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

20120723-4002 FERC PDF (Unofficial) 07/23/2012
monitoring plans and results; and discuss future schedules and planning for recreation
facility design and construction. Both the PCWA and Alternative 1 recreation plans
include annual consultation components that would provide orderly recreation
management at the project as well as on adjacent NFS lands that would benefit project
visitors and minimize undesirable recreation effects on environmental and cultural
resources.
Our Analysis
Providing New or Changed Recreation Facilities and Updating the
Recreation Plan
Both PCWA and the Forest Service measures include thresholds for considering
new or expanded recreation facilities. These measures are similar and would provide for
additional capacity to accommodate project recreation at developed facilities, if needed in
the future. From a compliance perspective, the provision in the Alternative 1 Recreation
Plan is ambiguous because it does not say what constitutes a “clear reason” in regard to
determining whether the occupancy determined during a third year of monitoring would
meet the threshold for initiating discussions with the Forest Service about changes to the
project recreation facilities. Lacking a clear threshold, Commission staff would not be
able to determine whether PCWA was complying with this aspect of the plan. PCWA’s
Recreation Plan approach is similar enough to the Alternative 1 plan approach to meet the
intent of working with the agency to provide adequate capacity yet it also provides clarity
that would be necessary for determining compliance with this element of the proposed
plan.
PCWA’s proposed Recreation Plan describes a clear approach for plan updates.
However, the approach described in the Alternative 1 Recreation Plan lacks the structure
necessary for review, approval, implementation, and Commission staff determination of
compliance with the provisions of the plan. For example, under the Alternative 1
Recreation Plan, PCWA would consult annually about the need for facility changes, and
any agreed-upon actions would be documented in an amendment to the plan that would
be filed for Commission approval. The Alternative 1 plan also has a provision to consult
on an unspecified schedule with unspecified agencies to determine if a plan revision is
necessary. Implementing both of these approaches could result in overlapping
timeframes such that PCWA could have a plan amendment awaiting Commission
approval when PCWA and the agencies decide it is necessary to update the plan. An
approach with specific timeframes, such as PCWA proposes based on a 6-year frequency,
would allow sufficient time for reviewing monitoring data, discussing and recommending
facility changes, and obtaining agency input and Commission approval. The ambiguity
included in the Alternative 1 Recreation Plan approach could lead to misunderstandings,
delayed implementation, disputes, and a Recreation Plan that is in a constant state of flux.
Further, a clear and definitive process would allow Commission staff to determine if
PCWA is in compliance with the measures specified in the plan.
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