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

20120723-4002 FERC PDF (Unofficial) 07/23/2012
Our Analysis
Noxious weeds have the potential to occur in nearly all areas within the project
boundary. Populations may become established by project-related activities or by natural
dispersal mechanisms. The survey, prevention, treatment, revegetation, monitoring, and
education elements that are common to both the proposed and Alternative 1 plans would
help to control existing populations of noxious weeds and minimize the establishment
and spread of noxious weeds in the future. Measures to limit the introduction and spread
of noxious weeds near riparian resources would enhance riparian habitats through
improving habitat conditions (i.e., reducing competition with noxious weeds).
Regarding the proposed plan’s phased approach to noxious weed management in
areas within the project boundary but not in areas where active vegetation management is
proposed to occur, we note that the project boundary is only intended to include all lands
necessary for the operation and maintenance of project-related facilities. Thus all lands
included in a new license for this project would have a nexus to project purposes. The
proposed one-time treatment of 27 acres of land during the first year after license
issuance and 26 acres during the second year after license issuance with subsequent
monitoring for a maximum of 3 years implies that noxious weed populations that occur
elsewhere within the project boundary but not in areas undergoing active vegetation
management, are not the responsibility of PCWA. Similarly, noxious weeds populations
could become established within the project boundary at any time during the term of a
new license. A one-time treatment of a total of 53 acres of noxious weed populations
with a maximum of 3 years of post-treatment monitoring suggests that future noxious
weed populations that could become established within the project boundary would be
the responsibility of another entity. The Alternative 1 VIPMP would provide for
comprehensive noxious weed control throughout the area within the project boundary and
for the duration of a new license.
The buffer zones specified in the Alternative 1 plan within which herbicides would
not be applied are much more expansive than those in the proposed plan. Noxious weeds
within the buffer zone would need to be controlled by manual methods, unless there are
site-specific prohibitions on manual control. These wider buffer zones would afford
additional protection of sensitive environmental resources from inadvertent adverse
effects from use of herbicides to control noxious weeds.
The three elements of the Alternative 1 VIPMP not included in the proposed plan
would include provisions that would address noxious weed control that may be associated
with future ground-disturbing activities not addressed in this NEPA document, provide
for the protection of traditional plant gathering locations that are important to Native
Americans, and provide for control of invasive algae should its presence be linked to
project operations and an effective and safe control protocol is established in the future.
These provisions provide a framework for future protection as site-specific information
becomes available.
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