Draft EIS_072312.pdf - Middle Fork American River Project ...

20120723-4002 FERC PDF (Unofficial) 07/23/2012
• Use of herbicide formulations that EPA considers safe for aquatic areas.
• Required supervision of pesticide application by a licensed pest control advisor
and restrictive application and disposal methods.
• Implementation of a Water Quality Monitoring Plan specific to the VIPMP to
evaluate the effectiveness of these protective measures.
The proposed VIPMP Water Quality Monitoring Plan would characterize the
presence or absence of herbicides in perennial streams and special aquatic sites
(i.e., project reservoirs and diversion pools) adjacent to areas where herbicides are
applied, including both pre-and post-treatment sampling. Sampling results would be
used, in consultation with the Forest Service, Water Board, and California Fish and
Game, to determine the effectiveness of protective measures and whether pesticides have
been applied safely, restricted to intended target areas, and did not result in unexpected
non-target effects. Following this consultation, the monitoring results report would be
filed with the Commission. Monitoring locations would be monitored for 3 consecutive
years: concurrent with the first application period and repeated for an additional 2 years.
If the results for years 1–3 do not detect any harmful levels of pesticides, no further
monitoring would occur unless new pesticides are identified and authorized for use at the
project. If harmful levels of pesticides are detected, PCWA and the agencies listed in the
monitoring plan would modify the VIPMP regarding pesticide application and resume the
3-year monitoring cycle. Water quality monitoring would continue until no harmful
levels of pesticides are detected at a sampling site for 3 consecutive years.
The Alternative 1 VIPMP is similar to the proposed action. In general, the
proposed buffer zones from waterbodies are more expansive than in the proposed plan
and more detail is provided regarding the specific application methods. Its Water Quality
Monitoring Plan for pesticide application would change the requirements to meet the
criteria for a determination of “no harmful effects for three consecutive years.” Storm
runoff sampling data also would be collected for a minimum of 2 years, as well as pretreatment
and post-treatment data for 3 years (or more).
Our Analysis
The Forest Service BMPs and avoidance and protection measures in both the
PCWA’s and the Alternative 1 VIPMPs would minimize the potential for inappropriate
introduction of herbicides, surfactants, rodenticides, and fungicides into waterbodies in
the project area such that water quality would not be adversely affected. The proposed
VIPMP Water Quality Monitoring Plan and the Alternative 1 plan would both adequately
monitor the water in and around areas of pesticide use to determine the effectiveness of
protective measures and whether pesticides have been applied safely, restricted to
intended target areas, and have not resulted in unexpected non-target effects. The more
detailed descriptions and, in most cases, broader buffer zones specified in the Alternative
1 VIPMP and inclusion of additional requirements for a determination of no harmful
effects in the Alternative 1 plan would ensure that the monitoring program continues for a
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