replace the annual and monthly flow duration curves (Figures 3.2-1 through 3.2-13) provided in the PAD will be provided. In addition, 15-minute stage and flow data for the gage for the period from October 1, 2007, through September 30, 2013, will be compiled in an Excel file.

ANALYSIS The scope of the study only requires the collection and compilation of existing data.

CONSISTENCY WITH GENERALLY ACCEPTED SCIENTIFIC PRACTICE The proposed methods are consistent with standard methodologies for collecting and compiling water flow and stage information for the evaluation of Project effects.

PRODUCTS The updated tables and figures to replace the PAD tables and figures will be presented in Microsoft Word for inclusion in the Application for Initial License, Exhibit E. The required daily data will be provided in Microsoft Excel files. All statistical information provided should be provided in tables in Microsoft Word format.

RELATIONSHIP TO OTHER STUDIES The data gathered for the study may also be used in the Visual and Aesthetic Resources Study Plan (RR-2); Water Temperature and Dissolved Oxygen Assessment Study Plan (WR-1); and aquatic resources studies (Fisheries Study Plan [AQ-1] and Fish Entrainment Study Plan [AQ- 2]).

SCHEDULE The data can be gathered at any time from the USGS website. The results would be available by June 2015 for use in the Visual and Aesthetic Resources Study (RR-2).

LEVEL OF EFFORT AND COST Costs are to be determined.

REFERENCES USGS website. Available at: waterdata.usgs.gov.

America Renewables. 2010. Lake Clementine Hydropower Project, FERC Project No. 13432, Pre-Application Document. America Renewables, Rolling Hills Estates, CA. August 2010.

WR-3

SEDIMENT TRANSPORT STUDY PLAN

October 17, 2014

STUDY GOAL AND OBJECTIVE The Lake Clementine Hydroelectric Project (Project) Pre-Application Document (PAD), filed August 2010, identified an issue associated with geology and soils for which the existing, relevant, and reasonably available information is insufficient to address the issue(s). This issue is:

Issue: The effects of Project construction and operation on turbidity and sediment resuspension, including potentially toxic chemicals.

The sediment transport study will provide the required data to evaluate the potential for mobilizing sediment near the dam and sediment entrainment into the powerhouse intake structure. The study objectives are to:

1. Calculate velocity at the intake structure and estimate the potential velocity field generated by the intake structure during different operational conditions over the expected range of flows (100 to 1,574 cubic feet per second [cfs]). This velocity field will be used in assessing the potential for sediment mobilization in the area of the project intake; 2. Evaluate the potential for the intake structure to mobilize and entrain sediment off the bottom of the lake given estimated velocities; 3. Assess whether or not sediment that would otherwise deposit in the lake could become entrained due to the intake structure and increase sedimentation downstream in the North Fork American River (NFAR); 4. Evaluate the grain size distribution and contaminant levels in sediments near the intake structure; and 5. Determine whether construction would disturb contaminated sediments, and if so, determine appropriate mitigation.

EXISTING INFORMATION The Project would be located at Lake Clementine adjacent to North Fork Dam on the NFAR in Placer County, California. Lake Clementine, which was formed by the North Fork debris dam constructed in 1939, is now owned by the U.S. Army Corps of Engineers. Lake Clementine has a surface area of 280 acres and a capacity of 14,700 acre-feet. It rises 155 feet (ft) above the lowest foundation and has a spillway crest elevation of 715 ft. The dam crest length is 620 ft and the thickness varies from 22 ft at the base to 6.8 ft at the top.

The proposed Project would consist of an intake near the left abutment of North Fork Dam, an open canal, and one or two penstocks connecting to a powerhouse that would house two or three generating units, totaling a combined capacity of 16 megawatts. The powerhouse would be located between 200 and 600 ft downstream of the dam. Construction of the intake, canal, and penstock intakes would require excavating the slope on the south side of the canyon adjacent to the dam. A switchyard consisting of a station generator bus, station service transformer, a step-up transformer, and circuit breaker would be located at an elevation above the high flood flow elevation of the NFAR near the powerhouse or in a room of the powerhouse building. A 60- kilovolt transmission line would be constructed to connect the powerhouse switchyard with Pacific Gas and Electric’s Halsey Substation. The exact location of the transmission line has not been determined at this time. Two alternative access routes are being considered for Project construction. One access route would entail reconstructing a 2.5-mile-long access road on the south side of the NFAR between the Old Foresthill Road and North Fork Dam. The route would follow the alignment of an abandoned dirt road that is currently used as a hiking and biking trail. After construction is completed, the road either could be removed and the site restored or could remain in place to serve another purpose, such as an emergency access or a recreation trail. The second access route would use the existing Lower Lake Clementine Road. This route would require making upgrades to accommodate construction equipment and traffic. In addition, improving and using this road for Project construction would likely require traffic controls to ensure public safety and to facilitate construction activities. The proposed Project would operate in a run-of-river mode with flows coming into Lake Clementine being equal to flows going out of Lake Clementine.

Historically, placer mining occurred upstream of North Fork Dam. Measurements in nearby water bodies, such as the Middle Fork American River, indicate that mercury levels in some sediments are higher than applicable screening criteria. This could be the case for sediments in Lake Clementine. Dredged sediments from gold mining activities in the American River watersheds caused the bed of the river to rise more than 20 ft in some areas, exacerbating flooding in Sacramento, California. The purpose of creating North Fork Dam was to contain sediments to keep it from moving downstream. Therefore, elements, such as mercury, are likely present in sediments within the reservoir. No data exist for parameters such as mercury or the nature of sediments in proximity to North Fork Dam. This study will provide this information.

NEXUS BETWEEN PROJECT AND RESOURCE TO BE STUDIED AND HOW THE RESULTS WILL BE USED The Project will be located at the North Fork dam on the NFAR in Placer County, California. As noted above, Lake Clementine was formed by the construction of a debris dam in 1939. The Project would modify the existing debris dam that was constructed in 1939 to accommodate electric power generation.

The proposed hydropower Project intake would not be designed to prevent suspended sediment that is mobilized during normal or flood conditions from passing through the hydropower facilities. Suspended sediment that does not settle out currently passes over the dam’s spillway. The intake would move a portion of the water, along with any suspended sediment that would otherwise flow over the dam via the existing spillways, through the intake structure to the proposed powerhouse. Suspended sediment would be transported to the NFAR downstream through the powerhouse tailrace, maintaining current sediment transport budget and dynamics.

Sediment mobilization and entrainment have the potential to increase sedimentation downstream. The California Gold Rush and associated activities, which included the widespread use of elemental mercury to separate gold from other river sediments, severely affected all three forks of the American River watershed. As a result, mercury, methylmercury and other contaminants have been detected in the Middle Fork American River and other western Sierra Nevada rivers, and it is likely that these constituents are in the NFAR watershed as well. Because the sediments could contain elevated concentrations of mercury, resuspension of sediments by construction or operation of the Project could increase the flux of mercury contaminants and sediment into downstream portions of the NFAR, potentially resulting in increased mercury exposure of aquatic biota.

The information developed by this study will serve as a basis to determine whether the Project will comply with the water quality criteria described in The Water Quality Control Plan (Basin Plan) for the California Regional Water Quality Control Board Central Valley Region, Fourth Edition, The Sacramento River Basin and the San Joaquin River Basin. The information will also be used to determine the need for mitigation measures to obtain compliance, if it is not in compliance, and to protect beneficial uses and aquatic resources of the NFAR.

STUDY AREA AND STUDY SITES The study area includes the part of Lake Clementine near the location of the proposed hydropower intake structure.

METHODS A stepwise approach will be used to evaluate Project-related sediment transport issues. The initial step will be a first order screening approximation technique using available information and well-established river hydraulics and fluvial geomorphology principles. If the results from the screening level assessment do not indicate a significant change in reservoir velocities and associated sediment transport dynamics, no further technical analysis will be deemed necessary. However, if results from the first order screening assessment suggest substantial changes in reservoir velocities and sediment transport dynamics due to Project operations, the following tasks will be undertaken. Lake Clementine Hydro, LLC (LCH), will use a three-dimensional (3- D) hydrodynamic modeling approach to accurately model conditions with a surface intake in a deep pool. LCH may also use the model to further refine the Project design. The following text describes the methods that will be used for the first order screening. However, much of the information collected in the field would need to be collected whether or not 3-D modeling is used in the future (i.e., grain size of sediments and contaminant testing).

A qualitative and quantitative first order screening level assessment will be conducted to evaluate the potential magnitude of the Project’s ability to mobilize and entrain sediment. The water velocities slope and other physical factors that are responsible for mobilizing and transporting the range of river sediment particle sizes (large boulders to fine clays) is well established in the field of fluvial geomorphology. This information will be used to evaluate the Project’s effects on altering the sediment transport dynamics in Lake Clementine. The velocities will be evaluated at different operational conditions (100 cfs to 1,574 cfs). Velocity in the water column and on the lake bottom is a function of depth and distance from the intake structure. Velocities at Lake Clementine will be evaluated based on typical velocity profiles identified in literature or through the assessment of studies at other lakes with similar conditions. If a lake with hydropower facilities similar to those proposed at Lake Clementine can be identified, velocities profiles could be taken for comparison and to provide insight into potential velocities at Lake Clementine.

To evaluate the potential of sediment mobilization near the intake, a better understanding of the grain size distribution will be required. Bulk samples will be taken from near the proposed intake and analyzed using sieve/hydrometer methodology for very fine sediment. Bulk samples of sediment will also be tested for mercury and other heavy metals using established U.S. Environmental Protection Agency methodology. Following the grain-size distribution analysis, the critical shear stress required to mobilize sediment at the bottom of the lake can be calculated.

Sediment sampling of the lake will consist of collecting bulk sediment samples using an Ekman dredge, testing for priority pollutant metals (i.e., mercury, methylmercury, arsenic, and cadmium), and conducting grain size distribution tests. Sampling will be conducted in a manner consistent with the State Water Resources Control Board mercury and metals sampling protocols for the American River.

An investigation will also be conducted to evaluate whether sediment that would otherwise deposit in Lake Clementine could become entrained through the proposed intake structure. Total suspended solid samples will be taken at three locations approaching the intake and at three depths (surface, mid-depth, and 3 ft off the bottom) at each location to provide a vertical profile near the intake structure and spillway. These vertical profiles will help to evaluate whether there are any differences in suspended sediment concentrations in the top of the water column (where water will primarily be drawn from by the proposed intake structure). Samples will be compared along the profile to evaluate whether suspended sediment concentrations in water that would be withdrawn through the intake differ from the water that typically spills over the spillway.

Regardless of whether 3-D hydrodynamic modeling is appropriate, LCH will sample sediment at the intake location by collecting bulk sediment samples using an Ekman dredge, testing for priority pollutant metals (i.e., mercury, methylmercury, arsenic, and cadmium), and conducting grain size distribution tests.

LCH will consult with resource agencies as each study phase progresses and at each point requiring a discussion of study methods. In addition technical memoranda will be prepared following each major study effort. These memoranda will describe the efforts to date, provide

4 October 17, 2014 Lake Clementine Hydroelectric Project, FERC No. 13432 ©2014, Lake Clementine Hydro, LLC Lake Clementine Hydroelectric Project, FERC No. 13432 Sediment Transport Study Plan raw data for agency analysis and interpretation, and identifying any topics requiring additional consultation with agencies.

ANALYSIS Historical and recently collected bathymetry data (using multi-beam side scan sonar) will be compared to establish sedimentation rates near the dam and the location of the intake. Comparing historic to recent bathymetry will enable an estimate of the rate of sediment deposition to be derived (e.g., ft per year) and will be useful to evaluate if and when sediment levels may become influenced by the intake. A literature search of similar hydropower projects that examined sediment transport and entrainment issues will also be conducted. If applicable, the analytical tools and results from these studies will be used to generate reasonable assumptions and to compare and contrast with the conclusions of this study.

To assess construction effects, the grain size distribution and shear stresses will be examined relative to the proposed construction techniques to assess the resuspension potential. Construction techniques may need to be implemented to limit resuspension or off site movement if it is determined to be a potential problem.

CONSISTENCY WITH GENERALLY ACCEPTED SCIENTIFIC PRACTICE Grain size analysis and sediment screening analysis for toxic chemicals are common practices used to assess potential threats to the environment from activities that may disturb sediments. Flow velocity modeling studies to determine whether altered hydraulic patterns may resuspend sediments are also commonly used. This modeling can be relatively simple, as described in this study plan, to more complex 3-D modeling, which may be used if this simple modeling suggests the potential exists for substantial resuspension of sediments.

PRODUCTS A technical memorandum will be prepared following the initial screening evaluation that documents whether or not there would likely be a significant change in reservoir velocities and associated sediment transport dynamics as a result of the proposed Project. Conclusions regarding the need to use 3-D modeling to further define flow and sediment transport dynamics will be included in this technical memorandum. If 3-D modeling is conducted, a separate technical memorandum will be prepared summarizing the results of that study. The technical memoranda will be distributed to stakeholders.

After completion of the study, including any 3-D modeling that may have been deemed appropriate, a final report will be prepared summarizing the technical memorandum and providing an analysis of the data collected.

Study results will be reported in Application for Initial License, Exhibit E.

SCHEDULE The screening study will be conducted in summer 2015. If needed, 3-D modeling would be conducted in late summer or early fall.

Implementation of studies is dependent on receiving required permissions and permits from the U.S. Army Corps of Engineers.

LEVEL OF EFFORT AND COST Costs are to be determined.

AQ-1

FISHERIES STUDY PLAN

October 17, 2014

STUDY GOAL AND OBJECTIVE The Lake Clementine Hydroelectric Project (Project) Pre-Application Document, filed August 2010, identified issues associated with fisheries for which the existing, relevant, and reasonably available information is insufficient to address the issues. These issues are:

Issue: The effects of Project construction and operation on resident fish in Lake Clementine and the North Fork American River (NFAR) downstream of the North Fork dam.

Issue: Project effects on fish habitat in bypass reach, including tailrace backwater effects.

Issue: The effects of entrainment of fish through the project turbines on fish populations in Lake Clementine and upstream reaches of the NFAR.

Issue: Project access road effects on aquatic habitat in the NFAR.

The goal of this study is to develop the essential additional information necessary to supplement existing information to address the identified issues. The primary objectives of this study are to: (1) document fish species composition, distribution, size, and relative abundance in Lake Clementine; (2) document fish species composition, distribution, size, and relative abundance in the bypass reach between North Fork Dam and the powerhouse tailrace; (3) document fish species composition, distribution, size, and relative abundance in the river downstream of the powerhouse tailrace; (4) describe fish habitats in the bypass reach of the NFAR and downstream of the powerhouse tailrace; and (5) document fish species composition, distribution, size, and relative abundance immediately upstream of Lake Clementine to represent an unaffected study control location. Results of this study will identify fish populations and aquatic habitats that may be subject to Project effects during construction and operation and may be used to plan and design the Project intake structure to minimize fish impingement and entrainment.

EXISTING INFORMATION The Project would be located at Lake Clementine adjacent to North Fork Dam on the NFAR in Placer County, California. Lake Clementine, which was formed by the North Fork debris dam constructed in 1939, is now owned by the U.S. Army Corps of Engineers. Lake Clementine has a surface area of 280 acres and a capacity of 14,700 acre-feet. It rises 155 feet (ft) above the lowest foundation and has a spillway crest elevation of 715 ft. The dam crest length is 620 ft and the thickness varies from 22 ft at the base to 6.8 ft at the top.

The proposed Project would consist of an intake near the left abutment of North Fork Dam, an open canal, one or two penstocks connecting to a powerhouse that would house two or three

generating units, totaling a combined capacity of 16 megawatts. The powerhouse would be located between 200 and 600 ft downstream of the dam. Construction of the intake, canal, and penstock intakes would require excavating the slope on the south side of the canyon adjacent to the dam. A switchyard consisting of a station generator bus, station service transformer, a step-up transformer, and circuit breaker would be located at an elevation above the high flood flow elevation of the NFAR near the powerhouse or in a room of the powerhouse building. A 60- kilovolt transmission line would be constructed to connect the powerhouse switchyard with Pacific Gas and Electric’s Halsey Substation. The exact location of the transmission line has not been determined at this time. Two alternative access routes are being considered for Project construction. One access route would entail reconstructing a 2.5-mile-long access road on the south side of the NFAR between the Old Foresthill Road and North Fork Dam. The route would follow the alignment of an abandoned dirt road that is currently used as a hiking and biking trail. After construction is completed, the road either could be removed and the site restored or could remain in place to serve another purpose, such as an emergency access or a recreation trail. The second access route would use the existing Lower Lake Clementine Road. This route would require making upgrades to accommodate construction equipment and traffic. In addition, improving and using this road for Project construction would likely require traffic controls to ensure public safety and to facilitate construction activities.

The proposed Project would operate in a run-of-river mode with flows coming into Lake Clementine being equal to flows going out of Lake Clementine.

No specific studies on temporal and spatial distribution of fish have been undertaken in Lake Clementine. However, Jones & Stokes (1998) report that the Lake Clementine fishery includes rainbow trout, smallmouth bass, green sunfish, and Sacramento sucker. Non-native fish introduced to the North and Middle Forks of the American River watersheds include brown trout, largemouth bass, brown bullhead, and green sunfish. The relatively warm temperature of Lake Clementine during the summer and fall would likely limit the presence of cold-water fish species, such as rainbow and brown trout, during this period. Hardhead, a species of concern to resource agencies, is known to occur upstream of Lake Clementine and in the adjacent watershed of the Middle Fork of the American River (Placer County Water Agency 2010, 2008).

NEXUS BETWEEN PROJECT AND RESOURCE TO BE STUDIED AND HOW THE RESULTS WILL BE USED Water is passed downstream over the dam spillway, and it is currently the only passage route for flow and fish to pass downstream over the dam. There are no other dams on the NFAR and river flow fluctuates seasonally. Since 1941, the 10 percent flow exceedance for May, the month with the highest average flow, is 2,940 cubic feet per second (cfs) (average 1,640 cfs) and low flow (average 50 cfs) occurs in September (data from USGS Gage No. 11427000, NFAR at North Fork Dam). The proposed Project would modify the existing dam water spill route to accommodate electric power generation.

Understanding the fish species that occur in Lake Clementine and their distribution and relative abundance would enable estimation of potential Project effects on fish populations from construction or operation of the proposed Project, especially those species of concern in the vicinity of the Project, such as game fish (trout and bass) and special-status species, such as hardhead. Quantitative data regarding the size of these fish will provide information to assess their susceptibility to entrainment, which will be addressed in the Study Plan AQ-2, Fish Entrainment Study Plan. Information about the fish community downstream of the dam will describe the affected environment that could be influenced by construction or operation of the Project and describe aquatic habitat downstream of North Fork Dam.

One of the access routes under consideration would involve the reconstruction and improvements to a road paralleling the NFAR between Old Foresthill Road and North Fork Dam. The potential for increased erosion and sedimentation could affect aquatic habitats in this reach.

STUDY AREA AND STUDY SITES The three primary study areas are (1) the main body of Lake Clementine, (2) NFAR between the dam and proposed Project tailrace, and (3) downstream of the tailrace discharge to the confluence with the Middle Fork of the American River. A fourth study site will be located immediately upstream of Lake Clementine to represent a study control location unaffected by Project development and operation. In Lake Clementine, gill net sampling will occur in four regions of the reservoir in both shallow-water and deep-water habitats. Four nets will be set in shallow-water habitats and four gill nets will be set in deep-water (greater than 50 feet) habitats. In addition, four gently sloping shoreline areas will be sampled using beach seines. Nighttime electrofishing surveys will be conducted along the Lake Clementine shoreline. The exact location of gill netting and beach seining stations will be determined in the field and locations documented by using Global Positioning System (GPS) units. The location of up to four riverine study sites will be determined by a team of fishery specialists consisting of staff representing Lake Clementine Hydro, LLC (LCH), and state and federal resource agencies. The location of specific study sites will be documented by using GPS units.

METHODS Fish sampling, as proposed, would include sampling at riverine study sites and in Lake Clementine.

River Sampling A reconnaissance level survey will be conducted to characterize and map fish habitats extending from the spillway plunge pool downstream to the confluence with the Middle Fork of the American River. The survey results will be used to select suitable transects for electrofishing.

In consultation with a selected technical consultant and resource agencies, LCH will evaluate various methodologies to determine the relationship between flow and fish habitat in the bypass reach between the dam and the powerhouse tailrace.

A snorkeling survey will be conducted in the 1,000-ft segment of the bypass reach downstream of the dam. Electrofishing in the three selected transects in the NFAR downstream of the dam

and in the control site upstream of Lake Clementine will be conducted to provide current information about fish populations and distribution in the study area. All river sampling will likely be conducted in August or September when flows are low. Snorkeling in late summer will improve sampling efficiency because water levels are expected to be lower, water clarity is expected at its best (post-peak flow), and a variety of age classes, including young-of-the-year fish, is likely to be present. Additionally, the anticipated warmer water temperatures at this time of year will likely increase fish movement and feeding in the water column where they will be more easily observed. Snorkeling is an efficient method to quantify fish species composition and abundance in moderately deep, clear water systems (O’Neal 2007; Dolloff et al. 1996). Advantages of this method include avoiding injury to fish because fish are not handled and having the ability to conduct sampling over a wide range of instream habitats, which are characteristic of the study area. In particular, the lengths and widths of the habitat area sampled will be recorded to calculate fish abundance by length and area of stream sampled. Sampling will be conducted during daylight periods. Two-pass snorkel surveys will be conducted in up to three pools downstream of Lake Clementine. Three to five snorkelers (depending on the width of the pool) will survey in lanes from the downstream to the upstream end of the pool and will identify, count, and estimate the length of each fish observed. Data will either be verbally communicated to the data recorder on the bank or recorded on wrist-mounted dive slates. Both passes in a pool will be conducted within 2 days to ensure comparability of data collected under similar conditions. Snorkeling protocols and field data forms will be consistent with guidelines in Flosi et al. (1998) and O’Neal (2007). When possible, larger salmonids will be identified as potential hatchery fish, based on visible fin erosion. Juvenile hardhead and Sacramento pikeminnow (less than approximately 10 inches) will be recorded as a single category—hardhead/pikeminnow guild—when identification is uncertain. Very small fish of all species that cannot be identified will be recorded as fry.

Each pool surveyed will be documented with digital photographs and geo-referenced using GPS. The physical habitat of each pool will be characterized including: the length, width, and depth of the pool at representative locations, substrate type, percent canopy cover, and any other noteworthy observations.

Data collected by electrofishing will supplement the snorkeling survey data. One or two suitable transects will be selected for electrofishing. Blocking nets will be placed up and downstream of each transect and multiple passes, a minimum of three, with an electrofishing unit will be conducted to capture all fish within each transect. The number of fish, by species, will be recorded to determine relative abundance. The length and weight of each fish will be recorded along with any observed abnormalities. Analysis will be based on Fulton’s condition factors (Ricker 1975), and the estimated number of fish per acre for the sample sites will be reported.

Reservoir Sampling Lake Clementine will be sampled four times: twice during the late summer, when the reservoir is stratified, and twice during a period when the reservoir is not stratified. Successive sampling periods will be at least 2 weeks apart during the stratified and unstratified sampling efforts. Sampling methods will include collecting fish in 150-ft-long and 6-ft-deep variable mesh gillnets

and electrofishing at night by boat. Using these methods will allow characterization of fish species composition and size range present within the reservoir.

Gill net sampling will occur concurrently at up to four deep areas (i.e., greater than 50 ft deep) of the reservoir. The deep water gill net sets will be used to collect information for characterizing near bottom fish populations located in offshore areas. These offshore sampling locations will be distributed along the length of the reservoir, including one location at the boat barrier of the dam. Nets will be set at dusk, checked at approximately 4-hour intervals, and retrieved at dawn. All fish collected will be identified, counted, weighed, and measured (total length) and the duration and mesh size of each net deployment recorded. All live fish will be held in an aerated live tank until the nets are removed and then released or transported to a distance far enough away to avoid recapture. The location of each gill net deployment will be geo-referenced by GPS for accurate mapping and also ensuring nets are deployed at approximately the same location during the stratified and unstratified sampling efforts.

An electrofishing boat will be used to sample shoreline habitats at night when some species occupy shallow-water areas. This sampling will be done to characterize smaller, shore-oriented fish that are not sampled by the deep-water gill net sets. Fish will be counted, weighed, and measured (total length). The primary purpose of the sampling will be to identify fish species composition, relative abundance, and size. When possible, wild fish and hatchery fish will be identified based on fin wear. The location of each electrofishing location will be geo-referenced by GPS for accurate mapping and also ensuring electrofishing is conducted at approximately the same location during the stratified and unstratified sampling efforts.

ANALYSIS Results will provide information about fish species in the study area. The analysis will be presented using the following metrics:

• Relative abundance (number or mass of fish caught per hour of net set) of fish species in Lake Clementine, including game fish and hardhead during stratified and unstratified lake conditions; • Size (length and weight) categories of fish species within Lake Clementine for each net mesh size; • Relative comparison of bottom near shore and bottom offshore species distribution in Lake Clementine and relative abundance during summer; • Relative comparison of fish communities in Lake Clementine during stratified and unstratified lake conditions; • Relative species composition in shallow near shore areas, particularly small fish including young-of-the-year fish, in Lake Clementine; • Distribution of species and size of fish in the vicinity of the proposed intake; and • Density (catch per unit effort), size categories, and species composition in the river study sites in the summer.

CONSISTENCY WITH GENERALLY ACCEPTED SCIENTIFIC PRACTICE The methods proposed in this study are consistent with commonly used scientific methods, as documented in the References section below.

PRODUCTS A technical memorandum will be prepared following each field effort describing the conditions at the time, observations, and providing any data collected. The purpose of the technical memorandum is to inform stakeholders of study progress and to allow them access to data as they become available.

Study results will be summarized in the Application for Initial License, Exhibit E; data gathered as part of the study will be included in a study report and included as an appendix. Study products will include a presentation to resource agency personnel and other stakeholders.

RELATIONSHIP TO OTHER STUDIES The results of this study will be used to conduct Study Plan AQ-2, Fish Entrainment Study Plan. The results of Study Plan WR-1, Water Temperature and Dissolved Oxygen Assessment Plan, will provide information to interpret the fish distribution aspects of this study and determine when the stratified and unstratified fish sampling in Lake Clementine will occur.

SCHEDULE The Lake Clementine fish sampling during reservoir stratification will occur in late summer 2015. The Lake Clementine unstratified fish sampling schedule will be determine by the results of the Water Quality Study but will likely occur in late fall 2015. Riverine fish sampling will occur in late summer 2015.

Implementation of studies is dependent on receiving required permissions and permits from the U.S. Army Corps of Engineers.

LEVEL OF EFFORT AND COST Costs are to be determined.

REFERENCES Crawford, B. 2007. Variable Mesh Gill Nets (in Lakes). Pages 425–433. In: D. Johnson et al. Salmonid Field Protocols Handbook. American Fisheries Society, Bethesda, MD. Dolloff, A., J. Kershner, and R. Thurow. 1996. Underwater Observations. Pages 533–554. In: B.R. Murphy and D. W. Willis (ed). Fisheries Techniques, 2nd Edition. American Fisheries Society, Bethesda, MD. Flosi, G., S. Downie, J. Hopelain, M. Bird, R. Coey, and B. Collins. 1998. California Salmonid Stream Restoration Manual. Third Edition. State of California. The Resources Agency, California Department of Fish and Game, Inland Fisheries Division, Sacramento, CA.

O’Neal, J.S. 2007. Snorkel Surveys. Pages 32–340. In: D. H. Johnson, B.M. Shrier, J.S. O’Neal, J.A. Knutzen, X. Augerot, T.A. O’Neil, and T.N. Pearsons. Salmonid Field Protocols Handbook: Techniques for Assessing Status and Trends in Salmon and Trout Populations. American Fisheries Society, Bethesda, MD. Jones & Stokes Associates, Inc. 1998. Environmental Information Paper North Fork Dam, American River. Placer County, California. Prepared for U.S. Army Corps of Engineers, Sacramento District, Sacramento, CA Placer County Water Agency. 2010. AQ 2: Fish Population Technical Study Report—2007– 2009. PCWA Middle Fork American River Project (FERC Project No. 2079). June 2010. Placer County Water Agency. 2008. AQ 2: Fish Population Technical Study Report—2007. PCWA Middle Fork American River Project (FERC Project No. 2079). July 2008. Ricker, W.E. 1975. Computation and Interpretation of Biological Statistics of Fish Populations. Bulletin of the Fisheries Research Board of Canada 191:1–382.

AQ-2

FISH ENTRAINMENT STUDY PLAN

October 17, 2014

Issue: The effects of entrainment of fish through the Project turbines on fish populations in Lake Clementine and upstream reaches of the North Fork American River (NFAR).

Issue: The effects of project operation on potential future efforts to restore anadromous fish to the American River Watershed.

Issue: The effects of entrainment on river otters, western pond turtle, California red- legged frog, and foothill yellow-legged frog.

The goal of this study is to estimate entrainment and survival through the project turbines of fish that inhabit Lake Clementine.

Potential entrainment of river otter will be addressed in Study Plan, TR-3,Wildlife Study Plan.

Potential entrainment of western pond turtle, California red-legged frog, and foothill yellow- legged frog will be addressed in Study Plan, TR-2, Amphibian and Reptile Study Plan.

EXISTING INFORMATION The Project would be located at Lake Clementine adjacent to North Fork Dam on the NFAR in Placer County, California. Lake Clementine, which was formed by the North Fork debris dam constructed in 1939, is now owned by the U.S. Army Corps of Engineers. Lake Clementine has a surface area of 280 acres and a capacity of 14,700 acre-feet. It rises 155 feet (ft) above the lowest foundation and has a spillway crest elevation of 715 ft. The dam crest length is 620 ft and the thickness varies from 22 ft at the base to 6.8 ft at the top.

kilovolt transmission line would be constructed to connect the powerhouse switchyard with Pacific Gas and Electric’s Halsey Substation. The exact location of the transmission line has not been determined at this time. Two alternative access routes are being considered for Project construction. One access route would entail reconstructing a 2.5-mile-long access road on the south side of the NFAR between the Old Foresthill Road and North Fork Dam. The route would follow the alignment of an abandoned dirt road that is currently used as a hiking and biking trail. After construction is completed, the road either could be removed and the site restored or could remain in place to serve another purpose, such as an emergency access or a recreation trail. The second access route would use the existing Lower Lake Clementine Road. This route would require making upgrades to accommodate construction equipment and traffic. In addition, improving and using this road for Project construction would likely require traffic controls to ensure public safety and to facilitate construction activities. The proposed Project would operate in a run-of-river mode with flows coming into Lake Clementine being equal to flows going out of Lake Clementine.

No specific studies on temporal and spatial distribution of fish have been undertaken in Lake Clementine. However, Jones & Stokes (1998) report that the Lake Clementine fishery includes trout, smallmouth bass, green sunfish, and Sacramento sucker. Non-native fish introduced to the North and Middle Forks American River watersheds include brown trout, largemouth bass, brown bullhead, and green sunfish. The relatively warm temperature of Lake Clementine during the summer and fall would likely limit the presence of cold-water fish species, such as rainbow and brown trout, during this period. The U.S. Bureau of Reclamation and the Interagency Fish Passage Steering Committee are assessing prospective habitats within the NFAR for the potential reintroduction of anadromous Central Valley steelhead. No assessments of fish passage over the North Fork Dam have been previously conducted.

NEXUS BETWEEN PROJECT AND RESOURCE TO BE STUDIED AND HOW THE RESULTS WILL BE USED The proposed Project would use the existing North Fork Dam, which was constructed in 1939 as a debris dam with the purpose of containing gold mining debris. Water is passed downstream over the dam through a spillway. The spillway is currently the only passage route for flow and fish to pass downstream over the dam. No other dams are located on the NFAR, and river flow fluctuates seasonally. Since 1941, the 10 percent flow exceedance for May, the month with the highest average flow, is 2,940 cubic feet per second (cfs) and minimum flow (average 50 cfs) occurs in September (data from USGS Gage No. 11427000, NFAR at North Fork Dam).

Under current conditions, the only downstream passage route for fish in Lake Clementine is by passage over the dam spillway. The proposed Project would provide a second downstream passage route through the powerhouse turbines. Understanding the estimated number of fish passing through the powerhouse as configured in conceptual designs and the estimated survival rate of those fish will provide a basis for evaluating Project effects relative to downstream passage over the dam.

STUDY AREA AND STUDY SITES The geographic scope of this study is the area in the vicinity of the Project intake and the powerhouse turbines.

METHODS This entrainment assessment will be a desktop study (i.e., no fieldwork will be involved). The characterization of entrainment potential and fish passage survival at the Project will be based on the existing fish population composition and density determined from the results of Study Plan AQ-1, Fisheries Study Plan, as well as characteristics of the proposed turbine units for a range of fish sizes. Entrainment and survival for fish of different size categories will be estimated based on site-specific information regarding the species and size of fishes likely to be entrained. To estimate survival of fish passing through the proposed hydroelectric turbines, LCH will use a combination of existing survival study results at similar hydroelectric project turbines and a predictive model to estimate turbine survival. This dual approach for estimating passage survival will provide a characterization and range of passage survival values. This approach to characterizing entrainment potential and estimating turbine passage survival will be useful for making decisions about plant structures (e.g., trash racks) and possible operations.

ANALYSIS Fish Entrainment Evaluation This evaluation will use existing information to assess the potential for fishes in the vicinity of the Project to be entrained and passed downstream through the powerhouse when it is operating. The assessment will use available fish abundance and distribution data, other fisheries management information (such as stocking records), entrainment assessments from nearby watersheds (e.g., the Middle Fork American River [Placer County Water Agency 2011]) and known characteristics of these fishes to estimate the likelihood of fish entrainment and passage through the powerhouse. In evaluating entrainment susceptibility and effects, target species and life stages (fish size) will be identified and considered separately. Life history accounts for each of the target species identified will be documented with an emphasis on their distribution and relative abundance within Lake Clementine.

The assessment will integrate information from numerous available sources, which may include: • Pertinent lake survey information; • Fish stocking records for Lake Clementine, including important variables of fish size and seasonal timing; • Abundant literature describing fish characteristics, focusing on those features such as seasonal movements and depth distributions that might pre-dispose a species to entrainment, or confer resistance to entrainment; and • Abundant fish entrainment literature that compiles and reviews many field studies, such as that prepared by Federal Energy Regulatory Commission (FERC 1995), Electric Power Research Institute (EPRI 1997), and others as appropriate.

These data sources discuss common trends in entrainment among reviewed projects, including seasonality and other types of variability (e.g., species composition) associated with entrainment. In addition to using existing fisheries data regarding life history, abundance, and relative density of fish populations present in Lake Clementine and likely to be found in proximity to North Fork Dam, as determined in Study Plan AQ-1, Fisheries Study Plan, LCH will incorporate an EPRI (1997) compilation of fish entrainment data from selected sites that are comparable to the Project. The EPRI database will be thoroughly screened to provide information for calculating reliable seasonal and annual estimated entrainment rates for fishes of three size groups—small (less than 6 inches), medium (6 to 12 inches), and large (greater than 12 inches) fish for target species considered for this estimate. Qualitative estimates (i.e., five categories ranging from low to high) of seasonal and annual entrainment densities per target species and fish size will be developed based on turbine flow, anticipated Project operations, and river flow to characterize the potential for fish entrainment during a dry year and a wet year to illustrate potential bounds for fish entrainment. Estimates of approach velocity at the Project intake will be developed as part of Study Plan WR-3, Sediment Transport Study Plan, and will be used in conjunction with literature-based fish swimming speed estimates to evaluate the potential for fish to avoid entrainment.

Turbine Passage Survival Estimates Turbine specifications and operating characteristics of the proposed Project will be compared to turbines at other hydroelectric projects where empirical studies of fish turbine passage survival were conducted. This information will be derived from an extensive EPRI (1997) database and more recent entrainment survival studies conducted since 1997 (including Winchell et al. 2000), which will provide fish survival results for sites operating turbines similar to those proposed at the Project.

In addition to the comparison of empirical entrainment studies at projects with similar characteristics to the Project, a predictive model developed to estimate turbine survival will be used. The formula developed by Franke et al. (1997) resulted from Department of Energy objectives to design more “fish-friendly” turbines. The Franke et al. (1997) predictive model calculates the probability of blade strike (i.e., mortality) by relating such turbine parameters as the number of buckets, runner diameter, and runner height to fish length and operating condition. Fish length and available passage space are the principal drivers of the output. Representative fish lengths will be established based on existing fisheries data to estimate survival for a range of fish sizes that are present at the Project. Results will be expressed as an estimated survival percentage. A matrix of survival estimates based on multiple values for some of the key input variables will be included in the study results.

CONSISTENCY WITH GENERALLY ACCEPTED SCIENTIFIC PRACTICE Desktop entrainment studies are used to estimate entrainment abundance and survival at existing and proposed hydroelectric projects on a routine basis.

PRODUCTS Study results will be summarized in the Application for Initial License, Exhibit E. Study products will include a presentation to resource agency personnel and other stakeholders. A report and data gathered as part of the study will be included as an appendix to the license application.

RELATIONSHIP TO OTHER STUDIES This study will rely heavily on the results of Study Plan AQ-1, Fisheries Study Plan. The results of Study Plan WR-1, Water Quality Study Plan may also provide information to determine the likely distribution of fish in the vicinity of North Fork Dam. Approach velocity estimates will be developed for Study Plan WR-3, Sediment Transport Study Plan, and will be used to assess the ability of fish that are likely to occur near the Project intake to avoid entrainment.

Study Plan TR-3, Wildlife Study Plan, will provide information about river otters that are likely to occur in the vicinity of the Project and TR-2, Amphibian and Reptile Study Plan, will provide information about the presence of western pond turtle, California red-legged frog, and foothill yellow-legged frog in the vicinity of the intake.

SCHEDULE This study can begin once the field data collected from Study Plans AQ-1, Fisheries Study Plan, and WR-1, Water Quality Study Plan, are summarized. Preliminary work not dependent on these data can occur at any time.

LEVEL OF EFFORT AND COST Costs are to be determined.

REFERENCES EPRI (Electric Power Research Institute). 1997. Turbine Entrainment and Survival Database— Field Tests. EPRI Report No. TR-108630. Prepared by Alden Research Laboratory, Inc. Franke, G.F., et al. (nine co-authors). 1997. Development of Environmentally Advanced Hydro Turbine Design Concepts. Prepared for the U.S. Department of Energy, Idaho Operations Office, Idaho Falls, ID. FERC (Federal Energy Regulatory Commission). 1995. Preliminary Assessment of Fish Entrainment at Hydropower Projects. Volume 1: A Report on Studies and Protective Measures. Paper No. DPR-10. Prepared by Stone & Webster Environmental Technology and Services. Prepared Federal Energy Regulatory Commission, Office of Hydropower Licensing, Washington, DC. Jones & Stokes Associates, Inc. 1998. Environmental Information Paper North Fork Dam, American River. Placer County, California. Prepared for U.S. Army Corps of Engineers, Sacramento District, Sacramento, CA.

Placer County Water Agency. 2011. Placer County Water Agency. Middle Fork American River Project (FERC No. 2079). Final AQ 7: Entrainment Technical Study Report—2011. February 2011. Winchell, F., S. Amaral, and D. Dixon. 2000. Hydroelectric Turbine Entrainment and Survival Database: An Alternative to Field Studies. Paper presented at HydroVision 2000.

TR-1

SPECIAL-STATUS PLANT AND NATURAL COMMUNITIES AND INVASIVE PLANT STUDY PLAN

October 17, 2014

STUDY GOAL AND OBJECTIVE The Lake Clementine Hydroelectric Project (Project) Pre-Application Document (PAD), August 2010, identified issue(s) associated with special-status plants and natural communities for which the existing, relevant, and reasonably available information is insufficient to address the issue(s). These issues are:

Issue: The project would require a certain amount of ground disturbing activities and removal of vegetation that may affect special-status plant species and natural communities.

Issue: Ground disturbing activities may cause the spread or introduction of invasive plant species. The location of invasive plant species will facilitate the preparation of a plan to manage invasive plants within the Project boundary.

The goal of this study is to develop the essential information necessary to supplement the existing information to address the identified issues. In this case, the objectives of this special- status plants and natural communities and invasive plant species study are to determine if there is suitable habitat for special-status plant species, conduct surveys and document the location of special-status native plants and natural communities within the area of proposed facilities and construction activities, and to document the presence and location of invasive plant species within the area of proposed Project facilities and construction activities. This information will then be used in Project planning. If avoidance of plant populations is not feasible or practicable during the Project planning process, mitigation measures may be recommended.

EXISTING INFORMATION The Project would be located at Lake Clementine adjacent to the North Fork Dam on the North Fork of the American River (NFAR) in Placer County, California. Lake Clementine, which was formed by the North Fork debris dam constructed in 1939, is now owned by the U.S. Army Corps of Engineers. Lake Clementine has a surface area of 280 acres and a capacity of 14,700 acre-feet. It rises 155 feet (ft) above the lowest foundation and has a spillway crest elevation of 715 ft. The dam crest length is 620 ft and the thickness varies from 22 ft at the base to 6.8 ft at the top.

penstock intakes would require excavating the slope on the south side of the canyon adjacent to the dam. A switchyard consisting of a station generator bus, station service transformer, a step-up transformer, and a circuit breaker would be located at an elevation above the high flood flow elevation of the NFAR near the powerhouse or in a room of the powerhouse building. A 60- kilovolt transmission line would be constructed to connect the switchyard with Pacific Gas and Electric’s Halsey Substation. The exact location of the transmission line has not been determined at this time. Two alternative access routes are being considered for Project construction. One access route would entail reconstructing a 2.5-mile-long access road on the south side of the NFAR between Old Foresthill Road and North Fork Dam. The route would follow the alignment of an abandoned dirt road that is currently used as a hiking and biking trail. After construction is completed, the road either could be removed and the site restored or could remain in place to serve another purpose, such as an emergency access or a recreation trail. The second access route under consideration would use the existing Lower Lake Clementine Road. This route would require making upgrades to accommodate construction equipment and traffic. In addition, improving and using this road for Project construction would likely require traffic controls to ensure public safety and facilitate construction activities. The proposed Project would be operated as a run-of-river project where flows coming into Lake Clementine are equal to flows going out of the Lake Clementine. A discussion of potential special-status species in the region was presented in the PAD (America Renewables 2010). Several studies have been conducted in the Lake Clementine area for other projects that are the source of useful information for this Project including Placer County’s North Fork Trail Project and USACE studies (Placer County 2007, USACE 2008).

Jepson’s onion (Allium jepsonii) and oval-leaved viburnum (Viburnum ellipticum) have been recorded as occurring within the Project area by recent searches of the California Natural Diversity Database (CNDDB 2010) for the Auburn and Greenwood U.S. Geological Survey 7.5- minute quads and the California Native Plant Society (CNPS 2010) rare plant inventory. The PAD also identified several invasive plant species that occur in the region that could be spread or introduced as a result of ground disturbing and construction activities.

Consultation with the Placer County Agricultural Commissioner indicated that invasive plants surveys should focus on B-rated tall whitetop (Lepidium latifolia) and three A-rated plants: spotted knapweed (Centaurea maculosa), musk thistle (Carduss nutans), and Scotch thistle (Onopordum acanthium).

NEXUS BETWEEN PROJECT AND RESOURCE TO BE STUDIED AND HOW THE RESULTS WILL BE USED During construction of the Project there is a potential to affect special-status plants and natural communities that may be found in the NFAR canyon and along the proposed transmission line.

The goal is to conduct floristic surveys of the Project areas during the proper blooming times to determine if special-status plant species and natural communities are present. This information will be used in future Project planning. If possible, Lake Clementine Hydro seeks to avoid special-status species and natural communities and to minimize impacts to the environment from this renewable energy Project.

STUDY AREA AND STUDY SITES Specific locations and boundaries of Project features are not identified at this time. Therefore, the potential maximum extent of the Project-affected Area is included in the survey area. Floristic surveys will be conducted within all proposed Project footprints, alignments, and alternatives for construction staging areas and access routes, road improvements, generation facilities, the powerhouse, transmission line corridors, and all other areas in which ground-disturbing activities would occur, plus a 100-ft buffer. Additionally floristic surveys will be conducted within a 100-ft radius of the dam extending upslope from the high-water mark of both Lake Clementine and the NFAR. A final determination of the location of these Project features is pending.

METHODOLOGY A special-status plant or natural community is defined as any plant species or natural community that is granted protection by a federal, state, or local agency. Methodology is described below.

• Review the following plant species lists for species and natural communities that will be surveyed: − Federally listed species granted status by the U.S. Fish and Wildlife Service (USFWS) under the Federal Endangered Species Act (ESA) include threatened (FT), endangered (FE), proposed threatened or endangered (FPT, FPE), candidate (FC), or listed species proposed for delisting (FPD); − State of California listed plant species, which are granted status by the California Department of Fish and Game (CDFG) under the California Endangered Species Act (CESA), include threatened (CT), endangered (CE), and rare (CR); − Species considered by the California Native Plant Society (CNPS) to be rare, threatened, or endangered in California (CNPS Lists 1 A and B and 2 A and B, and 3 and 4); and − Natural communities designated as rare on the California Department of Fish and Wildlife List of California Terrestrial Natural Communities (CDFG 2010). • Invasive plants include species listed by the California Department of Food and Agriculture as A-rated or B-rated. LCH will consult the following online resources for additional species of invasive plants that occur or have the potential to occur in the Project vicinity: California Invasive Plant Council (CalIPC) Invasive Plant Inventory (http://www. calipc.org/ip/inventorv/index.php), CalWeedMapper (http://calweedmapper.cal-

ipc.org/), Calflora (http://www.calflora.org/), and the California Department of Food and Agriculture's Biogeographic Information & Observation System (BIOS): (http://www.dfg.ca.gov/biogeodata/bios/). Additional resources for local invasive plant information may be obtained from the local Weed Management Area group (http://www.calipc.org/WMAs/Nevada Placer. WMA.php) and Placer County Resource Conservation District (http://www.placercountyrcd.org/). • Aquatic invasive plant species observed in Lake Clementine will also be recorded and mapped. • Identify and map occurrences of elderberry bushes. • Identify and map high priority culturally important plant species to be determined in consultation with the United Auburn Indian Community. • Identify and map known occurrences of special-status and invasive plants and natural plant communities within the study area, based on agency consultation and a review of existing information. Preliminary information is presented in the PAD. • Conduct focused special-status terrestrial plants field effort according to the Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (CDFG 2009). This methodology applies to invasive plant species as well. Culturally important plant species should be included to the extent it is reasonable. Field surveys shall also note the location of any elderberry bushes, which serve a critical habitat for valley elderberry long-horned beetle, listed as threatened by the U.S. Fish and Wildlife Service. • Field surveys will be conducted at the proper time of year when rare, threatened, or endangered and invasive species are both evident and identifiable. Generally, this is when the plants are flowering. Based on the blooming periods for plants known or potentially occurring within the Project vicinity, two surveys will be conducted, one in April and one in late May to early June. Due to extreme drought conditions in 2014 it may be necessary to conduct additional surveys in 2015. • Timing of surveys will be verified based on agency consultation and reference population monitoring. • Systematic field techniques will be implemented (e.g., zigzag patterns, random meandering, and linear transects) in the study area. • If a special-status plant species population is identified on the perimeter of the study area, the study area will be expanded, within reason, to document the extent of the population. • Surveys will be floristic in nature and taxonomy will be based on The Jepson Manual (Hickman 1993). • Digital photographs, Global Positioning System (GPS) information, an estimate of the number of individuals present, and associated vegetation will be collected for each

special-status or invasive plant population observed. For culturally important plant species that are abundant in the study area, estimates of the numbers of individual plants or the aerial extent of the population will be made. • Develop a Geographic Information System (GIS) map of special-status or invasive plant populations and overlay information on Project facilities and features. • Prepare and submit California Native Species Field Survey Forms for all special- status plants for submittal to the California Natural Diversity Database. • Prepare draft and final technical reports describing study objectives, methodologies, and results.

ANALYSIS Results will provide information about the presence, location, abundance and distribution of special-status and invasive plant species within the Project area. This would include the following:

• Confirmation of the presence of special-status plant species which include; Jepson’s onion, oval-leaved viburnum, Brandegee's clarkia ( Clarkia biloba ssp. brandegeeae), Butte County fritillary (Fritillaria eastwoodiae), dubious pea (Lathyrus sulphureus var. argillaceus), Humboldt lily (Lilium humboldtii var. humboldtii), Red Hills soaproot ( Chlorogalum grandiflorum), and streambank spring beauty (Claytonia parviflora ssp. grandiflora). • If present, the exact location and distribution of special-status and invasive plant species within the Project area. • If present, the relative abundance of individual special-status and invasive plants within the Project Area. The results of the special-status plant species surveys will aid in the assessment of potential effects of Project construction and operation on species of concern and invasive species. If present, knowing the special-status and invasive species’ location, abundance and distribution would aid in estimating the likelihood of Project effects on these populations. This information would also aid in developing a construction plan and operation plan to avoid or minimize the potential for adverse effects to special-status plant species and potential spread or introduction of invasive species in the Project area Lake Clementine.

CONSISTENCY WITH GENERALLY ACCEPTED SCIENTIFIC PRACTICE The methods proposed follow the Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (CDFG 2009) which is considered the standard for performing special-status and invasive plant and natural community surveys.

PRODUCTS Study results will be reported in Exhibit E of the License Application.

RELATIONSHIP TO OTHER STUDIES Ethnographic study if required to place the locations of any identified culturally important plants in the context of places with cultural importance.

SCHEDULE Floristic surveys will be conducted based on normal blooming periods for each species based on the Jepson manual which include Jepson’s onion (May-August) and oval-leaved viburnum (May- June). Blooming periods may be adjusted depending upon local rainfall and meteorological conditions in the NFAR watershed. Due to extreme drought conditions in 2014, it will be necessary to conduct additional surveys in 2015.

LEVEL OF EFFORT AND COST Costs are to be determined.

REFERENCES America Renewables. 2010. Lake Clementine Hydropower Project. FERC Project No. 13432. Pre-Application Document. August 2010. California Department of Fish and Game 2010. List of California Terrestrial Natural Communities (http://www.dfg.ca.gov/biogeodata/vegcamp/pdfs/natcomlist.pdf).

California Department of Fish and Game. 2009. Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities. November 24, 2009. (http://www.dfg.ca.gov/biogeodata/cnddb/pdfs/protocols_for_surveying_and_evaluating_ impacts.pdf). California Native Plant Society. 2010. Inventory of Rare and Endangered Plants (online 8th edition). Accessed December 30, 2010. California Natural Diversity Database. 2010. Biogeographic Data Branch, Sacramento, CA. Rarefind 4. Accessed December 30, 2010. Hickman, J.C. (ed.). 1993. The Jepson Manual. University of California Press, Berkeley, CA. Placer County. 2007. Draft Environmental Impact Report for North American River Trail. August 2007. United States Army Corps of Engineers, Sacramento District. 2008. North Fork American River study prepared by Jones & Stokes Associates.

TR-2

AMPHIBIAN AND REPTILE STUDY PLAN

October 17, 2014

STUDY GOAL AND OBJECTIVE The Lake Clementine Hydroelectric Project (Project) Pre-Application Document (PAD), filed August 2010, identified issues associated with terrestrial resources for which the existing, relevant, and reasonably available information is insufficient to address the issue. These issues are:

Issue: Construction of the Project intake, powerhouse, transmission line, and access roads has potential to disturb or degrade habitat for special-status reptile and amphibian species if existing suitable habitat is present within the areas of proposed disturbance.

Issue: Project operations have potential to affect special-status reptile and amphibian species if the Project causes changes in water temperature or hydraulic conditions downstream of the Project, resulting in reduced habitat quality within occupied habitat for these species.

Issue: The Project may have the potential to entrain western pond turtles (Emys marmorata) (WPT) if present in the vicinity of the intake structure.

Special-status reptile and amphibian species with potential to occur in the Project area include the California red-legged frog (Rana draytonii) (CRLF) listed by the U.S. Fish and Wildlife Service (USFWS) as threatened, and foothill yellow-legged frog (Rana boylii) (FYLF) and WPT listed as species of special concern by the California Department of Fish and Wildlife. The introduced, non-native red-eared slider turtle (Trachemys scripta elegans) may also be present in the Project- affected Area. The goal of this study is to develop the essential, additional information necessary to supplement the existing information to address the identified issues. Objectives in support of this goal include: (1) identifying and mapping known occurrences and distribution of suitable habitat for CRLF, FYLF and WPT within the Project-affected Area, (2) description of Project- affected streams or uplands with suitable habitat for CRLF, FYLF and WPT, (3) surveying for the presence/absence of CRLFs, if warranted based on locations of suitable habitat within the Project- affected Area; and (4) documenting observations of exotic species (e.g., bullfrog, red-eared slider turtle, non-native crayfish, bass, catfish, or mosquito fish) that may limit the occurrence of CRLF in otherwise suitable habitat.

Lake Clementine Hydroelectric Project, FERC No. 13432 Amphibian and Reptile Study Plan

feet (ft) above the lowest foundation and has a spillway crest elevation of 715 ft. The dam crest length is 620 ft and the thickness varies from 22 ft at the base to 6.8 ft at the top.

The proposed Project would consist of an intake near the left abutment of North Fork Dam, an open canal, and one or two penstocks connecting to a powerhouse that would house two or three generating units, totaling a combined capacity of 16 megawatts. The powerhouse would be located between 200 and 600 ft downstream of the dam. Construction of the intake, canal, and penstock intakes would require excavating the slope on the south side of the canyon adjacent to the dam. A switchyard consisting of a station generator bus, station service transformer, step-up transformer, and circuit breaker would be located at an elevation above the high flood flow elevation of the NFAR near the powerhouse or in a room of the powerhouse building. A 60- kilovolt transmission line would be constructed to connect the switchyard with Pacific Gas and Electric’s Halsey Substation. The exact location of the transmission line has not been determined at this time. Two alternative access routes are being considered for Project construction. One access route would entail reconstructing a 2.5-mile (mi) long access road on the south side of the NFAR between Old Foresthill Road and North Fork Dam. The route would follow the alignment of an abandoned dirt road that is currently used as a hiking and biking trail. After construction is completed, the road either could be removed and the site restored or could remain in place to serve another purpose, such as an emergency access or a recreation trail. The second access route under consideration would use the existing Lower Lake Clementine Road. This route would require making upgrades to accommodate construction equipment and traffic. In addition, improving and using this road for Project construction would likely require traffic controls to ensure public safety and facilitate construction activities. The proposed Project would operate in a run-of-river mode with flows coming into Lake Clementine being equal to flows going out of Lake Clementine.

A discussion of habitat preferences, known population ranges, and species listing status for CRLF, FYLF and WPT was presented in the PAD, Section 3, page 38 (America Renewables 2010). CRLFs and WPTs are known to occur in locations within the Greenwood and Auburn U.S. Geological Survey (USGS) 7.5-minute quadrangle maps, and FYLFs are known to occur in locations within the Greenwood quadrangle map (CNDDB 2010a,b). In addition, several studies were conducted in the region, such for the Middle Fork American River Project in Placer County, and are the source of useful information for this Project (Placer County Water Agency 2008).

NEXUS BETWEEN PROJECT AND RESOURCE TO BE STUDIED AND HOW THE RESULTS WILL BE USED Construction of Project facilities, including the intake, powerhouse, transmission line, and access roads, may occur in riparian and aquatic habitats that could support CRLF, FYLF, WPT, and the invasive red-eared slider turtle. Recent search of the California Natural Diversity Database (CNDDB 2010a,b) covering land within the Auburn and Greenwood USGS 7.5-minute quadrangle maps and review of the USFWS, Sacramento Office, website (USFWS 2014) indicate

Lake Clementine Hydroelectric Project, FERC No. 13432 Amphibian and Reptile Study Plan

that these species have the potential to occur within the Project-affected Area. As proposed, Project operations are not expected to alter existing water temperature in the river downstream of the Project. . However, construction of the access road along the preferred access route that roughly parallels the NFAR could alter suitable CRLF and FYLF habitats that may be present in the NFAR and tributaries downstream of North Fork Dam. Construction of the intake at Lake Clementine has the potential to eliminate suitable habitat for WPTs. The Project intake may also create an entrainment hazard for WPTs if they are present in the vicinity of the intake.

Information obtained from this study will be used for Project planning and for the development of measures to protect these amphibian and reptile species.

STUDY AREA AND STUDY SITES The primary study area will include lower Lake Clementine within 500 ft of the proposed intake location and the NFAR from North Fork Dam to the confluence with the Middle Fork of the American River. Additional survey areas will be defined by mapping these species habitats according to definitions provided by the California Wildlife Habitat Relationships Program. A map of the Project-affected Area is attached.

METHODS The field schedule for all surveys will be provided to resource agencies. Agency personnel wanting to participate in field surveys are requested to notify LCH in advance of the scheduled survey date to confirm the field logistics (i.e., date, time, and location).

The following describes the approach to complete a protocol-level site assessment and surveys for CRLF, FYLF and WPT.

California Red-legged Frog USFWS lists the CRLF as threatened. USFWS has designated 1,636,609 acres of critical habitat in 27 California counties, including 1,243 acres in Placer County (75 FR 51, March 17, 2010).

A USFWS protocol-level site assessment will be conducted in accordance with the Revised Guidance on Site Assessments and Field Surveys for the California Red Legged Frog (USFWS 2005). This process includes:

• Identifying and mapping known occurrences of CRLF within 1 mi of the Project- affected Area based on agency consultation, museum records, and other existing information; • Identifying and mapping CRLF habitat within 1 mi of the Project-affected Area based on review of aerial photography, helicopter surveys, or video surveys; • Conducting a field reconnaissance survey to verify habitat mapped in the Project- affected Area, including characterizing aquatic habitats (e.g., ponds versus creeks, pools versus riffles, ephemeral habitat versus permanent habitat, vegetation type (e.g., emergent, overhanging), water depth at the time of the site assessment, bank full

Lake Clementine Hydroelectric Project, FERC No. 13432 Amphibian and Reptile Study Plan

depth, stream gradient (percent slope), substrate, and description of bank, noting presence of bullfrogs, bass, perch, sunfish,, and other potential CRLF predators and characterizing upland habitats by describing upland vegetation communities, land uses, and any potential barriers to CRLF movement; and • Preparing a Site Assessment Report for submittal to USFWS, National Marine Fisheries Service, Bureau of Reclamation, California Department of Fish and Wildlife, State Water Resources Control Board, and California Department of Parks and Recreation (resource agencies) that includes the following: – Copies of data sheets; – Copies of field notes; – Global Positioning System (GPS) data for all field reconnaissance sites; – List of known occurrences of CRLF locations within 1 mi of the Project-affected Area; – Photographs of the study area, including a map of photo locations; – Geographic Information System (GIS) map of potential CRLF habitat within 1 mi of the Project-affected Area; and – A description of the Project work that would affect the area. Following submittal of the Site Assessment Report to resource agencies, LCH will meet and consult with state and federal agencies following the completion of the Site Assessment Report to determine whether protocol-level CRLF surveys are required. If it is determined that surveys are required, surveys will be completed in accordance with the Revised Guidance on Site Assessments and Field Surveys for the California Red-legged Frog (USFWS 2005) in Project-affected Areas. These guidelines include:

• Implementing USFWS-recommended decontamination guidelines (USFWS 2005), including removal of organic debris from vehicles and equipment, cleaning field equipment, properly disposing of cleaning liquids, and using gloves when handling CRLF before conducting surveys to prevent the spread of parasites and diseases to CRLF and other amphibians; • Submitting surveyor qualifications with survey results; • Conducting two daytime surveys and four nighttime surveys during the breeding season as well as one daytime and one nighttime survey during the non-breeding season with surveys occurring at least 7 days apart and spanning a minimum of 6 weeks; • Completing surveys by the end of September with adult surveys completed before June 30, sub-adult surveys between July 1 and September, and egg surveys beginning after April 15;

Lake Clementine Hydroelectric Project, FERC No. 13432 Amphibian and Reptile Study Plan

• Conducting surveys during appropriate weather conditions as defined in the USFWS guidelines (USFWS 2005); and • Discontinuing surveys in any areas where CRLF are identified. During each survey, LCH surveyors will walk entirely around areas determined to be suitable habitat within the study area while repeatedly scanning for frogs. Surveyors will begin by first working along the entire shoreline, then by entering the water (if necessary and if no egg masses would be crushed or disturbed), and visually scanning all shoreline areas and all aquatic habitats identified in the site assessment. Generally, surveyors will focus on all open water to at least 2 meters (6.5 ft) up the bank. When wading, surveyors will take care to avoid disturbing sediments, vegetation, or larvae. When walking on the bank, surveyors will be careful not to crush rootballs, overhanging banks, and stream-side vegetation that might provide shelter for frogs. Surveys will cover the entire area; otherwise, the remaining survey area will be surveyed the next day/night that weather conditions allow.

The main purpose of day surveys during the breeding season is to look for larvae, metamorphs, and egg masses; the main purpose of day surveys during the non-breeding season is to look for metamorphosing sub-adults and non-breeding adults. Daytime surveys will be conducted between 1 hour after sunrise and 1 hour before sunset.

The main purpose of nighttime surveys is to identify and locate adult and metamorphosed frogs. Conditions and requirements for conducting nighttime surveys follow: • Safety is a primary concern and surveys will only be performed where it is safe to do so. • Nighttime surveys will commence no earlier than 1 hour after sunset. • Because of diminished visibility, surveys will not be conducted during heavy rains, fog, or other conditions that impair the surveyor’s ability to accurately locate and identify frogs. • Nighttime surveys will be conducted with a USFWS-approved light. • The light will be held at the surveyor’s eye level so that the frog’s eye shine is visible to the surveyor. • Surveyors may require binoculars to effectively see the eye shine of the frogs. After CRLF surveys are completed, a survey report will be submitted to the resource agencies and will include copies of data sheets, field notes, photographs, and maps.

It should be noted that survey areas located on privately owned lands will be surveyed only if permissions from the land owner can be obtained. If permission cannot be obtained, LCH will meet with the resource agencies to discuss the potential for the Project to affect the survey area and make a determination if the project could affect CRLF. There are three possible determinations of effects under the Endangered Species Act (ESA):

Lake Clementine Hydroelectric Project, FERC No. 13432 Amphibian and Reptile Study Plan

• No Effect—The proposed action or interrelated or interdependent actions will not affect (positively or negatively listed species or their habitat. • May affect, not likely to adversely affect—The proposed action or interrelated or interdependent actions may affect listed species or their habitat, but the effects are expected to be insignificant, discountable, or entirely beneficial. – Insignificant effects relate to the size of the impact and should never reach the scale where a take will occur. – Discountable effects are those that are extremely unlikely to occur. Based on best judgment, one would not 1) be able to meaningful measure, detect, or evaluate insignificant effect; or 2) expect discountable effects to occur. – Beneficial effects are contemporaneous positive effects with no adverse effects on listed species. • May affect, likely to adversely affect—The proposed action or interrelated or interdependent actions may have measureable significant adverse effects on listed species or their habitat. Such a determination requires formal ESA Section 7 consultation. Foothill Yellow-legged Frog Suitable FYLF habitat may exist downstream of North Fork Dam. The study area will include the NFAR from North Fork Dam to the confluence with the Middle Fork of the American River. The specific objectives of this investigation are as follows: • Identify, compile, and map known occurrences of FYLF within the study area, including life history stage and associated habitat information as available in museum databases and agency records; • Identify habitats in the study area that are potentially suitable for FYLF and evaluate the suitability of these habitats for the species, including identifying breeding and rearing habitat; • Perform biological surveys in suitable habitats and determine the approximate period in which breeding and rearing occurs if FYLFs are found; and • Compile incidental observations from other aquatic studies documenting other native amphibians and non-native aquatic species that may affect the distribution of FYLFs. The California Department of Fish and Wildlife has not published specific recommendations for FYLF surveys.

Based on field reconnaissance, potential FYLF breeding and rearing habitat in the study area will be identified. Potential breeding and rearing habitat is defined as: • Breeding Habitat—Shallow, near-shore areas of low velocity with cobble/boulder substrate in open, sunny areas with little riparian vegetation; often adjacent to low gradient cobble/boulder bars, tributary confluences, side and backwater pools, or pool tailouts with coarse substrates.

Lake Clementine Hydroelectric Project, FERC No. 13432 Amphibian and Reptile Study Plan

• Rearing Habitat—Similar to breeding habitats early in the season, but tadpoles may distribute to shallow, warm, low velocity near-shore habitats with smaller substrate (i.e., gravel/sand) as the season progresses. Breeding and rearing habitat will be classified as follows: • Suitable—River reaches that have moderate gradients and valley widths wide enough to create frequent depositional features that provide locally low-gradient, low velocity (<10 centimeters per second), relatively shallow mesohabitats, such as shallow pool tailouts and wide runs with shallow margins where egg masses and tadpoles can persist; • Limited—River reaches where narrow confined conditions and steep gradients create only small, patchily distributed, shallow, low velocity mesohabitats in the channel; and • Unsuitable—River reaches where shallow, low velocity mesohabitats are typically not present. Habitat characterization will also include a qualitative assessment of presence of predators, food availability, (presence of algae), and observations of water temperature and flow stability.

Survey methods will follow the Visual Encounter Survey (VES) protocol described by S. M. Yarnell, R. A. Peek, A. J. Lind, 2014, included in Appendix 1 or by connecting on the link below. (https://watershed.ucdavis.edu/files/CWS%20FYLF%20VES%20Survey%20Protocol- DRAFT.pdf). Western Pond Turtle Pond turtles have been observed in Lake Clementine and in other reservoirs in the American River Watershed. Suitable habitat for basking and breeding exists in the area. Primary study sites include areas of proposed disturbance associated with construction of the Project intake facilities.. The objectives of this study are to: • Identify and map known occurrences of WPTs within the study area, based on agency consultation and a review of existing information; • Record sightings of WPTs during implementation of aquatic technical studies; in particular, surveyors will visually inspect pools and backwaters for WPTs at each study site during the FYLF and CRLF surveys; • Conduct a GIS analysis of potential WPT nesting or hibernating habitat locations in the Project-affected Area, including 500 ft around all areas of ground disturbance; GIS selection criteria will include areas within 150 ft of perennial streams and reservoir shoreline with: – Slope of 15 degrees or less, and – Southeast, south or southwest aspect; • Conduct a field reconnaissance survey of potential nesting locations identified in the GIS map to verify habitat mapping.

Lake Clementine Hydroelectric Project, FERC No. 13432 Amphibian and Reptile Study Plan

After the GIS analysis, surveyors will visit areas with potential WPT nesting habitat and verify the slope and aspect analysis. Surveyors will also quantify the amount of area with either grassy or dry clay/loam/silt soils greater than 10 centimeters deep in areas with canopy cover less than 10 percent. The GIS map of potential nesting sites will be updated based on the results of the field verification surveys. Surveyors will also document any incidental WPT and RES sightings that occur during field verification surveys or as part of the CRLF and FYLF surveys.

Surveys for the presence of WPT will also be performed in the vicinity of the Project intake. An initial survey of the Lake Clementine shoreline between North Fork Dam and the Auburn Boat Club marina to identify and locate any potential basking areas. Basking areas will be observed for 1 hour between noon and 4:00 p.m. for 3 consecutive days. If there are no basking areas along the shoreline, up to three artificial basking areas will be placed at strategic locations. LCH will consult with resource agency personnel and Auburn Boat Club officers regarding the placement and location of basking areas. If artificial basking structures are required, they will be placed at least 2 weeks prior to performing observations.

ANALYSIS Maps and field observations will be analyzed together with hydrologic data, fisheries study results, and plant community maps to assess Project effects on CRLFs, FYLFs, and WPTs.

CONSISTENCY WITH GENERALLY ACCEPTED SCIENTIFIC PRACTICE

The proposed study methods are consistent with standard methodologies recommended by USFWS for conducting habitat and presence/absence surveys for CRLFs. Methodologies for FYLF and WPT surveys are consistent with standard methodologies identified in studies for other hydroelectric projects in the area (Placer County Water Agency 2008a).

PRODUCTS A summary of the information and findings will be included in the Application for Initial License, Exhibit E. Data gathered as part of the study will be included as an appendix to the License Application. Stand-alone reports will not be prepared unless requested by resource agencies. Where a report is required, this section will specify why it is required and identify the major sections of the report (i.e., purpose of study, study area, methods, results, analysis, and references).

RELATIONSHIP TO OTHER STUDIES The results of the WR-1, Water Temperature and Dissolved Oxygen Assessment Study Plan, will provide information for analyzing Project effects on temperature in the NFAR and potential related effects on CRLFs and FYLFs. Results of the AQ-1, Fisheries Study Plan, will also provide information related to potential CRLF and FYLF predators in the study area.

SCHEDULE Reptile and amphibian surveys will be conducted between April 15 and September 30, 2015.

Lake Clementine Hydroelectric Project, FERC No. 13432 Amphibian and Reptile Study Plan

Implementation of studies is dependent on receiving required permissions and permits from the U.S. Army Corps of Engineers.

LEVEL OF EFFORT AND COST Costs are to be determined.

REFERENCES America Renewables. 2010. Lake Clementine Hydropower Project, FERC Project No. 13432, Pre- Application Document. America Renewables, Rolling Hills Estates, CA. August 2010. CNDDB (California Natural Diversity Databases). 2010a. CNDDB Quick Viewer: Element Occurrence Data for Auburn, Greenwood Quads. Available at: http://imaps.dfg.ca.gov/viewers/cnddb_quickviewer/app.asp. Accessed March 21, 2014. CNDDB. 2010b. CNDDB Quick Viewer: Unprocessed Element Occurrence Data for Auburn, Greenwood Quads. Available at: http://imaps.dfg.ca.gov/viewers/cnddb_quickviewer/app.asp. Accessed March 21, 2014. USFWS (U.S. Fish and Wildlife Service) 2014. Federal Endangered and Threatened Species that Occur in or may be Affected by Projects in the Auburn (527A) and Greenwood (526B) USGS 7.5-Mintue Quad. Available at: http://www.fws.gov/sacramento/es_species/Lists/es_species-lists_quad-finder.htm. Accessed March 21, 2014. USFWS. 2005. Revised Guidance on Site Assessments and Field Surveys for the California Red- legged Frog. Available at: http://www.fws.gov/sacramento/es/Survey-Protocols- Guidelines/Documents/crf_survey_guidance_aug2005.pdf. Accessed March 21, 2014. Placer County Water Agency. 2008a. Middle Fork American River Project (FERC Project No. 2079) Pre- Application Document. Supplement F: Existing Resource Report. Available at: http://relicensing.pcwa.net/html/filings/filings_pad.php. Accessed March 21, 2014. Placer County Water Agency. 2008b. Middle Fork American River Project (FERC Project No. 2079) Application for New License, Vol. 3: Exhibit E, Environmental Exhibit, Appendices, and Supporting Docs A, B, and C – SDB16_Aq12a_Special Status Amphibian and Aquatic Reptile Technical Study Report – 2007. Available at: http://relicensing.pcwa.net/documents/Application//04_Vol%203%20-%20Exhibit%20E%20- %20Environmental%20Exhibit,%20Appendices,%20and%20Supporting%20Docs%20A,%20B%2 0&%20C/SDB_TSRs_Intro_and_AQ/16_AQ12a_SSAmphibReptileTSR/01_AQ12_SSAmphibRe ptileTSR_2007.pdf. Accessed March 21, 2014. Yarnell, S.M., R.A. Peek, A.J. Lind. 2014. DRAFT: Visual Encounter Survey Protocol for Rana boylii in Lotic Environments.

Lake Clementine Hydroelectric Project, FERC No. 13432 Amphibian and Reptile Study Plan

APPENDIX 1

DRAFT: Visual Encounter Survey Protocol for Rana boylii in Lotic Environments

Lake Clementine Hydroelectric Project, FERC No. 13432 Amphibian and Reptile Study Plan

DRAFT: Visual Encounter Survey Protocol for Rana boylii in Lotic Environments

January, 2014

1 1 2 S.M. Yarnell , R.A. Peek , A.J. Lind

1 Center for Watershed Sciences, John Muir Institute of the Environment, One Shields Avenue, University of California, Davis, CA 95616

2 USDA Forest Service, Tahoe & Plumas National Forests, 631 Coyote Street, Nevada City, CA 95959

This Visual Encounter Survey (VES) protocol and associated datasheet are for use in river and stream reaches up several kilometers in length where information on all lifestages and the habitat associations of each individual is desired. The data from this survey protocol are intended to 1) describe the abundance, distribution and habitat associations of R. boylii (Foothill yellow-legged frog or FYLF), and 2) provide the data necessary to coordinate with other stream reach study efforts, such as instream flow studies where hydrodynamic modeling will be used.

VES OVERVIEW

The basic VES protocol follows Heyer et al. (1994) and Lind (1997), and is summarized for stream habitats as follows. Surveys will be conducted by a minimum of two surveyors but three or more surveyors may be needed in larger streams. Wherever possible, surveys are completed walking upstream so that as individuals seek cover in the stream (often swimming downstream), they are not counted twice. However, surveys could proceed in the downstream direction if surveyors are well-practiced in identification, are manually feeling and checking behind cobbles and boulders for egg masses, and can adequately keep track of any downstream migrating individuals. Surveyors may wade or walk the shoreline and shallow-water habitats where possible, scanning ahead for approximately 10 meters at a time, searching for all lifestages (eggs, larvae, juveniles, adults). If binoculars are available they may be used to scan upstream for post- metamorphic individuals (juveniles and adults) basking on exposed substrate or partially hiding under cover, in an attempt to identify animals before they hide or escape. Aquatic habitats are visually and manually searched along a several meter wide transect parallel to the stream at the water’s edge, and the number of animals encountered over a period of time is recorded. When wading in the near-shore habitat, surveyors will use a carefully gauged zig-zag pattern to search the shallows in one pass. A stopwatch or wristwatch with a timer will be carefully used, starting at the beginning of the survey time, and stopped for any time surveyors are not actively searching for frogs. This is the “survey time” and should be calculated and recorded for each survey site and visit to provide an estimate of relative effort. Any additional herpetofauna observed, particularly potential predators, invasive species, etc. (e.g., smallmouth bass, crayfish, bullfrogs), should be documented in the notes.

Egg Masses and Tadpoles

Lake Clementine Hydroelectric Project, FERC No. 13432 Amphibian and Reptile Study Plan

FYLF prefer lower gradient stream segments, often associated with pool tail-outs and gravel/cobble bar complexes, for oviposition habitat. Breeding can occur as early as March to as late as mid-May in coastal systems (generally April) and as early as late April through early July in the Sierra Nevada (generally mid-May) depending on the seasonal precipitation patterns and water year type. Most egg masses are attached to rocky substrates ranging from small gravel to large boulders and bedrock, however, in some locales egg masses may be attached to roots or large pieces of wood. While the majority of egg masses are located in shallow (< 1 m) water, eggs have been observed in water >2 m. As such, where safe and possible, snorkeling in deeper water (0.5-3 m deep) in and adjacent to suitable breeding habitat (e.g., edges of cobble bars, pool tail outs) can greatly aid in detection of egg masses, and is mandatory for spring egg mass surveys. Non-snorkeling surveyors should carefully use their hands to feel under bedrock and boulder ledges as well as in deep pockets beneath large cobble in low velocity areas where they cannot see, as eggs may be located in highly cryptic and well concealed locations only accessible by touch. Gently brush the entire surface of the rock substrate with a bare hand, following the surface of the rock until the junction between the rock and the stream bed can be felt to ensure the entire surface has been surveyed. This process is time-consuming but effective, and care should be taken to thoroughly survey suitable habitat (typically open canopy areas with low-flow, low-gradient habitat such as runs, pool tails, and edgewater of riffles, however sites and regions may differ).

In shallow water habitats, hand dip nets may be used to seine the channel bottom to collect tadpoles. This search effort in shallow water habitats should be balanced to minimize habitat disturbance, but adequately sift through any silt, gravel or vegetation where individuals may be hiding. Use of a viewing box in shallow, wadeable areas to aid in detection of egg and tadpole lifestages is helpful but not required. Polarized glasses help reduce glare and permit more effective inspection beneath the surface of the water, which can be particularly helpful during tadpole surveys. Tadpoles often are well concealed and highly cryptic, but they leave telltale signs of recent presence via the spiral shaped feces that are often uniform in color and highly prevalent in areas where tadpoles occur.

Post-metamorphic individuals (Young-of-Year, Juveniles and Adults)

For post-metamorphic individuals, a moderate level of search effort is used to survey for individuals active on the surface of the ground, on rocks, or at the water’s edge. All individuals are identified, and if possible, captured for species identification and measurement. If a surveyor is confident that subsequent observations are the same species, subsequent observations can be occasionally captured for confirmation or measurement purposes. Individuals observed in amplexus or gravid adult females should not be captured unless absolutely necessary to minimize stress during critical breeding periods, however notes should be taken on condition and location. Rocks, wood and other surface cover objects are also overturned in search of individuals, then returned to their original position to minimize disturbance to the habitat. Habitats are not systematically destroyed in order to find animals, and voucher specimens are not collected unless absolutely necessary for identification. In shallow water habitats, hand dip nets may be used to capture individual adults and sub-adults.

Lake Clementine Hydroelectric Project, FERC No. 13432 Amphibian and Reptile Study Plan

Disinfection Protocols

Field gear (i.e., wading boots, topset rods, waders) should be sterilized using standard protocols (Johnson et al. 2003; CCADC 2007). When sampling between multiple rivers and watersheds in the same day, prioritize the order of site visits to minimize the spread of pathogens (i.e. move from most pristine to least pristine sites or from upstream to downstream), and ensure appropriate time is permitted to treat gear between sites. All equipment that has been in contact with an amphibian or in the water needs to be disinfected, including rulers, dipnets, plastic bags, or other field gear. Be sure to avoid taking wet equipment saturated with disinfectant into aquatic habitats. Quat 128 (1 oz per gallon of water) or bleach that can be diluted to approximately a 5% solution (granulated chlorine bleach has better disinfectant efficacy over time, CCADC 2007), are standard disinfectants. Submerge and immerse all items that need disinfecting in the solution for 10 minutes. A large plastic tub with a tight lid can function as a sanitization station at the office or field site, but should be completely switched with new solution every few days, particularly with heavy use. Bleach can be discarded on site, well away from any water source.

Equipment and Datasheets

A list of field equipment required to complete the surveys is attached at the end of this protocol. In general, equipment should be selected to be lightweight, waterproof or water resistant, and compact enough to fit within a daypack so that surveyors can be fully mobile.

The associated datasheet was developed to document the data needed at each observation. It is similar to datasheets used in previous academic research and hydropower relicensing studies (Lind, 1997; PG&E 2002; Yarnell, 2005). In order to simplify the complications and potential errors associated with multiple datasheets for different lifestages, a single datasheet is used for each survey, regardless of time of year and focus of survey (i.e., breeding surveys in spring vs. tadpole surveys in summer). The data for each lifestage observed during the survey is recorded on a single row. The habitat data collected for each lifestage may differ and as a result, some fields in the row may be marked as N/A (i.e., total depth for an adult observation). Small modifications to the datasheet may be made to accommodate unique survey situations (such as associated habitat number rather than associated GPS point when identifying observation location), but these should be kept to a minimum.

Note that the datasheet is designed to be printed in landscape format on 8x11.5 paper (see FYLF VES Survey Datasheet.xlsx file). Details on recording data are provided below. The datasheet is designed for collection of data in metric units, so use of English US units must be explicitly noted.

General Data

Date: Month, Day, Year

Lake Clementine Hydroelectric Project, FERC No. 13432 Amphibian and Reptile Study Plan

River/Site: Name of river/stream/creek and site to be surveyed. If sub-reaches are used, clarify which sections are to be surveyed. For example: North Yuba River, Reach A-1, River Mile 12.5-13.5. Surveyors: Names or Initials of all participating surveyors. The initials of the team member filling out the datasheet should be noted first.

Start/End Time: Record start/end times of survey. This should reflect the total time, not the actual survey/search time. Survey Time: Record the total active time spent surveying. This represents the time spent between the start and end time that is exclusively expended searching for FYLF. Time spent filling out VES data sheets, capturing or identifying animals, or taking breaks is included within the start and end times, but is excluded from Survey Time. A stopwatch should be used as this variable should not be estimated. Start/End GPS: Coordinates of start and end survey locations on the stream. Average waypoints if possible.

Datum, Metric/US, Accy: Indicate coordinate datum (i.e., NAD83, WGS84) and circle either Metric or US if relevant. If possible record Accuracy of GPS (in same units as circled).

Air/Water Temp (C): Record temperature of air (in the shade) and water (well-mixed/moving flow) at start and end of survey or mid-day when possible, in degrees Celsius.

%Right/Left Bank: The proportion of the right bank or left bank (facing downstream) bank that was surveyed of the total survey reach, to the nearest 10 or 25%.

Circle the appropriate variable that describes the current survey conditions. If weather in the last 24 hours may have significance on survey, write a brief note explaining why.

Note presence/absence of non-native predators/invasives (i.e., bullfrogs, smallmouth bass or crayfish) anywhere in survey reach. If needed, add notes on back of page.

Photo numbers: Record digital photo ID numbers for photos taken throughoutsurvey. Include photos of the start and end locations, typical mid- channel habitat, typical edgewater and backwater habitats, examples of breeding habitat (occupied or otherwise), etc. If needed, add notes on back of page.

Detailed Data

***Note: Some fields are applicable only to certain lifestages. Be sure to record N/A or “–” in the datasheet for fields not appropriate to the observation. Avoid leaving fields blank.

Lake Clementine Hydroelectric Project, FERC No. 13432 Amphibian and Reptile Study Plan

UTM E/UTM N: Coordinates of observation location. Average waypoints and provide accuracy if possible.

Lifestage/Sex: Note life stage of individual; enter code from list:

AF Adult Female AM Adult Male AU Adult Unknown J Juvenile Y Young-of-Year (newly metamorphosed – fall only) L Larvae/Tadpole E Egg mass

# Observed: Number of individuals noted in a single location (e.g., 1 AM on boulder in a riffle vs. 50 tadpoles in a backwater pool)

Gosner Stage: Gosner stage for egg masses and tadpoles following Gosner (1960). If categorized, then note categories on back of datasheet. If possible, take macro photo underwater to use for validation/verification at a later time.

Length (mm): For post-metamorphic individuals (Adults, Juv, YOY) measure SVL (Snout to vent length). For Tadpoles, measure Total length (tip of nose to tip of tail)

Total Depth (m): For all egg masses and representative number of tadpole groups, record total depth at the location of the observation. If egg masses are at significantly different depths than total depth make a note.

Mid-Col Velocity (m/s): For egg masses and representative number of tadpole groups, record average local mid-column flow velocity of the microhabitat. For egg masses, this should be immediately adjacent to the oviposition location.

EM/Perch Substrate: Substrate size of perch for adults/juveniles/YOY or attachment site for egg masses (N/A for tadpoles)

SLT Silt SND Sand (< 2mm) GRV Gravel (2 – 64 mm) COB Cobble (64 – 256 mm)

Lake Clementine Hydroelectric Project, FERC No. 13432 Amphibian and Reptile Study Plan

BLD Boulder (> 256 mm) BDX Bedrock WOOD Woody debris, treeroots, logs VEG Vegetation

Dominant Riparian Type: Describe dominant riparian/adjacent channel vegetation based on Lind (1997) to provide data on vegetation encroachment; enter code from list:

1 Gravel/Cobble Bar (side or mid channel, clear of veg) 2 Pure Willow 3 Willow/Alder Mix 4 Alder Dominant 5 Mature Riparian 6 Bedrock (clear of veg) Geomorphic Unit: Identify the geomorphic unit at location of observation (Frissell et al. 1986, Montgomery and Buffington 1997). Categories used:

RIF (Riffle): swift flow, rippled water surface, shallow depth RUN: slow gently moving flow, faster than a pool, slower than a riffle, moderate depth POOL: includes flatwater, dammed pools, confluence pools, mid-channel pools and pool tail-outs STEP: boulders transverse to the flow creating short pour- overs and plunge pools on the downstream side RAP (Rapid): swift water with breaking waves, rapids of high gradient BDX (Bedrock): chutes or sheet flow over bedrock

Nearest Bank: Record the bank nearest the observation, when looking downstream. RB (Right Bank), LB (Left Bank), MC (Mid- Channel).

Photo Numbers: Photos of individual or habitat at location. For Adults, Juveniles and YOY, Chin photos can be very helpful for future surveys. Use white background and try to take picture with little/no angle (i.e., plane of camera is parallel to plane of frog chin.

Notes: Include here any relevant information. Description of local habitat, species condition, presence of non-natives, photo description, etc. References:

Heyer, W. R., M. A. Donnelly, R. W. McDiarmid, L. C. Hayek and M. S. Foster, Eds. (1994). Measuring and monitoring biological diversity: Standard methods for amphibians. Biological

Lake Clementine Hydroelectric Project, FERC No. 13432 Amphibian and Reptile Study Plan

Diversity Handbook Series. Washington D.C., Smithsonian Institution Press.

Lind, A.J. (1997). Survey Protocol for Foothill Yellow-legged Frogs (Rana boylii) in Streams. USDA Forest Service, Pacific Southwest Research Station, Arcata, CA. DG:S27L01A.

Seltinrich, C.P. and Pool, A.C. (2002). A Standardized Approach for Habitat Assessments and Visual Encounter Surveys for the Foothill Yellow-legged Frog (Rana boylii). Pacific Gas & Electric Company.

Frissell, C., W. Liss, C. Warren, and M. Hurley. 1986. A hierarchical framework for stream habitat classification: viewing streams in a watershed context. Environmental Management 10:199-214.

Montgomery, D., and J. Buffington. 1997. Channel-reach morphology in mountain drainage basins. Bulletin of the Geological Society of America 109:596-611.

CCADC. 2007. Decontamination Protocol to Reduce the Risk of Spreading Infectious Amphibian Diseases in Freshwater Systems. California Center for Amphibian Disease Control. http://www.ccadc.us/docs/DeconForProfessionals.pdf

Johnson M, Berger L, Philips L, Speare R. 2003. Fungicidal effects of chemical disinfectants, UV light, dessication and heat on the amphibian chytrid, Batrachochytrium dendrobatidis. Diseases of Aquatic Organisms. Vol(57) 255-260.

USFSR5 meso-habitat types

Lake Clementine Hydroelectric Project, FERC No. 13432 Amphibian and Reptile Study Plan

Field Equipment List Required:

Field notebook Datasheets (w/copy of survey protocol) and clipboard Clean copies of study site aerial/topo maps (for sketching habitats, survey area, etc.) Pencil, pen, sharpie Stopwatch Flagging Thermometer Binoculars Dip net or small handheld net for scooping tadpoles and catching individuals Clear see-thru rulers (marked in metric) to measure individual length Small clear plastic vial or wide-mouth bottle to capture tads for identification Camera – extra batteries, memory card Background for chin photo pictures (white piece of paper, or something of solid color) Handheld GPS – extra batteries Velocity meter w/wading rod or other stick/device to measure depth – Marsh McBirney recommended – need accuracy in low velocities - +/- 0.01 m/s ideal. Waders Snorkeling gear – drysuit, mask/snorkel, shoes – for spring eggmass surveys

First Aid kit Personal – water, food, sunscreen, bug juice, etc

Recommended:

Viewing box (ideal if made of plexiglass, but could be lightweight plastic with clear plastic affixed to hole in bottom) Snorkeling gear – drysuit, mask/snorkel, shoes Rope to tie off and use in swift water Hand lens (aid in Gosner staging and identification of limb buds and mouth parts on tadpoles) 30m tape – w/metric markings

Optional:

Range finder – to record large scale distances (river width, length of bar, etc) Compass Walkie talkies Inflatable kayak, inner tube, or some means of floating river if needed – includes lifejackets, drybags, paddles, ropes, etc.

TR-3

WILDLIFE STUDY PLAN

October 17, 2014

STUDY GOAL AND OBJECTIVE The Lake Clementine Hydroelectric Project (Project) Pre-Application Document, filed August 2010, and subsequent consultation with stakeholder identified issues associated with wildlife resources for which the existing, relevant, and reasonably available information is insufficient to address the issues. These issues are:

Issue: The effects of Project construction and operation on resident peregrine falcons.

Issue: Project effects on resident and migratory bald eagles.

Issue: Project effects on nesting raptors.

Issue: The effects of Project construction and operation on resident and migratory wildlife species.

Issue: The potential for river otters to become impinged on the intake trash rack.

Issue: Project effects on bats.

Issue: Project effects of security lighting on nocturnal wildlife use.

Issue: The effect of Project construction, operation, and maintenance on nesting and nesting success of special-status (i.e., State threatened, endangered, fully protected, and species of special concern) bird species.

Issue: The effects of Project construction, operation, and maintenance on raptors and special-status bird wintering use and foraging habitat.

Issue: The effects of Project facility noise on wildlife species.

Issue: The effects of powerhouse operations on wildlife species (i.e., electrocution).

Issue: The effects of transmission line construction and maintenance on wildlife habitat.

Issue: The effects of transmission line operations on all bird species (i.e., collision and electrocution).

The goal of this study is to identify wildlife habitats and wildlife species that are likely to occupy habitats in the area affected by the Project including Lake Clementine, North Fork American

1 October 17, 2014

River (NFAR), access routes, and transmission line routes and to assess the effects of Project construction, operation, and maintenance on wildlife species.

EXISTING INFORMATION The Project would be located on Lake Clementine adjacent to the North Fork Dam on the NFAR in Placer County, California. Lake Clementine, which was formed by the North Fork debris dam constructed in 1939, is now owned by the U.S. Army Corps of Engineers. Lake Clementine has a surface area of 280 acres and a capacity of 14,700 acre-feet. It rises 155 feet (ft) above the lowest foundation and has a spillway crest elevation of 715 ft. The dam crest length is 620 ft and the thickness varies from 22 ft at the base to 6.8 ft at the top.

The proposed Project would consist of an intake near the left abutment of North Fork Dam, an open canal, and one or two penstocks connecting to a powerhouse that would house two or three generating units, totaling a combined capacity of 16 megawatts. The powerhouse would be located between 200 and 600 ft downstream of the dam. Construction of the intake, canal, and penstock intakes would require excavating the slope on the south side of the canyon adjacent to the dam. A switchyard consisting of station generator bus, station service transformer, a step-up transformer, and a circuit breaker would be located at an elevation above the high flood flow elevation of the NFAR near the powerhouse or in a room of the powerhouse building. A 60- kilovolt transmission line would be constructed to connect the switchyard with Pacific Gas and Electric’s Halsey Substation. The exact location of the transmission line has not been determined at this time. Two alternative access routes are being considered for Project construction. One access route would entail reconstructing a 2.5-mile (mi) long access road on the south side of the NFAR between Old Foresthill Road and North Fork Dam. The route would follow the alignment of an abandoned dirt road that is currently used as a hiking and biking trail. After construction is completed, the road could either be removed and the site restored or could remain to in place to serve another purpose, such as an emergency access or a recreation trail. The second access route under consideration would use the existing Lower Lake Clementine Road. This route would require making upgrades to accommodate construction equipment and traffic. In addition, improving and using this road for Project construction would likely require traffic controls to ensure public safety and facilitate construction activities. The proposed Project would operate in a run-of-river mode with flows coming into Lake Clementine being equal to flows going out of Lake Clementine.

One specific study on wildlife species potentially occurring in the Project-affected area was conducted in the vicinity of Lake Clementine for the U.S. Army Corps of Engineers (Jones & Stokes 1998). In addition, studies performed for relicensing Placer County Water Agency’s Middle Fork American River Project (Federal Energy Regulatory Commission [FERC] Project No. 2079) may provide information applicable to the NFAR.

2 October 17, 2014

A peregrine falcon pair nests on Robbers Roost, a rock monolith located approximately 1 mi upstream of the dam. Robbers Roost is a historical peregrine falcon nesting location and has been active for several years producing three young in 2013. Nesting activities generally occur from March through July (personal communication with M. Jeter, Biologist, California Department of Fish and Wildlife [CDFW], Sacramento, CA, with J. Holeman, Consultant, J.R. Holeman Consulting, Rio Vista, CA, on May 6, 2014).

Migratory wintering bald eagles are commonly observed at Lake Clementine; however, the closest nest is located at Folsom Lake (personal communication with M. Jeter, Biologist, California Department of Fish and Wildlife [CDFW], Sacramento, CA, with J. Holeman, Consultant, J.R. Holeman Consulting, Rio Vista, CA, on May 6, 2014).

NEXUS BETWEEN PROJECT AND RESOURCE TO BE STUDIED AND HOW THE RESULTS WILL BE USED The proposed Project would use the existing North Fork Dam, which was constructed in 1939 as a debris dam with the purpose of containing gold mining debris. Water is passed downstream over the dam through a spillway. The spillway is currently the only passage route for flow. No other dams are located on the NFAR, and river flow fluctuates seasonally. Since 1941, the 10 percent flow exceedance for May, the month with the highest average flow, is 2,940 cubic feet per second (cfs) (average 1,640 cfs) and minimum flow (average 50 cfs) occurs in September (data from USGS Gage No. 11427000, NFAR at North Fork Dam).

Construction of the Project facilities has the potential to alter habitat used by various resident and migratory wildlife species. Construction would likely also require blasting or another method for excavating rock to construct Project facilities, either of which could disturb wildlife during critical periods of their reproductive cycles as well as use of nearby habitats.

STUDY AREA AND STUDY SITES The habitat mapping study area will include a 0.5-mi zone around all Project facilities and areas used for construction, such as temporary lay down and staging areas and access roads. A map of the approximate study area is attached.

The study area will include all temporary and permanent Project features including: laydown and staging areas, access routes, transmission line routes, intake and canal, penstock, powerhouse, and switchyard.

METHODS The study methods include use of the California Wildlife Habitat Relationships Program and site survey protocols for federally listed and California threatened, endangered, fully protected, and species of special concern that may occur in the Project-affected area.

3 October 17, 2014

Habitat Mapping Wildlife habitats within 0.5 mi of all Project facilities, including temporary laydown and staging areas, access routes, transmission line routes, powerhouse, switchyard, and any other areas used for Project development, operation, and maintenance will be mapped using habitat descriptions contained in the California Wildlife Habitat Relationships Database (CWHRD) (CDFW 2014). Although different species have individual levels of sensitivity to disturbance, Lake Clementine Hydro, LLC (LCH), believes that 0.5 mi will provide a reasonable distance from the Project to determine what species may be affected by the Project and to assess the relative importance of any habitat losses related to Project construction and operation. Using aerial photography, existing literature, and existing Geographic Information System data layers of habitat types, LCH will create maps of wildlife habitats within the study area. Maps of the habitat areas will be verified by field assessment of representative habitat types.

California Wildlife Habitat Relationships Database Once habitats have been identified and mapped, LCH will use the CWHRD to determine which species might be present within the study area and could be directly or indirectly affected by Project development and operation. LCH will use the predictive model suitability ratings to determine the species that are likely to occur in each habitat and the three life-stage requisites (i.e., breeding, cover, and feeding) that the habitat would provide for each of the species. The table below shows the tabular format that will be used to present this information.

Life Stage Requisite Habitat Species Breeding Cover Feeding (Habitat Type) (Species that may occur) X X X

The list of species generated using the CWHRD will be reviewed for any species that the U.S. Fish and Wildlife Service lists as threatened or endangered or as California threatened, endangered, fully protected, and species of special concern and raptor species that may occur in the Project-affected area and require additional study.

Field Surveys CDFW has identified several species that require specific surveys to determine whether they may be present within the areas directly affected by the Project, plus a 500-foot buffer zone. Each species or grouping of species requires a specific survey protocol. River Otter River otters are known to occur in the NFAR and stakeholders identified a concern for their possible impingement on the Project intake trash racks. To address this concern LCH plans to conduct a literature search regarding the relationship between flow velocity and river otter. The literature search will also look for any records of river otter being impinged on diversion intakes.

4 October 17, 2014

Given the expected flow velocity, LCH assumes that river otter would be able to swim against this level of current and that a healthy river otter would be able to avoid entrainment or impingement. Information gathered from literature and records would help to confirm this assumption.

Peregrine Falcon A known peregrine falcon eyrie is located at Robbers Roost approximately 1 mi upstream of North Fork Dam. The activities at this active nest have been observed by local bird enthusiasts for many years. This study will consist of two phases. The first phase will be to gather existing relevant information regarding any records of observations of breeding and nesting activities of the Robbers Roost eyrie. Information sources may include but are not limited to a local Audubon chapter, and CDFW staff.

Information collected will be presented in a technical memorandum and will identify sources of information, present results of discussions with knowledgeable individuals, and summarize any records LCH is able to locate. This information will be made available to and reviewed with state and federal resource agencies to make a determination whether additional study is required to address Project effects.

The second phase will be implemented if additional information is required and will consist of a protocol survey of the nest territory according the methods outlined in Protocol for Observing Known and Potential Peregrine Falcon Eyries in the Pacific Northwest (Pagel 1992). The protocol consists of two or more visits (a minimum of two visits is required to determine that an eyrie is unoccupied) of at least 4 continuous hours, spaced 25 to 30 days apart, and ground observations (i.e., no helicopter use) of existing or potential nest sites. Surveys will be conducted by a biologist familiar with peregrine falcon nesting behavior and proven experience in conducting peregrine falcon nest surveys to ensure accurate data are collected during surveys. All raptors and other birds incidentally observed during surveys should be identified and the date and location observed, behavior, age, and sex (if known) will be documented.

Information from the study will identify the nesting chronology, sensitivity to disturbances, and nesting success or failure. The information would also be used for discussions about establishing limited operating periods for certain construction activities. It would also be used to assess the potential for the Project to affect this species.

Bald Eagle The nearest known bald eagle nest is located at Folsom Lake. Bald eagles are occasionally observed at Lake Clementine and the NFAR Canyon. Consistent with the study for peregrine falcons, this study plan includes two phases. The first phase will consist of gathering available relevant information about bald eagle observations at Lake Clementine and the NFAR downstream of North Fork Dam. Information may be obtained from observation records, a local Audubon chapter, CDFW personnel, and California State Parks personnel. Additional records may be obtained from Audubon Christmas Bird counts that may cover the Lake Clementine vicinity and the 2-week nationwide mid-winter bald eagle survey.

5 October 17, 2014

Information from this phase will be compiled into a technical memorandum that identifies sources of information and summarizes any records LCH is able to locate. The number and regularity of bald eagle sightings could indicate the importance of the NFAR and Lake Clementine for bald eagles. This information will be made available and reviewed with state and federal resource agencies to make a determination whether or not additional study is required to address Project effects.

The second phase will be implemented if additional information is required and will consist of protocol surveys as defined by Bald Eagle Breeding Survey Instructions (CDFG 2010) and the Protocol for Evaluating Bald Eagle Habitat and Populations in California (Jackman and Jenkins 2004). The surveys will identify the presence of any nest territories, nesting chronology, and location (if any) of night roost sites. The information would also be used for discussions about establishing limited operating periods for certain construction activities and assessing the potential for the Project to affect this species.

The specific survey protocols for nesting, wintering, and night roosts are summarized below:

Nesting Surveys  Identify potential bald eagle nesting habitat and search for new nest sites. Searches for new nest sites will consist of three separate site visits with the initial site visit in late February through March, the second site visit during the mid- nesting season in late April through May, and third site visit during the late nesting season from early June to early July. Nest survey results will be reported to resource agencies using the California Bald Eagle Nesting Territory Form (CDFG 2010).  Monitor existing nest sites annually (during construction). Existing nest sites will be surveyed annually while the Project is being constructed and visited three times during each nesting season: early in the season (early March) to determine occupancy, during the mid-nesting season (late April/early May) to determine the presence of eggs or young, and late in the season (mid-June) to determine success and the number of young near fledging). Nest survey results will be reported to resource agencies using the California Bald Eagle Nesting Territory Form (CDFG 2010). Wintering Surveys  Monitor the size and distribution of wintering bald eagle populations. Single-day surveys will be conducted monthly along established survey census routes, from December through February (three surveys, at least two weeks apart) to encompass peak wintering activity in the Project vicinity. The January survey will occur during the 2-week, nationwide mid-winter bald eagle survey, typically scheduled during the first part of January every year, coordinated in California by CDFW and other entities. Survey forms from Jackman and Jenkins (2004) will be used to record survey data. If this survey is being conducted by others, LCH does not propose to conduct a separate survey.

6 October 17, 2014

Night Roost Surveys  Conduct night winter roost surveys for bald eagles monthly from December through February. These monthly surveys will be conducted in the afternoon/early evening in areas where eagles were observed wintering in an effort to identify any night roosts. If roosts are located, the number of eagles will be recorded as they move from foraging to roosting habitat. These locations will be revisited the following morning, one-half hour before sunrise for at least 2 hours to count the number of eagles leaving the roost. If a stand is identified as a probable night roost, the area will be revisited during the day to search for any evidence of bald eagle use (feathers and/or castings) and the exact location should be recorded onto a Global Positioning System (GPS). Survey forms from Jackman and Jenkins (2004) will be used to record survey data. Any other raptor species observed during the surveys will be recorded along with activities to the extent possible.

Other Raptor Species The surrounding area provides habitat that may support other raptor species. As part of the peregrine falcon and bald eagle surveys, information about any other raptor species observed will be recorded, including approximate location and activity, if discernible. Nesting surveys will be performed at all areas directly affected by the Project, including permanent and temporary Project features needed during the construction including a 500-foot buffer. Survey techniques described by Fuller and Mosher (1987) and Bird and Bildstein (2007) for surveying, researching, and managing raptors will be used. The area of habitat for each of the species will be estimated based on the habitat mapping and the CWHRD.

Special-Status Riparian Birds and Nest Monitoring This survey will focus primarily on yellow warbler and yellow-breasted chat and any other special status species identified from the CWHRD as having a high potential for occurring in riparian habitat within 500 ft of all permanent and temporary Project features. The purpose of this study is to document the presence and distribution of yellow warbler and yellow-breasted chat, their nesting status, and nest locations, and the species diversity of nesting riparian birds in the Project vicinity. Information from surveys will be used to develop, if appropriate, a limited operating period, buffers, and other avoidance and minimization measures for Project- related construction and long-term operations and maintenance activities that have the potential to affect special-status riparian birds.

As recommended by CDFW, LCH will survey for nesting riparian birds using point counts and conduct nest searches for any special-status riparian bird species detected during point count surveys. Point counts are standard methodologies used throughout the world to monitor birds. Point count methodologies are described in the Handbook of Field Methods for Monitoring Landbirds (Ralph et al., 1993). Nest searches will be conducted in accordance with Martin and Geupel (1993). Surveys and nest searches will be conducted by a biologist with knowledge of riparian birds and experience conducting nest searches. All birds detected or incidentally

7 October 17, 2014

Lake Clementine Hydroelectric Project, FERC No. 13432 ©2014, Lake Clementine Hydro, LLC Lake Clementine Hydroelectric Project, FERC No. 13432 Wildlife Study Plan observed during surveys will be identified and the date, location, behavior, age, and sex (if known) will be documented.

Information from this study will identify the presence of special-status bird species in the area affected by the Project. The information also will be used to develop mitigation measures to minimize Project effects on these species of birds, such as limited operating periods during construction, ensuring adequate buffer zones, and implementing avoidance measures.

Special-Status Bats Several species of bats have the potential to occur in the area affected by the Project. Using the results from the CWHRD, LCH will determine which bat species are most likely to occur in the vicinity of the Project. The goals of this study are to determine the effects of Project construction, operation, and maintenance activities on bats. The objective is to document the following information regarding special status bats: (1) species diversity, (2) specific locations of roosts relative to the Project features, (3) identification of roost types, and (4) the spatial and temporal distribution of species.

As recommended by CDFW, LCH will implement the following steps:

 Initial reconnaissance – Conduct surveys during the late spring (April to May) for bats and their signs at all existing facilities (e.g., North Fork Dam, bridges, buildings, and other structures) located within the proposed footprint of all proposed Project footprints, alignments, and alternatives for construction laydown and staging areas and access routes, road improvements, generation facilities, the powerhouse and substation, transmission line corridors, and all other areas in which ground-disturbing activities may occur as a result of the Project. Maternity roosts, day roosts, night roosts, and winter hibernacula for bats will be considered during initial reconnaissance.  Focused surveys – Acoustic sampling and mist net surveys will be conducted at locations where bats or their signs were found during initial reconnaissance surveys. Surveys will be conducted twice—once during the peak reproductive period (July to August) and once during the fall migration (September). Surveys will be conducted near dusk when bats begin to emerge from their roosts. – Acoustic sampling will be conducted at each sampling location during the two sampling events during peak bat activity using an Anabal SD1 bat detector system by Titley Scientific™1 or similar device to identify bat species. For known roost sites, Anabal units or similar device will be positioned to record bats exiting the

1 http://www.titley-scientific.com/us/index.php

8 October 17, 2014

roost. For sampling locations without known roosts, units will be placed in adjacent foraging habitats or flight corridors. Survey results will be analyzed using Analook software from Tilley Scientific™ or similar software compatible with detection device used. – Mist net sampling will be conducted at each sampling location during the two sampling events by opening mist nets from one-half hour before sunset to approximately 10PM or until bat activity has ceased. Nets should be placed adjacent to bat-occupied facilities, over or immediately adjacent to water, and in flight corridors between potential roosting structures and foraging habitats. Mist nets should be checked every 15 minutes for bats. Captured bats will be identified to species level and released. Description of Project Lighting LCH will prepare a description of the proposed Project security lighting and a site plan showing the proposed locations of lights. LCH will indicate the number of lights, locations, and brightness on the site plan. The results from the CWHRD will be used to identify nocturnal species that may be present in the vicinity of areas requiring security lighting such as the powerhouse and switchyard. LCH will also conduct a literature review regarding the response of nocturnal wildlife to lighting.

ANALYSIS Project effects will be determined based on the results of the various study elements described above. The area of each habitat type removed for the Project will be determined relative to the area of corresponding habitats of the same types within the study area. Species potentially affected by the loss of habitat will be listed.

LCH will determine the extent of area illuminated by each proposed light. The illuminated area created by all proposed lighting would be calculated using these “footprints” taking into account that some areas may be illuminated by more than one light and some areas may be affected by existing lights. Based on the results of the CWHRD and literature review LCH will determine the potential effects of lighting on nocturnal wildlife with a focus on special status wildlife species that may be affected.

CONSISTENCY WITH GENERALLY ACCEPTED SCIENTIFIC PRACTICE This approach to assessing project effects to wildlife is consistent with other hydroelectric proceedings throughout the United States.

PRODUCTS Based on study results, LCH will develop a map showing wildlife habitats within 0. 5 mi of all Project features, areas temporarily used during construction, and post construction security lighting. A table of wildlife species, including breeding, cover, and feeding life requisites, potentially occurring will be provided.

9 October 17, 2014

A technical memorandum documenting study dates, study personnel and qualifications, location of study or sampling sites, and information collected will be prepared and distributed to resource agencies following each study phase. The technical memoranda will present raw data only.

A final report will be prepared summarizing the technical memoranda and analyzing the potential effects the Project would have on target species.

RELATIONSHIP TO OTHER STUDIES

None.

SCHEDULE Habitat mapping and ground-truthing will be conducted in 2015. The California Wildlife Habitat Relationships modeling would occur after habitat mapping. Field studies will be initiated in 2015. A final report will be issued in October or November of 2015.

Implementation of studies is dependent on receiving required permissions and permits from the U.S. Army Corps of Engineers.

LEVEL OF EFFORT AND COST Costs are to be determined.

REFERENCES Bird, D.M. and K.L. Bildstein. 2007. Raptor Research and Management Techniques. Hancock House Publishers CDFG (California Department of Fish and Game). 2010. Bald Eagle Breeding Survey Instructions and California Bald Eagle Nesting Territory Field Form. California Department of Fish and Game, Sacramento, CA. CDFW (California Department of Fish and Wildlife). 2014. California Natural Diversity Database. Available at: http://www.dfg.ca.gov/biogeodata/cnddb/. California Department of Fish and Wildlife, Sacramento, CA Fuller, M.R. and J.A. Mosher. 1987. Raptor Survey Techniques. U.S. Fish and Wildlife Service. Jackman, R.E. and J.M. Jenkins. 2004. Protocol for Evaluating Bald Eagle Habitat and Populations in California. Prepared for the U.S. Fish and Wildlife Service, Sacramento, CA. Jones & Stokes Associates, Inc. 1998. Environmental Information Paper - North Fork Dam, American River, Placer County, California. Sacramento, CA. Martin, T.E. and G.R. Geupel. 1993. Nest-monitoring Plots: Methods for Locating Nests and Monitoring Success. Journal of Field Ornithology 64:507–514.

10 October 17, 2014

Mayer, K.E and W.F Laudenslayer. 1988. A Guide to Wildlife Habitats of California. Available at https://www.dfg.ca.gov/biogeodata/cwhr/wildlife_habitats.asp. Accessed May 12, 2014. California Department of Fish and Game, Sacramento, CA. 166 pp. Pagel, J.E. 1992. Protocol for Observing Known and Potential Peregrine Falcon Eyries in the Pacific Northwest. Hydropower Reform Coalition. Ralph, C.J., G.R. Geupel, P. Pyle, T.E. Martin, and D.F. DeSanta. 1993. Handbook of Field Methods for Monitoring Landbirds. General Technical Report PSW-GTR 144. U.S. Forest Service, Pacific Southwest Research Station, Albany, CA.

11 October 17, 2014

12 October 17, 2014

RR-1

RECREATION RESOURCES STUDY PLAN

October 17, 2014

STUDY GOAL AND OBJECTIVE The Lake Clementine Hydroelectric Project (Project) Pre-Application Document, filed August 2010, identified issues associated with recreation resources for which the existing, relevant, and reasonably available information is insufficient to address the issues (America Renewables 2010). These issues are:

Issue: Project construction and operation has the potential to affect recreational access to Lake Clementine near the dam and in the reach of the North Fork of the American River (NFAR) below the dam. Specific effects may relate to angling; route and trail use (i.e., vehicle, pedestrian, bicycle, and equestrian); and boat ramp use and safety.

Issue: Project operation has the potential to alter water temperature downstream of the dam.

Issue: The effects of Project operation on reservoir water level fluctuation.

Issue: Project operation consistency with Wild and Scenic River designation of the NFAR downstream of the dam.

Issue: Project effects on the ability of state parks to generate revenue.

Issue: Project effects on recreation events that take place in the area and use Lake Clementine and associated trails (e.g., Tevis Cup, Western States Equestrian Race, and triathlons), including effects on Auburn businesses that support these events.

Issue: Project effects on recreational angling in Lake Clementine and the NFAR between North Fork Dam and immediately downstream of the powerhouse tailrace.

Issue: Project effects on swimmers in the NFAR downstream of North Fork Dam.

The goal of this study is to develop the essential additional information necessary to supplement the existing information to address the identified issue(s). In this case, the objective of this study is to identify, map, and characterize the formal and informal points of recreational use and access near the proposed powerhouse. The study will rely on the temperature results of the Water Quality Study to compare the existing water temperature regime in the NFAR downstream of the dam to that which would be expected to exist under proposed Project operation. The study would also rely on the results of fishery studies that will identify game fish that exist in the vicinity of the dam and downstream of the dam for a distance of 1,000 feet (ft) downstream of the Project tailrace.

EXISTING INFORMATION The Project would be located at Lake Clementine adjacent to North Fork Dam on the NFAR in Placer County, California. Lake Clementine, which was formed by the North Fork debris dam constructed in 1939, is now owned by the U.S. Army Corps of Engineers. Lake Clementine has a surface area of 280 acres and a capacity of 14,700 acre-feet. It rises 155 ft above the lowest foundation and has a spillway crest elevation of 715 ft. The dam crest length is 620 ft and the thickness varies from 22 ft at the base to 6.8 ft at the top.

The proposed Project would consist of an intake near the left abutment of North Fork Dam, an open canal, and one or two penstocks connecting to a powerhouse that would house two or three generating units, totaling a combined capacity of 16 MW. The powerhouse would be located between 200 and 600 ft downstream of the dam. Construction of the intake, canal, and penstock intakes would require excavating the slope on the south side of the canyon adjacent to the dam. A switchyard consisting of a station generator bus, station service transformer, a step-up transformer, and circuit breaker would be located at an elevation above the high flood flow elevation of the NFAR near the powerhouse or in a room of the powerhouse building. A 60- kilovolt transmission line would be constructed to connect the powerhouse switchyard with Pacific Gas and Electric’s Halsey Substation. The exact location of the transmission line has not been determined at this time. Two alternative access routes are being considered for Project construction. One access route would entail reconstructing a 2.5-mile-long access road on the south side of the NFAR between the Old Foresthill Road and North Fork Dam. The route would follow the alignment of an abandoned dirt road that is currently used as a hiking and biking trail. After construction is completed, the road either could be removed and the site restored or could remain in place to serve another purpose, such as an emergency access or a recreation trail. The second access route would use the existing Lower Lake Clementine Road. This route would require making upgrades to accommodate construction equipment and traffic. In addition, improving and using this road for Project construction would likely require traffic controls to ensure public safety and to facilitate construction activities. The proposed Project would operate in a run-of-river mode with flows coming into Lake Clementine being equal to flows going out of Lake Clementine.

Recreation information including trail locations, recreation amenities, and road access in the vicinity of Lake Clementine are available on the internet (e.g., Google Earth and U.S. Geological Survey maps) and webpage information and recreation maps available for the Auburn State Recreation Area.

Road, Lake Clementine Road, parking areas, boat launch ramp, and the NFAR downstream of the dam. Although construction would be planned to take place primarily during the off-peak recreation season to minimize disrupting recreational use, the access currently available to the public may be affected at times during Project construction and operation.

Water from Lake Clementine that is used for generation and released back into NFAR could have a different temperature than that which currently exists with all water entering the NFAR by spilling over the dam. A changed water temperature regime could affect water contact recreational use in the NFAR downstream of the dam.

Construction work related to the intake, penstocks, and powerhouse could periodically limit use of the boat launch ramp and restrict access to the area immediately downstream of the dam.

STUDY AREA AND STUDY SITES The study area includes Project-affected areas near the dam such as the access road routes, boat ramp, formal and informal trails, and the NFAR immediately downstream of the dam.

METHODS This study will compile existing information about the areas used for recreational use along with the amount, type, and timing of recreational use at these locations.

Geographic Information System (GIS) technology and Global Positioning System (GPS) data will be used to create maps showing the locations of the access road, boat ramp, formal and informal trails, and any other point of recurrent recreation use. Maps will have a scale of no less than 1 inch equal to 60 ft and show elevation contours at 10-ft intervals. The Project footprint on the maps will show the area within 600 ft of the normal high water mark of the lake and river extending 0.2 mile up and downstream of the left (south) dam abutment. The locations of Project features and areas used for construction and maintenance will also be shown on these maps.

To characterize recreational use in the Project-affected area existing visitor use data will be compiled from sources including, but not limited to, Auburn State Recreation Area and Auburn Boat Club. In addition, visitor surveys and spot counts will be conducted to collect information about recreation use at the reservoir and downstream of the dam. Spot counts of vehicles at the parking lots near the boat launch at North Fork Dam and anglers in the reach immediately below North Fork Dam will be conducted on 2 non-holiday weekend days and 2 weekdays per month over a continuous 12 month period (i.e., to collect information during all seasons). Exit visitor surveys during this same period will also be administered by staff at the boat launch and drop boxes will be placed at access point(s) to the reach immediately below the dam to collect self- administered visitor surveys throughout the study period. Surveys will contain questions necessary to characterize visitor use at the reservoir and in the reach immediately below the dam, such as activity, party size, frequency of use, and general demographic information such as visitors’ place of residence. The survey will include also include specific questions about angling to report the (1) number of anglers, (2) number of hours spent angling, (3) number, species, and size of fish caught and retained; and (4) general demographic information such as visitors’ place of residence.

To estimate the number of visitors using the trail between Old Foresthill Road and North Fork Dam, which could potentially be used as an access road, at least one trail counter will be installed along the trail. Trail count data will be collected for a 6-month to 12-month period.

LCH will prepare a narrative description of Project operation and maintenance activities, including the locations of activities, routes used for access, type of vehicle or equipment (e.g., half ton truck, off-highway construction equipment) and frequency of maintenance activities. This information will be used to evaluate potential conflicts with recreation activities.

The study will report the status of the NFAR designation under the Wild and Scenic River Act and describe applicable agency management direction.

ANALYSIS GIS mapping will be used to determine the recreational features and access that would be affected by the Project and identify measures necessary to minimize these effects. Specifically, Project maps can be used to adjust, if necessary, locations of Project infrastructure, trails, and points of public access or the timing of Project activities.

Recreation use and creel census data will be used to quantify the total estimated number of users by time of year and type of recreational activity. This information can be considered in the development of the construction plan and schedule to minimize Project effects on recreation users. For any unavoidable effects on recreation resources, this information will be used to quantify these Project effects.

CONSISTENCY WITH GENERALLY ACCEPTED SCIENTIFIC PRACTICE The proposed study methods are consistent with standard methodologies for documenting the locations of recreational use and characterizing recreation use associated with hydropower development to assess Project effects.

PRODUCTS The study will generate a GIS base map of existing recreation features and points of public access and a summary of recreational use in the vicinity of the Project. These study results will be reported in the Application for Initial License, Exhibit E.

RELATIONSHIP TO OTHER STUDIES Results of the Water Quality Study will be reviewed to report any expected change in water temperature in the NFAR immediately downstream of the dam resulting from proposed Project operation. Results of fishery study will be used to identify the potential for angler use in the vicinity of the dam and the NFAR below the dam.

SCHEDULE GPS data collection and GPS mapping will be completed in 2015. Researching and compiling existing information about recreation use will be completed by the fall of 2015.

Implementation of studies is dependent on receiving required permissions and permits from the U.S. Army Corps of Engineers.

LEVEL OF EFFORT AND COST Costs are to be determined.

REFERENCES America Renewables. 2010. Lake Clementine Hydropower Project, FERC Project No. 13432, Pre-Application Document. America Renewables, Rolling Hills Estates, CA. August 2010.

6 October 17, 2014 Lake Clementine Hydroelectric Project, FERC No. 13432 ©2014, Lake Clementine Hydro, LLC Lake Clementine Hydroelectric Project, FERC No. 13432 Visual and Aesthetic Resources Study Plan

RR-2

VISUAL AND AESTHETIC RESOURCES STUDY PLAN

October 17, 2014

STUDY GOAL AND OBJECTIVE The Lake Clementine Hydroelectric Project (Project) Pre-Application Document, filed August 2010, identified issue(s) associated with visual and aesthetic resources for which the existing, relevant, and reasonably available information is insufficient to address the issue(s) (America Renewables 2010). These issues are:

Issue: The Project infrastructure, operation, and maintenance have the potential to change the visual environment and aesthetic resources in the vicinity of the Project.

Issue: Project operation would reduce the volume of flow over the spillway, potentially changing the look, sound, and feel of the water falling over the dam.

Issue: Project lighting may affect the visual quality of the area.

Issue: Noise produced at the Project switchyard.

The goal of this study is to develop the essential additional information necessary to supplement existing information needed to address the identified issue(s). In this case, the objective of this study is to document the appearance of different quantities of flow over the dam spillway and to provide visual simulations of Project facilities, including the powerhouse, road improvements, transmission line, and other appurtenant structures. Required security lighting may be designed to address Project effects on visual quality of the area.

EXISTING INFORMATION The Project would be located at Lake Clementine adjacent to North Fork Dam on the North Fork of the American River (NFAR) in Placer County, California. Lake Clementine, which was formed by the North Fork debris dam constructed in 1939, is now owned by the U.S. Army Corps of Engineers. Lake Clementine has a surface area of 280 acres and a capacity of 14,700 acre-feet. It rises 155 feet (ft) above the lowest foundation and has a spillway crest elevation of 715 ft. The dam crest length is 620 ft and the thickness varies from 22 ft at the base to 6.8 ft at the top.

1 October 17, 2014 Lake Clementine Hydroelectric Project, FERC No. 13432 ©2014, Lake Clementine Hydro, LLC Lake Clementine Hydroelectric Project, FERC No. 13432 Visual and Aesthetic Resources Study Plan

A switchyard consisting of a station generator bus, station service transformer, step-up transformer, and circuit breaker would be located at an elevation above the high flood flow elevation of the NFAR near the powerhouse or in a room of the powerhouse building. A 60- kilovolt transmission line would be constructed to connect the switchyard with Pacific Gas and Electric’s Halsey Substation. The exact location of the transmission line has not been determined at this time. Two alternative access routes are being considered for Project construction. One access route would entail reconstructing a 2.5-mile-long access road on the south side of the NFAR between Old Foresthill Road and North Fork Dam. The route would follow the alignment of an abandoned dirt road that is currently used as a hiking and biking trail. After construction is completed, the road either could be removed and the site restored or could remain in place to serve another purpose, such as an emergency access or a recreation trail. The second access route under consideration would use the existing Lower Lake Clementine Road. This route would require making upgrades to accommodate construction equipment and traffic. In addition, improving and using this road for Project construction would likely require traffic controls to ensure public safety and facilitate construction activities. The proposed Project would operate in a run-of-river mode with flows coming into Lake Clementine being equal to flows going out of Lake Clementine.

NEXUS BETWEEN PROJECT AND RESOURCE TO BE STUDIED AND HOW THE RESULTS WILL BE USED The spilling of water over North Fork Dam contributes visually and audibly to the aesthetic character of the landscape in the area near the dam. The aesthetic character of the area would be altered by construction of Project facilities and possibly by altered flows over the dam from Project operation. The effect on the aesthetic environment potentially caused by these alterations would depend on points from which they are observed, as well as the degree of variance from existing conditions.

Results of the study will be used to determine the potential effects to the visual/aesthetic environment of the North Fork of the American River Canyon in the project area from Project construction and operation. The results will be evaluated to recommend changes to the Project design and measures to reduce Project effects.

There is a concern that Project security lighting of may affect the visual quality of the area.

STUDY AREA AND STUDY SITES The primary study area for this assessment is the immediate area around North Fork Dam, the spillway, and the proposed transmission line corridor to the Halsey Substation (to be determined). Up to six Key Observation Points (KOPs) will be selected to prepare visual simulations of the transmission line (two KOPs), powerhouse (three KOPs), and water flowing over the dam at high, medium, and low flow rates (one KOP). At least one KOP will be located at on the canyon rim to represent homeowner views of the proposed Project facilities.

2 October 17, 2014 Lake Clementine Hydroelectric Project, FERC No. 13432 ©2014, Lake Clementine Hydro, LLC Lake Clementine Hydroelectric Project, FERC No. 13432 Visual and Aesthetic Resources Study Plan

METHODS The two methods used for this study include developing visual simulations and videotape recording the view and sound of the flows over the dam.

Visual Simulations The study will produce visual simulations by combining site photography with accurate, rendered computer-generated models of Project facilities to predict what would be seen if the proposed Project were constructed and operated. Creation of visual simulations to analyze the potential effects of the proposed Project consists of the following:

1. Design data preparation/Site photography Visual simulation specialists will conduct a thorough review of available data for the proposed Project before visiting the site. Using all available information, and an in- house viewshed study of the surrounding area, KOPs located on publicly accessible areas will be identified throughout the Project area. A photographic inventory from KOPs will be conducted using digital photography with a resolution of at least10 megapixels. This inventory will serve as a sampling of the visual landscape and typical views of the area potentially affect by the Project. Panoramic photographs with photopoint locations (GPS coordinates) will be created and used to select KOPs that will be used for preparing visual simulations.

2. Computer 3-D digital modeling/Terrain modeling/Materials texturing The site layout and design of the powerhouse and other Project facilities will be used to generate an accurate, scaled three-dimensional (3-D) computer model. Using the U.S. Geological Survey (USGS) National Elevation Dataset to generate a Digital Elevation Model and aerial imagery, the 3-D models will be placed in real world coordinates to maximize accuracy.

3. View-matching /Lighting/Rendering After reviewing the photographs, the KOPs will be selected to view-match in 3-D software that best represent the typical Project views visitors and residents have of the Project site and surrounding area. The model will use a real-world lighting system, thereby simulating the sun angle, date, and time of the photograph, and will render each of the views.

4. Digital painting/Compositing The rendering of the lighted and textured 3-D model of Project infrastructure will be added to the existing conditions photographs using image editing software such as Photoshop. This process blends details from the computer model into the base photograph to produce the final “before and after” visual simulations.

3 October 17, 2014 Lake Clementine Hydroelectric Project, FERC No. 13432 ©2014, Lake Clementine Hydro, LLC Lake Clementine Hydroelectric Project, FERC No. 13432 Visual and Aesthetic Resources Study Plan

Videotape Recording Views of the flow over North Fork Dam will be videotaped and photographed from one KOP at different flow rates. Based on 72 years of flows recorded at USGS Gage No. 11427000 (NFAR at North Fork Dam), the highest and lowest median daily flows range from 48 to 1,970 cubic feet per second. The view of the water flowing over the dam will be videotaped (including audio) and photographed at six different flow rates within this range with three of the six flows recorded in the range of 50 (or lower, if such flows occur during the study period) to 500 cubic feet per second. Specific target flows are not identified because the flows cannot be controlled. The flows recorded at the USGS gage at the time of videotaping will be recorded.

Audio Assessment To assess potential effects of the sound generated by the proposed Project, Lake Clementine Hydro, LLC, will record decibel readings at an existing and fully operating powerhouse with a similar design, capacity and location (i.e., foothill or Sierra Nevada Mountains) as the proposed Project powerhouse. The recordings will be made at distances beginning 100 ft from the exterior of the representative powerhouse building with repeated measurements taken at approximately 200-ft intervals for a distance of 1 mi or until there is no discernible sound from the powerhouse. To the degree possible, measurements will be taken at points with unobstructed topography, so the sound is not altered by terrain. Where this is not possible, actual conditions will be documented to accurately report the conditions under which the sound was measured. Measurements will likely be taken during morning hours, so they will not be influenced by environmental conditions, such as wind. Measurements will be taken with a digital sound level meter with an accuracy of 1.5 decibels or less.

A focus group of interested members of the public and stakeholders will assess the different flows using videography, photography and an accompanying questionnaire to assess the aesthetic qualities of the flows. The questionnaire will include a continuum of approximately four narrative descriptions designed to reflect acceptability of each of the flows. Focus group participants will be shown a short videotape of each flow and asked to select one of these narrative descriptions to characterize their impressions of the flow over the dam. Focus group participants will provide their assessments independent of other focus group participants using written responses on a survey form that will be collected at the end of the focus group meeting. Focus group participants will also be asked to provide information related to the season, days of the week and time of day that they prefer to visit the dam to view the water flowing over the dam.

ANALYSIS A printed presentation with three paired “before and after” simulations of the transmission line and powerhouse with appurtenant infrastructure will be compiled for each KOP location with a description of view locations, distances from proposed elements, renderings of proposed infrastructure, and vicinity maps for reference. Results will be used to assist in Project planning and to refine design elements, such as materials, color selection, and visual screening techniques, and address other issues to minimize visual effects associated with the Project.

4 October 17, 2014 Lake Clementine Hydroelectric Project, FERC No. 13432 ©2014, Lake Clementine Hydro, LLC Lake Clementine Hydroelectric Project, FERC No. 13432 Visual and Aesthetic Resources Study Plan

Videography and photography of the flows over the dam will be used to determine the minimum flow that should be maintained over the dam when the Project is diverting flow for generation to provide an aesthetically pleasing setting. The study results will include tabulated focus group responses about their impressions of each flow and viewing time preferences that will be used to report the frequency of responses and identify trends. The analysis will determine acceptable and optimal flows over the dam and the most preferred time to view the falls in terms of season, day of the week, and time of day. These results will be used in conjunction with the results of the fish study to determine timing and volume of flow over the spillway.

Sound measurements of the selected representative powerhouse will be presented in a graph that shows the decibel levels on the vertical axis and distance from the powerhouse on the horizontal axis. This analysis will provide an estimate of the expected amount of noise that would be generated by the proposed Project at different distances from the powerhouse. For a point of reference, the expected decibel levels will be correlated to everyday sounds such as a normal conversation or rock concert.

CONSISTENCY WITH GENERALLY ACCEPTED SCIENTIFIC PRACTICE The proposed study methods are consistent with standard methodologies for recording existing visual and aesthetic resources and simulating future conditions to determine Project effects.

PRODUCTS Study results will be reported in the Application for Initial License, Exhibit E.

RELATIONSHIP TO OTHER STUDIES The fish study may also result in a requirement to maintain volumes of flow over the spillway for fish habitat. The results of this study will be reviewed with the results of the fish study to evaluate the quantity of flow to maintain over the spillway.

SCHEDULE Site photography and KOP selection will be completed by fall 2014. Modeling work and photo simulations will be completed by December 2014.

Field work to collect videography and photography of flows over the dam will begin in October 2014 and continue until the lowest flow occurs. Sound measurements at a representative powerhouse will be taken in winter 2014–2015. Final videotape and photographs of each recorded flow will be compiled on a DVD by June 2015.

Implementation of studies is dependent on receiving required permissions and permits from the U.S. Army Corps of Engineers.

LEVEL OF EFFORT AND COST Costs are to be determined.

5 October 17, 2014 Lake Clementine Hydroelectric Project, FERC No. 13432 ©2014, Lake Clementine Hydro, LLC Lake Clementine Hydroelectric Project, FERC No. 13432 Visual and Aesthetic Resources Study Plan

REFERENCES America Renewables. 2010. Lake Clementine Hydropower Project, FERC Project No. 13432, Pre-Application Document. America Renewables, Rolling Hills Estates, CA. August 2010. The Louis Berger Group, Inc., 2003. Aesthetics Study Report Spokane River Project, FERC No. 2545, Prepared for Avista Corporation.

RR-3

SOCIOECONOMIC RESOURCES STUDY PLAN

October 17, 2014

STUDY GOAL AND OBJECTIVE The Lake Clementine Hydroelectric Project (Project) Pre-Application Document, filed August 2010, identified issues associated with socioeconomic resources for which the existing, relevant, and reasonably available information is insufficient to address the issues (America Renewables 2010). These issues are:

Issue: The Project has the potential to disrupt recreational use and associated visitor spending during the construction period, potentially impacting revenues for California State Parks and local economies.

Issue: The Project has the potential to affect recreational use if water temperatures are changed, with potential impacts to revenues for California State Parks and local economies.

Issue: The Project infrastructure and operation have the potential to impact property values in proximity to the Project powerhouse, transmission line, and other infrastructure.

Issue: The Project construction activity could benefit the local economy through jobs, income, taxes, and supporting economic activity.

Issue: The Project could affect tax receipts for Placer County through increases in industrial property values and sales and use taxes during construction.

The goal of this study is to develop the essential additional information necessary to supplement the existing information to address the identified issue(s). In this case, the objective of this study is to identify, describe, and characterize the Project effects on the above-mentioned socioeconomic issues. The study will rely on data and information collected for the land use and recreation evaluation, supplemental reports and literature, and interviews with stakeholders, state agencies, and other experts as needed.

EXISTING INFORMATION The Project would be located at Lake Clementine adjacent to North Fork Dam on the NFAR in Placer County, California. Lake Clementine, which was formed by the North Fork debris dam constructed in 1939, is now owned by the U.S. Army Corps of Engineers. Lake Clementine has a surface area of 280 acres and a capacity of 14,700 acre-feet. It rises 155 ft above the lowest foundation and has a spillway crest elevation of 715 ft. The dam crest length is 620 ft and the thickness varies from 22 ft at the base to 6.8 ft at the top.

The proposed Project would consist of an intake near the left abutment of North Fork Dam, an open canal, and one or two penstocks connecting to a powerhouse that would house two or three generating units, totaling a combined capacity of 16 MW. The powerhouse would be located between 200 and 600 ft downstream of the dam. Construction of the intake, canal, and penstock intakes would require excavating the slope on the south side of the canyon adjacent to the dam. A switchyard consisting of a station generator bus, station service transformer, a step-up transformer, and circuit breaker would be located at an elevation above the high flood flow elevation of the NFAR near the powerhouse or in a room of the powerhouse building. A 60- kilovolt transmission line would be constructed to connect the powerhouse switchyard with Pacific Gas and Electric’s Halsey Substation. The exact location of the transmission line has not been determined at this time. Two alternative access routes are being considered for Project construction. One access route would entail reconstructing a 2.5-mile-long access road on the south side of the NFAR between the Old Foresthill Road and North Fork Dam. The route would follow the alignment of an abandoned dirt road that is currently used as a hiking and biking trail. After construction is completed, the road either could be removed and the site restored or could remain in place to serve another purpose, such as an emergency access or a recreation trail. The second access route would use the existing Lower Lake Clementine Road. This route would require making upgrades to accommodate construction equipment and traffic. In addition, improving and using this road for Project construction would likely require traffic controls to ensure public safety and to facilitate construction activities. The proposed Project would operate in a run-of-river mode with flows coming into Lake Clementine being equal to flows going out of Lake Clementine.

NEXUS BETWEEN PROJECT AND RESOURCE TO BE STUDIED AND HOW THE RESULTS WILL BE USED The proposed powerhouse, switchyard, and appurtenant facilities would be located at North Fork Dam near the boat ramp and NFAR downstream of the dam, areas that receive considerable recreational use. Construction activity would affect these areas and would also likely affect, to some degree, use of the hiking and biking trail from the Old Foresthill Road to Lake Clementine Road, Lake Clementine Road, parking areas, boat launch ramp, and the NFAR downstream of the dam. Although construction would be planned to take place primarily during the off-peak recreation season to minimize disrupting recreational use, the access currently available to the public may be affected at times during Project construction and operation. Restrictions on recreational use may reduce visitor spending at the area, affecting revenues to California State Parks and local economies.

In addition, Project operations may have slight impacts on recreational use in the area, although the Project will minimize impacts to current recreation conditions such as lake levels and downstream flows. Any effects on visitation could have implications for visitor spending and business revenues in the area.

The spilling of water over North Fork Dam contributes visually and audibly to the aesthetic character of the landscape in the area near the dam. The aesthetic character of the area would be altered by construction of Project facilities and possibly by altered flows over the dam from Project operation. In addition, the powerhouse, transmission lines, and other additional infrastructure will likely not be visually appealing for residents. The effect on property values caused by these alterations would depend on land ownership in proximity to the dam, infrastructure, and transmission line; distance from infrastructure to the residences; vegetation, landscaping, and topography; the level of development prior to siting; as well as the degree of variance from existing conditions.

Construction activity will benefit local communities through jobs, income, sales and tax revenues, and associated economy activity. The work force for the Project is expected to come from the local area, primarily Placer County. In addition, Placer County and other city government will benefit through increased property tax revenue from the Project after it is completed.

Results of the study will be used to determine the potential effects to the socioeconomic environment of the region from Project construction and operation. The results will be evaluated to recommend changes to the Project design and measures to reduce Project effects.

STUDY AREA AND STUDY SITES The study area for the property values effects includes lands within view of the Project-affected areas near the dam, powerhouse, access road routes, transmission lines, and the NFAR immediately downstream of the dam. Placer County and communities in proximity to the Project, including the town of Auburn will be the study area for the regional economic and fiscal analysis for evaluating changes in visitor spending and construction activity.

METHODS This study will compile existing socioeconomic information about the property ownership and values, visitation to the area and associated visitor spending, and other relevant information as described in this section.

The siting of the powerhouse, transmission line, and other infrastructure can adversely impact private property values. The impact of the siting of transmission lines on residential property values has been studied extensively in the United States and Canada over the last 20 years or so, with mixed results. In general, the impacts are difficult to measure, vary among individual properties, and are influenced by a number of interplaying factors, including the following: • Proximity of residential properties to transmission line • Type and size of high-voltage transmission line structures • Appearance of easement landscaping • Surrounding topography (Pitts and Jackson 2007)

To evaluate the property value impacts, LCH will conduct a GIS survey of private residences in proximity to the Project infrastructure to specify the distances of these residences from the transmission line, powerhouse, and other infrastructure. In addition, data and information will be used from the recreation and visual and aesthetic resources to better understand the Project effects on characteristics important to property values, such as vegetation and landscaping, viewsheds, and other proximate development and roads. A narrative description of the number of potentially affected properties will be provided with sufficient rationale.

Recreation visitation to the state parks will likely be affected during the construction period. In addition, operation of the Project may also affect visitation. To characterize the potential impacts to visitation, recreational use, and visitor spending in the Project-affected area during construction and operations, the Project team will work with recreation and land use experts. The socioeconomic analysis will use information from the visitor surveys and spot counts conducted by the recreation and land use experts to obtain relevant data for the socioeconomic analysis, including number of anglers and other visitors, length of visit, visitors’ place of residence, and other demographic data. Visitor spending data will be obtained from Dean Runyan (2014) or other state sources to better understand the spending per visitor, spending profile, and associated jobs and income supported. A narrative description of the impacts to visitor spending and local economies will be provided, supported by survey data, reports and literature, and other local information.

Construction activity will benefit local communities through jobs and income. The level of effect will depend on the extent of the construction budget, duration of construction activity, workforce requirements, the location and residence of the workforce, and the sourcing of materials and equipment from the local area; this information will be provided by LCH. If warranted, the multiplier effects on jobs and income of the construction spending can be also estimated with standard multipliers from publicly available sources. A narrative description of Project effects on local economies in terms of jobs, income, and multiplier activity will be provided with supporting information. Construction activity will also benefit sales and use taxes as workers spend their wages and construction supplies and materials are purchased in the local economy. These effects will be described qualitatively.

Increased value of commercial or industrial property as a result of the Project will increase property tax receipts for local jurisdictions. Construction costs can be used to estimate the market value of the improved property values. The methods to estimate property taxes for California for industrial activity will be used along with the county mill levy to estimate the change in property tax receipts.

ANALYSIS GIS mapping will be used to determine the proximity of residences to the powerhouse, transmission line, and other Project infrastructure. This information, in combination with additional parameters described above, will be analyzed to evaluate property value effects associated with the Project. The analysis would also identify measures to minimize these effects, such as siting considerations and landscaping.

Visitor use (by type), trip duration, and residence of visitors, along with data on spending per visitor will be used to estimate regional economic impacts of changes in recreation during project construction and operations. This information can be considered in the development of the construction plan and schedule to minimize Project effects on California State Parks and local economies. For any unavoidable effects on socioeconomic resources, this information will be used to quantify these Project effects.

Data and information on construction activities, workforce, and expenditures will be used to estimate the regional economic impacts. Information to increase economic benefits, such as local sourcing of materials, can be considered in the development of the construction plan and schedule to maximize benefits to local economies.

CONSISTENCY WITH GENERALLY ACCEPTED SCIENTIFIC PRACTICE The proposed study methods are consistent with standard methodologies for assessing the socioeconomic effects associated with hydropower development and transmission projects to assess Project effects.

PRODUCTS The study will generate narrative descriptions of: existing visitation and visitor spending in the region, anticipated changes and impacts on California State Parks and local economies; construction impacts on local economies; fiscal impacts on local governments; and impacts to residential property values. A map will be produced if necessary to describe the proximity of residences to the dam, powerhouse, transmission line, and other infrastructure. These study results will be reported in the Application for Initial License, Exhibit E.

RELATIONSHIP TO OTHER STUDIES Results of the Recreation and Visual and Aesthetic studies will be reviewed to incorporate necessary information in the socioeconomic analysis. Results of visitor survey and spot counts will be used to identify important visitor characteristics for the socioeconomic study.

SCHEDULE The Socioeconomic Resource Study will be completed by the winter of 2015. Researching and compiling existing information about socioeconomic resources will be completed by the fall of 2015.

LEVEL OF EFFORT AND COST Costs are to be determined.

7 October 17, 2014 Lake Clementine Hydroelectric Project, FERC No. 13432 ©2014, Lake Clementine Hydro, LLC Lake Clementine Hydroelectric Project, FERC No. 13432 Cultural and Historic Properties Study Plan

CR-1

CULTURAL AND HISTORIC PROPERTIES STUDY PLAN

October 17, 2014

STUDY GOAL AND OBJECTIVE The Lake Clementine (Project) Pre-Application Document (PAD), filed August 2010, identified issues associated with cultural resources for which the existing, relevant, and reasonably available information is insufficient to address the issues (America Renewables 2010). Two of these issues are addressed herein:

Issue: Effects of Project construction, operation, and maintenance on historic and archeological resources within the Project Area of Potential Effect (APE) that are listed, or may be eligible for inclusion, in the National Register of Historic Places (National Register).

Issue: Effects of Project construction, operation, and maintenance on properties of traditional religious and cultural importance to an Indian tribe.

The goal of this study is to develop the essential additional information to supplement the existing information necessary to address the identified issues. Objectives in support of this goal include (1) identification and documentation of archaeological, historic-era properties, and traditional cultural properties (TCPs) within the APE, (2) determination of potential Project effects on archaeological, historic-era properties, and TCPs within the APE, and (3) evaluation of National Register eligibility (as appropriate and necessary) for properties affected by the Project. This information would then be used in Project planning. If significant cultural resources are identified within the APE, development of a Historic Properties Management Plan would be recommended.

EXISTING INFORMATION The Project would be located at Lake Clementine adjacent to North Fork Dam on the NFAR in Placer County, California. Lake Clementine, which was formed by the North Fork debris dam constructed in 1939, is now owned by the U.S. Army Corps of Engineers (USACE). Lake Clementine has a surface area of 280 acres and a capacity of 14,700 acre-feet. It rises 155 feet (ft) above the lowest foundation and has a spillway crest elevation of 715 ft. The dam crest length is 620 ft and the thickness varies from 22 ft at the base to 6.8 ft at the top.

1 October 17, 2014 Lake Clementine Hydroelectric Project, FERC No. 13432 ©2014, Lake Clementine Hydro, LLC Lake Clementine Hydroelectric Project, FERC No. 13432 Cultural and Historic Properties Study Plan

A switchyard consisting of a station generator bus, station service transformer, a step-up transformer, and circuit breaker would be located at an elevation above the high flood flow elevation of the NFAR near the powerhouse or in a room of the powerhouse building. A 60- kilovolt transmission line would be constructed to connect the powerhouse switchyard with Pacific Gas and Electric’s Halsey Substation. The exact location of the transmission line has not been determined at this time. Two alternative access routes are being considered for Project construction. One access route would entail reconstructing a 2.5-mile-long access road on the south side of the NFAR between the Old Foresthill Road and North Fork Dam. The route would follow the alignment of an abandoned dirt road that is currently used as a hiking and biking trail. After construction is completed, the road either could be removed and the site restored or could remain in place to serve another purpose, such as an emergency access or a recreation trail. The second access route would use the existing Lower Lake Clementine Road. This route would require making upgrades to accommodate construction equipment and traffic. In addition, improving and using this road for Project construction would likely require traffic controls to ensure public safety and to facilitate construction activities. The proposed Project would operate in a run-of-river mode with flows coming into Lake Clementine being equal to flows going out of Lake Clementine.

A discussion of known archaeological and historic cultural resources in the region was presented in the PAD (America Renewables 2010). At least 30 previous cultural resources investigations have been conducted within 1 mi of the proposed Project for other projects that are the source of useful information for this Project, including Placer County’s North Fork Trail Project (Placer County 2007) USACE studies. These studies documented a number of prehistoric and historic- era sites in the vicinity of the Project Area. Additionally, North Fork Dam was constructed in 1939 and is a historic resource. Additional archaeological and historic-era resources may be present in the APE.

TCPs are a type of historic property that are eligible for inclusion in the National Register because of their association with cultural practices or beliefs of a living community that: (1) are rooted in that community’s history; or (2) are important in maintaining the continuing cultural identity of the community (Parker and King 1998). Consultation with the California Native American Heritage Commission (NAHC) to prepare the PAD did not identify any documented lands of traditional or spiritual importance to Native American tribes. However, on August 12, 2010, NAHC provided a contact list of tribes that may have traditional ties to the Project Area, including the United Auburn Indian Community of the Auburn Rancheria, the Buena Vista Rancheria, the Washoe Tribe of Nevada and California, and the Shingle Springs Band of Miwok Indians. Subsequent consultation with the United Auburn Indian Community on March 13, 2014, indicates that at least one TCP may be located within the APE.

2 October 17, 2014 Lake Clementine Hydroelectric Project, FERC No. 13432 ©2014, Lake Clementine Hydro, LLC Lake Clementine Hydroelectric Project, FERC No. 13432 Cultural and Historic Properties Study Plan

NEXUS BETWEEN PROJECT AND RESOURCE TO BE STUDIED AND HOW THE RESULTS WILL BE USED The licensing of the Project is a federal undertaking; the Federal Energy Regulatory Commission (FERC) license will permit activities that may “…cause changes in the character or use of historic properties, if any such historic properties exist…” (36 CFR §800.16(d)). FERC must therefore comply with Section 106 of the National Historic Preservation Act, as amended, which requires the head of any federal department or independent agency having authority to license any undertaking to take into account the effect of the undertaking on historic properties. Historic properties are any prehistoric or historic district, site, building, structure, or object included in, or eligible for inclusion in, the National Register (36 CFR §800.16). Assessment of historic properties is conducted in continuous consultation with FERC, the California State Historic Preservation Officer (SHPO), Native American tribes (including the United Auburn Indian Community), and all appropriate agencies (e.g., USACE and the National Park Service). This information will be used in future Project planning. If possible, historic properties would be avoided to minimize Project effects from this renewable energy project.

STUDY AREA AND STUDY SITES For cultural resources, appropriate study areas are defined by regulations under 36 CFR §800 as an APE that is the geographic area or areas within which an undertaking may directly or indirectly cause changes in the character or use of historic properties, if any such properties exist. Currently, the APE is defined all lands within the proposed Project Boundary, and any areas where Project construction, ground disturbance, and visual effects may occur outside of the Project Boundary. A final determination of the Project Boundary and APE is pending agreement on a final Project engineering design.

METHODS Archival Research Upon the determination of a final Project engineering design, an APE map will be developed. Consultation with the SHPO, USACE, affected Native American tribes, and others as appropriate will be undertaken to obtain concurrence on boundaries of the APE. Cultural resources background research and field surveys may be initiated prior to the completion of the final engineering design, which would establish all areas of disturbance during Project implementation. In this case, a study area map that encompasses all possible areas of Project- related disturbance will be prepared and the work will be conducted over a broader area. Archival research for the study will entail the following:

• A records search for the proposed Project was conducted on July 27, 2010, and the results are summarized in the PAD (America Renewables 2010). However, an additional records search of a 0.25-mile radius around the APE at the North Central Information Center (NCIC) of the California Historical Resources Information System (CHRIS) at California State University, Sacramento, will be conducted to identify any new or updated cultural resource site records and cultural resource studies within or adjacent to the Project Area that have been submitted to the NCIC since the completion of the previous records search in 2010.

3 October 17, 2014 Lake Clementine Hydroelectric Project, FERC No. 13432 ©2014, Lake Clementine Hydro, LLC Lake Clementine Hydroelectric Project, FERC No. 13432 Cultural and Historic Properties Study Plan

• Background research will be conducted to obtain copies of any drawings, plans, maps, photographs, newspaper articles, or other secondary material on North Fork Dam and associated features and the surrounding area. The following repositories may be accessed: – United Auburn Indian Community; – The National Archives at San Francisco and San Bruno; – California State Parks, Sacramento; – U.S. Bureau of Reclamation, Mid-Pacific Region, Central California Area Office; – USACE, Sacramento District, Sacramento; and – University of California Water Resources Collections and Archives, Riverside (by telephone or email only). • Appropriate local and regional historical societies will be contacted and invited to comment on the Project’s potential effects on historic properties located within the APE. • A desktop geoarchaeological analysis of the APE will be conducted to assess the potential sensitivity of the area for the presence of subsurface prehistoric soils or deposits if deemed appropriate based on the Project and topography. Ultimately, this information would be combined with an understanding of the previous level of ground disturbance, proposed parameters of ground disturbance into native soils, and topography to provide a comprehensive understanding of the potential sensitivity for encountering subsurface prehistoric deposits during Project implementation. • Consultation with the Native American tribes previously identified by NAHC will be conducted to determine whether these organizations have knowledge of cultural resources and potential TCPs within the APE. Native American consultation will include written letters to the appropriate representatives, meetings, and at least one site visit with interested tribal members. Field Survey As noted above, FERC must take into account effects of the undertaking on historic properties, as required by the National Historic Preservation Act. To accomplish this, reasonable measures to identify and document archaeological and historic-era sites and TCPs that are located within the APE must be undertaken in the field.

To ensure that appropriate management decisions are made to address Project activities that may adversely affect significant sites within the APE, an intensive cultural resources survey will be conducted by qualified, professional archaeologists.

• The archaeologist will conduct a pedestrian field survey of the APE. During the fieldwork, an architectural historian will also record North Fork Dam and associated features, including notation of its current condition, construction materials, and character-defining features, in field notes and on maps and aerial photographs. The

4 October 17, 2014 Lake Clementine Hydroelectric Project, FERC No. 13432 ©2014, Lake Clementine Hydro, LLC Lake Clementine Hydroelectric Project, FERC No. 13432 Cultural and Historic Properties Study Plan

dam and associated features also will be documented using a handheld Geographic Positioning System (GPS) unit and a digital camera. • Areas within the APE that cannot be accessed in a safe manner (e.g., locations containing dense vegetation, unsafe slopes, or steep grades) will not be included in the survey or recording of sites; these areas will be identified in the resulting survey report and an explanation for survey exclusion will be provided. • If archaeological resources are identified through background research or during the field survey, their locations will be recorded with a sub-meter GPS unit and digital photography. Department of Parks and Recreation (DPR) 523A (Primary Record) and 523J (Location Map) forms for newly identified resources or the existing DPR 523 forms for previously recorded resources will be updated. No artifacts will be collected, and the sites will not be evaluated during the course of this investigation. • A qualified Native American archaeological field technician will be invited to assist with fieldwork. If archival research conducted with Native American tribes identifies potential TCPs within the APE, further consultation and any necessary fieldwork and potential TCP documentation will be undertaken.

• Consultation and fieldwork shall be undertaken in accordance with Section 106 of the National Historic Preservation Act, as amended, and shall take into consideration National Register Bulletin No. 38, Guidelines for Evaluating and Documenting Identification of Traditional Cultural Properties (Parker and King 1998). Documentation of TCPs will also consider other applicable professional standards and guidelines, and state, tribal, and local laws. • If TCPs are identified, their location and boundaries will be recorded with a sub- meter GPS unit and digital photography. A DPR 523A (Primary Record) or similar record suitable to document TCPs and a DPR 523J (Location Map) will be prepared. • To protect confidentiality, the locations of potential TCPs will not be disclosed to any parties other than select employees of Lake Clementine Hydro, LLC (LCH) and its consultants; federal land management agencies, as appropriate; FERC; SHPO; and the United Auburn Indian Community. At the instruction in writing by the participating tribes, this information may be disclosed to the NCIC of the CHRIS at California State University, Sacramento. • If participating Native American tribes do not wish to disclose the locations of any potential TCPs due to religious or confidentiality reasons, consultation will instead focus on the general issues and concerns that the tribe(s) may have regarding potential impacts of the Project upon resources known to the tribe(s) and work to develop agreeable measures to alleviate these concerns.

5 October 17, 2014 Lake Clementine Hydroelectric Project, FERC No. 13432 ©2014, Lake Clementine Hydro, LLC Lake Clementine Hydroelectric Project, FERC No. 13432 Cultural and Historic Properties Study Plan

ANALYSIS Section 106 Cultural Resource Inventory and Evaluation Report Following archival research and fieldwork, a draft Cultural Resources Section 106 Inventory and Evaluation Report to meet the requirements of the National Historic Preservation Act will be prepared. The report will include (1) the results of the background research on the environment, history, ethnography, and prehistory of the region and the construction of North Fork Dam; (2) documentation of the methods and results of the investigation; (3) the results of the pre-field research, consultations, survey findings, and a recommendation regarding the National Register eligibility for North Fork Dam identified within the APE; and (4) management recommendations for all cultural resources and TCPs identified within the APE. Following completion of the draft report, it will be presented to LCH for review and comment. The draft report will be revised to address any comments received from LCH, and LCH will then transmit copies to FERC, USCAE, SHPO, and participating Native American tribes for additional review and comment. Upon receipt of comments from these parties, a final report will be prepared and distributed.

As needed, a separate Finding of Effects document would be prepared if the SHPO concurs that there National Register-eligible resources located within the APE.

National Register of Historic Places Evaluation If cultural resources are identified during the inventory process that cannot be avoided during Project implementation, these properties may be assessed for their National Register eligibility. National Register evaluations are site-specific and depend on the nature of the identified impact (e.g., adverse effects and non-adverse effects). Individual site significance can be defined in a number of ways. The legal definition of site significance for the National Register is codified at 36 CFR §60.4:

National Register Criteria for Evaluation. The quality of significance in American history, architecture, archaeology, engineering, and culture is present in districts, sites, buildings, structures, and objects that possess integrity of location, design, setting, materials, workmanship, feeling, and association and:

(a) that are associated with events that have made a significant contribution to the broad pattern of our history;

(b) that are associated with the lives of persons significant in our past;

(c) that embody the distinctive characteristics of a type, period, or method of construction or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction; or

(d) that have yielded, or may be likely to yield, information important to prehistory or history.

6 October 17, 2014 Lake Clementine Hydroelectric Project, FERC No. 13432 ©2014, Lake Clementine Hydro, LLC Lake Clementine Hydroelectric Project, FERC No. 13432 Cultural and Historic Properties Study Plan

If specific prehistoric sites or sites containing both prehistoric and historic-era archaeological deposits are identified that are experiencing ongoing adverse effects that cannot be avoided, eliminated, or removed, and National Register evaluations without test excavations are not possible, additional fieldwork and archaeological test excavation may be warranted. The need for archaeological test excavation to determine National Register eligibility will be determined on a site-by-site basis in consultation with the appropriate federal and state agencies and tribes. If test excavation is deemed appropriate, a qualified Native American field technician will be invited to participate in fieldwork. If archaeological testing becomes necessary, an excavation plan will be prepared prior to the excavation work, detailing procedures regarding the collection and curation of recovered cultural materials.

In addition to the criteria set forth at 36 CFR §60.4, properties can have other cultural values that should be considered. Amendments to the National Historic Preservation Act in 1992 [§101(d)(6)(A)] specify that properties of traditional religious and cultural importance (TCPs) to an Native American tribe may be determined eligible for inclusion in the National Register because of their “association with cultural practices or beliefs of a living community that are (1) rooted in that community’s history; and (2) are important in maintaining the continuing cultural identity of the community.” Therefore, a property may also be significant if it has traditional or ethnographic significance because of its ties to the cultural past of Native Americans.

If formal evaluation is appropriate, the above criteria will be used to analyze the archaeological and historic-era resources and potential TCPs identified within the APE to provide National Register evaluations to be presented to the SHPO for concurrence.

Discovery and Treatment of Human Remains Human remains, graves, and cemeteries that may be encountered during field survey, testing or data recovery excavations are protected by both state and federal law. Under federal law, the provisions of the Archaeological Resources Protection Act of 1979 (ARPA), American Native American Religious Freedom Act (AIRFA), and Native American Graves Protection and Repatriation Act protect human graves, associated funerary objects, and the free expression of Native American religious beliefs. The California Penal Code, California Health and Safety Code (CH&SC), and California Public Resources Code (CPRC) also prohibit damage, defacement, or disinterment of human remains without legal authority and establish civil and criminal penalties. Although the provisions of the Native American Graves Protection and Repatriation Act apply only to remains discovered on federal or tribal lands, AIRFA and ARPA apply to the entire Project Area, whether federally or privately governed. Although the CH&SC and CPRC technically apply only to those portions of the APE not under federal jurisdiction, in practice, the law is applied throughout the area. Criminal sanctions provided for in the California Penal Code, CH&SC, and CPRC would be above and beyond the penalties authorized by the ARPA. If human remains are identified during the survey or any National Register evaluation phases of the Project, or prior to license issuance, all work in the immediate area will cease until the provisions contained within federal and/or state law have been followed.

CONSISTENCY WITH GENERALLY ACCEPTED SCIENTIFIC PRACTICE The proposed study methods discussed above are consistent with the study methods followed in several other recent licensing proceedings of hydroelectric projects in Northern California. These methods have been accepted by the participating Native American tribes, agencies, and other interested parties associated with those projects. The methods presented in this study plan also are consistent with the Advisory Council on Historic Preservation’s guidelines for compliance with the requirements of Section 106 of the National Historic Preservation Act.

PRODUCTS Because of the confidential nature of cultural resources, a stand-alone non-public study report will be prepared. However, results will be summarized in in Exhibit E of the License Application. A summary of the information and findings will be reported in Exhibit E of the License Application. Data gathered as part of the study that is not confidential will be included with the License Application.

RELATIONSHIP TO OTHER STUDIES Study Plan CR-1 is related to the Special Status and Invasive Plant Study (Study Plan TR-1). Areas traditionally used by Native American tribes to gather plant resources may be considered to be TCPs. These areas may correlate with rare plant locations identified during implementation of TR-1. Tribes will be asked to provide lists of important plant species to Project botanists prior to botanical fieldwork so that they may be included in botanical surveys and vegetation mapping.

SCHEDULE Cultural resources field studies will be initiated in 2015 and are expected to be completed by the end of September 2015. The draft inventory report will be provided to LCH by October 31, 2015, for a 15-day review. Incorporation of comments would be completed by November 30, 2015, with a draft report ready for submittal to government agencies and Native American tribes no later than December 15, 2015.

LEVEL OF EFFORT AND COST Costs are to be determined.

REFERENCES America Renewables. 2010. Lake Clementine Hydropower Project, FERC Project No. 13432, Pre-Application Document. America Renewables, Rolling Hills Estates, CA. August 2010. Parker, P.L., and T.K. King. 1998. Guidelines for Documenting and Evaluating Traditional Cultural Properties. National Register Bulletin 38. U.S. Department of the Interior, National Park Service, National Register, History and Education, National Register of Historic Places, Washington, DC.

8 October 17, 2014 Lake Clementine Hydroelectric Project, FERC No. 13432 ©2014, Lake Clementine Hydro, LLC Lake Clementine Hydroelectric Project, FERC No. 13432 Cultural and Historic Properties Study Plan

Placer County. 2007. Draft Environmental Impact Report for North American River Trail. August 2007. Available at: http://www.placer.ca.gov/Departments/CommunityDevelopment/EnvCoordSvcs/EIR/Nor thForkTrail.aspx. Accessed July 29, 2010.

9 October 17, 2014 Lake Clementine Hydroelectric Project, FERC No. 13432 ©2014, Lake Clementine Hydro, LLC Lake Clementine Hydroelectric Project, FERC No. 13432 Cultural and Historic Properties Study Plan

Lake Clementine Hydro, LLC Responses to Study Plan Comments

Lake Clementine Hydroelectric Project, FERC No. 13432 Response to Comments on Study Plans

Response to Comments on Study Plans (Acronyms and abbreviations are defined at the end of this table.)

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response ALL RESOURCE AREAS 1 5/30/2014 SWRCB R Evaluate all proposed Project design features 2 All LCH has chosen the bypass canal option (including both intake options) and narrowing the scope of studies to a single associated impacts when conducting Project option. studies, or LCH defined an area of potential Project Select a final Project design and move effect based on resources to be studied and forward with studies evaluating the impacts analyzed the location of Project features associated with the selected design based on the current level of information. LCH anticipates that this area will be modified as more information is developed about the location of Project features, such as the transmission line and access routes. 2 5/30/2014 SWRCB C Sufficient notification of planned field 2 All LCH will direct its consultants to develop a activities should be given to allow SWRCB field schedule for each study and will make staff the opportunity to be on-site and the schedule available to all stakeholders. observe field activities. 3 5/30/2014 SWRCB C SWRCB will be the CEQA lead agency. 2 All This is a statement of California policy and Once the application is filed the SWRCB will is applicable to all hydro licensing develop an MOA with LCH and the selected proceedings. CEQA consultant 4 5/30/2014 SWRCB R Please add the proposed start date and 3 All Initiation of field studies depends on duration of each study being proposed by receiving the necessary permits and LCH. permission for access to lands and facilities from USACE and BOR. LCH continues to contact these agencies to determine when the required permits and permissions can be expected so the study implementation schedule can be determined.

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response Once the required permits and permissions have been received, LCH will publish its study implementation schedule. 5 5/30/2014 SWRCB R SWRCB staff strongly recommends 3 All LCH plans to continue to consult with cooperative coordination between LCH and stakeholders during and after the licensing participants to discuss relevant development of the license application. issues that will assist in the protection of beneficial uses in the NFAR. 6 5/30/2014 SWRCB R Existing information relevant to the proposed 3 All A summary of available existing studies should be included in each study plan information is included in each study plan, so that licensing participants can evaluate the as applicable. Additional details regarding existing information and have a better available existing information can be found understanding of current conditions. in the PAD, dated August 2010. 7 5/30/2014 SWRCB C LCH has not proposed a study to address 2 All The Water Quantity Study will produce a Project effects on the bypass reach. flow duration curve based on the historical flow record. This information will be used to determine the period in which there will be sufficient flow to allow the Project to operate. Determining the minimum flow provided over the dam spillway during Project operation will take into consideration the results of studies to assess aquatic habitat, visual and aesthetic values, and water quality. Analysis of Project effects will take into consideration the results of the Water Quantity Study and other studies performed in the bypass reach.

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response 6/25/2014 1

8 10/1/2014 SWRCB C Consistent with the Traditional Licensing 1–2 All LCH appreciates the efforts of the state and Process, the applicant sets the schedule for federal agencies to provide comments and study plan review and comment. During the recommendations within the requested time August 29, 2014, meeting LCH asked State period. and Federal Agencies how much time they LCH distributed the study plans for review needed to review the study plans. State and and comment on at least three occasions and Federal Agencies replied 45 to 60 days would met with stakeholders on at least two be necessary to adequately review the plans. occasions to discuss and clarify comments For the Study Plans distributed September received. The study plan versions provided 12, 2014, LCH gave State and Federal on September 12 and 16, 2014 were Agencies only 13 days to review and provided with track changes to facilitate comment and for Study Plans distributed review by indicating where changes were September 16, 2014, LCH gave State and made to address comments. Federal Agencies just 17 days to review and comment. LCH anticipated receiving the necessary permits and permission for site access from State Water Board Staff has worked to the USACE to proceed with studies. It was accommodate LCH’s timeline but disagrees therefore necessary to request the short with LCH’s approach in limiting the Study review period so that technical consultants Plan review period. The short review period could be retained and so that field studies could result in deficient Study Plans, could begin. potentially resulting in the need for additional future studies. 9 10/1/2014 SWRCB C LCH limited distribution of the third round of 2 All LCH is committed to transparent licensing Study Plan revisions to the United Auburn proceedings and has established a Project Indian Community of the Auburn Rancheria, website for posting all proceeding and State and Federal Agencies. LCH did not documents. To that end LCH has held at

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response distribute the Study Plans to other licensing least 4 public meetings to describe the participants such as the Auburn Boaters Club, Project, licensing process, Project issues, Senator Jim Nielson’s office, and the local and study approaches. LCH did not include community. In order to address concerns and the more than 100 participants in the final issues in an effective and efficient manner, review of the study plans because the the State Water Board Staff promotes the revisions to the study plans were technical in inclusion of all licensing participants in the nature requiring review by the appropriate review of revised study plans. specialists. The final study plans as filed with the Commission will be posted on the website along with comments letters from agencies and notification of the posting will be distributed to all participants in the proceedings. Hard copies of the study plans and comment letters will be placed in the Auburn Community Library for public review. 10 6/26/2014 CDFW C Studies that involve the handling of fish, 5 Fisheries, LCH recognizes that permits and/or wildlife, or plant species listed as rare, Terrestrial authorizations from appropriate agencies threatened, or endangered, or candidates for may be required and will ensure that its these listings, may require a permit or other consultants secure such approvals before authorization from State and/or federal conducting field work that may entail agencies. CDFW encourages LCH to pursue handling special-status species. any necessary permits or authorization for proposed Project studies as soon as possible to avoid delays in implementing the studies. 11 6/26/2014 CDFW R CDFW requests that LCH: 1) finalize the 2 All LCH has chosen the canal operation for the Project design and alignment prior to Project. Where applicable, all studies will conducting resource studies, or 2) develop include analysis of the canal option and and implement all resource studies in a areas affected by each transmission manner which considers the potential effects alternative unless an alternative is selected of both generation facility designs and prior to initiating the study. encompasses all proposed alignment options The study area also includes access routes, for the transmission lines and construction staging and laydown areas, and any other access routes. areas that will be used for Project

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response construction and operation. Final Project design will depend, in part, on information provided by the studies. 12 6/26/2014 CDFW C Sufficient notification of planned field 5 All LCH will direct its consultants to develop a activities should be given to allow CDFW field schedule and will make the schedule staff the opportunity to be on-site and available to agency stakeholders. observe field activities. 13 9/25/2014 CDFW C The Department is having difficulty 2 All The map represents the area that may be interpreting the Project Area Map provided affected by Project construction, operation, by the Applicant. The map does not contain a and maintenance. The map includes an key or legend and the features drawn on the explanatory note of the symbology showing map are not labeled, thus the Department the area that may be affected by the Project. cannot determine what the yellow and orange The specific locations of Project features dashed lines and gray polygon are supposed and areas needed for construction have not to represent. been identified at this time. However, the study areas include sufficient buffers to ensure all area potentially affected by the Project are investigated for potential effects. WATER RESOURCES Water Quantity 14 5/30/2014 SWRCB C LCH has not determined the percentage of 2 Water The Water Quantity Study will compile spill or volume of flow that will top the dam Quantity USGS flow data at the North Fork Dam. during Project operations. LCH expects it will be required to maintain a minimum spill flow at all times when the powerhouse is operating. Information obtained from the Visual and Aesthetics Study, Water Quantity Study, Fisheries Study, and other relevant information will be used to determine the minimum spill flow requirement during Project operation. The Water Quantity Study will provide

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response information needed to determine the range of flows that will allow the Project to operate efficiently. The Project would cease operation once the inflow to Lake Clementine drops below the sum of the minimum flow for Project operation plus the minimum spill flow required during Project operation. When this condition is achieved, the entire inflow of the NFAR will pass over the dam spillway.

6/25/2014 1

15 6/26/2014 CDFW R All USGS hydrology data developed as part 6 Water LCH revised the study plan to specify that of the Water Quantity Study Plan should be Quantity hydrology data will be available in both provided in Data Storage System (DSS) Excel and DSS formats. format in addition to the Microsoft Excel format specified in the study plan. 9/25/2014 3

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response 16 5/30/2014 SWRCB C Reduced spillage at the dam could result in a 3 Water The results of water quantity, aquatic habitat disconnect in the bypass reach from flows Quantity, studies, and visual and aesthetics study will downstream and go subsurface be used to determine the minimum spill flow to be maintained during powerhouse operation. Observation on August 4, 2014, when the spill flow over North Fork Dam was approximately 35 cfs showed no evidence of disconnect in the bypass reach. 6/25/2014 2

Water Quality 17 5/30/2014 SWRCB C Reduced spillage at the dam could negatively 3 Water Results from the Water Quality Study will impact water quality in the bypass reach. Quality establish a baseline of existing water quality in the bypass reach. The results of this study 6/25/2014 2 and the Water Quantity Study will allow analysis of potential Project effects in the NFAR bypass reach. 18 5/30/2014 SWRCB R LCH should consider water quality impacts 3 Water LCH will consider the potential effects of associated with the transmission line route(s) Quality transmission line construction on water as clearing vegetation can increase potential quality in the license application. erosion into surface waters. LCH anticipates that the transmission line will require minimal clearing to remove hazard trees and to provide minimal conductor clearance. Any ground-disturbing activities will require adequate erosion and sediment transport measures to prevent any Project effects on water quality.

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response 19 5/30/2014 SWRCB R SWRCB staff recommends that LCH 3 Water LCH will review the study reports evaluate additional sources of existing water Quality developed by PCWA for the relicensing of quality information such as potential data the Middle Fork American River collected by Placer County Water Agency. Hydroelectric Project as well as other sources. Data relevant to characterizing the existing water quality of the NFAR will be included in the Water Quality Study report and license application. 20 5/30/2014 SWRCB R SWRCB staff recommends that LCH conduct 3 Water Initiation of field studies depends on DO and water temperature monitoring in Quality receiving the necessary permits and Lake Clementine and NFAR during both permission for access to lands and facilities 2014, an exceptionally dry year, and a second from USACE and BOR. LCH is prepared to water-year with either normal or above initiate these studies as soon as it receives normal precipitation. Two years of agency approvals. monitoring data as described above, will LCH agrees that the extremely dry water provide a baseline of DO and Water year of 2014 provides an example of the Temperature which can be used in worst case hydrological conditions. The comparison with post-operational DO and need for additional monitoring may be temperature levels to determine Project appropriate; however, 2015 may also be an impacts and the need for additional SWRCB extremely dry water year. LCH proposes to actions. evaluate the results of the first year of temperature and DO monitoring and discuss findings with the stakeholders to determine the need for and timing of subsequent monitoring. 21 5/30/2014 SWRCB R SWRCB staff should be consulted during the 4 Water As previously noted, LCH will make the site selection process for deployment Quality proposed fieldwork schedules for all studies locations of water quality monitoring available to stakeholders. Agency personnel equipment in the NFAR. SWRCB requests are welcome to observe study two weeks. notice prior to deployment of implementation, such as deployment of water quality monitoring equipment to water quality monitoring equipment. arrange availability to observe field However, requests to accompany field staff operations must be provided to LCH in a timely

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response manner so that logistics can be coordinated. 22 5/30/2014 SWRCB R Lake Clementine DO monitoring: 4 Water The Water Quality Study Plan has been recommend LCH reduce the number of Quality modified as suggested by reducing the temperature and DO monitoring locations in number of temperature and DO monitoring Lake Clementine from three stations to one locations in Lake Clementine. The Study station. The Lake Clementine station should Plan has been revised to reflect SWRCB’s be placed near the proposed intake location suggestion to record DO readings at the and monitoring three depths: 2) 3 feet below same time of day, to the extent practicable. the surface, 2) at the midpoint of the The beginning and end time of each profile proposed intake, 3) 3 feet off the reservoir data collection effort will be recorded in the bottom. DO readings should be taken field data logs. consistently at the same time of day to avoid introducing diurnal fluctuation into the data. 23 5/30/2014 SWRCB R NFAR monitoring: Hourly DO measurements 4 Water LCH understands that monitoring in the should be collected for two, one-week-long Quality winter is needed to assess Project effects at periods, in each of the two years. The first the time when the Project would most likely week of DO monitoring should occur during be operating. Therefore LCH modified the summer low flows. The second week of DO Water Quality Study Plan to include monitoring should occur during winter high additional monitoring in November and flows. December. As previously noted, determining the need for a second year of water quality monitoring would occur after the first year of data is analyzed and in consultation with the agencies. 24 5/30/2014 SWRCB R Sediment transport should study both intake 4 Water LCH selected the canal option. The study designs unless LCH makes a final design Quality areas and methodologies reflect this Project selection. design. 25 5/30/2014 SWRCB R Referring to the proposed stepwise approach 4 Water As previously noted, LCH plans to consult for evaluating Project- related sediment Quality with stakeholders during each of its transport issues, prior to determining proposed studies. This intent is stated in the additional analysis is not necessary, LCH Sediment Transport Study Plan. If there is should consult with participants to evaluate if disagreement regarding the need to proceed 9 October 17, 2014 Lake Clementine Hydroelectric Project, FERC No. 13432 ©2014, Lake Clementine Hydro, LLC Lake Clementine Hydroelectric Project, FERC No. 13432 Response to Comments on Study Plans

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response the initial step indicates a significant change with step 2 of the Sediment Transport Study in reservoir velocities and associated Plan, stakeholders and LCH could request sediment transport dynamics. If an agreement FERC resolve the study dispute, pursuant to cannot be reached, the discrepancy should be 18 CFR 16.8(b)(6). referred to FERC for determination on how to proceed with step 2 of the sediment transport study. 26 5/30/2014 SWRCB R The water quality sampling methodology in 5 Water LCH prefers to establish suspended the Sediment Transport Study Plan is unclear Quality sediment (solid) values under worst case about the target flows for collecting conditions, which would be during a high suspended sediment samples. SWRCB flow event. Based on a review of available recommends that suspended sediment flow information at the Project, LCH samples be collected at a variety of flows to proposes to consult with agencies to define a assess the range of environmental conditions high flow event and modify the study plan occurring in the Project area. Additional accordingly. Under low flow conditions, discussions are needed to select the target suspended sediment values are expected to flows under which suspended sediment be lower and the potential for the Project to samples will be collected and to determine modify downstream suspended sediment how many sampling events would be transport would be less. LCH notes that total necessary to define the suspended solid load suspended solid data will be collected in in the water column given the variety of flow profile grab samples collected near the dam conditions expected near the Project intake. in June, July, August, November, and December as part of the Water Quality Study. 27 5/30/2014 SWRCB R SWRCB recommends LCH collect grab 5 Water LCH proposes to collect grab water quality samples at the specified locations for two Quality samples in the reservoir once per month consecutive years once per month in June, during June, July, and August as SWRCB July, August, November, and December. recommends. LCH’s revised the study plan to include monitoring in November and December because the Project would most likely be operating during this period. As previously noted and included in the study plan, LCH will assess the need for an additional year of sampling when the results

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response of the first year of monitoring are analyzed. 28 5/30/2014 SWRCB C Water quality sampling should be 5 Water The study plan methodology includes coordinated with the DO and temperature Quality collecting reservoir grab samples during the monitoring events to reduce staff time and water temperature and DO profile costs. measurements. 29 10/1/2014 SWRCB C If there is any existing water quality data 3 Water PCWA studied water quality in the Middle pertinent to the Project that LCH would like Quality Fork American River and the NFAR the State Water Board and licensing upstream of Lake Clementine and near their participants to consider when evaluating confluence. While the information does Project effects to water quality, then LCH provide a description of water quality needs to include that information in the conditions in the region and do not describe Water Quality Study Plan. the water quality in the reach of the NFAR that would be affected by the Project. 30 10/1/2014 SWRCB C If October 2014 is dry and no significant 3 Water Initiation of field studies depends on rainfall is expected to occur, State Water Quality receiving the necessary permits and Board staff may support a deviation for permission for access to lands and facilities monitoring in 2014 from September to from USACE and BOR. LCH has been October, upon consultation and majority requesting permits and permissions since approval by conditioning agencies. March of 2014 and as of October 8, 2014, has not received the needed permits and permissions. It will therefore be necessary to postpone study implementation to 2015. All study plans have been changed to reflect this schedule change. 31 10/1/2014 SWRCB C LCH needs to clarify the role stakeholders 5 Water After field data collection, LCH will provide will have in determining whether to proceed Quality a technical memorandum describing dates, with the second study phase. field conditions, providing raw study data for agency review and interpretation. The technical memoranda will also be posted on the Project website and notifications will be distributed to stakeholders. LCH will consult with state and federal resource agencies with regard to the need to 11 October 17, 2014 Lake Clementine Hydroelectric Project, FERC No. 13432 ©2014, Lake Clementine Hydro, LLC Lake Clementine Hydroelectric Project, FERC No. 13432 Response to Comments on Study Plans

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response proceed with the second study phase, if any are specified in the study plan. Because this consultation will concern technical information it is not feasible to effectively do so in a forum of more than 100 stakeholders. 32 6/26/2014 CDFW R CDFW requests that in addition to the 25 5 Water LCH added the requested water quality water quality constituents proposed to be Quality constituents to the list contained in the analyzed from the grab samples at three Water Quality Study Plan. depths near the dam, specified in the Water Quality Study Plan, LCH also analyze the samples for nitrate-nitrite, total ammonia, total Kjeldahl nitrogen, total phosphorus, and dissolved orthophosphate. 33 6/26/2014 CDFW R CDFW requests that LCH also analyze from 5 Water The Project will not introduce bacteria or the surface grab samples collected near the Quality affect any existing bacteria present in Lake dam total coliform, fecal coliform, and Clementine. Consequently, fecal coliform Escherichia coli. sampling has not been included as a component of the study plan. 34 6/26/2014 CDFW R CDFW requests that water quality monitoring 5 Water The Water Quality Study Plan has been field crews record incidental observations of Quality modified to include collecting algal samples didymo (Didymosphenia geminata) and observed in the vicinity of water quality collect samples for laboratory confirmation. monitoring stations. Samples will be This nonnative alga alters stream ecology and provided to CDFW for laboratory to water quality and has been found in the determine if samples contain didymo. Middle Fork American River upstream of the confluence with the North Fork American River. 35 9/25/2014 CDFW C The Department appreciates the Applicant’s 3 Water No response needed. incorporation of our comments on WR-1 Quality Water Quality Study Plan and concurs with the content of the most recent version of this study plans dated September 11, 2014.

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response 36 9/25/2014 CDFW R Study WR-3 Sediment Transport - The 4 Water LCH will consult with resource agencies as Department recommends that analytic tools Quality each study progresses and at each point are selected in collaboration with the requiring a discussion of study methods. In Department and other stakeholders. Based addition technical memoranda will be on the timeline presented in this study, the prepared following each major study effort. Applicant should schedule a technical These memoranda will describe the efforts meeting with interested stakeholders to to date, provide raw data for agency analysis assess these analytic tools in early 2015, in and interpretation, and identify any topics the early part of the initial investigation requiring additional consultation with step. agencies. 37 6/10/2014 NMFS R NMFS recommends that the “Sediment Study 5 Water The objectives of the two studies are Plan” be merged with the Water Quality Quality different and merging them into one study Study Plan because water temperature, DO, plan would unnecessarily confuse the other water quality parameters, and sediment objectives. The objective of the Water quality are often included in a single plan, Quality Study is to characterize existing and the purpose of these two plans is to water quality conditions and the objective of assess the Project’s effects on water quality. the Sediment Transport Study is to assess whether proposed Project operations could mobilize sediments and whether any such mobilization could result in increased turbidity or exposure to contaminants at habitats downstream of the proposed Project. LCH believes it is appropriate to maintain separate study plans to investigate potential effects related to water quality. 38 6/10/2014 NMFS R NMFS agrees with the three proposed water 6 Water Based on comments from SWRCB and quality sampling locations in the reservoir, Quality CDFW, the water quality Study Plan but states that sampling should also be done provides for a single reservoir sampling upstream and downstream of the reservoir location near the proposed intake location. and that a more robust data set of water and Temperature and DO profiles will be taken sediment quality would be obtained if the at this location from June until reservoir sampling was done on a quarterly basis rather temperature stratification breaks down, than just sampling during the warmer, low- which may occur in October or November. flow periods. The rationale provided by The study plan includes provisions for

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response NMFS include: (1) it is common fisheries continuous water temperature monitoring practice to conduct seasonal or quarterly and monthly DO measurements at stations sampling both in the reservoir and upstream upstream of the reservoir, in the proposed and downstream of the reservoir, (2) DO bypassed reach, and downstream of the sampling during cold water versus warm proposed powerhouse during the same time water conditions will typically yield different frame. In addition two, 1-week periods— results, and (3) inadequate DO, such as may one in summer and one in November or exist in a stagnant reservoir, may detract from December—have been added to the ecosystem health and limit the presence and methodology for recording DO. This abundance of fish populations. sampling regime will capture worst case conditions in the reservoir (i.e., the warmest period of the year when the reservoir is stratified) and downstream of the dam. The additional monitoring in November or December will provide data about DO during the period when the Project would most likely be operating. It will enable seasonal changes in potentially Project influenced water to be discerned. Grab samples at all stations collected during June, July, and August will enable worst case conditions for other parameters to be characterized and sampling in November and December will provide information about water quality during the period of the year when the Project would be operating. 39 6/10/2014 NMFS R NMFS comments that LCH does not propose 6 Water On August 5, 2014, NMFS clarified that its a “sediment/gravel” budget study and that Quality comments assumed the intake would be knowing the amount and timing of sediment located at or near the bottom of the North as it is transported into a reservoir is desirable Fork Dam. Since the Project will draw water because it can help determine if from the surface of Lake Clementine, sedimentation will affect Project operations, sediment/gravel passage studies are not the water intake, and conveyance facilities. relevant to the Project design or operation. NMFS states that at a minimum, LCH should conduct a bathymetric survey of the reservoir

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response and compare to pre-dam surveys to determine volumetric sediment accumulation rates in the reservoir. 40 6/10/2014 NMFS R NMFS states that to more accurately 6 Water On August 5, 2014, NMFS clarified that its characterize the physical and geochemical Quality comments assumed the intake would be properties of the reservoir sediments, coring located at or near the bottom of the North samples should extend along the longitudinal Fork Dam and therefore more likely to path of the reservoir, which would mean mobilize sediments. The intake will be establishing at least two additional coring designed to only use surface water so there stations at the head of the reservoir and one will be no the potential to mobilize in the middle of the reservoir. Grain size and sediments located further upstream in the chemical composition of the core samples are reservoir. The study plan includes sampling recommended, which presumably would be sediments located in the vicinity of the the same as LCH proposes in the vicinity of intake for analysis for contaminants. the proposed intake. 41 6/10/2014 NMFS R NMFS recommends that suspended sediment 7 Water The Water Quality Study Plan requires sampling in the reservoir should occur Quality measuring total suspended solids (i.e., throughout the year with particular emphasis sediments) at three depths at one station on high flow events when the majority of located in the vicinity of the proposed intake suspended sediment is transported. in June, July, August, November, and December. The June, July, and August period represents the declining limb of the hydrograph and the period in which the Project may not be operating due to low flows. The November and December period represents the high flow period and when the powerhouse would most likely be operating. LCH believes that these sampling periods would provide adequate information to analyze and assess Project effects on sediment transport. High flow events such as flood flows would occur during major storms, rain on snow, and potentially spring run-off periods. To

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response take suspended sediment samples during these conditions would be extremely hazardous to field personnel responsible for taking measurements and would not be representative of conditions that normally occur. FISH AND AQUATIC RESOURCES 42 5/30/2014 SWRCB C Fluctuation in flows from the dam could 3 Fisheries The potential for fish stranding or isolation potentially strand or entrain resident fish in in the bypass reach (which LCH assumes is the bypass reach. what SWRCB means by entrainment in this comment) will be assessed in the Fisheries 6/25/2014 2 Study Plan. Determining the composition of the fish community in what would become the bypass reach will also enable an assessment of stranding potential. 43 5/30/2014 SWRCB C Clarify which fish species referenced in the 5 Fisheries The Fisheries Study Plan has been modified Fisheries Study Plan are native to the NFAR to delete rainbow trout from the non-native and which are stocked in Lake Clementine species introduced to the NFAR and Middle and the NFAR. Fork American River watersheds. Although stocking has introduced non-native strains of rainbow trout, to avoid confusion LCH deleted this species reference in the study plan. LCH will review available stocking records for Lake Clementine and the NFAR and include a summary of these data in the license application. 44 6/26/2014 CDFW R LCH should design a Before-After-Control- 6 Fisheries LCH has modified the fisheries study plan to Impact Study to include multi-year sampling include one sampling location upstream of efforts, a control study reach, and impact Lake Clementine to act as a control study study reach. site for post Project monitoring, if necessary. 45 6/26/2014 CDFW R LCH should add to the Fisheries Study Plan 6 Fisheries This methodology is already included on that gill nets should be deployed in the page 4 of the study plan: “These offshore 16 October 17, 2014 Lake Clementine Hydroelectric Project, FERC No. 13432 ©2014, Lake Clementine Hydro, LLC Lake Clementine Hydroelectric Project, FERC No. 13432 Response to Comments on Study Plans

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response vicinity of the proposed Project intake. sampling locations will be distributed along the length of the reservoir, including one location at the boat barrier of the dam.” 46 6/26/2014 CDFW R All fisheries data should be made available to 6 Fisheries LCH will direct its consultants to make all CDFW in electronic format using Microsoft data collected in an electronic format such Excel or Access. as Microsoft Excel or Access. 47 6/26/2014 CDFW R CDFW recommends that the study plan 6 Fisheries LCH has modified the study plan to include specify that the transects sampled by multiple multiple electrofishing passes. pass electrofishing downstream of the dam should strive for depletion but complete no less than three passes to ensure consistency with electrofishing methods used in other licensing studies in California. 48 6/26/2014 CDFW R Besides being measured, fish collected during 6 Fisheries LCH has modified the study plan to make it riverine electrofishing should also be clear that all fish collected by riverine weighed and any abnormalities noted, such as electrofishing will be weighed and the lesions or parasites. Length and weight data analysis will include presenting Fulton’s should be used to determine Fulton’s condition factors and the estimated number condition factor. Density of fish should be of fish per mi and fish per acre. expressed as fish per mi and pounds per acre. 49 6/26/2014 CDFW R CDFW is concerned that the proposed 7 Fisheries LCH has revised the gill net soak times to be overnight soak time for gill net sets would 2 hours and state that any live fish removed result in unacceptably high fish mortality from the nets will be retained in an aerated rates, including hardhead, a state species of tank until the end of the sampling period or special concern. released at a distance far enough away from the nets to avoid recapture of the same fish. 50 6/26/2014 CDFW R CDFW notes that gill nets are known to be 7 Fisheries The study plan has been modified to specify size selective, but the bias can be corrected that the length of each fish captured in each with the use of selectivity curves by size mesh of the variable mesh gillnets will comparing the catch of each length class of be recorded in the field. This will enable each fish species across multiple mesh correction of any size bias in the gill net panels. samples during the analysis.

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response 51 6/26/2014 CDFW R CDFW recommends that the results of gill 8 Fisheries LCH has modified the study plan to clarify netting be expressed as number or mass of that catch per unit of effort will be expressed fish caught per set. as catch per set. LCH also proposes to express catch as the number of fish caught per hour of gill net soak time. 52 6/26/2014 CDFW R Because one of the goals of the Fisheries 8 Fisheries LCH added an additional night of gill Study is to inform the results of the Fish netting at the station(s) near to the proposed Entrainment Study, CDFW recommends that intake location under both stratified and multiple sampling events occur in order to unstratified reservoir conditions. The goal detect temporal and spatial changes in the would be to have at least 2 weeks between vicinity of the Project intake structure. sampling efforts. This approach would result in a total of four nights of gill netting near the proposed location of the intake, which should result in adequate data to assess temporal and spatial differences near the intake. 53 6/26/2014 CDFW R The study plan does not indicate where live 8 Fisheries The Fisheries Study Plan methodology has fish would be released after they have been been modified to hold live fish removed removed from the gill net. Releasing fish near from the gill nets in an aerated tank and the net array could possibly result in released at the conclusion of the sampling recapture, which may result in decreased period or released at a distance far enough survivability of an already stressed fish. away from the net sets to avoid recapture of the same fish. 54 6/26/2014 CDFW C If the fish entrainment study is implemented 8 Fisheries LCH has chosen the intake canal option for prior to the determination final generation its proposed Project. design, specific methodologies for data collection and evaluation of entrainment risks for aquatic species will need to be developed for each proposed intake configuration in coordination with stakeholders.

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response 55 6/26/2014 CDFW C CDFW refers to a statement on page 2 of the 8 Fisheries CDFW misquotes the sentence on page 2 of Fish Entrainment Study plan: “Non-native the study plan. The reference to Sacramento fish introduced to the North and Middle sucker pertains to the fish in Lake Forks American River watersheds include Clementine, which includes Sacramento rainbow trout, brown trout, largemouth bass, sucker. In reference to non-native fish in the brown bullhead, green sunfish, and watershed, the study plan states: “Non- Sacramento sucker.” CDFW states that native fish introduced to the North and although rainbow trout are stocked in the Middle Forks American River watersheds American River watershed, it does not include rainbow trout, brown trout, consider them to be non-native introduced largemouth bass, brown bullhead, and green species. Native resident rainbow trout sunfish.” Although most stocked rainbow currently occur in the watershed. CDFW also trout are not native to the American River notes that the Sacramento sucker is also watershed, LCH has deleted the reference to native to the watershed. rainbow trout from the study plan because there are native populations that also occur. 56 6/26/2014 CDFW R The Fish Entrainment Study Plan states that: 8 Fisheries The intent of the study plan was to use the “The EPRI database will be thoroughly three size groups commonly used for screened to provide information for entrainment studies throughout the country calculating reliable seasonal and annual to enable potential entrainment survival to estimated entrainment rates for fishes of three be estimated at the Project. Varying from size groups—small (less than 6 inches), these generic size ranges reduces the medium (6 to 12 inches), and large (greater comparability of data from other sites to the than 12 inches) fish for target species proposed Lake Clementine Project. considered in this estimate.” CDFW However, LCH recognizes the potential to recommends that turbine fish survival is tailor the size range of potentially entrained estimated on a less restrictive size range and fish based on the results of the Fisheries is based on the size range and life stages of Study. The study plan states: “Entrainment all species found to be within the Project- and survival for fish of different size affected area during any time of the year. The categories will be estimated based on site- results of the Fisheries Study should be used specific information regarding the species to inform the specific size ranges and fish and size of fishes likely to be entrained.” species at risk of entrainment into the Project facilities. 57 6/26/2014 CDFW R The Fish Entrainment Study Plan states: 9 Fisheries LCH revised the study plan to reflect its

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response “Estimates of approach velocity at the Project intent to estimate sustained and burst speeds intake will be developed as part of Study Plan of fishes that may be subject to entrainment. WR-3, Sediment Transport Study Plan, and LCH intends to collaborate with will be used in conjunction with literature- stakeholders during the implementation of based fish swimming speed estimates to this study. evaluate the potential for fish to avoid entrainment.” CDFW recommends that a range of fish swim speeds should be calculated for fish found near the intakes using sustained and burst speeds derived from the literature in combination with the range of fish lengths measured at each sample location. CDFW recommends that LCH coordinate with stakeholders to develop the relationship values associated with fish body length and water chemistry in order to collaboratively agree on critical swimming speeds and burst speed values. 58 6/26/2014 CDFW C CDWF cautions against the sole reliance on a 9 Fisheries The Fish Entrainment Study Plan includes blade strike model to predict impacts on provision to predict turbine mortality by downstream migrating fish. It states that using two approaches: (1) a blade strike many other stressors result in fish turbine modeling analysis; and (2) a literature mortality. review of applicable entrainment studies conducted at existing hydroelectric projects with similar characteristics to the proposed Project. The latter element of the study will consider projects with similar head to the proposed Project, which will provide a measure of survival related to the cumulative effects on fish passing through the Project. 59 6/26/2014 CDFW R CDFW has determined that an instream flow 15 Fisheries The Water Quantity Study results will habitat study plan is needed to assess aquatic identify periods when there would be species habitat in relation to stream flow in reduced flow to the bypass reach. The Water

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response the bypass reach because this reach may Quality Study results will characterize the potentially be dewatered by Project existing water quality in the bypass reach. operations. CDFW states that LCH has not The Amphibian and Reptile Study will conducted an instream flow study or characterize habitat in the bypass reach and equivalent assessment of the aquatic habitat downstream of the proposed tailwaters. The in the bypass reach, nor is any related Fisheries Study will characterize the fish information provided in the proposed study community and habitat in the bypass reach, plans. CDFW recommends an instream flow including the substrate. As noted in the incremental methodology study, potentially Fisheries Study Plan, LCH and its technical using the Physical Habitat Simulation consultant will consult with resource (PHABSIM) system that takes into account agencies to determine appropriate river hydraulics, species life stage methodologies to determine the relationship microhabitat suitability, and physical habitat between flow and aquatic habitat in the modeling. bypass reach. This could entail the use of PHABSIM or other acceptable techniques. LCH considers it premature to specify a methodology for this aspect of the study until on-site conditions are better quantified. The results of these four studies should enable the Project effects on the bypass reach to be estimated without the need to conduct an additional specific study. 60 9/25/2014 CDFW C The Department appreciates the Applicant’s 4 Fisheries No response necessary. incorporation of our comments on AQ-1 Fisheries Resources Study Plan and concurs with the content of the most recent version of this study plan dated September 11, 2014. 61 9/25/2014 CDFW R According to the Applicant’s Pre-Application 4 Fisheries The fisheries study plan contains a Document (PAD; America Renewables methodology to identify the species of fish 2010), sampling in August showed that located in the vicinity of the Project intake surface water temperatures in Lake at all depths of the reservoir. The water Clementine were about 25° C from the quality study will provide information about surface to 20 feet in depth. However, water habitat conditions of the reservoir such as temperatures decreased to 12° C at a depth of temperature and dissolved oxygen profiles.

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response 50 feet. Deeper cold water areas of the reservoir can provide thermal refuge for trout species. Thus, the Department believes it is more likely that rainbow trout (Oncorynchus mykiss) and brown trout (Salmo trutta) would be present in Lake Clementine at depths greater than 20 feet during the summer and fall, seeking thermal refuge from higher surface water temperatures. 62 9/25/2014 CDFW C The Applicant will be studying the life 5 Fisheries AQ-2, Fish Entrainment Study Plan, has history, abundance, and relative density of been revised to include the results of AQ-1, fish populations present in Lake Clementine Fisheries Study Plan. and the NFAR in proximity to North Fork Dam under AQ-1 Fisheries Study Plan. The Department would like to remind the Applicant to use the results of AQ-1 Fisheries Study Plan in conjunction with any existing information mentioned above and revise the Methods section of this study plan to include the use of this information. 63 9/25/2014 CDFW R CDFW recommends an Instream Flow 12 Fisheries Due to the length of the bypass reach of the Habitat Study Plan (habitat) NFAR, approximately 600 to 1,000 ft and the conditions within the reach, LCH has proposed that its fisheries technical consultant (to be selected) consult with agency technical specialists on site to discuss and determine the most appropriate method for measuring fish habitat affected by the Project. At this time, LCH does not believe that it is appropriate or prudent to commit to a PHABSIM study. 64 6/10/2014 NMFS R NMFS states that low flows in the bypass 3 Fisheries The Water Quantity Study results will reach could potentially result in inhospitable (habitat) identify periods when there would be habitat for native species, including reduced flow to the bypass reach. The Water

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response salmonids, and a reduction in sediment Quality Study results will characterize the deposition and/or transport capacity. LCH existing water quality in the bypass reach. should conduct a detailed channel The Amphibian and Reptile Study results morphology study of the bypass reach will characterize habitat in the bypass reach including 2-dimensional mapping and/or and downstream of the proposed tailwaters. modeling including water depth, channel The Fisheries Study results will characterize width at all relevant flows, and mapping of the fish community and habitat in the bypass existing grain sizes and areal extent of any reach, including the substrate. As noted in sediment deposition in the bypass reach. the Fisheries Study Plan, LCH and its technical consultant will consult with resource agencies to determine appropriate methodologies to determine the relationship between flow and aquatic habitat in the bypass reach. The results of these four studies should enable the Project effects on the bypass reach to be estimated. 65 6/10/2014 NMFS R NMFS states that the specific locations of 3 Fisheries LCH considers it appropriate to base proposed riverine sampling stations should be specific electrofishing sampling locations on specified in the study plan. a reconnaissance-level survey conducted by the contractor selected to do this work, as proposed in the study plan. Similarly, it would also be appropriate to select the pools where snorkeling surveys will be conducted based on the site reconnaissance. Prior to conducting the site reconnaissance, LCH will notify stakeholders of the planned date and time of reconnaissance, and specific sampling locations will be identified in the field. 66 6/10/2014 NMFS R NMFS states that besides sampling fish in the 3 Fisheries The study plan includes sampling main body or Lake Clementine, riverine fish immediately downstream of the Project’s sampling should occur: (a) up to 1 mi tailrace, so part (c) of NMFS’ comment is upstream of Lake Clementine; (b) up to 1 mi already addressed in the methodology. downstream of the North Fork Dam; and (c) LCH added a sampling location upstream of

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response immediately downstream of the Project’s Lake Clementine to serve as an unaffected tailrace and “other local discharges.” control location should future monitoring be required. LCH also increased the study area to include the reach extending from the North Fork Dam to the confluence with the Middle Fork American River. 67 6/10/2014 NMFS R NMFS believes that a combination of 4 Fisheries Sampling the downstream reach during low quarterly electrofishing and snorkeling flow, high temperature conditions will should be used at all sampling stations, where collect information under conditions when appropriate, including the three locations Project operations would have the most suggested in the previous comment. NMFS potential to affect riverine fish populations. states that electrofishing can be more Under higher flow conditions, flows that effective sampling techniques when water exceed the hydraulic capacity of the turbines depth and turbidity limits snorkeling, such as would be beyond the control of LCH, and during spring runoff. the distribution of fish would be most influenced by spillage flows, not hydro operations. Sampling with a backpack electrofishing unit under high flow conditions is not typically recommended because of safety considerations. Also see our response to the previous comment. 68 6/10/2014 NMFS R NMFS states that reservoir sampling is only 4 Fisheries LCH revised the study plan to sample proposed for the summer, whereas it reservoir fish in Lake Clementine under considers spring, summer, fall, and winter stratified and unstratified conditions. The sampling to be the most appropriate. It information obtained under these conditions reiterates the same argument for quarterly would represent the distribution of fish in sampling in riverine reaches. the vicinity of the intake under both circumstances. 69 6/10/2014 NMFS R NMFS proposes that LCH develop a Large 7 Fisheries The amount of LWD trapped at the dam will Woody Debris (LWD) Study Plan with the (habitat) not change because of the Project. The goal of quantifying the annual LWD volume disposition of this LWD will remain the in the North Fork American River and Lake responsibility of the USACE. The one Clementine and how much is passed over the potential exception would be if LWD should spillway or potentially trapped at the new interfere with the flow of water at the

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response powerhouse intakes, and deposited below the proposed intake or with other Project-related dam. operations. However, this would be an operation and maintenance issue, not an environmental issue. 70 6/10/2014; NMFS R NMFS does not believe that using three 8 Fisheries The proposed three size ranges of entrained 10/1/2014 generic size ranges of fish is an accurate fish (< 6 in., 6-12 in., and >12 in.) are representation of all life stages of all fish. consistent with the approach used for desk- NMFS states that survival through the top entrainment studies conducted proposed turbines should be estimated for all throughout the country and commonly specific life stages of all species of fish found accepted by resource agencies and FERC. in the vicinity of the Project at any time of The rationale for using these size classes is year, which may mean using specific size based on the established fact that ranges for different species. entrainment survival is primarily a function of the size of the fish and not the species of [NMFS also made this same comment in an the fish, with smaller fish experiencing edited version of the study plan on 10/1/14.] higher survival rates than larger fish. After the results of the reservoir fisheries sampling are compiled, consideration can be given to adjusting these size classes, if appropriate. 71 6/10/2014 NMFS R NMFS recommends that LCH work with 9 Fisheries The purpose of the desk-top entrainment USACE to study the development of methods study is to provide a basis for evaluating or facilities that would provide safe and Project effects on fish that are likely to be effective downstream fish passage for entrained. This information will provide the existing fish populations and potential future basis for determining if protection, populations of Central Valley steelhead that mitigation, or enhancement measures are may be reintroduced upstream of the dam. appropriate. It is not LCH’s responsibility to NMFS notes that the only current assess current survival of fish passing over downstream passage option is by spilling the spillway or to provide measures that may over the 155-foot high dam onto a hard reduce the number of fish passing over the surface, and it does not consider this or spillway. turbine entrainment to be a safe and effective means of downstream fish passage.

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response 72 6/10/2014; NMFS C NMFS cautions against the sole reliance on a 9 Fisheries The Fish Entrainment Study Plan includes a 10/1/2014 blade strike model to predict impacts on provision to predict turbine mortality by downstream migrating fish. It states that using two approaches: (1) a blade strike many other stressors result in fish turbine modeling analysis; and (2) a literature mortality. review of applicable entrainment studies conducted at existing hydroelectric projects [NMFS also made this same comment in an with similar characteristics to the proposed edited version of the study plan on 10/1/14.] Project. The latter element of the study will consider projects with similar head to the proposed Project, which will provide a measure of survival related to the cumulative effects on fish passing through the Project. TERRESTRIAL RESOURCES Plant Species and Habitat 73 5/30/2014 SWRCB C Reduced spillage at the dam could create 3 Terrestrial The Amphibian and Reptile study will habitat in the bypass reach that is conducive (amphibians) evaluate whether habitat in the bypass reach 6/25/2014 to invasive species such as bullfrogs 2 could become conducive for invasive species, such as the bullfrog. 74 10/1/2014 SWRCB C LCH needs to clarify the role resource 4 Terrestrial The recommended change has been made to agencies will have in determining whether (amphibians) the study plan. protocol-level CRLF surveys are required. State Water Board staff recommends the following change, “LCH will meet and consult with State and Federal Agencies following the completion of the Site Assessment Report to determine collaboratively if protocol surveys are required.” 75 5/30/2014 SWRCB R The Amphibian and Reptile Study Plan only 5 Terrestrial Because the Project may use the alignment proposes to conduct habitat surveys for 1,000 of an abandoned road that extends from Old feet downstream of North Fork Dam. Given Foresthill Road to North Fork Dam for

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response that Project operations may alter water construction access, the study area has been temperatures in the NFAR, LCH should increased to include the NFAR below the survey the extent of the NFAR where North Fork Dam to its confluence with the SWRCB temperatures may be affected by Middle Fork American River. Project operations and not limit the survey area to 1,000 ft. LCH’s proposed powerhouse will be located 250 to 600 feet downstream of the North Fork Dam. A 1,000 ft habitat survey might only evaluate 400 ft of river below the powerhouse if the powerhouse will be 600 ft downstream of North Fork Dam. 76 5/30/2014 SWRCB R SWRCB staff requests that the Site 6 Terrestrial The draft Site Assessment document will be Assessment document be circulated to distributed to all agencies for review and SWRCB staff for review. comment. 77 6/26/2014 CDFW R In addition to special-status plants, Project 4 Terrestrial The study title has been modified to include construction and maintenance effects to (Botanical) natural communities and include special- special-status natural communities such as status plant community identification as a Sambucus nigra Alliance (blue elderberry study objective. stands) need to be considered. Surveys for special-status natural communities should be incorporated into and conducted concurrently with surveys for special-status plants. 78 6/26/2014 CDFW R This study was revised from the original 9 Terrestrial The recommended changes to the study plan version to include surveys for special-status (Botanical) have been made. LCH expects that the natural communities in addition to special- contractor conducting this study will status and invasive plants. Thus, the study identify and map any other special-status plan should be renamed to: Special-Status communities encountered during the survey. Plant and Natural Communities and Invasive Plant Study Plan and the resource issue revised as follows (italics): The Project would require a certain amount of ground disturbing activities and removal of vegetation that may affect special status plants and natural communities. Additionally,

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response text throughout the document should be revised to include natural communities as a component of the study plan. 79 6/26/2014 CDFW R The Department recommends the Applicant 10 Terrestrial LCH has modified the study plan to state conduct new queries of the CNPS Inventory (Botanical) that prior to initiating plant surveys, LCH and CNDDB prior to conducting surveys to will review up-to-date versions of the CNPS obtain an updated list of special-status plants California Native Plant Inventory and the that occur or have the potential to occur in CNDDB to identify all species with the Project vicinity and ensure surveys are potential to occur in the Project and review conducted during the blooming periods for specific blooming periods to ensure surveys those species. are conducted at appropriate times for each species. 80 6/26/2014 CDFW R Revise the description of the study area for 10 Terrestrial LCH has revised the description of the study the Special Status and Invasive Plants Study (Botanical) area as recommended. to read “Floristic surveys will be conducted within all proposed Project footprints, alignments, and alternatives for construction staging areas and access routes, road improvements, generation facilities, the powerhouse, transmission line corridors, and all other areas in which ground disturbing activities will occur, plus a 100-ft buffer. Additionally floristic surveys will be conducted within a 100 ft radius of the dam extending upslope from the high-water mark of both Lake Clementine and the NFAR. 81 6/26/2014 CDFW R In addition to CNPS List 1A, 1B, 2A, and 10 Terrestrial LCH has modified the study plan to include 2B, include CNPS List 3 and 4 species in the (Botanical) CNPS List 3 – Plants about which more survey plan. information is needed – A review list, as well as CNPS List 4 – Plants of limited distribution – A watch list. 82 6/26/2014 CDFW R In addition to using the CDFA List of A- and 10 Terrestrial LCH has made the recommended changes to B-rated invasive plants to identify potential (Botanical) the study plan.

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response invasive species in the Project Area, the agency recommends several additional resources. 83 9/25/2014 CDFW R This study was revised from the original 5 Terrestrial TR-1, Special-Status Plant and Natural version to include surveys for special- (Botanical) Communities Study Plan, has been revised status natural communities in addition to to include natural communities as special-status and invasive plants. Thus, recommended by CDFW. the first resource issue of the study plan should be revised as follows (italics): The project would require a certain amount of ground disturbing activities and removal of vegetation that may affect special status plants and natural communities.

84 9/25/2014 CDFW R The Analysis section on Page 6 of this 6 Terrestrial TR-1, Special-Status Plant and Natural study plan states that study results will (Botanical) Communities and Invasive Plant Study Plan, include "confirmation of the presence of has been revised to include Brandegee's special-status plant species, which include; clarkia ( Clarkia biloba ssp. brandegeeae), Jepson's onion and oval-leaved viburnum." Butte County fritillary (Fritillaria This list should also include the following eastwoodiae), dubious pea (Lathyrus rare plant species: Brandegee's clarkia sulphureus var. argillaceus), Humboldt (Clarkia biloba ssp. brandegeeae), Butte lily (Lilium humboldtii var. humboldtii), County fritillary (Fritillaria eastwoodiae), Red Hills soaproot ( Chlorogalum dubious pea (Lathyrus sulphureus var. grandiflorum), and streambank spring argillaceus), Humboldt lily (Lilium beauty (Claytonia parviflora ssp. humboldtii var. humboldtii), Red Hills grandiflora). It should be noted that the soaproot ( Chlorogalum grandiflorum), and study methodology includes a floristic streambank spring beauty (Claytonia survey which will identify and document parviflora ssp. grandiflora), which have all species encountered. been identified by the CNPS Inventory and/or CNDDB to potentially occur in the Project vicinity.

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response 85 9/25/2014 CDFW R The Department recommends surveying 6 Terrestrial LCH agrees that additional field surveys are the site for more than one year to increase (Botanical) needed in 2015 to include areas that were the likelihood of detecting special status not surveyed in 2014 because LCH did not plant species as well as surveying a nearby have permission to access private lands reference site to ensure the timing of associated with the transmission line routing surveys is appropriate. The Department study area. Also, 2014 was an atypical also recommends an additional season of climatic year due to the extreme drought floristic surveys as the surveys conducted conditions. by the Applicant in 2014 were limited in It should be noted that drought conditions geographic scope due to a lack of access to have persisted in California for several years portions of the study area, and surveys were and these conditions may continue into 2015 not conducted in recently identified Project and beyond. Therefore, LCH cannot plan for affected areas associated with alterative additional study periods based on the access routes. expectation that climatic conditions would return to normal. The results of the studies will provide the best available information for analyzing and assessing Project effects. Wildlife 86 6/26/2014 CDFW C The agency lists numerous state-listed, Fully 3–5 Terrestrial LCH has modified the Wildlife Study Plan Protected, Species of Concern, and raptor (Wildlife) to include habitat mapping, determination of species identified in the California Wildlife species likely to occur based on the CWHR Habitat Relationships (CWHR) database as Database, and field surveys for specific having potential to occur in the Project species or species groups. vicinity. 87 6/26/2014 CDFW R The special-status reptile and amphibian 4 Terrestrial LCH agrees these species spend the majority species of concern with potential to occur in (Amphibians of their time in aquatic environments, but the Project vicinity include western pond and Reptiles) we note that FERC typically addresses these turtle (Actinemys marmorata), CRLF, and species in the terrestrial section of its NEPA FYLF. Although these species may utilize documents. terrestrial habitats, these species spend a majority of their life in water and therefore are considered to be aquatic species.

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response 88 9/25/2014 CDFW R The Department believes the methodology 6–7 Terrestrial LCH has revised the TR-2, Amphibian and described above lacks fundamental details (Amphibians Reptile Study Plan, to include these regarding sampling periodicity (season) and and Reptiles recommendations. frequency (number of sampling events). Specifically, no time frame is given to indicate what time of year surveys will take place or how many sampling events will occur. The Department recommends that basking surveys are conducted on sunny days between the hours of 08:00 and 12:00, as outlined in Bury, Ashton, and Horn (2012), Alvarez (2006), and USGS (2006), for three consecutive days for three months (May, June, and July) when Lake Clementine surface water temperatures are greater than 12°C. This methodology will provide the best opportunity to determine the presence of western pond turtles in the proposed Project vicinity. 89 6/26/2014 CDFW C CDFW requests that the Fish Entrainment 9 Terrestrial LCH has modified the Amphibian and Study Plan address how the entrainment risk (Wildlife) Reptile Study Plan to include surveying the will be estimated for non-fish species, Lake Clementine shoreline near the location including river otters, western pond turtle, of the proposed intake for potential basking California red-legged frog, and foothill sites and using artificial basking sites to yellow-legged frog. determine if western pond turtles use the area near the proposed location of the intake. The Wildlife Study Plan has been modified to include a literature search regarding the relationship of flow velocity and potential impingement of river otters on the Project intake trash racks. 90 6/26/2014 CDFW C Red-eared sliders have been observed by 11 Terrestrial LCH has revised the study plan Department staff at Lake Clementine (A. (Wildlife) methodology to record any observations of Koons, pers. comm. 2014). red-eared slider turtles.

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response 91 6/26/2014 CDFW R Site assessment and survey reports for CRLF 11 Terrestrial LCH will provide all site assessment and should be provided to CDFW. (Wildlife) survey reports to all stakeholders. 92 6/26/2014 CDFW R Extend surveys for FYLF to at least 1 mi 11 Terrestrial LCH has expanded the study area to include downstream of the North Fork Dam (Wildlife) the NFAR between North Fork Dam and its confluence with the Middle Fork American River. 93 6/26/2014 CDFW R Use visual encounter survey methods 11 Terrestrial The study plan has been revised to include described in Yarnell, Peek, and Lind (2014) (Wildlife) the recommended protocol. for FYLF surveys, including conducting surveys for egg masses in water deeper than the proposed <50 cm. 94 6/26/2014 CDFW R CDFW notes that the time for spring surveys 12 Terrestrial LCH will conduct surveys during has passed but recommends conducting (Wildlife) appropriate periods. summer and fall surveys in 2014 and spring surveys in 2015 95 6/26/2014 CDFW R The proposed Amphibian and Reptile Study 12 Terrestrial LCH has consulted with CDFW during each Plan would not provide adequate information (Wildlife) of the study plan meetings on this study on the spatial and temporal distribution of plan. In addition to surveying for nesting western pond turtle. Recommend and wintering habitat, LCH has modified the coordinating with CDFW to develop study Reptile and Amphibian Study to include plan for site specific surveys to provide this identification of suitable basking areas information within 500 ft of the proposed intake. 96 6/26/2014 CDFW R Studies need to be conducted within all 13 Terrestrial The study plan has been revised to clarify proposed Project footprints, alignments, and (Wildlife) that the intent of the proposed 0.5 mi zone alternatives for construction staging areas and around Project facilities would include all access routes, road improvements, generation proposed Project footprints, alignments, and facilities, the powerhouse, transmission line alternatives for construction staging areas corridors, and all other areas in which ground and access routes, road improvements, disturbing activities will occur, plus a buffer generation facilities, the powerhouse, of some distance depending on the focal transmission line corridors, and all other species of the survey being conducted. areas in which ground disturbing activities will occur.

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response 97 6/26/2014 CDFW R Conversation between J. Holeman and M. 13–14 Terrestrial LCH has modified the Wildlife Study Plan Jeter and CDFW provided anecdotal (Wildlife) methodology to include specific survey information related to bald eagles and protocols for bald eagles and peregrine peregrine falcons in the Project vicinity, but falcons. specific studies are still needed to verify presence and determine the abundance, spatial and temporal distribution, status, and habitat use of species within an area. 98 6/26/2014 CDFW R The CWHR database cannot be used to 14 Terrestrial LCH has modified the Wildlife Study Plan determine the actual presence, abundance, (Wildlife) methodology to include habitat mapping, spatial and temporal distribution, status, and use of the CWHR Database to determine habitat use of species within an area. If the what species would likely occur in the Applicant does not conduct species-specific Project-affected area, potential presence of surveys, the Department will not be able to listed and special-status species, and survey determine if and how Project construction, protocols for specific species or species operations, and maintenance activities will groups. affect wildlife species. 99 6/26/2014 CDFW R Recommend a peregrine falcon survey to 17–20 Terrestrial LCH has revised the Wildlife Study Plan determine nest activity, nesting chronology, (Wildlife) methodology to include a two phase and pair sensitivity to disturbance. approach for studying peregrine falcons. The first phase is to gather existing available information regarding observations and records pertaining to existing eyries. If adequate information is not available, then LCH will conduct a survey using established protocol methods. 100 6/26/2014 CDFW R Recommend Bald Eagle Study for nests, 18–23 Terrestrial The Wildlife Study Plan has been modified roosts, wintering activity, and night roosts (Wildlife) to include a two phase approach, similar to within 0.5 mi of Project disturbance and the study approach for peregrine falcons, to footprints. determine the use of the NFAR in the Project vicinity and Lake Clementine by bald eagles.

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response 101 6/26/2014 CDFW R Recommend raptor surveys for nests, nest 23–25 Terrestrial The study area includes all temporary and success, wintering activity, and night roosts (Wildlife) permanent Project features such as staging within 500 ft of Project disturbance and and laydown areas, access roads, footprints. transmission line route, canal and canal, penstock(s), powerhouse, and switchyard plus a 500-ft buffer. 102 6/26/2014 CDFW R Recommend Special Status Riparian Bird 25–27 Terrestrial The study plan includes surveying for Surveys and Nest Monitoring. Study would (Wildlife) nesting riparian bird species. The study area include nesting surveys in riparian habitats includes all temporary and permanent within 500 feet of all Project footprints, Project features such as staging and laydown alignments, access roads, staging are etc. areas, access roads, transmission line route, Study would focus on yellow warbler and canal and canal, penstock(s), powerhouse, yellow breasted chat (both CDFW species of and switchyard plus a 500-ft buffer. special concern). 103 6/26/2014 CDFW R Recommend special status bat surveys to 27–30 Terrestrial The study plan includes surveying for identify bat use of existing man-made (Wildlife) special status bats. The study area includes structures within the proposed Project Area all structures within the footprint of all and disturbance areas. Surveys are to include temporary and permanent Project features the North Fork Dam, bridges, buildings and such as staging and laydown areas, access other structures, if present roads, transmission line route, canal and canal, penstock(s), powerhouse, and switchyard plus a 500-ft buffer. 104 9/25/2014 CDFW C However, the Department does not agree 7 Terrestrial TR-3, Wildlife Study Plan, describes a two- with the two-phased study approach (Wildlife) phase approach for studying peregrine described in the study plan for American falcon and bald eagle. The first phase will peregrine falcon (Falco peregrinus anatum) obtain and evaluate the adequacy of existing and bald eagle (Haliaeetus leucocephalus), information which will be compiled in a which includes a review of existing technical memorandum. LCH will review information (first phase} followed by a the technical memorandum with agencies to determination as to whether or not surveys determine if the information is adequate to are necessary (second phase). The Applicant analyze and assess project effects. If has not provided the Department with any adequate information is not available, protocol level survey data for American protocol surveys will be performed. This

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response peregrine falcon and bald eagle within the approach to making a determination if the Project vicinity. second phase of the study is necessary includes consultation with the resource agencies. Nesting chronology for peregrine falcons and bald eagles is well documented in the literature and nesting success may vary from year to year due to many variables. A review of existing information may provide valuable information regarding the general success of a nest over a period of time. Existing information including anecdotal information may also provide a general sense of the sensitivity of the nesting birds to disturbances. 105 9/25/2014 CDFW R The Study Goal and Objective section on 8 Terrestrial The changes recommended by CDFW have page 1 of this study plan does not provide a (Wildlife) been included in TR-3, Wildlife Study Plan. complete list of wildlife resource issues associated with the Project. The Department recommends the following issues are added to this study plan: • The effects of Project construction, operation, and maintenance activities on nesting habitat and nesting success of special-status (i.e., State threatened, endangered, fully protected, and species of special concern) bird species. • The effects of Project construction, operation, and maintenance on raptors and special- status bird wintering use and foraging habitat. • The effects of Project facility noise on wildlife species. 35 October 17, 2014 Lake Clementine Hydroelectric Project, FERC No. 13432 ©2014, Lake Clementine Hydro, LLC Lake Clementine Hydroelectric Project, FERC No. 13432 Response to Comments on Study Plans

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response • The effects of powerhouse operations on wildlife species (i.e., electrocution). • The effects of transmission line construction and maintenance on wildlife habitat. • The effects of transmission line construction and maintenance on wildlife movement. • The effects of transmission line operations on all bird species (i.e., collision and electrocution). 106 9/25/2014 CDFW C Additionally, the Study Goal and Objective 8 Terrestrial The study objective has been changed to section on page 1 of this study plan states, (Wildlife) include Project maintenance. "The goal of this study is to...and assess the effects of Project construction and operations on those species present." This study should also consider the potential effects of future Project maintenance, not just construction and operation, on wildlife species. 107 9/25/2014 CDFW R The Study Area and Study Sites section on 9 Terrestrial The recommended changes have been made page 3 of this study plan states, "The study (Wildlife) to TR-3, Wildlife Study Plan. area will include a 0.5-mile zone around all Project facilities and areas used for construction, such as temporary lay down and staging areas and access roads." The Department recommends this section of the study plan be revised as follows (italics) to ensure the study area incorporates the maximum extent of the Project affected area: The study area will include a 0.5-mile radial zone around North Fork Dam, and all

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response proposed Project footprints, alignments, and alternatives for construction laydown and staging areas and access routes, road improvements, generation facilities, the powerhouse and substation, transmission line corridors, and all other areas in which ground-disturbing activities may occur as a result of the Project. 108 9/25/2014 CDFW R For clarity and to ensure the study area 9 Terrestrial The recommended changes have been made includes the maximum extent of Project (Wildlife) to TR-3, Wildlife Study Plan. effects plus a 500-ft buffer, the Department recommends the study area is described in the study plan as follows: The study area will include North Fork Dam, and all proposed Project footprints, alignments, and alternatives for construction laydown and staging areas and access routes, road improvements, generation facilities, the powerhouse and substation, transmission line corridors, and all other areas in which ground-disturbing activities may occur as a result of the Project, plus a 500-ft buffer. Additionally, the Department requests that surveys are conducted twice in the same year, once during the generally bird nesting season (March-August) and once during the winter (December-February) to capture seasonal use by different raptor species. 109 9/25/2014 CDFW R The Department appreciates the Applicant's 9–10 Terrestrial The recommended changes have been made incorporation of riparian bird surveys and (Wildlife) to TR-3, Wildlife Study Plan. nest monitoring in this study plan. For riparian bird surveys and nest monitoring the study area is described on page 7 of this study plan as: "This survey will focus

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response primarily on yellow warbler and yellow- breasted chat and any other special status species identified from the CWHR database as having high potential for occurring within 500 feet of the Project." For clarity and to ensure the study area includes the maximum extent of Project effects plus a 500-ft buffer, the Department recommends the study area is described in the study plan as follows: The study area will include suitable riparian habitat within 500 feet of North Fork Dam, and all proposed Project footprints, alignments, and alternatives for construction laydown and staging areas and access routes, road improvements, generation facilities, the powerhouse and substation, transmission line corridors, and all other areas in which ground-disturbing activities may occur as a result of the Project. 110 9/25/2014 CDFW R The Department appreciates the Applicant's 10 Terrestrial The recommended changes have been made incorporation of special-status bat surveys in (Wildlife) to TR-3, Wildlife Study Plan. this study plan. For special-status bats, the study area is described on page 8 of this study plan as: "all existing facilities (e.g., North Fork Dam, bridges, buildings, and other structures) located within the proposed footprint of all temporary and permanent Project features. For clarity and to ensure the study area includes all facilities within the maximum extent of Project effects, the Department recommends the study area is described in the study plan as follows: The study area will include all existing facilities that may be used by bats (e.g., North Fork Dam, bridges, buildings, and other

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response structures) within all proposed Project footprints, alignments, and alternatives for construction laydown and staging areas and access routes, road improvements, generation facilities, the powerhouse and substation, transmission line corridors, and all other areas in which ground-disturbing activities may occur as a result of the Project. 111 9/25/2014 CDFW R CDFW recommends developing and 15 Terrestrial TR-3, Wildlife Study Plan, incorporates conducting an American Peregrine Falcon (Wildlife) studies specific to peregrine falcon and bald Study Plan and Bald Eagle Study Plan. eagle so it is not necessary to provide separate study plans for these species. Threatened and Endangered Species 112 6/26/2014 CDFW R The agency notes that the Threatened and 5 T&E The Threatened and Endangered species Endangered Species section of the Applicant- section of the application and subsequent prepared Scoping Document does not NEPA document is reserved for discussion identify any resources and lists state of federally listed or candidate species. threatened and endangered species identified State-listed species are discussed in the in the CWHR database that should be sensitive species section. No federally listed included. species have been identified at this time. LCH will continue to consult with the USFWS regarding listed threatened and endangered species that may occur in the Project vicinity. RECREATION, LAND USE, AND AESTHETIC RESOURCES Recreation 113 7/1/2014 Auburn C Using the parking areas for staging areas 1 Recreation The study area for RR-1, Recreation Boat because the most likely location for staging Resources Study Plan, includes all areas that Club areas would be one of two parking lots, using could potentially be used for construction so these lots would cut-off public access to the potential effects can be identified. Measures lake, reduce annual revenues to State Parks will be developed and included in the

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response and reduce or eliminate fuel sales to the license application that would consider Auburn Boat Club. selecting the season and time of day for construction activities and locations of laydown areas to minimize effects on recreation activities. 114 7/1/2014 Auburn C A two-year construction period would 1 Recreation LCH proposes an 18-month construction Boat preclude safe public boating access at a time period and Study Plan RR-1 includes Club when the drought limits the availability of methodology to identify the recreational safe boating in the area; this is unacceptable. resources that could be potentially affected by Project construction. During the estimated 18 months of construction, there will be periods of time when little or no restriction on public access to the lake will exist. 115 7/1/2014 Auburn C The Project poses a public safety issue 1 Recreation Study Plan RR-1 will identify the Boat because the boat ramp is about 30 yards from recreational resources that could be Club the dam, and adjacent to the Project intake. potentially affected by Project construction This area is often congested and there is a and operation. Recognizing the intake would safety concern about the current that would alter the flow of water near the left be created by the intake (either canal or abutment, the design and location of the siphon). intake will take public safety into consideration. 116 7/1/2014 Auburn C Relocating the boat ramp is impractical 2 Recreation Study Plan RR-1 will identify the Boat because of steep topography (i.e., large recreational resources that could be affected Club amount of excavation to achieve necessary by Project construction and operation. If turning radii) and, if successful, would relocating the ramp is proposed, LCH would decrease the number of parking spaces. consider such effects and develop measures to mitigate Project effects. 117 7/1/2014 Auburn C Relocating the boat ramp would place it too 2 Recreation Study Plan RR-1 will identify the Boat close to the marina subjecting the marina and recreational resources that could be affected Club docked boats to damaging wave action. by Project construction and operation. If relocating the ramp is proposed, LCH would consider such effects and develop measures

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response to mitigate Project effects. 118 7/1/2014 Auburn C Drawing the reservoir down during 2 Recreation LCH has no plans to draw down Lake Boat construction would damage docks and any Clementine during construction. Because Club boats in the slips. Other effects may include LCH proposes to operate the Project as run- detached anchor lines and severed power and of-river where inflow would equal outflow fuel lines that could cause a fire. the Project will not affect the water surface elevation of Lake Clementine. 119 6/27/2014 CA C The Project can potentially affect recreational 2 Recreation Study Plan RR-1 includes all areas that Parks access near the dam and NFAR downstream could be used for construction so potential of the dam. Specific effects may relate to effects to all recreation resources can be angling, route and trail use, boat ramp use identified. This includes the area near the and safety. dam such as the access road, boat ramp, formal and informal trails, and the NFAR immediately downstream of the dam. 120 6/27/2014 CA R RR-1 should specifically study access to and 2 Recreation Study Plan RR-1 includes all areas that Parks use of the marina; access to trails; and access could be used for construction so potential to and use of the entire Lake, including all effects to all recreation resources can be types of boating on the Lake and the boat-in identified. This includes the area near the camping. dam such as the access road, boat ramp, formal and informal trails, and the NFAR immediately downstream of the dam. Study Plan RR-1 does not include any study of boating or boat-in camping on Lake Clementine because LCH proposes to operate the Project as run-of-river. Accordingly, the Project will not change the water surface or shoreline so Project operation would not change the quality or availability of boating and boat-in camping at Lake Clementine. 121 6/27/2014 CA R The study should analyze the potential 2 Recreation Study Plan RR-1 will identify the Parks impacts of any change in flow velocities recreational resources that could be affected around the diversion near the boat ramp on by Project construction and operation. 41 October 17, 2014 Lake Clementine Hydroelectric Project, FERC No. 13432 ©2014, Lake Clementine Hydro, LLC Lake Clementine Hydroelectric Project, FERC No. 13432 Response to Comments on Study Plans

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response all types of boat launching and recreation use Recognizing the intake would alter the flow at this site. of water near the left abutment, the design and location of the intake will take public safety into consideration. 122 6/27/2014 CA R The scope of RR-1 should include the 2 Recreation Study area for Study Plan RR-1 includes the Parks recreation use of the area immediately below area near the dam such as the access road, the dam and whatever length of river that will boat ramp, formal and informal trails, and be substantially de-watered by the Project, the NFAR immediately downstream of the the area from the base of the Dam to the dam. proposed outlet of the powerhouse/turbines. 123 6/27/2014 CA R RR-1 needs to include all areas potentially 2 Recreation Study Plan RR-1 includes all areas that Parks affected by construction and operation could be used for construction so potential including construction access routes and effects to all recreation resources can be staging areas. identified. This includes the area near the dam such as the access road, boat ramp, formal and informal trails, and the NFAR immediately downstream of the dam. 124 6/27/2014 CA R Because Project operation has the potential to 2 Recreation Under Project operation, water flowing into Parks alter water temperature downstream of the the NFAR would be water that is released dam State Parks requests expanding the study from the powerhouse, spilled over the dam area to include effects on swimming, wading or a combination of both. Water entering the and angling at the confluence of the NFAR intake would be drawn from the top of the and MFAR. reservoir, just as the water that spills over the dam is from the top of the reservoir. Although recreationists would not likely detect any water temperature change as a result of the redirected reservoir surface water, Study Plan RR-1 will review the results of the water temperature study to identify any expected change in water temperature in the NFAR immediately downstream of the dam. Because the Project does not affect the area in the vicinity of the confluence of NFAR and Middle Fork

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response American River LCH does not include it in the RR-1 study area. 125 6/27/2014 CA C Study plans and issues for this Project should 2–3 Recreation The WSR status of NFAR is presented in Parks acknowledge the outstandingly remarkable the PAD. LCH will incorporate specific values established for the NFAR segment information that CA Parks provides about eligible for WSR designation. Outstandingly Remarkable Values into the analysis of Project effects in the license application. 126 6/27/2014 CA R To the extent the Project impacts recreation 3 Recreation Study Plan RR-1 includes methodology to Parks use, concession operations, special events or collect information from sources including, other revenues sources, data need to be but not limited to, Auburn State Recreation collected about the revenues retained by CA Area and Auburn Boat Club. LCH will Parks for its use in defraying operation and modify the methodology to collect and maintenance costs sufficient to identify report economic data from these recreation specific impacts. providers. 127 6/27/2014 CA R The existing data that State Parks has for 3 Recreation LCH will modify the methodology in Study Parks ASRA is generalized and compiled recreation Plan RR-1 to include spot counts and use data, which does not identify specific activity observations in the study area to types and amounts of use by individual refine information about recreation activities recreation site or trail. State Parks does not and use patterns. believe that the existing data and information about recreation use in the areas potentially affected by the Project is of sufficient detail and specificity to identify and address all of the potential impacts of the Project on recreation use. The study plan should include collection of specific information, including surveys and counts that document the amount, types and patterns of recreation use on the NFAR below the Dam, the amount and type of use on the trails and roads potentially affected by the Project and the amount, type and patterns

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response of use on Lake Clementine. Collection of specific recreation data on the types, amounts and patterns of recreation use in the Project area is necessary to identify the potential impacts of the Project on recreation use and the magnitude of those impacts and to address the issue identified in the study plan. 128 6/26/2014 CDFW R The agency believes that using existing data 14 Recreation Study Plan RR-1 does not include any study to characterize recreational use is a good of reservoir angling because LCH proposes starting point, but may not provide all to operate the Project as run-of-river. necessary information regarding recreational Accordingly, the Project will not change the use in the Project-affected Area. For water surface, shoreline or access to the example, compiled historical data may not reservoir so Project operation would not contain recreational angling data in terms of change the quality or availability of angling the number of angler hours spent fishing at Lake Clementine. from a boat, the shore, or downstream of Study Plan RR-2 includes a methodology to North Fork Dam on the NFAR. CDFW assess recreation use downstream of the recommends the Applicant include a creel dam. Because the Project may reduce the census of Lake Clementine and the NFAR area available for recreation use downstream downstream of the dam in this study plan to of the dam, Study Plan RR-1 will determine obtain detailed information regarding angler the area affected. Additionally, LCH will activity in the Project vicinity. modify Study Plan RR-1 to include spot counts and observations that will provide information about angling use in terms of numbers of anglers and timing of their use to assess potential Project effects on angling use downstream of the dam. 129 9/25/2014 CDFW C CDFW appreciates the Applicant’s 10 Recreation No response is necessary. incorporation of our comments on RR-1, Recreation Resources Study Plan and concurs with the content of the most recent version of this study plan dated September 11, 2014.

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response 130 10/3/2014 State R The methodology should include conducting 1 Recreation The methodology in RR-1, Recreation Parks visitor surveys and counts in the Resources Study Plan, was revised to winter/spring. conduct visitor surveys and counts during all seasons. Land Use 131 6/27/2014 BOR C Intend to develop and execute 2 land use 1 Land Use LCH has filed its application to BOR for a authorizations: (1) for temporary right of permit to conduct Project-related studies. entry to conduct studies and (2) to construct, LCH recognizes it must also obtain a permit maintain, and operate the proposed Project. to operate and maintain the Project on BOR- administered public land. 132 6/27/2014 BOR C NFAR extending from Colfax-Iowa Bridge to 1 Land Use LCH recognizes the Wild and Scenic River upper end of Lake Clementine is eligible for status of the NFAR between Colfax-Iowa classification as a Wild and Scenic River. Bridge and the upstream end of Lake Accordingly, the proposed Project power Clementine. LCH will incorporate specific lines cannot interfere or degrade the information about the Outstandingly identified outstandingly remarkable values Remarkable Values of the NFAR segment for this river segment. into the analysis of Project effects that will be provided in the license application. The Project will be operated in a run-of- river mode and not affect the lake water surface. Therefore, Project construction or operation will not affect the reach above the upper end of the lake. Aesthetic Resources 133 5/30/2014 SWRCB R LCH should assess noise impacts associated 6 Aesthetic The aesthetics study plan will include with the Project on recreation within the Resources provisions for taking ambient noise Project area measurements at representative locations, including that associated with the spill over the North Fork Dam. 134 6/27/2014 CA C Under run-of-river operation, how the inflow 2 Aesthetic Operating the Project as run-of-river will not Parks will be monitored or measured (in real time) Resources cause the reservoir to fluctuate. Measures to

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response to ensure the diversion does not exceed the determine Project compliance will be inflow and what if any variance from the developed and presented in the license inflow amount would be proposed or application. permitted as part of the Project operation? A better understanding of this element of the Project would help inform whether additional specific data is needed regarding the recreation uses on Lake Clementine and the potential visual impacts of the Project on the Lake. The potential for greater fluctuation of Lake Clementine than the current condition due to the Project is a key concern for State Parks. 135 6/27/2014 CA R Aesthetic study plan implementation needs to 4 Aesthetic The visual simulations will be based on the Parks be delayed until design and location of Resources current designs of the Project infrastructure. Project features are finalized or there is some The major structures of the Project have way to account for the uncertainty. been largely defined. Further design changes will have less effect on visual resources. 136 6/27/2014 CA C Locating the transmission lines as close as 4 Aesthetic At this time a single route has not been Parks possible to the alignment of the existing Resources determined. Studies will be performed on power lines across the canyon downstream of each alternative unless, and until a single the Dam would minimize the additional route is determined. visual impact of transmission lines crossing the canyon in another location. 137 6/27/2014 CA R Studies should identify the impacts of Project 4 Aesthetic Study Plan RR-2 includes methodology to Parks infrastructure on the scenic view of the dam Resources produce visual simulations by combining and spill over the dam. site photography with accurate, rendered computer models of Project facilities to predict what would be seen if the proposed Project were constructed and operated. Views of the flow over North Fork Dam will be videotaped from one KOP at different flow rates.

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response 138 6/27/2014 CA R Project operation would reduce the volume of 4 Aesthetic Views of the flow over North Fork Dam will Parks flow over the spillway and seasonal Resources be videotaped from one KOP at different variability of flows. This would, potentially flow rates. To report potential effects related change the look and feel of the water falling to seasonality LCH will modify RR-2 to 113over the dam. include methodology that would report the average monthly flows over the dam that would exist with and without the Project in wet, normal, and dry water year types based on the historical hydrological record. 139 6/27/2014 CA R Project lighting may affect the visual quality 4 Aesthetic LCH will modify RR-2 to include visual Parks of the area and impact wildlife. Resources simulations of Project lighting from key observation points. These simulations will also provide information for wildlife impacts. 140 6/27/2014 CA R An issue not identified in the study plan, but 4 Aesthetic LCH will modify RR-2 to include reporting Parks which needs study, is the potential noise Resources the estimated level and timing of noise impacts of the Project construction and associated with operating the Project operation. What are the potential noise infrastructure. impacts of the operation of the turbines and what mitigation measures can eliminate or reduce these impacts? 141 6/27/2014 CA R State Parks is generally supportive of the 4–5 Aesthetic LCH will modify Study Plan RR-2 to Parks proposed methods in the aesthetics study plan Resources include a total of 6 target flows with a goal but questions whether selecting only three of having 3 of the 6 target flows in the range different flows on which to get public input is of 50 to 500 cfs. sufficient to gather the necessary information to determine minimum flows to be retained over the dam. Because there could be significant differences in the appearance of the flows at the lower end of this range (say between 50, 100 and 500 cfs) and establishing a minimum acceptable spill flow will be a critical issue, State Parks

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response recommends the study plan include assessing more than three flow levels over the Dam and that these flows are documented in different lighting conditions. Other than the minimum acceptable spill flow over the dam, a separate issue will be the loss in the variability of the flows over the dam, which like a waterfall is part of the ongoing visual attraction and interest of this scenic feature. 142 9/26/2014 CA R Collecting information at three flows in the 1 Aesthetic The study will collect data at three flows in Parks low end of the median flow range may not be Resources the low end (50 to 500 cfs) of the median sufficient. The Applicant should make sure flow range which is an appropriate data for the low end of the median flow range representation of the lower flows. The study is well represented because the differences plan has also been revised to include could be important in establishing a collecting data at flows less than 50 cfs, if minimum acceptable flow. such flow exists during the study period. 143 9/26/2014 CA R The goal of the visual and aesthetic study 1 Aesthetic Although CA Parks’ suggestion could refine Parks plan should assess the project impact on Resources the flows that would be assessed during this visual quality of flows throughout the year. study, the study methodology includes a The study should include a process for wide enough range of flows to be determining target flows or range of flows in representative of the range of flows that the mid- and high-end flows to assess in the would be of concern during proposed study. Project operation. 144 9/26/2014 CA C/R Does the Project flatten out the variability in 2 Aesthetic The hydrology data for the period of record Parks the range of flows over the dam? In drier Resources will be developed as part of WR-2, Water years does the Project take out the normal Quantity Study Plan. This information will peaks in flows over the dam that would be used to characterize the effect of Project otherwise occur? It would be nice to retain operation on the timing and magnitude of some of the variability of flow over the dam. flows over the dam.

Date of Resource No. Letter Entity Type Description Page Area Rationale/Response 145 9/25/2014 CDFW R The Applicant should choose at least one set 11 Aesthetic Specific target flows are not identified in the of calibration flows that are lower than 50 Resources study plan because the flows cannot be cfs. Additionally, the lowest flow observable controlled. However, the study plan has during the summer sampling season should been revised to state that the study will be measured and recorded during this study. include six flows with three of the six flows being in the range of 50 (or lower, if such flows occur during the study period) to 500 cfs. The study plan was not modified to include the lowest flow observable during the sampling season because there is no way to predict when this would happen. Including this recommendation in the study plan would require LCH to guess on any given day whether the existing flow is the lowest flow that will occur for the year. If the flow decreases further, LCH would need to collect another set of data. This could happen over and over again throughout the study period and the cost would be unwarranted because the study plan, as written, will collect information over the appropriate range of flows. Notes: C – Comment, R – Recommendation Acronyms: BOR – Bureau of Reclamation, CA Parks – California Department of Parks and Recreation, cm – centimeter(s), cfs – cubic feet per second, CDFA – California Department of Food and Agriculture, CDFW – California Department of Fish and Wildlife, CNDDB – California Natural Diversity Database, CNPS – California Native Plant Society, CRLF – California red-legged frog, CWHR Database – California Wildlife Habitat Relationships Database, DO – dissolved oxygen, FERC – Federal Energy Regulatory Commission, ft – foot/feet, in. – inch/inches, FYLF – foothill yellow-legged frog, LCH – Lake Clementine Hydro, LLC, LWD – large woody debris, mi – mile(s), NFAR – North Fork American River, NMFS – National Marine Fisheries Service, PAD – Preliminary Application Document, PCWA – Placer County Water Agency, PM&E – protection, mitigation, and enhancement, KOP – key observation point, SWRCB – State Water Resources Control Board, USACE – U.S. Army Corps of Engineers, WSR – Wild and Scenic River

Comments on Study Plans from California Department of Parks and Recreation

Efird, Carol

From: Jim Holeman Sent: Friday, September 26, 2014 9:09 AM To: Efird, Carol Cc: 'Parker, Daniel'; 'America Renewables' Subject: FW: Visual and Aesthetics Study Plan

Carol:

Here are comments received from State Parks.

Jim

From: Micheaels, Jim@Parks [mailto:[email protected]] Sent: Thursday, September 25, 2014 5:10 PM To: [email protected]; [email protected]; [email protected] Cc: Hoobler, Sean@Wildlife; Lawson, Beth@Wildlife; Ewing, Anna@Wildlife; Thaler, Parker@Waterboards; Willy, Alison; [email protected]; [email protected]; [email protected]; [email protected]; Schneider, Michael K.@Parks; Hood, Roger@Parks; Preston, Rich@Parks Subject: Visual and Aesthetics Study Plan

Hello All –

I do not have time to put together a formal letter, but I did have a few additional thoughts on the Visual and Aesthetics Study Plan, specifically regarding the range of flows that should be videotaped and photographed to assess the potential visual impacts of the project on the flows over the Dam. Comments on this plan are due today, so I am sending them via this e‐mail. I reviewed the revised Study Plan and I read and appreciated the CDFW comments on this study plan in their letter submitted today. I believe many of the suggestions State Parks made in our 6/27/14 letter regarding the previous version of this study plan have been incorporated into the plan. The revised plan indicates the flow over the Dam will be recorded at six different flow rates, with three of the six in the 50 to 500 cfs range.

In order to be able to determine an acceptable minimum flow over the Dam, as the Plans indicates, there should be a number of flows recorded and photographed which focus on the lower end of the range of flows including possibly one below 50 cfs as CDFW suggests. I don’t know if looking at three different flows at the low end of the flow range is sufficient. It might be – I just don’t know if the visual differences are important between say ‐ 25, 50, 100, 250 and 500 cfs. It doesn’t seem particularly burdensome to capture flows with video and camera – I would make sure the range of flows recorded at the low end of the range is well represented because the differences could be important in establishing a minimum acceptable flow.

Also ‐ as we indicated in our 6/27/14 letter, like a waterfall, part of the attraction of the spill over the Dam is the variability of the flows throughout the year. The goal of the visual and aesthetic study plan shouldn’t just be to determine a minimum acceptable flow, but to assess the project impact on the visual quality of flows throughout the year. In addition to focusing on the lower end of the range in order to determine a minimum acceptable flow ‐ a process to determine the number and volume of other flows that should be recorded and assessed might be to look at the period during which the project will operate (October‐June?), look at the range of flows in this period from the historic record, look at the amount of water the project would divert from the spill over the Dam during this period, and to try to target flows or the range of flows where the volume diverted is likely to impact the visual quality of the balance flowing over the Dam. Looking at these various values might help in targeting the mid and higher flows to record and assess for visual impact.

At really high flows (which may or may not happen this winter), the project effect in diverting water from the flow over the Dam might be not be so much since the max amount diverted might be a relatively small percentage of the total flow. At this upper end of the flow range ‐ I don’t know what that critical point is where the % of the total flow diverted is negligible with regards to visual impact.

Does the project flatten out the variability in the range of flows over the Dam? In drier years does the project take out the normal peaks in flows over the Dam that would otherwise occur?

It would be nice if the some of the variability in flows over the Dam could be preserved.

Jm.

Jim Micheaels CA State Parks, Gold Fields District 7806 Folsom‐Auburn Road Folsom, CA 95630 (916) 988‐0513 ‐ office (916) 988‐9062 – fax [email protected]

2 Efird, Carol

From: Micheaels, Jim@Parks Sent: Friday, October 03, 2014 4:56 PM To: Jim Holeman; [email protected]; [email protected]; [email protected]; Willy, Alison; Ewing, Anna@Wildlife; [email protected]; Lawson, Beth@Wildlife; Joe Forbis; Thaler, Parker@Waterboards; Hoobler, Sean@Wildlife; Stephen Bowes; William Foster Cc: 'Parker, Daniel'; 'America Renewables'; Efird, Carol Subject: RE: LCH - Study Plans

Jim –

I have reviewed the revised Recreation Study Plan. It looks like most of the changes requested in our 6/27/14 letter have been incorporated into this plan.

My one comment is the plan indicates visitor surveys and spot counts will be conducted from May to October, which is a good time to capture the most recreation use. However, my understanding is that the project would likely operate primarily from October through June – when there is sufficient water. There are no doubt fewer recreation users in winter, but are there different types of recreation use in winter and spring? Should some surveys/counts also be conducted in winter/spring which would be the primary operating period for the proposed project?

Thanks, jm.

Jim Micheaels CA State Parks, Gold Fields District 7806 Folsom‐Auburn Road Folsom, CA 95630 (916) 988‐0513 ‐ office (916) 988‐9062 – fax [email protected]

From: Jim Holeman [mailto:[email protected]] Sent: Tuesday, September 16, 2014 4:13 PM To: [email protected]; [email protected]; [email protected]; Willy, Alison; Ewing, Anna@Wildlife; [email protected]; Lawson, Beth@Wildlife; Micheaels, Jim@Parks; Joe Forbis; Thaler, Parker@Waterboards; Hoobler, Sean@Wildlife; Stephen Bowes; William Foster Cc: 'Parker, Daniel'; 'America Renewables'; 'Efird, Carol' Subject: LCH - Study Plans

To Agencies:

The remaining redline version of study plans are ready for your review. As stated in my earlier message to you, we would appreciate any comments by October 3. As explained we would appreciate it is you would only comment if there are major omissions that would affect your ability to assess project effects.

Thank you again for your comments and participation. 1

Jim 415‐826‐8123