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

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20120723-4002 FERC PDF (Unofficial) 07/23/2012 • HPMP review and revision every 5 years in consultation with the Commission, Eldorado National Forest, Tahoe National Forest, the California SHPO, and interested Native <strong>American</strong> tribes; • a process for dispute resolution; and • A schedule for HPMP implementation. In its Alternative 1 HPMP, PCWA stated that all heavy maintenance and nonroutine recreation facility activities in the vicinity of National Register-eligible sites FS- 05-03-53-64, FS-05-03-53-65, FS-05-03-55-201, and FS-05-03-55-682 would be designed in consultation with the Forest Service and participating tribes to ensure avoidance of effects and that 30-foot buffer zones would be established around each resource. The Alternative 1 HPMP did not provide specific treatment for potential erosion at sites FS-05-03-55-682, FS-05-03-55-684, FS-05-03-55-689. However, PCWA proposes to conduct a formal archaeological survey of Hell Hole reservoir once over the term of any new license and during periods of low water levels (4,544–4,445 feet mean sea level) to determine if additional cultural resources may be present in areas typically submerged by the reservoir. Additionally, if reservoir levels extend below the lowest minimum pool elevation of 4,341 feet mean sea level, PCWA would also conduct additional surveys at that time. In its Alternative 1 HPMP (2011d), PCWA identifies project-related effects on the location identified as culturally significant by the Colfax-Todds Valley Consolidated Tribe. To address these effects, PCWA proposes to (a) remove material from an adjacent road that was deposited on the site during a slide event, (b) implement a site monitoring program for project activities and improper recreational use, and (c) consult with the Forest Service prior to removing hazard trees in the vicinity of the location. Further, PCWA’s VIPMP (see section 3.3.3.2, Terrestrial Resources) includes a requirement to avoid spraying or otherwise affecting any traditional plant gathering areas if they are identified in the future. Our Analysis The general treatment measures provided in PCWA’s Alternative 1 HPMP (PCWA, 2011d), including avoidance and monitoring of significant cultural resources, public and employee education, consultation, and reporting, are all adequate to ensure that most cultural resources within the project APE are appropriately managed and protected throughout the term of any license issued for the project. Archaeological resources within or along the shorelines of project reservoirs may be adversely affected by erosion or damage as a result of fluctuating reservoir levels and/or exposure during drawdown periods. PCWA identified three archaeological sites as subject to potential effects associated with reservoir drawdowns for operation and maintenance purposes at Hell Hole reservoir (FS-05-03-55-682, FS-05-03-55-684, and 264
20120723-4002 FERC PDF (Unofficial) 07/23/2012 FS-05-03-55-689). One of these sites is known to be eligible for listing on the National Register, and two are unevaluated because they were submerged during field studies. While PCWA proposes additional surveys of areas that may be exposed during reservoir drawdown for operation and maintenance purposes in its Alternative 1 HPMP, no mention for the analysis of potential effects on FS-05-03-55-682 is provided, and no sitespecific protection or mitigation measures for this resource are discussed. Additionally, there is no measure for National Register evaluation of any resources that may be identified during future reservoir surveys, including FS-05-03-55-684 and FS-05-03-55- 689. Any resources that are subject to project-related effects, including those that may be recorded below the high water line at project reservoirs, should be evaluated for the National Register, which may include test excavation. If test excavation is required at any site within the project APE, the HPMP should include a plan for the curation of recovered materials. Pursuant to section 106, project effects on eligible sites must be assessed, and measures to resolve adverse effects must be developed in consultation with the California SHPO, and as appropriate, the Forest Service, the BLM and participating tribes. If site FS-05-17-54-495 is determined to be eligible for listing on the National Register, this site would also require an effects assessment and development of treatment measures if effects are adverse. Revising the Alternative 1 HPMP to contain these requirements would ensure compliance with section 106. In its Alternative 1 HPMP, PCWA recommends that two sites (FS-04-17-54-372 and FS-05-17-54-478) are not eligible for listing on the National Register; however, no documentation of California SHPO concurrence, and in the case of FS-04-17-54-372, consultation with BLM, regarding these recommendations is provided. Receipt of California SHPO concurrence would ensure compliance with section 106 and would ensure that these two sites are treated appropriately. Further, FS-05-17-54-478 is listed twice in table 1 of the Alternative 1 HPMP: once as a water conveyance ditch that has been recommended as ineligible for listing on the National Register and a second time as an unevaluated mining ditch. We assume that the identification of the site as unevaluated is incorrect, but clarification in the HPMP would ensure document accuracy. Table 1 of PCWA’s Alternative 1 HPMP states that there are no potential project-related effects on sites PL-03 and PL-19 because PCWA activities are limited to trail alignment. However, the specific activities associated with trail alignment are not described and the extent to which these two sites could be affected by these activities is unclear. Any grounddisturbing activities associated with trail maintenance or alignment could result in damage to cultural materials. Additionally, the very presence of a recreation trail within a site’s boundary could also result in casual artifact collection and/or site vandalism. Clarification of such activities in the HPMP would enable a thorough analysis of potential project effects. If trail maintenance or use has the potential to affect these resources, National Register evaluations of both resources, and if necessary, development of measures to resolve effects that are deemed adverse, would ensure appropriate protection under section 106. 265
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41 Table 3.3.1-1. Average number of
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43 Site/Release Location Gravel Ini
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45 a Q 1 - TSR, Table G-1 (PCWA, 20
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69 Table 3.3.2-3. Hydrology for sel
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71 Exceedances and Summary Statisti
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91 Figure 3.3.2-6. Fish passage bar
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105 Location American River below M
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135 Species Name Status a Butte Cou
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145 Table 3.3.3-5. Special-status w
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195 Figure 3.3.5-1. French Meadows
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319 Table 5-2. Staff-recommended mi
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321 Location Middle Fork American R
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