Appendix E-6: Consultation - Part 1 - Loup Power District

Loup River Hydroelectric Project April 13, 2012
FERC Project No. 1256
NUMBER COMMENT / COMMENT SUMMARY DISTRICT RESPONSE
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reduction in pallid sturgeon habitat.
Project reductions in active channel area may affect pallid sturgeon habitats in two ways. Reduction in active channel area
may affect the longitudinal distribution of habitats which in turn affect the presence or absence of species at large spatial
scales (Rosenfeld 2003). Reductions in channel area may also reduce the lower Platte River's habitat capacity for a species
which in turn affect species abundance (Rosenfeld 2003). These reductions in channel area may result in river segments
that are unsuitable to pallid sturgeon, or suitability is so reduced that the river segment serves only as a migration corridor.
The Project's removal of 24 percent of the sediment supply at the Project tailrace return could affect the development of
channel sandbars and macroforms. Furthermore, the Project's release of clear water at the tailrace return would increase
water clarity in the lower Platte River. The clear water returns would affect the pallid sturgeon which select for dark to
very dark conditions, avoid areas of low turbidity, and have specialized physiological adaptations to turbid environments
(Peters and Parham 2008b). The increase in water clarity would decrease habitat suitability and may increase predation
pressure on individuals near the tailrace return (Peters and Parham 2008b).
Project hydrocycling may also affect pallid sturgeon habitats.
Elliot (2011) noted that deep water geomorphic classification (i.e., percent of deep water) was sensitive to discharge
changes resulting from hydrocycling; therefore, it is reasonable to assume that hydrocycling similarly affects pallid
sturgeon habitat.
Service April 7, 2011, comments on the SISR identified Project hydrocycling effects to the connectivity to pallid sturgeon
habitats.
The most prominent Project effects to connectivity occur from February through June and in November. For certain
months, Project effects to connectivity occur upstream to Study Site 4. These losses of connectivity at Study Site 3 could
imply Project diversions potentially affecting pallid sturgeon habitat in the Platte River Bypass area. Project effects to
habitat connectivity may reduce the capacity of the Platte River to support pallid sturgeon individuals. Reductions in
habitat connectivity may also affect the spawning migration of pallid sturgeon in the Platte River between April and July
when reproductive shovelnose and pallid sturgeon generally move upstream to spawn.
It is likely that Project operations would not affect spawning behavior of the pallid sturgeon. DeLonay etal. (2009)
identified potential long-term and short term cues for reproductive maturation and readiness to spawn. Day length is the
likely long-term cue that is initiated months before a predictable spawning date. Of three potential short-term spawning
cues (i.e., water temperature, discharge, day of year) water temperature is the most likely to affect the sensitivity of pallid
sturgeon hormones, embryo development, and embryo survival. Since Project operations are not known to affect stream
temperature in the Platte River, it is reasonable to conclude that Project operations would not affect spawning behavior.
The Project may affect pallid sturgeon prey items by: a) flow and sediment-related effects to sustainability of habitats, b)
flow and sediment-related effects to habitat quantity and quality, c) flow-related effects to habitat connectivity, and d)
flow-related effects on primary production.
Project reductions in channel area, reductions in suspended sediment, removal of sediment supply near the tailrace return
may affect habitat quality and quantity of pallid sturgeon prey items.
Project hydrocycling operations may affect habitat quality and connectivity of habitat for pallid sturgeon prey items.
Project hydrocycling effects to primary production has been well documented. This effect would be realized for benthic
invertebrates commonly consumed by juvenile pallid sturgeon as well as affecting small fishes commonly consumed by
adults.
University of Nebraska at Lincoln researchers have captured both stocked and wild pallid sturgeon upstream of the
Elkhorn River confluence for all three sampling years and all three sampling time periods (i.e., spring, summer, and fall).
Thus, implying that the Platte River provides habitat for the pallid sturgeon year round as opposed to providing seasonal
habitat described in the DBA.
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District analysis regarding this USFWS concern is included in Draft BA Section 6.3.2 and Section 6.3.9 (FLA Appendix
E-2).
The USFWS’s definitive statement regarding clean water discharge impacts to the Platte River is speculative, not
substantiated by associated turbidity sampling, and contrary to Project-specific study findings. Attachment B of the
District’s November 23, 2011 response to USFWS Comment 3 on the Updated Study Report illustrates a lack of bed
coarsening downstream of the Tailrace return: this suggests a lack of clear water, as clear water would result in bed
coarsening. In addition, the District previously responded to a similar USFWS comments regarding sediment supply in,
1) Attachment B of the District’s November 24, 2010 Response to Comments on the ISR (USFWS Comment 2 on
Project Sediment-related Effects: Tailrace to North Bend) and 2) Attachment B, Pages 24 to 28 of the District’s May 11,
2011 Response to Comments on the SISR.
District analysis regarding this USFWS concern is included in Draft BA Section 6.3.2 and Section 6.3.9 (FLA Appendix
E-2).
The District previously responded to a similar USFWS comment regarding the affects of hydrocycling on pallid
sturgeon on Attachment B, Pages 13-16 of the District’s May 11, 2011 Response to Comments on the SISR.
The District concurs with this USFWS conclusion.
District analysis regarding this USFWS concern is included in Draft BA Section 6.3.8 and Section 6.3.9 (FLA Appendix
E-2).
The District’s response to USFWC Comment No. 5 specifically addresses potential hydrocycling affects to the
macroinvertebrate community of the lower Platte River.
District analysis regarding this USFWS concern is included in Draft BA Section 6.3.2 and Section 6.3.9 (FLA Appendix
E-2).
The reference to seasonal habitat has been removed from the Draft BA (FLA Appendix E-2).
60 The Service cautions the use of angler-reported pallid sturgeon to determine the range of the species. The initial range of The District notes that the reference to angler reported sturgeon in the DBA is from Peters and Parham; which is a