Additional Information Requested by the Commission

Dan L. Ross O&M/Professional Services P.O. Box 968, MD 1030 Richland, WA 99352-0968 Ph. 509.377.8581 | F. 509.372.5078 [email protected]

June 5, 2008 PKWD-08-033

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

Dear Ms. Bose:

Subject: PACKWOOD LAKE HYDROELECTRIC PROJECT FERC DOCKET NO. P-2244-022 REQUEST FOR ADDITIONAL INFORMATION FOR PROJECT RELICENSING

Energy Northwest, Licensee of the Packwood Lake Hydroelectric Project (Project), herewith files our responses to the Commission’s Request for Additional Information (AIR), issued April 8, 2008, regarding the relicensing of the Project. With this cover letter are copies of our response in two volumes, one of which contains public information (Vol.I), and one of which contains Critical Energy Infrastructure Information (CEII) (Vol.II). An Original and two paper copies, together with nine CD copies of Volume I and three CD copies of Volume II are included in this filing.

Volume I contains only public materials. They include this cover letter and the main response document, together with the following Attachments:

Attachment 1 – Revised excerpt of Exhibit A of the Final Application for New License Attachment 2 – Revised Exhibits G-2 and G-8 of the Final Application for New License Attachment 3 – Debris Screen Conceptual Drawings Attachment 4 – Tailrace Water Temperature Monitoring and Enhancement Plan Attachment 5 – Avian Protection Plan Attachment 6 – Integrated Weed Management Plan Attachment 7 – Rare Plant Management Plan Attachment 8 – Packwood Lake Recreation Plan Attachment 9 – Long Range Estimate of Capital Expenditures Ms. Bose Page 2 of 3 June 5, 2008 PACKWOOD LAKE HYDROELECTRIC PROJECT FERC DOCKET NO. P-2244-022 REQUEST FOR ADDITIONAL INFORMATION FOR PROJECT RELICENSING

In addition to the responses described above, the following documents requested in the AIR are also being submitted this date, in Volume II, as they contain Critical Energy Infrastructure Information (CEII).

Attachment 10 – Stability Evaluation Report Attachment 11 – Revised Single Line Diagram Attachment 12 – Revised Exhibit F Drawings

Enclosed are three CDs with the electronic TIF files of the revised Exhibit F and G drawings and three CDs with the revised ArcView GIS shapefiles of the project boundary and federal lands.

We are also providing a paper copy and a CD copy of the AIR, including the full size revised Exhibit G and F maps and drawings, to the FERC Portland Regional Office. A copy of the public Volume I on CD is being provided to each party on the attached distribution list, and Energy Northwest will provide paper copies upon request. In addition, Energy Northwest will post Volume I of the AIR on its relicensing website at: http://www.energy-northwest.com/generation/packwood/relicensing/ferc_filings.php

We believe this filing provides all of the additional information requested by the Commission. Please contact me at (509) 377-8581 if you have any questions.

Respectfully,

Dan Ross Packwood Project Manager cc: Distribution List

Enclosures: Original and two paper copies of each volume of the AIR, including full size revised sheets of project exhibit maps and drawings Nine copies of Volume I on CD Three copies of Volumes II on CD (CEII) Three copies of Exhibit F in TIF format on CD (CEII) Three copies of Exhibit G in TIF format on CD Ms. Bose Page 3 of 3 June 5, 2008 PACKWOOD LAKE HYDROELECTRIC PROJECT FERC DOCKET NO. P-2244-022 REQUEST FOR ADDITIONAL INFORMATION FOR PROJECT RELICENSING

Three copies of Exhibit G ArcView Shapefiles on CD DISTRIBUTION LIST FOR ADDITIONAL INFORMATION REQUEST DATED APRIL 8, 2008

Secretary Mr. Blane Bellerud Federal Energy Regulatory Commission National Marine Fisheries Service 888 First Street, N.E. 1201 Lloyd Boulevard, Suite 1100 Washington, DC 20426 Portland, OR 97232

Mr. Ken Hogan Mr. Keith Kirkendall Federal Energy Regulatory Commission National Marine Fisheries Service 888 First Street, N.E. Hydropower Division Washington, DC 20426 1201 Lloyd Boulevard, Suite 1100 Portland, OR 97232 Mr. Timothy Looney Federal Energy Regulatory Commission Mr. Bryan Nordlund 888 First Street, N.E. National Marine Fisheries Service Washington, DC 20426 510 Desmond Drive SE, Suite 103 Lacey, WA 98503 Federal Energy Regulatory Commission Portland Regional Office Chris Fontecchio, GCNW 805 SW Broadway National Oceanic Atmospheric Administration Fox Tower - Suite 550 National Marine Fisheries Service Portland, OR 97205 7600 Sand Point Way, NE Seattle, WA 98115-0070 Mr. Brian Peck U.S. Fish & Wildlife Service Mr. Mike Gerdes 510 Desmond Dr., S.E., Suite 102 US Forest Service Lacey, WA 98503 3160 NE 3rd St Prineville, OR 97754 Mr. Ken Berg U.S. Fish & Wildlife Service Mr. Rick McClure 510 Desmond Dr., S.E. US Forest Service Lacey, WA 98503 Gifford Pinchot National Forest 2455 Highway 141 Mr. Tim Romanski Trout Lake, WA 98650 U.S. Fish & Wildlife Service 510 Desmond Dr., S.E. Ms. Ruth Tracy Lacey, WA 98503 US Forest Service Gifford Pinchot National Forest U.S. Fish & Wildlife Service 10600 NE 51st Circle Regional Office Vancouver, WA 98682 Attn: FERC Coordinator 911 NE 11th Ave Ms. Margaret Beilharz Portland, OR 97232-4169 US Forest Service 57600 McKenzee Hwy McKenzee Bridge, OR 97413

1 Environmental Project Agency Mr. Ken Wieman Region 10 US Forest Service 1200 Sixth Avenue Gifford Pinchot National Forest Seattle, WA 98101 10600 NE 51st Circle Vancouver, WA 98682 Federal Emergency Management Agency Regional Office Ms. Danna Hadley 130 228th Street, SW US Forest Service Bothell, WA 98021 10024 Hwy 12 P.O. Box 670 US Army Corps of Engineers Randle, WA 98377 State District Office Regulatory Branch/Permits Ms. Kristie Miller PO Box 3755 Cowlitz Valley Ranger District Office Seattle, WA 98124-3755 US Forest Service 10024 Hwy 12 US Army Corps of Engineers P.O. Box 670 Divisional Office Randle, WA 98377 Regulatory Branch PO Box 2946 Ms. Diane Bedell Portland, OR 97208-2946 Cowlitz Valley Ranger District Office US Forest Service Bureau of Indian Affairs 10024 Hwy 12 Northwest Regional Office P.O. Box 670 911 NE 11th Avenue Randle, WA 98377 Portland, OR 97232

Mr. Jack Thorne Bureau of Land Management US Forest Service Spokane District Office 10024 Hwy 12 1103 N. Fancher P.O. Box 670 Spokane, WA 99212-1275 Randle, WA 98377 Ms. Susan Rosebrough Mr. Tom Kogut National Park Service US Forest Service 909 First Avenue 10024 Hwy 12 Seattle, WA 98104 P.O. Box 670 Randle, WA 98377 Mount Rainier National Park Star Route, Tahoma Woods Mr. Walt Dortch Ashford, Washington 98304 US Forest Service Darrington Ranger District Department of Interior 1405 Emens St. Bureau of Reclamation Darrington, WA 98241-9502 Regional Office 1150 North Curtis Road, Suite 100 Boise, ID 83706-1234

2 Mr. James Miernyk Northwest Power Planning Office Washington Utilities and Transportation 851 SW Sixth Avenue, Suite 1100 PO Box 47250 Portland, OR 97204 Olympia, WA 98504-7250

Mr. Mark Hunter SEPA Center Washington Department of Fish and Wildlife Washington Dept of Natural Resources 600 Capital Way North PO Box 47015 Olympia, WA 98501 Olympia, WA 98504-7015

Mr. Hal Beecher Dr. Allyson Brooks Washington Department of Fish & Wildlife State Historic Preservation Officer 600 Capital Way North Washington Department of Archaeology and Olympia, WA 98501 Historic Preservation PO Box 48343 Mr. Brad Caldwell Olympia, WA 98504-8343 Washington Department of Ecology PO Box 47600 Mr. William C. Frymire, Senior Counsel Olympia, WA 98504 Assistant Attorney General Office of the Attorney General Ms. Deborah Cornett Fish, Wildlife and Parks Division Washington Department of Ecology P.O. Box 40100 PO Box 47600 Olympia, WA 98504-0100 Olympia, WA 98504-7600 Environmental Programs Manager Eric Schlorff Washington State Parks & Recreation Water Quality Program Commission Department of Ecology P.O. Box 42668 PO Box 47775 Olympia, WA 98504 Olympia, WA 98504-7775 Mr. Jim Eychaner Mr. Kelly Susewind Washington State Recreation and Department of Ecology Conservation Office PO Box 47600 P.O. Box 40917 Olympia, WA 98504-7600 Olympia, WA 98504-0917

SW Regional Director Mr. Eric Johnson, Commissioner Washington Department of Ecology Lewis County PO Box 47775 351 NW North Street Olympia, WA 98504-7775 Chehalis, WA 98532

State of Washington Director Department of Agriculture Lewis County Planning Department PO Box 42560 351 NW North Street Olympia, WA 98504-0001 Chehalis, WA 98532

3 Mr. Mike Iyall Ms. Kathy Dubé, R.G Cowlitz Tribe Watershed GeoDynamics 1215 SE Hall 14145 97th Ave NE Lacey, WA 98503 Bothell, WA 98011

Mr. Taylor Aalvik Mr. Stephen Nyman Cowlitz Tribe Devine Tarbell & Associates PO Box 2547 1111 N. Forest St. Longview, WA 98632 Bellingham, WA 98225

Mr. George Lee Ms. Katy Beck Confederated Tribes and Bands Beck Botanical of the Yakama Nation 1708 McKenzie Ave. PO Box 151 Bellingham, WA 98225 Toppenish, WA 98948 Ms. Gail Thompson Ms. Andrea Spencer Historical Research Associates Confederated Tribes and Bands 1904 Third Avenue, Suite 240 of the Yakama Nation Seattle, WA 98101 PO Box 151 Toppenish, WA 98948 Packwood Timberland Library PO Box 589 Mr. Carroll Palmer Packwood, WA 98361-0589 Confederated Tribes and Bands of the Yakama Nation Goat Rocks Homeowners Association PO Box 151 ATTN: Don Barto Toppenish, WA 98948 159 Tatoosh U Drive Packwood, WA 98361 Mr. Clifford Casseseka Destination Packwood Confederated Tribes and Bands P.O. Box 64 of the Yakama Nation Packwood, WA 98361-0064 PO Box 151 Toppenish, WA 98948 Packwood Improvement Club Attn: Mr. Steve McVicker Mr. Clarence Holford P.O. Box 111 Bureau of Indian Affairs Packwood, WA 98361 Yakama Agency PO Box 632 Mr. John Squires Toppenish, WA 98948-0632 CPR Fish PO Box 801 Mr. John Blum Packwood, WA 98361 EES Consulting, Inc. 1155 N State Street, Suite 700 Bellingham, WA 98225

4 Mr. Mike Kohn Mr. Mark G. LaRiviere Lewis County PUD Tacoma Power PO Box AJ 3628 South 35th Street Morton, WA 98356 Tacoma, WA 98409-3192

Mr. Thomas O’Keefe Ms. Kim Moore PNW Stewardship Director Snohomish PUD American Whitewater P.O. Box 1107 3537 NE 87th St. Everett, WA 98206 Seattle, WA 98115 Lower Columbia Fish Recovery Board 2127 8th Avenue Longview, WA 98632

5 RESPONSE TO FERC’S REQUEST FOR ADDITIONAL INFORMATION DATED APRIL 8, 2008

PACKWOOD LAKE HYDROELECTRIC PROJECT FERC NO. 2244

ENERGY NORTHWEST RICHLAND, WASHINGTON

JUNE 2008

VOLUME I (PUBLIC)

RESPONSE TO FERC’S REQUEST FOR ADDITIONAL INFORMATION DATED APRIL 8, 2008

Table of Contents

Volume I (Public) 1. Project Boundary...... 1 2. Supporting Design Report...... 3 3. Single-Line Electric Diagram...... 4 4. Exhibit F Drawings ...... 4 6. Tailrace Water Temperature Monitoring and Enhancement Plan ...... 5 7. Avian Protection Plan...... 6 8. Integrated Weed Management Plan...... 7 9. Rare Plant Management Plan ...... 8 10. Recreation Plan...... 9 11. Project Economics, Clarification of Costs, Benefits, and Income...... 11

List of Attachments Attachment 1 – Revised excerpt of Exhibit A of the Final Application for New License Attachment 2 – Revised Exhibits G-2 and G-8 of the Final Application for New License Attachment 3 – Debris Screen Conceptual Drawings Attachment 4 – Tailrace Water Temperature Monitoring and Enhancement Plan Attachment 5 – Avian Protection Plan Attachment 6 – Integrated Weed Management Plan Attachment 7 – Rare Plant Management Plan Attachment 8 – Packwood Lake Recreation Plan Attachment 9 – Long Range Estimate of Capital Expenditures

Volume II (Critical Energy Infrastructure Information) Attachment 10 – Stability Evaluation Report Attachment 11 – Revised Single Line Diagram Attachment 12 – Revised Exhibit F Drawings

June 2008 i

Response to FERC’s Request for Additional Information Dated April 8, 2008

The following responses address the questions and requests in the Commission’s Request for Additional Information (AIR). Excerpts of the AIR are provided for convenience, followed by Energy Northwest’s (EN) responses in bold type. The AIR requested that Energy Northwest file the following completed resource management plans, which were originally proposed to be developed in consultation with the resource agencies after the issuance of a new Project license.

1. Tailrace Water Temperature Monitoring and Enhancement Plan 2. Avian Protection Plan 3. Integrated Weed Management Plan 4. Rare and Sensitive Species Management Plan 5. Recreation Plan

Because the time for development of the plans was very abbreviated, the resource agencies were consulted, and the Forest Service assisted in drafting the Recreation, Integrated Weed and Rare Plant plans, but Energy Northwest was unable to provide the usual comment period or to obtain agency approval of these plans. If significant changes are requested, it may be necessary to revise and refile these plans after license issuance.

______FERC Request:

1. Project Boundary

As part of our review of the project boundary as provided in Exhibit G of your Final License Application (FLA) and in ArcView GIS shapefiles we need to resolve several apparent inconsistencies and changes from previous boundary submittals as follows:

a) We have processed the ArcView GIS shapefiles of the project boundary, federal lands, and reference points submitted with your FLA on February 22, 2008. Within the project boundary, we computed the area of the Goat Rock Wilderness Area as 18.16 acres and the acreage associated with the Gifford Pinchot National Forest as 497.86 acres resulting in a total of 516.02 acres of federal lands. On page A-1 of your FLA you state the total acreage of federal lands to be 503.25 acres. Please either correct the boundary in your shapefiles or revise your Exhibit A (and any other sections dealing with project boundary such as Exhibit G) so that they are consistent and accurate. Please provide a written explanation for any corrections made. b) In the course of processing the ArcView GIS shapefiles, we compute the total acreage of project lands as 548.52 acres. On page A-1 of your FLA you indicate that project lands encompass 539.23 acres (which you round to 540 acres). Please either correct the boundary in your shapefiles or revise your Exhibit A (and any other sections dealing with project boundary such as Exhibit G) so that they are consistent and accurate. Please provide a written explanation for any corrections made.

June 2008 1 Energy Northwest’s Response to FERC’s Request for Additional Information

c) In reviewing the ArcView GIS shapefiles, we note apparent changes from your project boundary maps filed on November 22, 2004. There are noticeable differences of the project boundary (2,860-foot contour) around Packwood Lake between the November 2004 Exhibit G maps and the boundary depicted in Exhibit G of your FLA and the supporting shapefiles submitted in February 2008. Please rectify and provide an explanation for these differences. If over the course of making your review, the area of previously submitted acreages (such as the federal lands, state of Washington lands, Energy Northwest lands) changes, please correct your license application exhibits accordingly.

EN Response:

Based on this AIR request, the Project acreage has been replotted. The USDA Forest Service was consulted regarding the wilderness boundary. Gifford Pinchot National Forest staff provided a legal description of the Goat Rocks Wilderness Area. The Forest Service considers the ordinary high water level as the boundary for the wilderness area. The Packwood Lake Hydroelectric Project was already licensed before the wilderness area was initially established and was operating for 20 years before the wilderness was expanded to include the Lake. During Energy Northwest’s consultation with the Forest Service on this issue, it was agreed to use an elevation of 2858.5 ft MSL as the ordinary high water level, as this relates to the top elevation of the drop structure of the Project, the hydraulic control of the lake since 1964. The federal lands layer was revised to reflect this, as well as a slight change of the boundary line, which should follow a drainage basin instead of a section line in T13N, R10E, Section 28. Currently, the revised federal lands GIS layer calculates the acreage at 9.79 acres for the Goat Rocks Wilderness, and 501.86 acres for the Gifford Pinchot National Forest system lands; for a total of 511.65 acres. Text in Exhibit A has been revised, as well as Exhibit G-2, the Project boundary map that shows the wilderness area (see attachments 1 and 2).

The Project boundary for the Packwood Lake Hydroelectric Project is based on a combination of metes and bounds and an elevation contour level of 2860 ft around Packwood Lake. To create the electronic files of the Project boundary, the surveyor notes from the original Exhibit K drawings were used to digitize in the metes-and-bounds portion of the Project, which includes the area from the intake canal at the outlet of the Lake down to the lower end of the Project at the tailrace, and the transmission line. The Project boundary map of the area around Packwood Lake that was submitted in the Pre-Application Document (PAD) had been digitized using a USGS topographical map. We realized that using the USGS map was not the most accurate method to obtain the 2860 ft contour elevation, and the Project boundary around Packwood Lake was replotted between the November 22, 2004 filing of the PAD and the filing of the Final License Application (FLA) in February 2008 as follows. During the Packwood Lake Drawdown Study that was conducted for relicensing, one-foot contours

June 2008 1 Energy Northwest’s Response to FERC’s Request for Additional Information were developed for the Lake between the elevations of 2849 ft and 2859 ft MSL, based on GPS transects. The Project boundary is at elev. 2860 ft MSL. For the map that was filed in the FLA, the boundary around the Lake was drawn just outside of the 2859 ft contour that was developed for the Drawdown Study.

In response to this AIR, Energy Northwest used a digital elevation matrix (DEM) to create contours around Packwood Lake. A contour for elevation 2860 ft was digitally developed in this way. Using this digitally generated contour line, the Project boundary around Packwood Lake was then replotted. We believed that this is the most accurate method to delineate the Project boundary contour. it is readily noticeable, however, that the 2860 ft contour line generated by this method is somewhat different from the contour shown on the original Exhibit K. Most notable is the upper end of Packwood Lake between the confluences of Upper Lake Creek and Muller Creek. The original Project boundary shows a wavy pattern along this stretch of the lake, while the GIS-generated layer shows a straighter line. Calculating the acreage using the more accurate 2860 ft GIS contour resulted in a slightly larger number of acres than was previously calculated. Based on the revision described here, the GIS calculated the Project acreage as a total of 545.6 acres. Text in Exhibit A has been revised to match this total (See the revised excerpt of Exhibit A in Attachment 1).

FERC Request:

d) We need an accurate depiction of the bearings associated with the boundary. It appears that there are two angle points labeled T-4 and that bearings for T-4 through T-4’, and bearings for lines between T-4’ through T-8 as shown on Exhibit G-8 of your FLA are not provided. Please provide a revised Exhibit G-8 that includes the missing bearings, and include the electronic files required in Section 4.41(h) of the Commission’s regulations.

EN Response:

There were two points labeled T4 and they have been edited to be T4 and T5. The survey data for the Points T4 through T8 (now T5 through T9) were inadvertently left off Exhibit G-8. Below are the missing data. This data has been added to Exhibit G-8, which is submitted as Attachment 2 with these responses to the Commission’s Additional Information Request.

SURVEY DATA Traverse Points Distance Bearing T5 - T6 70.00 S54°11'43"E T6 - T7 208.00 S54°11'43"E T7 - T8 314.00 N35°49'36"E T8 - T9 208.00 N54°11'43"W

June 2008 2 Energy Northwest’s Response to FERC’s Request for Additional Information

FERC Request:

e) Please clarify whether the 1.52 acres associated with the Lewis County PUD substation are included or not included in your project boundary (as mentioned on page A-1 of your FLA).

EN Response:

Yes, the 1.52 acres associated with the Lewis County PUD substation are included in the project boundary.

FERC Request:

f) Please also clarify whether the transmission line acreage associated with Highway 12 is included or excluded from the 15.04 acres of Washington State lands.

EN Response:

The acreage for the Washington State lands within the project boundary has been adjusted to 8.78 acres. This includes the transmission line acreage associated with Highway 12.

FERC Request:

2. Supporting Design Report

In volume 5 of your FLA, Supporting Design Report you referenced studies that may now be out of date (initial design studies). Additionally, neither supporting material from the original design phase nor the updated stability analyses were provided.

So that we may fully understand the dam safety aspects of your project, please provide a report that includes stability and stress analyses for all major structures and critical abutment slopes under all probable loading conditions, including seismic and hydrostatic forces, and that reflects the current FERC Engineering Guidelines for the Evaluation of Hydropower Projects. Note that the inflow design flood may have changed for the Packwood Lake drainage basin. If the new inflow design flood estimates are higher than the original estimates, please incorporate a revised inflow design flood study and related stability analyses. For your reference, the FERC Engineering Guidelines may be accessed at: http://www.ferc.gov/industries/hydropower/safety/guidelines/eng-guide.asp.

EN Response:

In response to this request, Energy Northwest conducted a stability analysis for the major structures and critical abutment slopes of the Project. The resulting Stability Evaluation report is being provided separately as Attachment 10 in

June 2008 3 Energy Northwest’s Response to FERC’s Request for Additional Information

Volume II of this response since it contains information that should be considered Critical Energy Infrastructure Information (CEII). Energy Northwest has provided copies of the report to the Portland Regional Engineer in addition to this filing.

FERC Request:

3. Single-Line Electric Diagram

While you provided a single-line electric diagram on page H-7 of your FLA it is not sufficiently detailed. Please provide a detailed single-line diagram that includes existing system facilities identified by name and circuit number and shows system transmission elements in relation to the project and other principal interconnected system elements. Power flow and loss data that represent system operating conditions may be appended if you determine such data would be useful to show that the operating impacts described would be beneficial.

EN Response:

A new detailed single line diagram is being filed. It is considered CEII and is being filed under separate cover as Attachment 11 in Volume II of this response with other CEII materials.

FERC Request:

4. Exhibit F Drawings

Exhibit F drawings do not meet our needs for engineering review because Exhibit F-1 does not include adequate sections and a profile through the inlet canal or adequate sections through the impervious earth-fill cutoff walls. Please revise Exhibit F-1 or add additional exhibits to address these concerns.

Exhibit F-1 has been revised to incorporate the sections and profile of the inlet canal. It is now on two sheets: Exhibit F-1.1 and Exhibit F-1.2. These drawings are considered CEII material and are being filed under separate cover as Attachment 12 in Volume II of this response to the AIR.

June 2008 4 Energy Northwest’s Response to FERC’s Request for Additional Information

FERC Request:

5. Debris Screen Conceptual Drawings

In Table D-2 of Exhibit D you list “Estimated Costs of Proposed Protection, Mitigation and Enhancement (PM&E) Measures.” However, to conduct our environmental analysis prior to a license decision and fully evaluate measures necessary to protect, mitigate, or enhance the project, we require additional information. We request that you file conceptual drawings for the proposed repairs or upgrade in the two 10’ x 11’ debris screens at the intake so that we can analyze the effectiveness of the proposed measure.

EN Response:

Conceptual drawings are provided in Attachment 3 to this response to the Commission’s AIR. The drawings illustrate the location and type of screen Energy Northwest would install if required.

FERC Request:

6. Tailrace Water Temperature Monitoring and Enhancement Plan

In section E.5.2.3 of your FLA, as one of your proposed environmental measures for water resources, you propose to develop a monitoring plan to evaluate the effectiveness of project operations under the new license in meeting the applicable temperature standard at the confluence of the tailrace with the Cowlitz River side channel. You also indicate the possible need for additional measures other than the timing of the project outage, such as the establishment of a mixing zone in the Cowlitz River below the tailrace. While we understand the overall goal of this monitoring plan, the lack of descriptions of the possible additional measures, and while we support adaptive management, the lack of a clearly defined strategy in your FLA, makes it difficult for us to complete our environmental analysis of this proposal.

So that we may more accurately analyze the effects of your proposed measure on water temperature, please develop and file with the Commission a detailed tailrace water temperature monitoring and enhancement plan. The plan should include (1) a thorough description of the monitoring that you propose to implement to monitor your compliance with applicable state temperature standards; and (2) a listing of any environmental measures that you may be implementing in the tailrace area over the term of a new license including and an approximate cost estimate for each of the proposed or possible measures. If applicable, the plan also should include a description of the steps that would be taken if performance goals are not achieved.

June 2008 5 Energy Northwest’s Response to FERC’s Request for Additional Information

EN Response:

To respond to this request, Energy Northwest has developed a Tailrace Water Temperature Monitoring and Enhancement Plan for the Project, (see Attachment 4). The plan was provided to the consulting agencies for review prior to this filing.

FERC Request:

7. Avian Protection Plan

In section E.5.4.3.2 of the FLA, Raptor Protection-Primary Distribution Line, you propose to survey project-related distribution lines, raptor-proof lines or poles that are involved in a bird fatality or injury, and implement measures that may be necessary to correct the problem. You indicate you would follow the APLIC/USFWS 2005 (or current) Avian Protection Plan Guidelines, and in Exhibit D, table D-2, you propose to develop an avian protection plan. The APLIC/USFWS guidelines provide strategies and methods for identifying and reducing risks to all birds, therefore we anticipate that your plan would address any species, including raptors, waterfowl or neotropical migrants, that may be of particular concern in the project area, but we need clarification of your proposed approach. So that we may accurately analyze the effects of your proposed measure, please develop and file with the Commission a detailed Avian Protection Plan that includes the following items:

a) Discussion of species that would be addressed in the plan, and the likely risks posed by project-related power lines and poles to various species; b) Explanation of proposed survey methods, including survey timing, frequency and reporting; c) Maps showing survey areas; d) Explanation of proposed methods to prevent or minimize adverse impacts and follow-up surveys following any modifications that are made; and e) Costs associated with planning and conducting surveys, modifying power lines and poles, consulting with stakeholders, and filing reports. f) Provisions for stakeholder consultation through implementation of the plan.

EN Response:

Energy Northwest developed an Avian Protection Plan for the Project with input from the USDA Forest Service, the U.S. Fish and Wildlife Service, and Washington Department of Fish and Wildlife. The plan addresses the six items listed above. See Attachment 5.

June 2008 6 Energy Northwest’s Response to FERC’s Request for Additional Information

FERC Request:

8. Integrated Weed Management Plan

In section E.5.5.3 of the FLA, you propose to revise your current Noxious Weed Control Plan and incorporate it into an Integrated Weed Management Plan that would be developed in consultation with the Forest Service. You indicate that the plan would provide a framework for consultation between Energy Northwest, the Forest Service, private landowners, and appropriate agencies, but do not indicate the goals or objectives of the revisions you would make, or explain how the plan would be coordinated and implemented with the various stakeholders. You indicate the importance of early detection of new infestations and propose periodic surveys, focusing on areas with a higher likelihood of infestation, but do not provide a schedule showing how often or where surveys would be conducted, or which areas you consider to be at higher risk. More specifically, you state that treatments will be proposed for reed canarygrass, Canada thistle, and meadow knapweed at three sites on National Forest System lands and for diffuse knapweed and butterfly bush at two sites on private lands in the project area, but do not explain what the treatments would be, when they would be applied, or how the sites would be monitored following treatment. So that we may accurately analyze the effects of your proposed measure, please develop and file with the Commission a detailed Integrated Weed Management Plan that includes the following items:

a) An initial list of species to be addressed in the plan, indicating habitats where each is most commonly found and times of year when each species is best identified; b) Maps of the area to be addressed in the Integrated Weed Management Plan, including areas outside the project boundary that may be affected by implementation of any proposed PM&Es, and occurrences of weeds documented during the 2005-2006 surveys; c) Explanation of proposed survey methods, including survey timing, frequency and reporting; d) Explanation of proposed weed prevention and control methods, including any education efforts, treatment timing, frequency, follow-up, and reporting; e) Provisions for stakeholder consultation during implementation of the plan, updating the species list, and updating the management plan; f) Costs associated with planning and conducting surveys and prevention and control efforts, consulting with stakeholders, and filing reports; g) Site-specific measures that will be implemented to treat weeds at three sites on National Forest System lands and two sites on private lands within the project boundary, and associated schedules and costs; h) Provisions for incorporating weed survey results and management activities with protection of rare plants.

EN Response:

In response to this request, Energy Northwest developed an Integrated Weed Management Plan for the Project. See Attachment 6. The plan was developed

June 2008 7 Energy Northwest’s Response to FERC’s Request for Additional Information together with the Forest Service and a complete copy was provided for their review prior to this filing.

FERC Request:

9. Rare Plant Management Plan

In section E.5.6.5.2 of the FLA (USDA Forest Service Sensitive Species), you propose to consult with the Forest Service and other agencies to develop a rare plant management plan. The goal of the plan is “to provide site-specific management to protect and monitor occurrences of rare plant species located in the Project boundary on Forest Service and Energy Northwest lands,” but you later indicate that the plan would be developed only for the USFS-managed portion of the project area, and that surveys and monitoring would be “of a limited scope.” As part of this plan, you would develop site-specific measures to protect Peltigera pacifica, a rare lichen.

In section E.5.6.5.3 of the FLA (Washington State Listed Species), you propose to develop a rare plant management plan that would address rare plant species located in the project boundary on private and Energy Northwest Lands. This plan would also include surveys and monitoring “of a limited scope.”

From these descriptions, it is not clear whether you are proposing to develop one rare plant management plan or two plans; what the scope of the plan(s) would be; how the plan(s) would be coordinated with the USFS preliminary 4(e) condition regarding development of a Threatened, Endangered and Sensitive Species Plan to which you have agreed “in concept”; or exactly what measures would be implemented to protect the rare lichen that has been documented. So that we may accurately analyze the effects of your proposed measure, please develop and file with the Commission a detailed rare plant management plan that includes the following items:

a) Explanation of how your plan addresses National Forest System lands, private, and ENW ownerships within the project boundary and lands affected by the project; b) Explanation of how the rare plant management plan would be coordinated with the Threatened, Endangered, and Sensitive Species Plan; c) An initial list of species to be addressed in the plan, indicating habitats where each is most commonly found and times of year when each species is best identified; d) Maps of the area to be addressed in the rare plant management plan, including any areas outside the project boundary that may be affected by implementation of any proposed PM&Es, and occurrences of rare plant species documented during the 2005-2006 surveys; e) Explanation of survey methods (including survey timing, frequency, and reporting); f) Provisions for stakeholder consultation during implementation of the plan, updating the species list, and updating the management plan, and associated schedules; g) Costs associated with planning and conducting surveys, consulting with stakeholders, and filing reports; h) Results of 2007 Peltigera pacifica surveys; and

June 2008 8 Energy Northwest’s Response to FERC’s Request for Additional Information

i) Site-specific measures that would be implemented to protect Peltigera pacifica from disturbance during road and trail maintenance and on-going recreation activity, including maps and/or drawings to illustrate such measures, and associated schedules and costs of implementation.

EN Response:

In response to this request, Energy Northwest has developed a Rare and Sensitive Species Management Plan to address the concerns listed above regarding rare plants that are near the Project. See Attachment 7. The plan was developed together with the USDA Forest Service, Gifford Pinchot National Forest (GPNF) staff, and a complete copy was provided for their review prior to this filing.

FERC Request:

10. Recreation Plan

In Exhibit E.5.7-Recreation/Land Use of your FLA, page E.5.7-24, you state that you propose to develop a Recreation Plan in “coordination with the Agencies” that would describe an annual implementation schedule, consultation, and approval procedures and would include:

1. Measures to adequately address the Agencies resource concerns and standards of quality (e.g., Meaningful Measures) throughout the License term; 2. Requirement to obtain and install a composting toilet at the Packwood Lake recreation site within three years of the issuance of the license; 3. Provisions for Operation and Maintenance annual funding over the life of the new license, for the composting toilet; 4. Provisions for Operation and Maintenance annual funding over the life of the new license, to address impacts from dispersed recreation beginning the first year of the License; 5. Development of a Road Maintenance Plan for the Pipeline Road (FS Road 1260-066) (level 2-drainage maintenance), Pipeline Trail (Trailhead No. 74) (maintaining the trail [drainage, trail clearing, and vegetation management to USDA Forest Service standard] and install and maintain a Kiosk for signage for “Pack it In/Pack it Out”), and Latch Road (FS Road 1262 above the gate) (level 2- drainage maintenance and vegetation management - brushing), in consultation with the Agencies. Coordinate the Road Maintenance Plan with the Integrated Weed Management Plan. 6. Continued provision of electricity to the USDA Forest Service guard station; and 7. Consultation with the USDA Forest Service, as repairs and maintenance to the Project intake-related structures or facilities are performed, on appropriate paint colors and materials to make the building blend in with the surrounding area.

The Recreation Plan, along with the additional clarifications requested below, would provide details regarding the type and location of the proposed recreation facilities, proposed

June 2008 9 Energy Northwest’s Response to FERC’s Request for Additional Information

operation, and maintenance measures associated with both the recreation facilities and the project-related roads, and proposed visual mitigation measures. This information will help us to assess the potential effects of the proposed measures on recreation and aesthetic resources, such as provision of public recreational access at the project. Therefore, please develop and file with the Commission your Recreation Plan and include as part of your filing the following items:

a) Provisions for stakeholder consultation through implementation of the plan and identification of the agencies consulted to date and any comments and your response to comments conducted in the development of the recreation plan. b) Identification of measures to adequately address the Agencies resource concerns and standards of quality and any associated identification of costs of these measures, if any. c) Description and figure of the location of the (1) “Packwood recreation site” at which the proposed composting toilet would be installed; and (2) proposed kiosk, including the relationship of these locations to the existing project boundary (i.e., inside or outside of the existing project boundary). d) The Road Maintenance Plan, and including a figure denoting the location of the roadways and trail segments such as the location of Pipeline Road (FS Road 1260-066), the Pipeline Trail (Trailhead No. 74) and Latch Road (FS Road 1262 above the gate), and the location of the existing project boundary to denote the relationship of these roadway and trail segments to the existing project boundary.

In Exhibit E, section E.5.7.4 of your FLA, in describing components of your proposed Recreation Plan you propose to install and maintain a kiosk for signage. However, you do not provide specific costs in Exhibit E table E.5.7-3 for this proposed kiosk. In table D-2, item 23 of Exhibit D of your FLA you provide costs for providing public education and interpretation. Specifically, you propose to “work with CRC members to develop an interpretive sign detailing the aspects of the prehistoric and historic use of Packwood Lake and work with the USFS to place that sign at the OHV parking area at Packwood Lake.” In table D-2 you provide capital costs of $3,500 to build and place the sign and of $3,275 for coordination and development. In addition, you state there are no annual costs associated with this measure. Please clarify if this measure described in item 23 of table D-2, is the same measure proposed in section E.5.7.4 of installing and maintaining a kiosk for signage, and if so, clarify why there would not be any annual costs associated with the maintenance of the kiosk. If these are not the same proposed measure, please provide a description and associated costs for each individual proposed measures.

EN Response:

In response to this request, Energy Northwest has developed a Recreation Management Plan for the Project. See Attachment 8. The plan was developed together with the Forest Service and a complete copy was provided to the GPNF staff for their review prior to this filing.

June 2008 10 Energy Northwest’s Response to FERC’s Request for Additional Information

FERC Request:

11. Project Economics, Clarification of Costs, Benefits, and Income

As part of our developmental analysis, we will be comparing the cost of your project with the power benefits. In reviewing the Three Year Periodic Report submitted with your Supporting Design Report, we note that your project has bonded debt. Please file with the Commission the bond interest rate. If the interest rate associated with new environmental measures or investments will be different, please provide these rates as well.

EN Response:

The project currently has outstanding bonds in the amount of $1, 241,000 that on the current schedule would be paid off on March 1, 2012. Of this amount $741,000 are from the 1962 Series, with a fixed interest rate of 3.625%, and $500,000 are from the 1965 Series, with a fixed interest rate of 3.75%. Energy Northwest expects to retire all of these bonds on March 1, 2009. The Project will pay the debt that is scheduled to be retired on March 1, 2009 totaling $690,000 with funds collected from power sales in the Project’s Revenue Fund. The additional $551,000 of principal will be retired with the use of $508,000 from the Project's Bond Fund Reserve Account and the remaining from the Revenue Fund. If circumstances beyond the Project’s control result in drastic reductions in generation and/or operating revenue during, FY 2008 (July 1, 2008 – June 30, 2009), the retirement of the bonds could be delayed.

FERC Request:

In the Three Year Periodic Report included in the Supporting Design Report, you indicate the maintenance of a Reserve and Contingency Fund of $280,000 and state that one purpose of this fund is to cover the cost of renewals and replacements to the project. Please estimate what it will cost on an annual basis (excluding inflation) over the next 30 years to maintain this fund. Your estimate should take into account major capital replacement projects likely to occur over the next 30 years.[1] Alternatively you can provide anticipated future cash flows associated with major capital replacements over the next 30 years. All estimates should be in current (uninflated) dollars.

EN Response:

There are no costs associated with maintaining the Contingency Fund. If the fund in not used, it remains invested and generates revenue for the Project, as shown on Table D-1 in Exhibit D of the FLA. See the table in Attachment 9 for a Long Range Estimate (LRE) of Capital expenditures

June 2008 11 Energy Northwest’s Response to FERC’s Request for Additional Information

FERC Request:

In your FLA you include revenues from interest on investments. Does this interest represent interest earned on the reserve and contingency fund? If not, please explain the source of this investment income.

EN Response:

The interest earned is on the reserve and contingency fund is included in table D-1.

FERC Request:

We note that the income is highly variable, so therefore please confirm that using a 5-year average of this income is reasonable for future projections, or provide your best estimate of future income (in current dollars).

EN Response:

The five year revenue projection is utilized by Energy Northwest to estimate revenue based on the forty year average Project generation, pricing of the power sales contract “in effect” and projected electrical market prices. If the contract is modified, revenue projections are adjusted accordingly. The Project generally relies on generation revenue to cover all O&M costs. If O&M costs should exceed revenues, the Twelve Public Utilities who are Participants in the Project are responsible for covering those costs based on their percent of participation. Conversely, they share in excess revenue over costs by percentage.

June 2008 12

Attachment 1

Revised Excerpt of Exhibit A of the Final Application for New License Packwood Lake Hydroelectric Project (FERC No. 2244)

Energy Northwest Response to Request for Additional Information June 2008 Exhibit A-Project Description

EXHIBIT A PROJECT DESCRIPTION (per 18 CFR 4.51(b))

A.1 PROJECT LANDS AND WATERS

The Packwood Lake Hydroelectric Project (FERC No. 2244) is located in Lewis County in southwest Washington State near the unincorporated town of Packwood about 20 miles south of Mt. Rainier. Packwood Lake is located in the Cascade Mountain Range within the Gifford Pinchot National Forest (see Figure A-1). The southern portion of the lake is bordered by the Goat Rocks Wilderness Area.

A.1.1 FERC Project Boundary

The Packwood Lake Hydroelectric Project (Project) boundary, as shown in Exhibit G, is defined to include Packwood Lake up to an elevation of 2860 feet mean sea level (MSL) and the intake canal, intake structure, drop structure, pipeline and tunnels, penstock, powerhouse area, tailrace, and transmission line. The Project boundary is generated through a combination of an elevation contour line around Packwood Lake as described above, and metes and bounds, beginning at the intake/drop structure and continuing down to the tailrace (see Exhibits G-2 through G-9). The Project includes 511.65 acres of USDA Forest Service land, 23.66 acres of Energy Northwest-owned land, and 8.78 acres of Washington State lands, and 1.52 acres of Lewis County PUD land. Total land acreage within the FERC boundary is approximately 546 (545.61) acres.

The transmission line falls within the larger blocks of land reserved for other facilities of the Project or shares a similar occupancy with other utilities. Accordingly, the transmission line was specified by length in feet that it occupies in each land ownership block. For example, the first 748 feet of transmission line leaving the project switchyard traverses Forest Service managed land. The line then runs 3,873 feet along the Energy Northwest-owned tailrace corridor. Upon reaching U.S. Highway 12, the line changes direction and runs 3,361 feet along the state highway right-of-way on poles shared by other power and telecommunication utilities until it reaches the Packwood substation, which includes 27 feet on Lewis County PUD land. The right-of-way varies within the Project boundary from 110 feet across Highway 12 up to 125 feet at the end of the line near the Packwood Substation. The acreage of the line along Highway 12 is 8.78 acres and 1.52 acres of Lewis County PUD land at the Packwood substation.

Revised June 2008 for FERC AIR

Packwood Lake Hydroelectric Project A-1 Final Application for New License FERC No. 2244 February 2008 Exhibit A-Project Description

A.3 PROPOSED PROJECT FACILITIES

No additional Project facilities are proposed for construction as part of the Project’s relicensing.

A.4 LANDS OF THE UNITED STATES

The Project boundary encompasses 546 acres, of which approximately 512 acres are federal lands managed by the USDA Forest Service. The Project facilities located on Forest Service managed land include the intake/drop structure, pipeline/tunnels, surge tank, penstock, raw water tank and constant head tank, powerhouse, warehouse, storage yard, stilling basin, switchyard, a portion of the tailrace and transmission line, and access roads. A breakdown of the federal acreage amount is provided below in Table A-1, and as noted in Exhibit G.

Table A-1. Lands of the U.S. within the Project Boundary Jurisdiction Acres Location (Township, Range, Section, Exhibit Dwg. No.) USDA Forest Service 512 Exhibit G-2; T13N, R10E, Sections 20, 21, 27, 28, 33, and 34 Exhibit G-3; T13N, R10E, Sections 20 and 21 Exhibit G-4; T13N, R10E, Sections 18,19, and 20 Exhibit G-5; T13N, R10E, Section 18 and T13N, R9E, Sections 13 and 24 Exhibit G-6; T13N, R9E, Sections 23 and 24 Exhibit G-7; T13N, R9E, Sections 22 and 23

Revised June 2008 for FERC AIR

Packwood Lake Hydroelectric Project A-18 Final Application for New License FERC No. 2244 February 2008

Attachment 2

Revised Exhibits G-2 and G-8 of the Final Application for New License Packwood Lake Hydroelectric Project (FERC No. 2244)

Energy Northwest Response to Request for Additional Information June 2008

Attachment 3

Debris Screen Conceptual Drawings Packwood Lake Hydroelectric Project (FERC No. 2244)

Energy Northwest Response to Request for Additional Information June 2008

Profile of Packwood Intake Structure

Permanent Trash Racks

Removable Debris Screens

Elev. 2840 ft Conceptual design for debris Screen at the Packwood Hydro Facility Intake Building • Frame to be fabricated from aluminum angle and equipped with a lower catch basket as shown • Fabrication dimensions to be field verified • Final dimensions and configuration to be determined during design phase • Screen to be equipped with permanent rigging features for ease of removal and cleaning • Two Screens approximately 10 ft. high X 9 ft. wide

Picking eyes, typical two sides for each screen

Polyethylene Trash Bars spaced per final design

Aluminum Frame (size/weight determined by final design)

Debris Basket

Side View Elevation view Debris Screen Support Frame • Extra High Molecular Weight Polyethylene trash bars • Mounted on an aluminum frame • Bars spacing is to be determined

•Debris Screen bars to completely cover frame and intake building opening •Bars spaced per final design

•Bars to be attached to frame per manufacturer recommendations. Example of Face of frame mounted screen

Attachment 4

Tailrace Water Temperature Monitoring and Enhancement Plan Packwood Lake Hydroelectric Project (FERC No. 2244)

Energy Northwest Response to Request for Additional Information June 2008

Tailrace Water Temperature Monitoring and Enhancement Plan

for

Energy Northwest's Packwood Lake Hydroelectric Project FERC No. 2244 Lewis County, Washington

Submitted to:

P.O. Box 968 Richland, Washington 99352-0968

Submitted by:

EES Consulting

1155 North State Street, Suite 700 Bellingham, Washington 98225 360.734.5915 phone, 360.734.5918 fax

June 2008 Tailrace Water Temperature Monitoring and Enhancement Plan

TABLE OF CONTENTS

1.0 INTRODUCTION ...... 1 1.1 Goals and Objectives ...... 1 1.2 Water Quality Standards ...... 2 1.3 Background ...... 2

2.0 ENVIRONMENTAL MEASURES ...... 5

3.0 TAILRACE WATER TEMPERATURE MONITORING ...... 7

4.0 SCHEDULE AND DELIVERABLES ...... 8

5.0 REFERENCES CITED ...... 11

APPENDIX A Washington Administrative Code Section 173-201A-510, Sections (4) and (5)

LIST OF FIGURES

Figure 1. Aerial Photo of Tailrace Terminus and Cowlitz River ...... 3

Figure 2. Packwood Lake Project and Lower Lake Creek ...... 4

Figure 3. Thermister Locations for Monitoring Packwood Tailrace Water Temperatures ...... 8

LIST OF TABLES

Table 1. Packwood Tailrace Water Temperature Monitoring and Enhancement Plan Schedule 9

Table 2. Estimated Costs of Proposed PME Measures for the Tailrace Slough ...... 10

June 2008 i Tailrace Water Temperature Monitoring and Enhancement Plan

TAILRACE WATER TEMPERATURE MONITORING AND ENHANCEMENT PLAN

1.0 INTRODUCTION

Energy Northwest, Licensee of the Packwood Lake Hydroelectric Project, filed its Final Application for New License (FLA) with the Federal Energy Regulatory Commission (FERC) on February 24, 2008. FERC issued an Additional Information Request (AIR) on April 8, 2008. FERC requested that Energy Northwest provide clarification of Protection Mitigation and Enhancement (PM&E) measures and to submit several fully developed resource management plans, including a Tailrace Water Temperature Monitoring and Enhancement Plan. As stated in the AIR:

In Section E.5.2.3 of your FLA, as one of your proposed environmental measures for water resources, you propose to develop a monitoring plan to evaluate the effectiveness of project operations under the new license in meeting the applicable temperature standard at the confluence of the tailrace with the Cowlitz River side channel. You also indicate the possible need for additional measures other than the timing of the project outage, such as the establishment of a mixing zone in the Cowlitz River below the tailrace. While we understand the overall goal of this monitoring plan, the lack of descriptions of the possible additional measures, and while we support adaptive management, the lack of a clearly defined strategy in your FLA, makes it difficult for us to complete our environmental analysis of this proposal.

This Tailrace Water Temperature Monitoring and Enhancement Plan is being submitted in response to the AIR.

1.1 Goals and Objectives

The purpose of the Tailrace Water Temperature Monitoring and Enhancement Plan is to monitor water temperatures in the Project’s lined tailrace, at the Packwood Lake outlet and the mouth of Lake Creek, to determine the effects of the tailrace water on Cowlitz

June 2008 1 Tailrace Water Temperature Monitoring and Enhancement Plan

River water temperature. The monitoring to be implemented under this plan is intended to document the Project’s compliance with water quality standards promulgated by the Washington Department of Ecology (Ecology). This monitoring, together with the proposed change in timing of the Project’s annual maintenance outage, will be the main actions that Energy Northwest will take toward achieving and demonstrating compliance with current water quality standards.

1.2 Water Quality Standards

Ecology will issue a water quality certification, pursuant to Section 401 of the Clean Water Act (CWA), for the operation of the Project under a new FERC license. The certification will require compliance with the water quality standards set forth by Ecology under the CWA. This Tailrace Water Temperature Monitoring and Enhancement Plan describes the methods Energy Northwest will employ to comply with the state standards and its Project-specific water quality certification.

Compliance with the state water quality standards requires, in part, knowing the natural water quality condition for a water body. When the 7-day average of the maximum daily temperatures (7-DAD Max)1 exceeds the water quality temperature criteria (16°C for Lake Creek), and that condition is due to natural conditions, then human actions, considered cumulatively, may not cause the 7-DADMax temperature to increase more than 0.3°C (WAC 173-201A-200(1)(c)(i)).

“AKART” is an acronym for “all known, available, and reasonable methods of prevention, control, and treatment.” AKART shall represent the most current methodology that can be reasonably required for preventing, controlling, or abating the pollutants associated with a discharge. The concept of AKART applies to both point and nonpoint sources of pollution. The term “best management practices,” typically applied to nonpoint source pollution controls is considered a subset of the AKART requirement. (WAC 173-201A).

Energy Northwest will use AKART in its efforts to achieve compliance with the water quality standards.

1.3 Background

Water from Packwood Lake enters the Cowlitz River by one of two routes: one is the natural route via Lake Creek, and the other is via the Packwood Lake Hydroelectric Project. Naturally warmed surface water is withdrawn from Packwood Lake at the Project intake and diverted through a water conveyance to the Packwood powerhouse, a portion of which is buried. There it passes over the turbine runner, enters a stilling

1 "7-DADMax" or "7-day average of the daily maximum temperatures" is the arithmetic average of seven consecutive measures of daily maximum temperatures. The 7-DADMax for any individual day is calculated by averaging that day's daily maximum temperature with the daily maximum temperatures of the three days prior and the three days after that date. WAC 173-201A-020.

June 2008 2 Tailrace Water Temperature Monitoring and Enhancement Plan

basin, and is routed back to a side channel of the Cowlitz River, via a lined tailrace canal (Figures 1 and 2, below).

Mainstem Cowlitz River Project Tailrace

Cowlitz River Side Channel

Figure 1. Aerial Photo of Tailrace Terminus and Cowlitz River

The Department of Ecology has established that waters in the tailrace are waters of the state and therefore must comply with the state water quality standards. Prior to construction and operation of the Packwood Lake Hydroelectric Project, the water that now enters the Cowlitz River through the Project tailrace entered the Cowlitz River via Lake Creek. (Figure 1-2).

June 2008 3 Tailrace Water Temperature Monitoring and Enhancement Plan

Figure 2. Packwood Lake Project and Lower Lake Creek

June 2008 4 Tailrace Water Temperature Monitoring and Enhancement Plan

Energy Northwest modeled pre-Project water temperature conditions in Lake Creek and used the findings as the basis for establishing the temperature criteria to be applied to the tailrace discharge into the Cowlitz River.

Energy Northwest utilized the QUAL2Kw model to assess pre-Project water temperatures in Lake Creek. QUAL2Kw is a river and stream water quality model that represents a modernized version of the QUAL2E model (Brown and Barnwell 1987). QUAL2Kw is similar to QUAL2E in the following respects:

• One dimensional. The channel is well mixed vertically and laterally. • Steady state hydraulics. Non-uniform, steady flow is simulated. • Diel heat budget. The heat budget and temperature are simulated as a function of meteorology of a diel time scale. • Diel water-quality kinetics. All water quality variables are simulated on a diel time scale. • Heat and mass inputs. Point and non-point loads and abstractions are simulated.

Analysis using the QUAL2Kw model determined the pre-Project 7-DADMax water temperature in Lake Creek to be 19.09°C (EES Consulting, 2007). Given this modeled, “natural” temperature, and applying the criteria for temperature in the Washington water quality standards, the maximum allowable temperature for water delivered by the Project to the Cowlitz River via the tailrace is 19.39oC. (WAC 173-201A)

Two years of water temperature monitoring and analysis were conducted in the Project tailrace (2004 and 2005). The highest seven-day period of water temperatures in the tailrace during both years of the monitoring occurred between August 15 and August 21, 2004. (EES Consulting, 2007). High temperatures ranged from 18.62 °C to 20.25 °C, with a 7-DADMax of 19.46 °C, which would exceed the maximum allowable temperature by 0.07°C.

Because the tailrace water is likely to exceed the temperature standard in August, Energy Northwest has agreed to undertake a schedule of compliance, to implement best management practices (non-construction facility operation changes), and to complete the necessary water quality studies (temperature monitoring) to verify the effectiveness of proposed changes in achieving compliance with the state water quality standards (Ten Year attainment plan, allowed under WAC 173-201A-510(5); see Appendix A).

2.0 ENVIRONMENTAL MEASURES

As part of a coordinated set of PM&E measures in the Final License Application for the Project, Energy Northwest plans to address Project effects on several environmental resources by implementing the following measures proposed in the final license application in the tailrace vicinity. (Energy Northwest, 2008):

June 2008 5 Tailrace Water Temperature Monitoring and Enhancement Plan

• Modifying the timing of the annual Project maintenance outage for the new license term • Eliminating the current lake drawdown that occurs prior to the annual outage. • Conducting a fish rescue effort in the tailrace slough below the tailrace if the project flows are the primary source of water for the tailrace slough. (See Final License Application, Exhibit E, Section E.5.3.1.3.7).

Currently, Energy Northwest shuts down the Project for annual maintenance on October 1, and the Project is off line during most or all of the month. Under the new license, Energy Northwest is proposing to shut down between August 15 and September 15. The new outage timing will coincide with the period when water temperatures are warmest at Packwood Lake. Because no water would be discharged to the Cowlitz River from the Project tailrace during the outage, there would be no elevation of temperature, or exceedence of temperature criteria caused by the Project during that time.

Changing the outage timing to this period, and eliminating the current pre-outage lake drawdown are expected not only to reduce the temperature impacts of the Project during the warmest time of the year, but also to provide benefits to any ESA-listed fish in the tailrace slough. Chinook spawning begins on about August 15 in the vicinity of the Project. By starting the outage on August 15th rather than the current October outage timing, the Project will avoid providing attraction water that would draw adult Chinook salmon into the tailrace slough to spawn. Because the lake will not be drawn down prior to the outage, there will be sufficient water stored for continuous flows when the Project comes back on line, thereby reducing the risk of dewatering any Chinook salmon eggs that may be present in the tailrace side channel.

It is important to note the Washington Department of Fish and Wildlife and the U.S. Fish and Wildlife Service have indicated that the outage timing will also be constrained by the spawn timing and out-migration of adfluvial rainbow trout in Packwood Lake, as well as the need to provide increased bypass flows to support spawning and rearing in the anadromous reach of lower Lake Creek.

As an additional measure, Energy Northwest will conduct a fish rescue effort in the tailrace slough from the terminus of the tailrace down to the confluence with the mainstem Cowlitz River when conditions warrant. The tailrace slough side channel of the Cowlitz River can experience frequent and dramatic changes. During some years, large volumes of river water flow through the tailrace slough and in other years the river provides very little flow. During low river flows the project tailrace provides the majority of water through the slough. Under these conditions the water flowing from the Project tailrace does not meet the river for several hundred feet or more downstream of the tailrace terminus.

This situation presents a challenge for monitoring temperature impacts to the mainstem of Cowlitz River. Energy Northwest will conduct monitoring and continue consultation

June 2008 6 Tailrace Water Temperature Monitoring and Enhancement Plan

with Ecology to determine how to best obtain data and document conditions and achieve compliance.

3.0 TAILRACE WATER TEMPERATURE MONITORING

It is anticipated that moving the outage will have a beneficial effect on water temperature in the Cowlitz River at the confluence with the Project tailrace, since no water at all will be released through the powerhouse during most of the hottest period of the year. Energy Northwest is proposing to monitor water temperature, as described below, after beginning the new outage schedule to determine if moving the outage brings the Project into compliance with the temperature standard.

To confirm the expected beneficial effect on water temperatures of the proposed change in the annual Project outage schedule, Energy Northwest will monitor water temperatures at seven sites in four areas: 1) in the tailrace, 2) Lake Creek, 3) Packwood Lake, and 4) the Cowlitz River. Monitoring will take place on an annual basis between June 25th and October 5th for the first ten years of the new license (or until modified by the Department of Ecology).

Data will be collected in 30-minute intervals using Onset tidbittm thermisters. Data will be organized on a monthly basis and a comparative analysis will be conducted. An annual report will be submitted to Ecology for a 60-day comment period, and Ecology’s comments will be addressed, prior to the report being filed with FERC. The annual report will document water temperatures in the tailrace, as well as differences in the mainstem Cowlitz River upstream and downstream of the tailrace contribution. The proposed placement of thermisters at the Cowlitz River sites is preliminary until landowner permission and permits have been received for access and placement of the probes.

The temperature loggers will be downloaded monthly. The seven sites will be established as follows:

1. POWT1 – Located near where the stilling basin empties into the tailrace. 2. POWT2 – Located in the immediate vicinity of the fish barrier near the terminus of the tailrace. This site will be established in an area that ensures that no mixing with Cowlitz River water is taking place. 3. CRUTR1 – A secure location upstream of the tailrace in the mainstem of the Cowlitz River. This site will monitor water temperatures in the Cowlitz River above the point where temperature can be affected by the tailrace. 4. CRUTR2 – Located upstream of the tailrace in the side channel of the Cowlitz River. 5. LCMH – Located in Lake Creek near the mouth. 6. PLO – Located in Packwood Lake near the outlet canal leading to the intake. 7. PAT – Located along the tailrace or side channel collecting ambient air temperature.

June 2008 7 Tailrace Water Temperature Monitoring and Enhancement Plan

The five monitoring sites in the vicinity of the Project tailrace are shown in Figure 3 below

Figure 3. Thermister Locations for Monitoring Packwood Tailrace Water Temperatures

Energy Northwest must send Ecology a temperature monitoring Quality Assurance Project Plan (QAPP) for approval 60 days prior to the start of temperature monitoring.

Energy Northwest will use best management practices in conducting temperature monitoring. If monitoring shows that shifting the annual outage to August, as proposed, does not bring the Project fully into compliance with the temperature criteria, Energy Northwest will consult with Ecology to determine whether alternative reasonable and feasible techniques exist that may be effective in achieving full compliance.

If Ecology determines that Energy Northwest has employed AKART and the temperature criteria still has not been met at the end of ten years of monitoring, Energy Northwest will consult with Ecology to determine the next appropriate steps to be taken, These may include the designating a mixing zone, determining whether the continued Project temperature excursions are economically and socially acceptable, doing temperature mitigation (such as shade tree plantings) upstream on the Cowlitz River, or ramping power usage, if all other reasonable, feasible measures have been tried or investigated.

4.0 SCHEDULE AND DELIVERABLES

Both the modification to the outage timing and water temperature monitoring will begin with Energy Northwest’s receipt of the new license from FERC. The outage timing modification will be permanent and continue for the duration of the new license. Water temperature monitoring will be conducted for the first ten years of the new license, unless the temperature criteria are met for three consecutive years, at which time

June 2008 8 Tailrace Water Temperature Monitoring and Enhancement Plan

Energy Northwest will petition DOE to suspend or modify the monitoring activities. As described above, an annual report will be submitted to Ecology and other agencies for a 60-day comment period, at the end of which, Energy Northwest will meet with Ecology to discuss the monitoring data and the need for continued monitoring. Ecology’s comments will be incorporated and addressed prior to filing with FERC. Table 1 displays an annual schedule of tasks related to the Packwood Tailrace Water Temperature Monitoring Plan. Each year’s data will be discussed with agency representatives at an annual resource coordination meeting intended to review all compliance work being conducted for Energy Northwest’s new license. Table 2 summarizes estimated annual costs for the environmental measures described in Section 2.0.

Table 1. Packwood Tailrace Water Temperature Monitoring and Enhancement Plan Schedule Task Time Frame Frequency Submit to Ecology a 60 days prior to the 1st Once, with updates as needed temperature monitoring QAPP monitoring period Temperature Monitoring in the June 25 – October 5 Annually for the first 10 years Tailrace of new license* Packwood Project Outage August 15 – September 15 Annually for the duration of the new license Draft Tailrace Water Annually, 60 days prior to the Annually for the first 10 years Temperature Monitoring Resource Coordination of new license* Report to Agencies for review Meeting Tailrace Water Temperature After receiving comments Annually for the first 10 years Monitoring Report to FERC from WDOE and other of new license* Agencies. Resource Coordination To be determined in Annually for the duration of Meeting consultation with Agencies the new license *if compliance not achieved for 3 consecutive years

June 2008 9 Tailrace Water Temperature Monitoring and Enhancement Plan

Table 2. Estimated Costs of Proposed PME Measures for the Tailrace Slough Environmental Measure Estimated Comments Annual Cost Temperature Monitoring $11,600 Modifying Outage Timing $16,268 Based on an increase of 3 hours of labor per week for weekly inspections and 40 hours per year for annual maintenance (196 manhours). (from Table D-2, Energy Northwest 2008) Eliminating Drawdown Prior to $5,722 The cost for a shutdown in August is Outage estimated at $5,772. (Based on a minimum shutdown duration of 12 hours X blended costs of $48.1/Megawatt hr X 5 MW/hr X 12 hrs; each occurrence) (from Table D-2, Energy Northwest 2008) Fish Rescue $12,980 2 continuous years of seining the stilling basin and tailrace fish rescue. If capture is below threshold set by the BO, seine 2 more times 3 years apart. Each occurrence requires a Fish capture permit and personnel with a fish handling experience Total is: 4 consultants trained in fish handling/snorkeling (80hrsX$95/hr=$7600) + Per Diem for 4 Consultants @$90 per day for two days=$720) + 2 Plant Staff $83/hr X 10hrs =$1660) + $3,000 annual permit costs 3. If the plant must be shut down to perform the stilling basin seining and tailrace fish rescue (from Table D-2, Energy Northwest 2008).

June 2008 10 Tailrace Water Temperature Monitoring and Enhancement Plan

5.0 REFERENCES CITED

Brown, L. C. and T. O. Barnwell, Jr., 1987. The enhanced water quality models QUAL2E and QUAL2E-UNCAS documentation and user manual. EPA document # EPA/600/3-87/007, Cooperative Agreement # 811883, Environmental Research Laboratory, U.S. Environmental Protection Agency, Athens, GA.

EES Consulting. 2007. Final temperature model, Lake Creek, for Energy Northwest’s Packwood Lake Hydroelectric Project (FERC No. 2244). Submitted to Energy Northwest. September, 2007.

Energy Northwest, 2008. Final Application for New License, Packwood Lake Hydroelectric Project, FERC No. 2244, Energy Northwest, Richland, WA. February, 2008.

June 2008 11 Tailrace Water Temperature Monitoring and Enhancement Plan

Appendix A

Washington Administrative Code Section 173-201A-510, Sections (4) and (5)

Tailrace Water Temperature Monitoring and Enhancement Plan

WAC 173-201A-510 Means of implementation.

(4) General allowance for compliance schedules.

(a) Permits, orders, and directives of the department for existing discharges may include a schedule for achieving compliance with water quality criteria contained in this chapter. Such schedules of compliance shall be developed to ensure final compliance with all water quality- based effluent limits in the shortest practicable time. Decisions regarding whether to issue schedules of compliance will be made on a case-by-case basis by the department. Schedules of compliance may not be issued for new discharges. Schedules of compliance may be issued to allow for: (i) Construction of necessary treatment capability; (ii) implementation of necessary best management practices; (iii) implementation of additional storm water best management practices for discharges determined not to meet water quality criteria following implementation of an initial set of best management practices; (iv) completion of necessary water quality studies; or (v) resolution of a pending water quality standards' issue through rule-making action.

(b) For the period of time during which compliance with water quality criteria is deferred, interim effluent limitations shall be formally established, based on the best professional judgment of the department. Interim effluent limitations may be numeric or nonnumeric (e.g., construction of necessary facilities by a specified date as contained in an ecology order or permit).

(c) Prior to establishing a schedule of compliance, the department shall require the discharger to evaluate the possibility of achieving water quality criteria via nonconstruction changes (e.g., facility operation, pollution prevention). Schedules of compliance may in no case exceed ten years, and shall generally not exceed the term of any permit.

(5) Compliance schedules for dams:

(a) All dams in the state of Washington must comply with the provisions of this chapter.

(b) For dams that cause or contribute to a violation of the water quality standards, the dam owner must develop a water quality attainment plan that provides a detailed strategy for achieving compliance. The plan must include:

(i) A compliance schedule that does not exceed ten years;

(ii) Identification of all reasonable and feasible improvements that could be used to meet standards, or if meeting the standards is not attainable, then to achieve the highest attainable level of improvement;

(iii) Any department-approved gas abatement plan as described in WAC 173-201A-200 (1)(f)(ii);

(iv) Analytical methods that will be used to evaluate all reasonable and feasible improvements;

(v) Water quality monitoring, which will be used by the department to track the progress in achieving compliance with the state water quality standards; and

June 2008 A-1 Tailrace Water Temperature Monitoring and Enhancement Plan

(vi) Benchmarks and reporting sufficient for the department to track the applicant's progress toward implementing the plan within the designated time period.

(c) The plan must ensure compliance with all applicable water quality criteria, as well as any other requirements established by the department (such as through a total maximum daily load, or TMDL, analysis).

(d) If the department is acting on an application for a water quality certification, the approved water quality attainment plan may be used by the department in its determination that there is reasonable assurance that the dam will not cause or contribute to a violation of the water quality standards.

(e) When evaluating compliance with the plan, the department will allow the use of models and engineering estimates to approximate design success in meeting the standards.

(f) If reasonable progress toward implementing the plan is not occurring in accordance with the designated time frame, the department may declare the project in violation of the water quality standards and any associated water quality certification.

(g) If an applicable water quality standard is not met by the end of the time provided in the attainment plan, or after completion of all reasonable and feasible improvements, the owner must take the following steps:

(i) Evaluate any new reasonable and feasible technologies that have been developed (such as new operational or structural modifications) to achieve compliance with the standards, and develop a new compliance schedule to evaluate and incorporate the new technology;

(ii) After this evaluation, if no new reasonable and feasible improvements have been identified, then propose an alternative to achieve compliance with the standards, such as site specific criteria (WAC 173-201A-430), a use attainability analysis (WAC 173-201A-440), or a water quality offset (WAC 173-201A-450).

(h) New dams, and any modifications to existing facilities that do not comply with a gas abatement or other pollution control plan established to meet criteria for the water body, must comply with the water quality standards at the time of project completion.

(i) Structural changes made as a part of a department approved gas abatement plan to aid fish passage, described in WAC 173-201A-200 (1)(f)(ii), may result in system performance limitations in meeting water quality criteria for that parameter at other times of the year.

[Statutory Authority: Chapters 90.48 and 90.54 RCW. 03-14-129 (Order 02-14), amended and recodified as § 173-201A-510, filed 7/1/03, effective 8/1/03. Statutory Authority: Chapter 90.48 RCW and 40 CFR 131. 97-23-064 (Order 94-19), § 173-201A-160, filed 11/18/97, effective 12/19/97. Statutory Authority: Chapter 90.48 RCW. 92-24-037 (Order 92-29), § 173-201A-160, filed 11/25/92, effective 12/26/92.]

June 2008 A-2

Attachment 5

Avian Protection Plan Packwood Lake Hydroelectric Project (FERC No. 2244)

Energy Northwest Response to Request for Additional Information June 2008

Avian Protection Plan

for

Energy Northwest's Packwood Lake Hydroelectric Project FERC No. 2244 Lewis County, Washington

Submitted to:

P.O. Box 968 Richland, Washington 99352-0968

Submitted by:

Devine Tarbell and Associates Bellingham, Washington Phone: 360.671.1150

June 2008

Packwood Lake Hydroelectric Project Avian Protection Plan

PACKWOOD LAKE HYDROELECTRIC PROJECT AVIAN PROTECTION PLAN

TABLE OF CONTENTS

1.0 Introduction ...... 1 1.1 Project Description ...... 1 1.2 Avian Species Addressed By This Plan ...... 6 1.3 Potential Risks to Avian Species ...... 6 2.0 Components of the Plan ...... 7 2.1 Transmission Line Survey ...... 7 2.2 Annual Surveys of Non-compliant Structures ...... 7 2.3 Incident Reporting ...... 8 2.4 Assessment ...... 8 2.5 Stakeholder Consultation ...... 8 3.0 Costs and Schedule ...... 8 4.0 Literature Cited ...... 10

Appendix 1 - Transmission Line Structure Drawings

List of Figures

Figure 1. Packwood Lake Hydroelectric Project Avian Protection Survey Map ...... 2 Figure 2. Transmission line adjacent to project tailrace canal, showing wishbone conductor configuration...... 3 Figure 3. Vertical conductor design used between the powerhouse and Highway 12. .... 4 Figure 4. Vertical conductor design used along Highway 12...... 5 Figure 5. Avian Incident Response Work Flow Diagram ...... 9

i Packwood Lake Hydroelectric Project Avian Protection Plan

PACKWOOD LAKE HYDROELECTRIC PROJECT AVIAN PROTECTION PLAN

1.0 INTRODUCTION

The following plan describes measures to be undertaken by Energy Northwest to address potential impacts to avian species associated with the Packwood Lake Hydroelectric Project (Project) transmission line. Nearly all native North American avian species are protected from “take” (i.e., to hunt, capture, kill, harass, or possess) under the federal Migratory Bird Act of 1918, as amended (16 U.S.C. 703-712, et. seq.). Other laws and regulations that prohibit unauthorized take of birds include the federal Endangered Species Act (16 U.S.C. 1531-1543, et. seq.) and the Bald and Golden Eagle Protection Act (16 U.S.C. 668-668C, et. seq.). Electric transmission and distributions systems are a potential source of bird electrocution or collision mortality, which may be considered “take.”

The extensive research has been devoted to the causes and solutions to address bird electrocution and collision mortality associated with electric transmission and distribution systems has been summarized by APLIC1 (2006). This research has prompted state and federal resource agencies, in concert with the electric utility industry, to adopt various standards for structural designs and siting of new lines that avoid or minimize bird electrocutions and collisions. The key standard for avoidance of bird electrocutions is a minimum spacing of 60 inches between energized phases (i.e., energized electrical conductors) or between a phase and a grounding source (APLIC 2006). The key requirements for minimizing risk of collision mortality are removal of overhead ground wires and siting new lines to avoid major bird flight paths (APLIC 2006).

1.1 Project Description

The Project transmission line begins at the powerhouse and terminates at the Packwood substation, spanning a distance of about 8,009 feet (about 1.5 miles) (Figure 1). Three conductors transmit electricity at 69 kV and are supported by a total of 31 poles. Between the powerhouse and Highway 12, the line follows the Project tailrace canal; the conductor arrangement on eight poles in this span is in the wishbone design (Figure 2), whereas the other five poles have a vertical conductor arrangement (Figure 3). Along Highway 12 to the Packwood substation, all of the 18 poles have a vertical conductor arrangement (Figure 4). The span along Highway 12, which also carries other lines and services not associated with the Project, was recently upgraded by Lewis County Public Utility District (PUD). Maintenance of the transmission line is performed by Lewis County PUD.

1Avian Power Line Interaction Committee. APLIC members consist of the Edison Electric Institute and its member utilities, U.S. Fish and Wildlife Service, Rural Utilities Service and other electric utilities. APLIC first published “Suggested Practices for Raptor Protection on Power Lines: The State of the Art” in 1975 with periodic updates. APLIC is considered the industry standard.

1 Packwood Lake Hydroelectric Project Avian Protection Plan

Figure 1. Packwood Lake Hydroelectric Project Avian Protection Survey Map

2 Packwood Lake Hydroelectric Project Avian Protection Plan

Figure 2. Transmission line adjacent to project tailrace canal, showing wishbone conductor configuration.

3 Packwood Lake Hydroelectric Project Avian Protection Plan

Figure 3. Vertical conductor design used between the powerhouse and Highway 12.

4 Packwood Lake Hydroelectric Project Avian Protection Plan

Figure 4. Vertical conductor design used along Highway 12.

5 Packwood Lake Hydroelectric Project Avian Protection Plan

Drawings of the wishbone and vertical, phase opposite designs are included (Appendix 1). The designs appear to conform to accepted standards for electrocution risk avoidance (i.e., adequate distance between phase conductors and between the phase conductors and a grounding source line), and are not equipped with overhead ground wires. Drawings of the vertical arrangement employed at turning points are not available. The conductor arrangements on the Project transmission line are not known to be hazardous to birds. Lewis County PUD has not experienced bird-related outages or known avian electrocutions with these designs, and the Project operators have not documented any bird collisions or problems.

1.2 Avian Species Addressed By This Plan

This plan addresses all native avian species potentially occurring in the vicinity of the Project transmission line. However, species with wider wing spans are typically more at risk of electrocution or collision with electric transmission lines than smaller birds. Raptors (birds-of-prey) are the focus of most electrocution avoidance protection measures. Raptors that may occur in the vicinity of the Project transmission line include bald eagle, osprey, turkey vulture, red-tailed hawk, northern harrier, Cooper’s hawk, sharp-shinned hawk, American kestrel, great horned owl, barn owl, barred owl, and western screech owl. Eagles and buteos (such as red-tailed hawk) are more commonly electrocuted than other raptors. Species unlikely to occur in the vicinity of the Project transmission line include golden eagle and northern spotted owl. Golden eagle is typically associated with extensive open, undeveloped habitats, usually characterized by topographic relief, cliffs and canyons. Northern spotted owl is known to occur elsewhere in the Project vicinity in association with structurally complex, late successional conifer forests.

Bald eagles are known to forage seasonally along the Cowlitz River (EES Consulting 2005), but there are no records of bald eagle nesting in the area. Information on bird occurrence along the transmission line is not available, but species composition is likely to reflect the predominant vegetation cover types around the transmission line corridor: Residential, Industrial and Roads (concentrated along Highway 12); and Palustrine Emergent Wetlands (Devine Tarbell & Associates 2007). Forested areas are limited in extent and occur mostly in small patches. Raptors are more likely to perch on transmission line structures in open areas where there are few tall perch sites than in forested habitats (APLIC 2006).

1.3 Potential Risks to Avian Species

Avian species that occupy forests, perch or nest primarily on the ground, or are of small size are rarely electrocuted. High voltage transmission lines (69 kV or greater) tend to pose a much lower risk of electrocution than lower voltage lines because of the required conductor spacing and above-ground clearance (National Electrical Safety Code 1993). Risks increase in weather that hinders flight maneuverability, or when feathers are wet, thereby increasing conductivity.

6 Packwood Lake Hydroelectric Project Avian Protection Plan

Bird collisions with transmission lines generally become biologically significant only in very specific localized situations (e.g., where major flight paths between feeding and nesting/roosting areas are intersected by a transmission line), or under the influence of distracting lighting at night or adverse weather conditions (APLIC 2006). Overhead ground wires are the major engineering factor contributing to the potential for bird collisions because these narrow wires (often only 0.4-0.5 inches in diameter) may not be detected by birds, particularly under dim lighting.

Overall, the Project transmission line is not likely to pose significant risks to avian species. As noted, the drawings suggest that conductors are adequately spaced and configured to avoid bird electrocution. The line is not equipped with an overhead ground wire, suggesting the collision risk is also low.

2.0 COMPONENTS OF THE PLAN

The Avian Protection Plan follows guidelines outlined by APLIC (2005) including adherence to construction design standards, risk assessment, avian incident reporting, mortality reduction measures, observer training, and public awareness.

2.1 Transmission Line Survey

Within one year of license issuance, the Project transmission line will be surveyed by a trained observer to evaluate the potential for avian electrocution and collision. The survey will be conducted in May or June, during the bird breeding season. After review of the transmission line structural drawings, the observer will walk the right-of-way, recording data on structure configuration, evidence of avian activity, and presence of dead birds. An area spanning 15 feet on each side of the center of the right-of-way and a 25-ft. radius around each pole will be searched for bird carcasses, prey remains, pellets, and fecal whitewash. At each pole, the pole number and/or location coordinates will also be recorded along with the conductor configuration type, cover type(s) surrounding the pole, presence of bird carcasses, live birds observed, evidence of raptor use, and presence of avian nests. Representative structures of each type will be photographed, compared to the drawings, and evaluated for consistency with the current APLIC standards (APLIC 2006). Energy Northwest will upgrade or replace non- compliant transmission line configurations during scheduled line maintenance or upgrade projects. Because bird fatality or injury associated with the Project transmission line is likely to be rare and evidence of incidents may not be persistent (an injured or dead bird is liable to succumb to predators or scavengers), the transmission line survey is intended to gauge risk, rather than quantifying incident frequency.

2.2 Annual Surveys of Non-compliant Structures

If there are structures identified in the initial survey that are designated to be rebuilt or retrofitted to comply with the APLIC standards, then annual surveys will be conducted until the upgrade or replacement occurs. The annual surveys will be performed by the project operators during the May or June period looking for evidence of mortality or

7 Packwood Lake Hydroelectric Project Avian Protection Plan

avian use as described above. The results of this survey will be documented and reported annually as a part of the Resource Coordination Plan annual report. Survey frequency and timing may be adjusted as necessary based on decisions made at the annual Resource Coordination Meeting. The annual surveys will be discontinued following completion of the line upgrade or replacement project.

2.3 Incident Reporting

The Project operators will be instructed to report and document any observed incidence of avian injury or mortality attributable to the Project transmission line, including outages associated with bird electrocution. Incident logs will be reviewed annually, assessed for evidence of risk (see below), and the results reported to stakeholders.

2.4 Assessment

If any Project transmission line structure is involved in a bird fatality or injury, Energy Northwest will evaluate the need for and feasibility of rebuilding or retrofitting structures to avoid or minimize future risk. Energy Northwest will follow an incident response process (Figure 5) similar to that used by other utilities and consistent with APLIC (2005) recommendations. Any rebuilding or replacement of the transmission line structures will be made to current APLIC configuration standards.

2.5 Stakeholder Consultation

Starting with the second year after license issuance, Energy Northwest will discuss the results of the initial and subsequent avian surveys and any incident reports at the annual Resource Coordination Meeting. This meeting will provide an opportunity for the agencies and stakeholders to collaborate on the decision-making process and work together to provide recommendations that can be effectively implemented. Energy Northwest shall also discuss, when appropriate, its future plans for pole replacement or line upgrades.

3.0 COSTS AND SCHEDULE

The cost for plan development is $4,800. The cost of the initial transmission line survey and reporting occurring one year after license issuance is estimated at $3,320. The subsequent annual surveys are estimated to cost $1,328 per year (in 2008 dollars). Typical pole replacement costs are about $3,500 per pole (based on May 2008 estimate from Lewis County PUD).

8 Packwood Lake Hydroelectric Project Avian Protection Plan

Figure 5. Avian Incident Response Work Flow Diagram

Injury

Incident Occurs Operator notes bird-related outage or dead/injured bird is found in proximity to Project transmission Project manager calls Type of line. Incident is documented and transmitted to WDFW or local Wildlife incident? Project manager as soon as possible. Rehabilitation Center for further instructions. For eagles only, call WDFW for further instruction.

Electrocution death Collision death, no signs of electrocution

Raptor Incident Raptor Type Supervisor/Delegate visits the site ASAP Non-raptor -Follows protocol to determine “adjacent of bird? poles” Evaluates need for remediation. Calls WDFW with questions

Yes

Work Recommended?

Done

Was job No Yes completed Project manager retains correctly? auditable records.

Construction (within 6 months) Supervisor/ Delegate -Works job to upgrade, retrofit, or -Perform work verification replace pole(s)/structure as appropriate -Completes job

9 Packwood Lake Hydroelectric Project Avian Protection Plan

4.0 LITERATURE CITED

APLIC (Avian Power Line Interaction Committee). 2005. Avian Protection Guidelines. A joint document prepared by the Edison Electric Institute’s Avian Power Line Interaction Committee (APLIC) and U.S. Fish and Wildlife Service (USFWS).

APLIC. 2006. Suggested Practices for Avian Protection on Power Lines: The State of the Art in 2006. Edison Electric Institute. Washington, D.C.

Devine Tarbell & Associates, Inc. 2007. Final Vegetation Cover Type Mapping Study Report for Energy Northwest's Packwood Lake Hydroelectric Project, FERC No. 2244, Lewis County, Washington.

EES Consulting, Inc. 2005. Revised Bald Eagle and Osprey Nest Survey Study Plan for Energy Northwest’s Packwood Lake Hydroelectric Project, FERC No. 2244, Lewis County, Washington. August 22, 2005.

National Electrical Safety Code. 1993. C2-1993. Published by the Institute of Electrical and Electronics Engineers, Inc. and the American National Standards Institute. New York, N.Y. 257

10 Packwood Lake Hydroelectric Project Avian Protection Plan

Appendix 1

Transmission Line Structure Drawings

Packwood Lake Hydroelectric Project Avian Protection Plan

Attachment 6

Integrated Weed Management Plan Packwood Lake Hydroelectric Project (FERC No. 2244)

Energy Northwest Response to Request for Additional Information June 2008

Integrated Weed Management Plan

for

Energy Northwest's Packwood Lake Hydroelectric Project FERC No. 2244 Lewis County, Washington

Submitted to:

P.O. Box 968 Richland, Washington 99352-0968

Submitted by:

EES Consulting

570 Kirkland Way, Suite 200 Kirkland, WA 98033 425.889.2700 phone, 425.889.2725 fax

June 2008

Packwood Lake Hydroelectric Project Integrated Weed Management Plan

TABLE OF CONTENTS

1.0 INTRODUCTION ...... 1 1.1 IWMP Implementation Area ...... 2 2.0 DEFINITIONS, SPECIES LIST, AND TARGET SPECIES...... 4 3.0 INVENTORY AND MONITORING...... 6 3.1 Initial Surveys...... 6 3.1.1 Initial Survey Results ...... 7 3.2 Annual Inventory ...... 8 3.3 Monitoring (Non-Treated Sites) ...... 8 4.0 PREVENTION ...... 9 4.1 Best Management Practices ...... 9 4.1.1 Training...... 9 4.1.2 Activity Planning and Scheduling...... 9 4.1.3 Equipment and Vehicle Cleaning...... 10 4.1.4 Minimize Ground Disturbance ...... 10 4.1.5 Use of Weed-Free Material...... 10 4.2 BMP Monitoring...... 11 4.3 Revegetation...... 11 5.0 CONTROL AND MONITORING...... 12 5.1 Treatment Plans...... 12 5.2 Control Method Tool Box ...... 13 5.2.1 Manual Methods ...... 13 5.2.2 Mechanical Methods...... 14 5.2.3 Cultural Methods ...... 14 5.2.4 Chemical Methods...... 15 5.2.5 Biological Controls...... 18 5.3 Project Specific Management...... 19 5.3.1 Zone A - Packwood Lake Shore above the Drop Structure ...... 19 5.3.2 Zone B - Wilderness Buffers...... 19 5.3.3 Zone C - Powerhouse Area to Stilling Pond, and Penstock below Surge Tank ...... 20 5.3.4 Zone D - Other Travel Corridors ...... 20 5.3.5 Zone E - Project Area below Stilling Pond...... 20 5.4 Monitoring and Effectiveness Analysis...... 21 6.0 REVEGETATION METHODS ...... 22 6.1 Determining Site Revegetation Needs ...... 22 6.2 Revegetating the Weed Treatment Site ...... 22 6.2.1 Site Evaluation ...... 23 6.2.2 Site Revegetation Objectives and Strategy...... 23 6.2.3 Revegetation Methods ...... 23 6.3 Monitoring ...... 24 7.0 REPORTING ...... 25 8.0 REFERENCES...... 26

Energy Northwest i June 2008 Packwood Lake Hydroelectric Project Integrated Weed Management Plan

Appendices Appendix A – Washington State Noxious Weed List 2008 with GPNF Weeds of Concern Appendix B – Description, General Location and Control Measures Considered for Noxious Weed Species within the Packwood Lake Project Area on USDA Forest Service Lands Appendix C –Description, General Location and Control Measures for Other Noxious Weeds Occurring Within the Project Boundary Appendix D – USDA Forest Service Invasive Plant Inventory Form Appendix E – Revegetation/Rehabilitation/Restoration Analysis Strategy Worksheet

List of Figures

Figure 1. IWMP Implementation Area ...... 3

List of Tables

Table 1. Target Noxious Weed Species for the Packwood Lake Hydroelectric Project Area ...... 6 Table 2. Noxious Weed Species Observed in the Packwood Lake Study Area, 2005 – 2006 ...... 7 Table 3. Herbicides Approved for use in Pacific Northwest Region 6 ...... 17

Energy Northwest ii June 2008 Packwood Lake Hydroelectric Project Integrated Weed Management Plan

Packwood Lake Integrated Weed Management Plan

1.0 INTRODUCTION

Energy Northwest, Licensee of the Packwood Lake Hydroelectric Project (Project), (FERC No. 2244), filed its Final Application for New License (FLA) with the Federal Energy Regulatory Commission (FERC or Commission) on February 24, 2008. Energy Northwest will be required to implement this Integrated Weed Management Plan (IWMP) in compliance with the terms of its new License for the Project. The IWMP will provide a framework for consultation about invasive weed management between Energy Northwest, the U.S. Department of Agriculture (USDA) Forest Service (USFS or FS), private landowners, and appropriate agencies. The intent of the IWMP is to enhance and promote the coordinated management of noxious weeds with the entities responsible for weed management in the Project vicinity. The goal of the IWMP is for the prevention, suppression, containment, eradication, and/or control, according to goals by species and location, for exotic invasive non-native plant species, including noxious weeds on National Forest System (NFS) lands affected by the Project and/or related to compliance activities under the Project License in and adjacent to the Project area.

The IWMP is meant to ensure that the Licensee’s activities, with respect to noxious weeds, are consistent with the Pacific Northwest Region Invasive Plant Program – Preventing and Managing Invasive Plants Final Environmental Impact Statement and Record of Decision Portland, Oregon (USFS, 2005) and the Record of Decision and Final Environmental Impact Statement and Forest Plan Amendment #20 – Gifford Pinchot National Forest and Columbia River Gorge National Scenic Area (Washington Portion) Site-Specific Invasive Plant Treatment Project and Forest Plan Amendment (USFS,2008). These documents add invasive plant management direction to all National Forest Land and Resource Management Plans (LRMP) in the Pacific Northwest Region. The Forest Service’s management direction includes invasive plant prevention and treatment/restoration standards intended to help achieve stated desired future conditions, goals and objectives on NFS lands. This is expected to result in decreased rates of spread of invasive plants, while protecting human health and the environment from the adverse effects of invasive plant treatment. The Licensee’s plan is intended to complement and support the efforts of the Forest Service by conducting appropriate efforts on lands described within this plan.

The State of Washington Administrative Code (WAC) provides a listing of Class A, B, and C noxious weeds (WAC 16-750 Sections 005, 011, 015). The WAC provides for a Washington State Noxious Weed Control Board (NWCB), and through its actions and policy decisions, the NWCB coordinates and supports the activities of 48 County noxious weed control boards and weed districts of Washington, including the Lewis County Noxious Weed Control Board (LCNWCB).

The IWMP defines the Licensee’s policy regarding noxious weed prevention and management. The geographic scope of the IWMP includes all NFS lands affected by

Energy Northwest 1 June 2008 Packwood Lake Hydroelectric Project Integrated Weed Management Plan

the Project, as well as other lands subject to the Energy Northwest’s License compliance activities. Any measures undertaken with respect to noxious weeds will be coordinated by the Licensee’s personnel with other resource protection efforts and will, in particular, take into account the need to prevent disturbance to any known cultural resources, and to take appropriate actions in the event of unanticipated discovery of cultural materials.

Exotic and invasive plants are defined as aggressively spreading species that have been either purposefully or inadvertently introduced to the natural landscape and are likely to cause economic or environmental harm or harm to human health. This definition includes, but is not limited, to noxious weeds listed by the State and/or County.

Integrated weed management involves using several management techniques in a well- planned, coordinated, organized and consistent program. This IWMP involves: (1) identifying and prioritizing target species; (2) conducting an inventory of the Project area; (3) preventing the establishment of new species or infestations; (4) controlling existing infestations; (5) re-vegetating treated areas, and (6) monitoring the treatment areas and evaluating weed management techniques.

1.1 IWMP Implementation Area

For purposes of the Packwood Lake IWMP, the inventory, management, and monitoring areas encompass the following areas: the Project boundary and 100 feet on each side of the Project boundary, including Project facilities, pipeline, penstock corridor, tailrace, and transmission line, FS Road 1260-066 (Pipeline Road), FS Road 1260 (Snyder Road) from the surge tank to the junction with FS Road 1260-066, FS Road 1260-013 (Powerhouse Road) in the vicinity of the penstock crossing, raw water and constant head tanks, FS Road 1262 (Latch Road) from the gate to where the road ends , FS Trail #74, including the parallel “Dyson Pass” trail segment, a 200-foot-wide margin around the perimeter of Packwood Lake (elevation 2860 ft MSL); the mouths of all class 1, 2, and 3 streams (Osprey Creek, Trap Creek, Baker Creek, Crawford Creek, Upper Lake Creek) that have a defined channel from the point where they enter Packwood Lake, upstream as far as weed species are present, and where noxious weeds are present in populations outside the implementation area that are considered contiguous to populations inside the implementation area. Lower Lake Creek stream restoration areas (i.e., the sections of Lake Creek subject to restoration or enhancement as directed by other plans) will also be subject to this plan as necessary. See Figure 1 for a map showing the Packwood Lake noxious weed inventory, management, and monitoring areas.

Energy Northwest 2 June 2008 Packwood Lake Hydroelectric Project Integrated Weed Management Plan

Figure 1. IWMP Implementation Area

Energy Northwest 3 June 2008 Packwood Lake Hydroelectric Project Integrated Weed Management Plan

2.0 DEFINITIONS, SPECIES LIST, AND TARGET SPECIES

The IWMP recognizes both the definition of noxious weeds in the WAC and the definition used by the Forest Service, in developing implementation measures. The WAC defines noxious weeds as, “plants, which the NWCB finds to be highly destructive, competitive, or difficult to control by cultural or chemical practices is adopted.” (WAC 16- 750-001, 2003)

The Forest Service uses a definition, provided by Public Law 93-629 (1975) and the Federal Noxious Weed Act of 1974, which defines noxious weeds as non-native in origin. By law, the Forest Service is required to prevent and control noxious and invasive weeds on lands under their jurisdiction and to develop and implement integrated weed management programs. In response to these Federal mandates to control noxious weeds on public lands, the Forest Service has developed various policies and procedures to implement programs and activities related to the control and prevention of noxious weeds. The Forest Service assisted the Licensee in drafting this plan to ensure that it will meet their standards and requirements.

Federal Executive Order 13112 on Invasive Species defines invasive non-native plants as aggressively spreading species that have been purposefully or inadvertently introduced to the natural landscape and are likely to cause economic or environmental harm or harm to human health. This definition includes, but is not limited to, noxious weeds.

Definitions for the IWMP include the following:

Adaptive Management – An approach to resource management that includes effectiveness monitoring of management measures, and periodic reassessment and use of alternative measures if the original control measures fail to provide the anticipated protection of the target resources.

Class A noxious weeds - Non-native species with a limited distribution in the State that pose a serious threat to the State. Preventing new infestations and eradicating existing infestations is the highest priority. Control of these species is required by State law (RCW 17.10.140, and RCW 17.10.170).

Class B noxious weeds - Noxious weeds not native to the State of Washington that are of limited distribution or are unrecorded in a region of the State and that pose a serious threat to the region.

Class B designate - Class B noxious weeds whose populations in a region or area are such that all seed production can be prevented within a calendar year.

Class B select weed species - Species for which there is mandatory control in selected areas in Lewis County.

Energy Northwest 4 June 2008 Packwood Lake Hydroelectric Project Integrated Weed Management Plan

Class C weeds - Non-native species that are already widely distributed in Washington or are of special interest to the State’s agricultural industry. Placement on the State Class C noxious weed list allows counties to enforce control if locally desired.

Class C select weed species - Species for which there is mandatory control in selected areas in Lewis County.

Contain - To confine a noxious weed and its propagules to an identified area of infestation.

Control - To prevent all seed production and to prevent the dispersal of the following propagules of aquatic noxious weeds - turions, fragments, tubers, and nutlets - within a growing season.

Eradicate - To eliminate a noxious weed within an area of infestation.

Noxious weed - A noxious weed is any plant designated by a Federal, State or County government as injurious to public health, agriculture, recreation, wildlife or property. They are non-native plants that have been introduced to the State of Washington through human actions. Due to aggressive growth and lack of natural enemies in the State, these species can be highly destructive, competitive or difficult to control.

Prevent the spread of noxious weeds - To contain noxious weeds.

The IWMP covers different land ownerships where the respective management agencies are required by Federal and State law to manage identified weed infestations. Each of these management agencies has developed an invasive non-native species list. Weed species lists designated by the USDA Forest Service – Gifford Pinchot National Forest (GPNF) and the LCNWCB that currently or potentially could occur within the Project area are included in a more comprehensive list (FS, Species of Concern to the GPNF, WSNWCB Class A, B & C list and WSNWCB monitoring list) displayed in Appendix A. Each year, at the annual Resource Coordination meeting (required under the USDA Forest Service – Preliminary Mandatory Condition No. 2), the group will review and update the list of weed species to reflect the establishment of new invaders or major infestations, changing control priorities or methods, or new/updated management plans.

In this IWMP, the term “target species” is used for invasive non-native weed species that have currently been identified as occurring within the Project study area (Beck Botanical Services 2007) or that pose threat for invasion of the Project area. Table 1 displays these “target” noxious weed species.

Energy Northwest 5 June 2008 Packwood Lake Hydroelectric Project Integrated Weed Management Plan

Table 1. Target Noxious Weed Species for the Packwood Lake Hydroelectric Project Area Burdock Arctium minus Butterfly bush Buddleja davidii Diffuse knapweed Centaurea diffusa Meadow knapweed Centaurea jacea x nigra (moncktonii) Canada thistle Cirsium arvense Bull thistle Cirsium vulgare Scotch broom Cytisus scoparius Wild carrot Daucus carota Herb Robert Geranium robertianum Common St. John’s-wort Hypericum perforatum Common catsear Hypochaeris radicata Oxeye daisy Leucanthemum vulgare Reed canarygrass Phalaris arundinacea Japanese knotweed Polygonum cuspidatum Sulfur cinquefoil Potentilla recta Tansy ragwort Senecio jacobaea Common groundsel Senecio vulgaris Common tansy Tanacetum vulgare

3.0 INVENTORY AND MONITORING

Comprehensive surveys to document infestations of invasive non-native plants are a fundamental first step in any weed management program. An initial inventory of invasive non-native plant infestations provides a basis for prioritizing control efforts and setting management goals.

3.1 Initial Surveys

The initial noxious weed survey of the Packwood Lake study area was performed using commonly accepted botanical survey methods to systematically locate and identify noxious weed infestations (Energy Northwest, 2005 and Beck Botanical Services, 2007). Survey methods are straightforward and involve visually searching the study area for the presence of noxious weeds. Timing of field surveys is based on flowering times and ability to identify potential weed species. The noxious weed survey was done concurrently with the rare plant survey in 2005 and 2006.

The entire study area was searched as noxious weed species are potentially present in many of the habitat types that comprise the Packwood Lake study area, although most noxious weed infestations are typically associated with areas that have had prior ground disturbance. Where feasible, a global positioning system (GPS) unit was used to aid in mapping. The majority of plants were identified in the field using the Flora of the Pacific Northwest (Hitchcock and Cronquist, 1973).

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3.1.1 Initial Survey Results

Infestations of Class A, Class B designate weeds, Class B select weeds, and Class C select weeds were the target species for this survey because the LCNWCB requires control and/or management measures to be implemented for these categories.

Seventeen noxious weed species were located in the Packwood Lake study area (Table 2). No Class A noxious weeds were located. Locations of occurrences in the study area are shown in Figure 1. Meadow knapweed (Centaurea jacea x nigra), Canada thistle (Cirsium arvense), and reed canarygrass (Phalaris arundinacea) were found on NFS lands. Observations of Class B (non-designate), Class C weeds and GPNF Species of Concern are given for a more complete picture of the presence of noxious weed species in the study area. More information can be found on all noxious weed species at the Washington State NWCB website: http://www.nwcb.wa.gov/.

Table 2. Noxious Weed Species Observed in the Packwood Lake Study Area, 2005 – 2006 Common Name Scientific Name Class * Burdock Arctium minus (GPNF Species of Concern) Butterfly bush Buddleja davidii C select Diffuse knapweed Centaurea diffusa B designate Meadow knapweed Centaurea jacea x B designate nigra (moncktonii) Canada thistle Cirsium arvense C select Bull thistle Cirsium vulgare C Scotch broom Cytisus scoparius B non-select Wild carrot Daucus carota B Herb Robert Geranium robertianum B Common St. John’s-wort Hypericum perforatum C Common catsear Hypochaeris radicata B Oxeye daisy Leucanthemum vulgare B Reed canarygrass Phalaris arundinacea C select Japanese knotweed Polygonum cuspidatum B select Sulfur cinquefoil Potentilla recta B non-select Tansy ragwort Senecio jacobaea B non-select Common groundsel Senecio vulgaris C Common tansy Tanacetum vulgare C * Refer to text for noxious weed Class definitions.

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3.2 Annual Inventory

Annual surveys will be conducted as necessary for invasive non-native plant species in specific areas where the probability of weed infestation establishment is high (e.g., disturbed sites and high use recreation areas), and where monitoring effectiveness of control methods is needed (see Section 5.4). Prior to conducting the annual surveys, the Licensee will consult with the Forest Service, Lewis County, and other interested stakeholders at the annual Resource Coordination meeting to update the list of invasive non-native species known or potentially occurring in the area, prioritize the survey areas, and develop a schedule and tracking mechanism to ensure that inventories occur at the appropriate time.

Noxious weed inventory of the entire implementation area will occur every 10 years and will be coordinated with the rare plant surveys. Survey frequency of some properties or infestations may be reduced at a future date as agreed by the Licensee and the agencies at the annual Resource Coordination meeting. Surveyors will record noxious weed species composition, location, and relative abundance on each property, including GPS coordinates documenting the boundaries of infestations of high-priority Class A weeds, and Class B or C select, if present. Methods for field surveys on NFS lands will meet USDA Forest Service protocols and will follow the procedure established in the Noxious Weed Survey Study Plan (Energy Northwest, 2005) or current methodologies being employed at the time and agreed upon by the Licensee in consultation with the Forest Service for NFS lands. Surveys will collect all data required to meet USDA Forest Service standards described in the Invasive Plant Inventory Form (USDA Forest Service, 2006) (Appendix D). The FOREST SERVICE prefers that Licensee staff or contractors collect the data using hand held computers with GPS capability. The invasive mobile software and computer training will be provided by the FOREST SERVICE. The Invasive Species Mobile application is a Personal Data Recorder (PDR) and PC desktop application used to collect field data related to invasive species inventory and treatments. The application loads the data into both NRIS and FACTS at the FOREST SERVICE-NITC Data Center in Kansas City. The Licensee would be responsible for data quality and completeness and to assure the data will successfully pass screens and can be downloaded to database.

3.3 Monitoring (Non-Treated Sites)

The Licensee will be responsible for monitoring infestations that have been identified but are currently not being controlled. Information collected will be the same as that collected for the annual surveys. Data collection, quality and completeness would be the same standard as described in Section 3.2.

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4.0 PREVENTION

A primary objective of the IWMP is to prevent the spread and establishment of invasive non-native species from construction and other Project-related activities. Without specific prevention measures, including best management practices (BMPs) and revegetation, Project-related activities have the potential to spread invasive non-native plants or create the requisite conditions for the establishment of new infestations. Prevention measures, including BMPs and re-vegetation, will be implemented for any activity that involves ground disturbance including, but not limited to, erosion control, road maintenance construction, and habitat enhancement.

4.1 Best Management Practices

Implementation of BMPs can prevent or reduce the establishment and spread of invasive non-native plants. The Licensee will be responsible for implementing appropriate BMPs to prevent the spread or establishment of invasive non-native plants in the Project area from Project-related activities. BMPs are discussed in more detail in the following sections.

4.1.1 Training

The Licensee will initiate efforts to educate its personnel as to the need for prevention, early detection, and control of invasive weed infestations. The Licensee’s personnel will receive awareness training, addressing at minimum the following topics:

Invasive weed policy,

Environmental and economic impacts of invasive weeds,

Invasive weed vectors, particularly movement of contaminated soil,

Recognition of key invasive weeds (common species and new invaders), and

Invasive weed reporting procedures and name of responsible Licensee personnel.

4.1.2 Activity Planning and Scheduling

Construction and maintenance activities will be planned and scheduled to minimize the spread of invasive non-native plants in areas with existing infestations. This is particularly applicable to vegetation clearing and maintenance activities that involve ground disturbance. The Licensee’s personnel will use the weed location map and database to help plan maintenance activities, and when possible, will incorporate one or both of the following measures:

Treat existing infestations prior to the start of the activity. If possible, the Licensee’s personnel will treat known infestations of priority species prior to initiating vegetation management activities.

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Begin in weed-free areas and work toward infested sites. The map and database will identify the locations of invasive non-native plant infestations relative to the planned activities. Where possible, the Licensee will initiate ground-disturbing activities in weed-free locations and work toward infested areas. This sequence can minimize the spread of weed seeds and/or rhizomes via equipment and vehicles.

Perform work in and through invasive non-native plan infestations prior to seed set or after dispersal. When possible, the Licensee will schedule specific maintenance activities to avoid the time of seed set.

4.1.3 Equipment and Vehicle Cleaning

Vehicles are effective at transporting weed seeds and plant parts over long distances. The Licensee will implement a cleaning program that involves power spraying with water to remove seeds, plant material, soil, or mud from equipment and vehicles. The Licensee will inspect all equipment, including that used by contractors, to insure that it is clean before it is allowed on project area job sites. In general, this program will apply to the following:

Boats, nets, fish traps, and other field gear (waders, hip boots, buckets, etc.) used in waters outside of Packwood Lake;

Equipment used off of paved or gravel roads that arrive from locations outside the general vicinity; and

Vehicles that have been used off paved or gravel roads where known infestations of noxious weeds occur.

4.1.4 Minimize Ground Disturbance

Since most infestations of invasive non-native plant species are associated with disturbed areas, minimizing ground disturbance is key to preventing establishment. In general, disturbance will be limited to sites that are as small and as contained as possible to accomplish the activity at hand. To the extent possible, these sites will be placed in areas that have been disturbed previously, or where the existing weeds have been treated.

4.1.5 Use of Weed-Free Material

Sand, gravel, and other fill or borrow material used for construction activities generally contain seeds, roots, and other plant parts. Depending on its source, this material can introduce new invaders and/or common invasive non-native plants that can quickly colonize disturbed sites. Materials used on USDA Forest Service sites must be inspected by a District or Forest weed specialist and judged to be weed-free before use (USDA Forest Service Preventing and Managing Invasive Plants Record of Decision Standard 7 [2005]). It is the Licensee’s responsibility to provide the Ranger District at least 30-days notice to inspect the borrow material or site for weed-free material. If

Energy Northwest 10 June 2008 Packwood Lake Hydroelectric Project Integrated Weed Management Plan weeds are found, material may be taken from a fresh face, or the contaminated layer excavated and set aside, and/or infested sources may be treated. Sources of weed- free material will be a topic of discussion at the each annual Resource Coordination Meeting.

4.2 BMP Monitoring

Prevention measures are designed to prevent the establishment of target weeds in areas where ground-disturbing activities are scheduled. Monitoring the effectiveness of these measures is difficult since many factors may affect the outcome. The Licensee will monitor activity sites for three years where ground-disturbing actions have been completed. If no target weed species are detected during the three years, then monitoring will be discontinued and the assumption will be that the prevention measures were successful. If target weed species are detected, then the area will be treated based on the weed species and site (see Section 5.0).

4.3 Revegetation

Revegetation is critical in preventing the establishment of invasive non-native plants in areas that have been disturbed or treated for weeds. Revegetation includes planting with desired non-invasive trees and shrubs and/or seeding with certified weed-free seed mixes. The revegetation section of this plan (see Section 6.0) provides guidelines and recommendations for revegetation of disturbed or treated areas.

The Licensee will continue to engage in construction and maintenance activities as needed for normal Project operations, including vegetation management and erosion control work. However, all ground-disturbing activities conducted as part of Project operations or License compliance activities will be planned and conducted in a manner as to prevent noxious weed infestations, and will include compliance with USDA Forest Service Noxious Weed Prevention Guidelines (1999), where activities are conducted on NFS lands.

All Project plans will emphasize minimization of ground disturbance. Sites will be evaluated for their potential to revegetate naturally from local seed sources (adjacent vegetation or seed bank). Small areas without established weed populations may regenerate without assistance. However, if sites are large with steep slopes, or already weed infested, revegetation with approved species is recommended using a mix of shrubs and grasses approved in advance by the Forest Service and the LCNWCB. Revegetation efforts will be conducted during an appropriate season (usually spring), and monitored at least annually. Appropriate erosion control measures (e.g., geotextiles or wattles) will be installed in disturbed areas until revegetation is complete.

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5.0 CONTROL AND MONITORING

There is no single effective treatment for controlling all invasive non-native plants. Weed treatment methods include manual, mechanical, cultural, chemical, and biological techniques. Controlling infestations of most species requires integrating a variety of treatment methods depending on target species, infestation characteristics, infestation location, and treatment objectives. At each infestation, the Licensee will consult with the Forest Service, the LCNWCB, and other interested stakeholders to determine site objectives for the infestation (e.g., containment, control or eradication).

5.1 Treatment Plans

At each treatment site, the species, its biological characteristics, infestation characteristics, location, site objectives, and available treatment methods will be considered in developing a treatment plan. Treatment plans will be consistent with the underlying land ownership and jurisdictional requirements. Monitoring and effectiveness analysis will be used to determine if selected control methods are providing the desired results. The following factors will be considered when selecting the control measure(s) to be applied to any given infestation:

Target species’ biological characteristics:

Growth characteristics (annual, biennial, or perennial) Growth form (grass, forb, shrub, or tree) Root structure (fibrous, tuber, bulb, tap, or rhizome) Reproductive strategy (sexual, asexual, or vegetative) Seed viability/dormancy Seed dispersal mechanism Species known response to control methods Allelopathic properties of the species Shade tolerance (ability invade under canopy)

Infestation characteristics:

Size and density of the infestation Single or multi-species infestation Presence and density of desired species New invader or naturalized

Location factors:

Proximity to water Land ownership

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Slope Access Proximity to transportation vectors Soil type Proximity to threatened, endangered, or sensitive (TES) species or culturally sensitive species or habitats

Site treatment objective:

Treatment goal (contain, control, or eradicate) Legal constraints (i.e., land ownership and existing LRMP, Resource Management Plans, etc.) Available treatment methods

5.2 Control Method Tool Box

In general, control efforts will be focused on infestations of priority invasive non-native plants in areas where there is thought to be the greatest chance of success. Noxious weed treatment methods can be grouped into several categories including manual, mechanical, cultural, chemical, and biological. Treatment measures should be followed by revegetation (see Section 6.0) when it is unlikely that surrounding native vegetation will readily recolonize the area.

5.2.1 Manual Methods

Manual control involves any non-mechanized approach to control or eradicate invasive non-native plants (USDA Forest Service, 2005). Manual methods for the control include the following:

Hand pulling - Physically pulling invasive non-native plants from the soil.

Cutting/lopping/clipping - Using shears, clippers, or brush saws to sever aboveground parts of plants.

Mulching - Covering plants with black plastic or jute to deprive them of sunlight.

Grubbing - Using a Pulaski, hoe, or shovel to remove entire plants, including roots, from the ground.

In general, hand pulling, cutting, and grubbing have relatively limited use in controlling populations of invasive non-native plants; these methods are labor intensive and not applicable to large areas. They do not reduce seeds in the soil or fully eliminate root systems. Some species may resprout after being cut or pulled. Because seeds of some species can remain viable for many years, other follow-up methods may be necessary to supplement manual methods. Although hand removal of weeds can be selective and minimize effects to surrounding vegetation, trampling damage and/or soil

Energy Northwest 13 June 2008 Packwood Lake Hydroelectric Project Integrated Weed Management Plan disturbance can sometimes be worse than mechanical methods. Manual methods will usually be restricted to infestations less than one acre in size or the treatment of scattered individuals over a larger area that are either just beginning to invade or remaining following application of another control method.

5.2.2 Mechanical Methods

Mechanical methods to treat terrestrial species of invasive non-native plants are typically power driven and include, but are not limited to, the following:

Cutting - Using chainsaws and other power tools to remove the branches and stems from woody invasive non-native plants.

Mowing - Cutting invasive non-native plants by mowing with a rotary head attached to tractors or rubber-tired vehicles, weed-eater, or high-wheel mower.

Discing/plowing - Using a tractor-pulled disc or plow to blade and turn the soil in areas infested with invasive non-native plants.

Power tools can be effective in controlling invasive non-native shrub species, such as Scotch broom. They can be used selectively to avoid or minimize damage to nearby desirable vegetation. Power tools can also be used near water and result in minimal soil disturbance. However, mechanical cutting methods have the same disadvantages as hand cutting in that they do not reduce seeds in the soil or eliminate roots, and are practical only in small areas. Mowers can be effective in controlling some invasive non- native plant species over large areas if used at the appropriate time. Mowers, however, are nonselective, cannot be used on steep or rocky sites, do not kill roots, and may spread weed seeds. Discing/plowing is also non-selective and limited by terrain and soil type. This method can be effective in killing roots and preventing resprouting for some species, but results in substantial soil disturbance and may spread rhizomes.

5.2.3 Cultural Methods

Cultural methods for treating invasive non-native terrestrial plant species involve measures that help establish or maintain competitive native vegetation. Cultural methods include the following:

Grazing - Using livestock (cattle, sheep, or goats) to reduce the aboveground portions of plants.

Seeding, mulching, and fertilizing - Planting and amending the soil to provide the existing or seeded desirable vegetation a competitive advantage (see Section 6.0).

Burning - Using fire to remove or reduce the aboveground portions of plants and seed banks.

Irrigation - Using water to give the competitive edge to desirable species.

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Grazing, particularly by cattle, has been used with mixed results, to control infestations of invasive non-native plants over relatively large areas. Goats, horses, sheep, and even geese have been used to control weed infestations. In recent years, the use of goats to control infestations of invasive non-native species has gained popularity because they are browsers, not grazers, and, therefore, eat a variety of forbs and shrubs, including knapweed and yellow starthistle. While goats do not compact the soil as do cattle, they need to be contained to effectively reduce weed populations, and thus require fencing and/or tending. Goats are also not selective and are best used to control dense infestations. Grazing with goats is generally more effective when the plants are flowering or fruiting. Grazing does not reduce seeds in the soil or eliminate root systems, and as a result some species may resprout.

Seeding, combined with mulching and fertilizing, is typically not used to control existing infestations of invasive non-native plants. Seeding is more often used on disturbed sites to prevent the establishment of invasive non-native plants or used to restore sites that have been previously treated (see Section 6.0). Crested wheatgrass, Sherman big blue, Magnar rye grass, and other grass species have been shown to be competitive with knapweeds when seeded after a chemical treatment.

Fire can be effective in controlling some invasive non-native species such as diffuse knapweed. It is usually more effective when used just before flowering or seed set or at the seedling/sapling stage. It also can be useful in reducing the residual biomass of an infestation so other treatments such as herbicide applications will be more effective. In addition, fire can sometimes stimulate the germination of both native and non-native species.

Irrigation has been used to favor establishment of desirable vegetation in arid environments. Once desirable vegetation has been established, irrigation can be scaled back or discontinued, depending on the vegetation's moisture requirements.

5.2.4 Chemical Methods

Chemical methods involve the use of naturally derived or synthetic chemicals, otherwise referred to as herbicides, to eliminate or control the growth of invasive non-native plants (USDA Forest Service, 2005). The effectiveness of any herbicide depends on the application rate, climatic conditions, timing, and the species on which it is applied. Some herbicides are specific to broadleaf plants but do not kill grasses. Others are not selective and kill both broadleaf plants and grasses. Several herbicides have aquatic formulas that allow for use in or near water. Few of the herbicide compounds inhibit seed germination in the soil.

All pesticides, which include herbicides, insecticides, and fungicides, sold in the United States are required by the Federal Insecticide Fungicide, Rodenticide Act (FIFRA) to have labeling that contains, at a minimum, the following information: application rates, health warnings, clean-up and disposal directions, personal protection equipment requirements, target species, and restrictions. All herbicide applicators are required by

Energy Northwest 15 June 2008 Packwood Lake Hydroelectric Project Integrated Weed Management Plan law to follow the label. Application rates can be less than the label recommendations, but only in a few circumstances with regulatory approval can application rates be exceeded. All herbicide use by the Licensee or their contractors will be in accordance with the label.

The Project area covers several ownerships, including Federal and private lands. Federal lands have written guidelines that are specific to which herbicides have been approved for weed control. will contract with licensed pesticide applicators to conduct Project-related herbicide treatments on Federal and non-licensee owned lands. Herbicide use on these lands will be in accordance with relevant management plans. The USDA Forest Service Record of Decision (ROD) for the Pacific Northwest Region Invasive Plant Program approved the use of 10 different herbicides in the Pacific Northwest Region (USDA Forest Service, 2005). The associated environmental impact statement (EIS) amends all forest plans in the Region and establishes uniform standards for treatment. In addition, the Gifford Pinchot National Forest is currently preparing a site-specific EIS that is tiered to the ROD that would allow the use of select herbicides to treat specific infestations. The herbicides approved by the ROD (USDA Forest Service, 2005) are listed in Table 3.

In general, care must be taken to avoid spraying non-target species. Herbicides can be applied as spot treatments to individual plants or a small area by hand using a squirt bottle, spray gun, backpack spray unit, or truck-mounted sprayer with a handgun. Herbicide application on larger areas can be accomplished by broadcasting with a spray gun, broadcast nozzle, or boom attached to a track, all-terrain vehicle (ATV), or tractor. Broadcast application should be limited to large, dense infestations where there is minimal risk of affecting non-target species. Herbicide applications must follow label directions (including application rates, target species, application types, and personal protection equipment). Buffers should be established around Threatened, Endangered, and Sensitive (TES) and culturally sensitive plant populations and streams when using broadcast applications of certain herbicides.

A pesticide use proposal must be filled out each season prior to use when herbicide use is planned on NFS lands. All pesticide use must be reported in format complete and suitable for entry in the Forest Service FACTS database, in addition to State reporting. At least 50% of all areas treated with pesticide must be monitored and the monitoring report entered into FACTS.

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Table 3. Herbicides Approved for use in Pacific Northwest Region 6 (Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005, selected from Table 3-13, p. 3-91, 3-92) Chemical/ Selected Brand Names/ General Uses/ Action Properties Known to be Effective On: Chlorsulfuron (Telar, Glean - Selective pre-emergent Use at very low rates on annual, Glean, Corsair)/ or early post-emergent. biennial, and perennial species; Sulfonylurea Telar – Selective pre- and post- especially Dalmatian toadflax, and Interferes with enzyme emergent. houndstongue and perennial acetolactate synthase w/ Both are for many annual, pepperweed. rapid cessation of cell biennial, and perennial division and plant growth broadleaf species. in shoots and roots. Clopyralid (Transline)/ A highly translocated, selective Particularly effective on Asteraceae, Synthetic auxin. Mimics herbicide active primarily Fabaceae, Polygonaceae, Solanaceae. natural plant hormones. through foliage of broadleaf Some species include knapweeds, species. yellow starthistle, Canada thistle, Little effect on grasses. hawkweeds. Provides control of new germinants for one to two growing seasons. Glyphosate A broad spectrum, non- Low volume applications are most (RoundUp, Rodeo, etc.)/ selective translocated herbicide effective. Translocates to roots and Inhibits three amino acids with no apparent soil activity. rhizomes of perennials. and protein synthesis. Adheres to soil which lessens While considered non-selective, or retards leaching or uptake sensitivities do vary depending on by non-targets. species. Main control for purple loosestrife, herb Robert, English ivy and reed canarygrass. Aquatic labeled formulations can be used near water. Imazapic Used for the control of some Use at low rates can control leafy (Plateau)/Inhibits the plant broadleaf plants and some spurge, cheatgrass, medusa head rye, enzyme acetolactate, grasses. toadflaxes, and houndstongue. which prevents protein synthesis. Imazapyr (Arsenal, Broad spectrum, non-selective Most effective as a post-emergent. Has Chopper, Stalker Habitat)/ pre- and post-emergent for been used on cheatgrass, whitetop, Inhibits the plant enzyme annual and perennial grasses perennial pepperweed, dyers woad, acetolactate, which and broadleaf species. tamarisk, woody species, and spartina. prevents protein Aquatic labeled formulations can be synthesis. used near water. Metsulfuron methyl Used for the control of many Use at low rates to control such (Escort)/ Sulfonylurea broadleaf and woody species. species as houndstongue, sulfur Inhibits acetolactate Most susceptible crop species cinquefoil perennial pepperweed. synthesis, protein in the Lily family (i.e. onions, synthesis inhibitor, block Allium). Safest sulfonylurea Sethoxydimformation of amino (Poast)/ acids. aroundA selective, non-target post-emergent grasses. Will control many annual and perennial PicloramInhibits acetyl (Tordon)/ co-enzyme, Selective,grass herbicide. systemic for many grassesUse at low such rates as tocheatgrass. control such Restricteda key step Usefor synthesis Herbicide of annual and perennial broadleaf species as knapweeds, Canada thistle, Syntheticfatty acids. auxin. Mimics herbs and woody plants. yellow starthistle, houndstongue, natural plant hormones. toadflaxes, sulfur cinquefoil, and hawkweeds. Provides control of new germinants for two to three growing seasons.

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Sulfometuron methyl Broad spectrum pre- and post- Used at low rates as a pre-emergent (Oust)/ Sulfonylurea emergent herbicide for both along roadsides. Known to be effective Inhibits acetolactase broadleaf species and grasses. on reed canarygrass.(but not labeled synthase, a key step in for aquatic use), cheatgrass, and branch chain amino acid medusahead. synthesis. Triclopyr (Garlon, A growth regulating selective, Not for broadcast application under Pathfinder, Remedy)/ systemic herbicide for control proposed action. Effective for many Synthetic auxin of woody and broadleaf woody species such as scotch broom Mimics natural plant perennial weeds. and blackberry. Also effective on hormones. Little or no impact on grasses. English ivy, Japanese knotweed. Amine formulation may be used near water.

Risk information found in SERA documents (2,4-D 1998, Triclopyr 2003, Picloram 2003, Sethoxydim 2001, Glyphosate 2003, all others 2004) for each active ingredient. Information on species effectiveness in Tu et al. (2001) or from product labels. * The list of herbicides for use on NFS lands will be re-evaluated and updated as necessary based on USDA Forest Service management direction.

5.2.5 Biological Controls

Biological controls have not received the required analysis for use in Region 6 of the USDA Forest Service, and, therefore, may not be used currently on NFS lands.

Insects, diseases, and other pathogens attack plants affecting survival and productivity. However, many non-native plants lack natural enemies, which give them a competitive advantage over native species. Biological control is defined as the use of non-native agents including invertebrate parasites and predators, and plant pathogens, to reduce populations of non-native invasive plants (USDA Forest Service, 2005). Biological control works best when there are several insects or pathogens per plant species. However, not all noxious weed species have available biological controls. In addition, the effectiveness of biological controls is variable, differing for each noxious weed species and site (Bonneville Power Administration, 2000). Some can be extremely slow acting, taking 30 years to have a noticeable effect. Others may reduce seed production or inhibit shoot and root growth, but not significantly reduce plant density or cover (Carpenter and Murray, 1998a, 1998b, and 1998c). None of the known biological controls prevent germination from seed reserves in the soil. A good summary of biological control information is available in Rees et al. (1996).

Biological controls have two effects on invasive non-native species - a direct impact by destroying plant tissue and an indirect impact by stressing the species and reducing its ability to compete with desirable species. Biological controls can be distributed by helicopter over large areas or transported to specific sites by vehicle or on foot. Biological controls are also used to reduce populations of naturalized nuisance species and noxious weed infestations in remote areas.

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5.3 Project Specific Management

This section describes the initial management direction for properties covered by the IWMP based on the initial surveys conducted in 2005 and 2006 (Beck Botanical Services, 2007). See Appendix B for Description, General Location and Common Control Measures For Invasive Plants Of The Pacific Northwest Region and Appendix C for Description, General Location and Summary Of Control Measures For Other Noxious Weeds Occurring Within The Project Boundary.

5.3.1 Zone A - Packwood Lake Shore above the Drop Structure

To protect the Goat Rocks Wilderness, the goal for this zone will be eradication of non- native plants.

The wilderness boundary extends around approximately two-thirds of the lake shore and is located at the ordinary high water mark. The Project boundary is located at elevation 2860 feet MSL and is generally located within a few feet of the Lake and wilderness boundary. First priority for control will be reed canarygrass (Class C select) and Canada thistle (Class C select). The Licensee will work with the USDA Forest Service and LCNWCB. Eight patches of Canada thistle are located around the Lake, ranging in size from several stems to a patch at the southeast end of the Lake that is over an acre in size. Control of these species in the wilderness will be deferred until such time as the USDA Forest Service is ready to control these species on the adjacent wilderness property. At the time this IWMP was developed, new treatment options were available pending final appeal, if any, of the March 2008 Record of Decision and Final Environmental Impact Statement for the Site-Specific Invasive Plant Treatment Project and Forest Plan Amendment. A plan and schedule for the treatment of these weeds will be developed in consultation with the USDA Forest Service.

Other invasive plants that have been observed in this zone include tansy ragwort, bull thistle, and common groundsel. These second priority plants will be controlled when there is a practical opportunity, possibly in conjunction with the annual survey, or when chemical controls are scheduled for reed canarygrass and Canada thistle. In general, pulling weeds is not allowed around the lake shore because of heritage concerns. Plants may be cut at ground level, getting as much of the crown as possible. Cutting is not effective for reed canarygrass and Canada thistle. Pulling is allowed in all other zones.

5.3.2 Zone B - Wilderness Buffers

This zone includes all access routes to the Lake from trailheads or parking lots. It includes FS Road 1262 (Latch Road) above the gate, FS Road 1260-066 (Pipeline Road) and the parking lot, and FS Trail #74 and Dyson Pass cutoff.

Control of reed canarygrass and Canada thistle is legally required by LCNWCB at wilderness trailheads to protect wilderness. Reed canarygrass will be controlled by the

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Licensee on the Latch Road above the gate, where it is well established. Shade will be maintained and promoted as much as possible on this road to discourage weeds.

5.3.3 Zone C - Powerhouse Area to Stilling Pond, and Penstock below Surge Tank

Scotch broom is established around the Powerhouse clearing, and is invading adjacent USDA Forest Service roads. Some scotch broom plants are also established on the penstock corridor below the surge tank. These scotch broom plants will be controlled (not allowed to set seed) by the Licensee to protect adjacent forest from establishment of a seed bank that would enable invasion of adjacent managed forest areas such as thinning units in the future.

5.3.4 Zone D - Other Travel Corridors

This zone includes FS Road 1260 (Snyder Road) from surge tank to parking lot. Control meadow knapweed and scotch broom to prevent spread of weeds by vehicles and by the movement of soil during road maintenance.

The Licensee will work with the USDA Forest Service and LCNWCB to control the meadow knapweed population where it occurs in the Implementation Area (see Section 1.1). Known populations are located along FS Road 1260 (Snyder Road) and along FS Road 1262 (Latch Road). Efforts by the Licensee will be coordinated with the USDA Forest Service and the road maintenance plan (Packwood Lake Recreation Plan, 2008). There have been on-going control efforts by the USDA Forest Service and LCNWCB regarding the meadow knapweed and scotch broom at the junction of FS Road 1260 (Snyder Road) and FS Road 1262 (Latch Road). In the past, the population has been treated by hand pulling.

5.3.5 Zone E - Project Area below Stilling Pond

The valley is heavily infested with weeds such as reed canarygrass, scotch broom, and Himalaya and cutleaf blackberries. These species are not designated for control in this zone by this plan.

There is a small diffuse knapweed population along the tailrace west of Highway 12. Most of the larger population that probably serves as a seed source is outside the Project boundary on Lewis County property. The LCNWCB has been treating plants at the County site on an on-going basis. The Licensee will control (prevent all seed set) any diffuse knapweed within the Implementation Area (see Section 1.1) by hand pulling and/or application of herbicides.

Several butterfly bush plants (2 to 3 individuals) were located near where the tailrace enters the Cowlitz River. The Licensee will control any butterfly bush plants by hand pulling. Flower spikes will be deadheaded to prevent the spread of seeds.

Energy Northwest 20 June 2008 Packwood Lake Hydroelectric Project Integrated Weed Management Plan

A small population of Japanese knotweed is located on private lands along a side channel of the Cowlitz River approximately 100 feet upstream of Lake Creek. It is a previously known population that the LCNWCB has been treating for several years. Since this population is located on private land, and is currently be managed by the LCNWCB, the Licensee does not propose any treatment or weed management for this area.

5.4 Monitoring and Effectiveness Analysis

The Licensee will be responsible for monitoring, evaluating and reporting the effectiveness of control methods used to treat infestations. Monitoring of treatment areas is important for determining the effectiveness of the control method(s) (including revegetation), evaluating the recovery of non-target species, and determining if infestation site objectives are being met. At each treatment site, a data sheet will be completed. The information collected will be the same as the inventory methods to facilitate effectiveness analysis and reporting.

The monitoring duration or timeframe will be based on the management objectives for each infestation. At least 50% of the area treated for weeds on NFS lands each year must be monitored and the reports entered into the Forest Service FACTS database. Annual monitoring will be conducted where the objective is to control and contain the infestation (see Section 3.2). Where eradication is the objective, the site will be monitored annually until five years of monitoring data indicate that no target species are detected and the desired vegetation community is present.

Monitoring data will be analyzed to determine whether control strategies are effective in meeting infestation management objectives. Treatment effectiveness will be analyzed on a site-specific basis, depending on the management objective. The analysis will be used to update and change, if necessary, the method of treatment, as well as schedule retreatment or revegetation activities. Effectiveness analysis is particularly important since different or new methods may become more appropriate over time.

Energy Northwest 21 June 2008 Packwood Lake Hydroelectric Project Integrated Weed Management Plan

6.0 REVEGETATION METHODS

Research has shown that most healthy, diverse plant communities are relatively weed- resistant (Sheley and Petroff 1999). Managing for self-sustaining, diverse, and healthy plant communities is the objective of any weed management plan. Through introducing and establishing competitive vegetation, managers often times can accelerate the recovery of weed-infested or disturbed areas to a weed-resistant plant community, but this is often difficult and expensive. However, the end results of these revegetation projects have the potential to restore watershed function, create wildlife habitat, and reduce the annual cost of weed management.

Successful revegetation of disturbed or treated areas requires a detailed evaluation of the site, establishing obtainable objectives, monitoring, follow-up control and patience. Many factors determine the success or failure of restoration projects. External environmental factors such as precipitation, natural herbivory, and local weather patterns are uncontrollable. However, many aspects of revegetation projects are known and therefore should be considered when planning to revegetate a site. Some of these factors include the physical site characteristics (soil, slope, access, and vegetation present), average precipitation, site potential, seed bank, site history, and seed availability. Outlined below are the steps that the Licensee will use when assessing weed treatment sites for revegetation.

6.1 Determining Site Revegetation Needs

The annual treatment monitoring and the effectiveness analysis will determine if a site requires revegetation. Generally, after weed treatments, if there is one desirable perennial species every 10 to 15 feet, then the site will revegetate on its own and little seeding will be necessary (Mattox, 2005). If little or none of the desirable species are present the year following the final weed treatment, then revegetation planning will begin. The annual monitoring analysis should indicate if the site is moving toward the site objectives. If the annual monitoring indicates that the site is not responding positively, an analysis will be conducted to determine what actions are necessary to revegetate the site. A worksheet to aid with the Revegetation/Rehabilitation/Restoration analysis is provided in Appendix E.

6.2 Revegetating the Weed Treatment Site

Establishing desired vegetation on treatment sites after weed treatments requires several steps. The first step is to evaluate the site to determine possible constraints, challenges, and site objectives. The next step is to define the revegetation strategy for achieving the site objectives. The final step is to implement the revegetation strategy using various methods. The monitoring strategy described above will be used to determine when a site will be considered revegetated.

Energy Northwest 22 June 2008 Packwood Lake Hydroelectric Project Integrated Weed Management Plan

6.2.1 Site Evaluation

Many physical factors will determine the success or failure of the revegetation project. Evaluating the site and possible limitations can reduce the potential for failure. Physical factors to be included in the site revegetation rehabilitation restoration analysis include the following:

Soil type (USDA soil surveys)

Aspect

Slope

Potential plant community

Existing plant community in the treatment area

Surrounding plant communities

Site history (disturbance history, soil compaction)

Vehicle and equipment access

Presence of residual biomass (dead weeds)

Erosion potential

6.2.2 Site Revegetation Objectives and Strategy

Based on the physical site evaluation, available plant material, treatment constraints, and approved revegetation methods, the site-specific objectives for the treatment site can be determined and a revegetation strategy formulated. The focus of the site revegetation objective is to determine the desired species composition and density for the site. The strategy will outline a methodology to achieve the site objectives based on any constraints (physical, social, or political) that may exist.

6.2.3 Revegetation Methods

Determining what species to plant, how and when to plant, seed mix composition, and site preparation are several of the decisions that need to be made if reseeding is warranted. Outlined below are several of the factors that need to be addressed when formulating the site revegetation strategy.

Seed Mix Composition and Seeding Rates

The seed mix should contain a mixture of species (annual and perennial) forbs, shrubs and grasses that are adapted to the site and soil type present. This diversified mix increases the potential that all available niches will be occupied, making it more difficult for undesirable species to become established. Seed establishment rate is also a consideration when choosing species. If the site has the potential to be reinvaded by undesirable plants, then a species that quickly occupies the site would be best. It may be necessary first to plant short-lived non-native species to compete with the

Energy Northwest 23 June 2008 Packwood Lake Hydroelectric Project Integrated Weed Management Plan undesirable vegetation and reduce erosion potential. Once the weed seed bank is depleted, the site can be over-seeded with desirable species. Seeding rates will differ depending on seeding method, seed size and weight, seed availability, seed performance, and revegetation objectives. Even though the use of weed-free seeds is required, it does not guarantee that unwanted species will not be introduced into the area.

Seeding Methods and Site Preparation

Various methods exist to seed areas including broadcast, broadcast and harrow, drill, and no-till drill. The seeding method is usually limited by the site's physical characteristics, existing vegetation, and equipment access. The seeding rate will be determined by the seeding method and the desired plant density. Generally, the seeding rate is reduced with methods that increase the seed-to-ground contact (drill and harrowing). Site preparation may be used to help desired vegetation become established. Site preparation can include, but is not limited to burning, discing, plowing, and adding soil amendments. Caution must be used when utilizing any method that creates surface disturbance as this may favor undesirable species present on the site. Removal of dead, dying biomass to increase the potential for seed-to-ground contact can increase germination rates and stand establishment.

Treatment Duration

In most instances, treating heavy infestations of weeds will require several years to accomplish treatment objectives since seed banks in the treatment area may take years to become depleted. Information on seed viability of target weed species should be incorporated into revegetation schedules to maximize the potential for success. For example, whitetop has a seed viability of three years (meaning that it would be unwise to seed heavily infested areas before three years have elapsed after treatment). Seeding weed treatment areas will usually be scheduled in the late fall through early winter to maximize soil moisture.

6.3 Monitoring

Once a treatment area has been seeded, monitoring will determine if follow-up weed control or additional seeding/plantings are necessary to achieve the site revegetation objectives. Information collected will be the same as that for monitoring untreated infestations, treatment areas, and the annual weed surveys.

Energy Northwest 24 June 2008 Packwood Lake Hydroelectric Project Integrated Weed Management Plan

7.0 REPORTING

All IWMP provisions will be implemented by the Licensee upon Commission approval of the IWMP. Each year the Licensee will report relevant information required by the IWMP as a part of the Resource Coordination Plan Annual Report. This report will contain information from Project compliance activities under the Forest Service mandatory conditions, and will be submitted to the Forest Service and LCNWCB for review at least 30 days prior to the annual Resource Coordination meeting. At the meeting, the activities to be conducted under the IWMP will be discussed to coordinate them with other project resource management activities (e.g., rare plants, road maintenance, planned ground-disturbing activities). At the meeting, the Licensee and the Forest Service will review noxious weed management goals and techniques, evaluate management results and monitoring data, discuss conditions in the Project area, and consider any applicable changes in technology or treatments under the IWMP. The annual report will include details for activities planned under the IWMP for the coming year. The Licensee will allow a minimum of 60 days for the USDA Forest Service and other agencies to comment and make recommendations prior to filing the final annual report with the Commission for approval. If the Licensee does not adopt a recommendation, the filing will include the reasons, based on Project-specific information.

The IWMP will be reviewed at least every five years, and updated, if needed, to include changes in management guidelines and the requirements for management of weeds on NFS lands and to keep the plan contemporary with new weed management science and practices. Weed management changes in the interim may be adopted by agreement at the annual Resource Coordination meeting or other times, as necessary. The IWMP weed list should be reviewed annually to reflect changes in the LCNWCB and Gifford Pinchot National Forest weeds lists. Relevant changes to the weed list that would affect the management practices specified in the IWMP will be discussed at the annual Resource Coordination meeting. Changes in the weed list and agreed changes in the management practices will be implemented immediately, as needed, and incorporated into the next scheduled revision of the IWMP.

Energy Northwest 25 June 2008 Packwood Lake Hydroelectric Project Integrated Weed Management Plan

8.0 REFERENCES

Beck Botanical Services. 2007. Noxious Weed Survey, Revised Final Report for Energy Northwest’s Packwood Lake Hydroelectric Project, FERC No. 2244, Lewis County, Washington, Submitted to Energy Northwest by Beck Botanical Services, May, 2007

BPA (Bonneville Power Administration). 2000. Transmission system vegetation management program. Final environmental impact statement. DOE/EIS-0285. Portland, Oregon. May, 2000.

Carpenter, Alan T., and Thomas A. Murray. 1998a. Element Stewardship Abstract for Linaria dalmatica and Linaria vulgaris. The Nature Conservancy, Wildlands Weeds Management & Research, Weed Science Program, University of California, Davis, California. http://tncweeds.ucdavis.edu/esadocs/documnts/linadal.pdf

Carpenter, Alan T. and Thomas A. Murray. 1998b. Element Stewardship Abstract for Acroptilon repens, Russian knapweed. The Nature Conservancy. Arlington, Virginia. Available: http://tncweed.ucdavis.edu/esadocs/acrorepe.html

Carpenter, A.T. and T.A. Murray. 1998c. The Nature Conservancy (TNC) Element Stewardship Abstract for Centaurea diffusa. 1998-1999 TNC Weed Report, Centaurea diffusa, Diffuse knapweed. Invasive Species Team, TNC, California. http://tncweeds.ucdavis.edu/esadocs/documnts/centdif.html

Energy Northwest. 2005. Noxious Weed Survey Study Plan for Energy Northwest’s Packwood Lake Hydroelectric Project FERC No. 2244, Lewis County, Washington, Prepared by Beck Botanical Services, August 22, 2005.

Energy Northwest and USDA Forest Service. 2008. Packwood Lake Hydroelectric Project Recreation Plan, June, 2008.

Federal Executive Order 13112 - Invasive Species, Federal Register: Feb 8, 1999 (Volume 64, Number 25).

Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) http://www.epa.gov/oecaagct/lfra.html

Federal Noxious Weed Act of 1974. P.L. 93-629, 7 U.S.C. 2801, as amended. January 3, 1975.

Hitchcock, C. L. and A. Cronquist. 1973. Flora of the Pacific Northwest. University of Washington Press. Seattle and London.

Lewis County Noxious Weed Control Board (LCNWCB), 2008 Noxious Weed List https://fortress.wa.gov/lewisco/home/lc/weedcontrol/Default.aspx?lcID=134

Energy Northwest 26 June 2008 Packwood Lake Hydroelectric Project Integrated Weed Management Plan

LCNWCB, Noxious Weed Management Plan, Lewis County Noxious Weed List & Action Levels, Appendix One, February 2008.

Mattox, M. 2005. Rangeland/pasture restoration. Rangelands Vol. 27, No. 6, pp 20-21. Wheat Ridge, Colorado.

Rees, N.E., R.W. Pemberton, N.R. Spencer, P.C. Quimby, and R.M. Nowierski. 1996. Spurge, pp. 1-36. In Rees, N.E., P.C. Quimby, G.L. Piper, C.E. Turner, E.M. Coombs, N.R. Spencer, and L.V. Knutson (eds.). Biological Control of Weeds in the West. Western Society of Weed Science and Montana State University, Bozeman, Montana, USA.

Revised Code of Washington (RCW) Title 17, Chapter 17.10 Noxious Weeds – Control Boards. http://apps.leg.wa.gov/RCW/default.aspx?cite=17.10

Sheley, Roger L. and Janet K. Petroff. 1999. Biology and Management of Noxious Rangeland Weeds. Oregon State University Press. April, 1999.

USDA Forest Service (USFS). 1990. Final environmental impact statement and land and resource management plan. Gifford Pinchot National Forest. USDA-FS Pacific Northwest Region, Portland, Oregon.

USDA Forest Service. 1995. Gifford Pinchot National Forest. Land and resource management plan amended by the Northwest Forest Plan of 1994.

USDA Forest Service. 2001. USDA Forest Service Noxious Weed Prevention Guidelines, (July 5, 2001). http://www.fs.fed.us/rangelands/ecology/invasives.shtml

USDA Forest Service. 2005. The Record of Decision for the Pacific Northwest Region Invasive Plant Program – Preventing and Managing Invasive Plants. October, 2005. http://www.fs.fed.us/r6/invasiveplant-eis/.

USDA Forest Service. 2006. Common Control Measures for Invasive Plants of the Pacific Northwest Region, March 31, 2006; Editor’s note added August 9, 2006.

USDA Forest Service. 2008. The Record of Decision and Final Environmental Impact Statement and Forest Plan Amendment #20 – Gifford-Pinchot National Forest and Columbia River Gorge National Scenic Area (Washington Portion) Site-Specific Invasive Plant Treatment Project and Forest Plan Amendment. March 2008. http://www.fs.fed.us/r6/invasiveplant-eis/site-specific/GIP/

Washington Administrative Code. Title 16, Chap.16-228, General Pesticide Rules. http://apps.leg.wa.gov/WAC/default.aspx?cite=16-228

Energy Northwest 27 June 2008 Packwood Lake Hydroelectric Project Integrated Weed Management Plan

Washington Administrative Code. Title 16, 16-750 Sections 005, 011, 015 State Noxious Weed Lists. http://apps.leg.wa.gov/WAC/default.aspx?cite=16-750

Washington Administrative Code. Title 16,16-752 Noxious Weed Control. http://apps.leg.wa.gov/WAC/default.aspx?cite=16-752

Washington State Noxious Weed Control Board, Weed List. http://www.nwcb.wa.gov/weed_list/weed_list.htm

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Packwood Lake Hydroelectric Project Integrated Weed Management Plan

APPENDIX A

Washington State Noxious Weed List 2008 with GPNF Weeds of Concern

(Compiled from WAC list at http://apps.leg.wa.gov/WAC/default.aspx?cite=16-750; and monitor list from http://www.nwcb.wa.gov/documents/weed%20lists/Monitor_List06.pdf; 11/7/2007. Updated with new spp from WA NWCB website 5/19/08.)

Energy Northwest June 2008

Packwood Lake Hydroelectric Project IWMP Appendix A - Noxious Weed Lists

Washington State Noxious Weed List 2008 with GPNF Weeds of Concern*

Scientific Name Common Name Class

Abutilon theophrasti velvetleaf A Acroptilon repens knapweed, Russian B Adonis annua Blooddrops monitor Aegilops cylindrica goatgrass, jointed C Alhagi maurorum camelthorn B Alliaria petiolata mustard, garlic A Alopecurus myosuroides blackgrass B Ambrosia tomentosa Bursage, skeletonleaf monitor Amorpha fruticosa indigobush B Anchusa arvensis bugloss, annual B Anchusa officinalis bugloss, common B Anthriscus sylvestris chervil, wild B Arctium minus burdock GP concern Artemisia absinthium wormwood, absinth C Berteroa incana alyssum, hoary B Brachypodium sylvaticum slender false brome not on WA list, suspected Bryonia alba bryony, white B Buddleja davidii butterfly bush C Cabomba caroliniana fanwort B Cardaria draba cress, hoary C Cardaria pubescens whitetop, hairy C Carduus acanthoides thistle, plumeless B Carduus nutans thistle, musk B Carduus pycnocephalus thistle, Italian A Carduus tenuiflorus thistle, slenderflower A Carthamus lanatus Thistle, distaff monitor Cenchrus longispinus sandbur, longspine B Centaurea calcitrapa starthistle, purple A Centaurea diffusa knapweed, diffuse B Centaurea jacea knapweed, brown B Centaurea jacea x nigra knapweed, meadow B Centaurea macrocephala knapweed, bighead A Centaurea nigrescens knapweed, Vochin A Centaurea solstitialis starthistle, yellow B Centaurea stoebe knapweed, spotted B Centaurea tricocephala Knapweed, featherhead monitor Chondrilla juncea skeletonweed, rush B Cirsium arvense thistle, Canada C Cirsium vulgare thistle, bull C Clematis orientalis Clematis, Chinese monitor Clematis vitalba beard, old man's C Conium maculatum poison-hemlock C Convolvulus arvensis bindweed, field C Cotoneaster spp cotoneaster GP concern

Energy Northwest A-1 June 2008 Packwood Lake Hydroelectric Project IWMP Appendix A - Noxious Weed Lists

Washington State Noxious Weed List 2008 with GPNF Weeds of Concern*

Scientific Name Common Name Class

Crateagus sp hawthorn, nonnative GP concern Crucianella angustifolia Crosswort, narrowleaved monitor Crupina vulgaris crupina, common A Cuscuta approximata dodder, smoothseed alfalfa C Cynoglossum officinale houndstongue B Cyperus eragrostis Sedge, lovegrass monitor Cyperus esculentus nutsedge, yellow B Cytisus scoparius broom, Scotch B Daphne laureola laurel, spurge B Daucus carota carrot, wild B Dipsacus fullonum Teasel, common monitor Echium vulgare blueweed B Egeria densa elodea, Brazilian B Eichhornia crassipes Waterhyacinth monitor Epilobium hirsutum willow-herb, hairy C Euphorbia esula spurge, leafy B Euphorbia myrsinites spurge, myrtle B Euphorbia oblongata spurge, eggleaf A Ficaria verna Celandine, lesser monitor Foeniculum vulgare (except var. fennel, common B azoricum) Galega officinalis goatsrue A Geranium robertianum herb-Robert B Glyceria maxima sweetgrass, reed A Gypsophila paniculata babysbreath C Hedera helix 'Baltica' C Hedera helix 'Pittsburgh' C Hedera helix 'Star' C Hedera hibernica 'Hibernicia' ivy, English, 4 cultivars C only: Helianthus ciliaris blueweed, Texas A Hemizonia pungens spikeweed C Heracleum mantegazzianum hogweed, giant A Hibiscus trionum Mallow, venice monitor Hieracium atratum hawkweed, polar B Hieracium aurantiacum hawkweed, orange B Hieracium caespitosum hawkweed, yellow B Hieracium floribundum hawkweed, yellow devil A Hieracium glomeratum hawkweed, queen-devil B Hieracium lachenalii hawkweed, common A Hieracium laevigatum hawkweed, smooth B Hieracium pilosella hawkweed, mouseear B Hieracium saboudum hawkweed, European A Hieracium sp., except species hawkweed, nonnative C designated in the note in the left- species hand column Hydrilla verticillata hydrilla A

Energy Northwest A-2 June 2008 Packwood Lake Hydroelectric Project IWMP Appendix A - Noxious Weed Lists

Washington State Noxious Weed List 2008 with GPNF Weeds of Concern*

Scientific Name Common Name Class

Hydrocharis morsus-ranae Frogs-bit, Eurasian monitor Hyoscyamus niger henbane, black C Hypericum perforatum St. Johnswort, common C Hypochaeris radicata catsear, common B Ilex aquifolium holly GP concern Impatiens glandulifera helmet, policeman's B Inula helenium Inula monitor Iris pseudacorus iris, yellow flag C Isatis tinctoria woad, dyers A Kochia scoparia kochia B Lamiastrum galeobdolon archangel, yellow C Lathyrus latifolius everlasting pea GP concern Lathyrus sylvestris narrow-leaved everlasting GP concern pea Lepidium latifolium pepperweed, perennial B Lepyrodiclis holosteoides lepyrodiclis B Leucanthemum vulgare daisy, oxeye B Linaria dalmatica ssp. dalmatica toadflax, Dalmatian B Linaria vulgaris toadflax, yellow C Ludwigia hexapetala primrose, water B Ludwigia peploides primrose-willow, floating A Lysimachia vulgaris loosestrife, garden B Lythrum salicaria loosestrife, purple B Lythrum virgatum loosestrife, wand B Matricaria perforata mayweed, scentless C Mirabilis nyctaginea four o'clock, wild A Myriophyllum aquaticum parrotfeather B Myriophyllum heterophyllum milfoil, variable-leaf A Myriophyllum spicatum watermilfoil, Eurasian B Nymphaea odorata water lily, fragrant C Nymphoides peltata floating heart, yellow B Onopordum acanthium thistle, Scotch B Phalaris arundinacea canarygrass, reed C Phragmites australis reed, common, nonnative C genotypes Picris hieracioides oxtongue, hawkweed B Polygonum albertii Vine, silverlace monitor Polygonum bohemicum knotweed, Bohemian B Polygonum cuspidatum knotweed, Japanese B Polygonum polystachyum knotweed, Himalayan B Polygonum sachalinense knotweed, giant B Potamogeton crispus pondweed, curly-leaf C Potentilla argentea Cinquefoil, silvery monitor Potentilla recta cinquefoil, sulfur B Proboscidea louisianica Unicorn-plant monitor

Energy Northwest A-3 June 2008 Packwood Lake Hydroelectric Project IWMP Appendix A - Noxious Weed Lists

Washington State Noxious Weed List 2008 with GPNF Weeds of Concern*

Scientific Name Common Name Class

Pueraria montana var. lobata kudzu A Rorippa austriaca fieldcress, Austrian B Rorippa nasturtium-aquaticum Watercress monitor Rorippa sylvestris Fieldcress, creeping monitor Sagittaria graminea arrowhead, grass-leaved B Salvia aethiopis sage, Mediterranean A Salvia pratensis clary, meadow A Salvia sclarea sage, clary A Schoenoplectus mucronatus ricefield bulrush A Secale cereale rye, cereal C Senecio jacobaea ragwort, tansy B Senecio vulgaris groundsel, common C Silene csereii Catchfly, Balkan monitor Silene latifolia ssp. alba cockle, white C Silybum marianum thistle, milk A Solanum elaeagnifolium nightshade, silverleaf A Solanum rostratum buffalobur A Soliva sessilis lawnweed A Sonchus arvensis ssp. arvensis sowthistle, perennial B Sorghum halepense johnsongrass A Spartina alterniflora cordgrass, smooth B Spartina anglica cordgrass, common B Spartina densiflora cordgrass, dense flower A Spartina patens cordgrass, salt meadow A Spartium junceum broom, Spanish A Sphaerophysa salsula Swainsonpea B Tamarix ramosissima Saltcedar B Tanacetum vulgare tansy, common C Taraxacum officinale dandelion GP concern Thymelaea passerina flax, spurge A Torilis arvensis hedgeparsley B Tribulus terrestris puncturevine B Typha angustifolia Cattail, lesser monitor Ulex europaeus gorse B Utricularia inflata Bladderwort, swollen monitor Verbena bonariensis Verbena, tall monitor Vinca major vinca GP concern Xanthium spinosum cocklebur, spiny C Zygophyllum fabago bean-caper, Syrian A

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Packwood Lake Hydroelectric Project Integrated Weed Management Plan

APPENDIX B

Description, General Location and Control Measures Considered for Noxious Weed Species within the Packwood Lake Project Area on USDA Forest Service Lands

Energy Northwest June 2008 Packwood Lake Hydroelectric Project IWMP Appendix B - Control Measures for USFS Lands

APPENDIX B

Description, General Location and Control Measures Considered for Noxious Weed Species within the Packwood Lake Project Area on USDA Forest Service Lands

The following summarizes information on noxious weeds from the Washington State Noxious Weed Control Board’s (WSNWCB) list of weeds, results from the Packwood Lake Noxious Weed Survey and options considered by Energy Northwest based on control measures listed in the USDA Forest Service’s, “Common Control Measures for Invasive Plants of the Pacific Northwest Region” for those species found within the Packwood Lake Hydroelectric Project area that require treatment, and those species that may require treatment in the future. Please refer to the Forest Service’s document for details on control measures; the document can be found at: http://www.fs.fed.us/r6/invasiveplant-eis/FEIS/appendicies-pdf/App-N-Com-Cont-Meas- fnl-update-063005-0405-FEIS-nowatermark.pdf

Centaurea diffusa – Diffuse Knapweed – Class B

Diffuse knapweed is an 8 to 40 inch tall, biennial or short-lived perennial species, with a long tap root. The single, upright stem produces several spreading branches. The basal leaves are short-stalked and divided into lobes on both sides of the center vein. The stem leaves are stalkless, becoming smaller and less divided near the top of the stem. The flowers, which are generally white (sometimes pink or lavender), occur in urn-shaped heads that grow in clusters at the ends of the branches. The bracts of the flower heads are leathery, with obvious veins. The lower and middle bracts are yellowish-green with a buff or brown margin; they are edged with a fringe of spines plus a longer, spreading spine at the tip. Diffuse knapweed may regenerate from the crown, but reproduces primarily by seed and is a prolific seed producer. A single flower stalk can produce 1,200 seeds. The seeds are dispersed when the plant breaks off at the base and behaves as a tumbleweed. The plants must reach a critical size in order to flower. Under favorable conditions a plant will bolt in May of its second growing season and flowers in July/August. Seeds mature by mid to late August. Seeds germinate in both early spring and fall.

In the study area, a small population of diffuse knapweed was located on private land along the tailrace west of Highway 12. Approximately ten to 15 scattered plants were observed between the gravel road and the fence along the tailrace. Its roadside habitat is disturbed and plant associates include many other non-native species. In the late- 1990’s, a very dense population of diffuse knapweed along the tailrace was treated with herbicides and largely eliminated (R. Crawford Energy Northwest personal communication). The tailrace knapweed population is near the Lewis County-owned solid waste and transfer station where there is a large known population of diffuse knapweed (B. Wamsley LCNWCB personal communication). This larger population may act as a local seed source for surrounding areas. The LCNWCB has been treating

Energy Northwest B-1 June 2008 Packwood Lake Hydroelectric Project IWMP Appendix B - Control Measures for USFS Lands

plants at that site on an on-going basis. Diffuse knapweed can be controlled by hand pulling, herbicides, and biocontrol methods.

Manual Control: Hand pulling before seed set is effective if done three times per year. Methods include: dig rosettes in the spring; pull mature and immature plants in early summer before seeds form; and pull and bag (to remove seed from area) remaining plants in mid to late summer. All of the infestation must be pulled, and all of the taproot must be removed.

Cultural Control: Deep plowing may be effective where feasible because knapweed seeds will not germinate below 3 cm.

Chemical Control: The following pesticides may be used: clopyralid (Transline), picloram (Tordon), and glyphosate (RoundUp, Rodeo). If used, treat using a backpack or wick to minimize drift. For clopyralid, apply up to the bud stage; for picloram, apply late spring prior to flower stem elongation; for glyphosate, apply when the plant is actively growing in bud stage. Clopyralid is less persistent than picloram, but is more selective. Clopyralid is potentially mobile in water. One application of picloram may be effective for 2 or more years. Picloram is persistent in the soil, and can move offsite through surface or subsurface water. Glyphosate only provides control during the year of application. It is not mobile in the environment. Glyphosate will not kill seeds or inhibit germination. Rain within 6 hours reduces effectiveness.

Centaurea pratensis – Meadow Knapweed – Class B

Meadow knapweed is a perennial growing from a woody root crown, with 20-40 inch tall upright stems. Its basal leaves can be up to 6 inches long and 1.25 inches wide, tapering at both ends. The stem leaves are lance-shaped, stalkless, and sometimes shallowly lobed, while the uppermost leaves are smaller and not lobed. The rose-purple to occasionally white flowers occur in solitary, oval, or almost globe-shaped flower heads at the ends of branches. Meadow knapweed flowers from July to September, producing ivory-white to light brown seeds that may or may not have a barely noticeable plume. Occasional flowers can be found west of the Cascades into November/December. However, because it is a hybrid, meadow knapweed traits are highly variable.

There is a large, previously known population of meadow knapweed on NFS lands along FS Road 1260 (Snyder Road) in the vicinity of FS Road 1262 (Latch Road) that the Forest Service and the LCNWCB have treated by hand pulling in the last few years (B. Wamsley LCWCB personal communication). It is also present on the roadside of the first tenth of a mile of FS Road 1262 (Latch Road). The plants growing along FS Road 1262 (Latch Road) are only portion of this population that is in the study area. Although co-dominant with other species along roadsides, it has not invaded adjacent forested areas. Meadow knapweed can be controlled by hand pulling, herbicides and biocontrol methods. Chemical Control: The following pesticides may be used: clopyralid (Transline), picloram (Tordon), and glyphosate (RoundUp, Rodeo). If used, treat using a backpack

Energy Northwest B-2 June 2008 Packwood Lake Hydroelectric Project IWMP Appendix B - Control Measures for USFS Lands

or wick to minimize drift. For clopyralid, apply up to the bud stage with two applications per season, one in spring and one in fall; for picloram, apply late spring prior to flower stem elongation; for glyphosate, apply when the plant is actively growing in bud stage. Clopyralid is less persistent than picloram, but is more selective. Clopyralid is potentially mobile in water. One application of picloram may be effective for 2 or more years. Picloram is persistent in the soil, and can move offsite through surface or subsurface water. Glyphosate only provides control during the year of application. It is not mobile in the environment. Glyphosate will not kill seeds or inhibit germination. Rain within 6 hours reduces effectiveness.

Cirsium arvense – Canada Thistle – Class C

Canada thistle is a perennial herb with a deep-seated complex system of roots spreading horizontally which give rise to aerial shoots. The 1-4 foot tall stems are slender, green, and freely branched. The leaves are alternate, sessile, and deeply lobed. The leaf margins have stiff yellowish spines. The heads are many and relatively small. The flowers are purple. The fruits are about 1/8 inch long, somewhat flattened, and brownish with an apical circle of long hairs. Canada thistle spreads primarily by vegetative reproduction, which is aided by a fibrous taproot capable of sending out lateral roots as deep as three feet below ground, and from which shoots sprout up at frequent intervals. It also readily regenerates from root fragments less than an inch in length. Canada thistle produces an abundance of seeds that are easily dispersed by the wind. Most seeds germinate within a year; but may remain viable for twenty years or more.

In early 2007, Canada thistle was selected for control at wilderness portals in Lewis County. This species was mapped on Packwood Lake and its tributaries in August 2007. Eight patches of Canada thistle are located around the Lake, ranging in size from several stems to a patch at the southeast end of the Lake that is over an acre in size. Canada thistle is most effectively controlled by herbicides. Other large patches of Canada thistle were observed in moist areas in and around the Packwood Lake powerplant, Snyder Creek and Hall Creek. Smaller patches were observed along the Latch Road, Lake Creek/Cowlitz River confluence, and the shores of Packwood Lake. Although not required, there has been some effort on the part of Energy Northwest to control Canada thistle populations in the vicinity of the powerplant in the past (R. Crawford Energy Northwest personal communication).

Manual Control: Hand cutting of flower heads can be used; however, this technique will only suppress seed production. Cut high enough to leave > 9 leaves per stem, or > 20 centimeters of bare stem tissue, as mature Canada thistle leaves and stems independently inhibit development of shoots and rootbuds.

Mechanical Control: Smothering Canada thistle with boards, sheet metal, or tar paper can kill plants. Chemical Control: The following pesticides may be used: clopyralid (Transline), picloram (Tordon), glyphosate (RoundUp, Rodeo), and chlorsulfuron (Telar, Glean). If used, treat using a backpack or wick to minimize drift. For clopyralid and picloram,

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apply at basal rosette stage after most leaves have emerged. Fall applications will reduce spring regrowth. For glyphosate, apply at basal rosette stage after most leaves have emerged; fall is the best season since translocation to root is highest. Chlorosulfuron could be applied at bud-bloom stage or to fall rosettes. Clopyralid is less persistent than picloram and is potentially mobile in water. Picloram is persistent in the soil, and can move offsite through surface or subsurface water. Glyphosate only provides control during the year of application. It is not mobile in the environment. Glyphosate will not kill seeds or inhibit germination. Rain within 6 hours reduces effectiveness. Chlorosulfuron primarily suppresses regrowth and secondarily reduces the number of root buds. It is extremely potent. There may be damage to non-target terrestrial and some aquatic plants.

Cytisus scoparius – Scotch Broom – Class B

Scotch broom is a shrub, 1-2 meters high, with leaves 6 to12 mm long, flowers and flat pods. Golden yellow flowers bloom between April and June, and resemble flowers of a pea. Scotch broom can reproduce vegetatively or by seed. Bushes can produce up to 60 seed pods per bush by their second year. Seed can remain viable for up to 80 years, and will germinate when shad is removed and ground is disturbed. Soil disturbance while treating will encourage sprouting.

Scotch broom is a common and widespread shrubby weed in the general Packwood area. In the study area, it ranges from common to uncommon along: FS Road 1262 (Latch Road) , FS Road 1260-066 (Pipeline Road), penstock, tailrace, powerhouse, Cowlitz River gravel bar, Lake Creek/Cowlitz River confluence, and FS Trail #78 parking lot. Although not required, Energy Northwest has done some control of Scotch broom along the tailrace over the last few years (R. Crawford Energy Northwest personal communication). Although common in disturbed areas, it was not observed growing in undisturbed forested areas. There is a population of Scotch broom around the powerhouse in the open areas, which is spreading onto adjacent forest roads, and a few plants on the penstock corridor below the surge tank (personal observation Linda Swartz).

Manual Control: Hand pulling may be used to destroy seedlings or plants up to 1.5 meters tall. It is most easily accomplished after a rain when the soil is loose when the root system can be removed in its entirety. Hand digging or hoeing can be effective, but care must be taken to remove all roots. Use of a weed wrench is effective on mid-size plants.

Mechanical Control: Cutting using various tools or mowers is most effective when done as plants are flowering, but before seed set. Clipping low to the ground is best. Brooms will most likely still resprout with this method, so repeated treatments will be needed. Return visits in the fall and winter will be necessary.

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Chemical Control: The following pesticides may be used: triclopyr (Garlon), picloram (Tordon), and glyphosate (RoundUp, Rodeo). For triclopyr, treatment should be in late spring during active growth; paint cut stumps or incised stem within 5-20 minutes of cutting. Offsite movement by water is possible. For picloram, apply to young plants during active spring growth using a backpack or wick to minimize drift. Picloram can move offsite through surface or subsurface water, and is persistent in the soil. Glyphosate is most effective when applied from flowering through first hard frost; apply using a backpack or wick to minimize drift. Glyphosate provides some control; however, repeated applications may be necessary. Rain within 6 hours reduces effectiveness.

Geranium robertianum – Herb Robert – Class B

Herb Robert is a shade tolerant, low growing geranium. A distinguishing characteristic of the species is the pungent odor of the crushed leaves; another common name for this plant is “stinky Bob.” The light green leaves are deeply dissected. In late fall the foliage turns red. The stems fork and are brittle at the joints. They are pubescent and under high light conditions are red and up to 25 cm long. The roots are shallow. The pink flowers are perfect with five petals that are 7-10 mm. The receptacle is elongated into a structure called a "torus." The fruit is a capsule. Herb Robert spreads entirely by seeds, which are brown and about 2 mm long. Each flower produces five seeds capable of being ejected 15-20 feet. With adequate moisture, seeds begin germinating soon after dispersal. New seedlings appear several times throughout the growing season, which is from early spring to late fall and even into early winter. It has the ability to overwinter as seeds or as a rosette.

Herb Robert is common to co-dominant along all of Lake Creek from Packwood Lake down to its confluence with the Cowlitz River. The lower one-mile reach of Lake Creek has a particularly high density of plants, sometimes almost entirely replacing other herbaceous plant species. Scattered plants were observed along the penstock upslope of the powerhouse and on the Cowlitz River gravel bar near the tailrace slough. Unlike many weed species, herb Robert readily invades undisturbed habitats including forests.

Manual Control: Hand pulling is quick and easy, due to the shallow roots, but stems are brittle, so care must be taken to get the entire plant. Seeds sprout throughout the year and plants bloom within weeks of sprouting. Therefore, all Herb Robert plants must be cleared several times during the growing season to prevent seed set. Use caution to ensure that desirable vegetation is not pulled.

Chemical Control: Glyphosate (RoundUp, Rodeo) may be used; however care must be taken as non-targets could also be killed. If used, treat at low rates early in the season, using a backpack or wick to minimize drift. Complete control may require re-treatment. Rain within 6 hours reduces effectiveness.

Hypericum perforatum – St. Johnswort – Class C

St. Johnswort is an erect, opposite-leaved perennial herb, ranging from 2-4 feet tall arising from a taproot. The plant can have single or multiple stems. The reddish stems

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are smooth, somewhat two-edged, woody at the base, and branching out toward the top of the plant. The narrow, lance shaped leaves are about one inch long; stalkless with pointed tips. Each leaf is spotted with tiny translucent dots. Each flower has five yellow petals and many yellow stamens. The black dots often visible along the petal margins are glands containing hypericin. This red pigment is also visible in glands on leaf margins giving the leaf a perforated look. The inflorescence is a flat topped cluster of many flowers found at branch ends. St. Johnswort reproduces by seeds and short runners. The taproot may reach depths of 4-5 feet. Lateral roots grow 2-3 inches beneath the soil surface but may reach depths of 3 feet. Flowering begins in May and continues through September. Developing capsules become very sticky and contain 400 to 500 seeds. Seeds may remain viable in soil for up to 10 years.

Common St. John’s-wort is common along roadsides and other disturbed areas, including the Latch Road, penstock, tailrace, Cowlitz River gravel bar, FS Road 1260- 066 (Pipeline Road), and the lake shore area. Although common in disturbed areas, it was not observed growing in undisturbed forested areas.

Manual Control: Hand pulling or digging of young plants in small, isolated infestations may be effective. Repeated treatments may be necessary because lateral roots can give rise to new plants. Pulled or dug plants must be removed from the area.

Chemical Control: The following pesticides may be used: metsulfuron (Escort), picloram (Tordon), and glyphosate (RoundUp, Rodeo). Apply using a backpack or wick to minimize drift. Apply metsulfuron after plants have fully emerged and are in active growth. Metsulfuron is potentially mobile in water through wind erosion. Damage to some aquatic plants is possible. Apply picloram in early growth stage before bloom. One application may be effective for two or more years. Pichloram is persistent in the soil, and can move through surface or subsurface water. Glyphosate should be applied in spring/summer when plants are growing rapidly. Aquatic formulation can be used near water. Rain within 6 hours of application may reduce effectiveness, and complete control may require retreatment.

Phalaris arundinacea – Reed Canarygrass – Class C

Reed canarygrass is a robust, cool season, sod-forming perennial that produces culms through creeping rhizomes. It is very tolerant of freezing temperatures and begins to grow early in spring; therefore it can out-compete many other species. Reed canarygrass can reach 3-6 feet in height. The sturdy, often hollow stems can be up to 1/2 inch in diameter, with some reddish coloration near the top. Leaf blades are flat and hairless, 1/4 to 3/4 of an inch wide. Flowers are in branched clusters on culms high above the leaves. The species flowers in June and July. Reed canarygrass is rarely fully eradicated and requires yearly, if not monthly attention. Like Canada thistle, reed canarygrass was selected for control at wilderness portals in Lewis County in early 2007. It was mapped on Packwood Lake and its tributaries in August 2007. Four relatively small patches of reed canarygrass were located at the northeast end of the Lake, in the vicinity of the boat launch and east of the footbridge. The average size of these patches is 10 by 20 feet. Most of the plants were short and

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vegetative. Reed canarygrass can be controlled by a variety of methods including: mechanical, manual, fire, and herbicides.

Manual Control: Removal by hand pulling is only practical for small stands. It can be effective if done over the entire population two to three times per year for five years. Covering populations with black plastic may work as long as shoots are not allowed to grow beyond the plastic.

Mechanical Control: Cutting can be effective, but must be done multiple times in one year.

Chemical Control: Glyphosate (Rodeo or Accord) and sulfometuron methyl (Oust) may be used. Apply with a backpack with adjustable spray nozzle. Glyphosate should be applied in early spring when plants are just sprouting and before other wetland species germinate. Rain within six hours reduces effectiveness. Some formulations may be used over water. Complete control may require re-treatment. Sulfometuron methyl should be applied to pre-emergent or early post-emergent plants. Sulfometuron methyl is highly mobile by water or by wind erosion. Damage to some aquatic plants is possible.

Polygonum cuspidatum – Japanese Knotweed – Class B

Japanese knotweed is a perennial species with spreading rhizomes and numerous reddish-brown, freely branched stems. The plant can reach 4-8 feet in height and is often shrubby. The leaves are 4-6 inches long and generally ovate with an abrupt point. The whitish flowers are borne in open, drooping panicles. The approximately 1/8 inch long fruits are brown, shiny, and triangular. The primary mode of reproduction is through extensive rhizomes that can reach 15-20 meters in length. Dispersal can occur when rhizome fragments are washed downstream.

Rhizomes can regenerate even if buried up to one meter deep and have been observed growing through two inches of asphalt. Shoots generally begin to emerge in April and growth rates exceeding eight centimeters per day have been recorded.

Near the study area, a small population of Japanese knotweed was observed on private land along a forested, muddy side channel on the Cowlitz River approximately 100 feet upstream of Lake Creek. It is a previously known population that the LCWCB has been treating for several years with glyphosate (B. Wamsley LCWCB personal communication). At the time of the observation, it had six non-reproductive stems, which were approximately 1.5 feet tall. In addition, there were several clumps of plants at the gravelly area at the Lewis County-owned and operated solid waste and transfer station near the tailrace that have been successfully treated and eliminated (B. Wamsley LCWCB personal communication). Japanese knotweed is most effectively controlled by herbicide application (NWCB 2006).

Mechanical Control: Covering, in conjunction with cutting, may be useful in smaller stands. Several layers of black plastic or shade cloth weighted down by blocks, mulch

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or stones may work. This should be done after cutting or when plants are fully grown. No reports of successful long term control using covering have been found.

Integrated approach: Cutting or pulling in combination with herbicide is most effective.

Chemical Control: Glyphosate (Rodeo) or triclopyr (Garlon) can be used. Triclopyr is most effective in fall when leaves are translocating to rhizomes. Application could follow a prior cut in late spring or early summer. Application by cut and paint stems: cut between first and second internode and then deliver tricloryr into “well” created by cut. Amine formulations may be used near or over water. Offsite movement by water is possible. Glyphosate application by cutting and injection is most effective in the fall when leaves are translocating to rhizomes. Application by cut and paint stems: cut between first and second internode and then deliver glyphosate into “well” created by cut. Foliar spray by backpack with adjustable nozzle can be used when plants are 1-2 meters tall, and is best if following a prior cut in the spring. Rain within six hours reduces effectiveness. Formulations approved for use over water must be used. Low concentrations (less than 5 percent) may be most effective.

Potentilla recta – Sulfur Cinquefoil- Class B

Sulfur cinquefoil is a long-lived, taprooted perennial herb that typically flowers from late May to mid July. It produces several erect stems which can reach 1-3 feet in height. The stout, leafy, hairy stems are unbranched up to the inflorescence. The leaves, which are also rough-hairy, have five-to-seven-toothed leaflets that are 2-4 inches long by 1/2- 1 inch wide. The flat-topped inflorescences are 3-6 inches across, and each flower has five light yellow petals surrounding a dark yellow center. The fruits are dark brown, with lighter, prominent, branched ridges, and narrow, winged margins. It reproduces primarily through seed; a single plant can produce thousands of seeds annually; and it can be spread by roots if they are moved by tillage or on soil-moving equipment. Seeds are dispersed primarily by wind from late summer through fall. Seeds may remain viable for more than four years. Sulfur cinquefoil can dominate a site within two to three years. New shoots can develop annually from the outer portion of the main root.

An infestation of sulfur cinquefoil was observed growing west of Highway 12 along the tailrace on disturbed ground.

Manual Control: Hand-digging may effectively control small infestations if the root crowns are completely removed.

Chemical Control: Repeated applications are needed for long term control. Backpack or wick to minimize drift. Broadcast spray may be necessary for large infestations. Picloram (Tordon) and metsulfuron (Escort) can be used. Apply picloram in the fall or spring prior to late bud stage. On dry sites, picloram is preferred because its residual activity will inhibit new plants from establishing from the seed bank. Apply metsulfuron after plants have fully emerged and are in active growth.

Senecio jacobaea – Tansy Ragwort – Class B

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Tansy ragwort is classified as a biennial herb. It can complete its life cycle as a winter annual and occasionally as a perennial, depending on environmental conditions. Tansy ragwort has stalked dark green, basal leaves. The leaf underside is somewhat hairy, and appears whitish. The overall rosette has a ruffled appearance, due to deeply indented and blunt toothed lobes of the leaves. The basal leaves are often deciduous. The size of the rosette may indicate the potential for flowering, with larger rosettes producing more flowers. During the second year, one or several flowering stems bolt, with the overall plant being 1-4 feet high. The leaves found on the flowering stem are alternate, and sessile. The flower heads are in flat topped clusters. Each flower head is composed of yellow, daisy-like flowers. Each flower head is a composite of many disc flowers surrounded usually by 13 ray flowers. A distinguishing characteristic is the 13 ‘petals,’ which are ray flowers. Tansy ragwort has a taproot, and often a large woody rootstock. Dispersal of seed is usually up to 9 meters. Seeds can remain viable in the soil for several years, and as deep as 25 centimeters. The species can also regenerate vegetatively.

Small patches of plants were observed along the FS Road 1262 (Latch Road), the junction with FS Road 1260 (Snyder Road) , FS Road 1260-066 (Pipeline Road), and occasionally at the lake shore area.

Manual Control: Hand pulling is effective if done when soils are moist and the hole left behind is mulched. Plants must be mature enough to bloom, so the stems will not be easily broken. Tug firmly from one side, and if the plant does not come out, move to the opposite side; this is because the primary root grows toward one side.

Mechanical Control: Mowing is the most commonly used technique. It is most effective if done prior to flowering when the plant has exhausted its reserves, but before seeds have started to develop.

Chemical Control: Metsulfuron (Escort) plus a surfactant and picloram can be applied using a backpack or wick to minimize drift. Metsulfuron should be applied to actively growing plants. It is potentially mobile in water or through wind erosion. Picloram can be applied up through the flowering stage. Fall application after rains have initiated seed germination have also proven effective. Picloram is persistent in the soil and can move offsite through surface or subsurface water.

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Packwood Lake Hydroelectric Project Integrated Weed Management Plan

APPENDIX C

Description, General Location and Control Measures for Other Noxious Weeds Occurring Within the Project Boundary

Energy Northwest June 2008

Packwood Lake Hydroelectric Project IWMP Appendix C – Other Control Measures

Description, General Location and Control Measures for Other Noxious Weeds Occurring Within the Project Boundary

The following summarizes information on noxious weeds from the Washington State Noxious Weed Control Board’s (NWCB) list of weeds, results from the Noxious Weed Survey, and control options considered by Energy Northwest.

Buddleja davidii – Butterfly bush – Class C

Butterfly bush is a deciduous shrub with arching branches that can reach a height of 15 feet. The showy flower spikes are often purple, and the leaves and stems are typically hairy. The leaves can be either lance-shaped or egg-shaped, and are either finely toothed or coarsely toothed, usually between 4-10 inches long and 1-3 inches wide. The leaves are often green or blue-gray above and whitish on the underside, due to the fuzzy hairs. Flowers are four-parted and bell-shaped, commonly purple with an orange center. Cultivars can be pink, magenta, red, blue, orange, yellow, and white. Flower spikes are erect or nodding, reaching a length of between 4-10 inches. The flowers are fragrant; blooming begins in mid-summer. Young stems are green; mature stems develop scraggly, gray-brown bark that peels off.

Several butterfly bush plants (2 to 3 individuals) were located on private land near where the tailrace enters the Cowlitz River. It was growing in semi-stabilized cobbles and gravels. The plants looked as though they might have originally have been plant fragments that washed downriver during a flood event and then took root. When not blooming, butterfly bush is difficult to spot amongst willows and other riverine vegetation. Butterfly bush can be controlled by herbicides and mechanical methods.

Manual control: Seedlings can be hand-picked and adult plants can be dug up. However, butterfly bush thrives in recently disturbed areas, so be aware that these methods of removing plants may actually promote the growth of new seedlings. Deadhead flowerspikes before they produce seed to prevent further spread.

Cirsium vulgare – Bull thistle – Class C

Bull thistle is an annual or biennial herbaceous plant. In the juvenile phase, individual bull thistle plants form a single rosette with a taproot up to 28 inches long. Rosettes may be up to 3.3 feet in diameter. The taproot does not spread, but may develop several smaller lateral roots. The tall, spiny, winged stems (up to 7 feet tall) have many spreading stems. Leaves are 3-12 inches long, lance-shaped, and very hairy. The purple flower heads are 1.5-2 inches in diameter and 1-2 inches long with narrow spine- tipped bracts.

Bull thistle is occasional along roadsides and other disturbed areas, including the Latch Road, Lake Creek/Cowlitz River confluence, FS Road 1260-066 (Pipeline Road), and the lake shore area. It was not observed growing in undisturbed forested areas.

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Packwood Lake Hydroelectric Project IWMP Appendix C – Other Control Measures

Mechanical Control: Mow to prevent seeding.

Chemical Control: Bull thistle can be effectively controlled using glyphosate (RoundUp, Rodeo), triclopyr (Garlon), picloram (Tordon), clopyralid (Transline), metsulfuron methyl (Escort), and dicamba (Banvel).

Daucus carota – Wild carrot – Class B

Wild carrot is an erect, taprooted herb, 1 to 4 feet tall. Although it can occur as an annual or short-lived perennial, the species is typically a biennial that bears a rosette of leaves its first season. The plant, which is covered with coarse, stiff hairs, has fern-like leaves that are divided several times into small, toothed leaflets; the ultimate segments are linear or lance-shaped. Leaves are basal or alternate. Basal leaves have a long petiole. Stem leaves are sessile with sheathing bases. The small, white flowers are borne in compound, flat-topped umbels. Umbels are 2-4 inches in diameter and may have one to several purple or pinkish flowers at the center. Umbels, which are surrounded by a circle of finely divided bracts, become concave as the fruits mature. A single plant may produce up to 100 umbels during the flowering season. The oblong, grayish-brown fruits are 1/16-1/8 inches long and flat on one side. The other side of the fruit has rows of bristles on the curved surface. Although plants are self-fertile, wild carrot flowers are typically cross-pollinated by a wide range of insects. Estimates of seed production vary, from 1,000 to 40,000 seeds per plant. Seeds of the terminal umbel ripen first; these umbels are heaviest and have more viable seed. The seeds are released from mid- summer through mid-winter and may be carried by wind or on animal fur.

Wild carrot is common on roadsides and other disturbed areas in the study area, including the FS Road 1262 (Latch Road), Lake Creek/Cowlitz River confluence, and the tailrace. Although common in disturbed areas, it was not observed growing in undisturbed forested areas.

Manual/Mechanical Control: Hand-pulling or mowing during the first year when the plants are 7 to 10 inches tall can be effective.

Cultural Control: Establishing and maintaining healthy stands of native/desirable vegetation can reduce wild carrot infestations.

Chemical Control: Pesticides are most effective when applied to seedlings. Older plants may not respond to herbicides. Annual applications may be required to control seedlings. Picloram (Tordon) and metsulfuron methyl (Escort) can be used.

Hypochaeris radicata – Common catsear – Class B

Common catsear is a perennial plant with basal rosettes of leaves. The leaves are rough-hairy and lobed, or wavy-margined. The hollow, sparsely branched flowering

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Packwood Lake Hydroelectric Project IWMP Appendix C – Other Control Measures

stems contain a white, milky juice, and are 0.75-2 feet tall. The yellow flowers occur in heads that are 1-1.5 inches in diameter. The fruits are long-beaked and tipped by a circle of plume-like bristles.

Common catsear is common along roadsides and other disturbed areas in the study area, including the penstock, FS Road 1262 (Latch Road), Lake Creek/Cowlitz River confluence, FS Trail #78 parking lot, tailrace, tailrace/Cowlitz River confluence, and FS Road 1260-066 (Pipeline Road) . Although common in disturbed areas, it was not observed growing in undisturbed forested areas.

Manual/Cultural Control: Scattered plants can be spaded out below the crown in early spring as soon as the leaves appear. Badly infested fields should be cultivated one to two years before reseeding with native vegetation.

Leucanthemum vulgare – Oxeye daisy – Class B

Oxeye daisy is a perennial herb, 1 to 3 feet tall, with shallow, branched rhizomes and adventitious roots. The stems, which arise from upturned rhizomes or buds on the root crown, range from hairless to slightly hairy. The prostrate, basal stems can root, while the other stems are erect and simple to slightly branched. Cotyledons open above ground and wither soon after the first leaves form. The toothed, spatula-shaped to round basal leaves occur on long stalks. The stem leaves are alternate and lack stalks; they are lance-shaped to ligulate, with coarse teeth and often have a few lobes at the base. Flowers are showy and daisy-like, with 20 to 30 white ray flowers and numerous, bright yellow disk flowers. Flower heads are usually solitary and grow on long, terminal stems; heads average 1-2.2 inches in diameter. Involucral bracts are narrow with a dark brown, scarious margin. The entire plant has a disagreeable odor when crushed. Oxeye daisy can spread both vegetatively and by seed.

Oxeye daisy is common along roadsides and other disturbed areas in the study area, including the FS Road 1262 (Latch Road), penstock, Lake Creek, FS Trail #78 parking lot, and FS Road 1260-066 (Pipeline Road) . Although common in disturbed areas, it was not observed growing in undisturbed forested areas.

Mechanical Control: Because of its shallow root system, oxeye daisy is easily killed by intensive cultivation.

Chemical Control: Metsulfuron methyl (Escort) can be used on oxeye daisy.

Senecio vulgaris – Common groundsel – Class C

Groundsel is a downy winter or summer annual or biennial. Leaves are elongate, with a blunt, rounded tip. The first true leaves have shallow teeth; the third and fourth leaves are more deeply lobed. The stems are succulent, hollow, slightly angled, and much branched, with many leaves on top. Leaves are alternate on the stem and deeply indented. Upper leaves are attached directly to the stem, but lower leaves have a short

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Packwood Lake Hydroelectric Project IWMP Appendix C – Other Control Measures

petiole. The green bracts surrounding the flower cluster have conspicuous black tips that distinguish groundsel from other weeds in the thistle family. Plants have simple or branched upright growth, 6-18 inches tall. The foliage is generally smooth but may have light pubescence. Flowers are yellow. Seeds germinate in early spring to late fall and three to four generations may develop in one season. The cotyledons and young leaves on seedlings are purple on the underside. Young plants appear as rosettes. Common groundsel flowers in April to October. This weed prefers cool and wet environments with nutrient rich soil. Common groundsel reproduces by seed. Seed dormancy may vary among populations. Seeds typically germinate early spring through late fall (year-round in some areas). Fluctuating temperatures, light, cold stratification, leaching with water, or scarification stimulate germination.

Common groundsel is uncommon in disturbed areas in the study area, with small groups of plants at the powerhouse, FS Road 1260-066 (Pipeline Road), and at Packwood Lake.

Mechanical Control: The key time to control common groundsel by mechanical methods is just prior to seed set. Shallow tillage in fall and early spring will control winter and some spring annuals.

Chemical Control: Several pesticides control groundsel, including metsulfuron methyl (Escort) and clopyralid (Transline).

Tanacetum vulgare – Common tansy – Class C

Common tansy is an aromatic and oily perennial that grows from 1 to 6 feet tall. Common tansy is often confused with tansy ragwort due only to its common name. They are easily distinguished since tansy ragwort is non-aromatic. The stems of common tansy grow in a cluster, causing the plant to have a bush appearance. Small, golden flower heads form many flat-topped clusters (flower heads are button shaped). Leaves are 2-10 inches long and divided into narrow, toothed segments.

Common tansy is occasionally found in disturbed areas in the study area. A few small patches of plants were observed at the tailrace.

Manual Control: Pull the plant and place in a plastic bag to remove plant from the area if flowers or seeds are present.

Chemical Control: The most effective herbicide for common tansy control is metsulfuron (Escort); however, metsulfuron should not be used to control weedy infestations near water as metsulfuron is persistent in soil and has the potential to leach into groundwater. Glyphosate (Rodeo) is an alternative for use near water, but is not very effective for controlling common tansy.

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Packwood Lake Hydroelectric Project Integrated Weed Management Plan

APPENDIX D

USDA Forest Service Invasive Plant Inventory Form

Energy Northwest June 2008 Packwood Lake Hydroelectric Project IWMP Appendix D – Invasive Plant Inventory Form

Gifford Pinchot NF Invasive Plant Inventory Form Adapted from NRIS TERRA Forms (based on MBS form, tf) Edited LS 2nov06

Fill out one form for each weed per survey unit, and attach a map to each form. Site ID must be unique for each form. *Site ID 1:______Sample Type: INPA Site ID 2:______Site ID 3:______Use multiple site ID’s on one form when there are Site ID 4:______multiple weed species present in same area.

*Project October 2004_pre-EIS data gathering Project Purpose: NW

*Date (MM/DD/YYYY):______

*Primary Examiner (Last, First, Middle Initial): ______

*Region 06, Forest 03, District (Circle) Mt. Adams Cowlitz Valley Mount St Helens

WA State *County (Circle) Lewis Cowlitz Skamania Pierce

USGS 7.5’ Quad Name ______Quad # ______

Watershed HUC code ______*Ownership ______*HUC required for aquatic weeds

Managed Area(s) ______

*Legal Description of Polygon Center T ____ R_____ S______1/4 of ____1/4 Willamette Mer.

*UTMs of Polygon Center Must use Geodetic Datum NAD 83 CONUS

Circle one: GPS GIS easting ______Zone 10 northing ______

GPS Model ______Error ______

Aspect (deg) _____ OR ALL Average Slope (%) ______Elevation (ft) ______min______max OR ______average

Circle *Dominant Life Form AL Algae LC Lichen SS Subshrub FB Forb NP Nonvascular plant TR Tree GR Graminoid SH Woody shrub 3 Dominants PLANTS Code Scientific Name. ______Plant Association ______Plant Assn Code ______Seral Stage ______

Energy Northwest D-1 June 2008

Packwood Lake Hydroelectric Project Integrated Weed Management Plan

APPENDIX E

Worksheet for Revegetation, Rehabilitation, and Restoration Analysis

Energy Northwest June 2008 Packwood Lake Hydroelectric Project IWMP Appendix E - Worksheet

Revegetation / Rehabilitation / Restoration Analysis - Strategy Worksheet

Project Area/Zone Infestation ID

Physical description: Treatment constraints: Soils: Political: Slope: Environmental: Aspect: Physical: Access: Land use: Past history: Residual biomass: Size: Cultural issues: Soil compaction: Other: Erodibility potential:

Existing plant community: Site potential: Species % Cover Species % Cover

Bare ground / litter

Site Objectives – Plant density by species Plant Mix Composition Species % Cover Species % by weight / # of stems

Revegetation strategy: Notes: Ground preparation: Planting method: Planting rate: Supplements: Schedule: Other:

Energy Northwest E-1 June 2008

Attachment 7

Rare Plant Management Plan Packwood Lake Hydroelectric Project (FERC No. 2244)

Energy Northwest Response to Request for Additional Information June 2008

Rare Plant Management Plan

for

Energy Northwest's Packwood Lake Hydroelectric Project FERC No. 2244 Lewis County, Washington

Submitted to:

P.O. Box 968 Richland, Washington 99352-0968

Submitted by:

Beck Botanical Services Kathryn Beck Bellingham, Washington Phone: 360.671.6913

June 2008

Packwood Lake Project Rare Plant Management Plan

Packwood Lake Hydroelectric Project Rare Plant Management Plan

TABLE OF CONTENTS

Section Title Page

1.0 INTRODUCTION...... 1

2.0 OBJECTIVES...... 3

3.0 CONSULTATION AND REPORTING ...... 3

4.0 SURVEYS AND PROTECTION ...... 5 4.1 Biological Evaluation...... 5 4.2 Project Area Rare Plant Survey ...... 5 4.3 Monitoring ...... 7 4.4 Management of Known Rare Plant Occurrences ...... 7

5.0 RARE PLANT MANAGEMENT COSTS...... 10

6.0 REFERENCES...... 11

LIST OF FIGURES Figure 1 Rare Plant Survey Area Map ...... 6

LIST OF APPENDICES

APPENDIX 1 - Updated US Forest Service Sensitive Species, and WNHP List of Known Occurrences of Rare Plants in Washington

APPENDIX 2 - Revised Rare Plant Survey Study Plan for Energy Northwest’s Packwood Lake Hydroelectric Project FERC No. 2244

APPENDIX 3 - Rare Plant Survey Final Report for Energy Northwest’s Packwood Lake Hydroelectric Project FERC No. 2244

Energy Northwest i June 2008 Packwood Lake Project Rare Plant Management Plan

Packwood Lake Project Rare Plant Management Plan

1.0 INTRODUCTION Energy Northwest, (ENW) Licensee of the Packwood Lake Hydroelectric Project (FERC Project 2244) filed its Final Application for New License on February 24, 2008. FERC issued an Additional Information Request (AIR) on April 8, 2008. FERC required that Energy Northwest provide clarification of Protection Mitigation and Enhancement Measures (PM&Es) and to submit several fully developed resource management plans, among them a Rare Plant Management Plan that addresses the following elements included in the AIR.

The Project occupies lands in the Gifford Pinchot National Forest (GPNF) and Packwood Lake is partially bordered by the Goat Rocks Wilderness. The USDA Forest Service (USFS or FS) has indicated that Energy Northwest will be required to develop a comprehensive Threatened, Endangered and Sensitive Species Management Plan to address the issues listed below as they apply to the management of rare plants. The Forest Service’s preliminary terms and conditions for the relicensing of the Project include the following:

Energy Northwest 1 June 2008 Packwood Lake Project Rare Plant Management Plan

Within one year of License issuance, the Licensee shall, in coordination and consultation with the USDA Forest Service prepare a Threatened, Endangered (Federal listed) and USDA Forest Service Regional Forester Special Status Species Management Plan that shall be filed with the Commission for approval. The goal of the plan is to provide protection, management, enhancement and monitoring of threatened, endangered, and sensitive species and their habitats that may be affected by project operation or project-related activities over the life of the License. The plan at a minimum shall require the Licensee to:

1. Initial species list - The initial list should include threatened, endangered and sensitive species that occur within the project boundary or on lands affected by project operation or project-related activities. For each species, the list should reference the relicensing studies that documented occurrence and/or evaluated project effects. 2. Updating the species list - The plan should provide for annual consultation, review, and updating of the list. Species would be added or removed according to changes in their status or changes in the potential for project effects (e.g., construction of new facilities). 3. Conducting baseline surveys - The plan should provide for baseline surveys of species currently on the list if no surveys have been completed at sites where project operations or project-related activities could affect them. Baseline surveys should also be conducted for species that may be added to the list if they occur at sites where the project could affect them. 4. Preparing biological evaluations - Where USDA Forest Service Regional Forester Special Status Species may be affected, ENW should consult with the USDA Forest Service to prepare a draft biological evaluation, in accordance with the Condition No. 1 - Implementation of Activities on National Forest System Lands. 5. Monitoring project effects - For USDA Forest Service Regional Forester Special Status Species, the plan should include monitoring to identify project effects at confirmed sensitive species sites every 2 years for 6 years following License issuance and at 3-year intervals thereafter, unless a determination can be made at year 6 that no additional monitoring is necessary. For other threatened, endangered, and sensitive species, the Licensee shall consult with the USDA Forest Service to determine an appropriate monitoring frequency, based on site-specific conditions. 6. Implementing protective measures - The plan should provide for designing and implementing protection, mitigation, enhancement or restoration measures if monitoring results show project-related effects. 7. Effectiveness monitoring and adaptive management - The plan should include follow-up monitoring to measure the effectiveness of any protective measures that are implemented, and use of this information to modify and improve the Threatened, Endangered, and Sensitive Species Management Plan. Adaptive management shall mean the adoption of the

Energy Northwest 2 June 2008 Packwood Lake Project Rare Plant Management Plan

following strategic actions: measures shall be implemented, effectiveness monitoring shall take place, and alternative fallback options shall be employed if proposed control measures fail to protect and enhance fish and wildlife resources as anticipated. 8. Consultation, reporting, and updating the Threatened, Endangered, and Sensitive Species Management Plan - The plan should provide for annual reporting and consultation, with updates to the plan as needed. The report shall be provided to the USDA Forest Service 30 days prior to the annual Resource Coordination meeting. The report shall also provide details for the out-years planned activities. The Licensee shall allow a minimum of 60 days for the USDA Forest Service to comment and to make recommendations prior to filing the final report with the Commission for approval. If the Licensee does not adopt a recommendation, the filing shall include the Licensee's reasons, based on Project-specific information.

The Packwood Lake Project Rare Plant Management Plan describes Energy Northwest’s efforts to comply with these requirements. The Rare Plant Management Plan is intended to become a part of the Threatened, Endangered and Sensitive Species Management Plan that will be required by the Forest Service, but is being developed and submitted separately, as required to respond to the FERC AIR. This plan was developed with consultation and assistance from the local GPNF staff, and the completed plan has been submitted to them and comments were incorporated prior to filing with FERC, however, due to the very short time in which this plan was required by FERC to be developed, the Forest Service did not have the usual amount of time to review the final version of the plan. 2.0 OBJECTIVES The primary objectives of the Rare Plant Management Plan are as follows:

Provide for protection, management, enhancement and monitoring of rare plant species and their habitats that may be affected by Project operation or Project-related activities over the life of the License. Provide Energy Northwest and appropriate agencies a process and framework for rare plant management (consultation, reporting and surveys) within the Project area, which includes the FERC-designated Project boundary, and lands affected by Project operation or Project-related activities over the life of the new License. 3.0 CONSULTATION AND REPORTING This section describes the consultation and reporting process Energy Northwest will follow with regard to rare plants in the Packwood Lake Project area. For the purposes of this Plan, “rare plant species” include all USDA Forest Service Regional Forester Special Status Species (USFS, 2008) vascular plants,

Energy Northwest 3 June 2008 Packwood Lake Project Rare Plant Management Plan

bryophytes, and lichens; Washington Natural Heritage Program (WNHP) plant species; and U.S. Fish and Wildlife Service (USFWS) Threatened, Endangered and Sensitive plant species (Appendix 1). The Rare Plant Management Plan will ultimately be a part of, and will be coordinated with, the Threatened, Endangered, and Sensitive Species Plan. Lands addressed by this Plan include those within the FERC Project boundary, or those outside of the Project boundary influenced by Project-related, ground-disturbing activities, or any other activities conducted as a part of Project operations or license compliance.

An annual rare plant management report describing all activities related to rare plant management will be provided to the Forest Service and other interested agencies 30 days prior to the annual Resource Coordination meeting (which will be required under the Forest Service mandatory conditions). The annual meeting will provide a routine opportunity for agency consultation regarding rare plants and other environmental topics important to the operation of the Project as they affect Forest Service administered lands. The report will also provide details for the coming year’s planned activities and determine whether preparation of any biological evaluations will be necessary. Energy Northwest will allow a minimum of 60 days for the Forest Service and other agencies to comment and make management recommendations prior to filing the final annual report with the Commission for approval. If Energy Northwest does not adopt a recommendation, the report will include the reasons, based on Project-specific information. The annual report and the Rare Plant Management Plan will include updated Forest Service, WNHP, and USFWS rare plant species lists, in which plant species are added or removed, according to changes in their status. Activities associated with other management plans, including the Integrated Weed Management Plan, Lower Lake Creek Stream Restoration Plan, and the Road Maintenance Plan will be coordinated with the provisions and goals of the Rare Plant Management Plan.

The Packwood Project Specialist will oversee and monitor activities relating to the Rare Plant Management Plan, evaluate the effectiveness of existing protective measures, coordinate with the Forest Service and other agencies, and maintain an in-house rare plant occurrence database and will be responsible for preparing the annual rare plant management report. New information will be added to the Plan annually and it will be reviewed every 5 years and updated, if needed, in consultation with the agencies. The agency review and comment procedures described above for the annual report will be used for any future filing of a revised, updated plan.

Rare plant surveys and monitoring efforts on GPNF lands will meet standards described in the Threatened, Endangered and Sensitive Plants Survey Field Guide (USFS 2005a). Newly located and existing rare plant occurrences will be documented following Threatened, Endangered, and Sensitive Plants Element Occurrences Field Guide (USFS 2005b). Rare plant surveys and monitoring of other public, private, and Energy Northwest lands will be performed and

Energy Northwest 4 June 2008 Packwood Lake Project Rare Plant Management Plan

documented according to the methodology described in the Revised Rare Plant Survey Study Plan for Energy Northwest’s Packwood Lake Hydroelectric Project FERC No. 2244, Lewis County, Washington located in Appendix 2. All rare plant surveys and monitoring will be done at an appropriate time of the year by qualified botanists. 4.0 SURVEYS AND PROTECTION This section describes how biological evaluations, rare plant surveys, monitoring, and rare plant management will occur within the Packwood Lake Project area.

4.1 Biological Evaluation

Where there is a potential for Regional Forester Special Status Species to be affected by Project operations or maintenance, actions associated with other management plans, or other ground disturbing activities, Energy Northwest will consult with the Forest Service in advance, to determine the need for, and if necessary, prepare a draft biological evaluation. Biological evaluations will be based on the location of known rare plant occurrences, the type of ground disturbing activity and potential impacts associated with it. Biological evaluations are subject to review and approval by the Forest Service for habitat and ground- disturbing activities on NFS lands. If Project-related effects to rare plant occurrences are anticipated, reasonable protection, mitigation, enhancement or restoration measures will be implemented, as defined in the approved biological evaluation. Updated Forest Service, WNHP, and USFWS rare plant species lists will be included in the biological evaluation. Any field surveys or monitoring will be conducted and reported according to Forest Service standards.

4.2 Project Area Rare Plant Survey

Rare plant surveys of the Packwood Lake Project area were conducted between 2005 and 2007. The results of these surveys are contained in the report included in Appendix 3. Additional surveys of the Project area will be conducted at 10- year intervals for the duration of the Project’s new license. The first survey will be in 2016; ten years after the initial rare plant survey. These surveys will follow the standard field methods described in the Revised Rare Plant Survey Study Plan for Energy Northwest’s Packwood Lake Hydroelectric Project FERC No. 2244, Lewis County, Washington (Appendix 2). Surveys of USFS lands will also meet standards described in the Threatened, Endangered and Sensitive Plants Survey Field Guide (USFS 2005a) and in the Threatened, Endangered, and Sensitive Plants Element Occurrences Field Guide (USFS 2005b). Figure 1 is a map of the area that will be surveyed. The 10-year survey is to include Lower Lake Creek with the exception of inaccessible areas that are a safety concern. (See Section 1.1 and Figure 1-1 of the revised Rare Plant Survey Final Report in Appendix 3 for a comprehensive description of the study area.) Results of surveys will be reported to appropriate agencies in the annual report and

Energy Northwest 5 June 2008

Packwood Lake Project Rare Plant Management Plan

Energy Northwest 6 June 2008 Packwood Lake Project Rare Plant Management Plan

protective measures will be developed and applied to any new rare plant occurrences.

4.3 Monitoring A strategy of adaptive management will be employed with respect to rare plant occurrences such that if protective measures are implemented, effectiveness monitoring will take place at agreed intervals. Alternative measures will be developed in consultation with the Forest Service if proposed control measures fail to protect or enhance rare plant occurrences as anticipated.

Known rare plant occurrences on NFS lands within the Project Boundary (i.e., the Peltigera pacifica and Oregon goldenaster occurrences) will be monitored to identify potential Project effects every 2 years for 6 years following License issuance and at 5-year intervals thereafter. The first of the every 2-year surveys will occur in year 1 of the new license. The 5-year surveys will be synchronized with the 10-year Project area surveys described above. Results of the monitoring effort will be included in the annual report to the appropriate agencies to evaluate the effectiveness of existing protection, mitigation, enhancement, and restoration measures. If there are negative Project-related effects, Energy Northwest will consult with the appropriate agencies during the annual meeting to modify and improve protective measures. Follow-up monitoring will measure the effectiveness of any protective measures that are implemented. This information will be included in the annual report and will be incorporated into the Rare Plant Management Plan.

4.4 Management of Known Rare Plant Occurrences The rare plant species located and mapped in the Packwood Lake study area during rare plant surveys conducted from 2005 to 2007 are included in Appendix 3. The Pipeline Road Peltigera pacifica occurrence and the Cowlitz River Oregon goldenaster occurrence are the only rare plant species known within the Project area.

4.4.1 Peltigera pacifica

The Peltigera pacifica Pipeline Road occurrence consists of eight small subpopulations along a 1.25 mile portion of FS Road 1260-066 (Pipeline Road), Pipeline Trail #74 and the buried pipeline (all on NFS lands; see Appendix 2). Project-related maintenance of any of these features has the potential to affect the Peltigera pacifica occurrence through direct loss, disturbance, noxious weed spread or habitat alterations. Invasive plant species could potentially degrade or occupy Peltigera habitat. The Peltigera occupies habitat adjacent to, but not on the road prism of FS Road 1260-066 and the Pipeline Trail, which has been subject to minimal routine maintenance during the last several years. While there are no planned changes to how the road, Pipeline Trail or pipeline will be used or maintained under the new License, inevitably some maintenance to the

Energy Northwest 7 June 2008 Packwood Lake Project Rare Plant Management Plan road, trail, or pipeline will be necessary in the future. Ground-disturbing activities associated with maintenance could affect Peltigera thalli or habitat. The overstory canopy of young coniferous trees and tall shrubs growing along the road and pipeline where the Peltigera pacifica grows might become too large and require trimming or removal. If disturbance in its habitat or to its population were unavoidable, Peltigera pacifica may be able to successfully maintain or reestablish itself through time based on the observation that the population initially established itself in the young forested stand that grew up after the road and pipeline were constructed in the early 1960s.

Peltigera pacifica is a USDA Forest Service Regional Forester Special Status Species lichen species that grows on soil, duff, woody debris and occasionally on tree bases in low elevation, moist forests. This lichen species is identifiable year round (when not under snow).

Energy Northwest proposes the following measures for protection, mitigation, and enhancement of the Pipeline Road Peltigera pacifica occurrence in the Project Area.

Monitor the Peltigera pacifica occurrence every 2 years for 6 years following License issuance and at 5-year intervals thereafter. During these surveys, monitor for noxious weed infestations in Peltigera habitat. If noxious weeds are located in Peltigera habitat, these weeds will be controlled according to the Packwood Lake Project Integrated Weed Management Plan in consultation with the Forest Service. FS Road 1260-066 will be maintained according to Forest Service Maintenance Level 2 guidelines. At this maintenance level, it is not anticipated that activities will need to occur off the road prism. Peltigera pacifica thalli have not been found growing on the road prism. A biological evaluation for Peltigera pacifica subpopulations would be done in advance of any road or trail maintenance, tree and shrub trimming, or other ground disturbing activities planned for the area outside of the road or trail prism that would affect Peltigera pacifica thalli. A plan would be developed in consultation with the Forest Service, with a goal of avoiding or minimizing damage to Peltigera pacifica thalli and habitat and would include provisions to monitor, mark, protect, or move affected subpopulations during ground- disturbing activities. If damage to Peltigera pacifica thalli or habitat were unavoidable, rocks and moss mats with the attached lichen thalli could be experimentally permanently moved to a similar habitat or temporarily moved and replaced after maintenance work has been completed. If such transplanting were attempted, the transplants would be monitored twice a season for two years, or as agreed, to track and document whether this technique is successful. If destruction of some Peltigera pacifica subpopulations were unavoidable, a survey would be made for other populations outside of the Project area in the

Energy Northwest 8 June 2008 Packwood Lake Project Rare Plant Management Plan

general vicinity. These populations would be preserved to provide for local propagation opportunities. Any needed revegetation of disturbed areas would be done with native plant species according to Forest Service standards. Rare plant training will be provided to appropriate Energy Northwest personnel. This training will cover all Forest Service rare plant species in the Project area, and provide information related to identification, ecology and protection.

4.4.2 Oregon goldenaster

An occurrence of Oregon goldenaster (Heterotheca oregona) is located on the Cowlitz River gravel bar near the tailrace, within the Project Boundary on land owned by Energy Northwest and on private land owned by others. There is also a small occurrence of four plants on private land at the confluence of Lake Creek and the Cowlitz River, which is not in the Project Boundary (see Appendix 3). Project-related activities or effects that would cause direct loss, disturbance, or habitat alterations are not likely to occur either under the current license or under the proposed Project operating regime. Oregon goldenaster is a WNHP Sensitive species. Its typical habitat is open, sunny to partially shaded sites on sand and gravel bars along rivers. Seasonal river flooding is probably important in maintaining the habitat for this species (WNHP 2007). It is identifiable from June to September.

Listed noxious weeds, such as butterfly bush and Japanese knotweed, could cause habitat degradation and destruction within the Oregon goldenaster population. Operation of the Project may provide continued avenues for noxious weed introduction, establishment and spread. Energy Northwest is developing an Integrated Weed Management Plan for the Project, which establishes responsibilities and requirements for the control of noxious weed infestations within the Project area. Noxious weed control would be deemed necessary, if listed noxious weeds such as butterfly bush or Japanese knotweed are present within Oregon goldenaster habitat in the Project area. As directed by the Integrated Weed Management Plan, Energy Northwest is required to remove butterfly bush, knotweed species and other weed species listed by the LCNWCB within the Project area. Control of the noxious weeds in and near the population would be beneficial, but care will be taken also, so that rare plants are not negatively affected by trampling or control measures.

Energy Northwest proposes the following measures for protection, mitigation, and enhancement of the Oregon goldenaster occurrence in the Project area.

Resurvey the Oregon goldenaster occurrence every five years to monitor and identify Project effects during the new license term. During these surveys, monitor for noxious weed infestations in Oregon goldenaster habitat. If noxious weeds are located, they will be controlled

Energy Northwest 9 June 2008 Packwood Lake Project Rare Plant Management Plan

according to the Integrated Weed Management Plan in consultation with the LCNWCB. Though none is planned during the next license period, if any Project-related ground disturbing activities in the vicinity of the Oregon goldenaster occurrence were to occur, the Forest Service would be consulted to determine the need for a biological evaluation. A biological evaluation would be prepared if necessary, in advance of any ground disturbing activities in the area, with the goal of avoiding or minimizing damage to the goldenaster occurrence. Ensure that any fish habitat restoration efforts in the Lower Lake Creek area (RM 0.0 to 0.3) do not disturb the small Oregon goldenaster subpopulation at the mouth of Lake Creek. Native plants should be used to revegetate any disturbed areas

4.4.3 Collema nigrescens, Nephroma bellum, Nephroma occultum, and Platismatia lacunose

Small occurrences of four Regional Forester Special Status Species lichens (Collema nigrescens, Nephroma bellum, Nephroma occultum, and Platismatia lacunosa) were located together just outside of the Project boundary, along the Packwood Lake Trail in the Goat Rocks Wilderness Area (see Appendix 3). Collema nigrescens grows on the bark of broad-leaved trees and shrubs, in low elevation forests. Nephroma bellum grows on trees, shrubs and mossy rocks, in moist forests with strong coastal influences. Nephroma occultum grows on the bark and wood of conifers in old growth forests in the west Cascades. Platismatia lacunosa grows on bark and wood of trees, especially alders, and mossy rocks, in moist riparian forests and moist cool upland sites. All four of these lichen species are identifiable year round. No Project-related activities are anticipated to affect any of these occurrences, and thus no special management measures for these species are proposed.

5.0 RARE PLANT MANAGEMENT COSTS The cost of consultation and development of the Rare Plant Management Plan is estimated to be approximately $10,000. The Rare Plant Management Plan requires the monitoring of rare plant occurrences every 2 years for 6 years following license issuance and at 5-year intervals thereafter. The cost of a monitoring and reporting effort for the Peltigera pacifica and Oregon goldenaster occurrences is estimated to be $4,000. The estimated cost of the Project area rare plant survey and report preparation, which is to be performed every ten years, is $25,000. The yearly costs associated with updating the Rare Plant Management Plan, consultation with stakeholders, and filing annual reports are estimated to be about $3,000.

Energy Northwest 10 June 2008 Packwood Lake Project Rare Plant Management Plan

6.0 REFERENCES

Energy Northwest. 2005. Revised Rare Plant Survey Study Plan for Energy Northwest’s Packwood Lake Hydroelectric Project FERC No. 2244, Lewis County, Washington.

Energy Northwest. 2008. Packwood Lake Hydroelectric Project Integrated Weed Management Plan.

Energy Northwest. 2008. Packwood Lake Road Maintenance Plan.

FERC. 2008. Request for Additional Information. Packwood Lake Hydroelectric Project No. 2244-022. Energy Northwest. April 8, 2008.

USDA Forest Service. 2005a. Threatened, Endangered, and Sensitive Plants Survey Field Guide.

USDA Forest Service. 2005b. Threatened, Endangered, and Sensitive Plants Element Occurrences Field Guide.

USDA Forest Service. 2008. Regional Forester’s Special Status Species List - Federally Threatened, Endangered, and Proposed (TE&P), USDA Forest Service, Pacific Northwest Region, January 2008. http://www.fs.fed.us/r6/sfpnw/issssp/agency-policy/

Washington Natural Heritage Program. 2007. Endangered, Threatened, and Sensitive Vascular Plants of Washington. On-line at: http://www.dnr.wa.gov/nhp/refdesk/fguide/pdf/hetore.pdf

Energy Northwest 11 June 2008

Packwood Lake Hydroelectric Project Rare Plant Management Plan

Appendix 1

Updated US Forest Service Sensitive Species, and WNHP List of Known Occurrences of Rare Plants in Washington

Packwood Lake Hydroelectric Project Rare Plant Management Plan Appendix 1

Updated US Forest Service Sensitive Species, and WNHP List of Known Occurrences of Rare Plants in Washington

GPNF Sensitive Species February 2008 Documented (D) or Suspected (S) Bolandra oregana D Calochortus longebarbatus var. longebarbatus S Carex macrochaeta S Chrysolepis chrysophylla D Cicuta bulbifera S Cimicifuga elata var. elata D Coptis aspleniifolia S Coptis trifolia S Corydalis aquae-gelidae D Cryptantha rostellata S Cypripedium fasciculatum D Damasonium californicum S Erigeron howellii S Erigeron oreganus S Eryngium petiolatum S Euonymus occidentalis S Fritillaria camschatcensis S Galium kamtschaticum S Hedysarum occidentale D Heuchera grossulariifolia var tenuifolia S Howellia aquatilis (threatened) Juncus howellii D Linanthus bolanderi S Lomatium suksdorfii S Luzula arcuata D Lycopodiella inundata S Meconella oregana S Microseris borealis D Mimulus pulsiferae S Mimulus suksdorfii S Montia diffusa D Navarretia tagetina S Ophioglossum pusillum S Orthocarpus bracteosus D Pedicularis rainierensis S Penstemon barrettiae D Penstemon wilcoxii D Platanthera sparsiflora D Poa laxiflora S

1-1 Updated May 29, 2008

GPNF Sensitive Species February 2008 Documented (D) or Suspected (S) Polemonium carneum S Ranunculus populago D Ranunculus triternatus S Rorippa columbiae S Scribneria bolanderi S Sidalcea hirtipes D Sisyrinchium sarmentosum D Spiraea splendens D Sullivantia oregana S Utricularia intermedia D Encalypta brevicollis S Schistostega pennata D Scouleria marginata S Tetraphis geniculata D Cetrelia cetrariodes D Chaenotheca subroscida D Collema nigrescens D Dendriscocaulon intricatulum D Dermatocarpon meiophyllizum D Hypotrachyna revoluta S Leptogium burnetiae S Leptogium cyanescens S Nephroma bellum D Nephroma occultum D Pannaria rubiginosa S Peltigera pacifica D Platismatia lacunosa D Pseudocyphellaria rainierensis D Tholurna dissimilis D Usnea longissima D Albatrellus ellisii D Bridgeoporus nobillisimus D Gomphus kauffmanii D Leucogaster citrinus D Otidea smithii D Pseudorhizina californica (syn. Gyromitra californica) D Ramaria cyaneigranosa D Ramaria gelatiniaurantia D Ramaria rubrievanescens D Sarcodon fuscoindicus D Sowerbyella rhenana D Spathularia flavida D

1-2 Updated May 29, 2008

Rare plant Management Plan, Appendix 1, continued.

Washington Natural Heritage Information System List of Known Occurrences of Rare Plants in Washington February 2008 Lewis County A key to status fields appears below. If a scientific name is underlined you may click on it to go to a field guide page (pdf format, average size 300 kb) for that taxon.

State Federal Historic Scientific Name Common Name Status Status Record Balsamorhiza deltoidea Puget Balsamroot R2 Calamagrostis canadensis var. Blue Joint Reedgrass R2 H imberbis Carex densa Dense Sedge T Cimicifuga elata var. elata Tall Bugbane S SC Delphinium leucophaeum Pale Larkspur E SC Erigeron aliceae Alice's Fleabane S Eryngium petiolatum Oregon Coyote-thistle T Erythronium revolutum Pink Fawn-lily S Euonymus occidentalis Western Wahoo T Githopsis specularioides Common Blue-cup S Isoetes nuttallii Nuttall's Quillwort S Lathyrus holochlorus Thin-leaved Peavine E SC Lathyrus vestitus ssp. bolanderi Pacific Pea E Lupinus sulphureus ssp. kincaidii Kincaid's Sulfur Lupine E LT Meconella oregana White Meconella T SC H Montia diffusa Branching Montia S H Pedicularis rainierensis Mt. Rainier Lousewort S Poa laxiflora Loose-flowered Bluegrass S Polemonium carneum Great Polemonium T Potentilla drummondii ssp. breweri Brewer's Cinquefoil T H Sidalcea hirtipes Hairy-stemmed Checker-mallow E Sidalcea nelsoniana Nelson's Checker-mallow E LT

Description of Codes Historic Record: H indicates most recent sighting in the county is before 1977. State Status: State Status of plant species is determined by the Washington Natural Heritage Program. Factors considered include abundance, occurrence patterns, vulnerability, threats, existing protection, and taxonomic distinctness. Values include: E = Endangered. In danger of becoming extinct or extirpated from Washington. T = Threatened. Likely to become Endangered in Washington. S = Sensitive. Vulnerable or declining and could become Endangered or Threatened in the state. X = Possibly extinct or Extirpated from Washington.

1-3 Updated May 29, 2008

R1 = Review group 1. Of potential concern but needs more field work to assign another rank. R2 = Review group 2. Of potential concern but with unresolved taxonomic questions.

Federal Status

Federal Status under the U.S. Endangered Species Act(USESA) as published in the Federal Register: LE = Listed Endangered. In danger of extinction. LT = Listed Threatened. Likely to become endangered. PE = Proposed Endangered. PT = Proposed Threatened. C = Candidate species. Sufficient information exists to support listing as Endangered or Threatened. SC = Species of Concern. An unofficial status, the species appears to be in jeopardy, but insufficient information to support listing.

1-4 Updated May 29, 2008

Packwood Lake Hydroelectric Project Rare Plant Management Plan

Appendix 2

Revised Rare Plant Survey Study Plan for Energy Northwest’s Packwood Lake Hydroelectric Project FERC No. 2244

Revised

Rare Plant Survey Study Plan for Energy Northwest's Packwood Lake Hydroelectric Project FERC No. 2244 Lewis County, Washington

Submitted to

P.O. Box 968 Richland, Washington 99352-0968

Submitted by Beck Botanical Services

Kathryn Beck Bellingham, Washington 98225 360.671.6913 phone

August 22, 2005

Revised Rare Plant Survey Study Plan Energy Northwest Packwood Lake Hydroelectric Project August 22, 2005 FERC No. 2244

TABLE OF CONTENTS

Section Title Page

1.0 INTRODUCTION...... 1 1.1 Study Plan Goals and Objectives ...... 1

2.0 AGENCY AND TRIBE RESOURCE MANAGEMENT GOALS AND OBJECTIVES 3 2.1 USDA Forest Service Resource Management Goals ...... 1 2.2 WDFW Resource Management Goals ...... 1

3.0 EXISTING INFORMATION AND NEED FOR ADDITIONAL INFORMATION 3 3.1 Existing Information ...... 3 3.2 Need for Additional Information ...... 4

4.0 NEXUS BETWEEN PROJECT OPERATIONS AND EFFECTS ON RESOURCES ...... 5

5.0 STUDY AREA AND METHODS...... 10 5.1 Study Area ...... 4 5.2 Rare Plant Survey Methodology...... 4 5.2.1 Pre-field Review...... 4 5.2.2 Field Surveys ...... 4 5.3 Products...... 5 5.4 Consistency with Generally Accepted Scientific Practice...... 5

6.0 CONSULTATION WITH AGENCIES, TRIBES AND OTHER STAKEHOLDERS 6

7.0 PROGRESS REPORTS, INFORMATION SHARING, AND TECHNICAL REVIEW...... 6 7.1 Progress Reports...... 6 7.2 Information Sharing ...... 6 7.3 Technical Review...... 6

8.0 SCHEDULE...... 6

9.0 LEVEL OF EFFORT AND COST ...... 7

10.0 LITERATURE CITED ...... 13

i Revised Rare Plant Survey Study Plan Energy Northwest Packwood Lake Hydroelectric Project August 22, 2005 FERC No. 2244

LIST OF FIGURES

Figure Title Page

5-1 Study Area Map...... 3

ii Revised Rare Plant Survey Study Plan Energy Northwest Packwood Lake Hydroelectric Project August 22, 2005 FERC No. 2244

APPENDICES

Appendix A - Current List of Known Occurrences of Rare Plants in Lewis County, WNHP Appendix B - Current Sensitive Species Vascular Plant List for the Gifford Pinchot National Forest, from the Region 6 USFS Sensitive Species Plant List Appendix C - Current USDA Forest Service, Pacific Northwest Region. Regional Forester’s Sensitive Plant List, Lichens and Bryophytes

iii Revised Rare Plant Survey Study Plan Energy Northwest Packwood Lake Hydroelectric Project August 22, 2005 FERC No. 2244

1.0 INTRODUCTION

Energy Northwest’s Packwood Lake Hydroelectric Project, FERC No. 2244, received its initial license in 1960. The majority of the Project is located within the Gifford Pinchot National Forest and consists of an intake canal, a concrete drop structure (dam) and intake building on Lake Creek located about 424 feet downstream from the outlet of Packwood Lake, a 21,691-foot system of concrete pipe and tunnels, a 5,621-foot penstock, a surge tank, and powerhouse with a 26,125 kW turbine generator.

The source of water for the Project, Packwood Lake, is a natural lake situated at an elevation of approximately 2,857 feet above mean sea level (MSL), about 1,800 feet above the powerhouse. Water discharged from the Project is released to the Cowlitz River via a tailrace channel. Power from the Project is delivered over an 8,009-foot 69 kV transmission line to the Packwood substation.

1.1 Study Plan Goals and Objectives

The rare plant survey of the Packwood Lake Hydroelectric Project will determine the location and distribution of rare plants within the Project boundary and areas of influence, assess potential relicensing effects on them, and will provide a baseline of information for future surveys. For the proposed work, the term “rare plant” includes USDA Forest Service Sensitive species, Washington Natural Heritage Program (WNHP) species, and U.S. Fish and Wildlife Service (USFWS) Threatened, Endangered and Sensitive species. The Forest Service Sensitive species list includes vascular plants, lichens, and bryophytes. The work will be conducted in consultation with the Gifford Pinchot National Forest, WNHP, Washington Department of Fish and Wildlife (WDFW), USFWS, and concerned tribes.

2.0 AGENCY AND TRIBE RESOURCE MANAGEMENT GOALS AND OBJECTIVES

The Forest Service and WDFW requested this study (USDA Forest Service 2005b, WDFW 2005). Resource management goals were provided by these agencies and are listed below.

2.1 USDA Forest Service Resource Management Goals

The 1990 Gifford Pinchot Land and Resource Management Plan contains the following direction pertinent to this study (USDA Forest Service 2005b):

• Management activities will be reviewed to make sure that Sensitive, Threatened, or Endangered plants are being protected (IV-37).

2.2 WDFW Resource Management Goals

WDFW Resource Management goals include (WDFW 2005):

1 Revised Rare Plant Survey Study Plan Energy Northwest Packwood Lake Hydroelectric Project August 22, 2005 FERC No. 2244

• Facilitate the recovery of species proposed or listed under federal Endangered Species Act. • Facilitate the recovery of state listed endangered and threatened, and state and federally proposed candidate, sensitive or monitor species.

3.0 EXISTING INFORMATION AND NEED FOR ADDITIONAL INFORMATION

The following sections discuss previous rare plant surveys in the Packwood Lake Project area and the need for additional information.

3.1 Existing Information

Existing information on rare plants and botanical resources generally in and near the Packwood Lake Project area is very limited. No known dedicated rare plant surveys have been conducted in or near the Project area. The WNHP reports no records of state or federally listed rare plants or high quality native ecosystems in the vicinity of the Project (WNHP 2004). Rare plant species known from elsewhere in Lewis County are listed in Appendix A.

3.2 Need for Additional Information

The lack of past surveys or existing information regarding rare plants in the Project area indicates the need for information on the presence and distribution of rare plants within the area influenced by Project operations and maintenance activities. Additional information will help identify Project related actions that may be influencing the distribution of rare plants and potential measures that may be taken to protect, mitigate and enhance them.

4.0 NEXUS BETWEEN PROJECT OPERATIONS AND EFFECTS ON RESOURCES

Rare plant surveys will provide current baseline information on existing conditions in the Project area and assess Project-related effects. Project-related actions, such as water level fluctuations in Packwood Lake, operation and maintenance of Project rights-of- way, erosion, recreation effects, potential new construction, and any other Project- related activities could adversely affect rare plant populations through direct loss, disturbance, noxious weed spread, or habitat alterations. If potentially negative effects are identified, measures may be developed to reduce or eliminate these effects.

5.0 STUDY AREA AND METHODS

A rare plant survey in the Packwood Lake Project area (see Figure 5-1) will identify rare plant populations present in the Project area and evaluate potential Project effects on them. The following sections discuss the planned survey.

2 Revised Rare Plant Survey Study Plan Energy Northwest Packwood Lake Hydroelectric Project August 22, 2005 FERC No. 2244

Figure 5-1. Study Area Map

3 Revised Rare Plant Survey Study Plan Energy Northwest Packwood Lake Hydroelectric Project August 22, 2005 FERC No. 2244

5.1 Study Area

For purposes of the Packwood Lake rare plant survey, the study area is defined as including: 100 feet on each side of the Project boundary, including Project facilities, pipeline, tailrace, penstock corridor, transmission line, Pipeline Road (FS Road 1260- 066), FS Road 1260 from the surge tank to the junction with FSR 1260-066; Trail #74, Latch Road (FS Road 1262); a 200-foot-margin around the perimeter of Packwood Lake (elevation 2860); and the mouths of all USFS Type 1, 2, and 3 streams (Osprey Creek, Trap Creek, Baker Creek, Crawford Creek, Upper Lake Creek) that have a defined channel from the point where they enter Packwood Lake, upstream 200 feet. The survey will identify and include wetland and riparian sites related to the Project. Lower Lake Creek below the drop structure will be surveyed in riparian areas (stream buffer) with the exception of inaccessible safety areas. In addition, two landslide areas (from 1995 and 2000) near the pipeline will be surveyed for rare plants. See Figure 5-1 for a map showing the proposed study area.

5.2 Rare Plant Survey Methodology

The rare plant inventory will consist of pre-field review, field surveys and herbarium research if deemed necessary.

5.2.1 Pre-field Review

Rare plant species known from Lewis County are listed in Appendix A. An information request to the WNHP was done in 2004 (WNHP 2004). A pre-field review was completed by Gifford Pinchot botanist Andrea Ruchty (USDA Forest Service 2005a). Appendix B contains the Sensitive Species Vascular Plant List for the Gifford Pinchot National Forest, which was compiled from the Region 6 USFS Sensitive Species Plant List (July 2004). Appendix C contains the Regional Forester’s Sensitive Lichens and Bryophytes List for the Gifford Pinchot National Forest (updated July 2004).

5.2.2 Field Surveys

The rare plant survey of the study area will be performed using commonly accepted botanical survey methods to locate and identify rare plant occurrences. Rare plant survey methods are straightforward, and involve visually searching the study area for the presence of rare plant species. Timing of field surveys is based on flowering times of potential rare plant species, i.e., upland plant species will be searched for earlier in the field season than plants that occur in wetlands and riparian areas, because they typically bloom earlier. Some areas may need to be visited twice to search for both early and late blooming rare plants. Forest Service protocols for locating lichens and bryophytes will be used. Lichen and bryophyte species are generally identifiable during the summer months. The entire study area will be searched as rare plant species could be found in many of the habitat types that comprise the study area. A GPS unit will be used to accurately map rare plant populations where feasible. Photographs will be taken of all rare plant species (close-ups of individual plants and more general habitat

4 Revised Rare Plant Survey Study Plan Energy Northwest Packwood Lake Hydroelectric Project August 22, 2005 FERC No. 2244

shots). Plant collections will be made when it is deemed necessary to identify a plant. Most collections will eventually be deposited at either the University of Washington herbarium or at the Gifford Pinchot herbarium. Depending on the habitat, the survey intensity employed in the field will be a combination of:

Moderate: Moderate search intensity through an area, with higher intensity surveys in portions of areas which appear unique or which appear to have a high potential for rare plant populations.

Complete: Close searching in areas with rare plant populations or in habitats with a very high potential of having rare plant populations.

It is expected that most of the study area will receive a moderate search intensity. The majority of plants will be identified in the field using the Flora of the Pacific Northwest (Hitchcock and Cronquist 1973). Plant determinations will be supplemented by other regional floras and published papers as needed. Bryophyte and lichen species may be collected for identification. Vouchers of rare lichen or bryophyte species will be made. Visits to the University of Washington herbarium to aid in plant determinations will be made if necessary. The rare plant survey will be done concurrently with the noxious weed survey.

5.3 Products

Products of the Packwood Lake rare plant survey will include: Botanical Survey Forms for each general area surveyed and Region 6 Threatened, Endangered and Sensitive Plant Sighting Forms for each rare plant population located or revisited. The Region 6 Threatened, Endangered and Sensitive Plant Sighting Form includes detailed site information, such as population size, area, habitat, substrate, disturbance, potential or on-going threats, and associated species. Sighting forms will be accompanied by USGS maps with rare plant population polygons and survey routes. Populations will be mapped on USGS maps with the aid of a GPS unit. A draft final report will be written, which will discuss the methods, and survey results (rare species found, their distribution and habitat associations). In addition, a complete list of all plant species identified during the survey will be compiled. If study results indicate that there is a demonstrated Project impact or likely impact, a management plan will be developed to include some combination of avoiding impacts, protecting resources, monitoring their condition, and conducting mitigation as needed.

Draft copies of the products will be provided to agencies for review and comment. Following production of final products, copies will be provided to agencies for their files.

5.4 Consistency with Generally Accepted Scientific Practice

The planned study methods discussed above are consistent with the methods followed in the Baker Lake Hazard Tree Project (USDA Forest Service 2005b), the Rocky Reach Hydroelectric Project, the Lake Chelan Hydroelectric Project, and the Methow

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Transmission Project and have been accepted by the participating agencies, and parties in those projects.

6.0 CONSULTATION WITH AGENCIES, TRIBES AND OTHER STAKEHOLDERS

Energy Northwest initiated agency consultation in December 2003. Meetings with the stakeholder representatives will take place periodically beginning in May 2005. This may include one or more field visits to the study area, as needed. Stakeholder representatives will be invited to provide information for the study and technical reviews of the draft Project rare plant report.

7.0 PROGRESS REPORTS, INFORMATION SHARING, AND TECHNICAL REVIEW

The following sections discuss progress reports, information sharing, and technical review. These activities pertain to the Project’s botanical resource stakeholders: designated representatives of the Gifford Pinchot National Forest, WNHP, WDFW, USFWS, FERC, and concerned tribes.

7.1 Progress Reports

In meetings with agency and tribal representatives, Energy Northwest and its consultants will report on the methods, progress, and results of the rare plant survey.

7.2 Information Sharing

Reports containing confidential information regarding rare plant population locations will be marked “confidential” and shared only with the agencies and tribes. Confidential rare plant population information will be removed from documents that are shared with the public.

7.3 Technical Review

Energy Northwest will provide copies of the draft rare plant survey report to agency and tribal representatives for review. Review periods will be 30 days, after which Energy Northwest and its consultants will take review comments into consideration when making revisions and producing final reports.

8.0 SCHEDULE

Most of the pre-field review has been completed. Rare plant surveys for the Packwood Lake study area are scheduled to begin during the summer field season of 2005 and completed in spring and summer of 2006. The noxious weed survey will be done concurrently with the rare plant survey. Data analysis and report writing will occur by September 2006. The completed draft rare plant survey report will be distributed to the agencies and concerned tribes for review in mid-September 2006.

6 Revised Rare Plant Survey Study Plan Energy Northwest Packwood Lake Hydroelectric Project August 22, 2005 FERC No. 2244

9.0 LEVEL OF EFFORT AND COST

The study efforts outlined above are intended to provide relevant information regarding rare plant populations in the Project area. Taking into account past planning, research, and studies, and the size, location and nature of the Project, Energy Northwest and its consultants will make a reasonable and good faith effort to conduct a high quality rare plant survey. Because it is cost effective to conduct the Rare Plant Survey concurrently with the Noxious Weed Survey; the cost estimate provided below includes both studies. The time and cost are estimates because rough terrain, difficult access, and a large number of rare plant and noxious weed populations could increase the amount of overall time needed for the survey. Given those caveats, it is estimated that to conduct both studies would require approximately 390 hours of time for the botanist to conduct field investigations and write the reports. It is estimated that both studies will cost approximately $30,382.

10.0 LITERATURE CITED

Energy Northwest. 2004. Packwood Lake Hydroelectric Project. FERC Project No. 2244. Pre-Application Document. Supplement No. 1. December 6, 2004.

Hitchcock, C.L. and A. Cronquist. 1973. Flora of the Pacific Northwest. University of Washington Press. Seattle, Washington.

USDA Forest Service. 2005a. Pre-field Review. Summary of Potential Botanical Concerns, Packwood Lake. A. Ruchty, Forest Service. February 7, 2005.

USDA Forest Service. 2005b. Comments on PAD and Scoping Document 1 and Study Requests. Packwood Lake Project Number 2244-012. March 11, 2005.

Washington Department of Fish and Wildlife. 2005. Comments on PAD, Study Requests, Comments on Scoping Document 1. Packwood Lake Hydroelectric Project FERC No. 2244-012. March 9, 2005.

Washington Natural Heritage Program (WNHP). 2004. Memorandum from S. Swope, WNHP. Packwood Hydroelectric Relicensing Project (T13NR09-10E). June 2, 2004.

Washington Natural Heritage Program. 2004. Endangered, Threatened, and Sensitive Vascular Plants of Washington. On-line at http://www.dnr.wa.gov/nhp/refdesk/lists/plantsxco/countyindex.html

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Appendices to be updated with lists current at time of survey

APPENDIX A Current List of Known Occurrences of Rare Plants in Lewis County, WNHP

APPENDIX B Current Sensitive Species Vascular Plant List for the Gifford Pinchot National Forest, from the Region 6 USFS Sensitive Species Plant List

APPENDIX C Current USDA Forest Service, Pacific Northwest Region. Regional Forester’s Sensitive Plant List, Lichens and Bryophytes.

Packwood Lake Hydroelectric Project Rare Plant Management Plan Appendix 3

Rare Plant Survey Final Report for Energy Northwest’s Packwood Lake Hydroelectric Project

Revised

Rare Plant Survey Final Report for Energy Northwest's Packwood Lake Hydroelectric Project FERC No. 2244 Lewis County, Washington

Submitted to

P.O. Box 968 Richland, Washington 99352-0968

Submitted by Beck Botanical Services

Kathryn Beck Bellingham, Washington 98225 360.671.6913 phone

May 2008

Rare Plant Survey Report Energy Northwest Packwood Lake Hydroelectric Project May 2008 FERC No. 2244

TABLE OF CONTENTS

Section Title Page 1.0 INTRODUCTION ...... 1 1.1 Study Area...... 1 2.0 STUDY GOALS AND OBJECTIVES ...... 3 3.0 METHODS...... 3 3.1 Pre-field Review ...... 3 3.2 Field Surveys...... 4 3.3 Documentation of Results ...... 4 4.0 RESULTS...... 5 5.0 DISCUSSION AND RECOMMENDATIONS...... 10 6.0 LITERATURE CITED ...... 13

LIST OF FIGURES

Figure Title Page

1-1 Study Area Map...... 2 4-1 Approximate locations of the TES species located in the Packwood Lake study area, 2005-2006 ...... 6 4-2 Oregon goldenaster (Heterotheca oregona) in the Packwood area...... 7

LIST OF APPENDICES

Appendix A - List of Known Occurrences of Rare Plants in Lewis County, WNHP, 2004 Appendix B - Sensitive Species Vascular Plant List for the Gifford Pinchot National Forest, from the Region 6 USFS Sensitive Species Plant List, April 2006 Appendix C - USDA Forest Service, Pacific Northwest Region. Regional Forester’s Sensitive Plant List, Lichens and Bryophytes. Updated July 2004 Appendix D – List of Plant Species Observed in the Packwood Lake Study Area, 2005 – 2006 Appendix E – List of Lichen Species Observed in the Packwood Lake Study Area, 2005 - 2006

i Rare Plant Survey Report Energy Northwest Packwood Lake Hydroelectric Project May 2008 FERC No. 2244

1.0 INTRODUCTION

Energy Northwest operates the Packwood Lake Hydroelectric Project (Project) near the Town of Packwood in Lewis County, Washington. The Project, FERC No. 2244, received its initial license in 1960. On November 12, 2004 Energy Northwest filed a Notice of Intent (NOI) to file an application for a new license to operate the Project. Energy Northwest also concurrently filed with the Federal Energy Regulatory Commission (FERC) and the resource agencies, a Pre-Application Document (PAD) (Energy Northwest 2004), containing existing, relevant and reasonably available information describing the existing environment and the potential effects of Project facilities and operations. Studies of the potential effects of the Project on native plant communities and populations of any rare plant species present were requested to supplement information contained in the PAD (WDFW 2005, USDA Forest Service b 2005). In consultation with tribes and agencies, Energy Northwest developed a study plan to survey for rare plants in the Project area. This report presents results of the field surveys between July 2005 and May 2007.

The majority of the Project is located within the Gifford Pinchot National Forest and consists of an intake canal, a concrete drop structure (dam) and intake building on Lake Creek located about 424 feet downstream from the outlet of Packwood Lake, a 21,691- foot system of concrete pipe and tunnels, a 5,621-foot penstock, a surge tank, and powerhouse with a 26,125 kW turbine generator. The source of water for the Project, Packwood Lake, the boundary of which is at elevation 2860 feet mean sea level (MSL), about 1,800 feet above the powerhouse. Water discharged from the Project is released to the Cowlitz River via a tailrace channel. Power from the Project is delivered over an 8,009-foot 69 kV transmission line to the Packwood substation.

1.1 Study Area

For purposes of the Packwood Lake rare plant survey, the study area is defined as including: the Project boundary and 100 feet on each side of the Project boundary, including Project facilities, pipeline, tailrace, penstock corridor, transmission line, Pipeline Road (FSR 1260-066), and FSR 1260 from the surge tank to the junction with FSR 1260-066; Trail #74, Latch Road (FSR 1262); a 200-foot-margin around the perimeter of Packwood Lake (elevation 2860 ft MSL); and the mouths of all Forest Service type 1, 2, and 3 streams (Osprey Creek, Trap Creek, Baker Creek, Crawford Creek, Upper Lake Creek) that have a defined channel from the point where they enter Packwood Lake, upstream 200 feet. The survey included wetland and riparian sites related to the Project. Lower Lake Creek below the drop structure was surveyed in riparian areas (stream buffer) with the exception of inaccessible safety areas. Two landslide areas (from 1995 and 2000) near the pipeline were included in the survey. See Figure 1-1 for a map showing the rare plant survey study area.

1 Rare Plant Survey Report Energy Northwest Packwood Lake Hydroelectric Project May 2008 FERC No. 2244

Figure 1-1. Study Area Map

2 Rare Plant Survey Report Energy Northwest Packwood Lake Hydroelectric Project May 2008 FERC No. 2244

2.0 STUDY GOALS AND OBJECTIVES

The rare plant survey for the Packwood Lake Hydroelectric Project identified the location and distribution of rare plants within the Project boundary and areas of potential influence, and assessed potential relicensing effects on them. For the purposes of this survey, the term “rare plant” includes USDA Forest Service Sensitive species, Forest Service Survey and Manage (S&M) species, Washington Natural Heritage Program (WNHP) species, and U.S. Fish and Wildlife Service (USFWS) Threatened, Endangered and Sensitive species. The Forest Service Sensitive species list includes vascular plants, lichens, and bryophytes. The work was conducted in consultation with the Gifford Pinchot National Forest, WNHP, Washington Department of Fish and Wildlife (WDFW), USFWS, and concerned tribes.

3.0 METHODS

The goals of the rare plant survey in the Packwood Lake study area (see Figure 1-1) are to identify rare plant populations present in the Project area and evaluate potential Project effects on them. The rare plant inventory consists of a pre-field review, field surveys and herbarium research if deemed necessary, and documentation of results.

Kathryn Beck is a botanist with 24 years of fieldwork in Washington, Oregon, Idaho, Alaska, and California. Ms. Beck has designed and participated in a diversity of vegetation analysis and natural resources planning projects, and provides botanical consulting and expertise in the following fields: RTE plant surveys, vegetation mapping, and natural resources planning. She is familiar with numerous RTE plant species throughout the Pacific Northwest, their phenology, and habitat requirements. Ms. Beck has over ten years of experience in hydroelectric project licensing and land management assessments. Ms. Beck was involved in locating, describing, and publishing three plant taxa new to science. She has a B.S. in Environmental Sciences and a B.A. in Biology from Western Washington University.

3.1 Pre-field Review

The main goal of a pre-field review is to gather pertinent information about the study area and its botanical resources and to develop a list of target rare plants for the survey. Existing information on rare plants and botanical resources generally in and near the Packwood Lake Project area was very limited. No known dedicated rare plant surveys had been conducted in or near the Project area. An information request to the WNHP done in 2004 yielded no records of state or federally listed rare plants or high quality native ecosystems in the vicinity of the Project (WNHP 2004). WNHP-listed rare plant species known from elsewhere in Lewis County are listed in Appendix A. A pre-field review was completed by Gifford Pinchot National Forest botanist Andrea Ruchty (USDA Forest Service 2005a). Appendix B contains the Sensitive Species Vascular Plant List for the Gifford Pinchot National Forest, which was compiled from the Region 6 Forest Service Sensitive Species Plant List (July 2004). Appendix C contains the Regional Forester’s Sensitive Lichens and Bryophytes List for the Gifford Pinchot

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National Forest (updated July 2004). The lists in these three appendices collectively comprise the target rare plant species for this survey.

3.2 Field Surveys

The Packwood Lake rare plant survey was performed using commonly accepted botanical survey methods to locate and identify rare plant occurrences. Rare plant survey methods are straightforward, and involve visually searching the study area for the presence of rare plant species. Timing of field surveys is critical to the validity of the survey and is based on flowering times of potential rare plant species, i.e., upland plant species are searched for earlier in the field season than plants that occur in wetlands and riparian areas, because they typically bloom earlier. Some areas are visited twice to search for both early and late blooming rare plants. Forest Service protocols for locating lichens and bryophytes are used. Lichen and bryophyte species are generally identifiable during the summer months.

The entire study area is searched, as rare plant species are potentially present in many of the habitat types that comprise the study area. Where feasible, a GPS unit is used to aid in mapping. Photographs are taken of all rare plant species (close-ups of individual plants and more general habitat shots). Plant collections are made when it was deemed necessary to identify a plant. Most collections will eventually be deposited at either the University of Washington herbarium or at the Gifford Pinchot National Forest herbarium. Depending on the habitat, the survey intensity employed in the field is a combination of:

Moderate: Moderate search intensity through an area, with higher intensity surveys in portions of areas which appear unique or which appear to have a high potential for rare plant populations.

Complete: Close searching in areas with rare plant populations or in habitats with a very high potential of having rare plant populations.

Most of the study area received a moderate search intensity.

The majority of plants are identified in the field using the Flora of the Pacific Northwest (Hitchcock and Cronquist 1973). Plant determinations are supplemented by other regional floras and published papers as needed. Vouchers of bryophyte and lichen species are collected for identification. The rare plant survey was done concurrently with the noxious weed survey.

3.3 Documentation of Results

Products of the Packwood Lake rare plant survey include: a Region 6 Threatened, Endangered and Sensitive Plant Element Occurrence Field Form for each rare plant population located or revisited on Forest Service land and a WNHP Sighting Form for each rare plant population located on non-Forest Service portions of the study area.

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Data collected on both forms include detailed site information such as population size, area, habitat, substrate, slope, aspect, elevation, disturbance, potential or on-going threats, and associated species. Sighting forms are accompanied by USGS maps with rare plant population polygons. These documents will be provided separately to the Forest Service, FERC, WDFW, and other agencies and tribes as appropriate.

4.0 RESULTS

Field surveys for rare plant species were conducted in the Packwood Lake Study area during the following dates: July 21 - 25, 2005, July 18 – 26, 2006, August 23, 2006 and May 29 – 31, 2007. No federally listed species were observed in the study area. Appendix D contains a list of the 370 plant species observed during the survey. Appendix E contains a list of lichen species observed during the survey. No federally listed species were observed in the study area. During field surveys, five USDA Forest Service Sensitive lichen species (Collema nigrescens, Nephroma bellum, Nephroma occultum, Platismatia lacunosa and Peltigera pacifica) and one population of the state Threatened plant species Oregon goldenaster were located in the Study area. Figure 4- 1 shows approximate locations of the TES species located in the Packwood Lake Study area, 2005-2007.

A population of each of the five Forest Service Sensitive lichen species Collema nigrescens, Nephroma bellum, Nephroma occultum, Platismatia lacunosa and Peltigera pacifica were located in Forest Service-owned portions of the Study area. Forest Service sensitive lichen species Collema nigrescens, Nephroma bellum, Nephroma occultum, and Platismatia lacunosa were found together growing in a one-acre stand of vine maple within the Goat Rocks Wilderness area. This vine maple stand is growing on a south-facing, stabilized, boulder field near the Packwood Lake shore. It is surrounded by old growth western hemlock and western red cedar forest. The Upper Lake Creek Trail bisects the stand and is used by hikers and pack animals. It is evident that pack animals graze the deciduous shrubs and trees on the side of the trail in this area. No noxious weeds are present in the area. The vine maple stand is not in the Project area or near any Project facilities or management activities.

Collema nigrescens is a foliose lichen which is black, translucent and jelly-like when wet. It typically grows on the bark of broad-leaved trees and shrubs in low-elevation, hardwood forests, often in riparian areas. In the Study area, it was collected from the trunk of a single large Douglas maple in the vine maple stand. A total of ten Collema nigrescens thalli were observed, though there may be additional thalli higher up in this or other tree canopies.

Nephroma bellum is an epiphytic cyanolichen that grows on the boles, lower limbs, or lower twigs of conifers and hardwoods. In the Study area, it was collected from the trunks of vine maples in an old vine maple stand. An estimated total of 125 - 150 Nephroma bellum thalli were observed, though there may be additional thalli higher up in other tree canopies. There were three other species of Nephroma in the stand.

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Nephroma occultum is a foliose lichen that typically grows on the bark and wood of conifers in the mid to upper canopy in moist old-growth forests. In the Study area, Nephroma occultum occupies the trunks of vine maples with a high diversity of other lichen species. A total of 15 Nephroma occultum thalli were observed in the stand, though there may be other thalli higher up in tree canopies in the stand. In the Study area, it grows with a number of other similar appearing lichens from which it must be differentiated. Only eight other Nephroma occultum populations are known from Washington (COSEWIC 2006).

Platismatia lacunosa is a foliose lichen that typically occurs on the boles and branches of hardwoods and conifers in moist, cool upland sites as well as in moist riparian forests to 3500’ in elevation. In the Study area, Platismatia lacunosa occupies the trunks of vine maple trees with a high diversity of other lichen species. A total of three Platismatia lacunosa thalli were observed in the stand, though there may be other thalli higher up in the tree canopies in the stand. In the Study area, it grows with Platismatia glauca, Platismatia herrei, and Platismatia norvegica; very similar looking lichens from which it must be carefully differentiated.

Peltigera pacifica is a foliose lichen species that grows on soil, duff, woody debris and occasionally on tree bases in low elevation, moist forests. In the Study area, eight subpopulations were mapped in a scattered patchy distribution adjacent FS Road 1260- 066 (Pipeline Road) and Pipeline Trail #74 (an ATV trail). The population is approximately 1.25 miles long. Subpopulation sizes range from 3 to 25 thalli, for an estimated total of 80 to 100 thalli in the population. Peltigera pacifica occupies a narrow forested strip between the roadside and the Pipeline Trail, and the buried pipeline. It typically grows on rocks on moss beneath a stand of young coniferous trees. Moss cover is generally high in the immediate area where Peltigera pacifica grows. Thalli have become established since the road, trail and pipeline were constructed and buried in the early 1960’s. This species established itself in an early seral forested community and apparently tolerates some degree of disturbance given its location next to a road and pipeline. Non-native species do not seem to be a threat to this population, though several weed species such as Cytisus scoparius, Leucanthemum vulgare, and Tanacetum vulgare grow in a narrow strip between Peltigera habitat and the roadbed. There may be additional Peltigera pacifica subpopulations along FS Road 1260-066 and the Pipeline Trail as the species must be individually differentiated from seven other species of Peltigera occupying similar habitat.

One population with two sub-populations of the state Threatened species Oregon goldenaster (Heterotheca oregona) (see Figure 4-2) was located on private land. This species was not included on the WNHP list of potential rare plant species for Lewis County (Appendix A) as the only currently known WNHP occurrence of it is from Yakima County (WNHP 1996). Subsequent online research at the University of Washington herbarium website revealed that there are a number of older herbarium specimens of this species from Grays Harbor, Mason, Pierce, Kittitas, and Klickitat Counties (WTU 2006).

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Oregon goldenaster is a perennial species in the sunflower family with alternate leaves and yellow disk flowers. It typically has several stems from a woody base and is usually 10 to 20 inches tall (WNHP 2003). Oregon goldenaster is found from Washington to California, chiefly west of the Cascade Mountains (WNHP 2006). Its habitat is typically sand and gravel bars along rivers. Seasonal flooding is probably important in maintaining the habitat for this species (WNHP 2006). It tends to prefer open sunny to partially shaded sites. Many botanical references including Hitchcock et al., 1973 refer to this species as Chrysopsis oregona.

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Figure 4-1. Approximate locations of the TES species located in the Packwood Lake study area, 2005-2006.

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Figure 4-2. Oregon goldenaster (Heterotheca oregona) in the Packwood area

In the study area, Oregon goldenaster was observed in two locations; on a gravel bar near where the tailrace enters the Cowlitz River (Tailrace Subpopulation A) and on the cobble bank of Lake Creek upstream of the creek’s confluence with the Cowlitz River (Lake Creek Subpopulation B). Both sites are privately owned. Plants are growing on semi-stabilized cobble and gravels, i.e., on neither the oldest or youngest vegetated substrate at sunny to partially shaded sites. Associated species include: red alder (Alnus rubra), Sitka willow (Salix sitchensis), Scotch broom (Cytisus scoparius), black cottonwood (Populus trichocarpa), butterfly bush (Buddleja davidii), common St. John’s- wort (Hypericum perforatum), Jerusalem-oak (Chenopodium botrys), bladder campion (Silene cucubalus), sheep sorrel (Rumex acetosella), blue wildrye (Elymus glaucus), bentgrass (Agrostis sp.), tall annual willow-herb (Epilobium paniculatum), Nuttall’s knotweed (Polygonum nuttallii), white sweet-clover (Melilotus alba), spotted cat’s-ear (Hypochaeris radicata), herb-Robert (Geranium robertianum), Canada bluegrass (Poa compressa), meadow fescue (Festuca pratensis), and Queen Anne’s lace (Daucus carota). Sighting forms and mapped locations of Oregon goldenaster will be provided separately to the WNHP, FERC, WDFW, and other agencies and tribes as appropriate.

In addition to the plants in the study area proper, extensive populations of many thousands of Oregon goldenaster plants were observed on the cobble and gravel bars

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on the shores and islands of the Cowlitz River upriver and downriver of the study area. A gravel bar island near the Tailrace Subpopulation supports many thousands of plants. There are also large numbers of plants on gravel bar habitat along the Cowlitz River upstream of the Lake Creek Subpopulation. Suitable potential habitat associated with Lake Creek upstream of its confluence with the Cowlitz River is strictly limited to a narrow band of cobble/gravel adjacent the creek along its last 75 feet. Immediately downriver of both the Lake Creek and Tailrace Subpopulations, the riverbank is steep with tall, forested vegetation and is therefore unsuitable habitat for Oregon goldenaster. Oregon goldenaster is probably more common in Washington than botanists realize because it blooms late in the growing season (August) and is thus underreported.

5.0 DISCUSSION AND RECOMMENDATIONS

Collema nigrescens, Nephroma bellum, Nephroma occultum, and Platismatia lacunosa A population of each of the four Forest Service Sensitive lichen species Collema nigrescens, Nephroma bellum, Nephroma occultum, and Platismatia lacunosa were located in a single locality in Goat Rocks Wilderness Area, a Forest Service-owned portion of the Study area. The Upper Lake Creek Trail bisects the stand and is used by hikers and pack animals. It is evident that pack animals graze the deciduous shrubs and trees on the side of the trail in the vicinity of the lichen populations. While the four Sensitive lichen populations are in the Rare Plant Study area, they are not in the Project area or near any Project facilities or management activities. Because no change is being proposed in the way the Project and its facilities are currently being maintained and operated, current conditions in these populations will be maintained.

Peltigera pacifica A population of the FS sensitive lichen Peltigera pacifica was located in young coniferous forest habitat in the Project area along the FS Road 1260-066 (the Pipeline Road) and PipelineTrail #74 (an ATV trail) between the roadside and the buried pipeline. The population is comprised of eight small subpopulations and is approximately 1.25 miles in length. The two easternmost subpopulations are along the first half-mile of the Pipeline Trail. The road and Pipeline Trail are gated, although they are used by EN personnel to access Project facilities with vehicles and ATVs, and by the public to access the Packwood Lake with ATVs. FS Road 1260-066 is in fair condition but may need minor reconstruction in a few areas (USFS 2005c). Pipeline Trail #74 is in fair to poor condition and is in need of maintenance. In the past, Energy Northwest has performed minor maintenance on the road. If ground disturbing maintenance on the road, trail or pipeline were to occur in the vicinity of the lichen population, Peltigera pacifica thalli could potentially be affected through direct loss, disturbance, or habitat alterations at least in the short term. If disturbance were unavoidable in its habitat or to its population, Peltigera pacifica may be able to successfully maintain or reestablish itself based on the observation that the population initially established itself in the young forested stand that grew up after the road and pipeline were constructed in the early 1960’s.

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• Monitor the Peltigera pacifica occurrence every 2 years for 6 years following License issuance and at 5-year intervals thereafter. • During these surveys, monitor for noxious weed infestations in Peltigera habitat. If noxious weeds are located in Peltigera habitat, these weeds will be controlled according to the Packwood Project Integrated Weed Management Plan in consultation with the Forest Service. • FS Road 1260-066 will be maintained according to FS Maintenance Level 2 guidelines (ENW 2008). At this maintenance level, it is not anticipated that maintenance activities will need to occur off of the road prism. • A biological evaluation for Peltigera pacifica subpopulations would be done in advance of any road or trail maintenance, tree and shrub trimming, or other ground disturbing activities planned for the area outside of the road or trail prism. Peltigera pacifica thalli do not grow on the road prism. A plan would be developed with a goal of avoiding or minimizing damage to Peltigera pacifica thalli and habitat in consultation with the FS to monitor, mark, protect, or move affected subpopulations during ground disturbing activities. • If damage to Peltigera pacifica thalli or habitat were unavoidable, rocks and moss mats with the attached lichen thalli could be permanently moved to a similar habitat or temporarily moved and replaced after maintenance work has been completed. • If destruction of some Peltigera pacifica subpopulations were unavoidable, a survey would be made for other populations outside of the Project area in the general vicinity. These populations would be preserved to provide for local propagation opportunities. • Revegetation of disturbed areas would be done with native plant species according to FS standards. • Rare plant training will be provided to appropriate ENW personnel. This training will cover all USFS rare plant species in the Project Boundary, as well as information related to identification, ecology and protection.

Oregon goldenaster All of the Oregon goldenaster plants along the Cowlitz River are likely to constitute a single population because their habitat is hydrologically connected. The estimated 250 plants in the Project boundary (tailrace) and four plants in the Lake Creek area thus constitute a small fraction of the thousands of plants observed growing along the Cowlitz River both inside and outside of the study area. It is unlikely that Project operations have a negative impact on either of the Oregon goldenaster subpopulations. Construction and maintenance activities associated with the tailrace at its confluence with the Cowlitz River are limited and are unlikely to affect the subpopulation there. At some future time, the plants at the Lake Creek subpopulation may be washed out by high flows on Lake Creek, but this could occur regardless of Project operations. The Yakima County Oregon goldenaster population is also characterized by having many thousands of plants, making it one of the commonest plants on the riverbank (WNHP 1996).

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Probably the most significant threat to the Oregon goldenaster population is habitat degradation and destruction by invasive noxious weeds; particularly Scotch broom (Cytisus scoparius), butterfly bush (Buddleja davidii), and knotweed species (Polygonum spp.). All three of these weed species are listed by the Lewis County Noxious Weed Control Board (LCWCB); with the latter two being considered high priority species for management (LCWCB 2006). Scotch broom is extremely common up and down the Cowlitz River on gravel bars and at adjacent disturbed and developed habitats. Scotch broom is a co-dominant species at both Oregon goldenaster Subpopulations. Butterfly bush and knotweed are far less common, though they are present in the area and have the potential to spread. Both species can reproduce vegetatively by resprouting from root and stem fragments, which can fall into rivers and streams and create new infestations downstream (NWCB 2006). There are three or four butterfly bush plants in close proximity to the tailrace Subpopulation. There is a known population of Japanese knotweed (Polygonum cuspidatum) near the Lake Creek Subpopulation. It has been treated with glyphosate for the last few years by the LCWCB (B. Wamsley LCWCB personal communication). It is unlikely that the infestations of Scotch broom, butterfly bush and Japanese knotweed in and near the Oregon goldenaster population are there due to Project related activities.

The following are some potential measures that may be taken to protect, mitigate and enhance the Oregon goldenaster population in the Project boundary.

• Resurvey the Oregon goldenaster occurrence every five years to monitor and identify Project effects during the new license term.

• During these surveys, monitor for noxious weed infestations in Oregon goldenaster habitat. If noxious weeds are located, they will be controlled according to the Packwood Project Integrated Weed Management Plan in consultation with the LCWCB.

• Though none is planned during the next license period, if any Project related ground disturbing activities in the vicinity of the Oregon goldenaster occurrence were to occur, a biological evaluation would be prepared with the goal of avoiding or minimizing damage in advance of any ground disturbing activities in the area.

• Ensure that efforts at the Lower Lake Creek Stream Restoration Project (RM 0.0 to 0.3) do not disturb the small Oregon goldenaster subpopulation at the mouth of Lake Creek.

• Native plants should be used to revegetate any disturbed areas

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6.0 LITERATURE CITED

COSEWIC. 2006. COSEWIC Assessment and Update Status Report on the Cryptic Paw Nephroma occultum in Canada. Committee on the Status of Endangered Wildlife in Canada. Ottawa. vi + 28 pp.

Energy Northwest. 2004. Packwood Lake Hydroelectric Project. FERC Project No. 2244. Pre-Application Document. Supplement No. 1. December 6, 2004.

Hitchcock, C.L. and A. Cronquist. 1973. Flora of the Pacific Northwest. University of Washington Press. Seattle, Washington.

Lewis County Noxious Weed Control Board (LCWCB). 2006. 2006 Noxious Weed List Lewis County, WA. Accessed August 2006. Available at URL: http://fortress.wa.gov/lewisco/home/DesktopDefault.aspx?tabid=233 NWCB (Washington Noxious Weed Control Board). 2006. Available at URL: http://www.nwcb.wa.gov/. (accessed August 2006) USDA Forest Service. 2005a. Pre-field Review. Summary of Potential Botanical Concerns, Packwood Lake. A. Ruchty, Forest Service. February 7, 2005.

USDA Forest Service. 2005b. Comments on PAD and Scoping Document 1 and Study Requests. Packwood Lake Project Number 2244-012. March 11, 2005.

USDA Forest Service. 2005c. Gifford Pinchot National Forest Existing information Analysis for Packwood Lake Access. March 3, 2005.

Wamsley, Bill, Lewis County Noxious Weed Board Coordinator. Telephone conversation with K. Beck, botanist, Beck Botanical Services, August 2006. Washington Department of Fish and Wildlife. 2005. Comments on PAD, Study Requests, Comments on Scoping Document 1. Packwood Lake Hydroelectric Project FERC No. 2244-012. March 9, 2005.

Washington Natural Heritage Program (WNHP). 1996. WHNP rare plant survey form – Heterotheca oregona EO-001, reported by Curtis R. Bjork.

Washington Natural Heritage Program (WNHP). 2004. Memorandum from S. Swope, WNHP. Packwood Hydroelectric Relicensing Project (T13NR09-10E). June 2, 2004.

Washington Natural Heritage Program. 2006. Endangered, Threatened, and Sensitive Vascular Plants of Washington. On-line at: http://www.dnr.wa.gov/nhp/refdesk/lists/plantsxco/countyindex.html (accessed August 2006).

WTU (University of Washington Herbarium, Burke Museum). Available at URL: http://biology.burke.washington.edu/herbarium/collections/list.php (accessed August 2006).

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APPENDIX A

List of Known Occurrences of Rare Plants in Lewis County, WNHP, 2004

State Federal Historic Scientific Name Common Name Status Status Record Balsamorhiza deltoidea Puget Balsamroot R2 Calamagrostis canadensis var. Blue Joint Reedgrass R2 H imberbis Cardamine penduliflora Willamette Valley Bitter-cress T Cimicifuga elata Tall Bugbane S SC Delphinium leucophaeum Pale Larkspur E SC Erigeron aliceae Alice's Fleabane S Erythronium revolutum Pink Fawn-lily S Euonymus occidentalis Western Wahoo T Githopsis specularioides Common Blue-cup S Isoetes nuttallii Nuttall's Quillwort S Lathyrus holochlorus Thin-leaved Peavine E Lupinus sulphureus ssp. kincaidii Kincaid's Sulfur Lupine E LT Meconella oregana White Meconella T SC H Montia diffusa Branching Montia S H Pedicularis rainierensis Mt. Rainier Lousewort S Poa laxiflora Loose-flowered Bluegrass T Polemonium carneum Great Polemonium T H Sidalcea hirtipes Hairy-stemmed Checker-mallow E Sidalcea nelsoniana Nelson's Checker-mallow E LT Trillium parviflorum Small-flowered Trillium S

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APPENDIX A (CONTINUED)

Description of Codes

Historic Record: H indicates most recent sighting in the county is before 1977.

State Status: State Status of plant species is determined by the Washington Natural Heritage Program. Factors considered include abundance, occurrence patterns, vulnerability, threats, existing protection, and taxonomic distinctness. Values include: E = Endangered. In danger of becoming extinct or extirpated from Washington. T = Threatened. Likely to become Endangered in Washington. S = Sensitive. Vulnerable or declining and could become Endangered or Threatened in the state. X = Possibly extinct or Extirpated from Washington. R1 = Review group 1. Of potential concern but needs more field work to assign another rank. R2 = Review group 2. Of potential concern but with unresolved taxonomic questions.

Federal Status: Federal Status under the U.S. Endangered Species Act (USESA) as published in the Federal Register: LE = Listed Endangered. In danger of extinction. LT = Listed Threatened. Likely to become endangered. PE = Proposed Endangered. PT = Proposed Threatened. C = Candidate species. Sufficient information exists to support listing as Endangered or Threatened. SC = Species of Concern. An unofficial status, the species appears to be in jeopardy, but insufficient information to support listing. NL = Not Listed. Used when two portions of a taxon have different federal status.

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APPENDIX B

Sensitive Species Vascular Plant List for the Gifford Pinchot National Forest, from the Region 6 USFS Sensitive Species Plant List, April 2006

USFWS Suspected/Documented on Species Name Status Gifford Pinchot National Forest Agoseris elata S Bolandra oregana D Botrychium lanceolatum D Botrychium montanum D Calochortus longebarbatus var. D longebarbatus Carex densa D Carex heteroneura D Carex stenophylla S Chrysolepis chrysophylla D Cicuta bulbifera S Cimicifuga elata D Coptis asplenifolia S Coptis trifolia S Corydalis aquae-gelidae D Cryptantha rostellata S Cyperus bipartitus S Cypripedium fasciculatum D Cypripedium montanum S Damasonium californicum S Erigeron howellii S Erigeron oreganus S Eryngium petiolatum S Euonymus occidentalis S Fritillaria camschatcensis S Galium kamtshaticum S Heuchera grossulariifolia var. tenuifolia S Howellia aquatilis LT S Linanthus bolanderi S Liparis loeselii S Lomatium suksdorfii S Luzula arcuata D Meconella oregana S Microseris borealis D Mimulus jungermannioides S Mimulus pulsiferae S Mimulus suksdorfii S

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APPENDIX B. (continued)

USFWS Suspected/Documented on Species Name Status Gifford Pinchot National Forest Montia diffusa D Navarretia tagetina S Ophioglossum pusillum S Parnassia fimbriata var. hoodiana S Pedicularis rainierensis S Penstemon barettiae D Pityopus californica S Platanthera orbiculata var. orbiculata S Platanthera sparsiflora S Poa laxiflora S Polemonium carneum S Potentilla breweri S Ranunculus reconditus S Rorippa columbiae S Scribneria bolanderi S Sidalcea hirtipes D Sisyrinchium sarmentosum D Utricularia intermedia D Veratrum insolitum S

LT = Listed Threatened. Likely to become endangered. S = Suspected D = Documented

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APPENDIX C

USDA Forest Service, Pacific Northwest Region. Regional Forester’s Sensitive Plant List, Lichens and Bryophytes. Updated July 2004

Species Name Documented/Suspected on Gifford Pinchot National Forest LICHENS Cetrelia cetrarioides D Chaenotheca subroscida D Collema nigrescens D Dendriscocaulon intriculatum D Dermatocarpon luridum D Hypogymnia duplicata S Hypotrachyna revoluta S Leptogium burnetiae var. hirsutum S Leptogium cyanescens S Leptogium rivale D Lobaria linita var. tenuoir D Nephroma bellum D Nephroma occultum D Pannaria rubiginosa S Peltigera neckeri S Peltigera pacifica D Pilophorus nigricaulis D Platismatia lacunosa D Pseudocyphellaria rainierensis D Tholurna dissimilis D Usnea longissima D BRYOPHYTES Encalypta brevicolia var crumiana S Schistostega pennata D Scouleria marginata S Tetraphis geniculata D FUNGUS Bridgeoporus nobilissimus D

S = Suspected D = Documented

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APPENDIX D

List of Plant Species Observed in the Packwood Lake Study Area, 2005 – 2006.

Scientific Name Non-native Family Weed Class Rare Plant* Acer circinatum Aceraceae Acer glabrum var. douglasii Aceraceae Acer macrophyllum Aceraceae Alisma plantago-aquatica Alismataceae Angelica arguta Apiaceae Cicuta douglasii Apiaceae Daucus carota x Apiaceae B Heracleum lanatum Apiaceae Oenanthe sarmentosa Apiaceae Osmorhiza chilensis Apiaceae Apocynum androsaemifolium Apocyanaceae Ilex aquifolium x Aquifoliaceae Lysichiton americanus Araceae Oplopanax horridus Araliaceae Asarum caudatum Aristolochiaceae Asplenium trichomanes Aspleniaceae Achillea millefolium Asteraceae Adenocaulon bicolor Asteraceae Agoseris grandiflora Asteraceae Anaphalis margaritacea Asteraceae Antennaria cf howellii Asteraceae Antennaria rosea Asteraceae Arctium minus x Asteraceae Arnica amplexicaulis Asteraceae Arnica cordifolia Asteraceae Arnica latifolia Asteraceae Artemisia sp. x Asteraceae Bidens sp. Asteraceae Centaurea diffusa x Asteraceae B-designate Centaurea jacea x nigra x Asteraceae B-designate Cichorium intybus x Asteraceae Cirsium canadensis x Asteraceae C Cirsium vulgare x Asteraceae C Conyza canadensis Asteraceae Crepis capillaris x Asteraceae Erigeron philadelphicus x Asteraceae Gnaphalium palustre Asteraceae Heterotheca oregona Asteraceae ST Hieracium albiflorum Asteraceae Hypochaeris radicata x Asteraceae B Scientific Name Non-native Family Weed Class Rare Plant* Lactuca muralis x Asteraceae Lactuca serriola x Asteraceae Lapsana communis x Asteraceae Leucanthemum vulgare x Asteraceae B Luina hypoleuca Asteraceae Madia gracilis Asteraceae Petasites frigidus var. palmatus Asteraceae Psilocarphus elatior Asteraceae

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Scientific Name Non-native Family Weed Class Rare Plant* Senecio jacobaea x Asteraceae B Senecio sylvaticus x Asteraceae Senecio triangularis Asteraceae Senecio vulgaris x Asteraceae C Solidago canadensis Asteraceae Sonchus asper x Asteraceae Sonchus sp. x Asteraceae Tanacetum vulgare x Asteraceae C Taraxacum officinale x Asteraceae Tragopogon dubius x Asteraceae Achllys triphylla Berberidaceae Mahonia aquifolium Berberidaceae Mahonia nervosa Berberidaceae Alnus rubra Betulaceae Alnus viridis ssp. sinuata Betulaceae Corylus cornuta Betulaceae Blechum spicant Blechnaceae Cryptantha intemedia Boraginaceae Myosotis laxa x Boraginaceae Myosotis scouleri x Boraginaceae Myosotis sp. Boraginaceae Arabis glabra Brassicaceae Cardamine pensylvanica x Brassicaceae Cardamine perennial sp. Brassicaceae Rorippa islandica Brassicaceae Sisymbrium officinale x Brassicaceae Teesdalia nudicaulis x Brassicaceae Buddleja davidii x Buddlejaceae C select Callitriche sp. Callitrichaceae Campanula scouleri Campanulaceae Holodiscus discolor Caprifoliaceae Linnaea borealis Caprifoliaceae Lonicera ciliosa Caprifoliaceae Lonicera involucrata Caprifoliaceae Sambucus racemosa Caprifoliaceae Symphoricarpos albus Caprifoliaceae Viburnum edule Caprifoliaceae Arenaria serpyllifolia x Caryophyllaceae Cerastium nutans x Caryophyllaceae Cerastium vulgatum x Caryophyllaceae Dianthus armeria x Caryophyllaceae Moeringia macrophylla Caryophyllaceae Sagina procumbens x Caryophyllaceae Silene csereii x Caryophyllaceae Silene cucubalus x Caryophyllaceae Silene sp. x Caryophyllaceae Spergularia rubra x Caryophyllaceae Stellaria calycantha Caryophyllaceae Stellaria crispa Caryophyllaceae Stellaria media x Caryophyllaceae Stellaria sp. Caryophyllaceae Pachistima myrsinites Celestraceae Chenopodium botrys x Chenopodiaceae Cornus canadensis Cornaceae Cornus nuttallii Cornaceae

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Scientific Name Non-native Family Weed Class Rare Plant* Cornus sericea Cornaceae Sedum divergens Crassulaceae Sedum oreganum Crassulaceae Thuja plicata Cupressaceae Carex arcta Cyperaceae Carex canescens Cyperaceae Carex cf muricata Cyperaceae Carex cusickii Cyperaceae Carex deweyana Cyperaceae Carex exsiccata Cyperaceae Carex hendersonii Cyperaceae Carex lenticularis Cyperaceae Carex mertensii Cyperaceae Carex obnupta Cyperaceae Carex pachystachya Cyperaceae Carex pensylvanica Cyperaceae Carex scoparia Cyperaceae Carex sitchensis Cyperaceae Carex stipata Cyperaceae Eleocharis cf acicularis Cyperaceae Eleocharis ovata Cyperaceae Eleocharis palustris Cyperaceae Scirpus microcarpus Cyperaceae Pteridium aquilinum Dennstaedtiaceae Athyrium filix-femina Dryopteridaceae Cystopteris fragilis Dryopteridaceae Dryopteris expansa Dryopteridaceae Gymnocarpium dryopteris Dryopteridaceae Polystichum imbricans Dryopteridaceae Polystichum munitum Dryopteridaceae Equisetum arvense Equisetaceae Equisetum fluviatile Equisetaceae Equisetum hyemale Equisetaceae Equisetum telmateia Equisetaceae Arbutus menziesii Ericaceae Arctostaphylos columbiana Ericaceae Arctostaphylos uva-ursi Ericaceae Chimophila menziesii Ericaceae Chimophila umbellata Ericaceae Gautheria ovatifolia Ericaceae Gautheria shallon Ericaceae Menziesia ferruginea Ericaceae Orthilia secunda Ericaceae Phyllodoce sp. Ericaceae Pyrola aphylla Ericaceae Pyrola asarifolia Ericaceae Pyrola chlorantha Ericaceae Pyrola picta Ericaceae Vaccinium alaskense Ericaceae Vaccinium membranaceum Ericaceae Vaccinium parvifolium Ericaceae Vaccinium scoparium Ericaceae Cytisus scoparius x Fabaceae B Lathyrus latifolius x Fabaceae Lotus corniculatus x Fabaceae

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Scientific Name Non-native Family Weed Class Rare Plant* Lotus micranthus Fabaceae Lupinus albicaulis Fabaceae Lupinus rivularis Fabaceae Lupinus sp. Fabaceae Melilotus alba x Fabaceae Trifolium arvense x Fabaceae Trifolium dubium x Fabaceae Trifolium hybridum x Fabaceae Trifolium pratense x Fabaceae Trifolium repens x Fabaceae Vicia americana Fabaceae Vicia tetrasperma x Fabaceae Vicia villosa x Fabaceae Erodium cicutarium x Geraniaceae Geranium robertianum x Geraniaceae B Ribes bracteosum Grossulariaceae Ribes divaricatum Grossulariaceae Ribes lacustre Grossulariaceae Ribes lobbii Grossulariaceae Ribes sanguineum Grossulariaceae Elodea canadensis Hydrocharitaceae Hydrophyllum fendleri Hydrophyllaceae Phacelia mutabilis Hydrophyllaceae Hypericum anagalloides Hypericaceae Hypericum perforatum x Hypericaceae C Juncus articulatus Juncaceae Juncus bufonius Juncaceae Juncus effusus Juncaceae Juncus ensifolius Juncaceae Juncus tenuis Juncaceae Luzula campestris Juncaceae Luzula divaricata Juncaceae Luzula multiflora Juncaceae Luzula parviflora Juncaceae Lycopus americanus Lamiaceae Mentha arvensis Lamiaceae Mentha x piperita x Lamiaceae Prunella vulgaris x Lamiaceae Satureja douglasii Lamiaceae Stachys cooleyae Lamiaceae Lemna minor Lemnaceae Clintonia uniflora Liliaceae Lilium columbianum Liliaceae Maianthemum dilatatum Liliaceae Maianthemum racemosum Liliaceae Maianthemum stellatum Liliaceae Stenanthium occidentale Liliaceae Streptopus amplexicaulis Liliaceae Trillium ovatum Liliaceae Veratrum viride Liliaceae Xerophyllum tenax Liliaceae Linum perenne x Linaceae Lycopodium clavatum Lycopodiaceae Lycopodium sp. Lycopodiaceae Allotropa virgata Monotropaceae

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Scientific Name Non-native Family Weed Class Rare Plant* Hemitomes congestum Monotropaceae Hypopitys monotropa Monotropaceae Monotropa uniflora Monotropaceae Pterospora andromedea Monotropaceae Epilobium alpinum Onagraceae Epilobium angustifolium Onagraceae Epilobium cf ciliatum Onagraceae Epilobium glaberrimum Onagraceae Epilobium luteum Onagraceae Epilobium minutum Onagraceae Epilobium paniculatum Onagraceae Epilobium sp. Onagraceae Oenothera biennis x Onagraceae Corallorhiza sp. Orchidaceae Eburophyton austiniae Orchidaceae Goodyera oblongifolia Orchidaceae Listera convallarioides Orchidaceae Listera cordata Orchidaceae Piperia elegans Orchidaceae Piperia unalascensis Orchidaceae Platanthera saccata Orchidaceae Spiranthes romanzoffiana Orchidaceae Eschscholzia californica x Papaveraceae Abies amabilis Pinaceae Abies grandis Pinaceae Abies lasiocarpa Pinaceae Pinus monticola Pinaceae Pinus ponderosa x Pinaceae Pseudotsuga menziesii Pinaceae Tsuga heterophylla Pinaceae Plantago lanceolata x Plantaginaceae Plantago major x Plantaginaceae Agrostis capillaris x Poaceae Agrostis sp. Poaceae Aira caryophyllea x Poaceae Aira praecox x Poaceae Anthoxanthum odoratum x Poaceae Arrhenatherum elatius x Poaceae Bromus hordeaceus Poaceae Bromus pacificus Poaceae Bromus sp. Poaceae Bromus tectorum x Poaceae Calamagrostis canadensis Poaceae Cinna latifolia Poaceae Cynosurus cristatus x Poaceae Cynosurus echinatus x Poaceae Dactylis glomerata x Poaceae Danthonia californica Poaceae Deschampsia elongata Poaceae Elymus glaucus Poaceae Elymus repens x Poaceae Festuca arundinacea x Poaceae Scientific Name Non-native Family Weed Class Rare Plant* Festuca occidentalis Poaceae Festuca pratensis x Poaceae

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Scientific Name Non-native Family Weed Class Rare Plant* Festuca rubra Poaceae Festuca subulata Poaceae Festuca subuliflora Poaceae Glyceria elata Poaceae Glyceria grandis Poaceae Glyceria leptostachya Poaceae Holcus lanatus x Poaceae Lolium perenne ssp. multiflorum x Poaceae Melica cf smithii Poaceae Panicum sp. Poaceae Phalaris arundinacea x Poaceae C Phleum pratense x Poaceae Pleuropogon refractus Poaceae Poa annua x Poaceae Poa compressa x Poaceae Poa palustris Poaceae Poa pratensis x Poaceae Poa sp. Poaceae Poa trivialis x Poaceae Trisetum cernuum Poaceae Trisetum spicatum Poaceae Collomia grandiflora Polemoniaceae Collomia heterophylla Polemoniaceae Phlox gracilis Polemoniaceae Polygonum aviculare x Polygonaceae Polygonum cuspidatum x Polygonaceae B select Polygonum douglasii Polygonaceae Polygonum nuttallii Polygonaceae Polygonum sp. x Polygonaceae Rumex acetosella x Polygonaceae Rumex obtusifolius x Polygonaceae Polypodium glycyrrhiza Polypodiaceae Polypodium hesperium Polypodiaceae Montia parvifolia Portulacaceae Montia sibirica Portulacaceae Trientalis latifolia Primulaceae Adiantum pedatum Pteridaceae Cryptogramma crispa Pteridaceae Actaea rubra Ranunculaceae Anemone deltoidea Ranunculaceae Ranunculus repens x Ranunculaceae Ranunculus uncinatus Ranunculaceae Scientific Name Non-native Family Weed Class Rare Plant* Rhamnus purshiana Rhamnaceae Amelanchier alnifolia Rosaceae Aruncus sylvester Rosaceae Crataegus douglasii Rosaceae Crataegus monogyna x Rosaceae Fragaria vesca Rosaceae Fragaria virginiana Rosaceae Geum macrophyllum Rosaceae Malus fusca Rosaceae Malus x domestica x Rosaceae Oemleria cerasiformis Rosaceae Potentilla recta x Rosaceae B

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Scientific Name Non-native Family Weed Class Rare Plant* Prunus emarginata Rosaceae Rosa cf canina x Rosaceae Rosa gymnocarpa Rosaceae Rosa nutkana Rosaceae Rubus discolor x Rosaceae Rubus laciniatus x Rosaceae Rubus lasiococcus Rosaceae Rubus leucodermis Rosaceae Rubus nivalis Rosaceae Rubus parviflorus Rosaceae Rubus pedatus Rosaceae Rubus spectabilis Rosaceae Rubus ursinus Rosaceae Sorbus sp. Rosaceae Spiraea betulifolia Rosaceae Spiraea douglasii Rosaceae Galium aparine Rubiaceae Galium triflorum Rubiaceae Populus trichocarpa Salicaceae Salix lucida ssp. lasiandra Salicaceae Salix scouleriana Salicaceae Salix sitchensis Salicaceae Salix sp. Salicaceae Heuchera micrantha Saxifragaceae Mitella sp. Saxifragaceae Saxifraga bronchialis Saxifragaceae Tiarella trifoliata var. unifoliata Saxifragaceae Tolmiea menziesii Saxifragaceae Castilleja hispida Scrophulariaceae Circaea alpina Scrophulariaceae Collinsia parviflora Scrophulariaceae Digitalis purpurea x Scrophulariaceae Euphrasia officinalis x Scrophulariaceae Mimulus guttatus Scrophulariaceae Mimulus sp. Scrophulariaceae Nothochelone nemorosa Scrophulariaceae Parentucellia viscosa x Scrophulariaceae Penstemon rupicola Scrophulariaceae Rhinanthus minor ssp. minor Scrophulariaceae Verbascum thapsus x Scrophulariaceae Veronica americana Scrophulariaceae Veronica officinalis x Scrophulariaceae Veronica scutellata Scrophulariaceae Solanum dulcamara x Solanaceae Taxus brevifolia Taxaceae Typha latifolia Typhaceae Urtica dioica Urticaceae Valeriana sitchensis Valerianaceae Viola glabella Violaceae Viola sempervirens Violaceae Viola sp. Violaceae Arceuthobium sp. Viscaceae *ST – Threatened in Washington state (WNHP 2006).

7 Rare Plant Survey Report Energy Northwest Packwood Lake Hydroelectric Project May 2008 FERC No. 2244

APPENDIX E

List of Lichen Species Observed in the Packwood Lake Study Area, 2005 – 2007.

Scientific Name FS Status Alectoria sarmentosa Bryoria fremontii Bryoria fuscescens Bryoria sp. Bryoria trichodes ssp. americana Calicium glaucellum Calicium sp. Cetraria chlorophylla Cetraria platyphylla Chaenotheca brunneola Cladina sp. Cladonia spp. Collema nigrescens S Evernia prunastri Hypogymnia enteromorpha Hypogymnia imshaugii Hypogymnia inactiva Hypogymnia metaphysodes Hypogymnia physodes Hypogymnia sp. Hypogymnia tubulosa Ichmadophila ericetorum Leptogium corniculatum Leptogium tacomae Letharia vulpina Lobaria oregana Lobaria pulmonaria Lobaria sp. Lobaria scrobiculata Melanelia exasperatula Melanelia fuliginosa Melanelia multispora Melanelia subaurifera Nephroma bellum S Nephroma helveticum Nephroma occultum S Nephroma resupinatum Nephroma sp.

8 Rare Plant Survey Report Energy Northwest Packwood Lake Hydroelectric Project May 2008 FERC No. 2244

Normandina pulchella Ochrolechia sp. Pannaria leucophaea Pannaria leucostichtoides Pannaria praetertexta Pannaria pezizoides Pannaria saubinetii Parmelia sp. Parmelia sulcata Parmeliopsis hyperopta Peltigera apthosa Peltigera brittanica Peltigera canina Peltigera collina Peltigera didactyla Peltigera neopolydactyla Peltigera pacifica S Peltigera ponojensis Peltigera praetextata Peltigera sp. Peltigera venosa Physcia aipolia Physconia americana Pilophorus acicularis Placopsis gelida Platismatia glauca Platismatia herrei Platismatia lacunosa S Platismatia norvegica Platismatia stenophylla Pseudocyphellaria anomala Pseudocyphellaria crocata Psoroma hypnorum Ramalina dilacerata Ramalina farinacea Sphaerophorus globosus Stereocaulon sp. Stereocaulon tomentosum Sticta fuliginosa Umbilicaria torrefacta Usnea filipendula Usnea sp. Vestergrenopsis isidiata

Attachment 8

Packwood Lake Recreation Plan Packwood Lake Hydroelectric Project (FERC No. 2244)

Energy Northwest Response to Request for Additional Information June 2008

PACKWOOD LAKE HYDROELECTRIC PROJECT (FERC NO. 2244)

Packwood Lake Recreation Plan

Energy Northwest and the USDA Forest Service

June 2008

Packwood Lake Recreation Plan

Table of Contents

1.0 Introduction...... 1 1.1 Goals...... 3 1.2 USDA Forest Service Management Direction ...... 4 1.2.1 Northwest Forest Plan – Aquatic Conservation Strategy (ACS) ...... 4 1.2.2 Gifford Pinchot National Forest Land and Resource Management Plan (LRMP) ...... 5 1.2.3 Wilderness...... 5 1.2.4 Other Resource Management Goals ...... 8 2.0 Roles and Coordination...... 9 2.1 Licensee Roles...... 9 2.2 USDA Forest Service Roles...... 9 2.3 Communication ...... 10 2.4 Coordination with Other Project Plans ...... 10 2.5 Annual Meeting and Report...... 10 2.6 Plan Updates...... 11 2.7 Review and Comments ...... 11 3.0 Implementation Components...... 12 3.1 Design Standards, Guidelines, Operation and Maintenance...... 12 3.2 Implementation Schedule...... 12 3.2.1 Recreation PME Measures...... 13 3.2.2 USDA Forest Service Road Maintenance PME Measures ...... 18 3.2.3 USDA Forest Service Meaningful Measures ...... 22 3.3 Regulatory Compliance...... 26 3.3.1 Measures on National Forest System Lands...... 26 4.0 Resources Cited...... 27

Appendices Appendix A – Stakeholder Consultation Appendix B – Road and Trail Maintenance Log

List of Figures

Figure 1: Packwood Lake Hydroelectric Project - Project Boundary ...... 2 Figure 2: Gifford Pinchot National Forest Management Allocations ...... 6 Figure 3: Proposed Location for Compositing Toilet and OHV Parking Area...... 15 Figure 4: Locations for Compositing Toilet...... 16 Figure 5: Location of Kiosk...... 17 Figure 6: Recommended Placement of Kiosk...... 18

List of Tables

Table 1: Recreation PME Measures and Implementation Schedule...... 14 Table 2: Meaningful Measures...... 23

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1.0 Introduction

On September 17, 2007, Energy Northwest (Licensee) filed its Preliminary Licensing Proposal (PLP) for the Packwood Lake Hydroelectric Project (Project) with the Federal Energy Regulatory Commission (FERC or Commission). Upon filing, the Licensee and interested stakeholders, including the USDA Forest Service, met frequently and informally to reach agreement in concept on all Protection, Mitigation and Enhancement (PME) measures outlined in the PLP and additional measures the stakeholders deemed necessary to mitigate effects for the Project. By February 2008, the Licensee and all stakeholders reached agreement in concept on all PME measures, with several of the PME measures fully described. The Licensee filed with the Commission its Final License Application (FLA) in February 2008 containing the PME measures agreed to in concept, including the measure for Recreation Management found in Exhibit E, Section E.5.7.4 and Appendix C.

On April 8, 2008, the Commission issued a request for additional information (AIR) including a Recreation Plan (described in the FLA) to allow the Commission to better assess the potential effects of the relicensing on recreation resources. The Packwood Lake Recreation Plan (PLRP) was developed collaboratively by Energy Northwest and the Forest Service, and included stakeholder review and comment within the Commission’s 60-day AIR time period.

Prior to filing the FLA, Energy Northwest conducted a Recreation Resources Study and Needs Analysis to obtain information regarding recreation opportunities, visitor use, activity types and dispersed camp locations around Packwood Lake for the Project (Howe Consulting 2007). The studies also evaluated recreation use of the Pipeline Road/Trail #74, Trail #78, the parking lot that serves both trails, and addressed future additional recreation needs and management objectives in preparation for the new Project license. Study design and implementation included consultation with a number of parties: Energy Northwest, the Forest Service, the National Park Service, the Washington State Interagency Committee for Outdoor Recreation (IAC) now known as the Recreation and Conservation Office of Washington State (RCO), the Washington Department of Fish and Wildlife, the Washington State Parks and Recreation Commission, the US Fish and Wildlife Service, Lewis County, the Confederated Tribes and Bands of the Yakama Nation, and the Cowlitz Tribe among others. For a complete list of cooperators, see Appendix A.

The Packwood Lake Hydroelectric Project boundary and surrounding area are shown on Figure 1. There are no developed recreation facilities (campgrounds, picnic areas, boat launch, docks, swimming area, potable water, etc.) available at Packwood Lake. USDA Forest Service management objectives for the Packwood Lake area limit opportunities for recreation facility development. For the purposes of the PLRP, the term “campsite” refers to any site where significant visitor use impacts are evident, but does not include developments such as picnic table, fire grate, or tent pad.

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Figure 1: Packwood Lake Hydroelectric Project - Project Boundary

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The PLRP has several components. First and foremost, it defines Energy Northwest’s long-term roles and responsibilities for providing, enhancing and managing recreation resources and opportunities on National Forest System (NFS) lands administered by the Forest Service in the Project area. It lists specific recreation measures and protocols for operations and maintenance, management, and resource coordination over the term of the new license. Second, it recognizes a shared responsibility in the management of recreation resources available to the public in the Project area with the Forest Service. Finally, the PLRP acknowledges Energy Northwest’s responsibility under its new Commission license to provide reasonable and safe access to Project lands and waters.

1.1 Goals

The proposed Protection, Mitigation and Enhancement (PME) measures for recreation resources at the Project are based on the results of the Recreation Resources Study and Needs Analysis study conducted by the Energy Northwest.

As a result of these efforts and the associated consultation, several recreation management goals and objectives were developed for the Project, consistent with the Gifford Pinchot National Forest Land and Resource Management Plan (LRMP) as amended by the Northwest Forest Plan (USDA Forest Service 1995b). The proposed recreation PME measures, as well as actions to be taken by the Forest Service, are based on the following goals:

Promote high-quality recreation opportunities and experiences that connect visitors to the land and that foster a strong land ethic.

Provide for and manage a range of feasible and desirable recreation opportunities based on information collected and filed pursuant to the reporting requirements for FERC Form 80 – Recreation Report, Section 8 of the Commission’s regulations (18 CFR 8.11) and applicable existing management plans.

Manage for appropriate levels of recreational use during peak use periods.

Do not purposely attract increased use levels beyond the social or physical recreation carrying capacity of the Project area, including adjacent Wilderness lands.

Provide adequate and safe public access to Project lands and waters, and

Coordinate ongoing and proposed recreation management actions in the Project area with other resource needs to avoid or minimize recreation-related impacts on sensitive resources.

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These goals for implementing and managing recreation resources will be referenced throughout the term of the new license as the basis for decisionmaking under the new license. As questions arise regarding implementation decisions, resource managers may compare proposed actions with these goals to evaluate consistency with the intent of the PLRP.

1.2 USDA Forest Service Management Direction

Recreation at, and around, Packwood Lake is managed and controlled by the Forest Service. There are several USDA Forest Service Land Management Classifications found within the Project area, which are described below.

1.2.1 Northwest Forest Plan – Aquatic Conservation Strategy (ACS)

Overlaying all land allocations outlined in the LRMP are watersheds and riparian reserves along lakes, streams, and wetlands, which are key components of the Northwest Forest Plan ACS. The ACS seeks to restore and maintain the ecological health of watersheds and aquatic ecosystems contained within them on public lands. Out of the nine ACS objectives outlined within the range of the northern spotted owl, four provide management direction associated with recreation use at Packwood Lake. These include (USDA Forest Service 1995b):

Maintain and restore the physical integrity of the aquatic system, including shorelines, banks, and bottom configurations.

Maintain and restore water quality necessary to support healthy riparian, aquatic, and wetland ecosystems. Water quality must remain within the range that maintains the biological, physical, and chemical integrity of the system and benefits survival, growth, reproduction, and migration of individuals composing aquatic and riparian communities.

Maintain and restore the species composition and structural diversity of plant communities in riparian areas and wetlands to provide adequate summer and winter thermal regulation, nutrient filtering, appropriate rates of surface erosion, bank erosion, and channel migration and to supply amounts and distributions of coarse woody debris sufficient to sustain physical complexity and stability.

Maintain and restore habitat to support well-distributed populations of native plant, invertebrate and vertebrate riparian-dependent species.

Federally managed lands within the Lake Creek Watershed are designated as a Tier 1 Key Watershed. Tier 1 Key Watersheds were selected for directly contributing to anadromous salmonid and bull trout conservation and are highest priority for watershed restoration. Riparian Reserves are portions of watersheds where standards and guidelines prohibit or regulate activities that retard or prevent attainment of the ACS objectives. The Late Successional Reserve (LSR) designation includes Project area

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lands outside of the Wilderness boundary. The LRMP management goal of the LSR is to protect and enhance habitat for late-successional and old-growth related species, including the northern spotted owl (USDA Forest Service 1995b).

1.2.2 Gifford Pinchot National Forest Land and Resource Management Plan (LRMP)

Several additional management allocations overlap the LSR designation, including Unroaded Recreation without Timber Harvest (UH), Roaded Recreation without Timber Harvest (RL), Visual Emphasis (VL), and Utility (4W). The UH, RL, and 4W management categories are designated Administratively Withdrawn Areas. Administratively Withdrawn Areas include wildlife, recreation, visual, and other areas not managed to provide timber outputs. Where administratively withdrawn areas (UH, RL and 4W) overlap the Late Successional Reserve (LSR), standards and guidelines from both designated areas may apply (USDA Forest Service 1995b). Packwood Lake itself is within the UH management allocation outside of the Wilderness and LSR boundaries (Figure 2). The Lake’s northern shoreline and lands to the north of Packwood Lake, including the intake and upper pipeline route, are located within the LSR and UH management category. Under the UH allocation, the resource management goal is to provide a variety of dispersed recreation opportunities in a semi-primitive or undeveloped setting, with an emphasis on maintaining a predominantly natural or naturally appearing environment. Hydroelectric facilities or recreation facilities should be designed to minimize adverse effects on the natural setting. The Recreation Opportunity Spectrum (ROS) management prescription for this area (Semi-primitive Motorized) suggests no more than 15 encounters between groups of visitors per day with groups no larger than 25 persons (encounter no more than 400 individuals each day), and no more than three other [dispersed] campsites visible from a given site. Campsites should be located away from lakeshores, streamsides, and trails (USDA Forest Service, 1995).

1.2.3 Wilderness

A majority of the Packwood Lake shoreline is identified as the Wilderness (WW) boundary for the Goat Rocks Wilderness Area. The WW (Figure 2) management allocation is a designated Congressionally Reserved Area. In 1964, Congress passed the Wilderness Act, which added the Goat Rocks to the new National Wilderness Preservation System. The boundary of the Goat Rocks Wilderness Area was modified by Congress in 1984 to be the “ordinary high water line of Packwood Lake” (USDA Forest Service, 1987). The Act continues to be the guiding piece of legislation for all Wilderness areas. The Act defines Wilderness as follows:

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Figure 2: Gifford Pinchot National Forest Management Allocations

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“…lands designated for preservation and protection in their natural condition…” Section 2(a) “…an area where the earth and its community of life are untrammeled by man…” Section 2(c) “…an area of undeveloped Federal land retaining its primeval character and influence, without permanent improvement or human habitation…” Section 2(c) “…generally appears to have been affected primarily by the forces of nature, with the imprint of man’s work substantially unnoticeable…” Section 2(c) “…has outstanding opportunities for solitude or a primitive and unconfined type of recreation…” Section 2(c) “…shall be devoted to the public purposes of recreation, scenic, scientific, educational, conservation and historic use.” Section 4(b)

As described in the Gifford Pinchot National Forest LRMP (USDA Forest Service 1995b), the goal of the Wilderness designation is to preserve the wilderness character, allowing for “untrammeled” natural processes and providing opportunities for solitude, challenge and inspiration. Within this intent, primitive or unconfined types of recreational, scenic, scientific, educational and historical uses are allowed. Desired future conditions of Wilderness follow a policy of non-degradation of Wilderness character and prohibit developed recreation facilities, roads or motorized activities within the Wilderness, except as required to serve valid mineral or energy projects initiated prior to December 31, 1983.

Management objectives and policies for recreation within the Wilderness include the following (USDA Forest Service 2007a):

Provide, consistent with management of the area as wilderness, opportunities for public use, enjoyment and understanding of wilderness, through experiences that depend upon a wilderness setting.

Provide outstanding opportunities for solitude or a primitive and unconfined type of recreation.

Maximize visitor freedom within the wilderness. Minimize direct controls and restrictions. Apply controls only when they are essential for protection of the wilderness resource and after indirect measures have failed.

Use information, interpretation, and education as the primary tools for management of wilderness visitors.

The Wilderness Recreation Spectrum (WRS) management prescription for this area (Transition) directs that the average number of people encountered each day should be 24 or less and that no more than two [dispersed] campsites should be visible from a given site. All campsites should be located at least 100 feet from the shoreline, and the

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impacted area should not be greater than 900 square feet (USDA Forest Service, 1998).

1.2.4 Other Resource Management Goals

In its licensing decisions, the Commission considers a hydroelectric project’s consistency with relevant comprehensive plans for developing or conserving waterways, which includes the Washington State Recreation and Conservation Office (RCO), Statewide Comprehensive Outdoor Recreation Plan (SCORP) (IAC, 2002 and 2003), as amended. The SCORP encourages hydropower project operators to review recreation enhancement opportunities at projects. Recommendations and goals outlined in the SCORP were reviewed, as part of the need analysis that was conducted for the Project (Howe Consulting/EES Consulting, 2007). Recreation policies and goals outlined in the Lewis County Comprehensive Plan (Lewis County, 2002) encourage opportunities for recreational and tourist activities that are well managed with respect to the overall preservation of natural resources. The County encourages the multiple use of forest land, which acknowledges the primary use and provides for other compatible uses. These uses may include air and water quality, fauna, flora and their habitats, viewsheds, watersheds and dispersed recreation. Policies and goals outlined in the Lewis County Comprehensive Plan were also reviewed as part of the needs analysis performed for Project relicensing, which informs the PLRP.

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2.0 Roles and Coordination

The Licensee has the responsibility to implement the PLRP as required by the new Commission license. The Licensee’s overall roles and responsibilities and those of the USDA Forest Service in implementing the PLRP are described below. Other aspects of coordination during PLRP implementation are also described.

2.1 Licensee Roles

The Licensee is responsible for the following elements: • Provide funding and implement all mitigation measures identified in the PLRP. • Provide funding for the National Environmental Policy Act (NEPA) actions where necessary and appropriate for measures on NFS lands according to USDA Forest Service Condition No. 1. • Coordinate all aspects of implementing the PLRP with federal, state, local and Tribal governments. If potential effects to sensitive resources are identified, the Licensee will consult with the appropriate resource agency. • Consult with the USDA Forest Service and other appropriate agencies and Tribes when necessary. • Coordinate the annual meeting as described in USDA Forest Service Condition No. 2. • Prepare and submit all annual reports to the Commission and distribute to the USDA Forest Service and other agencies as appropriate.

2.2 USDA Forest Service Roles

The USDA Forest Service is responsible for the following elements: • Provide available technical data and expertise as needed to assist in achieving PLRP goals. • Coordinate with the Licensee, in general, and specifically informing the Licensee of any management proposals or activities (such as fire, timber harvest, or grazing) within or near the Project boundary, including but not limited to dispersed recreation sites discussed in the PLRP. • Review, approve, and update as needed any plans for operations and maintenance of recreation facilities on NFS lands.

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2.3 Communication

Timely and effective communications and coordination between the Licensee and the USDA Forest Service will be crucial to the successful implementation of the PLRP and the achievement of resource goals. While much of this communication is expected to be informal and direct, more formal consultation may be needed to advise the USDA Forest Service of actions taken or proposed.

Therefore, the Licensee and the USDA Forest Service will meet once annually to review PLRP implementation activities during the previous year, coordinate implementation of the measures defined in the PLRP, and to review long-term implementation goals and objectives. This meeting will generally be held in conjunction with the annual resource coordination meeting described in USDA Forest Service Condition No. 2.

2.4 Coordination with Other Project Plans

The Licensee will evaluate measures proposed to benefit non-recreation resource values (aquatic or terrestrial, for example) for their potential effect on recreation facilities and uses. The internal review will occur at least annually and will focus on any proposed operational changes, facility modifications, resource protection plans that involve restricting or modifying public access, and monitoring programs to be implemented. If such reviews identify potential conflicts with recreation uses, the issue and its proposed resolution will be discussed with the affected agencies or entities and summarized in the annual implementation report.

2.5 Annual Meeting and Report

The Licensee and the USDA Forest Service will meet at least once per year, as required under the USDA Forest Service Condition No. 2, to review the previous year’s achievements and activities, and discuss and approve a final annual work plan for the current year. In addition to this meeting, the Licensee and the USDA Forest Service may choose to meet at other times of the year, as needed, to address specific PLRP activities or unanticipated matters or circumstances.

The Licensee, after consultation with the USDA Forest Service, will file an annual report documenting the implementation of the PLRP. The report, which is to be filed by June 1 of each year after Commission approval of the PLRP, is to (i) document the implementation of PME measures as scheduled in the PLRP; (ii) describe the coming year’s proposals for implementing scheduled management actions pursuant to the PLRP; (iii) document consultation activities related to the PLRP; and (iv) document the results of monitoring of completed actions (to the extent monitoring is required for any particular action) to ensure proper implementation and effectiveness.

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2.6 Plan Updates

The Licensee, in consultation with the USDA Forest Service and other agencies/stakeholders as appropriate, will review, update, and/or revise the PLRP if FERC Form 80 monitoring indicates significant changes in recreation use/conditions at Packwood Lake. Changes or revisions to the PLRP would be expected if recreation resource conditions change as a result of unforeseen effects from new or existing Project-related activities or from natural events. Changes may also be implemented if monitoring feedback indicates that resource objectives are not being met and/or it is determined that a specific PME is not providing the intended result and needs to be revised or replaced. Based on the Form 80 Recreation Report schedule, the next report (for the year 2008) will be due to the Commission by April 1, 2009. Thereafter, Form 80 reporting will be submitted to the Commission every six years by April 1 which will include monitoring data through the end of the previous calendar year (December 31).

2.7 Review and Comments

Any updates to the PLRP shall be prepared in coordination and consultation with the USDA Forest Service, and other agencies/stakeholders as appropriate. A minimum of 60 days shall be allowed for the USDA Forest Service and other agencies/stakeholders as appropriate to comment and to make recommendations prior to filing the plan with the Commission for approval. The Licensee shall include with the plan documentation of coordination/consultation, and copies of comments and recommendations. If the Licensee does not adopt a recommendation, the filing shall include the reasons, based on Project-specific information.

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3.0 Implementation Components

Implementation of recreation measures will require coordination and cooperation between the Licensee and the USDA Forest Service.

3.1 Design Standards, Guidelines, Operation and Maintenance

The Licensee shall follow a number of general design guidelines, siting criteria, and other standards in the development, modification or operation of recreation facilities. These will influence decisions for the following purposes: Complying, when applicable, with public health and safety codes and regulations. Considering universal access design standards. Maintaining consistency with the applicable development level (as in the USDA Forest Service ROS classes). Providing a high quality visitor experience and/or enhancing visitor convenience. Minimizing facility and site deterioration and operations and maintenance costs. Avoiding or minimizing impacts to sensitive resources. Recreation facilities constructed on NFS lands will be designed and constructed to meet USDA Forest Service facility construction standards and other design guidelines pertaining to the specific site. Standards and guidelines are defined for operations and maintenance (O&M) for all mitigation measures described in the PLRP (Table 1). Specific implementation tasks and schedule for each mitigation measure are listed in Section 3.2 Implementation Schedule.

3.2 Implementation Schedule

Based upon the PLRP, and with the Commission’s approval, the Licensee will begin the implementation of the PME measures within one year of license issuance and will continue with the implementation of PME measures according to the schedule identified in the PLRP for the life of the new license. Items identified in this PLRP are inclusive of appropriate License requirements and also address Project-related recreation resources located on NFS and other lands affected by the Project or as otherwise ordered by the Commission. The PLRP includes provisions for adaptive management to address changing recreation needs and preferences via Form 80 monitoring and reporting. See PLRP update procedures described above.

PME measures identified below will be implemented and overseen by the Licensee in coordination and consultation with the USDA Forest Service.

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3.2.1 Recreation PME Measures

The following Recreation PME Measures are displayed in Table 1:

1. Development and installation of a composting toilet at Packwood Lake. The toilet will be installed in the vicinity of the Guard Station and the Off Highway Vehicle (OHV) parking area near the lake (Figures 3 and 4). This measure includes all NEPA, permitting and engineering / landscape design requirements.

2. Over the life of the new license, provide for O&M annual funding for the composting toilet. This specifically refers to the ongoing maintenance necessary to keep a composing toilet operational. Waste material must be aerated on a regular basis and additional organic material may be necessary to effectively achieve composting. At a minimum, the toilet should be inspected and maintained on a monthly basis during peak use seasons, or as recommended by the manufacturer.

3. Over the life of the new license, the Licensee will provide for O&M or provide annual funding for a seasonal employee to address dispersed recreation. The items addressed through this PME measure include improved sense of security and safety for visitors, cleanliness of area, responsiveness to visitors needs and improved implementation of USDA Forest Service standards and guidelines.

4. Over the life of the new license, the Licensee will provide annual maintenance to the Pipeline Trail (Trailhead No. 74) and the Pipeline Bypass Trail (Dyson Pass) (drainage, trail clearing, and vegetation management to USDA Forest Service standard), and install and maintain a Kiosk for signage for “Pack it In/Pack it Out” (Figures 3, 5 and 6).

5. Continue to provide electricity to the USDA Forest Service guard station; and

6. As repairs and maintenance to the all Project intake-related structures or facilities are performed, the Licensee will consult with the USDA Forest Service on appropriate paint colors and materials to make the building blend in with the surrounding area.

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Table 1: Recreation PME Measures and Implementation Schedule.

PME Element Action Year Due for Competition

Composting toilet (1, 2) Design and NEPA actions Within 2 years of license issuance

Construction Within the 3rd year of license issuance

Ongoing O&M of facility Annually for the life of license according to USDA Forest Service standards.

Dispersed Recreation (3) Fund seasonal employee to patrol and clean dispersed Annually for the life of license recreation sites along shoreline of Packwood Lake.

Trail #74 and “Dyson Pass Maintain Trail #74 and “Dyson cutoff” (4) Pass cutoff” to Forest Service Annually for the life of license standards.

Kiosk (4) Design and install single panel wood kiosk at Packwood Lake

Trailhead near existing CXT Within 1 year of license issuance toilet to reflect USDA Forest Service standards.

Maintain signing on kiosk – purchase and replace approved Kiosk (4) cont. Annually for the life of license signing.

Guard Station (5) The Licensee will provide power to the USDA Forest Service Annually for the life of license Guard Station at Packwood Lake.

Aesthetic Resources (6) The Licensee will consult with the USDA Forest Service on As repairs and maintenance to appropriate paint colors and the all Project intake-related materials to make Project structures or facilities are developments blend in with the performed surrounding area.

Monitoring and Adaptive Provide a mechanism to adapt Management - USDA Forest Project PME measures when Annually for the life of license Service Condition No.2 resource objectives are not achieved.

Update Recreation Plan Review and modify the PLRP in Every 6 years of new license, or conjunction with filing the as necessary due to unforeseen Commission Form 80. events (catastrophic events such as fires or natural disasters)

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Figure 3: Proposed Location for Compositing Toilet and OHV Parking Area.

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Figure 4: Location for Compositing Toilet

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Figure 5: Location of Kiosk.

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Figure 6: Recommended Placement of Kiosk.

3.2.2 USDA Forest Service Road Maintenance PME Measures

Development of a Road Maintenance Plan for Snyder Road (USDA Forest Service Road 1260), Power house Road (USDA Forest Service Road 1260-013), Pipeline Road (USDA Forest Service Road 1260-066) (level 2-drainage maintenance), and Latch Road (USDA Forest Service Road 1262 above the gate) (level 2-drainage maintenance and vegetation management - brushing) in consultation with the USDA Forest Service. The plan shall include the appropriate Licensee share of the roads the Licensee uses for Project operations. The Licensee shall coordinate the Road Maintenance Plan with the Integrated Weed Management Plan (IWMP).

USDA Forest Service Road 1260 (ML2) was recently changed from a Maintenance Level 4 (ML4). The road, also known as Snyder Road, has a need for continued minor maintenance. The first 1.2 miles is Lewis County (county) jurisdiction, the last 4.6 miles is USDA Forest Service jurisdiction. The full length is a double-lane asphalt road.

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Brushing and drainage maintenance has been accomplished in the past by the USDA Forest Service and the road is in fair condition. USDA Forest Service Road 1260 is used to access Powerhouse Road, Latch Road, and Pipeline Road. The road ends at a large parking lot used as a trail head for accessing Packwood Lake over two USDA Forest Service trails - Trail #78 (maintained by USDA Forest Service) and Trail #74.

USDA Forest Service Road 1260-013 (ML2) also known as Powerhouse Road. This road is gated where it begins just off the end of the county road and extends 2.5 miles. The only vehicle traffic is that of the USDA Forest Service and the Licensee authorized personnel. Travel on this road is very infrequent. The Licensee uses less than ½ mile of this road to access the penstock, raw water, and constant head tanks. The road is native surface and is in fair condition. A short wooden “bridge”, approximately 10 to 12 foot in length and no more than 2-4 foot off the ground, crosses the pipeline at approximately the ¼ mile point. This bridge currently serves no known purpose, and so either needs to be removed or repaired. It is thought that it was installed early in the Project to cross the pipeline, however, the pipeline is estimated to be buried at a depth of approximately 7-10 feet, and traffic over the pipeline is not likely to cause damage; confirmed by the Licensee. There is potential for a Timber Sale up this road in the future. The Licensee has agreed to either; remove the existing bridge and place additional fill material where the road crosses the penstock; or repair the bridge by replacing the decking, if an inspection of the support members determines they are structurally sound.

USDA Forest Service Road 1260-066 (ML2) also known as Pipeline Road, has a few areas that are in need of repair, mostly because of drainage problems. Aside from the drainage structures, the road is in fair condition with little to no surface rock. This road is approximately 1.3 miles in length and ends where Trail #74 begins. It provides parallel access to the pipeline and allows monitoring of the pipeline. This road is gated at the beginning and is open its entire length to the public, via OHV, to access Trail #74.

USDA Forest Service Road 1262 (ML2) also known as Latch Road. The road is a single lane gravel road with few turnouts. This road is located 1.66 miles up Snyder Road. Approximately 3 miles of the road lies in the Lake Creek drainage. Latch Road is gated and locked approximately 2.4 miles in from its junction with Snyder Road. From this point, the road is for administrative use only. It is another 2.2 miles from the gate to where the road ends. There is a large turnaround at the end. Currently, the road prism is partially wheel rutted with several drivable water bars that are semi-functional (meaning in heavy rains they would not function properly). Much of the ditch lines are full of debris and non-functional, and many of the culverts are partially blocked, both inlet and outlet. Other road conditions include; brush encroaching into the roadway and a few springs in the ditch line that corrodes the traveled way or otherwise fill ditch lines with unsuitable material.

In the spring 2007, the Licensee preformed major clearing and minor reconstruction on Latch Road due to a slide that came down from the pipeline trail. The slide covered 300 to 400 feet of road surface. To avoid resource damage on the lower section of road

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below the slide, the Licensee did minor blading to eliminate the rilling caused by excessive rainfall and repaired numerous sections of washout from the slide area to the gate.

Road Maintenance Plan Guidelines and Basis: The maintenance and reconstruction of these facilities would be based on commensurate project personnel, administrative and induced recreational use. This Plan is based on USDA Forest Service guidelines for maintenance level assigned to them and USDA Forest Service Handbook (FSH) 7709.58, 10, 12.16:

1. Work to be accomplished (maintenance activities). 2. Who will perform the work (USDA Forest Service or the Licensee)? 3. Estimated cost of the work. 4. When the work will be accomplished. 5. What needed work will not be accomplished.

Maintenance Levels: Maintenance levels (ML) define the level of service provided by, and maintenance required for, a specific road. Maintenance levels must be consistent with road management objectives and maintenance criteria.

ML 2: Assigned to roads open for use by high clearance vehicles. Passenger car traffic is not a consideration. Traffic is normally minor, usually consisting of one or a combination of administrative, permitted, dispersed recreation, or other specialized uses. Log haul may occur at this level. Appropriate traffic management strategies are either to (1) discourage or prohibit passenger cars or (2) accept or discourage high clearance vehicles.

Sharing Requirements: The legal basis for requiring road users to share in the maintenance of forest development roads is found in Title 36 of the Code of Federal Regulations (36 CFR 212.7). These sharing requirements will be implemented through contracts, permits, and agreements as described in the following sections:

Road Maintenance Agreements: Implement maintenance agreements with State, county or local government agencies, and other Federal agencies to document the sharing of road maintenance responsibilities. See USDA Forest Service Manual (FSM) 1530 for policy and model agreement for the exchange of road maintenance responsibilities or maintenance operations between Federal agencies.

See FSH 1509.11, Grants and Agreements Handbook, Chapter 30, for direction and sample agreement for cooperative maintenance activities with States, counties, or local governments.

Work Performance: Require road users to perform road maintenance work equal in value to their commensurate road maintenance obligation. This may involve performing all or a portion of selected maintenance activities on a continuing or rotating basis.

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Deposited Funds: Use this procedure in situations where the user's share is relatively small in comparison with the total maintenance job, when it is not feasible for the user to perform the work, or when work (such as surfacing replacement or brush cutting) will not be required until some future date. Collect from users those funds that are equal in value to their maintenance obligation. Arrange for the maintenance work to be accomplished. See FSM 6510 for fiscal direction on use of deposited funds.

Road Maintenance Plan: Licensee percent (%) share commensurate with use is based on the Engineering Needs for Access Routes Study Report (Watershed GeoDynamics 2007).

USDA Forest Maintenance Licensee % Miles of Road Service Road & Level Share Name

Road 1260 ML2 1.3% 4.3 miles Snyder Road

Road 1260-013 ML2 80% 0.25 miles Powerhouse Road Road 1260-066 ML2 1.3% 1.3 miles past Pipeline Road gate

Road 1262 ML2 50% 2.2 miles past Latch Road gate

All four roads are Maintenance Level 2 and require general maintenance as needed in accordance with FSH 7709.58, 10, 12.6. The Licensee will perform maintenance in accordance with their commensurate use and according to USDA Forest Service Standards. The Licensee will establish, and keep for record; a form that will track the maintenance performed annually, and will provide a copy to the USDA Forest Service at each annual meeting and upon request (See Appendix B).

Work to be accomplished is as follows:

Traveled way - Log out and brush as necessary to provide passage for planned traffic. Maintain road prism to provide passage of high-clearance vehicles. Surface smoothness is not a consideration. Shoulder - Maintain only as necessary for planned traffic. Drainage - Perform maintenance as necessary to keep drainage facilities functional and prevent unacceptable environmental damage. Dips are the preferred drainage treatment.

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Roadway - Manage vegetative cover as needed for planned traffic. Remove and/or repair slides and/or slumps as needed for access with high clearance vehicles to control resource damage. Roadside – Generally, no work is required. Structure - Maintain all structures to provide for the passage of planned traffic.

Road maintenance cost per mile on a ML2 road ranges from $600/single lane mile for very basic maintenance, to $1300/single lane mile for major maintenance activities. Work will be accomplished as needed. All road maintenance activities by the Licensee or its contractors will be approved by the USDA Forest Service prior to beginning work, to assure all efforts meet USDA Forest Service Regulations and Standards. Excluded in the pre-approval process is logging out the traveled way; however, the USDA Forest Service must be notified after such action has been taken. No wood shall be removed from the forest without proper permits.

3.2.3 USDA Forest Service Meaningful Measures

The Licensee shall apply measures to adequately address the USDA Forest Service resource concerns and standards of quality (e.g., Meaningful Measures) throughout the new License term as described in Table 2 below.

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Table 2: Meaningful Measures. Key Element Key Measure Outcome Standard and guideline Developed Recreation Sites Health and Cleanliness * Visitors are not exposed to Toilet: Clean fixture, disinfect surface, * Denotes Critical Element human waste. refill paper holder, maintain composting toilet in functioning order (extra

operational costs of composing toilet) based on use levels. Remove waste from composting toilet as necessary. Facilities are free of graffiti. Use appropriate graffiti removal products and techniques. Restrooms are free of Sweep toilet, deodorize fixtures, remove objectionable odor. garbage from building, Constructed features are clean. Clean exterior of building.

* Effects from recreation use do Conduct NEPA: Scoping, CE, EA, EIS as not conflict with environmental necessary to implement projects. laws (such as Endangered Species Act, National Historic Protection Act, Clean Water Act, etc).

* When signed as accessible, Check accessible features and constructed features meet current accessibility signing at appropriate accessibility guidelines. frequencies and ensure signing is accurate. Remove signing if feature does not meet standards. Condition of facilities Constructed features are Annual maintenance. serviceable and in good repair throughout the designed service life. Resource Setting Landscape character at the Evaluate scenic objectives; modify Recreation site is consistent with structures (paint, roofing material, design) the Forest scenic integrity as necessary to improve visual setting as

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Table 2: Meaningful Measures. Key Element Key Measure Outcome Standard and guideline objectives. replacement occurs. Dispersed Recreation Sites Resource Setting Recreation opportunities, site Evaluate dispersed recreation impacts * Denotes Critical Element development, and site and rehabilitate sites as necessary to management are consistent with meet management objectives.

ROS objectives, development scale, and the LRMP.

Visitors do not exceed site Monitor use and utilize visitor controls if capacity. necessary.

* High-risk conditions do not exist Identify and document hazards, remove in Recreation sites. hazards.

Safety and Security Laws, regulations and special Regulation enforcement (36 CFR 261

* Denotes Critical Element orders are enforced. [Prohibitions] Subpart A and Subpart B Orders) Visitors are provided a sense of Patrol to create a sense of security. security.

Responsiveness Visitors feel welcome. Agency representatives demonstrate good customer service practices. Information boards are posted in a Allowable site uses, restrictions and other user-friendly and professional important information are posted. manner. Posters are easy to read, boards are not cluttered and posters are kept up so they are not faded, torn, or out-of-date. Trails Health and Cleanliness Remove litter (including dog Pick-up and dispose of litter visible along * Denotes Critical Element waste) along the trail at an trail. appropriate frequency to minimize

accumulation.

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Table 2: Meaningful Measures. Key Element Key Measure Outcome Standard and guideline Trails cont. Remove graffiti visible from the Use appropriate graffiti removal products trail in a timely manner given the and techniques. relative offensiveness (size, symbol, content)

*Hazardous conditions are Identify and document hazards, remove corrected per the trail description. hazards, close trail if necessary. Safety and Security Enforce 36 CFR 261 Prohibitions Enforce regulations upon contact with regulations users engaged in prohibited activities. Respond to complaints from third parties.

Educate users engaged in prohibited activities on the effects of their actions.

Safety and Security cont. Allowable trail uses, restrictions Maintain appropriate signing. and other important information such as access are posted along the trail or at the trailhead. Responsiveness Work performed to maintain Inspect trail structures (culverts, retaining serviceability, or repair failures walls) conditions annually. Perform during the year in which they annual or cyclic work to restore occur. Includes preventive and or functionality to trail structure. Annual cyclic maintenance performed in maintenance is performed to Forest the year in which it is scheduled to Service standards to include; log out, occur. Unscheduled or slough and berm removal, brushing, and catastrophic failures of drainage structure maintenance. components or assets may need to be repaired as a part of annual maintenance.

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3.3 Regulatory Compliance

Recreation measures identified in the PLRP will be implemented in compliance with the requirements of the USDA Forest Service and the Project’s new FERC license. The Licensee will be responsible for funding and/or conducting environmental analyses, compliance, and permitting for actions described in the PLRP, as necessary, subject to applicable laws, regulations, and policies in force at the time individual actions are taken. The Licensee will refer to, or rely upon applicable NEPA compliance documentation prepared by the Commission, USDA Forest Service, Tribal or other parties to the maximum extent possible to avoid unnecessary costs, duplication, and delay.

3.3.1 Measures on National Forest System Lands

To the extent required, projects proposed on National Forest System lands will be reviewed by the Commission and the USDA Forest Service. NEPA and other environmental and land use regulations and policies will be followed. This will include review procedures for the protection of historic properties on federal land as described in the Historic Properties Management Plan (HPMP) (Energy Northwest, 2008).

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4.0 RESOURCES CITED

Energy Northwest, Application for New License Packwood Lake Hydroelectric Project (FERC No. 2244), Public Volume II, February 2008.

Historical Research Associates (HRA). 2005. Cultural Resources Study Plan for Energy Northwest’s Packwood Lake Hydroelectric Project FERC No. 2244, Lewis County, Washington. August 22, 2005.

Howe Consulting, Inc. 2005. Revised Recreation Resources Study Plan for Energy Northwest’s Packwood Lake Hydroelectric Project, FERC No. 2244. August 22, 2005.

Howe Consulting, Inc. 2007a. Final Recreation Resources Study Report for Energy Northwest’s Packwood Lake Hydroelectric Project FERC No. 2244, Lewis County, Washington. April 2007.

Howe Consulting/EES Consulting. 2007b. Recreation Needs Analysis for Energy Northwest’s Packwood Lake Hydroelectric Project, FERC No. 2244, Lewis County, Washington.

Interagency for Outdoor Recreation (IAC). 2002. An Assessment of Outdoor Recreation in Washington State: A State Comprehensive Outdoor Recreation Planning (SCORP) document 2002-2007. October 2002.

Interagency for Outdoor Recreation (IAC). 2003. Estimates of Future Participation in Outdoor Recreation in Washington State. March 2003.

Lewis County. 2002. Lewis County Comprehensive Plan. Lewis County Community Development Dept. Adopted June 1, 1999, Amended December 18, 2000 and April 4, 2002.

USDA Forest Service. 1973. National Forest Landscape Management: Volume 1. Agriculture Handbook 434. U.S. Department of Agriculture Washington, DC: U.S. Department of Agriculture, 1973.

USDA Forest Service. 1974. National Forest Landscape Management: Volume 2. Chapter 1: The Visual Management System. Agriculture Handbook 462. U.S. Department of Agriculture Washington, DC. April 1974.

USDA Forest Service. 1987. The exterior boundary of the GOAT ROCKS WILDERNESS Gifford Pinchot National Forest and Snoqualmie National Forest. Pacific Northwest Region. U.S. Department of Agriculture, Washington, DC.

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USDA Forest Service. 1990. Gifford Pinchot National Forest Land and Resource Management Plan. First Publication. U.S. Department of Agriculture, Washington, DC.

USDA Forest Service. 1995a. Landscape Aesthetics, A Handbook for Scenery Management. Agriculture Handbook 701 (replaces Handbook 462). U.S. Department of Agriculture Washington, DC. December 1995.

USDA Forest Service. 1995b. Land and Resource Management Plan, Gifford Pinchot National Forest. U.S. Department of Agriculture Washington, DC. Amendment 11 (Update #3, replaces pp. IV-45 to IV-150 of the plan).

USDA Forest Service. 1998. Wilderness Resource Protection Environmental Assessment, Gifford Pinchot National Forest. U.S. Department of Agriculture Washington, DC.

USDA Forest Service. 2001. The Built Environment Image Guide For the National Forests and Grasslands. FS-710. U.S. Department of Agriculture Washington, DC. September 2001.

USDA Forest Service Gifford Pinchot National Forest. 2004. Existing Information Analysis for Packwood Lake Recreation Resources. Prepared by D. Bedell for the Packwood Lake Hydroelectric Project FERC No. 2244.

USDA Forest Service. 2005. Gifford Pinchot National Forest Existing Information Analysis for Packwood Lake Access. D. Hadley, Forest Service. Edited March 3, 2005.

USDA Forest Service. 2007. Forest Service Manual, Chapter 2320 – Wilderness Management. U.S. Department of Agriculture Washington, DC. Amended January 2007.

Watershed GeoDynamics. 2007. Engineering Needs for Access Routes Study Report for Energy Northwest's Packwood Lake Hydroelectric Project FERC No. 2244, Lewis County, Washington. May 2007

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APPENDIX A

STAKEHOLDER CONSULTATION

The Packwood Lake Recreation Plan (PLRP) was developed based on the results of several years of consultation and study of the Packwood Lake area. Stakeholder representatives were invited to provide information, technical review and comments during study planning, study implementation and reporting, and during development of the Application for New License for the Packwood Lake Hydroelectric Project.

Energy Northwest, initiated agency consultation in December 2003. In April 2005, a draft Recreation Resources Study Plan was prepared for stakeholder review and comment and meetings were held with stakeholders in April, May and June 2005. The Recreation Resources Study Plan was finalized in August 2005, based on stakeholder input, and the study was initiated. A draft Recreation Resources Study Report was distributed to stakeholders for review and comment in February 2007. A meeting, including a preliminary report of study results, was held with stakeholders in December 2006. The Recreation Resources Study Report was finalized, based on comments received, and issued in April 2007.

A draft Recreation Needs Analysis Study Plan was issued in April 2007 for review and comment, with a final Study Plan completed, based on stakeholder input, in May 2007. The draft Recreation Needs Analysis Report was issued in July 2007 for stakeholder review and comment, and a meeting was held to discuss the report in August 2007. The Final Recreation Needs Analysis Report incorporated stakeholder comments and was issued in September 2007.

PLRP incorporates environmental measures identified, in consultation with stakeholders, during development of recreation studies and the Application for New License for the Packwood Lake Hydroelectric Project.

Stakeholders who were consulted and/or received notice of study plans and report postings available for review and comment, throughout the licensing study process, and who will continue to be included in the development and implementation of the PLRP include:

• USDA Forest Service • National Park Service • Washington State Parks and Recreation Commission • Recreation and Conservation Office (Formerly the Interagency Committee for Outdoor Recreation) • Destination Packwood • American Whitewater • CPR Fish • Washington Department of Fish and Wildlife

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• U.S. Fish and Wildlife Service • National Marine Fisheries Service • Federal Energy Regulatory Commission • National Oceanic Atmospheric Administration • Mount Rainier National Park • Environmental Protection Agency • U.S. Army Corps of Engineers • Bureau of Land Management • Department of Interior Bureau of Reclamation • Northwest Power Planning Office • Washington Department of Ecology • Washington Department of Agriculture • Washington Utilities and Transportation • Washington Dept. of Natural Resources • Washington Department of Archaeology and Historic Preservation • Lewis County • Bureau of Indian Affairs • Cowlitz Tribe • Confederated Tribes and Bands of the Yakama Nation

The PLRP was developed collaboratively between Energy Northwest (the Licensee) and the USDA Forest Service and will include stakeholder review and comment within the Commission’s 60-day AIR time period. Stakeholders will be provided additional opportunity to file comments on the PLRP in response to the Commission’s Notice of Application Acceptance and Ready for Environmental Analysis.

During implementation of the PLRP, consultation with interested stakeholders will continue via annual meetings to discuss progress during the past year and action items for the following year. Once comments are resolved, an annual report include documentation of the implementation of PME measures as scheduled in the PLRP; descriptions the coming year’s proposals for implementing scheduled management actions pursuant to the PLRP; documentation of consultation activities related to the PLRP; and documentation of the results of monitoring of completed actions (to the extent monitoring is required for any particular action) to ensure proper implementation and effectiveness. All relevant recreation updates will be added to this report.

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APPENDIX B

ROAD AND TRAIL MAINTENANCE LOG PACKWOOD LAKE HYDROELECTRIC PROJECT FERC 2244

Road / Trail # Maint Insp. Location//Work Performed/Comments (Note Deferred Hours Date Signature Maint)

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MAINTENANCE PRESCRIPTION GUIDELINES FROM FOREST SERVICE HANDBOOK (FSH) 7709.58 10 and 7709.58 12.6 EXHIBIT 01 General: As needed. Traveled Way: Log out and brush as necessary to provide passage for planned traffic. Maintain road prism to provide for passage of high-clearance vehicles. Shoulder: Maintain only as necessary for planned traffic. Drainage: As necessary to keep drainage facilities functional and prevent unacceptable environmental damage. Roadway: Manage vegetative cover as needed for planned traffic. Remove and/or repair slides and/or slumps as needed for access with high clearance vehicles to control resource damage. Roadside: Generally no work is required. Structure: Maintain all structures to provide for the passage of planned traffic.

ROAD MAINTENANCE LEVEL 2 FSH 7709 58.10 12.3 Assigned to roads open for use by high-clearance vehicles. Passenger car traffic is not a consideration. Traffic is normally minor, usually consisting of one or a combination of administrative, permitted, dispersed recreation, or other specialized uses. Log haul may occur at this level. Appropriate traffic management strategies are either to (1) discourage or prohibit passenger cars or (2) accept or discourage high-clearance vehicles.

These roads have the following attributes: Roads have low traffic volume and low speed Typically local roads Typically connect collectors or other local roads Dips are the preferred drainage treatment Not subject to the requirements of the Highway Safety Act Surface smoothness is not a consideration Not suitable for passenger cars

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Attachment 9

Long Range Estimate of Capital Expenditures Packwood Lake Hydroelectric Project (FERC No. 2244)

Energy Northwest Response to Request for Additional Information June 2008 Packwood Lake Hydroelectric Project FERC No. 2244 Response to FERC's AIR on Project Economics - Clarification of Costs, Benefits, and Income Long Range Estimate of Anticipated Major Maintenance Costs This Long Range Estimate (LRE) is based on 2008 dollars. It includes only items that are considered major capital expenditures and can be expected to occur over the next thirty years of project operations. No attempt has been made to determine when a replacement/failure might occur. The total costs would be allocated over the thirty years of the license as requested by FERC Item Project Cost Long Range Estimate 1 Generator rewind $500,000 2 Penstock anchor stabilization $550,000 3 Communication cable replacement (five miles of minimum 26 pair cable) $625,000 4 4160 cable replacement (five miles of 4160 cable) $575,000 5 Transformer replacement (40 MVA) $450,000 6 Turbine runner replacement (new design and fabrication est. from 2005) $1,100,000 7 Emergency diesel generator replacement (upgrade from gas to diesel) $125,000 8 Turbine bearing replacement $280,000 9 Replace 13 power poles and cable from Transformer Yard Packwood sub-station $61,000 10 "Potential Retrofit Costs" if fish screens require major modification to meet velocity req. $1,400,000 of WDFW 11 Replace electromechanical relays with digital for station safety trip functions $315,000 12 Replace lake level, plant flow, bypass flow, penstock pressure with digital sensors and $165,000 transducers, recorders, data acquisition system 13 Replace/upgrade governor controls with digital $150,000 14 Install bioswale and drainage modifications to meet new state SWPP requirements $45,000 15 Switchyard – replace other components: potential transformers, station service $325,000 16 Replace and upgrade transformer yard braces and standards $35,000 17 Flume refurbishments - new lining, check/replace footing plates and bolts $115,000 18 Structural repair and line tailrace 1 mile (estmated at $125/ft) $660,000 19 Moveable equipement $250,000 20 Maintenance Facilities upgrades (New Building) $300,000 Total Major Maintenance to be added to the Long Range Estimate for Project Economics $8,026,000

AVERAGE COSTS PER YEAR OVER THIRTY YEARS $267,533

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