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

20120723-4002 FERC PDF (Unofficial) 07/23/2012
for adverse effects may require archaeological excavation, but no plan for the curation
of recovered materials is provided. We recommend minor revisions to the document,
including: (1) requirements for National Register evaluation of all currently
unevaluated resources subject to unavoidable project-related effects. These effects
would include those associated with reservoir drawdown for operation and maintenance
purposes (i.e., FS-05-03-55-684 and FS-05-03-55-689), recreation activities, including
trail maintenance and alignment (PL-03 and PL-19), and road construction (FS-05-03-
55-495), and documentation of California SHPO concurrence with all National Register
recommendations; (2) a plan for assessment of project effects to any properties that are
determined to be eligible for listing on the National Register; (3) a plan for the curation
of any recovered archaeological materials; and (4) a plan to develop mitigation
measures in consultation with the California SHPO, Forest Service, and participating
tribes for all eligible properties where effects are adverse. Development and
implementation of a revised HPMP would have an estimated levelized annual cost of
about $44,100, which is about $160 more than the estimated levelized annual cost of the
proposed and Alternative 1 HPMP. We conclude that the benefits of implementation of
our recommended revised HPMP would be worth the cost because it would ensure that
properties that are eligible for listing on the National Register are managed
appropriately in the future in accordance with section 106.
5.2.3 Measures Not Recommended by Staff
Staff finds that some of the measures recommended by other interested parties
would not contribute to the best comprehensive use of the Middle Fork American River
water resources, do not exhibit sufficient nexus to project environmental effects, or
would not result in benefits to non-power resources that would be worth their cost. The
following section discusses the basis for staff’s conclusion not to recommend such
measures.
Streamflow Gages on the Lower Rubicon and North Fork American Rivers
Two gages on the Rubicon River are included in the Alternative 1 Streamflow
and Reservoir Gaging Plan that are not intended to document compliance with any
specified flow measures. The primary purpose of both gages is to provide the public
with real-time flow data that would be helpful for making decisions about traveling to
the Rubicon River for recreational purposes in the reach between Ellicott Bridge and the
Ralston afterbay. Our recommended Streamflow and Reservoir Gaging Plan would
provide for documentation of flows from Hell Hole dam and powerhouse to the
Rubicon River as measured in the vicinity of the dam. PCWA has control over such
flows during most circumstances. Flows on the Rubicon River at and downstream of
Ellicott Bridge are not only influenced from project release from the Hell Hole
development, but also from inflows from the South Fork Rubicon River. South Fork
Rubicon River flows are heavily influenced by the operation of the Upper American
River Hydroelectric Project (FERC No. 2101). We do not dispute the value to potential
recreational visitors of having real-time flow information on the lower reach of the
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