LIBBY DAM AND LAKE KOOCANUSA KOOTENAI RIVER, MONTANA

f ] Draft [ X ] Final Environmental Statement

Responsible Office: U.S. Army Engineer District, Seattle, Washington

1. Name of Action: [ X ] Administrative [ ] Legislative

2. Description of Action: The Libby Dam and Lake Koocanusa Project, located in Lincoln County, Montana, is a multiple-purpose project included in the International Water Resource Development Plan of the Columbia River Basin in the United States and Canada. The project was authorized for flood control, at-site power generation, and related water uses by the Flood Control Act of 1950, Public Law 516. Under the provision of a 1964 treaty between Canada and the United States, the project is to commence full storage within seven years after starting construction. Construction on the project started in June 1966 and is scheduled so that the dam will be operational for flood control storage by 30 June 1973. The railroad relocation was completed and in use in November 1970. The Forest Development Road is essentially completed. The reservoir bridge and approach roads are essentially completed.

3. a. Environmental Impacts: This project will provide: protection to the downstream Kootenai River flood plain from spring floods, and, together with Canadian storage and existing storage in Columbia Basin, will provide additional flood protection to the Lower Columbia River flood plain; 854,000 kw of firm power initially to the Pacific Northwest power system; about 13,000 acres for public recreation use. About 300 people will have to relocate in the United States portion of the project. Material cleared for construction and from the reservoir area is disposed of by burning and burying. Construction activities have not had a significant impact on water quality. A selective with­ drawal system is being installed to control the water quality of down­ stream releases. A reregulating dam will be constructed when the addi­ tional units are installed at Libby Dam to regulate peaking flows. Population increases due to construction activities have had an effect on the economy and public schools in the project area.

b. Adverse Environmental Effects: Completion of the dam will per­ manently impound the free flow of the river and alter fish and wildlife habitat in the area. Stream habitat improvement measures and a barrier dam to block non-game fish intrusion are in progress on one tributary and are being planned or programmed for other tributaries of Lake Koocanusa. The Corps of Engineers will provide funds to the State of Montana for construction of a hatchery to produce game fish with which to stock project associated waters. Important wildlife winter range will be inundated by Lake Koocanusa. Relocation of the Forest Development Road and Montana State Highway 37 will further reduce available wildlife habitat and hamper wildlife movements. Relocation of the Burlington-Northern mainline caused an additional loss of wildlife habitat. As partial mitigation for lost wildlife habitat, the Forest Service is carrying out a habitat improvement program on about 7,000 acres of National Forest land. Acquisition, in fee or by easements, of private land to be developed as replacement wildlife habitat is also being considered; however, Congressional authorization may be required. Channel changes required by the relocation of Burlington-Northern resulted in shortening the stream channel in the Fisher River, Wolf Creek and Fortine Creek by about 2 miles. A total of 140 rock groins were placed in these channel changes to assist and expedite the redevelopment of fish habitat in the new channel and pre­ vent degradation of the remaining natural channel. New meandering channels were created in one section of Wolf Creek.

Alternatives: At this time, the only alternatives, other than possible design changes, would be to abandon the project or finish con­ struction to a lesser extent than authorized. Alternative methods of debris disposal are being studied. The alternative of adding power to the reregulating dam is being studied; however Congressional authori­ zation would be required for the addition of power to the reregulating dam. An alternate route for Montana State Highway 37 to lessen its environmental impact was proposed by the Montana Department of Fish and Game but additional consideration by the State's Natural Resources Advisory Council concluded that the proposed route should be developed. The Governor of Montana concurred with this conclusion.

5. Written Comments Received:

Bonneville Power Administration Soil Conservation Service

Bureau of Sport Fisheries and Wildlife Department of Health, Education and Welfare

Bureau of Outdoor Recreation Federal Power Commission

National Park Service Montana Department of Fish and Game

Bureau of Reclamation Montana Department of Health

U.S. Coast Guard Montana Department of Highways

Federal Highway Administration Montana Water Resource Board

National Marine Fisheries Service Idaho Department of Fish and Game

Forest Service Idhao Water Resource Board

Town of Rexford 6. Draft Statement to CEQ: 24 June 1971

Final Statement to CEQ: £ § 1972. Environmental Statement

Libby Dam and Lake Koocanusa Kootenai River, Montana

Prepared by

U. S. Army Corps of Engineers District Seattle, Washington Libby Dam and Lake Koocanusa will be located on the Kootenai River m northwest Montana (inclosure 1). The damsite is 219 miles upstream from the confluence of the Kootenai and Columbia Rivers and about 17 miles upstream from the town of Libby, Montana. This is a multiple- purpose project included in the International Water Resource Develop­ ment Plan of the Columbia River Basin in the United States and Canada. The project is authorized for flood control, at-site power generation, and related water uses by the Flood Control Act of 1950, Public Law 516 •

Lake Koocanusa ^ill extend into British Columbia, Canada. Under the provisions of a 1964 treaty between Canada and the United States, the project is to commence full storage within 7 years after starting construction. Project construction was initiated in June 1966 and is scheduled so that the dam will be operational for flood control storage by 30 June 1973. Lake Koocanusa, at normal full pool elevation 2,459 feet, will have a surface area of 46,500 acres (28,850 in the United States and 17,650 in Canada) and 4,965,000 acre-feet of usable storage. The lake will have a shoreline of 229 miles (117 in United States and 107 in Canada) and length of 90 miles (48 in United States and 42 in Canada). The treaty also provides that Canada has responsi­ bility for project development and impacts where the lake extends into British Columbia.

Libby Dam will rise about 446 feet above bedrock, be 3,055 feet long and will include a powerhouse on the west (right) bank with four 105,000 kw generators initially and provisions for four additional units to be installed later. A visitor center building currently being used as the construction office, and an observation overlook have been constructed on the west bank.

Initial pool raising to the spillway crest, elevation 2405, will begin in May 1972. Full storage will occur in June or July 1973 if sufficient water is available. Riverflow is presently diverted through a low diversion opening left in the dam. Overall project construction is about 64 percent complete as of July 1971.

The dam construction is 86 percent complete with a total of 3,325,695 cubic yards of concrete having been placed as of 11 August 1971. The schedule for concrete placement is shown on the attached chart (inclosure 2).

Powerhouse construction is scheduled to begin in 1972 and the first four generating units will be on line in 1976. A selective withdrawal structure will be constructed to control the release of water through the turbines to improve the capability of adhering to interstate water quality standards. The system will permit control of the downstream water quality by generally selecting the reservoir level from which water is withdrawn.

Mainline tracks of the Burlington-Northern Railroad north to Jennings, Montana, and within the future Lake Koocanusa were relocated to a completely new 60-mile route between Stryker, Montana, and Jennings, Montana, starting near the confluence of the Fisher and Kootenai Rivers, about 3 miles downstream from Libby Dam. Railroad relocation work was completed in October 1970 and the new line went into service on 1 November 1970. The new Burlington-Northern route is shown on inclosure 3.

The existing Montana State Highway 37, now located on the west bank of the Kootenai River, will be relocated on the east bank. A Forest Development Road is being constructed along the west bank. The two roads will be connected by bridges, one crossing the Kootenai River 3 miles downstream of Libby Dam and one crossing Lake Koocanusa about 32 miles upstream of the dam. Montana State Highway 37 is about 27 percent completed and the Forest Development Road is about 96 percent completed.

The Forest Development Road from the mouth of the Fisher River to the Lake Koocanusa Bridge, scheduled for completion in late 1971, will be used as a substitute Montana State Highway until the new highway is completed in 1975. Lake Koocanusa Bridge was completed in November 1970 except for painting and road surfacing. The highway and road relocations are shown on inclosure 4.

All of the trees and large shrubs above elevation 2,282 feet will be cleared from the reservoir before filling. In addition, most of the stumps between elevations 2439 and 2462 will be removed to enhance recreational use of the lake. Clearing work was about 90 percent complete as of August 1971 and is scheduled to be completed prior to May 1972. The town of Rexford will be relocated to a new townsite just upstream of the present town. The City Hall-Fire Station was completed in June 1971. Completion of New Rexford School is scheduled for November 1971. Street paving, a water supply system and sanitary sewer system with interim treatment will be completed in October 1971, November 1971 and September 1971, respectively. Permanent treatment facilities will be completed in June 1972. The interim facility will be a septic tank with effluent discharge into a tile field. Permanent facilities will provide secondary treatment with the effluent being discharged by a spray system onto a grassy area adjacent to the aeration ponds.

The project is located and occupies land within Kootenai National Forest. The Forest Service under a Memorandum of Agreement between the Secretaries of Army and Agriculture will develop and administer all recreation developments with the exception of those immediately associated with the dam. The Corps of Engineers will operate day use areas in the vicinity of the dam. The future installation of units beyond the initial four units will require a low downstream dam and reservoir to regulate the fluc­ tuating powerhouse release during peaking operations to a more uniform flow to avoid damage to fisheries and to eliminate danger to fishermen and the general public in their access to areas adjacent to the Kootenai River downstream from Libby Dam. This reregulating dam was authorized as a part of the main project and will be located at river mile 208.9, 10 miles below Libby Dam. The reregulating reservoir would have a maximum pool elevation of 2,130 feet and a minimum pool elevation of 2,100 feet. Usable storage capacity would be 30,000 acre- feet. The dam would be about 80 feet high.

The current benefit-to-cost ratio for the project is 1.3 to 1.

2- Environmental Setting

The Kootenai River (Kootenay in Canada) originates in the Rocky Mountains near the west boundary of Kootenay National Park in British Columbia (inclosure 5). The river flows southward and enters the United States near Gateway, Montana, continues south to Jennings, Montana, and then assumes a northwesterly direction, flowing through the Kootenai Valley of northern Idaho and re-entering Canada near Porthill, Idaho. In Canada the Kootenay River flows into Kootenay Lake and emerges from the west arm of the lake to enter the Columbia River near Castlegar, British Columbia. About one-third, or 165 miles, of the river's length lies within the United States (inclosure 1).

The 19,300 square mile drainage basin is a sparsely settled, mountainous region. Access to the river and drainage basin is by a network of Federal, State, county, and logging roads. Approximately 90 percent or 17,000 square miles of the basin area is forested. Agriculture is the primary use of the remaining 10 percent or about 2,300 square miles. The largest agricultural area is situated in the Kootenai River flood plain near Bonners Ferry, Idaho. The average annual flow of the Kootenai River at Libby, Montana, is 12,120 cubic feet per second (c.f.s.). Discharge has varied from a maximum of 121,000 c.f.s. to a minimum of 895 c.f.s.

The broad flood plains in the lower reaches of the river, between Bonners Ferry and the Canadian Border, cover an area of approximately 56 square miles. These plains are protected, in part, by dikes and drainage channels; however, seasonal flooding and a high water table hamper agricultural activities. Little arable land occurs in the rest of the basin due to topography and the fact that the soils have developed almost entirely under coniferous tree cover. Parent soils are mostly: glacial lake sediments; partially water-sorted glacial fluvial drift; or alluvium deposited over cobbles and gravels of the glacial outwash. The project spans two distinct types of natural terrain. The damsite and lower reaches of the lake will be within a steep-walled, heavily forested valley. The lake will occupy the entire valley floor in this reach. The shoreline will be steep and layered with periodic flat benches buttressed by tiers of exposed rock outcrops. The upper reach of the lake, from Rexford into Canada, will be located on the Tobacco Plains area which is characterized by a broad, gently rolling, valley floor with gently sloped valley walls. The lake will occupy only a small portion of the valley floor and will be bordered by rolling rangeland interspersed with cultivated land and open ponderosa forests.

Geologically, the project lies entirely within the Northern Rocky Mountain Physiographic province. The south half of Lake Koccanusa will lie between the Purcell and Flathead (Salish) Ranges, both gla­ cially subdued mountain groups rising 3,000 to 4,000 feet above the adjacent valleys; the north half will lie within the Rocky Mountain Trench, a deep structural and topographic trough trending north to northwest and extending from south of Flathead Lake into Canada. Strong fault controlled valleys trending north to northwest and east- west are within the mountain groups of the project area. Continental ice covered the entire area during the Pleistocene, modifying the pri­ mary landforms. The deposits related to glaciation and later dissec­ tion of these deposits have created some spectacular landforms in terms of moraines, ice contact terraces, fill terraces and gravel capped, cut terraces in the Kootenai and Fisher River valley and in some of the lesser valleys. A series of impressive streamlined glacial hills and kettles, some of which contain lakes, characterize the Tobacco Plains area within the Rocky Mountain Trench. Post glacial alluvial fans are common where tributary valleys meet major valleys.

Most bedrock exposed in the area belong to the Belt Series of Precambrian age. The series consists of shallow water clastic and chemical sediments (argillites, metasandstones, quartzites and lime­ stones) have a thickness in excess of 40,000 feet. In spite of their age, the rocks are lightly metomorphosed. The rocks are closely jointed in several directions permitting easy natural and artificial quarrying and contributing to the formation of impressive cliffs. Fossils within these rocks are rare and consist largely of colonial algae within limestone beds. A small percentage of the rock is igneous consisting of both basic and acidic stocks, dikes, sills and flows varying in age from Precambrian to Tertiary. The basic geologic structure consists of broad, shallow, open, north to north­ west trending folds, interrupted by faults having a similar trend together with strong east-west faults. Displacement varies from several feet to several thousand feet. Age of the faults range from Cretaceous to Recent. Lode mineral deposits of silver, lead, gold, zinc, copper and tungsten are scattered throughout the area, but none are commercially active at the present time. Placer gold is also found. Recreational use in the basin has been varied with the major use occurring at bodies of water offering a wide range of activities. Al­ though exact figures are not available for recreation use in the basin, use has probably followed national trends. Recreational use in the immediate project, estimated to be 80,000 user days annually centered on fishing and hunting activities. The Forest Service has completed initial construction and opened to public use one recreation area within the project area, located about 5 miles above the dam on the west bank.

The United States portion of the Kootenai River Basin lies in­ clusively within the political boundaries of Flathead and Lincoln Counties in northwestern Montana, and Boundary and Bonner Counties in northern Idaho. Incorporated towns in the basin are Troy, Libby, Rexford and Eureka in Montana and Bonners Ferry and Moyie Springs in Idaho. The combined population of these towns is about 9,000.

Regional economic activity and population is centered within Lincoln and Boundary Counties. The major economic activity of Lincoln County is production of lumber and wood products derived from the forest resource. Of the 3,352 square miles of commercial forest­ land in Lincoln County', 2,539 square miles, or about 76 percent are within the Kootenai National Forest. The important species harvested are western larch, lodgepole pine and ponderosa pine. A million Christmas trees are exported from Lincoln County each year. Lincoln County is the foremost national producer of vermiculite products. Originally valuable for its insulating properties, vermiculite is increasing in importance with development of new markets in construction and agriculture.

The manufacture of lumber and wood products is also the primary economic activity in Boundary County, Idaho. Of the 1,105 square miles of commercial forestland in Boundary County, 650 square miles or about 59 percent are within the Kootenai and Kaniksu National Forests. Important species harvested are western larch, Douglas fir and Engelmann spruce.

Agriculture also contributes significantly to the economy of Boundary County. In 1964 the value of all farm products sold totaled over 2 million dollars. Field crops such as oats, wheat and barley were the major product group, representing 62 percent of the total value sold. Livestock such as hogs and beef cattle were next in impor­ tance, consisting of about 20 percent of the total.

The Federal power system provides about 50 percent of the Pacific Northwest's power supply and has about 80 percent of the Pacific Northwest's bulk power transmission capability. However, expansion of direct power sales to electroprocess industries in the Pacific Northwest has been halted because of the present tight power situation. No new firm electroprocess loads have been added in the Pacific Northwest by BPA since 1966 nor have any additional firm power commit­ ments for future industrial loads been made. Finn power is power that is always available as opposed to secondary power which is only available part of the time.

The Kootenai River is classified by Montana Water Quality Standards as suitable for use as ~ water supply with minimum treatment to remove natural impurities. Tributaries are mostly typical mountain streams; rising in snowfields, forested ridges, or mountain lakes, and coursing through deep, narrow valleys to join the main stream. Floods on the main stream are of long duration and are notable for great volume rather than for short, extreme crest discharge. The Kootenai River is the third largest tributary of the Columbia River in terms of drainage area, but is second largest in volume of runoff, being exceeded only by the Snake River. Winter flows are ordinarily low and spring flows the highest. Floods occurring during the spring snow-melt season reach damaging stages an average of one year in five.

Most of the Kootenai River basin in the United States is forested with mixed species of coniferous trees. The valley floors are vege­ tated with broadleaf trees, such as cottonwood, willow, birch, alder and dogwood. Many of the south and west facing slopes are timbered with open stands of ponderosa pine, while the north facing slopes are more densely forested with Douglas fir, lodgepole pine, and western larch. Cedar, hemlock, spruce, white pine, and grand fir are present also. The understory includes redstem ceanothus, bitterbrush, service- berry, choke cherry, snowberry, snowbush, Oregon grape, mountain maple, rose, kinnikinnick, mockorange, nannyberry, ninebark, and various grasses.

Wildlife inhabiting the basin include white-tailed and mule deer, big horn sheep, black and grizzly bear, moose, Rocky Mountain elk, ruffed, blue and spruce grouse, beaver, muskrat, mink, weasel, river otter, bobcat, skunk and coyote. In addition, the Columbia sharp­ tailed grouse inhabits prairie lands in the Tobacco Plains area which serve as a breeding ground for this species and comprise an ecological niche unique in western Montana. Waterfowl, once numerous in the extensive marshes of the Kootenai Valley of Idaho prior to agricultural development, now occur throughout the basin in comparatively small numbers; the major concentrations being in the Duck Lake area of British Columbia.

Fish inhabiting the Kootenai River include cutthroat, brook, and rainbow trout, Dolly Varden, mountain whitefish, burbot, northern squawfish, suckers, peamouth, kokanee, yellow perch, sunfish and white sturgeon. All but the last four species occur in the project area. In Montana the white sturgeon is unique to the Kootenai drainage. Upstream migration of this species is blocked by Kootenai Falls, a series of low falls and rapids located 29 miles downstream of the dam- site.

The historic and archeological aspects of the project region are centered on the Kutenai and Upper Pend Oreille or Kalispell Indians who inhabited the valley. David Thompson, trading for furs and explor­ ing for the Northwest Company, entered the area in 1808. Father DeSmet, a Belgian Jesuit priest, established a mission station at Tobacco Plains in 1845. The community of Libby was established about 1862. The Great Northern Railway Line was completed in 1891 connect­ ing Jennings with Kalispell, Montana, by way of Haskill Pass near Pleasant Valley. In 1892, the first steamboat made the trip from Jennings to Fort Steele, British Columbia. The Great Northern line was extended northward from Jennings to Fernie, British Columbia about 1900 ending the steamboat traffic. In 1904, the mainline was rerouted from Whitefish to Jennings via Eureka.

Archeological surveys of the area from the Fisher River upstream were made in 1950 by the Smithsonian and in 1966 and 1967 by the University of Montana under contract to the National Park Service. Salvage of the most promising sites was completed in 1967. Artifactual material salvaged consisted of stone tools, projectile points, mauls, pestles, pipes and historic items. There was little trace of the more fragile elements of Kutenai culture.

The now completed relocation on the Burlington-Northern mainline starts at Jennings, parallels the Fisher River to Wolf Creek, follows Wolf Creek to its headwaters on Elk Mountain, passes through the 7 mile long Flathead Tunnel, and then follows Fortine Creek downstream. The new line meets the old line at Stryker, Montana. The new route is about 14.5 miles shorter than the old one, though the grade is steeper. The new mainline parallels the original line built in 1891 for about 18 miles, to the junction of Atlantic Creek and Wolf Creek.

Relocation of Forest Service and county roads and reconnection of some private roads was necessary to provide access to both sides of the tracks because of the alinement of the new railroad line. A total of 26.5 miles of roads were relocated as a result of railroad construc­ tion.

The relationship of the completed portion of the dam with the environment is best illustrated by the attached photograph (inclosure 6). The Visitors Center and Visitors Observation Point are completed and are open to the public except for the lower floors of the Visitors Center currently in use as the Resident Engineer's office. Landscape restoration at these two facilities has been completed. About 14 miles of the 54 miles required for the relocation of Montana State Highway 37 have been essentially completed. All cuts and fills have been made and the roadway is at grade over most of this 14 miles. A total of 284 acres have been cleared fcr this construction. About 4? of the nearly 51 miles required for the relocation of the Forest Development Road have been essentially completed. All cuts and fills have been made and generally the only work left is surfacing and the installation of guard rail. A total of 817 acres have been cleared for this construction.

Nearly all the private property required for the project has been acquired by the Government but, in some instances the residences have been leased back to the former owner until the fall of 1971. The rela­ tionship of this portion of the construction with the natural environ­ ment is that there is essentially a barren reservoir without a lake.

3. The Environmental Impact of the Proposed Action

Recurring flood damages occur to leveed land in the flood plain of the Kootenai River, extending about 70 miles from above the town of Bonners Ferry, Idaho, downstream to Kootenay Lake, British Columbia. Levee systems give partial protection to 34,400 acres of fertile land (including 190 acres in the community of Bonners Ferry) in the United States and 17,500 acres in Canada. The Kootenai River is the third largest tributary of the Columbia River, and contributes about 18 per­ cent of the runoff of major floods on the Lower Columbia. Libby Dam, together with Canadian storage and existing storage in Columbia Basin, would be sufficient to control the flood of record (1894 flood, with peak discharge of 1,240,000 c.f.s. at The Dalles) to less than 800,000 c.f.s. at The Dalles, Oregon. Fifteen percent of the total reduction would be directly attributable to Libby Dam as a component of the Columbia River Treaty projects. Therefore, additional flood protec­ tion is provided to lower Columbia Rivt~ areas such as Portland, The Dalles and Hood River, Oregon and Vancouver, Kelso, and Longview, Washington.

Libby project operation will result in increased river levels in the Kootenai during the winter and early spring. These are expected to increase existing water table elevations within 1,000 to 2,000 feet of the river by decreasing natural drainage to the river and requiring extra pumping. Regulated river levels from April through July will be lower than normal, thereby reducing the head that some of the drainage pumps must work against. A review of United States Geological Survey ground water data indicates that the Kootenai River does not provide significant subirrigation for Kootenai Flats crops during the summer months and that decreased river levels due to Libby project operation will have a negligible effect on subirrigation. Completion of Libby Dam will add a total of 854,000 kw of firm power to the Pacific Northwest power system to aid in meeting future power requirements in the Pacific Northwest. Of this total, 270,000 kw is at-site power production at Libby Dam and 584,000 kw is attributable to increased production at the 5 Canadian and 10 United States power plants downstream of Libby. The downstream power generation total is slightly greater than the present installed capacity of Bonneville Dam.

Completion of Libby Dam can be expected to benefit mosquito control around Bonners Ferry, Idaho, to the extent that downstream flooding of the Kootenai River is curtailed in this vicinity. Bonners Ferry his­ torically has had a severe mosquito problem.

Concrete structures have been placed in a near wilderness setting with the dam blocking the natural flow of the river. This impact on the natural setting will be minimized to the extent possible by: integrating the architectural design of the dam, powerhouse and visitors facilities into a single unit; disturbing nature as little as possible and, where land is disturbed, restoring it to simulate the natural; providing staging, borrow and waste areas below the pool line where possible. Informal landscape treatment around the dam will complement the natural topographic features of the project area and provide a transition between the man-made features of the project and the natural surroundings.

Creation of Lake Koocanusa will, in the United States, convert 4,750 surface acres of river to a 28,850 acre lake, remove nearly 2,000 acres from cultivation, over 6,500 acres from natural grazing, over 7,000 acres from private forests, 150 acres from residential developments, 80 acres from industrial use, and 8,370 acres from National Forest lands. Lake Koocanusa will inundate: 43 miles of the Burlington-Northern mainline track (formerly Great Northern Railway); 42 miles of Montana State Highway 37; 92 miles of Forest Development roads; 28 miles of Lincoln County roads; the communities of Warland and Rexford, with a combined population of about 300 and a number of scattered homesites and farms.

Recreational use in the project area will change from a river oriented pattern to a lake oriented pattern and will be increased by the project. Lake Koocanusa, as a recreation resource, will increase recreation demand and facilities are being provided to take care of the demand. The Forest Service plans for ultimate development of twenty-two authorized recreation areas ranging from primitive to com­ mercial complexes. About 13,000 acres of public land will be available in the United States to provide recreation and public access at the project. Due to public landownership, the aesthetic qualities of the shoreline can be maintained in a near-natural state by proper planning and the prevention of unplanned, unsightly development. Lake Koocanusa's original filling and subsequent operation will cause all flotsam to come to the surface. Initial disposal of this debris will be accomplished by the Corps of Engineers. The current approved plan is to dispose of this debris by tilling it into the soil in clearcut areas outside the reservoir. Adverse impacts associated with this method of disposal include: increased fire hazards, damage to wildlife habitat, erosion, necessity of clearing a disposal area and the possibility of degrading water quality by ground water leaching through the material and into the stream course. Alternative methods of disposal are currently being studied to determine if a method with less impact is available. Methods being studied include burial other than by tilling, chipping, improved burning and recycling (i.e. chipping and making "pressed" logs, chipping and mulch­ ing, etc.) and combinations of the above. The Forest Service will assume the responsibility of future disposal.

Disposal of material from construction areas and the area the lake will occupy temporarily affects air quality at localized sites when open-air burning is permitted during clearing operations.

The visual impact of reservoir drawdown will be lessened by stump removal and complete clearing between elevations 2462 and 2439. Between elevations 2439 and 2282 all stumps will be cut flush with the ground and larger shrubs removed. Removal of this material reduces the impact of decomposing herbaceous material on water quality.

Sloughing and beaching of overburden material along the lake margins are expected as a result of filling Lake Koocanusa. These failures commonly occur during the early stages of projects of this nature and are not expected to seriously affect the operation of the project. However, precautions will have to be taken to assure that recreation or other public use areas are safe from direct and indirect consequences of sliding. Development near the reservoir shore will be restricted until some experience is gained during reservoir operation. Areas of concern from the standpoint of major rock slides are restric­ ted to a reach of about 1/2 mile upstream from the dam on the left side of the canyon. Older rock slides are in evidence here and, because of adverse bedrock structure, careful evaluation of the hillside stability must be made because the effect of raising the pool and operating the reservoir will be reduced stability. The relocation route of Montana State Highway 37 is through this area, so design and investigation studies are currently being made to determine the optimum alinement of the highway and the feasibility of increasing the stability of the valley side.

The physical and biological characteristics of fish habitat in the Kootenai River downstream of Libby Dam will be altered because of river fluctuations and water temperatures. The daily river fluctuations downstream, resulting from power peaking operations, will reduce aquatic fish food organisms by stranding them and may hamper angler use. In addition to fluctuations, temperature of the water released may have an effect on fish habitat downstream of the project. Cutthroat trout spawning could be delayed by colder water temperatures in the spring and mountain whitefish and burbot spawning could be earlier due to warmer water temperatures in the winter. Little is known about the spawning habitat requirements of the white sturgeon, which spawns downstream from Kootenai Falls in Montana. Reduced water temperatures may affect their spawning activities. A selective withdrawal system is being installed to improve the control of the quality of water released downstream. Water released after completion of the project will be clearer than that which existed without the project due to sediment retention in Lake Koocanusa. Construction activities at Libby Dam have not had a significant effect on turbidity except during periods of high discharge or during diversion operations. To reduce the impact of power releases on downstream use, fluctuations will be limited to no more than 1 foot per hour and 4 feet per day during the summer recreation season and 2 feet per hour and 6 feet per day during the rest of the year. To help sustain downstream fish production, a minimum release of 2,000 c.f.s. will be maintained. Additional impacts on the Columbia River system, which are incompletely understood and are currently being investigated as part of the Columbia River and Tributaries study, may result from peaking operations at Libby Dam.

Construction of the project will have no effect on the habitat of the Columbian sharp-tailed grouse. The portion of the Tobacco Plains area used by these birds as a breeding ground is outside the area being inundated.

Construction of the reregulating dam will convert 10 miles of river containing about 100 acres of water surface to a lake having 1,350 acres of water surface at normal full pool elevation of 2,130 feet. The reregulating dam would meet the same criteria on minimum flow releases and fluctuations at Libby Dam. The following relocations would be required: nearly 9 miles of Burlington-Northern Railway mainline tracks; about 8 miles of Montana State Highway 37; about 1/2 mile of Forest Development Road. The St. Regis Paper Company will have to relocate their road located on the south bank of the Kootenai River.

Current studies indicate that the reregulating dam will be an earthfill structure with a concrete spillway, but actual design of the facilities has not begun. Architectural treatment and landscaping will be employed to integrate the visual impact of the structure with its environment.

As with construction of Libby Dam, little effect on the water quality of the area would be anticipated except during diversion operations. Inundation of an additional 1,100 acres of wildlife habitat will have an adverse impact on wildlife using the area for winter range. Management of the land acquired around the periphery of the reservoir for wildlife habitat would be carried out to lessen this impact on wildlife. The reregulating dam would block upstream fish passage to Fisher River. Final determination of the need for including fish passage facilities will be made after the Montana Department of Fish and Game completes fish population and migration studies on the Fisher and Kootenai Rivers. The Fish and Wildlife Service has estimated that about 2,800 angler days annually would be lost because of construc­ tion of the reregulating dam.

The University of Montana, under contract to the National Park Service, has completed an archeological survey of both reservoir areas. The majority of sites discovered were within the reservoir area. A salvage program of representative sites has been completed by the University and no further work will be done. A salvage program has not yet been completed for the reregulating dam reservoir area.

There has been an impact on the population and economy of the immediate project area because of project construction. Population increase in the Libby market area from 7,374 in 1960 to 12,045 in 1970 have provided a larger volume of retail sales and an expansion of services such as motels and restaurants. Population, retail sales and other economic indicators are expected to return to preproject rates after completion of construction. Increasing number of people in the area has also had a noticeable impact upon the public schools in the project area. In some public schools, enrollments have more than doubled. Portable classrooms were provided where the need was imme­ diate and temporary and permanent school buildings were constructed when normal growth would utilize these facilities after project con­ struction is completed. The majority of housing required for project personnel has been provided by private enterprise through the develop­ ment of new housing and trailer courts.

Existing Pacific Power and Light Company and Lincoln Electric Cooperative powerlines which serve customers in the Warland, Rexford and other areas will be flooded by the filling of Lake Koocanusa. Relocations of these facilities will be required to continue service to customers above the lake. Telephone lines of Interbel Telephone Cooperative will also be relocated. In determining the route and method of construction for the relocated facilities, consideration has been given to avoidance of disturbing the natural environment unneces­ sarily and creating unsightly scars. Most lines will be buried. Where powerlines must be placed overhead, they will be screened from the view of the motoring public. 4. Adverse Environmental Effects Which Cannot be Avoided

The following table summarizes project-caused average annual fisherman-day and hunter-day losses as estimated by the Bureau of Sport Fisheries and Wildlife, and programmed mitigation measures and their effect on fisherman-day and hunter-day use as estimated by the Corps of Engineers.

Table 1

Project caused Proposed Effect of Unmitigated Item Losses 1/ Mitigation Mitigation 2/ Balance (use days) (use days) (use days)

Reservoir -16,000 3/ Reservoir +14,400 3 / -1,600 (in U.S.) stocking

Reservoir -3,100 Barrier Dam +8,400 +5,300 tributary and fish s treams habitat im­ provement

Kootenai River -17,700 Multilevel +15,000 -2,700 (damsite down outlet stream to structure Canadian Border)

Fisher River, -4,600 Rock Groins +3,350 -1,250 Wolf Creek an

TOTAL -41,400 +41,150 -250

Big Game -7,504 Habitat im­ +7,504 0 provement an< i land acquisi­ tion 4/

Upland Game -1,000 None -1,000 Table 1 (Cont'd)

Project caused Proposed Effect of Unmitigated Item Losses 1/ Mitigation Mitigation 2/ Balance (use days) (use days) (use days)

Waterfowl -2,500 Habitat im­ +61 -2,439 provement

TOTAL -11,004 +7,565 -3,439

^/Estimated by Bureau of Sport Fisheries and Wildlife. 2/The policy of the Bureau of Sport Fisheries and Wildlife does not permit their developing estimates of the effects of proposed miti­ gation measures. These estimates were made by the Corps of Engineers and informally coordinated with the Bureau of Sport Fisheries and Wildlife. _3/This figure represents the actual use and does not reflect the higher — dollar value placed on stream fishery as opposed to lake fishery. 4/Land acquisition may require Congressional authorization.

Completion of Libby Dam will permanently block the valley and eliminate free flow of the river in the area occupied by the lake. With no fish passage facilities provided, the dam will be a permanent barrier to upstream fish movement.

Lake Koocanusa will inundate about 12,000 acres of prime winter range used by about 3,250 deer, 300 elk and 300 moose and 3,500 acres used by 170 mountain sheep. This range consists of bottom and low bench lands that are critical to survival of big-game animals during severe winters. Displaced animals will seek food on adjacent forested lands. A population adjustment to the reduced habitat will result from starvation probably during the first severe winter following project completion. A reduction in the number of mountain sheep would be particularly serious because of the presently small population and because they are a rare and endangered species. This inundation, besides reducing big game numbers, will impede migrations and compli­ cate game management.

To partially offset this loss of winter range, the Forest Service is implementing a timber and wildlife habitat management program on about 7,000 acres of National Forest lands. The areas to be used are on potential big game winter range sites on open slopes with southern exposures, below elevation 4,000 feet, and within or adjacent to existing winter ranges. Techniques to provide benefits to both timber and wildlife will include: thinning pole stands; burning some slash; retaining other slash for moisture retention; scarifying and burning to encourage the establishment of desirable browse species. Escape cover and protection from severe weather would be provided by leaving some timber. Additionally, the Fish and Wildlife Service and Montana Department of Fish and Game have proposed that $1,300,000 be budgeted for development of land purchases or easements obtained from willing landowners. This land would be managed to improve its carrying capacity for game animals as a substitute for the inundated habitat not compensated for by the Forest Service management plan. This proposal is now under consideration; however, congressional approval and authorization would be required. In addition, the Forest Service plans to improve waterfowl habitat on 157 acres of marshes and lakes in the project area.

Lake Koocanusa will inundate 48 miles of the Kootenai River and over 10 miles of tributary streams in the United States. Stream habitat will be replaced with a lake having an average annual fluctua­ tion of about 60 feet for the first 15 years and 40 feet for the remainder of the project life. Maximum fluctuation would be 172 feet. Trout and whitefish will not spawn in the lake and natural reproduc­ tion will depend on the remaining tributary habitat. Existing winter fishery for whitefish in the inundated areas will be eliminated. Non­ game fish will increase in the lake environment which will favor these forms over most game fish. Conversion from a river fishery to a lake fishery will reduce the value of the fishing opportunities.

The loss of stream production habitat will be mitigated by stocking 25,000 pounds of game fish in Lake Koocanusa and project associated waters annually. The plant will be made by the Montana Department of Fish and Game from a hatchery to be constructed and operated with project supplied funds. In addition, stream habitat improvement measures and a barrier dam to block nongame fish intrusion are in progress on one tributary, Young Creek, and are being planned or programmed for other tributaries of Lake Koocanusa.

The Forest Development Road had to be cut into the hillside because of the valley's steepness but the horizontal alinement generally follows natural contours. Because of this steepness of terrain, many cut and fill areas throughout the Forest Development Road are of greater magnitude than would be required for flatter terrain. Design features explained in succeeding paragraphs have been utilized to minimize the visual impact of these features. Forest Development Road construction and clearing will require 886 acres of wildlife habitat. Access will be provided to the recreation areas on the reservoir side and to the landward side. Scenic turnouts and parking area widenings have been provided throughout the length of the highway.

The impacts created by construction of Montana State Highway 37 would be the same as those mentioned for the Forest Development Road except that 1,253 acres of wildlife habitat would be lost through clearing and construction. The impact of highway construction on wildlife would be greater because of the additional acreage required and because of greater concentrations of wintering wildlife on the east side of the Lake Koocanusa, particularly a herd of big horn sheep, an endangered species. Scenic turnouts will be provided but parking area widenings were not required because of the road's design width.

Various methods were used in design and construction of both roads to reduce their environmental impact. In several instances, the alinement of the roads have been changed to protect environmental features such as Kutenai pictographs, a game watering hole, and a scenic high rock bluff adjacent to a recreation area. Haul and access roads, staging areas and stockpile areas have been designated on the plans and, where possible, located within the reservoir. Borrow areas, with the exception of those below the dam, have been or will be located within the reservoir. Waste material will be disposed of by widening embankments or disposal within the reservoir. All streams designated by the Montana Department of Fish and Game as significant with respect to fish propagation, with the exception of McGuire Creek, have been crossed by bridges or culverts with fish passage facilities. Topography and foundation conditions precluded both a bridge and fish passage facility in the McGuire Creek culvert. Embankments and cuts have been designed with minimum stable slopes to reduce the area affected by construction. Clearing limits were reduced to 15 feet beyond the top of cuts and 10 feet beyond the toe of fills. Topsoil will be hauled from below the reservoir and stockpiled for restoration of all cut and fill slopes that will support vegetation. Special restrictions will be placed in specifications for new contracts to minimize air pollution caused by the open burning of cleared material. Critical environmental control areas, which are areas requiring care and special construction methods to avoid damage to areas adjacent to the construction area, have been designated in plans and specifications for all highway construction. Excess rock excavation is being stock­ piled for use as surfacing on the north half of Montana State Highway 37 so that a borrow area will not have to be opened above the reservoir. Game trails with granular surfacing are being constructed underneath bridges to encourage animals to cross beneath them rather than across the highway. The addition of special underpass structures to allow game animals to cross the highway were discussed with the Montana Department of Fish and Game but they did not recommend their inclusion.

Spillway flow at Libby Dam may create a condition of supersaturated nitrogen downstream of the dam. With the initial installation of four generating units, the estimated frequency of spillway discharge is 7 out of 10 years. With eight generating units, the frequency would be 3 out of 10 years. The spillway will be used yearly until the powerhouse is completed. However, the excess nitrogen will more readily come out of solution in a turbulent, fast flowing river such as the Kootenai than it would in a smooth slow moving river. The Corps of Engineers is currently working on a computer model simulation to determine the approximate distance required for the excess nitrogen to leave solution.

Potential water quality problems which may develop in Lake Koocanusa include excessive algae blooms, introduction of taste, odor and color and the possible addition of hydrogen sulfide gas. Algal blooms resulting from high phosphate concentrations in the inflow and warm surface water and the subsequent decay of these blooms could contribute to the reduced dissolved oxygen and odor problem and could also produce an undesirable appearance. Tannins and lignins released from decaying vegetation also may cause undesirable taste, odor and color. Decaying herbaceous material within the reservoir will place an oxygen demand on the impounded waters and generate hydrogen sulfide gas. Monitoring of water quality of the Kootenai River was initiated in 1967 to determine the effects of the construction of Libby Dam and Lake Koocanusa on the water quality of the Kootenai River before, during and after project construction. The study encompasses the entire river and is being cooperatively conducted by the United States and Canada. In the United States, the U.S. Geological Survey and the Environmental Protection Agency are cooperating with the Corps of Engineers in collecting and analyzing data. All sampling and analysis is being accomplished under a mutual agreement between these three agencies and with the advise of the Montana Department of Health and the Montana Department of Fish and Game. Completion of the studies will define actual water quality problems and recommend solutions for these problems. Results of this study to date indicate that water quality degradation will be less than initially anticipated and may be insignificant.

A selective withdrawal system is being added to improve water quality control for downstream releases. Installation of this facility will not permit complete duplication of preproject water quality conditions but will improve water quality downstream of the project over conditions that would prevail without the facility. Generally, the temperature of water released in the spring will be lower than normal and temperatures in the fall will be higher than normal. The facility will be operated to consider all controllable parameters such as temperature, dissolved oxygen and noxious gases.

The relocation of the Burlington-Northern mainline essentially follows the valley floor of the Fisher River, Wolf Creek and Fortine Creek drainages, and it was necessary to either bridge the river or creeks or to alter their channels. The fish and wildlife agencies recommended and preferred an alternate route along Fivemile Creek but this alternate involved a substantial increase in construction and maintenance costs and was not acceptable to the railroad (the owner of the facility being relocated). There were a total of 40 channel changes on the three streams, which affected nearly 53,000 feet of stream. These channel changes reduced the lengths of the streams as follows: Fisher River, 16 channel changes reducing 27,440 feet of stream to 22,625 feet of stream, a total reduction of 4,815 feet in river length; Wolf Creek, 17 channel changes reducing 25,240 feet of stream to 20,111 feet of stream, a total reduction of 5,129 feet in creek length; Fortine Creek, 10 channel changes reducing 4,560 feet of stream to 3,831 feet of stream, a total reduction of 729 feet in creek length. In addition to the channel changes mentioned, a new meandering channel was constructed in one section of Wolf Creek replacing 4,410 feet of severed channel with 4,690 feet of new channel or an increase of 280 feet in creek length. These new meanders were constructed with the assistance of Montana Department of Fish and Game to partially offset project-caused fish habitat losses in Wolf Creek. To mitigate channel changes 140 groins were constructed in the three streams: 67 in the Fisher River; 58 in Wolf Creek; 15 in Fortine Creek. These structures are to stabilize the channel, reduce flow velocities, concentrate low flows, minimize the adverse effect of rechanneling in undisturbed areas, and assist in the restoration of suitable pool and riffle habitat essential for productive fish habitat. The effec­ tiveness of the groins in accomplishing these goals is currently being evaluated by the Montana Department of Fish and Game. Excessive turbidity occurred during construction of the groins and channel changes in Fisher River and Wolf Creek.

The portion of the relocated mainline in the Fisher River Valley passes through one of the more important winter ranges for white-tailed deer in northwestern Montana. About 7,000 white-tailed deer utilize this winter range. Small herds of elk (400) and mule deer (1,500) also utilize these ranges. The animals that seek winter range along the newly constructed line may follow the cleared track during heavy snow for easier movement. Increased mortalities may result from the animal concentrations and the higher speeds on the relocated route. The greatest losses may be expected in the late winter months when the animals will use the cleared tracks for movement. The Montana Department of Fish and Game is conducting a study, funded by project funds, to determine if incremental loss occurs and, if so, to seek ways of eliminating or reducing this loss.

A Secondary adverse affect would result from the elimination of flooding in Kootenai Flats. Most of the present 900 acres of marshes, open-water areas and seep areas used by waterfowl will be available for agricultural uses rather than waterfowl habitat.

The Corps of Engineers and concerned conservation agencies will continue to investigate and determine means of compensating for project incurred environmental losses.

5. Alternatives to the Proposed Action

With overall physical project construction about 62 percent com­ plete, the only alternatives would be abandonment of the project or construction to a lesser extent than authorized. Over a period of years, the portions of valley floor that have been cleared would either re­ forest themselves or be utilized for agricultural purposes. Those dwellings already destroyed could be replaced. The borrow sources for the concrete aggregate for the dam and other borrow sources within the reservoir could be regraded. The Forest Development Road and bridges already constructed could be left as they are since removal would still leave permanent scars. The railroad would remain on its relocated line for the same reason. The dam could be left in its present uncompleted state or removed if a suitable disposal site could be found for the 3,325,695 cubic yards of concrete already placed.

As of 30 June 1971, $258,575,000 has been committed for construc­ tion of the project. In Fiscal Year 1972, another $52,705,000 is expected to be committed for project construction. Abandonment of the project at this point would leave many of the damaging effects and would realize none of the assets of the project. Further, the United States would fail to keep a commitment made in the treaty with Canada. Benefits foregone would amount to $22,307,000 annually for a 50-year project life or $22,757,000 annually or a 100-year project life. These benefits include flood control, at-site and downstream power generation and recreation (exclusive of fish and wildlife).

Alternative means of providing project benefits were not studied prior to project authorization in 1950. However, alternatives do exist. Such alternatives as thermal power production, flood control storage in different areas, flood plain zoning and recreational development both at the project site or elsewhere could provide about the same benefits; however, each of these alternatives would have adverse effects on the environment and would undoubtedly be more costly.

The Montana Department of Fish and Game requested consideration be given to rerouting Montana State Highway 37 or combining it with the Forest Development Road to lessen the impact on wildlife habitat. However, after study by the State's Natural Resources Advisory Council, the Governor of Montana requested that the relocation of Montana State Highway 37 be continued as planned.

The reregulating dam would not be required if the additional units are not added at Libby, although it would be desirable to reregulate discharges from the initial four units. With the additional units the only alternative to the reregulating dam would be operating the pro­ ject without regulating the downstream flows. Libby Dam could not be operated for peaking power and still maintain downstream fluctuation limits without the reregulating dam.

Four site locations were studied for the reregulating dam with final selection based on environmental and economic considerations. The site selected would have the least effect on the environment based on considerations given to recreation, aesthetics, fish, wildlife, and water quality. The alternative of adding power to the reregulating dam is under study. Reservoir operations would be the same with or without the addition of power generating facilities in the reregula­ ting dam.

6. The Relationship Between Local Short-Term Uses of Man’s Environment and the Maintenance and Enhancement of Long-Term Productivity

Completion of Libby Dam will permanently remove over 41,000 acres of the Kootenai River Valley in the United States from agricultural, residential, logging and manufacturing uses. About 13,000 acres of this total will be reserved for public recreation and access at Lake Koocanusa. Over 14,000 acres of wildlife habitat will be permanently lost by construction of the project.

Lake Koocanusa will transform 4,750 acres of natural free flowing stream habitat in the United States to a lake 48 miles long. The existing stream is currently used for recreation and fishing. Native trout spawn in the stream. Long term use of the reservoir will include recreation and fishing; however, the reservoir will not be suitable habitat for trout to spawn. The Corps of Engineers has not attempted to estimate the overall value of the stream for its present uses in preproject condition.

Relocation of the Burlington-Northern has resulted in a loss of 1.97 miles of natural free flowing streams because of channel changes. During the channel changes, an additional 9.7 miles of streambed were disrupted. The use of the streams for recreational purposes will be the same as uses prior to the relocation of the railroad. Aesthetically the Fisher River and Wolf Creek are not as pleasing as they were prior to construction because of the straightness of the channel and the lack of vegetation on the streambanks.

About 8,500 deer and 400 elk occupy winter ranges through which the relocated mainline will pass. This area will continue to be used for winter range. Increased mortalities may occur because of the animal concentration and higher train speeds on the relocated route.

The reregulating dam would convert an additional 1,350 acres of natural natural habitat to a 10 mile long lake and further deplete natural stream spawning areas and wildlife habitat. Use of the area for recreational purposes will continue.

Lake Koocanusa will have 4,965,000 acre feet of flood control storage capacity providing flood control protection from spring floods of between 85 and 100 year flood magnitudes on the Kootenai River and together with Canadian storage and existing Columbia Basin storage would provide additional flood protection on the lower Columbia River.

Operation of Lake Koocanusa after installation of initial genera­ ting facilities would add 854,000 kw of firm power to the Pacific Northwest Power System. Recreation use in the project area will be increased, estimated to grow from an initial use of 300,000 to 4,700,000 recreation days annually (excluding fisherman-day and hunter-day use). Recreational use without the project would approach 200,000 visitor days annually within 100 years. Recreation in the project area will be converted from river oriented to lake oriented activities. The Corps of Engineers has not yet developed methods and procedures to quantify the value of the Kootenai River without the dam. However, estimates of recreation benefits did take into consideration the use the river was receiving in its undeveloped state (approximately 80,000 user days including recrea­ tion, fishing and hunting). Although 48 miles of the Kootenai River in the United States will be inundated, about 6,000 miles of free flowing stream will remain in western Montana. About 100 lakes in western Montana are large enough to support water-oriented sports such as power boating and water skiing. Flathead Lake and Hungry Horse Lake, both within 125 miles of Lake Koocanusa, are the only two comparable in size to Lake Koocanusa. Unlike most lakes in western Montana, the entire shoreline of Lake Koocanusa will be in public ownership assuring the perpetual availability of the resource for recreational use. Because of the greater number of people using the project area for recreational purposes, there will be some adverse secondary environmental effects. The proposed recreational areas will be designed to adequately accom­ modate the estimated users and minimize these secondary effects by such means as screening to reduce noise, providing adequate sanitary facil­ ities and other design details.

7• Any Irreversible and Irretrievable Commitments of Resources Which Would be Involved in the Proposed Action

In the United States, 4,276 acres of land would be irreversibly and irretrievably committed to use as roads and railroads and 24,100 acres of land and 4,750 acres of river are committed to use as a reservoir.

Locally important historical areas such as Rexford, Warland, and Gateway will be irrevocably lost with Libby Dam. The Jennings townsite would be inundated by construction of the reregulating dam.

Twenty-five known archeological sites will be irrevocably lost by inundation in Lake Koocanusa; however, salvage of the most promising sites has been completed by the University of Montana. Two additional archeological sites will be inundated if the reregulating dam is con­ structed, unless they are salvaged prior to filling.

Existing natural stream production habitat and wildlife habitat in the reservoir area will be irreversibly and irretrievably committed to use as a reservoir.

Aggregate sources located within the reservoir area will be lost.

Materials and labor used for construction of the project are irrevocably lost. 8. Coordination

Coordination of the project started in about 1949 and has continued at an accelerated pace to the present. Numerous public hearings and public meetings have been held concerning the entire project. Coordi­ nation has been maintained with appropriate State, Federal, county and local agencies on all phases of project planning, design, and construc­ tion.

A public anouncement and a news release were prepared and circulated to advise the public that the draft environmental statement was available for review and comment. The draft environmental statement was provided to the following State, Federal and local agencies and interested groups and citizens and their views and comments are summarize below and copies of the replies are attached.

a. BONNEVILLE POWER ADMINISTRATION

Comment: The statement appears to us to adequately cover the environmental impact of the project.

b. BUREAU OF SPORT FISHERIES AND WILDLIFE

Comment: Basically it (the statement) covers most important points, but in many instances, it seems to be written in a vein designed to cover up problem areas.

Response: All problem areas defined by the Bureau of Sport Fisheries and Wildlife and others are discussed in both the original statement and this revision. (The goal in this statement is to use value-neutral words and phrases rather than "loaded" text).

Comment: It is our understanding that the authorization document for Libby states that "recreation" was a project purpose not "related water uses."

Response: The related water uses referred to in the authorizing document are navigation and recreation. Page 466, paragraph 169 of H.D. 531 states in part: "Primary benefits of flood control and power would accrue from the Libby project. This project would also provide incidental benefits to navagation and recreation." While we realize recreation is an important and valuable asset to the project, the cost and actual provision o:: recreational facilities is borne by the Forest Service. Therefore, no costs for recreation facilities are allocated to Libby Dam and Lake Koocanusa Project. As the authoriza­ tion document made no specific provisions for fish and wildlife, fish and wildlife conservation measures for the project ape evaluated in accordance with provisions of the Fish and Wildlife Coordination Act, as amended. Comment: The major impact of inundating a free flowing river and associated natural resources with a 46,500-acre-fluctuating reservoir should be stated here (paragraph 3a of the summary sheet). We note that you have included this observation in the body of the Environmental Statement.

Response: The major impacts of inundation are discussed in the body of the Environmental Statement under Section 4, "Adverse Environmental Effects Which Cannot be Avoided" and summarized in paragraph 3b of the summary sheet.

Comment: (Summary sheet, paragraph 3b). First sentence, add "and destroy" between "alter" and "fish." Third sentence, replace "the lake" with "project associated waters." Seventh sentence, remove "partial." Eighth sentence, replace with "Authority is being sought to acquire land in fee or under easements and to develop such land in the interest of offsetting some wildlife habitat losses."

Response: The project will not "destroy" the area's fish and wildlife habitat. The phrase "and destroy" appears to be value loaded and non- descriptive of the change that will actually take place. Some habitat will be lost, other areas will change (i.e. river to lake), but much of the area's wildlife habitat will be unaffected. "Project associated waters" has been included in the revised summary sheet. The word "partial" while not entirely proper has been left to better convey to most readers that point that this measure does not complete the miti- gative action. The eighth sentence has been expanded to cover acquis­ ition by easements.

Comment: (Summary sheet, paragraph 4). There should be a statement in this section that informs of alternatives to various parts of the project.

Response: As this is the summary, alternatives are summarized here and explained in more detail in the body of the statement under Section 5, "Alternatives to the Proposed Action."

Comment: (Project Description). "Related water uses" should be "recreation."

Response: Same as response to their second comment.

Comment: White sturgeon should be included as a species within the project area of influence.

Response: All known species inhabiting the Kootenai River are listed. The project area referred to is that area physically occupied by the project, not the project area of influence. However, the paragraph dealing with downstream effects on fish habitat has been expanded and mentions the possibility of affects to white sturgeon. Comment: We wonder if there are five Canadian powerplants downstream of Libby.

Response: The five downstream Canadian powerplants are Corra Linn, Upper Bonnington, Lower Bonnington, South Slocan and Brilliant. B.C. Power is currently planning the installation of a sixth powerplant in the same area.

Comment: Suggest sentence (page 15, paragraph 1, first sentence) be altered to indicate reservoir fluctuations and paragraph be expanded to cover wildlife habitat lost.

Response: These items have been discussed in the statement in the section headed "Adverse Environmental Effects Which Cannot be Avoided."

Comment: The word "lake" should be replaced by the word "reservoir."

Response: The body of water which will form behind Libby Dam has been named Lake Koocanusa by Congressional action.

Comment: The problem of debris disposal is a serious one.

Response: We agree that debris disposal is a serious matter and for this reason, as stated, alternative methods of disposal are being studied.

Comment: "Areas" should follow reservoir. (Page 16, first full para­ graph) .

Response: The referenced paragraph has been revised.

Comment: Page 17, first full paragraph, fourth sentence should be rewritten as follows: "Water released after completion of the project will be clearer during spring runoff than under original free-flowing river conditions due to retention of sediment in the reservoir."

Response: Although there are periods when the Kootenai River in this reach appears clear to the naked eye, it's actually carrying a sedi­ ment load estimated to range between 30 and 100 tons per day. Conser­ vatively, 90 percent of this sediment load is expected to be retained in Lake Koocanusa throughout the year. For these reasons, a change in text is inappropriate.

Comment: The sentence (page 17, first full paragraph, fifth sentence). The sentence sounds as though turbidity from construction activities was insignificant.

Response: This sentence refers only to the dam. Comment on turbidity caused by construction of channel changes in Fisher River and Wolf Creek has been added to Section 4. The turbidity referred to on the Tobacco River was caused by a local gravel operation not connected with the project.

Comment: A minimum release of 2,500 c.f.s. was recommended by con­ servation agencies.

Response: Average natural minimum low flow near the damsite is estimated to be 1,650 c.f.s. compared to our proposed minimum releases of 2,000 c.f.s. Studies of tailwater conditions expected with the project indicate that the difference in stage between the minimum instantaneous flow of 2,500 c.f.s. requested by conservation agencies and the 2,000 c.f.s. now planned would only be about 0.3 foot.

Comment: This paragraph (page 17, second full paragraph) should be expanded to include all wildlife affected by the project.

Response: All known adverse effects to wildlife are discussed in Section 4, "Adverse Environmental Effects Which Cannot be Avoided."

Comment: Suggest this sentence (page 18, first paragraph, first sentence) be rewritten as follows: "Construction of the raregulating dam will destroy an additional 10 miles of Kootenai River and replace it with a widely fluctuating reservoir having little fishery value."

Response: The sentence as written factually and unemotionally expresses the physical results of construction of the reregulating dam. The second paragraph following this one indicates the annual fisherman days to be lost because of its construction. The lake behind the reregula­ ting dam will be more usable and productive of fish than would the river channel with no reregulation of water released for peak power production at Libby Dam.

Comment: Page 18, paragraph 3, should include a statement that wild­ life will be compensated for. It should also be stated that the fluctuating reservoir will have little fishery value compared to the river reaches lost.

Response: This paragraph does state that lands acquired around the periphery of the reservoir will be managed for wildlife habitat to reduce the impact on wildlife. Further, the land acquisition program being considered, as mentioned in Section 4, is expected to partially mitigate all project-caused-wildlife losses. The number of angler- days lost because of construction of the reregulating dam is also contained in this paragraph.

Comment: The 2,800 angler-days of use to be lost was based upon con­ ditions expected without a water quality structure in Libby Dam as now planned. Response: The Corps of Engineers has requested the Bureau of Sport Fisheries and Wildlife to furnish new data on angler-days lost.

Comment: Page 19, first full paragraph: Suggest wording be changed to "no known sites of, etc."

Response: Paragraph has been changed as recommended by the National Park Service.

Comment: The Bureau of Sport Fisheries and Wildlife estimated the fisherman-day and hunter-day losses but the Corps is responsible for the other data in these tables and it should be so stated.

Response: Appropriate footnotes have been added to the table in the revised statement.

ConnnenJt: This Bureau does not consider a fisherman-day of use on a reservoir comparable to a fisherman-day of use on a free-flowing stream.

Response: Same as response to preceding comment.

Comment: Your figure of -8,400 was obviously intended as +8,400. However, to accomplish this degree of mitigation would necessitate more work on tributaries than has been accomplished to date.

Response: Programmed and proposed mitigation measures listed in the table are for the entire project, not just those measures completed. The only mitigation measure which is completed is the construction of rock groins in the channel changes in the Fisher River, Wolf Creek and Fortine Creek, the stream meanders in Wolf Creek and the barrier dam and habitat improvement work on Young Creek. Typographical errors in the table have been corrected.

Comment: Total of unmitigated fishery balance of -250 days make it appear that the project has compensated for all losses when in reality it has not.

Response: The fishery mitigation measures for project caused fishery losses as recommended in the Bureau of Sport Fisheries and Wildlife report are essentially being included in the project. Further evalua­ tion studies and field investigations not included in the Bureau of Sport Fisheries and Wildlife report have also been provided for.

Comment: Under proposed mitigation it should be made abundantly clear that land acquisition in fee is not the only criteria.

Response: This point is covered in the text following the table in the revised statement. Comment: Table 1, in our view, is a conglomerate of estimates that do not reflect the true picture. To date, practically nothing has been done for wildlife and yet, the table looks like all is well.

Response: As previously stated, programmed and proposed mitigation measures listed in the table are for the entire project, not just those measures completed. The Corps of Engineers currently has an agreement with the Forest Service for the implementation of a timber and wildlife habitat management program on about 7,000 acres of National Forest land. In addition, we have two contracts with the Montana Department of Game. One contract concerns a study to deter­ mine the effects of railroad relocation on deer mortality, the other an evaluation of the habitat improvement program being conducted by the Forest Service.

Comment: The dam and reservoir will destroy or eliminate the river, not merely "prohibits free flow."

Response: The word "eliminate" has been added to Section 4 of this revised statement.

Comment: Second sentence (page 21, paragraph 1), should include "upstream" before the words "fish movement."

Response: The recommended wording has been used in the revised statement.

Comment: Page 21, paragraph 2, first sentence: Add the word "prime" before "winter range."

Response: The word "prime" has been included in the revised statement.

Comment: The 12,000 acres of prime winter range is used every winter and is not necessarily "lightly used." Suggest you delete this sentence.

Response: Paragraph 79 of the substantiating report attached to the Bureau of Sport Fisheries and Wildlife report dated 24 February 1965 on the effects of Libby Dam and Lake Koocanusa project on Fish and Wildlife states that "... the 12,000 acres is used only lightly by big game during normal winters." However, in light of the Bureau of Sport Fisheries and Wildlife comment, this sentence has been deleted in the revised statement.

Comment: Add "and poorer winter range" following "reduced habitat."

Response: Paragraph 80 of the above referenced substantiating report does not mention poorer winter range; however, for the reason listed above, the sentence has been changed in the revised statement. Comment: Moisture is misspelled.

Response: Typographical errors in the draft statement have been corrected in the revised statement.

Comment: After "budgeted for" change the wording to "development of land purchases or easements obtained from willing landowners.

Response: This change has been made in the revised statement.

Comment: Add this sentence to the end of paragraph: "The U.S. Forest Service is responsible for wildlife habitat manipulation on its lands and only a small amount of their work can be considered mitigation for losses attributable to Libby project."

Response: The Forest Service is currently conducting extensive and unusual wildlife habitat improvement measures at the specific request of the Bureau of Sport Fisheries and Wildlife and Corps of Engineers. These measures are being funded by the Libby Dam and Lake Koocanusa project as part of the wildlife mitigation. The Bureau of Sport Fisheries and Wildlife acceptance of this method of mitigation is con­ tained in Recommendation 17 of their report on Libby project dated 24 February 1965 and reconfirmed by their letter of 16 March 1967. For these reasons a change in text is inappropriate.

Comment: Should read "Trout and whitefish will not spawn in the reservoir, etc."

Response: The revised statement reflects this change.

Conmient: The 25,000 pounds were to be stocked in project associated waters not only in Koocanusa Reservoir.

Response: The recommeded change has been made in the revised statement.

Comment: Page 27, first incomplete paragraph, fourth full sentence. Should be rewritten as follows: "These new meanders were constructed with the assistance of Montana Department of Fish and Game to partially offset project—caused fish habitat losses in Wolf Creek."

Response: This change has been made in the revised statement.

Comment: Section 4 should be ended with the following paragraph: "The project sponsor and concerned conservation agencies will continue to investigate and determine means of compensating for all project- incurred fish and wildlife losses."

Response: A similar paragraph is contained in the revised statement.

Comment: Add "exclusive of fish and wildlife" to the last sentence, page 29, paragraph 1. Response: This has been added to the revised statement.

Comment: This Bureau dees not agree that the site selected would have the least effect on the environment based on considerations given to fish and wildlife.

Response: The environmental effect of the selected site was based on its cumulative effect on all environmental parameters, not just fish and wildlife. The site selected had the least adverse effect on fish and wildlife of all the sites considered but was not the most favorable site from the standpoint of recreation and aesthetics.

Comment: The 4,750 acres should be replaced with "about 58 miles." This acreage figure, although true, tends to minimize the effects.

Response: The revised statement has been changed to include both acreage and milage.

Comment: The stream fishery value has been estimated in user-days.

Response: The sentence has been modified to clarify its intended meaning.

Comment: How much of the projected recreation use would occur without the project?

Response: The forecast recreation use with the project excludes fisher- man-day and hunter-day use. The majority of use in the project area under preproject conditions was based on fishing or'hunting. While recreational use without the project would increase, increases would be limited by recreational development in the area. Without the project, the Forest Service would not be developing 22 recreation sites in this area. However, recreational use without the project would approach 200,000 visitor days annually within 100 years.

Comment: Add "adverse" after secondary.

Response: Done.

c. BUREAU OF OUTDOOR RECREATION

Comment: The statement is considered satisfactory.

d. NATIONAL PARK SERVICE

Comment: Suggest statement that no sites of archeological importance will be inundated be modified. Response: Suggested changes have been made in the revised statement,

e. BUREAU OF RECLAMATION

Comment: The statement should include a discussion of the possible effect that Libby Dam would have on ground water tables in the Kootenai Flats area.

Response: This discussion has been included in Section 3 of the revised statement.

Comment: An expanded discussion of flood damages to be prevented would be of value in the "Environmental Impact" section.

Response: This discussion has been expanded in the revised statement.

Comment: Transmission facilities to be constructed as a part of the power function need to be identified and related impact discussed.

Response: The Bonneville Power Administration has the responsibility of route selection, design and construction of the transmission facilities from the switchyard to the intertie. As the lead agency in this construction, the Bonneville Power Administration will be discuss­ ing this impact in their environmental statement on the Libby-Conkelley line.

Comment: There needs to be some explanation as to who the downstream users are.

Response: This point has been clarified in Section 1 of the revised statement.

Comment: That part of the 440,000 c.f.s. reduction in flood of record at The Dalles which is attributable to Libby should be clearly identified rather than state only the cumulative benefit of all storage in the Columbia Basin.

Response: The suggested information is contained in Section 3 of the revised statement.

Comment: Suggest rewrite as follows (page 14, second paragraph, first sentence): "... power system to aid in meeting future power require­ ments in the Pacific Northwest."

Response: Recommended change has been included in the revised statement.

Comment: It is not clear whether all 22 planned Forest Service recrea­ tion areas are provided for in the project authorization. Response; The 22 recreation sites will be developed by the Forest Service under their continuing authority for recreational development at projects forming a lake on National Forest lands.

Comment: It appears the figures -8,400 and 15,000 in Table 1 should read +8,400 and +15,000.

Response: These typographical errors have been corrected in the revised statement.

Comment: The portion of Table 1 dealing with wildlife losses, miti­ gation and effect of mitigation assumes habitat improvement measures and land acquisition which are not yet authorized.

Response: The footnote for Table 1 in the revised statement has been changed to clarify that land acquisition is the only measure which may require Congressional authorization.

Comment: The 85- and 100-year floods controlled by Libby are along the Kootenai River only— not the Columbia.

Response: This point has been clarified in the revised statement.

Comment: Suggest clarification of the power produced by Libby Dam.

Response: The suggested change has been made in the revised statement.

Comment: We believe that future "without project" recreation growth needs to be contrasted to the figures shown for "with project" condi­ tions to give reader a better summary of project effect.

Response: Use without the project has been included in the revised statement. The figures shown for recreation with the project are net use or use contributable to the project exclusive of fishing and hunting use. Recreational use without the project would approach 200,000 visitor days annually within 100 years.

Comment: Some shade areas representing previously placed concrete are difficult to distinguish from the white areas representing 1972 con­ crete placement.

Response: Inclosure 2 has been modified in the revised statement,

f. COAST GUARD

Comment: The Coast Guard concurred with the Environmental Statement and pointed out their areas of responsibility with the completed project. g. FEDERAL HIGHWAY ADMINISTRATION

Comment: We assume reconstruction of Montana Route 37 in the area to be inundated by the reregulating dam will be handled similarly to that portion of Route 37 being reconstructed upstream from the main dam; i.e., by Corps of Engineers contracts and State Highway Commission reviews and inspection.

Response: The same procedures will be followed on the reregulating dam highway relocations as have been followed on the MSH 37 relocations on the main project.

Comment: Views to and from the proposed relocation of MSH 37 should be carefully considered.

Response: Final alinement and grade of MSH 37 were made after a field review by the Corps of Engineers and Montana Highway Commission personnel to determine environmental effects. In areas where the effect was detrimental alinement or grade changes were made.

Comment: Positive drainage in highway ditches and culverts should be maintained.

Response: The designed highways meet all standards for provisions of drainage and prevention of soil erosion.

Comment: Close coordination should be maintained with highway officials to minimize disruption to traffic.

Response; The relocation of MSH 37 is being closely coordinated with the State Highway Commission.

Comment: The existing natural features of the surrounding environment should be fully protected to fulfill the basic concepts of aesthetic design, if and when overhead powerline crossings of State Highway 37 are made.

Response: These considerations will be made.

h. NATIONAL MARINE FISHERIES SERVICE

Comment: A statement relating to effects of peaking on the Columbia River system could be noted in your discussion on page 27.

Response: The Columbia River and Tributaries study currently underway will investigate the entire Columbia River system including any environmental impacts attributable to peaking operations at Libby Dam. The revised statement notes possible impacts and indicates that studies are being made. i. FOREST SERVICE

Comment: The discussion in connection with big game range habitat can be further amplified by stating that the objective of the work currently being accomplished to partially mitigate the loss of big game habitat by inundation is to create and sustain winter range on potential winter range sites.

Response: The discussion has been amplified in the revised statement.

Comment: Possibilities of improvements on tributary streams by the installation of rotary screens or fish ladders could potentially insure natural reproduction of some salmonidae.

Response: Stream habitat improvement measures and a barrier dam to block nongame fish intrusion are being presently carried out on Youngs Creek. Similar measures are planned and programmed for other tributaries of Lake Koocanusa. The revised statement has been expanded to discuss this.

Comment: The Forest Service emphasizes that Lake Koocanusa itself, as a recreation attraction resource will increase recreation demand and facilities are being provided by them to take care of the demand.

Response: This is included in the revised statement.

Comment: When full, Lake Koocanusa will be an attractive body of water with the shoreline managed in a near-natural state because of public land ownership and prevention of unplanned, unsightly development.

Response: This point is brought out in the revised statement.

Comment: The Forest Service emphasizes that the planned restrictions on reservoir drawdown during the principal recreation and the removal of stumps around the reservoir are important factors in lessening the adverse impacts of scenic values.

Response: Concur.

j. SOIL CONSERVATION SERVICE

Comment: We have no additional comments to add to the statements provided by the Corps of Engineers.

k. FEDERAL POWER COMMISSION

Comment: The Federal Power Commission concurs with the draft environ­ mental statement and re-emphasizes the future need for power produc­ tion in the Pacific Northwest region. l. DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE

Comment: Libby Dam can be expected to benefit mosquito control around Bonners Ferry to the extent that downstream flooding of Kootenai River is curtailed in the vicinity of Bonners Ferry, Idaho, which historically has had a severe mosquito problem.

Response: This comment has been added to Section 3 of the statement.

Comment: In view of the fact that potential vectors of disease and the "so-called" vectors of misery and discomfort do occur in the project area, appropriate prevention and control measures should be included in project construction and operation.

Response: Appropriate control measures have and will continue to be taken at the project for control of vectors of disease and misery and discomfort. Drainage has been designed so that water will not stand in construction areas. Also, at least one employee at each project is licensed by the State for insect control using State approved measures.

m. MONTANA HIGHWAY COMMISSION

Comment: The Montana Highway Commission concurs with the draft environ­ mental statement and offers the following statements of fact: The contract for Relocation of Montana State Highway 37 was approved by the Montana Highway Commission and signed by the Secretary of State. The Montana Highway Commission believes that their working continually with the Corps of Engineers on all phases of the reconstruction of MSH 37 has had the effect of keeping the environmental impact of reconstruction to a minimum. As noted in the draft environmental statement, an alternate route for MSH 37 to lessen its environment impact was proposed by the Montana Fish and Game Department. After study and consideration, the State’s Natural Resources Advisory Council concluded that the proposed route should be developed. The Governor of Montana concurred with this conclusion.

Response: Construction is proceeding in accordance with state desires.

n. MONTANA DEPARTMENT OF FISH AND GAME

Comment: We believe it would be appropriate to add a statement point­ ing out that the remainder of Highway 37 Project presents perhaps the only significant opportunity to ease the adverse impact that the project is having on the environment.

Response: As stated in the comment by the Montana Highway Commission, the Montana Natural Resources Advisory Council studied and considered the Montana Department of Fish and Game recommendation for an alternate route for MSH 37 and concluded that the original route be developed. The Governor of Montana concurred with this conclusion. To further reduce the adverse environmental effect of construction of MSH 37, design and construction has been coordinated with the Montana Highway Commission, Montana Department of Fish and Game, and the Bureau of Sport Fisheries and Wildlife.

Comment: On page 15, in the first paragraph, we would also like to see the discussion of the habitat losses to fish and wildlife from Lake Koocanusa and associated relocation projects included.

Response: These items are discussed in detail in Section 4, "Adverse Environmental Effects Which Cannot be Avoided."

Comment: Table 1 should accept the net loss for big game habitat until the funds necessary for big game acquisition are secured.

Response: Proposed mitigation measures listed in the table are for the entire project, not just those measures which have been completed. The footnotes to the table have been expanded to clarify that the land acquisition portion of big game habitat replacement may require Congressional authorization. The Corps of Engineers currently has a contract with the Forest Service for the implementation of a timber and wildlife habitat management program on about 7,000 acres of National Forest land and a contract with the Montana Department of Fish and Game for evaluation of the habitat improvement program being conducted by the Forest Service.

Comment: Perhaps it is again time to admit that the project and its associated relocations are making a significant contribution to the possible extinction of a rare and endangered species.

Response: The fact that the bighorn sheep are a rare and endangered species has been added to the revised statement. However, we are unaware' of the existence of any evidence that project effects might significantly contribute to extinction of the species. For example, there is a thriving herd of bighorn sheep approximately 20 miles downstream of the project in the vicinity of Kootenai Falls.

Comment: We would like to see it mentioned in this discussion that the present alinement of the Burlington-Northern mainline was selected over the constant objection of the Montana Fish and Game Department as well as the Bureau of Sport Fisheries and Wildlife. Discussions of our efforts to minimize the losses leads the reader to believe that our agency played a significant role in this relocation.

Response: The text of the revised statement points out this fact.

Comment: I believe that it should be stated in this discussion that through the years numerous objections were raised regarding project design and, practically without exception, environmental considerations were disregarded for project efficiency. Unless this is clearly stated, the reader of this report could draw the conclusion that participating agencies are willing to accept a portion of the responsibility for the environmental damage that is designed into the Libby project.

Response: The location and design of the dam and powerhouse are the responsibility of the Corps of Engineers. The location and design of facilities authorized for relocation are being accomplished by negotia­ tion with the owner of these facilities. In addition, the planning and design of these facilities have been coordinated with appropriate State, Federal and local agencies. While we recognize that some adverse environmental effects are attributable to the project, no environmental damage has been intentionally designed into it. ,

o. MONTANA STATE DEPARTMENT OF HEALTH

Comment: The State Department of Health found the statement to be satisfactory.

p. MONTANA WATER RESOURCE BOARD

Comment: What plans have been made in case of the eventuality of a low intensity earthquake in the Libby Dam area? Also, we are apprehensive that the weight of the lake could pressure a dormant fault into some movement. Has this possibility been foreseen in the design of this dam?

Response: Libby Dam has been designed using moderate to severe seismic forces applied to the dam and lake. During structural analysis, seismic forces were applied to the structure along with the normal forces to verify that the structure would withstand the additional forces that might result from earthquakes. Additionally, the Corps of Engineers have been monitoring seismic activities in the project area since February 1970 to determine general regional seismicity prior to pool raising. The United States Geological Survey has also been studying this activity since early 1971. The two agencies will coordinate their data. In addition to the seismic studies, the Corps of Engineers is establishing 35 gravity stations throughout the region to monitor changes in elevation resulting from pool raising and fluctuations. The information obtained from the gravity stations combined with the regional seismicity studies will give a factual picture of the effect of the project on the earth's crust.

Comment: Has there been any planning along the lines of controlling the subaerial erosion of fine grain sediments in low flat areas exposed during periods of low water?

Response: Except for topsoil, these areas are largely composed of gravel which is not highly erodable. Therefore, no plans have been made to control erosion on the flat areas between the Tobacco River and the Canadian Border. Comment: According to the Montana Bureau of Mines and Geology Bulletin 81, the United States Geological Survey's hydrologists have predicted the possibility of water levels in the aquifer beneath Sophie Lake and Tetrault Lake may rise as much as 30 feet in 10 years time.

Response: A thorough review of the referenced bulletin and discussions with its author does not confirm the contention that the bulletin makes the prediction that the levels of Sophie and Tetrault Lakes will be seriously influenced by the raising of the pool.

Comment: We would like to encourage the Corps to explore every possibility of controlling the algal bloom in the lake.

Response: Reduction of nutrients in the inflow to Lake Koocanusa will reduce the possibility of algal bloom in the lake. The Corps of Engineers is currently cooperating with the British Columbia Pollution Control Branch to determine what measures, if any, are necessary to prevent excessive algal blooms.

Comment: On lakes with steep banks, shorelines tend to slump off into the reservoir. We hope that your planning for the development on this lake will prohibit investments on such shaky terrain.

Response: Areas where sloughing is anticipated will not be developed until several cycles of drawdown have been completed.

Comment: We are not sure that the flooded septic tank will be a serious problem in the lake area due to the sparsity of population.

Response: Design of all ‘publicly owned sanitary' facilities to be constructed around the lake will take ground water levels into considera­ tion and will comply with all regulations governing sanitary facili­ ties. There will be no private development around the lake.

Comment: We would like to urge the Corps of Engineers to have someone study the archeology of any sites that may not have already been studied.

Response: Studies have been completed of sites in the area to be occupied by Lake Koocanusa and representative samples of artifacts recovered. The National Park Service will make arrangements for the study of sites to be inundated by construction of the reregulating dam.

Comment: We encourage the early construction of the reregulating dam below Libby Dam. Both to add continuity to the economic impact and to minimize the adverse environmental factor of surging water levels.

Response: Concur. q. IDAHO WATER RESOURCE BOARD

Comment: Effects Libby Dam operation will have on ground water in the Kootenai Flats area should be discussed in the statement.

Response: A discussion on this subject is contained in the revised statement.

r. IDAHO FISH AND GAME DEPARTMENT

Comment: It is pointed out that the selective withdrawal system will improve the capability of adnering to interstate water quality standards but does not state whether the standards will be met or the predicted degree of deviation from the standards.

Response: Although the Corps of Engineers is unable to predict the degree of deviation from interstate water quality standards, being able to select the elevation from which the water is released will improve the capability of meeting these standards.

Comment: While present waterfowl numbers using Kootenai Flats are comparatively small in relation to historic numbers, most of the 900 acres of remaining waterfowl habitat will be eliminated as a result of the project.

Response: This loss has been noted in the revised statement.

Comment: White sturgeon, while not found in the immediate project area, will be affected downstream by project operation.

Response: The paragraph dealing with downstream effects has been expanded and mentions the possibility that the spawning of white sturgeon may be affected by reduced water temperatures.

Comment: No mention is made of possible adverse effects on spawning as a result of daily stream fluctuations.

Response: Stream flow fluctuations downstream of the reregulating dam are expected to be minimal (less than would occur naturally) and should not adversely affect spawning.

Comment: No figures are shown for maximum fluctuations in elevation of stream surface.

Response: Maximum fluctuations which will be less than under natural conditions are indicated in the revised statement.

Comment: We do not feel that construction of a multi-level outlet structure to meet interstate water quality standards can technically be classified as fisheries mitigation. Response: The Bureau of Sport Fisheries and Wildlife classifies construction of the selective withdrawal system as fishery mitigation. However classified, the selective withdrawal system will substantially reduce the impact on fish in downstream reaches.

Comment: The use figures in Table 1 present annual use or use over the life of the project.

Response: The paragraph preceding the table in the draft statement states that the table summarizes project-caused average annual losses.

Comment: The predicted degree of temperature changes during the fall and spring should be stated.

Response: No prediction is available on the exact degree of temperature changes in the spring and fall.

Comment: There is no mention or discussion of the possibility of nitrogen supersaturation during periods of spill.

Response: The revised statement discusses nitrogen supersaturation and the extent to which this is expected to occur.

Comment: The impoundment behind Libby Dam should be referred to through- out the statement as a reservoir rather than as a "lake."

Response: The body of water which will be formed behind Libby Dam has been named Lake Koocanusa by Congressional action.

Comment: "Alter and eliminate" would be more accurate than "alter fish and wildlife habitat."

Response: The elimination of fish and wildlife habitat in the area occupied by project structures and the lake are clearly pointed out in the statement. On a regional basis, the word "alter" more accurately describes the project-caused changes in fish and wildlife habitat.

Comment: Even with stump removal and clearing, there will be an unavoidable serious adverse visual impact from reservoir drawdown and this fact should be made clear.

Response: During the period of maximum drawdown, few people other than area residents will be using MSH 37. Most years, the lake will be above elevation 2439 during the peak tourist season, exposing less than 20 vertical feet of beach.

Comment: It is not made clear whether the noticeable impact on public schools is good or bad. Response: Undoubtedly there have been both favorable and unfavorable impacts from the influx df people. However, additional school facili­ ties have been provided by the Corps of Engineers to handle the pre­ dicted increased student load. A total of $3,110,800 were expended to construct 72 permanent classrooms or provide 8 temporary classrooms in communities affected by project construction.

Comment: We do not believe that, in this instance, day-use figures are appropriate or accurate means of portraying environmental impacts.

Response: A footnote has been added to Table 1 in the revised state­ ment indicating the higher economic value of stream fishery compared to lake fishery. The table is meant to express the average annual user day difference with and without the project, not the economic value of this use.

Comment: Habitat improvement by the U.S. Forest Service as a result of a timber and wildlife program cannot be considered project mitiga­ tion.

Response: The Forest Service is currently conducting extensive and unusual wildlife measures at the specific request of the Bureau of Sport Fisheries and Wildlife and the Corps of Engineers. These measures are being funded by the Libby Dam and Lake Koocanusa project as part of the wildlife mitigation. The Bureau of Sport Fisheries and Wildlife acceptance of this method of mitigation is contained in Recommendation 17 of their report on Libby Project dated 24 February 1965 and reconfirmed by their letter of 16 March 1967.

Comment: It is impossible to replace inundated habitat.

Response: The word "replace" has been changed in the revised statement.

Comment: It would be helpful if the maximum fluctuation as well as average was stated.

Response: Maximum fluctuation is given in the revised statement.

Comment: Page 29, second paragraph — Reasonably clear cut alternatives such as reduced power output by not constructing the proposed reregu­ lating dam and reservoir regulation for greater recreation and fishery benefits are not mentioned.

Response: Page 30 of the draft environmental statement contained the alternative of foregoing power peaking and not building the reregula­ ting dam. During the period June through September Lake Koocanusa will be regulated for maximization of recreation uses.

Comment: Wildlife habitat is not mentioned as one of the uses of resources that will be permanently removed by project construction. Response: The loss of wildlife habitat has been added to the revised statement.

Comment: While no total value estimate of the stream in its present condition has been made, information contained in the statement makes it abundantly clear that existing fish and wildlife values are much greater than those that will be present after project construction.

Response: None.

Comment: Reservoir impoundment will only add to an already abundant recreational resource while further decreasing stream recreational opportunity which is in comparatively short supply.

Response: The entire shoreline of Lake Koocanusa in the United States will be in public ownership assuring the perpetual availability of the resource for recreational use. The basic recreational uses of the lake will be different than the uses associated with a stream. Also, the size of the lake itself will provide recreational experiences not available at the small lakes found in this region. Forty-eight miles of the Kootenai River in the United States will become a lake; however, approximately 6,000 miles of stream will remain in western Montana.

s. TOWN OF REXFORD

Comment: The location of Montana State Highway 37 along the east Canyon Wall from Five Mile Creek to the Reservoir Bridge does not mention any alternative or any basis whatsoever to justify the environ­ mental destruction and added cost.

Response: Alternative routes were studied prior to the selection of the final route which was the least costly. The route selected was concurred by in the Forest Service, Montana Highway Commission, Montana Natural Resources Advisory Council and the Governor, all of whom were and are concerned with environmental values.

Comment: Access to 100,000 acres of timber land above the Kootenai River is restricted since there has not been any new logging access road approaches constructed along the Forest Development Road.

Response: The Corps of Engineers is not altering the road network except in the area to be occupied by Lake Koocanusa. However, the two road systems serving both sides of the lake will substitute two surfaced roads to serve the area previously served by one surfaced road.

t. MONTANA COOPERATIVE WILDLIFE RESEARCH UNIT

Comment: I fear that depth of snow will limit the usefulness of some of the range improved by the Forest Service. In view of this, I feel strongly that acquisition of private land, to be developed as a replacement wildlife habitat, is the best solution.

Response: The land being improved by the Forest Service is adjacent to presently used winter range on south slopes. Consideration is also being given to the acquisition of private land, in fee or by easement, for development as wildlife habitat.

Comment: I feel that the statement that construction of the project will have no effect on the habitat of the Columbian sharp-tailed grouse may or may not be correct but land acquisition would probably be the only way to replace the types of vegetation that sharp-tails need during winter.

Response: No consideration is being given to land acquisition for the development of sharp-tailed grouse habitat.

u. LINCOLN COUNTY COMMISSION

No comments received.

v. FEDERAL RAILROAD ADMINISTRATION

No comments received.

w. ENVIRONMENTAL PROTECTION AGENCY

No comments received.

x. IDAHO DEPARTMENT OF HEALTH

No comments received.

26 Incl 1. Location Map 2. Concrete Placement Chart 3. Burlington-Northern Line Change 4. Highway and Road Relocation 5. Major Northwest Recreation Areas 6. Damsite View 7. Bonneville Power Administration, 7 July 1971 8. Bureau of Sport Fisheries & Wildlife, 30 June 1971 9. Bureau of Outdoor Recreation, 2 July 1971 10. National Park Service, 21 June 1971 11. Bureau of Reclamation, 2 July 1971 12. United States Coast Guard, 29 June 1971 13. Federal Highway Administration, 2 July 1971 14- National Marine Fisheries Service, 12 July 1971 15. Forest Service, 21 July 1971 16. Soil Conservation Service, 29 June 1971 and 22 July 1971 17. Federal Power Commission, 29 June 1971 18. Department of Health, Education and Welfare, 30 July 1971 19. Montana Highway Commission, 9 July 1971 20. Montana Department of Fish and Game, 19 July 1971 21. Montana State Department of Health, 22 June 1971 22. Montana Water Resources Board, 12 July 1971 23. Idaho Water Resource Board, 7 July 1971 24. Idaho Fish and Game Department, 8 July 1971 25. Town of Rexford, 7 July 1971 26. Montana Cooperative Wildlife Research Unit, 6 July 1971

United States Department of the Interior

BONNEVILLE POWER ADMINISTRATION

PORTLAND, OREGON 97208

JUL 7 1971

Mr. Pred H. Weber Assistant Chief, Engineering Division Department of the Army Seattle District, Corps of Engineers 1519 Alaskan Way South Seattle, Washington 98134

Dear Mr. Webers

We have reviewed your draft Environmental Statement for impacts associated with the Libby Dam and Lake Koocanusa Project, as requested in your letter of June 8. The Statement appears to us to adequately cover the environ­ mental impact of the project.

This information is offered only to provide assistance in preparing your Environmental Statement. Formal Interior Department comments as specified in Section 8 of the Council on Environmental Quality Guidelines should be obtained directly from the Secretary of the Interior.

a Sincerely,

Administrator United States Department of the Interior FISH AND WILDLIFE SERVICE BUREAU OF SPORT FISHERIES AND WILDLIFE

730 N. E. PACIFIC STREET P. O. BOX 3737 PORTLAND, OREGON 97208

June 30, 1971

District Engineer Seattle District, Corps of Engineers 1519 Alaskan Way South Seattle, WA 98134

Dear Sir:

This is in response to your letter dated June 8, 1971, requesting our views on your draft environmental statement for Libby Dam and Reservoir project.

We appreciate the difficult task that your agency had in developing this rough draft. We hope our comments will be helpful. Basically it covers most important points, but in many instances, it seems to be written in a vein designed to cover up problem areas.

These comments are for your consideration during your review of the en­ vironmental statement and do not constitute this Bureau's formal analy­ sis under provisions of P.L. 91-190.

The following corrections and suggestions are offered for your con­ sideration in preparing a final draft environmental report for Libby project.

Page 1, para. 2: Description of Action: It is our understanding that the authorization document for Libby states that "recreation" was a project purpose not "related water uses." Fish and wildlife have not been considered, as a project purpose, but certainly they would be considered a related water use.

Page 1, para. 3a: Environmental Impacts: The major impact of inundating a freeflowing river and associated natural resources with a 46,500-acre fluctuating reservoir should be stated here. We note that you have in­ cluded this observation in the body of the environmental statement. Page 1» para. 3b: Adverse Environmental Effects: First sentence add "and destroy" between "alter" and "fish." Third sentence, replace "the lake" with "project associated waters." Seventh sentence, remove "partial." Eighth sentence, replace with "Authority is being sought to acquire land in fee or under easements and to develop such lands in the interest of offsetting some wildlife habitat losses."

Page 2, para, 4: Alternatives: There should be a statement in this sec­ tion that informs of alternatives to various parts of the project such as: (1) State highway 37 on the east side of the reservoir could have been eliminated and the U. S. Forest Service road on the west side of the reservoir designed to accommodate all travel, (2) the railroad could have been placed on a less damaging route as far as the environ­ ment is concerned, (3) the reregulating dam might not be needed even if additional units are added, (4) operation plans might be re-evaluated to accommodate other purposes than power production and flood control, (5) sections of abandoned railroad bed above the reservoir might be re­ claimed for wildlife, i.e., planting browse species for big game winter range, etc., (6) etc.

Undoubtedly the total number of such alternatives would be large and should be given consideration even if they are not listed in this statement.

Para. 1, Project Description. Sentence four: "Related water uses" should be "recreation." In our view, Congress intended that recreation include fish and wildlife but the Corps interpretation excluded them. Fish and wildlife features and their administration should be mentioned here.

Page 11, first full para.: White sturgeon should be included as a species within the project area of influence. Project effects are related to more than tne immediate project area. For example, project- incurred water quality changes will affect to some degree fishlife, including sturgeon, for many miles downstream.

Page 14, first full para., second sentence: We wonder if there are five Canadian powerplants downstream of Libby.

Page 15, para. 1, first sentence: Suggest sentence be altered as follows: "Creation of Lake Koocanusa will, in the United States, re­ place 48 miles of Kootenai River with a 28,850-acre fluctuating reser­ voir. . ." This paragraph should also mention the estimated 12,000 acres of critical big game winter range that will be inundated, and additional thousands of habitat acres destroyed by campgrounds, high­ way relocations, etc. Page 15, para. 2, first sentence: The word "lake" should be replaced by the word "reservoir."

Page 15, para. 3: The problem of debris disposal is a serious one. Disposal proposed by tilling will require a rather large area in view of the tremendous amount of debris expected. Damage to wildlife habi­ tat and erosion problems could be significant.

Page 16, first full para.: "Areas" should follow reservoir.

Page 17, first full para., fourth sentence should be rewritten as follows: "Water released after completion of the project will be clearer during spring runoff than under original freeflowing river conditions due to retention of sediment in the reservoir." There are times in the winter when Kootenai River is clear in this reacii.

Page 17, first full para., fifth sentence: The sentence sounds as though turbidity from construction activities was insignificant. Channel changes along Fisher River, Wolf Creek, and the subcontractor's operations along the Tobacco River created significant turbidity.

Page 17, first full para., last sentence: A minimum release of 2,500 cfs was recommended by conservation agencies.

Page 17, second full para.: This paragraph should be expanded to in­ clude all wildlife affected by the project. Limiting comments in this section to sharp-tailed grouse habitat grossly neglects a major project environmental impact the Droject will have on wildlife habitat in the United States alone. The paragraph is essentially correct; however, Columbiaisharp-tailed grouse have been observed in habitat to be inun­ dated by the reservoir. The project might have accomplished something for this endangered species through land acquisition or leasing and development as partial replacement for the large amount of ruffed grouse habitat inundated by the reservoir. We suggest replacing this paragraph as follows: "Construction of the project will result in the destruction of about 28,000 acres of wildlife habitat in the United States. Heavy losses will occur to a variety of upland game, songbirds, big game, fur animals, and other wildlife dependent upon this habitat. Wildlife los­ ses of a similar magnitude are expected from reservoir inundation of upstream Kootenai River flood plain in Canada."

Page 18, first para., sentence one: Suggest this sentence be rewritten as follows: "Construction of the reregulating dam will destroy an additional ten miles of Kootenai River and replace it with a widely fluctuating reservoir having little fishery value." Page 18, para. 3, should include a statement that wildlife will be compensated for. It should also be stated that the fluctuating reservoir will have very little fishery value compared to the river reaches lost.

Page 19, partial para., top of page: The 2,800 angler-days of use to be lost was based upon conditions expected without a water quality structure in Libby Dam as now planned.

Page 19, first full para.: Suggest wording be changed to "no known sites of, etc.,"

Page 20, table 1: The Bureau of Sport Fisheries and Wildlife esti­ mated the fisherman-day and hunter-day losses but the Corps is responsible for the other data in these tables and it should be so stated.

Table 1, item 1: This Bureau does not consider a fishenrtan-day of use on a reservoir as being of comparable quality or even economic value as a day's fishing in a freeflowing river. We believe the table is mis­ leading unless tiiis qualitative difference is expressed.

Table 1, item 2: Your figure of -8,400 was obviously intended as +S,4G0. However, to accomplish this degree of mitigation would necessitate more work on tributaries than has been accomplished to date.

Table 1: Total of unmitigated fishery balance of -250 days makes it appear that the project has compensated for all losses when in reality it has not.

Page 21, table 1, Big Game: Under proposed mitigation it should be made abundantly clear that land acquisition in fee is not the only criteria. Easements are probably our best opportunity in most instances. Wildlife habitat development would also be a very important part of our proposal for this land.

Table 1, in our view, is a conglomerate of estimates that do not reflect the true picture. To date, practically nothing has been done for wild­ life and yet the table looks like all is well.

P3ge 21, first para., first sentence: The dam and reservoir will destroy or eliminate the river not merely "prohibits freeflow." Second sentence should include "upstream" before the words "fish movement."

Page 21, para. 2, first sentence: Add the word "prime" before "winter range."

Page 21, para. 2, third sentence: The 12,000 acres of prime winter range is used every winter and is not itcessarily "lightly used." Suggest you delete this sentence. Page 21, para. 2, fifth sentence: Add "and poorer winter range" fol­ lowing "reduced habitat.:

Page 22, para. 1, third sentence: "Moisture" is misspelled.

Page 22, para. 1, fifth sentence: After "budgeted for" change the wording to "development of land purchases or easements obtained from willing landowners."

Page 22, para. 1: Add this sentence to the end of paragraph. "The U. S. Forest Service is responsible for wildlife habitat manipulation on its lands and only a small amount of their work can be considered mitigation for losses attributable to Libby project."

Page 22, para. 2, sentence two: The word "lake" should be replaced with the word "reservoir."

Page 22, para. 2, sentence three: Should read "Trout and whitefish will not spawn in the reservoir, etc."

Page 23, top partial para., second and third sentences: "Lake" should be "reservoir." Many of the cold water game fishes will spawn in natural lakes but few spawn in widely fluctuating reservoirs. It seems you are demeaning the biological sense of the word lake in these instances.

Page 23, first full para., first sentence: The 25,000 pounds were to be stocked in project associated waters not only in Koocanusa Reservoir.

Page 25, first full para., first sentence: "Odor" is spelled wrong. Also, third sentence "lignins" is also misspelled.

Page 27, first incomplete para., fourth full sentence: Should be re­ written as follows: "These new meanders were constructed with the assistance of Montana Department of Fish and Game to partially offset project-caused fish habitat losses in Wolf Creek."

Page 28: Adverse Environmental Effects Which Cannot be Avoided: End this section with the following paragraph: "The project sponsor and concerned conservation agencies will continue to investigate and deter­ mine means of compensating for all project-incurred fish and wildlife losses."

Page 28, Alternatives to the Proposed Action: First sentence— alter­ native should be plural and "project o£ construction" should be "project or construction." Second sentence also has an "of" instead of an "or."

Page 29, para. 1: Add "exclusive of fish and wildlife" to the last sentence. Page 30, para. 2, second sentence: This Bureau does not agree that the site selected would have the least effect on the environment based on considerations given to fish and wildlife.

Page 30, last partial para.: The 4,750 acres should be replaced with "about 58 miles." This acreage figure, although true, tends to minimize the effects.

Page 31, second sentence: This is incorrect. The stream fishery value has been estimated in user-days.

Page 32, para. 1, sentence one: How much of the projected recreation use would occur without the project? This projection is misleading as it infers that all recreation use is related to project construction.

Page 32, para. 1, second sentence: Replace word "lake" with "reservoir."

Page 32, para. 1, line 11: Add "adverse" after secondary.

Page 33, fourth para.: "Project" misspelled.

We appreciate the opportunity to comment on your draft statement.

Sincerely yours,

Regional Director UNITED STATES DEPARTMENT OF THE INTERIOR BUREAU OF OUTDOOR RECREATION PACIFIC NORTHWEST REGION IOOO SECOND AVENUE SEATTLE. WASHINGTON 98104

J U L ?. 1971

Colonel Howard L. Sargent, Jr. District Engineer Seattle District, Corps of Engineers 1519 Alaskan Way South Seattle, Washington 98134

Dear Colonel Sargent:

Wa have reviewed the draft environmental statement for the Libby Dam and Lake Koocanusa Project, Montana, as requested in your letter of June 8, 1971. In general, the draft appears to be satisfactory for the purposes of this office's interest in outdoor recreation and aesthetic considerations. We have no further comments at this time.

Sincerely yours,

Ernest E. Allen Acting Regional Director UNITED STATES DEPARTMENT OF THE INTERIOR NATIONAL PARK SERVICE

WESTERN SERVICE CENTER 450 GOLDEN GATE AVENUE, BOX 36025 SAN FRANCISCO, CALIFORNIA 94102 June 21, 1971

Mr. Fred Weber, Assistant Chief Engineering Division Corps of Engineers U.S. Army District, Seattle 1519 Alaskan Way South (Pier 30) Seattle, Washington 98134

Dear Mr. Weber:

Thank you for allowing us the opportunity to comment on the preliminary draft of the environmental statement for the pro­ posed Libby Dam Project.

The statement on page 19 of the draft that no sites of archeo­ logical importance will be inundated should perhaps be quali­ fied. A number of sites will indeed be inundated. However, archeological survey and salvage excavations conducted by the University of Montana succeeded in recovering a representative sample of the archeology of the reservoir area. Thus, no fur­ ther work will be required.

Sincerely yours,

Paul J. F. Schumacher Chief, Archeological Investigations UNITED STATES DEPARTMENT OF THE INTERIOR BUREAU OF RECLAMATION

REGIONAL OFFICE. REGION I BOX 8 0 0 8 BOISE. IDAHO 83707

' ^ <4 A 171

Mr. Fred H. Weber, Assistant Chief Eng. Division, Dept, of the Am\y Seattle District, Corps of Engineers 1519 Alaskan Way South Seattle, Washington 98134

Dear Mr. Weber:

We have reviewed the preliminary draft environmental statement for the Libby Dam and Lake Koocanusa Project as requested in your letter of June 10.

Our specific comments on the preliminary draft environmental statement follow:

1. In view of present concern at the local level, the statement should include a discussion of the possible effect that Libby Dam would have on ground water tables in the Kootenai Flats area. Farm operators in that area are concerned that operation of Libby storage will disrupt their present ground water condition. This subject was briefly covered by the Corps' Seattle District Office in a Public Information Bulletin dated April 30, 1971, which was prepared for use in conjunction with a June 7, 1971, Public Information Meeting at Bonners Ferry. Investigations made to date on the possible effect of Libby on the water table and con­ clusions drawn from these investigations should be mentioned in the final statement.

2. An expanded discussion of flood damages to be prevented would be of value in the "Environmental Impact" section.

3. Transmission facilities to be constructed as a part of the power function need to be identified and related impact discussed.

4. Page 4, 2nd full paragraph, 1st sentence. Reference is made to "downstream users." There needs to be some explanation as to who the affected downstream users are. 5. Page 14, 1st paragraph. That part of the 440,000 c.f.s. reduc­ tion in flood of record at The Dalles which is attributable to Libby should be clearly identified rather than state only the cumulative benefit of all storage in the Columbia basin.

6. Page 14, 2nd paragraph, 1st sentence. Suggest rewrite as follows: "... power system to aid in meeting future power requirements in the Pacific Northwest."

7. Page 15, 2nd paragraph, 2nd sentence. It is not clear whether all 22 planned Forest Service recreation areas are provided for in the project authorization. If so, this fact should be stated. If not, a note regarding required authorization should be added.

8. Page 20, table 1. It appears that the figures -8,400 and 15,000 should read +8,400 and +15,000.

9. Page 21, table 1 continued. The portion of table 1 dealing with wildlife losses, mitigation and effect of mitigation assumes habitat improvement measures and land acquisition which are not yet authorized. We would suggest that the status of obtaining authorization for this feature, if action is in fact being taken, be stated in footnote 1. If there is no action being taken, we suggest that the effect of these unauthorized measures be deleted from the table and the footnote expanded to include the effects should authorization be realized.

10. Page 31, paragraph 5. On page 13, the 85- and 100-year floods controlled by Libby are along the Kootenai River only— not the Columbia.

11. Page 31, last paragraph, 1st sentence. This sentence implies initial generation facilities at Libby Dam would add 854,000 kw. of firm power. On page 14, power production at Libby Dam is shown as 270,000 kw. Suggest rewrite as follows: "Operation of Lake Koocanusa after instal­ lation of initial generating facilities would add 854,000 kw. of firm power to the PNWPS."

12. Page 32, 1st paragraph, 1st sentence. We believe that future "without project" recreation growth needs to be contrasted to the figures shown for "with project" conditions to give reader a better summary of project effect.

13. Enclosure 2, Libby Dam - Concrete Placement Chart. Some of the shaded areas representing previously placed concrete are difficult to distinguish from the white areas representing 1972 concrete place­ ment (see columns 28 through 32).

The opportunity to review this statement is appreciated.

Sincerely,

Regional Director DEPARTMENT OF TRANSPORTATION Address reply to: COMMANDER (dpa) UNITED STATES COAST GUARD Thirteenth Coast Guard District 618 Second Ave. Seattle, Wash. 98104

2 9 JUN 1971 Mr. Sydney Steinborn Chief Engineering Division Seattle.District, Corps of Engineers 1519 Alaskan Way South Seattle, Washington 98134

Dear Mr. Steinborn:

The Draft Environmental Statement, concerning the Libby Dam and Lake Koocanusa Project, has been reviewed by the Commander, 13th Coast Guard District, Seattle, Washington, and the Coast Guard has no adverse comment concerning the Corps of Engineers' preliminary draft environmental statement relating to that proj ec t .

It is to be noted, however, that inasmuch as Lake Koocanusa will extend into British Columbia, Canada, the waters of the lake will be international, and therefore deemed to be navi­ gable waters of the United States. In this regard, the de­ velopment of this project will have impact upon the following Coast Guard areas of responsibility:

a. Aids to Navigation.

b. Law Enforcement (Recreational Boating).

c. Merchant Marine Safety.

In particular, the operation of passenger and freight carrying vessels will require inspection, licensing, and will be sub­ ject to the law enforcement responsibilities of the U. S. Coast Guard.

Sincerely,

j . j . M c C l e l l a n d Rear Admiral, U. S. Coast Guard Commander, 13th Coast Guard District U. S. DEPARTMENT OF TRANSPORTATION FEDERAL HIGHWAY ADMINISTRATION Room 412 Mohawk Building 222 S. W. Morrison Street Portland, Oregon 97204

July 2, 1971

IN REPLY REFER TO 08-00.36

Re: Your letter of June 8, 1971 Code NPSEN-PL-ER

Mr. Fred H. Weber Assistant Chief, Engineering Division Department of the Army Seattle District, Corps of Engineers 1519 Alaskan Way South Seattle, Washington 98134

Dear Mr. Weber:

We have reviewed your draft environmental statement for the Libby Dam and Lake Koocanusa Project as requested by your letter of June 8, 1971.

Our interests and areas of concern relate to the various highways and bridges within the project area that are on the Federal-aid system. In checking with our Division Engineer in Helena, Montana, the following comments are noted for your review and consideration:

"Construction of the reregulating dam some ten miles below the main dam will necessitate reconstruction of Montana Route 37. A portion of this route which was constructed as Forest Highway Project 57-1(1) and completed in 1968 will be inundated. We assume reconstruction of Montana Route 37 will be handled similarly to that portion of Route 37 being reconstructed upstream from the main dam; i.e., by Corps of Engineer contracts and State Highway Commission reviews and inspection."

You may wish to consider the following comments in addition to the above:

Views to and from the proposed relocation of SH 37 should be carefully considered when selecting the alignment and final grade line, especially as to how these views would relate to the various project elements and the total environmental setting. Mr. Fred H. Weber July 2, 1971

Positive drainage in highway ditches and culverts should be main­ tained. Soil erosion and water pollution control features should be incorporated in the detailed design plans to ensure conditions satisfactory to the Montana State Highway Commission both during and after construction.

Close coordination should be maintained with highway officials to minimize disruption to traffic and to avoid unsafe conditions for motorists.

The existing natural features of the surrounding environment should be fully protected to fulfill the basic concepts of aesthetic design, if and when overhead powerline crossings of State Highway 37 are made. Tower design, siting, and construction should be care­ fully considered to minimize visual and physical impact on the landscape and to maintain or enhance views to and from the road.

Very truly yours,

BAL$H M. PHILLIPS Regional Administrator U.S. DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration National Marine Fisheries Service 6116 Arcade Building Seattle, Washington 98101

jUl 1 2 1971

District Engineer, Seattle District Corps of Engineers 1519 Alaskan Way South Seattle, Washington 98134

ATTENTION: Fred H. Weber, Assistant Chief Engineering Division

Dear Sir:

Reference is made to your letter of June 8, 1971, and the environmental impact report associated with the Libby Dam and Lake Koocanusa Project located on the Kootenai River in Montana.

In general, this project is out of the responsibility of the National Marine Fisheries Service. We are, however, concerned about water re­ leases downstream from the project and the need for an overall evalua­ tion of storage and peaking from this and other projects in the Columbia Basin. A statement relating to peaking could be noted in your discussion on page 26.

These comments express evaluation by the National Marine Fisheries Service scientists in the region. Formal response to this environ­ mental impact statement will be made by the Department of Commerce, Washington, D.C.

Sincerely yours,

Regional Director U n i t e d S t a t e s D e p a r t m e n t o f A g r i c u l t u r e FOREST SERVICE

N o r t h e r n R e g i o n ADDRESS REPLY TO F e d e r a l B u i l d i n g REGIONAL FORESTER M i s s o u l a . M o n t a n a s s s o i ANO REFER TO 2140

July 21, 1971

District Engineer U. S. Army, Corps of Engineers 1519 Alaskan Way South Seattle, Washington 98134

Dear Sir:

Reference is made to your letter of June 8, 1971, designated NP-SEN-PL-ER, requesting our comments on your preliminary environmental statement for Libby Dam and Lake Koocanusa project, requiredby section 102(2)c of PL 91-190. Our comments follow.

The discussion in connection with big game range habitat can be further am­ plified by stating that the objective of the work currently being accomplished to partially mitigate the loss of big game habitat by inundation is to create and sustain winter range on potential winter range sites.

Improvement to date has been limited to thinning of timber stands to stimulate browse reproduction. Evaluation of these improvement measures are currently being made. If research shows the improvement to be successful it will be necessary to maintain the areas.

There has been very little mention made of the tributary streams which feed the reservoir. Such streams as Youngs Creek and Graves Creek are presently Dolly Varden and cutthroat spawning streams. Possibilities of improvements on streams, such as above, by the installation of rotary screens or fish ladders, could potentially ensure natural reproduction of some salmonidae.

On page 15 of the Environmental Statement draft, the second paragraph in­ dicates that recreation use will be increased because of the planned recrea­ tional development. The reservoir itself, as a recreation attraction resource, will increase this demand and facilities are being provided to take care of the demand.

As an expansion of the material covered under item 3 - The Environmental Impact of the Proposed Action, we suggest that further consideration be given to aesthetics or natural beauty. When full, the reservoir will be an attract­ ive body of water provided the shoreline can be managed in a near-natural state. Due to public landownership, the aesthetic qualities of the shoreline can be maintained in a near-natural state by proper planning and prevention of unplanned, unsightly developments. There are also two primary measures to be considered in mitigating the loss of scenic values. First, if possible, is to hold the reservoir drawdown to a minimum during the principal recreation season of July 1 to August 31. Secondly, the removal of stumps, now being accomplished, will be an important factor in lessening the adverse impacts of scenic values.

We appreciate the opportunity to review the Draft Environmental Statement for Libby Dam and Lake Koocanusa.

Sincerely,

SHERWOOD C. TROTTER Chief, Division of Soil, Air, and Water Management UNITED STATES DEPARTMENT OF AGRICULTURE SOIL CONSERVATION SERVICE P. 0. Box 970, Bozeman, Montana 59715

June 29, 1971

Mr. Fred H. Weber Assistant Chief Engineering Division Corps of Engineers 1519 Alaskan Way South Seattle, Washington 98134

Dear Mr. Weber:

We have reviewed the environmental statement prepared by your agency for the Libby Dam and Koocanusa Project.

We have no additional comments to add to the statements provided by the Corps.

Thank you for the opportunity to comment.

Sincerely,

A. B, Linford State Conservationist UNITED STATES DEPARTMENT OF AGRICULTURE SOIL CONSERVATION SERVICE Room 345, 304 No. 8th Street Boise, Idaho 83702

July 22, 1971

Mr. Sydney Steinborn Chief, Engineering Division Corps of Engineers 1519 Alaskan Way South Seattle, Washington 98134

Dear Mr. Steinborn:

Thank you for the opportunity to review your environmental state­ ment for the Libby Dam and Lake Koocanusa Project.

We have no comment to make at this level. Due to the large area affected by the proposed project, we have forwarded the statement to our Washington office for their review.

Creighton N. Gilbert, Assistant State Conservationist for Water­ sheds, has been assigned responsibility in this office for environ­ mental statements.

Sincerely yours,

Gay W. Nutt State Conservationist F e d e r a l p o w e r C o m m i s s i o n REGIONAL OFFICE 555 BATTERY STREET. ROOM 415 SAN FRANCISCO, CALIF. 94111

June 29, 1971

Fred H. Weber Assistant Chief, Engineering Division Seattle District, Corps of Engineers 1519 Alaskan Way South Seattle, Washington 93l3U

Dear Mr. Weber:

This is in reply to your letter of June 8 , 1971, requesting comments of the Federal Power Commission on the preliminary draft of the environ­ mental statement for the Libby Dam and Lake Koocanusa Project on the Kootenai River.

Pursuant to the National Environmental Policy Act of 1969 , and the role of expertise assigned to the Federal power Commission as designated in the memorandum of July 29, 1970, of the Council of Environmental Quality, the comments herewith are directed to the relationship of the electrical capacity of these units, to the prospective power supply and demand situation of the systems and region involved, to the fuel supply situation related to the type of plant and its environmental effects; and to comment on alternative means of meeting the power supply needs for which these units are proposed. It is understood that other agencies will review and comment on specific aspects relating to effects of the units on air and water quality, and other environmental factors.

(1) The Need for Power in the Area

To determine the need for power in the area necessitates an appraisal of the future power resources and requirements of the Pacific Northwest area. An annual projection of power loads and resources is prepared by the Subcommittee on Loads and Resources of the Pacific Northwest Utilities Conference Committee (PNUCC). The most recent of the subcommittee's reports is the "West Group Forecast of Power Loads and Resources, 1971-72 through 19 8 1 -8 2 ," dated May 3, 1971, which revises part of a previous report dated April 9, 1971, which included a forecast for the period 1971-72 through 1990-91. Mr. Fred H. Weber June 29, 1971

In a recent statement to the Appropriations Subcommittees of Congress, the Chairman of the PNUCC expressed great concern about the precarious power situation the entire region is facing in the mid 19 70 's and in later years. It is shown in the April report that although the total firm requirements virtually triple in the years 1971-19 9 1, the total resources merely double during the same period. Loads and resources indicate a general deficiency throughout the period of both reports based on the assured resources of the West Group Forecast.

According to present scheduling, Libby's initial four units will be completed in April of 1976. Energy surpluses exist for the years 1975-76, 1976-77, and 1977-78 resulting from installation of Hanford #2 and increased energy imports from California utilities through peak-energy exchange contracts. Energy deficits commence again in 1978-79 and increase there­ after to about 15,000 megawatts by 1990-9 1 .

There is little doubt that additional capacity will be required to serve electric loads in the Pacific Northwest region by the time the proposed project begins operating.

(2) A Possible Alternative Power Source

In order to determine a possible alternative power source, future plant factors must be ascertained. Kootenai River diversions provided for in the Columbia River Treaty make the future uncertain. If the Treaty Diversions are consummated, the following plant factors would result:

Libby Dam Project l/ (8 units - 966,000 kW 2/)

Assumed Water Conditions: Effective Annual Plant Average Annual Date Factor ( r>)

No Diversion 25 1st Sept. 1984 21 2nd Sept. 202U 7.5 3rd Sept. 29U+ 1+

Critical Period

No Diversion 20.5 1st Sept. 1931+ 17 2nd Sept. ?Q?l 6 3rd Sent. 20UU p 1/ Partial table extracted from Corps of Engineers' report "Libby Dam Project, Number and Size of Units, September 19 65."

?J II59 of nameplate capacxty (dependable peaking capacity). Mr. Fred II. Weber June 29, 1971

Informed sources relate that the first diversion, in all likelihood, will be provided in the Columbia River Treaty. In this event, the annual plant factor would be 17-21 percent with the ultimate eight unit instal­ lation, and for the initial four unit installation, would be in the 35-bO percent range.

Based on our estimates of power values at-site for the Pacific North­ west region, the most economic alternative power source would be a peak­ ing, oil-fired, steam-electric generating plant located northeast of Portland. Calculations for hydroelectric plant power values at-site were based on composite financing; i.e., 25 percent private and 75 percent public non-federal.

(3) The Fuel Situation Relative to Such Alternative Power Source

In the Pacific Northwest region, oil is expected to be available in sufficient quantities to fuel an oil-fired plant for at least its 30-35 year life. Oil reserves in the immediate market region are limited, but for the next several decades imports, shale oil, and especially oil from Western Canada and Alaska, assure sufficient oil to meet total require­ ment. If future regional policy dictates the necessity of burning low sulphur oil, it must be imported from either Indonesia or Alaska.

With regard to foreign oil, its availability and price depend on United States import restrictions, as well as the world supply and demand for petroleum products. Availability of Alaskan low-sulphur oil is largely dependent on solution of the North Slope pipeline problem, or adoption of some feasible alternative. Its future price cannot be estimated at this time.

(4) The Effect of the Project on Downstream Thermal-Electric Power Projects

The Hanfwrd Nuclear Plant, owned by the Washington Public Power Supply System, is the only existing downstream thermal-electric power project. It is located far downstream with a number of large hydroelectric plants and reservoirs intervening between it and Libby so that Libby operation will have no effect on Hanford operations.

These informal comments are those of the San Francisco Regional Office, and have not been approved by our Washington office. They may differ from formal comments which they may wish to make.

Sincere^ you>?

Robert H. Jr u i n Acting Regional Enginee^ DEPARTMENT OF HEALTH. EDUCATION. AND WELFARE REGION VIII FEDERAL OFFICE BUILDING

19th AND STOUT STREETS DENVER. COLORADO 80202

July 30, 1971

Chief, Engineering Division Dept, of the Army Seattle District, Corps of Engineers 1519 Alaskan Way, South Seattle, Washington 98134

Dear Sir:

This is in response to your letter of June 8, 1971 addressed to Mr. Bernard E. Kelly in which you requested review of your draft environmental statement for the Libby Dam and Lake Koocanusa Project.

It is noted that Libby Dam and Lake Koocanusa will be located on the Kootenai River about 17 miles upstream from the town of Libby, Montana. This is a multiple project authorized for flood control, at site power generation, recreation and related water uses.

Because of the generally steep shoreline of the reservoir basin and the anticipated draw down of the lake to furnish hydroelectric power, relatively little adverse effects on mosquito production are anticipated as a result of project development. There may possibly be some need for selective shoreline modification in some of the flatter upstream portions of the reservoir and in embayments that are protected from wave action to minimize mosquito production, particularly where mosquitoes would inter­ fere with recreational activities.

Historically, the town of Bonners Ferry, Idaho has had a severe mosquito problem. Innundation of surface depressions along the flood plain of the Kootenai River by the annual spring runoff results in tre­ mendous production of vicious biting Aedes mosquitoes including Aedes Canadens is. A. cinereous. A. excrucians. A. fitchii, A. flavescens. A. ^ticticus, and A. vexans. A mosquito abatement district was established in the Bonners Ferry area about 1966 in a not too successful endeavor to alleviate this mosquito problem. The Libby Dam can be expected to benefit mosquito control around Bonners Ferry to the extent that downstream flood­ ing of the Kootenai River is curtailed in the vicinity of this community.

Based on previous surveys, it is known that other vectors such as ticks, deerflies, blackflies, biting gnats, and fleas are prevalent in the general area of the proposed project. Likewise rabbits and wild rodents, including the Columbian ground squirrel, the long tailed deer mouse, the golden mantle ground squirrel, chipmunks, and various other species of wild mice occur in the project area. These rabbits and wild rodents are reservoirs of organisms that cause tularemia, plague, Rocky Mountain spotted fever, relapsing fever, and California encephalitis virus. The presence of these host reservoirs and their respective arthropod vectors constitute a hazard to public health which may be expected to increase as recreational areas are developed and larger numbers of people frequent the project area and are consequently exposed to these vectors and the disease organisms they carry.

During the Boy Scout Jamborees held at Farragut State Park during 1967 and 1969 yellow jacket wasps occurred in such large numbers as to seriously interfere with scout activities. In order to protect scouts from wasp stings, control measures had to be carried out. It is anticipated that similar yellow jacket wasp problems will occur at recreational areas around Lake Koocanusa.

In view of the fact that potential vectors of disease and the "so-called" vectors of misery and discomfort do occur in the project area, appropriate prevention and control measures should be included in project construction and operation.

When your agency develops a revised environmental statement as required by Sec. 102 (2)(c) of the National Environmental Policy Act, it is requested that you send your request for comments to this office.

Sincerely yours,

William T. Van Orman Regional Director, DHEW MONTANA HIGHWAY COMMISSION

Helena, Montana 59601

July 9 , 1971

Libby Dam and Lake Koocanusa Draft Environmental Impact Statement

Mr. Fred H. Weber Assistant Chief, Engineering Division Department of the Army Seattle District, Corps of Engineers 1519 Alaskan Way South Seattle, Washington y8134

Dear Mr. Weber:

We have reviewed the Draft Environmental Empact Statement for the Libby Dam and Lake Koocanusa Project, and have confined our comments to those items concerned directly with the reconstruction of Montana State High­ way 37.

The Contract for Relocation of Montana State Highway 37 was approved by the Montana Highway Commission and signed by the Secretary of State. The Montana Highway Commission has been continually working with the Corps of Engineers on all phases of the reconstruction of MSH 37 which has had the effect, in our opinion, of keeping the environmental impact of this reconstruction to a minimum.

As noted in the draft environmental statement, an alternate route for MSH 37 to lessen its environmental impact was proposed by the Montana Fish and Game Department. After study and consideration, the State's Natural Resources Advisory Council concluded that the proposed route should be developed. The Governor of Montana concurred with this con­ clusion.

We appreciate having the opportunity to review and comment on the draft environmental Impact statement for this project.

Very truly yours,

LEWIS M. CHITTIM, P.E., 30-JRB/JCU/lm State Highway Engineer cc: State Natural Resources Advisory Council J.C. Ulberg j . k . cecKerc, r.t., Assistant State Hiehwav Eneineer- Engineenng STATE OF M O ITAJTA

DEl'.UlTJIEJfT OF RsiI Gh%3UE Helena, Montana July 19, 1971

Mr. Fred H. Weber Assistant Chief, Engineering Division Seattle District, Corps of Engineers 1519 Alaskan Way South Seattle, Washington 98134

Dear Mr. Weber:

We have reviewed the draft of the Environmental Impact Statement for Libby Dam and Lake Koocanusa transmitted to us with your letter of June 8, 1971. We have also had the opportunity to review comments sub­ mitted by the Idaho Fish and Game Department in their letter of July 8, 1971 and the Bureau of Sport Fisheries and Wildlife in their letter of June 30, 1971. For the purpose of brevity, we strongly endorse the suggestions made in both of these letters and omit comments on the sug­ gestions that they have made.

In addition to the points made in these letters, we would like to offer these additional comments:

On page 13 of the report, the second paragraph discusses the current state of progress on the report. We believe it would be appropriate to add a statement to this paragraph point­ ing out to the environmental protection agency that the remainder of Highway 37 Project presents perhaps the only significant op­ portunity to ease the adverse impact that the project is having on the environment.

On page 15, in the first paragraph, we would also like to see the discussion of the habitat losses to fish and wildlife from Libby Reservoir and associated relocation projects included.

On pages 20 and 21, Table 1 discusses the net effect of Libby Project on fish and wildlife. Of particular concern is the table showing a balance in user-days regarding the big game re­ source. The fact that big game mitigation is not taking place is merely dismissed with a four word footnote. This presentation seems to be wilfully misleading when in fact it will be extremely difficult, if not impossible, to accomplish meaningful game range acquisition when viewed in light of the fact that all efforts Mr. Fred H. Weber July 19, 1971

expended in this direction have so far failed. I believe the table should accept the net loss until the funds necessary for big game acquisition are secured. The discussion also tends to lump bighorn sheep in with other big game species. Given the habits of this particular species, we know from experience that replacing or relocating these animals on alternate ranges may be impossible. Perhaps it is again time to admit that the project and its associated relocations are making a significant contri­ bution to the possible extinction of a rare and endangered species.

In the final paragraph on page 26, the relocation of the Burlington-Northern mainline is discussed. We would like to see it mentioned in this discussion that the present alignment was selected over the constant objection of the Montana Fish and Game Department as well as the Bureau of Sport Fisheries and Wildlife. Discussions of our efforts to minimize the losses leads the reader to believe that our agency played a significant role in this reloca­ tion. The fact of the matter is that prior to the public controversy regarding the destruction of the major portion of the Fisher River, recommendations made by the department were for all practical purposes totally ignored.

On page 33, Item 8 discusses inter-agency coordination, which according to the report began in about 1949. I believe that it should be stated in this discussion that through the years numerous objections were raised regarding project design and, practically without exception, environmental considerations were disregarded for project efficiency. Unless this is clearly stated the reader of this report could draw the conclusion that participating agencies are willing to accept a portion of the responsibility for the environmental damage that is designed into the Libby Project. This is not the case.

Once again we reiterate our support for the comments by the Idaho Department of Fish and Game and the Bureau of Sport Fisheries and Wildlife, and thank you for the opportunity to comment.

Sincerely,

FRANK H. DUNKLE FHD/eb STATE FISH AND GAME DIRECTOR c.c. Robert L. Salter J. Norvell Brown John Findlay Don Brown Perry Roys jg’tate of (Montana

department of Jficaltlj

H e l e n a , M o n t a n a 59601

June 22, 1971

Mr. Fred ii. Weber Seattle District Corps of engineers 1519 Alaskan Way South Seattle, Washington 98134

Re: environmental Statement for Libby Dam and Lake Koocanusa Proj ect

Dear Mr. Weber:

We have reviewed the preliminary draft of the environmental statement for the above mentioned project, and it was found to be satisfactory.

Sincerely,

Claiborne W. Drinck, P.L., Director Division of Environmental Sanitation :>.TtXWA:VA 1VATKM MRSOURCES BOARD

HAM W. J13TCIIKIJ. m HKI.KNA, MOXTAXA

DOUGLAS G SMITH DIRECTOR HELENA EVERETT REDEEN f o r s v t h

JOSEPH B REBER. h e l e n a

July 12, 1971

In reply refer to: Water Resources Division

Mr. Fred H. Weber Corps of Engineers 1519 Alaskan Way South Seattle, Washington 98134

Dear Mr. Weber:

The Montana Water Resources Board's environmental impact reviewing committee would like to congratulate you on your very comprehensive environmental impact appraisal. This impact statement is one of the better ones that we have seen. We do however have some comments that we wish that you would consider:

1. Some of our major concerns are the Koocanusa Lake area is the earthquake potential. Where Lake Koocanusa will be located in the Rocky Mountain trench is fairly close to the seismicly active Flathead Lake area. Admittedly, the earth­ quakes in the Flathead Lake area have been of low intensity. WTe would like to know what plans have been made in case of the eventuality of a low intensity or medium intensity earthquake in the Libby Dam area? We are apprehensive that the weight of the lake could pressure a dormant fault into some movement. Has this possibility been foreseen in the design of this dam?

2. We are aware of certain low flats that exist in the upstream part of the lake that will be uncovered during periods of low water level. These flats could present a similar situation as exists in the flats and the upstream part of Canyon Ferry Reservoir. Has there been any planning along the lines of controlling the subaerial erosion of these fine grain sediments?

3. According to the Montana Bureau of Mines and Geology's Bulletin 81, the United States Geological Survey's hydrologists have predicted the possibility of water levels in the aquifer beneath Sophie Lake and Tetrault Lake may rise as much as 30 feet in 10 years time. If this situation occurs, then perhaps these may witness according increases in their water levels. Any large increase in water levels on these lakes would flood out a number of facilities on these lakes. We don't feel like that this would be such a catastrophe, but we would like to have seen some mention of this in your impact statement.

4. We would like to encourage the Corps to explore every possibility of con­ trolling the algal bloom in the lake; whether these possibilities be scientific research into the retardation of lacustrine algae, or negotiations with Canada to somehow reduce the phosphate input into the Kootenay River. 5. On lakes with steep banks, shore lines tend to slump off into the reser­ voir. We hope that your planning for the development on this lake will prohibit investments on such shaky terrain.

6. We are not sure that the flooded septic tank will be a serious problem in the lake area due to the sparsity of population. Other lakes have had this problem, such as Flathead Lake. Groundwater levels rise and flood septic tanks. The pollution from these septic tanks gets in the groundwater aquifer and even­ tually flows into the lake.

7. We would like to urge the Corps of Engineers to have someone study the archaeology of any sites that may not have already been studied.

8; "*■- encourage the early construction of the reregulating dam below Libby Dam. Both to add continuity to the economic impact and to minimize the adverse environmental factor of surging water levels.

Thank you for this opportunity to comment on the environmental impact.

Sincere ly,

MONTANA WATER RESOURCES BOARD

Douglas G/Smith Director STATE OF IDAHO IDAHO WATER RESOURCE BOARD BTATEHOUSE BOISE. IDAHO 83707

July 7, 1971

Mr. Fred H. Weber, Acting Chief Engineering division Seattle District, U.S. Array Corps of Engineers 1519 Alaskan Way Seattle, Washington 981'!/i

Dear Mr. Weber:

We have reviewed the preliminary draft of the environmental statement for Libby Dara and Lake Koocanusa project located on Kootenai River in Montana and have the following comments regarding the statement.

The future Libby Dan operation and the resulting impact on the Kootenai River Flats agricultural activities in Idaho is of concern to the local farmers and the Idaho Water Resource Board. The local farmers fear the possibility of (1) loss of sub-irrigation potentials and (2) difficulties with surface drainage from diking districts in the winter months due to the changes that would occur in historic river stages with Libby Dam in operation. Also with the Libby Dam operation a change in Kootenay Lake operation may be proposed. If Kootenay Lake operation is varied from the present operation it could further compound the problems of agriculture activities in the Kootenai River Flats. These possible effects of Libby Project operation on Kootenai Flats in Idaho should be recognized in the environmental impact statement and dis­ cussed in as much detail as possible. If such problems are anticipated, alternatives to mitigate should be explored.

Hie Board appreciates the opportunity to submit comments on this project.

Sincerely vours,

ROBERT R. LEE D i r e c t o r

cc: Mr. John J t r e l f f Mr. S c o tt Feed IDAHO FISH AND GAME DEPARTMENT

July 8, 1971

District Engineer U. S. Army Corps of Engineers 1519 Alaskan Way South Seattle, Washington 98134

Dear S i r :

We have reviewed the draft Environmental Impact Statement for Libby Dam Project which was transmitted with your letter of June 8, 1971.

Ou.t specific comments are confined to those portions of the statemen concerned with downstream effects in the State of Idaho. We also offer some general remarks which might be considered in the prepara­ tion of future statements on other projects.

Downstream Effects - Idaho

Page 2, third full paragraph, last two sentences — it is pointed out that the selective withdrawal system will improve the capability of adhering to interstate water quality standards. Whether this improved capability will actually enable the standards to be met and the predicted degree of deviation from the standards, if any, should be clarified.

Page 11, line 5 — While present water1 owl numbers using Kootenai Flat are comparatively small in relation to historic numbers prior to agricultural development, it should be pointed out that most of the 900 acres of remaining waterfowl habitat will be eliminated as a result of the project.

Page 11, first full paragraph -- Whice sturgeon, while not found in the immediate project area, will be affected downstream by project op e r a t i o n . District Engineer Page 2 July 8, 1971

Page 17, first full paragraph, sentence 2 — No mention is made of possible adverse effects on spawning as a result of daily stream fluctuations.

Page 17, first full paragraph, next to last sentence — Rate of change for daily fluctuations is given but no figures are shown for maximum fluctuation in elevation of stream surface. Maximum fluctuations in height will have major bearing on the magnitude of adverse effects related to spawning, fish food production, and angler use.

Page 20, Table 1 — We do not feel that construction of a multi­ level outlet structure to meet interstate water quality standards (as stated on page 2) can technically be classified as fishery miti­ gation .

This table should be further explained. Are use figures present annual use or use over the life of the project?

Page 26, first full paragraph, next to last sentence — It should be pointed out that changing the temperature regimen in the fall and spring has potential for adverse effects on downstream fish reproduc­ tion. There is a definite relationship between temperature, time of spawning, emergence of young and availability of food to insure survival of young fish. The predicted degree of temperature changes during these time periods should be stated.

There is no mention or discussion of the possibility of nitrogen supersaturation during periods of spill. This possibility should be fully explained, both with initial construction and with a reregulating dam. It appears there is potential for very serious downstream effects from nitrogen supersaturation.

General

In the interests of semantic accuracy and in presenting an accurate picture of environmental impact, the impoundment behind Libby Dam should be referred to throughout the statement as a reservoir rather than as a "lake." There is little resemblance between a widely fluctuating reservoir with a maximum 177—foot drawdown and a true l a k e . District Engineer Page 3 July 8, 1971

Page 1 (summary) 3. b. — Here and in other portions of the statement the phrase "alter fish and wildlife habitat" is used. "Alter and eliminate" would be more accurate.

Page 16, second full paragraph — Stump removal and clearing will lessen the visual impact of reservoir drawdown as stated. There will still remain, however, an unavoidable serious adverse visual impact from reservoir drawdown and this fact should be made clear.

Page 19, second full paragraph, line 7 — It is not made clear whether the noticeable impact on public schools of increased numbers of people is good or bad.

Page 20, Table 1 — We do not believe that in this instance day-use figures are appropriate or accurate means of portraying environmental impacts. This is particularly true in the case of stream vs reservoir. Artificial factors having little or no relationship to the natural environment or resource base such as access and facility development bias any such comparison of use. The higher comparative quality and value of a stream fishery is not expressed. As pointed out in other portions of the statement, there is an obvious major detrimental effect on the fishery resource as a result of this project. Use figures in Table 1 contrarily indicate that there is essentially no effect on the fishery resource.

Page 21, Table 1 — Use figures also do not accurately portray environ­ mental impacts as related to wildlife. Access and regulations govern use to a large extent. These factors are subject to change. Losses to the habitat base are not subject to change and the habitat base will determine possible maximum use. A similar table clearly summar­ izing habitat losses would be much more accurate and meaningful.

Habitat improvement by the U. S. Forest Service as a result of a timber and wildlife program cannot be considered project mitigation. This type of program is routine with the Forest Service and would or should be carried on regardless of whether or not a project is b u i l t .

Page 22, first paragraph, line 14 — It is impossible to replace inundated habitat. This habitat is irreplaceably removed from the total habitat base upon inundation. District Engineer Page 4 July 8, 1971

Page 22, last paragraph — It would be helpful if the maximum fluctua- tion as well as average was stated.

Page 29, second paragraph — Reasonably clear cut alternatives such as reduced power output by not constructing the proposed reregulating dam and reservoir regulation for greater recreation and fishery benefits are not mentioned.

Page 30, item 6, first sentence — Wildlife habitat is not mentioned as one of the uses or resources that will be permanently removed by project construction.

Page 31, line 3 — While no total value estimate of the stream in its present condition has been made, information contained in the statement makes it abundantly clear that existing fish and wildlife values are much greater than those that will be present after project construc­ tion .

Page 32, first paragraph -- Full consideration of reservoir vs stream recreational use should include discussion of comparative need. There is an abundance of lakes in the general project vicinity. Reservoir impoundment will only add to an already abundant recreational resource while further decreasing stream recreational opportunity which is in comparatively short supply.

We appreciate the opportunity to comment on your draft Environmental Impact Statement for this project.

Sincerely,

IDAHO FISH AND GAME DEPARTMENT

Rdbert\L. Salter Acting Director cc: Montana Department of Fish and Game BSFW - Portland BSFW - Spokane Sox 68 Rexford, Montana 59930 July 7, 1971

Re.: Draft Environmental Statement Libby Dam and Lake Koocanusa, Libby, Montana

Fred H. Weber Chief Engineering Division Department of the Army Seattle District, Corps of Engineers 1519 Alaskan Way South Seattle, Washington 9813^-

Dear Sir:

I admire the frank and honest way the preliminary draft of the Libby Dam Environmental Statement is presented. There is sufficient and logical detail in most instances to substantiate each statement in the draft. The descriptions and statistical data are of real interest to those of us how care for such things.

In my rersonal field of endeavor, I see two weak points in the draft. They are: (l) road location and (2) forest quality. Ironically, there is an endangered species in each, the Big Horn sheep and the Lincoln County logger.

(1) The location of Montana State Highway #37 along the East Canyon Wall from Five Mile Creek to the Reservoir Bridge does not mention any alternative or any basis whatsoever to justify the environmental destruction and added cost. The one lone paragraph on the bottom of page 29 of the Draft Environmental Statement is as follows: "The Montana Deoartment of Fish and Game requested consideration be given to re-routing Montana State Highway #37.... to lessen the impact on wildlife habitat. However, after study by the State's Natural Resources Advisory Counsil, the Governor of Montana requested that the relocation of Montana State Highway #37 be continued as planned."

(2) Forest quality is never mentioned in any of the many quality statements about the environment. I find this rather odd in that rage 8 under Environmental Setting states: "The major economic activity of Lincoln County is production of lumber and wood products derived from the forest resource." The Environmental Statement further reports, "A million Christmas trees are exported from Lincoln County each vear." For the future under the Environmental Impact of the Proposed Action, page 19, states: "Population, retail sales and other economic indicators are expected to return to pre-project rates after completion of construction." This implies that nothing good or bad has happened, but under The Relationship Between Local Short Term Uses of Man's Environment and The Maintenance and Enhancement of Long-Term Productivity, page 30, I find, "Completion of Libby Dam will permanently remove over 1*1,000 acres of the Kootenai River Valley in the United States from agricultural, residential, logging and manufacturing uses. About 13,000 acres of this total will be reserved for public recreation access at Lake Koocanusa."

This would seem an insignificant amount of land withdrawal from the 3,352 square miles of commercial forest land in Lincoln County. However, the problem comes from the fact that access to 100,000 acres of timered land above the Kootenai River is restricted since there has not been any new logging access road approaches constructed along the Forest Development Road.

A quality forest can only be attained and maintained by having a good permanent road system for the management, protection, and harvest of the individual tree. The lack of roads means that the 100,000 acres is not going to be a quality forest, and, therefore, the total environmental quality will be substandard.

A stagnated forest, like stagnated water, has a foul odor and suggests that something is wrong. The professional forest can, by checking the conditions of each tree's growth rings, soon determine the problem and recommend treatment for the tree, the area, or the entire drainage as the case may be. Usually the tree cutter or the logger will be called upon to perform the treatment in a prescribed manner. This may seem over-simplified, but it suggests that the forest products industry is dependent upon keeping a healthy and productive forest.

Since the forest is a continuous and renewable natural resource, I see no reason to disregard or restrict the habitat of the Lincoln County logger.

In closing and at the risk of being misunderstood, might I suggest if the choice of environmental destruction for economic gain be made, that it be made to favor the established forest industry of Lincoln County rather than an industry that uses powder and steel, neither of which is produced here?

Sincerely

/ack B. Parrish MONTANA COOPERATIVE WILDLIFE RESEARCH UNIT

U n iversity of Mo n t a n a Mo n t a n a F ish a n d G ame C o m m iss io n W ildlife M an a g e m e n t Institute F ish a n d W ildlife S ervice, U nited S tates D epartm ent of the Interior

UNIVERSITY OF MONTANA

MISSOULA, MONTANA 59801 July 6, 1971

Department of the A rm y Seattle District, Corps of Engineers 1519 Alaska Way South Seattle, Washington 9813^

Dear Sirs:

Enclosed are brief comments on your Libby Dam and lake Koocanusa, Kootenai River, Montana, impact statement. Comments were requested by the Rocky Mountain Center on Environment.

Inundation of big game winter range and relocation of the Burlington- Northern through prime white-tailed deer winter range will substantially reduce the big-game population of northwestern Montana. The Dam and relocation are so far along that little can be done now except to replace as much winter range as possible. The habitat improvement program being carried out by the Forest Service is a step in the right direction, but what has been done so far looks more like timber stand improvement than game-range improvement - not that the two are mutually exclusive. I fear that depth of snow will limit the usefulness of some of the improved range; in view of this, I feel strongly that acquisition of private land, to be developed as replacement wildlife habitat, is the best solution. Man chooses areas for farming which are natural wintering area for big game. The Forest Service land will require more manipulation than the private land if suitable winter range is to be maintained.

I feel that the statement that construction of the project will have no effect on the habitat of the Columbian sharp-tailed grouse may or may not be correct. These birds ordinarily spend summers on grasslands and winters in the river bottoms where cottonwoods and other deciduous trees furnish roosting sites and buds for winter food. Again, acquisition of private land would probably be the only way to replace the types of vegetation that sharp-tails need during winter.

Sincerely,

Bart W. O'Gara Ph.D. Assistant Leader, Cooperative Wildlife Research Unit, University of Montana