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UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION

Portland General Electric Company Project No. 2195-088

NOTICE OF AVAILABILITY OF ENVIRONMENTAL ASSESSMENT

(March 20, 2014)

In accordance with the National Environmental Policy Act of 1969 and the Federal Energy Regulatory Commission's (Commission) regulations, 18 CFR Part 380 (Order No. 486, 52 F.R. 47897), the Office of Energy Projects has reviewed an application submitted by Portland General Electric Company (licensee) to construct, operate and maintain minimum flow turbines at its 136.6-MW Hydroelectric Project. The new minimum flow turbines would increase the capacity of the project by 3.89 MW. The project is located on the Oak Grove Fork of the Clackamas River and the mainstem of the Clackamas River in Clackamas County, . The project occupies federal lands within the Mt. Hood National Forest, under the jurisdiction of the U.S. Forest Service, and a reservation of the U.S. Department of Interior’s Bureau of Land Management.

An environmental assessment (EA) has been prepared as part of staff’s review of the proposal. In the application the licensee proposes to construct, operate and maintain: 1) a powerhouse at the base of Dam housing two 0.95-MW turbines, 2) a powerhouse at Crack-in-the-Ground located downstream of housing a 1 MW turbine, 3) a powerhouse housing a 135-kW turbine utilizing return flows from the juvenile downstream migrant collection systems and the North Fork fishway adult fish trap, and 4) a turbine and an 850-kW turbine and induction generator utilizing North Fork fishway attraction flows. The EA contains Commission staff’s analysis of the probable environmental impacts of the proposed action and concludes that approval of the proposal would not constitute a major federal action significantly affecting the quality of the human environment.

The EA is available for review and reproduction at the Commission’s Public Reference Room, located at 888 First Street, NE, Room 2A, Washington, DC 20426. The EA may also be viewed on the Commission’s website at http://www.ferc.gov using 20140320-3029 FERC PDF (Unofficial) 03/20/2014

the “elibrary” link. Enter the docket number (P-2195) in the docket number field to access the document. For assistance, contact FERC Online Support at [email protected] or toll-free at 1-866-208-3372, or for TTY, (202) 502- 865.

Kimberly D. Bose, Secretary. 20140320-3029 FERC PDF (Unofficial) 03/20/2014

ENVIRONMENTAL ASSESSMENT FOR NON-CAPACITY AMENDMENT TO LICENSE

Clackamas River Hydroelectric Project—FERC Project No. 2195-088

Oregon

Federal Energy Regulatory Commission Office of Energy Projects Division of Hydropower Administration and Compliance 888 First Street, NE Washington, D.C. 20426

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TABLE OF CONTENTS

LIST OF FIGURES ...... iii

LIST OF TABLES...... iii

1.0 INTRODUCTION...... 1 1.1 APPLICATION...... 1 1.2 PURPOSE OF ACTION AND NEED FOR POWER...... 1 1.2.1 Purpose of Action ...... 1 1.2.2 Need for Power...... 2 1.3 STATUTORY AND REGULATORY REQUIREMENTS ...... 3 1.3.1 Federal Power Act ...... 3 1.3.1.1 Section 4(e) Conditions ...... 3 1.3.1.2 Section 10(j) Recommendations...... 4 1.3.2 Clean Water Act ...... 5 1.3.3 Endangered Species Act...... 6 1.3.4 Coastal Zone Management Act ...... 7 1.3.5 National Historic Preservation Act...... 7 1.4 PRE-FILING PUBLIC REVIEW AND CONSULTATION...... 8 1.4.1 Consultation...... 8 1.4.2 Comments on the License Amendment Application and Interventions ...... 8

2.0 PROPOSED ACTION AND NO-ACTION ALTERNATIVES ...... 9 2.1 NO-ACTION ALTERNATIVE...... 9 2.1.1 Existing Project Facilities...... 9 2.1.2 Existing Project Operation ...... 10 2.2 LICENSEE’S PROPOSAL ...... 14 2.2.1 Proposed Project Facilities and Construction Activities ...... 14 2.2.1.1 Proposed Project Facilities...... 14 2.2.1.2 Proposed Construction Activities ...... 15 2.2.2 Proposed Operational Modifications...... 15 2.2.3 Proposed Environmental Measures ...... 16 2.2.4 Construction Schedule...... 19 2.3 STAFF ALTERNATIVE ...... 19 2.4 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED ANALYSIS ...... 19

3.0 ENVIRONMENTAL ANALYSIS...... 20 3.1 GENERAL SETTING...... 20 3.2 SCOPE OF CUMULATIVE EFFECTS ANALYSIS ...... 26 3.3 PROPOSED ACTION ...... 26 3.3.1 Geology and Soils...... 26

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3.3.1.1 Affected Environment...... 26 3.3.1.2 Environmental Effects ...... 27 3.3.2 Water Resources...... 28 3.3.2.1 Affected Environment...... 28 3.3.2.2 Environmental Effects ...... 36 3.3.3 Aquatic Resources ...... 39 3.3.3.1 Affected Environment...... 39 3.3.3.2 Environmental Effects ...... 43 3.3.4 Wetland, Wildlife, and Botanical Resources ...... 48 3.3.4.1 Affected Environment...... 48 3.3.4.2 Environmental Effects ...... 52 3.3.5 Threatened, Endangered, and Sensitive Species ...... 54 3.3.5.1 Affected Environment...... 54 3.3.5.2 Environmental Effects ...... 57 3.3.6 Recreation and Land Use...... 60 3.3.6.1 Affected Environment...... 60 3.3.6.2 Environmental Effects ...... 61 3.3.7 Aesthetic Resources...... 62 3.3.7.1 Affected Environment...... 62 3.3.7.2 Environmental Effects ...... 63 3.3.8 Cultural Resources...... 65 3.3.8.1 Affected Environment...... 65 3.3.8.2 Environmental Effects ...... 65 3.4 NO-ACTION ALTERNATIVE...... 66

4.0 CONCLUSIONS AND RECOMMENDATIONS...... 67 4.1 COMPREHENSIVE DEVELOPMENT AND STAFF RECOMMENDED MEASURES...... 67 4.2 UNAVOIDABLE ADVERSE EFFECTS...... 69 4.3 CONSISTENCY WITH COMPREHENSIVE PLANS...... 70

5.0 FINDING OF NO SIGNIFICANT IMPACT ...... 71

6.0 LITERATURE CITED...... 72

7.0 LIST OF PREPARERS ...... 73

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LIST OF FIGURES

Figure 1. Proposed turbine locations - Oak Grove Fork. (Source: Portland General Electric) ...... 12

Figure 2. Proposed turbine locations - Clackamas River. (Source: Portland General Electric) ...... 13

LIST OF TABLES

Table 1. Listed threatened, endangered, and other rare species occurring or potentially occurring in the Project vicinity...... 23

Table 2. USGS Government Camp Gage (No. 14208700) average monthly flows based on a record from 1957 to 2011...... 28

Table 3. Timothy Dam flow releases, ramping, and monitoring...... 29

Table 4. USGS Oak Grove Fork above Powerplant Intake (No. 14209000) average monthly flows based on a record from 1909 to 2011...... 30

Table 5. Current Lake Harriet Dam baseflow releases...... 30

Table 6. USGS gage above Three Lynx Creek (No. 14209500) average monthly flows based on a record from 1910 to 2011...... 32

Table 7. Faraday Diversion Dam flow releases and ramping rates...... 33

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ENVIRONMENTAL ASSESSMENT

Federal Energy Regulatory Commission Office of Energy Projects Division of Hydropower Administration and Compliance Washington, D.C.

Clackamas River Hydroelectric Project FERC Project No. 2195 — Oregon

1.0 INTRODUCTION

1.1 APPLICATION

Application Type: Non-capacity related amendment of license

Date Filed: April 10, 2013, and supplemented August 7, 2013, December 12, 2013, and January 17, 2014

Applicant’s Name: Portland General Electric Company

Waterbody: Oak Grove Fork of the Clackamas River and the mainstem Clackamas River

County and State: Clackamas County, Oregon

Federal Lands: The project currently occupies 2,755.9 acres of federal lands managed by the U.S. Forest Service (Forest Service) within the Mt. Hood National Forest and 111.3 acres administered by the U.S. Bureau of Land Management. Under the licensee’s proposal in this proceeding, the amount of federal land occupied by the project would not change.

1.2 PURPOSE OF ACTION AND NEED FOR POWER

1.2.1 Purpose of Action

Portland General Electric Company (PGE or licensee) owns and operates the 136.6 megawatt (MW) Clackamas River Project. The project consists of four developments: Oak Grove, including the Timothy Lake and Lake Harriet dams; North Fork; Faraday; and River Mill. The Oak Grove development is located on the Oak Grove

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Fork of the Clackamas River and the other three developments are located on the mainstem of the Clackamas River.

The Federal Energy Regulatory Commission (Commission) issued a new license for the project on December 21, 2010. Several mandatory license conditions provided by the Oregon Department of Environmental Quality (Oregon DEQ), Forest Service, National Marine Fisheries Service (NMFS), and the U.S. Fish and Wildlife Service (FWS), require the licensee to increase flow releases, initiate new minimum flows, and construct new flow facilities for the benefit of fish passage. More specifically, the licensee is required to: 1) increase flows below the Timothy Lake dam, 2) release new flows at Crack-in-the-Ground below the Lake Harriet dam, 3) release a new flow through the Faraday diversion dam fish ladder entrance, and 4) construct new fish passage facilities at the North Fork dam which would include excess flow being returned to the Clackamas River.1

Because these flows are substantial enough to support the installation of cost effective turbine-generator units, the licensee filed an application on April 10, 2013, and supplemented August 7, 2013, December 12, 2013, and January 17, 2014 to add generation facilities at three of the four developments. The licensee proposes to: 1) add two approximately 0.95-MW units at the base of Timothy Lake dam, 2) install a single 1- MW unit at Crack-in-the-Ground below the Lake Harriet dam, 3) place a 135-kilowatt (kW) unit on excess return flows within the downstream fish passage facilities at the North Fork development, and 4) install an 850-kW unit to utilize flows passing through the Faraday diversion dam fish ladder entrance. The River Mill Development is not affected by this proposed amendment. The new units would increase the total installed capacity of the project by 3.89 MW.

1.2.2 Need for Power

The Clackamas River Project generation is delivered to the licensee’s electrical and transmission system and contributes to its power requirements, resources diversity, and capacity needs. The licensee’s fully owned hydropower projects supply about nine percent of its electrical energy needs.

In its Sixth Power Plan Mid-Term Assessment Report, the Northwest Power and Conservation Council (Council) forecasts the load in the pacific northwest region to rise at an average rate of approximately 130 average MW per year between now and 2030 (NWPCC, 2013). The report also predicts the loss of load probability to reach the Council’s limit in 2017, indicating that power generation resources may be unable to

1 Crack-in-the-Ground is the local name for a cataract of the Oak Grove Fork located about 0.25 mile below Lake Harriet dam.

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meet regional demand. This is the first time the council has identified an impending shortfall; however, the deficit would need to be reduced by only 350 MW to bring the probability with the Council’s standards.

Although the proposed action would supply a minor portion of the deficit forecasted by the Council, and would contribute a small share to the expected need for increased generation in the region, the use of mandatory flow releases guarantees this generation would be available at nearly all times and would use flows that would otherwise be unavailable for generation. The proposed action would displace the use of non-renewable resources and help contribute to the licensee’s diversified mix of generation resources.

1.3 STATUTORY AND REGULATORY REQUIREMENTS

A license amendment for the Clackamas River Hydroelectric Project is subject to numerous requirements under the Federal Power Act (FPA) and other applicable statutes described below.

1.3.1 Federal Power Act

1.3.1.1 Section 4(e) Conditions

Section 4(e) of the FPA provides that any license issued by the Commission for a project within a federal reservation shall be subject to and contain such conditions as the Secretary of the responsible federal land management agency deems necessary for the adequate protection and use of the reservation. The Forest Service filed preliminary conditions on August 12, 2013, pursuant to section 4(e) of the FPA. The Forest Service’s conditions require PGE to:

 Amend Appendix B, Article 19(b) of the Clackamas License Order to require the removal of all woody debris captured in Lake Harriet and stockpile it for use (i) in the lower Oak Grove Fork below Lake Harriet at locations identified by the Forest Service; or (ii) in habitat restoration projects identified by the Forest Service in the Mt. Hood National Forest in accordance with Section IX of the Fish Passage and Protection Plan, Exhibit D, to the Relicensing Settlement Agreement.

 Amend Appendix B, Article 7 (b)(ii) of the Clackamas License Order to require a 5-cubic foot per second (cfs) minimum flow from the sand trap which would be included in the overall total minimum flow required by Appendix B, Article 7 (b)(ii).

 Design the powerhouse at Crack-in-the-Ground to provide for the maximum possible exclusion of viable fish from the powerhouse discharge.

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 Modify Appendix B, Article 15 (b) in the Clackamas License Order to read as follows: (i) Within five years of completion of the turbine at Crack-in- the-Ground, if NMFS provides evidence of significant predation from non- native fish on anadromous fish in the area below the Barrier Falls on the Oak Grove Fork, the licensee shall, after consultation with the Fish Committee and with the approval of the Fish Agencies, file with the Commission, for approval, either a plan for a three-year monitoring study to determine whether non-native fish are passing through the minimum flow system into the Oak Grove Fork, or a report explaining why a study is not required; (ii) Within six months after completing the monitoring study described in the preceding paragraph, the licensee shall, after consultation with the Fish Committee and with the approval of the Fish Agencies, file a report summarizing the results of the study. If the report determines that unacceptably high numbers of non-native fish are escaping through the minimum flow releases, the licensee shall, in consultation with the Fish Committee and with the approval of the Forest Service file with the Commission, for approval, a plan to reduce the discharge of those non- native fish.

 Establish a $250,000 Resident Fish Mitigation Fund, which would provide funding to habitat mitigation and enhancements intended to benefit resident fish in the Clackamas River Basin upstream of North Fork Dam within three months of a Commission order approving the installation of a turbine at Crack-in-the-Ground becomes final.

The Resident Fish Mitigation Fund would not accrue interest and would be separate from the Clackamas River Hydroelectric Project Mitigation and Enhancement Fund established pursuant to Appendix B, Article 20, of the Clackamas License Order. The fund would be maintained and administered by PGE at its own expense under the direction of Forest Service and Oregon Department of Fish and Wildlife (Oregon DFW) who would select Resource Projects to be funded by the Resident Fish Mitigation Fund. Within six months after issuance of an order amending license, the licensee, Forest Service, and Oregon DFW would agree upon procedures to implement the Resident Fish Mitigation Fund.

1.3.1.2 Section 10(j) Recommendations

Under section 10(j) of the FPA, each hydroelectric license issued by the Commission must include conditions based on recommendations provided by federal and state fish and wildlife agencies for the protection, mitigation, or enhancement of fish and wildlife resources affected by the project. The Commission is required to include these conditions unless it determines that they are inconsistent with the purposes and requirements of the FPA or other applicable law. Before rejecting or modifying an

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agency recommendation, the Commission is required to attempt to resolve any such inconsistency with the agency, giving due weight to the recommendations, expertise, and statutory responsibilities of such agency.

On August 9, 2013, the Oregon DFW filed timely section 10(j) recommendations. The NMFS and the FWS filed timely recommendations under section 10(j) on August 12, 2013. The recommendations filed by the Oregon DFW, NMFS and FWS are identical to the mandatory 4(e) conditions provided by the Forest Service, and therefore are not repeated here.

1.3.2 Clean Water Act

Under section 401 of the Clean Water Act (CWA), a license applicant must obtain certification from the appropriate state pollution control agency verifying compliance with the CWA. On April 10, 2013, PGE applied to the Oregon DEQ for 401 water quality certification (WQC) for the amendment to install the proposed new minimum flow units. The Oregon DEQ timely issued the section 401 WQC on August 6, 2013 (letter from Nina DeConcini, Northwest Region Administrator, Oregon DEQ).2 The conditions in the WQC are:

1) PGE must implement the revised Water Quality Management and Monitoring Plan (WQMMP).3

2) If the Oregon DEQ, after consultation with PGE, determines that monitoring indicates that project operations result in violations of the dissolved oxygen water quality criterion below the turbines located at the outlet of Timothy Lake Dam or below the turbine at Crack-in-the-Ground, PGE must consult with Oregon DEQ and develop and implement project modifications to ensure compliance with water quality standards.

3) If the Oregon DEQ, after consultation with PGE, determines that monitoring below any of the turbines indicates that project operations result in non-compliance with the Total Dissolved Gas (TDG) criterion, PGE must consult with the Oregon DEQ and develop and implement project modifications to ensure compliance with water quality standards.

2 The licensee filed the WQC with the Commission on August 28, 2013.

3 The licensee filed the revised Oregon DEQ approved WQMMP with the Commission on August 22, 2013.

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4) Notwithstanding the conditions of this certification, PGE is prohibited from discharging or conducting activities that cause or contribute to violation of state water quality standards.

1.3.3 Endangered Species Act

Section 7 of the Endangered Species Act (ESA) requires federal agencies to ensure that their actions are not likely to jeopardize the continued existence of endangered or threatened species or result in the destruction or adverse modification of the critical habitat of such species. On March 11, 2013, PGE requested to be designated the Commission’s non-federal representative for the purpose of conducting informal consultation with the FWS under section 7 of the ESA. On May 10, 2013, the Commission designated PGE to act as its non-federal representative.

On August 27, 2013, in support of its amendment application, PGE filed its biological evaluation of the effects of its amendment application on northern spotted owl (Strix occidentalis) and its critical habitat. We reviewed the biological evaluation as well as PGE’s application and we adopted the evaluation without change as the Commission’s Biological Assessment (BA) for this proposed action. We concluded that the construction, operation, and maintenance of the new powerhouses at Timothy Lake Dam, the North Fork fishway trap and sort facility, and at the North Fork fishway entrance would have no effect on federally listed northern spotted owl or its critical habitat. At the Crack-in-the-Ground site, we concluded that construction of the new powerhouse may affect, but is not likely to adversely affect northern spotted owl and its critical habitat. We requested FWS concurrence with our conclusions by letter dated September 10, 2013. FWS concurred with our determinations in a letter filed on October 22, 2013.4

In this environmental assessment, we conclude that there would be no affect from the construction and operation of the minimum flow turbines at the Faraday Diversion Dam and North Fork Return Flow on coho and Chinook salmon, and steelhead trout. No flow changes are proposed therefore there would be no change to aquatic habitat from the construction or operation of the minimum flow turbines. Return flows from the downstream migrant floating surface collector, downstream bypass system, and the North Fork fish ladder are screened before entering the return flow pipe. As a result, no fish will be able to pass from the North Fork Fish ladder or downstream passage facilities to the return flow turbine.

Flows for the operation of the Faraday Diversion Dam turbine would originate from the existing attraction water supply (AWS) pipe structures. Under normal

4 Letter from Paul Henson, State Supervisor, FWS, Portland, Oregon, to K. Bose, Secretary, FERC, Washington, D.C.

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operation, fish do not pass over the North Fork Dam and are not present at the AWS intake. Under high-flow conditions when flows pass over the North Fork Dam spillway, the Faraday Diversion Dam is also operated to spill flows, which precludes fish from entering the AWS intake location.

1.3.4 Coastal Zone Management Act

Under section 307(c)(3)(A) of the Coastal Zone Management Act (CZMA), 16 U.S.C. § 1456(3)(A), the Commission cannot issue a license for a project within or affecting a state's coastal zone unless the state CZMA agency concurs with the license applicant's certification of consistency with the state's CZMA program, or the agency's concurrence is conclusively presumed by its failure to act within 180 days of its receipt of the applicant's certification.

The project is not located within the state-designated Coastal Management Zone, which extends inland to the crest of the Coast Mountain Range, and the project would not affect Oregon’s coastal resources. Therefore, the project is not subject to Oregon coastal zone program review and no consistency certification is needed for the action.

1.3.5 National Historic Preservation Act

Section 106 of the National Historic Preservation Act (NHPA) requires that every federal agency “take into account” how each of its undertakings could affect historic properties. Historic properties are districts, sites, buildings, structures, traditional cultural properties, and objects significant in American history, architecture, engineering, and culture that are eligible for inclusion in the National Register of Historic Places (National Register).

The licensee determined that the proposed undertaking would not have an adverse effect on historic properties to include archaeological or built cultural resources. By letter dated January 8, 2014, PGE requested concurrence on its finding of no effect based on the report provided to the Oregon State Historic Preservation Office (SHPO) on January 6, 2014. The report summarized PGE’s examination of the potential impacts from the proposed generation on cultural resources. By letter dated January 14, 2014, SHPO concurred that the proposed project would have no effect and determined that no further archaeological research is needed pertaining to the project.5

The SHPO does recommend, and Commission staff concurs, that if during development activities PGE staff encounter any cultural material (historic or prehistoric),

5 Letter from Mr. Dennis Griffin, State Archaeologist, SHPO, to Mr. Matthew Bottinglieri, PGE, Hydro Licensing and Water Rights.

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all activities should cease immediately and an archaeologist should be contacted to evaluate the discovery. In its letter, SHPO states that under federal and state law archaeological sites, objects and human remains are protected on both public and private land. We conclude that there would be no affect to archaeological or cultural resources from the proposed construction and operation of the minimum flow turbines.

1.4 PRE-FILING PUBLIC REVIEW AND CONSULTATION

The Commission’s regulations require that licensees consult with appropriate resource agencies, tribes, and other entities before filing an application for amendment of license. Pre-filing consultation must be complete and documented according to the Commission’s regulations.

1.4.1 Consultation

In its pre-filing consultation, the licensee conducted the three-stage consultation process applicable to non-capacity related amendments with additional turbines described in 18 CFR § 4.38. On July 21, 2011, the licensee distributed a document describing its proposed license amendment to members of the settlement agreement for the project relicensing. A joint agency meeting was held on August 22, 2011, where the amendment and stakeholder input were discussed. A second meeting was held on November 1, 2011, to review information requests and discuss plans and other concerns put forth by stakeholders. A third meeting was held on May 12, 2012, to review the licensee’s modified proposal and address remaining concerns.

A draft amendment application was presented to the stakeholders on September 4, 2012. Another meeting was held on November 2, 2012, to discuss the draft application with stakeholders. Comments and preliminary terms and conditions from stakeholders have been incorporated into the license amendment application filed with the Commission. Finally on January 17, 2014, PGE filed with the Commission supplemental consultation with Oregon SHPO pursuant to section 106 of the NHPA.

1.4.2 Comments on the License Amendment Application and Interventions

On June 13, 2013, the Commission issued a public notice that PGE’s application for amendment of license had been accepted for filing and solicited motions to intervene, protests, comments, recommendation, terms and conditions, and fishway prescriptions and announced that the application was ready for environmental analysis.

On August 9, 2013, the Oregon DFW filed 10(j) terms and conditions, and a notice of intervention. On the same day, American Whitewater, Trout Unlimited, and WaterWatch of Oregon filed a joint motion to intervene. On August 12, 2013, NMFS filed comments, 10(j) terms and conditions, and a notice of intervention; the Department

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of the Interior filed comments and 10(j) terms and conditions; and the U.S. Forest Service filed 4(e) terms and conditions.

2.0 PROPOSED ACTION AND NO-ACTION ALTERNATIVES

2.1 NO-ACTION ALTERNATIVE

The no-action alternative is amendment denial with the currently licensed project remaining unchanged. Under the no-action alternative, the project would continue to operate under the terms and conditions of the existing license. The project would discharge the minimum flows required under its license, however no power would be generated, and no new environmental protection, mitigation, or enhancement measures would be implemented. We use this alternative as the baseline environmental condition for comparison with the proposed alternative.

2.1.1 Existing Project Facilities

The Oak Grove development, located on the Oak Grove Fork of the Clackamas River, is the most upstream of the project developments. The uppermost reservoir in the development, Timothy Lake, has a storage capacity of 69,000 acre-feet (ac-ft) and releases flows directly into the Oak Grove Fork. A 25 kW turbine-generator unit is located at the toe of Timothy Lake dam and is used as a backup generator for station service and a nearby lodge complex. Dam releases, plus local inflow from the intervening 72.5 square mile drainage area, travel about 10 miles before entering Lake Harriet with a gross storage capacity of approximately 300 ac-ft. Water is diverted from Lake Harriet into a 9-foot-diameter, 4.1-mile-long pipeline to Frog Lake, an off-stream forebay with a storage capacity of 252 ac-ft. From Frog Lake, water travels through a 9- foot-diameter, 2.3-mile-long pipeline to a surge tank and then enters two 1,220-foot-long steel penstocks to the Oak Grove powerhouse. The powerhouse contains two Francis turbines with a combined capacity of 40.825 MW. The Oak Grove powerhouse discharges water into the mainstem Clackamas River about 5 miles below its confluence with the Oak Grove Fork. The Oak Grove development also includes an 18-mile-long, 115-kilovolt (kV) transmission line from the Oak Grove powerhouse to the Faraday substation.

Approximately 14 miles below the Oak Grove powerhouse, the Clackamas River enters the 18,630-ac-ft North Fork reservoir. The North Fork dam includes an integral powerhouse with two Francis units having a combined installed capacity of 40.8 MW. A 2.7-mile-long, 115-kV transmission line carries power from the North Fork powerhouse to the Faraday substation. The North Fork development includes two downstream fish passage facilities, one of which includes a juvenile collector on the north bank of the North Fork reservoir that transports juvenile fish down below the River Mill development and another, floating surface collector facility. Although it is not yet installed, the floating surface collector, which is required to be constructed prior to

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December 21, 2015, would collect and direct downstream migrating fish into the existing downstream migrant pipeline.6 The development also includes a 1.9-mile-long fish ladder which begins just below the downstream Faraday diversion dam. This fish ladder contains an adult sorting facility which discharges excess flow into the Clackamas River downstream of the North Fork development via a return flow pipeline. Excess flows from the downstream migrant facilities are also directed into the return flow pipeline.

The Faraday diversion dam, located 1.6 miles downstream from the North Fork development, impounds a reservoir with a gross storage capacity of 1,200 ac-ft. Water from the reservoir is routed through a 0.5-mile-long, 23-foot-diameter tunnel and 0.67- mile-long canal into a 430 ac-ft forebay. From the forebay, flows pass through the Faraday powerhouse which contains six Francis turbine/generator units with a combined installed capacity of 35.92 MW. See Figures 1 and 2 for the proposed locations of the new units.

2.1.2 Existing Project Operation

Flow through the Oak Grove Fork of the Clackamas River is controlled through the licensee’s operation of Timothy Lake, Frog Lake, and the Oak Grove powerhouse. Timothy Lake reservoir is maintained near full pool during between Memorial Day and Labor Day and may be drawn down by a maximum of approximately 60 feet outside of the summer season. Releases from Timothy Lake dam are managed to ensure minimum and maximum flows below the dam as stipulated in Article 8 of the WQC and Article 5 of the U.S. Forest Service’s 4(e) conditions filed during project licensing.

The reservoir behind the lake Harriet dam is maintained at full pool year round, but the reservoir may be drafted by 19 feet, if necessary. From Lake Harriet, the licensee releases a minimum flow into the Oak Grove Fork of 100 cubic feet per second (cfs) at the sand trap, which is located in the pipeline between Lake Harriet and Frog Lake. Although the licensee is required to release flows near Crack-in-the-Ground, the Commission has granted authorization to temporarily release flows from the sand trap while the licensee investigates the installation of a new powerhouse as proposed in this amendment application.7 The Commission also approved the design of the ultimate release facilities which would release minimum flows of between 70 to 100 cfs depending upon season and the particular water year type. These minimum flows would

6 The Commission approved the design of the floating surface collector on July 25, 2013. See Order Modifying and Approving North Fork Dam Floating Surface Collector under Article 27 of Appendices D and E, 144 FERC ¶ 62,068 (2013).

7 Order Modifying and Approving Lake Harriet Dam Flow Release System Plan and Schedule, 137 FERC ¶ 62,004 (issued October 4, 2011).

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be released at Crack-in-the-Ground and are required by Article 8 of the WQC and Articles 5 and 15 of the U.S. Forest Service’s 4(e) conditions.

The North Fork reservoir is operated to utilize the upper 2 feet of storage capacity, except in winter when the reservoir elevation can be drawn down by 5 feet. The licensee directs 45 cfs through the North Fork fish ladder. The floating surface collector would operate on 1,000 cfs and direct this flow into the downstream migrant bypass facilities. Approximately 15 to 25 cfs of the flow from the downstream passage facilities and 10 cfs from the upstream fish ladder would be diverted into the Clackamas River downstream of the North Fork dam as excess return flow. Screens would be installed to prevent fish within the fish passage facilities from entering the return flow pipeline.

The reservoir at the Faraday development can vary by about 10 feet in elevation. However, during downstream fish migration periods in the spring and autumn, the Faraday diversion dam would spill 50 percent of inflow whenever spill over the North Fork dam occurs. The licensee is also required to release a minimum flow of 270 cfs from the Faraday diversion dam at all times. This minimum flow includes the 45 cfs released through the fish ladder which extends up to the North Fork development and 225 cfs added to the entrance of the fish ladder through the existing attraction water supply pipeline.

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Figure 1. Proposed turbine locations - Oak Grove Fork. (Source: Portland General Electric)

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Figure 2. Proposed turbine locations - Clackamas River. (Source: Portland General Electric)

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2.2 LICENSEE’S PROPOSAL

The licensee proposes to install new powerhouses below the Timothy Lake, Lake Harriet, and Faraday diversion dams which would utilize mandatory minimum flows for generation. The proposal also includes the installation of a turbine on return flows diverted from upstream and downstream fish passage facilities at the North Fork dam. The installation of the turbines does not alter the timing, quantity, or location of the existing flow releases. The new units would increase the total installed capacity of the project by 3.885 MW.

2.2.1 Proposed Project Facilities and Construction Activities

2.2.1.1 Proposed Project Facilities

As part of the licensee’s proposal, a new approximately 16-foot-wide, 25-foot- long, 20-foot-high powerhouse would be constructed directly downstream of the Timothy Lake dam and house two 0.95-MW Francis turbine-generator units. The proposed powerhouse would be served by an existing 9-foot-diameter penstock used to feed the existing 25 kW unit and Howell-Bunger valve. The turbines would be designed to handle flows between 30 and 300 cfs. Any flows in excess of 300 cfs would be released through the Howell-Bunger valve immediately adjacent to the proposed powerhouse. The Howell-Bunger valve would also be used in the event the new powerhouse is offline or if use of the turbines would lead to non-compliance with dissolved oxygen (DO) standards below Timothy Lake dam. The new powerhouse would be connected to the existing underground transmission lines at the site and would not require any new transmission facilities.

The new powerhouse at the Lake Harriet dam would consist of an approximately 20 by 20-foot-square, 28-foot-high metal structure built on a concrete foundation placed on bedrock. The powerhouse would be located approximately 1,100 feet downstream of the Lake Harriet dam and discharge flows near Crack-in-the-Ground. The licensee would also construct a 70-foot-long, 10 to 15-foot-high retaining wall along an adjacent hillside. The powerhouse would contain a single 1 MW Francis turbine-generator unit which would be connected to an existing distribution line via an approximately 540-foot-long underground transmission line. Flow would exit the unit through an approximately 50- foot-long discharge pipe, traveling down a shotcrete armored slope, into the Oak Grove Fork.

The powerhouse, which is proposed to be constructed on the return flows from the North Fork fish passage facilities, would contain a single 135 kW turbine-generator unit designed to pass flows between 25 and 35 cfs. The powerhouse would include a concrete foundation and metal structure and be approximately 20 feet by 20 feet and 24 feet high. Water exiting the turbine would enter a tailwater pool and would pass over a weir before entering the Clackamas River. The new powerhouse would be connected to an existing 14 20140320-3029 FERC PDF (Unofficial) 03/20/2014

distribution line via a new approximately 25-foot-long, 12.5-kV underground transmission line. The return flow pipeline would include a bypass to release flows when the new unit is offline.

The licensee proposes to construct a 20-foot-wide, 100-foot-deep underground vault next to an adjacent retaining wall below the Faraday dam to house the new Faraday development minimum flow unit. The new unit would be designed to operate on flows from 205 to 225 cfs and have a capacity of 850 kW. The unit would be supplied by a tee from the existing attraction water supply pipeline and release flow through a new underground draft tube into the existing diffusion pool within the fish ladder. The existing pipeline would be automatically opened in the event the new unit goes off-line. The vault would also house a 480-volt/12.5-kV transformer and power would be delivered to an existing distribution line though a new 12.5-kV, 400-foot-long overhead transmission line.

2.2.1.2 Proposed Construction Activities

Prior to beginning construction of the proposed facilities, the licensee would remove and stockpile natural woody debris and topsoil. These materials would be stored and used to restore the site following construction. To construct the new powerhouse at the Timothy Lake development, the licensee would need to shut down the existing minimum flow pipeline for a short time; however, the licensee would release minimum flows by passing water over the spillway or through other methods. The licensee would also implement best management practices (BMPs), discussed in section 2.2.3, to prevent and control soil erosion and run-off. Construction of the powerhouse would require the use of an approximately 0.25 acre lay down area.

At the Lake Harriet construction site, a few large trees up to 2 feet in diameter may need to be removed and no more than 0.25 acres of land would be disturbed. Construction of the Lake Harriet powerhouse would require three laydown areas with a total area of approximately 2,000 square feet which would be used between July and October.

In order to install the Faraday minimum flow turbine, the licensee would excavate into the area adjacent to an existing retaining wall and tee into the existing attraction water system pipeline. The draft tube from the proposed unit to the fish ladder would be constructed using a jack and bore method. The new overhead transmission line at the Faraday minimum flow turbine would be constructed in compliance with guidelines of the Avian Power Line Interaction Committee.

2.2.2 Proposed Operational Modifications

The licensee proposes no changes to project operations. Each of the new generating facilities would release flows that are already required and would be

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constructed on conduits that have been authorized by the Commission. The licensee’s proposal includes provisions for bypassing the new units; therefore, if any of the units were offline, the required flows would be released at an equal rate and in essentially the same locations.

2.2.3 Proposed Environmental Measures

The licensee proposes a number of BMPs which would be implemented during construction of the new facilities. As part of its proposal, the licensee intends to:

 Ensure construction activities associated with habitat enhancement and erosion control meet or exceed the requirements of applicable state and federal permits;

 Perform construction boundary flagging, stockpile sufficient emergency erosion control supplies, and install temporary erosion control measures prior to significant alteration of the construction site;

 Limit construction impacts to the minimum area necessary;

 Install temporary erosion control on exposed slopes if a construction hiatus would exceed 7 days;

 Minimize alteration and disturbance of stream banks and riparian vegetation;

 Avoid herbicide application as part of the construction activities unless specifically authorized;

 Retain, to the greatest feasible extent, all existing vegetation within 150 feet of a streambank;

 Perform work below the normal waterline during periods preferred by the U.S. Army Corps of Engineers and the State of Oregon, unless otherwise approved;

 Remove materials, equipment, and fuel and cease construction if high flows are expected to inundate construction areas within 24 hours;

 Provide passage to any anadromous salmonid species within the construction area unless otherwise approved in writing by NMFS;

 Monitor instream turbidity and inspect erosion control measures and repair as necessary;

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 Treat all construction water such as concrete washout, discharge from dewatering pumps, vehicle wash water, and drilling discharge;

 Disallow any pollutant such as sewage, waste spoils, or petroleum from contacting a water body or its substrate;

 Avoid construction activities in which treated lumber or its leachate could contact flowing water except for the use of pilings following NMFS guidelines;

 Construct temporary access roads only where necessary and avoid steep slopes or crossing streams at less than right angles and obliterate and revegetate roads when no longer needed;

 Use the least environmentally damaging heavy equipment possible and refuel, inspect for leaks, and clean heavy equipment at least 150 feet from any water body unless otherwise authorized in writing;

 Install containment around all stationary power equipment which would be used within 150 feet of a water body;

 Avoid, replace, or stockpile native materials such as woody debris, vegetation, and topsoil during construction activities;

 Completely isolate in-water work from the flowing water body if fish are reasonably certain to be present or spawning areas are nearby;

 Complete drilling, excavation, dredging and filling as quickly as possible; and

 Provide applicable agencies with periodic construction reports.

PGE also proposes a number of measures for the protection, mitigation, or enhancement of environmental resources affected by the project which it adopted based on the recommendations, terms and conditions proposed by state and federal resources agencies.

 PGE would design the Faraday Diversion Dam transmission line upgrade to meet Avian Power Line Interaction Committee (APLIC) standards for raptor protection.

 Avoid high impact construction involving loud noise or high levels of disturbance within 65 yards of suitable northern spotted owl habitat during the critical nesting period of March 1 - July 15.

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 Implement a revised Water Quality Management and Monitoring Plan and supplemented on December 12, 2013, to monitor downstream of Timothy Lake and Crack-in-the Ground ambient dissolved oxygen (DO) concentrations May through September and monitor total dissolved gas (TDG) one day per month over a four-hour period in July through November downstream of Timothy Lake, Crack-in-the Ground, Faraday Lake, Faraday Diversion Dam, and River Mills.

 PGE proposes to amend Appendix B, Article 19(b) of the Clackamas License Order to require the removal of all woody debris captured in Lake Harriet and stockpile it for use (i) in the lower Oak Grove Fork below Lake Harriet at locations identified by the USFS; or (ii) in habitat restoration projects identified by the USFS in the Mt. Hood National Forest in accordance with Section IX of the Fish Passage and Protection Plan, Exhibit D to the Relicensing Settlement Agreement.

 Amend Appendix B, Article 7 (b)(ii) of the Clackamas License Order to require a 5-cfs minimum flow from the sand trap which would be included in the overall total minimum flow required by Appendix B, Article 7 (b)(ii).

 The design for the powerhouse at Crack-in-the-Ground to provide for the maximum possible exclusion of viable fish from the powerhouse discharge.

 Amend the Fish Passage and Protection Plan, Section V.C of Exhibit D to the Clackamas Relicensing Settlement Agreement, to delete the requirement to install new bar racks at the intake to the Frog Lake flow line.

 Modifying Appendix B, Article 15 (b) in the Clackamas License Order to read as follows: (i) Within five years of completion of the turbine at Crack- in-the-Ground, if NMFS provides evidence of significant predation from non-native fish on anadromous fish in the area below the Barrier Falls on the Oak Grove Fork, the Licensee shall, after consultation with the Fish Committee and with the approval of the Fish Agencies, file with the Commission, for approval, either a plan for a three-year monitoring study to determine whether non-native fish are passing through the minimum flow system into the Oak Grove Fork, or a report explaining why a study is not required; (ii) Within six months after completing the monitoring study described in the preceding paragraph, the Licensee shall, after consultation with the Fish Committee and with the approval of the Fish Agencies, file a report summarizing the results of the study. If the report determines that unacceptably high numbers of non-native fish are escaping through the minimum flow releases, the Licensee shall, in consultation with the Fish

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Committee and with the approval of USFS file with the Commission, for approval, a plan to reduce the discharge of those non-native fish.

 Establish a $250,000 Resident Fish Mitigation Fund, which would provide funding for habitat mitigation and enhancements intended to benefit resident fish in the Clackamas River Basin upstream of North Fork Dam within three months of a Commission order approving the installation of a turbine at Crack-in-the-Ground becoming final.

The Resident Fish Mitigation Fund would not accrue interest and would be separate from the Clackamas River Hydroelectric Project Mitigation and Enhancement Fund established pursuant to Appendix B, Article 20 of the Clackamas License Order. The fund would be maintained and administered by PGE at its own expense under the direction of USFS and Oregon DFW, who would select Resource Projects to be funded by the Resident Fish Mitigation Fund. Within six months after issuance an order amending license, the Licensee, USFS, and Oregon DFW would agree upon procedures to implement the Resident Fish Mitigation Fund.

2.2.4 Construction Schedule

Under the licensee’s preliminary schedule, construction on the new Timothy Lake and Lake Harriet powerhouses would begin in 2014 and be completed by the end of 2015. Construction of the new North Fork return flow powerhouse would begin in 2015 and the units would be operational in late 2016. Construction of the new Faraday development minimum flow turbine-generator unit would begin in 2016 and the unit would be operational by the end of 2017.

2.3 STAFF ALTERNATIVE

Under the staff alternative, the project would include PGE’s proposed measures adopted from the recommendations of the Oregon DFW, FWS, NMFS, the Forest Service’s mandatory 4(e) conditions and the Oregon DEQ’s mandatory WQC conditions. Staff did not identify any additional alternatives for analysis.

2.4 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED ANALYSIS

No reasonable alternatives have been identified other than PGE’s proposal, staff alternative, and no action.

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3.0 ENVIRONMENTAL ANALYSIS

3.1 GENERAL SETTING

Geology

The Clackamas River Basin lies within three physiographic regions: High Cascades, Western Cascades, and . The High Cascades region consists of Quaternary-age (< 2 million year-old) basalt and andesite flows, which have formed the ridges and canyons that confine the Clackamas River. The rivers in this region produce a low sediment yield.

Below elevation 3,500 ft to about elevation 300 ft, the Clackamas River and Oak Grove Fork run through the Western Cascades physiographic region. Near the North Fork, Faraday, and River Mill developments, the river has incised into basaltic rocks and created steep canyon walls.

The Willamette Valley physiographic region occurs from Estacada to the confluence of the Clackamas and Willamette rivers. This area contains mostly flat-lying sedimentary rocks from as far back as the Pliocene (5.3 - 1.6 million years ago) to as recent as 10,000 years ago.

Water Resources

The Project is within the Clackamas River Basin, which is located west of the Cascade Range and south of the Columbia River Gorge and includes part of the Portland metropolitan area. The Clackamas River drains more than 940 mi2 beginning on the slopes of Olallie Butte (elevation 6,000 ft) in the Cascade Mountains, and flows 82.7 mi to its confluence with the near Gladstone and Oregon City. Hydroelectric project operations influence the hydrologic regime of the Clackamas River watershed. Modifications to the natural flow regime include storage in reservoirs/impoundments, diversions of water from the mainstem, spills over the dams, and powerhouse releases.

Water released into the Oak Grove Fork from Timothy Lake Dam flows approximately 11 mi to Lake Harriet. Seasonal pulsed flows pass over Lake Harriet Dam and through a sand trap when appropriate. Pursuant to license conditions, PGE will divert minimum flows from the primary pipeline through a baseflow pipeline and release these flows at a location near Crack-in-the-Ground. The primary pipeline passes flows from Harriet Dam to Frog Lake and eventually to the Oak Grove Powerhouse. The Oak Grove powerhouse discharges into the mainstem Clackamas River, where the combined flow continues downstream to North Fork Reservoir. From there, first North Fork Powerhouse, then Faraday Powerhouse, and lastly River Mill Powerhouse use the combined flow for power generation.

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Aquatic Resources

The Clackamas River system, including the Oak Grove Fork, has good water quality. Water quality indicators are generally within the Oregon Department of Environmental Quality’s (ODEQ) criteria with some transient, site-specific issues discussed in relevant sections below. Potential temporary effects of turbine installation on water quality relate to temporary construction activities exclusively and are discussed in the relevant sections below.

The Clackamas River Basin provides 142 mi of anadromous fish habitat (FERC 2006) including the reach of river with the North Fork, Faraday, and River Mill Developments; however, the anadromous fish populations do not occur in the Oak Grove Fork above two natural fish passage barriers, approximately 0.25 and 1.0 mi downstream of the Lake Harriet Dam. Five native species of anadromous fish occur in the basin. These include wild late-run and naturalized early-run (naturalized hatchery stock) coho salmon (Oncorhynchus kisutch), spring-run and fall-run Chinook salmon (O. tshawytscha), winter- and summer-run steelhead trout (O. mykiss), a remnant wild population of coastal cutthroat trout (O. clarki clarki) , and Pacific lamprey (Lampetra tridentata) (FERC 2006). Three of these species (coho, Chinook, and steelhead) are currently listed as threatened under the ESA.

The basin also supports a diverse range of resident species including populations of cutthroat trout, kokanee salmon, rainbow trout, brook trout, brown trout, and mountain whitefish, among other species. Recreational anglers fish some areas within the Project heavily (FERC 2006). Resident fish inhabit all of the Project reservoirs and the stream reaches between Project structures. Cutthroat trout, rainbow trout, and mountain whitefish are indigenous to the basin, whereas kokanee, brook trout, and brown trout are introduced species. Bull trout, which are federally listed under the ESA, were historically present in the Clackamas River Basin, but were believed to have been extirpated in recent decades (FERC 2006). The US Fish and Wildlife Service (USFWS) began bull trout reintroduction efforts in the watershed in 2011; however, these are experimental populations.

Wetland, Wildlife, and Botanical Resources

The area within the Project boundary contains over 3,750 ac of relatively undeveloped land. The Mount Hood National Forest manages much of this area for timber production and protection and maintenance of wildlife habitats and species, scenic values, and recreation. Terrestrial wildlife habitats and communities in the Project area are typical of those found in undeveloped landscapes at similar elevations along the west slope of the Cascades.

Over 300 animal species are known to occur or potentially occur in the Project vicinity. Birds are the most diverse group of animals in and around the Project. In 21 20140320-3029 FERC PDF (Unofficial) 03/20/2014

addition, 18 species of amphibians, 13 species of reptiles, and 72 or more species of mammals have the potential to occur in Project vicinity (FERC 2006).

The Project lies within the Western Hemlock Zone, which typically occurs below elevation 3,500 ft and is associated with relatively warm climate conditions and highly productive soils. Forty-three cover types occur within the Project vicinity. These include upland conifer forest; upland deciduous forest; riparian; wetland; non-forested upland; rock and cliff; developed and disturbed; Project rights-of-way (ROWs); and riverine and lacustrine. Upland conifer forest is the dominant general vegetation type in the terrestrial study area followed by riparian cover types.

Threatened, Endangered, and Sensitive Species PGE reviewed the updated USDA Forest Service (USFS) Regional Forester's Sensitive Species, Region 6 (December 1, 2011) and identified those species that, based on past surveys, occurrence records, and site habitat conditions, have the potential to occur at or near the proposed small turbine sites (Table 1). Four federally-listed fish species occur in the mainstem Clackamas and lower Oak Grove Fork. Critical habitat and historic nest locations for the federally-threatened northern spotted owl occur in proximity to both the Timothy Lake and Crack-in-the-Ground proposed turbine locations. Townsend’s big-eared bats, a federal species of concern, use a hibernaculum near the Crack-in-the-Ground turbine site. Other species listed on the USFS Region 6 Sensitive Species List that could occur at the turbine sites include Cope’s giant salamander and fringed myotis bat, both considered vulnerable species by the Oregon Department of Fish and Wildlife. Other species that were listed on the TES species list for the overall Clackamas Project vicinity, such as the peregrine falcon and harlequin duck, are not likely to occur at the proposed turbine sites due to lack of nearby breeding habitat or typical foraging habitat.

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Table 1. Listed threatened, endangered, and other rare species occurring or potentially occurring in the Project vicinity.

SPECIES Scientific Name USFWS/NMFS1 ODFW2 USFS3 ONHP4 FISH (4) Steelhead Oncorhynchus mykiss T SC -- 1 Chinook salmon Oncorhynchus T -- -- 1 tshawytscha Coho salmon Oncorhynchus kisutch T E -- 1 Bull trout Salvelinus conflventus T SC -- 1 AMPHIBIANS (4) Cascade torrent salamander Rhyacotriton cascadae -- SV X 2 Oregon slender salamander Batrachoseps wrighti SoC SU X 1 Cascades frog Rana cascadae SoC SU -- 2 Red-legged frog Rana aurora aurora SoC SV X 2 BIRDS (5) Northern spotted owl Strix occidentalis T T -- 1 Greater sandhill crane Grus canadensis -- SV X 4 Harlequin duck Histrionicus histrionicus SoC SU X 2 Peregrine falcon Falco peregrinus -- E X 2 MAMMALS (1) Townsend’s big-eared bat Corynorhinus townsendii SoC SC X 2 townsendii PLANTS (6) Cold-water corydalis Corydalis aquae-gelidae -- -- X 1 Pale blue-eyed grass Sisyrinchium SoC -- X 1 sarmentosum Northern bladderwort Ultricularia ochroleuca ------3 Stiff clubmoss Lycopodium annotinum ------4 Tall bugbane Cimicifuga elata -- -- X 1 Nuttall’s larkspur Delphinium nuttallii ------2 FUNGI (6) Gastroid King Bolete Gastroboletus subalpinus X -- Pig’s ears Gomphus clavatus X -- Elastic Saddle Helvella esastica X 3 Blue Chanterelle Polyozellus multiplex X 4 Ramaria celerivirescens X -- Ramaria maculatipes X 3 1 E=Listed as Endangered, T=Listed as Threatened, P=Proposed for federal listing. C=Candidate for federal listing, SoC=Federal species of concern. NMFS manages steelhead and chinook salmon. The USFWS manages all other federally listed species presented. 2 Oregon Department of Fish and Wildlife (ODFW) Status: E = endangered, T = threatened, U = Undetermined Status - species for which status is unclear; SV = Sensitive Vulnerable - species for which listing as threatened or endangered is not imminent and can be avoided through protective measures; SC = Sensitive Critical - species for which listing as threatened or endangered is pending or warranted if immediate conservation measures are not taken; SU = Sensitive Undetermined – sensitive species for which status is unclear. 3 USDA Forest Service Regional Forester's Sensitive Species, Region 6. 4 Oregon Natural Heritage Program (ONHP) Status: 1 = List 1 -- taxa threatened with extinction or presumed to be extinct throughout their entire range. 2 = List 2 -- taxa threatened with extirpation or presumed to be extirpated from the state of Oregon. 3 = List 3 -- taxa for which more information is needed before status can be determined, but which may be threatened or endangered in Oregon or throughout their range. 4 = List 4 -- taxa which are of conservation concern but are not currently threatened or endangered.

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Recreational Resources and Land Use

The Clackamas River Project is located within a large expanse of rugged and relatively undeveloped land on the west side of the Cascade Mountains. The Project is approximately 50 mi from Portland and offers a variety of recreational opportunities to the greater Portland metropolitan area.

Timothy Lake receives the highest recreational use within the Mount Hood National Forest. Primary recreation activities include camping, boating, fishing, hiking, wildlife observation, and winter sports. Lake Harriet is also a popular fishing destination. Little recreational use occurs on the Lower Oak Grove Fork, below Lake Harriet, because of difficult access. The Clackamas River between the confluence of the Lower Oak Grove Fork and North Fork Reservoir is a popular whitewater boating, fishing, and camping area. The North Fork Development offers a variety of recreation opportunities. The 350-ac North Fork Reservoir provides angling and flatwater boating opportunities. The Faraday Development offers land-based day-use recreational opportunities; PGE does not allow boating or overnight use at this development. The primary recreational activity is bank fishing at Faraday Lake, the 50-ac forebay for the Faraday Powerhouse. The Faraday Diversion Reach is not open to vehicular access, but it is currently used for walk-in fishing and viewing wildlife (FERC 2006). The upper most extent of Estacada Lake, a relatively small waterbody (150 ac) impounded by the River Mill Development, extends to the base of the Faraday Diversion dam.

Approximately 71 percent of the land in the Clackamas River Basin is in public ownership. Most of the upper watershed is in the Mount Hood National Forest, while most of the lower watershed is privately owned. Approximately 73 percent of the watershed is classified as mature or regrowth forest, while only approximately 3 percent is urban and about 3 percent is in agricultural use. There is a limited amount of industrial land use in the watershed, primarily related to hydropower operations, agriculture and other resource-related operations, and most of it is concentrated in the lower watershed downstream of River Mill Dam (FERC 2006).

Aesthetic Resources

The Clackamas River Project is located on the west slope of the Cascade Mountains. Primary landscape features include dense conifer forests dominated by mature Douglas fir and western red cedar, riparian flats with wetlands and with groves of cottonwood and red alder, beaches of river-rounded cobbles, occasional views of Mount Hood, and water cascading through narrow canyons. In general, the Project area is in a natural to a natural-dominated condition, but a combination of highway construction, timber harvesting, recreational development, and transmission lines have affected the natural appearance.

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Cultural Resources

The four developments that constitute the Project contributed to the history and economic development of the Clackamas River Basin. The demand for electricity in Portland spurred initial efforts to develop hydropower facilities along the Clackamas River. Construction of the Cazadero Diversion Dam and Faraday Powerhouse began in 1902 and was completed in 1907.

In 1909, construction of the River Mill Development was initiated. River Mill Dam is the oldest and apparently sole survivor of only three Ambursen type dams built west of the Rocky Mountains. This style dam was noted for its innovative hollow flat slab and buttress construction. It is currently listed in the National Register of Historic Places.

Construction of the Oak Grove Development began in 1921. The development was completed in 1924 and President Calvin Coolidge officially opened the development. As originally developed, Lake Harriet fed the Oak Grove Powerhouse. Between 1953 and 1956, Timothy Lake was constructed to provide additional seasonal storage (FERC 2006).

The North Fork Development began operation in 1958. It is one of the tallest arch dams in Oregon with a crest height of 207 ft. The North Fork fish ladder was constructed as part of the original development and at 1.9 mi is one of the longest operating fish ladders in the world.

Traditional tribal territories within, or adjacent to, the Clackamas River Hydroelectric Project correspond to two Aboriginal groups known as the and Clackamas. The Molala traditionally occupied more upland and interior areas. They occupied the Western Oregon Cascade Range and were best known as hunters and for their access to plant resource areas in the uplands. The Molala seasonally occupied the Willamette Valley, where the Clackamas River provided the best fishing within their territory. The Clackamas lived along the Willamette River below the Willamette Falls and up the Clackamas River to what is now Estacada and subsisted mainly on anadromous fish. They were part of the larger Chinookan-speaking groups along the Columbia River to the Pacific Ocean.

These tribal groups continued to use their traditional lands following the arrival of Europeans; however, the treaties of 1855 and establishment of reservations gradually relocated the Molala and Clackamas people out of the Project area. Small groups would return to their native lands at various times throughout the year to fish and gather resources, but this practice ended by World War I. Remaining trips were associated with commercial harvesting as the local tribes began to seek employment from the European Americans.

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During Project relicensing, PGE surveyed approximately 1,675 ac identified as the Area of Potential Effect (APE). The remaining lands were previously developed, too steep, or otherwise unsafe to examine. In addition, the USFS and other private investigators have conducted numerous small and large-scale cultural resource investigations in the Clackamas River Basin. These surveys consisted of small pedestrian surveys, timber sales surveys, the Wild and Scenic River designation process, and test and large-scale data recovery excavations. While these studies do not focus on the APE for the Clackamas River Hydroelectric Project, they include portions of the APE.

Twenty-seven archeological sites and 12 isolated finds have been investigated. Nineteen of the sites are prehistoric, five are historic, and three sites have both historic and prehistoric components. None of the identified sites occurs within the area proposed for minimum flow generation facilities.

3.2 SCOPE OF CUMULATIVE EFFECTS ANALYSIS

According to the Council on Environmental Quality’s regulations for implementing NEPA (40 CFR, section 1508.7), a cumulative effect is the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (federal or non-federal) or person undertakes such other actions. Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time, including hydropower and other land and water development activities.

Based on our review of the amendment application and agency and public comments, we have not identified any resources that may be cumulatively affected the addition of the minimum flow turbines.

3.3 PROPOSED ACTION

In this section, we discuss the effect of the project alternatives on environmental resources. For each resource, we first describe the affected environment, which is the existing condition and baseline against which we measure effects. We then discuss and analyze the specific site-specific and cumulative environmental issues.

3.3.1 Geology and Soils

3.3.1.1 Affected Environment

The location of the proposed Timothy Lake minimum flow powerhouse is nearly on the approximate boundary between the High Cascades and Western Cascades physiographic regions. During a study of fluvial geomorphology downstream of the Timothy Lake dam, the licensee determined that channel morphology near the site of the proposed powerhouse is primarily impacted by flow. The site of the proposed

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powerhouse is at the base of a steep rock slope and immediately adjacent to the Oak Grove Fork.

The licensee conducted a similar study of fluvial geomorphology for the Oak Grove Fork near the Lake Harriet dam and found that course sediment supply in the area of the proposed powerhouse is low, due to both natural conditions and the presence of Lake Harriet dam. Being in the Western Cascades region, the site of the proposed powerhouse includes volcanic deposits that are susceptible to mass wasting events. Several landslides have occurred in the area below Lake Harriet dam.

The proposed return flow powerhouse at the North Fork development and the proposed minimum flow unit at the Faraday development are also located in the Western Cascades physiographic region. Here the Clackamas River has cut through the basaltic bedrock to create steep canyons. The site of the proposed North Fork powerhouse is on a level area approximately 45 feet up a steep bedrock slope from the Clackamas River. The Faraday development minimum flow turbine would be located adjacent to an existing retaining wall within an area of engineered fill over bedrock.

3.3.1.2 Environmental Effects

Impacts to geology and soils caused by the proposed action at the four dams would be limited to those directly related to construction of the new facilities. Ground disturbance for construction and creation of the 0.25-acre laydown area at Timothy Lake dam and 2,000-square-foot laydown area at Lake Harriet would disturb soils and lead to possible erosion. However, the licensee proposes to implement the BMPs described above which would reduce the possibility of soil erosion. The retaining wall proposed at the new Lake Harriet powerhouse would help to reduce the possibility of landslides and other mass wasting events. Additionally, the underground transmission line from the proposed Lake Harriet minimum flow powerhouse would not cause any additional soil disturbance as it would follow the same route as the authorized flow conduit to the proposed powerhouse.

Although the tailwater pool of the proposed North Fork return flow powerhouse would discharge water down a steep bank approximately 45 feet to the Clackamas River, the river bank at this location is bedrock and there would be little possibility of soil erosion. Additionally, construction of the Faraday development minimum flow unit would occur within an area of engineered fill, and much of the construction would occur underground. The only locations in which construction would occur on the surface are adjacent to an existing retaining wall and within the fish ladder, both of which are areas heavily disturbed by prior construction and largely consist of concrete and other engineered materials. We determine that the impacts on geology and soils from the proposed action would have a minor and short-term impact.

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3.3.2 Water Resources

3.3.2.1 Affected Environment

Water Quantity

Timothy Lake

Timothy Lake

The Upper Oak Grove Fork watershed is located in the High Cascade region of Clackamas County, Oregon. Spring snowmelt dominates the watershed hydrology. Timothy Dam, a 105-ft-high earth-fill structure impounds the Upper Oak Grove Fork at RM 16.2 to form Timothy Lake with a surface area of 1,439 ac at a maximum lake elevation of 3,191.9 ft (PGE Datum). The tributaries to Timothy Lake are unregulated. The average annual flow of the Upper Oak Grove Fork is 131.7 cfs as measured at the U.S. Geological Survey’s (USGS) Government Camp Gage (No, 14208700) downstream of the Timothy Lake Dam. The storage capacity of Timothy Lake dampens the hydrograph of the Upper Oak Grove Fork watershed such that average monthly flows are relatively consistent (Table 2).

Table 2. USGS Government Camp Gage (No. 14208700) average monthly flows based on a record from 1957 to 2011.

Month Average Monthly Flow (cfs) January 158 February 155 March 153 April 118 May 128 June 112 July 76 August 77 September 124 October 153 November 177 December 151

The proposed minimum flow turbine would house a turbine designed to take advantage of the minimum flows required by the license and shown in Table 3.

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Table 3. Timothy Dam flow releases, ramping, and monitoring.

Flow Release, cfs Date Notes Minimum Maximum

Memorial Day through Inflow + 70 Labor Day

Day after Labor Day 60 cfs or inflow, Inflow + 100 through Sept 30 whichever is less Oct. 1 through Oct 31 Inflow + 150

Nov. 1 through Nov 30 Limit of three large scale flow Inflow +300 30 cfs or inflow, events during this period Dec. 1 through Feb. 28/29 whichever is less

Mar. 1 through day before 40 cfs or inflow, Inflow +100 Memorial Day whichever is less

Additional Maximum Flow Release Constraints

1. During the period from Nov 1 through Feb 28/29, PGE allows no more than three large-scale flow events, defined as a day or series of consecutive days in which Timothy Lake outflow exceeds inflow by 200 cfs or more. This limitation does not apply during system power emergencies or equipment failures at Timothy Lake Dam or Oak Grove Powerhouse.

Ramping Rates

1. Ramping rates below Timothy Lake are controlled by PGE's operation of the Timothy Lake facilities as measured at the USGS Government Camp gage. 2. PGE operates the project with the following limits for stage changes below the Timothy Lake development, except during certain conditions, including: (1) anticipated flood events; (2) any event that triggers the Project Emergency Action Plan; (3) rapid changes in Timothy Lake inflows, when the rate of inflow change exceeds the stage change limits; (4) periods when flow must be passed through the spillway gates because flows exceed the capacity of the Howell-Bunger valve; and (5) equipment failures or emergencies at the project facilities. During such conditions, PGE may deviate from these stage change limits, but would attempt to minimize the frequency and duration of events when the stage change rate exceeds these limits. 3. Declines in stream stage at the USGS gage not to exceed 0.2 ft in any 1 hour period year-round, except during extraordinary circumstances. 4. Increases in stream stage at the gage not to exceed 0.2 ft in any one hour period except during extraordinary circumstances and during days associated with inflow events that result in average daily inflows to Timothy Lake exceeding 600 cfs.

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Lake Harriet at Crack-in-the-Ground

The average annual flow of Lower Oak Grove Fork is 484 cfs as measured at the USGS gage No. 14209000 located about 1.7 miles upstream of Lake Harriet dam. Flows in the lower Oak Grove Fork are partially influenced by flow releases from the Timothy Lake Dam. Average monthly flows are at this location are shown in Table 4.

Table 4. USGS Oak Grove Fork above Powerplant Intake (No. 14209000) average monthly flows based on a record from 1909 to 2011.

Month Average Monthly Flow (cfs) January 566 February 555 March 548 April 611 May 667 June 519 July 363 August 326 September 344 October 369 November 467 December 540

Flow releases from Harriet Dam and development include “baseflows” throughout the year, combined with higher flow releases during winter floods and spring runoff events as described below. Flow releases from Lake Harriet dam are made by new flow release facilities at the dam, designed to provide the required baseflows. Typically, winter flood and snowmelt runoff releases are made by a combination of the new flow release facility, by flows over the sharp-crested weir at the crest of Harriet Dam, and through a sand trap original designed to flush debris that passed through the Lake Harriet trashracks. Baseflow releases are summarized in Table 5.

Table 5. Current Lake Harriet Dam baseflow releases. Baseflow Release, cfs Date Wet Year Normal Year Dry Year

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April 1 to June 15 100 90 80 June 16 to August 31 100 90 80 Sept. 1 to Sept. 30 100 90 80 Oct. 1 to Oct. 15 100 100 100 Oct. 16 to Dec. 15 80 80 80 Dec. 16 to March 31 70 70 70 Definition of Wet, Normal, and Dry Water Years Forecasted April 1-September 30 Inflows Wet >182,000 ac-ft Normal <182,000 ac-ft and >123,000 ac-ft Dry <123,000 ac-ft

The proposed baseflow turbine would be located in a powerhouse at the terminus of the baseflow facility which consists of a tap at the downstream portal of the flow tunnel leading from Lake Harriet to Frog Lake, a 588-foot-long buried baseflow pipeline extending to Oak Grove Fork at a location near a site known as Crack-in-the-Ground. The turbine would be designed to accommodate flows up to 150 cfs, which is up to 50 cfs higher than the minimum baseflow requirements. The intent of the higher capacity is to use the turbine, in conjunction with the hinged sharp-crested weir or sand trap, to help control snowmelt runoff releases from Lake Harriet. The turbine would be able to step down releases in 10 cfs increments, as required by the license. A continuous flow of 5 cfs would be released from the upstream sand trap located approximately 380 ft downstream of Lake Harriet Dam. During a unit outage, flows would be discharged through the sand trap or over the hinged sharp-crested weir at Lake Harriet dam. North Fork dam

Large rainfall and rain-on-snow flood events dominate the Clackamas River's hydrology. The high flows in the mainstem of the Clackamas River downstream of the Oak Grove Fork are controlled by discharge from the Upper Clackamas River and Collawash River, with relatively minor flows from the Oak Grove Fork. North Fork dam impounds the Clackamas River at RM 29 to form North Fork Reservoir with a surface area of approximately 350 ac. The average annual flow of the Clackamas River is 1,974 cfs at the Three Lynx Creek USGS gage No. 14209500, located about 0.25 miles downstream of the Oak Grove Powerhouse and about 17.0 miles upstream of North Fork Reservoir. Flow releases from the North Fork Dam control the inflow to the Faraday Diversion Dam impoundment. Table 6 shows the average monthly flows of the Clackamas River at Three Lynx Creek.

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Table 6. USGS gage above Three Lynx Creek (No. 14209500) average monthly flows based on a record from 1910 to 2011.

Month Average Monthly Flow (cfs) January 2,920 February 2,720 March 2,490 April 2,650 May 2,660 June 1,790 July 944 August 748 September 763 October 997 November 2,170 December 2,880

At a normal maximum elevation (665 ft. PGE datum), the North Fork Reservoir has a gross storage capacity of approximately 18,630 ac-ft. The reservoir is normally maintained between 663 and 665 ft. except in the winter when the reservoir is drawn down as much as 5 ft. During extreme situations, however, the North Fork Reservoir may be drawn down to 640 ft. Faraday Diversion dam

The North Fork dam controls the hydrology at Faraday Diversion dam. The Faraday Diversion dam reservoir has a gross storage capacity of approximately 1,200 ac- ft. The Faraday Diversion dam reservoir surface elevation normally varies up to 5 ft. to re-regulate flows associated with peaking at the North Fork Powerhouse located about 1.6 miles upstream.

Flow releases from Faraday Diversion Dam include year-round baseflows, plus scheduled pulsed flows to assist upstream migrating fish. Baseflows are released from an attraction water supply pipe discharging into the energy dissipater at the entrance of the North Fork fish ladder or into the proposed turbine and subsequently into the diffusion pool. Pulsed flows are released through the drum gates at the Faraday Diversion dam (Table 7).

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Table 7. Faraday Diversion Dam flow releases and ramping rates.

Baseflow Releases

Baseflow release, Notes cfs Date Starting in the eighth year after license issuance, PGE may reduce 270 (subject to baseflows to 250 cfs, if PGE demonstrated, during the preceding state instream water year, that spillway entrainment of juvenile steelhead was reduced Year-round right) by at least 50% by the spillway exclusion net at spills up to 4,000 cfs.

A State instream water right requires the following flows below the Faraday Diversion Dam:

Date Release to Faraday Diversion Reach*

July 1 – Sept. 15 As flows above Faraday Diversion Dam increase above 5290 cfs, moving to 5270 cfs if the condition above in the table is met, the flow in the Faraday Diversion Reach increases until it reaches 400 cfs to acknowledge the senior status of the State’s instream water right. Additional flows above 5,420 cfs are routed through the Faraday Powerhouse.

Sept. 16 – June 30 As flows above Faraday Diversion Dam increase above 5290 cfs, moving to 5270 cfs if the condition above in the table is met, the flow in the Faraday Diversion Reach increases until it reaches 640 cfs to acknowledge the senior status of the State’s instream water right. Additional flows above 5660 cfs are routed through the Faraday Powerhouse.

* 5290/5270 cfs is the sum of PGE’s pre-1968 water rights at Faraday, which total 5,020 cfs, plus the baseflows of 270 cfs, potentially moving to 250 cfs. The obligation to bypass flows of 400 cfs or 640 cfs, depending on time of year, is triggered when flows exceed 5,020 cfs.

Pulsed Flow Releases

Date Pulse flow rate Pulse duration Pulse frequency Notes

April to Will vary, Will vary, approx Will vary, approx See Pulsed Flow Regime October approx 120 to 12 to 36 hours every 4 days to study plan in Fish Passage 480 cfs biweekly and Protection Plan.

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Water Quality Timothy Lake

PGE conducted a comprehensive assessment of water quality, involving in situ measurements (including measurement of intergravel dissolved oxygen [IGDO]), collection of water samples for laboratory analysis, and temperature and water quality modeling, in the Oak Grove Fork between Timothy Lake Dam and Lake Harriet (Doughty 2004a and 2004b, EES Consulting 2004, Battelle 2004) during relicensing. Water quality parameters evaluated included temperature, DO, pH, hardness, alkalinity, conductivity, nutrients, chlorophyll a, turbidity, total suspended solids, and total dissolved solids. Results of the assessment show that water quality in this reach complies with ODEQ's relevant surface water criteria throughout the year.

Due to the depth of the intake, the Upper Oak Grove Fork receives cool water (highest temperature measured was 8.12°C) from Timothy Lake throughout the year such that temperatures are well below ODEQ standards (EES 2004). Accretion flows from cold springs maintain these cool temperatures (≈8.5°C) throughout the Upper Oak Grove Fork (USFS 1996).

In 2005, PGE monitored IGDO in the river reach below Timothy Lake at times when the water quality model predicted that ambient DO would be less than the 11.0 mg/l criterion under the flow regime required by the license (PGE 2011). During 2005, median IGDO concentrations measured below Timothy Lake ranged from 8.1 mg/l to 10.3 mg/l (PGE 2011). Pursuant to its license PGE monitors IGDO under the flow regime identified in the license for the Oak Grove Fork between Timothy Lake Dam and Lake Harriet. The purpose of these measurements is to determine whether the 11.0 mg/l or 9.0 mg/l ambient DO criterion is to apply in this reach8. Follow-up studies in 2012 confirmed the assumption that DO values would increase under the higher flow releases implemented since license issuance. Measurements ranged from 9.72 to 11.08 mg/l between April 19 and June 1, 2012.

All other water quality parameters in the Upper Oak Grove Fork are at normal levels, with the pH of the system being slightly basic (EES 2004). Macroinvertebrate studies showed good abundance and moderate taxa richness with no major differences between the Timothy Lake tributaries and the reach immediately downstream from the Timothy Lake Dam (EES 2004).

8 If median IGDO concentrations exceed 8.0 mg/l, the ambient DO criterion is 9.0 mg/l.

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Crack-in-the-Ground

During the relicensing of the project, PGE completed a water quality assessment including both sampling and modeling of Lake Harriet and the reach of the Oak Grove Fork downstream of Lake Harriet Dam to the confluence with the Clackamas River (Doughty 2004a; Doughty 2004b; EES Consulting 2004; Battelle 2004). The following water quality variables were measured or sampled: temperature, DO, pH, hardness, alkalinity, conductivity, nutrients, chlorophyll a, turbidity, total suspended solids, and total dissolved solids. Study data were used to develop and calibrate a water quality model that investigated the environmental effects of the Project. Results of the assessment show that water quality in this reach complies with ODEQ's relevant surface water criteria throughout the year.

The short residence time of approximately 10 hours in Lake Harriet results in little warming of incoming water from the Upper Oak Grove Fork. Lake Harriet does not thermally stratify and DO levels comply with ODEQ standards (Doughty 2004a; Doughty 2004b). Lake Harriet is classified as mesotrophic based on phosphorus concentration, but oligotrophic for nitrogen and other water quality parameters. Diatoms dominate the planktonic community and the water remains clear throughout the year (Doughty 2004a; Doughty 2004b).

The Oak Grove Fork has good water quality immediately upstream of Lake Harriet as determined by macroinvertebrate taxa richness and biological indicators of water quality. Immediately downstream of Lake Harriet, the macroinvertebrate density and diversity is low. This is a result of a lack of flow, not water quality (EES 2004).

Under the terms of the previous license, the Oak Grove Fork flow was entirely diverted except during flood flows and the water quality downstream from Lake Harriet Dam was a function of accretion flow (i.e., groundwater and tributaries) which, because volume was low, was susceptible to warming. In 2005, PGE monitored IGDO in this reach at times when the CE-QUAL-W2 model predicted that ambient DO would be less than the 11.0 mg/l criterion under the flow regime now required by the license (PGE 2008). In 2005, the median IGDO concentrations were in the range from 7.7 mg/L to 9.6 mg/L. The addition of baseflows from Lake Harriet Dam to the Clackamas River is predicted to improve water quality with respect to temperature and DO downstream from Crack-in-the-Ground. This improvement in water quality would meet ODEQ water quality requirements for the presence of anadromous fish.

Pursuant to its license PGE monitors IGDO under the flow regime identified in the license for the Oak Grove Fork between Crack-in-the-Ground and the confluence with the Clackamas River. PGE began operating Lake Harriet pursuant to the license requirements on December 21, 2012. IGDO measurements are currently underway and would be used to determine whether the 11.0 mg/l or 9.0 mg/l ambient DO criterion is to apply in this reach.

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North Fork Dam return flow

PGE completed a water quality assessment including both sampling and water quality modeling for the North Fork Reservoir and the reach of the Clackamas River between North Fork Dam tailrace and the Faraday Diversion Dam (Doughty 2004a; Doughty 2004b; EES Consulting 2004; Battelle 2004) during the relicensing of the project. Water samples were collected and/or measurements were made for temperature, DO, pH, hardness, alkalinity, conductivity, nutrients, chlorophyll a, turbidity, total suspended solids, and total dissolved solids. Study data collected from the sampling regime were used to develop and calibrate a water quality model that investigated the environmental impacts of the existing Project and the proposed Project.

The water quality in this section of river meets the ODEQ standards for the parameters measured. Some concerns have been raised regarding both total dissolved gases (TDG) below the spillway and blue-green algae blooms in the North Fork Reservoir. PGE developed and is currently implementing monitoring plans for both blue- green algae and TDG under the requirements of its license.

Faraday Diversion Dam

PGE completed a water quality assessment for the Faraday Reservoir and the Faraday Bypass reach including both sampling and modeling (Doughty 2004a; Doughty 2004b; EES Consulting 2004; Battelle 2004). Water quality variables measured or sampled included temperature, DO, pH, hardness, alkalinity, conductivity, nutrients, chlorophyll a, turbidity, total suspended solids, and total dissolved solids. The study data were used to develop and calibrate a water quality model that investigated the environmental impacts of the existing Project and the proposed Project.

The Clackamas River around the Faraday Diversion Dam has similar water quality to that near the North Fork Dam due to the close proximity of the two facilities. Accordingly, like North Fork, the assessment showed that water quality in this reach complies with ODEQ’s surface water criteria throughout the year. Faraday Diversion Dam Reservoir does not thermally stratify during the summer months due to relatively short residence times.

3.3.2.2 Environmental Effects

The construction and operation of the proposed turbines would not alter water quantity or quality. PGE would continue to meet all license requirements identified to protect, mitigate, and enhance water resources affected by the operations of Timothy Lake Dam, Lake Harriet, North Fork Dam, and Faraday Diversion Dam.

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PGE would meet all license requirements associated with Lake Harriet and Crack- in-the-Ground developed to protect, mitigate, and enhance resources affected by Lake Harriet. Specifically, the proposed turbine installation and operation would not alter Lake Harriet baseflows, winter flood flow releases, or spring snowmelt runoff releases. Because PGE would construct the baseflow pipeline pursuant to license conditions, regardless of whether or not it installs the proposed turbine, there would be no increase in the construction footprint associated with the proposed action. The small powerhouse and turbine would be constructed instead of the energy dissipation structure at the end of the pipeline currently required by the license. Water quality between Lake Harriet Dam and Crack-in-the-Ground would be improved by the release of 5 cfs at the sand trap.

The proposed North Fork Return Flow turbine installation and operation would not affect fish passage return flows, TDG, and the potential for algal blooms. The proposed Faraday Diversion Dam turbine installation would not alter the fish ladder augmented attraction flow water supply (AWS) flows and temperature benefits.

Water Quantity

Construction Effects

Construction of the proposed turbines at Timothy Dam, Crack-in-the-Ground, North Fork return flow, and Faraday Diversion Dam would have no incremental water quantity effects. During installation, the existing penstock would be briefly shut off to connect it to the new turbines; however, PGE would maintain minimum flows using either the spillway or another alternate bypass.

Operational Effects

During turbine operation, PGE would continue to manage water level in Timothy Lake as prescribed in the Project license. Minimum flow turbine operation would comply with the flow, ramping rate, and other water quantity restrictions of the license. Therefore, operation of the proposed turbines would have no incremental water quantity effects. The operation of the proposed turbine at Crack-in-the-Ground would have no incremental effect to the quantity or timing of flows in the lower Oak Grove Fork. PGE would continue to manage Lake Harriet water levels as required by the Project license. The operation of the turbine in conjunction with the sharp-crested weir and sand trap would comply with the baseflow, winter flood release, and snowmelt release requirements.

The North fork return flow turbine’s operation would comply with the existing fish passage flow requirements. The flow to the proposed turbine originates as return water from the fish passage facilities and would not exceed 35 cfs. Even at the driest time of the year, this discharge constitutes less than 5 percent of the average monthly flow in the reach between North Fork Dam and the Faraday Diversion Dam.

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The operation of the proposed Faraday Diversion Dam minimum flow turbine would comply with the terms of the existing license. The 225 cfs flow to the proposed turbine would originate from the AWS. Therefore, proposed turbine operation would have no incremental water quantity effects. If the proposed turbine were to go offline, the AWS pipeline would still be operational to release the 225 cfs flow which, when combined with the 45 cfs fish ladder flow, constitutes the required 270 cfs for the Faraday Diversion reach.

Water Quality

Construction Effects

Construction of the proposed turbines would have minimal to no temporary, incremental water quality effects. During installation, PGE proposes to adhere to relevant construction BMPs to control sediment, minimize ground disturbance, protect water quality, and diminish any detrimental effects on aquatic biota. PGE would base these BMPs on the applicable guidelines and protocols outlined in the National Marine Fisheries Service (NMFS) Biological Opinion for the Project (NMFS 2010).

Operational Effects

To maintain water quality in compliance with the Project license Appendix A, Article 2 (c) PGE would ensure the generation units are designed to provide sufficient aeration to comply with ambient DO criteria. In addition, PGE proposes to modify the WQMMP to include protocols for monitoring to confirm that the turbines to be installed at Timothy Lake would not adversely affect DO and TDG concentrations in the Oak Grove Fork.

To ensure that IGDO TDG concentrations downstream of the proposed Timothy Lake turbines, and Crack-in-the-Ground comply with ODEQ criteria, PGE would monitor ambient DO during the first two years following turbine installation, PGE would also monitor TDG at Faraday Lake, Faraday Diversion Dam turbine, and River Mills. DO monitoring would be conducted from May through September downstream of Timothy Lake and at Crack-in-the-Ground, and PGE would monitor TDG one day per month (over a 4-hour period each monitoring day) from July through November, over the range of flows released through Timothy Lake Dam and the releases from Lake Harriet. PGE would conduct ambient DO and TDG monitoring according to the methods described in the proposed revisions to the WQMMP. Should post-construction monitoring indicate that DO standards are not being met, PGE would consult with ODEQ to develop a plan to comply with the applicable standards. The Howell-Bunger valve would remain in place to pass flows in excess of 300 cfs, its use could be incorporated into a DO compliance plan to ensure compliance with the applicable DO standards at all times.

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Similarly, the operation of the proposed return flow turbine in the North Fork Reservoir discharging into the tailrace would have no incremental water quality effects in the Clackamas River. The proposed turbine would be designed to meet all relevant water quality standards outlined by the ODEQ. The return water from the fish passage facilities is of high quality and the weir at the turbine discharge would provide sufficient aeration. The return flows from the fish passage system are small compared to spill over the dam and discharge from the powerhouse such that proposed turbine operation would have no effect on TDG levels. PGE’s existing TDG monitoring program would enable PGE to confirm that the North Fork return flow turbine is not adversely affecting TDG levels.

The proposed turbine operation at the Faraday Diversion Dam would have no incremental water quality effects on the Clackamas River. The turbine would be designed to meet all relevant ODEQ water quality standards. The water exiting from the AWS is of high quality and the temperature of the water is similar to or colder than the flow in the North Fork fish ladder, depending on the time of year. As noted above, the license requires baseflows in the Faraday Diversion reach to be 270 cfs, which would include 25 cfs of cold water that would be exchanged for warmer water at the North Fork fish ladder adult fish trap. The larger volume of slightly cooler water is expected to improve water temperatures in the diversion reach (FERC 2006, PGE 2008). Based on an evaluation of the overall temperature regime associated with the flows required by the license, temperatures in this reach should continue to comply with ODEQ criteria with the proposed minimum flow turbine in operation. PGE’s proposed TDG monitoring program would enable PGE to confirm that the proposed minimum flow turbines are not adversely affecting TDG levels.

3.3.3 Aquatic Resources

3.3.3.1 Affected Environment

Several resident fish species occur in Timothy Lake and in the Oak Grove Fork between Timothy Lake and Lake Harriet. These species include cutthroat trout, rainbow trout, brook trout, and kokanee in Timothy Lake and cutthroat trout and brook trout in the Oak Grove Fork. Of these species, cutthroat trout and rainbow trout are indigenous to the basin, whereas brook trout and kokanee are introduced species.

During relicensing, PGE evaluated Project effects on aquatic habitat and fluvial geomorphology in the Oak Grove Fork between Timothy Lake Dam and Lake Harriet as part of a synthesis of geomorphic, vegetation, and instream flow studies (synthesis report). Prior to relicensing, operation of Timothy Lake Dam resulted in short-term flow fluctuations, reduced baseflows, and elevated water temperature (FERC 2006). Between Timothy Lake Dam and Lake Harriet, the effects identified were primarily flow-based.

The synthesis report provided the following characterizations of factors influencing aquatic habitat conditions in the reach:

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 Coarse sediment supply into Timothy Meadows (now inundated by Timothy Lake) was likely very low due to low sediment yield, low relief, low drainage density, and the snowmelt-dominated hydrologic characteristic of the High Cascades terrain.  Historic loading and routing of large wood past Timothy Meadows was likely very limited due to the snowmelt-dominated hydrography, the low gradient of the channel meandering through Timothy Meadows, and a limited source of large wood.  USFS management of the Oak Grove Fork corridor downstream of Timothy Lake Dam has preserved excellent woody riparian stand density and overall health of the riparian zone.  Low storage capacity, moderate seasonal storage fluctuation, and lack of flow diversion from Timothy Lake have minimized changes in flood peak magnitude and frequency to downstream reaches.  Springs immediately downstream of Timothy Lake Dam, which contribute significant seasonal baseflows, greatly buffer changes to baseflows due to Project operation.

The synthesis report concluded that, with the exception the first 1,000 ft downstream of Timothy Lake Dam, geomorphic impacts to fisheries caused by Timothy Lake Dam were minimal.

PGE’s license implementation has addressed License Appendix A, Article 8 (h)(3) and Appendix B, Article 16(f) requiring channel modifications to enhance adult and juvenile cutthroat trout habitat in the Oak Grove Fork between Timothy Lake Dam and Hammer Springs. The Commission approved PGE’s plans to implement these modifications on July 12, 2011. PGE completed the work in August 2011.

In addition to the synthesis report, PGE undertook several studies during the relicensing between Timothy Lake Dam and Lake Harriet to assess habitat-flow relationships. Studies included habitat mapping, hydrologic and operational analysis, comparisons of channel cross-sectional geometry under different flows, and supplemental cross-sectional measurements at six target flows that included a cell-based habitat analysis. A Physical Habitat Simulation (PHABSIM) study conducted as part of licensing activities for the Stone Creek Project provided additional information relative to habitat-flow relationships in the 5.4-mi segment of stream from the Stone Creek

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Diversion dam to the Stone Creek Powerhouse.9 This information informed the development of PM&E measures incorporated into the Project license.

During relicensing, entrainment of cutthroat trout into the Timothy Lake Dam intake was also identified as a potential impact of the Project. Screw-trapping conducted in 2001-2002 showed that low rates of cutthroat trout entrainment were occurring, and that entrainment was most likely in the fall (Shibahara and Filbert 2004). Entrained fish experienced high rates of injury and mortality as they passed through an existing Howell- Bunger valve.10

The license identifies specific fish and aquatic PM&E measures and operational changes to mitigate for Project impacts to the aquatic resources between Timothy Lake Dam and Lake Harriet. These measures include:

 The provision of seasonal minimum and maximum instream flows ranging from 30 to 300 cfs (plus inflow) (see Table 3).  Operational limits on large-scale flow events (see Table 3).  Establishment and monitoring of ramping rates (see Table 3).  Release of water to the Timothy Lake tailrace in a manner that meets DO criteria (i.e., release of water through the existing Howell-Bunger valve).  Enhancement of aquatic habitat between Timothy Lake and Hammer Springs, and associated post-habitat enhancement assessments.  To mitigate for entrainment of cutthroat trout at the Timothy Lake intake, the top bar rack section of the existing Timothy Lake intake structure would be replaced with a solid panel to a depth of 29 ft below the water surface at elevation 3,190 ft and that the panels below this level would be replaced with new racks with narrower spacing, i.e., 3/8-inch bar racks with 3/4-inch clear spacing.11

9 The Stone Creek Hydroelectric Project No. 5264 is located on the Oak Grove Fork of the Clackamas River in between Timothy Lake and Lake Harriet. It is owned and operated by the Eugene Water and Electric Board.

10 Howell-Bunger valves (also known as fixed cone valves) are designed to dissipate energy during reservoir discharge. They typically consist of rounded pipe with an adjustable gate and a cone at the discharge end. The design allows high pressure water from the base of a dam to be released without causing erosion to the surrounding environment. 11 The Commission approved PGE’s bar rack replacement plan on March 16, 2012. Portland General Electric Company, 138 FERC ¶ 62,250 (2012).

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 Studies to evaluate the effectiveness of the new bar rack structures.  Studies to evaluate migratory behavior of cutthroat trout to determine if Timothy Lake Dam is a barrier to upstream migration of this native species.

The Clackamas River between the North Fork tailrace and the Faraday Diversion Dam supports a small number of cutthroat trout, rainbow trout, steelhead, coho salmon, and spring Chinook salmon (FERC 2006). Coho, Chinook, and steelhead are currently listed as threatened under the ESA (FERC 2006).

Fish and aquatic PM&E measures required by the License for the Clackamas River downstream of North Fork Dam include the implementation of the following measures:

 TDG monitoring in the North Fork Dam tailrace at flows up to 21,000 cfs.  Design and deployment of a 1,000-cfs floating surface collector in the forebay to improve downstream passage for smolts.  Limitation of reservoir drawdowns.  The continued operation of the existing downstream migrant bypass.  Installation of a spillway exclusion net.  Installation of strobe lights in the North Fork Dam forebay.12  The decommissioning of an existing adult fish trap facility on the North Fork fish ladder and replacement with a new fish trap and sorting facility.

The Clackamas River from the Faraday Diversion Dam downstream to the Faraday Powerhouse supports cutthroat trout, rainbow trout, steelhead, coho salmon, and spring Chinook salmon, among other species. Coho, Chinook, and steelhead are currently listed as threatened under the Endangered Species Act (ESA) (FERC 2006)

The Project license requires measures to enhance physical habitat, allowing for the unimpeded passage of adult fish through the Faraday bypass reach, and provide flows and water temperatures conducive to upstream passage of adult fish. Adult spring Chinook do not exhibit a strong response to pulsed flows evaluated during the relicensing studies, there was some indication that fish at the Faraday Powerhouse were more likely to move

12 PGE has filed an amendment application to remove this requirement from the Project license.

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upstream during a pulsed flow event than during stable baseflows. Based on NMFS, USFWS, and Oregon DFW recommendations PGE instituted the following pulsed-flow protocol:13

 Maintenance of 270 cfs in the Faraday Diversion bypassed reach.  Release of periodic pulsed-flows ranging from 120 to 480 cfs to improve geomorphic function and enhance upstream fish movements.  Evaluate delay, injury, or mortality of salmonids migrating upstream through the Project facilities.  Provide safe and timely passage of Pacific lamprey.  License Appendix E, Article 13(d)(i) requires PGE to maintain a spill protocol for the Faraday Diversion Dam during any periods of unscreened spill at North Fork Dam. The spill protocol remains in effect at Faraday Diversion Dam until it is demonstrated that overall Project smolt survival would not be diminished by discontinuing the spill protocol. However, the spill protocol could be discontinued if the Project smolt survival standard has been, and would continue to be, met without the spill protocol. 3.3.3.2 Environmental Effects

There would be no significant changes or effects on fish and aquatic resources related to installation and operation of the proposed Timothy Lake Dam turbines.

Construction Effects

There is a potential for minor, short-term incremental effects due to construction activities associated with installation of the proposed minimum flow turbines at Timothy Lake Dam, Crack-in-the-Ground, North Fork return flow, and the Faraday Diversion Dam. Effects consist of increased erosion, turbidity, and subsequent sediment deposition. PGE proposes to implement BMPs to control sediment, minimize ground disturbance, protect water quality, and minimize other potential detrimental effects on salmonids and other aquatic biota. PGE would conduct all construction activities associated with the proposed turbine installations in coordination with the USFS, Oregon DFW, and USFWS.

13 The pulsed flow study is being repeated. The results of the continued study may have implications for the measures listed below.

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Operational Effects

Timothy Lake

Operation of the proposed turbines would not change the flow regime required by the Project license for the Oak Grove Fork downstream of Timothy Lake and is not expected to result in any incremental fisheries and aquatic resources effects in Timothy Lake or in the Oak Grove Fork between Timothy Lake and Lake Harriet. The flow regime as licensed would continue when the proposed turbines are in operation. The baseflow regime established by the new license would continue to benefit aquatic biota, including cutthroat trout and aquatic macroinvertebrates, by providing suitable pool depth, riffles and adequate wetted area and hydraulic roughness along channel margins. Ramping rates required by the license would continue to benefit aquatic biota by minimizing rapid, dramatic operations-related stage changes in Oak Grove Fork between Timothy Lake and Lake Harriet and minimizing the potential for stranding or trapping of juvenile cutthroat trout and aquatic macroinvertebrates in the reach. Habitat enhancement measures required by the license to be implemented between Timothy Lake Dam and Lake Harriet would continue to benefit all life-stages of cutthroat trout throughout the year.

Operation of the proposed turbines would have no effect on the performance of the new panel and bar rack at the intake; therefore, an equivalent reduction in cutthroat trout entrainment is expected with or without the turbines in place. There would be no incremental effect to fish entrainment injury and mortality associated with operating the proposed turbines. Flow from the turbines would discharge below the water's surface in the Timothy Lake Dam tailrace. The draft tubes would be designed to have a discharge velocity around 3 to 4 ft/s. Because there are no large, migratory fish in this reach, discharge velocities would be sufficient to prevent resident fish from entering the draft tubes.

Crack-in-the-Ground

Operation of the turbine would have no effect on PGE’s ability to provide baseflows, winter flood flows, and snowmelt runoff flows to the lower Oak Grove Fork downstream of Crack-in-the-Ground. Habitat availability in side channels, in combination with the provision of the existing baseflow regime, would continue to provide more and higher quality habitat for 1+ year-class coho salmon. Proposed turbine operation would have no effect on planned and completed mainstem habitat enhancement measures (e.g., gravel augmentation and large wood management).

Transport of large wood from Lake Harriet to the lower Oak Grove Fork would be unaffected by the presence or operation of the proposed turbine. However, in response to concerns expressed by USFS that the large wood collected at Lake Harriet could be used more effectively elsewhere in the Mount Hood National Forest, PGE proposes to revise 44 20140320-3029 FERC PDF (Unofficial) 03/20/2014

Section IX of the Fish Passage and Protection Plan (Exhibit D to the Relicensing Settlement Agreement). PGE proposes to remove all large woody debris captured in Lake Harriet and stockpile it for use: (1) in the lower Oak Grove Fork below Lake Harriet at locations identified by the USFS; or (2) in habitat restoration projects identified by the USFS in the Mount Hood National Forest in a manner consistent with Section IX of the Fish Passage and Protection Plan (Exhibit D to the Relicensing Settlement Agreement). This proposal would modify Appendix B, Article 19(b) of the new license, which currently requires PGE to place all of this large woody debris downstream of Lake Harriet Dam.

PGE proposes to release a minimum flow of approximately 5 cfs through the sand trap located approximately 380 ft downstream of Lake Harriet Dam to address concerns that a small but constant minimum flow could enhance habitat between Lake Harriet Dam and Crack-in-the-Ground. Pursuant to the Commission’s October 4, 2011 order approving the temporary use of the sand trap to release the baseflows required by the new license, PGE has been releasing 100 cfs from the sand trap since December 21, 2012. The 5 cfs flow released at the sand trap would be subtracted from the flow otherwise required to be released, pursuant to Appendix B, Article 6, below Lake Harriet Dam at Crack-in-the-Ground; but the total baseflow at Crack-in-the-Ground would be consistent with the requirements of Appendix B, Article 6.

PGE proposes to implement three related measures at Lake Harriet to correct inconsistencies between the Fish Passage and Protection Plan, Exhibit D to the Relicensing Settlement Agreement and the license.

 The powerhouse at Crack-in-the-Ground would be designed to provide for the maximum possible exclusion of viable fish from the powerhouse discharge.  Section V.C of Fish Passage and Protection Plan would be deleted so that it is clear that there is no requirement to install new bar racks at the intake to the Frog Lake flow line.  The requirement in Appendix B, Article 15(b)(ii) to conduct a three-year monitoring study to determine whether non-native fish are passing through the minimum flow system into the Oak Grove Fork, and to modify facilities at Lake Harriet to more effectively exclude the downstream movement of non-native fish would be deleted. Rather as recommended by NMFS, PGE proposes to evaluate the source of non-native fish in the area below the Barrier Falls on the Oak Grove Fork if evidence is found of significant predation from non-native fish on anadromous fish in that reach. If it is found that the source of predators is the discharge at Crack-in-the-Ground, PGE would develop plans to reduce the discharge of these predators after consultation with the Fish Committee. If PGE and the fish committee determine the plan is necessary, PGE would file it with the

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Commission after consultation with the Fish Committee and with the approval of the FWS, Oregon DFW and NMFS. Lastly PGE proposes to establish a Clackamas Resident Fish Mitigation Fund (the “Resident Fish Mitigation Fund”), which would provide $250,000 funding to habitat mitigation and enhancements (“Resource Projects”) intended to benefit resident fish in the Clackamas River Basin upstream of North Fork Dam. The Resident Fish Mitigation Fund would be maintained and administered by PGE under its own expense under the direction of the USFS and Oregon DFW, who would select Resource Projects to be funded by the Resident Fish Mitigation Fund.

Although operation of the proposed turbine would not change the flow regime required by the Project license for the Oak Grove Fork downstream of Lake Harriet Dam, it would change the way in which flow is released. The minimum flow from the turbine would discharge below the water's surface through a high-density polyethylene (HDPE) pipe set into a slot in the rocks, rather than above the water's surface through the flow dissipater required by the existing license. Because there are no large migratory fish in this reach (because of natural barrier falls located downstream), discharge velocities would be sufficient to prevent fish from entering the discharge pipe. The flow release facility would be designed to create significant turbulence and shear in the flow path to curtail the downstream movement of non-native fish through the pipeline and into the lower Oak Grove Fork. Water from the turbine would be accelerated from the intake to the turbine runner. As a result, velocities directly below the runner would range from 25 to 35 ft/s, but would slow to 6 to 8 ft/s where the flow discharges below the surface of the Oak Grove Fork. This design would provide aeration and energy dissipation while precluding fish from entering the draft tube. The proposed turbine would be as effective as the proposed energy dissipater or new screens at Lake Harriet at curtailing the downstream passage of non-native fish via the flow line from Lake Harriet to the lower Oak Grove Fork.

Operation of the proposed turbine would also have no effect on the implementation of biological monitoring in the lower Oak Grove Fork designed to evaluate dewatering of steelhead redds, outmigrating juvenile salmonids numbers, and use of the lower Oak Grove Fork by spring Chinook, as required by the license. The proposed turbine would be designed to meet all relevant water quality standards, including the provision of sufficient aeration of outflows to allow compliance with ODEQ’s dissolved oxygen criteria for the Oak Grove Fork downstream of Crack-in-the Ground.

PGE does not provide any specific measures to be implemented under the Clackamas Resident Fish Mitigation Fund. Without specific measures, we cannot evaluate the fund’s environmental effects or the fund’s nexus to the project. We make our final recommendation regarding the Clackamas Resident Fish Mitigation Fund in section 4.1 Comprehensive Development and Recommended Alternative.

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North Dam Return Flow

Return flow turbine operation would not affect instream flows in the reach of the Clackamas River between the North Fork Dam and the Faraday Diversion Dam. Flow passed through the turbine for generation are the flows for the normal operation of North Fork fish passage facilities and consist of approximately 10 cfs from the adult fish trap in the North Fork fish ladder and 15 to 25 cfs from the downstream fish passage facilities in the North Fork Dam forebay. Water from the two sources would be combined at a location immediately up- gradient of the turbine and would be released at the current location.

The 10 cfs flow from the new adult fishway fish trap would be derived from the replacement of water in the fish ladder with cooler water withdrawn at depth from the North Fork Dam forebay. The cooler water could improve conditions for adult fish in and downstream of the fish ladder during their upstream migration. The 10 cfs return flow would be screened before it leaves the adult trap on its way to the new turbine; therefore, no fish would be passed from the fish trap to the return flow turbine.

Flow from the downstream passage facilities is available as the result of the new North Fork floating surface collector and the existing North Fork Dam downstream bypass facility. All flow routed to the proposed return flow turbine from these two facilities would be produced as the result of dewatering associated with operation of the tertiary screen structure facilities and therefore contain no fish (i.e., fish would have been separated from the downstream passage facilities prior to diversion for generation).

There would be no incremental effect on upstream fish passage as the result of operating the proposed North Fork return flow turbine. Because upstream-migrating anadromous salmonids and Pacific lamprey enter the North Fork fish ladder and bypass the reach where water from the turbine would be discharged, there would be no false attraction of adult anadromous fish to the turbine outflow, just as there would be no false attraction if the water were simply discharged into this reach without the turbine as currently required. Similarly, there would be no incremental effect on downstream fish passage from operation of the North Fork return flow turbine.

Faraday Diversion Dam

Operation of the proposed Faraday Diversion Dam minimum flow turbine would have no effect on the pulsed-flow regime required by the license, because pulse flows are released from the Faraday Diversion Dam spillway. Pulsed flows would continue to stimulate upstream migration of adult anadromous salmonids, minimize holding time and false attraction of adult Chinook in the Faraday Powerhouse tailrace, and potentially reduce migration time through the diversion reach.

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Operation of a minimum flow turbine at the Faraday Diversion Dam would not affect PGE's ability to maintain a minimum flow of 270 cfs in the Faraday diversion reach. The turbine would not alter conditions in the North Fork fish ladder or at the fish ladder entrance; therefore, upstream passage of salmonids and lamprey would be safe and effective with the turbine in place and operating. The existing minimum flows and ladder entrance conditions that meet NMFS criteria would minimize any effects related to delay of upstream migrating salmonids. Turbine installation would not affect the timing or scope of the studies developed by PGE pursuant to the license to assess delay, injury, and mortality to salmonids or lamprey migrating upstream through the Project area.

Under existing conditions, there are few fish in the AWS intake area in the Faraday Diversion Dam forebay. There would be even fewer fish when the proposed turbine would be operating due to the 1,000-cfs floating surface collector in the North Fork Dam forebay, the spillway net, and spill protocols moving fish through the reach. Therefore, installation of the proposed turbine would have no effect on salmonids or lamprey migrating through the Project area, nor would it affect planned fish passage evaluations required by the license. As such, there would be no incremental effects to fish passage and protection in the Faraday Diversion Dam forebay related to operating the proposed turbine.

3.3.4 Wetland, Wildlife, and Botanical Resources

3.3.4.1 Affected Environment

Timothy Lake

Timothy Lake and its surrounding emergent wetlands and the two small man- made islands in the northeastern portion of the lake provide nesting habitat for several species of waterfowl, including goldeneyes, mallards, ring-neck ducks, and wood ducks. Timothy Lake supports one or more nesting pairs of osprey and provides stopover habitat for a wide variety of migratory waterbirds. Bald eagles occasionally forage in Timothy Lake, particularly in the North Arm area where there is an active nest on the shoreline. The North Arm area is potentially the best bald eagle foraging and breeding habitat at the Project, partly because of the seasonal abundance of waterfowl, a preferred food resource for this species, and partly due to the lake's fish resources (FERC 2006).

The drainages adjacent to and along the Oak Grove pipeline and pothole areas in the Oak Grove Meadows provide still water breeding habitat for northwestern salamander, rough-skinned newt, tree frog, and red-legged frog. These meadows also serve as calving grounds and summer habitat for elk from March through July. The vegetation diversity at the meadows provides high quality forage and protective cover close to water (FERC 2006).

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Timothy Lake provides habitat for a unique assemblage of wildlife. Dispersed and developed recreation influences wildlife usage at Timothy Lake, particularly along the south and west shores. The North Arm of Timothy Lake, located more than 2 mi from the dam and proposed turbine site, is unique among lands within the Project boundary in that it provides a diversity of high quality nesting, breeding, foraging, migratory, and loafing habitats for a wide variety of terrestrial wildlife species found at the Project, including invertebrates, amphibians, reptiles, mammals, and birds. Six species of amphibians breed in the emergent wetlands and still-water pools at the North Arm, including the long-toed salamander, northwestern salamander, rough-skinned newt, Cascades frog, treefrog, and the red-legged frog, a federal species of concern. The North Arm area of Timothy Lake, with its emergent wetlands and two small man-made islands, provides nesting habitat for several species of waterfowl, including goldeneyes, mallards, ring-neck ducks, and wood ducks. Several mammal species including river otter and beaver breed and overwinter at Timothy Lake.

Twelve species of bat potentially occur near the lake, and natural bat roosts and reproduction sites (i.e., standing trees with voids between the bark and trunk) likely exist in the mature and old-growth conifer forests in the area. Field surveys in 2002 documented bat use in four structures associated with the Timothy Lake Lodge (located approximately 800 ft from the proposed turbine site) (FERC 2006).

A variety of migratory bird species are likely to nest in habitats surrounding Timothy Lake, and the lake provides stopover habitat for a wide variety of migratory waterbirds. The lake shoreline also provides nesting habitat for at least one pair of osprey. A bald eagle nest is located along the shoreline of the Timothy Lake North Arm (see Section 3.6, TES). No raptor nests or waterfowl nesting habitat are known to occur in the immediate vicinity of Timothy Lake Dam.

Several amphibian species (northwestern salamander, rough-skinned newt, and Pacific treefrog) were found in side channel habitat of the upper Oak Grove Fork during pond breeding amphibian surveys conducted in 2001. Also, electrofishing surveys conducted in 2000 in the upper Oak Grove Fork found larval Pacific giant salamanders. Documented species locations were in stream and side-channel habitat in the upper Oak Grove Fork downstream of the turbine site. There is no amphibian habitat at the turbine site itself.”

The proposed turbine site is located at the outflow area at the toe of Timothy Lake Dam. The dam provides a visual and distance buffer from wildlife habitat associated with the lake. The site consists of previously disturbed, non-forested habitat associated with Project facilities. Therefore, wildlife habitat quality is low in the immediate proximity of the Project site. USFS management indicator species for nearby forested habitats include pileated woodpecker, American marten, and deer and elk.

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The only survey-and-manage animal species with potential to occur in the immediate area are terrestrial mollusks. However, because the proposed project footprint would be located completely within a non-forested area of previously disturbed, low quality habitat with minimal woody debris and ground litter, the project would not significantly impact habitat for survey-and-manage mollusk species.

Upland conifer forest is the dominant general vegetation type in the Timothy Lake area, followed by riparian cover types associated with the Timothy Lake shoreline and the Oak Grove Fork. The planned turbine site is located at the toe of the Timothy Lake Dam, several hundred feet from the lake shoreline and out of sight of lake shore habitats. The site is located directly adjacent to current dam outflow facilities within an approximately 3-ac area of previously disturbed and non-forested ground.

Surveys for threatened, endangered, and sensitive (TES) plant species and vascular survey-and-manage plant species were conducted during Project relicensing surveys (FERC 2006), and known locations of survey-and-manage fungi and lichen were also documented. The study area included the proposed Timothy Lake Dam turbine site and downstream habitat along the Oak Grove Fork. Two sensitive plant species were found in habitats along the Oak Grove Fork between Timothy Lake and Lake Harriet. Cold water corydalis is found distributed throughout streamside habitat along the Oak Grove Fork from Stone Creek to Lake Harriet, and PGE is monitoring the population with annual surveys, as required by the in the Terrestrial Resources Management Plan. The lichen species Nephroma occultum (a USFS sensitive species) occurs at three sites approximately 0.5 mi southwest of the Timothy Lake Dam.

No TES plant species or survey-and-manage vascular plant species were found at or close by the Timothy Lake Dam small turbine site. The project site is located on non- forested, previously disturbed habitat and is unlikely to contain TES or survey-and- manage botanical species.

Crack in-the-Ground Site

Wetland habitats, other than those at the North Arm of Timothy Lake, are relatively rare at the Project. The Oak Grove Meadows and Little Crater Meadows provide valuable emergent wetland habitats, particularly for songbirds. These mid- elevation meadow habitats provide important stopover and breeding habitat for migratory and resident songbirds.

Emergent wetland habitat dominates both sides of the Oak Grove pipeline through Oak Grove Meadows, covering roughly 14 acres. This wetland is composed primarily of reed canary grass, although several small, excavated ponds support other submerged aquatic and emergent wetland plant species. Forested wetland habitat, consisting primarily of red alder with an understory of skunk cabbage, occurs in two locations along the pipeline. Other small wetlands associated with mountain seeps or low-lying pothole 50 20140320-3029 FERC PDF (Unofficial) 03/20/2014

areas are interspersed throughout the Project area. These areas include a 4-acres alder- dominated forested wetland located immediately upstream of Lake Harriet.

Terrestrial wildlife habitats and communities in the Project area are typical of those found in undeveloped landscapes at similar elevations along the west slope of the Cascades. Upland forests, adjacent meadows, and riparian areas provide quality foraging habitat for elk and black-tailed deer throughout the year. Upland forests proximate to the Oak Grove development also provide suitable habitat for a variety of smaller mammals including ermine, bobcat, coyote, snowshoe hare, Townsend’s chipmunk, western gray squirrel, and several other species of rodents. Field surveys in 2002 documented bat use in valve shacks along the Oak Grove pipeline (FERC 2006

A variety of migratory bird species are likely to nest in the habitats surrounding Lake Harriet and along the Oak Grove Fork, and Lake Harriet provides stopover habitat for a wide variety of migratory waterbirds. Osprey and bald eagles may forage and nest along the Lake Harriet shoreline, although there are currently no known bald eagle nests in the immediate vicinity. The Crack-in-the-Ground site is located approximately 1,600 feet downstream of the Lake Harriet Dam and is separated from lake-related wildlife habitat by distance and forest buffer. No raptor nests or waterfowl nesting habitat are known to occur in the immediate vicinity of the Crack-in-the-Ground site.

The Oak Grove Fork provides potential breeding habitat and post-breeding summer habitat for amphibians. Nearby portions of the Oak Grove Fork were surveyed for amphibians during relicensing surveys (EDAW 2003). Identified species included red-legged frogs, Pacific giant salamanders, tailed frogs, and rough-skinned newts. Species found during terrestrial surveys in the area included Pacific treefrog, Oregon slender salamander, rough-skinned newt, and Dunn’s salamander. USFS management indicator species for nearby forested habitats include pileated woodpecker, American marten, and deer and elk.

The only survey-and-manage animal species with the potential to occur in the proposed turbine project’s impact area are terrestrial mollusks. Because the project footprint is located on an area of previously disturbed, low quality habitat (mostly gravel roadway and an old road/trail area through second-growth forest) within a surrounding matrix of better quality older forested habitat, it is unlikely that the project would significantly impact habitat for survey-and-manage mollusk species. PGE conducted pre- disturbance surveys for terrestrial survey-and-manage mollusks at the site in fall 2010 and spring 2011. Only common mollusk species were found.

The proposed Crack-in-the-Ground turbine site is located on an open area on a rocky streamside bench within adjoining mixed conifer forest on a southwest-facing slope north of the Oak Grove Fork. The site is on previously disturbed ground at the base of a current access road where a bridge formerly crossed the stream to a mine site.

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Surveys for threatened, endangered, and sensitive (TES) plant species and vascular survey-and-manage plant species were conducted during Project relicensing surveys (Dwerlkotte 2003), and known locations of survey-and-manage fungi and lichen were also documented. The study area included the Crack-in-the-Ground turbine site and associated habitat along the Oak Grove Fork. No TES plant species or survey-and- manage vascular plant species were found at or nearby the Crack-in-the-Ground site. There are also no known locations of survey-and-manage fungi or lichen at the site.

The project footprint would be located on an area of previously disturbed, low quality habitat (mostly gravel roadway and an old road/trail area through second-growth forest) within a surrounding matrix of better quality older forested habitat. The project site does not contain important habitat for TES or survey-and-manage botanical species, and none have been documented at the site.

North Fork Return Flow Turbine

Roads and dispersed and developed recreation sites along much of the Clackamas from North Fork Dam to the Faraday Diversion Dam have fragmented and disturbed riparian habitats. Extensive wetlands are not found along the Clackamas River in the vicinity of the North Fork Dam or the Faraday Diversion Dam. Shorelines mostly consist of mid-successional upland conifer forest and contain little riparian and wetland habitat (FERC 2006).

Surveys conducted during relicensing of the project found no rare amphibians along the reach of the Clackamas River between North Fork Dam and the Faraday Diversion Dam, and no TES wildlife or plant species are known to occur in the vicinity.

Faraday Diversion Dam

The proposed minimum flow turbine area is located within an existing, disturbed area dedicated to hydroelectric generation. There are no wetlands, significant wildlife or botanical resources within the proposed project area.

3.3.4.2 Environmental Effects

Construction effects During turbine installation at Timothy Lake, Crack-in-the-Ground, North Fork return flow turbine, and the Faraday Diversion dam PGE would adhere to construction related BMPs to control sediment, minimize ground disturbance, and protect water quality to minimize any potential detrimental effects on wildlife, wildlife habitat, or botanical resources. Guidelines in the Project’s Vegetation Management Plan and Terrestrial Resources Management Plan, as appropriate, would be followed regarding

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sensitive species seasonal restrictions, revegetation, and prevention and control of invasive non-native plant species. The new underground distribution line for the Crack-in-the-Turbine would follow the route or the minimum flow discharge pipeline authorized in the license. Therefore, there would be no incremental effects as a result of its construction. The construction of the new Timothy Lake, North Fork return flow underground transmission line and new above ground 12.5kV distribution line at Faraday Diversion Dam would follow BMPs to control sediment, minimize ground disturbance, and protect water quality to minimize any potential detrimental effects on wildlife, wildlife habitat, or botanical resources. Additionally, PGE’s proposal to use underground transmission lines for the proposed minimum flow units at Timothy Lake and North Fork return flow would prevent any incremental adverse effects on birds. PGE would ensure that Faraday Diversion Dam upgrade meets Avian Power Line Interaction Committee (APLIC) standards for raptor protection. Impacts to migratory birds would be avoided by scheduling construction outside of the nesting season and minimizing the disturbance footprint and construction duration to the extent possible. The project would not impact the viability of any management indicator species. Available habitat for American martens and pileated woodpeckers, such as large potential nest/den trees or foraging habitat would not be affected. The Timothy Lake turbine would be located in a non-forested, previously- disturbed area below Timothy Lake Dam and would have no impact on snags and downed wood. The project footprint is limited and associated with existing Project facilities and would not significantly impact habitat availability or connectivity for deer and elk. Seasonal restrictions to avoid disturbance to wintering deer and elk, as outlined in the Project’s Terrestrial Resources Management Plan and Vegetation Management Plan, would be observed during construction. The Crack-in-the Ground minimum flow turbine would be located on a previously-disturbed access road route and would have minimal impact on snags and downed wood. Any downed wood within the construction disturbance area may be retained on site by moving it to site margins and redistributing it in revegetated areas as appropriate following project completion. It is unlikely that removal of snags would be necessary. However, any snags or danger trees removed would be tracked and mitigated for consistent with guidelines in the Project’s Terrestrial Resources Management Plan. Operational Effects Minimum flows required for the Oak Grove Fork between Timothy Lake Dam and Lake Harriet are expected to benefit aquatic amphibian species through a more consistent flow regime and increased instream, stream margin, and side-channel habitat availability. Minimum flows would also provide suitable habitat for cold water corydalis.

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Operation of the proposed turbines at Timothy Lake and Crack-in-the-Ground would not affect the flow regime required by the license. Therefore, compared to current operations, the turbines would have no effect on wildlife, wildlife habitats, and botanical populations along the Oak Grove Fork, including Cascades frogs using portions of the Lower Oak Grove Fork as migratory habitat. Minimum flows required by the license would continue to benefit amphibian species using portions of the Lower Oak Grove Fork by providing a more consistent flow regime and increased instream habitat availability. In addition there would be no change in the flow regime from the North Dam return flow turbine and the Faraday Diversion Dam turbine. As a result, there would be no incremental effect on wildlife or botanical resources related to their operation. Given the highly disturbed location and existing hydroelectric infrastructure at Timothy Dam and the North Dam return flow turbine, turbine operation would have no incremental effects on wetlands, wildlife, or botanical resources. Because operation of the turbine would not change conditions proximate to the Faraday Diversion Dam there would be no incremental effects on amphibians. Because the turbine site is in close proximity to existing Project infrastructure and no species of concern occur nearby, turbine operation would have no incremental effects on wildlife or plants. Other than a likely small increase in the number of vehicles along existing access roads (occasional maintenance access by PGE pickup trucks), turbine operation at Timothy Dam, Crack-in-the-Ground, North Fork return flow, and Faraday Diversion Dam should result in little change from current operation. Considering local wildlife is already adapted to frequent recreational traffic on nearby roads, turbine operation should result in minimal incremental disturbance to wildlife or plant populations. Given the highly disturbed location and existing hydroelectric infrastructure at the proposed North Dam return flow turbine, turbine operation would have no incremental effects on wetlands, wildlife, or botanical resources. 3.3.5 Threatened, Endangered, and Sensitive Species

3.3.5.1 Affected Environment

Timothy Lake

One federally-threatened wildlife species, the northern spotted owl, likely occurs in the Timothy Lake vicinity. One sensitive species, the bald eagle, nests at Timothy Lake. Other species on the USFS Region 6 Sensitive Species List, such as Cope’s giant salamander or sensitive bat species (Townsend’s big-eared bat or fringed myotis) could use nearby habitats but have not been documented. Other species that were listed on the TES species list for the overall Clackamas Project vicinity, such as the peregrine falcon and harlequin duck, are not likely to frequent the immediate vicinity of the Timothy Lake Dam turbine site due to lack of nearby breeding habitat or typical foraging habitat.

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Northern spotted owls may use the coniferous forests around Timothy Lake for foraging, roosting, and potentially, nesting. Areas immediately west of Timothy Lake, including forests adjacent to the Timothy Lake Dam area, are included in USFWS’s 2012 revised critical habitat for the northern spotted owl. The USFWS 15-year review habitat mapping for the northern spotted owl also maps nearby forest as suitable habitat. Potentially suitable nesting, roosting, and foraging habitat is defined to include 60- to 80- percent canopy cover with multi-layer, multispecies canopy, greater than 30-inch diameter trees, high instance of large trees with deformities, large snags, large accumulations of fallen trees and woody debris, and sufficient open space under the canopy to fly. Areas of such habitat are located approximately 300 feet to the southwest and northwest of the proposed project site, with the site access road passing directly adjacent to mapped suitable habitat. The closest historic northern spotted owl location is approximately 1 mi to the west of the turbine site. No known currently active nest sites are located nearby, but recent surveys have not been done. As noted above, the proposed turbine site is located within an approximately 3-ac area of non-forested, previously disturbed habitat that is maintained as part of hydroelectric project facilities, so the turbine project site itself does not include northern spotted owl habitat in any form and is not capable of developing into owl habitat for the life of the Project.

Bald eagles are known to use the Timothy Lake area for foraging and nesting activities. Although no longer federally-listed under the ESA, bald eagles and their nests are protected by the Bald and Golden Eagle Protection Act. A bald eagle nest was first discovered on the Timothy Lake North Arm shoreline in 2004, and PGE monitoring documented that the nest was occupied by a bald eagle pair during the 2010-2012 breeding seasons. The nest site is more than 2 mi from the Timothy Lake Dam turbine site.

Cope’s giant salamander and other amphibian species could occur in habitat along the Oak Grove Fork downstream of the turbine site. However, no sensitive amphibian species have been documented in nearby portions of the Oak Grove Fork. Likewise, sensitive bat species could forage in the area or use large trees or other habitat in the vicinity for roosting, but bats are not likely to use the project site itself other than for aerial foraging over the Oak Grove Fork and nearby open areas. As stated in the botanical section, no TES or survey-and-manage botanical species are known to occur at the project site.

Crack-in-the-ground

One federally-threatened wildlife species, the northern spotted owl, occurs in mature forest habitats along the Oak Grove Fork in the vicinity of Crack-in-the-Ground. One sensitive species, the bald eagle, is known to forage at Lake Harriet, but no current bald eagle nest sites are known to exist in the immediate vicinity. Townsend’s big eared bats, a federal species of concern, use a hibernaculum along the Oak Grove Fork on the far side of the stream from the proposed project. Other species on the USFS Region 6

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Sensitive Species List, such as Cope’s giant salamander or sensitive bat species (fringed myotis) could use nearby habitats but their occurrence has not been documented. Additional sensitive species that were listed on the TES species list for the overall Clackamas Project vicinity, such as the peregrine falcon and harlequin duck, are not likely to frequent the immediate vicinity of the Crack-in-the-Ground turbine site due to a lack of nearby breeding habitat or typical foraging habitat.

Northern spotted owls may use the coniferous forests around Lake Harriet and the Oak Grove Fork for foraging, roosting, and potentially nesting. The USFWS’s 15-year review habitat mapping for the northern spotted owl maps nearby forest as suitable habitat. The proposed project site is also within a larger area of the 2012 Revised Critical Habitat for the northern spotted owl. However, the habitat within and adjoining the project footprint does not meet the criteria for suitable nesting/roosting/foraging habitat. Such habitat is defined to include 60- to 80-percent canopy cover with multi-layer, multispecies canopy, greater than 30-inch diameter trees, high instance of large trees with deformities, large snags, large accumulations of fallen trees and woody debris, and sufficient open space under the canopy to fly (USFWS 2012). Forest directly adjacent to the project site contains second growth forest with high canopy cover and a range of tree sizes, with some larger trees, mostly in the 11-inch to 24-inch diameter range. This forest type should be classified as dispersal habitat, which is defined as containing at least 11- inch diameter trees and greater than 40-percent canopy cover (USFWS 2012). The closest historic northern spotted owl location is approximately 300 ft to the north of the access road and pipeline route leading to the turbine site and approximately 600 ft from the turbine site itself. No known currently active nest sites are located nearby.

Sensitive species surveys, including amphibian surveys (Tressler 2003) and bat surveys (in PGE facility structures along the nearby Oak Grove Pipeline [Concannon 2003]), were conducted along the Oak Grove Fork and its tributaries and along the Oak Grove Pipeline during relicensing studies. No TES species were found in the vicinity of the Crack-in-the-Ground turbine site. Portions of the Oak Grove Fork were also surveyed for Cope’s giant salamanders in August 2011. No Cope’s giant salamanders were found, but the more common Pacific giant salamander was present (pers. comm., Andy Bidwell, PGE). As stated in the botanical section, no TES or survey-and-manage botanical species are known to occur at the project site.

North Fork Return Flow

PGE conducted amphibian surveys in the location of the proposed North Fork return flow turbine during 2001 and 2002. No rare amphibians were observed along the reach of the Clackamas River between North Fork Dam and the Faraday Diversion Dam, and no TES wildlife or plant species are known to occur on site or nearby (FERC 2006).

Faraday Diversion Dam

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Field surveys in 2001 and 2002 documented breeding red-legged frogs, a species of concern, in a drainage ditch near the Faraday Diversion Dam. No other TES wildlife or plant species occur on site or nearby. 3.3.5.2 Environmental Effects

No threatened, endangered, or sensitive wildlife or plant species are known to occur near or at the Timothy Dam site. The only effects on threatened, endangered, or sensitive species associated with the installation and operation of the proposed turbines at Timothy Lake Dam would be potential short-term noise disturbance to any northern spotted owls that are using nearby habitat. No spotted owl habitat would be modified and any disturbance effects would be avoided or minimized as described below. PGE would observe, as appropriate, guidelines in the Biological Assessment of Activities with Potential to Disturb Northern Spotted Owls FY 2010 - 2013 (or current version at the time of construction). No disturbance to bald eagle nesting and foraging at Timothy Lake is expected. Known threatened, endangered, or sensitive species occurring in the immediate vicinity of the Crack-in-the-Ground site include the Townsend’s big-eared bat and historic nest sites and critical habitat for the northern spotted owl. There are no other known threatened, endangered, or sensitive species proximate to the proposed turbine location. As described below, the Townsend’s big-eared bat hibernaculum in the area is not likely to be impacted by the turbine project. Therefore, other than potential impacts to the northern spotted owl and its critical habitat described below, there would be no incremental effects on threatened, endangered, or sensitive species related to installation and operation of the proposed baseflow at turbine at Crack-in-the-Ground. No rare amphibians have been observed along the reach of the Clackamas River between North Fork Dam and the Faraday Diversion Dam, and no threatened, endangered, or sensitive species wildlife or plant species are known to occur on site or nearby (FERC 2006). Breeding red-legged frogs, a species of concern, have been documented in a drainage ditch near the Faraday Diversion Dam, however no other TES wildlife or plant species occur on the Faraday Diversion Dam site or nearby. Construction Effects The new Timothy Lake minimum flow turbines would be constructed on non- forested, previously disturbed hydroelectric facility land below the Timothy Lake Dam. The project would not involve modification of northern spotted owl habitat. Typical project construction disturbance would involve heavy equipment use and general construction noise (hammering, power tools, etc.), but is not expected to include high impact activity such pile driving or explosives. An existing maintenance road would be used for site access.

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Construction of the proposed turbine at Crack-in-the-ground may cause short-term disturbance of northern spotted owls that may be using habitat in the immediate vicinity. Specifically, high impact construction involving loud noise or high levels of disturbance would be avoided within 65 yards of suitable habitat during the critical nesting period of March 1 - July 15. Project effects would be limited almost exclusively to existing access road or to open areas within second-growth forest located on fill areas from construction of the Oak Grove Pipeline. Potentially six to eight trees (two of which are approximately 11-inch to 18-inch diameter, with the rest small trees) would need to be removed along the upper pipeline corridor. A few larger (up to 24-inch diameter) trees also may need to be removed at the turbine site because their exposed roots at the base of the slope overlap with a planned retaining wall footprint. It is possible that additional danger/hazard trees may need to be removed from the slope above the project. However, all the tree removals described above would likely not exceed 12-15 trees. Also, PGE would replace any removed danger trees by creating snags on the Mount Hood National Forest as required by the Project’s Vegetation Management Plan. Because the project location is within mapped critical habitat, the tree removal described above could be considered modification of critical habitat for northern spotted owls. However, considering the large amount of critical habitat in the immediate area, this small modification would have an insignificant effect on critical habitat at the landscape scale or stand level (i.e., 500 ac circle). Removal of a small number of trees from existing forest edges would also not significantly impact the current function of the site as dispersal habitat for the northern spotted owl. To minimize chances of impacting spotted owls that may be using the area, PGE would observe, as appropriate, guidelines in the Biological Assessment of Activities with Potential to Disturb Northern Spotted Owls FY 2010-2013 (or current version at the time of construction), and northern spotted owl disturbance avoidance guidelines in the Project’s Terrestrial Resources Management Plan and Vegetation Management Plan The Townsend’s big-eared bat hibernaculum is located in an abandoned mine on the lower slope to the west of the Oak Grove Fork. It is on the far side of the river and more than 200-ft from the turbine site, with vegetation and topography buffers between the two areas. Considering the distance, existing noise levels from rushing river water, vegetation buffer, and the short duration of construction, the bats should not be disturbed by the project. A site visit with the USFS wildlife biologist in April 2010 revealed that there should be sufficient distance and topography buffers to prevent impacts to the bats using the hibernaculum. The Timothy Lake bald eagle nest is located more than 2 mi from the project site, and portions of the lake far from the turbine site contain extensive foraging habitat. No disturbance to bald eagle nesting and foraging at Timothy Lake is expected.

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No TES species are known to occur at the North Dam flow return site. Accordingly, there are no expected effects on TES species related to installation and operation of the proposed return flow turbine. PGE would manage any ground disturbance associated with the construction of the North Fork return flow turbine according to the guidelines for projects on PGE land, as established in the Vegetation Management Plan developed by PGE and Parties to the Settlement Agreement. Vegetation Management Plan protocol governs roles and responsibilities; coordination; approvals, compliance, and permitting; reporting; planning to minimize disturbance to sensitive species; invasive non-native plant species prevention and control; and revegetation. During installation of the proposed return flow turbine at North Fork Dam Tailrace, PGE would adhere to construction related BMPs (Appendix A) to minimize ground disturbance, protect water quality, and minimize other potential detrimental effects on habitat. There are no known Threatened, endangered, or sensitive species proximate to the proposed minimum flow turbine location. PGE would employ BMPs to ensure that construction activities associated with installation of the turbine at the Faraday Diversion Dam would result in no effects on amphibians in the area, including the red-legged frog. Accordingly, there would be no significant effects related to installation and operation of the proposed minimum flow turbine at the Faraday Diversion Dam. Operation Effects Operation of proposed turbines at the Timothy Lake Dam would result in no change to the flow regime required by the Project license for this section of the Oak Grove Fork. The flow regime, which was developed to benefit aquatic resources by enhancing habitat and managing ramping rates to avoid adverse effects on biota, would continue to mitigate the effects of Project operation in this reach when the turbines are in operation. No impacts to any sensitive species, such as amphibians or bats that may be using aquatic or riparian habitats downstream of the project are expected. Operation of a minimum flow turbine at Crack-in-the-Ground would result in no change to the flow regime required by the Project license for this section of the Oak Grove Fork, downstream of Lake Harriet Dam. Minimum flows required by the license would continue to provide wetted habitat for aquatic species using portions of the Lower Oak Grove Fork. The increased minimum flows should provide more wetted habitat, thus providing a potential benefit to amphibians and other species. No negative impacts to any sensitive species such as amphibians or bats that may be using aquatic or riparian habitats downstream of the project are expected. Turbine operation would not significantly increase background noise levels or other disturbances when compared to current Project operation and maintenance. Current site maintenance for dam safety involves keeping the area free of woody vegetation. Some increase in operational/maintenance traffic (periodic pick-up truck traffic) may

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occur along the existing access roads, but animals using the area are already accustomed to periodic recreational and project traffic on nearby roads. 3.3.6 Recreation and Land Use

3.3.6.1 Affected Environment

Timothy Lake Timothy Lake receives the highest concentration of recreational use within the Mount Hood National Forest. Primary recreational activities include camping, boating, fishing, hiking, wildlife observation, and winter sports. Predominantly natural-appearing environments with moderate evidence of human presence characterize “roaded natural areas”. The USFS manages Timothy Lake as a roaded natural area on the Recreation Opportunity Spectrum (ROS). The definition includes the expectation of moderate to high contact with other users, but with opportunities for isolation from anthropogenic influences. There are more than 30 mi of trails near Timothy Lake, including the Timothy Lake Trail, which extends along the south and west sides of Timothy Lake and connects with the Pacific Crest Trail that extends along the east side of Timothy Lake, to complete an 13-mi-long loop trail around Timothy Lake. These trails are used for hiking, mountain biking, and equestrian use, although biking is prohibited on the Pacific Crest Trail (FERC 2006). Crack-in-the-Ground The Lower Oak Grove Fork extends for approximately 5.4 mi from Lake Harriet to its confluence with the Clackamas River. Little recreational use occurs in this reach because of difficult access. The upper portion of the Lower Oak Grove Fork is a high- gradient reach that includes at least two Class V rapids, the Crack-in-the-Ground waterfalls and the 25-ft-high barrier falls. The lower portion of the reach downstream of the barrier falls has a gentler gradient and is classified as Class III. Lake Harriet is a popular fishing destination, despite its relatively small surface area (approximately 20 ac). Oregon DFW stocks the lake with rainbow trout several times a year. A boat ramp allows motorized boating, although the lake is most commonly used for car top boating (e.g., canoes, kayaks, tubes, and inflatable boats). “Car fishing” (fishing from, or immediately adjacent to, the angler's vehicle) is popular along Forest Road 4630, which is attributable to the steep topography, limited shoreline access, and user preference to be near their vehicle for security and convenience (FERC 2006). The minimum flow requirement in the License for the reach downstream of Lake Harriet Dam may increase the fishing related recreational activities in this location.

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Trail development is limited in this area because of the steep terrain. Other nearby sites outside the Project area attract most of the trail use (such as along the Clackamas River). Rainbow and Ripplebrook campgrounds are two small USFS campgrounds located along the Oak Grove Fork near its confluence with the Clackamas River (FERC 2006). North Fork Return Flow The reach of the Clackamas River between North Fork Dam and the Faraday Diversion Dam is closed to recreational access. Faraday Diversion Dam The reach downstream of the Faraday Diversion Dam is not open to vehicular access, but it is currently used for walk-in fishing and wildlife viewing. There is also anecdotal information indicating that it is paddled at least sporadically during spill events. One guidebook rates this reach as Class II-III whitewater at relatively low flows, but interviews with paddlers after a recent flow test suggest that the reach is Class III-IV at flows in the range of 600 to 1,200 cfs, and probably has Class V rapids at very high flows. 3.3.6.2 Environmental Effects

There would be no significant effects on recreational resources related to installation and operation of the proposed turbines at Timothy Lake Dam, Crack-in-the- Ground, and Faraday Diversion Dam. The site of the North Fork Dam return flow turbine is closed to recreation access; therefore there would be no significant effects on recreational resources related to installation and operation of the proposed North Fork Dam return flow turbines. Construction Effects During turbine construction of the Timothy Lake Dam turbines, a 0.25-ac lay- down area would be located approximately 800 feet southeast of the proposed powerhouse. Due to safety concerns, PGE would prohibit foot traffic on the access road during construction and would limit access thereafter, consistent with the Commission’s regulations governing public access to Project facilities. During construction of the proposed Crack-in-the-Ground turbine, there may be short-term effects on recreation at the immediate site. The lay-down area adjacent to the Oak Grove Fork downstream of Lake Harriet Dam would be approximately 2,000 sq. ft., spread out over three areas, and is expected to be in use from July to October. PGE would curtail recreation access to this portion of the Oak Grove Fork during the construction period. However, construction activities would result in no incremental effects on recreation activities adjacent to this section of the Oak Grove Fork, because

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there would be no expansion of the lay-down area or construction period beyond that which would occur to install the energy dissipater at this location. PGE would conduct all construction activities associated with the Faraday Diversion Dam minimum flow turbine on the east side of the Faraday Diversion Reach, proximate to existing PGE facilities. Because the immediate area of the turbine is not available for recreational access, there would be no effects on recreation associated with the turbine construction. Operational Effects Operation of the proposed turbines at the Timothy Lake Dam outlet would result in no change to Timothy Lake elevations and the flow regime downstream of Timothy Lake. Additionally, the proposed powerhouse is within the Timothy Lake Dam operation area, which is generally not available or appropriate for recreation; therefore, the proposed action would not affect recreational uses. Operation of the proposed turbine at Crack-in-the-Ground would result in no change to the flow regime and lake levels required by the Project license for this section of the Oak Grove Fork and Lake Harriet, resulting in no impacts to recreational activities. Additionally, the addition of minimum flow below Lake Harriet may create additional fishing opportunities in the Oak Grove Fork. Operation of the Faraday Diversion Dam turbine would result in no change to the flow regime required by the Project license for this section of the Clackamas River. Therefore, minimum flow turbine operation would have no effect on any paddling activities that might occur during spill events. 3.3.7 Aesthetic Resources

3.3.7.1 Affected Environment

Timothy Lake is located in a broad open valley, surrounded by forested ridges. Forest cover extends to practically the normal maximum water level (i.e., surcharge level), and creates a natural appearing condition. Other than the area near the dam, the overall appearance of the lake is natural. There are five primary, developed campgrounds along the south shore of Timothy Lake, but they are well concealed within the forest and are relatively unobtrusive from the water or from Forest Road 57. The 10 mi of the Upper Oak Grove Fork from Timothy Lake Dam to Lake Harriet flow through a relatively narrow river valley with small intermittent rock outcrops. Mature conifers dominate the steep terrain. The gravel road that hugs the steep ridge side offers many scenic views of the landscape, but few views of the stream. PGE's operation of Timothy Lake modifies the natural flow regime in this reach, but a minimum flow is

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provided. The Stone Creek Project (FERC No. 5264) is located in this reach and diverts water from the stream for several miles. Lake Harriet is in the Oak Grove Fork Scenic Viewshed. The USFS Visual Quality Objectives for this viewshed are Retention (foreground) and Partial Retention (middle ground and background). Lake Harriet is located in a narrow, well-defined forested canyon. It is a relatively small lake, but because of its winding shape, only portions of the lake can be seen from any one location. The south side of the lake is forested, has very steep topography, and is difficult to access. Forest Road 4630 closely follows a portion of the north side of the lake. People regularly park cars along the road, and both are clearly visible from the lake because of the lack of riparian vegetation on this shore. The dam is relatively unobtrusive, not readily visible, difficult to access from Forest Road 4630, and appears to have weathered well into the narrow rocky cleft of the canyon (FERC 2006). The Crack-in-the-Ground site is behind a locked gate on the road, and public access is discouraged and difficult. In addition, the site is not visible from any publicly accessible viewpoints. The North Fork Development is set in a relatively wide, deep, forested canyon. Highway 224 parallels the Development closely on its north side for its entire length and the dam is clearly visible from the highway. The powerhouse is integral to the dam, and therefore does not have any additional aesthetic effects. While much of the land around the reservoir appears natural, timber harvest and highway cuts have clearly modified the visible landscape (FERC 2006). The Faraday Development is set in a narrow forested canyon. The Faraday Diversion Dam is only accessible from a closed road from Highway 224 that is used primarily by hikers and bicyclists, or via a trail from Faraday Lake. It is not visible from Highway 224, so relatively few people see this facility. Faraday Lake is set relatively high above the river and constructed with an embankment against a forested hillside. The penstocks, powerhouse, and a substation are located at the toe of the embankment and are not easily visible from the recreation areas above or from Highway 224. The Faraday bypass reach flows through a winding scenic gorge and is visible from the bridge (limited to pedestrians and service vehicles) across the Clackamas River that links the parking area with the recreation areas at Faraday Lake. The aesthetic resource evaluation study identified six Key Observation Points (KOPs) at the Faraday Development, including views of the dam, penstocks, powerhouse, transmission lines, substation, bypass reach, and fish ladder. 3.3.7.2 Environmental Effects

Given the small size of the proposed Timothy Lake powerhouse, its construction immediately adjacent to a large existing Project facility, and observation of protocol identified in the Aesthetic Resources Protection Strategy, there would be no incremental

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aesthetic effects associated with construction or operation of the proposed turbines at the Timothy Lake Dam.

Given the already heavily developed nature of the reach of the Clackamas River between the North Fork and Faraday Diversion dams, coupled with the existing structures at the North Fork Dam and Faraday Diversion Dam, there would be no incremental aesthetic effect associated with the construction or operation of the North Fork return flow turbine or the Faraday Diversion Dam turbine.

Given the already heavily developed nature of the reach of the Clackamas River in the vicinity of the Faraday Diversion Dam, coupled with the existing dam and hydroelectric structures, there would be no incremental aesthetic effect associated with the construction or operation of the Faraday Diversion Dam minimum flow turbine. Turbine operation would result in no change to the flow regime required by the Project license for this section of the Clackamas River and no change to KOPs.

Construction Effects

PGE would implement its Aesthetic Resources Protection Strategy (Strategy) which is included in its Recreation Resources Management Plan. The Strategy stipulates that PGE "ensure that human activities associated with the Project do not unnecessarily detract from the National Forest Service (NFS) land's natural scenic qualities." The Strategy states that the design of any newly constructed facility on NFS lands would take into account the appropriate use of color, materials, design features, and plant materials to protect visual resources in the Project area. PGE would not implement any aesthetic treatments that could present any environmental or human risk, and all treatments would be compatible with Commission requirements and Project operations objectives. PGE would complete construction of the powerhouse and appurtenant facilities in accordance with the Aesthetic Resources Protection Strategy included in the Recreation Resources Management Plan and in consultation with the USFS. PGE would work with a landscape architect and the USFS to identify feasible measures to address the USFS Visual Quality Objectives as well as potentially applicable requirements of the Aesthetic Resources Protection Strategy of the Project's Recreation Resources Management Plan.

During installation of the proposed turbine at Crack-in-the-Ground, PGE would adhere to construction related BMPs. PGE would conduct an analysis of the level of contrast of new facilities in relation to the river corridor, the aesthetic effect of any necessary access upgrades, and the implications of any necessary Project lighting.

Operation Effects

The small powerhouse proposed for installation at the toe of the existing Timothy Lake Dam would not appreciably change the visual character of existing facilities (i.e., the existing dam and release structure/Howell-Bunger valve). PGE would complete

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construction of the powerhouse and appurtenant facilities in accordance with the Aesthetic Resources Protection Strategy and in consultation with the USFS. PGE expects to include an analysis of the level of contrast of new facilities in relation to the river corridor, the aesthetic effect of any necessary access upgrades (including transmission upgrades), and the implications of any necessary Project lighting. Crack-in-the-Ground baseflow turbine operation would result in no incremental aesthetic effects beyond those associated with the flow-release pipeline and energy dissipater required by the existing license.

3.3.8 Cultural Resources

3.3.8.1 Affected Environment

Pursuant to section 106 of the NHPA, the Commission must take into account whether any historic property could be affected by a proposed undertaking within a project’s APE. “Undertakings” include activities that require a federal permit, license, or approval (36 CFR 800.16[y]). The APE is determined in consultation with the SHPO and is defined as “the geographic area or areas within which an undertaking may directly or indirectly cause alterations in the character or use of historic properties, if any such properties exist” (36 CFR 800.16[3]).

The Timothy Dam, Lake Harriet Dam, North Fork Dam and the related features of these three dams were determined eligible for listing in the National Register of Historic Places (NRHP) in 2003. The Faraday Diversion Dam, built in 1966, was determined to be a non-historic element of the Clackamas River Project in 2003.

Due to the determinations of eligibility, PGE conducted surface pedestrian surveys for approximately 1,675 acres identified as the area of potential effect (APE) for relicensing, as previously stated in Section 3.1. In addition, twenty-seven archeological sites and 12 isolated finds were investigated. Nineteen of the sites are prehistoric, 5 are historic, and 3 sites have both historic and prehistoric components. However, none of the identified archaeological sites occur within the APE for the proposed minimum flow generation facilities and it is not likely that intact buried cultural deposits exist at these sites.

3.3.8.2 Environmental Effects

Our Analysis The licensee is not proposing any alteration to the dams. Proposed ground disturbance from construction, beginning in 2014, includes: (1) a new powerhouse 16-ft wide by 25-ft long located downstream of Timothy Lake Dam plus the 0.25 acre laydown area; (2) a 20-ft wide by 20-ft long powerhouse built on a concrete foundation placed on bedrock downstream of Lake Harriet Dam, plus a 70-ft long retaining wall along an

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adjacent hillside, plus three laydown areas totaling 2,000 square feet; (3) and a 20-ft wide by 100-ft deep underground vault next to an adjacent retaining wall below the Faraday Dam to house the new Faraday development minimum flow unit, plus construction of poles for the new overhead transmission line. Some of the proposed construction would occur in previously disturbed areas. The licensee proposes to implement best management practices during construction to control sediment and run-off and to minimize effects from ground disturbance. While two of the four turbine locations would be located near project features that are eligible to the NRHP, all plans and designs for the four new small turbines for Timothy Lake, Lake Harriet and North Fork comply with the requirements of PGE’s Historic Properties Management Plan (HPMP) and the approved Manual for Built Resources, using compatible industrial materials and designs. In addition, all plans and siting options would be reviewed by a qualified historic preservation specialist. At Timothy Lake Dam no archaeological or other cultural materials were found during investigations. At Crack –in-the-Ground, no archaeological or other cultural materials were observed at the turbine powerhouse location or along the pipeline route. At North Fork no archaeological sites, features, or artifacts were found during surveys and all of the project elements are (or very near) steep slopes unlikely to contain archaeological material. At Faraday Diversion Dam, no archaeological materials were observed during inspections and none are expected, given the steep slopes and the extensive disturbance and modifications from previous dam construction, floods, and other activities. In summary, any ground disturbance related to the small turbine projects would occur in areas that contain no found archaeological materials. The proposed locations are either already disturbed by previous construction and other activities, or are on steep slopes or bedrock settings that are unlikely to contain buried archaeological deposits. Therefore, the proposed undertakings would have no effect from construction or operation on archaeological resources. Details of the results from the archeological surveys are found in the 2005 Archaeological Investigations for the Portland General Electric Clackamas River Hydroelectric Project.\

3.4 NO-ACTION ALTERNATIVE

Under the no-action alternative, the minimum flow turbines would not be constructed. There would be no changes to the natural, biological, recreational or cultural resources of the area and the project would generate the same amount of electrical power as it does now.

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4.0 CONCLUSIONS AND RECOMMENDATIONS

4.1 COMPREHENSIVE DEVELOPMENT AND STAFF RECOMMENDED MEASURES

Sections 4(e) and 10(a) of the FPA require the Commission to give equal consideration to all uses of the waterway on which a project is located. When we review a hydropower project, we consider the water quality, fish and wildlife, recreation, cultural, and other non-developmental values of the involved waterway equally with its electric energy and other developmental values. In deciding whether, and under what conditions a hydropower project should be licensed, the Commission must determine that the project would be best adapted to a comprehensive plan for improving or developing the waterway. This section contains the basis for, and a summary of, our recommendations for conditions to be included in any amendment to the license for the Clackamas River Project.

Based on our independent review and evaluation of the environmental and economic effects of the proposed action, the proposed action with additional staff modifications, and the no-action alternative, we recommend the proposed action with additional staff-recommended measures as the preferred alternative. We recommend this alternative because: (1) issuing the amendment to the project license would allow the licensee to continue operating the project as a beneficial and dependable source of electric energy; (2) increasing the installed capacity of the project by 3.89 MW would eliminate the need for an equivalent amount of fossil-fuel-produced energy and capacity, which would help conserve nonrenewable resources and decrease atmospheric pollution; and (3) the proposed and staff-recommended environmental measures would protect project resources.

We recommend including the following environmental measures proposed by PGE in any amended license issued by the Commission for the Clackamas River Project. These recommendations are consistent with the recommendations of the Oregon DFW, FWS, and NMFS and the 4(e) conditions of the Forest Service.

 The BMP’s listed in section 2.2.3

 Ensuring that Faraday Diversion Dam distribution line upgrade meets Avian Power Line Interaction Committee (APLIC) standards for raptor protection.

 Avoiding high impact construction involving loud noise or high levels of disturbance within 65 yards of suitable northern spotted owl habitat during the critical nesting period of March 1 - July 15.

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 Implement a revised Water Quality Management and Monitoring Plan and supplemented on December 12, 2013, to monitor downstream of Timothy Lake and Crack-in-the Ground ambient dissolved oxygen (DO) concentrations May through September and monitor total dissolved gas (TDG) one day per month over a four-hour period in July through November downstream of Timothy Lake, Crack-in-the Ground, Faraday Lake, Faraday Diversion Dam, and River Mills.

 Amending Appendix B, Article 19(b) of the Clackamas License Order to require the removal of all woody debris captured in Lake Harriet and stockpile it for use (i) in the lower Oak Grove Fork below Lake Harriet at locations identified by the USFS; or (ii) in habitat restoration projects identified by the USFS in the Mt. Hood National Forest in accordance with Section IX of the Fish Passage and Protection Plan, Exhibit D to the Relicensing Settlement Agreement.

 Amending Appendix B, Article 7 (b)(ii) of the Clackamas License Order to require a 5-cfs minimum flow from the sand trap which would be included in the overall total minimum flow required by Appendix B, Article 7 (b)(ii).

 Designing the powerhouse at Crack-in-the-Ground to provide for the maximum possible exclusion of viable fish from the powerhouse discharge.

 Modifying Appendix B, Article 15 (b) in the Clackamas License Order to read as follows: (i) Within five years of completion of the turbine at Crack- in-the-Ground, if NMFS provides evidence of significant predation from non-native fish on anadromous fish in the area below the Barrier Falls on the Oak Grove Fork, the licensee shall, after consultation with the Fish Committee and with the approval of the Fish Agencies, file with the Commission, for approval, either a plan for a three-year monitoring study to determine whether non-native fish are passing through the minimum flow system into the Oak Grove Fork, or a report explaining why a study is not required; (ii) Within six months after completing the monitoring study described in the preceding paragraph, the licensee shall, after consultation with the Fish Committee and with the approval of the Fish Agencies, file a report summarizing the results of the study. If the report determines that unacceptably high numbers of non-native fish are escaping through the minimum flow releases, the licensee shall, in consultation with the Fish Committee and with the approval of USFS file with the Commission, for approval, a plan to reduce the discharge of those non-native fish.

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In addition to the measures described above, we recommend amending the license to delete from the Fish Passage and Protection Plan, Section V.C of Exhibit D to the Clackamas Relicensing Settlement Agreement, the requirement to install new bar racks at the intake to the Frog Lake flow line.

Establish a $250,000 Resident Fish Mitigation Fund, which would provide funding to habitat mitigation and enhancements intended to benefit resident fish in the Clackamas River Basin upstream of North Fork Dam within three months of a Commission order approving the installation of a turbine at Crack-in-the-Ground becoming final. The fund would be maintained and administered by PGE at its own expense and would be under the direction of USFS and Oregon DFW, who would select Resource Projects to be funded.

With respect to the 250,000 Resident Fish Mitigation Fund for general habitat enhancement, PGE does not provide any specific measures to be implemented under the Clackamas Resident Fish Mitigation Fund. Without specific measures, we cannot evaluate the fund’s environmental effects or the fund’s nexus to the project. Further, the Commission in its 2006 Policy Statement on Hydropower Licensing Settlements14 noted that it has no jurisdiction over any party to a hydroelectric licensing proceeding other than the licensee, and that, it would look to the licensee to undertake particular measures that it requires to fulfill a project purpose. We find that a license requirement for PGE to simply provide $250,000 to Oregon DFW and the Forest Service would not ensure that the performance of any specific measures considering that the Commission does not have the necessary jurisdiction over Oregon DFW and the Forest Service. However, this condition is included in the mandatory 4(e) conditions submitted by the Forest Service; it is required to be included in any amendment of license issued by the Commission.

4.2 UNAVOIDABLE ADVERSE EFFECTS

Unavoidable adverse effects from the proposed action at the four dams would be limited to those directly related to construction of the new facilities. Ground disturbance for construction and creation of the 0.25-acre laydown area at Timothy Lake dam and 2,000-square-foot laydown area at Lake Harriet would disturb soils and lead to possible erosion. Construction of the proposed turbines would have minimal to no temporary, incremental water quality effects. During installation, PGE proposes to adhere to relevant construction BMPs to control sediment, minimize ground disturbance, protect water quality, and diminish any detrimental effects on aquatic biota.

14 116 FERC ¶ 61,270

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Access to the construction area at Timothy Lake Dam would be limited. PGE would prohibit foot traffic on the access road during construction and would limit access thereafter, consistent with the Commission’s regulations governing public access to Project facilities.

During construction of the proposed Crack-in-the-Ground turbine, there may be short-term effects on recreation at the immediate site. PGE would curtail recreation access to this portion of the Oak Grove Fork during the construction period. However, construction activities would result in no incremental effects on recreation activities adjacent to this section of the Oak Grove Fork, because there would be no expansion of the lay-down area or construction period beyond that which would occur to install the previously authorized energy dissipater at this location.

4.3 CONSISTENCY WITH COMPREHENSIVE PLANS

Section 10(a)(2)(A) of the FPA15 requires the Commission to consider the extent to which a project is consistent with federal or state comprehensive plans for improving, developing, or conserving a waterway or waterways affected by the project.16 Under section 10(a)(2)(A), federal and state agencies filed 115 comprehensive plans that address various resources in Oregon. Of these, the staff identified and reviewed 35 comprehensive plans 17 that are relevant to this project. No conflicts were found.

15 16 U.S.C. § 803(a)(2)(A) (2006). 16 Comprehensive plans for this purpose are defined at 18 C.F.R. § 2.19 (2010). 17 Department of the Army, Corps of Engineers, Portland District. Water resources development in Oregon. Portland, Oregon 1993; Hydro Task Force and Strategic Water Management Group. Oregon comprehensive waterway management plan. Salem, Oregon 1988; National Park Service. The nationwide rivers inventory. Department of the Interior, Washington, D.C. January 1982; Northwest Power and Conservation Council. Protected areas amendments and response to comments. Council Document 88-22. Portland, Oregon September, 1988; Northwest Power and Conservation Council. Mainstem amendments to the Columbia River Basin fish and wildlife program. Council Document 2003-11. Portland, Oregon 2003; Oregon Department of Energy. Oregon final summary report for the Pacific Northwest rivers study. Salem, Oregon November 1987; Oregon DFW. Trout mini-management plans. Portland, Oregon December 1987; Oregon DFW. Willamette Basin fish management plan. Portland, Oregon March 1988. Revised spring Chinook chapters, dated March 1998, included; Oregon DFW. Draft Upper Willamette recovery plan. Salem, Oregon August 2007; Oregon DFW. Oregon wildlife and commercial fishing codes: 2001-2002. Portland, Oregon 2001; Oregon DFW. Oregon conservation strategy. Salem, Oregon

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5.0 FINDING OF NO SIGNIFICANT IMPACT

If the non-capacity related amendment to the Clackamas River Project is approved with the staff-recommended measures, the project would continue to operate and provide increased hydroelectric power generation, while providing protection and enhancements to water quality, aquatic, terrestrial, recreation, and cultural resources.

Based on our independent analysis, approval of the amendment with staff- recommended measures would not constitute a major federal action significantly affecting the quality of the human environment.

February 2006; Oregon Water Resources Commission. State of Oregon water use programs. Salem, Oregon 1987; Oregon WRD. Oregon water laws. Salem, Oregon 1988; Pacific Fishery Management Council. Eighth amendment to the fishery management plan for commercial and recreation salmon fisheries off the coasts of Washington, Oregon, and California commencing in 1978. Portland, Oregon 1988; State of Idaho. State of Oregon. State of Washington. Confederated Tribes of the Warm Springs Reservation of Oregon. Confederated Tribes of the Umatilla Indian Reservation. Nez Perce Tribe. Confederated Tribes and Bands of the Yakima Indian Nation. Settlement Agreement pursuant to the September 1, 1983, Order of the U.S. District Court for the District of Oregon in Case No. 68-5113. Columbia River fish management plan. Portland, Oregon November 1987; U.S. FWS. Fisheries USA: the recreational fisheries policy of the U.S. Fish and Wildlife Service. Washington, D.C. undated; BLM. Salem District resource management plan. Interior. Salem, Oregon. May 1995; BLM. Forest Service. Standards and guidelines for management of habitat for late-successional and old-growth forest related species within the range of the northern spotted owl. Washington, D.C. April 1994; Oregon DFW. Oregon’s elk management plan. Portland, Oregon February 2003; Oregon DFW. Oregon black bear management plan, 1993-1998. Portland, Oregon 1993; Oregon DFW. Oregon wildlife diversity plan. Portland, Oregon November 1993; Oregon DFW. Oregon cougar management plan. Roseburg, Oregon May 2006; Oregon DFW. Species at risk: Sensitive, threatened, and endangered vertebrates of Oregon. Portland, Oregon June 1996; U.S. FWS. Canadian Wildlife Service. North American waterfowl management plan. Interior. Environment Canada May 1986; Forest Service and BLM. The Northwest Forest Plan, 1994; Forest Service. Mt. Hood National Forest Land and Resource Management Plan, 1990; Clackamas River State Scenic Waterway: Management program and background report. 1985, ODOT 1985; OPRD. Oregon Outdoor Recreation Plan (SCORP): 2003-07, 2003; BLM. Salem District Resource Management Plan, 1995.

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6.0 LITERATURE CITED

Battelle Memorial Institute (Battelle). 2004. Draft Water Quality Model of the Clackamas River. Clackamas Hydroelectric Project. Prepared for Portland General Electric Company.

Doughty, K. 2004a. Final report for study year 2000, WQ1 – Water temperature monitoring. Prepared for Portland General Electric Company.

Doughty, K. 2004b. Final report for study year 2001, WQ1 – Water temperature monitoring. Prepared for Portland General Electric Company.

EDAW. 2003. Amphibian surveys final report. Report prepared for Portland General Electric Company, January 2003, 45 pages plus figures and appendices.

EES Consulting. 2004. Final: Clackamas River WQ2 Water Quality Studies. Prepared for Portland General Electric Company.

Federal Energy Regulatory Commission (FERC). 2006. Final Environmental Impact Statement for Hydropower Relicensing Clackamas River Hydroelectric Project Clackamas County, Oregon FERC Project No. 2195. Prepared by FERC Office of Energy Projects, FERC/FEIS – 0187F

National Marine Fisheries Service (NMFS). 2010. Biological Opinion, and Magnuson- Stevens Fishery Conservation and Management Act Essential Fish Habitat Conservation Recommendations for the Operation of Portland General Electric Company’s Clackamas River Hydroelectric Project No. 2195. NMFS, F/NWR/2006/04980

NWPCC. 2013. Northwest Power and Conservation Council. Sixth Power Plan Mid- Term Assessment Report. March 2013.

PGE (Portland General Electric Company). 2008. Application for Certification Pursuant to Section 401 of the Federal Clean Water Act. Submitted by PGE for the Relicensing of the Clackamas Hydroelectric Project on the Clackamas River, Clackamas County, Oregon (FERC No. 2195), Pursuant to Oregon Administrative Rules Chapter 340, Division 48, 259 pages plus appendices.

PGE. 2011. Clackamas River Project Water Quality Management and Monitoring Plan. Submitted by PGE to satisfy requirements of the 401 Water Quality Certification of the Clackamas River Project, 38 pages plus appendices.

United States Forest Service (USFS). 1996. Lower Clackamas River Watershed Analysis. USDA Forest Service, Pacific Northwest Region, Mt. Hood National Forest, and USDI Bureau of Land Management.Doughty, K. 2004a. Final report for study

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year 2000, WQ1 – Water temperature monitoring. Prepared for Portland General Electric Company.

7.0 LIST OF PREPARERS

Steven Sachs - Geology and Soils, (B.S., Environmental Systems Engineering)

Mark Pawlowski – Water, Aquatic, Wetland, Wildlife, Botanical and Recreation Resources, Land use, Threatened and Endangered Species, Aesthetics (B.S. Biology, Graduate Course Work, Fisheries Management)

CarLisa Linton-Peters – Cultural Resources, Ecologist. M.S., Marine Estuarine Biology and Environmental Science; B.S. Biology.

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