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

20120723-4002 FERC PDF (Unofficial) 07/23/2012
The organization of both plans makes it difficult to locate information about the
recreation sites and, as they are written, would be inadequate to determine if PCWA is
complying with the measures specified in the plan that may be included in a new license
issued for this project. For example, both plans list Middle Meadows as a project facility
but neither plan describes the facility, capacity, or amenities provided. Further,
developments proposed in the same general location are presented in separate sections of
the plans based on whether an improvement is a change to an existing facility or a new
facility. For example, section 4.3.18, Ralston Picnic Area, of the Alternative 1
Recreation Plan describes changes at Ralston picnic area; however, the proposed boat
launch, which appears to be within 1,000 feet of the picnic area, is discussed in section
4.4.1, Improvements at Select Dispersed Use Areas. Further, information in the tables is
not consistent with text. For example, the Alternative 1 plan specifies that PCWA should
develop a water system at Ahart Campground; however, this system is not included on
the list of water systems presented in table 1, Project Recreation Facilities and Features,
which purports to show existing and any new recreation-related facilities. Although site
information is provided in a relicensing report, the project recreation plan should present
a comprehensive discussion of all project recreation developments that includes both
existing and planned improvements at each site. In addition, the plan should contain all
information needed for Commission staff to determine compliance with measures
specified in the plan without having to refer to relicensing reports. Section 4.3.20 of the
Alternative 1 Recreation Plan states “The road will be improved as specified in the
PCWA’s TSMP, which is available in supporting document A of PCWA’s final license
application (PCWA, 2011a).” Instead of referring to the relicensing document, the
recreation plan should describe the road improvement that is proposed.
Recreation Facility Operation and Maintenance
PCWA proposes to enter into a collection agreement to provide funding to the
Forest Service for operation, maintenance, and administration of project recreation
facilities. Forest Service condition no. 34 and the Alternative 1 Recreation Plan also
specify that PCWA should provide funding to the agency for these purposes.
Our Analysis
It is appropriate for PCWA to be responsible for operating and maintaining the
facilities that support project recreation to provide safe and adequate public recreation
facilities. Although the Recreation Plans in PCWA’s proposal and Alternative 1 indicate
that PCWA would enter into a collection agreement to provide funding for the agency to
operate and maintain the project recreation facilities, this mechanism would not relieve
PCWA of its responsibility and therefore would not be an appropriate measure to include
in the Recreation Plan. Because it would only be appropriate for PCWA to operate and
maintain project recreation facilities, and Cache Rock (see Forest Service condition no.
35) and the Hell Hole administrative station (see Forest Service condition no. 36) do not
support project recreation, PCWA should not be responsible for operating and
maintaining these facilities. It should also be noted that, as indicated in its funding
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