18.08.2013 Views

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

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

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

SHOW MORE
SHOW LESS

Create successful ePaper yourself

Turn your PDF publications into a flip-book with our unique Google optimized e-Paper software.

20120723-4002 FERC PDF (Unofficial) 07/23/2012<br />

Our Analysis<br />

Both VIPMPs provide sound avoidance and protection measures that would<br />

protect plant resources that may be affected by the project. However, the proposed plan<br />

is not specific regarding how much riparian vegetation would be removed at sediment<br />

augmentation sites, whereas the Alternative 1 plan is very specific about the maximum<br />

amount of riparian vegetation that can be removed: about 0.94 acre. The specificity in<br />

the Alternative 1 plan regarding riparian vegetation removal at augmentation sites would<br />

avoid any misinterpretation about the acceptable limit of riparian disturbance and enable<br />

Commission staff to confirm compliance with the VIPMP during the term of a new<br />

license. Sediment management activities and vegetation management at the<br />

augmentation areas would permanently eliminate up to 0.94 acre of riparian vegetation at<br />

Junction Bar, Indian Bar, and Willow Bar. These effects, however, would be outweighed<br />

by a net benefit to riparian vegetation from proposed sediment management activities<br />

because natural sediment supply and transport function would be restored to these areas.<br />

Sediment management is discussed in more detail in section 3.3.1.2, Geologic and Soils<br />

Resources.<br />

Similarly, sediment management activities in conjunction with the proposed and<br />

Alternative 1 modified instream flow regime have the potential to affect special status<br />

plant populations along unsurveyed project stream reaches. Any such effects on<br />

unidentified plant populations would be outweighed by the overall ecosystem<br />

enhancements that would accrue from approaching more natural geomorphological<br />

processes and flow regimes.<br />

For the Commission to approve a proposed plan, it should represent a stand-alone<br />

document that can be used by Commission staff to document compliance with the plan<br />

without having to refer to documents not included in the plan. Both plans state that<br />

surveys would be conducted in accordance with methods specified in a technical study<br />

report filed with the final license application (PCWA, 2008a). We therefore assume that<br />

implementation of either VIPMP would entail the methods specified in the technical<br />

study report, even though the report is not appended to either plan.<br />

Protection of Riparian Vegetation along Bypassed and Peaking Reaches<br />

Routine maintenance activities, changes in project operations and maintenance<br />

activities, and construction activities associated with modification of existing or<br />

construction of new project facilities could alter the abundance or distribution of riparian<br />

species and communities. Routine vegetation management and noxious weed control<br />

measures, discussed previously and addressed in the VIPMPs, could result in direct loss<br />

of individuals. Other effects on riparian resources could include direct loss of individuals<br />

from trampling riparian plants, and crushing or cutting resulting from vehicle and<br />

equipment use.<br />

Under the proposed and Alternative 1 operating regimes, minimum flows in the<br />

peaking and bypassed reaches would be equal to or greater than under existing conditions<br />

166

Hooray! Your file is uploaded and ready to be published.

Saved successfully!

Ooh no, something went wrong!