FERC/FEIS – 0191F 

 

Final Environmental Impact Statement 

 Lake Elsinore Advanced Pumped Storage 

Project 

FERC Project No. 11858 

Federal Energy 

Regulatory Commission 

888 First Street N.E. 

Washington, DC 20426 

Office of 

Energy 

Project 

 

January 2007 

U. S. Forest Service 

Trabuco Ranger District 

U.S. Department of 

Agriculture 

1147 East 6th Street 

Corona, CA 92897 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
Final Environmental Impact Statement January 2007 FE

Lake Elsinore Advanced Pumped Storage Project – FERC Project No. 11858 Federal Energy Regulatory Commission – Office of Energy Projects U. S. Forest Service - Trabuco Ranger District - U.S. Department of Agriculture 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
COVER SHEET 

FEDERAL ENERGY REGULATORY COMMISSION 

FINAL ENVIRONMENTAL IMPACT STATEMENT 

FOR HYDROPOWER LICENSE 

Lake Elsinore Advanced Pumped Storage Project 

Docket No. P-11858-002 

Cover Letter (and other information before the Table of Contents) 

FEIS 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
FERC/EIS – 0191F 

FINAL ENVIRONMENTAL IMPACT STATEMENT 

FOR HYDROPOWER LICENSE 

Lake Elsinore Advanced Pumped Storage Project 

FERC Project No. 11858 

California 

Federal Energy Regulatory Commission 

Office of Energy Projects 

Division of Hydropower Licensing 

888 First Street, NE 

Washington, DC 20426 

U.S. Department of Agriculture 

Cleveland National Forest 

San Diego, CA 

January 2007 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
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Document Accession #: 20070130-4000 Filed Date: 01/30/2007
FEDERAL ENERGY REGULATORY COMMISSION 

WASHINGTON, D.C. 20426 

OFFICE OF ENERGY PROJECTS 

TO THE PARTY ADDRESSED: 

Attached is the final environmental impact statement (EIS) for the Lake Elsinore Advanced 

Pumped Storage (LEAPS) Project, located primarily on Lake Elsinore and San Juan Creek, in the city of 

Lake Elsinore, Riverside County, with transmission lines extending into San Diego and Orange counties, 

California. 

This final EIS documents the view of governmental agencies, non-governmental organizations, 

affected Indian tribes, the public, the license applicant, U.S. Department of Agriculture, Forest Service 

(USFS) staff and Federal Energy Regulatory Commission (Commission) staff. It contains evaluations on 

Elsinore Valley Municipal Water District and Nevada Hydro Company, Inc.’s (the co-applicants’) 

proposal and the staff alternative for licensing the LEAPS Project. 

The Commission and the USFS have agreed to participate as cooperating agencies in the 

preparation of this EIS for the LEAPS Project. The Commission will use the EIS to determine whether, 

and under what conditions, to issue an original hydropower license for the project. The USFS will use the 

EIS to base its finding under Section 4(e) of the Federal Power Act and to decide whether to issue any 

necessary special use authorizations. 

Before the Commission makes a licensing decision, it will take into account all concerns relevant 

to the public interest. The final EIS will be part of the record from which the Commission will make its 

decision. The final EIS was sent to the U.S. Environmental Protection Agency and made available to the 

public on or before (on or before January 31, 2007). 

Copies of the final EIS are available for review in the Commission’s Public Reference Branch, 

Room 2A, located at 888 First Street, N.E., Washington, DC 20426. The final EIS also may be viewed 

on the Internet at www.ferc.gov under the eLibrary link. Please call (202) 502-8822 for assistance. 

Attachment: Final Environmental Impact Statement 

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vii 

COVER SHEET 

a. Title: Licensing the proposed Lake Elsinore Advanced Pumped Storage (LEAPS) 

Project in the city of Lake Elsinore, Riverside County, California, Federal 

Energy Regulatory Commission (Commission or FERC) Project No. 11858. 

b. Subject: Final Environmental Impact Statement 

c. Lead Agency: FERC with the U.S. Forest Service (USFS) as a cooperating agency 

d. Abstract: The Elsinore Valley Municipal Water District (Elsinore Valley MWD) and 

Nevada Hydro Company, Inc. (Nevada Hydro) filed an application for an 

original license for the construction and operation of its proposed Lake Elsinore 

Advanced Pumped Storage (LEAPS) Project, which would be located primarily 

on Lake Elsinore and San Juan Creek, in the city of Lake Elsinore, Riverside 

County, with transmission lines extending into San Diego and Orange counties, 

California. The USFS is reviewing an application for a special use permit for 

constructing the Talega-Escondido/Valley-Serrano 500-kilovolt transmission 

interconnection, including transmission lines associated with the LEAPS 

Project, as a transmission line only project. 

e. Contact: FERC Staff: 

James Fargo 

Federal Energy Regulatory Commission

Office of Energy Projects 

888 First Street, N.E. 

Washington, DC 20426 

202-502-6095 

U.S. Forest Service Staff: 

Virgil Mink 

Trabuco Ranger District 

Cleveland National Forest 

1147 East 6th Street 

Corona, CA 92879 

951-736-1811, ext. 3277

f. Transmittal: This final environmental impact statement jointly prepared by the Commission’s 

and USFS’ staff on the hydroelectric license application filed by the Elsinore 

Valley MWD and Nevada Hydro for the proposed LEAPS Project (FERC 

Project No. 11858) is being made available to the public on or before 

January 31, 2007, as required by the National Environmental Policy Act of 

19691

 

1

 National Environmental Policy Act of 1969, amended (Pub. L. 91-190. 42 U.S.C. 4321-4347, 

January 1, 1970, as amended by Pub. L. 94-52, July 3, 1975, Pub. L. 94-83, August 9, 1975, and Pub. 

L. 97-258, §4(b), September 13, 1982). 

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FOREWORD 

The Federal Energy Regulatory Commission (Commission), pursuant to the Federal Power Act 

(FPA)2 and the U.S. Department of Energy Organization Act3 is authorized to issue licenses for up to 

50 years for the construction and operation of non-federal hydroelectric development subject to its 

jurisdiction, on the necessary conditions: 

That the project...shall be such as in the judgment of the Commission will be best 

adapted to a comprehensive plan for improving or developing a waterway or 

waterways for the use or benefit of interstate or foreign commerce, for the 

improvement and utilization of water-power development, for the adequate 

protection, mitigation, and enhancement of fish and wildlife (including related 

spawning grounds and habitat), and for other beneficial public uses, including 

irrigation, flood control, water supply, and recreational and other purposes referred 

to in Section 4(e)...4

The Commission may require such other conditions not inconsistent with the FPA as may be 

found necessary to provide for the various public interests to be served by the project.5

 Compliance with 

such conditions during the licensing period is required. The Commission’s Rules of Practice and 

Procedure allow any person objecting to a licensee’s compliance or noncompliance with such conditions 

to file a complaint noting the basis for such objection for the Commission’s consideration.6

 

2

 16 U.S.C. §791(a)-825r, as amended by the Electric Consumers Protection Act of 1986, Public Law 

99-495 (1986) and the Energy Policy Act of 1992, Public Law 102-486 (1992). 

3

 Public Law 95-91, 91 Stat. 556 (1977). 

4

 16 U.S.C. §803(a). 

5

 16 U.S.C. §803(g). 

6

 18 C.F.R. §385.206 (1987). 

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Document Accession #: 20070130-4000 Filed Date: 01/30/2007
COVER SHEET 

FEDERAL ENERGY REGULATORY COMMISSION 

FINAL ENVIRONMENTAL IMPACT STATEMENT 

FOR HYDROPOWER LICENSE 

Lake Elsinore Advanced Pumped Storage Project 

Docket No. P-11858-002 

Table of Contents 

Pages xi through xx 

FEIS 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
xi 

TABLE OF CONTENTS 

LIST OF FIGURES .................................................................................................................................... xv 

LIST OF TABLES....................................................................................................................................xvii 

ACRONYMS AND ABBREVIATIONS .................................................................................................. xix

EXECUTIVE SUMMARY ....................................................................................................................... xxi 

1.0 PURPOSE OF ACTION AND NEED FOR POWER..................................................................1-1 

1.1 PURPOSE OF ACTION..................................................................................................1-1 

1.2 NEED FOR POWER AND TRANSMISSION...............................................................1-3 

1.2.1 Power...............................................................................................................1-3 

1.2.2 Transmission....................................................................................................1-4 

1.3 INTERVENTIONS..........................................................................................................1-6 

1.4 SCOPING PROCESS ......................................................................................................1-7 

1.5 AGENCY CONSULTATION.......................................................................................1-10 

1.6 CALIFORNIA ENVIRONMENTAL QUALITY ACT................................................1-10 

1.7 COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT.......1-11 

2.0 PROPOSED ACTION AND ALTERNATIVES .........................................................................2-1 

2.1 INTRODUCTION ...........................................................................................................2-1 

2.2 NO-ACTION ALTERNATIVE.......................................................................................2-1 

2.3 CO-APPLICANTS’ PROPOSAL....................................................................................2-2 

2.3.1 Description of Existing and Proposed Project Facilities .................................2-2 

2.3.2 Construction Sequence ....................................................................................2-7 

2.3.3 Proposed Project Boundary .............................................................................2-8 

2.3.4 Description of Proposed Project Operations....................................................2-8 

2.3.5 Project Safety.................................................................................................2-10 

2.3.6 Proposed Environmental Measures ...............................................................2-10 

2.4 MODIFICATION OF THE CO-APPLICANTS’ PROPOSED ACTION.....................2-14 

2.4.1 Agency and Other Interested Party Recommendations .................................2-14 

2.4.2 Environmental Conditions.............................................................................2-14 

2.4.2.1 Federal Land Management Conditions ......................................2-14 

2.4.2.2 Section 18...................................................................................2-17 

2.4.2.3 Water Quality Certification........................................................2-17 

2.4.3 Staff Alternative ............................................................................................2-18 

2.4.3.1 Project Facilities.........................................................................2-18 

2.4.3.2 Environmental Measures............................................................2-21 

2.5 OTHER PROJECT FEATURES CONSIDERED OR ELIMINATED FROM 

DETAILED ANALYSIS...............................................................................................2-24 

2.5.1 Powerhouse Location ....................................................................................2-24 

2.5.2 Water Conduit Routes ...................................................................................2-24 

2.5.3 Transmission Alignments..............................................................................2-27 

3.0 ENVIRONMENTAL CONSEQUENCES ...................................................................................3-1 

3.1 GENERAL SETTING .....................................................................................................3-1 

3.2 CUMULATIVELY AFFECTED RESOURCES.............................................................3-1 

3.2.1 Geographic Scope............................................................................................3-2 

3.2.2 Temporal Scope...............................................................................................3-2 

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xii 

3.3 PROPOSED ACTION AND ACTION ALTERNATIVES ............................................3-2 

3.3.1 Geology and Soils............................................................................................3-2 

3.3.1.1 Affected Environment..................................................................3-2 

3.3.1.2 Environmental Consequences....................................................3-10 

3.3.1.3 Unavoidable Adverse Effects.....................................................3-26 

3.3.2 Water Resources............................................................................................3-26 

3.3.2.1 Affected Environment................................................................3-26 

3.3.2.2 Environmental Consequences....................................................3-36 

3.3.2.3 Cumulative Effects on Water Quantity and Quality ..................3-58 

3.3.2.4 Unavoidable Adverse Effects.....................................................3-58 

3.3.3 Aquatic Resources .........................................................................................3-59 

3.3.3.1 Affected Environment................................................................3-59 

3.3.3.2 Environmental Consequences....................................................3-65 

3.3.3.3 Cumulative Effects.....................................................................3-72 

3.3.3.4 Unavoidable Adverse Effects.....................................................3-73 

3.3.4 Terrestrial Resources .....................................................................................3-73 

3.3.4.1 Affected Environment................................................................3-73 

3.3.4.2 Environmental Consequences....................................................3-90 

3.3.4.3 Cumulative Effects...................................................................3-123 

3.3.4.4 Unavoidable Adverse Effects...................................................3-124 

3.3.5 Threatened and Endangered Species ...........................................................3-124 

3.3.5.1 Affected Environment..............................................................3-124 

3.3.5.2 Environmental Consequences..................................................3-129 

3.3.5.3 Cumulative Effects...................................................................3-145 

3.3.5.4 Unavoidable Adverse Effects...................................................3-146 

3.3.6 Recreational Resources................................................................................3-147 

3.3.6.1 Affected Environment..............................................................3-147 

3.3.6.2 Environmental Consequences..................................................3-155 

3.3.6.3 Unavoidable Adverse Effects...................................................3-169 

3.3.7 Land Use and Aesthetic Resources .............................................................3-169 

3.3.7.1 Affected Environment..............................................................3-169 

3.3.7.2 Environmental Consequences..................................................3-186 

3.3.7.3 Unavoidable Adverse Effects...................................................3-214 

3.3.8 Socioeconomic Resources ...........................................................................3-214 

3.3.8.1 Affected Environment..............................................................3-214 

3.3.8.2 Environmental Consequences..................................................3-218 

3.3.8.3 Unavoidable Adverse Effects...................................................3-224 

3.3.9 Cultural Resources.......................................................................................3-225 

3.3.9.1 Affected Environment..............................................................3-225 

3.3.9.2 Environmental Consequences..................................................3-230 

3.3.9.3 Unavoidable Adverse Effects...................................................3-235 

3.3.10 Air Quality and Noise..................................................................................3-235 

3.3.10.1 Air Quality ...............................................................................3-235 

3.3.10.2 Noise ........................................................................................3-240 

3.3.10.3 Environmental Consequences..................................................3-244 

3.3.10.4 Unavoidable Adverse Effects...................................................3-253 

3.4 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES.....3-253 

3.5 RELATIONSHIP BETWEEN SHORT-TERM USES AND LONG-TERM 

PRODUCTIVITY........................................................................................................3-253 

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xiii 

4.0 DEVELOPMENTAL ANALYSIS...............................................................................................4-1 

4.1 PROPOSED PROJECT ALTERNATIVES ....................................................................4-1 

4.1.1 Economic Assumptions ...................................................................................4-1 

4.1.2 Projected Energy Facility Costs for the No-action Alternative .......................4-2 

4.1.3 Projected Energy Facility Costs for the Co-applicants’ Proposal....................4-2 

4.1.4 Projected Energy Facility Costs for Staff Alternative .....................................4-6 

4.2 PROJECTED ENVIRONMENTAL COSTS ..................................................................4-8 

4.3 PROJECTED ENERGY COSTS...................................................................................4-22 

4.4 ECONOMIC COMPARISON.......................................................................................4-24 

4.5 COST OF ALTERNATIVE TRANSMISSION ALIGNMENTS .................................4-26 

4.6 SENSITIVITY TO TRANSMISSION LINE FACILITY COST OF THE LEAPS 

PROJECT AND OTHER FACTORS............................................................................4-27 

5.0 STAFF CONCLUSIONS..............................................................................................................5-1 

5.1 COMPARISON OF PROPOSED ACTION AND ALTERNATIVES ...........................5-2 

5.1.1 Co-applicants’ Proposed Action....................................................................5-10 

5.1.2 Staff Alternative ............................................................................................5-13 

5.2 DISCUSSION OF KEY ISSUES ..................................................................................5-16 

5.2.1 Project Facilities ............................................................................................5-16 

5.2.2 Construction Oversight..................................................................................5-19 

5.2.3 Geology and Soils..........................................................................................5-20 

5.2.4 Water Resources............................................................................................5-21 

5.2.5 Aquatic Resources .........................................................................................5-23 

5.2.6 Terrestrial Resources .....................................................................................5-25 

5.2.7 Threatened and Endangered Species .............................................................5-28 

5.2.8 Recreational Resources..................................................................................5-29 

5.2.9 Land Use and Aesthetics ...............................................................................5-31 

5.2.10 Cultural Resources.........................................................................................5-32 

5.3 FISH AND WILDLIFE AGENCY RECOMMENDATIONS ......................................5-33 

5.3.1 Recommendations Pursuant to Section 10(j) of the FPA ..............................5-33 

5.3.2 Recommendations Pursuant to Section 10(a)(1) of the FPA.........................5-34 

5.4 CONSISTENCY WITH COMPREHENSIVE AND OTHER RESOURCE PLANS...5-34 

5.5 RELATIONSHIP OF LICENSE PROCESS TO LAWS AND POLICIES ..................5-35 

5.5.1 Section 401 of the Clean Water Act—Water Quality Certification ..............5-35 

5.5.2 Section 18 of the Federal Power Act—Authority to Require Fishways........5-35 

5.5.3 Section 4(e) of the Federal Power Act...........................................................5-36 

5.5.4 Endangered Species Act ................................................................................5-36 

5.6.5 National Historic Preservation Act................................................................5-41 

6.0 LITERATURE CITED .................................................................................................................6-1 

7.0 LIST OF PREPARERS.................................................................................................................7-1 

8.0 LIST OF RECIPIENTS ................................................................................................................8-1 

APPENDIX A USFS REVIEW OF SPECIAL USE PERMIT APPLICATION 

APPENDIX B NEED DETERMINATION FOR 500-KV TRANSMISSION LINE 

APPENDIX C REVISED U.S. FOREST SERVICE PRELIMINARY SECTION 4(E) CONDITIONS 

APPENDIX D VISUAL SIMULATIONS 

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xiv 

APPENDIX E COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT AND 

THE OCTOBER 3, 2006, PUBLIC NOTICE FOR THE LAKE ELSINORE 

ADVANCED PUMPED STORAGE PROJECT, PROJECT NO. 11858-00 

APPENDIX F MAPS OF THE CO-APPLICANTS’ PROPOSED AND STAFF ALTERNATIVE 

TRANSMISSION ALIGNMENT 

APPENDIX G MANAGEMENT INDICATOR SPECIES (MIS) ANALYSIS 

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xv 

LIST OF FIGURES 

Figure 1. LEAPS Project—Location map.......................................................................................1-2

Figure 2. LEAPS Project—Proposed project facility locations ......................................................2-3

Figure 3. LEAPS Project—Proposed upper reservoir and powerhouse sites..................................2-4

Figure 4. Proposed operation of the LEAPS Project in pumping and generating modes................2-9

Figure 5. Staff alternative project facility locations ......................................................................2-19

Figure 6. Staff alternative showing the location of Decker Canyon upper reservoir and 

Santa Rosa powerhouse site...........................................................................................2-20

Figure 7. LEAPS Project—Location of optional Ortega Oaks and Evergreen powerhouse 

sites ................................................................................................................................2-25

Figure 8. LEAPS Project—Transmission alignments (1–5) considered but eliminated from 

detailed analyses ............................................................................................................2-29

Figure 9. LEAPS Project—Fault zones in the project area.............................................................3-6

Figure 10. LEAPS Project—Extent of inundation resulting from dam/dike break.........................3-25

Figure 11. Projected frequency of Lake Elsinore lake elevations under current conditions 

(baseline) and proposed 2020 conditions with make-up water......................................3-43

Figure 12. San Juan and San Mateo creeks near the project area....................................................3-64

Figure 13. LEAPS Project—Habitat subarea locations...................................................................3-76

Figure 14. Jurisdictional waters of the U.S. (the Corps) and of the State of California 

(CDFG) ........................................................................................................................3-102

Figure 15. LEAPS Project—Habitat core areas and linkages .......................................................3-114

Figure 16. LEAPS Project—Transmission line segments.............................................................3-121

Figure 17. LEAPS Project—Existing recreational facilities .........................................................3-152

Figure 18. LEAPS Project—Land uses and communities near proposed and alternative 

reservoir sites ...............................................................................................................3-167

Figure 19. LEAPS Project—Land uses near proposed and alternative powerhouse sites ............3-171

Figure 20. LEAPS Project—Scenic integrity objectives in the Cleveland National Forest 

and San Mateo Wilderness area...................................................................................3-181

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LIST OF TABLES 

Table ES-1. Summary of key differences in the potential effects of the co-applicants’ proposal 

and the staff alternative..................................................................................................xxiii

Table 1. Excavation quantities for penstock alternatives (per conduit) .......................................2-26

Table 2. Fill quantities for upper reservoir alternatives ...............................................................3-18

Table 3. Daily discharge (cfs) statistics for USGS gage no. 11070500 San Jacinto River at 

Elsinore, California, for water years 1975 to 2004........................................................3-27

Table 4. Daily discharge (cfs) statistics for USGS gage no. 11046530, San Juan Creek at 

La Novia Street Bridge near San Juan Capistrano, for water years 1986 to 2004.........3-29

Table 5. Estimated groundwater basin budget for Elsinore groundwater basin...........................3-30

Table 6. Beneficial use designation definitions ...........................................................................3-32

Table 7. Applicable water quality objectives for waters potentially affected by the 

proposed project.............................................................................................................3-33

Table 8. Projected Lake Elsinore response to proposed sources of make-up water ....................3-42

Table 9. Fish species reported to occur in Lake Elsinore from 1964 to 2003..............................3-59

Table 10. Special status fish species that may occur or are known to be present within the 

study area .......................................................................................................................3-65

Table 11. Natural communities mapped in the study area.............................................................3-73

Table 12. Invasive non-native plants documented to occur within the study area.........................3-77

Table 13. Special status plant species that may occur or are known to occur in the LEAPS 

study area .......................................................................................................................3-80

Table 14. Special status wildlife species that may occur or are known to be present within the 

study area .......................................................................................................................3-87

Table 15. Acreage that would be affected by construction and revegetation at proposed and 

alternative reservoir, powerhouse, staging, substation, transmission, and road 

locations.........................................................................................................................3-91

Table 16. Number of field visits conducted during FWS protocol surveys for listed species, 

by year, in the LEAPS Project area .............................................................................3-137

Table 17. Description of Recreation Opportunity Spectrum classes ...........................................3-148

Table 18. Shoreline locations of recreational value potentially affected by lake-level 

fluctuations...................................................................................................................3-150

Table 19. City of Lake Elsinore recreational facilities ................................................................3-154

Table 20. Description of SIO designations and guidelines for National Forest System lands.....3-179

Table 21. SIO designations for lands within the proposed project area or lands influenced 

by project operations....................................................................................................3-182

Table 22. BLM scenic quality scoring and evaluation criteria ....................................................3-182

Table 23. Existing scenic quality based on BLM Visual Resource Management 

inventory/evaluation criteria ........................................................................................3-183

Table 24. Comparison of proposed and alternative alignments proximity to privately 

owned parcels and land zoned for residential uses ......................................................3-189

Table 25. Suitable uses by land use zone.....................................................................................3-194

Table 26. Transmission line mileage by slope and land use zone ...............................................3-194

Table 27. Trip assignments for each of the five road segments analyzed by the 

co-applicants ................................................................................................................3-209

Table 28. Population, 1990, 2000, and 2003 (estimate) ..............................................................3-215

Table 29. Race and ethnicity, 2000..............................................................................................3-215

Table 30. Total employment by sector, 1990 and 2000...............................................................3-216

Table 31. Per capita incomes and percent of individuals below poverty level, 1999 ..................3-218

Table 32. California and federal ambient air quality standards ...................................................3-237

Table 33. California toxic air contaminants unit risk factors.......................................................3-238

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Table 34. California State area designations for criteria air pollutants........................................3-239

Table 35. A-weighted (dBA) sound levels of typical noise environments ..................................3-240

Table 36. City of Lake Elsinore construction noise standards.....................................................3-243

Table 37. Estimated air emissions from construction activities...................................................3-245

Table 38. Estimated air emissions from construction activities associated with alternate 

powerhouse locations...................................................................................................3-245

Table 39. Typical electric generation mix for California.............................................................3-247

Table 40. Comparison of emissions between the co-applicants’ proposal and no action............3-247

Table 41. Minimum distances (in feet)/construction Lmax noise levels (in dBA) at sensitive 

land uses.......................................................................................................................3-249

Table 42. Noise level increase attributed to the construction of the proposed project ................3-250

Table 43. Estimated noise levels during construction of transmission lines................................3-251

Table 44. Assumptions for economic analysis of the LEAPS Hydroelectric Project......................4-1

Table 45. Projected energy facility costs for the co-applicants’ proposal (Morrell-Santa Rosa 

alternative, excluding environmental measures), including staff review 

items (in italics) ...............................................................................................................4-3

Table 46. Projected energy facility costs for the staff alternative (Decker-Santa Rosa 

alternative excluding environmental measures), including staff review items 

(in italics).........................................................................................................................4-6

Table 47. Summary of capital and one-time costs, annual costs, and total annualized costs of 

environmental measures proposed by the co-applicants, included in the staff 

alternative, and recommended by others for the LEAPS Project ....................................4-9

Table 48. Comparison of annualized costs of environmental measures by resource area and 

overall project costs .......................................................................................................4-22

Table 49. Analysis of the pumping and turbining weekly cycles for the LEAPS Project .............4-23

Table 50. Summary of projected annual costs and capital costs under the 

co-applicants’ proposal ..................................................................................................4-24

Table 51. Summary of projected annual costs and capital costs under the staff alternative..........4-25

Table 52. Summary of annual net benefits for the no-action alternative, co-applicants’ 

proposal and staff alternative for the LEAPS Project ....................................................4-26

Table 53. Summary of construction costs and characteristics for the co-applicants’ 

proposed and staff alternative transmission alignments ................................................4-27

Table 54. Summary of annual net benefits for the no-action alternative, co-applicants’ 

proposal, and staff alternative for the LEAPS Project excluding transmission line 

construction costs...........................................................................................................4-28

Table 55. Summary of key differences in the potential effects of the co-applicants’ proposal 

and the staff alternative....................................................................................................5-2

Table 56. Fish and wildlife agency Section 10(j) recommendations.............................................5-34

Table 57. Summary of species and critical habitat findings under the staff alternative ................5-36

Table 58. Information requested in FWS letter dated June 9, 2006, and staff responses ..............5-40

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xix 

ACRONYMS AND ABBREVIATIONS 

APE area of potential effects 

APLIC Avian Power Line Interaction Committee 

AQMD Air Quality Management District 

BIA U.S. Bureau of Indian Affairs 

BLM U.S. Bureau of Land Management 

BMP best management practice 

oC degrees Celsius 

Caltrans California Department of Transportation 

CARB California Air Resources Board 

CDFG California Department of Fish and Game 

CDP Census Designated Place 

CEQA California Environmental Quality Act 

cfs cubic feet per second 

CNPS California Native Plant Society 

co-applicants Elsinore Valley Municipal Water District and Nevada Hydro 

Company, Inc. 

Commission Federal Energy Regulatory Commission 

Corps U.S. Army Corps of Engineers 

CRAM California Rapid Assessment Method 

dBA A-weighted decibel scale 

dbh diameter at breast height 

DO dissolved oxygen 

EIS environmental impact statement 

Elsinore Valley MWD Elsinore Valley Municipal Water District 

EMF electromagnetic field 

EPA U.S. Environmental Protection Agency 

ESA Endangered Species Act 

oF degrees Fahrenheit 

Flood Control District Flood Control and Water Conservation District 

FERC Federal Energy Regulatory Commission 

FPA Federal Power Act 

FWS U.S. Fish and Wildlife Service 

GIS geographic information system 

HCP Habitat Conservation Plan 

HPMP Historic Properties Management Plan 

Hz Hertz 

Interior U.S. Department of the Interior 

kV kilovolt 

Ldn day-night average sound level 

Leq equivalent sound level 

L% percentile distributions of sound levels 

LEAPS Lake Elsinore Advanced Pumped Storage 

Joint Watershed Authority Lake Elsinore and San Jacinto Watersheds Authority 

LOS level of service 

MBA Michael Brandman Associates 

mG milliGauss 

mg/l milligrams per liter 

msl mean sea level 

MIS management indicator species 

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Multi-Species HCP Multi-Species Habitat Conservation Plan 

MW megawatt 

MWh megawatt-hours 

National Register National Register of Historic Places 

NEPA National Environmental Policy Act 

Nevada Hydro Nevada Hydro Company 

NMFS National Marine Fisheries Service 

NOAA Fisheries National Oceanic and Atmospheric Administration Fisheries 

O&M operation and maintenance 

OHV off-highway vehicle 

PM10 particulates that have an aerodynamic diameter of 10 microns or 

smaller 

PM2.5 particulates that have an aerodynamic diameter of 2.5 microns or 

smaller 

R rural 

RN Roaded Natural 

ROS Recreation Opportunity Spectrum 

San Diego Water Board San Diego Regional Water Quality Control Board 

Santa Ana Water Board Santa Ana Regional Water Quality Control Board 

SCE Southern California Edison 

SDG&E San Diego Gas & Electric Company 

SHPO State Historic Preservation Officer 

SIO Scenic Integrity Objective 

SPNM Semi-primitive, Non-motorized 

SPM Semi-primitive, Motorized 

STEP Southwest Transmission Expansion Plan 

State Water Board State Water Resources Control Board 

TCP traditional cultural properties 

TE/VS Interconnect Talega-Escondido/Valley-Serrano 500-kV Interconnect Project 

TMDL Total Maximum Daily Load 

μg/l micrograms per liter 

USFS U.S. Department of Agriculture, Forest Service 

USGS U.S. Geological Survey 

V/m volts per meter 

WECC Western Electricity Coordinating Council 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
COVER SHEET 

FEDERAL ENERGY REGULATORY COMMISSION 

FINAL ENVIRONMENTAL IMPACT STATEMENT 

FOR HYDROPOWER LICENSE 

Lake Elsinore Advanced Pumped Storage Project 

Docket No. P-11858-002 

Executive Summary 

Pages xxi through xxx 

FEIS 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
xxi 

EXECUTIVE SUMMARY 

On February 2, 2004, the Elsinore Valley Municipal Water District (Elsinore Valley MWD) and 

the Nevada Hydro Company, Inc. (Nevada Hydro), or co-applicants, filed an application for an original 

license with the Federal Energy Regulatory Commission (Commission or FERC) for constructing and 

operating the 500-megawatt Lake Elsinore Advanced Pumped Storage Project (LEAPS Project). The 

project would occupy 2,412 acres of federal lands, including lands managed by the U.S. Department of 

Agriculture, Forest Service (USFS), Cleveland National Forest; U.S. Bureau of Land Management; and 

the Department of Defense (Camp Pendleton). The USFS is reviewing an application for special use 

permit for constructing the Talega-Escondido/Valley-Serrano 500-kilovolt transmission interconnection, 

including transmission lines associated with the LEAPS Project, as a transmission line only project. The 

USFS is a cooperating agency in preparing this environmental impact statement (EIS) for the LEAPS 

Project (FERC No. 11858), including both the pumped-storage facilities and the transmission lines. 

This final EIS evaluates the potential natural resource benefits, environmental effects, and 

economic costs associated with granting a FERC license for the entire LEAPS Project and granting a 

USFS special use permit for the transmission lines associated with the project. The alternatives examined 

include the following: (1) no action (likely construction of a simple-cycle combustion turbine and denial 

of the special use permit); (2) the co-applicants’ proposed action; and (3) a staff alternative. 

As described in detail in section 2.3, the co-applicants’ proposed action consists of an upper 

reservoir in Morrell Canyon, a powerhouse at the Santa Rosa location, and a transmission line that would 

cross the Cleveland National Forest. The co-applicants propose numerous measures to address the 

potential effects of the proposed LEAPS Project on environmental resources in the project area. We 

describe these proposed measures in detail in section 2.3.6. The staff alternative that comprises an upper 

reservoir at the Decker Canyon site, a powerhouse at the Santa Rosa location, and a transmission 

alignment is described in detail in section 2.4.3. The staff alternative includes most of the co-applicants’ 

protection, mitigation, and environmental measures, except for those measures associated with the 

Morrell Canyon upper reservoir site and the installation of fish screens. We have modified several of the 

co-applicants-proposed measures and added others. 

The co-applicants’ proposal to locate the upper reservoir in Morrell Canyon would disrupt flows 

in the San Juan Creek drainage, displace Lion Spring, and remove more than 20 acres of southern coast 

live oak riparian forest. Recreational use at this location would be adversely affected because Morgan 

Trail, which accesses the San Mateo Wilderness Area, would need to be relocated either temporarily or 

permanently depending on the final design of this facility and because two of the most-used hang gliding 

launch sites (E and Edwards) would be closed or subjected to use restrictions during construction. To 

avoid these potential adverse effects, the staff alternative would locate the upper reservoir in Decker 

Canyon. There would be no need to install a stream bypass conveyance system at this location because 

the footprint of the reservoir is situated at the very top of the watershed, with no established stream 

network entering the site. Only 5 acres of southern coast live oak would be affected and less off-site 

mitigation for habitat loss would be required, and no rare plant species would be affected. Locating the 

upper reservoir at the Decker Canyon location would avoid construction effects on the use of the E and 

Edwards hang gliding launch sites. Table ES-1 compares the potential effects at the proposed Morrell 

Canyon and Decker Canyon locations. 

As described in the draft EIS, the co-applicants proposal to connect to the proposed underground 

powerhouse at the Santa Rosa location via an above-ground transmission line along the South Main 

Divide Road would have adversely affected the egress from the community of Rancho Capistrano in the 

case of a wildfire and would have precluded hang gliding activities at the USFS permitted launch sites. In 

the draft EIS, we included an underground powerhouse at the Ortega Oaks site and a mid-slope 

transmission alignment in a staff alternative to the co-applicants’ proposal. The Ortega Oaks site 

combined with routing the transmission lines along a mid-slope alignment and west of the USFSDocument Accession #: 20070130-4000 Filed Date: 01/30/2007
xxii 

permitted launching sites lessened the potential effects on hang gliding opportunities and provided an 

opportunity to provide a formal landing area. 

In comments on the draft EIS, the co-applicants and others point out that Riverside County 

approved a subdivision of 100 single family residential lots at Ortega Oaks in April 2004, including the 

58-acre site included in the staff alternative for the powerhouse and substation. The co-applicants also 

filed a report on the comparative geological and geotechnical conditions at the three powerhouse sites 

(Genterra, 2006). This report concludes that the Ortega Oaks site offers the least desirable subsurface 

conditions of the three sites. Hang gliding advocates commented that the proposed 5-acre formal landing 

area at Ortega Oaks would be inadequate and the staff alternative would still present hazards associated 

with an aboveground substation and the above-ground electrical distribution lines. 

In response to the draft EIS and comments on the draft EIS, the co-applicants revised their 

proposed transmission alignment. In response to comments on the draft EIS, we also revised the staff 

alternative transmission alignment and powerhouse location. Given the proximity to the existing 

residential community adjacent to the Ortega Oaks site, the approved subdivision of lands that comprise 

the site, and the fact it would not eliminate hazards to hang gliders, we have revised the staff alternative to 

include a powerhouse at the Santa Rosa location. Locating the powerhouse at the Santa Rosa site would 

avoid conflicts with existing and planned high-density residential communities at Ortega Oaks. This 

alternative also would provide a clear path for hang gliding from the USFS-permitted launch sites along 

South Main Divide Road and the existing informal landing site at Ortega Oaks and would place the above 

ground substation away from the existing landing site. Table ES-1 compares the potential effects of the 

Santa Rosa and Ortega Oaks powerhouse locations. 

As described in the draft EIS, both the co-applicants’ proposed and staff alternative alignments 

would have created conflicts with commercial enterprises along the northern segment of the transmission 

alignments. Both the co-applicants’ proposed and staff alternative alignments now avoid those conflicts. 

Both also include underground segments of about 3 and 2.1 miles, respectively, to reduce potential effects 

on egress from the Rancho Capistrano community and on hang gliding activities at the USFS permitted 

hang gliding launch sites. The staff alternative transmission alignment also reduces conflicts with the 

Cleveland National Forest Land Management Plan and USFS fire suppression activities. The coapplicants' proposed alignment reduces conflicts with residential subdivisions along the southern segment 

and would generally be less visible to area residents. The southern segment of the staff alternative 

transmission alignment avoids the San Mateo Wilderness area but runs near private residential properties, 

including the La Cresta community. The two routes are the same along about 4 miles of the southern end 

of the alignment to the connection with the SDG&E line. Table ES-1 compares the effects of the coapplicants’ proposed transmission alignment and the staff alternative transmission alignment. 

We considered whether to include in the staff alternative the burial of the entire 32-mile-long 

transmission line and the 2-mile connection to the powerhouse or burying portions along the northern and 

southern alignments. Burying the entire line would eliminate most of the visual effects (there would still 

be above ground substation connections) but would be cost prohibitive at an incremental cost in excess of 

$350 million. However, we recognize that there may be locations near the alignment (such as Sycamore 

Creek or Glen Eden Sun Club) where the acquisition of easements may displace residents and where 

additional underground segments may be a feasible solution. 

Overall, the staff alternative transmission alignment would reduce conflicts with USFS 

management plan and fire suppression activities, hang gliding activities, and commercial enterprises. We 

recognize that the co-applicants’ proposed alignment is the less visible from key viewpoints in the 

wilderness area, along Ortega Highway, and from Lake Elsinore, but it would still interfere with USFS 

fire suppression activities in several areas and would cross back-country non-motorized areas of the 

Cleveland National Forest. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
xxiii 

We estimate that the cost of building and operating either the co-applicants’ proposal or the staff 

alternative would exceed their economic benefits during the project’s first year of operation. The 

proposed LEAPS Project is estimated to cost $120,172,600 ($77.03/MWh) more annually than alternative 

power and the staff alternative is estimated to cost $124,841,500 ($80.03/MWh) more than alternative 

power annually. Although there are several reasons why the staff cost estimate is higher than the coapplicants’ estimate, the main one is that our estimated cost to construct the project is higher than the coapplicants’. Because of the limited subsurface data available, we have significantly increased the coapplicants’ cost estimate in several areas because we do not think the co-applicants’ cost estimate 

properly accounts for the site-specific geological and groundwater conditions. During the final design 

process, the co-applicants’ propose to conduct more detailed geotechnical studies. If the site information 

the co-applicants gather shows the site conditions are better than what we assumed, they may be able to 

build the project for less than the cost we estimate. 

Despite the higher cost of the staff alternative compared to no action, it would have the benefit of 

allowing the co-applicants to construct and operate the project as a peak energy resource and as part of a 

long-term solution to southern California’s transmission congestion bottlenecks. The TalegaEscondido/Valley-Serrano transmission line could provide up to 1,000 MW of import capability into the 

San Diego area with up to 500 MW of this imported power being supplied by the LEAPS Project during 

high-demand periods. Pumped storage stores power during off-peak periods that can be provided rapidly 

during on-peak periods, which could provide a valuable addition to the regional system. 

Based on our independent analysis of the LEAPS Project, including our consideration of all 

relevant economic and environmental concerns, we select the staff alternative as our preferred alternative 

and conclude that our preferred alternative represents the best balance between developmental and nondevelopmental resources. 

Table ES-1. Summary of key differences in the potential effects of the co-applicants’ 

proposal and the staff alternative. (Source: Staff) 

Upper Reservoir Comparison 

Resource/Issue Morrell Canyon (co-applicants) Decker Canyon (staff) 

130-acre footprint; daily fluctuations of 40 

feet and weekly fluctuations of 75 feet 

120-acre footprint; daily and weekly 

fluctuations would be on the same order of 

magnitude as the upper reservoir at Morrell 

Canyon 

Area of effect 

2.6 million cubic yards of fill needed for 

dam 

3.0 million cubic yards of fill needed for 

dam 

Fill materials Less overburden at Decker Canyon would 

allow easier procurement of solid rock 

material for fill for dam and dike 

construction 

Groundwater Construction of tunnels for high pressure 

conduits could affect groundwater; design 

review of collection system for Lion Spring 

and effects on groundwater 

Construction of tunnels for high pressure 

conduits could affect groundwater; no 

collection system would be required 

Seismic hazards Faults may control surface flows at the 

Morrell Canyon site 

No faults have been identified at the Decker 

Canyon site and subsurface flow does not 

appear to be controlled by the presence of 

faults 

Surface water Upper reservoir would interrupt stream flow Same 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
xxiv 

Upper Reservoir Comparison 

Resource/Issue Morrell Canyon (co-applicants) Decker Canyon (staff) 

Wetland and riparian 

habitat 

Would affect 1.7 acres of waters of the U.S. 

and 4.8 acres of waters of the state, 

including Lion Spring; loss of these waters 

and associated riparian habitat would affect 

plant diversity and wildlife species; effects 

on downstream areas would be minimized 

by the water conveyance system under the 

reservoir 

Would affect 0.3 acre of waters of the U.S. 

and 0.9 acre of waters of the state; no effects 

on springs or seeps; smaller effects on 

downstream areas because drainage area is 

smaller 

Oak woodland 

communities 

Would convert about 20 acres of southern 

coast live oak forest (500 to 600 individual 

trees over 8 diameter at breast height [dbh]) 

to project use; would need to plant 20 acres 

to mitigate 

Would convert about 5 acres of southern 

coast live oak forest to project use so effects 

would be similar to Morrell Canyon but on a 

smaller scale; would only need 5 acres to 

mitigate 

Special status 

wildlife 

Would convert 80 acres of chamise 

chaparral and 20 acres of southern coastal 

live oak to project facilities 

Would convert 95 acres of chamise 

chaparral and 5 acres of southern coastal 

live oak to project facilities 

Mountain lion Would remove 100 acres of suitable 

mountain lion habitat from Core B; project 

operation and maintenance would not likely 

increase disturbance or risk of interaction 

over levels that currently result from traffic 

on South Main Divide Road and use of 

Morgan Trail 

Would remove 100 acres of suitable 

mountain lion habitat from Core B; project 

operation and maintenance would represent 

a very small increase in disturbance, because 

no trails currently provide for recreation at 

Decker Canyon site 

Munz’s onion No suitable habitat at reservoir site; 

however, South Main Divide Road in 

vicinity passes through a soil type that is 

known to support occurrences of this species 

Same 

Developed recreation 

facilities 

Footprint would not include Morgan Trail 

trailhead with minimal effect on users of the 

trailhead during construction but trail would 

need to be re-routed either temporarily or 

permanently depending on final design 

Morgan Trail would not have to be rerouted 

and because visitation is low, increased 

traffic on South Main Divide Road would 

have minimal effect on Morgan trailhead 

users 

Dispersed recreation Would affect hang gliders using the 2 most 

suitable of the 9 launch sites and waterside 

setting offered at Lion Spring 

Would avoid effects on two most popular 

hang glider launch sites 

 Would eliminate a natural looking canyon 

with oak woodland vegetation and replace it 

with a reservoir surrounded by a chain link 

fence; inconsistent with Retention VQO 

The existing aesthetic resources within 

Decker Canyon are subordinate to Morrell 

Canyon and construction effects associated 

with building a reservoir in this location 

would be less than those at the Morrell site; 

development of the alternative site would 

not build over a mature oak-woodland 

riparian area (Lion Spring) 

Traffic Would achieve a balance of excavation to 

fill within the entire project site 

Same 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
xxv 

Upper Reservoir Comparison 

Resource/Issue Morrell Canyon (co-applicants) Decker Canyon (staff) 

Cultural resources Would destroy or damage four prehistoric 

archaeological sites 

No known sites at Decker Canyon location 

Powerhouse Site Comparison 

Resource/Issue 

Santa Rosa 

(Co-applicants and Staff) Ortega Oaks Evergreen 

30-acre site, 20-acre laydown, 

340 depth of excavation 

58 acres, inclusive of 

laydown; 320 depth of 

excavation; groundwater 30 

to 70 feet 

75 acres, 30-acre laydown, 

290 depth of excavation 

Area of effect 

327,500 cubic yards (includes 

207,000 from the powerhouse 

cavern; 35,000 from the 

transformer gallery; 32,000 

from the surge shaft; 500 

from the vent shaft; and 

53,000 from the powerhouse 

access shaft) 

There will be similar values 

to Santa Rosa but about 33 

percent more excavation for 

the tailrace tunnel, which 

would be about 86,450 cubic 

yards since the Santa Rosa 

tailrace tunnel is 65,000 cubic 

yards; also, the depth of 

excavation is slightly less 

than that of Santa Rosa 

There will be similar values 

to Santa Rosa but about 10 

percent less excavation for the 

tailrace tunnel, which would 

be about 58,500 cubic yards 

since the Santa Rosa tailrace 

tunnel is 65,000 cubic yards; 

also the depth of excavation is 

less than that of Santa Rosa 

Special status 

plants 

Construction of the 

powerhouse could affect 

Coulter’s matilija poppy 

Construction of tunnel 

between upper reservoir and 

powerhouse could affect 

Coulter’s matilija poppy 

No rare plants identified in 

vicinity of Evergreen 

powerhouse location 

Wetland and 

riparian habitat 

Would affect about 0.4 acre 

of waters of the U.S. and state 

Same as Santa Rosa. Would affect less than onetenth of an acre of waters of 

the U.S. and state 

Special status 

wildlife 

Would affect 30 acres of 

coastal sage scrub and 

20 acres of non-native 

grassland 

Would affect 53 acres of nonnative grassland and 5 acres 

of coastal sage scrub 

Would affect 55 acres of nonnative grasslands and 20 acres 

of coastal sage scrub 

Future recreation 

use 

Location of substation and 

above ground transmission 

lines from this location would 

affect hang gliding activities 

Would affect use of hang 

gliding landing site during 

construction; would provide 

formal hang gliding landing 

site following construction 

Would displace informal 

disperse recreational use at 

site 

Land Use and 

Property values 

Would permanently change 

use to utility and recreation 

use and preclude residential 

use specified in General Plan; 

would purchase, modify, and 

reuse adjacent private 

property (Santa Rosa 

Mountain Villa apartments) 

and buffer would reduce 

effect on property values 

No effect on adjacent 

residential property values at 

Ortega Oaks 

Either raze or use current 

Lakeland Childcare Center at 

the Lakeland Village Plaza 

for construction office 

resulting in displacement of 

child-related businesses and 

purchase/raze one single 

family home 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
xxvi 

Powerhouse Site Comparison 

Resource/Issue 

Santa Rosa 

(Co-applicants and Staff) Ortega Oaks Evergreen 

Aesthetics The powerhouse would be 

underground but the 

substation would be visible 

from surrounding residential 

and commercial properties 

The powerhouse would be 

underground but the 

substation would be visible 

from the heavily used Ortega 

Highway 

Same as Santa Rosa. 

Aesthetics 

(cont). 

All construction activities 

within this area would 

conflict with the Partial 

Retention VQO designated by 

the USFS; these effects would 

be short term and last for the 

duration of the construction 

Construction activity at 

Ortega Oaks site would be 

visible from the Ortega 

Highway and a small portion 

of Grand Avenue in Lakeland 

Village; two prominent 

viewpoints to commuters in 

the area 

Similar effects on the 

aesthetic resources as 

described above with respect 

to the proposed Santa Rosa 

site 

Cultural 

Resources 

Would affect two historic 

sites and one prehistoric 

archaeological site; could 

affect two historic buildings 

(vibration) and penstock 

Would directly affect one 

prehistoric site 

No known sites at Evergreen 

location 

Transmission Alignment Comparison 

Resource/Issue Co-applicants’ Proposed Alignment Staff Alternative Alignment 

Area of effect 34.1 miles in length with 10.8 miles of 

temporary access roads and 5.2 miles of 

permanent access road. 

33.7 miles in length with 9.3 miles of 

temporary access roads and 4.1 miles of 

permanent access road. 

Fire suppression 

activities 

Could interfere with USFS fire suppression 

activities. 

Would avoid interference with USFS fire 

suppression activities. 

Special status plants Could affect Humboldt lily (Subarea 3); 

passes through potential habitat for 

Hammitt’s clay-cress (Subarea 5). Preconstruction surveys could be conducted to 

prevent adverse effects during construction, 

but temporary access roads and permanent 

maintenance roads would substantially 

increase the risk of disturbance and habitat 

damage during project operation, if public 

access is not controlled. 

Could affect Humboldt lily (Subarea 3); 

avoids potential habitat for Hammitt’s claycress (Subarea 5). Pre-construction surveys 

could be conducted to prevent adverse 

effects during construction, but temporary 

access roads and permanent maintenance 

roads would substantially increase the risk 

of disturbance and habitat damage during 

project operation, if public access is not 

controlled. 

Wetland and riparian 

habitat 

Substation could affect about 1.1 acres of 

waters of the U.S. and state; effects from 

transmission towers would be minor as 

towers would be placed to avoid wetland 

and riparian habitat, but locations of access 

roads are unknown. 

Same. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
xxvii 

Transmission Alignment Comparison 

Resource/Issue Co-applicants’ Proposed Alignment Staff Alternative Alignment 

Special status 

wildlife 

Substations would affect 35 acres and 

transmission line towers would affect 

30 acres of potential habitat for special 

status species. About 10.3 miles of 

temporary access roads would affect an 

estimated 15.7 acres, plus indirect effects of 

construction (edge effects) and potential for 

disturbance (e.g., poaching, harassment) and 

habitat damage during operation, if public 

access is not controlled. Permanent 

maintenance road would affect 5.2 miles 

(9.5 acres). 

Substations would affect 35 acres and 

transmission line towers would affect 

30 acres of potential habitat for special 

status species. About 9.3 miles of 

temporary access roads would affect an 

estimated 13.5 acres, plus indirect effects of 

construction (edge effects) and potential for 

disturbance (e.g., poaching, harassment) and 

habitat damage during operation, if public 

access is not controlled. Permanent 

maintenance road would affect 4.1 miles 

(7.5 acres). 

Mountain lion Would remove about 21.25 acres of suitable 

mountain lion habitat from Core B for about 

85 towers; although mountain lions may use 

roads for travel, construction of 5.2 miles of 

permanent and 10.8 miles of temporary 

access roads would substantially increase 

the risk of disturbance (e.g., poaching, 

harassment) and habitat damage during 

project operation, if public access is not 

controlled. Would cross proposed linkage 1 

at Temescal Wash, but tower placement 

should not interrupt travel corridor. 

Same, except construction of 4 miles of 

permanent roads and 9.3 miles of temporary 

access roads would increase the risk of 

disturbance. 

Bird/T-lines Northern portion (Temescal Wash/Lee 

Lake) of line presents a high risk to 

waterfowl; central portion siting either 

underground or behind ridgeline would 

minimize risk to raptors; southern portion 

poses moderate risk of collision where it 

would cross major drainages. 

Same. 

Munz’s onion Would affect about 3.25 acres of potential 

habitat along the northern portion of the 

transmission line, about 23.2 acres at 

underground segment, and 35 acres at the 

northern substation. Pre-construction 

surveys could be conducted to prevent 

adverse effects during construction, but 

temporary access roads and permanent 

maintenance roads would substantially 

increase the risk of disturbance and habitat 

damage during project operation, if public 

access is not controlled. 

Same except would affect about 15.1 acres 

at underground segment. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
xxviii 

Transmission Alignment Comparison 

Resource/Issue Co-applicants’ Proposed Alignment Staff Alternative Alignment 

Slender-horned spine 

flower, San Diego 

ambrosia, California 

Orcutt grass, San 

Jacinto Valley 

crownscale 

Occurrences at Temescal Wash at Indian 

Creek and Alberhill (Subarea 1); vernal pool 

habitat may exist along southern segment of 

alignment (Subarea 8). Tower construction 

could affect about 3.25 acres of potential 

habitat. Pre-construction surveys could be 

conducted to prevent adverse effects during 

construction, but temporary access roads 

would substantially increase the risk of 

disturbance and habitat damage during 

project operation, if public access is not 

controlled. 

Same. 

Thread-leaved 

brodiaea 

Occurrences in the vicinity of Tenaja Creek 

(Subarea 7). Tower construction could 

affect about 0.25 acre of potential habitat. 

Pre-construction surveys could be conducted 

to prevent adverse effects during 

construction, but temporary access roads 

would substantially increase the risk of 

disturbance and habitat damage during 

project operation, if public access is not 

controlled. 

Same. 

Quino checkerspot 

butterfly 

Substation and tower construction would 

affect 36.75 acres within designated critical 

habitat and about 0.75 acre of potential 

habitat. Temporary access roads would 

substantially increase the risk of disturbance 

and habitat damage during project operation, 

if public access is not controlled. 

Same. 

Arroyo toad and 

California red-legged 

frog 

Construction of towers at Temescal Wash 

(north) and Los Alamos Canyon and Tenaja 

Creek (south) could adversely affect about 

1.25 acres of potential arroyo toad habitat; 

but could avoid California red-legged frog 

habitat through siting. No effects on critical 

habitat for either species, but temporary 

access roads would substantially increase 

the risk of disturbance and habitat damage 

during project operation, if public access is 

not controlled. 

Same. 

Southwestern willow 

flycatcher and least 

Bell’s vireo 

Occurrences at Temescal Wash and Tenaja 

Creek; construction of towers could affect 

about 1 acre of potential habitat. Access 

roads could also adversely affect habitat; 

temporary access roads would increase risk 

of disturbance and habitat damage during 

project operation, if public access is not 

controlled. 

Same. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
xxix 

Transmission Alignment Comparison 

Resource/Issue Co-applicants’ Proposed Alignment Staff Alternative Alignment 

Coastal California 

gnatcatcher 

Construction of northern substation and 

towers could affect 38.5 acres of habitat 

within proposed critical habitat; access roads 

could also adversely affect habitat; 

temporary access roads would increase risk 

of disturbance and habitat damage during 

project operation, if public access is not 

controlled. 

Same. 

Stephens’ kangaroo 

rat 

Construction of northern substation and 

towers could affect over 38.25 acres of 

habitat within the Stephens’ Kangaroo Rat 

Fee Assessment Area and Lake MathewsEstelle Mountain Core Reserve; temporary 

access roads could also affect habitat and 

would increase the risk of disturbance and 

habitat damage during project operation, if 

public access is not controlled. 

Same except includes access roads with 

northern substation and towers. 

Developed recreation 

facilities 

Would affect Wildomar OHV area and 

campground and these facilities would likely 

need to be closed during the first 2 years of 

construction (would be covered in the 

detailed site plan for construction) 

Would avoid Wildomar OHV and 

campground locations; increased traffic due 

to construction would have minimal effects 

on users at these facilities 

Dispersed recreation Major effect on dispersed recreation would 

be in the vicinity of flight paths used by 

hang gliders; would present safety hazards; 

would result in considerable loss of hang 

gliding opportunities 

Avoids some conflicts with hang gliding and 

USFS land classifications where 

transmission line construction would be 

inconsistent with USFS land management 

directives 

Aesthetics Towers and corridors would be visible in the 

foreground, middleground and background; 

construction activities within the Cleveland 

National Forest would result in features 

which conflict with the Retention and Partial 

Retention VQO standards 

Would introduce line, colors, and textures 

into the landscape that do not currently exist 

and this would not be consistent with 

Retention VQO and would be slightly more 

visible from key viewpoints than the coapplicants’ proposed alignment 

 The linear features of the lines would 

contrast with the mountain and within the 

Cleveland National Forest be in conflict 

with the VQOs; the towers, conductors and 

resulting footprint of the corridor would be 

visible from highly traveled roadways 

Same. Also because the lines would be 

lower down on the mountain they would be 

closer to Lakeland Village and more visible 

from the community of Lake Elsinore 

Future recreation use Transmission alignment would affect use by 

hang gliders of both launch and landing 

areas but avoids residential areas. 

Would reduce conflicts with hang gliding 

uses. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
xxx 

Transmission Alignment Comparison 

Resource/Issue Co-applicants’ Proposed Alignment Staff Alternative Alignment 

Roads About 15.7 acres of temporary access roads 

could be revegetated; it is estimated that 

about 10.8 miles of road would be needed to 

service 32.1 miles of transmission line. 

About 5.2 miles (9.5 acres) would be needed 

for a permanent maintenance road along the 

underground segment. 

About 13.5 acres of roads could be 

revegetated; public use could adversely 

affect habitat along 9.3 miles of road. 

About 4.1 miles (7.5 acres) would be needed 

for a permanent maintenance road along the 

underground segment. 

Property values Would adversely affect private property 

values up to 3 miles and 5 miles from where 

transmission alignment would cross or 

parallel private properties along northern 

portion and southern portion, respectively 

and would cross or be parallel within 

0.25 mile about 8.6 miles of lands 

designated for residential development and 

may make these lands less desirable for 

development. 

Would adversely affect private property 

values up to 4 miles and 9 miles from where 

transmission alignment would cross or 

parallel private properties along northern 

portion and southern portion, respectively 

and would cross or be parallel within 

0.25 acres of about 15.9 miles of land 

designated for residential development 

under the General Plan and may make these 

location less desirable for development. 

Land Use Would be within 0.25 mile of 406 privately 

owned parcels and would cross or be 

adjacent to 6.1 miles of property zoned for 

residential use. 

Would be within 0.25 miles of 452 privately 

owned parcels and would cross or be 

adjacent to 13.4 miles of property zoned for 

residential use. 

Cultural resources Northern segment could affect one 

prehistoric and two historic period 

archaeological sites; southern portion would 

not effect any known sites, but southern 

substation would affect one prehistoric site 

and sites in unsurveyed areas 

Alignment has not been surveyed; could 

affect as yet unknown prehistoric sites 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
Document Accession #: 20070130-4000 Filed Date: 01/30/2007

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COVER SHEET 

FEDERAL ENERGY REGULATORY COMMISSION 

FINAL ENVIRONMENTAL IMPACT STATEMENT 

FOR HYDROPOWER LICENSE 

Lake Elsinore Advanced Pumped Storage Project 

Docket No. P-11858-002 

Section 4 

Developmental Analysis 

Pages 4-1 through 4-28 

FEIS 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-1 

4.0 DEVELOPMENTAL ANALYSIS77

4.1 PROPOSED PROJECT ALTERNATIVES 

4.1.1 Economic Assumptions 

Under its approach to evaluating the economics of hydropower projects, as articulated in Mead 

Corporation, Publishing Paper Division (72 FERC ¶61,027, July 13, 1995), the Commission employs an 

analysis that uses present day price levels to compare the costs of the proposed project and likely 

alternative power sources, with no consideration for potential future inflation, escalation, or deflation 

beyond the license issuance date. The Commission’s economic analysis provides a general estimate of 

the potential power benefits and costs of the project and its reasonable alternatives. The estimate helps to 

support an informed decision concerning what is in the public interest with respect to a proposed license. 

For our economic analysis of the LEAPS Project, we used the assumptions, values, and sources 

shown in table 44. Information supporting the assumptions was provided in the Elsinore Valley MWD 

and Nevada Hydro (2005, 2004a). 

Table 44. Assumptions for economic analysis of the LEAPS Hydroelectric Project. 

Assumption Value Source 

Dollar basis 2005 Staff 

Period of analysis (years) 30 Staff 

Term of financing (years) 20 Staff 

Interest rate 9.50% Co-applicants 

Return on equity ratea

 12% 

Discount rateb 9.50% Staff 

Debt:Equity ratio 70:30 Co-applicants 

Depreciation Modified Accelerated Cost 

Recovery Systems 

(150% early on) 

Staff 

Insurance ratec

 0.23% Co-applicants 

Property tax rated

 1.73% Co-applicants 

Federal income tax rate 34% Co-applicants 

State income tax rate 8.84% Co-applicants 

Escalation after 2005 0% Staff 

Simple-cycle Combustion Turbine Parameters

Heat rate (MMBTU/kWh) 10,000 Co-applicants 

Cost of natural gas ($/MWh) 62.17 EIA (2005) 

Variable O&M cost ($/MWh) 9.28 CEC (2003, as adjusted by staff)

 

77 This is a standard section for Commission NEPA documents that does not necessarily reflect the 

methods or conclusions of the USFS staff on project economics. In this section, “we” means 

“Commission staff.” 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-2 

Assumption Value Source 

Fixed cost component (capacity benefit) 

($/MW) 

$81,800 CEC (2003, as adjusted by staff)

Energy Value Parameters 

Off-peak energy value at south of 

path 15 ($/MWh) 

$40.00 Platts (2005) 

Peak energy value at south of path 15 

($/MWh) rate 

$57.65 Platts (2005) 

Higher demand peak energy value at 

south of path 15 ($/MWh)e

$69.18 Platts (2005) 

a

 The co-applicants assumed an after tax return on equity of 15 percent. Recent rate makings in California led 

staff to choose a before tax return on equity of 12 percent for purposes of this analysis. 

b

 The discount rate is assumed equal to the co-applicants’ interest rate on debt. 

c

 The co-applicants provided an insurance figure of $2,000,000, which staff divided by a project cost of 

$866,333,000. 

d

 The co-applicants provided a property tax figure of $15,000,000, which staff divided by a project cost of 

$866,333,000. 

e

 The ratio for higher demand peak energy value to peak energy value is 1.20. 

4.1.2 Projected Energy Facility Costs for the No-action Alternative 

The likely no-action alternative to the LEAPS Project that would provide a comparable amount of 

energy (1,560,000 MWh) and capacity is a 500-MW simple cycle turbine operating at a heat rate of about 

10,000 Btu/kWh. Based on our review of recent energy prices in the state of California, such a project 

would have an annual cost of about $97.7 per MWh. 

4.1.3 Projected Energy Facility Costs for the Co-applicants’ Proposal 

The co-applicants propose a pumped storage project with an upper reservoir located in Morrell 

Canyon and a powerhouse located at the Santa Rosa site. The detailed proposal is described in section 

2.3. Staff independently reviewed the engineering costs associated with the LEAPS Project. Our review 

suggests that the co-applicants’ estimated costs may be understated with regard to overburden excavation, 

disposal, and foundation preparation for the upper reservoir, the unit cost of tunnel excavation, the length 

of the steel-lined section, seismic design features for the penstocks, engineering and construction 

management, and the allowance provided for contingencies. 

The co-applicants’ upper reservoir cost estimate does not explicitly include items for overburden 

excavation and disposal, foundation preparation, the dam concrete face plinth, and reservoir lining and 

drainage measures. The concrete plinth may be included in the face concrete so we have not added costs 

for this component. Although the proposed concrete-faced rock fill dam is not one of the conceptual 

designs presented by the co-applicants in exhibit F (figure F-2), it is probably the most suitable dam type 

for a seismically active region and for a reservoir subject to the rapid filling and drawdown associated 

with a pumped storage facility. Our review questions the co-applicants’ proposed use of a random earth 

fill dam because of the risk of settlement and cracking of the facing. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-3 

A concrete-faced rock fill dam would require excavation of the overburden down to sound 

bedrock over approximately two-thirds of the base. Assuming that the rock fill quantities shown in the 

co-applicants’ cost estimate were measured to the bedrock surface and not to the ground surface, 

excavation of the 25 to 50 feet of overburden at the Morrell Canyon site could amount to 25 to 40 percent 

of the dam fill volume. It is unlikely that the overburden would yield significant quantities of material 

suitable for a concrete-faced rock fill dam and that the material would require disposal. Therefore, we 

have increased the co-applicants’ cost estimate by adding $6,500,000 for overburden disposal (at Morrell 

Canyon only), $10,000,000 for additional excavation, foundation preparation, and preparation of the 

surface for lining, and $6,000,000 for additional quarrying and haulage of suitable fill. 

The co-applicants show a unit cost for tunnel and penstock excavation of $125 per cubic yard. 

Recent contracts for hard rock tunneling suggest that a unit cost of $200 per cubic yard would be more 

realistic, particularly in view of the double handling required at the powerhouse shaft and the possibility 

that haulage to disposal would be required. The co-applicants show the penstock excavation for the steellined section of the tunnel as 600 feet. However, the drawings of the penstock alternatives and table of 

quantities presented in the license application indicate 2,500 feet of steel lining would be required. We 

are uncertain if the ground slope has been taken into account and suggest that the length of the steel-lined 

section should be at least 2,800 feet. Assuming two lengths of penstock, as the co-applicants propose, the 

total length of steel lining would be 5,600 feet, or about 10 times the length included in the co-applicants’ 

cost estimate. We also question the co-applicants cost estimate for the tailrace tunnel through the rock-tosoft ground transition zone, and we are uncertain as to the co-applicants’ intended diameter of the tailrace 

penstock. Constructing two tunnels of 125 feet length, 40 feet diameter, and 150 feet depth to permit safe 

crossing of this transition zone could add $13,600,000 to the cost of construction. Therefore, we have 

added $13,875,000 for the higher unit cost of excavation of the tunnel and penstock shafts, $51,000,000 

for the longer length of the steel-lined section of the penstock, and $13,600,000 for the transition zone 

tunnels to the co-applicants’ cost estimate. Additionally, we included $5,000,000 for seismic design 

features along the Willard Fault. We also determined that the co-applicants appear to have assumed three 

rather than two tunnels for purposes of estimating excavation costs. We have therefore reduced those 

costs by 1/6 or $25,722,000. 

Finally, the co-applicants provided a contingency allowance of 20 percent in the license 

application, but only 2.28 percent in the revised cost estimate filed in response to the our request for 

additional information. The co-applicants' cost estimate does not appear to include costs for final designs, 

model tests, and construction management which would typically add 10 percent to overall project costs. 

The design is also at a very conceptual level. Contingencies of 30 percent and 15 percent would typically 

be added to the estimates for civil works, and mechanical and electrical equipment, respectively, at this 

stage of design development. Therefore, we have added contingencies of 30 percent and 15 percent to the 

co-applicants' cost estimate. Finally, we adjusted the financing and the other miscellaneous project cost 

categories to reflect the higher total capital costs. 

We present our evaluation of these costs and the resulting total facility costs, excluding 

environmental measures, in table 45. 

Table 45. Projected energy facility costs for the co-applicants’ proposal (Morrell-Santa 

Rosa alternative, excluding environmental measures), including staff review items 

(in italics). 

Costa

 Subtotal 

Site Preparation 

Co-applicants’ cost $15,425,000 $15,425,000 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-4 

Costa

 Subtotal 

Upper Reservoir (Morrell Canyon) 

Co-applicants’ cost $59,275,000 

Overburden disposal $6,500,000 

Additional excavation, foundation preparation and lining $10,000,000 

Quarrying and additional haulage $6,000,000 

Subtotal upper reservoir $81,775,000 

Tunnels and Shafts 

Co-applicants’ cost $154,332,000 

Lower total excavation length (reduction by one-sixth)b

 –$25,722,000 

Higher unit cost of excavation $13,875,000 

Additional steel liner costs $51,000,000 

Willard Fault seismic mitigation $5,000,000 

Transition zone shafts $13,600,000 

Subtotal tunnels and shafts $212,085,000 

Powerhouse Cavern 

Co-applicants’ cost $62,570,000 $62,570,000 

Powerhouse Auxiliary: Mechanical 

Co-applicants’ cost $5,725,000 $5,725,000 

Powerhouse Auxiliary: Electrical 

Co-applicants’ cost $15,000,000 $15,000,000 

Powerhouse Major Equipment 

Co-applicants’ cost $1,750,000 $1,750,000 

Powerhouse Turbine Generators 

Co-applicants’ cost $64,200,000 $64,200,000 

Lower Reservoir 

Co-applicants’ cost $17,448,000 $17,448,000 

Subtotal major facilities $475,978,000 

Contingencies 

30 percent contingency on civil works $116,790,900 

15 percent contingency on electrical-mechanical $13,001,300 

Subtotal Contingencies $129,792,200 

Subtotal Without Transmission $605,770,200 

Transmission Line 

Co-applicants’ cost $309,654,000 $309,654,000 

Additional staff contingency for transmission line $21,613,800 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-5 

Costa

 Subtotal 

Construction Cost $937,038,000 

Elsinore Valley MWD Payment 

Co-applicants’ cost $1,329,000 

Additional payment associated with higher capital costs $450,600 

Subtotal Elsinore Valley MWD payment $1,779,600 

Total Project Costs $938,817,600 

Feasibility study, associated site investigations, final 

design, model tests, and construction management 

$93,703,800 $93,703,800 

Project-related costs $12,914,000 $12,914,000 

Assumed environmental mitigation costsc

 $0 $0 

Interest during Construction 

Co-applicants’ cost $85,000,000 

Additional interest during construction with higher capital 

costs 

$36,489,800 

Subtotal interest during construction $121,489,800 

Other Financing Costs 

Co-applicants’ cost $14,262,000 

Additional financing costs with higher capital costs $5,957,000 

Subtotal other financing costs $20,219,000 

Financial Contingency 

Co-applicants’ cost $19,786,000 

Additional financing costs with higher capital costs $8,264,000 

Subtotal financial contingency $28,050,000 

Development Fee 

Co-applicants’ cost $12,803,000 

Additional fees for higher capital costs $5,347,000 

Subtotal development fee $18,150,000 

Subtotal Project Development Costs $294,526,600 $294,526,600 

Grand Total Project Costs $1,233,344,200 

Adjust to 2005 dollars $1,283,171,300 

a

 Costs are in 2003 dollars to permit a comparison with the co-applicants’ cost estimate. Costs are converted to 

2005 dollars in the final row. 

b Lineal feet dimensions appear to reflect three rather than two conduit systems in Elsinore Valley MWD and 

Nevada Hydro (2005); however, additional analysis may be needed to resolve this issue including a complete 

review of all conduit quantities. Because there were changes in diameters as well we have made a one-sixth 

adjustment to the quantities rather than one-third. 

c

 These costs are accounted for in a separate table. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-6 

4.1.4 Projected Energy Facility Costs for Staff Alternative 

Commission staff and USFS staff suggest that a modified pumped storage project configuration 

with an upper reservoir located in Decker Canyon with the powerhouse located at Santa Rosa site may 

reduce environmental effects while maintaining a comparable facility cost. This alternative is described 

in section 2.6. Staff has assumed that the engineering review conducted for Morrell Canyon alternative 

would also apply to Decker Canyon alternative, although the details of the omitted items might be 

somewhat different. Therefore we have included the same set of additional cost estimates to the coapplicants’ cost estimate. In addition we applied the cost differentials developed by the co-applicants for 

each of the construction elements in response to our AIR (Elsinore Valley MWD and Nevada Hydro, 

2005). We present our evaluation of these costs and the resulting total facility costs, excluding 

environmental measures, in table 46. 

Table 46. Projected energy facility costs for the staff alternative (Decker-Santa Rosa 

alternative excluding environmental measures), including staff review items (in 

italics). 

Costa

 Subtotal 

Site Preparation 

Co-applicants’ cost $15,425,000 $15,425,000 

Upper Reservoir (Decker Canyon) 

Co-applicants’ cost $80,021,300 

Additional excavation, foundation preparation and lining $10,000,000 

Quarrying and additional hauling $6,000,000 

Subtotal upper reservoir $96,021,300 

Tunnels and Shafts 

Co-applicants’ cost $170,065,000 

Lower total excavation length (reduction by one-sixth)b

 –$28,344,200 

Higher unit cost of excavation $13,875,000 

Additional steel liner costs $51,000,000 

Willard Fault seismic mitigation $5,000,000 

Transition zone shafts $13,600,000 

Subtotal tunnels and shafts $225,195,800 

Powerhouse Cavern 

Co-applicants’ cost $61,410,000 $61,410,000 

Powerhouse Auxiliary: Mechanical 

Co-applicants’ cost $5,725,000 $5,725,000 

Powerhouse Auxiliary: Electrical 

Co-applicants’ cost $15,000,000 $15,000,000 

Powerhouse Major Equipment 

Co-applicants’ cost $1,750,000 $1,750,000 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-7 

Costa

 Subtotal 

Powerhouse Turbine Generators 

Co-applicants’ cost $64,200,000 $64,200,000 

Lower Reservoir 

Co-applicants’ cost $17,448,000 $17,448,000 

Subtotal major facilities $503,335,100 

Contingencies 

30 percent contingency on civil works $124,998,000 $124,998,000 

15 percent contingency on electrical-mechanical $13,001,300 $13,001,300 

Subtotal Contingencies $137,999,300 

Subtotal Without Transmission $641,334,400 

Transmission Line 

Co-applicants’ cost $308,794,000 $308,794,000 

Additional staff contingency for transmission line $21,553,800 $21,553,800 

Elsinore Valley MWD Payment 

Co-applicants’ cost $1,329,000 

Additional payment associated with higher capital costs $516,400 

Subtotal Elsinore Valley MWD payment $1,845,400 

Total Project Costs 

Feasibility study, associated site investigations, final design, model 

tests, and construction management 

$93,703,800 $93,703,800 

Project-related costs $12,914,000 $12,914,000 

Assumed environmental mitigation costsc

 $0 $0 

Interest during Construction 

Co-applicants’ cost $85,000,000 

Additional interest during construction with higher capital costs $40,926,000 

Subtotal interest during construction $125,926,000 

Other Financing Costs 

Co-applicants’ cost $14,262,000 

Additional financing costs with higher capital costs $5,728,000 

Subtotal additional financing costs $19,990,000 

Financial Contingency 

Co-applicants’ cost $19,786,000 

Additional financing costs with higher capital costs $7,947,000 

Subtotal financial contingency $27,733,000 

Development Fee 

Co-applicants’ cost $12,803,000 

Additional fees for higher capital costs $5,142,000 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-8 

Costa

 Subtotal 

Subtotal development fee $17,945,000 

Subtotal Project Development Costs $301,676,200 $301,676,200 

Grand Total Project Costs $1,275,203,700 

Total Adjusted to 2005 dollars $1,326,722,000 

a

 Costs are in 2003 dollars to permit a comparison with the co-applicants’ cost estimate. Costs are converted to 

2005 dollars in the final row. 

b

 Lineal feet dimensions appear to reflect three rather than two conduit systems in Elsinore Valley MWD and 

Nevada Hydro (2005); however, additional analysis may be needed to resolve this issue including a complete 

review of all conduit quantities. 

c

 These costs are accounted for in a separate table. 

4.2 PROJECTED ENVIRONMENTAL COSTS 

Staff developed estimates for the costs of environmental mitigation measures based on 

information provided by the co-applicants and agencies, and on staff experience with similar 

hydroelectric projects in California (refer to table 47). The details of the co-applicants’ proposal, staff 

alternative, and agency recommendations are included in section 2. 

Several of the items shown in table 47 appear similar. In these cases, the co-applicants may have 

proposed one measure to address a particular resource concern, an agency may have specified or 

recommended a slightly different measure addressing the same issue, and staff may have further 

modifications. The column titled “Staff Adopted” indicates the measures that would be included in the 

staff alternative. 

The co-applicants estimated environmental mitigation capital costs at $14,450,000 (Elsinore 

Valley MWD and Nevada Hydro, 2005), including $6,450,000 for parks and recreation development and 

$8,000,000 for other environmental measure in 2003 dollars. Many of the co-applicants’ environmental 

measures were not priced individually and had to be estimated by staff. We have footnoted those costs in 

table 47. We adjusted those costs by a factor or 1.04 to account for the effects of inflation between 2003 

and 2005. After taking into account the unpriced measures, we estimate the annualized cost of 

environmental measures for the co-applicants’ proposal to be about $13,681,100, based on an estimated 

capital cost of $84,201,100 and combined with $2,005,700 in operations and maintenance costs. 

The estimated annualized cost of environmental measures for the staff alternative is about 

$12,207,500 based on an estimated capital cost of $72,159,200 combined with $2,279,100 in operations 

and maintenance costs. 

Staff did not develop a full alternative for the Morrell Canyon location; however, we note that, 

should such an alternative be developed, several additional measures would likely be required by staff and 

agencies. Staff anticipates, for example, that a more sophisticated liner system, coupled with an upstream 

collection system and underdrain collection system for several known springs would potentially add in 

excess of $18,000,000 to the environmental costs. Additional measures such as relocation of the Morgan 

Trail and additional lands mitigation as shown in table 47 would further narrow the difference in cost 

between the Morrell and Decker upper reservoir locations. 

None of the environmental measures proposed by the co-applicants, staff or agencies were 

deemed to have significant effects on energy generation or dependable capacity. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-9 

Table 47. Summary of capital and one-time costs, annual costs, and total annualized costs of environmental 

by the co-applicants, included in the staff alternative, and recommended by others for the LEAPS 

Elsinore Valley MWD and Nevada Hydro, 2005, 2004a, and 2004b) 

Measure Entity 

Capital and 

One Time Costs 

($2005) 

Annualized 

Operations and 

Maintenance Cost 

($2005) 

Total 

Annualized 

Cost 

($2005) 

S

Alte

Soils and Geology1. Retain board of three consulting geologists/engineers 

Co-applicants $500,000 $70,500 Y

2. Conduct additional geotechnical studies Co-applicants $1,000,000 $141,100 Y3. Prepare erosion control plan prior to construction and implement during construction. 

Co-applicants $230,000 $32,500 Y

4. Prepare and implement an erosion control plan over the term of the license 

USFS, Riverside 

County Flood 

Control District 

$70,000 $9,900 Y

5. Implement erosion control during construction and operation 

Co-applicants $1,922,900 $30,400 $301,700 Y

6. Implement erosion control during construction and operation including the staff alternative transmission alignment 

Staff $40,100 $1,200 $6,900 Y

7. Develop and implement a plan and design for construction of a system that will automatically detect a conduit or penstock failure and immediately shut off flow in the conduit or penstock at the headworks in the event of such a failure 

Co-applicants $91,000 $12,800 Y

8. Develop a plan for clearing the reservoir area 

Co-applicants $35,000 $4,900 Y

9. Develop a plan to revegetate disturbed areas with native plant species beneficial to wildlife 

Co-applicants $30,000 $4,200 Y

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-10 

Measure Entity 

Capital and 

One Time Costs 

($2005) 

Annualized 

Operations and 

Maintenance Cost 

($2005) 

Total 

Annualized 

Cost 

($2005) 

S

Alte

Water Resources (Quantity)10. Pay an annual lake management fee to Elsinore Valley MWD to maintain Lake Elsinore at 1,240 feet msl or above 

Co-applicants $1,872,000 $1,872,000 Y

11. Develop and implement a revised lake operating plan for Lake Elsinore, addressing increased minimum lake levels, flood control implications, and water supply issues 

Staff $200,000 $28,200 Y

12. Develop and implement a plan for the installation of drainage and flood control measures and any water detention structures to control storm runoff over the term of any license issued for the project 

Co-applicants $100,000 $14,100 Y

13. Incremental additional program associated with upstream and seepage collection and delivery system and improved double liner system at Morrell Canyon 

Staff $18,000,000 $2,539,800 

14. Develop and implement an upper reservoir and water conduit monitoring program to assess the effects of the upper reservoir liner and seepage collection systems, shafts, and tunnels on the groundwater levels and water quality, including installation of perimeter wells designed to establish groundwater levels and water quality prior to construction and to detect any changes after construction 

Co-applicants $500,000 $70,500 Y

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-11 

Measure Entity 

Capital and 

One Time Costs 

($2005) 

Annualized 

Operations and 

Maintenance Cost 

($2005) 

Total 

Annualized 

Cost 

($2005) 

S

Alte

15. Include specific remediation measures in the upper reservoir and water conduit monitoring program to allow immediate action to be taken if water or non-native aquatic species are released from the upper reservoir into the San Juan Creek drainage 

Interior, staff Y

16. Include specific provisions in the upper reservoir and water conduit monitoring program for groundwater exploration and aquifer characterization, consultation on groundwater inflow criteria, and to monitor groundwater levels during the construction and operation of the water conduits including the tunnels and penstocks that convey water between the upper reservoir and the powerhouse for 10 years or longer, if necessary, specifying remedial actions if monitoring reveals changes in groundwater or seepage into the tunnels 

Staff and USFS $110,000 $19,200 $34,700 Y

17. Develop and implement a surface water resources manage plan to control and monitor project-related effects on water resources that support riparian vegetation on National Forest System lands 

USFS $200,000 $30,000 $58,200 Y

Water Resources (Quality)18. Develop and implement water quality plan to monitor DO and temperature in Lake Elsinore and Temescal during construction and operation 

Co-applicants $115,000 $15,000 $31,200 Y

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-12 

Measure Entity 

Capital and 

One Time Costs 

($2005) 

Annualized 

Operations and 

Maintenance Cost 

($2005) 

Total 

Annualized 

Cost 

($2005) 

S

Alte

19. Develop and implement a plan to determine the toxicity of sediments in Lake Elsinore and to provide for proper handling and disposal if toxins are identified 

Staff $50,000 $7,100 Y

20. Prepare a hazardous substances spill prevention and control plan 

Co-applicants 

USFS 

$10,000 $1,400 Y

Aquatic Resources21. Employ a qualified specialist to monitor construction activities in the aquatic environment 

Co-applicants $130,000 $18,300 Y

22. Develop and implement a detailed plan for environmental monitoring during construction by a qualified specialist for aquatic and terrestrial resources 

USFS $20,000 $2,800 Y

23. Establish appropriate setbacks from streams, avoid sediment discharges, and implement BMPs to avoid conflicts with the USFS steelhead recovery efforts in San Mateo Creek 

Co-applicants $0 Y

24. Remove/reduce fish population via netting or rotenone poisoning during construction 

Co-applicants $50,000 $7,100 

25. Design and install intake screens for fish consistent with NMFS 

Co-applicants $8,000,000 $10,000 $1,138,800 

26. Consult with FWS and CDFG to develop intake fish screen criteria as specified by NMFS and modified, if necessary, to ensure screening addresses bass and crappie and other resident fish species in Lake Elsinore 

FWS $10,000 $1,400 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-13 

Measure Entity 

Capital and 

One Time Costs 

($2005) 

Annualized 

Operations and 

Maintenance Cost 

($2005) 

Total 

Annualized 

Cost 

($2005) 

S

Alte

27. Establish limits of flow velocity rates of 1.5 to 1.8 feet per second at underwater intakes to reduce entrainment of sport fish 

Co-applicants $0 Y

28. Monitor sport fish for entrainment and mortality for 1 year 

Co-applicants $9,300 $9,300 Y

29. Monitor sports fish for entrainment and mortality for 1 year and once every 5 years over the term of the license and, based on the monitoring results, develop and implement a plan to mitigate effects on sport fish 

Staff $200,000 $33,800 $62,000 Y

30. Test behavioral avoidance devices if entrainment is significant 

Co-applicants $250,000 $9,100 $41,300 

Terrestrial Resources

32. Employ a qualified specialist to monitor construction activities in the terrestrial environment 

Co-applicants $300,000 $42,300 Y

33. Conduct wetland delineations and prepare a habitat mitigation and monitoring plan for Corps, CDFG, and USFS approval 

Co-applicants $60,000 $6,700 $15,200 Y

34. Develop and implement plan to prevent and control weeds 

Co-applicants $100,000 $14,100 Y

35. Consult with the USFS to develop and implement a vegetation and invasive weed management plan 

USFS $20,000 $20,000 $22,800 Y

36. Develop a Lake Elsinore monitoring and remediation plan to eliminate or reduce impacts to nesting shorebirds, waterfowl, and other birds 

Interior $20,000 $20,000 $22,800 Y

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-14 

Measure Entity 

Capital and 

One Time Costs 

($2005) 

Annualized 

Operations and 

Maintenance Cost 

($2005) 

Total 

Annualized 

Cost 

($2005) 

S

Alte

37. Design and construct power line in accordance with APLIC et al. (1996) 

Co-applicants, 

USFS 

$20,000 $2,800 Y

38. Develop and implement bird-power line protection plan, following designs in the APLIC and FWS (2005) guidelines; develop and implement long-term avian protection plan 

Staff $20,000 $20,000 Y

39. Conduct additional pre-construction special status plant and animal surveys for compliance with the Multi-Species HCPs. 

Interior $100,000 $14,100 Y

40. For Morrell Canyon, mitigate loss of special status habitats at 2:1 ratio (oak woodland 40 acres; coastal sage scrub 62 acres) 

Co-applicants $2,060,000 $2,100 $204,100 

41. For Morrell Canyon, evaluate effects in terms of the Multi-Species HCP; mitigate based on equivalency analysis, minimum 1:1 ratio for habitat loss (203.5 acres) 

Interior $3,242,500 $4,200 $325,200 

42. For Decker Canyon, evaluate effects in terms of the Multi-Species HCP; mitigate based on equivalency analysis, minimum 1:1 ratio for habitat loss (207.5 acres) 

Interior $3,212,500 $4,200 $322,300 Y

43. For Morrell, mitigate any permanent loss of habitat on National Forest System lands at a minimum 1:1 ratio for riparian oak woodland, coastal sage scrub, and habitats that support listed species 

USFS $2,665,000 $3,500 $268,100 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-15 

Measure Entity 

Capital and 

One Time Costs 

($2005) 

Annualized 

Operations and 

Maintenance Cost 

($2005) 

Total 

Annualized 

Cost 

($2005) 

S

Alte

44. For Decker Canyon, mitigate any permanent loss of habitat on National Forest System lands at a minimum 1:1 ratio for riparian oak woodland, coastal sage scrub, and habitats that support listed species 

USFS $2,635,000 $3,400 $265,100 

45. Prepare and implement a habitat mitigation plan to meet habitat objectives and standards and for additional enhancement activities to offset the direct effects of construction 

USFS $20,000 $2,800 Y

46. Provide $500 per acre for project effects within Stephen’s Kangaroo Rat Assessment Area (38.25 acres) 

Co-applicants $19,100 $2,700 Y

47. Annually review list of special status species 

USFS $10,000 $4,800 $6,200 Y

48. Provide annual employee awareness training regarding special status plants and animals 

USFS $10,000 $10,000 $11,400 Y

49. Consult with FWS in developing final designs and measures to protect fish and wildlife 

Interior $10,000 $2,000 $3,400 Y

50. In emergency, take immediate action to prevent or minimize further loss of fish and wildlife 

Interior $0 

51. Commission include ESA reopener provision in license 

Interior $0 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-16 

Measure Entity 

Capital and 

One Time Costs 

($2005) 

Annualized 

Operations and 

Maintenance Cost 

($2005) 

Total 

Annualized 

Cost 

($2005) 

S

Alte

Recreation 52. Prepare a detailed plan of construction sites and laydown areas relative to recreational safety. 

Co-applicants, 

USFS 

 $0 Y

53. Implement safety during construction plan and include daily inspections for fire plan compliance, public safety, and environmental protection 

USFS Y

54. Install fencing around upper reservoir Co-applicants $74,000 $2,200 $12,600 Y55. Provide interpretive signage at upper reservoir site 

Co-applicants $7,000 $200 $1,200 Y

56. Construct and maintain an ancillary structure to complement the firefighters memorial (visitors information center) at a USFS-site off Ortega Highway 

Co-applicants $49,900 $7,000 Y

57. Grade/contour/prepare site at the construction laydown area or another area for future development by USFS or another entity as determined by the USFS 

Co-applicants $18,700 $2,600 Y

58. Develop recreation facility at the construction laydown area for upper reservoir and/or an alternate location 

USFS $144,200 $4,000 $20,100 Y

59. Relocate portions of Morgan Trail if the upper reservoir is in Morrell Canyon 

Co-applicants $18,700 $2,600 

60. Develop and implement a recreation plan, including a botanical garden/community park at Santa Rosa or Evergreen powerhouse sites 

Co-applicants $5,610,800 $678,500 Y

61. Provide public tours at powerhouse at any of the powerhouse locations 

Co-applicants $18,700 $18,700 Y

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-17 

Measure Entity 

Capital and 

One Time Costs 

($2005) 

Annualized 

Operations and 

Maintenance Cost 

($2005) 

Total 

Annualized 

Cost 

($2005) 

S

Alte

62. Develop a hang glider landing site and provide for a community park if powerhouse is located at Ortega Oaks sites and a northern transmission alignment is selected. 

Co-applicants $5,610,800 $678,500 No b

alte

loca

sel

63. Implement recreation plan providing for land transfer, development of recreation facility and O&M funding for community park development and/or hang gliding facility 

Staff $125,400 $125,400 Y

64. Develop and implement fish stocking program for Lake Elsinore 

Co-applicants $10,000 $20,000 $21,400 Y

Land Use and Aesthetic Resources 65. Acquire easements, fee simple or leasehold interests in lands needed for project purposes by voluntary sale or conveyance to extent possible. 

Co-applicants $70,000 $9,900 Y

66. Acquire and demolish or modify the multifamily residences nearest the proposed powerhouse at Santa Rosa. 

Co-applicants 

67. Prepare and implement visual resources plan 

Co-applicants $20,000 $2,800 

68. Prepare and implement a scenery conservation plan to achieve the greatest degree of consistency with USFS High Scenic Integrity Objective 

USFS $20,000 $2,800 Y

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-18 

Measure Entity 

Capital and 

One Time Costs 

($2005) 

Annualized 

Operations and 

Maintenance Cost 

($2005) 

Total 

Annualized 

Cost 

($2005) 

S

Alte

69. Develop, in consultation with Riverside County, and implement a plan to avoid effects to existing drainage facilities and to control any project-related drainage. 

Co-applicants $0 Y

incl

pla

drain

flood 

me

70. Additional excavation at Decker Canyon in lieu of trucking fill material uphill from powerhouse 

Staff $5,193,500 $732,800 Y

71. Achieve a balance of the excavation and fill materials at the Decker Canyon on reservoir site through additional excavation and dispose of all excavated material from all other project facilities off site 

Co-applicants Y

72. Participate in installation of traffic signal at Grand Avenue / Ortega Highway intersection 

Co-applicants $0 

73. For the Ortega Oaks power house location, dedicate and improve any additional rights-of-way 

Co-applicants $0 

74. Develop and implement traffic management and control plans to address construction and access to and from the active construction sites 

Co-applicants $100,000 $10,000 $24,100 Y

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-19 

Measure Entity 

Capital and 

One Time Costs 

($2005) 

Annualized 

Operations and 

Maintenance Cost 

($2005) 

Total 

Annualized 

Cost 

($2005) 

S

Alte

75. Install temporary roads on the National Forest System lands only with USFS approval and according to USFS policies, and remove, re-contour, and revegetate roads following construction except where the USFS authorizes continued use of the roads for transmission line maintenance 

Co-applicants Y

76. Consult with the USFS to develop a project road and traffic management plan on National Forest System lands 

USFS $10,000 $1,400 Y

77. Consult with appropriate authorities to develop road and traffic management plan on non-National Forest System lands for USFS roads 

Staff 10,000 $1,400 Y

78. Transmission tower placement plan Staff $100,000 $14,100 Y79. Helicopter installation costs for coapplicants’ proposed transmission alignment 

Co-applicants $1,368,900 $193,200 

80. Helicopter installation costs for staff alternative transmission alignment 

Staff $1,799,600 $253,900 Y

81. Incremental transmission alignment road costs for staff alternative transmission alignment 

Staff –$183,900 –$25,900 Y

82. Incremental underground powerline costs for the co-applicants’ proposed alignment (based on an incremental cost of $10,400,000 per mile including contingency) 

Co-applicants $60,680,100 $8,561,900 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-20 

Measure Entity 

Capital and 

One Time Costs 

($2005) 

Annualized 

Operations and 

Maintenance Cost 

($2005) 

Total 

Annualized 

Cost 

($2005) 

S

Alte

83. Incremental underground powerline costs for the staff alternative transmission alignment (based on an incremental cost of $10,400,000 per mile including contingency) 

Staff $48,999,800 $6,913,800 Y

84. Comply with noise element of Riverside General Plan and other applicable codes and standards 

Co-applicants Y

Cultural Resources

85. Consult with SHPO and the USFS at least 180 days prior to commencement of any land-clearing or land-disturbing activities 

Co-applicants $10,000 $1,400 Y

86. Stop all land-clearing and landdisturbing activities in the vicinity of such properties where unidentified archaeological or historic properties are discovered during construction and consult with the SHPO or the USFS on USFS lands 

Co-applicants $120,000 $16,900 Y

87. Implement measures proposed in the draft HPMP filed with the Commission. 

Co-applicants $420,000 $59,300 Y

88. Conduct paleontological monitoring of earth-moving activities on a part-time basis in locations that are sensitive for paleontological resources. 

Co-applicants $80,000 $11,300 Y

89. Prepare any recovered fossil remains to the point of identification, and prepare them for curation by the Los Angeles County Museum or San Bernardino County Museum 

Co-applicants $20,000 $2,800 Y

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-21 

Measure Entity 

Capital and 

One Time Costs 

($2005) 

Annualized 

Operations and 

Maintenance Cost 

($2005) 

Total 

Annualized 

Cost 

($2005) 

S

Alte

90. Revise draft HPMP in consultation with the USFS and file a final HPMP for Commission approval within 1 year of any license issuance. 

Staff $20,000 $2,800 Y

Total Co-applicants’ Proposed Measures $84,201,100 $2,005,700 $13,681,100 Total Staff Adopted Measures $72,159,200 $2,279,100 $12,207,500 a These costs are staff estimates based on the co-applicants’ description of the measure. b This cost applies to the liner in the upper reservoir only at the Morrell Canyon location. c Cost of developing remediation measures assumed to be included in staff measure, item no. 16. d This measure includes O&M costs that are not constant over our 30-year economic evaluation period that follows construction. e Cost for this measure is assumed to be included in the development and implementation of the co-applicants’ erosion control plan. f We expect that the costs associated with the limits for velocities are included in the fish screen cost estimate. g This measure includes capital costs incurred in other than year 1 or during original construction. h We assume that the co-applicants will address drawdowns in the lake management plan. i Staff has added monitoring to this Interior-proposed measure. j We assume that this consultation is limited to project design. k An ESA reopener is a legal matter that will be addressed by the Commission in any license that may be issued for the project. l We assume this cost would be included in the co-applicants’ overall construction cost. m We assume this cost would be included in the co-applicants’ overall construction cost except for land easements associated with th

alignments which amounted to 28 acres times $2,500. 

n We assume these costs are included in the co-applicants’ costs for managing traffic to and from the construction sites. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-22 

We group expenditures on environmental measures by resource area and compare costs of the 

staff alternative to those of the co-applicants in table 48. 

Table 48. Comparison of annualized costs of environmental measures by resource area and 

overall project costs. (Source: Staff) 

Environmental 

Protection Measure 

Co-applicants’ 

Proposal 

(2005 dollars) 

Co-applicants’ 

Proposal 

(2005 dollars per 

MWh) 

Staff Alternative 

(2005 dollars) 

Staff Alternative

(2005 dollars per 

MWh) 

Soils and geology $567,700 $0.36 $584,500 $0.37 

Water resources 

Quantity $1,956,600 $1.25 $2,077,700 $1.33 

Quality $32,600 $0.02 $39,700 $0.03 

Aquatic $1,214,800 $0.78 $92,400 $0.06 

Terrestrial $281,200 $0.18 $500,100 $0.32 

Recreation $744,600 $0.48 $887,500 $0.57 

Land use and aesthetic 

resources $8,791,900 $5.64 $7,931,100 $5.08 

Cultural resources $91,700 $0.06 $94,500 $0.06 

Total Environmental $13,681,100 $8.77 $12,207,500 $7.83 

4.3 PROJECTED ENERGY COSTS 

Both the co-applicants’ proposal and the staff alternative would require a comparable amount of 

energy to power the pumps that raise water from the lower reservoir to the upper reservoir. In their most 

recent filing (Elsinore Valley MWD and Nevada Hydro, 2005), the co-applicants’ estimate that 1,872,000 

MWh of pumping energy would be required to generate 1,560,000 MWh of project energy. The coapplicants’ did not refile the “Operational Spreadsheets” (Elsinore Valley MWD and Nevada Hydro, 

2004a, exhibits A, B, C, D, F, and G) based on this slightly revised estimate, so we have assumed average 

values corresponding to the same 60 hours of turbine operation and 66 hours of pumping operation to 

analyze the energy costs associated with the LEAPS Project. Table 49 includes our analysis of the 

“Maximum Generation Scenario” as described in section 2.1.3. The co-applicants did not provide this 

type of analysis in its license application (Elsinore Valley MWD and Nevada Hydro, 2004a) or 

subsequent filings. Our analysis assumes operation over a typical week that includes peak hours from 

6:00 a.m. through 10 p.m. (16 hours per week day). We assume that half of these hours are extra high 

demand periods and classify them as higher demand peak hourssuch as those that might be served by a 

rapidly dispatchable pumped storage hydro project. Energy generated during these hours is estimated to 

have a 20 percent premium compared to regular peak hours. The remaining hours (10:00 p.m. through 

6:00 a.m.) are classified as off-peak hours as are all weekend hours. We recognize that these definitions 

are subject to change over time and that there may be seasonal differences between summer and winter 

periods. Furthermore, our analysis may be slightly optimistic since several holidays throughout the year 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-23 

Table 49. Analysis of the pumping and turbining weekly cycles for the LEAPS Project. (Source: Staff) Item Hours 

Energy Value 

($2005) 

Pumping Energy 

Required (MWh) 

Cost of 

Pumping 

Energy 

($2005) 

Average Pumped 

Storage 

Generation 

(MWh) 

Valu

Pumped 

Gener

($20

Higher demand peak hours 

40 69.18 -- -- 20,000 1,383

Peak hours 40 57.65 10,909 503,100 10,000 576Off-peak hours 88 40.00 25,091 1,090,900 -- -Total or average 168 51.15 36,000 1,594,000 30,000 1,960Yearly 1,872,000 82,889,400 1,560,000 101,92

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-24 

are classified as off-peak periods. Additionally, it may take up to an hour to switch from the turbining 

cycle to the pumping cycle. We have not included that level of refinement in our analysis. 

We determine that over a typical week, the cost of generation to provide pumping energy during 

the periods specified by the co-applicants would be $1,594,000. On an annual basis this would amount to 

$82,889,400. 

4.4 ECONOMIC COMPARISON 

Based on the costs developed in sections 4.1 through 4.3, we estimate the total capital and annual 

costs for the co-applicants’ proposal as shown in table 50. The co-applicants’ proposal consists of the 

Morrell Canyon/Santa Rosa project configuration with staff’s cost estimate adjustments, the TE/VS 

Interconnnect Project, and the co-applicants’ proposed environmental measures. Similarly, we show the 

total costs for the staff alternative in table 51. The staff alternative consists of the Decker Canyon/Ortega 

project configuration, the mid-slope transmission alignment with up-slope segment, and environmental 

measures. 

Table 52 compares the power value, annual costs, and net benefits of the no-action alternative, 

co-applicants’ proposal and the staff alternative for the Leaps Project. The decrease in net benefits 

between the co-applicants’ proposal and the staff alternative is about $2.99 per MWh. 

Within the limits of the preliminary design of the project components, the overall costs of the coapplicants’ proposed action and the staff alternative are within the same order of magnitude, although the 

staff alternative would be more costly. As shown in table 51, and discussed in section 4.4, the additional 

environmental measures and cost estimates would not significantly affect the project economics. During 

the final design phase of the project, the co-applicants would provide the engineering and cost estimate 

information to the Commission staff necessary to review the final design of each of the project 

components. 

Table 50. Summary of projected annual costs and capital costs under the co-applicants’ 

proposal. (Source: Staff) 

Cost 

Capital and One-time 

Costs 

Annual Costs, 

Including O&M 

Total Annualized 

Costs 

Project cost excluding environmental measures 1,283,171,300 181,054,300 

Environmental measures 84,201,100 2,005,700 13,681,100 

Licensing cost 12,000,000 1,693,200 

Total net investment 1,379,372,400 196,428,600 

Materials and supplies 1,435,200 

Energy for pumpinga

 82,889,400 

Dam Safety Program 100,000 

Insuranceb

 

General and Administrative 561,100 

O&M contingencyc

 1,920,000 

Subtotal operations and maintenance costs 86,905,700 86,905,700 

FERC feesc

 1,200,000 1,200,000 

Subtotal annual costs 88,105,700 

Total 284,534,300 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-25 

a Pumping energy is based on average energy values at SP-15 for August 2004 through July 2005, assuming 

pumping during all off peak hours (10 p.m. through 6 a.m., Monday through Friday including on into the next 

day) and additional pumping operations during 16 hours (4 hours Monday through Thursday) of regular peak 

hours in the final EIS plus 10 off-peak hours on Saturday. 

b

 Insurance costs are rolled into the annualized cost of the total net investment based on the co-applicants’ 

estimate of 0.23 percent of the overall project cost. 

c

 We estimate FERC fees at $1,200,000. Additional fees may be added for the use of federal lands. We have 

reduced the co-applicants’ O&M contingency by this amount. 

Table 51. Summary of projected annual costs and capital costs under the staff alternative. 

(Source: Staff) 

Cost 

Capital and One-time 

Costs 

Annual Costs, 

Including O&M 

Total Annualized 

Costs 

Project cost excluding environmental 

measures 

1,326,704,600 187,196,800 

Environmental measures 72,159,200 2,279,100 12,207,500 

Licensing cost 12,000,000 1,693,200 

Total net investment 1,410,863,800 201,097,500 

Materials and supplies 1,435,200 

Energy for pumpinga

 82,889,400 

Dam Safety Program 100,000 

Insuranceb

 

General and administrative 561,100 

O&M contingencyc

 1,920,000 

Subtotal operations and maintenance 

costs 

 86,905,700 86,905,700 

FERC feesc

 1,200,000 1,200,000 

Subtotal annual costs 88,105,700 

Total 289,203,200 

a Pumping energy is based on average energy values at SP-15 for August 2004 through July 2005, assuming 

pumping during all off peak hours (10 p.m. through 6 a.m., Monday through Friday including on into the next 

day) and additional pumping operations during 16 hours (4 hours Monday through Thursday) of regular peak 

hours in the final EIS plus 10 off-peak hours on Saturday.

b Insurance costs are rolled into the annualized cost of the total net investment based on the co-applicants’ 

estimate of 0.23 percent of the overall project cost. 

c We estimate FERC fees at $1,200,000. Additional fees may be added for the use of federal lands. We have 

reduced the co-applicants’ O&M contingency by this amount. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-26 

Table 52. Summary of annual net benefits for the no-action alternative, co-applicants’ 

proposal and staff alternative for the LEAPS Project. (Source: Staff) 

 No Action 

Co-applicants’ 

Proposal Staff Alternative 

Dependable capacity (MW) 500 500 500 

Capacity benefit ($/MW) 81,800 81,800 81,800 

Annual capacity benefit ($2005) 40,900,000 40,900,000 40,900,000 

Generation (MWh) 1,560,000 1,560,000 1,560,000 

Annual energy benefits ($2005) 89,932,200 101,923,100 101,923,100 

Dollars/MWh 57.65 65.34 65.34 

Overall benefits ($2005)a

 130,832,200 142,823,100 142,823,100 

Dollars/MWh 83.87 91.55 91.55 

Annual cost ($2005) 152,370,800 284,534,300 289,203,200 

Dollars/MWh 97.67 182.39 185.39 

Annual net benefit ($2005)b

 –21,538,600 –141,711,200 –146,380,100 

Dollars/MWh –13.81 –90.84 –93.83 

Change in annual net benefit relative 

to no-action alternative ($2005) 

 –120,172,600 –124,841,500 

Dollars/MWh –77.03 –80.03 

a The Nevada Hydro Company has estimated combined transmission and pumped storage benefits as high as 

$178,000,000 per year (letter from R. Wait, Vice President, Nevada Hydro, Vista, CA, to M. Salas, Secretary, 

the Commission, Washington, DC, dated June 8, 2006) using a method where cost savings (i.e., benefits) would 

rise over time. Our standard approach is to use a constant dollar method as described in section 4.1.1.

b We have estimated net benefits based on time of day pricing as described in section 4.3. The net benefit for the 

no-action alternative is negative because under current economic assumptions the benefit from our assumed 

time of day pricing would not fully cover the estimated costs of a simple-cycle combustion turbine project. 

4.5 COST OF ALTERNATIVE TRANSMISSION ALIGNMENTS 

In this NEPA document, staff evaluated two transmission line alternatives in detail (as described 

in section 2) including: 

• Revised co-applicants’ proposed transmission alignment as described in this document 

• Staff alternative transmission alignment as described in this document. 

These two alternatives have a slightly different lengths and construction characteristics. The 

USFS is also evaluating the TE/VS Interconnect Project and alternatives in a separate document. 

Commission staff have analyzed the costs associated with the co-applicants’ proposed transmission 

alignment and two alternative alignments. Table 53 summarizes the construction costs and characteristic 

for the three alternatives. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-27 

Table 53. Summary of construction costs and characteristics for the co-applicants’ proposed 

and staff alternative transmission alignments. (Source: Staff) 

Alignment 

Overall 

Length 

(miles) 

Buried 

Length 

(miles) 

Helicopter 

Installed 

Length 

(miles)a

Conventional 

Transmission 

Line (miles) 

Access 

Road 

Length 

(miles)b

Total 

Construction 

Cost ($2005)c

Revised coapplicants’ proposed 

transmission 

alignment 

32.1 3.2 24.9 4.0 10.8 $393,316,800 

Staff alternative 

transmission 

alignment 

31.7 2.1 25.5 4.1 9.3 $381,082,875 

a

 This length results in additional cost for construction of transmission lines by helicopter in areas where slopes 

are greater the 15 percent. 

b

 We assume that access road lengths are equal to 1.5 times the transmission line length and are required in areas 

with slopes less than or equal to 15 percent. 

c

 Total construction costs include the applicants estimated transmission lines costs and contingency, additional 

staff contingency and other major construction items such as additional access roads, buried lines or helicopter 

aided construction. Certain environmental measures associated with erosion control, easements, and terrestrial 

lands mitigation, etc. are not included in this cost. 

d

 We assume the co-applicants may have accounted for up to 50 percent of the helicopter aided construction costs 

in their cost estimate and have added an additional $1,984,100 for possibly unaccounted helicopter installation 

costs. We assume a transmission line tower every 1000 feet and that incremental helicopter costs would amount 

to one-half of $30,761 per tower. 

e

 We assume that shorter line lengths in the area where slopes are greater than 15 percent result in saving of 

$30,761 per tower eliminated or in this case 3 towers or $92,300. We also account for longer access roads at 

$125,000 per mile or in this case $337,500. Because the overall transmission line is 1.2 miles longer, we also 

estimate an additional construction cost of $2,496,000. 

f

 An additional 2-mile segment connects the main transmission line to the Santa Rosa powerhouse. 

g

 The number of towers per mile were determine by GIS analysis for each alignment. 

4.6 SENSITIVITY TO TRANSMISSION LINE FACILITY COST OF THE LEAPS 

PROJECT AND OTHER FACTORS 

Although we do no have a clear assessment of the potential economic benefits from a 32-mile 

transmission line that would also potentially serve as an intertie, we concur that such a project would 

provide benefits to regional utilities and the co-applicants would likely be reimbursed for such benefits 

and services including elements such as increased reliability, and improved load flows. Studies 

conducted under the STEP concluded that an intertie, such as the TE/VS Interconnect Project, may lack 

the economic benefits to fully justify the costs. However these studies did not include significant 

strategic benefits such as improved reliability, better load diversity, improved fuel diversity, access to 

lower cost power resources, more firm power, better opportunity for power exchanges, and improved 

sharing of reserves. When these items are factored in by the co-applicants, perhaps the economics of the 

transmission line would improve to either a break-even or positive benefit. 

If we assume the co-applicants were able to cover the facility costs associated with the 

transmission lines by contracts with regional utilities, we estimate that the economics of the pumped 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
4-28 

storage project would improve by 43.5 dollars per MWh for the staff alternative as shown in table 54. 

Besides including benefits for the proposed intertie, the co-applicants may take into account escalating 

gas prices over time, other ancillary benefits not considered by staff and improved knowledge developed 

from detailed site investigations to improve the economic outlook for the LEAPS Project. 

Table 54. Summary of annual net benefits for the no-action alternative, co-applicants’ 

proposal, and staff alternative for the LEAPS Project excluding transmission line 

construction costs. (Source: Staff) 

No Action 

Co-applicants’ 

Proposal Staff Alternative 

Dependable capacity (MW) 500 500 500 

Generation (MWh) 1,580,000 1,580,000 1,560,000 

Annual power value ($2005) 130,832,200 142,823,100 142,823,100 

Dollars/MWh 83.87 91.55 91.55 

Annual cost ($2005)a 152,370,800 212,268,100 219,163,500 

Dollars/MWh 97.67 136.07 140.49 

Annual net benefit ($2005) –21,538,600 –69,445,000 –76,340,400 

Dollars/MWh –13.81 –44.52 –48.94 

Decrease from table 51 –30.71 

–35.13 

a

 The annual costs have been reduced by the co-applicants’ estimated transmission lines costs and contingency, 

additional staff contingency, and other major construction items such as additional access roads, buried lines or 

helicopter aided construction. Certain environmental measures associated with erosion control, easements and 

terrestrial lands mitigation, etc. are not included in this cost reduction. 

In a filing of June 12, 2006, Nevada Hydro comments that besides having energy benefits similar 

to what staff estimates, the proposed LEAPS project would have ancillary service benefits that it 

estimates at about $9 million annually, based on the project’s potential ability to integrate wind generation 

in the system. 

We agree that operational flexibility of pumped storage projects give them an advantage of other 

types of generators to compete in the ancillary services market. This flexibility includes the ability for 

pumped storage projects to start up quickly, rapidly increase load, switch from pumping to generating, 

and shape the project’s output to meet load requirements. Our problem in assigning specific value to the 

LEAPS project in these various ancillary markets is that the project can not perform these various 

functions at the same time—if the project is using its reservoir storage to integrate wind generation into 

the system, it cannot at the same time use its storage to maximize the capacity it supplies. So, absent a 

executed power purchase contract that details the proposed project operation, we’ve used an approach that 

assumes the storage from the project can be used weekly to displace gas-fired generation. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
COVER SHEET 

FEDERAL ENERGY REGULATORY COMMISSION 

FINAL ENVIRONMENTAL IMPACT STATEMENT 

FOR HYDROPOWER LICENSE 

Lake Elsinore Advanced Pumped Storage Project 

Docket No. P-11858-002 

Section 5 

Staff’s Conclusions 

Pages 5-1 through 5-42 

FEIS 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
5-1 

5.0 STAFF CONCLUSIONS78

When the Commission considers license proposals, besides looking at power and other 

developmental purposes—irrigation, flood control, water supply—it must also give equal consideration to 

the purposes of energy conservation, the protection, mitigation of damage to, and enhancement of fish and 

wildlife, the protection of recreational opportunities, and the preservation of other aspects of 

environmental quality. So far in this final EIS, we have described both the environmental effects and our 

estimated cost of building the proposed project and the staff alternative. Based on this analysis, we select 

the staff alternative as our preferred alternative. In this section, we examine the environmental effects and 

project costs of the alternatives and explain how we decided on the environmental measures we include in 

our preferred alternative. 

During scoping and in comments on the draft EIS, many people commented about the potential 

effects of the co-applicants’ proposed Morrell Canyon upper reservoir on Lion Spring, oak woodlands, 

and the use of existing trails and about the potential effects of the proposed transmission alignment on fire 

suppression activities, the use of existing hang gliding launch and landing sites, and adjacent residential 

communities. The staff alternative includes an alternative facility location for the upper reservoir as well 

as a revised transmission alignment developed by the USFS and Commission staff. 

These alternative facility locations address many of the key issues raised during scoping and in 

comments on the draft EIS. Though the staff alternative transmission alignment may affect nearby 

residential communities to a greater extent than the proposed project, we prefer the revised staff 

alignment because the transmission alignment avoids as many private in-holdings within the Cleveland 

National Forest as possible while continuing to avoid the San Mateo Wilderness Area and to minimize 

encroachment on lands designated as back-country non-motorized and back-country motorized-use 

restricted in the Land Management Plan. For these reasons, we prefer the staff alternative to the coapplicant’s proposed project. 

Comparing the staff alternative to no-action, we find that we also prefer the staff alternative. The 

staff alternative would allow the co-applicants to construct and operate the project as a peak energy 

resource and as part of a long-term solution to southern California’s transmission congestion bottlenecks. 

The Talega-Escondido/Valley-Serrano transmission line could provide up to 1,000 MW of import 

capability into the San Diego area with up to 500 MW of this imported power being supplied by the 

LEAPS Project during high-demand periods. 

Although neither of the co-applicants currently has contracts with end use customers, licensing 

the LEAPS Project would allow the co-applicants the opportunity to compete in the power market for sale 

of the project’s power and other ancillary benefits. Pumped storage projects store power during off-peak 

periods that can be provided rapidly during on-peak periods and may provide a valuable addition to the 

regional system. Besides the potential power and transmission benefits, the LEAPS Project, through the 

proposed lake management fee, would provide reliable funding for water to maintain the lake level targets 

specified in the Lake Elsinore Stabilization and Enhancement Project, which is necessary both to improve 

water quality in Lake Elsinore and to allow the pumped storage project to operate. The LEAPS Project 

also would fund annual stocking of sport fish in Lake Elsinore. The project-funded park facilities would 

also enhance recreational opportunities in the area. 

As we’ve said, the staff alternative that we describe in this final EIS greatly reduces the 

environmental effects of the project as originally proposed. The staff alternative would substantially 

reduce but not eliminate the loss of southern coast live oak as shown in table 55. The effects on hang 

gliding activities would be mostly eliminated through the underground placement of the transmission 

 

78 In this section, “we” means the Commission staff. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
5-2 

lines in the vicinity of the USFS permitted launch sites and along the connection to the Santa Rosa 

powerhouse. 

Construction and operation of the LEAPS Project as defined in the staff alternative would result 

in several unavoidable adverse impacts. Construction of the upper reservoir and powerhouse would cause 

the short-term disruption of traffic along Grand Avenue, Ortega Highway, and South Main Divide Road. 

Construction of the powerhouse would displace several residents and businesses located in buildings in 

close proximity to the construction site. The co-applicants propose to acquire these buildings and use 

them for construction offices. After construction, the co-applicants propose to return these buildings to 

the local building inventory. The construction of the transmission line would permanently displace a few 

residents whose property would need to be acquired for the right-of-way. Although the effects on 

aesthetics would be reduced by placing segments of the transmission line underground, construction of 

the transmission lines would introduce a permanent linear facility that would affect the aesthetics of the 

project area. The presence of the transmission line also could affect property values in the vicinity of the 

project facilities including about 450 parcels within 0.25 miles of the transmission alignment. The exact 

number of parcels requiring the acquisition of easements would depend upon the final placement of the 

line within the 500-foot-wide alignment considered in the EIS. The southern segment of the staff 

alternative transmission alignment is also within 3,000 feet of a private airstrip, which could render the 

airstrip unusable. Although the owner of the property would have to be compensated for loss of the 

property’s use, people who currently use the strip for pleasure flying or commuting would lose that 

resource. 

5.1 COMPARISON OF PROPOSED ACTION AND ALTERNATIVES 

We summarize the key differences of the potential effects of the co-applicants’ proposal and the 

staff alternative in table 55. 

Table 55. Summary of key differences in the potential effects of the co-applicants’ proposal 

and the staff alternative (Source: Staff) 

Upper Reservoir Comparison 

Resource/Issue Morrell Canyon (Co-applicants) Decker Canyon (Staff) 

130-acre footprint; daily fluctuations of 40 

feet and weekly fluctuations of 75 feet 

120-acre footprint; daily and weekly 

fluctuations would be on the same order of 

magnitude as the upper reservoir at Morrell 

Canyon 

Area of effect 

2.6 million cubic yards of fill needed for 

dam 

3.0 million cubic yards of fill needed for 

dam 

Fill materials Less overburden at Decker Canyon would 

allow easier procurement of solid rock 

material for fill for dam and dike 

construction 

Groundwater Construction of tunnels for high pressure 

conduits could affect groundwater; design 

review of collection system for Lion Spring 

and effects on groundwater 

Construction of tunnels for high pressure 

conduits could affect groundwater; no 

collection system would be required 

Seismic hazards Faults may control surface flows at the 

Morrell Canyon site 

No faults have been identified at the Decker 

Canyon site and subsurface flow does not 

appear to be controlled by the presence of 

faults 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
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Upper Reservoir Comparison 

Resource/Issue Morrell Canyon (Co-applicants) Decker Canyon (Staff) 

Surface water Upper reservoir would interrupt stream flow Same 

Wetland and riparian 

habitat 

Would affect 1.7 acres of waters of the U.S. 

and 4.8 acres of waters of the state, 

including Lion Spring; loss of these waters 

and associated riparian habitat would affect 

plant diversity and wildlife species; effects 

on downstream areas would be minimized 

by the water conveyance system under the 

reservoir 

Would affect 0.3 acre of waters of the U.S. 

and 0.9 acres of waters of the state; no 

effects on springs or seeps; smaller effects 

on downstream areas because drainage area 

is smaller 

Oak woodland 

communities 

Would convert about 20 acres of southern 

coast live oak forest (500 to 600 individual 

trees over 8 dbh) to project use; would need 

to plant 20 acres to mitigate 

Would convert about 5 acres of southern 

coast live oak forest to project use so effects 

would be similar to Morrell Canyon but on a 

smaller scale; would only need 5 acres to 

mitigate 

Special status 

wildlife 

Would convert 80 acres of chamise 

chaparral and 20 acres of southern coastal 

live oak to project facilities. 

Would convert 95 acres of chamise 

chaparral and 5 acres of southern coastal 

live oak to project facilities. 

Mountain lion Would remove 100 acres of suitable 

mountain lion habitat from Core B; project 

operation and maintenance would not likely 

increase disturbance or risk of interaction 

over levels that currently result from traffic 

on South Main Divide Road and use of 

Morgan Trail 

Would remove 100 acres of suitable 

mountain lion habitat from Core B; project 

operation and maintenance would represent 

a very small increase in disturbance, because 

no trails currently provide for recreation at 

Decker Canyon site 

Munz’s onion No suitable habitat at reservoir site; 

however, South Main Divide Road in 

vicinity passes through a soil type that is 

known to support occurrences of this species 

Same 

Developed recreation 

facilities 

Footprint would not include Morgan Trail 

trailhead with minimal effect on users of the 

trailhead during construction but trail would 

need to be re-routed either temporarily or 

permanently depending on final design 

Morgan Trail would not have to be rerouted 

and because visitation is low, increased 

traffic on South Main Divide Road would 

have minimal effect on Morgan trailhead 

users 

Dispersed recreation Would affect hang gliders using the 2 most 

suitable of the 9 launch sites and waterside 

setting offered at Lion Spring 

Would avoid effects on two most popular 

hang glider launch sites 

 Would eliminate a natural looking canyon 

with oak woodland vegetation and replace it 

with a reservoir surrounded by a chain link 

fence; inconsistent with Retention VQO 

The existing aesthetic resources within 

Decker Canyon are subordinate to Morrell 

Canyon and construction effects associated 

with building a reservoir in this location 

would be less than those at the Morrell site; 

development of the alternative site would 

not build over a mature oak-woodland 

riparian area (Lion Spring) 

Traffic Would achieve a balance of excavation to 

fill within the entire project site 

Same 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
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Upper Reservoir Comparison 

Resource/Issue Morrell Canyon (Co-applicants) Decker Canyon (Staff) 

Cultural resources Would destroy or damage four prehistoric 

archaeological sites 

No known sites at Decker Canyon location 

Powerhouse Site Comparison 

Resource/Issue 

Santa Rosa 

(co-applicants and staff) 

Ortega Oaks Evergreen 

30-acre site, 20-acre laydown, 

340 depth of excavation 

58 acres, inclusive of 

laydown; 320 depth of 

excavation; groundwater 

30 to 70 feet 

75 acres, 30-acre laydown, 

290 depth of excavation 

Area of effect 

327,500 cubic yards (includes 

207,000 from the powerhouse 

cavern; 35,000 from the 

transformer gallery; 32,000 

from the surge shaft; 500 

from the vent shaft; and 

53,000 from the powerhouse 

access shaft) 

There will be similar values 

to Santa Rosa but about 

33 percent more excavation 

for the tailrace tunnel, which 

would be about 86,450 cubic 

yards since the Santa Rosa 

tailrace tunnel is 65,000 cubic 

yards; also, the depth of 

excavation is slightly less 

than that of Santa Rosa 

There will be similar values 

to Santa Rosa but about 10 

percent less excavation for the 

tailrace tunnel, which would 

be about 58,500 cubic yards 

since the Santa Rosa tailrace 

tunnel is 65,000 cubic yards; 

also the depth of excavation is 

less than that of Santa Rosa 

Special status 

plants 

Construction of the 

powerhouse could affect 

Coulter’s matilija poppy 

Construction of tunnel 

between upper reservoir and 

powerhouse could affect 

Coulter’s matilija poppy 

No rare plants identified in 

vicinity of Evergreen 

powerhouse location 

Wetland and 

riparian habitat 

Would affect about 0.4 acre 

of waters of the U.S. and state 

Same as Santa Rosa. Would affect less than onetenth of an acre of waters of 

the U.S. and state 

Special status 

wildlife 

Would affect 30 acres of 

coastal sage scrub and 

20 acres of non-native 

grassland 

Would affect 53 acres of nonnative grassland and 5 acres 

of coastal sage scrub 

Would affect 55 acres of nonnative grasslands and 20 acres 

of coastal sage scrub 

Future recreation 

use 

Location of substation and 

above ground transmission 

lines from this location would 

affect hang gliding activities 

Would affect use of hang 

gliding landing site during 

construction; would provide 

formal hang gliding landing 

site following construction 

Would displace informal 

disperse recreational use at 

site 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
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Powerhouse Site Comparison 

Resource/Issue 

Santa Rosa 

(co-applicants and staff) 

Ortega Oaks Evergreen 

Land Use and 

Property values 

Would permanently change 

use to utility and recreation 

use and preclude residential 

use specified in General Plan; 

would purchase, modify, and 

reuse adjacent private 

property (Santa Rosa 

Mountain Villa apartments) 

and buffer would reduce 

effect on property values 

No effect on adjacent 

residential property values at 

Ortega Oaks 

Either raze or use current 

Lakeland Childcare Center at 

the Lakeland Village Plaza 

for construction office 

resulting in displacement of 

child-related businesses and 

purchase/raze one single 

family home 

Aesthetics The powerhouse would be 

underground but the 

substation would be visible 

from surrounding residential 

and commercial properties 

The powerhouse would be 

underground but the 

substation would be visible 

from the heavily used Ortega 

Highway 

Same as Santa Rosa. 

Aesthetics All construction activities 

within this area would 

conflict with the Partial 

Retention VQO designated by 

the USFS; these effects would 

be short term and last for the 

duration of the construction 

Construction activity at 

Ortega Oaks site would be 

visible from the Ortega 

Highway and a small portion 

of Grand Avenue in Lakeland 

Village; two prominent 

viewpoints to commuters in 

the area 

Similar effects on the 

aesthetic resources as 

described above with respect 

to the proposed Santa Rosa 

site 

Cultural 

Resources 

Would affect two historic 

sites and one prehistoric 

archaeological site; could 

affect two historic buildings 

(vibration) 

Would directly affect one 

prehistoric site 

No known sites at Evergreen 

location 

Transmission Alignment Comparison 

Resource/Issue Co-applicants’ Proposed Alignment Staff Alternative Alignment 

Area of effect 34.1 miles in length with 10.8 miles of 

temporary access roads and 5.2 miles of 

permanent access road 

33.7 miles in length with 9.3 miles of 

temporary access roads and 4.1 miles of 

permanent access road 

Fire suppression 

activities 

Could interfere with USFS fire suppression 

activities 

Would avoid interference with USFS fire 

suppression activities 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
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Transmission Alignment Comparison 

Resource/Issue Co-applicants’ Proposed Alignment Staff Alternative Alignment 

Special status plants Could affect Humboldt lily (Subarea 3); 

passes through potential habitat for 

Hammitt’s clay-cress (Subarea 5). Preconstruction surveys could be conducted to 

prevent adverse effects during construction, 

but temporary access roads and permanent 

maintenance roads would substantially 

increase the risk of disturbance and habitat 

damage during project operation, if public 

access is not controlled 

Could affect Humboldt lily (Subarea 3); 

avoids potential habitat for Hammitt’s claycress (Subarea 5). Pre-construction surveys 

could be conducted to prevent adverse 

effects during construction, but temporary 

access roads and permanent maintenance 

roads would substantially increase the risk 

of disturbance and habitat damage during 

project operation, if public access is not 

controlled 

Wetland and riparian 

habitat 

Substation could affect about 1.1 acres of 

waters of the U.S. and state; effects from 

transmission towers would be minor as 

towers would be placed to avoid wetland 

and riparian habitat, but locations of access 

roads are unknown 

Same 

Special status 

wildlife 

Substations would affect 35 acres and 

transmission line towers would affect 

30 acres of potential habitat for special 

status species. About 10.3 miles of 

temporary access roads would affect an 

estimated 15.7 acres, plus indirect effects of 

construction (edge effects) and potential for 

disturbance (e.g., poaching, harassment) and 

habitat damage during operation, if public 

access is not controlled. Permanent 

maintenance road would affect 5.2 miles 

(9.5 acres) 

Substations would affect 35 acres and 

transmission line towers would affect 

30 acres of potential habitat for special 

status species. About 9.3 miles of 

temporary access roads would affect an 

estimated 13.5 acres, plus indirect effects of 

construction (edge effects) and potential for 

disturbance (e.g., poaching, harassment) and 

habitat damage during operation, if public 

access is not controlled. Permanent 

maintenance road would affect 4.1 miles 

(7.5 acres) 

Mountain lion Would remove about 21.25 acres of suitable 

mountain lion habitat from Core B for about 

85 towers; although mountain lions may use 

roads for travel, construction of 5.2 miles of 

permanent and 10.8 miles of temporary 

access roads would substantially increase 

the risk of disturbance (e.g., poaching, 

harassment) and habitat damage during 

project operation, if public access is not 

controlled. Would cross proposed linkage 

1 at Temescal Wash, but tower placement 

should not interrupt travel corridor 

Same, except construction of 4 miles of 

permanent roads and 9.3 miles of temporary 

access roads would increase the risk of 

disturbance 

Bird/T-lines Northern portion (Temescal Wash/Lee 

Lake) of line presents a high risk to 

waterfowl; central portion siting either 

underground or behind ridgeline would 

minimize risk to raptors; southern portion 

poses moderate risk of collision where it 

would cross major drainages 

Same 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
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Transmission Alignment Comparison 

Resource/Issue Co-applicants’ Proposed Alignment Staff Alternative Alignment 

Munz’s onion Would affect about 3.25 acres of potential 

habitat along the northern portion of the 

transmission line, about 23.2 acres at 

underground segment, and 35 acres at the 

northern substation. Pre-construction 

surveys could be conducted to prevent 

adverse effects during construction, but 

temporary access roads and permanent 

maintenance roads would substantially 

increase the risk of disturbance and habitat 

damage during project operation, if public 

access is not controlled 

Same, except would affect about 15.1 acres 

at underground segment 

Slender-horned spine 

flower, San Diego 

ambrosia, California 

Orcutt grass, San 

Jacinto Valley 

crownscale 

Occurrences at Temescal Wash at Indian 

Creek and Alberhill (Subarea 1); vernal pool 

habitat may exist along southern segment of 

alignment (Subarea 8). Tower construction 

could affect about 3.25 acres of potential 

habitat. Pre-construction surveys could be 

conducted to prevent adverse effects during 

construction, but temporary access roads 

would substantially increase the risk of 

disturbance and habitat damage during 

project operation, if public access is not 

controlled 

Same 

Thread-leaved 

brodiaea 

Occurrences in the vicinity of Tenaja Creek 

(Subarea 7). Tower construction could 

affect about 0.25 acre of potential habitat. 

Pre-construction surveys could be conducted 

to prevent adverse effects during 

construction, but temporary access roads 

would substantially increase the risk of 

disturbance and habitat damage during 

project operation, if public access is not 

controlled 

Same. 

Quino checkerspot 

butterfly 

Substation and tower construction would 

affect 36.75 acres within designated critical 

habitat and about 0.75 acre of potential 

habitat; temporary access roads would 

substantially increase the risk of disturbance 

and habitat damage during project operation, 

if public access is not controlled 

Same 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
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Transmission Alignment Comparison 

Resource/Issue Co-applicants’ Proposed Alignment Staff Alternative Alignment 

Arroyo toad and 

California red-legged 

frog 

Construction of towers at Temescal Wash 

(north) and Los Alamos Canyon and Tenaja 

Creek (south) could adversely affect about 

1.25 acres of potential arroyo toad habitat; 

but could avoid California red-legged frog 

habitat through siting. No effects on critical 

habitat for either species, but temporary 

access roads would substantially increase 

the risk of disturbance and habitat damage 

during project operation, if public access is 

not controlled 

Same 

Southwestern willow 

flycatcher and least 

Bell’s vireo 

Occurrences at Temescal Wash and Tenaja 

Creek; construction of towers could affect 

about 1 acre of potential habitat. Access 

roads could also adversely affect habitat; 

temporary access roads would increase risk 

of disturbance and habitat damage during 

project operation, if public access is not 

controlled 

Same 

Coastal California 

gnatcatcher 

Construction of northern substation and 

towers could affect 38.5 acres of habitat 

within proposed critical habitat; access roads 

could also adversely affect habitat; 

temporary access roads would increase risk 

of disturbance and habitat damage during 

project operation, if public access is not 

controlled. 

Same 

Stephens’ kangaroo 

rat 

Construction of northern substation and 

towers could affect over 38.5 acres of 

habitat within the Stephens’ Kangaroo Rat 

Fee Assessment Area and Lake MathewsEstelle Mountain Core Reserve; temporary 

access roads could also affect habitat and 

would increase the risk of disturbance and 

habitat damage during project operation, if 

public access is not controlled 

Same except includes access roads with 

northern substation and towers 

Developed recreation 

facilities 

Would affect Wildomar OHV area and 

campground and these facilities would likely 

need to be closed during the first two years 

of construction (would be covered in the 

detailed site plan for construction) 

Would avoid Wildomar OHV and 

campground locations; increased traffic due 

to construction would have minimal effects 

on users at these facilities 

Dispersed recreation Major effect on dispersed recreation would 

be in the vicinity of flight paths used by 

hang gliders; would present safety hazards; 

would result in considerable loss of hang 

gliding opportunities 

Avoids some conflicts with hang gliding and 

FS land classifications where transmission 

line construction would be inconsistent with 

FS land management directives 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
5-9 

Transmission Alignment Comparison 

Resource/Issue Co-applicants’ Proposed Alignment Staff Alternative Alignment 

Aesthetics Towers and corridors would be visible in the 

foreground, middleground and background; 

construction activities within the Cleveland 

National Forest would result in features 

which conflict with the Retention and Partial 

Retention VQO standards 

Would introduce line, colors, and textures 

into the landscape that do not currently exist 

and this would not be consistent with 

Retention VQO and would be slightly more 

visible from key viewpoints than the coapplicants’ proposed alignment 

 The linear features of the lines would 

contrast with the mountain and within the 

Cleveland National Forest be in conflict 

with the VQOs; the towers, conductors and 

resulting footprint of the corridor would be 

visible from highly traveled roadways 

Same. Also because the lines would be 

lower down on the mountain they would be 

closer to Lakeland Village and more visible 

from the community of Lake Elsinore 

Future recreation use Transmission alignment would affect use by 

hang gliders of both launch and landing 

areas but avoids residential areas 

Would reduce conflicts with hang gliding 

uses 

Roads About 15.7 acres of temporary access roads 

could be revegetated; it is estimated that 

about 10.8 miles of road would be needed to 

service 32.1 miles of transmission line. 

About 5.2 miles (9.5 acres) would be needed 

for a permanent maintenance road along the 

underground segment 

About 13.5 acres of roads could be 

revegetated; public use could adversely 

affect habitat along 9.3 miles of road. 

About 4.1 miles (7.5 acres) would be needed 

for a permanent maintenance road along the 

underground segment 

Property values Would adversely affect private property 

values up to 3 miles and 5 miles from where 

transmission alignment would cross or 

parallel private properties along northern 

portion and southern portion, respectively 

and would cross or be parallel within 

0.25 mile about 8.6 miles of lands 

designated for residential development and 

may make these lands less desirable for 

development 

Would adversely affect private property 

values up to 4 miles and 9 miles from where 

transmission alignment would cross or 

parallels private properties along northern 

portion and southern portion, respectively 

and would cross or be parallel within 

0.25 acre of about 15.9 miles of land 

designated for residential development 

under the General Plan and may make these 

location less desirable for development 

Land Use Would be within 0.25 mile of 406 privately 

owned parcels and would cross or be 

adjacent to 6.1 miles of property zoned for 

residential use 

Would be within 0.25 miles of 452 privately 

owned parcels and would cross or be 

adjacent to 13.4 miles of property zoned for 

residential use 

Cultural resources Northern segment could affect one 

prehistoric and two historic period 

archaeological sites; southern portion would 

not effect any known sites, but southern 

substation would affect one prehistoric site 

and sites in unsurveyed areas 

Alignment has not been surveyed; could 

affect as yet unknown prehistoric sites 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
5-10 

5.1.1 Co-applicants’ Proposed Action 

Project Facilities 

• Construct an upper reservoir at Morrell Canyon based on the conceptual designs for alternate 

A.3. 

• Construct a powerhouse at the Santa Rosa site based on the conceptual designs for the water 

conduit alternative H.3. 

• Install a 500-kV line along the proposed transmission alignment. 

Geology and Soils 

• Retain a board of three or more qualified independent engineering consultants experienced in 

critical disciplines, such as geotechnical, mechanical, and civil engineering, to review the 

design specifications and construction of the project for safety and adequacy. 

• Conduct additional geotechnical studies. 

• Develop an erosion control plan prior to construction. 

• Implement erosion control measures during construction. 

• Develop and implement a plan for the design and construction of a system that would 

automatically detect conduit or penstock failure and, in the event of such a failure, 

immediately shut off flow in the conduit or penstock at the headworks. 

• Develop and implement plans for clearing the upper reservoir area and re-vegetating 

disturbed areas with native plant species beneficial to wildlife prior to the start of any landdisturbing or land-clearing activities at the project. 

Water Resources 

• Develop and implement a upper reservoir and water conduit monitoring program to assess the 

effects of the upper reservoir liner and seepage collection systems, shafts, and tunnel on 

groundwater levels and water quality, including the installation of perimeter wells designed to 

establish groundwater levels and water quality prior to construction and to detect changes in 

groundwater levels and water quality after construction. 

• Develop and implement a plan for installing drainage and flood control measures and any 

water detention structures to control storm run-off over the term of any license issued for the 

project. 

• Pay an annual lake management fee to Elsinore Valley MWD to maintain Lake Elsinore at 

the minimum target elevation of 1,240 feet msl consistent with the goals of the Lake Elsinore 

Stabilization and Enhancement Project.79

• Develop and implement a dam safety monitoring program.80

 

79 The co-applicants estimate this fee at $1.8 million per year and indicate that it is subject to further 

negotiations with the Elsinore Valley MWD. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
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• Prepare a hazardous substances spill prevention and control plan. 

• Develop and implement a plan to monitor DO and temperature downstream of the tailrace in 

Lake Elsinore and in Temescal Wash during construction and operation. 

Aquatic Resources 

• During construction drawdown, remove or reduce the existing fish population via netting or 

rotenone poisoning. 

• Retain a qualified biologist or natural resource specialist to serve as an environmental 

construction monitor to ensure that incidental construction effects on biological resources are 

avoided or limited to the maximum feasible extent. 

• Establish appropriate setbacks from streams, avoid sediment discharge, and implement BMPs 

identified by the USFS to avoid any effects on the existing steelhead recovery efforts in the 

San Mateo Watershed as part of the erosion control plan. 

• Design and install physical barrier screens consistent with NMFS criteria in areas of 

underwater intakes to prevent impingement and entrainment. 

• Establish limits of flow velocity rates of underwater intakes of less than 1.5 feet per second 

reduce impingement and entrainment of fish. 

• Conduct monitoring for 1 year to determine the extent of fish entrainment and mortality at the 

Lake Elsinore intake/outlet structures, and implement and test behavioral avoidance devices 

if entrainment is significant. 

Terrestrial Resources 

• Employ a qualified biologist and/or natural resource specialist to monitor construction 

activities and help prevent adverse effects on sensitive species or habitats. 

• Conduct wetlands delineations and prepare habitat mitigation and management plans in 

consultation with the Corps, CDFG, and the USFS. 

• Develop and implement a plan to prevent and control noxious weeds and exotic plants of 

concern in project-affected areas. 

• Design and construct the transmission line to the standards outlined in 1996 by APLIC. 

• Consult with the USFS and Interior to identify appropriate parcels for mitigation of habitat 

losses including 2:1 replacement ratio for about of 20 acres of oak woodlands and 1:1 

replacement of 31 acres of coastal sage scrub. 

• Provide compensation of $500 per acre for project effects within Stephens’ Kangaroo Rat Fee 

Assessment Area. 

 

80 This co-applicant-proposed measure is more of an administrative measure and would be coordinated 

with the Commission’s Division of Dam Safety and Inspection and the California Department of 

Water Resources. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
5-12 

Recreational Resources 

• Develop and implement a detailed site plan of construction sites and laydown areas relative to 

existing recreational facilities and specify contingencies for restricting public access to these 

areas and providing alternative facilities. 

• Install fencing around the upper reservoir. 

• Provide interpretive signage at the upper reservoir. 

• Provide USFS with an ancillary structure that would complement the USFS firefighter's 

memorial along Ortega Highway. 

• Grade, contour, and revegetate using native plants to return the site to pre-construction 

conditions or prepare the upper reservoir construction laydown area or another location for 

future development by the USFS or other entity as determined by the USFS. 

• Relocate portions of the Morgan Trail (Forest Route 7-s-12) if the upper reservoir is located 

in Morrell Canyon. 

• Develop and implement a recreation plan, including the construction of a botanical garden, 

and provision of powerhouse tours and other amenities at the Santa Rosa or Evergreen 

powerhouse location. 

• Develop a hang glider landing site, provide for a community park, and public tours of the 

powerhouse if the powerhouse is located at the Ortega Oaks site and the proposed northern 

transmission alignment is used. 

• Develop an annual fish stocking program for Lake Elsinore in consultation with FWS, 

CDFG, and the Joint Watershed Authority. 

Land Use and Aesthetic Resources 

• Acquire and modify the multi-family residences nearest the proposed powerhouse site (the 

Santa Rosa Villas in the case of the Santa Rosa powerhouse site and a single family home and 

Lakeland Village Plaza in the case of the optional Evergreen powerhouse site), provide 

relocation assistance, use properties for construction purposes or retain in vacant condition, 

and return to the regional housing inventory upon completion of construction to address 

potential adverse effects on residents during construction. 

• Acquire fee simple or leasehold interests in lands needed for project purposes by voluntary 

sale or conveyance to the extent possible. 

• Prepare a plan to avoid or minimize disturbances to the quality of the existing visual resource 

of the project area. 

• Consult with the Riverside County Flood Control District and formulate and implement plans 

to avoid adversely affecting existing drainage facilities and to control any project-related 

drainage. 

• Achieve a balance of excavation and fill materials at the project site by using excavated 

materials from the intake, powerhouse, penstock, tunnel, and upper reservoir excavations in 

the construction of upper reservoir dam and embankments. 

• Participate in the installation of traffic signal at the Grand/Ortega intersection. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
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• If the Ortega Oaks power house location is selected, dedicate and improve any additional 

right-of-way along Ortega Highway that would be required to accommodate existing or 

anticipated future traffic volumes. 

• Develop and implement traffic management and control plans to address construction traffic 

and access to and from active construction sites. 

• Install temporary roads on National Forest System lands only with USFS approval and 

according to USFS policies and remove, recontour, and revegetate roads following 

construction, except where the USFS authorizes continued use of the roads for transmission 

line maintenance. 

• Conduct all construction activities in accordance with the noise element of the County of 

Riverside Comprehensive General Plan, city of Elsinore construction noise standards and any 

applicable codes or standards. 

Cultural Resources 

• Consult with the SHPO or USFS at least 180 days prior to commencement of any landclearing or land-disturbing activities within the project boundaries, other than those 

specifically authorized in the license, including recreational development at the project.81 

• If previously unidentified archaeological or historic properties are discovered during the 

course of constructing or developing the project works or other facilities at the project, stop 

all land-clearing and land-disturbing activities in the vicinity of such properties and consult 

with the SHPO.82

• Implement measures proposed in the draft HPMP developed in consultation with the SHPO 

and USFS and filed with Commission, including provisions for the following: (1) completing 

pre-construction archaeological surveys in the APE; (2) determining the need for intensive 

surveys; (3) monitoring historic properties during construction; (4) appointing a tribal liaison; 

(5) studying the potential effects of ground acceleration on historic buildings; (6) developing 

a program to monitor archaeological sites for 5 years; and (7) developing a public 

interpretative program. 

• Conduct paleontological monitoring of earth-moving activities on a part-time basis in 

locations that are sensitive for paleontological resources. 

• Prepare any recovered fossil remains to the point of identification and prepare them for 

curation by the Los Angeles County Museum or San Bernardino County Museum. 

5.1.2 Staff Alternative (Preferred Alternative) 

The staff alternative consists of an upper reservoir at the Decker Canyon site a powerhouse at the 

Santa Rosa site, and a transmission alignment. The staff alternative includes most of the co-applicants’ 

environmental measures, except for their proposed recreational measures associated with the Morrell 

Canyon upper reservoir site, the measure to remove or reduce the existing fish population via netting or 

rotenone poisoning during construction, and the installation of fish screens. We have expanded the scope, 

 

81 If activity is on USFS lands, also consult with the USFS at least 180 days prior to commencement of 

any land-clearing or land-disturbing activities within the project boundaries, other than those 

specifically authorized in the license, including recreational development at the project. 

82 Also consult with the USFS, if archaeological site or historic property is identified on USFS lands. 

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added consultation requirements or otherwise modified the co-applicants proposed measures for erosion 

control, water quality monitoring for the conveyance system, entrainment monitoring, habitat mitigation 

ratios, noxious weed control, avian protection guidelines, and construction monitoring in aquatic and 

terrestrial environments. The staff alternative would include the following modified and additional 

environmental measures. 

Project Facilities 

• Construct an upper reservoir at Decker Canyon based on the conceptual designs for 

alternative B.2. 

• Install a 500-kV transmission line along the staff alternative transmission alignment. 

Geology and Soils 

• Include specific provisions in the proposed erosion control plan that apply erosion control 

measures and BMPs to all construction locations including the upper reservoir, drainage and 

flood control locations, penstock tunnels, powerhouse, tailrace, inlet/outlet structure, 

transmission lines, and all associated construction laydown areas and temporary on-site 

borrow areas and for all subsequent ground disturbing activities over the term of the license. 

Water Resources 

• Develop and implement a revised lake operating plan for Lake Elsinore, addressing increased 

minimum lake levels, flood control implications, and water supply issues. 

• Develop and implement a surface water resources management plan to control and monitor 

project-related effects on water resources that support riparian vegetation on National Forest 

System lands. 

• Include specific remediation measures in the proposed upper reservoir and water conduit 

monitoring program to allow immediate action to be taken should water and non-native 

aquatic species be released from the upper reservoir into the San Juan Creek drainage. 

• Include specific provisions in the proposed upper reservoir and water conduit monitoring 

program to explore the groundwater and characterize the aquifer, to consult on groundwater 

inflow criteria, and to monitor groundwater levels during construction and operation of the 

water conduits including the tunnels and penstocks that convey water between the upper 

reservoir and the powerhouse for 10 years or longer if necessary, specifying remedial actions 

if monitoring reveals changes in groundwater levels or seepage into the tunnels. 

Aquatic Resources 

• Develop and implement a detailed plan specifying the activities, locations, methods, and 

schedules that the qualified environmental construction monitor would use to monitor 

construction activities in aquatic environments. 

• Conduct entrainment monitoring for 1 year and once every 5 years over the term of any 

license issued to the project to determine the extent of fish entrainment and mortality at the 

Lake Elsinore intake/outlet structures and provide the monitoring results to CDFG, FWS, the 

State Water Board and the Joint Watershed Authority, and, based on the results of 

entrainment monitoring, develop and implement a plan to mitigate for entrainment losses 

through measures, such as enhancing nearshore fish habitat or stocking fish, that would aid in 

establishment of naturally sustaining population of desirable sport fish. 

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Terrestrial Resources 

• Develop and implement a detailed plan specifying activities, locations, methods and 

schedules the qualified environmental construction monitor would use to monitor 

construction in terrestrial environments. 

• Develop and implement a vegetation and invasive weed management plan to prevent and 

control noxious weeds and exotic plants of concern in project-affected areas during 

construction and over the term of any license issued for the project. 

• Develop and implement a Lake Elsinore monitoring and remediation plan to eliminate or 

reduce project-related effects, if any are identified, on nesting shorebirds, waterfowl, and 

other birds. 

• Implement the proposed avian protection plan consistent with April 2005 avian protection 

plan guidelines and over the term of any license issued for the project. 

• Conduct additional pre-construction special status plant surveys at transmission line tower 

sites and along transmission alignment access roads, consistent with the Multi-Species HCP. 

• Prepare a habitat mitigation plan in consultation with the USFS, Interior, CDFG, and 

Riverside County to identify appropriate mitigation of habitat losses including a 1:1 

replacement ratio for about 5 acres of oak woodlands, about 32 acres of coastal sage scrub, 

and about 216 acres of chaparral and grasslands. 

• Consult with the USFS annually to review the list of special status species and survey new 

areas as needed. 

• Develop and implement an annual employee awareness training program regarding special 

status plants and animals. 

• Consult with the FWS during the process of developing final design drawings on measures to 

protect fish and wildlife resources. 

Recreational Resources 

• Develop and implement a safety during construction plan identifying potential hazard areas 

near public roads, trails, and recreation areas and facilities, and measures necessary to protect 

public safety and conduct daily inspections on National Forest System lands for fire plan 

compliance, public safety, and environmental protection. 

• In consultation with the USFS, develop and implement a plan for a recreational facility at the 

construction laydown area used during construction of the upper reservoir on National Forest 

System lands or for an alternative use and/or location. 

• Develop and implement a recreation plan that provides for transfer of cleared land to a local 

entity and development of recreation facilities at the powerhouse location and O&M funding 

sufficient to operate the facility. 

Land Use and Aesthetics 

• Develop and implement a plan to determine the toxicity of sediments in Lake Elsinore 

lakebed that would be disturbed by construction of the intake/outlet structure and to provide 

for appropriate handling and disposal if toxins are identified in the lakebed sediment prior to 

the commencement of the construction of the intake/outlet structure in Lake Elsinore. 

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• Achieve a balance of excavation and fill materials at the Decker Canyon reservoir site 

through additional excavation and dispose of all excavated materials from all other project 

facilities off site. 

• Include in the proposed road and traffic management plan applicable on National Forest 

System lands, provisions addressing road construction, realignment, maintenance, use, and 

closure and identifying the co-applicants’ responsibility for road maintenance and repair 

costs. 

• Include in the proposed road and traffic management plan applicable on non-National Forest 

System lands, provisions addressing road construction, realignment, maintenance, use, and 

closure, as well as land management policies and practices associated with project-related 

roads during both construction and operations. 

• Prepare and implement a scenery conservation plan to achieve the greatest consistency 

possible with the High Scenic Integrity Objectives of the Cleveland National Forest Land 

Management Plan. 

• Develop and implement a transmission tower placement plan. 

Cultural Resources 

• Revise the draft HPMP in consultation with the SHPO, Tribes, BIA, the Lake Elsinore 

Historical Society, and the USFS and file a final HPMP for Commission approval within 1 

year of license issuance. 

Finally, Commission staff notes that the staff alternative includes all of the revised preliminary 

4(e) conditions specified by the USFS and described in section 2.6.2, USFS Section 4(e) Conditions. 

Commission staff would supplement the following measure: 

• Ensure all transmission facilities conform to APLIC et al. (1996) guidelines, including power 

lines to reduce risks of bird strikes. The co-applicants should conform to the April 2005 

avian protection plan guidelines. 

5.2 DISCUSSION OF KEY ISSUES 

5.2.1 Project Facilities 

Upper Reservoir 

The co-applicants propose to locate the upper reservoir in Morrell Canyon. Our analysis shows 

that construction of an upper reservoir at the Morrell Canyon site would disrupt flows in the San Juan 

Creek drainage, displace Lion Spring, and remove more than 20 acres of southern coast live oak riparian 

forest. Oak woodlands are considered to support higher levels of biodiversity than any other terrestrial 

ecosystem in California and would be difficult to replace at the project site. Construction at this location 

would also remove 80 acres of chamise chaparral. Although abundant in the vicinity, conversion of 

chaparral to project use would reduce habitat available for the Santa Ana mountain lion population, which 

is at risk of extirpation because of rapid urban development. Recreational use at this location would be 

adversely affected because Morgan Trail, which accesses the San Mateo Wilderness Area, would need to 

be relocated either temporarily or permanently depending on the final design of this facility and because 

two of the most-used hang gliding launch sites (E and Edwards) would be closed or subjected to use 

restrictions during construction. 

To avoid these potential adverse effects, the staff alternative would locate the upper reservoir in 

Decker Canyon. There would be no need to install a stream bypass conveyance system at this location 

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because the footprint of the reservoir is situated at the very top of the watershed, with no established 

stream network entering the site. Only 5 acres of southern coastal live oak would be affected and less offsite mitigation for habitat loss would be required, and no rare plant species would be affected. Locating 

the upper reservoir at the Decker Canyon location would avoid construction effects on the use of the E 

and Edwards hang gliding launch sites. 

Table 55 compares the potential effects at the proposed Morrell Canyon and Decker Canyon 

locations. We estimate that the overall energy facility and transmission line, including an upper reservoir 

at Decker Canyon, would have a cost of construction (which includes development costs but excludes the 

license and environmental measures) of about $1,326,722,000, about $43,550,700 more than our estimate 

for the cost associated with such a facility at the proposed Morrell Canyon location. Additionally, we 

estimate that significant water control costs at Morrell Canyon given its upstream drainage, upstream and 

groundwater collection systems, and potentially higher liner costs could add more than $18,000,000 to the 

cost, decreasing the cost advantage of the co-applicants’ proposed alternative to about $20,500,000. 

Because these estimates are based on preliminary designs and cost estimates and additional geotechnical 

investigations may identify other issues, we consider the cost of construction at either site to be within a 

comparable range. 

Powerhouse 

In the draft EIS, we included an underground powerhouse at the Ortega Oaks site and a mid-slope 

transmission alignment in a staff alternative to the co-applicants’ proposal. The Ortega Oaks site 

combined with routing the transmission lines along a mid-slope alignment and west of the USFSpermitted launching sites lessened the potential effects on hang gliding opportunities and provided an 

opportunity to provide a formal landing area. In comments on the draft EIS, the co-applicants and others 

point out that Riverside County approved a subdivision of 100-single family residential lots at Ortega 

Oaks in April 2004, including the 58-acre site proposed by the co-applicants for the powerhouse and 

substation. The co-applicants also filed a report on the comparative geological and geotechnical 

conditions at the three powerhouse sites (Genterra, 2006). This report concludes that the Ortega Oaks site 

offers the least desirable subsurface conditions of the three sites. Hang gliding advocates commented that 

the proposed 5-acre formal landing area at Ortega Oaks would be inadequate and would still present 

hazards associated with an aboveground substation and the above ground distribution lines. 

Our intent on including the Ortega Oaks powerhouse site in the draft EIS staff alternative was to 

avoid displacing residents and disrupting or eliminating hang gliding opportunities. We concluded that 

the geological and geotechnical challenges at any of three sites could be addressed in the final designs. 

However, given the proximity to the existing residential community adjacent to the site, the approved 

subdivision of lands that comprise the site, and the fact it would not eliminate hazards to hang gliders, we 

have revised the staff alternative to include a powerhouse at the Santa Rosa location. Locating the 

powerhouse at the Santa Rosa site combined with burying the transmission line connection to the 

powerhouse (see discussion under Transmission Alignment) would avoid conflicts with existing and 

planned high-density residential communities. This alternative also would provide a clear path for hang 

gliding from the USFS-permitted launch sites along South Main Divide Road and the existing informal 

landing site at Ortega Oaks and would place the above ground substation away from the existing landing 

site. 

Construction activity at the Santa Rosa powerhouse site would affect the adjacent Butterfield 

school population, increase traffic on Grand Avenue, and disturb two historic archaeological sites and one 

prehistoric archaeological site. Vibrations could affect two historic buildings. Implementation of the coapplicants’ proposed erosion control plan with our recommended measures and adherence to local noise 

and air quality ordinances would keep the effects of construction activity within acceptable limits for 

noise and dust. Implementation of the programmatic agreement and associated HPMP for cultural 

resources would avoid, reduce, or mitigate adverse effects to the three archaeological sites and two 

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historic buildings. It is important to note that National Register eligibility needs to be determined for the 

three affected archaeological sites. The construction activity would be short term. Operation of the 

project with an underground powerhouse at the Santa Rosa powerhouse site would introduce a new visual 

element (the substation) into a predominately low-density residential area instead of adjacent to a highdensity residential development at the Ortega Oaks site. 

Transmission Line 

In response to comments on the draft EIS, the co-applicants revised their proposed transmission 

alignment. In response to comments, we revised the staff alternative transmission alignment as well. 

Table 55 compares the effects of the co-applicants’ proposed transmission alignment and the staff 

alternative transmission alignment 

Both the proposed and staff alternative alignments now avoid conflicts with commercial 

enterprises along the northern segment and include underground segments to reduce potential effects on 

hang gliding activities at the USFS permitted hang gliding launch sites and egress from the Rancho 

Capistrano community. The staff alternative transmission alignment also reduces conflicts with the 

Cleveland National Forest Land Management Plan and USFS fire suppression activities. The coapplicants' proposed alignment reduces conflicts with residential subdivisions along the southern segment 

and would generally be less visible to area residents. From the connection with the SCE line for about 4 

miles to the northern border of the Cleveland National Forest, the co-applicants’ proposed transmission 

alignment and the staff alternative transmission alignment follow the same route (see figures F-1 through 

F-4 in appendix F). About 2 miles of this segment of the alignment would run north/south on or adjacent 

to the existing Glen Eden Sun Club and the third phase of the planned Sycamore Creek community. 

Here, the overhead transmission lines would introduce a new unattractive visual element to subdivisions 

where utility lines are buried. As discussed in section 3.3.7.2 use of tree-type poles and non-reflective 

coatings could lessen the affects of above ground lines on adjacent residential areas, especially where the 

line runs adjacent to the Sycamore Creek and Glen Eden Sun Club communities. The transmission 

alignment under consideration in this EIS is a 500-foot-wide corridor within which the line and towers 

can be placed to minimize the potential effects on the aesthetics of adjacent communities within the 

requirement of the National Electric Safety Code. We considered whether to bury the entire 32-mile-long 

line and the 2-mile connection to the powerhouse. Burying the entire line would eliminate most of the 

visual effects (there would still be above ground substation connections) but would be cost prohibitive at 

an incremental cost in excess of $350 million. However, we recognize that there may be locations in 

close proximity to the alignment (such as Sycamore Creek or Glen Eden Sun Club) where the acquisition 

of easements may displace residents and where additional underground segments may be a feasible 

solution. 

Within the Cleveland National Forest, the co-applicants’ proposed transmission alignment would 

cross mostly National Forest System lands on relatively inaccessible, rugged, and steep terrain of the 

Elsinore Mountains and surrounding foothills for about 28 miles and would include an underground 

segment (about 3 miles) in the vicinity of the hang gliding launch sites and Rancho Capistrano and 

connecting to the powerhouse. The staff alternative transmission alignment generally follows a similar 

north/south through the Cleveland National Forest but runs up to a mile more easterly to avoid 

interference with firefighting activities, back country non-motorized areas, and wilderness areas. The 

staff alternative transmission alignment would include an underground segment of about 2.1 miles in the 

vicinity of the hang gliding launch sites. The two routes are the same along about 4 miles of the southern 

end of the alignment to the connection with the SDG&E line. 

Hang gliding advocates raised concerns about the potential effects the proposed transmission line 

as discussed in the draft EIS would have on the current hang gliding opportunities in the city of Lake 

Elsinore and Riverside County. We concluded in section 3.3.8 of the draft EIS that the hang gliding 

industry may contribute about $1 million per year to the local economy. The underground segments of 

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both the co-applicants and staff alternative transmission alignments in the vicinity of the USFS-permitted 

launch sites and to the Santa Rosa powerhouse site address these concerns and greatly reduce effects on 

hang gliding activities. 

The southern segment of the staff alternative transmission alignment avoids the San Mateo 

Wilderness area but runs in proximity to private residential properties, including the La Cresta 

community. As with the northern portion of the line, the final line and tower placement would be 

determined by the National Electric Safety Code and could include tree-type towers and non-reflective 

coatings to lessen the effects on adjacent communities. Again we considered whether to bury the line 

along this southern segment and concluded that the reduced effects on the visual resources (see figure D7) did not justify the incremental cost of about $170 million. 

As discussed in section 3.3.7, Land Use and Aesthetic Resources, the USFS has recently gone 

through an extensive public planning process to identify and develop policy for the forest. The Cleveland 

National Forest Land Use Plan is the framework designed to provide for management of USFS resources 

and values. The plan recognizes the potential for future development within the forest, and has 

designated certain lands as acceptable for various land uses, and sets guidelines for allowable alterations 

to the landscape. The plan provides for the preservation of certain unspoiled vistas and lands. This EIS 

discloses the effects of the proposed project on the USFS lands and indicates where it is incompatible 

with the approved plan. The Cleveland National Forest Land Management Plan may need to be amended 

to accept the project’s inconsistencies while retaining the current plan’s desired conditions and outcomes. 

Overall, the staff alternative transmission alignment would reduce conflicts with USFS plan and 

fire suppression activities, hang gliding activities, and commercial enterprises. We recognize that, the coapplicants’ proposed alignment is the less visible from key viewpoints in the wilderness area, along 

Ortega Highway, and from Lake Elsinore, but would still interfere with USFS fire suppression activities 

in several areas and would cross back-country non-motorized areas of the Cleveland National Forest. The 

staff alternative transmission alignment that would run parallel but east of the co-applicants’ proposed 

alignment would avoid potential conflicts with fire suppression activities, although it would be more 

visible than the co-applicants’ proposed alignment and would cross more private properties, many of 

which are in-holdings within the boundaries of the Cleveland National Forest. The proposed and staff 

alternative transmission line alignments are about the same length (about 32 miles with a 2 mile 

connection to the Santa Rosa powerhouse) and would involve comparable costs with the co-applicants 

alignment costing slightly more due to its longer overall length (34.1 miles versus 33.7 miles) and longer 

buried segment (5.2 miles versus 4.1 miles). 

Both the co-applicants’ proposed and staff alternative transmission alignments are considered as 

500-foot-wide corridors within which the placement of transmission towers can be adjusted to avoid 

effects on buildings, sensitive habitats, riparian areas, viewsheds, and other environmental resources. The 

co-applicants propose to minimize the effects of the transmission line on environmental resources by 

placing towers outside of sensitive areas and riparian areas. The co-applicants also indicate that they 

would consider the use of tree-type towers in areas that cross or are adjacent to residential areas to reduce 

the visual impact of the transmission lines. Given these various considerations in the placing of towers, 

we recommend that the co-applicants prepare a transmission tower placement plan in consultation with 

the city of Lake Elsinore, Riverside County, the USFS, FWS, and CDFG. We estimate that this plan 

would entail a one time capital cost about $100,000 or $14,100 annualized and would be warranted as a 

means to ensure full consideration of the concerns of property owners, fish and wildlife resource 

agencies, and local governmental agencies about minimizing the effects of tower placements. 

5.2.2 Construction Oversight 

The co-applicants would be required to submit plans and specifications and a supporting design 

report prior to construction. The plans and specifications would describe how the project will be 

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constructed and the supporting design report would ensure the proposed project structures are designed in 

accordance with the Commission’s Engineering Guidelines and sound engineering practice. All project 

construction would be overseen by quality control personnel, independent of the contractor, as well as 

engineers from the Commission’s Division of Dam Safety and Inspections – San Francisco Regional 

Office. 

The co-applicants’ proposal to retain a board of three qualified independent engineering 

consultants experienced in critical hydropower construction disciplines would ensure that design 

specifications are appropriate to the site and that construction would proceed in a reasonable and safe 

manner under either alternative. This is particularly critical given the additional geotechnical studies 

proposed by the co-applicants and the need to develop final design drawings for the project features 

included in the staff alternative. We estimate that it would cost about $1,500,000 for the additional 

geotechnical and engineering design and review board services prior to and during construction of the 

project under either alternative, or $211,600 annually. 

5.2.3 Geology and Soils 

The potential for slope erosion and sediment transport into streams exists at the proposed project 

construction sites under both alternatives. The co-applicants’ proposed erosion control plan would 

include measures and BMPs designed to avoid or minimize erosion at all construction locations during 

project construction. BMPs would include the co-applicants’ proposal for appropriate setbacks from 

streams and avoidance of sediment discharges into streams to avoid effects on the existing steelhead 

recovery efforts in the San Mateo Watershed. 

USFS revised preliminary 4(e) condition no. 15 specifies a plan that includes measures to control 

erosion, stream sedimentation, dust, and soil mass movement during construction and operation of the 

project. Development and implementation of an erosion control plan that applies erosion control 

measures and BMPs to all construction locations (including the upper reservoir, drainage and flood 

control locations, penstock tunnels, powerhouse, tailrace, inlet/outlet structure, transmission lines, and all 

associated construction laydown areas and temporary on-site borrow areas during project construction) 

would minimize the effects of erosion on water resources and other environmental resources in the project 

area. 

A Quality Control and Inspection Program, including the co-applicants' proposed erosion and 

sediment control plan for construction activities, would be submitted prior to construction under the staff 

alternative. The staff alternative also would specify that the erosion control plan be implemented for any 

subsequent maintenance and ground-disturbing activities over the term of any license issued for the 

project. 

The potential exists for high-pressure water conduits or penstock to fail. The co-applicants’ 

proposed system to detect a water conduit or penstock failure and immediately shut off flow in the 

conduit or penstock at the headworks would limit the potential effects of erosion at and down slope of the 

failure point. 

Removing vegetative cover during construction could result in the loss of native plants beneficial 

to wildlife and could result in surface erosion at the construction sites. To address this concern, the coapplicants propose two plans in conjunction with the erosion control plan. These plans address reservoir 

clearing and revegetation of disturbed soils. The reservoir clearing plan would identify the location and 

acres of lands to be cleared, describe the vegetation to be cleared, describe resource management goals 

related to fish and wildlife enhancement, and describe and map disposal methods and locations. The 

revegetation plan would address plant species and densities to be used, fertilization and irrigation 

requirements, an effectiveness monitoring program, provision for filing monitoring reports, and 

procedures to be followed if monitoring reveals that revegetation is not successful. These plans would be 

valuable in minimizing adverse effects on existing soil and botanical resources and helping to re-establish 

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appropriate plant communities. These plans would be consistent with USFS revised preliminary 4(e) 

condition no. 15, as described in section 3.3.1.2. 

In section 3.3.4.2, we conclude that adding success criteria for replanting would improve the 

potential for restoring vegetation to its existing condition. Therefore, under the staff alternative the plan 

would specify that the co-applicants add a specific measure to the revegetation plan to identify criteria for 

success (e.g., percent coverage of desired species at specified time intervals) to provide the basis for 

determining which vegetation parameters to monitor as revegetation proceeds. 

Under the staff alternative, the co-applicants would add a specific measure to the clearing plan to 

address stockpiling as clearing takes place and replacing topsoil after construction is completed. This step 

would provide additional support for re-establishment of native plant communities in native soils. 

We estimate that the cost of developing the co-applicants' proposed erosion control plan would be 

about $32,500 annually and the cost to implement the proposed erosion control measures and BMPs 

during the construction of the project would be about $301,700 annually. The staff alternative would be 

$308,600 annually, or $6,900 more than the co-applicants’ proposal. We estimate that the additional cost 

to implement the plan during the term of any license issued would be $9,900. We estimate that the cost of 

developing and maintaining the co-applicants' proposed conduit shut-down system would be $12,800 

annually; the cost of their vegetative clearing plan would be $4,900 annually; and the cost of the 

revegetation plan would be $4,200. 

5.2.4 Water Resources 

Revised Lake Operating Plan 

The co-applicants would pay an annual fee to the Elsinore Valley MWD to provide make-up 

water necessary to maintain lake elevations at 1,240 feet msl or above and would typically operate the 

project between lake elevations 1,240 and 1,247 feet msl under both alternatives. 

The staff-recommended revised lake operating plan for Lake Elsinore would ensure that the 

measures related to make-up water, flood control, and project operations, in combination, would not 

produce unexpected consequences. Under the staff alternative the plan would, at a minimum, specify the 

amount and timing of minimum inflow for the make-up water and the point of discharge. In section 

3.3.2.2, we conclude that the added volume of water from pumped storage operations (5,500 acre-feet) 

during flood seasons could raise the lake elevation several feet beyond the 1,249-foot msl elevation. 

Higher elevations could increase shoreline flooding and exacerbate the magnitude of spills into Temescal 

Wash and the Back Basin. 

The co-applicants indicate that the annual lake management fee would be $1.872 million subject 

to further negotiation. We estimate that the cost of developing and implementing a revised lake operating 

plan over the term of any license issued would be $28,200 annually and would be necessary to address the 

effects of project operations of lake management. Developing and implementing a drainage and flood 

control plan as proposed by the co-applicants’ and recommended by Riverside County would cost on 

additional $14,100 annually. As we said in section 3.3.2.2, these measures would assure that the reservoir 

levels would be within the operating range of the proposed project. 

Preventing Interbasin Water Transfers 

The storage of low quality Lake Elsinore water in the upper reservoir within the San Juan Creek 

Watershed has the potential to negatively affect water quality in the San Juan Creek. The co-applicants 

would monitor water quality and liner performance as part of their proposed upper reservoir and water 

conduit monitoring program (see discussion under Groundwater Monitoring). The co-applicants’ plan to 

monitor the effectiveness of the drainage system/reservoir liner for the protection of existing flow 

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conditions at the upper reservoir would provide for an early detection of leakage from the upper reservoir 

liner and drain system. This plan would meet most of the objectives of Interior’s recommendation for 

monitoring and maintaining the upper reservoir to eliminate or reduce release of water and non-native 

aquatic species from the upper reservoir into the San Juan Creek drainage. However, the co-applicants’ 

plan is silent with regard to steps to take if monitoring shows that the liner and drain are not effective. In 

section 3.3.2.2, we conclude that advanced planning for remedial steps would allow for a rapid response 

in the unlikely event of leakage. Under the staff alternative, at this plan also would include specific 

remediation measures that could be taken. Our estimate for the cost of this plan is provided at the end of 

the discussion on groundwater monitoring. 

Groundwater Monitoring 

The co-applicants identified groundwater monitoring as an important consideration in their 

technical reports and description of anticipated affects. They propose an upper reservoir and water 

conduit (tunnels, shafts, and penstocks) monitoring program that would assess the affects of project 

construction on ground water levels and water quality. The co-applicants' program calls for gathering 

information on groundwater levels and water quality prior to the start of construction, monitoring 

groundwater levels during project construction, and taking remedial steps to grout and seal any observed 

seeps during construction. Because the majority of the water conduits would be lined, we would not 

expect excessive seepage during project operation. However, seepage could occur. Under the staff 

alternative, the monitoring program would specify continued monitoring of ground water levels for at 

least 10 years following commencement of project operations and would specify what remedial steps 

would be taken should changes in groundwater levels be detected. Our alternative would also include the 

development of groundwater inflow criteria in consultation with the USFS as part of the characterization 

of the aquifer prior to construction of the project. We would consider this step to be consistent with the 

co-applicants’ proposal to gather information about groundwater levels prior to the start of construction at 

the upper reservoir site. 

Developing and implementing the co-applicants' groundwater monitoring program would have a 

capital cost of $500,000 that would be incurred during the construction period and during the first 2 years 

of project operation. This would result in an annual cost of $70,500. Including provisions in the 

groundwater monitoring program for groundwater exploration and aquifer characterizations, monitoring 

groundwater levels and water quality for at least 10 years after the start of operation, and specifying 

remedial actions as called for under the staff alternative would add an annual cost of $34,700. The 

additional cost would be justified to ensure that the reservoir and tunnel linings are effective in preventing 

seepage that could adversely affect groundwater levels and water quality in surface streams. 

Surface Water Monitoring 

Project construction could affect wetlands and riparian habitat. The USFS specifies in revised 

preliminary 4(e) condition no. 35 that the co-applicants develop and implement a water surface 

management plan to control and monitor project-related effects on water resources that support riparian 

vegetation on National Forest System lands. Following construction, interception of rainfall within the 

area occupied by the reservoir would reduce peak flows during extreme (i.e., 100-year) flood events by 

about 6 percent, as discussed in section 3.3.2.2. Effects would be greater just below the dam, and would 

diminish downstream. During most years, assuming that design features would not alter the natural 

hydrograph (i.e., flow volume and timing would be the same), and we do not anticipate any effects on 

downstream waters, streams, wetlands, or riparian habitat to result from project operation at the proposed 

Morrell Canyon site. 

Implementation of USFS revised preliminary 4(e) condition no. 35 would provide baseline 

information about hydrology, water quality, riparian plant communities and wildlife in Decker Canyon or 

Morrell Canyon and would establish a mechanism for long-term monitoring to evaluate project effects on 

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these resources. The condition indicates that the co-applicants should conduct inventories at both 

reservoir sites, although we note that if the Commission issues a license for the project, only one upper 

reservoir would be constructed. Implementation of a surface water management plan would provide 

baseline information that could be used for long-term monitoring and management. 

Development and implementation of a water surface management plan add about $58,200 

annually to the cost of the project but would be warranted. 

Water Quality Monitoring 

Project operations could affect temperature, DO, and nutrient cycling occurring in Lake Elsinore 

under both alternatives. In section 3.3.2.2, we conclude that operating the project would slightly improve 

DO levels in Lake Elsinore as a result of the mixing of denser, cooler water from the upper reservoir with 

the warmer water in Lake Elsinore. The co-applicants propose to monitor DO and water temperature in 

the tailrace area and Temescal Wash during and after construction of the project. However, the actual 

effect of project operations may be difficult to separate from the improvements in DO from 

implementation of the aeration program under the Lake Elsinore Stabilization and Enhancement Project. 

We estimate that the annual cost of water quality monitoring would be $31,200. 

Spill Prevention Plan 

The potential for the release of fuels, oils, lubricants, and other hazardous substances exists at the 

sites of project features during construction and during operation of the project under both alternatives. 

The co-applicants’ proposal to prepare a hazardous substances spill prevention and control plan would 

prevent and minimize any effects associated with the handling of hazardous substances during project 

construction and operation. We estimate the cost to develop and implement this plan would be $1,400. 

5.2.5 Aquatic Resources 

Environmental Construction Monitor 

The potential for slope erosion, sediment transport into streams, and hazardous substance spills 

exists at all the proposed construction sites under both alternatives. To address these concerns, the coapplicants propose to develop and implement a detailed plan for monitoring construction activities in 

aquatic and terrestrial environments by a qualified environmental construction monitor. USFS revised 

preliminary 4(e) condition no. 32 specifies that this plan should specify the activities, locations, and 

frequency of the monitoring that would occur. We conclude in section 3.3.3.2 that more specifics are 

needed to ensure that all the activities, locations, and frequencies of inspections are commensurate with 

the potential effects of project construction. Under the staff alternative, the detailed plan would describe 

the specific monitoring activities, locations, and frequencies. We estimate that the co-applicants’ annual 

costs for environmental monitoring during construction would be $18,300 for aquatic resources and 

$42,300 for terrestrial resources. We estimate that the annual cost for developing our more detailed plan 

would be about $20,000, or about $2,800 more than the co-applicants’ proposal for construction 

monitoring. These cost estimates would be the same under either alternative. 

Entrainment Prevention Measures 

Operation of the project has the potential to entrain fish at the intake/outlet structure in Lake 

Elsinore. The co-applicants’ propose a program to install screens in the areas of the intake structures, to 

monitor entrainment over a 1-year period, and to test and implement devices that would decrease 

entrainment if significant entrainment is documented, and reduce the potential project-related mortality of 

fish in Lake Elsinore. The co-applicants propose to adhere to the NMFS’ design criteria for salmonids in 

designing and installing the intake fish screen. Lake Elsinore contains resident fish such as carp, 

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threadfin shad, bass and crappie, and the Joint Watershed Authority intends to stock largemouth bass, 

black crappie, Sacramento perch, and bluegill. Screen design criteria for these resident species have not 

been studied, however, assuming that NMFS approach velocity criteria of 0.8 feet per second were used 

(fish longer than 2.36 inches), the screens would need to be quite large in relation to the tailrace tunnels, 

and are likely not feasible for the Lake Elsinore Project. Without screens, the co-applicants state the 

approach velocity for the intakes will range from 1.5 to 1.8 cfs and entrainment would occur. 

We estimate that the co-applicants’ annual cost to design and install fish screens would be 

between $4 and $15 million for each tailrace tunnel, based on cost information provided by Washington 

DFW (2005). Assuming costs near the low end of the range and adding $10,000 per year for O&M 

results in an annual cost of $1,138,800. We estimate the cost of additional consultation with the agencies 

would add about $1,400 annually. 

Besides screening, other measures to provide entrainment could be considered. However, the 

costs of implementation of other behavioral devices cannot be estimated at this time, as it is not known 

which species might need to be targeted, such devices are highly dependent upon site-specific 

characteristics, and are as yet highly experimental and costly. 

As discussed in section 3.3.3, Fisheries Resources, without more information on the exact 

location, distance from shore, depth and orientation of the intake/outlet structure to the surface and shore 

we can only generalize the potential impacts to the Lake Elsinore fishery from entrainment. If the intake 

structure were to be placed on the shoreline where juvenile fish would encounter the intake while foraging 

or cruising, the likelihood for entrainment is higher than if the structure were placed farther away from 

shore where juvenile fish are less likely to be found. Also, we note that many of the sport fish in the lake 

will continue to originate from stocking efforts, and most will be large enough to avoid entrainment, so 

that project effects on adult stocks is likely to be small. In addition, unlike river systems, the intake/outlet 

structure area is small in relation to the overall size of the lake, and fish would need to actively swim into 

the area in order to be vulnerable to entrainment. Therefore the likelihood of significant impacts from 

entrainment is low. 

The relatively high costs and technical challenges of installing intake screens and/or experimental 

behavioral devices, as well as the changing nature of the fish populations in the lake due to efforts by the 

Joint Watershed Authority, make it difficult to assess the impact of the pump storage project would have 

on Lake Elsinore fish populations over the life of the license. Measures described by the Fisheries 

Management Plan developed by the Joint Watershed Authority seek to change the existing population 

structure and fish populations in the lake over a 20-year planning horizon as a result of bio-manipulation 

techniques, stocking activities, and habitat enhancement measures. As a result of these non-projectrelated activities the species of fish present in the lake subject to entrainment over time would likely 

change. Therefore, in lieu of physical fish barriers or screens, the staff alternative includes provisions for 

monitoring the intakes for entrainment for a period of 1 year after the project is put into operation, and 

again once every 5 years as recommended by the State Water Board. Such monitoring would provide 

information on the level of project impacts from entrainment over time. We recommend the co-applicants 

provide the monitoring results to and consult with CDFG, FWS, the State Water Board, and the Joint 

Watershed Authority to assess and, based on monitoring results, develop measures to mitigate for project 

impacts to the existing fishery. A report describing the results of the entrainment study and recommended 

measures to mitigate for any project impacts on the fishery in Lake Elsinore should be submitted to the 

Commission for approval. Measures to be implemented could range from making improvements to 

nearshore habitat including the establishment of aquatic and emergent vegetation, placement of log cribs 

and/or brush structures, placing spawning gravels where appropriate and providing spawning benches for 

bass as described in the Joint Watershed Authority Fisheries Management Plan. Coordinating activities 

with the Joint Water Authority and CDFG would help to ensure that activities are consistent with local 

and regional efforts to improve the sport fishery in Lake Elsinore. 

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We estimate that monitoring sports fish for entrainment and mortality once every 5 years as 

recommended by staff would cost about $9,300. We estimate that the development and implementation 

of a plan to mitigate the effects of entrainment, including measures consistent with the Joint Watershed 

Authority Fisheries Management Plan, would be $33,800 annually.

5.2.6 Terrestrial Resources 

Special Status Plants and Animals 

The co-applicants propose to employ a construction monitor to assist in identifying measures to 

protect native plants and wildlife, starting with pre-design conferencing and continuing through 

completion of the project. Interior’s recommendation 10(a)-1 would provide specifically for consultation 

with FWS during project design to identify measures that may be needed to protect fish and wildlife. 

Implementation of USFS revised preliminary 4(e) condition nos. 29 and 30 would continue these benefits 

to terrestrial resources through the term of the license by providing for annual employee awareness 

training, annual review of species’ status, consultation with USFS on the need for new surveys, and 

implementation of protective measures, if needed. 

The staff alternative includes pre-construction surveys for special status plants and animals in 

areas that have not been covered yet or that have not been thoroughly covered during previous surveys. 

These surveys should also cover Multi-Species HCP narrow endemics, riverine/riparian, and Criteria Area 

Study species, to allow Riverside County to evaluate project consistency with this plan. The measures 

identified above would provide adequate protection for special status plants and animals, including 

federally listed species, from project design through any new license period. These actions would be 

consistent with Interior’s request for consultation with FWS in designing measures to protect fish and 

wildlife, with Interior’s and Riverside County’s recommendations for an analysis of consistency of the 

project with the Multi-Species HCP. 

Interior recommends that the co-applicants immediately halt project construction or operation if 

situations arise where fish or wildlife are being harmed or endangered, but the recommendation does not 

define what would constitute such an emergency or specify methods for determining whether harm or 

endangerment are occurring. This concern would be appropriately addressed, under either alternative, in 

the construction monitoring plan described above. 

We estimate that the annual cost of the staff alternative measures for monitoring special status 

plants and animals would be about $14,100 for pre-construction surveys; $6,200 for annual reviews of 

species status; and $11,400 annually for employee awareness training, or about $31,700 annually for all 

three measures. 

Noxious Weeds and Exotic Plants 

The co-applicants propose to design and implement an integrated pest management plan to 

prevent the introduction of weeds during construction and to control any populations of weeds that are 

identified near construction sites during project implementation. USFS revised preliminary 4(e) condition 

no. 33 is very similar, specifying that the co-applicants should consult with the USFS to develop and 

implement a plan to monitor and control noxious weeds and non-native invasive species, but the USFS 

specifies this plan should be continued through any license period. USFS also indicates that the 

vegetation and invasive weed management plan should be consistent with guidance provided in the 

Cleveland National Forest Land Management Plan, including consulting with USFS to design and 

conduct an invasive non-native plant and noxious weed risk assessment, using weed lists that are current 

at the time of survey (USFS, 2005b). Implementation of USFS revised preliminary 4(e) condition no. 29, 

which provides for annual employee awareness training, would apply to noxious weeds and invasive nonnative plants, as well as to special status plants, as described above. Section 3.3.4.2, Noxious Weeds and 

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Exotic Plants, provides information about the minimum requirements of USFS revised preliminary 4(e) 

condition no. 29. 

Although the co-applicants may not propose to construct any new project features during the 

license period, routine project maintenance could cause ground disturbance at project facilities, and 

project-related traffic would pose a risk of introducing and spreading weeds. Public use of any access 

roads would have an especially high potential for adverse effects because it would likely be difficult to 

control. Implementation of a noxious weed management plan throughout the term of any new license for 

both USFS and non-USFS lands within the project boundary would reduce these risks and help to protect 

native plant communities and wildlife habitat values. This approach would minimize planning costs and 

would provide coverage for weeds and invasive exotic plants throughout the project area, as a whole. 

We estimate the annual cost of developing and implementing the co-applicants’ noxious weed 

control plan would be $14,100. We estimate the additional annual cost of developing and implementing 

the plan under the staff alternative would be $22,800. 

Habitat Mitigation 

The co-applicants propose to provide mitigation for the loss of high-value habitats at a ratio of 2:1 

for oak woodlands and 1:1 for coastal sage scrub. The co-applicants do not propose mitigation for 

habitats, such as chamise chaparral and non-native grassland, because they are abundant in the project 

area. The co-applicants propose to mitigate wetland and riparian habitat effects. They would conduct 

formal wetland delineations when the final location of each project feature has been determined, and then 

prepare a habitat mitigation management plan for approval by the Corps, CDFG, and the USFS. We 

estimate the annual cost for the co-applicants' plan would be $15,200. 

Interior recommends that the co-applicants evaluate consistency of the project with the existing 

Multi-Species HCP and Stephens’ Kangaroo Rat HCP, and with the North County Multi-Species HCP, 

which is under development. Interior recommends the co-applicants conduct an in-depth equivalency 

analysis to determine adequate mitigation ratios for effects that may occur within the Multi-Species HCP 

area. Interior indicates that in these areas the minimum ratio for mitigation would be 1:1. Riverside 

County also recommends an evaluation of consistency with the Multi-Species HCP. 

The USFS revised preliminary condition no. 38 species a minimum mitigation ratio would be 1:1 

for riparian oak woodland, coastal sage scrub, and habitats that are sensitive or support listed species, as 

well as the development of a habitat mitigation plan. 

The staff alternative includes mitigation at a minimum ratio of 1:1 for oak woodlands and for 

coastal sage scrub and an equivalency analysis as specified by USFS and recommended by Interior. 

Although chamise chaparral and non-native grasslands vegetation cover types are currently abundant in 

the project area and in southern California, they provide habitat for native plants and wildlife, including 

many special status species. They are undergoing rapid development as a result of human population 

growth. We recommend replacing them at a 1:1 mitigation ratio, to reduce the project’s contribution to 

cumulative habitat loss. The staff alternative’s mitigation ratio would be consistent with Interior and 

USFS recommendations in terms of compensation ratios. Under the staff alternative the co-applicants 

would conduct formal wetland delineations when the location of each project feature has been 

determined. The co-applicants would also consult with the Corps regarding formal delineation of effects 

on Lake Elsinore. When the delineations are complete, the co-applicants would consult with the agencies 

to develop and implement a habitat mitigation and management plan. The habitat mitigation management 

plan would focus to the extent possible on replacing wetland acreage, functions, and values in-kind and 

on site. Where this is not possible, habitats associated with Lake Elsinore would provide a range of 

opportunities for wetland enhancement. 

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In developing cost estimates for habitat mitigation of project effects that occur on non-National 

Forest System lands under any alternative, we have assumed the co-applicants would acquire (in fee title 

or via conservation easements) private lands that are degraded or under threat of development, and 

transfer those lands into reserves that could be managed over the long-term by a non-governmental 

organization or public land trust. This approach would ensure the protection and management of large 

blocks of land and habitat linkages, would offer greater benefits to wildlife, and could be managed more 

economically than small, scattered parcels in individual ownership. The USFS revised preliminary 4(e) 

condition no. 38 specifies that mitigation should occur in the project area; otherwise, the highest priorities 

would be the Elsinore “Place,” the Trabuco Ranger District, or the Cleveland National Forest. Thus, 

mitigation for project effects that occur on National Forest System lands may focus on private inholdings. 

We estimate that the capital cost of these measures at Decker Canyon for habitat mitigation under 

the staff alternative would total $3,212,500 with an annual cost of $322, 300 including $4,200 for O&M, 

as compared to the co-applicants’ Morrell Canyon proposal with an estimated capital cost of $2,060,000 

and annual cost of $204,100, resulting in an overall annual cost increase of $118,200. 

Avian Protection Plan 

The co-applicants propose to design the transmission line features to be consistent with guidelines 

developed by APLIC et al. (1996). USFS revised preliminary 4(e) condition no. 34 specifies this 

approach, also, and specifies marking the power lines if they are adjacent to Lake Elsinore or in a flyway 

where bird strikes may occur. In section 3.3.4.2, Environmental Consequences in Terrestrial Resources, 

we conclude that there is moderate risk of avian collision along several segments of both the co-applicants 

and staff alternative transmission alignments. The co-applicants should make use of Avian Power Line 

Interaction Committee’s publications, including Suggested Practices for Raptor Protection on Power 

Lines: The State of the Art in 1996 and Mitigating Bird Collisions with Power Lines: The State of the Art 

in 1994. We note that APLIC and FWS (2005) recently completed new guidelines for the development of 

avian protection plans. These guidelines would assist the co-applicants with initial design and alignment 

of the transmission line and in design of a long-term plan for monitoring. A pre-construction evaluation 

of the transmission line design and alignment would be needed to identify high-risk crossings, where 

markers or bird diverters could be used to reduce the risk of bird collisions with the transmission line. A 

long-term plan for monitoring and managing risks, based on recent recommendations developed by 

APLIC and FWS (2005), could be used to track the effectiveness of measures that are implemented to 

protect birds. Results of monitoring could be used to identify problem spans or poles and allow for 

retrofitting where needed. The cost of the staff alternative measure to develop the avian protection plan 

would be $20,000, or $2,800 annually, the same cost as estimated by the co-applicants. The additional 

annual cost of implementing the plan over the term of the license under the staff alternative would be 

about $20,000. 

Lake Elsinore Monitoring and Remediation Plan 

The co-applicants do not propose any measures to address potential project-related effects to 

nesting shorebirds, waterfowl, or other birds at Lake Elsinore. Under the proposed operations, Lake 

Elsinore would fluctuate about 1 foot daily and about 1.7 feet weekly. Interior recommends that the coapplicants consult with FWS and CDFG to develop a plan to eliminate or reduce effects on nesting 

shorebirds that might be affected by water surface fluctuations. The plan would include monitoring to 

allow early detection of effects, immediate steps to remedy effects, timing and performance criteria, and 

annual reporting to FWS and CDFG. In section 3.3.4.2, Environmental Consequences, Terrestrial 

Resources, we conclude that habitat along the Lake Elsinore shoreline is generally not suitable for nesting 

waterfowl, although City of Lake Elsinore staff report that black-necked stilts, avocets, and killdeer 

(ground-nesters that use scrapes in bare soils or sparsely vegetated areas) do nest in undisturbed areas 

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around the lake. With implementation of the Lake Elsinore Stabilization and Enhancement Project, yearto-year water-level fluctuations would be reduced and Lake Elsinore would no longer dry up in drought 

years. Under these circumstances, additional riparian vegetation, such as cattails, tule, and willows may 

be able to establish along the shoreline. Improvements in riparian habitat could increase its suitability for 

nesting shorebirds, waterfowl, and other birds. For these reasons, the staff alternative would incorporate 

Interior’s recommendation, and would further recommend that the co-applicants consult with the resource 

management agencies and other interested parties (FWS, CDFG, Riverside County, City of Lake 

Elsinore) to develop and implement the plan. We estimate that the initial capital cost to develop the staff 

alternative plan would be $20,000 and the cost of implementing the plan would be $20,000 annually, 

resulting in an overall annual cost of $22,800. 

5.2.7 Threatened and Endangered Species 

As discussed in section 3.3.5.2, Threatened and Endangered Species), several federally listed 

species may occur in the project area. MBA conducted focused surveys for listed plants and animals 

between 2001 and 2006, and found no occurrences83. However, MBA’s surveys did not cover all areas 

that would be affected by project construction, primarily because transmission alignments have been 

modified since the surveys were conducted, and the locations of many project features (e.g., access roads, 

helicopter fly yards, overhead/underground transition stations, pulling and tensioning stations) have not 

yet been determined. Some areas were excluded from survey due to private ownership, difficult access, 

or impenetrable vegetation. Thus, we have no evidence to support a conclusion that the project would not 

adversely affect any listed species that may be present. As discussed in section 5.6.4 (Endangered 

Species Act), we therefore find that the project may adversely affect San Diego thornmint, San Diego 

button-celery, spreading navarretia, Nevin’s barberry, Munz’s onion, slender-horned spineflower, San 

Diego ambrosia, California Orcutt grass, thread-leaved brodiaea, San Jacinto Valley crownscale, Quino 

checkerspot butterfly, arroyo toad, southwestern willow flycatcher, least Bell’s vireo, coastal California 

gnatcatcher, and Stephens’ kangaroo rat. Construction of some project features would occur within 

designated critical habitat for Quino checkerspot butterfly, proposed critical habitat for coastal California 

gnatcatcher, and a Core Reserve for the Stephens’ kangaroo rat. Construction would also affect suitable 

habitat for these species, outside designated areas. 

Operation of the project may also adversely affect listed species. Although temporary access 

roads would be obliterated, it is difficult to prevent OHV use, once a road has been cleared. OHV use 

directly affects soils and vegetation, promotes the introduction and spread of noxious weeds and invasive 

non-native plants, increases the risk of wildfire, and causes noise disturbance. Helicopter access for 

regular maintenance of the transmission line would also cause noise disturbance, but effects would be 

short-term and local. 

To mitigate for project effects on listed species, the co-applicants propose to pay the $500-peracre fee required within the Stephens’ Kangaroo Rat Fee Assessment Area. Interior 10(j)-3 recommends 

a minimum of 1:1 mitigation for any habitat impacts that occur inside the Core Reserve for this species. 

We estimate that construction would convert about 38.25 acres of Stephens’ kangaroo rat habitat to 

project use. The staff alternative includes this acreage as part of the recommended habitat mitigation 

described above (section 5.2.6, Habitat Mitigation). 

 

83 MBA did not conduct surveys for bald eagles, because they are rarely present in the project area. 

Rather than surveying for Stephens’ kangaroo rat, the co-applicants elected to assume presence and 

provide mitigation. MBA observed Munz’s onion “adjacent to the project right-of-way” at one 

location at the northern end of the transmission alignment. Although not observed during MBA’s 

surveys, the Forest Service has records of coastal California gnatcatcher in the vicinity of the north 

end of the transmission alignment. 

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Interior’s 10(a) recommendation no. 1 calls for the co-applicants to consult with FWS regarding 

protection, mitigation, and enhancement measures for fish and wildlife, as designs for the LEAPS Project 

are developed. Under the staff alternative, we recommend the co-applicants consult with FWS (and the 

USFS, on National Forest System lands) to design and conduct pre-construction surveys in areas that 

have not already been thoroughly covered; prepare detailed survey reports and maps for FWS (and the 

USFS) review and comment; and use this information to design and locate project features to avoid or 

minimize adverse effects on listed species and their habitat. We are recommending that if listed species 

are present, the co-applicants consult with the agencies to develop and implement a plan for annual 

consultation and implementation of protective measures (e.g., maintenance timing restrictions) to 

continue through any new license period. At a minimum, the plan should identify BMPs to be 

implemented during construction and operation, and provide mechanisms for monitoring, reporting, and 

adaptive management. We are also recommending the co-applicants develop road management and 

vegetation management plans, which should also be protective of listed species, if any are present. 

We estimate the cost of the staff measure to consult with FWS would be $3,400 annually. We 

estimate the annual cost of the Stephens’ kangaroo rat fee for the co-applicants’ proposal (38.25 acres) 

would be $2,700 

5.2.8 Recreational Resources 

Hang Gliding 

The co-applicants propose to place the transmission lines underground in the vicinity of the USFS 

permitted hang gliding launch areas. The staff alternative transmission alignment also would include an 

underground segment in this area. Lake Elsinore is a very popular location for hang gliding. The site 

possesses unique atmospheric conditions that create this opportunity and the site has become one of the 

best locations for this activity in the world. Both alignments would avoid placing transmission lines 

between the most popular launch sites and the informal landing site just west of the proposed Ortega Oaks 

powerhouse site and would allow for the continuation of world-class hang gliding and parasailing 

opportunities in the Lake Elsinore region. 

We estimate that the additional cost associated with burying the transmission line underground 

for 4.1 miles in the vicinity of the USFS permitted hang gliding launch sites would be $48,999,800 or 

$6,913,800 annually. 

Developed Recreational Facilities at the Upper Reservoir 

It is not the intent of the co-applicants to provide new water-based recreational activities at the 

upper reservoir. The focus during construction would be to ensure the safe use of existing roads, trails, 

and nearby recreational areas during construction. Following construction, the co-applicants would install 

a fence around the perimeter of the upper reservoir to prevent public access. The co-applicants’ would 

install an ancillary structure, at a USFS-site off Ortega Highway, provide interpretive signage, and 

provide a cleared parcel at the upper reservoir or at another site to the USFS for future recreational 

development. USFS revised preliminary 4(e) condition no. 27 specifies that the co-applicants develop 

and implement a recreational development facility plan for a day-use recreational facility at the 

construction laydown area used to construct the upper reservoir. The co-applicants filed an alternative 

4(e) condition that would broaden the USFS revised preliminary 4(e) conditions no. 27 to allow the coapplicants to provide an another site near the upper reservoir. 

We conclude in section 3.3.6.2 that developing a recreational facility on the site used for the 

construction laydown area or another site near the upper reservoir would accommodate visitors who are 

coming to the area, visiting the upper reservoir, or viewing Lake Elsinore. Providing a formal 

recreational area would reduce pollution by providing visitors with facilities for disposing of trash and 

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human waste, protecting vegetation and soil by controlling the locations where vehicles may travel and 

park, and reducing the potential for fires by providing cleared areas for parking. Because day-use 

facilities do not currently exist in this area, this facility, along with an ancillary structure such as a visitor 

center, and signage, would meet the needs of visitors who are coming to the upper reservoir area by 

providing a few basic conveniences while protecting natural resources from the effects of wide-spread 

dispersed recreational use. 

Fencing the upper reservoir would result in an annual cost of $12,600. We estimate that the 

annual cost of the co-applicants’ proposed ancillary structure (visitor center) and signage would be $7,000 

and $1,200, respectively. We estimate the cost of developing and implementing the staff alternative plan 

for a recreational facility at the upper reservoir would have a capital cost of $144,200 and annual costs of 

$4,000, resulting in an overall annual cost of $20,100 beyond what the co-applicants propose. 

Developed Recreational Facilities at the Powerhouse 

The co-applicants propose to provide cleared lands and funding for the construction of 

recreational facilities at the powerhouse location. The co-applicants would consult with the USFS and 

local agencies to determine the type of community recreational facility to provide at the selected 

powerhouse. At the proposed Santa Rosa powerhouse site, the co-applicants would also provide a 

botanical garden and powerhouse tours to promote awareness of water conservation and use of droughtresistance plant species. In section 3.3.6.2, we conclude that the co-applicants’ proposed measures would 

provide recreational opportunities that currently do not exist in these locations. Under both the coapplicants’ proposal and the staff alternative, the existing informal hang gliding landing area at the Ortega 

Oaks location would remain available and any future development at that subject would be subject to 

local plans. Because the staff alternative would place the powerhouse at the Santa Rosa site (as opposed 

to the Ortega Oaks location) and would bury the transmission lines in the vicinity of the launching sites 

and the connection to the powerhouse, we do not include any provision for a formal hang gliding landing 

area our recommended recreation plan. 

The co-applicants would not provide funding for the O&M of the facilities unless they remain in 

public ownership and are located on National Forest System lands. The co-applicants are willing to retain 

ownership and be responsible for O&M subject to a determination whether such ownership and operation 

would be authorized under the Elsinore Valley MWD’s existing special district authority for 

developments not in public ownership and not located on National Forest System lands. We conclude in 

section 3.3.7.2 that relying on funding that may or not be available to local agencies would not provide 

certainty that the facilities would be properly maintained through the period of the license. The staff 

alternative includes a recreation plan for the facility development that includes financial commitments to 

provide for O&M funding in the event that intended sources of O&M funding are either insufficient or 

unavailable. 

We estimate the cost of providing public tours at the powerhouse would be $18,700. We estimate 

that the capital cost of the co-applicants' proposed recreational facilities at the Santa Rosa powerhouse site 

would be $5,610,800 (including land acquisition costs) and the annual cost would be $678,500. We 

estimate that the additional cost of the staff alternative measure to provide O&M funds for this 

recreational facility would be about $125,400 annually. 

Recreational Angling at Lake Elsinore 

The Joint Water Authority's Program Environmental Impact Report includes a detailed Fish 

Management Plan with objectives to improve the sport fishery in Lake Elsinore. The co-applicants’ 

proposal to provide funds in support of the annual fish stocking program recommended in the Joint 

Watershed Authority’s Fish Management Plan would enhance recreational fisheries in Lake Elsinore. We 

conclude in section 3.3.3.2 that the stocking of predators to carp and threadfin shad, consistent with the 

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Fish Management Plan, would reduce populations of those species and allow more game fish to survive, 

enhancing recreational angling opportunities. We estimate the annual cost for the co-applicants’ proposed 

stocking program would be $21,400. 

5.2.9 Land Use and Aesthetics 

Road and Traffic Management 

The construction and operation of the proposed project facilities and about 32 miles of 

transmission lines across federal and private properties and access to project facilities would require the 

construction of an estimated 10.8 miles of temporary access roads and 1.0 mile of permanent access 

roads, the exact location of which are not identified at the current level of planning. We anticipate that 

about 9.3 miles of temporary roads to access the staff alternative’s mid-slope transmission alignment 

would be constructed in part on National Forest System lands, and would also intersect with numerous 

existing roads on non-National Forest System lands. 

USFS revised preliminary 4(e) condition no. 26 specifies the development and implementation of 

a road and traffic management plan for all USFS roads and unclassified roads needed for project access 

that would be constructed on National Forest System lands. The plan, to be developed in consultation 

with the USFS, would identify and map the roads, describe their purpose and use, explain maintenance 

levels and responsibilities show the locations and status of any gates or barricades, demonstrate 

authorization for their use, and assess their condition. The plan would specify maintenance and 

management standards that would provide for traffic safety and minimize erosion and damage to natural 

resources. 

We conclude in section 3.3.7.2 that a plan would be needed to ensure the proper use and 

maintenance of both temporary and permanent roads necessary to access the project facilities. The staff 

alternative includes a provision to specify the exact segments of roads that would serve the project and the 

permanent roads that would need to be included in the project boundary. 

Public access (and OHVs, in particular) would create the potential for trampling and soil 

compaction, dumping, vandalism, noise disturbance, harassment, poaching, collision, wildfire, and 

introduction of weeds. For this reason, under the staff alternative, the land and road management plan 

would include methods for closing and obliterating temporary roads following construction; minimizing 

adverse effects of project-related use; identifying areas of specific concern; providing for regular patrol 

and enforcement to ensure that closed roads area not being used by the public; and provide for long-term 

monitoring, reporting, and changes to the plan, as needed. The staff alternative includes a road 

management plan for non-National Forest System lands that would address the same issues. 

The co-applicants propose to achieve a balance of excavated materials and fill at the entire project 

site and propose to haul up to 776,000 cubic yards of fill along Ortega Highway and South Main Divide 

Road to the upper reservoir site. In section 3.3.7.2, we conclude that hauling this volume of fill material 

on Ortega Oaks Highway and South Main Divide Road to the upper reservoir site would significantly 

affect the flow of traffic on this busy crossroad between Lake Elsinore the California coast. Instead of 

overtaxing this road, the staff alternative calls for the co-applicants to excavate additional depth at the 

Decker Canyon upper reservoir site to provide the fill deficit for the dam construction. We estimate that 

about 10 additional feet would need to be excavated to provide sufficient fill for the dam. Achieving the 

balance of excavation and fill entirely at the upper reservoir site would greatly reduce the construction 

truck traffic on Ortega Highway. 

The co-applicants also propose several specific measures to improve traffic flow on Grand 

Avenue and Ortega Highway during construction and to prepare and implement traffic management and 

control plans. The staff alternative would specify that the co-applicants develop, with County of 

Riverside Transportation Department consultation, and implement a road and traffic management plan for 

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non-USFS roads that: (1) details plans to manage construction at road crossings and along access roads; 

(2) provides a schedule for the volume and timing of construction traffic; (3) describes methods for 

closing and obliterating temporary roads following construction; (4) minimizes adverse impacts of 

project-related use; (5) identifies areas of specific concern; and (6) provides for monitoring, reporting, and 

changes to the plan during the 4.5-year construction period. 

We estimate that the annual cost associated with the staff alternative additional excavation at 

Decker Canyon to achieve the excavation and fill balance at the upper reservoir site would be $732,800. 

The initial cost of developing co-applicants’ traffic plans would be $100,000 with an annual cost of 

$24,100. The staff alternative traffic plans would add $20,000 initial costs and $2,800 to the annual costs.

Sediment Sampling in Lake Elsinore 

Excavations in Lake Elsinore to construct the intake/outlet structure would disturb lakebed 

sediments that could contain toxins. Water quality testing in Lake Elsinore did not include testing 

lakebed sediment for toxicity. In section 3.3.7.2, we conclude that excavated material from the lakebed 

should be disposed of off site. The toxicity of these sediments is unknown. Toxic materials require 

special handling and disposal. The staff alternative would specify that the co-applicants develop a plan to 

sample lakebed sediments for toxicity prior to construction and, if toxins are identified, for proper 

handling and disposal. We estimate that the annual cost for the staff alternative sediment sampling plan 

would be $7,100 and would be necessary to protect the public from exposure to potentially toxic 

materials. 

Visual Resources Plan 

Construction of the proposed project would introduce new visual elements to the landscape both 

during and following construction. The co-applicants propose to develop and implement a visual 

resources management plan. The co-applicants’ proposed plan would be similar to the scenery 

conservation plan specified in the USFS revised preliminary 4(e) condition 37. We conclude that such a 

plan prepared in consultation with the USFS, under either alternative, would help to ensure that the design 

and materials proposed for project facilities on USFS-lands and any subsequent changes to the project 

facilities are compatible with the USFS’ Land Management Plan's High Scenic Integrity Objectives and 

related standards for new construction in National Forests. We estimate that the annual cost for the coapplicants’ proposed visual resources management plan would be $2,800. 

Project Boundary 

The co-applicants do not include Lake Elsinore within the proposed project boundary as defined 

in the exhibit G boundary maps for the project. Lake Elsinore is an integral part of the pumped storage 

project, serving as the lower reservoir. Under either alternative, inclusion of Lake Elsinore within the 

project boundary would provide for a complete unit of development. At the conceptual level of design, 

the co-applicants have not identified the location of temporary access roads for construction or permanent 

access roads for project operations. Access roads to project facilities, whether public, private, or USFSowned, would need to be included in the project boundary, under either alternative, when the final exhibit 

G drawings are filed with the Commission. We assume this cost is included in the co-applicants’ 

$12,000,000 allocated to relicensing. 

5.2.10 Cultural Resources 

Construction at the project sites has the potential to destroy or disturb historic properties. The coapplicants would consult with the USFS or SHPO prior to any ground-disturbing activities and would 

implement a stop-work procedure if unanticipated discoveries occur during construction. Given that 

known sites occur near project construction sites, we assume that over a 4.5-year construction period, one 

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or more unanticipated discoveries would occur. The draft HPMP filed with the Commission in April 

2005, includes measures to: (1) complete pre-construction archaeological surveys in the APE; (2) 

determine the need for intensive surveys; (3) monitor historic properties during construction; (4) appoint a 

tribal liaison; (5) study the potential effects of ground acceleration on historic buildings; (6) develop a 

program to monitor archaeological sites for 5 years; and (7) develop a public interpretative program. The 

co-applicants also would conduct limited paleontological studies at sensitive locations during construction 

and prepare any fossil remains for curation by a local museum. In section 3.3.9.2, we conclude that coapplicants’ proposal, as reflected in the draft HPMP, and including modifications under the staff 

alternative, would mitigate or avoid adverse effects on historic properties. These measures would address 

the site-specific needs to take into account historic properties during the construction and operation of the 

project under either alternative. 

The staff alternative would specify that the co-applicants develop and implement a final HPMP 

that incorporates provisions to avoid or mitigate effects to known and as yet unknown historic properties. 

The plan would be developed in consultation with the SHPO, Tribes, the BIA, and the USFS, and other 

entities as appropriate. USFS revised preliminary condition no. 28 specifies that the HPMP accurately 

define the APE, including the effects of implementing the Section 4(e) condition. As discussed in section 

3.3.9.2, the co-applicants’ proposed HPMP would address the procedures and substantive requirements of 

Section 106 of the National Historic Preservation Act. The Commission would execute a Programmatic 

Agreement providing for the filing of the final revised HPMP with 1 year after license. Shortly thereafter, 

the final HPMP would then be implemented. 

We estimate that the costs for the co-applicants’ proposed consultation would be $1,400, the 

annual cost for addressing unanticipated discoveries during construction would be $16,900, the annual 

costs for implementing the co-applicants draft HPMP would be $59,300, and the paleontological studies 

would cost $14,100. We estimate the additional annual cost of filing the final HPMP under the staff 

alternative would be $2,800. 

5.3 FISH AND WILDLIFE AGENCY RECOMMENDATIONS 

5.3.1 Recommendations Pursuant to Section 10(j) of the FPA 

Under Section 10(j) of the FPA, each hydroelectric license issued by the Commission would 

include conditions based on recommendations provided by federal and state fish and wildlife agencies for 

the protection, mitigation, and enhancement of fish and wildlife resources affected by the project. 

Section 10(j) of the FPA states that whenever the Commission finds that any fish and wildlife 

agency recommendations is inconsistent with the purposes and requirement of the FPA or other 

applicable law, the Commission and the agency shall attempt to resolve any such inconsistency, giving 

due weight to the recommendation, expertise, and statutory responsibilities of such agency. 

By letter dated April 22, 2005, Interior provided three fish and wildlife recommendations. 

Table 56 lists Interior’s recommendations and presents Commission staff’s conclusion as to whether each 

recommendation is within the scope of Section 10(j), an estimate of the annual cost of each 

recommendation, and the decision about whether or not to recommend adopting each recommendation as 

part of the staff alternative. When a recommendation is not adopted, we provide a rationale. 

Recommendations that Commission staff consider outside the scope of Section 10(j) have been 

considered under Section 10(a) of the FPA and are addressed in the specific resource sections of this 

document. The staff alternative includes all current recommendations that Commission staff found to be 

within the scope of Section 10(j). 

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Table 56. Fish and wildlife agency Section 10(j) recommendations. (Source: Staff) 

No. Recommendation Agency 

Within the 

Scope of 

10(j)? 

Annualized 

Cost 

Commission Staff 

Recommending? 

1. Lake Elsinore monitoring and 

remediation plan to reduce or eliminate 

impacts to nesting shorebirds 

Interior Yes $22,800 Yes 

2. San Juan Creek drainage monitoring 

and remediation plan to eliminate or 

reduce release of water and non-native 

species from the upper reservoir into 

San Juan Creek 

Interior Yes $74,000 Yes 

3. Consistency with existing and proposed 

HCPs 

Interior No, not a 

specific 

measure to 

protect fish 

and wildlife 

$0 No 

Note: HCP – Habitat Conservation Plan 

5.3.2 Recommendations Pursuant to Section 10(a)(1) of the FPA 

Our recommendation not to adopt Interior 10(j) no. 3 is based on our finding that we could not 

evaluate the environmental effects that would result from recommending consistency of the LEAPS 

Project with HCPs that have not yet been developed. Although we do not adopt Interior 10(j) no. 3, we 

anticipate that our recommendations for specific measures for terrestrial resource protection and 

mitigation will meet Interior’s objectives regarding consistency of the LEAPS Project with existing 

HCPs. In some cases (e.g., minimum habitat compensation ratios), our recommendations may be more 

stringent than those that would be required under the Multi-Species HCP, because the Commission’s view 

of acceptable resource trade-offs may differ from the views of the Multi-Species HCP signatories. 

In addition to it's section 10(j) recommendations, Interior filed 3 recommendations under section 

10(a) for (1) consultation with the FWS on completion of project plans and designs for measures to 

protect, mitigate damages to, and enhance fish and wildlife, (2) notification to FWS and remedial actions 

under emergency or special conditions arise where fish or wildlife are being killed, harmed, or 

endangered, and (3) a request for a specific ESA reopener in any license issued for the proposed project. 

As discussed in section 5.2.6, the staff alternative measures would provide adequate protection for special 

status plants and animals, including federally listed species, starting at project design and extending 

through the term of any license issued for the project. 

5.4 CONSISTENCY WITH COMPREHENSIVE AND OTHER RESOURCE PLANS 

Section 10(a)(2) of the FPA requires the Commission to consider the extent to which a project is 

consistent with federal and state comprehensive plans for improving, developing, and conserving 

waterways affected by the project. Under section 10(a)(2), federal and state agencies filed comprehensive 

plans that address various resources in California. Fourteen of these plans address resources relevant to 

the LEAPS Project: 

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California Advisory Committee on Salmon and Steelhead Trout. 1988. Restoring the balance. 1988 

annual report. Sausalito, California. 84 pp. 

California Department of Fish and Game. 1996. Steelhead restoration and management plan for 

California. February 1996. 234 pp. 

California Department of Parks and Recreation. 1998. Public Opinions and Attitudes on Outdoor 

Recreation in California – 1997. March 1998. 72 pp. and appendices. 

California Department of Parks and Recreation. 1988. California Outdoor Recreation Plan. Sacramento, 

California. June 1988. 223 pp. 

California Department of Parks and Recreation. 1994. California Outdoor Recreation Plan -1993. 

Sacramento, California. April 1994. 154 pp. and appendices. 

California Department of Water Resources. 1983. The California water plan: projected use and 

available water supplies to 2010. Bulletin 160-83. Sacramento, California. December 1983. 

268 pp. and attachments. 

California Department of Water Resources. 1994. California water plan update. Bulletin 160-93. 

Sacramento, California. October 1994. Two volumes and executive summary. 

California State Water Resources Control Board. 1975. Water quality control plan report. Sacramento, 

California. Nine volumes. 

California—The Resources Agency. Department of Parks and Recreation. 1983. Recreation needs in 

California. Sacramento, California. March 1983. 39 pp. and appendices. 

Forest Service. 1986. Cleveland National Forest land and resources management plan. Department of 

Agriculture, Corona, California. February 1986. 

State Water Resources Control Board. 1999. Water quality control plans and policies. Adopted as part 

of the State Comprehensive Plan. April 1999. Three enclosures. 

Fish and Wildlife Service. Canadian Wildlife Service. 1986. North American waterfowl management 

plan. Department of the Interior. May 1986. 19 pp. 

Fish and Wildlife Service. Undated. Fisheries USA: The recreational fisheries policy of the U.S. Fish 

and Wildlife Service. Washington, DC. 11 pp. 

National Park Service. 1982. The nationwide rivers inventory. Department of the Interior, Washington, 

DC. January 1982. 432 pp. 

5.5 RELATIONSHIP OF LICENSE PROCESS TO LAWS AND POLICIES 

5.5.1 Section 401 of the Clean Water Act—Water Quality Certification 

By letter dated March 16, 2005, the co-applicants applied to the State Water Board for Water 

Quality Certification for the LEAPS Project, pursuant to Section 401 of the Clean Water Act. On March 

1, 2006, the co-applicants withdrew and refiled individual requests for water quality certifications for both 

the LEAPS and the TE/VS Interconnect projects. The Water Quality Certification is now due on March 

1, 2007. 

5.5.2 Section 18 of the Federal Power Act—Authority to Require Fishways 

Section 18 of the FPA, 16 USC Section 811, states that the Commission shall require the 

construction, maintenance, and operation by a licensee of such fishways as the secretaries of Commerce 

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and the Interior may prescribe. By letter dated April 22, 2005, Interior reserved its authority to amend 

prescriptions. The Secretary of Commerce did not file any fishway prescriptions for this project. 

5.5.3 Section 4(e) of the Federal Power Act 

Because the proposed LEAPS Project would occupy lands of the Cleveland National Forest and 

lands administered by BLM and the DOD, the USFS, DOD, and BLM have authority to impose 

conditions under Section 4(e) of the FPA. The USFS provided preliminary license conditions for the 

LEAPS Project by letter dated April 27, 2005 and revised preliminary Section 4(e) conditions on June 23, 

2006. 

The USFS provided 25 standard USFS conditions and 10 project-specific conditions. Condition 

nos. 1 through 25 are standard conditions that would involve obtaining USFS approval on final project 

design and changes, yearly consultation with the USFS to ensure the protection and development of 

natural resources, restrictions and protective measures that should be in place, and project O&M 

procedures that would enable continued project operations to be consistent with applicable provisions of 

the Cleveland Nation Forest Land Management Plan. 

Condition nos. 26, 27, 28, 33, 34 35, and 36 pertain to development of plans for use of USFSmanaged lands (including road and traffic management, recreation facilities, heritage resources, 

vegetation and invasive weeds management, wildlife management, surface water management, and 

ground water management). Condition no. 29 pertains to project-specific consultation with the USFS 

regarding annual employee awareness training pertaining to natural resource issues of importance to the 

Cleveland National Forest. Condition no. 30 pertains to updates regarding USFS special status plants and 

wildlife, monitoring needs of existing and future special status species. Condition no. 31 pertains to an 

action plan for ground-disturbing activities that are not addressed in this EIS. Condition no.32 pertains to 

the development of detailed monitoring plans. 

5.5.4 Endangered Species Act 

Section 7 of the ESA requires federal agencies to ensure that their actions are not likely to 

jeopardize the continued existence of endangered or threatened species or result in the destruction or 

adverse modification of the critical habitat of such species. By letter dated April 22, 2005, Interior 

indicated that the federally threatened coastal California gnatcatcher and the federally endangered arroyo 

toad, Stephens’ kangaroo rat, and Munz’s onion are known to occur within the project vicinity. No 

individuals of these species were observed during surveys associated with the project. We also evaluated 

the effect of the project on other listed species that may occur in the project area (table 57). Table 57 

summarizes our determinations regarding the effect of the proposed action on these species, based on the 

analyses presented in section 3.3.5, Threatened and Endangered Species, and our recommendations as 

presented in section 5.2, Comprehensive Development and Recommended Alternative. 

Table 57. Summary of species and critical habitat findings under the staff alternative. 

Species Species Status Species Finding 

Critical Habitat 

Finding 

Southern California steelhead 

(Oncorhynchus mykiss) 

E Likely to adversely affect Not likely to adversely 

affect 

San Diego thornmint 

(Acanthomintha ilicifolia)

T Likely to adversely affect No 

effect 

No effect 

San Diego button-celery 

(Eryngium aristulatum var.

parishii) 

E Likely to adversely affect No 

effect 

No effect 

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Species Species Status Species Finding 

Critical Habitat 

Finding 

Mexican flannelbush 

(Fremontodendron mexicanum) 

E No effect No effect 

Spreading navarretia (Navarretia 

fossalis) 

T Likely to adversely affect No 

effect 

No effect 

Nevin’s barberry (Berberis nevinii) E Likely to adversely affect No 

effect 

No effect 

Munz’s onion (Allium munzii) E Likely to adversely affect No effect 

Slender-horned spine flower 

(Dodecahema leptoceras) 

E Likely to adversely affect No effect 

San Diego ambrosia (Ambrosia 

pumila) 

E Likely to adversely affect No effect 

California Orcutt grass (Orcuttia 

californica) 

E Likely to adversely affect No effect 

Thread-leaved brodiaea (Brodiaea 

filifolia) 

T Likely to adversely affect No effect 

San Jacinto Valley crownscale 

(Atriplex coronata var. notatior) 

E Likely to adversely affect No effect 

Quino checkerspot butterfly 

(Euphydryas edith quino) 

E Likely to adversely affect Likely to adversely 

affect 

Arroyo toad (Bufo californicus) E Likely to adversely affect No effect 

California red-legged frog (Rana 

aurora draytonii) 

T No effect No affect 

Southwestern willow flycatcher 

(Empidonax traillii extimus) 

E Likely to adversely affect No effect 

Least Bell’s vireo (Vireo bellii 

pusillus) 

E Likely to adversely affect No effect 

Bald eagle (Haliaeetus 

leucocephalus) 

T Not likely to adversely affect No effect 

Coastal California gnatcatcher 

(Polioptila californica) 

T Likely to adversely affect Likely to adversely 

modify proposed 

critical habitat 

Stephens’ kangaroo rat 

(Dipodomys stephensi) 

E Likely to adversely affect Likely to adversely 

affect 

The basis for our findings is summarized below. 

Southern California Steelhead 

We conclude that the construction of the LEAPS Project may affect, but would not likely 

adversely affect the southern California steelhead or steelhead habitat. Only the lower 6 or 7 miles of San 

Mateo Creek are accessible to southern steelhead trout and spawning occurs in the downstream reach 

during periods of significant precipitation. Steelhead trout have not been identified in the tributaries to 

San Mateo Creek that would be crossed by transmission lines. A combination of BMPs during 

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construction and water quality monitoring during the life of the project would reduce, but not eliminate, 

the potential risk of adverse impacts from the downstream transport of sediments. 

Mexican Flannelbush 

We conclude that the construction of the LEAPS Project would have no effect on Mexican 

flannelbush, because no suitable habitat is located at sites where project features would be constructed 

San Diego Thornmint, San Diego Button-Celery, Mexican Flannelbush, Spreading 

Navarretia, and Nevin’s Barberry 

We conclude that construction and operation of the LEAPS Project is likely to adversely affect 

San Diego thornmint, San Diego button-celery, spreading navarretia, and Nevin’s barberry. Based on a 

comparison of the known range and habitat associations of these species with the project area’s location, 

elevation, soils, and vegetation cover types, we think it is unlikely that they occur in the project area. 

However, because these plants are rare, their habitat requirements are not as well understood as many 

other native species, and it is possible that they are present. None were identified during MBA’s surveys. 

MBA’s surveys covered many, but not all, of the areas that would be disturbed by construction. For this 

reason, we recommend that the co-applicants conduct pre-construction surveys at all sites where ground 

disturbance would occur. If these species are identified, we recommend the co-applicants consult with 

FWS (and the USFS, if plants are located on National Forest System lands) to determine how project 

features could be re-sited or re-aligned to avoid impacts. Flexibility in project design and implementation 

of construction BMPs (such as those discussed in section 3.3.4.2, Vegetation) should minimize the risk of 

adverse effects during construction. To minimize the risk of adverse impacts during operation, we 

recommend the co-applicants develop and implement a threatened and endangered species management 

plan. The plan should specify protective measures, including road management and weed management, a 

monitoring program, and mechanisms for consultation, reporting and adaptive management. Such a plan 

would reduce, but would not eliminate, the potential for adverse effects during the life of the project, as a 

result of fuel management activities, road and transmission line maintenance, and unauthorized public use 

of temporary and permanent access roads. 

Munz’s Onion, Slender-horned Spine Flower, San Diego Ambrosia, California 

Orcutt Grass, Thread-leaved Brodiaea, and San Jacinto Valley Crownscale 

We conclude that construction of the LEAPS Project is likely to adversely affect Munz’s onion, 

slender-horned spine flower, San Diego ambrosia, California Orcutt grass, thread-leaved brodiaea, and 

San Jacinto Valley crownscale. Suitable habitat for these species occurs in the project area. None of 

these species were observed during MBA’s surveys. MBA’s surveys covered many, but not all, of the 

areas that would be disturbed by construction. For this reason, we recommend pre-construction surveys 

and development and implementation of a threatened and endangered species management plan, as 

described above. 

Quino Checkerspot Butterfly 

We conclude that construction of the LEAPS Project is likely to adversely affect the Quino 

checkerspot butterfly and designated critical habitat. MBA’s surveys did not indicate the presence of any 

Quino checkerspot butterflies, but about 1.75 acres of designated critical habitat for this species would be 

removed to install transmission line towers at the northernmost end of the proposed transmission 

alignment and 35 acres would be removed to build the northern substation near Lee Lake. Construction 

of three transmission towers outside designated critical habitat would remove about 0.75 acre of potential 

habitat in the same vicinity. Construction of temporary access roads could affect additional habitat. 

Vegetation management and unauthorized public use of temporary access roads, if any are constructed in 

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butterfly habitat, could adversely affect habitat quality during project operation. Implementation of 

BMPs during construction and protective measures such as weed management and road management 

would reduce, but not eliminate, the risk of adverse effects through the life of the project. 

Arroyo Toad 

We conclude that construction of the LEAPS Project is likely to adversely affect the arroyo toad, 

which is known to occur in Los Alamos Creek and Tenaja Creek, and could also occur in Temescal Wash. 

No occurrences of this species are documented at sites that would be affected by construction, and 

MBA’s surveys did not indicate the presence of any arroyo toads in the project area. However, about 

1.0 acre of potential habitat may be removed for the construction of five transmission towers where the 

proposed transmission alignment would cross these creeks. Construction of temporary access roads could 

affect additional habitat. Vegetation management and unauthorized public use of temporary access roads, 

if any are constructed in arroyo toad habitat, could adversely affect habitat quality during project 

operation. Implementation of BMPs during construction and protective measures such as weed 

management and road management plans would reduce, but not eliminate, the risk of adverse effects 

through the life of the project. 

California Red-legged Frog 

We conclude that construction of the LEAPS Project would not affect the California red-legged 

frog. Although Los Alamos Creek and Tenaja Creek could provide suitable habitat, there are no known 

occurrences in either watershed, and MBA’s surveys did not indicate the presence of this species. Only 

one population (three adult males) of California red-legged frogs is known to exist in Riverside County, 

and none are known in Orange or San Diego counties. FWS considers the potential for recovery in 

southern California to be low because there are few existing populations, habitat is generally of medium 

quality, and threats to its existence are high, due to human activities and competing land uses (FWS, 

2002). 

We conclude that construction of the project would not affect designated critical habitat. No 

designated critical habitat exists in Riverside, Orange, or San Diego counties. 

Southwestern Willow Flycatcher and Least Bell’s Vireo 

We conclude the project is likely to adversely affect the southwestern willow flycatcher and least 

Bell’s vireo. These species were not detected during surveys, but suitable habitat is present along the 

transmission line route, and construction of transmission towers could affect about 0.5 acre of riparian 

shrub at Temescal Wash and Tenaja Creek crossings. Construction of temporary access roads could 

affect additional habitat. Vegetation management and unauthorized public use of temporary access roads, 

if any are constructed in southwestern willow flycatcher or least Bell’s vireo habitat, could adversely 

affect habitat quality during project operation. Implementation of BMPs during construction and 

protective measures such as weed management and road management plans would reduce, but not 

eliminate, the risk of adverse effects through the life of the project. 

Bald Eagle 

We conclude the project may affect, but would not likely adversely affect, the bald eagle. Under 

current conditions, bald eagles are rarely seen in the project area. Construction would not remove habitat, 

alter the prey base, or increase disturbance. The presence of a transmission line would represent a very 

low level of risk, because it would be designed to minimize the risk of electrocution and collision. As 

bald eagle populations in the state and in the county increase, however, bald eagle use may be more 

frequent, and monitoring would be needed to ensure that avian/power line interactions could be identified 

and addressed without delay. 

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Coastal California Gnatcatcher 

We conclude that construction of the LEAPS Project is likely to adversely affect the coastal 

California gnatcatcher. No coastal California gnatcatchers were observed during the co-applicants’ 

surveys, but the USFS has documented occupied habitat along the northern segment of the proposed 

transmission line. Construction of transmission towers would affect about 38.5 acres of designated 

critical habitat along the northern segment of the transmission alignment and at the northern substation, 

about 1 acre nearby, and about 30.5 acres of potential habitat at the Santa Rosa powerhouse site. 

Construction of temporary access roads could affect additional habitat. Vegetation management and 

unauthorized public use of temporary access roads, if any are constructed in coastal California 

gnatcatcher habitat, could adversely affect habitat quality during project operation. Implementation of 

BMPs during construction and protective measures such as weed management and road management 

plans would reduce, but not eliminate, the risk of adverse effects through the life of the project. 

Stephens’ Kangaroo Rat 

We conclude the project is likely to adversely affect the Stephens’ kangaroo rat. The coapplicants did not conduct surveys for this species, but it is known to occur in Riverside County. 

Construction of transmission towers and the northern substation would affect about 38.5 acres of habitat 

within the Stephens’ Kangaroo Rat Fee Assessment Area or Lake Mathews-Estelle Mountain Core 

Reserve. Construction of temporary access roads could affect additional habitat. Vegetation management 

and unauthorized public use of temporary access roads, if any are constructed in Stephens’ kangaroo rat 

habitat, could adversely affect habitat quality during project operation. Implementation of BMPs during 

construction and protective measures such as weed management and road management plans would 

reduce, but not eliminate, the risk of adverse effects through the life of the project. We are also 

recommending the co-applicants provide habitat mitigation at a ratio of 1:1 for losses of chaparral and 

non-native grasslands, coastal sage scrub, and oak woodland. 

Consultation with the U.S. Fish and Wildlife Service 

By letter dated June 9, 2006, FWS concurred with our finding of “no effect” on Mexican 

flannelbush, “not likely to adversely affect” the bald eagle, and “not likely to adversely affect” California 

red-legged frog critical habitat. FWS did not discuss our findings of “likely to adversely affect” Quino 

checkerspot butterfly, coastal California gnatcatcher, and Stephens’ kangaroo rat. FWS disagreed with 

our findings of either “no effect” or “not likely to adversely affect” regarding all the other species 

discussed above, and requested additional information about the project. Table 58 shows the requests and 

our responses. 

Table 58. Information requested in FWS letter dated June 9, 2006, and staff responses. 

(Source: Staff) 

Requested Information Staff Response 

Identification of which alternative represents the 

proposed action submitted for consultation 

The staff alternative is the action submitted for consultation. 

Information about the proposed locations of access 

roads, habitat that would be affected, any survey 

results, and analysis of effects associated with road 

building, use and maintenance on federally listed 

species 

Locations of many project features have not been finalized at 

this time. We recommend the co-applicants consult with 

FWS (and the USFS, on National Forest System lands) to 

design and conduct surveys where they are needed; prepare 

detailed reports and maps for FWS (and USFS) review and 

comment; and design project features to avoid or minimize 

adverse effects on listed species. We recommend that if 

listed species are present, the co-applicants consult with the 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
5-41 

Requested Information Staff Response 

agencies to develop and implement a threatened and 

endangered species management plan. We also recommend 

development and implementation of road management and 

vegetation management plans that should be protective of 

listed species, and habitat mitigation at a minimum ratio of 

1:1 for all habitats that are converted to project use. 

Information about vegetation management 

measures, and how they would affect listed species 

Detailed information about vegetation management is not 

available at this time, but we recommend development and 

implementation of plans to manage vegetation and noxious 

and invasive weeds. 

Information about noxious weed control, and how it 

would affect listed species 

Detailed information about vegetation management is not 

available at this time, but we recommend development and 

implementation of plans to manage vegetation and noxious 

and invasive weeds. 

Information about project effects on the Stephens’ 

kangaroo rat Core Reserve lands 

This information is shown in figure 15 and discussed in 

section 3.3.5.2. The staff alternative recommends 1:1 

mitigation for impacts on chaparral and non-native 

grasslands. 

Analysis of effects on arroyo toad that could occur 

in the event of a dam failure with release of water 

into San Juan Creek, and remediation measures that 

would be implemented. 

Effects of a dam break on arroyo toads have not been studied 

in depth. We conclude the risk of a failure is small because 

the dam would be designed to comply with the 

Commission’s Engineering Guidelines for the Evaluation of 

Hydropower Projects as well as State criteria. High hazard 

dams such as those proposed for the LEAPS Project must be 

able to safely pass the probable maximum flood, and to 

withstand the maximum credible earthquake. Both the 

Commission and the State of California routinely inspect 

dams and the Commission requires a rigorous dam safety 

review during the design process and every 5 years during 

project operations. However, the staff alternative includes a 

recommendation for the co-applicants to develop and 

implement a monitoring and remediation plan for San Juan 

Creek, as discussed in section 5.2.4, Preventing Interbasin 

Water Transfers. 

5.6.5 National Historic Preservation Act 

Relicensing is considered an undertaking within section 106 of the National Historic Preservation 

Act, as amended (P.L.89-665; 16 USC 470). Section 106 requires that every federal agency “take into 

account” how each of its undertakings could affect historic properties. Historic properties are districts, 

sites, buildings, structures, TCPs, and objects significant in American history, architecture, engineering, 

and culture that are eligible for inclusion in the National Register. As the lead federal agency for issuing 

a license, the Commission is responsible for ensuring that the licensee will take all necessary steps to 

“evaluate alternatives or modifications” that “would avoid, minimize, or mitigate any adverse effects on 

historic properties” for the term of any license involving the project. The lead agency also must consult 

with the SHPO(s), as well as with other land management agencies where the undertaking may have an 

effect, and with Indian tribes who may have cultural affiliations with affected properties involving the 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
5-42 

undertaking. The overall review process involving Section 106 is administered by the Advisory Council 

on Historic Preservation, an independent federal agency. 

To meet the requirements of Section 106, the Commission will execute the Programmatic 

Agreement to take into account the effects on historic properties from the operation of the LEAPS 

Project. The terms of the Programmatic Agreement would ensure that the co-applicants would address 

and treat all historic properties identified within the project area through the HPMP. The HPMP entails 

ongoing consultation involving historic properties for the license term. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
COVER SHEET 

FEDERAL ENERGY REGULATORY COMMISSION 

FINAL ENVIRONMENTAL IMPACT STATEMENT 

FOR HYDROPOWER LICENSE 

Lake Elsinore Advanced Pumped Storage Project 

Docket No. P-11858-002 

Section 6 

Literature Cited 

Pages 6-1 through 6-14 

FEIS 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
6-1

6.0 LITERATURE CITED 

ACMAD (Alameda County Mosquito Abatement District). 2005. ACMAD the mosquitoes of 

California—A checklist web site. http://www.mosquitoes.org/checklist.html, accessed May 4, 

2005. Alameda County Mosquito Abatement District, Haywood, CA. 

Amaral, S., F. Winchell, and T. Pearsons. 2001. Reaction of Chinook salmon, northern pikeminnow, and 

smallmouth bass to behavioral guidance stimuli. American Fisheries Society Symposium 

26:124–144. 

Anderson, M. 2006. Technical analysis of the potential water quality impacts of the LEAPS Project on 

Lake Elsinore. Prepared for the Santa Ana Regional Water Quality Control Board. January 31, 

2006. 

Anderson, M.A. 2001. Internal loading and nutrient cycling in Lake Elsinore. Final Report. Prepared 

for Santa Ana Regional Water Quality Control Board. Prepared by Michael A. Anderson, 

Department of Environmental Sciences, University of California, Riverside, CA. August 31, 

2001. 

APLIC (Avian Power Line Interaction Committee). 1994. Mitigating bird collisions with power lines: 

the state of the art in 1994. Edison Electric Institute. Washington, DC. 

APLIC and FWS (Avian Power Line Interaction Committee and U.S. Fish and Wildlife Service). 2005. 

Avian protection plan (APP) guidelines. A joint document prepared by The Edison Electric 

Institute’s Avian Power Line Interaction Committee and the U.S. Fish and Wildlife Service. 

April 2005. 

APLIC (Avian Power Line Interaction Committee), Edison Electric Institute, and Raptor Research 

Foundation. 1996. Suggested practices for raptor protection on power lines: The state of the art 

in 1996. Avian Power Line Interaction Committee, Edison Electric Institute, and the Raptor 

Research Foundation. Washington, DC. 

Audubon. 2005. Audubon West Nile virus web site. http://www.audubon.org/bird/wnv, accessed May 

4, 2005. Audubon, New York, NY. 

Beck, T.W. and G.I. Gould, Jr. 1992. Background and the current management situation for the 

California spotted owl. Chapter 3. In: The California Spotted Owl: A Technical Assessment of 

its Current Status. J. Verner, K.S. McKelvey, B.R. Noon, R.J. Gutierrez, G.I. Bould, and T.W. 

Beck (eds.). USDA Forest Service General Technical Report PSW-GTR-133. U.S. Forest 

Service, Albany, CA. 

Beier, P. 1993. Determining minimum habitat areas and habitat corridors for cougars. Conservation 

Biology 7(1):94–108. 

Beier, P. and R.H. Barrett. 1993. The cougar in the Santa Ana Mountain Range, California. Final 

Report. Orange County Cooperative Mountain Lion Study, June 1, 1993. 

Bell, M. 1991. Fisheries handbook of engineering requirements and biological criteria. Third Edition. 

U.S. Army Corps of Engineers, North Pacific Division, Fish Passage Development Program, 

Portland, OR. 307 pp. 

Berger, V. 1997. Second stage geotechnical evaluation: A 300-MW Advanced Pump Storage Project, 

Lake Elsinore, Riverside County, California. In: Elsinore Valley MWD and Nevada Hydro 

(2004) as exhibit E, appendix E-11. Prepared for Elsinore Valley Municipal Water District, Lake 

Elsinore, CA, and the Nevada Hydro Company, Inc., Vista, CA. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
6-2

Bottemiller, S.C., J.M. Cahill, and J.R. Cowger. 2000. Impacts on residential property values along 

transmission lines. An update of three Pacific Northwest metropolitan area. Right of Way. 

July/August. 

Brehme, C.S. 2003. Responses of small terrestrial vertebrates to roads in a coastal sage scrub ecosystem. 

M.S. Thesis. San Diego State University, San Diego, CA. 

California Department of Conservation, California Geological Survey. 1994. The fault activity map of 

California and adjacent areas. California geologic data map 6. Scale 1:750,000. 

California Department of Health Services. 2003. Staff report: 2003 environmental performance report. 

Publication 100-03-010. California Department of Health Services, Sacramento, CA. pp. 125–

126. (not seen, as cited in Elsinore Valley MWD and Nevada Hydro, 2004) 

California Department of Finance. 2002. California county profiles—A companion to the 2001 

California statistical abstract, economic research. California Department of Finance, Sacramento, 

CA. February 2002. 

CalPIF (California Partners in Flight). 2002. The oak woodland bird conservation plan: a strategy for 

protecting and managing oak woodland habitats and associated birds in California. 

http://www.prbo.org/calpif/plans.html, accessed July 11, 2005. Version 2.0. Point Reyes Bird 

Observatory, Stinson Beach, CA. 

Caltrans (California Department of Transportation). 2005a. Caltrans vehicle weights in California, 

summary of the CA Vehicle Code (CVC) web page. 

http://www.dot.ca.gov/hq/traffops/trucks/trucksize/weight.htm, accessed on September 23, 2005, 

last updated July 13, 2005. California Department of Transportation. 

Caltrans. 2005b. SR-74 Ortega Highway safety improvement project from San Juan 

bridge to Orange/Riverside county line, initial statement/environmental 

assessment web site. http://www.dot.ca.gov/dist12/sr74.htm, accessed October 6, 2005. 

California Department of Transportation. 

CARB (California Air Resources Board). 2005a. The California almanac of emissions and air quality. 

2005 Edition. Available at http://www.arb.ca.gov/aqd/almanac/almanac05/almanac2005all.pdf, 

accessed August 18, 2005. California Air Resources Board, Planning and Technical Support 

Division, Sacramento CA. 

CARB (California Air Resources Board). 2005b. California ambient air quality standards, California and 

federal ambient air quality standards chart. http://www.arb.ca.gov/aqs/aaqs2.pdf, accessed August 

18, 2005. California Air Resources Board, Sacramento, CA. May 5, 2005. 

CARB. 2004. 2004 area designation maps/state and national, 2004 state area designation maps. 

http://www.arb.ca.gov/desig/adm/adm.htm#state, accessed August 18, 2005. California Air 

Resources Board, Sacramento, CA. 

CDFG (California Department of Fish and Game). 2005. CDFG California’s plants and animals web 

page. http://www.dfg.ca.gov/hcpb/species/species.shtml, updated, May 11, 2005, accessed May 

25, 2005. Habitat Conservation Planning Branch, California Department of Fish and Game, 

Sacramento, CA. 

CDFG. 1998. An assessment of mule and black-tailed deer habitats and populations in California with 

special emphasis on public lands administered by the Bureau of Land Management and the 

United States Forest Service. Report to the Fish and Game Commission. Available at 

http://www.dfg.ca.gov/hunting/deer/habitatassessment.htm, accessed November 17, 2005. 

California Department of Fish and Game. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
6-3

CDFG and CRA (California Department of Fish and Game and California Resources Agency). 1993. 

Southern California coastal sage scrub NCCP conservation guidelines. Available at 

http://www.dfg.ca.gov/nccp/Proc%20Guid/cgindex.htm, accessed August 18, 2006. California 

Department of Fish and Game and California Resources Agency, Sacramento, CA. August, 

1993. 

CDPR (California Department of Parks and Recreation). 1984. Lake Elsinore State recreation area. 

Preliminary general plan. California Department of Parks and Recreation, Sacramento, CA. 

CEC (California Energy Commission). 2003. Comparative cost of California central station electricity 

generation technologies. Final Staff Report. Docket 02-IEP-01. California Energy Commission, 

Sacramento, CA. June 5, 2003. 

CEDD (California Employment Development Department). 2005. CEDD labor market info web site. 

http://www.labormarketinfo.edd.ca.gov/cgi, accessed May 25, 2005. California Employment 

Development Department, Sacramento, CA. 

CERES (California Environmental Resources Evaluation System). 2005. CERES San Juan Creek web 

site. ceres.ca.gov/wetlands/geo_info/so_cal/san_juan_creek.html, accessed May 25, 2005. 

California Environmental Resources Evaluation System, Sacramento, CA. 

CERES. 1998. California Environmental Quality Act, Sections 21083 and 21087, Appendix G—

Environment checklist form, Section XI: Noise. 

http://ceres.ca.gov/topic/env_law/ceqa/rev/appg_102698.pdf, accessed August, 19, 2005. 

California Environmental Resources Evaluation System, Sacramento, CA. 

CNPS (California Native Plant Society). 2005. Inventory of rare and endangered plants, Online Edition 

No. 6. http:///cnps.web/aplus.net/cgi-bin/inv/inventory.cgi, accessed September 28, 2005. 

California Native Plant Society. 

Cole, D.N. and P.B. Landres. 1995. Indirect effects of recreation on wildlife. Chapter 11. In: Wildlife 

and Recreationists: Coexistence through Management and Research. R.L. Knight and K. J. 

Gutzwiller (eds.). Island Press, Washington, DC. 

Collins, J.N., E. Stein, and M. Sutula. 2004. California Rapid Assessment Method (CRAM) for 

wetlands, V. 3.0. September 30, 2004. 

Colwell, P.F. 1990. Power lines and land values. Journal of Real Estate Research 5(1):117–127. 

Consumers Energy Company and Detroit Energy Company. 2005. 2005 Annual report of net barrier 

operation. Ludington Pumped Storage Project No. 2680. Report filed with FERC December 14, 

2005. Consumers Energy Company and Detroit Energy Company. 

Coutant, C. 2001. Integrated, multi-sensory, behavioral guidance systems for fish diversions. American 

Fisheries Society Symposium 26:105–113. 

Corps (U.S. Army Corps of Engineers). 2005a. San Juan Creek/San Mateo Creek special area 

management plan web site. http://www.spl.usace.army.mil/samp/sanjuancreeksamp.htm, 

accessed May 25, 2005. Los Angeles District, U.S. Army Corps of Engineers, Los Angeles, CA. 

Corps. 2005b. Volume I. Draft environmental impact statement, San Juan Creek and western San Mateo 

Creek watershed special area management plan. U.S. Army Corps of Engineers, Los Angeles, 

CA. November 2005. 

Corps. 2004. Special public notice: Final mitigation guidelines and monitoring requirements. Public 

Notice No. 970031200-RRS. U.S. Army Corps of Engineers, Los Angeles District, Los Angeles, 

CA. April 19, 2004. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
6-4

Corps. 2003. Water control manual for Seven Oaks dam and reservoir, Santa Ana, CA. Los Angeles 

District, U.S. Army Corps of Engineers, Los Angeles, CA. September, 2003. 

Corps. 1995. Engineering and design - earthquake design and evaluation for civil works projects. ER 

1110-2-1806. U.S. Army Corps of Engineers. July 31, 1995. 

County of Orange. 2005a. County of Orange General Plan. Resources and Development 

Management Department. Accessed November 18, 2006, at

http://www.ocplanning.net/docs/GeneralPlan2005/. Updated September 13, 2005. 

County of Orange. 2005a. County of Orange General Plan. Resources and Development Management 

Department. Accessed November 18, 2006,at 

http://www.ocplanning.net/docs/GeneralPlan2005/Chapter_III_Land_Use_Element_Map_2005.p

df Updated September 13, 2005.

County of Riverside. 2003a. County of Riverside general plan, web page. http://www.rcip.org/general 

plan.htm, accessed May 20, 2005, and November 20, 2006. County of Riverside. 

County of Riverside, 2003b. County of Riverside Elsinore area plan, web page. 

http://www.tima.co.riverside.ca.us/generalplan/ap1/elsinore.html, accessed May 20, 2005, and 

November 20, 2006. County of Riverside 

Cowger, J.R., S.C. Botttemiller, and J.M. Cahill. 1996. Transmission line impact on residential property 

values. A study of three pacific Northwest metropolitan areas. Right of Way. 

September/October. 

CPUC/USFS (California Public Utility Commission and U. S. Forest Service). 2006. Antelope-Pardee 

Transmission Project environmental impact report/environmental impact statement. Available at 

http://www.cpuc.ca.gov/environment/info/aspen/antelopepardee/antelopepardee.htm, accessed 

November 18, 2006. California Public Utility Commission and U. S. Forest Service. 

Delaney, C.J. and D. Timmons. 1992. High voltage power lines: Do they affect residential property 

value? Journal of Real Estate Research 7(3):315–329. 

deMaynadier, P. and M. Hunter. 1995. The relationship between forest management and amphibian 

ecology: a review of the North American literature. Environmental Review 3:230-261. 

Department of Health Services (California Department of Health Services, Health and Human Services 

Agency). 2002. Policy options in the Face of Possible Risk from Power Frequency Electric and 

Magnetic Fields (EMF). Final Report. California Department of Health Services, Health and 

Human Services Agency, EMF Program. June 2002. 

Dickson, B.G., J.S. Jenness, and P. Beier. 2005. Influence of vegetation, topography, and roads on 

cougar movement in southern California. Journal of Wildlife Management 69(1): 264–276. 

Dobson-Brown, D., P. Daly, J. K. Sander, and S. Underbrink. 2005. Cultural resources survey of Lake 

Elsinore Advance Pumped Storage Project, Orange, Riverside and San Diego Counties, 

California. Chambers Group Inc., Irving, CA. 

EIA (Energy Information Association). 2005. EIA’s natural gas prices for California website. Available 

at: http://www.eia.doe.gov/emeu/states/ngprices/ngprices_ca.html, accessed October 25, 2005. 

Energy Information Association. 

EIP Associates (EIP Associates, Inc.). 2005. Fisheries management plan for Lake Elsinore, Riverside 

County, California. Final Report. Prepared for Lake Elsinore and San Jacinto Watersheds 

Authority, Riverside, CA. Prepared by EIP Associates, Inc., Sacramento, CA. August 2005. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
6-5

Elsinore Valley MWD and Nevada Hydro (Elsinore Valley Municipal Water District and the Nevada 

Hydro Company, Inc.). 2006. Comments on the Draft EIS for the Lake Elsinore Advanced 

Pumped Storage Project, Federal Energy Regulatory Commission Project Number 11858-002. 

Elsinore Valley Municipal Water District, Lake Elsinore, CA, and the Nevada Hydro Company, 

Inc., Vista, CA. April 25, 2006. 

Elsinore Valley MWD and Nevada Hydro (Elsinore Valley Municipal Water District and the Nevada 

Hydro Company, Inc.). 2005. Final application for license of major unconstructed project: 

Response to FERC deficiency letter, Volume III, for the Lake Elsinore Advanced Pumped 

Storage Project, Federal Energy Regulatory Commission Project Number 11858-002. Elsinore 

Valley Municipal Water District, Lake Elsinore, CA, and the Nevada Hydro Company, Inc., 

Vista, CA. February 2005. 

Elsinore Valley MWD and Nevada Hydro. 2004a. Final application for license of major unconstructed 

project, Lake Elsinore Advanced Pumped Storage Project, Federal Energy Regulatory 

Commission Project Number 11858. Elsinore Valley Municipal Water District, Lake Elsinore, 

CA, and the Nevada Hydro Company, Inc., Vista, CA. February 2004. 

Elsinore Valley MWD and Nevada Hydro. 2004b. Final application for license of major unconstructed 

project: Response to FERC deficiency letter, Volume I, for the Lake Elsinore Advanced Pumped 

Storage Project, Federal Energy Regulatory Commission Project Number 11858-002. Elsinore 

Valley Municipal Water District, Lake Elsinore, CA, and the Nevada Hydro Company, Inc., 

Vista, CA. November 2004. 

Elsinore Valley MWD and Nevada Hydro. 2004c. Final application for license of major unconstructed 

project: Response to FERC deficiency letter, Volume II, for the Lake Elsinore Advanced 

Pumped Storage Project, Federal Energy Regulatory Commission Project Number 11858-002. 

Elsinore Valley Municipal Water District, Lake Elsinore, CA, and the Nevada Hydro Company, 

Inc., Vista, CA. November 2004. 

EPA (U.S. Environmental Protection Agency). 2005a. The emissions and generation resource integrated 

database (eGrid2002), Version 2.0. http://www.epa.gov/cleanenergy/egrid/download.htm, 

accessed August 18, 2005. Office of Air Quality Planning and Standards, U.S. Environmental 

Protection Agency, Research Triangle Park, NC. July 2005. 

EPA. 2005b. Technology transfer network clearinghouse for emission inventories and factors, AP-42, 

Volume 1. Fifth Edition: Stationary Point and Area Sources – January 1995, Sections 1.1, 1.2 

and 3.1. http://www.epa.gov/ttn/chief/ap42/> http://www.epa.gov/ttn/chief/ap42/, accessed 

August 18, 2005. Office of Air Quality Planning and Standards, U.S. Environmental Protection 

Agency, Research Triangle Park, NC. June, 2005. 

EPA. 1995. Compilation of air pollutant emission factors, Volume 1: Stationary point and area source. 

Fifth Edition. U.S. Environmental Protection Agency. 

FICON (Federal Interagency Committee on Noise). 1992. Federal agency review of selected airport 

noise analysis issues. http://www.fican.org/download/nai-8-92.pdf, accessed August 19, 2005. 

Federal Interagency Committee on Noise. August 1992. 

FEMA (Federal Emergency Management Agency). 1998. Federal guidelines for dam safety: emergency 

action planning for dam owners, Federal Emergency Management Agency 333, Interagency 

Committee on Dam Safety, Section Ill(B)(3). October 1998 

FERC (Federal Energy Regulatory Commission). 2000. Engineering guidelines for the evaluation of 

hydropower projects. Federal Energy Regulatory Commission, Washington, DC. Revised 

November 9, 2000. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
6-6

FHWA (Federal Highway Administration). 1995. Traffic and construction noise analyses guidelines. 

U.S. Department of Transportation, Federal Highway Administration. 

Frank Hovore Associates. 2003. Biological impacts assessment, proposed facilities installation, Lake 

Elsinore back-basin well field, Riverside County, CA. Appendix E3 of Lake Elsinore 

Stabilization and Enhancement Project, Draft program environmental impact report. SCH No. 

2001071042. Prepared for Lake Elsinore and San Jacinto Watersheds Authority. Prepared by 

MWH, Pasadena, CA. March 2005. 

FTA (Federal Transit Administration). 1995. Transit noise and vibration assessment guidance manual. 

http://www.fta.dot.gov/transit_data_info/reports_publications/publications/environment/4805_51

44_ENG_HTML.htm, accessed August 19, 2005. Federal Transit Administration, U.S. 

Department of Transportation, Washington, D.C. April 1995.

FWS (U.S. Fish and Wildlife Service). 2004a. Findings and recommendations for the issuance of a 

section 10(a)(1)(B) incidental take permit associated with the western Riverside County multiple 

species habitat conservation plan/natural community conservation plan. Available at: 

http://www.fws.gov/pacific/carlsbad, accessed May 17, 2005. U.S. Fish and Wildlife Service. 

FWS. 2004b. Draft recovery plan for vernal pool ecosystems of California and southern Oregon. Region 

1, U.S. Fish and Wildlife Service, Portland, OR. October, 2004. 

FWS. 2004c. Findings and recommendations for the issuance of a section 10(a)(1)(B) incidental take 

permit associated with the western Riverside County multiple species habitat conservation 

plan/natural community conservation plan. U.S. Fish and Wildlife Service, California/Nevada 

Operations Office. June 22, 2004. 

FWS. 2003. Recovery plan for the Quino checkerspot butterfly (Euphydryas editha quino). Region 1, 

U.S. Fish and Wildlife Service, Portland, OR. September 17, 2003. 

FWS. 2002. Recovery plan for the California red-legged frog (Rana aurora draytonii). Region 1, U.S. 

Fish and Wildlife Service, Portland, OR. May 28, 2002. 

FWS. 1999. Arroyo southwestern toad (Bufo microscaphus californicus) recovery plan. Region 1, U.S. 

Fish and Wildlife Service, Portland, OR. July 24, 1999. 

FWS. 1998. Draft recovery plan for the least Bell’s vireo (Vireo bellii pusillus). Region 1, U.S. Fish and 

Wildlife Service, Portland, OR. May 6, 1998. 

FWS. 1997. Draft recovery plan for the Stephen’s kangaroo rat (Dipodomys stephensii). Region 1, U.S. 

Fish and Wildlife Service, Portland, OR. June 23, 1997. 

Gauger, J.R. 1985. Household appliance magnetic field survey. Institute of Electrical and Electronics 

Engineers. Vol. PAS-104, No. 9:2436–44. (not seen, as cited in CPUC/USFS, 2006). 

Genterra Consultants (Genterra Consultants Inc.). 2005. Report on water quality sampling events 2004–

05 wet season, sampling of baseline water-quality conditions, Lake Elsinore Advanced Pumped 

Storage (LEAPS) Project, FERC Project No. 11858-02, Riverside County, California. May 31, 

2005. 

Genterra Consultants. 2003. Geotechnical feasibility report: Lake Elsinore Advanced Pump Storage 

Project (LEAPS). In: Elsinore Valley MWD and Nevada Hydro (2004) as exhibit E, appendix E10. Prepared for Elsinore Valley Municipal Water District, Lake Elsinore, CA, and the Nevada 

Hydro Company, Inc., Vista, CA. 

Gibbs, J. 1998. Amphibian movements in response to forest edges, roads and streambeds in southern 

New England. Journal of Wildlife Management 62(2):584–589. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
6-7

Giusti, G.A., R.B. Standiford, D.D. McCreary, A. Merenlender and T. Scott. 2004. Oak woodland 

conservation in California’s changing landscape. IHRMP website http://danr.ucop.edu/ihrmp. 

October, 2004. Accessed September 19, 2005. 

Goetz, F., J. Dawson, T. Shaw, and J. Dillon. 2001. Evaluation of low-frequency sound transducers for 

guiding salmon smolts away from a navigation lock. American Fisheries Society Symposium 

26:91–104. 

Gucinski, H., M.J. Furniss, R.B. Ziemer, and M. H. Brookes. 2001. Forest roads: A synthesis of 

scientific information. General Technical Report PNW-GTR-509. U.S. Forest Service, Pacific 

Northwest Research Station, Portland, OR. 

Hamilton, S.W. and G.M. Schwann. 1995. Do high voltage electric transmission lines affect property 

value? Land Economics 71(4):436–444. 

Hart, E.W. and W.A. Bryant. 1997. Fault-rupture hazard zones in California: Alquist-Priolo Earthquake 

Fault Zoning Act with index to Earthquake Fault Zones maps. California Department of 

Conservation, Division of Mines and Geology, Special Publication 42, 32 p. (Revised 1997; 

Supplements 1 and 2 added 1999). 

Hoag, J.C. 2000. Harvesting, propagating, and planting wetland plants. Riparian/Wetland Project 

Information Series No. 14. Natural Resources Conservation Service, Plant Materials Center, 

Aberdeen, ID. July 2000. 

Hoag, J.C. 1994. Seed and live transplant collection procedures for 7 wetland plant species. Natural 

Resources Conservation Service, Plant Materials Center, Aberdeen, ID. 

Holland, V.L. 1988. Coastal oak woodland. www.dfg.ca.gov/whdab/cwhr/pdfs/COW.pdf, accessed July 

11, 2005. California Department of Fish and Game, California Interagency Wildlife Task Group. 

Hoover’s (Hoover’s Online: The Business Information Authority). 2004. Southern California Edison 

Company factsheet on Hoover’s web page. http://www.hoovers.com/southern-california-edisoncompany/--ID__106299--/free-co-factsheet.xhtml, accessed 12/6/04. 

Hunting, K. 2002a. A roadmap for PIER research on avian collisions with power lines in California. 

Commission Staff Report P500-02-071F. Prepared for the California Energy Commission, 

Energy Related Environmental Research. December 2002. 

Hunting, K. 2002b. A roadmap for PIER research on avian power line electrocution in California. 

Commission Staff Report P500-02-072F. Prepared for the California Energy Commission, 

Energy Related Environmental Research. December 2002. 

Jackman, R.E. and J.M. Jenkins. 2004. Protocol for evaluating bald eagle habitat and populations in 

California. Prepared for U.S. Fish and Wildlife Service, Endangered Species Division, 

Sacramento, CA. June, 2004. 

Joslin, G. and H. Youmans. 1999. Project overview. pages 1.1–1.18. In: Effects of Recreation on 

Rocky Mountain Wildlife: A Review for Montana. G. Joslin and H. Youmans, coordinators. 

Committee on Effects of Recreation on Wildlife, Montana Chapter of The Wildlife Society. 

Keeler-Wolf, T., D.R. Elam, K. Lewis and S.A. Flint. 1998. California vernal pool assessment 

preliminary report. http://maphost.dfg.ca.gov/wetlands/vp_asses_rept.htm. State of California 

Department of Fish and Game, modified July 27, 2000. May 1998. 

King, J.G. and L.C. Tennyson. 1984. Alteration of streamflow characteristics following road 

construction in north central Idaho. Water Resources Research 20(8):1,159–1,163. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
6-8

Korinek, D. 2003. Direct testimony of David Korinek, San Diego Gas & Electric Company, before the 

Public Utilities Commission of the State of California web page. 

http://www.sdge.com/news/korinek.pdf, accessed August 31, 2004. San Diego Gas & Electric 

Company. April 15, 2003. 

Knudsen, F.R. and E.O. Sand. 1994. Avoidance responses to low frequency sound in downstream 

migrating Atlantic salmon smolt, Salmo salar. Journal of Fish Biology 45:227–233. 

Kyei, J. 2004. Comparative reliability evaluation for alternative new 500-Kv transmission lines into San 

Diego web page. http://www1.caiso.com/docs/2004/05/17/2004051710385016456.pdf, accessed 

August 31, 2004. Grid Planning Department, California Independent System Operators. May 17, 

2004. 

K.S. Dunbar & Associates. 1990. Environmental assessment / environmental impact report, San Jacinto 

Water Reclamation Project. Prepared for Easter Municipal Water District. May 1989. (not seen, 

as cited by Joint Watershed Authority, 2005) 

Joint Watershed Authority (Lake Elsinore and San Jacinto Watersheds Authority). 2005. Lake Elsinore 

stabilization and enhancement project draft program environmental impact report. SCH No. 

2001071042. Prepared by Montgomery Watson Harza, Pasadena, CA. Prepared for Lake 

Elsinore and San Jacinto Watersheds Authority, Riverside, CA. March 2005. 

Joint Watershed Authority. 2004. Lake Elsinore recycled water project. Draft Final Report. Prepared by 

R.A. Veiga Nasceiento and M.A. Anderson, Department of Environmental Sciences, University 

of California Riverside, Riverside, CA. Prepared for Lake Elsinore and San Jacinto Watersheds 

Authority, Riverside, CA. August 9, 2004. (not seen, as cited by Elsinore Valley MWD and 

Nevada Hydro, 2004) 

Mathur, D., P. Heisey, and N. Nagnusson. 1977. Impingement of fishes at the Peach Bottom Atomic 

Power Station in Pennsylvania Transactions of the American Fisheries Society 106(3):258–267. 

MBA (Michael Brandman Associates). 2006. Delineation of jurisdictional waters and wetlands and 

California Rapid Assessment Method (CRAM) Assessment, proposed Lake Elsinore Advanced 

Pump Storage (LEAPS), unincorporated Riverside County, California. Prepared for the Nevada 

Hydro Company, Inc. Prepared by Michael Brandman Associates, Irvine, CA. March 23, 2006. 

MBA. 2004. Terrestrial biological resources study Lake Elsinore Advanced Pump Storage/TalegaEscondido/Valley-Serrano Interconnect Project. Prepared for Elsinore Valley Municipal Water 

District, Lake Elsinore, CA. Prepared by Michael Brandman Associates, Irvine, CA. November 

2004. 

MBA. 2003. Final biological resources study, Lake Elsinore Advanced Pump Storage Project, Riverside 

County, California. Prepared for Elsinore Valley Municipal Water District, Lake Elsinore, CA. 

Prepared by Michael Brandman Associates, Irvine, CA. August, 2003. 

MBA. 2002. Biological survey reports—2002. Appendix D of Terrestrial Biological Resources Study. 

Lake Elsinore Advanced Pump Storage Project and Talega-Escondido/Valley-Serrano 500-kV 

Interconnection Project, Riverside County, California. Prepared for Elsinore Valley Municipal 

Water District. Prepared by Michael Brandman Associates, Irvine, CA. November, 2004. 

McCaskie, G. 1977. The winter season. Southern Pacific Coast Region. Amer. Birds 31:372–376. 

McCaskie, G. 1975a. Spring migration. Southern Pacific Coast Region. Amer. Birds 29:907–911. 

McCaskie, G. 1975b. The nesting season. Southern Pacific Coast Region. Amer. Birds 29:740–745. 

McCaskie, G. 1975c. The winter season. Southern Pacific Coast Region. Amer. Birds 29:1029–1036. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
6-9

McCaskie, G. 1974a. Spring migration. Southern Pacific Coast Region. Amer. Birds 27:851–854. 

McCaskie, G. 1974b. The nesting season. Southern Pacific Coast Region. Amer. Birds 28:948–951. 

McCaskie, G. 1974c. The winter season. Southern Pacific Coast Region. Amer. Birds 28:681–684. 

McCaskie, G. 1973a. Spring migration. Southern Pacific Coast Region. Amer. Birds 27:818–822. 

McCaskie, G. 1973b. The nesting season. Southern Pacific Coast Region. Amer. Birds 27:917–920. 

McCaskie, G. 1973c. The winter season. Southern Pacific Coast Region. Amer. Birds 27:662–665. 

McCaskie, G. 1973a. Spring migration. Southern Pacific Coast Region. Amer. Birds 30:886–894. 

McCaskie, G. 1973b. The nesting season. Southern Pacific Coast Region. Amer. Birds 30:1002–1005. 

McCaskie, G. 1973c. The winter season. Southern Pacific Coast Region. Amer. Birds 30:764–770. 

Morgan, M.G. 1991. 60 Hz electric and magnetic fields: An overview of the issues. Carnegie Mellon 

University. (Not seen, as cited in CPUC/USFS, 2006) 

Moriarty, J.R., III. 1967. Transitional pre-desert phase in San Diego County, California. Science 

155(3762):553–556. 

Moyle, P. 2002. Inland Fishes of California. Revised and Expanded. University of California Press, 

Berkeley, CA. 

MWH. 2005. Lake Elsinore and San Jacinto Watersheds Authority, Lake Elsinore stabilization and 

enhancement project, draft program environmental impact report. SCH No. 2001071042. MWH, 

Pasadena, CA. March 2005. 

MWH. 2003. Elsinore Basin groundwater management plan, final draft report. Prepared for Elsinore 

Valley Municipal Water District. MWH, Pasadena, CA. June 2003. (not seen, as cited in Joint 

Watershed Authority, 2005) 

Myers, N., R.A. Mittermeier, C.G. Mittermeier, G.A.B. da Fonseca, and J. Kent. 2000. Biodiversity 

hotspots for conservation priorities. Nature Vol. 403:853–858. 

NIEHS (National Institute of Environmental Health Sciences). 1999. Report on Health Effects from 

Exposure to Power-Line Frequency Electric and Magnetic Fields. Available at: 

http://www.niehs.nih.gov/emfrapid/html/EMF_DIR_RPT/NIEHS_Report.pdf, accessed January

23, 2006.NIH Publication No. 99-4493. Research Triangle Park, NC. May 1999. 

NMFS. 1996. Addendum: Juvenile fish screen criteria for pump intakes. 

http://www.nwr.noaa.gov/1salmon/salmesa/pubs/nmfscrit.pdf, accessed August 14, 2005. 

National Marie Fisheries Service, Portland, OR. May 9, 1996. 

NMFS (National Marine Fisheries Service). 1995. Juvenile fish screen criteria. 

http://www.nwr.noaa.gov/1salmon/salmesa/pubs/nmfscrit.pdf, accessed August 14, 2005. 

National Marie Fisheries Service, Portland, OR. February 16, 1995. 

North County Times. 2005. North County Times website. Lake’ water losses slowed with extra water. 

www.nctimes.com.article.2004.7.8. The North County Time, Escondido, CA. 

O’Malley, D. 2005. World famous Elsinore hang gliding venue threatened by power lines. Fallbrook 

Bonsall Village News, June 9, 2005. 

O’Neil, S. and J.C. Brown. 2003. Evaluative cultural resources investigation of CA-ORA-35, located 

within the Los Pinos Conservation Camp in the Cleveland National Forest, Orange County, 

California. On file at the Cleveland National Forest Supervisory Office. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
6-10

Orange County. 2005. South Orange County integrated regional water management plan, 2005, total 

watershed efficiency. Final Draft. County of Orange, Resources and Development Management 

Department, Watershed and Coastal Resources Division, Santa Ana, CA. May 18, 2005. 

Panjabi, A.O., E.H. Dunn, P.J. Blancher, W.C. Hunter, B. Altman, J. Bart, C.J. Beardmore, H. Berlanga, 

G.S. Butcher, S.K. Davis, D.W. Demarest, R. Dettmers, W. Easton, H. Gomez de Silva Garza, 

E.E. Inigo-Elias, D.N. Pashley, C.J. Ralph, T.D. Rich, K.V. Rosenberg, C.M. Rustay, J.M. Ruth, 

J.S. Wendt, and T.C. Will. 2005. The partners in flight handbook on species assessment. 

Version 2005. Partners in Flight Technical Series No. 3. Rocky Mountain Bird Observatory 

website: http://www.rmbo.org/pubs/downloads/Handbook2005.pdf, accessed November 17, 

2005. 

Platts. 2005. Platts web site. http://www.platts.com, accessed August 8, 2005. Platts, Washington, DC. 

Ploskey, G. and P. Johnson. 2001. Effectiveness of strobe lights and infrasound device for eliciting 

avoidance by juvenile salmon. American Fisheries Society Symposium 26:37–56. 

Popper, A. and T. Carlson. 1998. Application of sound and other stimuli to control fish behavior. 

Transactions of the American Fisheries Society 127:673–707. 

Public Policy Institute of California. 2002. California counts: Population trends and profiles. In: A 

State of Diversity—Demographic Trends in California’s Regions. Volume 3, Number 5. 

http://www.ppic.org//main/pubs.asp, accessed May 25, 2005. Public Policy Institute of 

California, San Francisco, CA. May 2002. 

Raleigh, R.F., T. Hickman, R.C. Solomon, and P.C. Nelson. 1984. Habitat suitability information: 

Rainbow trout. FWS/OBS-82/10.60. U.S. Fish and Wildlife Service. 64 pp. 

Reade Advanced Materials. 2005. Reade Advanced Materials weight per cubic foot and specific gravity 

reference sheet web site. http://www.reade.com/Particle_Briefings/spec_gra2.html, accessed 

September 30, 2005. Reade Advanced Materials, Reno. NV. 

Reid, L. 1999. Presentation made at the “Sociological and Ecological Consequences of Roads in the 

Sierra Nevada” Conference; October 22-24, 1999, Tahoe, CA. U.S. Forest Service, Pacific 

Southwest Research Station, Redwood Sciences Laboratory, CA. 

Reed, R., J. Jonson-Barnard, and W. Baker. 1996. Contribution of roads to forest fragmentation in the 

Rocky Mountains. Cons. Bio. 10(4):1098–1106. 

Riverside County (Riverside County Board of Commissioners). 2003. Western Riverside County multispecies habitat conservation plan. http://www.rcip.org/conservation.htm, accessed April 29. 

2005. Riverside County Board of Commissioners. 

San Diego Water Board (Regional Water Quality Control Board). 1994. Water quality control plan for 

the San Diego Region. San Diego Regional Water Quality Control Board, San Diego, CA. 

Santa Ana Water Board (Regional Water Quality Control Board). 2001. Status report on Lake Elsinore 

water quality restoration activities, item 17. Santa Ana Regional Water Quality Control Board, 

Riverside, CA. June 1, 2001. 

Santa Ana Water Board. 1995. Water quality control plan, Santa Ana Basin. Santa Ana Regional Water 

Quality Control Board, Riverside, CA. June 1, 2001. 

SCAG (Southern California Association of Governments). 1998. Regional economic forecast for 

southern California, 2003–2004. Southern California Association of Governments. November 

2002. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
6-11

Scott Laboratory. 2001. Understanding the plants and animals of the western Riverside County MSHCP. 

http://ecoregion.ucr.edu. Department of Earth Sciences, University of California, Riverside, 

Riverside, CA. 

SCS (U.S. Department of Agriculture, Soil Conservation Service). 1971. General soil map, Riverside 

and western part of Riverside Counties, California. U.S. Department of Agriculture, Soil 

Conservation Service. Compiled 1971. 

SDG&E (San Diego Gas & Electric Company). 2006. Amended application of San Diego Gas & 

Electric Company for a Certificate of Public Convenience and Necessity for the Sunrise 

Powerlink Transmission Project. Available at: 

www.cpuc.ca.gov/static/hottopics/1energy/a0512014+.htm, accessed November 27, 2006. San 

Diego Gas & Electric Company, San Diego, CA. August 4, 2006. 

Severson et al. 1988. Acute “nonlymphocytic leukemia and residential exposure to power frequency 

magnetic fields.” American Journal of Epidemiology. (not seen, cited in CPUC/USFS, 2006). 

Sierra Energy & Risk Assessment, Inc. 2002. Assessment of the Valley-Rainbow Transmission Project. 

Prepared for Office of Ratepayer Advocates, California Public Utilities Commission. Sierra 

Energy & Risk Assessment, Inc. 

Silva et al. 1988. Power frequency magnetic fields in the home. Institute of Electrical and Electronics 

Engineers, No. 88 WM 101-8. (not seen, cited in CPUC/USFS, 2006) 

Smart, M., G. Dick, J. Snow, L. Williams, M. Webb, and R. Ott. 2006. Aquatic plant establishment 

workshop web page. 

www.sdafs.org/reservoir/manuals/aqveg/native_Aquatic_Plant_Establishment.pdf, accessed 

August 18, 2006. Spring Meeting, Southern Division of the American Fisheries Society, San 

Antonio, TX. February 10, 2006. 

South Coast AQMD (The South Coast Air Quality Management District). 1993. CEQA air quality 

handbook, 1993. http://www.aqmd.gov/ceqa/hdbk.html#, updated July 19, 2005, accessed 

August 19, 2005. The South Coast Air Quality Management District, Diamond Bar, CA. 

Stephenson, J. and G.M. Calcarone. 1999. Southern California mountains and foothills assessment: 

habitat and species conservation issues. PSW-GTR-172. U.S. Forest Service, Pacific Southwest 

Research Station, Albany, CA. 

SAWPA (Santa Ana Watershed Project Authority). Santa Ana integrated watershed plan 2005 update: 

An integrated regional water management plan. Planning Department, Santa Ana Watershed 

Project Authority, Riverside, CA. June 2005. 

Swihart, R. and N. Slade. 1984. Road crossing in Sigmodon hispidus and Microtus ochrogaster. Journal 

of Mammal. 65:357–360. 

Tesky, J.L. 1992. Salix nigra. In: Fire Effects Information System. http://www.fs.fed.us/database/feis, 

accessed July 11, 2005. U.S. Forest Service Rocky Mountain Research Station, Fire Sciences 

Laboratory (Producer). 

Tetra Tech FW, Inc. 2005. Methow transmission project draft environmental impact statement. 

Prepared by Tetra Tech FW, Inc., Seattle, WA. Prepared for Public Utility District No. 1 of 

Okanogan County and U.S. Forest Service, Okanogan and Wenatchee National Forests, 

Okanogan, WA. January 2005. 

Tinker, D., C. Resor, G. Beauvais, K. Kipfmueller, C. Fernandes, and W. Baker. 1998. Watershed 

analysis of forest fragmentation by clearcuts and roads in a Wyoming forest. Landscape Ecology 

13:149–165. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
6-12

True, D. 1958. An early complex in San Diego County, California. American Antiquity 23(3):255–263. 

Tu, M., C. Hurd, and J.M. Randall. 2001. Weed control methods handbook: Tools and techniques for 

use in natural areas. Available at http://tncweeds.ucdavis.edu, accessed July 11, 2005. April 

2001. 

TVA (Tennessee Valley Authority). 2004. Programmatic environmental impact statement, Tennessee 

Valley Authority reservoir operations study. http://www.tva.gov/environment/reports/ROS_eis, 

accessed May 4, 2005. Tennessee Valley Authority, Knoxville, TN. May, 2004. 

Uchytil, R.J. 1992. Typha latifolia. In: Fire Effects Information System. 

http://www.fs.fed.us/database/feis, accessed July 11, 2005. U.S. Forest Service Rocky Mountain 

Research Station, Fire Sciences Laboratory (Producer). 

Uchytil, R.J. 1989. Salix exigua. In: Fire Effects Information System. 

http://www.fs.fed.us/database/feis, accessed July 11, 2005. U.S. Forest Service Rocky Mountain 

Research Station, Fire Sciences Laboratory (Producer). 

U.S. Census Bureau. 2005. State and county quickfacts—Data derived from population estimates, 2000 

census of population and housing, 1990 census of population and housing, small area income and 

poverty estimates, county business patterns, 1997 economic census, minority- and women-owned 

business, building permits, consolidated federal funds report, 1997 census of governments. U.S. 

Census Bureau web page. http://quickfacts.census.gov/qfd/states/06/06059.html, accessed May 

19, 2005, updated February 1, 2005. U.S. Census Bureau. 

U.S. Bureau of the Census. 2000a. U.S. Census Bureau California quickfacts. 

http://quickfacts.census.gov. U.S. Census Bureau. 

U.S. Census Bureau. 2000b. U.S. Census Bureau DP-3 (Profile of Selected Economic Characteristics: 

2000), Census 2000 Summary File 3 (SF3) – Sample Data. http://factfinder.census.gov. U.S. 

Census Bureau. 

U.S. Census Bureau. 2000c. GCT-P14. U.S. Census Bureau income and poverty in 1999:2000, Census 

2000 Summary File 3 (SF 3) – Sample Data. http://factfinder.census.gov. U.S. Census Bureau. 

U.S. Census Bureau. 2000d. U.S. Census Bureau People quickfacts web site. 

http://quickfacts.census.gov, accessed May 25, 2005. U.S. Census Bureau. 

U.S. Census Bureau. 2000e. U.S. Census Bureau Table GCT-PH1, Population, housing units, area, and 

density: 2000, Census 2000 Summary File 1 (SF 1) web site. http://factfinder.census.gov. U.S. 

Census Bureau. 

U.S. Census Bureau. 2000f. U.S. Census Bureau Table GCT-PL, Race and Hispanic or Latino:2000. 

Census 2000 Redistricting Date Summary File. Available online at http://factfinder.census.gov. 

U.S. Census Bureau. 

USFS (U.S. Forest Service). 2005a. Cleveland National Forest land management plan. Available at 

http://www.fs.fed.us/r5/scfpr/projects/lmp/index.htm, accessed on September 28, 2005. Last 

updated on September 20, 2005. U.S. Department of Agriculture. U.S. Forest Service, Pacific 

Southwest Region. September. 

USFS. 2005b. Final environmental impact statement for revised land management plans: Angeles 

National Forest, Cleveland National Forest, Los Padres National Forest, San Bernardino National 

Forest. U.S. Forest Service, Pacific Southwest Region, R5-MB-085. September 2005. 

USFS (U.S. Forest Service). 2005. Press release: Volunteers needed to count bald eagles. 

http://www.fs.fed.us/r5/sanbernardino/documents/baldeagle.pdf, accessed April 25, 2005. 

Mountain Top Ranger District, U.S. Forest Service, Fawnskin, CA. March 7, 2005. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
6-13

USFS. 2004. Foothill/Crown Fire narrative and summary. 

http://www.fs.fed.us/r5/angeles/incident/foothill/summary.html, accessed May 20, 2005. U.S. 

Forest, Service, Angeles National Forest, Arcadia, CA. 

USFS. 2003. Places. Paper distributed by at Forest Service open house. March 8, 2003. 

USFS. 2002a. National visitor use monitoring results. Region 5, Cleveland National Forest, U.S. Forest 

Service. August 2002. 

USFS. 2002b. Final environmental impact statement—AEP 765 kV transmission line: American Electric 

Power transmission line construction, Jackson Ferry, Virginia to Oceana, West Virginia. U.S. 

Forest Service. December 2002. (not seen, cited in Elsinore Valley MWD and Nevada Hydro, 

2004) 

USFS. 2000. Water quality management for Forest System Lands in California—best management 

practices. Available at: 

http://www.fs.fed.us/r5/publications/water_resources/waterquality/water-best-mgmt.pdf, accessed 

August 14, 2005. U.S. Forest Service, Pacific Southwest Region. September 2000. 

USFS. 1994, with minor revisions 2004. Cleveland National Forest Map. Forest Supervisor’s Office, 

San Diego, CA. 

USFS. 1990. 1990 ROS primer and field guide. R6-REC-021-90. U.S. Forest Service, Portland, OR. 

USGS (U.S. Geological Survey). 2005a. USGS Earthquake Hazards Program web site. Partial report for 

Elsinore fault zone, Temecula section (Class A) no. 126d. 

http://qfaults.cr.usgs.gov/faults/FMPro?-db=us%20web%20fault%20database&-

format=record2_detail.htm&-lay=scientist%20input&-recid=35116&-find, updated May 18, 

2005, accessed on May 19, 2005. Earthquake Hazards Program, U.S. Geological Survey. 

USGS. 2005b. Daily streamflow for the nation: California web page. 

http://waterdata.usgs.gov/nwis/discharge, accessed on May 23, 2005. U.S. Geological Survey, 

Reston, VA. 

USGS. 2005c. USGS West Nile virus maps: California—Bird web site. 

http://westnilemaps.usgs.gov/2004/ca bird.html, accessed May 3, 2005. U.S. Geological Survey. 

USGS. 2005d. USGS West Nile virus maps: California—Human web site. 

http://westnilemaps.usgs.gov/2004/ca human.html, accessed May 3, 2005.U.S. Geological 

Survey. 

USGS. 2005e. Highest peak flow: California web page. http://nwis.waterdata.usgs.gov/nwis/peak?site 

no=11072100&agency cd=USGS&format=html. U.S. Geological Survey. 

USGS. 2004. North American breeding bird survey. Internet data set 19 October 2004. 

http://www.pwrc/usgs.gov/bbc/retrieval/. U.S. Geological Survey, Patuxent Wildlife Research 

Center. 

Wallace, W. 1978. Post Pleistocene archeology, 9000 to 2000 B.C. Handbook of North American 

Indians 8:26–36. Smithsonian Institution, Washington, DC. 

Water Tech (Water Tech.online). 2005. Southern California water plan approved by Congress. 

Available at: http://www.watertechonline.com/News.asp?mode+4&N_ID=57764, accessed 

October 19, 2005. 

WDFW (Washington Department of Fish and Wildlife). 2005. WDFW fish passage technical assistance: 

Washington State fish screening unit costs website. 

http://wdfw.wa.gov/hab/engineer/scrnunit.htm, accessed January 6, 2006. Washington 

Department of Fish and Wildlife, Olympia, WA. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
6-14

Weatherhead, P.J. and K.A. Prior. 1992. Preliminary observations of habitat use and movements of the 

eastern massasauga rattlesnake (Sistrurus catenatus). J. Herp. 26:447–452. 

WECC (Western Electricity Coordinating Council). 2005. 10-year coordinated plan summary: Planning 

and operation for Electric System Reliability. Western Electricity Coordinating Council. 

September 2005. 

Wemple, B., J.A. Jones, and G.E. Grant. 1996. Channel network extension by logging roads in two 

basins, western Cascades, Oregon. Water Resources Bulletin 32(6): 1195–1207. 

World Health Organization. 2002. Establishing a dialogue on risks from electromagnetic fields. 

Available at: www.WHO.int/peh-emf/publications/risk_hand/en/index.html, accessed on October 

4, 2005. Radiation and Environmental Health, Department of Protection of the Human 

Environment, World Health Organization, Geneva, Switzerland. 41 pp. 

Wydoski, R. and R. Whitney. 2003. Inland fishes of Washington. Second Edition. University of 

Washington Press, Seattle, WA. 

Zeiner, D.C., W.F. Laudenslayer, Jr., K.E. Mayer, M. White (eds.). 1990. California’s wildlife: Volume 

2, Birds. California Department of Fish and Game, Sacramento, CA. 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
COVER SHEET 

FEDERAL ENERGY REGULATORY COMMISSION 

FINAL ENVIRONMENTAL IMPACT STATEMENT 

FOR HYDROPOWER LICENSE 

Lake Elsinore Advanced Pumped Storage Project 

Docket No. P-11858-002 

Section 7 

List of Preparers 

Pages 7-1 through 7-2 

FEIS 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
7-1 

7.0 LIST OF PREPARERS 

Federal Energy Regulatory Commission 

James Fargo—Project Coordinator/Engineering (Civil Engineer; M.S., Civil Engineering) 

Ken Hogan—Geology and Soils, Water Resources, and Fisheries (Fishery Biologist; B.S., Fisheries 

Management and Aquaculture) 

Alan Mitchnick—Threatened and Endangered Species (Environmental Biologist; M.S., Wildlife and 

Fisheries Sciences 

Ann-Ariel Vecchio—Terrestrial and Threatened and Endangered Species (Terrestrial Biologist; B.A. 

Environmental Studies and International Relations; M.P.A Environmental Science and Policy) 

Frank Winchell—Cultural Resources (Archeologist; B.A., M.A., Ph.D., Anthropology) 

Louis Berger Group 

Martha Bowers—Cultural Resources (Architectural Historian; M.A., American History) 

Steven Eget—Air Quality (Air Quality Specialist; M.S., Environmental Engineering, B.S., Civil and 

Environmental Engineering) 

Eric Ginney—Geology and Soils (Senior Geomorphologist; M.S., Environmental Geomorphology; 

B.S., Geosciences [Hydrology and Environmental Science]; B.A., Geography and Planning) 

Ellen Hall—Land Use and Socioeconomics (Economist; Ph.D., Natural Resource Economics; M.Ag., 

Agricultural Economics; B.A., History) 

Coreen Johnson—Editorial Review (Technical Editor; B.A., English Education) 

John Hart—Water Quantity (Hydrologist; B.A., Physics) 

Mark Killgore—Engineering, Economics, and Water Quantity (Water Resources Engineer; M.S.C.E., 

Water Resources Engineering; B.C.E., Civil Engineering; B.A., Liberal Arts) 

William Koogler—Engineering, High-Voltage Transmission and Substation Engineering (Electrical 

Engineer, B.S., Electrical Engineering) 

Marcelle Lynde—Aquatic Resources and Threatened and Endangered Species (Fisheries Biologist; 

B.S. Fisheries, M.M.A. Marine Resource Management) 

Eileen McLanahan—Terrestrial Resources and Threatened and Endangered Species (Terrestrial 

Biologist; B.S., Biology; M.S., Biology) 

Robert Mohn—Senior Technical Review and Economics (B.S., Engineering; M.P.A., Environmental 

Policy) 

Jot Splenda—Water Quality, Recreation, and Aesthetics (M.E.S.M., Water Resources; B.S., Ecology 

and Evolution) 

Pat Weslowski—Task Manager (Preservation Planner; Master of Public Administration) 

Chris Wilson—Senior Technical Review, Engineering (Senior Civil/Hydrotechnical Engineer, B.S., 

Civil Engineering)

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
7-2 

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Document Accession #: 20070130-4000 Filed Date: 01/30/2007
COVER SHEET 

FEDERAL ENERGY REGULATORY COMMISSION 

FINAL ENVIRONMENTAL IMPACT STATEMENT 

FOR HYDROPOWER LICENSE 

Lake Elsinore Advanced Pumped Storage Project 

Docket No. P-11858-002 

Section 8 

List of Recipients 

Pages 8-1 through 8-28 

FEIS 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-1 

8.0 LIST OF RECIPIENTS 

Party Name/Address Party Name/Address 

Dawn Davila 

Ace Federal Reporting 

8096 La Crosse Way 

Riverside, CA 92508-6142 

Suma Peesapati, Associate 

Adams Broadwell Joseph & Cardozo 

651 Gateway Blvd., Suite 900 

South San Francisco, CA 94080 

George G. Alongi 

32941 Mountain View Ave 

Lake Elsinore, CA 92530-4612 

Bonnie S. Blair, Esquire 

Thompson Coburn LLP 

1909 K Street NW, Suite 600 

Washington, DC 20006-1167 

Marcie Edwards, General Manager 

City of Anaheim 

Public Utilities Department 

201 S. Anaheim Blvd, CHW, 11th Floor 

Anaheim, CA 92805-3826 

Al Anderson 

38680 Calle de Lobo 

Murrieta, CA 92562-8861 

Kristine M. Anderson 

22266 Walnut Drive 

Wildomar, CA 92595-8904 

Donald E. Ash 

1131 Mill Street 

Lake Elsinore, CA 92530-4327 

Ruth Atkins 

15237 Lake Trail Cir 

Lake Elsinore, CA 92530-7310 

Gus Ayer 

17135 Reimer Street 

Fountain Valley, CA 92708-3807 

Lisa G. Urick 

Managing Attorney 

Sempra Energy, Inc. 

555 W. Fifth Street 

Los Angeles, CA 90013-1011 

Greg Bain 

72 Glen Arbor 

Irvine, CA 92602-1668 

Tim Earheart, Public Works Director 

City of Banning, 

176 E. Lincoln Street 

Banning, CA 92220-4962 

Thomas P. Evans, Director 

City of Riverside, 

3900 Main Street 

Public Utilities Department 

Riverside, CA 92522-0001 

Jack Barth 

1146 Moreno Way 

Placentia, CA 92870-5225 

Mark Bates 

16875 Monterey Rd 

Lake Elsinore, CA 92530-7528 

Joan Becktel 

29621 Monarch Drive 

San Juan Capistrano, CA 92675-1425 

Bennett William 

The Californian 

5990 Dandridge Lane, Unit 167 

San Diego, CA 92115-6578 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-2 

Party Name/Address Party Name/Address 

Phillip G. Berg 

Crane Lakeside Park & Resort 

15980 Grand Ave. 

Lake Elsinore, CA 92530-5613 

Keele Bertek 

143 N. Pennsylvania Street 

Lake Elsinore, CA 92530-1824 

David Bertoldo 

33019 Buena Vista Street 

Lake Elsinore, CA 92530-1412 

Edward L. Bertrand 

3750 University Ave. 

Riverside, CA 92501-3366 

Charity Schiller 

Best, Best & Krieger 

PO Box 1028 

Riverside, CA 92502-1028 

Rick Bingham 

34800 El Dorado Street 

Lake Elsinore, CA 92530-7540 

Chris Binkley 

19680 Avenida Presa 

Murrieta, CA 92562-7128 

Barbara Bowers 

38865 Avenida La Cresta 

Murrieta, CA 92562-9155 

James Bradley 

2658 Griffith Park Blvd, Unit 122 

Los Angeles, CA 90039-2520 

Gary Brock 

4 Via Belleza 

San Clemente, CA 92673-6910 

John E. Brown 

3750 University Ave 

Riverside, CA 92501-3366 

Russ Brown 

27567 Via Fortuna 

San Juan Capistrano, CA 92675-5355 

Dale Buckeridge 

16037 Via Sola 

Lake Elsinore, CA 92530-1448 

Tom Dang 

Bureau of Indian Affairs 

Department of the Interior 

2800 Cottage Way 

Sacramento, CA 95825-1846 

State of California 

California Air Resources Board 

P.O. Box 2815 

Sacramento, CA 95812-2815 

Director 

California Department of Water Resources 

P.O. Box 942836 

Sacramento, CA 94236-0001 

Environmental Analyst 

California Dept. of Conservation 

MS 24-01 

801 K Street 

Sacramento, CA 95814-3500 

Mike Meinz 

FERC Relicensing Coordinator 

California Dept. of Fish and Game 

1701 Nimbus Road, Suite A 

Rancho Cordova, CA 95670-4503 

Regional Manager 

California Dept. of Fish and Game 

1234 E. Shaw Ave. 

Fresno, CA 93710-7802 

Water Rights & FERC Coordinator 

California Dept. of Fish and Game 

P.O. Box 944209 

Sacramento, CA 94244-2090 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-3 

Party Name/Address Party Name/Address 

Resource Mgmt. Division, Chief 

California Dept. of Parks & Recreation 

P.O. Box 942896 

Sacramento, CA 94296-0001 

State of California 

California Fish & Game Commission 

Attn: Environmental Services Division 

1416 9th Street 

Sacramento, CA 95814-5511 

Jeffrey C. Miller 

California Independent System Oper. Corp 

151 Blue Ravine Road 

Folsom, CA 95630-4704 

Anthony J. Ivancovich, Senior Regulatory 

Counsel 

California ISO Corporation 

151 Blue Ravine Road 

Folsom, CA 95630 

Celia Kutcher 

California Native Plant Society 

Orange County Chapter 

34681 Calle Los Robles 

Capistrano Beach, CA 92624-1524 

Matthew R. Campbell 

California Office of Attorney General 

1300 I Street, # 125 

Sacramento, CA 95814-2919 

State of California 

Attorney General 

California Office of Attorney General 

300 S Spring Street, Floor 2 

Los Angeles, CA 90013-1230 

Cherilyn E. Widell, Director 

California Office of Historic Preser. 

P.O. Box 942896 

Sacramento, CA 94296-0001 

Secretary 

California Public Utilities Commission 

505 Van Ness Ave. 

San Francisco, CA 94102-3214 

Director 

California State Lands Commission 

Suite 100-South 

100 Howe Ave. 

Sacramento, CA 95825-8202 

James Canaday, Senior Environmental Scientist 

California State Water Resources Control Board 

P.O. Box 2000 

Sacramento, CA 95812-2000 

Kathy Mrowka 

California State Water Resources Control Board 

P.O. Box 2000 

Sacramento, CA 95812-2000 

George S. Cambero 

21584 Grand Ave. 

Wildomar, CA 92595-9561 

Paul Carlton 

3280 Paseo Gallita 

San Clemente, CA 92672-3520 

Roberta Christ 

18020 Tenaja Road 

Murrieta, CA 92562-9184 

John Freiman, City Planner 

City of Lake Canyon 

Suites 101 and 103 

31532 Railroad Canyon Road 

Canyon Lake, CA 92587-9437 

Pat Kilroy 

City of Lake Elsinore 

130 S. Main Street 

Lake Elsinore, CA 92530-4109 

Armando G Villa 

City of Lake Elsinore 

130 S. Main Street 

Lake Elsinore, CA 92530-4109 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-4 

Party Name/Address Party Name/Address 

Barbara Leibold, City Attorney 

City of Lake Elsinore 

130 South Main Street 

Lake Elsinore, CA 92530 

Dick Watenpaugh, City Manager 

City of Lake Elsinore 

130 S. Main Street 

Lake Elsinore, CA 92530-4109 

Marlene Best, Asst. City Manager 

City of Lake Elsinore 

130 S. Main Street 

Lake Elsinore, CA 92530-4109 

Bob Brady 

City of Lake Elsinore 

130 S. Main Street 

Lake Elsinore, CA 92530-4109 

LeeAnn Uhler, Projects/Contracts Mgr. 

City of Riverside 

2911 Adams Street 

Riverside, CA 92504-4303 

Charlene Cleary 

15990 Annette Drive 

Lake Elsinore, CA 92530-5606 

Tina Terrell, Forest Supervisor 

Cleveland National Forest 

10845 Rancho Bernardo Road, 

Suite 2000 

San Diego, CA 92127-2107 

Mary L. Thomas 

Cleveland National Forest 

1147 E. 6th Street 

Corona, CA 92879-1616 

Thomas K. Clarke 

Colton Electric Department 

160 S. 10th Street 

Colton, CA 92324-3406 

Joseph F. Hsu, Director 

Azusa Light, Power & Water 

729 N Azusa Ave. 

P.O. Box 9500 

Azusa, CA 91702-9500 

Donn Furman 

Executive Director 

Committee To Save The Kings River 

P.O. Box 4221 

Fresno, CA 93744-4221 

David Compas 

39 Villa Valtelena 

Lake Elsinore, CA 92532-0110 

Rhonda King 

County of Riverside 

Deputy County Executive Office 

4080 Lemon Street, Floor 4 

Riverside, CA 92501-3679 

Kim Cousins 

14395 Amorose Street 

Lake Elsinore, CA 92530-7423 

Craig G. Cowie 

U.S. Forest Service 

10845 Rancho Bernardo Rd, Suite 200 

San Diego, CA 92127-2107 

Michael Crews 

13530 Fairfield Drive 

Corona, CA 92883-6631 

Jerome Daoust 

6002 Camino Tierra 

San Clemente, CA 92673-6402 

Linda L. Dreier 

33455 Brand Street 

Lake Elsinore, CA 92530-5779 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-5 

Party Name/Address Party Name/Address 

Herman Dreier 

33455 Brand Street 

Lake Elsinore, CA 92530-5779 

Barbara Dye 

33127 Dowman Street 

Lake Elsinore, CA 92530-6078 

Bill Soderquist, Secretary 

Elsinore Hang Gliding Association 

39481 Oak Cliff Dr 

Temecula, CA 92591-4520 

Rexford J. Wait, Vice President 

Hydro Company, Inc. dba Nevada Hydro Com 

2416 Cades Way 

Vista, CA 92083-7830 

D.J. Laughlin 

Elsinore Valley Municipal Water District 

P.O. Box 3000 

Lake Elsinore, CA 92531-3000 

Arnold B. Podgorsky, Esquire 

Wright & Talisman, P.C. 

1200 G Street NW, Suite 600 

Washington, DC 20005-3814 

Ronald Young 

Elsinore Valley Municipal Water District 

31315 Chaney Street 

Lake Elsinore, CA 92530-2743 

Bill Estenger 

34655 Arroyo Rd 

Lake Elsinore, CA 92530-7512 

Robin Everett 

Sierra Club 

2000 Parsons Street Apt 8 

Costa Mesa, CA 92627-2064 

Edward J. Perez 

Federal Energy Regulatory Commission 

101 SW Main Street Suite 905 

Portland, OR 97204-3217 

Regional Engineer 

Federal Energy Regulatory Commission 

Portland Regional Office 

101 S.W. Main Street, Suite 905 

Portland, OR 97204-3217 

Keith Fletcher 

12 Gifford Pinchot Street 

Lake Elsinore, CA 92530-6602 

Keith Fletcher 

1147 E. 6th Street 

Corona, CA 92879-1616 

Seth Foerster 

758 Via Otono 

San Clemente, CA 92672-6018 

Bob Fraser 

1536 E. Washington Ave. 

Santa Ana, CA 92701-3246 

Stephen M. Bowes, Planner 

National Park Service 

1111 Jackson Street 

Oakland, CA 94607 

Gene Frick 

Friends of the Forest 

4271 Baggett Drive 

Riverside, CA 92505 

Elin Motherhead, Secretary 

Friends of the Forest, Trabuco District 

18575 Vista de Montanas 

Murrieta, CA 92562-7138 

John Garrett 

32851 Alderbrook Road 

Wildomar, CA 92595-8249 

William Garrigues 

18675 La Ventana 

Murrieta, CA 92562-8894 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-6 

Party Name/Address Party Name/Address 

Michael Ghafouri 

P.O. Box 97 

Temecula, CA 92593-0097 

Joseph J. Kulikowski 

Genterra Consultants Inc. 

15375 Barranca Pkwy, Suite K102 

Irvine, CA 92618-2211 

Pete Gomben 

12311 Old Pomerado Road, Apt. 4 

Poway, CA 92064-5350 

Garry Grant 

27068 Jarvis Street 

Perris, CA 92570-6948 

Donna Guzman 

17540 Bodkin Ave. 

Lake Elsinore, CA 92530-5728 

Mike Guzman 

17540 Bodkin Ave. 

Lake Elsinore, CA 92530-5728 

John Guzman, Sr. 

17540 Bodkin Ave. 

Lake Elsinore, CA 92530-5728 

Linda Hale 

31318 Euclid Loop 

Winchester, CA 92596-8704 

Bob Hank 

34747 Ortega Highway 

Lake Elsinore, CA 92530-6516 

Rick Gelormino 

LaCresta Highlands Association 

40333 Hidden Meadow Circle 

Murrieta, CA 92562 

Tom & Sandra Hansen 

31480 Nicolas Road 

Temecula, CA 92591-7249 

Bo Hansson 

24217 Calle Artino 

Murrieta, CA 92562-5577 

Mike Harper 

24582 del Prado, Apt. 211 

Dana Point, CA 92629-3816 

Larry and Carol Hasty 

14130 N. Main Divide Road 

Lake Elsinore, CA 92530-6534 

Keith Haworth 

33858 Amberton Street 

Wildomar, CA 92595-8763 

Michael A Hilberath 

27641 Sweetbrier Lane 

Mission Viejo, CA 92691-6673 

Francis X. Hoffman 

E-Team, Inc. 

33370 Westlong Drive 

Lake Elsinore, CA 92530-5546 

Linda Hoffman 

32471 Ortega Highway 

Lake Elsinore, CA 92530-6564 

Zachary Hoisington 

257 Santa Ana Ave., Apt B 

Long Beach, CA 90803-3569 

Johanna E. Howard 

17540 Grand Ave. 

Lake Elsinore, CA 92530-5872 

Kenneth N. Howard 

17540 Grand Ave. 

Lake Elsinore, CA 92530-5872 

John (Tao) Hurst 

11969 Oakview Way 

San Diego, CA 92128-5295 

Jay W. Scott 

22074 Country Hills Dr. 

Wildomar, CA 02595 

Christine Hyland 

15191 Wavecrest Drive 

Lake Elsinore, CA 92530-5391 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-7 

Party Name/Address Party Name/Address 

Charles L. Shreves, General Manager 

Imperial Irrigation District 

P.O. Box 937 

Imperial, CA 92251-0937 

Peter Jones 

18975 Hombre Lane 

Murrieta, CA 92562 

Joan P. Johnson 

35150 El Niguel Road 

Lake Elsinore, CA 92530-7501 

Lana Johnson 

35150 El Niguel Road 

Lake Elsinore, CA 92530-7501 

Erika Jones 

35105 Loma Road 

Lake Elsinore, CA 92530-7515 

Mark Jones 

35105 Loma Road 

Lake Elsinore, CA 92530-7515 

John Kalachian 

350 Los Altos Ave. 

Long Beach, CA 90814-1906 

Vera Kalachian 

350 Los Altos Ave. 

Long Beach, CA 90814-1906 

Roy Kellogg 

16755 Monterey Road 

Lake Elsinore, CA 92530-7511 

Nancy K. Kensic 

39370 Avenida Bonita 

Murrieta, CA 92562-9157 

Stanley O. Kensic 

39370 Avenida Bonita 

Murrieta, CA 92562-9157 

John W. Kirk 

33700 Ortega Highway 

Lake Elsinore, CA 92530-6551 

Ric Olalde 

Kleinfelder Inc 

1220 Research Drive, Suite B 

Redlands, CA 92374-4563 

Wendy P. Kolk 

333 W. Limited Street 

Lake Elsinore, CA 92530-3746 

Martin Kreisler 

13160 Bay Meadows Court 

Corona, CA 92883-8408 

Harvey Dorland, President 

La Cresta Highlands Homeowners Association 

18590 Hombre Lane 

Murrieta, CA 92562-7136 

Fletcher Satterwhite, President 

La Cresta Property Owners Association 

42430 Winchester Road 

Temecula, CA 92590-2504 

David Lovingier 

Lake Elsinore Unified School District 

545 Chaney Street 

Lake Elsinore, CA 92530-2712 

Gayle Larsson 

17721 Rodeo Road 

Lake Elsinore, CA 92530-7527 

Curtis LeBlanc 

40214 Via Marisa 

Murrieta, CA 92562-5543 

Anna J. Lee 

33628 Landerville Blvd. 

Lake Elsinore, CA 92530-5763 

Gil Lerma 

16812 Grand Ave. 

Lake Elsinore, CA 92530-1403 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-8 

Party Name/Address Party Name/Address 

Vicki Long 

40390 Via Caballos 

Murrieta, CA 92562-9315 

Mark Lovich 

34501 S. Main Divide Road 

Lake Elsinore, CA 92530-6528 

Ken Lord 

200 Commerce 

Irvine, CA 92602-1318 

Barbara Magan 

18322 Grand Ave. 

Lake Elsinore, CA 92530-6134 

Ben Keasler 

ac/s ES 

Marine Corps Base 

Camp Pendleton, CA 92055 

Larry Rannals 

Marine Corps Base 

Box 555010 

Camp Pendleton, CA 92055 

Herb Massdwoen 

39300 Redondo Mesa Rd 

Murrieta, CA 92562-7385 

JoAnn McCracken 

33040 Dowman Street 

Lake Elsinore, CA 92530-6029 

Paul McGinnis 

32476 El Cariso Road 

Lake Elsinore, CA 92530-6505 

Lisa McIntyre 

34475 S. Main Divide Road 

Lake Elsinore, CA 92530-7542 

Kathleen Mead 

34561 S Main Divide Road 

Lake Elsinore, CA 92530-6528 

Irene Meyer 

3582 Hatfield Cir 

Oceanside, CA 92056-4902 

Robert Moore 

33648 Brand Street 

Lake Elsinore, CA 92530-5741 

Greg A. Morrison 

31315 Chaney Street 

Lake Elsinore, CA 92531 

Hugh and Jean Mosbachsi 

600 3rd Street 

Lake Elsinore, CA 92530-2748 

Roni J. Dickerson, Senior Legal Typist 

1001 I Street 

Sacramento, CA 95814 

Jim Miller, Director 

City of Murrieta 

26442 Beckman Ct 

Murrieta, CA 92562-7022 

Dina and Ferenc Nagy 

520 Cliff Drive, Apt 304 

Laguna Beach, CA 92651-1481 

Regional Director 

National Marine Fisheries Service 

501 W Ocean Blvd, Suite 4200 

Long Beach, CA 90802-4221 

Alan Schmierer 

National Park Service 

1111 Jackson Street, Suite 700 

Oakland, CA 94607-4807 

Southern California Hydro Coordinator 

National Park Service 

1111 Jackson Street, Suite 700 

Oakland, CA 94607-4807 

Brandi L. Bradford, Hydro Program Coordinator 

National Park Service 

1111 Jackson Street, Suite 700 

Oakland, CA 94607-4807 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-9 

Party Name/Address Party Name/Address 

Salman Nawaz 

24602 Polaris Drive 

Dana Point, CA 92629-1778 

David Kajes 

Nevada Hydro 

3510 Unocal Place, Suite 200 

Santa Rosa, CA 95403-0918 

Steve Niedziela 

2765 Taylor Ave. 

Corona, CA 92882-5931 

Madeleine O’Leary 

15158 Chaumont Street 

Lake Elsinore, CA 92530-7326 

Thomas B. Matthews, Director 

Orange County 

P.O. Box 4048 

Santa Ana, CA 92702-4048 

Mike Palmer 

33281 Ortega Highway 

Lake Elsinore, CA 92530-6554 

Phil Paule 

1800 Thibodo Road, Suite 310 

Vista, CA 92081-7515 

Olivia Gutierrez, Director 

City of Perris 

101 N. D Street 

Perris, CA 92570-1917 

Cherie Peterson 

P.O. Box 252 

Wildomar, CA 92595-0252 

Robert O. Peterson 

P.O. Box 252 

Wildomar, CA 92595-0252 

Kathleen A. Smith, Clerk of the Board 

Placer County Water Agency 

P.O. Box 6570 

Auburn, CA 95604-6570 

Bill Plummer 

44025 Tenaja Road 

Murrieta, CA 92562-7335 

Cowan A. Plummer 

44025 Tenaja Road 

Murrieta, CA 92562-7335 

Diane Plummer 

44025 Tenaja Road 

Murrieta, CA 92562-7335 

Ferenc Raksi 

53 Rockview 

Irvine, CA 92612-3244 

Amalia and Hal Ramser 

39100 Avenida La Cresta 

Murrieta, CA 92562-9233 

Kathleen Recker, Sr. Planner 

City of Rancho Santa Margarita 

30211 Avenida de Las Bandera 

Rancho Santa Margarita, CA 92688-2132 

Bradley Powell, Regional Forester 

Pacific SW Region 5, MRM-Lands Staff 

1323 Club Drive 

Vallejo, CA 94592-1110 

Dave Woelfel 

Regional Water Quality Control Board 

42347 Dusty Trail 

Murrieta, CA 92562-5213 

State of California 

Resources Agency of California 

Room 1311 

1416 9th Street 

Sacramento, CA 95814-5511 

Linda Ridenour 

33628 Brand Street 

Lake Elsinore, CA 92530-5741 

Martin E. Ridenour 

33628 Brand Street 

Lake Elsinore, CA 92530-5741 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-10 

Party Name/Address Party Name/Address 

Katherine Gifford, Management Analyst 

Riverdale County Executive Office 

4080 Lemon Street, Floor 4 

Riverside, CA 92501-3679 

Richard Lashbrook, Director 

City of Riverside 

P.O. Box 1605 

Riverside, CA 92502-1605 

Harry Ryan 

17000 Grand Ave. 

Lake Elsinore, CA 92530-5755 

Harvey R. Ryan 

17561 Sunnyslope Ave. 

Lake Elsinore, CA 92530-3049 

David Hanson, Project Manager 

Sacramento Municipal Utility District 

P.O. Box 15830 

Sacramento, CA 95852-1830 

Terry Wold, Manager 

San Gorgonio Chapter of the Sierra Club 

4079 Mission Inn Ave. 

Riverside, CA 92501-3204 

Eileen C. Sarace 

38400 Via Vista Grande 

Murrieta, CA 92562-9242 

Leroy Saunders 

13748 Buckskin Trail Drive 

Corona, CA 92883-6607 

Linda R. Scoles 

615 Le Harve Ave. 

Lake Elsinore, CA 92530-5386 

Heidi Sheldon 

43242 Calle Collado 

Murrieta, CA 92562-9211 

Stuart Sheldon 

Shledon, Stuart 

43242 Calle Collado 

Murrieta, CA 92562-9211 

Leonard J. Skarvan 

33110 Buena Vista Street 

Lake Elsinore, CA 92530-1462 

John Slemmer 

1685 Halsey Street 

Redlands, CA 92373-7262 

Kelly Smith 

39100 Vista del Bosque 

Murrieta, CA 92562-8606 

Lou Smith 

38717 Bears Paw Drive 

Murrieta, CA 92562-3011 

Benjamin R. Grentis 

29358 3rd Street 

Lake Elsinore, CA 92532 

Mohan Kondragunta 

Southern California Edison Company 

2244 Walnut Grove Ave. 

GO3, 3rd Floor 

Rosemead, CA 91770-3714 

Ellen A. Berman, Attorney 

Southern California Edison Company 

2244 Walnut Grove Avenue 

P.O. Box 800 

Rosemead, CA 91770 

James Canaday, Sr. Env. Scientist 

State Water Resources Control Board 

P.O. Box 100 

Sacramento, CA 95812-0100 

Samantha K. Olson, Staff Counsel 

CA State Water Resources Control Board 

1001 I Street 

P.O. Box 100 

Sacramento, CA 95812-0100 

John and Soma Stickler 

P.O. Box 1543 

Wildomar, CA 92595-1543 

Paul Sulman 

41270 Calle Azul 

Murrieta, CA 92562-8643 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-11 

Party Name/Address Party Name/Address 

Len Szafaryn 

171 Rivo Alton Canal 

Long Beach, Ca 90803 

Debbie Ubnoske, Director 

City of Temecula, 

P.O. Box 9033 

Temecula, Ca 92589-9033 

Peter Lewandowski 

The Nevada Hydro Company 

2416 Cades Way 

Vista, CA 92081-7830 

Edwin Thorell 

P.O. Box 611 

Lake Elsinore, CA 92531-0611 

Timothy R. McCullough 

General Manager 

Toulumne Utilities District 

P.O. Box 3728 

Sonora, CA 95370-3728 

Charlton H. Bonham 

Hydropower Coordinator 

Trout Unlimited 

828 San Pablo Ave., Suite 208 

Albany, CA 94706-1678 

Virgil W. Mink 

U.S. Forest Service 

1147 E. 6th Street 

Corona, CA 92879-1616 

Chief 

U.S. Army Corps of Engineers 

San Francisco District Office 

333 Market Street, Floor 8 

San Francisco, CA 94105-2102 

Fred Allgaier 

U.S. Bureau of Indian Affairs 

3000 Youngfield Street. Suite 230 

Lakewood, CO 80215-6551 

Area Director 

U.S. Bureau of Indian Affairs 

2800 Cottage Way 

Sacramento, CA 95825-1846 

Director 

U.S. Bureau of Land Management 

California State Office 

2800 Cottage Way, Suite W1834 

Sacramento, CA 95825-1886 

Regional Director 

Attn: LC 705 

U.S. Bureau of Reclamation 

P.O. Box 61470 

Boulder City, NV 89006-1470 

Jack Gipsman, Attorney 

U.S. Department of Agriculture 

Office of General Counsel 

33 New Montgomery Street, Floor 17 

San Francisco, CA 94105-4506 

Jennifer L. Frozena 

U.S. Department of the Interior 

1849 C Street NW, Mailstop 6557 

Washington, DC 20240-0001 

David P. Schmidt 

CMD-2 

U.S. Environmental Protection Agency 

Region 9 - Federal Activities Office 

75 Hawthorne Street 

San Francisco, CA 94105-3920 

Supervisor 

U.S. Fish and Wildlife Service 

ARCATA FWO 

1655 Heindon Road 

Arcata, CA 95521-4573 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-12 

Party Name/Address Party Name/Address 

Supervisor 

U.S. Fish and Wildlife Service 

2493 Portola Rd Suite B 

Ventura, CA 93003-7726 

Field Supervisor 

US Fish and Wildlife Service 

Room W-2605 

2800 Cottage Way 

Sacramento, CA 95825-1846 

Regional Director 

U.S. Fish and Wildlife Service 

Attn: FERC Coordinator 

911 NE 11th Ave 

Portland, OR 97232-4169 

FERC Coordinator 

U.S. Geological Survey 

Placer Hall—6000 J Street, Suite 2012 

Sacramento, 95819-6129 

Honorable Barbara Boxer 

U.S. Senate 

Washington, DC 20510 

Honorable Dianne Feinstein 

U.S. Senate 

Washington, DC 20510 

Benjamin R. Grentis 

29358 3rd Street 

Lake Elsinore, CA 92532 

John White 

13440 Goldenhorn Drive 

Corona, CA 92883-6654 

W. Ben Wicke 

22428 Whirlaway Court 

Canyon Lake, CA 92587-7626 

Phil Williams 

30365 Ainsworth Place 

Lake Elsinore, CA 92530-7419 

Brian Woods 

2 Ada Suite 200 

Irvine, CA 92618-2349 

Jose Carvajal 

28765 Single Oak Drive 

Temecula, CA 92590-3661 

Jack Burdy 

Elsinore Municipal Water District 

17807 Hayes Ave. 

Lake Elsinore, CA 92530-6157 

Eric Smith 

Ellsinore Municipal Water District 

32755 Morrison Pl. 

Lake Elsinore, CA 92530-6236 

Lyne Perry 

2157 Arnold Way, Apt. 724 

Alpine, CA 91901-2174 

Ms. Susan K. Hori 

Manatt, Phelps & Phillips, LLP 

695 Town Center Drive 

Costa Mesa, CA 92626 

Mr. John E. Young 

Sycamore Creek Marketplace, LLC 

3 Imperial Promenade, Suite 550 

South Coast Metro, CA 92707 

Ms. Ellen Hazinski 

29770 Blue Heron Court 

Canyon Lake, CA 

Mr. John E. Heggard (??) 

33241 Stoneman Street 

Lake Land Village 

Lake Elsinore, CA 92530 

Ms. Tina Grande, Senior Mgt Analyst 

County of Riverside 

4080 Lemon Street, 4th Floor 

Riverside, CA 92501 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-13 

Party Name/Address Party Name/Address 

Ms. Cheri Phelps,Vice President 

PBR 

7 Upper Newport Plaza Drive 

Newport Beach, CA 92660-8002 

Tamar C. Stein 

Cox, Castle & Nicholson LLP 

2049 Century Park East, Suite 2800 

Los Angeles, CA 90067 

James A. Diamond 

Davidson, Russ and Diamond 

1875 West Redondo Beach Blvd., Suite 301 

PO. Box 2017 

Gardena, CA 90247 

Ms. Sandra M. Weaver 

28672 Paseo Bahia 

San Juan Capistrano, CA 92675 

Ms. Lois Nisporic 

26655 Glen Eden Road 

Corona, CA 92883 

Dr. Christopher A.Wills 

Betty-Jo A. Wills 

11622 Vista Mar 

Santa Ana, CA 92705 

Mr. Dave Goodward, Conservation Chair 

San Bernardino Valley Audubon Society 

22430 Pico Street 

Grand Terrace, CA 92313 

Theodore H. & Katie Elaine Miller 

16699 Markham Street 

Riverside, CA 92504 

Mr. Roy Salameh 

2642 Unicornio St. 

Carlsbad, CA 92009 

Ms. Michelle Randall 

12401 Dawson Canyon Road 

Corona, CA 

Luis Stahl 

Empire Pre-Cast 

19473 Grand Ave. 

Lake Elsinore, CA 92530 

Michael Wayne Smith 

1288 East Vermont Ave. 

Anaheim, CA 92805 

Jon R. Johnson 

16765 Charro Rd. 

Lake Elsinore, CA 92530 

John & Karen Pecora 

16336 Union Ave. 

Lake Elsinore, CA 92530 

Gary Knapp, Treasurer 

Lake Elsinore Soaring Club 

P.O. Box 317 

Wildomar, CA 92596 

Tom Hazelleaf 

4656 Fir Ave. 

Seal Beach, CA 90740 

Richard W. & Margaret J. Long 

617 Narcissus Ave. 

Corona del Mar, CA 92625 

Arthur F. Coon 

Stephen E. Velyvis 

Miller, Starr & Regalia 

1331 N. California Blvd., 5th Floor 

Walnut Creek, CA 94596 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-14 

Party Name/Address Party Name/Address 

Robert L. Shipley 

Law Office of Robert L. Shipley 

5857 Owens Ave., Suite 200 

Carlsbad, CA 92008 

George H. (Greg) Williams, Jr. 

John J. Bartus 

Bracewell & Giuliani LLP 

2000 K Street, N.W., Suite 500 

Washington, DC 20006-1872 

Lynice Spangler 

33105 Oregon Street 

Lake Elsinore, CA 92530 

Ms. Edith Stafford 

29700 Hursh Street 

Lake Elsinore, CA 92530 

Mark Durham, Chief 

South Coast Section, Regulatory Branch 

Los Angeles District 

Army Corps of Engineers 

P.O. Box 532711 

Los Angeles, CA 90053-2325 

Willie R. Taylor, Director 

Office of the Secretary 

Office of Env. Policy & Compliance 

U.S. Dept. of the Interior 

1849 C Street, NW, MS 2342 – MIB 

Washington, DC 20240 

Mr. David Voss 

502 Springfield Ave. 

Oceanside, CA 92057 

Nick Bimbo 

16500 McPherson Circle 

Lake Elsinore, CA 92530 

Tom Gilmart 

16038 Shadybend Dr. 

Hal Heights, CA 91745 

Larry L. Eng, Ph.D. 

Regional Manager, Region 5 

California Dept. of Fish and Game 

4949 Viewridge Ave 

San Diego, CA 92123 

Curt Taucher 

Regional Manager, Region 6 

California Dept. of Fish and Game 

4949 Viewridge Ave 

San Diego, CA 92123 

Mark G. Adelson, Chief 

Regional Planning Programs Section 

California Reg. Water Quality Control Bd 

3737 Main Street, Suite 500 

Riverside, CA 92501-3348 

Bruce Campbell 

614 Gretna Green Way 

Los Angeles, CA 90049 

John Buse 

Center for Biological Diversity 

5656 S. Dorchester Ave., #3 

Chicago, IL 60637 

Ronald L. Tippets, Chief 

Environmental Planning Division 

County of Orange 

P.O. Box 4048 

300 N. Flower Street 

Santa Ana, CA 92702-4048 

Bob Buster, Chairman 

Riverside County Board of Supervisors 

County Administrative Center 

4080 Lemon Street, 5th Floor 

Riverside, CA 92501 

Peter H. Dawson 

18010 Grand Avenue 

Lake Elsinore, CA 92530-6066 

Dan Silver, Executive Director 

Engangered Habitats League 

8424-A Santa Monica Blvd., #592 

Los Angeles, CA 90069-4267 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-15 

Party Name/Address Party Name/Address 

The Honorable Duncan Hunter 

U.S. House of Representatives 

Washington, DC 20515 

The Honorable Ken Calvert 

U.S. House of Representatives 

Washington, DC 20515 

The Honorable Mary Bono 

U.S. House of Representatives 

Washington, DC 20515 

The Honorable Darrell Issa 

U.S. House of Representatives 

Washington, DC 20515 

Charles T. Jancic 

18950 Starvation Mt. Rd. 

Escondido, CA 92025 

Robert H. Konoske 

Susan E. Konoske 

32060 Baywood Street 

Lake Elsinore, CA 92532 

Dr. Frank W. Passarella, Superintendent 

Lake Elsinore Unified School District 

545 Chaney Street 

Lake Elsinore, CA 92530 

Kami Sabetzadeh 

21260 Cielo Vista Way 

Wildomar, CA 92595 

Barbara Harrison 

16755 Grand Ave. 

Lakeland Village, CA 92530 

Andrew K. Mauthe 

Sandra W. Mauthe 

35210 El Niguel Road 

Lake Elsinore, CA 92530 

James M. Birkelund, Senior Project Attorney 

NRDC 

1314 Second Street 

Santa Monica, CA 90401 

W. Scott Kardel 

Palomar Observatory 

California Institute of Technology 

P.O. Box 200 

Palomar Mountain, CA 92060-0200 

Gary P. Dubois, Cultural Resources Director 

Penchanga Indian Reservation 

Pechanga Cultural Resources 

Post Office Box 2183 

Temecula, CA 92592 

William Smith, Chairman 

Rancho Capistrano Property Owners Assoc. 

35240 Calle Grande 

Lake Elsinore, CA 92530 

Christopher P. Terzich, REA 

Senior Environmental Analyst 

SDGE, A Sempra Energy Utility 

8315 Century Park Court 

San Diego, CA 92123 

Christopher Adkins 

17700 Rodeo Rd. 

Lake Elsinore, CA 92530 

Marian Alexander 

6182 Saddle Tree Lane 

Yorba Linda, CA 92686 

Richard Amador 

P.O. Box 739 

Wildomar, CA 92595 

Dale Anderson 

310 Elizabeth Lane 

Corona, CA 92880 

Nguyen Anh 

21562 St. John Lane 

Huntington Beach, CA 92646 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-16 

Party Name/Address Party Name/Address 

Antelope Valley Land 

1718 Westwood Blvd. 

Los Angeles, CA 90024 

Walter Arnold 

P.O. Box 157 

Murrieta, CA 92564 

Loida Atienza 

3340 Riverside Dr. NO M 

Chino, CA 91709 

Austin Murrietta Inc. 

c/o Michael A. Michalske 

2429 W Coast Hwy No. 207 

Newport Beach, CA 92663 

Michael Ayer 

c/o Jacqueline Ayer 

2010 W. Avenue K, No. 701 

Lancaster, CA 93536 

Raymond Badger 

24798 Holly Leaf Ln. 

Murrieta , CA 92562 

James Bancroft 

36 Rustling Wind 

Irving, CA 92612 

Donald Barclift 

39850 Via Sereno 

Murrieta, CA 92562 

Barsby Property Ltd. 

c/o Robert S. Barsby 

2206 Paseo Del Mar 

Palos Verdes Est, CA 90274 

E. Beaumont 

200 Via Mentone 

Newport Beach, CA 92663 

Richard Becktel 

29621 Morarch Dr. 

San Juan Capistrano, CA 92675 

Big Jake Enterprises 

19301 Jasmine Ct. 

Lake Elsinore, CA 92530 

Big Jake Enterprises 

32295 Mission Trail, No. 206 

Lake Elsinore, CA 92530 

Maria Blanco 

33235 Macy Street 

Lake Elsinore, CA 92530 

Chad Blough 

1645 Calle Del Oro 

Corona, CA 92882 

Richard Bogard 

P.O. Box 1535 

Corona, CA 92878 

Frank & Lynn Boimilla 

33315 Macy Street 

Lake Elsinore, CA 92530 

Victor Bonilla 

739 W. 19th Street 

Costa Mesa, CA 92627 

Clarence Bostian 

371 Hannalei Dr. 

Vista, CA 92083 

Marjorie Boughton 

12917 Caminito Beso 

San Diego, CA 92130 

Jacque Braswell 

38151 Calle de Lobo 

Murrieta, CA 92562 

Jacqueline Brown 

30959 Del Rey Rd. 

Temecula, CA 92591 

Clyde Brunner 

24921 Dana Pt. Harbor 8230 

Dana Pt., CA 92629 

Freda Bunting 

2315 Paseo Saucedal 

Carlsbad, CA 92009 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-17 

Party Name/Address Party Name/Address 

Edward Burrow 

c/o Ola Jo Burrow 

P.O. Box 2146 

Jonesboro, AR 72401 

Tony Butcher 

439 NE 82nd Street, Apt. 4 

Miami, FL 33138 

Silvia Cabrera 

2106 E 92nd Street 

Los Angeles, CA 90002 

Denise Canterberry 

18263 Sanders Drive 

Lake Elsinore, CA 92530 

Richard Cantrell 

2254 Moore St, #207 

Lake Elsinore, CA 92530 

Paul T. & Donna J. Caraher Jr., Trustees 

c/o Ripley Richard K & Violet, et al. 

2061 Omega Drive 

Santa Ana, CA 92705 

Joseph Caramello 

1612 Melrose Ave. 

Chula Vista, CA 91911 

Robert Carrick 

37550 Calle de Companero 

Murrieta, CA 92562 

Paul Caruso 

P.O. Box 616 

Wildomar, CA 92595 

Thomas C. Casey, Trustee 

6 Amador 

Newport Coast, CA 92657 

Paul Chafe 

c/o Robert E. Lowe 

2942 Seaview Ave. 

Ventura, CA 93001 

Frank Chen 

12255 Vista Panorama 

Santa Ana, CA 92705 

Yung Hsiung Chiu 

24428 Penrose Ct. 

Diamond Bar, CA 91765 

Charles Cleveland 

13232 Cullen St., Apt. A 

Whittier, CA 90602 

Jack Cline 

c/o James Cline 

1702 N. Diamondback Rd. 

Maricopa, AZ 85239 

Don Coffman 

24158 Rosita Drive 

Wildomar, CA 92595 

Concordia Cks Inv 

4959 Palo Verde Suite B110 

Montclair, CA 91763 

David Connell 

1231 Hygeia Ave. 

Leucadia, CA 92024 

Ray Connett 

25999 Glen Eden Rd. 

Corona, CA 92883 

Paul Connors 

806 E. Avenida Pico, Ste I 

San Clemente, CA 92673 

Christopher Cook 

32140 Ortega 

Lake Elsinore, CA 92530 

Joseph Cordes 

c/o Cordes Trust 

P.O. Box 1236 

Corona, CA 92878 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-18 

Party Name/Address Party Name/Address 

Corona Lake 

c/o Billy Andrews 

4060 E. La Palm Ave 

Anaheim, CA 92806 

Jaime Cortes 

15 Temecula Ct. 

Rancho Santa Margarita, CA 92688 

County of Riverside 

c/o Amelia M. Vailuu 

3525 14th Street 

Riverside, CA 92501 

Marian Cowles 

33350 Macy St. 

Lake Elsinore, CA 92530 

Craftsmen Homes 

1157 N. Red Gum Street 

Anaheim, CA 92806 

Randall Craig 

19682 Calle Ladera 

Murrieta, CA 92562 

John Cuchessi 

125 Avenida San Dimas 

San Clemente, CA 92672 

Simon Cudby 

21032 Cimmaron Ln. 

Trabuco Canyon, CA 92679 

Warren Dean 

10491 Easter Hill Dr. 

Santa Ana, CA 92705 

Elizabeth Dean 

1323 Pine Dr. 

El Cajon, CA 92020 

Richard Deandero 

28946 Capano Bay Ct. 

Menifee, CA 92584 

Roger Lee Delong 

40701 Ortega Hwy 

Lake Elsinore, CA 92530 

Yvonne L. Dodson 

14340 Marianopolis Way 

San Diego, CA 92129 

Clifford Dombrady 

19200 Saint Gallen 

Murrieta, CA 92562 

Kathleen Doty 

13 Via De La Valle 

Lake Elsinore, CA 92532 

Kenneth Drake 

19945 Paseo Montanas 

Murrieta, CA 92562 

Edward Dufresne 

38550 Calle De Companero 

Murrietta, CA 92562 

Jerry Duncan 

17111 S. Main Divide 

Lake Elsinore, CA 92530 

Jerry Duncan 

34870 Arroyo Rd. 

Lake Elsinore, CA 92530 

Mary Dworzan 

368 S. Carolet Ln. 

Orange, CA 92669 

East West Fun 

6984 Overlook Terrace 

Anaheim, CA 92807 

Edbell LLC 

44 Mancera 

Rancho Santa Margarita, CA 92688 

Tina Elliot 

PMB 882 

324 S. Diamond Bar Blvd. 

Diamond Bar, CA 91765 

EVMWD 

P.O. Box 3000 

Lake Elsinore, CA 92530 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-19 

Party Name/Address Party Name/Address 

Allen Faass 

24661 Venablo Dr. 

Mission Viejo, CA 92691 

Far Eastern Group Partnership IV 

c/o Milbridge Corp. 

12188 Central Ave., No. 600 

Chino, CA 91710 

Bennie Feeley 

P.O. Box 153 

Lake Elsinore, CA 92531 

Feuerman Family 

c/o Tony Fraser Feuerman 

5352 Topeka Drive 

Tarzana, CA 91356 

First American Title Ins. & Tr. Co. 

Rancho Capistrano Property Owners Assoc. 

35240 Calle Grande 

Lake Elsinore, CA 92530 

First Trust Bank 

c/o Pomona First Federal 

393 W. Foothill Blvd., 2nd Floor 

Claremont, CA 91711 

Friesian Focus 

c/o Joseph Fernandez 

P.O. Box 2763 

La Jolla, CA 92038 

John Gamble 

20091 Mt. Israel Pl. 

Escondido, CA 92029 

Jeffery Gati 

P.O. Box 23905 

Wildomar, CA 92595 

Glen Eden Corp. 

25999 Glen Eden Rd. 

Corona, CA 92883 

Roland F. Gonzales Revocable Trust 

153 S. Cypress Street 

Orange, CA 92866 

Good Land Inv III 

2142 Liane Ln. 

Santa Ana, CA 92705 

Grace Korean Church at Norwalk 

1645 W. Valencia Dr. 

Fullerton, CA 92833 

Katherine Greenway 

39660 Via Dereno 

Murrieta, CA 92562 

Richard & Georgiana R. Guthrie 

43077 Tenaja Rd. 

Murrieta, CA 92562 

Miguel Gutierrez 

33265 Macy Street 

Lake Elsinore, CA 92530 

Mark Hansen 

26721 Cuenca Dr. 

Mission Viejo, CA 92691 

Shaun Hanson 

17650 Calle Pescar 

Murrieta, CA 92562 

Douglas Hartman 

333 N. Wilshire Ave. 

Anaheim, CA 92801 

Caroline Hasty 

14130 Main Divide 

Lake Elsinore, CA 92530 

Hetzner Family Ltd. Partnership 

20121 Amapola 

Orange, CA 92669 

Lisa Hill 

38365 Calle De Lobo 

Murrieta, CA 92562 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-20 

Party Name/Address Party Name/Address 

Stephen Hobbs 

45397 Via Jaca 

Temecula, CA 92592 

Wen Mei Hsu 

12160 S. Riviera 

Tustin, CA 92782 

John Hubbard 

32490 Ortega Hwy. 

Lake Elsinore, CA 92530 

Toyomi Igus 

4721 Collidge Ave. 

Culver City, CA 90230 

Inland Empire Real Estate Rehabilitation 

c/o Lisa Bengochea 

26880 Filly Ct. 

Corona, CA 92883 

Heisaburo Ishige 

529 Bourdet Ave. 

Walnut, CA 91789 

J. Ayer Family Limited Partnership 

2010 W. Avenue K #701 

Lancaster, CA 93536 

Randy Jacobs 

19691 Calle Ladera 

Murrieta, CA 92562 

J. James 

1017 Patronella Ave 

Torrance, CA 90503 

Roland J. Jensen Trust 

Helen M. Jensen Trust 

c/o William G. Sommerville, et. al., Trustees 

1010 E. Chestnut Ave. 

Santa Ana, CA 92701 

JJ & RR Prop 

c/o John L. Martin, Jr. 

26886 Eagle Street 

Corona, CA 92883 

Robert Jones 

1459 Sutherland Dr. 

Riverside, CA 92507 

Hyung Jung 

901 N. Villa Ave. 

Villa Park, IL 60181 

Randall Kanemaki 

8751 Valley View St., No. B 

Buena Park, CA 90620 

Timothy Kennison 

44788 Rhiannon Way 

Temecula, CA 92592 

Caroline Morrow 

Elizabeth Knesel 

27672 Via Turina 

Mission Viejo, CA 92692 

Tom & Rita Knight 

P.O. Box 601 

Murrieta, CA 92564 

Harvey Koskovich 

38305 Maisel Ave. 

Murrieta, CA 92562 

Lynlee Kruse 

c/o Letty Jane Bassler 

79466 Cetrino 

La Quinta, CA 92253 

Lake Elsinore Holdings 

1438 9th Street 

Santa Monica, CA 90401 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-21 

Party Name/Address Party Name/Address 

Lakeview Mutual Water Co. 

Vista Del Lago Inc. 

c/o Joe Dietz 

P.O. Box 1344 

Lake Elsinore, CA 92531 

David Lawrence 

P.O. Box 797 

Murrieta, CA 92654 

Lemon Grove Home Owners Assn. 

c/o KB Home Coastal Inc. 

3 Jenner St., NO. 100 

Irvine, CA 92618 

Liliana Lendaro 

17300 Monterey Rd., Box 12 

Lake Elsinore, CA 92531 

Lisa Leonard 

19495 Lobo De Pradera 

Murrieta, CA 92562 

Laura Loew Hunt 

26 Santolina 

Rancho Santa Margarita, CA 92679 

Sumala Lopansri 

233 N. Garfield Ave., No. 206 

Monterey Park, CA 91754 

Mark Lovich 

25545 Calle Becerra 

Laguna Niguel, CA 92677 

Charles Lucas 

P.O. Box 13037 

Long Beach, CA 90803 

Bruce MacDonald 

30773 Young Dove St. 

Menifee, CA 92584 

Ron Mahaney 

2769 Vista Umbrosa 

Newport Beach, CA 92660 

Socorro Margis 

22215 Norma St. 

Perris, CA 92570 

Laszlo & Alice Mariahazy 

5405 Alton Pkwy, #102 

Irvine, CA 92604 

Curtis McCart 

721 E. Foothill Blvd. 

Monrovia, CA 91016 

Helen McCue 

231 W. El Portal, No. A 

San Clemente, CA 92672 

Danny McGehee 

2260 Astoria Cir, #208 

Herndon, VA 20170 

Timothy McIntyre 

34475 S. Main Divide 

Lake Elsinore, CA 92530 

Harry Mead 

34561 S. Main Dr. 

Lake Elsinore, CA 92530 

Meadow Oaks Homeowners Assoc. 

19129 Calle Juanito 

Murrieta, CA 92562 

Lyle Medeiros 

18933 Calle Juanito 

Murrieta, CA 92562 

Tino Metzger 

29508 Westwind Dr. 

Lake Elsinore, CA 92530 

Georges Meyer 

c/o Niguel Home Centers 

24921 Dana Point HRB B230 

Dana Point, CA 92629 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-22 

Party Name/Address Party Name/Address 

William Mezin 

19690 Corte Palo Viejo 

Murrieta, CA 92569 

Lance Miller 

2700 Lakecrest Dr. 

Las Vegas, NV 89128 

Jason Miller 

30129 Calle Halcon 

Temecula, CA 92591 

Theodore Miller 

16699 Markham Street 

Riverside, CA 92504 

Molthen Family Trust 

511 Center Street 

Laguna Beach, CA 92651 

Steven Morico 

P.O. Box 1043 

Grand Cayman Island 

British West Indies 

Nature Conservancy 

c/o California Regional Counsel 

201 Mission St., 4th Fl 

San Francisco, CA 94105 

Edward Nelson 

204 Pompano Dr. 

Emerald Isle, NC 28594 

Collette Nguyen 

8722 Bermuda Ave. 

Westminster, CA 92683 

Elizabeth Nguyen 

10192 Morning Side Dr. 

Garden Grove, CA 92643 

Cheryl Nicolosi 

43061 Agena St. 

Temecula, CA 92592 

Richard Niggemann 

P.O. Box 1034 

San Clemente, CA 92674 

Nilson Flora Adina 

40051 Long Canyon Rd. 

Lake Elsinore, CA 92530 

North Peak Partners LP 

20272 Carrey Rd. 

Walnut, CA 91789 

Oak Meadow Enterprises 

c/o Diane Bathgate 

P.O. Box 1870 

San Juan Capistrano, CA 92693 

Hans Oei 

39555 Vista Del Bosque 

Murrieta, CA 92562 

Jarnette Olsen 

c/o Edward White & Co. LLP 

21700 Oxnard St., Suite 400 

Woodland Hills, CA 91367 

Pacific Clay Products 

c/o G. Dale Kline 

14741 Lake Street 

Lake Elsinore, CA 92530 

Paragon Building Products, Inc. 

2895 Hamner Ave. 

Norco, CA 92860 

Raymond Patscheck 

2620 Riverside Dr. 

Costa Mesa, CA 92627 

Johnny Patty 

c/o Independence Ranch Trust 

P.O. Box 747 

Wildomar, CA 92595 

Pecuniary Capital 

P.O. Box 6130 

Corona, CA 92878 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-23 

Party Name/Address Party Name/Address 

Delores Pelz 

33368 Macy St. 

Lake Elsinore, CA 92530 

Brian Penna 

37961 Calle de Lobo 

Murrieta, CA 92562 

David Perez 

36550 Glenoaks Rd. 

Temecula, CA 92592 

Jose Perez 

9005 Sorbonne Way 

Buena Park, CA 90620 

Kent Pham 

2355 Cornell Cir. 

Corona, CA 92881 

Symantha Pham 

31805 Ortega 

Lake Elsinore, CA 92530 

Franklin O. & Rosemary C. Pierce Trustees 

P.O. Box 1021 

Wildomar, CA 92595 

Larry Plavala 

2678 Skyline Dr. 

Minden, NV 89423 

Lawrence Plavala 

P.O. Box 963 

Lake Elsinore, CA 92531 

Cowan A. & Martha B. Plummer Family Trust 

Albert J. Lamptert Trustee 

1421 Hollencrest Dr. 

West Covina, CA 91791 

Anthony Polo 

P.O. Box 2497 

Temecula, CA 92593 

Robert Pritchett 

32333 Ortega Highway 

Lake Elsinore, CA 92530 

Rancho Amistad 

455 Hilledge Dr. 

Laguna Beach, CA 92651 

Rancho Calif Water Dist 

42135 Winchester Rd. 

Temecula, CA 92590 

Rancho La Cresta Partners 

c/o Roy K. Salameh 

2642 Unicornio St. 

Carlsbad, CA 92009 

Hartsel Reed 

12472 Bosley 

Corona, CA 92883 

John Reese 

c/o J. Merry 

4041 MacArthur Blvd., No. 120 

Newport Beach, CA 92660 

Margarito Rico 

P.O. Box 515 

Norco, CA 92660 

Kurt Rietsch 

16836 Marina Bay Dr. 

Huntington Beach, CA 92649 

Irma Rivera 

P.O. Box 666 

Mira Loma, CA 91752 

Riverside County Habitat Conserv. Agency 

4080 Lemon St., 12th Floor 

Riverside, CA 92501 

Riverside County Habitat Conserv. Agency 

c/o Best, Best & Krieger 

600 E. Tahquitz Canyon Way 

Palm Springs, CA 92262 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-24 

Party Name/Address Party Name/Address 

Riverside County Habitat Conserv. Agency 

c/o Dept of Bldg. Services 

3133 7th Street 

Riverside, CA 92507 

Josh Robinson 

39461 Vista Del Bosque 

Murrieta, CA 92563 

Ron Sabatini 

41275 Hacienda 

Murrieta, CA 92562 

Alice Saxon 

15068 Rosecrans Ave., #208 

La Mirada, CA 90638 

Janet Schmidt 

P.O. Box 426 

Fallbrook, CA 92088 

Tim Scott 

41890 Enterprise Cir S, Suite 220 

Temecula, CA 92590 

Emmet Sheahan 

32107 Ortega Highway 

Lake Elsinore, CA 92530 

James Sheffield 

41225 Hacienda 

Murrieta, CA 92562 

Anne Marie Smith 

17330 Monterey Rd. 

Lake Elsinore, CA 92530 

William Smith 

34920 Calle Grande 

Lake Elsinore, CA 92530 

Henry Smith 

40670 Calle Torcida 

Temecula, CA 92591 

Thomas Spencer 

37570 Calle De Companero 

Murrieta, CA 92562 

Cande Sridhar 

18803 Fairfield Rd. 

Northridge, CA 91326 

Starfield Sycamore Inv. 

c/o Steven C. Cameron 

14 Corporate Plaza 

Newport Beach, CA 92660 

Department of Transportation 

State of California 

464 W. Fourth St., 6th Floor 

San Bernardino, CA 92401 

Department of Transportation 

State of California 

P.O. Box 231 

San Bernardino, CA 92403 

State of California 

1416 9th Street 

Sacramento, CA 95818 

Daniel L. Stephenson Family Trust 

c/o Daniel L. Stephenson 

22740 Jefferson Ave. 

Temecula, CA 92590 

Lucy Stickler 

P.O. Box 1543 

Wildomar, CA 92595 

Rodney Strachan 

11632 Ranch Hill 

Santa Ana, CA 92705 

Carrie W. Styles 

P.O. Box 1524 

Travelers Rest, SC 29690-1205 

Vifu Suen 

c/o Patrick W. Suen 

4000 San Dimas, Suite 1 

Bakersfield, CA 93301 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-25 

Party Name/Address Party Name/Address 

Harvey Tabb 

37565 Calle De Companero 

Murrieta, CA 92562 

William Taylor 

309 Paseo de Cristobal 

San Clemente, CA 92672 

Jerry Tedder 

37797 Calle de Lobo 

Murrieta, CA 92562 

Cloyce Thomas 

39570 Via Sereno 

Murrieta, CA 92562 

Jeffrey Thompson 

3454 Golfport Ln. 

Corona, CA 92881 

Andrew Thurley 

33525 Follman Ln. 

Lake Elsinore, CA 92530 

TJH Inc. 

36041 Blackstone Cir. 

Wildomar, CA 92595 

Terry Tran 

531 Green Acrue Dr. 

Fullerton, CA 92835 

Theoni Trangas 

El Venizelou 98 Holargos 

15561 Athens 

GREECE 

Donald Trout 

33360 Hollister Dr. 

Lake Elsinore, CA 92530 

Tupelo Auto Museum Inc. 

1 Otis Dr. 

Tupelo, MS 38804 

USA 386 

c/o Cleveland Nat. Forest 

332 Juniper St., Suite 100 

Escondido, CA 92025 

USA 391 

c/o Cleveland National Forest 

10845 Rancho Bernardo, #200 

San Diego, CA 92127 

USA BLM 

c/o California Desert Dist. 

6221 Box Springs Bl. 

Riverside, CA 92507 

Jeffrey Vieyra 

623 Sky Hy Cir. 

Lafayette, CA 94549 

Banh Vo 

937 Adobe Ave. 

Montebello, CA 90640 

W R A (Survivors) Trust 

c/0 William C. Arterberry 

40147 Calle Roxanne 

Fallbrook, CA 92028 

Margaret Waisanen 

P.O. Box 158 

Occidental, CA 95465 

Robert Waits 

594 Endicott Dr. 

Sunnyvale, CA 94087 

Delis Walker 

17392 Los Alisos Rd. 

Lake Elsinore, CA 92530 

Wallis Wallis 

33202 Paseo Blanco 

San Juan Capistrano, CA 92675 

Duke Watts 

29723 Eagle Point Dr. 

Canyon Lake, CA 92587 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-26 

Party Name/Address Party Name/Address 

Timothy Webb 

P.O. Box 3622 

Mission Viejo, CA 92690 

Lawrence Weill 

100 Surf Pl. 

Seal Beach, CA 90740 

Cathy Weinstein 

24921 Dana Pt. Harbor, B230 

Dana Point, CA 92629 

Carolyn Welch 

PMB 289 

23905 Clinton Keith, 114 

Wildomar, CA 92595 

Western Temple 

c/o Ms. Angela Sabella 

853 E. Valley Blvd., Suite 200 

San Gabriel, CA 91776 

Jack Wheeler 

9104 High Oak Ct. 

Fair Oaks, CA 95628 

John Willett 

19960 Calle Lobito 

Murrieta, CA 92562 

Nellie Williams 

c/o Pomona First Federal 

393 W. Foothill Blvd, 2nd Fl 

Claremont, CA 91711 

John Wilson 

6802 E. Belice Street 

Long Beach, CA 90815 

James Wilson 

c/o Greg McKendall 

20619 Union Street 

Wildomar, CA 92595 

Brian Wood 

31212 Belford Dr. 

San Juan Capistrano, CA 92675 

Edward Wright 

307 Lee Ann Ln. 

Encinitas, CA 92024 

Rex Xanders 

41995 Calle Corriente 

Murrieta, CA 92562 

Ta Ching Yu 

1982 McClean Dr. 

Santa Ana, CA 92705 

Darroll Buytenhuys 

20202 Avenida de Arboles 

Murrieta , CA 92562 

Douglas Pinnow 

7 Via del Lago 

Lake Elsinore, CA 92532 

David L. Huard, Partner 

Manatt, Phelps & Phillips, LLP 

11355 W. Olympic Blvd. 

Los Angeles, CA 90064 

Benjamin Richard Grenis 

29358 3rd St. 

Lake Elsinore, CA 92532 

Nancy Whang 

Manatt, Phelps & Phillips, LLP 

11355 W. Olympic Boulevard 

Los Angeles, CA 90064 

Andrea Sims 

33280 Hollister Dr. 

Lake Elsinore, CA 92530 

Billy Chen, Project Manager 

Sycamore Creek HOA 

2 Ada 

Irvine, CA 92618 

John (Tad) Hurst, Regional Director 

United States Hang Gliding Association 

P.O. Box 1330 

Colorado Springs, CO 80901 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-27 

Party Name/Address Party Name/Address 

Director of Public Utilities 

Public Utilities Department 

City of Riverside 

3900 Main St 

Riverside, CA 92522-0001 

Tom Weiner 

City of Lake Elsinore 

130 S Main 

Lake Elsinore, CA 92530-4109 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
8-28 

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Document Accession #: 20070130-4000 Filed Date: 01/30/2007
COVER SHEET 

FEDERAL ENERGY REGULATORY COMMISSION 

FINAL ENVIRONMENTAL IMPACT STATEMENT 

FOR HYDROPOWER LICENSE 

Lake Elsinore Advanced Pumped Storage Project 

Docket No. P-11858-002 

Appendix A 

USFS Review of Special Use Permit Application 

Pages A-1 to A-2 

FEIS 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
APPENDIX A 

Review of Special Use Application for the Transmission Line 

Proposal Relative to the Need for Federal Land 

and Non-Federal Alternatives 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
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Document Accession #: 20070130-4000 Filed Date: 01/30/2007
A-1 

REVIEW OF SPECIAL USE APPLICATION FOR THE TRANSMISSION LINE 

PROPOSAL RELATIVE TO THE NEED FOR FEDERAL LAND AND 

NON-FEDERAL ALTERNATIVES 

Nevada Hydro Company and Elisnore Valley Municipal Water District have filed an application 

with the Cleveland National Forest for a “stand alone” transmission line authorization. The U.S. Forest 

Service (USFS) has accepted this application and is evaluating this proposal in conjunction with the 

hydropower license application filed with the Federal Energy Regulatory Commission. When the USFS 

screens proposals, the need for federal land is evaluated to determine if the proposal is in the public 

interest. In the case of the “transmission line only” proposal, the applicants provided information used to 

evaluate other alternative alignments that were reasonably available to the applicant that did not require 

National Forest System lands. This appendix briefly summarizes the information considered by the 

USFS. 

San Diego Gas & Electric Company proposed the Valley Rainbow transmission line 

interconnection project in 2001. Although the project was denied by the California Public Utility 

Commission (CPUC) in 2003, the CPUC staff released a preliminary report on the alternatives screening 

analysis in November 2002. The co-applicants have incorporated this information into the license 

application, Volume 3 of 6, Attachment 3. The analysis identified and screened 45 alternatives, including 

non-wires alternatives. The analysis identified 33 alternative routes that would provide the 500-kilovolt 

interconnection proposed by the LEAPS Project, 12 of those alternatives required use of National Forest 

System lands. The proposed routes on the National Forests were significantly constrained. Many crossed 

wilderness areas or tribal lands, which are essentially unavailable for development. Those routes that did 

not have wilderness or tribal lands are primarily those routes that have evolved into the alternatives 

considered in the LEAPS analysis. 

Of the 21 alternative routes that did not need National Forest System lands, 15 crossed tribal 

lands that were not available for development. The remaining six routes were also constrained by land 

ownership, historic sites, habitat reserves, and displacement of homes and businesses along the right-ofway. 

Given the numerous constraints on locating transmission line corridors in the Lake Elsinore area, 

the USFS concluded during the application screening that National Forest System lands are necessary for 

the proposed interconnect. It is also evident that alternative locations are not reasonably available to the 

co-applicants. For the purposes of this analysis, the range of alternatives includes several different routes 

that were designed to respond to specific issues while meeting the purpose and need of the project. 

Alternative routes that cross wilderness areas, tribal lands, or densely populated urban areas are not 

reasonably available to the proponent, and will not be considered in detail. 

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COVER SHEET 

FEDERAL ENERGY REGULATORY COMMISSION 

FINAL ENVIRONMENTAL IMPACT STATEMENT 

FOR HYDROPOWER LICENSE 

Lake Elsinore Advanced Pumped Storage Project 

Docket No. P-11858-002 

Appendix C 

Revised U.S. Forest Service Preliminary Section 4(e) Conditions 

Pages C-1 to C-24 

FEIS 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
APPENDIX C 

Revised U.S. Forest Service 

Preliminary Section 4(e) Conditions 

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File Code: 2770-2 

Date: June 22, 2006 

 

Magalie R. Salas 

Secretary 

Federal Energy Regulatory Commission 

888 First Street NE 

Washington, DC 20426 

Via Electronic Filing 

RE: Revised Forest Service Preliminary Section 4(e) Conditions, FERC No. 11858 

Dear Secretary Salas: 

Enclosed for filing are the Forest Service Revised Preliminary Terms and Conditions for 

inclusion in the Final EIS. This filing is in response to your notice of Draft EIS Publication, and 

is consistent with the schedule we filed with our preliminary conditions. We plan to file Final 

4(e) conditions within 60 days of publication of the Final EIS. 

It is important that the record support our Final Conditions. We have added several additional 

conditions that were not included in the Draft EIS, so filing revised preliminary conditions will 

allow us to work with Commission staff to include those conditions in the analysis developed for 

the Final EIS. We also expect to work closely with staff to respond to the many comments filed 

on the Draft EIS, and we expect the analysis that results from that work will further support our 

Final Conditions. Specifically, we have added conditions to address surface and groundwater 

management, scenery conservation, and habitat mitigation. 

Enclosure 1 contains the Revised Preliminary 4(e) Terms and Conditions found to be necessary 

for the adequate protection and utilization of the Cleveland National Forest. Applicable 

comprehensive plans include the Cleveland National Forest Land and Resource Management 

Plan (2006). 

Several key components of the proposed project are on reserved lands that are part of the 

Cleveland National Forest. If the Commission chooses to license this project, they must make an 

independent determination that the proposed project or the selected alternative is consistent with 

the purposes of the reservation. The Forest Service offers the following background for the 

Commission’s consideration. 

The increased urbanization, ranching, mining, agricultural, and timber production within 

California in the late 1800’s often resulted in significant flooding of downstream areas, affecting 

commerce as well as communities in Southern California. There also was a public realization of 

the need for reliable water sources to maintain viability of the developing industries and 

municipalities. Following the enactment of the Desert Lands Act of 1877 and the Wright Act of 

1887, large land parcels with water rights were acquired, first by timber and cattle interests and 

later by farmers and communities. Under the Wright Act, water districts were formed to divert 

and deliver water to developing cities, particularly in Southern California. The Forest Reserve 

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Lake Elsinore Advanced Pump Storage Project 

FERC Project No. 11858 

Revised Preliminary 4(e) Terms and Conditions and 10(a) Recommendations 

C-2 

Act, passed in 1891, authorized the establishment of forest reserves from forest and range lands 

in public domain. 

In 1893, President Harrison withdrew 109,920 acres of public domain lands in the Santa Ana 

Mountains (The Trabuco Canyon Forest Reserve). These lands were specifically withdrawn for 

watershed protection. After the establishment of the Trabuco Canyon Reserve and The San 

Jacinto Forest Reserve in 1897, these areas were designated as a National Forest in 1908 and 

named in honor of President Grover Cleveland. 

The Organic Act of June 4, 1897, stated that ‘no national forest shall be established, except to 

improve and protect the forest within the boundaries, or for the purpose of securing favorable 

conditions of water flows’, and established the National Forests to initially halt wasteful 

exploitation of the public lands and forests. Though opposition by vested interests slowed 

progress, policies dealing with timber management, mining, watershed protection, wildlife 

management, grazing, and recreation emerged and evolved into the multiple-use concept 

practiced now. However, the Cleveland National Forest, located in Southern California, was 

atypical. Created with public support, it was from the beginning a watershed forest; all of its 

problems and policies centered on protection of the watersheds which provide water to the 

surrounding agricultural areas and towns, especially the city of San Diego. It was to protect their 

watersheds that Californians immediately began demanding Forest Reserves. The Cleveland 

National Forest became one of the first in the new system and had its basis in the 50,000 acre 

Trabuco Canyon Forest Reserve, created by President Harrison in February 1893 (The Journal of 

San Diego History , Fall 1975, Volume 21, Number 4). 

Based on our review, we would conclude that project features that would eliminate critical 

watershed components such as riparian areas and springs would not be consistent with the 

purposes of the reservation. The staff alternative, which avoids impacts to unique riparian 

habitat, and provides transmission line locations that would not hinder fire suppression actions 

necessary to protect watershed values, would be consistent with the reservation. 

Please contact Virgil Mink at (951) 736-1811 ext. 3277 if you have any questions. 

Sincerely, 

/S/ BETH G. 

PENDLETON 

(FOR) 

BERNARD WEINGARDT 

Regional Forester 

Enclosure 

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Enclosure 1 

PACIFIC SOUTHWEST REGION 

USDA FOREST SERVICE 

Revised preliminary 4(e) TERMS AND CONDITIONS AND 10(a) 

Recommendations 

Lake Elsinore Advance Pump Storage Hydroelectric Project 

FERC Project No. 11858 

Index 

I. Introduction ................................................................................................................................. 5 

II. Standard Forest Service Conditions ........................................................................................... 6 

Condition No. 1— Requirement to Obtain a Forest Service Special-Use Authorization 6 

Condition No. 2—Modification of 4(e) Conditions After Biological Opinion or Water 

Quality Certification 6 

Condition No. 3—Forest Service Approval of Final Design 6 

Condition No. 4—Approval of Changes 7 

Condition No. 5—Consultation 7 

Condition No. 6—Surrender of License or Transfer of Ownership 7 

Condition No. 7—Hazardous Substances Plan 8 

Condition No. 8—Use of Explosives 8 

Condition No. 9—Fire Prevention, Response, and Investigation 9 

Condition No. 10—Road Use by Government 11 

Condition No. 11—Road Use 11 

Condition No. 12—Maintenance of Improvements 11 

Condition No. 13—Safety during Project Construction 11 

Condition No. 14—Pesticide Use Restrictions 12 

Condition No. 15—Erosion Control Plan 12 

Condition No. 16—Valid Claims and Existing Rights 13 

Condition No. 17—Compliance with Regulations 13 

Condition No. 18—Protection of United States Property 13 

Condition No. 19—Indemnification 13 

Condition No. 20—Surveys, Land Corners 13 

Condition No. 21—Damage to Land, Property, and Interests of the United States 14 

Condition No. 22—Risks and Hazards 14 

Condition No. 23—Crossings 15 

Condition No. 24—Access 15 

Condition No. 25—Signs 15 

III. Project Specific Forest Service Conditions............................................................................. 15 

Condition No. 26—Road and Traffic Management Plan 15 

Condition No. 27—Recreation Facilities and Administration 16 

Condition No. 28 – Heritage Resources Management Plan 17 

Condition No. 29—Annual Employee Awareness Training 17 

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Lake Elsinore Advanced Pump Storage Project 

FERC Project No. 11858 

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Condition No. 30—Special Status Species 18 

Condition No. 31—Ground Disturbing Activities 18 

Condition No. 32—Environmental Monitoring 18 

Condition No. 33—Vegatation and Invasive Weed Management Plan 19 

Condition No. 34—Wildlife Management 20

Condition No. 35—Surface Water Resources Management Plan 18 

Condition No. 36— Ground Water Management Plan 18

Condition No. 37— Scenery Conservation Plan 19

Condition No. 38— Habitat Mitigation Plan 19

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REVISED PRELIMINARY 4(e) Terms and Conditions 

Lake Elsinore Advanced Pumped Storage Hydroelectric Project 

FERC Project No. 11858 

I. Introduction

The Forest Service hereby submits its Revised Preliminary 4(e) Terms and Conditions 

(Conditions) and Section 10(a) recommendations, as applicable, for the Lake Elsinore Advanced 

Pumped Storage Hydroelectric Project (FERC Project No. 11585), in accordance with 18 CFR 

4.34(b)(1)(i). Wording in [brackets] in these conditions indicates that the Forest Service 

determined that this portion of the condition was not within its jurisdiction; however the Forest 

Service recommends it be included in the license under Section 10(a) of the Federal Power Act. 

Section 4(e) of the Federal Power Act states the Commission may issue a license for a project 

within a reservation only if it finds that the license will not interfere or be inconsistent with the 

purpose for which such reservation was created or acquired. This is an independent threshold 

determination made by FERC, with the purpose of the reservation defined by the authorizing 

legislation or proclamation (see Rainsong v. FERC, 106 F.3d 269 (9th Cir. 1977). The Forest 

Service, for its protection and utilization determination under Section 4(e) of the FPA may rely 

on broader purposes than those contained in the original authorizing statutes and proclamations 

in prescribing conditions (see Southern California Edison v. FERC, 116F.3d 507 (D.C. Cir. 

1997)). These terms and conditions are based on those resource and management requirements 

enumerated in the Organic Administration Act of 1897 (30 Stat. 11), the Multiple-Use Sustained 

Yield Act of 1960 (74 Stat. 215), the National Forest Management Act of 1976 (90 Stat. 2949), 

and any other law specifically establishing a unit of the National Forest System or prescribing 

the management thereof (such as the Wilderness Act or the Wild and Scenic Rivers Act), as such 

laws may be amended from time to time, and as implemented by regulations and approved Land 

and Resource Management Plans prepared in accordance with the National Forest Management 

Act. Specifically, the 4(e) conditions are based on the Land and Resource Management Plan (as 

amended) for the Cleveland National Forest, as approved by the Regional Forester of the Pacific 

Southwest Region. 

Pursuant to Section 4(e) of the Federal Power Act, the Secretary of Agriculture, acting by and 

through the Forest Service, considers the following conditions necessary for the adequate 

protection and utilization of the land and resources of the Cleveland National Forest. License 

articles contained in the Federal Energy Regulatory Commission’s (hereinafter referred to as the 

Commission) Standard Form L-2 (revised October 1975) issued by Order No. 540, and dated 

October 31, 1975, cover general requirements. Section II of this document includes standard 

conditions deemed necessary for the administration of National Forest System lands. Section III 

covers specific requirements for protection and utilization of National Forest System lands and 

shall also be included in any license issued. 

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II. Standard Forest Service Conditions

Condition No. 1— Requirement to Obtain a Forest Service Special-Use 

Authorization 

The Licensee shall secure a special-use authorization from the Forest Service for the 

occupancy and use of National Forest System lands. The licensee shall obtain the executed 

authorization before beginning ground-disturbing activities on National Forest System lands. 

The licensee may commence ground-disturbing activities authorized by the license and 

special-use authorization no sooner than 60 days following the date the licensee files the 

Forest Service special-use authorization with the Commission, unless the Commission 

prescribes a different commencement schedule. 

In the event there is a conflict between any provision of the license and Forest Service 

special-use authorization, the special-use authorization shall prevail to the extent that the 

Forest Service, in consultation with the Commission, deems necessary to protect and utilize 

National Forest System resources. 

Condition No. 2—Modification of 4(e) Conditions After Biological Opinion or 

Water Quality Certification 

The Forest Service reserves the right, after notice and opportunity for comment, to modify 

these conditions, if necessary, to respond to any Final Biological Opinion issued for this 

Project by the United States Fish and Wildlife Service, NOAA Fisheries, or any Certification 

or permit issued for this Project by the State Water Resources Control Board or Army Corps 

of Engineers. 

Condition No. 3—Forest Service Approval of Final Design 

Before any new construction of the Project occurs on National Forest System lands, the 

Licensee shall obtain prior written approval of the Forest Service for all final design plans 

for Project components, which the Forest Service deems as affecting or potentially 

affecting National Forest System resources. The Licensee shall follow the schedules and 

procedures for design review and approval specified in the conditions herein and in the 

Special Use Permit. As part of such written approval, the Forest Service may require 

adjustments to the final plans and facility locations to preclude or mitigate impacts and to 

insure that the Project is either compatible with on-the-ground conditions or approved by 

the Forest Service based on agreed upon compensation or mitigation measures to address 

compatibility issues. Should such necessary adjustments be deemed by the Forest 

Service, the Commission, or the Licensee to be a substantial change, the Licensee shall 

follow the procedures of Article 2 of the license. Any changes to the license made for 

any reason pursuant to Article 2 or Article 3 shall be made subject to any new terms and 

conditions of the Secretary of Agriculture made pursuant to Section 4(e) of the Federal 

Power Act. 

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Condition No. 4—Approval of Changes 

Notwithstanding any Commission approval or license provisions to make changes to the 

Project when such changes directly affect National Forest System lands, the Licensee 

shall obtain written approval from the Forest Service prior to making any changes in any 

constructed Project features or facilities, or in the uses of Project lands and waters, or any 

departure from the requirements of any approved exhibits filed with the Commission. 

Following receipt of such approval from the Forest Service, and at least 60 days prior to 

initiating any such changes or departure, the Licensee shall file a report with the 

Commission describing the changes, the reasons for the changes, and showing the 

approval of the Forest Service for such changes. The Licensee shall file an exact copy of 

this report with the Forest Service at the same time it is filed with the Commission. This 

article does not relieve the Licensee from the amendment or other requirements of Article 

2 or Article 3 of this license, nor shall it affect the Licensee’s obligation to comply with 

Commission requirements. 

Condition No. 5—Consultation 

Each year between February 15 and April 15, the Licensee shall consult with the Forest 

Service with regard to measures needed to ensure protection and utilization of the National 

Forest resources affected by the Project. Within 60 days following such consultation, the 

Licensee shall file with the Commission evidence of the consultation with any 

recommendations made by the Forest Service. The Forest Service reserves the right, after 

notice and opportunity for comment, to require changes in the Project and its operation 

through revision of the 4(e) conditions that require measures necessary to accomplish 

protection and utilization of National Forest resources. 

When Forest Service section 4(e) conditions require the Licensee to file a plan with the 

Commission that is approved by the Forest Service, the Licensee shall provide the Forest 

Service a minimum of 60 days to review and approve the plan before filing with the 

Commission. Upon Commission approval, the Licensee shall implement Forest Service 

required and approved plans. 

Condition No. 6—Surrender of License or Transfer of Ownership 

Prior to any surrender of this license, the Licensee shall provide assurance acceptable to 

the Forest Service that Licensee shall restore any project area directly affecting National 

Forest System lands to a condition satisfactory to the Forest Service upon or after 

surrender of the license, as appropriate. The restoration plan shall identify the measures 

to be taken to restore National Forest System lands and shall include adequate financial 

mechanisms to ensure performance of the restoration measures. 

In the event of any transfer of the license or sale of the Project, the Licensee shall assure, in a 

manner satisfactory to the Forest Service, that the Licensee or transferee will provide for the 

costs of surrender and restoration. If deemed necessary by the Forest Service to assist in 

evaluating the Licensee's proposal, the Licensee shall conduct an analysis, using experts 

approved by the Forest Service, to estimate the potential costs associated with surrender and 

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restoration of any Project area directly affecting National Forest System lands to Forest 

Service specifications. In addition, the Forest Service may require the Licensee to pay for an 

independent audit of the transferee to assist the Forest Service in determining whether the 

transferee has the financial ability to fund the surrender and restoration work specified in the 

analysis. 

Condition No. 7—Hazardous Substances Plan 

Within one year of license issuance, or prior to any ground disturbing activities, the 

Licensee shall file with the Commission a plan approved by the Forest Service for 

hazardous substances storage, spill prevention, and spill cleanup for Project facilities on 

or directly affecting National Forest System Lands. In addition, during planning and 

prior to any new construction or maintenance not addressed in an existing plan, the 

Licensee shall notify the Forest Service, and the Forest Service shall make a 

determination whether a plan approved by the Forest Service for oil and hazardous 

substances storage and spill prevention and cleanup is needed. 

At a minimum, the plan must require the Licensee to (1) maintain in the Project area, or 

at an alternative location approved by the Forest Service, a cache of spill cleanup 

equipment suitable to contain any spill from the Project; (2) to periodically inform the 

Forest Service of the location of the spill cleanup equipment on National Forest System 

lands and of the location, type, and quantity of oil and hazardous substances stored in the 

Project area; (3) to inform the Forest Service immediately of the nature, time, date, 

location, and action taken for any spill affecting National Forest System lands, and 

Licensee adjoining property when such spill could reasonably be expected to affect 

National Forest System lands, and (4) provide annually to the Forest Service a list of 

Licensee project contacts. 

Condition No. 8—Use of Explosives 

Use of explosives shall be consistent with state and local requirements. 

1. The Licensee shall use only electronic detonators for blasting on National Forest System 

lands and Licensee adjoining property, except near high-voltage powerlines. The Forest 

Service may allow specific exceptions when in the public interest. 

2. In the use of explosives, the Licensee shall exercise the utmost care not to endanger life 

or property and shall comply with the requirements of the Forest Service. The Licensee 

shall contact the Forest Service prior to blasting to obtain the requirements from the 

Forest Service. The Licensee shall be responsible for any and all damages resulting from 

the use of explosives and shall adopt precautions to prevent damage to surrounding 

objects. The Licensee shall furnish and erect special signs to warn the public of the 

Licensee's blasting operations. The Licensee shall place and maintain such signs so they 

are clearly evident to the public during all critical periods of the blasting operations, and 

shall ensure that they include a warning statement to have radio transmitters turned off. 

3. If stored on National Forest System lands. the Licensee shall store all explosives in a 

secure manner, in compliance with State and local laws and ordinances, and shall mark 

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all such storage places "DANGEROUS—EXPLOSIVES”, or in any alternative manner 

approved by the Forest Service. Where no local laws or ordinances apply, the Licensee 

shall provide storage that is satisfactory to the Forest Service and in general not closer 

than 1,000 feet from the road or from any building or camping area unless otherwise 

approved by the Forest Service. 

4. When using explosives on National Forest System lands, the Licensee shall adopt 

precautions to prevent damage to landscape features and other surrounding objects. 

When directed by the Forest Service, the Licensee shall leave trees within an area 

designated to be cleared as a protective screen for surrounding vegetation during blasting 

operations. The Licensee shall remove and dispose of trees so left when blasting is 

complete. When necessary, and at any point of special danger, the Licensee shall use 

suitable mats or some other approved method to smother blasts. 

Condition No. 9—Fire Prevention, Response, and Investigation 

A. Hazardous Vegetation Fuel Treatment Plan 

Within one year of license issuance or prior to any ground disturbing activities, the 

Licensee shall file with the Commission a plan approved by the Forest Service for 

Hazardous Vegetative Fuel Treatment on or directly affecting National Forest System 

lands. The purpose of the plan shall be to reduce the potential for wildfires originating at 

Project facilities, and to protect Project facilities from adjacent wildfires. At a minimum, 

the Hazardous Vegetative Fuel Treatment Plan shall: 

1. Analyze fuel loading on Cleveland National Forest lands [and other project lands] that 

extend from the edge of each Project facility area (excluding the area around reservoir 

shorelines). Maintain fuel profiles within the project area consistent with plan standards 

set forth in the Cleveland Forest Land Management Plan, guidelines for development and 

maintenance of wildland urban interface defense and threat zones, and California Public 

Resource Code. 

2. Identify fuel treatment methods to mitigate identified hazard fuels. Such treatment 

methods shall generally be limited to thinning of small trees, removing excess brush, and 

reducing fuel load and continuity of surface and ladder fuels. 

3. Include a map and schedule of treatments. 

4. Assure fire prevention measures will conform to water quality protection practices as 

enumerated in USDA, Forest Service, Pacific Southwest Region, Water Quality 

Management for National Forest System Lands in California-Best Management Practices. 

The Licensee is responsible for implementing the approved plan. 

B. Fire Prevention and Response Plan 

Within one year of license issuance or prior to any ground disturbing activities, the Licensee 

shall file with the Commission a Fire Prevention and Response Plan that is approved by the 

Forest Service, and developed in consultation with appropriate State and local fire agencies. 

The plan shall set forth in detail the Licensee’s responsibility for the prevention (excluding 

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fuel treatment as described above), reporting, control, and extinguishing of fires in the 

vicinity of the Project resulting from Project operations. 

At a minimum the plan shall address the following categories: 

1. Prevention 

• Availability of fire access roads, community road escape routes, helispots to allow 

aerial firefighting assistance in the steep canyon, water drafting sites and other 

fire suppression strategies. 

• Address fire danger and public safety associated with project induced recreation, 

including fire danger associated with dispersed camping, existing and proposed 

developed recreation sites, trails, and vehicle access. 

2. Emergency Response Preparedness 

• Analyze fire prevention needs including equipment and personnel availability. 

4. Reporting 

• Licensee shall report any project related fires to the Forest Service within 24 

hours. 

5. Fire Control/Extinguishing 

• Provide the Forest Service with a list of the locations of available fire suppression 

equipment and the location and availability of fire suppression personnel. 

Assure fire prevention measures will conform to water quality protection practices as 

enumerated in USDA, Forest Service, Pacific Southwest Region, Water Quality Management 

for National Forest System Lands in California-Best Management Practices or its successor. 

C. Investigation of Project Related Fires 

The Licensee agrees to fully cooperate with the Forest Service on all fire investigations. 

The Licensee shall produce upon request all material and witnesses not subject to 

attorney client or attorney work product privilege, over which the Licensee has control, 

related to the fire and its investigation including: 

• All investigation reports 

• All witness statements 

• All photographs 

• All drawings 

• All analysis of cause and origin 

• All other, similar materials and documents regardless of how collected or maintained 

The Licensee shall preserve all physical evidence, and give custody to the Forest Service of 

all physical evidence requested. The Forest Service shall provide the Licensee with 

reasonable access to the physical evidence and documents the Licensee requires in order to 

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defend any and all claims, which may arise from a fire resulting from project operations, to 

the extent such access is not precluded by ongoing criminal or civil litigation. 

Condition No. 10—Road Use by Government 

The United States shall have unrestricted use of any road over which the licensee has 

control, within the project area for all purposes deemed necessary and desirable in 

connection with the protection, administration, management, and utilization of National 

Forest System lands or resources. When needed for the protection, administration, and 

management of Federal lands or resources, the United States shall have the right to 

extend rights and privileges for use of the right-of-way and road thereon, to States and 

local subdivisions thereof, as well as to other users. The United States shall control such 

use so as not to unreasonably interfere with the use of the road by the Licensee, safety or 

security uses, or cause the Licensee to bear a share of costs disproportionate to the 

Licensee’s use in comparison to the use of the road by others. 

Condition No. 11—Road Use 

The Licensee shall confine all vehicles being used for project purposes, including but not 

limited to administrative and transportation vehicles and construction and inspection 

equipment, to roads or specifically designed access routes, and approved construction and 

staging areas, as identified in the Road and Traffic Management Plan (Condition No. 26). 

The Forest Service reserves the right to close any and all such routes where damage 

(impacts beyond the expected and approved disturbance) is occurring to the soil or 

vegetation, or, if requested by Licensee, to require reconstruction/construction by the 

Licensee to the extent needed to accommodate the Licensee's use. The Forest Service 

agrees to provide notice to the Licensee and the Commission prior to road closures, 

except in an emergency, in which case notice will be provided as soon as practicable. 

Condition No. 12—Maintenance of Improvements 

The Licensee shall maintain all its improvements and premises on National Forest 

System lands to standards of repair, orderliness, neatness, sanitation, architectural 

character, and safety consistent with applicable Forest Service guidelines and acceptable 

to the Forest Service. Disposal will be at an approved existing location, except as 

otherwise agreed by the Forest Service. 

Condition No. 13—Safety during Project Construction 

Sixty days prior to ground-disturbing activity related to new Project construction on or 

affecting National Forest System Lands, the Licensee shall file a Safety During 

Construction Plan with the Commission that is approved by the Forest Service that 

identifies potential hazard areas and measures necessary to protect public safety. Areas 

to consider include construction activities near public roads, trails and recreation area and 

facilities. 

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The Licensee shall perform daily (or on a schedule otherwise agreed to by the Forest 

Service in writing) inspections of Licensee's construction operations on or affecting 

National Forest System while construction is in progress. The Licensee shall document 

these inspections (informal writing sufficient) and shall deliver such documentation to the 

Forest Service on a schedule agreed to by the Forest Service. The inspections must 

specifically include fire plan compliance, public safety, and environmental protection. 

The Licensee shall act immediately to correct any items found to need correction to be 

incompliance with the license. 

Condition No. 14—Pesticide Use Restrictions 

Pesticides may not be used to control undesirable woody and herbaceous vegetation, 

aquatic plants, fish, insects, and rodents on National Forest System lands without the 

prior written approval of the Forest Service. The Licensee shall submit a request for 

approval of planned uses of pesticides on National Forest System lands. The request 

must cover annual planned use and be updated as required by the Forest Service. The 

Licensee shall provide information essential for review, including a forest-specific 

pesticide risk assessment, in the form specified. Exceptions to this schedule may be 

allowed only when unexpected outbreaks of pests require control measures that were not 

anticipated at the time the request was submitted. In such an instance, an emergency 

request and approval may be made. 

The Licensee shall use on National Forest System lands only those materials registered 

by the U. S. Environmental Protection Agency for the specific purpose planned. The 

Licensee must strictly follow label instructions in the preparation and application of 

pesticides and disposal of excess materials and containers. 

Condition No. 15—Erosion Control Plan 

During planning and before any new construction or non-routine maintenance projects 

with the potential for causing erosion and/or stream sedimentation on or affecting 

National Forest System Lands, the Licensee shall file with the Commission an Erosion 

Control Measures Plan that is approved by the Forest Service. The Plan shall include 

measures to control erosion, stream sedimentation, dust, and soil mass movement 

attributable to the Project. 

The plan shall be based on actual-site geological, soil, and groundwater conditions and 

shall include: 

1. A description of the actual site conditions; 

2. Detailed descriptions, design drawings, and specific topographic locations of all control 

measures; 

3. Measures to divert runoff away from disturbed land surfaces; 

4. Measures to collect and filter runoff over disturbed land surfaces, including sediment 

ponds at the diversion and powerhouse sites; 

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5. Revegetating disturbed areas in accordance with current direction on use of native plants 

and locality of plant and seed sources; 

6. Measures to dissipate energy and prevent erosion; and, 

7. A monitoring and maintenance schedule. 

Upon Commission approval, the Licensee shall implement the plan. 

Condition No. 16—Valid Claims and Existing Rights 

This license is subject to all valid rights and claims of third parties. The United States is 

not liable to the Licensee for the exercise of any such right or claim. 

Condition No. 17—Compliance with Regulations 

The Licensee shall comply with the regulations of the Department of Agriculture for 

activities on NFS lands, and all applicable federal, state, county, and municipal laws, 

ordinances, or regulations in regards to the area or operations on or directly affecting 

NFS lands, to the extent those laws, ordinances, or regulations are not preempted by 

federal law. 

Condition No. 18—Protection of United States Property 

The Licensee shall exercise diligence in protecting from damage the land and property of 

the United States covered by and used in connection with the license. 

Condition No. 19—Indemnification 

The Licensee shall indemnify, defend, and hold the United States harmless for any 

violations incurred under any applicable laws and regulations or for judgments, claims, or 

demands assessed against the United States caused by the construction, maintenance, or 

operation of the project works or of the works appurtenant or accessory thereto under the 

license. The licensee’s indemnification of the United States shall include any loss by 

personal injury, loss of life or damage to property in connection with the construction, 

maintenance, or operation of the project works or of the works appurtenant or accessory 

thereto under this license. Indemnification shall include, but is not limited to, the value of 

resources damaged or destroyed; the costs of restoration, cleanup, or other mitigation; fire 

suppression or other types of abatement costs; third party claims and judgments; and all 

administrative, interest, and other legal costs. Upon surrender, transfer, or termination of 

the license, the Licensee’s obligation to indemnify and hold harmless the United States 

shall survive all valid claims for actions that occurred prior to such surrender, transfer or 

termination. 

Condition No. 20—Surveys, Land Corners 

The Licensee shall avoid disturbance to all public land survey monuments, private 

property corners, and forest boundary markers. In the event that any such land markers 

or monuments on National Forest System lands are destroyed by an act or omission of the 

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C-14 

Licensee, in connection with the use and/or occupancy authorized by this license, 

depending on the type of monument destroyed, the Licensee shall reestablish or reference 

same in accordance with (1) the procedures outlined in the "Manual of Instructions for 

the Survey of the Public Land of the United States," (2) the specifications of the County 

Surveyor, or (3) the specifications of the Forest Service. 

Further, the Licensee shall ensure that any such official survey records affected are 

amended as provided by law. 

Condition No. 21—Damage to Land, Property, and Interests of the United States 

The Licensee has an affirmative duty to protect the land, property and interests of the United 

States from damage arising from the Licensee’s construction, maintenance, or operation of 

the project works or of the works appurtenant or accessory thereto under the license. 

The Licensee is liable for all damages, costs and expenses associated with damage to the 

land, property and interests of the United States occasioned by the construction, maintenance, 

or operation of the project works or of the works appurtenant or accessory thereto under the 

license, including but not limited to damages, costs and expenses resulting from fire. Such 

damages, costs and expenses shall include, but not be limited to: 

1. Fire suppression costs 

2. Rehabilitation and restoration costs 

3. Value of lost resources 

4. Abatement costs 

5. Investigative and administrative expenses 

6. Attorneys' fees 

The Licensee’s liability under this condition shall not extend to acts or omissions of parties 

outside of the Licensee’s control. Licensee’s contractors or employees of contractors are not 

considered parties outside the Licensee’s control. Damages will be determined by the value 

of the resources lost or impaired, as determined by the Forest Service. The basis for damages 

will be provided to the Licensee. The licensee shall accept transaction registers certified by 

the appropriate Forest Service official as evidence of costs and expenses. The Licensee shall 

have an opportunity to review the basis for the Forest Service’s damages, costs and expenses, 

and to meet and confer with the Forest Service to resolve any questions or disputes regarding 

such damages, costs and expenses. After the opportunity for review, the Licensee shall 

promptly pay to the United States such damages, costs and expenses upon written demand by 

the United States. 

Condition No. 22—Risks and Hazards 

As part of the occupancy and use of the project area, the Licensee has a continuing 

responsibility to reasonably identify and report all known or observed hazardous 

conditions on or directly affecting NFS lands that would affect the improvements, 

resources, or pose a risk of injury to individuals. Licensee will abate those conditions, 

except those caused by third parties not related to the occupancy and use authorized by 

the License. Any non-emergency actions to abate such hazards on National Forest 

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System lands shall be performed after consultation with the Forest Service. In emergency 

situations, the Licensee shall notify the Forest Service of its actions as soon as possible, 

but not more than 48 hours, after such actions have been taken. Whether or not the 

Forest Service is notified or provides consultation; the Licensee shall remain solely 

responsible for all abatement measures performed. Other hazards should be reported to 

the appropriate agency as soon as possible. 

Condition No. 23—Crossings 

Except as otherwise authorized, the Licensee shall maintain existing crossings as required 

by the Forest Service for all roads and trails that intersect the right-of-way occupied by 

linear Project facilities (powerline, penstock, ditch, and pipeline) on or affecting National 

Forest System lands. 

Condition No. 24—Access 

The Forest Service reserves the right to use or permit others to use any part of the 

licensed area on National Forest System lands for any purpose, provided such use does 

not interfere with the rights and privileges authorized by this license or the Federal Power 

Act. 

Condition No. 25—Signs 

The Licensee shall consult with the Forest Service prior to erecting signs related to safety 

issues on National Forest System lands covered by the license. Prior to the Licensee 

erecting any other signs or advertising devices on National Forest System lands covered 

by the license, the Licensee must obtain the approval of the Forest Service as to location, 

design, size, color, and message. The Licensee shall be responsible for maintaining all 

Licensee-erected signs to neat and presentable standards. 

III. Project Specific Forest Service Conditions

Condition No. 26—Road and Traffic Management Plan 

Within one year of license issuance or prior to any ground disturbing activities, the 

Licensee shall file with the Commission a plan approved by the Forest Service for 

management of all Forest Service and unclassified roads required by the licensee to 

access the project area. The Project Road and Traffic Management Plan shall include: 

1. Identification of all Forest Service roads and unclassified roads on National Forest 

System Lands needed for project access, including road numbers. 

2. A map of all Forest Service roads and unclassified roads on National Forest System land 

used for project access, including digital spatial data accurate to within 40 feet, 

identifying each road by Forest Service essential for review road number. 

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3. A description of each Forest Service road segment and unclassified roads on National 

Forest System land needed for project access including: 

• Termini 

• Length 

• Purpose and use 

• Party responsible for maintenance 

• Level of maintenance 

• Structures accessed 

• Location and status of gates and barricades, if any 

• Ownership of road segment and underlying property 

• Instrument of authorization for road use 

• Assessment of road condition and licensee reconstruction needs 

• Rehabilitation of temporary access disturbance 

• Temporary access locations will be gated to prevent unauthorized public vehicle 

access 

Provisions for the licensee to consult with the Forest Service in advance of performing any 

road construction, realignment, maintenance, or closure involving Forest Service roads. 

The licensee shall cooperate with Forest Service on the preparation of a condition survey and 

a proposed maintenance plan subject to Forest Service approval annually; beginning the first 

full-year after the Road and Traffic Management Plan has been approved. 

[The licensee shall use non-Forest Service roads in accordance with applicable state, county, 

city, and/or local authority standards.] 

The Road and Traffic Management Plan shall identify the licensee’s responsibility for 

road maintenance and repair costs commensurate with the licensee’s use and projectinduced use. The Road and Traffic Management Plan shall specify road maintenance and 

management standards; that provide for traffic safety, minimize erosion and damage to 

natural resources, and that are acceptable to the Forest Service. 

Licensee shall be responsible for any new construction, realignment, closure, or other 

road management actions proposed by the licensee in the future, subject to Forest Service 

standards in effect at the time, including related studies, analyses or reviews required by 

Forest Service. 

Upon Commission approval, the Licensee shall implement the plan. 

Condition No. 27—Recreation Facilities and Administration 

Within one year of license issuance, the licensee shall file with the Commission a Recreation 

Facility Development Plan, approved by the Forest Service, for a recreation facility at the 

project equipment and material laydown area on National Forest System lands or for an 

alternative use and/or location as may be approved by the Forest Service. 

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Condition No. 28 – Heritage Resources Management Plan 

The Licensee shall file with the Commission, within one year following license issuance, or 

prior to any ground disturbing activities, a Heritage Resources Management Plan (HRMP), 

approved by the Forest Service, for the purpose of protecting and interpreting heritage 

resources. The HRMP is tiered to a Programmatic Agreement, to which the Forest Service 

will be a signatory, as defined by 36 CFR 800, and implements regulations of the National 

Historic Preservation Act. The Licensee shall consult with the State Historic Preservation 

Officer, Native American Tribes, Forest Service, and other applicable agencies and 

communities during the preparation of the Plan. The HRMP shall accurately define the area 

of potential effects, including effects of implementing Section 4(e) conditions, Native 

American traditional cultural values, and Project-induced recreational impacts to 

archaeological properties on or affecting National Forest System lands. The HRMP shall 

also provide measures to mitigate the identified impacts, including a monitoring program, a 

patrolling program, and management protocols for the ongoing protection of archaeological 

properties. 

If, prior to or during ground-disturbing activities or as a result of project operations, items of 

potential cultural, historical, archaeological, or paleontological value are reported or 

discovered, or a known deposit of such items is disturbed on National Forest System lands, 

the Licensee shall immediately cease work in the area affected. The Licensee shall then: (1) 

consult with the California State Historic Preservation Officer (SHPO) and the Forest Service 

about the discovery; (2) prepare a site-specific plan, including a schedule, to evaluate the 

significance of the find and to avoid or mitigate any impacts to sites found eligible for 

inclusion in the National Register of Historic Places; (3) base the site-specific plan on 

recommendations of the SHPO, the Forest Service, and Secretary of the Interior’s Standards 

and guidelines for Archaeology and Historic Preservation; (4) file the site specific plan for 

Commission approval, together with the written comments of the SHPO and the Forest 

Service; and (5) take the necessary steps to protect the sites from further impact until 

informed by the Commission that the requirements have been fulfilled. 

Upon Commission approval, the Licensee shall implement the plan. 

Condition No. 29—Annual Employee Awareness Training 

The licensee shall, beginning the first full calendar year after license issuance, provide 

annual employee awareness training in coordination with the Forest Service. The goal of 

the training shall be to familiarize the licensee’s maintenance and operations staff with 

local Forest Service issues. Topics to be covered in this training include local resource 

issues, special status species, invasive weeds, procedures for reporting to the Forest 

Service, and Forest Service orders that pertain to the Cleveland National Forest lands in 

the vicinity of the project. 

Information on special status species and invasive weeds and their locations in the project 

area shall be provided to licensee’s field personnel. 

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Condition No. 30—Special Status Species 

The Licensee shall, beginning the first full calendar year after license issuance, in 

consultation with the Forest Service, annually review the current list of special status 

plant and wildlife species (species that are, Forest Service Sensitive, Cleveland National 

Forest Watch List, or U.S. Fish and Wildlife Service Federally listed) that might occur on 

National Forest System Lands in the project area directly affected by project operations. 

When a species is added to one or more of the lists, the Forest Service, in consultation 

with the Licensee, shall determine if the species or un-surveyed suitable habitat for the 

species is likely to occur on such National Forest System Lands. For such newly added 

species, if the Forest Service determines that the species is likely to occur on such 

National Forest System Lands, the Licensee shall develop and implement a study plan in 

consultation with the Forest Service to assess the effects of the Project on the species. 

The Licensee shall prepare a report on the study including objectives, methods, results, 

recommended resource measures where appropriate, and a schedule of implementation, 

and shall provide a draft of the final report to the Forest Service for review and approval. 

The Licensee shall file the report, including evidence of consultation, with the 

Commission and shall implement those resource management measures required by the 

Commission. 

Condition No. 31—Ground Disturbing Activities 

Ground disturbing activities on or affecting National Forest System lands may proceed 

only after appropriate NEPA analysis and documentation completion. If the licensee 

proposes new activities to the Commission not previously addressed in the Commission’s 

NEPA analysis processes, the licensee, in consultation with the Forest Service, shall 

determine the scope of work, and the potential project related effects and whether 

additional information is required to proceed with the planned ground disturbing activity. 

The licensee shall enter into a collection agreement with the Forest Service under which 

the licensee shall fund the Forest Service staff time required for staff activities related to 

the analysis and documentation of the proposed activities. 

Condition No. 32—Environmental Monitoring and Adaptive Management 

The licensee shall, within six months after license issuance, or as otherwise indicated, and 

in consultation with the Forest Service and appropriate governmental agencies, develop 

detailed monitoring and adaptive management plans consistent with the applicable 

conditions provided herein. The licensee shall provide the final detailed plans, along 

with all agency comments received and an explanation for any such comments not 

incorporated, to the Commission for final approval. The licensee shall perform the 

environmental monitoring and adaptive management as approved by the Commission. It 

is anticipated that certain details of the environmental monitoring (e.g., specific years of 

sampling and/or specific study sites) and management may need modification during 

development of detailed study plans or during subsequent implementation of the 

environmental monitoring. All such modifications shall be developed in consultation 

with the Forest Service and appropriate governmental agencies, and approved by these 

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agencies and provided to the Commission before implementation. Where years are 

specified, year one is the first full calendar year after issuance of the new license. 

Condition No. 33 -- Vegetation and Invasive Weed Management Plans 

Within one year of license issuance, or prior to any ground disturbing activities, the Licensee 

shall file with the Commission a Vegetation and Invasive Weed Management Plan developed 

in consultation with the Forest Service and the appropriate government agencies. Invasive 

weeds will be those weeds identified in the California Department Food and Agriculture 

(CDFA) code, and other non-native species of concern identified by the Forest Service and 

other resource agencies. The plan will address both aquatic and terrestrial invasive weeds 

within the project boundary and adjacent to project features directly affecting National Forest 

System lands including roads and distribution and transmission lines. 

1) The Invasive Weed Plan will include and address the following elements: 

• Inventory and mapping of new populations of invasive weeds using a Forest Service 

compatible database and GIS software. The Invasive weed GIS data layer will be 

updated annually and shared with other resource agencies. 

• Weed risk assessment. 

• An Integrated Pest Management approach for invasive weed control (IPM evaluates 

alternatives for managing forest pest populations, based on consideration of pest-host 

relationships). 

• Development of a schedule for control of all known A, B, Q (CDFA) and selected 

other invasive weed species, designated by resource agencies. 

• On-going monitoring of known populations of invasive weeds for the life of the 

license in locations tied to Project actions or effects, such as road maintenance, at 

project facilities, O&M activities, new construction sites, etc. to evaluate the 

effectiveness of re-vegetation and invasive weed control measures. 

• Action and/or strategies to prevent and control spread of known populations or 

introductions of new populations, such as: 1) public education and signing, 2) 

vehicle/equipment wash stations, 3) use of certified weed-free hay or straw for all 

construction or restoration needs, and 4) avoidance of use of gravel and fill from 

known weed infested borrow pits. 

New infestations of A & B rated weeds shall be controlled within 12 months of detection 

or as soon as is practical and feasible. At specific sites where other resource objectives 

need to be met, all classes of invasive weeds may be required to be treated. 

Monitoring will be done in conjunction with other project maintenance and resource 

surveys, so as not to require separate travel and personnel. Monitoring information, in 

database and GIS formats, will be provided to the Forest Service as part of the annual 

consultation on affected National Forest resources (Condition No. 5). To assist with this 

monitoring requirement, training in invasive plant identification will be provided to 

Project employees and contractors by the Forest Service to assure that project staff is 

aware of the current location of invasive weeds and how to identify the invasive weeds 

likely to occur in the project area. 

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C-20 

Licensee shall restore/revegetate areas where treatment has eliminated invasive weeds in 

an effort to eliminate the reintroduction of invasive weed species. Project-induced 

ground disturbing activities shall be monitored annually for the first 3 years after 

disturbance to detect and map new populations of Invasive weeds. 

2) The Vegetation Management plan shall include and/or address the following elements: 

• Hazard tree removal and trimming; 

• Powerline/transmission line clearing to comply with electrical safety and fire 

clearance requirements; 

• Vegetation management for native habitat and biodiversity improvement; 

• Revegetation of disturbed sites (including plant palette, planting methods, plant 

densities, propagation materials, and plant maintenance); 

• Soil fertility and moisture analysis, soil grading, soil amendments, soil protection and 

erosion control, including use of certified weed free straw; 

• Use of clean, weed free seed with a preference for locally collected seed,; 

• Use of approved mixes of plant species native to the Cleveland National Forest for 

restoration or erosion control purposes; 

• Irrigation amounts, methods, and schedule; 

• Pest treatment, monitoring, and prevention methods and schedule; 

 

Upon Commission approval, the Licensee shall implement the plan. 

Condition No. 34—Wildlife Management 

The licensee shall, within one year after license issuance, implement the following 

raptor/avian safety measures on National Forest System lands or on areas directly affecting 

National Forest System lands to maintain and enhance existing native wildlife species 

potentially affected by the project: 

• All power lines, power stations, and other facilities on or affecting National Forest 

System lands shall be constructed to conform with the “Suggested Practices for Raptor 

Protection on Power Lines” by the Avian Powerline Interaction Committee (1996), 

including marking the power lines themselves if they are adjacent to Lake Elsinore or in a 

flyway where bird strikes may occur. 

Condition No. 35—Surface Water Resources Management Plan 

The Licensee shall within 6 months after license issuance file with the Commission a 

Water Resources Management Plan that is approved by the Forest Service, for the 

purpose of controlling and monitoring the Project-related effects to water resources on 

National Forest System lands, which are related to the Licensee’s activities. The purpose 

of the plan is to protect ground water related surface water and other ground water 

dependent resources. At a minimum the plan shall: 

1. Develop in consultation with and approved by Forest Service technical specialists and 

their consultants an inventory of springs and other water courses within 1 mile of Morrell 

and Decker canyon and their related riparian areas. The inventory shall include water 

chemistry and physical analysis in addition to monthly and annual hydrographs. Riparian 

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C-21 

areas shall be delineated and inventoried. Inventories shall include flora and fauna 

specific to each water source and shall also include special indicator species (i.e. spring 

snails), as required by the Forest Service technical specialists, which describe the overall 

health of the system. 

2. Develop and implement in consultation with and approved by Forest Service technical 

specialists and their consultants a riparian vegetation and surface water monitoring plan 

addressing springs and other surface water courses in the canyon selected for the storage 

portion of the Pumped Storage Project and their associated riparian areas. Baseline data 

prior to initiation of the project shall be obtained for both water quantity and quality 

because project activities could alter groundwater levels and quality, with subsequent 

alteration of surface water dynamics. The surface water monitoring should include 

intermittent as well as any perennial systems, and should be done no less frequently than 

monthly. Surface water monitoring stations shall be established at locations (e.g., at 

bedrock outcroppings) that would be unlikely to become unusable due to sedimentation 

or erosion. Riparian vegetation monitoring shall include quantifying extent of riparian 

vegetation associated with springs, streams, and other riparian areas. The monitoring 

plan shall be in effect upon approval for pre-construction so that baseline data can be 

established and shall continue for the entire duration of the project while in construction, 

and for the post construction period as long as project related impacts to groundwater 

and/or surface waters are anticipated by the Forest Service technical specialists and their 

consultants. 

Condition No. 36— Groundwater Management Plan 

Within one year of license issuance the Licensee shall file with the Commission a plan 

approved by the Forest Service for the management of groundwater and the associated 

surface waters on or affecting National Forest System lands. The purpose of the plan shall be 

to reduce the potential for groundwater extraction or contamination and related effects to 

surface water resources. At a minimum, the Groundwater Management Plan shall: 

1. Develop in consultation with and approved by the Forest Service technical specialists and 

their consultants a groundwater exploration and aquifer characterization plan which 

includes the use of existing data as well as installation of additional exploration boreholes 

and monitoring wells, aquifer testing (which includes water quality) and geophysics as 

deemed necessary to determine baseline data, construction monitoring data and post 

construction monitoring data for the area potentially impacted by the project. 

2. Groundwater inflow criteria for tunneling will be established by the Forest Service in 

consultation with the co-applicants. Inflow criteria will be approved by the forest service 

prior to construction. 

3. Develop and implement, in consultation with and approved by the Forest Service, a plan 

to monitor and control groundwater levels and tunnel inflows for the duration of the 

construction of the penstocks and tunnels and for a minimum of 10 years post 

construction unless it can be determined that construction related impacts no longer exist. 

This plan may include, but is not limited to, the development and use of a groundwater 

model as well as the installation and use of in-tunnel piezometers, monitoring wells, and 

seepage collars (or other means to control longitudinal flows along the tunnel). 

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4. Develop in consultation with and approved by the Forest Service technical specialists and 

their consultants a groundwater testing and monitoring program for the lined reservoir 

which will detect seepage from the reservoir into the groundwater and riparian areas. 

This monitoring program will remain in place for the life of the permit project. 

5. Develop in consultation with and approved by the Forest Service technical specialists and 

their consultants a groundwater testing and monitoring program for the tunnel (unless a 

final impervious liner is installed prior to commissioning) which will detect seepage from 

the tunnel liner into the groundwater and riparian areas. This monitoring program will 

remain in place for the life of the permit project. 

Condition No. 37 – Scenery Conservation Plan 

Within one year after license issuance, or prior to any ground disturbing activities, the 

Licensee shall file with the Commission a Scenery Conservation Plan that is approved by the 

Forest Service. The purpose of the Plan is to identify actions that will minimize the project’s 

visible disturbance to the naturally established landscape. Implementation of the Plan will 

achieve the greatest degree of compatibility possible with the Cleveland National Forest 

Land and Resource Management Plan Scenic Integrity Objectives. 

In order to achieve the greatest consistency with the “High” Scenic Integrity Objective 

(natural appearing conditions), the project shall integrate the following design 

recommendations into the Scenery Conservation Plan: 

• Powerline - Transmission lines shall be nonspecular (nonreflective) and dark as 

possible. The towers shall be custom-colored with a flat, nonreflective finish, to 

visually blend with the native vegetation colors and be as visually transparent as 

possible within the natural landscape pattern. Towers shall be designed to minimize 

their visual prominence and contrast to the natural landscape. Vegetation and 

ground clearing at the foot of each tower and between towers will be limited to the 

clearing necessary to comply with electrical safety and fire clearance requirements. 

Mitigation will be incorporated to reduce the visual impact of vegetation clearing. 

• Reservoir – The upper storage reservoir shall be surrounded by a berm with 

irregular form and profile to reflect the local topography, which shall also be 

revegetated with adjacent native species. Screen views into the reservoir that may 

otherwise be visible along the adjacent sensitive roadways (South Main Divide and 

Ortega Highway), recreation areas, trails and wilderness. Security fencing shall be 

colored to blend with the planted/restored native vegetation. 

• Roads - New temporary roads (maximum 15% ground slope) or roads needing 

reconstruction/expansion shall be configured to minimize the creation of cut/fill 

slopes, and where such slopes are created, they shall be immediately treated to 

minimize their level of scenery disturbance. These treatments may include 

construction of structural elements designed to blend with the adjacent natural 

scenery, or revegetation with native species. 

• Penstock Pipes – Penstocks shall be located in underground tunnels and any 

associated ground disturbance shall be reshaped to natural appearing contours and 

revegetated with native species. 

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C-23 

• Structures – All structures and structural elements, that may be constructed as part 

of the Project shall be designed, located, shaped, textured, colored and/or screened 

as necessary to minimize their visual contrast, blend, and complement the adjacent 

forest and community architectural character. 

The Licensee may be required to provide photorealistic visual simulations of proposed 

designs and mitigation measures to demonstrate their effectiveness in achieving Land and 

Resource Management Plan Scenic Integrity Objectives for the Elsinore Place as viewed 

from sensitive viewsheds. Where project features create unavoidable scenery effects that are 

inconsistent with those Scenic Integrity Objectives, additional scenery enhancement activities 

approved by the Forest Service shall be performed in the nearest suitable areas to offset the 

direct effects of those project features. 

Condition No. 38 -- Habitat Mitigation Plan 

Within 1 year from license issuance or prior to any ground disturbing activities, and before 

starting any activities the Forest Service determines to be of a land-disturbing nature on or 

affecting National Forest System land, the Licensee shall file with the Commission a Habitat 

Mitigation Plan approved by the Forest Service. This plan must identify requirements for 

construction and mitigation measures to meet Forest Service habitat objectives and standards. 

Where project features create unavoidable effects that are inconsistent with Cleveland 

National Forest Land and Resource Management Plan Habitat Objectives, additional 

enhancement activities shall be performed to offset the direct effects of project construction. 

The enhancements would be most appropriately located within the project area, but if 

opportunities are not fully available there, then alternatively and in order of priority, to be 

located elsewhere within the Elsinore “Place”, the Trabuco Ranger District, or the Cleveland 

NF. The plan also must include dates for accomplishing these objectives and standards and 

must identify needs for and timing of any additional studies necessary. The plan must consist 

of the following minimum mitigation ratios for permanent loss of habitat: 

1:1 for habitats that are sensitive or support listed species 

1:1 for coastal sage scrub 

1:1 ratio for riparian oak woodland 

-ENDDocument Accession #: 20070130-4000 Filed Date: 01/30/2007
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Document Accession #: 20070130-4000 Filed Date: 01/30/2007
COVER SHEET 

FEDERAL ENERGY REGULATORY COMMISSION 

FINAL ENVIRONMENTAL IMPACT STATEMENT 

FOR HYDROPOWER LICENSE 

Lake Elsinore Advanced Pumped Storage Project 

Docket No. P-11858-002 

Appendix D 

Visual Simulations 

Pages D-1 to D-22 

FEIS 

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APPENDIX D 

Visual Simulations 

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D-1 

Location of viewpoints for photo simulations D.1-a through D.6 

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D-2 

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D-3 

D.1-a–Decker Canyon upper reservoir site looking north along South Main Divide Road, Before and After 

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D-4 

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D-5 

D.1-b–Decker Canyon upper reservoir site looking south along South Main Divide Road, Before and After 

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D-6 

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D-7 

D.2–Santa Rosa Powerhouse Site looking west from Grand Avenue, Before and After 

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D-8 

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D-9 

D.3–Northern sub-station looking west from I-15, Before and After 

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D-10 

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D-11 

D.4-a–Co-Applicants proposed transmission alignment, northern segment, looking west from Lake Elsinore boat ramp, Befo

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D-12 

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D-13 

D.4-b–Co-Applicants proposed transmission alignment, southern segment, looking west from Lake Elsinore boat ramp, Before 

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D-14 

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D-15 

D.5-a–Staff alternative transmission alignment, northern segment, looking west from Lake Elsinore boat ramp, Before and Aft

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D-16 

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D-17 

D.5-b–Staff alternative transmission alignment, southern segment, looking west from Lake Elsinore boat ramp, Before and Af

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D-18 

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D-19 

D.6-a–Co-Applicants proposed transmission alignment, southern segment, looking west from La Cresta, Before and After 

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D-20 

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D-21 

D.6-b–Staff alternative transmission alignment, southern segment, looking west from La Cresta, Before and After 

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D-22 

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COVER SHEET 

FEDERAL ENERGY REGULATORY COMMISSION 

FINAL ENVIRONMENTAL IMPACT STATEMENT 

FOR HYDROPOWER LICENSE 

Lake Elsinore Advanced Pumped Storage Project 

Docket No. P-11858-002 

Appendix E 

Comments on the Draft Environmental Impact Statement and the 

October 3, 2006, Public Notice for the Lake Elsinore Advanced Pumped 

Storage Project, Project No. 11858-00 

Pages E-1 to E-92 

FEIS 

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APPENDIX E 

Comments on the Draft Environmental Impact Statement 

and the 

October 3, 2006, Public Notice 

for the 

Lake Elsinore Advanced Pumped Storage Project 

Project no. 11858-002 

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APPENDIX E 

COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT 

FOR THE 

LAKE ELSINORE ADVANCED PUMPED STORAGE PROJECT 

PROJECT NO. 11858-002 

The Federal Energy Regulatory Commission (Commission or FERC) issued its draft 

environmental impact statement (EIS) for the licensing of the Lake Elsinore Advanced Pumped Storage 

Project (LEAPS Project) on February 17, 2006. The Commission requested comments be filed by April 

25, 2006. In addition, the Commission conducted two public meetings on April 4 and 5 in the cities of 

San Juan Capistrano and Lake Elsinore. In this appendix, we summarize the written comments received; 

provide responses to those comments; and indicate, where appropriate, how we have modified the text in 

the final EIS. We grouped the comment summaries and responses by topic for convenience. The 

following entities filed comments on the draft EIS:

Commenting Entity Filing Date 

Elsinore Hang Gliding Association March 6, 2006 

Robert V. Wills March 13, 2006 

Michael Wayne Smith March 23, 2006 

Bill Soderquist, Elsinore Hang Gliding Association March 25, 2006 

Jeeni Criscenzo April 4, 2006 

Nick Bimbo et al. (letter filed by 13 individuals) April 5, 2006 

Elsinore Valley Municipal Water District April 6, 2006 

Palomar Observatory April 7, 2006 

Elsinore Hang Gliding Association April 11, 2006 

Endangered Habitat League April 12, 2006 

Jay Scott et al. (letter filed by 33 individuals) April 17, 2006 

John and Soma Stickler April 17, 2006 

LaCresta Property Owners Association April 19, 2006 

John Pecora April 19, 2006 

County of Riverside April 20, 2006 

Michael Hilberath et al. (letter filed by five individuals) April 20, 2006 

Peter Dawson April 21, 2006 

U.S. Department of the Interior April 21, 2006 

Deanna and Charles Whitney April 22, 2006 

David Anderson April 24, 2006 

Elsinore Testing of Experimental Aircraft Mechanisms, Inc. (Francis Hoffman) April 24, 2006 

Friends of the Forest (Trabuco District) April 24, 2006 

Douglas Pinnow April 24, 2006 

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Commenting Entity Filing Date 

California Regional Water Quality Control Board, Santa Ana April 25, 2006 

California Department of Fish and Game April 25, 2006 

Center for Biological Diversity, Sierra Club April 25, 2006 

City of Lake Elsinore April 25, 2006 

Elsinore Valley Municipal Water District (two letters) April 25, 2006 

Fernandez Partiesa

 April 25, 2006 

Chris Hyland April 25, 2006 

Robert and Susan Konoske April 25, 2006 

Jerry Mosier April 25, 2006 

Lake Elsinore United School District April 25, 2006 

Natural Resources Defense Council April 25, 2006 

Pacific Clay Industries April 25, 2006 

Rancho Capistrano Property Owners Association April 25, 2006 

Linda Lou and Martin Ridenour April 25, 2006 

State Water Resources Control Board April 25, 2006 

California Native Plant Society (Orange County Chapter) April 26, 2006 

Jon Johnson April 26, 2006 

Andrew and Sandra Mauthe April 26, 2006 

San Diego Gas & Electric Company April 26, 2006 

Edith Stafford April 26, 2006 

Edwin Thorell April 26, 2006 

David Voss April 26, 2006 

Scott Werner April 26, 2006 

Ruth Atkins April 27, 2006 

Bruce Campbell April 27, 2006 

Lake Elsinore Sailing Club April 27, 2006 

Lakeland Village/Wildomar Redevelopment Project Area Committee April 27, 2006 

Anna Lee April 27, 2006 

Pechanga Band of Luiseno Indians April 27, 2006 

U.S. Environmental Protection Agency April 27, 2006 

U.S. Marine Corps (Camp Pendleton) April 27, 2006 

County of Orange May 1, 2006 

Luis Stahl May 1, 2006 

Honorable Darrell Issa , Honorable Ken Calvert, Honorable Mary Bono, Honorable 

Duncan Hunter May 2, 2006 

Charles Jancic May 3, 2006 

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Commenting Entity Filing Date 

US Army Corps of Engineers, Los Angeles District May 8, 2006 

Elsinore Valley Municipal Water District May 31, 2006 

a

 Miller, Staff, & Regalia filed on behalf of Friesian Focus, LLC, the Fernandez Trust, and Joseph and Joan 

Fernandez (collectively “Fernandez Parties”). 

In addition to the above-listed filings, 95 individuals from the project area filed letters in 

opposition to the proposed project citing general concerns. These individuals are listed at the end of 

Appendix E. Also, organizations and individuals filed several letters echoing the same themes. We 

summarize these letters as follows: 

(1) On April 25, 2006, the Commission received 1,905 letters from individuals across the 

country outside of the project area requesting that the Commission adopt the No-action Alternative. 

These individuals oppose the potential destruction of wilderness-quality and oak trees in Morrell Canyon, 

the potential effects on world class hang gliding opportunities, and the potential effects on nesting 

shorebirds in one of Riverside County’s most important wildlife reserves. 

(2) The San Diego Chapter of the Sierra Club filed 151 postcards from residents of San 

Diego County on April 25, 2006, and the Los Angeles Chapter of the Sierra Club filed 430 comment 

cards (signed by 430 individuals) on April 27, 2006, saying that we need to preserve both Decker and 

Morrell canyons in the Santa Ana mountains and stop the proposed pumped storage project from 

destroying a prized recreational area and drowning the rare southern oak forest. 

(3) By letters filed on April 26 and 28, 2006, 200 individuals from the project area oppose 

the proposed project citing concerns about risks to the environment, property, and people. Specifically 

they state that the project would violate the Cleveland National Forest Land Management Plan and would 

harm the San Mateo Wilderness Area, create a risk of flooding, complicate fire fighting, encourage offroad vehicle trespass, and put hang gliders at risk. They also question the need for the project, the 

competence of the co-applicants, and the adequacy of the environmental studies completed in support of 

the project. They urge adoption of the No-action Alternative for a project anywhere in the Cleveland 

National Forest. These individuals are listed at the end of Appendix E. 

These general letters provide comments similar to those comments provided in the letters listed 

above. We address all the issues, as appropriate, in the final EIS. Comments regarding purely editorial 

issues are addressed in the final EIS and are not summarized below. 

GENERAL 

Comment 1: Ninety-five regional residents filed letters with general comments about consideration of 

alternative energy sources and the potential effects of the proposed project on the environmental and 

recreational resources of Decker and Morrell canyons, including the disturbance of natural springs, 

removal of California live oak trees, interruption of use of hiking trails and hang glider launch sites, and 

interference with fire fighting activities; changes in the water quality and recreational boating use on Lake 

Elsinore; on the property values, and aesthetics qualities. These regional residents encourage the 

Commission to take no action. 

Response: We appreciate the general comments put forth by regional residents and have addressed them, 

as appropriate, throughout the final EIS. 

Comment 2: David Voss, Charles and Deanna Whitney, and other individuals question how the 

Commission could issue a license to an entity that has had no prior experience in the construction and 

operation of a pumped storage facility and transmission line. 

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Response: Under the Federal Power Act (FPA), any citizen, municipality, corporation, or Indian tribe 

can apply for a hydropower license. The Commission will consider whether the Nevada Hydro Company 

(Nevada Hydro) and the Elsinore Valley Municipal Water District (Elsinore Valley MWD), as coapplicants, can comply with the terms of a license and safely manage and operate the project to provide 

efficient and reliable service in any order issued for this project. 

PURPOSE AND NEED 

Comment 3: Jenni Criscenzo states that the conclusions of the draft EIS are in direct conflict with the 

goals of the San Diego Association of Governments as published in May 2003 in Energy in 2030: The 

San Diego Regional Energy Strategy. She also states that as an energy consumer, the LEAPS Project is 

in conflict with the State law (SB 1037) that requires all utilities to meet their unmet resource needs first 

with energy efficiency and demand reduction resources that are cost-effective, reliable, and feasible. She 

points out that Southern California Edison (SCE) and San Diego Gas & Electric Company (SDG&E) 

might not actually be permitted to purchase power generated by LEAPS after meeting all of their legal 

and regulatory requirements. 

Response: If the Commission decides to grant a license to the project, it is the responsibility of the coapplicants to then secure a power purchase agreement. 

Comment 4: The Friends of the Forest question how the Commission can accept a license application 

that includes a transmission line that the Commission does not have the authority to grant. 

Response: The Commission has authority to license a transmission line from a waterpower project to the 

“point of junction” with the interconnected primary transmission system, in this case the SDG&E and the 

SCE systems. Appendix B-7 provides further explanation of this project’s point of junction. We have 

deleted paragraph 1.2.3.3 on page B-8 from the final EIS as the Talega-Escondido/Valley Serrano 500 

kilovolt (kV) Interconnect Project (TE/VS Interconnect) transmission line is not being proposed as a 

separately permitted transmission line. 

Comment 5: Pacific Clay and the Center for Biological Diversity state that the statement of Purpose and 

Need in the draft EIS is inadequate because it does not provide a meaningful discussion of why the 

project is the best comprehensive plan for improving and developing Lake Elsinore; whether the project 

forwards the purposes of energy conservation, the protection of fish and wildlife, and promotion of 

recreation; and whether there are feasible alternative energy sources or other feasible project locations. 

They state that there is no discussion of the likelihood of a transmission line only portion of the project 

going forward without the hydropower portion. 

Response: Section 1.2.1 of the draft EIS describes the current and future demand for electricity in the 

California-Mexico Power area of the Western Electricity Coordinating Council (WECC) and the specific 

role that a pumped storage project could play in helping to meet the future energy demand. The draft EIS 

is intended to disclose the potential effects of the proposed project on the environmental resources of the 

projects. The draft EIS provides an analysis of the effects of each project component, including the 

transmission line, as summarized in table 53. Decisions about whether or not to license the proposed 

LEAPS Project or the TE/VS Interconnect will be addressed in any license order issued by the 

Commission and in any Record of Decision issued by the USFS. 

Comment 6: The Friends of the Forest state that there is no market for large-scale pumped storage 

projects, citing four examples of projects licensed by the Commission between 1991 and 1997 for which 

the Commission terminated the licenses because construction had not begun. They request that the final 

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EIS include information about pumped storage projects licensed by the Commission during the past 20 

years. 

Response: Whether pumped storage projects licensed by the Commission during the past 20 years have 

been built or terminated is not relevant to current proceeding. An applicant may apply for a license for a 

pumped storage project and the Commission must consider any application on a case-by-case basis that 

meets the regulatory requirements. 

Comment 7: The Friends of the Forest and Charles and Deanna Whitney point out that SDG&E has 

eliminated the LEAPS Project transmission alignment as a preferred route in the Southwest Transmission 

Expansion Plan (STEP) process, finding it not suitable from a construction and maintenance point of 

view; that the Los Angeles Department of Water and Power and Imperial District have announced the 

Green Path Project; and that a new 775-megawatt (MW) combined power plant is under construction less 

than a mile from the Valley substation. They conclude that Nevada Hydro has overstated its case relative 

to the need for power. 

Response: The proposed transmission line is currently a primary line associated with the proposed 

advanced pumped storage facility. The draft EIS states that the WECC anticipates that 6,783 MW of new 

capacity would come on line in the next 10 years, including the combined power plant under construction 

near the Valley substation. About 390 MW of hydroelectric pumped storage, not including the LEAPS 

Project, is included in this forecast. Of interest is not the amount of new capacity, but the type of capacity 

that would be provided by pumped storage. Pumped storage generates and stores power during off-peak 

periods that can be provided rapidly during on-peak periods when supplies of energy are tight. 

Comment 8: The State Water Resources Control Board (State Water Board) states that the final EIS 

should compare the estimated consumer energy costs of the project with the estimated consumer energy 

costs resulting from the development of a 500-MW gas-powered combined cycle facility with peaking 

abilities in the South Coast Region. It states that this comparison should include a discussion of the 

relative project footprints and the cost and feasibility of mitigation for each. 

Response: Our developmental analysis considers the No-action Alternative to include a 500-MW gaspowered simple cycle turbine. We refer to “Comparative cost of California central station electricity 

generation technologies” (CEC, 2003) as the basis for making this selection. The document describes 

simple-cycle turbines as operating in a peaking mode, which staff concludes is a reasonable basis for 

comparison to pumped storage projects. The document estimates that 50 acres would be required for a 

100-MW simple-cycle combustion turbine plant. A 500-MW plant would likely require less than 

250 acres due to economies of scale. Such a plant would require emissions controls and various 

environmental permits.

Comment 9: The State Water Board states that staff should take note of the recent agreement of seven 

utilities to underwrite the economic and environmental studies for a transmission line that would bring 

electricity to California from out-of-state generation sources, known as the “Frontier Line.” The cost and 

need for the TE/VS Interconnect Project should be considered in light of the “Frontier Line” Project and 

its place in the STEP.

Response: We note that the transmission system expansion alternatives proposed under the “Frontier 

Line” Project would partially address energy transmission needs in the Western states. However, the 

project’s feasibility study and conceptual plan were only recently announced (April 2006) and will take 

approximately 12 months to complete. Therefore it is premature to consider it in the final EIS. 

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Comment 10: Bill Soderquist, on behalf of the Elsinore Hang Gliding Association, presented a list of 

new power projects that have gone online or are due to go online since the project was proposed. He 

states these projects are adequate to supply the new demand. 

Response: We appreciate the research by Mr. Soderquist into new power projects serving the California 

area. Our basis for the Need for Power section of the draft EIS is the 10-Year Coordinated Plan 

Summary: Planning and Operation for Electric System Reliability (WECC, 2005). We note that table 30 

on page 49 of this document provides information similar to the information provided by Mr. Soderquist 

and that project generation additions and retirements are included in the WECC analysis. We continue to 

rely on the WECC assessment that says by 2014, California will have to add 6,783 MW of new capacity 

of which pumped storage could be a part. 

Comment 11: The Army Corps of Engineers (Corps) recommends adding to the final EIS an explicit 

explanation of why a 500-MW capacity facility is needed, as opposed to a lesser amount of capacity. 

Response: We previously requested clarification on the selection of the proposed installed capacity from 

the co-applicants. The co-applicants responded in Clarification (4) (c) to their November 12, 2004, 

deficiency letter response that the 500-MW facility optimizes the site and available equipment 

configurations, doing so in an economical manner. We note that for pumped storage the amount of 

capacity installed is highly sensitive to the power purchasers’ load shape, and the co-applicants have not 

indicated who would purchase the energy generated by the project. 

Comment 12: Edwin Thorell states that power production can be better produced by using “peakers” 

powered from methane produced by Elsinore Valley MWD’s plant. He also states that solar power and 

wind power are better investments than the proposed project. 

Response: As noted in the draft EIS, forecasts of new capacity do not treat wind power as firm capacity 

because of the intermittent nature of wind. Although other sources of energy may evolve, the coapplicants propose a pumped storage facility and our need for power addresses the role of pumped storage 

in the energy resource mix for the region. 

Comment 13: The Natural Resources Defense Council states that the project’s use of nuclear power and 

its associated environmental effects must be examined under the National Environmental Policy Act 

(NEPA). 

Response: The co-applicants have not indicated that they have generation contracts with nuclear power 

providers at this time and, in any event, the environmental effects associated with nuclear power would 

have been disclosed in the NEPA analysis associated with the Nuclear Regulatory Commission’s 

proceeding. 

PROCEDURAL 

Comment 14: Nevada Hydro requests that the Cover Sheet and Abstract be revised to state that the 

project transmission lines are located in Orange and San Diego counties. It also requests that figure 1 

show the locations of the pumped storage facility as well as the proposed transmission alignment. 

Response: We have revised the Cover Sheet and Abstract to include all the counties within which the 

proposed project is located. We have revised figure 1 to expand the project location box to include the 

transmission component of the proposed project. 

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Comment 15: Nevada Hydro requests that the Purpose of Action discussion on page 1-1 of the draft EIS 

be revised to say that the Commission and the USFS have agreed to participate as cooperating agencies in 

the preparation of an EIS for the LEAPS Project and for the TE/VS Interconnect Project so that the EIS 

can by used by the Commission, the USFS, and other agencies as the environmental basis for any and all 

actions that may be required from those federal agencies from whom discretionary actions are required. 

Response: The Commission invited the USFS to participate as cooperating agency for the preparation of 

an EIS for licensing of the LEAPS Project. The LEAPS Project, as proposed by the co-applicants, 

includes an upper and lower reservoir, water conduits, a powerhouse, tailrace channel, an intake/outlet 

structure, and 30 miles of transmission lines. The co-applicants also filed a separate special use permit 

application with the USFS for permission to occupy Cleveland National Forest lands to construct and 

operate the stand alone TE/VS Interconnect Project. The jointly prepared EIS will provide the 

environmental disclosures necessary for the Commission to make a decision on whether to issue a 

hydropower license and, if it so chooses, for the USFS to make a decision on whether to issue a special 

use permit to allow the LEAPS Project to occupy Cleveland National Forest lands. The Commission is 

not cooperating with the USFS on any decision related to the transmission alone project. 

Comment 16: The Friends of the Forest point out that it filed a motion to intervene on June 2, 2004, but 

was not listed as an intervener on page 7 of the draft EIS. 

Response: We have corrected this oversight and have listed Friends of the Forest in the list of interveners 

in the final EIS. 

Comment 17: The Friends of the Forest question why the Commission chose not to use the Docket 

ER06-278 service list to notify parties in the P-11858 proceeding that ER06-278 had been opened for 

comments and interventions. They request that the record of ER06-278 be made part of the record in the 

P-11858 proceeding. 

Response: These are two separate Commission proceedings with separate dockets and service lists. 

Comment 18: Many individuals state that they did not receive any written notice that their property was 

in the path of the transmission alignment and question whether proper notification procedures have been 

followed. 

Response: The co-applicants followed the Commission’s notification requirements under 18 CFR § 

4.32(a)(3)(i)(A). The Commission issued a public notice on October 3, 2006, to all owners of record to 

ensure that every owner who could be directly affected by the proposed and alternative transmission 

alignments (presented in the final EIS) received notification and had an opportunity to comment on the 

proposed and alternative actions prior to issuance of the final EIS. 

Comment 19: Riverside County recommends that an additional public hearing be held in the local area 

because many people were forced to stand outside and were unable to hear the proceedings at the only 

Commission-conducted public hearing previously held. 

Response: As noted by others in attendance, the alternative sites for the public meeting were no larger 

than the neutral site selected for the meeting. We note that everyone who wished to speak at the public 

meetings held on April 4 and 5, 2006, was able to do so and everyone who wished to file written 

comments could do so. Transcripts from the scoping meetings and the public meetings on the draft EIS 

are available on eLibrary through the Commission’s web site. 

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Comment 20: Riverside County requests that it be notified of any and all additional hearings and be 

provided future reports prepared for this project so that it has the opportunity to review and coordinate 

regarding project-related effects on Riverside County activities. 

Response: Riverside County filed a motion to intervene and as such will receive all Commission 

issuance and other filings in this proceeding. 

Comment 21: The Fernandez Parties state that the Commission does not have authority over the 

Interconnect Project, and therefore that portion of the project needs to be redirected to the California 

Public Utilities Commission.

Response: The co-applicants propose a pumped storage project with a primary transmission line to 

convey the energy produced to the grid. Until an interconnection with the grid is achieved, the primary 

line is clearly within the Commission’s authority to license. 

PROPOSED ACTION AND ALTERNATIVES 

Comment 22: SDG&E states that the final EIS should evaluate the statement in section 2.2 of the draft 

EIS: “Pumped storage does not depend on fossil fuels and is not subject to supply disruptions” to 

determine the fuel source for unit at margin during off-peak pumping periods since the project is a net 

consumer of energy. The Center for Biological Diversity also expresses this concern. 

Response: The co-applicants have stated their intent to pursue off-peak generating sources, such as 

geothermal, wind, and other non-fossil based energy sources. We recognize that until they negotiate a 

power sales agreement, the final off-peak fuel mix would not be fully defined. We have therefore 

modified the statement referenced accordingly. We note that as long as there is water in the upper 

reservoir, it can be dispatched for power; however, once empty, the project is dependent on electricity for 

refill. 

Comment 23: Nevada Hydro suggested several modifications to the proposed project including: 

(1) using a single high pressure conduit rather than two parallel high pressure conduits from the upper 

reservoir to the powerhouse; (2) changing the proposed generator voltage from 13.8 kV to 16 kV and 

changing oil-filled cables to gas-insulated cables; and (3) accelerating the construction schedule from 4.5 

to 3 years. Nevada Hydro also revised its proposed transmission alignment: (1) to relocate the southern 

substation from the Tenaja area to an area south of the existing Case Springs Fire Station within the 

existing SDG&E right-of-way; (2) to include underground segments near the hang gliding launch areas 

and between the upper reservoir and the powerhouse; (3) and to provide preliminary tower sites along the 

revised proposed alignment. 

Response: In subsequent clarification communication with Commission staff (personal communication, 

D. Kates, Nevada Hydro, Vista California, and James Fargo, Commission, Washington, DC, on May 26, 

2006), Nevada Hydro indicated that the co-applicants were not formally modifying their proposed action 

to include changes to the high pressure conduit design or to accelerate the construction schedule. 

Therefore, we present only the co-applicants’ revised transmission alignment and analyze the effects of 

this proposed alignment along with the preliminary tower placements in the final EIS. 

Comment 24: Nevada Hydro requests that several measures proposed by the co-applicants in the license 

application and subsequent filings be deleted, modified, or clarified as follows: 

(1) Nevada Hydro no longer proposes to develop and implement a revised lake operating 

plan for Lake Elsinore, addressing increased minimum lake levels, flood control implications, and water 

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supply issues; instead, Nevada Hydro proposes to work cooperatively with the agencies in authority 

(pages 2-13 and 5-11 of the draft EIS). 

(2) Nevada Hydro requests the deletion from the EIS the measure to reduce the maximum 

operational drawdown during summer months following a winter with below-normal precipitation to 

control algal blooms that could result in fish kills (pages 2-14 and 5-12 of the draft EIS) because the coapplicants no longer propose this measure. 

(3) Nevada Hydro requests that the proposed measure to acquire and demolish the multifamily residences nearest the proposed powerhouse site to address potential adverse effects on residents 

during construction (pages 2-15 and 5-13) be clarified to state that it pertains to the Santa Rosa site and be 

modified to allow the co-applicants to use these properties to provide relocation assistance or for 

construction purposes, and to return these properties to the regional housing inventory or other productive 

uses, following completion of construction. 

(4) Nevada Hydro states that it is currently the co-applicants’ objective to achieve a balance 

of excavation and fill materials (pages 2-15 and 5-13 of the draft EIS) but requests that this objective be a 

target rather than an absolute requirement because it may be difficult to achieve for the construction of the 

transmission line. 

(5) Nevada Hydro states that it agrees to provide a fair-share contribution toward the 

installation of a traffic signal at the Grand Avenue/Ortega intersection but requests that the appropriate 

state or local agency establish the need for the signal, develop plans and cost estimates, identify the 

proportion of costs associated with the proportion of project-related traffic use and that the co-applicants 

contribute funding rather than be responsible for implementation of the improvement. 

(6) Finally, Nevada Hydro asks that the proposed measure to conduct all construction 

activities in accordance with the noise element of the county of Riverside Comprehensive General Plan 

and city of Lake Elsinore construction noise standards be revised to allow the co-applicants to conduct 

24-hour construction operations subject to further noise studies demonstrating that, as proposed or 

modified, no sensitive receptors would be exposed to noise that exceeds the locally established standards. 

Response: We removed the proposed measure to prepare a revised lake operating plan for Lake Elsinore 

from the co-applicants’ proposed measures in section 2.3.6 and have added this measure to the staff 

alternative in section 2.4.3.2. We have deleted the proposed measure to reduce the maximum operational 

drawdown during summer months following a winter with below-normal precipitation. We concluded in 

the draft EIS that this measure is not necessary because the lake level would be maintained at or above 

1,240 feet mean sea level (msl). We have revised the text in section 2.3.6 and 5.1.1 to indicate that 

housing acquired within the construction right of way could be returned to the regional housing market 

upon completion of construction. The staff-recommended measure only pertains to achieving a balance 

of excavation and fill materials at the upper reservoir. We would expect that the specifics for 

participating in the installation of any traffic signal would be addressed in the co-applicants’ proposed 

road and traffic management plan. In their comments on the draft EIS filed on April 25, 2006, the coapplicants suggested and then withdrew their suggestion during a clarifying phone call with Commission 

staff on May 26, 2006, to accelerate the construction schedule, eliminating any need for studies to 

demonstrate that 24-hour construction would not violate local ordinances. 

Comment 25: Linda and Martin Ridenour comment that the figures 2 and 3 in the draft EIS do not show 

the many homes, apartments, and schools that would be affected by the proposed project, the individual 

lakeside properties that would be affected, or the exact location of the inlet/outlet structure. They also 

comment that figures 5 and 6 do not include enough detail and suggest that the final EIS include a 

satellite map showing the location of houses near the transmission lines so that people can comment on 

the effect on their properties. 

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Response: Figures 2 and 5 show the approximate location of the inlet/outlet structure in Lake Elsinore. 

Appendix F of the final EIS includes aerial photographs that show the co-applicants’ proposed and staff 

alternative transmission alignments. These aerial photographs also were sent to property owners of 

record within 0.25 mile of the co-applicants’ proposed and staff alternative transmission alignments. 

Comment 26: Nevada Hydro points out that some language in the draft EIS (e.g., page 3-136) is 

inconsistent with the co-applicants’ proposal and with USFS preliminary 4(e) condition no. 28 that would 

provide a day-use area at either the upper reservoir construction staging and laydown area or elsewhere. 

Response: USFS revised preliminary 4(e) condition no. 27 adopts the co-applicants’ alternative 4(e) 

language and now allows for an alternative location for the day-use area. We have revised the final EIS 

to eliminate the inconsistent language in the terrestrial resources analysis. 

Comment 27: Linda and Martin Ridenour provide comments on the USFS 4(e) conditions citing the 

need for detailed plans in order to evaluate effects. They comment that a special use permit should not be 

granted without more detailed information about vegetative fuel management, road and traffic 

management, recreational facilities (how will the USFS specified facility relate to the county trail 

system?), protection of historic properties, and protection of wildlife (information on the Pacific flyway). 

Response: Site-specific analysis would be required before issuance of a special use authorization. A 

vegetation fuel treatment plan (condition no. 9), a vegetation and invasive weed management plan 

(condition no. 33), road and traffic management plan (condition no. 26), recreation facilities and 

administration plan (condition no. 27), historic properties management plan (condition no. 28), and a 

wildlife management plan (condition no. 34) would be required prior to construction and within 1 year of 

any license issued. The only system trail that may be affected is the Morgan Trail, which has been 

analyzed within the draft EIS (section 3.3.6.2). 

Comment 28: Nevada Hydro states that, as described in section 2.3.4 of the draft EIS, the staff 

alternative transmission alignment would be a circuitous rather than a linear configuration that would 

require additional tower fortifications and additional temporary or permanent access roads. Nevada 

Hydro also suggests that figures 5 and 6 show a corridor rather than a specific transmission alignment. 

Response: Commission and USFS staff modified the staff alternative transmission alignment to provide 

a more linear configuration and to minimize effects on the wilderness area and back-country nonmotorized areas within the Cleveland National Forest. The figures included in volume 1 of the license 

application identified the primary transmission line as a transmission alignment and we describe the 

proposed route as an alignment in the EIS to be consistent. We consider the alignment to represent a 500-

foot-wide corridor with a 200-foot-wide permanent right-of-way. 

Comment 29: Nevada Hydro assumes that the staff-recommended measure for a plan to determine the 

toxicity of sediments in the lakebed relates only to the lake area that would be directly impacted by 

construction activity and only to the identification of toxins above actionable levels and does not 

encompass the entire lake or extend beyond areas of direct disturbance. Nevada Hydro requests that the 

measure be clarified to reflect these assumptions. 

Response: Your assumptions are correct, and we have revised section 2.4.3.2 in the final EIS to clarify 

the scope of the recommended plan. 

Comment 30: Nevada Hydro provides updated information on the housing development at Ortega Oaks 

and states that subdivision approvals in April 2004 and unknown to the co-applicants would increase both 

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the cost and the complexity of constructing the powerhouse at the Ortega Oaks site substantially. Nevada 

Hydro states that if the license is restricted to the Ortega Oaks site, there would remain an unresolved 

question concerning whether the co-applicants could feasibly and reasonably secure the Ortega Oaks site. 

Nevada Hydro also points out that its study reports show that of the three powerhouse sites, the Ortega 

Oaks site possesses the least desirable subsurface conditions, (i.e., the site offers greater geotechnical 

challenges and design-level obstacles). Nevada Hydro requests that both the Commission license and the 

USFS permit authorize use of either the Santa Rosa or Evergreen powerhouse sites in the event that the 

Ortega Oaks property cannot be feasibly or reasonably acquired. 

Response: We have reviewed your filing including the information about the permitted housing 

development at the Ortega Oaks powerhouse location. Based on this new information and on other 

considerations, the staff alternative now includes the Santa Rosa powerhouse location. 

Comment 31: Nevada Hydro states that the Decker Canyon upper reservoir site offers the most direct 

(and least expensive) connection to the Ortega Oaks powerhouse site. If that site is not feasibly acquired, 

the Decker Canyon upper reservoir site would not offer the most direct (and least expensive) connection 

to either the Santa Rosa or Evergreen powerhouse sites. It states that as the distance between the upper 

reservoir and powerhouse increases, so does the penstock tunnel length between these two facilities. 

Because tunneling costs represent one of the greatest construction line-item costs, it is important to 

maintain relative proximity between the powerhouse and upper reservoir. Nevada Hydro provides a 

wetland delineation report in the April 15, 2006, filing (attachment F) that states “While some minor 

differences in the overall species composition and structure of the drainage features exist, their functions 

are considered similar.” Nevada Hydro states that given the findings of the wetland delineations, the 

avoidance of jurisdictional waters, in and of itself, does not provide a supportable basis for the selection 

of one upper reservoir site over the other. Further, because Decker Canyon contains 0.3 acre of waters of 

the United States, it does not meet the definition of a practicable alternative pursuant to 40 CFR 230.10. 

Response: We have reviewed the new information on wetlands provided in attachment F to your 

comments on the draft EIS. The potential effect on wetlands is only one of several issues we considered 

in determining the effects of the construction and operation of the upper reservoir at the Decker Canyon 

and Morrell Canyon locations. We continue to conclude that construction of the upper reservoir at 

Morrell Canyon would have greater effects on Lion Spring, oak woodlands, and recreational use of trails 

and hang gliding launch sites. 

Comment 32: Nevada Hydro states that if the Ortega Oaks powerhouse site cannot be acquired, the staff 

alternative transmission alignment would need to be modified to facilitate connection to either the Santa 

Rosa or Evergreen powerhouse sites. With the exception of the northernmost segment, Nevada Hydro 

does not have any objection to the staff alternative transmission alignment. However, it continues to 

believe that, with the exception of that segment located near the area now used as a principal launching 

site by hang gliders, the co-applicants originally proposed and now revised transmission alignment would 

result in lesser impacts on existing homes located near the base of the Elsinore Mountains. With regard to 

the northernmost segment of the staff alternative transmission alignment, Nevada Hydro points out land 

use conflicts with Pacific Clay Products and housing developments at Horsethief Canyon and Alberhill 

Ranch and requests that Commission staff revise the staff alternative transmission alignment to adopt the 

northernmost segment of the co-applicants’ proposed/revised alignment that avoids these land use 

conflicts. 

Response: We have considered all the comments made in response to the draft EIS and have revised the 

staff alternative transmission alignment. We agree that your alignment to the north of the Cleveland 

National Forest and to the south along the existing SDG&E route would avoid conflicts with Clay 

Products and housing developments. The staff alternative transmission alignment as shown in figure 5 

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and figures F-1 through F-4 in appendix F of the final EIS would follow the same alignment as the coapplicants’ proposed alignment at both the northern (north of the Cleveland National Forest) and southern 

ends. Within the Cleveland National Forest, the staff alternative transmission alignment would still be to 

the east of your alignment, but generally to the west of the private in-holdings within the forest. We also 

would place the line underground near the hang gliding launch sites, but for a shorter distance just past 

the egress to Rancho Capistrano. 

Comment 33: Nevada Hydro points out that figures 5, 8, 12, and 15 in the draft EIS show the 

transmission alignments east of the Cleveland National Forest instead of within the jurisdictional 

boundary of the forest. 

Response: Our intention was for the alignment to be within the Cleveland National Forest. All of the 

figures in the final EIS have been revised to show the co-applicants’ and staff’s revised alternative 

transmission alignments. In addition, aerial photographs showing the proposed and staff alternative 

transmission lines have been added as appendix F to the final EIS. 

Comment 34: The Environmental Protection Agency (EPA) indicates the alternatives analysis for the 

LEAPS Project needs to be expanded to include alternative sites, alternative technologies, and sustainable 

approaches that would avoid or minimize effects on waters of the United States while providing peak 

energy. It recommends that the final EIS include: (1) a clear, concise purpose statement for the project 

that allows for the analysis of alternatives that avoid waters to the extent practicable; (2) an expansion of 

the alternatives analysis to consider other alternative sites, technologies, and sustainable approaches 

within a reasonable market area; and (3) a discussion of appropriate mitigation measures for those effects 

that are unavoidable. 

Response: Our alternatives analysis is adequate. The purpose of the project is to provide an advanced 

pumped storage facility for the generation of energy during off-peak energy use periods for delivery and 

use during peak energy use periods. This is clearly stated in the draft EIS. Under the no-action 

alternative, other forms of generation would be needed to meet future needs during peak energy use 

periods. We include in the draft EIS alternative locations for the upper reservoir, powerhouse, and 

transmission lines. We considered two transmission alignments in the draft EIS and, based on public and 

agency comments, both the co-applicants and staff have revised the proposed and staff alternative 

transmission alignments to address issues raised in the comments on the draft EIS including conflicts with 

businesses, housing developments, wetlands, oak woodlands, fire fighting protocols, recreational use of 

hang gliding launch sites and trails, and the aesthetic effects on wilderness and back country areas. The 

development of transmission alignments under consideration in the final EIS took into account the need to 

efficiently convey power while avoiding as many effects on environmental resources as possible. 

Comment 35: The Corps recommends the final EIS include project alternatives with reduced effects on 

waters of the United States and a detailed discussion of practicability in terms of engineering, cost, and 

logistics as part of the section 404 analysis. If these requirements are not met in the final EIS, the Corps 

states it would conduct its own analysis before reaching a final permit decision. 

Response: The co-applicants provided additional technical studies in their filing of April 25, 2006, 

including delineations of jurisdictional waters and wetlands at the Decker Canyon and Morrell Canyon 

upper reservoir sites. We include this information along with a new figure 14 that shows the location of 

waters of the United States and the state of California at the upper reservoir sites. In section 3.3.4.2, we 

conclude that construction at the Decker Canyon reservoir site would have a smaller effect on waters of 

the United States than construction at the proposed Morrell Canyon site. Due in large part to this finding, 

we include the Decker Canyon reservoir site in the staff alternative. We conducted a detailed review of 

the engineering assumptions, costs and logistics of the construction of both the proposed and staff 

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alternative facilities and presented the information about the practicability of this alternative in section 4.1 

of the draft EIS. 

Comment 36: The California Department of Fish and Game (CDFG), the Fernandez Parties, the Center 

for Biological Diversity, and Pacific Clay believe that the Commission did not explore all project 

alternatives and that the co-applicants have not fully explored the cost and feasibility of implementing 

other renewable options that would be less detrimental to the environment. CDFG further states that it 

does not concur with the draft EIS finding that the generation of renewable power by the placement of a 

hydroelectric facility within a location as environmentally sensitive and valuable as Morrell Canyon and 

the Cleveland National Forest is more beneficial than producing the required additional electricity via 

gas-fired means in non-sensitive areas. 

Response: We did not conclude that a Morrell Canyon upper reservoir was a preferred location nor did 

we conclude that the project was more beneficial than producing electricity via other means, but rather 

concluded on page 5-1 of the draft EIS that both the staff alternative and co-applicants’ proposal would 

likely be more expensive than a combustion turbine alternative. 

Comment 37: The State Water Board agrees the Morrell Canyon upper reservoir option is the more 

environmentally sensitive and the Decker Canyon option is the least environmentally sensitive; however, 

the effects of the project on Decker Canyon must be fully analyzed by further footprint assessments. 

Response: The co-applicants filed the results of their wetland delineations at the upper reservoir 

locations in appendix F to their comments on the draft EIS. We have included this new information in the 

final EIS and have added a new figure 14 that shows jurisdictional wetlands in relation to the alternative 

footprints for the upper reservoir in Decker Canyon. The USFS filed revised preliminary 4(e) conditions 

on June 23, 2006, that include plans for pre-construction surveys and post-construction monitoring of 

ground and surface waters at the upper reservoir location. We discuss these preliminary conditions in the 

final EIS. These pre-construction surveys may result in modifications to the footprint of the upper 

reservoir at Decker Canyon. 

Comment 38: Francis Hoffman, on behalf of the Elsinore Testing of Experimental Aircraft Mechanism, 

and Robert and Susan Konoske question why an alternative placing transmission lines completely 

underground was not included in the draft EIS. Mr. Hoffman further states that placing the transmission 

lines underground would make them less terrorist-vulnerable. The Fernandez Parties also question why 

the draft EIS did not include alternatives that would: (1) route the lines outside the Cleveland National 

Forest, such as along Interstate 15; (2) place the transmission lines completely underground; or (3) avoid 

placement of substations and transmission towers and lines near private property. 

Response: As stated in section 2.5.3 of the draft EIS, we considered several variations for the 

transmission alignment that included placing segments underground to avoid conflicts with hang gliding 

activities. We cited cost as the primary reason for eliminating these alternatives. Based on comments on 

the draft EIS and subsequent filings by the co-applicants, both the co-applicants’ proposed and staff 

alternative transmission alignment would place the transmission line underground near the hang gliding 

launching and landing areas and along the east-west connection to the powerhouse location. However, 

we find that placing the entire length underground would still be cost-prohibitive, adding $320 million to 

the project costs. Interstate 15 was not considered as a viable alternative for an overhead route because of 

Caltrans written policy that issuing a Utilities Permit for a Freeway Aerial (UF) transmission line 

requesting a longitudinal encroachment is normally not permitted. In reviewing the co-applicants 

consideration of alternative transmission alignments we concluded that there were no alignments that 

would entirely avoid proximity to existing or planned residential communities, even when going deeper 

(west) into the Cleveland National Forest. 

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Comment 39: CDFG states that because the project is contingent on the installation of the transmission 

line once the final alignment has been determined, a detailed analysis of the effects associated with the 

transmission line should be included in the EIS. 

Response: Both the draft and final EIS include our assessment of the effects of the proposed and staff 

alternative transmission alignments on environmental resources. 

Comment 40: Robert and Susan Konoske cite information presented on page 3-133 of the draft EIS that 

11.1 acres of vegetation would be disturbed by the construction of temporary roads to install the 

transmission line. They question whether one can build 30 miles of transmission line with only 6.1 miles 

of temporary roads (they assume the roads will be 15 feet wide, whereas the authors of the draft EIS 

assume the temporary roads would be 12 feet wide). 

Response: In the draft EIS we estimated that along the 5.1 miles of the proposed transmission alignment 

having slopes less than 15 percent the conventional installation of transmission lines would require 7.6 

miles (not 6.1 miles) of temporary access roads. Straight road width estimates vary from 12 feet wide 

(see the Antelope-Pardee 500-kV Line Draft EIR/EIS [CPUC/USFS, 2006]) to 14-feet wide (see 

SDG&E’s Sunrise Powerlink 500-kV Project Application [SDG&E, 2006]). Roadway widths also range 

from 14 to 20 feet-wide at curves to allow safe movement of construction equipment and vehicles 

(SDG&E, 2006, Chapter 2). At structure sites located in rugged terrain with grades that exceed 15 

percent, small vehicles and manual labor delivered via helicopters will be used during construction. 

Approximately 78 percent of the co-applicants’ proposed alignment and 80 percent of the staff alternative 

transmission alignment presented in final EIS is expected to have structures located on grades exceeding 

15 percent. Based on this, we estimate that 10.8 and 9.3 miles of temporary road would be needed for the 

two alignments. This is an increase over the estimated 7.6 and 10.3 miles of temporary roads presented in 

the draft EIS and reflects the longer lengths of both the revised co-applicants and staff alternative 

transmission alignments. 

Comment 41: The Honorable Darrell Issa, Ken Calvert, Mary Bono, and Duncan Hunter in comments in 

support of the LEAPS Project request that FERC adopt the co-applicants’ proposed transmission line 

because it minimizes the visual impact on several existing and proposed housing developments. They 

comment that keeping the proposed line farther in the Cleveland National Forest is a better option than 

siting the line close to those developments. 

Response: The mid-slope transmission alignment presented in the draft EIS crossed major planned 

subdivisions in Horsethief Canyon and at Ortega Oaks, mining operations of the Pacific Clay Company, 

as well as dozens of private in-holdings west of Grand Avenue and in the vicinity of the residential area at 

LaCresta. This initial alignment was designed to minimize interference with fire suppression activities, 

avoid designated wilderness and back country non-motorized areas in the Cleveland National Forest, and 

reduce effects on hang-gliding activities. Commission and USFS staff developed a revised staff 

alternative transmission alignment in response to hundreds of complaints about the proximity of our midslope transmission alignment to private residential and commercial development. Our revised staff 

alternative transmission alignment avoids as many private in-holdings with the Cleveland National Forest 

as possible while continuing to avoid the San Mateo Wilderness Area and to minimize encroachment on 

lands designated as back-country, non-motorized and back-country, motored-use restricted in the Land 

Management Plan. The staff alternative transmission alignment lies within 0.25 mile of 452 privatelyowned parcels while the co-applicants proposed alignment lies within 406 privately-owned parcels, with 

the major difference being along the southern segment of the alignments where the staff alternative avoids 

crossing back country areas. The figures presented in appendix F compare the co-applicants’ proposed 

and staff alternative transmission alignments. 

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Comment 42: Jon R. Johnson recommends an alternate transmission line alignment that extends to the 

lower portion of the mid-slope alignment approximately 0.5 mile to the north and then ascends the slope 

to the north of Edwards launch site. He states that this would allow the lines to cross the Main Divide 

Road in an area where the terrain is flat on both sides of the road, allowing greater fire fighting ability and 

residents to pass during a fire. 

Response: We appreciate your suggestions on how best to route the proposed transmission line near 

Edwards launch site. The staff alternative transmission alignment was modified in the final EIS to address 

concerns about fire fighting and hang gliding safety. 

Comment 43: Rancho Capistrano Property Owners Association and Bruce Campbell recommend 

analysis of alternate transmission line routes along the freeway corridor or in the wilderness area away 

from homes and roads. 

Response: Both the co-applicants’ and staff alternative transmission alignments now include 

underground segments near the egress to the community of Rancho Capistrano, and the staff alternative 

transmission alignment, which is under consideration in the final EIS, now avoids private in-holdings in 

the Cleveland National Forest. However, there is no provision in the Wilderness Act that would allow for 

the inclusion of a power transmission line within the designated San Mateo Wilderness. Transmission 

line alignments along freeway corridors were not considered in the draft EIS. I-15 was not considered as 

a viable alternative for an overhead route because of Caltrans written policy that issuing a Utilities Permit 

for a Freeway Aerial (UF) transmission line requesting a longitudinal encroachment is normally not 

permitted. This information can be found at: 

http://www.dot.ca.gov/hq/traffops/developserv/permits/encroachment_permits_manual/index.html

Comment 44: SDG&E requests a more specific location map of the site of the southern substation be 

included in the final EIS with an aerial photograph base at a scale more useful for a detailed site review. 

SDG&E needs a better map to determine that the location, site characteristics, and environmental 

conditions are feasible from engineering and cost perspectives and that environmental and permitting 

issued can be addressed in a timely and cost-effective manner. 

Response: Appendix F of the final EIS includes a more specific location map shown on an aerial base or 

U.S. Geological Survey (USGS) map at a scale that is more useful for a detailed site review. 

Comment 45: SDG&E requests the final EIS include a discussion on why the south substation site and 

SDG&E substation site alternatives were eliminated from consideration. 

Response: The SDG&E substation alternative shown on figure 8 was erroneously shown as an existing 

substation. It was eliminated because its purpose and location were replaced by the alternative substation 

shown in the revised figure 8. The alternative substation was included in the staff alternative mid-slope 

alignment and its various environmental issues were discussed in the draft EIS. The co-applicants have 

filed a revised transmission alignment that includes their preferred southern substation site. The coapplicants’ preferred location is generally underneath or adjacent to the existing SDG&E 230-kV 

transmission line partially within, or directly adjacent to, the boundaries of Camp Pendleton, east of the 

existing Case Springs Fire Station (No. 28). 

Comment 46: SDG&E requests a clarification on the type of habitat depicted in table 15 (pages 3-114 

and 3-115) that would be affected by the construction of the southern substation—disturbed or chaparral. 

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Response: We have added headers to table 15 in the final EIS to clarify that the proposed southern 

substation is currently disturbed, and that the alternative southern substation location is characterized by 

chaparral. 

Comment 47: SDG&E expressed its concern that a 25-acre 500/230-kV substation site may not be large 

enough for planned project and future equipment. 

Response: We reviewed the Single Line Diagram, General Arrangement and conceptual Grading Plan 

for the Central East Substation (as shown in the Sunrise Powerlink Application [SDG&E, 2006]) and 

performed a conceptual layout based on the 500-kV and 230-kV equipment components in the southern 

substation to arrive at a revised site requirement of 50 acres. This value was found to be consistent when 

compared to the Antelope Substation (as shown in SCE’s Antelope-Pardee 500 kV Transmission Line 

Project Application [CPUC/USFS, 2006]). 

Comment 48: SDG&E requests that additional detail be provided for the south substation and that 

SDG&E be allowed to provide input on its requirements to ensure that the impact analysis is as accurate 

and complete as possible. 

Response: In their filing of April 25, 2006, the co-applicants requested based on continuing discussions 

with SDG&E, Camp Pendleton, and additional engineering studies, the relocation of the proposed 

southern substation from the Tenaja area to an area south of the existing Case Springs Fire Station, within 

the existing SDG&E right-of-way and beneath SDG&E's existing 230-kV lines, within or adjacent to 

Camp Pendleton. This alignment was originally alternative 5 as shown on figure 8 of the EIS and is now 

included as part of both the co-applicants proposed and staff alternative transmission alignment. In the 

co-applicants’ System Study of equipment quantities and capacities, the southern substation would 

contain two 500-kV breaker-and-a-half bays, two 1,000 MVA 500/500-kV phase-shift transformers, two 

1,000 MVA 500/230-kV transformers, and two 230-kV breaker-and-a half bays. If licensed, Nevada 

Hydro would consult with SDG&E directly about the design of the southern substation. 

Comment 49: SDG&E requests the final EIS disclose the status of the March 16, 2005, application for 

water quality certification under section 401.

Response: The status of the application for water quality certification as of the date of issuance of the 

final EIS is discussed in section 2.4.2.3 of the final EIS. 

Comment 50: Edith Stafford asks if the proposed project is consistent with the California Water Code 

71663.5 (b) and (d), which she interprets to mean that: (1) a water district can generate power for its own 

purposes and may sell surplus power to a public or private entity that is engaged in the distribution or sale 

of power and (2) a water district may not acquire property employed in the generation of power for public 

or private utility purposes, except by mutual agreement between the district and the owner of that 

property. Linda and Martin Ridenour also point out that Elsinore Valley MWD does not have eminent 

domain authority and must acquire property through mutual agreement. They request that the final EIS 

include documentation that allows Elsinore Valley MWD to provide electric power generation. 

Response: The co-applicants are required to comply with federal, state, and local laws and regulations. 

We note that Nevada Hydro also is an applicant and is not a water district. Any license issued by the 

Commission would include the use of eminent domain if necessary to allow the co-applicants to build the 

project and to sell the power generated by the project, subject to all the necessary state and federal 

permits. 

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PROJECT SAFETY 

Comment 51: Riverside County states that project licensing should not occur until there is sufficient 

project design to determine the boundaries of the dam inundation area and it is assured that potential 

effects can be mitigated. Precise inundation maps and flows resulting from a potential dam/dike break 

should be provided to the Riverside County Fire Department, Office of Emergency Services so that these 

plans can be reviewed for compliance with local and state regulations. Lake Elsinore United School 

District is also concerned with the lack of discussion in the draft EIS regarding flooding danger from a 

potential dam break. 

Response: Figure 10 in the draft EIS shows the potential extent of inundations that could result from a 

dam or dike break. This figure was developed from a more detailed study included in the license 

application. If the project is issued a license, the licensees would need to prepare more detailed dam 

break studies and coordinate with local agencies to develop an emergency action plan. 

Comment 52: Mr. Campbell asks whether the USFS would use more toxic fire retardants in the future as 

a result of any limitations on fire fighting that might result from the construction and maintenance of the 

transmission lines. 

Response: The proposed location of the towers and lines may result in less efficient firefighting in the 

area and could result in less or more retardant used overall. USFS indicates that a variety of fire 

suppression techniques will be used to control, contain, and suppress wildland fires.

ENVIRONMENTAL CONSEQUENCES/GENERAL 

Comment 53: The Natural Resources Defense Council and Pacific Clay state that the project’s effects 

are not discussed in the draft EIS at a sufficient level of detail. The Center for Biological Diversity and 

the Orange County Chapter of the California Native Plant Society also question how an informed decision 

can be made about the proposed action until more knowledge is provided by detailed habitat studies, 

mitigation, and monitoring plans. EPA states that the draft EIS does not provide sufficient information to 

demonstrate that any of the build alternatives represent the least environmentally damaging practicable 

alternative. The State Water Board, the Fernandez Parties, Pacific Clay, and SDG&E also indicate that 

several studies and mitigation measures identified in the draft EIS should be conducted prior to issuance 

of the final EIS instead of deferred until after license issuance. The Fernandez Parties state the draft EIS 

was prepared prematurely because the co-applicants’ proposal is in the conceptual planning stage and 

does not include information needed to adequately assess potential effects.

Response: The draft and final EIS include a sufficient level of detail to assess the potential effects of the 

proposed project on environmental resources in the project area. We acknowledge that facility designs 

are still conceptual. We are confident that the level of information provided in the proceeding is 

sufficient to allow Commission and USFS staff to make an informed judgment of the relative effects of 

the alternative project configurations. Any license issued by the Commission and any permit issued by 

the USFS would include requirements to complete studies and resolve the details of any outstanding 

environmental issues prior to the commencement of construction. 

Comment 54: Riverside County, Pacific Clay, the Center for Biological Diversity, and Lake Elsinore 

Unified School District state that the draft EIS does not supply specific locations and acreages to be 

affected by construction laydown areas during development of the powerhouse, the upper reservoir, the 

intake/outlet tunnels, and acreages affected during construction of the transmission lines or upstream 

detention basin. The absence of a detailed plan limits the ability of reviewers to completely assess the 

potential effects resulting from the project and the adequacy of mitigation measures. Pacific Clay states 

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that the draft EIS should be withdrawn, revised, and recirculated for no less than 120 days for public 

review and comment. 

Response: The draft and final EIS include specific information on the staging and laydown area acreage 

that would be affected by the alternative project configurations. The type and amount of vegetative cover 

that would be affected are shown in table 15 of the draft EIS and have been revised to account for the 

revised proposed and staff alternative transmission alignments in the final EIS. 

Comment 55: The State Water Board questions if the co-applicants would be willing to have an open 

license until environmental effects are known because much of the environmental documentation and 

plans have been deferred to post licensing. 

Response: We are not sure what you mean by an open license. Any license order issued by the 

Commission would specify the location of project facilities and require the completion of any outstanding 

environmental studies specified in mandatory conditions, final design drawings, and plans to protect 

environmental resources prior to the commencement of construction. In addition, any license issued for 

the project would include a requirement for a detailed plan, developed in consultation with the resource 

agencies, for environmental construction monitoring in aquatic and terrestrial environments. 

Comment 56: Pacific Clay states that the project outlined in the draft EIS varies from the projects 

outlined in Scoping Documents 1 and 2, specifically the deletion of a “preferred project” designation, 

deletions, amendments, and alterations to the project alternatives, and the inclusion of the “staff 

alternative” at the last minute. It states that because the text of the draft EIS does not match the 

information from the April 5, 2006, Commission public meeting and because the draft EIS does not 

contain detailed maps or figures, it was unable to determine where the staff’s alignment occurs and 

therefore is unable to assess potential effects.

Response: In their license application, the co-applicants identified a preferred project, which is treated as 

the proposed action in the draft EIS. Commission and USFS staff developed a staff alternative based on 

the analysis of the proposed action and action alternatives presented in the license application. The staff 

alternative evolved from scoping meeting comments and technical review of the potential effects of the 

proposed action and alternatives. Following the public meeting and review of comments filed on the draft 

EIS, Commission and USFS staff developed a revised staff alternative transmission alignment that now 

avoids conflicts with Clay Products. The Commission issued a notice on October 3, 2006, to property 

owners affected by the revised alignments and included a detailed aerial-based map with the notice. 

Property owners were afforded 30 days to comment and the comments are summarized in this appendix 

and addressed in the final EIS. 

Comment 57: Nevada Hydro and a number of agencies expressed concerns about coordination with 

CEQA. CDFG recommends that the final EIS address the state’s concerns pursuant to CEQA and EPA 

recommends the Commission coordinate with state and local agencies to prepare one document that 

combines NEPA with state and local environmental impact statement requirements like CEQA. Riverside 

County also recommends that the draft EIS be rewritten as an EIS/EIR to satisfy CEQA and recirculated 

for review and comment. The State Water Board states that final designs and sediment control plans and 

measures should be developed and included in the final EIS or they can not consider it mitigation under 

CEQA. EPA states that in order to be CEQA compliant, the final EIS should identify and describe all 

appropriate mitigation measures and contingency measures (if such measures are deemed necessary by 

monitoring results), referencing any that are adopted into the record of decision and stating whether all 

practicable means to avoid or minimize environmental harm have been selected. Nevada Hydro requests 

that the final EIS and the USFS’ Record of Decision contain an explicit acknowledgement that federal 

law authorizes the use of the FERC/USFS document either in whole or in part, in fulfillment of any stateDocument Accession #: 20070130-4000 Filed Date: 01/30/2007
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imposed environmental disclosure requirements such as those associated with California Environmental 

Quality Act (CEQA) and section 1500.4(n) and (o), 1500.5(h), 1506.2, and 1506.4 of CEQ regulations 

implementing NEPA. 

Response: Elsinore Valley MWD is the lead agency for CEQA review. In the EIS, we have addressed 

all of the CEQA requirements to the extent possible given the information provided in the license 

applications. The Commission is considering the overall proposal in the EIS. If licensed, the licensees 

would need to provide the details associated with many of the mitigation measures in the plans 

recommended by staff and specified by USFS that would be developed in consultation with the federal 

and state resource agencies and local agencies. 

Comment 58: The city of Lake Elsinore states that the EIS should include a condition that the 

construction of power generating facilities occurs before the construction of the transmission lines. 

Response: The sequence of construction would be considered in any license issued by the Commission 

for this proposed project. 

Comment 59: The city of Lake Elsinore recommends an adaptive management plan be developed and 

implemented which includes a rigorous 3-year post-construction monitoring program, mitigation 

measures in the event that the project causes unanticipated and ecologically significant environmental 

effects, establishment of a third-party administered fund for the protection of habitat, and the 

establishment of an independent scientific oversight panel. 

Response: USFS revised preliminary 4(e) condition no. 32 (Environmental Monitoring) includes the 

type of construction monitoring and adaptive management program that you recommend. The detailed 

monitoring plan would be developed in consultation with resource agencies. 

GEOLOGICAL AND SOIL RESOURCES 

Comment 60: Pacific Clay states that the geology, soils, and erosion analysis in the draft EIS is 

inadequate because project facility sitings have not been finalized, geophysical survey data has not been 

confirmed, stream crossings have not been mapped, no studies or data are provided to support conclusions 

regarding the effects of lake level fluctuations on Lake Elsinore shorelines, and proper mitigation is not 

proposed. Pacific Clay also is critical of the analysis in the draft EIS regarding applicable requirements of 

state and local agencies, effects on local storm drainage facilities, formulation of mitigation to control 

erosion and surface runoff, and secondary effects of migration measures because it defers the analysis to 

post-licensing. 

Response: The draft and final EIS include a sufficient level of detail to assess the potential effects of the 

proposed project on environmental resources in the project area. We acknowledge that facility designs 

are still conceptual and additional geotechnical studies are proposed. We do identify stream crossings in 

section 3.3.2.2 of the draft EIS and evaluate the potential effects on stream crossings in the water 

resources section. The co-applicants filed additional information including studies of the potential effects 

of lake level fluctuations (Anderson, 2006) that have been added to the final EIS. The level of 

information provided in the proceeding is sufficient to allow Commission and USFS staff to make an 

informed judgment of the relative effects of the alternative project configurations. Any license issued by 

the Commission and any permit issued by the USFS would include requirements to complete studies and 

resolve the details of any outstanding environmental issues prior to the commencement of construction. 

Comment 61: The State Water Board states that the upper reservoir clearing plan should be developed 

for the final EIS so that the public and agencies can determine if the plan would mitigate or address those 

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affects identified in the draft EIS. It states that the final EIS should discuss spoil storage areas, storm 

runoff management, and spoil stabilization measures. 

Response: The upper reservoir clearing plan would be developed in consultation with the state and 

federal resource agencies and filed with the Commission prior to the commencement of any construction. 

This plan would include the specifics relative to the location and management of spoil storage areas. 

Comment 62: SDG&E states that over the term of the license, sediment transport at velocities of 40 

feet/second (on page 3-52 of the draft EIS) would cause significant corrosion on most pipe materials and 

requests this design be reassessed. 

Response: We agree that the design of the upper reservoir would need to provide for an emergency 

spillway or overflow pipeline of sufficient size and durability to control waters during a maximum 

probable flood. Design details of this nature are generally addressed during the final design phase and are 

subject to an external engineering board of review. The example cited by staff in the draft EIS was 

provided simply to illustrate the large diameter and high velocities that would be involved in controlling 

such a hydrologic event. In the final EIS we’ve modified our example to reflect a pipe size that results in 

water velocities that would not be detrimental to an overflow pipe, should that be the design solution. 

Comment 63: The State Water Board states that the final EIS should disclose the type and materials to 

be used for the cofferdam in the construction of the tailrace/intake structure and whether or not the 

cofferdam would require the driving of sheet-piling into the lakebed sediments. 

Response: The draft EIS indicates that the co-applicants would use a cofferdam; however, the material 

specifications for the cofferdam would be submitted in the final design plans, which would be reviewed 

by the independent board of engineers, the Commission, and applicable agencies, including the State 

Water Board. 

Comment 64: The city of Lake Elsinore notes that the draft EIS does not address the potential effects 

that higher average water elevations would have on Lake Elsinore’s levee system. 

Response: Alteration to the lake’s water surface elevations were evaluated under the Environmental 

Impact Report for the Lake Elsinore Stabilization and Enhancement Project. A key objective of that 

project is the stabilization of the water level of Lake Elsinore, by maintaining the lake elevation within a 

desirable operating range (minimum of 1,240 feet msl to a maximum of 1, 247 feet msl). The proposed 

LEAPS Project does not intend to operate outside of the lake levels evaluated in the Lake Elsinore 

Stabilization and Enhancement Project and therefore should not affect the levee system. Also, we have 

recommended that any license issued for the project include a requirement for a revised lake operating 

plan to include the pumped storage project operations. 

Comment 65: The State Water Board points out an inconsistency in the project description regarding 

vegetation management along the transmission alignment. It notes that in several places the EIS says that 

vegetation clearing or management is not proposed; however, on page 3-20, the EIS states that periodic 

vegetation clearing may be needed due to high fire risk. The State Water Board requests clarification so it 

can assess the potential for erosion and sedimentation of streams. The Center for Biological Diversity 

also comments on the analysis of the effects of vegetation clearing and raises concerns about the lack of 

analysis of the potential effects of fire abatement activities on soils and soil productivity. It further 

comments that the final EIS include specific details about the BMPs to be taken to protect the integrity of 

stream ecosystems during construction and operation of the project. 

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Response: The co-applicants do not propose to clear vegetation under the transmission line, but fuel 

management in the future may require manipulation to reduce the risk of fire. Methods selected for fuel 

management would depend on site-specific factors (e.g., vegetation type, slope, aspect, access), and could 

include grazing, prescribed fire, or mechanical means to create and maintain firebreaks. Existing 

firebreaks that intersect the proposed alignment would also be maintained, as needed. We have revised 

the final EIS to reflect these factors. 

Comment 66: The Center for Biological Diversity notes that during 2004-2005 winter storms, numerous 

transmission line towers located on steep slopes experienced substantial damage. It recommends that the 

final EIS discuss the risks to property, life, and the environment as well as the costs associated with 

maintaining and repairing the extensive lengths of transmission lines. It also asks that the EIS disclose 

whether there have been similar lengths of transmission line installation and maintenance via helicopter at 

other locations. 

Response: If licensed, the co-applicants would be required to develop and file with the Commission an 

emergency action plan to avoid risks to property, life, and environment in case of emergencies. About 12 

miles of the Valley–Serrano 500-kV Transmission Line cross the Trabuco Ranger District of the 

Cleveland National Forest in an east-west alignment. Much of the line was constructed by and is 

presently maintained using helicopters. 

Comment 67: Riverside County indicates that no geotechnical studies are provided to determine whether 

soils excavated during construction of the powerhouse would qualify for use in the construction of the 

upper reservoir main dam or perimeter embankment. Determining whether a balance can be achieved 

between excavation and fill materials onsite can not be determined without further testing of subsurface 

soils. 

Response: We agree that additional geotechnical studies would be necessary to determine whether soils 

excavated from the powerhouse sites would be suitable to use as fill for the upper reservoir dam. 

However, we conclude in the draft EIS that transporting excavated materials from the powerhouse to the 

upper reservoir site would tax the local traffic and roads and recommend that excavated materials from 

the powerhouse construction be disposed of off-site. We recommend a balance of excavated and fill be 

achieved at the Decker Canyon upper reservoir site. 

Comment 68: Riverside County states that the draft EIS fails to identify and quantify the subsurface 

effects on project components that may result from the active faults in the project location. 

Response: We discussed seismic considerations for project construction and operation in the Geology 

and Soils section of the draft EIS (on page 3-26), as well as in the Developmental Analysis section (at 

pages 4-2 and 4-3). Specific potential effects of the faults that we mentioned in our analysis include 

damage to project infrastructure or construction-related equipment, or injury or loss of life of construction 

crews. 

Comment 69: The State Water Board and Pacific Clay state that it appears to be necessary to answer the 

questions and disclose the answers regarding seismic issues in the construction of the proposed Santa 

Rosa powerhouse and tailrace/intake structures due to the cost of the proposed project. The Lake Elsinore 

United School District is critical of the discussion in the draft EIS regarding the potential affect of a 

seismic event on the project and mitigation, including its ability to withstand an earthquake and the risk of 

a high-pressure water line rupture. The EPA recommends the final EIS indicate geologic/seismic hazard 

mapping would be completed before the Commission licenses this project in order to ensure that site and 

mitigation selection is based upon this information. 

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Response: We discussed seismic considerations for project construction in the Developmental Analysis 

section (on pages 4-2 and 4-3), and made cost adjustments to reflect those considerations. In its March 

2006 report appended to the April 25, 2006, filing by Nevada Hydro, Genterra Consultants indicate that 

faults may lie beneath all three powerhouse sites and that detailed investigations of faulting would be 

undertaken once the powerhouse location is selected. These additional studies were proposed by the coapplicants and recommended by the staff in the draft EIS as part of the final design process. The final 

designs process would include detailed geologic and seismic studies and analyses, which would be 

reviewed by the Commission and appropriate agencies prior to the commencement of any construction. 

Comment 70: The State Water Board states that deferring analysis and mitigation regarding dam breach 

and dike failure is inconsistent with CEQA, whereas Pacific Clay states it is inadequate under NEPA. 

Response: The draft EIS includes a summary of the dam break and inundation analysis developed by the 

co-applicants and included in the license application. Figure 10 on page 3-31 of the draft EIS shows the 

potential inundation that could result from a dam or dike failure. The information provided in the draft 

EIS is sufficient to address the potential effects of the unlikely occurrence of a dam breach or dike failure. 

If the project is issued a license, the licensees would need to prepare more detailed dam break studies and 

coordinate with local agencies to develop and file with the Commission's Division of Dam Safety and 

Inspections, an emergency action plan. 

WATER RESOURCES 

Water Quantity 

Comment 71: The U.S. Department of the Interior (Interior) comments that relative to table 3 in the draft 

EIS, the monthly streamflow statistics for the USGS gage no. 11070500 for the entire period of record 

(1916-2004) are available on the USGS web site. It also notes that the gage number in the table is 

incorrect. 

Response: We have corrected the gage no. in table 3 to read “11070500” to be consistent with the text. 

Although a long period of record for this gage is available, considerable development has occurred in the 

basin and it appears that the 30 years from 1975 through 2004 would be more representative of current 

hydrologic conditions. Additionally, a 30-year representative period of record is fairly common in 

hydrology and in this case, more appropriate for our analysis of the effects of the proposed project 

operations on lake level. 

Comment 72: Interior points out that the highest peak flow recorded at USGS gage no. 11072100, 

Temescal Creek near Corona, since the construction of the flood control improvements in the 1990’s is 

now 4,030 cfs recorded on January 9, 2005. 

Response: We have made this suggested edit to the final EIS. 

Comment 73: Interior comments that figure 11 does not accurately depict the frequency curve for Lake 

Elsinore lake level elevations under current conditions and mis-labels elevation of 1,263.3 feet msl. 

Response: We have corrected the mislabeled elevation on figure 11. The curve shown is an elevationduration curve based on daily values. Interior argues that the 100 year flood value of 1,263.3 feet msl 

should correspond to the 1-percent value; however, flood analyses are based on the record high for each 

year and are based on instantaneous maximum elevations for the year (a different type of analysis). The 

correct definition of a 1-percent exceedance elevation in the context of this curve would be the elevation 

equaled or exceeded at least 365 days out of a 100-year period of record. 

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Comment 74: Nevada Hydro provides a technical analysis of the potential water quality impacts of the 

LEAPS Project on Lake Elsinore (Anderson, 2006) that concludes that the LEAPS Project could either 

enhance or impede dissolved oxygen (DO) conditions, suspended sediments, and the development of an 

aquatic macrophyte community; however, the overall effects are still unclear at this time. The report 

recommended that additional heat calculations be performed and an ecological model conducted. As 

such, Nevada Hydro requests that any additional water quality studies that might be required as a 

condition of any license be limited to the LEAPS Project and not required of a transmission stand alone 

project. 

Response: Because both aspects of the proposed project— as a complete unit of development, the 

hydropower and the transmission line—would require a license, they are both subject to license 

conditions that could include monitoring. 

Comment 75: The Santa Ana Regional Water Quality Control Board (Santa Ana Water Board) indicates 

that, other than the payment of money each year to buy water to stabilize lake levels, the other claims of 

water quality improvement provided by the Lake Elsinore Stabilization and Enhancement Project, as 

stated in the draft EIS, would occur even if the project does not move forward. Therefore, the Santa Ana 

Water Board requests the final EIS indicate how much water can be purchased through the lake 

management fee and how it would affect lake levels.

Response: The effect on lake levels was summarized in figure 11 of the draft EIS. The lake management 

fee provides a vehicle for paying for supplemental water which we estimate to be from 4,000 acre-feet to 

15,000 acre-feet depending on the water year. Replacement water would come from wells and would be 

primarily from recycled water by year 2020. We assume that the management fee would pay for the 

water needed to maintain water level targets included in the plan. 

Comment 76: The State Water Board states that the draft EIS does not describe the area of relicted 

lakebed (fluctuation zone) that would result from the drop in water elevation on Lake Elsinore from 

project operations. It states that the final EIS should include an assessment based on bathymetry data that 

discloses the areal extent of the expanding shoreline due to project operations at various lake levels, 

including drought years. 

Response: We have revised section 3.3.1.2 of the final EIS to include new information (Anderson, 2006) 

on the areal extent of the shoreline migration resulting from the daily and weekly fluctuation of the water 

surface elevation under proposed project operations. 

 

Comment 77: The Santa Ana Water Board would like a discussion in the final EIS on the project’s 

policy of operation during low lake levels, such as occurred during the drying cycle from 1941 to 1973 

when Lake Elsinore regularly dried up.

Response: The co-applicants have specified that the minimum operating level for the LEAPS Project 

would be 1,240 feet msl. The project would not operate below this level. A comparison of operations 

under baseline and 2020 conditions is provided in section 3.3.2.2, Environmental Consequences Water 

Quantity. 

Comment 78: Nevada Hydro comments that the description in section 3.3.2 on page 3.51 of the draft 

EIS that the co-applicants propose to operate the lower reservoir (Lake Elsinore) between 1,240 and 1,249 

feet msl is incorrect. Nevada Hydro requests that the text be clarified to state that the operational range of 

the proposed project is 1,240 to 1,247 feet msl and that any operation of Lake Elsinore would be 

independent of the proposed projects and would be undertaken by the Elsinore Valley MWD, operating in 

conjunction with other agencies and acting separately from the hydropower project. Further, Nevada 

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Hydro states that as proposed, the facility operators would pay to Elsinore Valley MWD a lake 

management fee. Under the provisions of an operating agreement to the operator, the Elsinore Valley 

MWD would maintain Lake Elsinore at a minimum depth of 1,240 feet msl. Therefore Nevada Hydro 

states that the two energy projects would have no direct obligations or responsibilities with regard to the 

active management of Lake Elsinore. 

Response: We have revised the text in the final EIS to read that the co-applicants propose to operate the 

project within the fluctuation range of 1,240 and 1,247 feet msl. We respectfully disagree that the coapplicants would have no responsibilities relative to the operation of Lake Elsinore. Under any license 

issued for the LEAPS Project, Lake Elsinore would be part of the complete unit of development in that it 

is required for the operation of the project and a revised operating plan for the pumped storage operation 

would be necessary. 

Comment 79: The Center for Biological Diversity states that an increase in the maximum water levels to 

1,249 feet msl could potentially have impacts on flooding within the city of Lake Elsinore and requests 

that the final EIS address this public safety issue. 

Response: The co-applicants propose to operate the pumped storage consistent with the target minimum 

and maximum lake levels of 1,240 and 1,247 msl recommended in the Lake Elsinore Stabilization and 

Enhancement Project. As proposed, the pumped storage project operations would not increase the 

maximum target lake level. We have revised section 3.3.2.2 of the final EIS to reflect the co-applicants’ 

intent. We recommend that the co-applicants develop a revised lake operating plan for Lake Elsinore. 

This plan would address how the Elsinore Valley MWD would operate Lake Elsinore to meet the 

objectives of the pumped storage operations within the target elevations established by the Lake Elsinore 

Stabilization and Enhancement Project and to make sure that the operation of the project would not have 

unintended consequences such as flooding. We further describe this plan in section 5 of the final EIS. 

Comment 80: Riverside County states that the proposed reservoir/dam could potentially impound flood 

waters during the rainy season and design of the reservoir/dam should accommodate the flooding and 

normal operating volume. 

Response: A FERC-licensed project must have a spillway designed in accordance with the 

Commission’s Engineering Guidelines and the spillway must accommodate appropriate flood conditions. 

More detailed hydrologic design would be conducted for the effects of flood waters at the licensed upper 

reservoir site. Normal operations are accommodated by the co-applicants’ proposed reservoir preliminary 

designs. 

 

Comment 81: SDG&E indicates the proposed water level fluctuations at Lake Elsinore, as described on 

p. 3-54, are in conflict with the Fisheries Management Plan and recommends a water level management 

plan be developed to mitigate for effects on target sport fisheries.

Response: Actions proposed in the Fisheries Management Plan anticipate the stabilization of lake level 

fluctuations between 1,240 feet msl and 1,247 feet msl. The proposed project will operate within those 

lake levels. However daily flow fluctuations of 1 foot during the week and to 1.7 feet during the 

weekends would likely prevent many submergent plant species from establishing within the fluctuation 

zone and rooted shallow-water vegetation that provides spawning, rearing, foraging, and cover from 

predators would continue to be limited, particularly in the shallow, southern area of the lake. 

Comment 82: EPA and the Center for Biological Diversity recommend that the final EIS include more 

detailed information regarding the potential effects of the Morrell Canyon reservoir on groundwater 

resources and discuss measures to mitigate any adverse effects to groundwater and to potential 

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construction problems. EPA also recommends that the final EIS analyze how the Morrell Canyon 

reservoir site alternative would affect upstream and downstream flows, flows from Lion Spring, and 

designated beneficial uses.

Response: We recognize that additional information on groundwater characterization may be developed, 

once a preferred site for the upper reservoir is selected. We recommend the Decker Canyon site over the 

Morrell Canyon site. On page 5-24 of the draft EIS we described a groundwater monitoring program that 

would address potential impacts on ground water at either upper reservoir site. We summarized 

information on hydrology from the license application and responses to additional information requests in 

the affected environment section of the draft EIS. In response to the draft EIS, the USFS filed revised 

preliminary 4(e) conditions including a new condition that specifies the development of a groundwater 

management plan. The USFS plan would include studies to determine baseline groundwater conditions 

prior to the commencement of construction. 

Comment 83: The State Water Board states that additional groundwater studies should be conducted at 

the Decker Canyon site because only geologic assessments for groundwater have been conducted. Pacific 

Clay is critical of the analysis in the draft EIS regarding the effects of operation on groundwater and the 

effects of the failure of the proposed liner system on groundwater in the San Juan Basin, groundwater 

recharge, and potential make-up water. EPA recommends the final EIS include the leak detection 

monitoring and mitigation plan, including action levels and response measures that would be required for 

the types of leaks that could occur and demonstrate the long-term effectiveness of the reservoir liner and 

leak detection system. 

Response: We respectfully disagree. Our cost estimate in the draft EIS does address site-specific 

geological and groundwater conditions. Implementation of the staff recommended upper reservoir and 

water conduit program to monitor groundwater and implementation of USFS revised preliminary 

condition no. 36 specifying a groundwater management plan would address the concerns about the longterm operation of the reservoir liner. 

Water Quality 

Comment 84: The Corps indicates that the draft EIS does not include a quantification of waters of the 

United States that could be affected by the project and no mitigation to offset losses of waters of the 

United States. It recommends this information be included in the final EIS. 

Response: We have added new information to section 3.3.4.2 about waters of the United States at the 

Morrell Canyon and Decker Canyon reservoir sites and their functions and values, based on reports filed 

by the co-applicants as attachments to their comments on the draft EIS. New figure 14 shows the 

jurisdictional waters relative to the proposed and alternative upper reservoir locations.

Comment 85: Riverside County states that the proposed intake/outtake structure at Lake Elsinore should 

be designed to ensure disturbance of sediments in the bottom of the lake are avoided to the satisfaction of 

the city of Lake Elsinore and the Santa Ana Regional Water Quality Control Board (Santa Ana Water 

Board). 

Response: The co-applicants propose maximum velocities at the intake/outflow structure not exceed 

1.5 feet per second. We recommend the co-applicants consult with the Santa Ana Water Board and local 

authorities prior to final design approval by the board of three qualified engineers. Additionally, agency 

and governmental approval could be included as part of the permitting of all dredging and work to be 

performed in waters of the U.S. (including the intake/outflow structures) which would be the 

responsibility of the Corps and also would include consultation with other agencies. 

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Comment 86: The Santa Ana Water Board requests that the final EIS include a discussion of the BMPs 

that would be used to adequately reduce effects to water quality from the construction of the 

intake/outflow structures. 

Response: In the event of a license being issued, the co-applicants would need to develop an erosion 

control plan in consultation with the agencies for Commission approval; the erosion control plan would 

detail the specific BMPs to be implemented to reduce the potential effects of the construction of the 

intake/outflow structures on water quality.

Comment 87: The State Water Board states that the co-applicants should have conducted soil toxicity 

assessments on lakebed sediments and the results disclosed in the draft EIS. It also states that, contrary to 

what is stated on page 3-66 of the draft EIS, there is the potential for effects on water quality and 

beneficial uses from the release of nutrients and potentially other chemicals during the construction of the 

tailrace/intake structure. The State Water Board also states that the draft EIS is not clear on what effects 

the discharges from the outlet pipes will have on the lake’s water quality standards. 

Response: We considered the degree to which lakebed sediments might be disturbed during the 

installation of the cofferdam and the construction of the tailrace/intake structure and our analysis indicates 

that typically very little disturbance would result because excavation would occur in an area physically 

separated from Lake Elsinore by the cofferdam. We would not expect the release of toxins during this 

construction. However, fish samples have shown toxins below actionable levels and that is an indication 

that there could be toxins in the lakebed sediments. Therefore, we recommend, that the lakebed 

sediments be tested for toxicity prior to the disposals or reuse of the lakebed sediments. We have 

provided a more detailed description of the proposed construction activity and the potential effects from 

the construction of the intake/outflow structure in the final EIS. As far as operational effects from flows 

in the intake/outflow structure with respect to water quality standards we discussed the effects of 

operations on pages 3-68 and 3-69 of the draft EIS. 

Comment 88: The Santa Ana Water Board indicates that the draft EIS states that the co-applicants 

require target minimum water surface elevation of 1,240 feet msl to operate the pump storage project. 

The Santa Ana Water Board comments that it was stated that operating the project at lower lake levels 

would degrade water quality unacceptably. The Santa Ana Water Board requests that a firm commitment 

of what lake levels the project would operate at to adequately protect the lake water quality. 

Response: The co-applicants propose to operate the pumped storage project consistent with the Lake 

Elsinore Stabilization and Enhancement Project between elevations 1,240 and 1,247 feet msl. Further, the 

co-applicants propose and we recommend payment of an annual management fee to the Elsinore Valley 

MWD to maintain the minimum target elevation at 1,240 feet msl. If the project is licensed with either 

the proposed action or the staff alternative, the licensees would be required to maintain lake levels at or 

above 1,240 feet msl. 

Comment 89: The Friends of the Forest and the Center for Biological Diversity criticize the level of 

analysis and the conclusions drawn in the draft EIS concerning the potential effects of project operations 

on the re-suspension of sediments in Lake Elsinore. They also question whether the project proponents 

can demonstrate whether the project can operate without exceeding existing Total Maximum Daily Load 

(TMDL) limitations. 

Response: The Lake Level Stabilization and Enhancement Project was developed in response to the 

listing of Lake Elsinore as impaired which triggered development of a TMDL. It is our understanding 

that the LEAPS Project is related to the Lake Elsinore Stabilization and Enhancement Project, which has 

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received local governmental and agency support, including the city of Lake Elsinore and the Riverside 

County. Other environmental documents show that current programs developed to improve water quality 

(lake level stabilization, axial-flow pumps, and line diffusers) would be beneficial to water quality. 

Considering the role the proposed project could play in the overall lake water quality, we concluded in the 

final EIS that the proposed project operations would provide incremental benefits to the same water 

quality parameters the other programs target through improved mixing of the water column. Furthermore, 

the thousands of bottom feeding carp in Lake Elsinore are responsible for stirring up sediments 

throughout the entire lake bottom, not just localized areas as proposed under both the Lake Level 

Stabilization and Enhancement Project and the LEAPS Project. To clarify the relationships between the 

proposed action, approved programs, and the existing biotic community, we have augmented the 

discussion on the potential effects of project operations on the re-suspension of sediments in section 

3.3.2.2 of the final EIS (beginning on page 3-67 of the draft EIS). 

Comment 90: Mr. Pinnow comments that Elsinore Valley MWD supports the costly program of carp 

removal because these bottom-feeding fish stir up sediments and yet the potential effects of project 

operations on the disturbance of sediments could be far more serious than the effects of carp. He points 

out that computer modeling could be used to study this potential and ensure that the worse-case scenario 

involving massive fish kills does not occur. He further suggests that the co-applicants be required to post 

a bond or procure insurance that would compensate home and business owners in an around Lake 

Elsinore for loss of property values as a result of any decline in the water quality of Lake Elsinore caused 

by the LEAPS Project. 

Response: Carp are considered a nuisance species to the lake with almost 500,000 pounds removed as 

recently as 2003. We conclude that the proposed project would supply oxygenated water to the sedimentwater interface improving nutrient conditions at the bottom of the lake. Further, the intake-outlet 

structure would be located in a fixed location near the western shoreline and flows into Lake Elsinore 

would occur within the same linear area on a daily basis whereas carp graze and stir up sediments across 

the entire lakebed. Additionally, the axial flow program implemented under the Lake Elsinore 

Stabilization and Enhancement Project is designed to destabilize the water column by applying downward 

currents toward the lakebed, which would also disturb sediments. Environmental review of this program 

considered the objectives to be beneficial to water quality. The kinetic energy of the water flowing into 

and out of the intake structure would further assist in mixing the water column. We discuss the effects of 

operations on page 3-67 of the draft EIS. 

Regarding the co-applicants’ requirement to secure insurance for property surrounding Lake Elsinore, it is 

our understanding that the LEAPS Project is contingent upon the lake levels that are planned to be met 

under the Lake Elsinore Stabilization and Enhancement Project, which has received local governmental 

and agency support, including the support of the city of Lake Elsinore and the Riverside County. As 

discussed in our response to Comment 89, we concluded in the final EIS that the proposed project 

operations would provide incremental benefits to the same water quality parameters as the other 

programs. 

Comment 91: The Santa Ana Water Board states that recent studies on Lake Elsinore show that under 

the proposed project operation the southern portions of the lake would experience greater daily shoreline 

migration than the rest of the lake with an estimated 40 foot average daily shoreline migration when the 

project operates. The shallow embayments in the southern part of the lake would experience the greatest 

daily oscillation in exposed sediments, up to hundreds of feet. Because the draft EIS did not address the 

effects of wave action on the exposed shoreline in the southern part of the lake, CRWQCB recommends 

further discussion of the effects of increased turbidity from the raising and lowering of the shoreline be 

included in the final EIS. 

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Response: Based on Anderson (2006), it is our understanding that the shoreline migration would range 

from 8 feet to over 100 feet depending on location and shoreline configuration; however, because the 

amount of shoreline subject to the large shoreline exposures (of up to 100 feet) represents a small 

percentage of the shoreline length (less than 10 percent) that is predominately located along the southern 

shore within an embayment with west facing exposure, any increases in turbidity or suspension of fine 

grained sediments would largely be confined to these protected areas and only marginally effect the 

turbidity within the main water body of Lake Elsinore. At the same time stable lake levels may be 

beneficial to these areas by promoting macrophytes or riparian vegetation growth which may promote an 

evolution of the shoreline substrate in these areas from barren, sandy soils susceptible to wave actions 

suspending sediments to an aquatic vegetation induced stable substrate that traps suspended materials and 

prevents future sediment suspension improving water quality. We have modified the text in the final EIS 

to include this discussion. 

Comment 92: The Santa Ana Water Board states that the draft EIS has not taken into account the effect 

that cycling the water would have on its temperature in the discussion on page 3-68 of the draft EIS 

regarding the project benefiting the annual mean water quality of Lake Elsinore. The friction exerted on 

the cycled water as it is pumped to the upper reservoir, cycled down and through turbines may increase 

the water temperature. The Santa Ana Water Board and EPA recommend a 3-D hydrodynamic model for 

the lake be developed to predict turbulent energy inputs, mixing, and circulation and their effects on the 

lake. The Santa Ana Water Board requests that in the final EIS an appropriate model is used to 

recalculate the effects on the temperature and DO levels of the cycled water. 

Response: The cycling of water through 1.5 miles of conduit is likely to have a negligible effect on 

raising the temperature of the water as the conduits would be underground where annual temperatures are 

consistently cooler (about 60 degrees F) than the summer lake temperatures (time when the demand for 

the project would be greatest) thereby negating any increase resulting from friction. Concerning the 

overall effect of cycling water between reservoirs and the potential effects on Lake Elsinore’s thermal 

regime, we have augmented our discussion on the effects of cycling on temperatures in the lake in section 

3.3.2.2 of the final EIS. Further, we find that given the uncertainties associated with the success of other 

water quality related programs such a the Lake Elsinore Stabilization and Enhancement Project and the 

axial flow pumps designed to disturb the thermal gradient that develops throughout the lake in the 

summer, the implementation of a 3-D hydrodynamic model prior to making a licensing decision would 

not make sense. 

Comment 93: The city of Lake Elsinore states that Lake Elsinore and San Jacinto Watersheds Authority 

(Joint Watershed Authority) has invested considerable funds to develop, build, install, and operate a 

reliable aeration system for the lake to improve water quality and that any alteration to the design or 

operation of the existing system to accommodate the project should require mitigation through the 

development of an equally reliable, dedicated, and applicant-funded aeration system. 

Response: We do not expect any negative effects from the LEAPS Project operation on the aeration 

system implemented as part of the Joint Watershed Authority’s Lake Elsinore Stabilization and 

Enhancement Project. We also note that Dr. Alex Horne (Elsinore Valley MWD and Nevada Hydro, 

2005) has suggested that design features could be incorporated into the final LEAPS Project that could be 

beneficial to the efforts of the Joint Watershed Authority programs. Our recommended revised lake 

management plan is the proper place to recognize the relationships between the proposed project and 

other lake management programs. 

Comment 94: Riverside County states that the addition of imported water to Lake Elsinore should not 

introduce Total Phosphorus or Total Nitrogen in excess of the respective TMDL Load Allocations 

assigned to Supplemental Water discharges to Lake Elsinore. Total Phosphorus offsets for supplemental 

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water discharges should not be allowed unless the required 35 percent in-lake Total Phosphorous load 

reductions have been achieved by in-lake nutrient treatment and removal projects. 

Response: Make-up water to maintain Lake Elsinore at elevation of 1,240 feet msl would be acquired by 

Elsinore Valley MWD, using funds from the co-applicants designated for this specific purpose. Because 

the water would be delivered by Elsinore Valley MWD, the quality of the water would be subject to its 

allocated or supplemental load allocations under the TMDL. As such, we expect make-up water as part 

of the proposed project would meet the TMDL requirements. 

Comment 95: The Santa Ana Water Board comments that is unclear from the discussion on page 3-67 of 

the draft EIS what effect the intake/outlet discharges would have on Lake Elsinore water quality, and 

therefore recommends that appropriate modeling be used to assess the effects of the project on internal 

nutrient loading in the lake and results be presented in the final EIS. The State Water Board also states 

that it is unclear what affect the discharges from the intake/ outlet structure into Lake Elsinore would have 

on the lake’s water quality standards because the reversal of flows during project operation could resuspend bottom sediments. 

Response: We have modified the text in section 3.3.2.2 of the final EIS to clarify the expected effects of 

discharges from the intake/outlet structure during project operations on suspended sediments and nutrients 

within Lake Elsinore. As noted in our response to comment 92, given the uncertainties associated with 

the success of other water quality related programs such a the Lake Elsinore Stabilization and 

Enhancement Project and the axial flow pumps designed to disturb the thermal gradient that develops 

throughout the lake in the summer, the implementation of a 3-D hydrodynamic model prior to making a 

licensing decision would not make sense. 

Comment 96: Mr. Pinnow comments that water quality analysis in the draft EIS contains some obvious 

mistakes such as the statement on page 3-67 that “a greater surface area to volume in the upper reservoir” 

used in support of the co-applicants’ view that the operation of the pumped storage project could improve 

DO in Lake Elsinore. He points out that the average depth of the upper reservoir would be much greater 

than the average depth of Lake Elsinore (180 versus 15 feet) so that the surface area to volume ratio in the 

upper reservoir would be less than the surface area to volume ratio in Lake Elsinore. 

Response: We have corrected the text in the final EIS based on Mr. Pinnow’s comment. At 1,240 feet 

msl, Lake Elsinore has a surface area of 3,074 acres and a volume of 38,519 acre-feet (surface area to 

volume ratio of 0.08). Decker Canyon reservoir would have a surface area of about 76 acres which 

corresponds to a volume of 5,500 acre-feet, resulting in a ratio of 0.01, smaller than Lake Elsinore. 

However, we still conclude that over time, project operations should provide a measurable benefit to the 

annual mean water quality by using temperature and oxygen concentration differences between the two 

water bodies to promote mixing of the water column and control internal nutrient loading within Lake 

Elsinore. Our view that project operations could increase oxygen concentrations within Lake Elsinore is 

also supported by Dr. Alex Horne in his memo to David Kates filed in response to AIR-WQ-6 (Elsinore 

Valley MWD and Nevada Hydro, 2005) and by Dr. Micheal Anderson (Anderson, 2006) in his technical 

analysis of the potential water quality effects of the LEAPS Project on Lake Elsinore submitted to the 

Santa Ana Water Board, January 31, 2006, and filed by Nevada Hydro as appendix D of its comments on 

the draft EIS. 

Comment 97: The Center for Biological Diversity questions the conclusion in the draft EIS that lake 

level stabilization would result in benefits to water quality greater than the effects associated with 

sediment disturbances from the project. It points out the Santa Ana Water Board studies referenced in 

draft EIS conclude that both control of nutrients and lake level stabilization are necessary to improve 

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water quality in Lake Elsinore and do not specify that water levels are more important than sediment 

disturbance. 

Response: Based on comments on the draft EIS we have modified the text in the final EIS to clarify the 

point raised by the Center for Biological Diversity; however, we would also like to note that Lake 

Elsinore is a terminal lake that has at times completely dried up. The fluctuation in shoreline widths 

during the historic drying and filling phases of the lake has resulted in sediment disturbances at all 

reservoir elevations. The cycling of water into and out of Lake Elsinore, and the resulting changes in 

exposed shoreline would not be substantially different than historical conditions save for the timing 

between the rising and falling surface elevations. Once water sources and levels are secured, secondary 

programs and projects have been proposed and implemented to improve the quality of water in the lake. 

The LEAPS Project is one such project dependent on water levels which could contain design features 

that could assist the already approved Lake Stabilization and Enhancement Project. The TMDL is the 

appropriate tool to control nutrient loading into Lake Elsinore and the lake level stabilization has been 

determined by local agencies as a promising method to improve water quality. We discuss the effects of 

project operations on water quality in section 3.3.3.2. 

Comment 98: The Santa Ana Water Board states that the comments in the draft EIS regarding the 

positive effects of the project on phytoplankton are speculative and request that the final EIS include more 

comprehensive documentation of the effects, including specific references supporting the claims. The 

Santa Ana Water Board also indicates that the draft EIS does not include a discussion of the project’s 

effects on zooplankton in Lake Elsinore, which are important in the reduction of phytoplankton. Dr. 

Michael Anderson, referenced by the Santa Ana Water Board, states the operation of the project could 

result in significant zooplankton mortality. As such, the Santa Ana Water Board recommends that the 

final EIS evaluate the project’s effect on zooplankton.

Response: Based on comments on the draft EIS we have modified the final EIS and discuss the 

anticipated effects of the proposed project on phytoplankton and zooplankton. We conclude that the 

natural mixing processes resulting from the project operations combined with the increased efficiency of 

the axial flow pumps, installation of the diffused aeration system and the proposed project should all help 

to achieve oxic conditions in the subsurface that would help to control algae blooms. Project operations 

could negatively affect zooplankton populations through entrainment. However, this extent of potential 

effect would depend on the depth of the intake. 

Comment 99: The Santa Ana Water Board and EPA indicate that the effects of operating a pump storage 

system on a terminal lake are unknown. The Santa Ana Water Board requests a thorough discussion on 

the possible effects of a pump storage system on a terminal lake, such as Lake Elsinore, be included in the 

final EIS that takes into consideration the unique nature of this lake.

Response: We conclude that the effects of operating a pumped storage project on a terminal lake like 

Lake Elsinore would not be substantially different from operating a pumped storage project on a nonterminal lake. The effects of pumping water into and out of Lake Elsinore on a daily basis within the 

Joint Water Authority’s specified target range would be less dramatic over the long term than maintaining 

lake levels between 1,240 feet msl and 1,247 feet msl on a terminal lake that has dried up completely in 

the past. 

Comment 100: The Santa Ana Water Board requests the following studies be done to better quantify 

project effects on water quality standards of Lake Elsinore and reduce uncertainty concerning predicted 

effects: (1) evaluation of the water temperature gain and/or loss that would occur as the project transfers 

water between the lake and the upper reservoir and back and the effects of the temperature change on 

water quality; (2) develop and apply a 3-D hydrodynamic model for the lake; and (3) develop an 

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ecological model that can be used to better understand the trophic cascades that may result from the 

project. EPA requested the previous two models listed be applied, as well. 

Response: We conclude that the information in the record of this proceeding is currently sufficient to 

assess the potential effects and to recommend proposed measures to address the potential effects. Further, 

as explained in our response to comment 92, we find that given the uncertainties associated with the 

success of other water quality related programs such a the Lake Elsinore Stabilization and Enhancement 

Project and the axial flow pumps designed to disturb the thermal gradient that develops throughout the 

lake in the summer, the implementation of a 3-D hydrodynamic model prior to making a licensing 

decision would not make sense. 

Comment 101: EPA and the Corps recommend the final EIS include a functional assessment of direct, 

indirect, and cumulative effects to waters at both upper reservoir sites from watershed changes. 

Response: In the final EIS, we have provided such an assessment on the Decker Canyon site as we did 

for the Morrell Canyon site in the draft EIS. 

Comment 102: The County of Orange questions where water collected by the proposed seepage 

collection systems would be discharged and how water from dam seepage would affect the water quality 

and habitat of the upper San Juan Creek watershed. It also asks under what circumstances water would be 

released to the San Juan Watershed in the event of dam failure, how much water would be released to the 

San Juan Watershed, and how would the release affect water quality. The Center for Biological Diversity 

also raises this concern. Further, the State Water Board questions where emergency releases from the 

upper reservoir would be discharged to and what would be the effect of releasing Lake Elsinore water into 

Morrell or Decker Canyons. 

Response: The purpose of the seepage collection system is to collect natural seepage from the San Juan 

Creek within the footprint of the proposed upper reservoir and convey that water beyond the dam to keep 

it in the watershed. The co-applicants propose a liner system to prevent Lake Elsinore water from leaking 

into the San Juan Creek watershed. We discussed potential dam failures at the upper reservoir sites on 

page 3-32 of the draft EIS. We noted that dam failure analyses submitted in the license application were 

preliminary and that if licensed, a more detailed inflow design flood and dam break analysis would be 

developed in the final supporting design report prior to construction. The dam break analysis is described 

in detail on page E.6-43 through E.6-50 of the license application. Failure of any dams or dikes 

associated with the upper reservoirs would temporarily affect water quality and introduce considerable 

sediment into the San Juan Creek. However, the probability of dam failure is remote. Emergency 

overflows associated with the spillway would also discharge into the San Juan Creek watershed and 

temporarily introduce Lake Elsinore water into the watershed. 

Comment 103: The Center for Biological Diversity states that the final EIS must include a more specific 

comprehensive monitoring plan, particularly with regard to water quality impacts to the San Juan Creek. 

Response: The liner system proposed for the upper reservoir would prevent any water from seeping out 

of the upper reservoir to mix with waters in San Juan Creek under normal operating conditions; however, 

the EIS does recognize there is some risk of inter-basin transfer regardless of the preventive measures. 

Failure of any dams or dikes associated with the upper reservoirs would be considered outside normal 

operations and would temporarily affect water quality and introduce considerable sediment into the San 

Juan Creek. The co-applicants propose and we recommend the development and implementation of an 

upper reservoir water conduit monitoring program to assess the effects of the upper reservoir liner and 

seepage collection systems, shafts, and tunnel on groundwater levels and water quality. 

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Comment 104: Interior points out that the analysis in section 3.3.2.2 of the potential effects of operations 

of the proposed project on algae blooms in Lake Elsinore does not take into account the potential effect of 

algal decomposition on DO levels if the intake structure were designed to draw in water near the surface. 

Response: We have augmented the discussion on the potential effects of the proposed operations on 

algae and the resulting increases on oxygen demand after algae die-off. We conclude that it would be 

unlikely that the water level and suction of the intake would be sufficient to draw significant amounts of 

algae into the intakes where pressure gradient could eliminate their ability to float causing them to die and 

sink to the bottom of the lake as suggested by the co-applicants. 

Comment 105: The Santa Ana Water Board states that the draft EIS contains very little discussion of the 

effects on water quality and beneficial uses from the construction and operation of the high voltage power 

line that is part of the project. It requests that in the final EIS BMPs, non-point source pollution 

management measures, and other techniques to be employed to reduce effects on water quality standards 

from power line construction and operation be discussed.

Response: The effects of the construction of the transmission lines are detailed in section 3.3.1.2, 

Environmental Consequences, in Geology and Soils and succinctly stated with respect to water quality in 

section 3.3.2.2, Environmental Consequences, in Water quality. The co-applicants proposed and our 

recommended soil erosion control plan would use BMPs to control the effects of construction on water 

quality in the project vicinity. We recommend implementation of the soil erosion control plan and 

hazardous substances spill prevention and control plan over the term of any license issued for project. 

Comment 106: EPA and the Corps recommend the final EIS include a description of the functions and 

values of the streams that could be affected by the construction of crossings for the transmission line 

access road, a discussion of the significance of the aquatic resources at risk from construction and 

operation of the transmission line, and an evaluation of less damaging alternatives to culverted crossings.

Response: We identify the drainages that would be crossed by the proposed and staff alternative 

transmission alignments. The co-applicants indicate that they would place transmission towers to avoid 

sensitive areas and riparian areas. Further, our recommended measures to conduct site-specific preconstruction surveys for specials plants and wildlife in sensitive areas and implement a vegetation control 

plan along with the co-applicants proposed soil erosion control plan would avoid effects on aquatic 

resources during the construction and operation of the transmission line. As tower placement and 

temporary access roads would have the potential to affect streams, culverted crossings, and sensitive 

areas, we recommend in the final EIS that the co-applicants prepare and implement a transmission tower 

placement plan in consultation with the USFS, CDFG and FWS. 

Comment 107: Pacific Clay states that the cumulative effects analysis in the draft EIS for water 

resources is inadequate and only references the Santa Ana Integrated Watershed Plan and lists 

Congressional appropriations without going beyond general statements or perfunctory analysis. 

Response: The cumulative effects analysis not only covers the Santa Ana Integrated Watershed Plan but 

also mentions the pending TMDL developed for Lake Elsinore and Canyon reservoir as well as the Joint 

Watershed Authority’s Lake Level Stabilization and Enhancement Project. The cumulative effects 

analysis raises the most pertinent programs that could have additional effect on the water quality of Lake 

Elsinore and discloses the cumulative effect relative to the proposed project. 

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AQUATIC RESOURCES 

Comment 108: Pacific Clay is critical of the analysis in the draft EIS regarding the effects of 

construction on fish habitats and populations. It states that transmission tower locations could affect fish 

populations through stream crossings and ground disturbing activities washing sediment into streams; 

however, these locations are not yet sited, measures are not specified in the draft EIS to prevent these 

effects, and affects to major drainages are not discussed. It also notes that the draft EIS does not suggest 

alternate approaches from rotenone poisoning in Lake Elsinore or discuss the consequences of this 

poisoning. Further, Pacific Clay questions the speculative conclusions about the effects of the 

intake/outlet in Lake Elsinore absent specific information on the location, depth, and distance from the 

shore. 

Response: Measures to avoid potential effects to fish populations from ground disturbing activities from 

transmission tower placement are addressed on page 3-81 of the draft EIS. The co-applicants indicate 

that they would avoid placing towers in sensitive areas and riparian areas. Although exact tower locations 

have not yet been sited, implementation of established BMPs are commonly applied during construction 

activities and are typically effective at protecting stream resources if implemented properly. As noted in 

our response to Comment 106, tower placement and temporary access roads would have the potential to 

affect streams and sensitive areas and therefore we recommend in the final EIS that the co-applicants 

prepare and implement a transmission tower placement plan in consultation with the USFS, CDFG and 

FWS. 

As discussed on page 3-84 of the draft EIS, rotenone poisoning would remove desirable game fish as well 

as undesirable carp from Lake Elsinore, and this measure is not supported by the Joint Watershed 

Authority Fisheries Management Plan. Current presence of carp in Lake Elsinore is not the result of the 

co-applicants’ proposal, and therefore we do not recommend the co-applicants be responsible for the 

extirpation of carp from the lake by rotenone poisoning or any other means. 

While we agree with Pacific Clay that the location, depth and distance from shore of the intakes are only 

conceptual, we respectfully disagree that the analysis for entrainment potential is inadequate for the EIS. 

In the draft EIS, we examined the likelihood for entrainment if the intakes were located near the shore or 

far out into the lake, and concluded that the likelihood of fish entrainment in the intakes was low. We 

also reviewed performance of several physical and behavioral barriers used at other projects or that are 

under development, and we conclude that implementation of such facilities is very expensive relative to 

the potential benefit to the fishery. Therefore, our staff recommendation is that the co-applicants monitor 

the intakes for entrainment losses during the first year and once every 5 years thereafter over the term of 

any new license. Based on the monitoring results, we recommend the co-applicants develop and 

implement, with Commission approval, measure to mitigate for any losses. Mitigation activities may 

include implementing measures such as those identified in the Fisheries Management Plan, including 

annually stocking desirable game fish that would lead to the establishment of a productive sport fish 

fishery in Lake Elsinore. 

Comment 109: Linda and Martin Ridenour take issue with the statement in section 3.3.3.2 of the draft 

EIS that the Santa Rosa powerhouse would not be near a stream. They state that a USFS map shows a 

blue line (stream) in the vicinity of the proposed powerhouse. 

Response: We have modified the final EIS to state that small streams are located on the Santa Rosa 

powerhouse site. The co-applicants proposed and our recommended soil erosion control plan would 

include measures to avoid impacts to the water quality in these streams. 

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Comment 110: CDFG states that the final EIS should address project effects on the arroyo chub (Gila 

orcutti), a species of special concern and the tidewater goby (Eucyclogobius newberryi), a federally 

threatened species and state species of concern from the reservoir’s effects on water quality and the 

introduction of non-native species to the watershed. The State Water Board also is concerned about the 

potential introduction of exotic species (bass and sunfish) in Lake Elsinore being a threat to the upper 

reservoir’s watershed if a spill or overflow releases adults or larvae of these species. 

Response: A discussion of project effects on arroyo chub has been included in section 3.3.3.2 of the final 

EIS. Tidewater goby are not known to occur in the project area or watershed, the only reference to the 

presence of tidewater goby in the San Juan drainage is from an observation noted in 1939. Habitat for 

tidewater goby consists of brackish shallow tidal lagoons and lower stream reaches where the water is 

fairly still but not stagnant. Currently San Juan Creek does not provide habitat suitable for the tidewater 

goby (FR 65:69693), and San Juan Creek does not contain designated critical habitat for this species. 

Therefore we did not include a discussion of tidewater goby in the EIS. 

See also response to Comment 102. The likelihood for a spill or overflow event is remote, and would be 

the result of a catastrophic event. Therefore the likelihood for adult fish to be introduced into the upper 

reaches is remote, and larvae of warmwater fish would not likely survive such an event. As stated on pg. 

3-80 of the draft EIS, non-native species including bass and sunfish are already present in lower reaches 

of San Juan Creek. Surface water quality monitoring below the upper reservoir was proposed by the coapplicants and recommended by the USFS and staff and clarified requirements for a monitoring and 

remediation plan should fish from Lake Elsinore be introduced into San Juan Creek. 

Comment 111: The city of Lake Elsinore recommends that an Aquatic Vegetative Management Plan for 

Lake Elsinore be developed and implemented to mitigate for the possible negative effects of lakestabilization and sediment resuspension. 

Response: The Final Fisheries Management Plan for Lake Elsinore developed for the Joint Watershed 

Authority contains measures to address establishment of stands of aquatic vegetation. However, such 

activities will not be successful until the number of carp, which feed on aquatic plants, in the lake is 

reduced. Also see our response to comment 112. 

Comment 112: The city of Lake Elsinore states that the project may have a substantial negative 

environmental effect on achieving the goals of the Fisheries Management Plan and the state beneficial use 

designation. As such it recommends the following mitigation measures be implemented: (1) fund an 

intensive 2-year carp removal program by the city in the amount of $500,000 in lieu of the proposed 

“rotenone poisoning”; (2) fund improvements to sport fish spawning habitat in the large cove off the Tpeninsula of the levee system based on the plans and specifications prepared by Wildlands Inc. for the 

Joint Watershed Authority in the amount of $500,000; (3) develop and fund improvements to 

approximately 60 acres of adjacent fry and fingerling nursery habitat in the southeast bay area in the 

amount of $1,500,000; (4) develop and conduct fish population surveys every 3 years on Lake Elsinore to 

assess the fishery and attainment of the goals of the Fisheries Management Plan, with sport fish stocking 

based on the results of the surveys and consultation with CDFG at a cost no less than $50,000 annually; 

and (5) immediately clean up any fish kills that occur during project construction, count the loss of sport 

fish, and replace the lost sport fish before the project is operational. 

Response: We respectfully disagree that the operation of the proposed project would have substantial 

negative effects on achieving the goals of the Fish Management Plan and the state beneficial use 

designation. Management of fisheries resources in Lake Elsinore is the responsibility of the Joint 

Watershed Authority that developed the Fisheries Management Plan for Lake Elsinore to address agency 

priorities for manipulating the current composition of fish species as well as implementation of habitat 

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enhancement measures to restructure and improve the sport fishery in the lake. There are many elements 

of the Fisheries Management Plan, which is designed to be adaptive in order to respond to changes in the 

fishery over time that may occur as a direct result of actions described in the plan, or as an indirect result 

of other activities that affect fish resources in the lake. 

The current state of the Lake Elsinore fishery, lack of aquatic vegetation, and presence of undesirable 

populations of carp in Lake Elsinore is unrelated to the proposed project construction and operations. 

Carp removal is a key element of the Fisheries Management Plan to restructure the fishery in the lake, and 

the measure is already being implemented through annual netting operations. Rotenone poisoning is not 

recommended as it would also remove desirable game fish from the lake. The habitat enhancement 

measures recommended by the city of Lake Elsinore do not appear to address potential project affects on 

the fishery, but are enhancement activities that are already planned. Our recommendation is that the coapplicants monitor for entrainment in year 1 and every 5 years thereafter over the term of any license 

issued for the project. Any contributions to the implementation of the Fisheries Management Plan, would 

depend on the results of the entrainment monitoring and would be tied to project-related fish mortality 

and impingement. The monitoring plan would be developed in consultation with the CDFG, FWS, the 

State Water Board and the Joint Watershed Authority. 

Comment 113: Linda and Martin Ridenour request information about the fish stocking program 

including the frequency of fish stocking, the types of fish to be stocked, and the cost to Elsinore Valley 

MWD to do the stocking. 

Response: The co-applicants propose and we recommend consultation with CDFG and FWS to support a 

sports fish stocking program in Lake Elsinore consistent with the Fisheries Management Plan for 

recreational angling. The details of this support would be determined in the event that the Commission 

issues a license for the project. 

Comment 114: The Santa Ana Water Board indicates that the project may potentially affect the lake’s 

fish population, especially larval fish or ichthyoplankton through entrainment and impingement. It states 

that although the draft EIS briefly discusses methods to reduce mortality to fish from project operations, 

the final EIS should provide more discussion on methods to be used to reduce fish and ichthyoplankton 

effects. 

Response: Section 3.3.3.2 (pages 3-88 and 3-89) of the draft EIS discusses the known technologies 

currently available to prevent fish entrainment as well as anticipated effects of project operations on fish 

of various life-stages. In a report filed by the co-applicants, Anderson (2006) estimated potential 

entrainment losses of ichthyoplankton, zooplankton, and phytoplankton from operation of the project to 

be 40 to 100 percent, 7 to 24.8 percent, and 1.1 to 4 percent, respectively, based on specific operating 

scenarios and generalized modeling assumptions. Anderson (2006) also speculated on the effectiveness 

of a filter-fabric-curtain to prevent entrainment mortality. The co-applicants suggested but did not 

propose an aquatic filter barrier system might be employed to prevent entrainment of fish, fish eggs and 

larvae, however such systems were designed for much smaller flow rates and have not been tested for 

flows as high as 1967 cfs for each intake, as is proposed for Lake Elsinore and we do not recommend 

such a system in Lake Elsinore. 

Comment 115: The State Water Board states that the proposed 1-year entrainment monitoring program 

may not be long enough to evaluate the potential effects on the Lake Elsinore fishery. 

Response: We agree with the State Water Board and have revised our staff recommendation to include 

monitoring for entrainment losses once every 5 years over the term of any license issued because of the 

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structure and composition of the fisheries is expected to change as a result of implementation of the 

Fisheries Management Plan. 

Comment 116: The Friends of the Forest comments that the draft EIS does not provide much 

information about the littoral zone of Lake Elsinore. It points out that this is the area of the lake that 

would be most affected by the proposed project operation and state that biological studies must be 

completed. The State Water Board and the Center for Biological Diversity also states that the final EIS 

needs to address the consequences of lake fluctuation and the exposure of near-shore littoral habitats on 

game fish spawning habitat and other wildlife habitat. 

Response: We have added text to section 3.3.4.2 to provide further information regarding the effects of 

lake fluctuations on wildlife habitat in the fluctuation zone. Current seasonal and annual lake level 

fluctuations in Lake Elsinore contribute to the lack of vegetation on the shore and the lack of submerged 

aquatic vegetation. The Joint Watershed Authority concluded that the lack of floating or submerged 

aquatic plants results from several factors in addition to the lake level fluctuations, including limited 

availability of shoreline sediments for rooting, shading by dense algal populations; turbidity caused by 

several mechanisms, and constant foraging by carp (Joint Watershed Authority, 2005). Limiting lake 

level fluctuations to 1 foot on a daily basis, and 1.7 feet on a weekly basis as proposed by the coapplicants would provide a more stable regime of constant inundation and may contribute to the 

establishment of rooted shallow-water vegetation that provides spawning, rearing, foraging, and cover 

from predators. Anderson (2006) estimated the fluctuations in shoreline exposure would not result in 

increased turbidity, since natural wave action would likely prevent fine material from accumulating near 

the active shoreline. 

Comment 117: Pacific Clay states that the cumulative effects analysis in the draft EIS for fisheries is 

inadequate and only provides a project-specific discussion of the effects of project operations on the city 

of Lake Elsinore’s fishery programs. It states that this is a violation of NEPA because it fails to provide a 

listing of related actions and never addresses project effects in combination with those of other past, 

present, and reasonably foreseeable future actions within the San Juan River Basin. 

Response: We have expanded the cumulative effects section in regards to fisheries to include 

reconfiguration of the Back Basin Wetlands as part of the Lake Elsinore Stabilization and Enhancement 

Project and the proposed Special Area Management Plan for the San Juan Creek and Western San Mateo 

watersheds. 

TERRESTRIAL RESOURCES 

Comment 118: The Orange County Chapter of the California Native Plant Society states that the EIS 

should include a large-scale map or overlay that clarifies what percentage of the total southern coast live 

oak forest and other vegetation types would be removed at the sites. Furthermore, CDFG states that it is 

not possible to determine the existence of significant adverse effects because the draft EIS did not contain 

a detailed description or map of existing biological resources and habitat value within the project area, 

specifically the Lion’s Springs and Morrell canyon sites. EPA recommends the final EIS include detailed 

maps of both the Decker and Morrell canyon reservoir sites showing plant communities, water and 

wetland boundaries, riparian areas, and acreages for each. Linda and Martin Ridenour also comment that 

information about vegetation that would be disturbed is insufficient. 

Response: As an attachment to their April, 24, 2006, filing, the co-applicants submitted a report 

discussing a delineation of wetlands and waters at the Morrell and Decker Canyon sites that was 

conducted by Michael Brandman Associated (MBA) in January, 2006. We have overlaid the reservoir 

footprint for each alternative on an aerial photo that was included in the delineation report, to provide 

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additional detail about waters of the U.S. and waters of the state that occur on each site, as shown in 

figure 14 of the final EIS. Survey results are summarized in section 3.3.4.2. We conclude that the level 

of detail provided in the final EIS is sufficient to serve as the basis for comparing the biological effects of 

the staff alternative with those that would occur under the co-applicants’ proposal. Based on this 

comparison, we conclude that the staff alternative would be the least environmentally damaging action 

alternative. Additional information, including all the technical studies filed by the co-applicants, with 

attached aerial photos, site drawings, topographic maps, cover type maps, jurisdictional wetland 

delineations, functions and values assessments, field notes, and other exhibits, are available to the public 

on the Commission’s eLibrary or by request from the co-applicants. 

Comment 119: SDG&E requests a clarification concerning the type of vegetation cover (disturbed or 

chaparral) at the southern substation site given that the information in table 15 conflicts with the table 

note. 

Response: We have added headers to table 15 to clarify that the proposed southern substation is 

currently disturbed, and that the alternative southern substation is characterized by chaparral. 

Comment 120: CDFG notes that an accurate statement of the potential for impacts on sensitive species 

cannot be made because the final alignments of the transmission line and access roads have not been 

established. CDFG comments that the Department would require biological surveys for all sensitive and 

endangered species in the development footprint, according to the policies of the Multi-Species Habitat 

Conservation Plan (Multi-Species HCP). CDFG also notes that the California black walnut is considered 

locally and regionally sensitive, is covered by the Multi-Species HCP, and would be affected by the 

project. 

Response: As discussed in sections 2.4.3.2, 5.2.6 and 5.2.7, we recommend pre-construction surveys for 

special status species in any areas that have not yet been covered. We have added the California black 

walnut to table 13, and modified tables 13 and 14 to indicate species for which focused surveys would be 

needed, according to the Multi-Species HCP. 

Comment 121: Nevada Hydro states that no factual basis exists to impose a compensation requirement 

for those plant communities not recognized by the California Natural Diversity Database as high priority 

habitats. Nevada Hydro states that coastal sage scrub has not been identified as communities known or 

believed to be of high priority. However, although not required, the co-applicants would replace coastal 

sage scrub at a 1:1 ratio and requests that the proposed measure as described on page 2-14 of the draft EIS 

be corrected to reflect the 1:1 replacement ratio for coastal sage scrub. Nevada Hydro states that the 

appropriate replacement ratio for southern coast live oak riparian forest, southern sycamore-alder riparian 

forest, and southern willow scrub, should these habitats types be present with the area of physical 

disturbance, is 2:1. 

Response: We have corrected the text on page 2-14 to reflect the co-applicants’ proposal to replace 

coastal sage scrub at a 1:1 ratio and we have included this lower ratio in the staff alternative in the final 

EIS. The staff alternative also includes compensation for the loss of chaparral and non-native grasslands, 

at a 1:1 mitigation ratio because many special status species use non-native grasslands, including whitetailed kite, burrowing owl, loggerhead shrike, southern California rufous-crowned sparrow, northwestern 

San Diego pocket mouse and Stephens’ kangaroo rat. Chaparral habitat for these species would be 

reduced as a result of project construction, unless the co-applicants provide compensation. 

Comment 122: The Center for Biological Diversity comments that coastal sage scrub is also a rare plant 

community according to California Natural Diversity Data Base (CNDDB) and should be addressed in the 

final EIS (on page 3-92). It also comments that the draft EIS did not adequately describe the biological 

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resources of the project area and state that sticky Dudley, Parry’s tetracoccus, and Robinson’s peppergrass are additional List 1B species that occur in the San Juan Creek area and should be included in the 

final EIS. 

 

Response: The Center for Biological Diversity references CNDDB (2005) as the basis for stating that 

coastal sage scrub is a rare plant community. However, we could not find this reference in the Literature 

Cited section of the Center for Biological Diversity letter. In preparing the draft EIS, we used the List of 

Terrestrial Vegetation Natural Communities Recognized by the California Natural Diversity Database, 

September 2003 Edition, as posted on the CNDDB web site. The 2003 edition is still posted on the web 

site, as of August 17, 2006, and we assume this is the most current version. This version does not 

indicate that CNDDB considers coastal sage scrub to be a rare plant community. Regardless of the 

“official” status of the community, however, the draft EIS does address its special importance, and we 

recommend that the co-applicants mitigate for project effects (please see response to Comment 124). We 

did not conduct an in-depth analysis of any resources in San Juan Creek because we consider the risk of a 

dam break to be extremely low. 

Comment 123: Riverside County states that several species’ habitat assessments or focused surveys 

were not included in the draft EIS, specifically some of the narrow endemic and Criteria Area plant 

species required by the Western Riverside County Multi-Species HCP. A thorough analysis of effects on 

riverine and riparian habitats would be needed. 

Response: We have modified tables 13 and 14 to identify which species are narrow endemics, and have 

added Criteria Area species. We anticipate that additional plant surveys, burrowing owl surveys (if 

needed) and delineations of wetlands and waters that would be conducted prior to project construction 

would provide the information the County would need to evaluate project consistency with the MultiSpecies HCP. We have specified in section 5.2.6 that the co-applicants should consider these species, as 

well as others previously identified in the document, during planning for additional, focused surveys in 

areas that have not yet been covered (e.g., the final placement of transmission towers and temporary 

access roads) and that may be affected by project construction or operation. We have described the 

amount of temporary and permanent disturbance to habitats that support these species. 

Comment 124: CDFG states that the project occurs within the Western Riverside County Multi-Species 

HCP and CDFG will review the project for compliance with the plan. It states that a future habitat 

management plan for the project should include an in-depth analysis of the project’s effects on the MultiSpecies HCP and demonstrate how the project is consistent with the Multi-Species HCP. 

Response: We agree that the habitat mitigation plan should address project effects on species covered 

under the Multi-Species HCP and support CDFG’s intention to review the LEAPS Project for compliance 

with the plan. 

Comment 125: The Center for Biological Diversity also cites the lack of analysis of the potential effects 

of the co-applicants’ proposal to not clear vegetation under transmission lines as inadequate. It is 

concerned that failure to clear out vegetation under the transmission lines would increase the fire hazard 

in the project area. 

Response: The co-applicants do not propose to clear vegetation under the transmission line, but fuel 

management in the future may require manipulation to reduce the risk of fire. Methods selected for fuel 

management would be developed in consultation with the USFS and would depend on site-specific 

factors (e.g., vegetation type, slope, aspect, access), and could include grazing, prescribed fire, or 

mechanical means to create and maintain firebreaks. Existing firebreaks that intersect the proposed 

alignment would also be maintained, as needed and as specified by the USFS. The increased risk of fire 

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that would be associated with uncontrolled public access and weed invasion highlights the importance of 

effective road and weed management. The objective is to eliminate all man caused fires within the 

project area and to take prompt, aggressive action on all fires in the vicinity. Our recommended 

hazardous vegetative fuel treatment plan as specified by the USFS would set forth protocols for the 

treatment of vegetation in the vicinity of the transmission lines. 

 

Comment 126: Pacific Clay and Linda and Martin Ridenour state that the analysis of the construction 

effects on special status plants is inadequate because several areas were not included in survey efforts, 

mesa horkelia was not included in surveys, the effects of the transmission line are unknown because it has 

not been sited, no rare plant surveys have been conducted for the staff alternative, and maps do not 

provide a sufficient level of detail. They state that because of these reasons the mitigation proposed is not 

effective. The Ridenours would like to see all the plans that relate to the protection of rare plant species. 

Response: As mentioned in section 3.3.4.2, we recognize that site-specific pre-construction surveys 

would be needed for special status plants in any areas that have not yet been covered or that have not been 

thoroughly covered during previous surveys. We have added text to section 5.2.6 to clarify that data 

obtained through additional surveys should be used to avoid, minimize or mitigate adverse effects, first by 

locating transmission towers, roads and other project features away from any rare plant populations that 

may be present. We have added text to this section to specify that the co-applicants should consult with 

the resource management agencies and other stakeholders to develop a survey plan and then to develop 

mitigation plan, before submitting finalized reports and plans to the Commission. 

Comment 127: The Center for Biological Diversity points to a recent declaration by USFS that invasive 

species of weeds is one of the four greatest threats to National Forest System lands and comments that the 

EIS needs to include a description of weed communities in the project area as well as identification of 

higher protective standards for areas without invasive weed problems. It criticizes the co-applicants’ 

proposal to develop a weed control plan pursuant to the new Cleveland National Forest Land 

Management Plan because that plan only provides general guidance for the development of site specific 

plans. 

Response: The Center for Biological Diversity letter notes that non-native species are widespread in the 

South Coast Bioregion of California. Although only 12 weeds were documented during the coapplicants’ plant surveys, it is very likely that most, if not all, of the 42 non-native invasive species 

known to occur in the project vicinity are present in areas that would be affected by the project. On one 

hand, it would be advantageous to design the project to avoid areas that do not currently support weed 

species, in order to reduce the threat of introduction. On the other hand, it would be beneficial to design 

the project to avoid sites that support weed species, in order to reduce the threat of spreading them to uninfested areas. Neither scenario is likely possible, given that project features must also be located to 

avoid or minimize impacts on steep slopes; streams and riparian habitats; special status plants, plant 

communities, and animals; listed species; high quality recreation sites, sensitive viewsheds, and other 

important resources. This situation points out the importance of weed management, without any need for 

additional detail about existing conditions. 

We recognize that the Land Management Plan was developed at a general level to address almost 567,000 

acres of lands within the Cleveland National Forest, and was not intended to serve as a blueprint for the 

development of site-specific weed management plans. Many weed management handbooks are readily 

available that could serve as a blueprint for developing a plan to manage weeds in lands affected by the 

LEAPS Project. With their site-specific knowledge, we conclude that selection of any particular 

document as a model for developing a plan is best left to the co-applicants, in consultation with the 

resource management agencies and other stakeholders. In any case, because some project features would 

be located on National Forest System lands, we recommend that the co-applicants consult with the USFS 

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to develop a plan that is consistent with the Land Management Plan goals, objectives, and design criteria. 

We have added text in section 5.2.6 to clarify the elements that should be included in a weed management 

plan for the project area, including National Forest System and non-National Forest System lands. 

Comment 128: Bruce Campbell comments on the lack of information about the potential effects of the 

use of toxic and hazardous materials during the construction and operation of the project and requests that 

a supplemental or new draft EIS be issued that addresses these concerns. He comments that non-native 

plant species would spread in the area because of the construction of the transmission lines, increased use 

of OHVs, and transmission line maintenance activities. He requests more information in the draft EIS 

about the maintenance activities including what herbicides would be used, if toxicological profiles would 

be presented in a supplement or new draft EIS, and whether hazardous Material Safety Data Sheets will 

be completed and made available to the public. He asks if this information about herbicides would be 

made available to the public in both English and Spanish. 

Response: For the most part, the transmission line would traverse chaparral and grassland vegetation that 

does not reach a height that would interfere with project operation, and there would be no need to manage 

any vegetation except weeds. If taller vegetation is present and would interfere with system reliability or 

safety, it could be removed by periodic cutting or trimming. We anticipate that herbicides could be used 

for spot treatment of certain weed species. However, there are many alternatives to herbicides, and nonchemical treatments are almost always preferable (in terms of safety and environmental stewardship), 

unless other attempts at control have failed, and the risk of damage caused by weeds is greater than the 

risk of damage caused by an herbicide (Tu et al., 2001). 

As discussed in our response to comment 127, we have added text to section 5.2.6 to clarify our 

recommendations for development of a weed management plan. The plan should include an evaluation of 

all available methods of weed control for target species, a comparison of their costs and benefits, and 

finally, selection of the most appropriate treatment. If an herbicide is to be applied, the co-applicants 

would be required to comply with federal, state and local regulations for proper use and application. 

Comment 129: The Center for Biological Diversity indicates that the draft EIS fails to consider native 

willows, tule, and cattails at Lake Elsinore as potentially important riparian habitat and requests that 

information about stands of these species and wildlife use of these habitats be included in the final EIS. 

Linda and Martin Ridenour also state that information about wetlands associated with Lake Elsinore is 

insufficient. 

Response: We have added text in section 3.3.4.2 to recognize that even small and scattered patches of 

native riparian vegetation can provide important habitat for wildlife. We have added some anecdotal 

information about birds that use Lake Elsinore, reflecting comments supplied by the city of Lake 

Elsinore. We also note that implementation of the Lake Elsinore Stabilization and Enhancement Project 

combined with proposed operations, would be expected to result in a stable upper shoreline at 1,241.7 feet 

msl, with a variable fluctuation zone that covers about 79 acres 5 days a week and an additional 55 acres 

during the weekend. We would expect that additional shoreline vegetation and possible new wetlands 

that could support nesting shorebirds would develop above elevation 1,241.7 feet msl. Given this 

likelihood, we include a monitoring plan for shorebirds in our staff alternative. 

Comment 130: Nevada Hydro states that the co-applicants disagree with the statement on page 3-129 of 

the draft EIS that wetland delineations would be needed to evaluate and quantify effects. Nevada Hydro 

comments that the proposed LEAPS Project would not alter the operational parameters established under 

the Lake Elsinore Stabilization and Enhancement Project but would provide a revenue source that would 

facilitate the implementation of the plan. It indicates that seasonal variations are substantially greater than 

the limits outlined in the adopted plan, which has gone through environmental review, and it requests that 

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measures in the staff alternative for wetland delineations and habitat mitigation and monitoring for Lake 

Elsinore be eliminated from the final EIS. 

Response: We agree that stabilizing year-to-year and seasonal lake elevations, while allowing daily and 

weekly fluctuations, may have little effect on existing wetlands around Lake Elsinore, if any are present. 

Native species that persist around the shoreline, such as willows, tule and cattails, are tolerant of seasonal 

water level fluctuations that occur in natural systems throughout the semi-arid west and these species 

would likely tolerate daily fluctuations of 1 foot. Fluctuations limited to 1 foot and occurring within a 24-

hour time-frame, as proposed, should allow for soils to remain moist and these species would likely 

persist. Operational effects on wetlands that may be associated with Lake Elsinore would likely be minor. 

We do not recommend in the EIS any additional wetland delineations other than those proposed by the 

co-applicants as needed after the final placement of project facilities. 

Comment 131: CDFG recommends that all areas supporting hydrophytic cover be mapped in order to 

assess the potential effects on wetlands from the proposed project. It also recommends a CDFG-approved 

wetland restoration/protection plan, including a means of replacing or protecting the hydrologic 

conditions, which contribute to the existing wetlands. CDFG states that its policy has no net loss of 

wetlands and that buffers between existing or proposed development and existing wetlands or wetland 

compensation sites should be included in any mitigation plan. The Corps, the State Water Board, and 

Pacific Clay also state that wetland delineations need to occur to determine potential project effects. 

Response: As an attachment to their April 24, 2006, comments on the draft EIS, the co-applicants filed a 

delineation of jurisdictional waters and wetlands at the Morrell and Decker Canyon sites and an 

assessment of functions and values, using the California Rapid Assessment Method (CRAM). We have 

included exhibit 4 of the delineation report as figure 14 in the final EIS. We have revised and added text 

in section 3.3.4.2 to reflect information contained in this report. As noted in section 3.3.4.2, delineation 

of wetlands associated with Lake Elsinore would be needed, as well, to meet federal and state permitting 

requirements. 

Comment 132: The Orange County Chapter of the California Native Plant Society indicates that 

although the draft EIS properly states that the Lion Spring wetland fulfills important habitat functions that 

would lost if the project is built, it is not clear if there is an intention to replace the habitat function with a 

new wetland formed by the upstream and spring water that are proposed to be diverted under the 

reservoir’s geofabric liner. 

Response: A settling pond may be needed to ensure that clean water is returned to the creek downstream 

of the reservoir if Morrell Canyon is selected as the site of the upper reservoir. Returning flows to the 

creek would maintain natural processes downstream of the dam. However, we anticipate that replacement 

of habitat functions associated with Lion Spring itself would not be feasible, because of the complex 

geology and hydrology that characterize this site. The staff alternative includes an upper reservoir at the 

Decker Canyon location, which would eliminate the effect on Lion Spring.

Comment 133: The EPA and the Corps state that information regarding the need for section 404 

compliance for wetland effects should have been disclosed for consideration in the draft EIS. 

Additionally, EPA states that it considers this project and the TE/VS 500-kilovolt Interconnect Project to 

be separate projects in regard to section 404 compliance. SDG&E also questions whether the south 

substation would require a wetland permit for access or pad construction. 

Response: In general, Commission staff is not in a position to speculate about the permit requirements 

other agencies may impose. 

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Comment 134: Nevada Hydro provides a report containing the findings of jurisdictional wetland 

delineations at the Morrell Canyon and Decker Canyon upper reservation sites and requests that the 

descriptions of wetlands that might be affected by the construction of an upper reservoir be revised to 

reflect the findings of the wetland delineation report. 

Response: We appreciate the additional information and have included it in the document.

Comment 135: EPA states that the draft EIS should have included a conceptual description of what is 

being considered as compensatory mitigation to offset unavoidable effects to waters of the US, including 

wetlands at both the Decker and Morrell canyon reservoir sites. It states that compensatory mitigation 

should include restoration or enhancement of waters along with the acquisition/preservation of other 

waters. It recommends that the final EIS analyze an alternative that combines the Decker Canyon site 

with a minimal functional transmission line that avoids waters of the United States to the maximum 

extent possible. EPA recommends the final EIS indicate how riparian habitat losses would be mitigated 

for under the staff alternative. 

Response: We do not include a conceptual description of compensatory mitigation, because we do not 

have information about opportunities/resource needs that may exist within the upper San Juan Creek 

basin. However, we have added text discussing mitigation priorities to sections 3.3.4.2 and 5.2.6. 

Comment 136: CDFG states that the draft EIS did not address its comments from the October 21, 2004, 

letter pertaining to the loss of approximately 100 acres of mature oak woodlands associated with Lion’s 

springs and a rare perennial spring. 

Response: The referenced letter was sent to the co-applicants only and was not filed with the 

Commission until April 2006; therefore, CDFG comments were not considered in the draft EIS; however, 

we now acknowledge CDFG's October 21, 2004, letter and note that the draft EIS did consider the 

potential effects of the project on the mature oak woodlands associated with Lion Spring at the proposed 

upper reservoir location in Morrell Canyon. 

Comment 137: Nevada Hydro points out that the exact acreages for replacement ratios remain subject to 

further refinement based on site selection and final grading plans. Further, Nevada Hydro states that 

either the 3:1 or the 5:1 replacement ratio for oak woodlands would appear to be beyond the ability of the 

co-applicants to achieve. Nevada Hydro requests that the final EIS reference California Senate Bill 1334 

which established section 21083.4 of the Public Resource Code and specifies oak woodland mitigation 

under CEQA and maintains the proposed ratio of 3:1 for replacement of oak woodlands. 

Response: As noted in section 3.3.4.3, we considered California Senate Bill 1334 establishing section 

21083.4 of the Public Resource Code in making our recommendations regarding an appropriate 

mitigation ratio. In section 3.3.4.2, we identified the advantages and disadvantages of various approaches 

to mitigation, including on-site planting, on-site transplanting, contribution to a mitigation banks, and 

purchase of off-site lands or conservation easements. We concluded that the first two options would not 

likely be successful, and that the third option might not allow the co-applicants, resource management 

agencies and other stakeholders to choose site(s) for mitigation that would provide the highest local 

benefits. For this reason, we recommended purchase and protection of existing oak woodlands at the 1:1 

ratio recommended by Interior and specified by USFS. 

Comment 138: The Orange County Chapter of the California Native Plant Society states that the 

proposed 2:1 oak mitigation is inadequate and that oaks should be mitigated at 5:1. SDG&E requests 

further discussion of why the co-applicants propose a 2:1 ratio rather than the 5:1 ratio recommended by 

the USFS as well as discussion of CDFG’s permitting requirements under section 1600 of the Fish and 

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Game Code for riparian and oak woodland impacts. CDFG states that the proposed 5:1 ratio mitigation 

for the loss of oak woodland is not adequate, and instead should be 10:1, which is the CDFG standard for 

removal of mature coastal live oak trees. Additionally, CDFG states that the spacing of the replacement 

trees should be 20 feet minimum and should be monitored, nurtured, and protected within the drip line so 

they survive a minimum of 5 years. Off-site mitigation alternatives should be included in detail in the 

EIS and should be agreed upon by CDFG. The Center for Biological Diversity also recommends a higher 

mitigation ratio as well as information about where and how the mitigation would occur. 

Response: The staff alternative now includes a 1:1 habitat mitigation replacement ratio for oak 

woodlands and an equivalency analysis to ensure that the replacement habitat is of equal value consistent 

with Interior's recommendations and a priority for replacement with the Cleveland National Forest, 

consist with measures specified by the USFS, instead of the 5:1 habitat mitigation replacement ratio we 

recommended in the draft EIS. We consider CDFG’s recommended ratio of 10:1 to be excessive, because 

off-site mitigation will involve mature oak woodlands that currently provide high-quality habitat for 

wildlife, and there would be no time gap between the impact (project construction) and functional 

mitigation, as would be the case if oaks were planted on-site. We have not identified off-site options for 

mitigation, but have added text to section 5.2.6 to outline a general order of priority, and clarify that we 

recommend the co-applicants consult with the resource management agencies and other stakeholders to 

identify appropriate sites. 

Comment 139: The Orange County Chapter of the California Native Plant Society states that the draft 

EIS does not indicate the range of dbh above 8” or analyze dbh measurements to indicate age-classes, 

which would help determine the habitat functions of woodland oak communities that would need to be 

replaced by mitigation (page 3-130). 

Response: Coast live oak woodlands in Morrell Canyon contain a variety of age classes; trees range in 

size from 2 to at least 24 inches diameter at breast height (dbh), with most individuals in the 8 to 12-inch 

range. For this reason, we are recommending the co-applicants purchase and protect mature coast live 

oak woodlands as mitigation for habitat losses at Morrell or Decker Canyon. 

Comment 140: CDFG states that mitigation for the loss of biological resources should include both 

temporary and permanent effects. It believes that the draft EIS understates the habitat values of Morrell 

Canyon and Lion’s Spring oak woodland and that the loss of these resources to wildlife in the Cleveland 

National Forest and surrounding wilderness area would be a significant effect. As such, CDFG 

recommends that the co-applicants submit additional environmental analysis of the reservoir location and 

its effect on wildlife habitat function and value and submit a detailed Mitigation and Monitoring Plan to 

CDFG for approval. Additionally, CDFG states that any management plans developed as a result of the 

project should include CDFG input and approval. 

Response: The information filed with the Commission to date serves as an adequate basis for our 

conclusion that project effects on biological resources in Morrell Canyon (including Lion Spring) would 

be substantial. We have added text to section 5.2.6 to clarify that we are recommending the co-applicants 

consult with the resource management agencies (including CDFG) to develop a detailed habitat 

mitigation and monitoring plan. 

Comment 141: The Center for Biological Diversity states that the occurrence in the planning area and 

potential spread of sudden oak death syndrome that affects oak woodlands in coastal California must be 

addressed in the final EIS. 

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Response: Our review of maps posted on the California Oak Mortality Task Force website in 2005 

indicated that Phytophthora ramorum had not been reported south of Monterey. A review of the July, 

2006, maps shows the same result 

(http://kellylab.berkeley.edu/SODmonitoring/maps/PDF/SODCalifornia07-25-06page.pdf). Based on the 

Task Force’s evaluation, we conclude that there is a low risk of infection in western Riverside County and 

in Orange and San Diego counties 

(http://kellylab.berkeley.edu/SODmonitoring/maps/PDF/state_risk_05a_avg.pdf). 

Comment 142: The Center for Biological Diversity comments that the draft EIS lacks any meaningful 

information on how habitat loss at Morrell Canyon would affect special-status wildlife populations. It 

also comments that there is no meaningful or quantitative analysis of edge effects on wildlife from the 

loss of Morrell Canyon. 

Response: Section 3.3.4.2 concludes that project construction and operation would reduce habitat 

quantity and quality for special status wildlife populations in the area. We agree the draft EIS does not 

contain a detailed analysis of effects at the population level, but clearly, the analysis is sufficient to 

compare the effects of the proposed action and the staff alternative, in terms of acres and types of habitat 

that would be affected. We conclude that special status wildlife species that use those habitats would be 

adversely affected by the loss of those habitats, in direct relation to the acreage of each habitat type that is 

lost to construction. Thus, acres and types of habitat that would be affected serve as an adequate indicator 

of impacts on wildlife. Given similar reservoir configurations under both alternatives, the extent of edge 

effects would depend primarily on acreage, so again, the analysis is adequate to compare the effects of the 

proposed action and the staff alternative. Based on these relationships, no additional information is 

necessary to conclude that loss of Lion Spring (a unique habitat feature) and 20 acres of mature oak 

woodlands at Morrell Canyon would have a greater impact on wildlife, including special status species, 

than loss of 5 acres of mature oak woodland at Decker Canyon, and that the no-action alternative would 

have the least impact. 

Comment 143: Pacific Clay is critical of the special status wildlife analysis because survey data is out of 

date with none more recent than 1998 and mitigation measures are not consistent with the Western 

Riverside County Multi-Species HCP or the Cleveland National Forest Land Management Plan. 

Response: We have added text to section 3.3.4.1 to clarify that the co-applicants conducted general 

biological surveys in the project area in 2001and noted the presence of any special status species observed 

during other field efforts. Table 16 shows federally listed special status species for which focused 

surveys were conducted between 2001 and 2005. We anticipate that mitigation measures would be 

consistent with the Multi-Species HCP in calling for pre-construction surveys, where needed, and 

recommending compensation ratios that exceed the Multi-Species HCP minimum of 1:1. 

Comment 144: CDFG states that the EIS should address project effects on the southwestern pond turtle 

(Emy marmorata pallida), a state species of special concern from the reservoir’s effects on water quality 

and the introduction of non-native species to the watershed. 

Response: Only a dam failure at the upper reservoir could adversely affect the southwestern pond turtle. 

We have not conducted an in-depth analysis of any aquatic resources in San Juan Creek including the 

southwestern pond turtle, because the risk of a dam failure is very small. 

Comment 145: Scott Werner comments that the draft EIS does not provide specifics on the immediate 

and cumulative effects to many species, especially several CDFG-listed California Species of Concern 

including the Coast-horned lizard, and Southern California rufous-crowned sparrow, and Bell's sage 

sparrow. 

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Response: We used the lists provided in the license application and the co-applicants’ responses to 

additional information requests as the basis for describing special status species that could occur in the 

project area. Some special status species, such as Bell’s sage sparrow, may have been omitted from the 

lists. We have added the California Species of Special Concern that you text to section 3.3.4.2 and 

3.3.4.3 to indicate that other special status species may also occur, and would also be adversely affected 

by the loss of habitat types they use and by the increased risk of disturbance, both directly and 

cumulatively. 

Comment 146: The Center for Biological Diversity comments that the draft EIS cannot be used to 

satisfy the NEPA requirements for the USFS decision on the proposed project because it does not present 

any population data on Management Indicator Species, assuming that the Cleveland National Forest is 

currently operating under the 1982 regulations. 

Response: We used information taken from the Land Management Plan to provide general population 

data for the Trabuco Ranger District, Cleveland National Forest or the Santa Ana Mountains, wherever 

possible (see section 3.3.4.1), supplemented with results of MBA’s project-specific surveys for the 

California spotted owl and arroyo toad. Although no detailed data are available about management 

indicator species (MIS) populations, we find that the project would adversely affect MIS by removing 

habitat, and, for this reason, we recommend substantial mitigation if either of the action alternatives is 

implemented. 

Comment 147: Riverside County states that the location description of the project is too vague to 

accurately determine the potential effects of the project on reserve assembly; however, it is likely to be 

within cell criteria areas and has the potential to affect reserves and/or corridors including Core Reserve 

Area 1, the proposed extension of Core Area 2, and proposed Constrained Linkages 1, 2, and 9. 

Response: We agree with your assessment that the project has the potential to affect the reserves and 

corridors mentioned. 

Comment 148: Nevada Hydro cites numerous conclusions in the draft EIS that suggest that the project 

would have little effect on nesting shorebirds and requests that Interior's 10(j) recommendation for a 

monitoring and remediation plan to eliminate or reduce impacts to nesting shorebirds be deleted from the 

staff alternative and no conditions or measures be imposed with regard to shorebirds. 

Response: We respectfully disagree. The draft EIS concluded that while limited in size, small areas of 

suitable habitat that provides forage and cover for waterfowl, wading birds, and songbirds could be 

affected by project operations. We also concluded that the more stable water level would promote the 

development of emergent herbaceous plants within the 79-acre fluctuation zone and additional riparian 

vegetation may establish along the shoreline above the fluctuation zone providing additional suitable 

habitat for a variety of ducks, wading birds, and songbirds. Further, in comments on the draft EIS, the 

city of Lake Elsinore provided more information on water-associated bird species that currently use 

undisturbed shorelines of Lake Elsinore. Our recommended nesting shorebird plan would monitor 

project-related effects on these species. 

Comment 149: The city of Lake Elsinore states that the draft EIS seriously underestimates the lake’s 

avian resources and provides additional information of bird use of the lake. It states that to mitigate for 

the potential negative effects of the project on great blue heron and egrets, the co-applicants should be 

required to provide educational outreach to the general public by purchasing the nesting sites of these 

wading birds in both the Four Corners and Rome Hill areas of Lake Elsinore. The Center for Biological 

Diversity comments that the draft EIS presents no data about the shorebirds, waterfowl, and riparian birds 

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that use Lake Elsinore and relies on speculation to downplay potential impacts to avian species that use 

the lake. It also comments that the draft EIS does not provide an analysis of potential impacts to 

migratory birds sufficient to allow the reader to compare the various transmission route corridors relative 

to which alignment would best avoid such impacts. Linda and Martin Ridenour also comment that 

information provided by MBA is flawed and inadequate to serve as a basis for analysis of potential effects 

on birds at Lake Elsinore and within the Pacific flyway. 

Response: We have added text to sections 3.3.4 and 3.3.5 reflecting information the city of Lake 

Elsinore provided about bird species observed at Lake Elsinore. However, we have not included the 

city’s recommendation to include purchase of land in the Rome Hill and Four Corners areas to the staff 

alternative, because we conclude it is very unlikely that the project would affect nesting habitat for great 

blue herons or egrets. Great blue herons and egrets nest in trees that are large enough to support their 

sizable nests, in fairly close proximity to foraging areas. The co-applicants do not propose to remove any 

mature trees along the shoreline, and lake fluctuations should not affect existing trees. For these reasons, 

there should be no project effects on nesting habitat for these two species. 

Although the level of detail provided in the EIS is adequate to identify major areas of concern, we agree 

that monitoring will be needed to identify high-risk crossings along the selected alignment. As discussed 

in section 5.2.6, we are recommending the co-applicants implement measures to minimize the risk of 

collision. Consistent with Avian Power Line Interaction Committee (APLIC) and FWS guidelines for 

avian protection plans, the co-applicants would monitor the effectiveness of any measures that are 

implemented, and use the results to design and implement further protective measures if any are needed. 

Comment 150: The city of Lake Elsinore states that the fluctuating water levels caused by the project 

may have a substantial negative effect on shoreline birds and recommend the co-applicants mitigate for 

these effects by acquiring substantial shoreline property to restore, enhance, and protect the seasonal 

shoreline nesting sites. 

Response: The city’s comment letter indicates that several bird species that do not require emergent or 

woody riparian vegetation for nesting (including black-necked stilts, avocets, and killdeer) are known to 

breed along the Lake Elsinore shoreline, and that western snowy plover nested there at one time. This 

information highlights the importance of implementing a monitoring and remediation plan to determine if 

additional mitigation measures might be warranted. However, as pointed out in section 3.3.4.2, land use 

and land management practices (construction, soil disturbance, mowing, fertilizing, herbicide use, 

domestic pets) are likely to have as much or more influence on shorebird use of Lake Elsinore than 

project operations. 

Comment 151: Pacific Clay states that the final EIS should include analysis of an entirely underground 

transmission option that would avoid potential bird collisions. 

Response: The cost of an entirely underground transmission line option would be an additional $320 

million or about $10 million per mile for about 32 miles. While such an option would prevent many of 

the terrestrial resource impacts discussed in the analysis, costs would be prohibitive. 

Comment 152: The Fernandez Parties, the Center for Biological Diversity, and Pacific Clay indicate that 

the draft EIS was missing information regarding the wetlands, wildlife habitat, and rare animal and plant 

species located in the areas to be affected by the project, and as such the analysis is not adequate. 

Response: The analysis is adequate for determining the relative extent of impacts likely to occur under 

the proposed action and the staff alternative, and to compare these with the no-action alternative. Further 

detailed, site-specific analysis would be needed in finalizing the location of project facilities, including 

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access roads, in order to avoid and minimize project effects and design appropriate mitigation where 

necessary. 

Comment 153: Linda and Martin Ridenour comment that the effects of an increase in mosquito 

production at the 86 acre margin of Lake Elsinore were not addressed in the draft EIS. They question the 

co-applicants’ statements about no effect from mosquito and ask if any Vector Control has commented on 

the co-applicants’ statements. 

Response: We have added text to section 3.3.4.2 of the final EIS to clarify why we conclude that project 

operation would not affect mosquito production in Lake Elsinore. We are not aware of any Vector 

Control comments. 

Comment 154: Pacific Clay states that the cumulative effects analysis in the draft EIS for wetlands and 

riparian habitat is inadequate because it does not identify habitat locations, related actions, or quantify the 

project’s incremental effect when taken in conjunction with the effects of related actions, it does not 

analyze effects to each habitat separately, and it does not quantify the cumulative risk if the project were 

to go forwards. 

Response: We have added more specific information about project cumulative effects to wetland and 

riparian habitat the cumulative effects discussion in section 3.3.4.3. 

THREATENED AND ENDANGERED SPECIES 

Comment 155: CDFG states that the draft EIS does not address its concerns regarding steelhead trout 

and the habitat function and value of the lower San Juan Creek, as found in its October 21, 2004 letter. 

Response: As noted, the referenced letter was sent to the co-applicants only and was not filed with the 

Commission until April 2006, therefore it was not considered in the draft EIS. However, we analyzed the 

potential effects of the proposed project on steelhead in San Mateo Creek in section 3.3.5.2 of the draft 

EIS and concluded that construction at either upper reservoir location would not affect steelhead or 

steelhead habitat in San Mateo Creek. We also concluded that measures proposed by the co-applicants 

including their soil erosion control plan, water quality monitoring program at the upper reservoir, and the 

placement of transmission line poles outside of sensitive area would limit the potential for sediment 

discharge into San Mateo Creek. We concluded in section 3.3.4.2 of the draft EIS sediment transport 

several miles downstream to the perennial segments of San Juan Creek would be unlikely and that 

implementation of a drainage monitoring and remediation plan as recommended by staff and Interior 

would minimize the potential for negative effects on native fish in the lower San Juan Creek. 

Comment 156: Linda and Martin Ridenour asks if the National Marine Fisheries Service (NMFS) 

responded to the conclusion in the draft EIS that the California summer steelhead would be not adversely 

affected and requests more specific data to support this conclusion. 

Response: We conclude that the construction of the LEAPS Project may affect, but would not likely 

adversely affect the southern California summer steelhead or steelhead habitat. Only the lower 6 or 

7 miles of San Mateo Creek are accessible to southern steelhead trout and spawning occurs in the 

downstream reach during periods of significant precipitation. Steelhead trout have not been identified in 

the tributaries to San Mateo Creek that would be crossed by transmission lines. A combination of BMPs 

during construction and water quality monitoring during the life of the project would reduce, but not 

eliminate, the potential risk of adverse impacts from the downstream transport of sediments. We sent a 

letter to NMFS on February 28, 2006, requesting concurrence with our finding that the project would not 

likely adversely affect California summer steelhead and NMFS has yet to respond. 

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Comment 157: CDFG does not concur with the finding that the placement of the reservoir in Morrell 

Canyon would not have an adverse effect to steelhead trout. It states that the project would introduce 

non-native fish species to the San Juan Creek watershed and affect the water quality of the lower reaches 

of San Juan Creek from the storage of low quality Lake Elsinore water, which could adversely affect the 

ability of steelhead to utilize spawning and rearing habitat in the watershed. The introduction of lowquality water from Lake Elsinore could also affect the sustainability of the San Juan Creek as critical 

habitat. CDFG recommends the co-applicants conduct surveys for steelhead in the San Juan Creek 

consistent with CDFG and NMFS protocol, and in coordination with CDFG and NMFS, to identify the 

project effects to steelhead and the portion of the Creek that has been designated as critical habitat. 

Response: Introduction of water from the upper reservoir into San Juan Creek would only occur were 

there to be a spill event, failure of the proposed liner system, or failure of the dam structure, which are 

highly unlikely given the design of the reservoir. As stated in the draft, surveys of San Juan Creek from 

Interstate 5 east to just beyond Hot Springs Canyon did not find steelhead; however, non-native species 

were found, such as mosquitofish, green sunfish, smallmouth bass (Micopterus dolornieu), yellow 

bullhead (Ameiurus natalis), and red shiner (Cyprinella lutrensis) (FWS, undated, as cited in the Elsinore 

Valley MWD and Nevada Hydro, 2004a, exhibit E). In its final listings for steelhead, NMFS stated that it 

believes that steelhead have been extirpated from San Juan Creek, because viable habitat is extremely 

limited or no longer exists as a result of habitat degradation and they do not anticipate they will occupy 

the watershed in the future absent major restoration efforts (71 FR 834). In NMFS’ final critical habitat 

designations, San Juan Creek above the I-5 bridge, was excluded as critical habitat based on information 

provided by CDFG (70 FR 52488). We do not believe effects of project construction or operation will 

extend to the designated critical habitat portion of San Juan Creek below the Interstate 5 bridge; therefore, 

we do not recommend surveys for steelhead in that portion of the creek. 

Comment 158: The Center for Biological Diversity points out the Cleveland National Forest S10 states 

that “the future development at Elsinore Peak will be designed to avoid adverse effects to Munz’s onion.” 

It states that the construction of eleven towers would disturb nearly 3 acres of potential habitat for this 

species as well as the spread of non-native species associated with the disturbance would violate the 

standards of the Cleveland National Forest Land Management Plan. Linda and Martin Ridenour disagree 

with the draft EIS and the MBA statement that occurrences of Munz’s onion are outside the project 

boundary. They note that they observed this species during a site visit with FERC and USFS staff in 

2004. 

Response: Neither the proposed nor alternative alignments would affect known populations of Munz’s 

onion on National Forest System lands at Elsinore Peak that USFS staff pointed out during the 

September, 2004, site visit. Based on the current proposed and alternative alignments, construction of 

towers should not affect the USFS’s ability to meet its objectives under S10. However, the potential 

occurrence of this species highlights the importance of conducting site-specific surveys at each tower 

location, inside or outside the Cleveland National Forest, so that the footprint of each tower can be 

adjusted to avoid affecting this listed species, if it is present. The high risk of introducing and spreading 

non-native weed species highlights the importance of preparing and implementing plans to manage and 

monitor weeds and public access. 

Comment 159: CDFG disagrees with the conclusion that the project would have no effects on the Quino 

checkerspot butterfly (Euphydrayas editha quino). It states that because the actual alignment of the 

transmission line and its associated construction effects are unknown, the draft EIS can not determine if 

the species or its critical habitat would be affected. It recommends conducting protocol level surveys, in 

coordination with FWS, for suitable habitat along the transmission line corridor once an exact route is 

established. The Center for Biological Diversity cites the goals of the recovery plan for this species, 

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which calls for the protection and management of as much as possible of the remaining undeveloped 

suitable and restorable habitat that is part of the known and historic population distributions and states 

that the project would impede recovery. Linda and Martin Ridenour ask if the University of California at 

Riverside, as the leading experts on the Quino checkerspot butterfly, was asked to respond to the data 

filed by the co-applicants. The Ridenours states that more information is needed on the potential effects 

of the project on this species. 

Response: CDFG misunderstood our conclusions regarding the Quino checkerspot butterfly. As 

discussed in sections 3.3.5.2, 5.2.7 and 5.6.4, we found that project construction would adversely affect 

this species as a result of direct and indirect effects on habitat. We did not request expert review of the 

co-applicants’ survey results because we based our conclusions on the project’s impact on habitat for this 

species, rather than its impact on individual butterflies. We anticipate that FWS would determine whether 

project construction would impede recovery, or whether conservation measures (such as establishing and 

maintaining preferred plant species in areas where soils are disturbed as a result of construction) would 

provide adequate mitigation for project impacts. 

Comment 160: CDFG does not agree with the finding that “no critical habitat for this species [arroyo 

toad (Bufo californicus)] will be affected.” The potential discharge of sediment associated with the 

construction of the reservoir, permanent reduction in water quality to the creek, as well as the introduction 

of non-native species that prey on arroyo toad would have an effect on the species and its critical habitat. 

CDFG states that the EIS needs to address these effects and recommends consultation with FWS. Linda 

and Martin Ridenour also comment on the inadequate study of the arroyo toad habitat and request that 

USFS conduct its own study. 

Response: To our knowledge, the most current designation of critical habitat (70 FR 70, April 13, 2005) 

does not include any lands within the San Juan or San Mateo creek watersheds. We did not conduct indepth analysis of any resources in San Juan Creek, because the risk of a dam failure is very low. 

However, as indicated in section 3.3.4.2, implementation of a sediment and erosion control plan during 

construction would be important in maintaining downstream water quality, which would protect essential 

habitat for the arroyo toad. We have added text to indicate that implementation of Interior’s 

recommended drainage monitoring and remediation plan would also benefit habitat for the arroyo toad in 

San Juan Creek. To our knowledge, no arroyo toads have been observed at Decker Canyon. 

Comment 161: The Center for Biological Diversity and Linda and Martin Ridenour comment that the 

draft EIS does not address the potentially significant impact to the declining populations of the coastal 

California gnatcatcher. 

Response: Section 3.3.5.2 provides estimates of the amount of suitable habitat that would be removed 

under either of the project alternatives, and section 5.6.4 concludes the project is likely to adversely affect 

this species and adversely affect critical habitat. Section 3.3.5.3, though brief, points out that the project 

would contribute to cumulative adverse effects on this species. In light of the significance of this impact, 

we are recommending that the co-applicants consult with FWS regarding protection, mitigation and 

enhancement measures as project designs are being developed. Because the coastal California 

gnatcatcher is so closely linked to coastal sage scrub habitat at lower elevations, loss of chaparral and oak 

woodlands at the Decker Canyon site should not affect this species. 

Comment 162: Linda and Martin Ridenour comment that MBA did an inadequate job by ignoring areas 

where the California red-legged frog is located. They ask for information on the dates of the surveys 

conducted by MBA for the Southwestern willow flycatcher, noting that table 16 in the draft EIS only tells 

the reader the number of visits but not the dates of the surveys. They also comment that they did not read 

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any information in the draft EIS about potential effects of helicopter use during construction on this 

species and recommend that helicopters not be allowed during the breeding and nesting seasons. 

Response: Red-legged frog surveys were conducted only in areas that might provide habitat for this 

species; we are not aware that MBA overlooked any areas that should have been surveyed. The 

completed survey reports for each species for each year of survey are available to the public on eLibrary 

(www.ferc.gov) using the “eLibrary” link. For assistance, contact FERC Online Support at 

FERCOnlineSupport@ferc.gov or toll-free at (866) 208-3676, or for TTY, (202) 502-8659. The 

description given in section 3.3.5.1 regarding the location of critical habitat is meant only to indicate that 

it is not immediately adjacent to the project, and that no project features would be constructed within it. 

We anticipate that the need for timing restrictions would be addressed through consultation with USFS, 

FWS and CDFG on final designs. 

Comment 163: Linda and Martin Ridenour ask how many pairs of Least Bell's vireos were found during 

the surveys and ask that USFS conduct its own study of this species in the project: 

Response: As indicated in section 3.3.5.2, MBA did not observe any least Bell’s vireos during its 

surveys. 

Comment 164: The Center for Biological Diversity states that the draft EIS does not address the 50 acres 

of Stephens’ kangaroo rat habitat that would be eliminated but not mitigated outside of the Stephens’ 

Kangaroo Rat HCP area. It again states that the draft EIS cannot analyze effects to any species without 

population or locational data. 

Response: We have added text to section 3.3.5.2 to clarify anticipated project effects on the Stephens’ 

kangaroo rat. Based on information in the Multi-Species HCP, there are no reliable data on Stephens’ 

kangaroo rat populations in the vicinity. CDFG’s recent report on special status species indicates the 

Stephens’ kangaroo rat’s status is unknown. 

Comment 165: The Center for Biological Diversity states that the draft EIS is wholly deficient in its 

analysis of the proposed project’s impact on listed species because it fails to provide population and 

abundance data either on the project site or region. 

Response: We have added information, where available, about populations in the region; however, 

MBA’s surveys did not reveal the presence of any federally listed wildlife species in the project area. 

Comment 166: The Center for Biological Diversity comments that the draft EIS needs to disclose what 

actions would be taken if new populations of listed species are identified and what remedial actions would 

be taken to prevent or minimize loss of fish or wildlife. It also states that Interior’s recommendation no. 2 

is not properly described in section 5 of the draft EIS. 

Response: We have added text in section 5.2.7 to clarify that the staff alternative includes provisions for 

implementation of protective measures, if monitoring indicates they are needed. This approach is 

consistent with the USFS revised preliminary 4(e) condition no. 38 (see appendix C for full text). We 

have included all the information Interior provided about its 10(a) recommendation no. 2 and Interior did 

not take issue with our characterization of its recommendations in its letter commenting on the draft EIS. 

Comment 167: Pacific Clay states that the cumulative effects analysis in the draft EIS for federally listed 

species is inadequate because it does not define the range in southern California for each relevant species, 

fails to identify past, present, and reasonably foreseeable future actions that might affect each species in 

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its range, fails to identify the project’s incremental effect to each species when evaluated in conjunction 

with the related actions, and fails to evaluate the risks of adverse cumulative affects to each species.

Response: We respectfully disagree and note that we did address cumulative affects to the listed species 

in the draft EIS. However, in the final EIS we now provide information on the cumulative effects to 

listed species on a species-by-species basis. 

RECREATIONAL RESOURCES 

Comment 168: The city of Lake Elsinore and Peter Dawson state that any construction-related 

drawdown of Lake Elsinore below 1,240 feet msl would have substantial negative affects on recreational 

use because the Seaport Boat Launch facility and the inlet channel “event” concession are not functional 

below that elevation. They state that any drawdown below that elevation should be prohibited or a 

mitigation plan should be developed to mitigate for the effects. John Pecora is concerned the fluctuating 

water levels of Lake Elsinore would prohibit the launch of his boat from its present storage location. 

Empire Pre-Cast is concerned that the shoreline would be useless when water elevations are down. Peter 

Dawson comments that the PRINCESS, a 94 foot paddlewheeler currently being refurbished, would not 

be able to operate at an elevation below 1,240 feet msl. The Santa Ana Water Board, the State Water 

Board, and Pacific Clay state that the draft EIS did not address the effects on recreational boating from 

the project-caused shoreline fluctuations and requests that the final EIS discuss this issue. 

Response: The construction and operation of the proposed project would not draw down Lake Elsinore 

below the minimum target elevation of 1,240 feet msl. The co-applicants propose to perform all in-lake 

construction, including the intake/outlet structure, behind a cofferdam and would not drawdown the lake 

below 1,240 feet msl. The project would operate between 1,240 and 1,247 feet msl consistent with the 

Lake Level Stabilization and Enhancement Project, and would not be able to operate if water levels fell 

below 1,240 feet msl. We conclude in section 3.3.6.2 of the EIS that because the project would not 

operate below 1, 240 feet msl, project-related fluctuation in water elevations would not adversely affect 

existing recreational boating facilities at Lake Elsinore. 

Comment 169: The city of Lake Elsinore states that the estimated 6 acres or 0.5 percent loss of Lake 

Elsinore’s surface acreage from the construction of the tailrace tunnels is a mischaracterization of the true 

negative effect on the boating traffic pattern. The City estimates that approximately 20 percent of the lake 

would be affected and a detailed assessment and mitigation plan for the loss of recreational use by the 

proposed navigational restrictions should be performed to determine the affect of boating capacity and 

traffic pattern. 

Response: We respectfully disagree. We calculated 6 acres by multiplying two-thirds of the length of 

the tailrace tunnel (the length that would be in Lake Elsinore and thus would affect boating) by 200 feet 

and converting to acres. 

Comment 170: To assist the city of Lake Elsinore in carrying out its mandatory police powers on Lake 

Elsinore, the city recommends the co-applicants develop and fund implementation of a Boating Traffic 

Plan prior to construction to ensure public safety. The city recommends that it review and approve the 

plan prior to implementation. 

Response: To protect public safety during construction, the co-applicants propose detailed site plans that 

identify contingencies for restricting public access to certain areas, such as near construction activities in 

the lower reservoir including boating. Therefore, we do not see the need for a separate boating traffic 

plan. 

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Comment 171: The city of Lake Elsinore recommends the co-applicants be required to perform an 

aquatic safety study to consider the public safety element on Lake Elsinore from operations of the project. 

Response: If licensed, the licensee would be required by the Commission’s regulations to prepare a 

public safety plan that would detail the location of safety signage and buoys and any other safety 

measures designed to protect the public using Lake Elsinore or other project facilities. 

Comment 172: The city of Lake Elsinore recommends that the co-applicants provide annual employee 

orientation on the projects to all city employees, local law enforcement, fire department staff, and 

commercial boating facilities on the lake. 

Response: The co-applicants, as one of their environmental measures, propose to provide tours of the 

generating facilities. As needed, local public safety agency personnel could tour facilities and ask 

questions about public safety obligations.

Comment 173: Linda and Martin Ridenour disagree that the fish stocking program would improve 

angling and state that anglers would have to wade out 95 feet (during drawdowns) to be able cast. As 

mitigation, they recommend a walkway with a non-slip surface, preferably located at Perret Park, wide 

enough for 10 anglers and their gear. 

Response: The fish stocking program would not only improve angling from the shore but also from the 

water as angling occurs from both the shore and on the water. Before the implementation of the Lake 

Level Stabilization and Enhancement Project, changes in lake level elevations resulted in fluctuations of 

more than 95 feet. The proposed project supports the Lake Level Stabilization and Enhancement Project, 

would reduce overall effects to fishermen who wade out into Lake Elsinore as lake levels would be higher 

than, and fluctuate within a narrower range than historical levels. Therefore we do not find that the 

provision of a walkway for fisherman is warranted. 

Comment 174: Riverside County recommends the co-applicants develop and fund the operation and 

maintenance costs for a 30-acre sports park to meet local recreation needs. 

Response: Based on comments received on the draft EIS, the co-applicants now propose to provide a 

developed turn-key park facility, which could include sports fields, at the proposed powerhouse 

construction lay down locations to either the city of Lake Elsinore or Riverside County. The coapplicants propose to retain ownership and responsibility for O&M activities subject to a determination 

whether such ownership and operation would be authorized under the Elsinore Valley MWD’s existing 

special district authority for developments not in public ownership and not located on National Forest 

System lands. 

Comment 175: Riverside County states that the co-applicants should be required to secure, renovate, and 

fund a lakeside park facility on 10 to 15 acres on Grand Avenue, on the Naval Academy site if available. 

Response: We have analyzed the potential effects of the proposed project on recreational opportunities 

in the project vicinity and conclude that the co-applicants proposed recreational facilities at the Santa 

Rosa powerhouse construction lay-down area would provide a new recreational experience. There is no 

evidence that the existing public access to Lake Elsinore is inadequate and therefore we do not include an 

additional lake side park facility in the staff alternative. 

Comment 176: Jay Scott and other individuals protest the finding in the draft EIS that development of a 

formal landing site at Ortega Oaks would benefit hang gliders as there would still be interference from 

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transmission lines, substations, fencing, and other structures that would cause air disturbance of normal 

wind conditions. 

Response: The revised co-applicants’ proposal and staff alternative transmission alignment to place the 

transmission lines underground in the vicinity of the launch sites and from the north/south transmission 

line to the Santa Rosa powerhouse and not the Ortega Oaks powerhouse site would be greatly reduce 

interference with hang gliding activities over the alignments included in the draft EIS. We have revised 

the text in section 3.3.6 Recreational Resources of the EIS relative to the co-applicants’ proposal. While 

we agree that a formal landing site at Ortega Oak would benefit hang gliders, we no longer include this 

measure in the staff alternative because we now include the Santa Rosa powerhouse location. 

Comment 177: Nevada Hydro comments that the co-applicants’ initial assessment of impacts on the 

existing Morgan Trail was based on plotting the trail on USGS topographic maps. USFS subsequently 

provided the co-applicants with additional information identifying the as-built routing of the trail, which 

differed considerably from the initial presentation. Based on the updated information, the co-applicants 

agree that the proposed Morrell Canyon upper reservoir would necessitate both the temporary closure and 

permanent re-routing of a portion of the trail should the Morrell Canyon site be selected. 

Response: We have clarified the text in the final EIS to disclose that the proposed Morrell Canyon 

reservoir would require the relocation of the Morgan Trail. 

Comment 178: The Center for Biological Diversity comments that the draft EIS should not characterize 

the Morgan trail use as “low” in the absence of any user studies. It also points out that the map showing 

trail seems to follow an old ridge route rather than the current trail, which rapidly descends into the 

riparian oak woodland of upper Morrell Canyon. David Voss questions the use of USFS staff 

observations of the number of vehicles parked at the trailhead as a basis for determining usage of Morgan 

Trail. He comments that users typically carpool and that just counting vehicles underestimates the usage. 

Linda and Martin Ridenour also disagree with the use characterization of Morgan Trail in the draft EIS 

and question the lack of information on the effects of the proposed project on the other three trailheads 

within the Cleveland National Forest. They disagree with statement in the draft EIS that there are no 

developed recreational sites in Decker Canyon and ask the USFS to respond that there is a trail system 

located there. 

Response: We agree that in the absence of user studies the exact level of use is unattainable; however, 

we have based our characterization of use on communications with USFS staff who are responsible for 

managing the resource. The presence of 2 to 3 vehicles on a peak use weekend, even if full of passengers, 

would comprise only 15 hikers and represent 20 percent of the parking lots capacity. Non-peak weekends 

and weekdays would receive even less use, supporting our characterization as “low,” especially when the 

forest received more than 31,000 visits to the wilderness alone. We have modified the map to show the 

current location of Morgan Trail, which is consistent with the effects analysis. As for Decker Canyon, 

there are no system trails maintained by the Cleveland National Forest in Decker Canyon. 

Comment 179: Pacific Clay and Linda and Martin Ridenour criticize the recreational resource analysis 

because it understates the effects of the project on trail destruction, public access to the Cleveland 

National Forest, disturbance of developed recreation sites, inconsistency with the USFS Land 

Management Plan’s designations, and inadequate figures. 

Response: We respectfully disagree. The draft EIS discloses the effects of the proposed project on 

existing trails, recreational use in the Cleveland National Forest, and affects on existing developed 

recreational facilities in section 3.3.6.2, and disclose inconsistencies with the Cleveland National Forest 

Land Management Plan in section 3.3.7.2. We have clarified the text in section 3.3.6.2 of the final EIS 

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that construction of the Morrell Canyon Reservoir alternative would require the relocation of portions the 

Morgan Trail. Also, placing the transmission line underground in the vicinity of the hang gliding launch 

sites would affect use of the Morgan Trailhead for about a year during the construction of the 

transmission line. Access to the Cleveland National Forest in the general vicinity of construction would 

not be precluded; however, the recreational experience along forest access routes near proposed project 

facilities (reservoir, transmission lines, support towers) would be adversely affected. 

Comment 180: Linda and Martin Ridenour comment that if an upper reservoir were built then it should 

be open to the public as a water resource and should not be enclosed behind a chain link fence. In 

addition, they state that a day-use recreation facility should be located at the upper reservoir site as 

mitigation for losing use of Decker Canyon. 

Response: We conclude that the co-applicants’ proposal to fence the upper reservoir is reasonable given 

that the surface elevation of the upper reservoir would fluctuate over 50 vertical feet during the day. 

Instead, the co-applicants propose to develop a recreation facility either at the upper reservoir 

construction laydown area or at an alternative location as may be approved by the USFS. 

Comment 181: The County of Orange requests the co-applicants work with the Cleveland National 

Forest staff to ensure that the Main Divide Road is kept open during project construction and restored to 

its original condition, or better, as part of project completion. 

Response: Construction of the proposed upper reservoir and buried transmission line would require work 

to be performed in close proximity to South Main Divide Road and rely on the road network to deliver 

construction related equipment and materials. Because homeowners who live in the area also rely on the 

road, it would be open for the duration of project construction. The co-applicants propose to prepare a 

traffic management plan that would include controls to traffic flow in and around project construction. 

The co-applicants also propose to maintain or rehabilitate the road to pre-project construction conditions. 

Furthermore, USFS preliminary 4(e) condition no. 13 specifies that the co-applicants provide a “safety 

during project construction plan” to identify potential hazards near public roads, trails, and recreational 

facilities, and measures necessary to protect public safety. Implementation of this measure should address 

the County of Orange’s concerns. 

Comment 182: Nevada Hydro states that the draft EIS mischaracterizes the nature of Lion Spring by 

describing that feature as a “cluster of natural springs” (on page 3-33). Further, Nevada Hydro is unaware 

of the existence of “Lion Spring Trail.” Finally, Nevada Hydro questions the statement “this type of 

setting is not abundant in the general area” on page 3-202 when there are 35,330 acres of oak woodlands 

with the Multi-Species HCP study area and three large clusters in the Cleveland National Forest from the 

Santa Ana Mountains near Glen Ivy south toward San Mateo Canyon (Riverside County, 2003, page IIC94). 

Response: In section 3.3.6.2 of the draft EIS we describe Lion Spring as a location where a complex of 

seeps rise through subsurface fractures on the east side of Morrell Canyon, consistent with the description 

in MBA 2006. We revised the description in the water quality section of the final EIS to be consistent. 

We agree that there is no Lion Spring Trail and have revised the text in section 3.3.6.2 to refer to Morgan 

Trail. The 35,330 acres of oak woodlands within the Plan Area account for less than 3 percent of the 

existing vegetative cover, a fact that supports our description of the oak woodlands as “not abundant.” 

More importantly, coast live oak woodlands, such as those that occur at Morrell and Decker canyons, 

account for only 6,660 acres of the Plan Area, or 0.5 percent of the existing vegetative cover. 

Comment 183: Elsinore Hang Gliding Association comments that there are no specific measures for 

dispersed recreation. The project as proposed by the co-applicants could affect dispersed recreational use 

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at the wilderness area, hang gliding launch sites, Morgan Trail, powerhouse site, and hang gliding flight 

paths and landing areas. 

Response: We analyzed the potential effects of the proposed project on dispersed recreation in section 

3.3.6.2 of the EIS and conclude that there would be a temporary disruption to use of the Morgan Trail and 

hang gliding for about one year during construction of the project. The staff alternative includes 

reasonable measures to ensure the safe public use of existing the dispersed recreational opportunities in 

Cleveland National Forest during the construction of the upper reservoir and placement of the 

transmission towers. 

Comment 184: Nevada Hydro comments that none of the studies conducted by the co-applicants have 

identified or suggested the potential likelihood of any micro-meteorological impacts on air currents or 

thermals associated with the construction of the upper reservoir and, therefore, disagree with the 

statement on page 3-202 of the draft EIS that the construction of a reservoir in Morrell Canyon would 

eliminate a series (over 3) of known house thermals along the ridge to the southwest of Morrell Canyon. 

Response: We agree that the construction of a reservoir with a 100 acre surface area would not affect air 

currents in the project area. However, the footprint of the upper reservoir in Morrell Canyon covers the 

originating location of several house thermals and therefore would eliminate them as known locations of 

thermals. 

Comment 185: Jay Scott and other individuals state the draft EIS is incorrect in reporting that hang 

gliders launch from nine various points along South Main Divide Road in the vicinity of the proposed 

Morrell Canyon upper reservoir site and indicate that they know of only two authorized launch sites 

(Edwards and E) in the Cleveland National Forest. 

Response: We have modified the text in the final EIS accordingly. 

Comment 186: Jay Scott and other individuals state that the staff transmission alignment would be 

hazardous to hang glider pilots because of the close proximity of the switch yard and buildings to the 

landing area. They state that placing the power lines underground or placing the overhead lines at least 

one mile from the two authorized launch sites and the landing area would put hang gliders at an 

acceptable risk that would most likely not result in loss of life. They also comment the current reference 

to parasailing should be changed to paragliding as parasailing occurs on waterbodies. 

Response: We have reconsidered the transmission alignment and now include a staff alternative 

transmission alignment in the final EIS that places the transmission lines underground in the vicinity of 

the hang gliding launch. We also now include the Santa Rosa powerhouse location in the staff alternative 

which eliminates the construction of an above ground substation and transmission lines in the vicinity of 

the landing area at Ortega Oaks. Under both the co-applicants’ proposed and staff alternative 

transmission alignments, there would no longer be any above ground transmission lines between the 

launch areas and the landing site at Ortega Oaks. We have deleted references to parasailing in the final 

EIS. 

Comment 187: Francis Hoffman, on behalf of the Elsinore Testing of Experimental Aircraft Mechanism, 

states that the comment on page 3-184 of the draft EIS that successful launches occur about 75 percent of 

the time is inaccurate and further suggests that the USFS should be collecting statistics on hang gliding 

activities in the Cleveland National Forest. 

Response: We discussed hang gliding use in general with Mr. Charles Mackin of Infrastructure 

Solutions, a local business that services the hang gliding industry. He indicated that about 75 percent of 

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the pilots taking off at the launch sites travel east and then west and find thermals that support them. Mr. 

Mackin indicated on a typical day with 50 pilots launching from the E site 10 may head cross country, 25 

would find sufficient thermals and stay above the mountains for a number of hours and land at the landing 

zone while others, unsuccessful in finding adequate thermals would ‘sled’ to the landing site. He 

indicated that these were estimates based on his knowledge of practice in the area. 

Comment 188: Bret Daniel, Rancho Capistrano Property Owners Association, and other individuals 

comment that the hang gliding safety mitigation measures proposed in the draft EIS are “vastly 

inadequate.” In particular they are concerned that adding power lines either in front or behind the South 

Main Divide Road will create a major hazard for recreational flight in this area. They also comment that 

this area is a destination for pilots from all over the world and the project will compromise not only his 

safety but the safety of other local pilots. Francis Hoffman, on behalf of the Elsinore Testing of 

Experimental Aircraft Mechanism, and Pacific Clay state that the mid-slope alignment will cause an 

unacceptable risk of death to hang gliders. Jay Scott and other individuals request that the Commission 

prohibit new overhead power lines within one mile of the two authorized hang glider launches (Edwards 

and E) located in the Cleveland National Forest or within one mile of the landing zone located on parcel 

386120029 in Riverside County. In support of this request, they cite the draft EIS for the Agua Fria 

National Monument/Bradshaw-Harquahala Planning Areas issued by National Park Service that includes 

an alternative to prohibit new overhead power lines, phone lines, or communication facilities within one 

mile of launching and landing zones in the general project area that hang gliding commonly takes place. 

The city of Lake Elsinore also states its concern for hang-glider safety with the staff alternative 

transmission alignment and request than an underground transmission line in certain locations be 

evaluated. 

Response: We have reconsidered the transmission alignment and now include a staff alternative 

transmission alignment in the final EIS that places the transmission lines underground in the vicinity of 

the hang gliding launch sites. We also now include the Santa Rosa powerhouse location in the staff 

alternative which eliminates the construction of an above ground substation and transmission lines in the 

vicinity of the landing area at Ortega Oaks. Under both the co-applicants’ proposed and staff alternative 

transmission alignments, there were no longer be any above ground transmission lines between the launch 

areas and the landing site at Ortega Oaks. 

Comment 189: Riverside County states that the final EIS should describe the types of improvements that 

would occur at the top or bottom of the hill to meet the needs of hang gliders. 

Response: Both the co-applicants proposed and staff alternative transmission alignments would bury the 

line in the vicinity of the USFS permitted hang gliding launch sites and significantly reduce conflicts with 

hang gliding activities. The staff alternative no longer includes a powerhouse and substation at the Ortega 

Oaks sites and eliminates conflicts with the existing informal landing site at Ortega Oaks. The staff 

alternative does not include any other measures to enhance hang gliding activities. 

Comment 190: Lake Elsinore Soaring Club indicates the placement of transmission lines and towers 

anywhere along the crest or northeast facing slop of the Ortega Mountains between Clinton-Keith Road 

and Santiago Peak would make gliding (different than hang gliding in that pilots are in an enclosed, 

lightweight, powerless aircraft) much more dangerous and even deadly. It recommends the relocation of 

the transmission lines to the southwest side of the Ortega Mountains. 

Response: According to the Soaring Club, the sport of gliding uses the lift winds rushing into the east 

side of the mountains near Lake Elsinore as hang gliders rush up and over the mountains, analogous to 

pelicans flying along ocean waves, typically flying near the ridgeline. Based on comments received on 

the draft EIS, we reconsidered the transmission alignment and now include a staff alternative transmission 

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alignment in the final EIS that places the transmission lines further west away from the crest or northeast 

facing slope of the Ortega Mountains and also includes an underground portion in the vicinity of the hang 

gliding launch and landing sites. 

LAND USE AND AESTHETICS RESOURCES 

Comment 191: Riverside County states that the lack of specificity in the draft EIS makes it impossible 

to determine what effects would result from the daily lowering of the surface level of Lake Elsinore. It 

states a more detailed study of the lake shore and properties that adjoin it is needed to ensure that property 

values, land uses, and access points are protected. The city of Lake Elsinore states that the co-applicants 

should be required to acquire undeveloped shoreline property that lies below 1,263.3 feet msl to reduce 

effects on private property owners and then should be used for development of public recreation and 

environmental habitat preservation.

Response: As described on pages 3-50 through 3-56 of the draft EIS, project operations would reduce 

seasonal lake level fluctuations compared to the natural pattern and would maintain the lake level 

between 1,240 and 1,249 feet msl (revised in the final EIS to 1,240 to 1,247 feet msl). However, project 

operations would introduce a daily fluctuation that does not currently occur. This would be similar to 

beach property where the tide goes in and out over the course of a day resulting in shoreline migration 

from 8 feet to over 100 feet. Because this daily and weekly shift in shoreline would be less than the 

shoreline migration experienced during dry years, we do not see the need to do a more detailed study of 

the potential effects on lake shore properties, nor do we see the need for the co-applicants to acquire this 

undeveloped shoreline property. The lake is already managed by other parties to the 1,263 elevation. 

Comment 192: Riverside County comments that a major portion of the proposed project is located 

within the Riverside County Flood Control and Water Conservation District’s (Flood Control District’s) 

preliminary Lakeland Village Master Drainage Plan (MDP) boundary and the proposed alignment for the 

powerhouse and the inlet/outlet structure may be in potential conflict with one of its proposed facilities. 

Although the powerhouse is likely to be constructed underground and therefore, would most likely not 

affect the facility, the issue of right-of-way and easement for future operation and maintenance of the 

MDP facility needs to be addressed in the draft EIS. Additionally, it states that the intake/outlet structure 

may be in potential conflict with one of its proposed drainage facility outlets downstream of the 

intersection of Grand Avenue and Adelfa Street into Lake Elsinore. Riverside County states that the draft 

EIS should address potential effects on the proposed MDP facilities in the project area. 

Response: We have revised the text of section 3.3.7.2, Environmental Consequences, Effects of 

Construction and Operation on Infrastructure, to include the information about the MDP provided by 

Riverside County and conclude that consultation with the Flood Control District would address both 

existing and proposed Flood Control District facilities. 

Comment 193: Riverside County states that the project would have a cumulative adverse effect on the 

Fire Department’s ability to provide an acceptable level of service. They recommend the following 

mitigation measures: (1) participate in the Fire Protection Impact Mitigation Program; (2) prepare a 

traffic management plan to be reviewed by the County Fire Department; (3) all buildings located in 

Riverside County would be required to have an approved access and be constructed in accordance with 

Riverside County Ordinance Nos. 460 and/or 787, subject to review and approval by the Riverside 

County Fire Department; (4) all water mains and fire hydrants providing fire flows should be constructed 

in accordance with the appropriate sections of the Riverside County ordinance and be subject to review 

and approval by the Riverside County Fire Department; (5) any buildings constructed within the 

“Hazardous Fire Area” of Riverside County should comply with the special construction provisions 

contained in Riverside County Ordinance 787 and subject to approval by the Riverside County Fire 

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Department; and, (6) prior to approval of any development plan for lands adjacent to open space areas, a 

fire protection/vegetation management (fuel modification) plan should be submitted to the Riverside 

County Fire Department for review and approval. 

Response: As discussed on page 5-37 of the draft EIS, the staff recommends that the co-applicants 

prepare and file a road and traffic management plan for non USFS roads. This plan would be developed 

in consultation with Riverside County and the city of Lake Elsinore. The co-applicants have indicated 

that they will comply will all applicable local and county ordinance during the construction and operation 

of the project. 

Comment 194: The Lake Elsinore Unified School District and Pacific Clay indicate that the draft EIS 

does not discuss the potential effects of project construction on the Butterfield Elementary School on 

Grand Avenue. According to the Lake Elsinore Unified School District, the school would be inoperable 

for several years under the co-applicants’ proposal because of construction activities and the resulting 

noise levels directly adjacent to the school. Additionally, Lake Elsinore Unified School District states 

that the electromagnetic fields (EMFs) resulting from the powerhouse and transmission lines may be too 

large a risk to the students and teachers, which would require permanently closing the school and building 

a costly new school in an another location. The Lake Elsinore Unified School District would like to see 

these effects evaluated in the final EIS along with appropriate mitigation measures.

Response: The effects analysis on page 3-305 of the draft EIS, Effects of Construction on Noise,

discloses the proximity of the Butterfield School to the proposed Santa Rosa powerhouse site and 

evaluates the worst case scenario for noise levels, concluding that because the majority of the loudest 

work would occur underground, noise effects would be less than significant and would be within the 

Riverside County and city of Lake Elsinore’s regulations. The effects of operation on EMF is discussed 

on page 3-250 of the draft EIS, and concludes that there would be no adverse EMF effects at the school. 

Furthermore, based on comments received on the draft EIS, we have evaluated the scenario of placing the 

transmission lines underground, thereby diminishing the EMF concerns raised by the District and by 

Pacific Clay. 

Comment 195: Anna Lee states that construction of a powerhouse at the Evergreen Site would lower the 

value of her retirement properties on Evergreen Street (primary residence) and Garner Road (income 

property). 

Response: Given that the majority of the powerhouse would be underground and that the property would 

be landscaped into a park-like setting, we conclude that the powerhouse would not be likely to adversely 

affect nearby property values except perhaps temporarily, during construction. The co-applicants’ 

proposed acquisition of properties nearest the powerhouse site would help reduce the effects of 

construction on those living closest to the site. The aboveground substation could adversely affect nearby 

property values, as described on page 3-269 of the draft EIS. 

Comment 196: The Lakeland Village/Wildomar Redevelopment Project Area Committee comments that 

both the proposed and staff alternatives would place a hydroelectric plant adjacent to the redevelopment 

project area. It states that the draft EIS does not mention the redevelopment project area or address how 

construction and operation of the proposed project would affect its mission of redevelopment. It 

expresses concern about traffic during construction on Grand Avenue, the condition of pavement and 

shoreline staging areas after construction, fluctuating water levels on the appeal of Perret Park, the effect 

on property values, and the potential for inundation of its project area should there be a dam break at the 

upper reservoir. It sees no acceptable mitigation relative to these concerns. Linda and Martin Ridenour 

also request information on the effects of project-induced fluctuation on the use of Perret Park. 

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Response: Construction and operation of the project would affect the redevelopment area in the same 

way that it would affect the land uses and property owners, which we discuss in the draft EIS on pages 3-

227 through 3-233 and pages 3-268 through 3-273. We discuss effects on traffic and pavement on pages 

3-251 through 3-259 of the draft EIS, and discuss the risks associated with a dam break on pages 3-29 

through 3-33. With respect to effects on property values, the fact that the majority of the powerhouse 

would be underground and that the property would be landscaped into a park-like setting leads us to 

conclude that the facility would not be likely to adversely affect the redevelopment project area or 

property values except perhaps temporarily, during construction. The aboveground substation could 

adversely affect nearby property values, as described on page 3-269 of the draft EIS. 

Perret Park is a county-owned park along the southwestern shore of Lake Elsinore in Lakeland Village. 

Riverside County closed the park in 1999, but has since reopened the park with renovations. We are not 

aware of any renovations that included the development of beaches at the park. As such, we maintain that 

the only developed recreational facilities on Lake Elsinore that would potentially be directly affected by 

project operations would be boat docks, as stated on page 3-198 of the draft EIS. 

Comment 197: Linda and Martin Ridenour state that figure 17 in the draft EIS shows their home within 

the Cleveland National Forest boundary, and they request clarification of this information. They also 

state that figure 18 is inadequate because it does not show adjacent properties. They state that residents 

need to know the location of their properties relative to the proposed project facilities including the 

construction lay-down areas and the water flow pipes. 

Response: Figure 18 shows the jurisdictional boundary of the Cleveland National Forest, as shown on 

official USFS maps (USFS, 1994). However, the USFS does not have jurisdiction over private lands (inholdings) within the boundary. The Commission issued a public notice describing the revised coapplicants’ proposed transmission alignment and the revised staff alternative transmission alignment to all 

affected property owners (within 0.25 mile) on October 3, 2006. This notice included the identifying 

numbers of all parcels located within 0.25 mile of both transmission alignments and the proposed Santa 

Rosa powerhouse location such that property owners could determine if their lands would be affected by 

the proposed project. The Commission afforded affected property owners an opportunity to submit 

additional comments at that time, and this final EIS reflects our assessment of the additional comments 

that were submitted. 

Comment 198: Edwin Thorell questions whether the reference to Canadian studies on the effects of 

transmission lines on property value is relevant to California and suggests that the USFS should engage in 

land swaps with displaced landowners to provide the landowners with property in the same rural 

condition of their current land. 

Response: The effect of any project on property values is a function of the particular circumstances of 

the project, the affected properties, and the real estate market at large. However, potential effects can be 

estimated based on the experiences of similar projects. In that respect, the Canadian studies are just as 

relevant as other studies, which together suggest that transmission line effects on property values are not 

as significant as property owners generally expect. Any landowners whose land would be used for 

project facilities would be compensated by the co-applicants for their land. 

Comment 199: Pacific Clay states that the staff alternative transmission alignment would run directly 

through its multi-million dollar brick making kilns and brick storage facilities, which would affect and 

likely destroy the entire manufacturing area. Pacific Clay states that it is being asked to bear a 

disproportionate economic burden because it, along with affiliated companies, has large-scale commercial 

and residential development plans that would be affected either directly or indirectly by the route of the 

transmission line. It estimates the potential economic damage to itself would be in excess of 

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$150,000,000. It further states that the two northerly proposed alignments would result in a more equal 

distribution of the economic damage, and it would not consent to the use of or voluntarily convey any of 

its property holdings for the advancement of the proposed project. Nevada Hydro comments that 

placement of towers on Pacific Clay property could be problematic since mining operations create a 

changing landscape that would prevent the placement of towers within the actively mined area. Nevada 

Hydro notes that the resources present at Pacific Clay are designated as a mineral resource zone and are of 

regional and statewide significance. The city of Lake Elsinore also states that transmission alignment 

alternative no. 2 presents an unnecessary incursion into a soon to be developed area of Lake Elsinore and 

would adversely affect this new community while providing few off-setting benefits. It further states that 

although it generally supports the proposed mid-slope alignment, the northern segment should follow the 

alignment proposed by the co-applicants to begin at the existing SCE substation to the proposed northern 

substation and then running along the Cleveland National Forest border. 

Response: We have reconsidered the staff alternative transmission alignment and now recommend an 

alignment that coincides with the co-applicants’ proposed alignment in areas outside of the Cleveland 

National Forest (to the north and to the south of the Forest). Pacific Clay lands and areas in the city of 

Elsinore targeted for future development would no longer be traversed or be adjacent to the co-applicants' 

proposed or staff alternative transmission alignment. 

Comment 200: Nevada Hydro disagrees with the statement in the draft EIS on page 3-229 that the 

northern and southern segments of the proposed transmission line are located on undeveloped lands and 

no homes or buildings would need to be razed or moved to accommodate construction along the proposed 

transmission alignment. Nevada Hydro states that as proposed the co-applicants’ transmission alignment 

traverses a limited number of forest in-holdings upon which easements or other rights-of-way would be 

required and that a limited number of existing residences could be displaced. Nevada Hydro also 

comments that the mid-slope alignment would adversely affect more private property than the coapplicants’ proposal. 

Response: We have revised the text of section 3.3.7.2, Environmental Consequences, Effects of 

Construction on Change of Land Use, to reflect the fact that some residences could be displaced by the 

co-applicants’ proposal and by the staff alternative transmission alignments, both of which have been 

modified since the draft EIS was published. 

Comment 201: Rancho Capistrano Property Owners Association and Jon R. Johnson note that safety 

recommendations during fires prohibit people from being within 100 to 500 feet of transmission lines. 

Because much of the proposed transmission line route would be within 100-500 feet community escape 

route, it would be safety hazard during brush fires. 

Response: Both the proposed and staff alternative transmission alignments now include underground 

segments that eliminate the conflict between the transmission line routes and the community escape route 

for Rancho Capistrano residents. 

Comment 202: Rancho Capistrano Property Owners Association, Jon R. Johnson, and Andrew and 

Sandra Mauthe note the proposed and staff alternative transmission lines would interfere with the ability 

for fire crews to fight fires from the air. 

Response: The USFS’ number one priority in firefighting is public and firefighter safety. The USFS 

does not place aircraft, crews, engines or fire fighting equipment in fire areas unless the agency can 

provide for their utmost safety. Smoke consists of carbon particles, which can conduct electricity. If the 

concentration of carbon is high enough, an electrical discharge from the line to the ground, similar to 

lightning, can occur. The discharge hazard increases as line voltage increases, distance to the ground 

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decreases, and the amount of smoke increases. High power transmission lines are just one of several 

safety considerations that need to be addressed in fire suppression. Based on the history of fire 

suppression in southern California, the presence of transmission lines would interfere with aerial fire 

suppression operations. Placing the line underground along South Main Divide Road in the vicinity of 

the two USFS permitted hang gliding launch sites to a point south of the egress road to Rancho 

Capistrano and along the connection to the Santa Rosa powerhouse as currently proposed by the coapplicants and recommended by the staff would reduce interference with fire suppression activities in 

these locations. 

Comment 203: The Fernandez Parties, Rancho Capistrano Property Owners Association, La Cresta 

Property Owners Association, and Lynice Spangler state that the draft EIS does not adequately identify 

and mitigate for the potential fire hazard created by the transmission lines near their property. La Cresta 

Property Owners Association recommends if the transmission lines are built, the co-applicants be required 

to build alternate evacuation routes for residents of the Santa Rosa Plateau communities. 

Response: The staff recommended alternative includes several measures that would address your 

concerns about safe egress from Santa Rosa Plateau communities in areas prone to wildfires. Should the 

proposed project be licensed, the co-applicants would be required to provide the USFS with a hazardous 

vegetative fuel treatment plan and the USFS and the city of Lake Elsinore with road and traffic 

management plans for both USFS and non-USFS roads. 

Comment 204: The Fernandez Parties indicate that there is a private airport located on the property 

directly adjacent and south of their property that would not be usable if the transmission lines were built 

above ground in that location. They state that the State Aeronautics Act prohibits the building of 

structures such as transmission lines in the vicinity of an airport and require permits for all other 

structures that may obstruct air navigation in the vicinity of an airport. 

Response: We have revised the text of section 3.3.7.1, Affected Environment, Land Use Within and 

Adjacent to the Project Boundary to correctly describe the airstrip and have revised section 3.3.7.2, 

Environmental Consequences, Effects of Construction on Change of Land Use, to conclude the coapplicants’ proposed or staff alternative transmission alignment would be located within 3,000 feet of the 

private airstrip and could render the private airstrip unusable. 

Comment 205: Nevada Hydro comments that the draft EIS concludes that the staff alternative 

transmission alignment, located about 1.5 miles from the Skylark Airport, would not be expected to pose 

a safety hazard to aircraft operating according to standard flight rules. The draft EIS concludes that the 

co-applicants have not provided enough detail to assess the effects of their proposed transmission 

alignment on operations at Skylark Airport. Nevada Hydro states that given that the co-applicants’ 

proposed transmission alignment is located 2 miles from Skylark Airport, it would be reasonable to 

conclude that the co-applicants’ proposed transmission alignment would have less effect than those 

associated with an alignment that is closer to the airport. It refers Commission staff to the discussion of 

aircraft safety hazards in section 11 of the final license application. Nevada Hydro also points out that the 

description of Skylark Airport as a private dirt airstrip on page 3-297 is incorrect. 

Response: We have revised the text to clarify that neither the co-applicants’ proposal nor the staff 

alternative transmission alignment would be expected to pose a safety hazard to aircraft operating 

according to standard flight rules out of Skylark Airport. We have also corrected the text on page 3-297 

concerning the airport. 

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Comment 206: Elsinore Hang Gliding Association (EHGA) comments that the Commission must ensure 

that the project meets all appropriate comprehensive plans associated with the Land Management Plan 

Cleveland National Forest Strategy R5-MB-077 September 2005. 

Response: As discussed in section 3.3.7.2, Environmental Consequences, Consistency with Land 

Management Plans, in the draft EIS (page 3-235), we state that the staff alternative transmission 

alignment would not be consistent with the Land Management Plan land use zones and that an 

amendment would be required before construction of the transmission line could occur. 

Comment 207: The Center for Biological Diversity states that the proposed LEAPS Project violates the 

Cleveland National Forest Land Management Plan by failing to demonstrate why an alternative 

transmission alignment off the forest would not be entirely reasonable. Further, it states that the draft EIS 

incorrectly identifies the land use zoning for the proposed Morrell upper reservoir and part of the 

proposed Decker upper reservoir sites. It points out that these proposed facilities would be located within 

the Back Country Motorized Use Restricted land use zone and that developed facilities in this zone are 

suitable only by exception. 

Response: We agree that the Morrell Canyon upper reservoir site and portions of the Decker Canyon 

upper reservoir site are located in the Back Country Motorized Use Restricted land use zone and have 

revised the text in the final EIS accordingly. The USFS indicates that it could consider utility facilities as 

a suitable use by exception in this land use zone. 

Comment 208: The Center for Biological Diversity comments that the proposed LEAPS Project would 

not enable the USFS to meet the desired condition for Elsinore Place under the Cleveland National Forest 

Land Management Plan. 

Response: Based on comments on the draft EIS we have included photo simulations to characterize the 

effects of the proposed project on the aesthetic resources. The EIS does disclose that construction and 

operation of the proposed project would conflict with the USFS Land Management Plan’s Scenic 

Integrity Objectives, as stated on page 3-242 of the draft EIS. The 2005/2006 revised Cleveland National 

Forest Land Management may need to be amended to make the project consistent with the plan. 

Comment 209: The Natural Resource Defense Council and Pacific Clay state that the project is 

incompatible with Cleveland National Forest and Lake Elsinore land-use plans and policies, such as the 

High Scenic Integrity Objectives and the BLM’s Visual Resource Management Program. Additionally, 

the Natural Resource Defense Council states the draft EIS dismisses the possibility that Morrell Canyon 

could be designated a wilderness area by the USFS and Pacific Clay states that the Visual Resource 

Management Plan recommended in the draft EIS is inadequate mitigation for the level of effects. Mr. 

Mosier recommends the final EIS affected environment identify the existing viewsheds pertinent to the 

LEAPS Project and that the surface of Lake Elsinore should be included as a key observation point due to 

its panoramic views. Additionally, Mr. Mosier suggests the final EIS include an application of the 

Scenery Management System to inventory and analyze the scenery values of those lands in the final EIS. 

Mr. Mosier recommends the Scenery Management System should be applied so as to predict future scenic 

integrity levels and present photo simulations of the proposed alternatives. Mr. Mosier also claims that a 

more thorough analysis is needed to support the analysis in the draft EIS related to the mid-slope 

transmission alignment. Lastly, Mr. Mosier recommends using the title Scenery Conservation Plan to be 

consistent with USFS policy direction as opposed to Visual Resource Management as proposed by the coapplicants and used in the draft EIS. 

Response: In the final EIS, we have included the viewsheds pertinent to the discussion of the aesthetic 

affected environment and included Lake Elsinore as a key observation point. We have also developed 

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photo simulations of the proposed project alternatives as seen from important viewsheds to enhance the 

presentation of the existing landscape and the potential effects of the project on the visual resources. The 

simulations portray the full range of the project’s effects on scenery expected within the project area’s 

sensitive public viewsheds. The Scenery Management System (SMS) was used by the USFS to develop 

the current Scenery Integrity Objective’s against which the proposed project is evaluated against. The 

SMS also provides a nationally consistent method for identifying degrees of scenic integrity effects that 

may be created by project proposals. 

Comment 210: The Center for Biological Diversity comments that the draft EIS is inappropriately silent 

on the location of Morrell and Decker upper reservoir sites in the Wildhorse Inventoried Roadless Area. 

It points out that the USFS has agreed not to authorize road construction of the type contemplated by the 

proposed project until the state’s roadless areas’ status under the new Roadless Rule (section 1925.04b of 

the Interim Directive [1920-2006-1]) has been determined. 

Response: According to the current Cleveland National Forest Land Management Plan, the areas of the 

forest where Morrell and Decker reservoirs are proposed is designated as an Inventoried Roadless Area 

that allows consideration for road construction or reconstruction. However, the USFS is enjoined from 

implementing the 2005 Roadless Rules. Contrary to the Center for Biological Diversity’s comments, the 

Final Land Management Plan does not specify a Wildhorse Inventoried Roadless Area. 

Comment 211: Pacific Clay also states that an amendment would be needed to the Cleveland National 

Forest Land Management Plan to construct either the co-applicants’ proposed or staff’s recommended 

transmission line alignments. 

Response: On page 3-239 of the draft EIS, we acknowledge that construction along either the coapplicants’ proposed transmission alignment or the staff alternative transmission alignment would require 

an amendment to the Cleveland National Forest Land Management Plan. 

Comment 212: Christopher Willis comments that the proposed project would “destroy the untouched 

feel and character of the pristine open areas.” He is especially concerned about the irreparable damage to 

the beauty that the current National Forest is mandated to preserve and speaks of the public benefit that 

extends beyond actual visitors. There is societal benefit to knowing that such unspoiled vistas exist. 

Response: The Cleveland National Forest Land Use Plan is the framework designed to provide for a 

balanced management of forest service resources and values. We recognize the USFS has recently gone 

through an extensive public planning process to identify and develop policy to be balanced stewards of 

the forest. The plan recognizes the potential for future development within the forest, designates certain 

lands as acceptable for various land uses, and sets guidelines for allowable alterations to the landscape. 

The plan provides for the preservation of certain unspoiled vistas and lands. We believe the EIS discloses 

the effects of the proposed project on the USFS lands and indicate where it is incompatible with the 

approved plan. The Cleveland National Forest Land Management Plan may need to be amended to 

accept the project’s inconsistencies while retaining the current plan’s desired conditions and outcomes. 

Comment 213: EHGA, Jay Scott, and other individuals comment that the EIS should consider the 

effects on Preservation Visual Quality Objective under the original Visual Management Plan. It states 

that no above-ground transmission alignments should be placed on the Trabuco Ranger District, 

Cleveland National Forest. 

Response: The EIS evaluates the effects of the proposed project with the most current Cleveland 

National Forest Land Management Plan, which uses Scenic Integrity Objectives. The “Very High” 

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Scenic Integrity Objective is essentially the same as, and correlates directly with, the “Preservation” 

Visual Quality Objective of the original USFS Visual Management System. The Cleveland National 

Forest Management plan assigns the “Very High” Scenic Integrity Level within the entire San Mateo 

Wilderness and no other lands near the project area. Since no Project features are proposed within the 

wilderness, the Very High Scenic Integrity Objective (corresponding to the Preservation Visual Quality 

Objective) does not apply to this project. 

Comment 214: Mr. Mosier suggests that the final EIS be more informative by indicating that the 

Moderate Scenic Integrity Objective applies to less than 2 to 3 percent of the total length of the proposed 

transmission line. 

Response: The final EIS discloses the approximate length of the proposed transmission lines that would 

traverse Moderate Scenic Integrity Objective lands. 

Comment 215: The Palomar Observatory and the Lakeland Village/Wildomar Redevelopment Project 

Area Committee state that the draft EIS does not address the issue of outdoor lighting and dark skies and 

requests that all permanent lighting be fully shielded low-pressure sodium and comply with Riverside 

County’s lighting ordinance. 

Response: The co-applicants state that they would comply with Riverside County's lighting ordinance. 

Comment 216: The city of Lake Elsinore and Riverside County state that the visual aids presented in the 

draft EIS are not adequate to evaluate the visual effects of transmission line placement and a 

comprehensive simulated visual study should be done. Linda and Martin Ridenour state that visual 

simulations of the aesthetic effects should be taken from Grand Avenue and should clearly show the 

locations of the powerhouses so that residents of Lakeland Village can understand the potential effects on 

their neighborhood. 

Response: We have provided visual simulations of the transmission line and the powerhouse in appendix 

D of the final EIS. 

Comment 217: Nevada Hydro comments that in the analysis of effects of project construction of the 

proposed transmission alignment on aesthetics the draft EIS states that over the term of any license, USFS 

maintenance crews would maintain a fire break below the lines and these fire breaks also would be 

apparent as a scar across the native vegetation. Nevada Hydro requests that the USFS identify where fire 

breaks should be developed and maintained. Alternatively, it requests that if fire breaks are deemed not 

to be beneficial, the final EIS should state that brush clearance activities should be limited to the extent 

feasible. 

Response: While the co-applicants are not proposing to clear vegetation under the transmission line, the 

final EIS states that fuel management in the future may require manipulation to reduce the risk of fire. 

Methods selected for fuel management would depend on site-specific factors (e.g., vegetation type, slope, 

aspect, access), and could include grazing, prescribed fire, or mechanical means to create and maintain 

firebreaks. Existing firebreaks that intersect the proposed alignment would also be maintained, as needed. 

These issues would need to be addressed in the hazardous vegetation fuel treatment plan and the scenery 

conservation plan as specified by USFS in their revised preliminary 4(e) conditions under any license 

issued for the project. 

Comment 218: The Fernandez Parties, Pacific Clay, Rancho Capistrano Property Owners Association, 

La Cresta Property Owners Association, and individuals state the draft EIS does not adequately identify 

the project’s aesthetic and property valuation effects on property owners who purchased land based on the 

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wide open spaces and natural beauty of the region and national forest. The beauty and property values 

would be diminished with construction of transmission lines and towers. Pacific Clay states that the 

claim in the draft EIS, on page 3-232, that the effect of the staff alternative transmission line alignment on 

future development “cannot be determined” is not true because there are standard appraisal 

methodologies. 

Response: In section 3.3.8.2 of the draft EIS, Environmental Consequences, Effects of Construction and 

Operation on Property Values and Development (see pages 3-269 through 3-273), we discuss the 

potential effects of the project transmission line on property values in great detail, and indicate that 

various studies have shown transmission line effects on property values ranging from small positive 

effects to negative effects as high as 53.8 percent. We indicate that most results show a negative impact 

on property values of 1 to 10 percent. We maintain, however, that despite standard appraisal methods, the 

precise effect on future development cannot be determined except on a case-by-case basis at this time. 

Comment 219: The Fernandez Parties, Pacific Clay, and Lake Elsinore Unified School District state that 

the draft EIS fails to consider the effects of EMFs associated with the project on residents, rare horses, 

and students along the transmission route. The Fernandez Parties state that the brief analysis on page 3-

248 through 3-251 of the draft EIS is inadequate because the World Health Organization has stated there 

is “sufficient evidence” to apply a “precautionary principle” to power and electromagnetic fields. The 

District indicates that state school site selection guidelines limit the placement of schools near high 

voltage transmission lines. John Pecora is concerned regarding his family’s elevated exposure to 

electromagnetic fields. 

Response: We are aware of the World Health Organization’s adoption of its precautionary principle, but 

stand by our analysis of electromagnetic field effects and our conclusion that the project would not have 

adverse effects on animals or humans in the project area. The transmission line would be far enough 

away from residences that any potential health effects would be minimized. Additionally, the coapplicants’ proposed transmission alignment and staff alternative transmission alignment now contain 

longer underground segments that would reduce the risk of any potential health effect. We have revised 

section 3.3.8.2, Environmental Consequences.

Comment 220: The city of Lake Elsinore states that it appears that there has been a trade-off of 95 

percent of the aquatic mitigation funds proposed by the co-applicants to partially alleviate short-term 

inconveniences on the Ortega Highway with the recommendation of a measure to excavate an area of 

Decker Canyon. The city states that this is not a thoughtful use of limited project resources set aside for 

environmental mitigation and that alternative mitigation measures represent a much more common sense 

approach to addressing the needs of commuters. 

Response: Our determination of the level of funding to address aquatic mitigation has no relationship to 

the staff recommendation to achieve a balance of excavation to fill at the upper reservoir location. Using 

fill excavated at the construction would greatly reduce the volume of large truck traffic on portions of 

Ortega Highway and Grand Avenue during construction. 

Comment 221: Rancho Capistrano Property Owners Association and Andrew and Sandra Mauthe 

comment that they paid for the paving of South Mountain Divide Road, which was designed as a 35 mph 

road and express concerns about an estimated potential increase of 400,000 cars annually on this road. 

Response: We estimated the project related increase in traffic volume on South Main Divide Road to 

increase to 150 vehicles during the a.m. and p.m. peak travel times, which would still be well below the 

estimated capacity of 2,100 vehicles and maintain the same level of service. USFS preliminary 4(e) 

condition no. 26, Road and Traffic Management Plan, would address the concerns raised in this 

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comment. We discuss the effects of construction and operations on South Main Divide Road on pages 3-

253 through 3-259 of the draft EIS. 

Comment 222: Lake Elsinore Unified School District is critical of the traffic analysis in the draft EIS, 

stating that it did not account for the transportation of imported and excavated soil and arbitrarily divides 

trip generation numbers among various areas to cover different construction scenarios. It also states that 

the final EIS should address traffic effects in the event that the 73,750 truck loads of excavated soil 

cannot be used at the upper reservoir. Robert and Susan Konoske question whether truck trips to import 

clay have been included, whether truck trips for disposal have been included, and the effects of the 

construction truck trips on local traffic patterns. 

Response: We based our truck trip estimates in the draft EIS on the assumption that traffic volume 

increases associated with construction activities would increase but not above the threshold that would 

drop the road’s Level of Service. The truck trip estimates are for the number of trips necessary to relocate 

the excavated soil materials under the co-applicants’ proposed construction configuration and the staff 

alternative. We discuss the assumptions and effects of each, including the import of clay material to line 

the upper reservoir between pages 3-253 and 3-259 of the draft EIS. We discuss the potential traffic 

effects associated with the potential transport of excavated material away from the proposed powerhouse 

site in the first paragraph on page 3-256 of the draft EIS. 

Comment 223: Riverside County states that a comprehensive traffic study should be prepared and 

submitted to the County prior to finalizing the EIS so that the Transportation Department can complete its 

review of the EIS. Riverside County and Pacific Clay recommend a traffic management plan be 

developed and approved by the Riverside Country Transportation Department to accommodate truck 

traffic on county roads such as Grand Avenue. Riverside County also makes numerous recommendations 

related to road maintenance, traffic flow, light signals, road improvements, and cost sharing 

responsibilities. These recommendations include road pavement testing be conducted before and after 

construction and funding should be provided to the Transportation Department to mitigate for project 

effects that cause pavement deterioration; the co-applicants fund a traffic signal to be located at the 

adjacent major intersection of Grand Avenue and Ortega Highway; the co-applicants be required to 

construct truck turnouts, a truck climbing lane, and/or other safety improvements on the affected areas of 

the Ortega Highway; safety improvements along Grand Avenue, including shoulder widening to 

accommodate the truck traffic activities; and that the co-applicants contribute on a fair share basis to the 

Regional Transportation Network by participating in the County’s Transportation Uniform Mitigation Fee 

program. Lake Elsinore Unified School District indicates the traffic hazards from construction traffic 

would be most severe on Grand Avenue with three schools and no sidewalks, forcing students to travel on 

the road or dirt shoulder in close proximity to vehicular traffic. Empire Pre-Cast is also concerned about 

increased truck traffic and safety hazards on Grand Avenue. 

Response: The EIS considers the need for traffic control plans which would include among other items 

schedules for the volume and timing of construction traffic and long term monitoring, reporting, and 

changes to the plan as necessary. Based on comments received on the draft EIS, the co-applicants road 

and traffic management plan for non-USFS roads should be developed in consultation with the Riverside 

County’s Transportation Department. Pre-construction monitoring and baseline condition documentation 

could be developed as part of the plan so as construction related effects could be separated from normal 

traffic effects. The co-applicants also propose to participate in the development of a traffic signal at the 

intersection of Grand Avenue and Ortega Highway. Further, the co-applicants also propose several 

specific measures to improve traffic flow on Grand Avenue and Ortega Highway during construction. 

The details of involvement, measures, responsibilities, and schedule would be included in the coapplicants’ proposed final road and traffic management plan, which would be developed in consultation 

with local agencies and filed for approval with the Commission. Development of the plan prior to 

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construction would address the concerns of Riverside County and the Lake Elsinore Unified School 

District. 

Comment 224: Pacific Clay, Linda and Martin Ridenour, and Robert and Susan Konoske state that the 

traffic counts conducted by the co-applicants were deficient since the counts only captured data from 1 

day in July.

Response: Our review of California Department of Transportation (Caltran), Traffic Operations Division 

Traffic and Vehicle Data for Ortega Highway and Grand Avenue indicates that recorded peak hour traffic 

(2005) data are relatively consistent with the co-applicants’ traffic study data validating our use of the 

study. For example the Caltrans traffic volume estimates the peak hourly traffic on Ortega Highway west 

of Grand Avenue (between Grand Avenue and the Riverside County line) at 1300 where as the coapplicants peak estimate for Ortega Highway west of Grand Avenue was 1252. In addition, Caltrans peak 

hourly estimate for Ortega Highway east of Grand Ave (between the intersection with Grand Avenue and 

Lake Shore Drive) at 1800 vehicles whereas the co-applicants estimated peak hourly traffic volume on 

Grand Avenue south of Ortega Highway at 1382. Although these two road segments are not the same 

segment, they do present a reasonable picture of the estimated traffic volumes on Grand Avenue in the 

vicinity of its intersection with Ortega Highway and in the proposed project area. As such, we feel the 

Caltrans data supports our use of the co-applicants traffic study. Our review of the co-applicants traffic 

study also indicated that the 38 trucks per hour (as shown on page 3-254 of the draft EIS) is adequate for 

the purposes here because this estimate was made for the highest peak hour operation on the most critical 

street section. Furthermore this construction volume assumes level of service (LOS) “C” is maintained, 

while LOS “D” would also be generally acceptable. Effects from construction would last 4 years and, 

with implementation of a road and traffic management plan, traffic scheduling could help alleviate these 

concerns. In addition we have addressed the scheduling of truck traffic relative to the traffic data on page 

3-257 of the draft EIS. 

Comment 225: Riverside County comments that the draft EIS states that clay may be imported from the 

Alberhill area but does not analyze the effects of resulting truck traffic.

Response: Contrary to Riverside County’s statement, we analyze the number of truck trips necessary to 

transport clay for the lining of the upper reservoir on page 3-256 of the draft EIS. We analyze the air and 

noise pollution generated by such truck traffic in subsequent sections. 

Comment 226: Linda and Martin Ridenour state that the 58-acre Ortega Oaks powerhouse would affect 

park and ride use that currently occurs on that vacant parcel. 

Response: According to Riverside County’s Transportation Commission, whose Transportation Services 

department oversees the local park and ride program, the 58-acre parcel at Ortega Oaks is not a formal 

park and ride facility (website: http://www.rctc.org/transportation/carpool.asp; accessed September 14, 

2006). Therefore we do not evaluate the effects of a potential powerhouse at the site on car-pooling. 

SOCIOECONOMIC RESOURCES 

Comment 227: Francis Hoffman, on behalf of the Elsinore Testing of Experimental Aircraft Mechanism, 

indicates that the Commission staff is deliberately concealing the appearance, size, noise, and proximity 

of the facilities from homeowners whose property values might be affected by the proposed project. 

Response: The draft EIS provides a detailed description of the proposed project facilities and discloses 

the potential effects on the aesthetic resources of the project area. In addition, we now have included 

visual simulations of the appearance of the proposed project facilities in the final EIS. 

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Comment 228: The city of Lake Elsinore states that the draft EIS only provides a cursory economic 

analysis of the potential effects of the project and a more detailed analysis is needed. 

Response: The city does not indicate in its comments what other economic effects not included in the 

draft EIS it believes would occur. We stand by our conclusion that the most likely project economic 

effects would be potential effects on property values, which we discuss in detail. 

Comment 229: Riverside County states that the EIS should describe mitigation measures due to effects 

on displaced persons from the construction of the project. It recommends that the co-applicants work 

directly with the Department of Public Social Services to develop plans to address this issue, prior to 

construction. 

Response: In the case of the limited properties where residences would be razed, owners would be 

compensated for their property. With respect to potentially displaced persons who might be in need of 

social services provided by the county, the co-applicants now propose to provide relocation assistance for 

persons who might be displaced from rental properties. We have revised the text in section 3.3.7.2, 

Environmental Consequences, Change of Land Use, to address this point. 

Comment 230: Riverside County, the Fernandez Parties, and Edwin Thorell inquire as to whether or not 

eminent domain would be used to acquire properties near the proposed powerhouse. Additionally, they 

would like to know what other mitigation measures would be proposed to reduce construction-related 

effects on residents. The Fernandez Parties also state that Elsinore Valley MWD does not have the right 

of eminent domain, so therefore the draft EIS must identify all project elements and locations that are 

proposed for private property and discuss alternative locations in instances where use or acquisition of the 

property is likely. 

Response: On pages 3-269 and 3-270 of the draft EIS, we discuss the co-applicants’ plans to use eminent 

domain authority if necessary to acquire needed property. 

Comment 231: Linda and Martin Ridenour comment that the section on growth-inducing impacts states 

that power would be used locally, but Elsinore Valley MWD has stated publicly that the power would not 

be used locally and that it would go into the grid. 

Response: Once power enters the grid, the electricity may be transmitted either locally or elsewhere in 

the region. However, we have revised the text related to growth-inducing impacts to delete the reference 

to local power sales. 

CULTURAL RESOURCES 

Comment 232: Nevada Hydro disagrees that the Area of Potential Effects (APE) includes the shoreline 

around Lake Elsinore to the upper limit of the zone of daily fluctuations expected from the project as 

stated on page 3-276 of the draft EIS because the operational range of the project is within the range of 

natural seasonal variations in the lake. 

Response: Inclusion of an area within an APE does not mean that an undertaking would affect any or all 

cultural resources within that area. An APE is a hypothetical construct intended to establish a geographic 

framework in which there is reasonable possibility that an undertaking could affect historic properties. 

We included the Lake Elsinore shoreline in the APE as a starting point for analysis.

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Comment 233: Nevada Hydro comments that, contrary to the information on page 3-288 in the draft 

EIS, no previous study, including the EIR for the Lake Elsinore Stabilization and Enhancement Program 

and the Corps NEPA documentation for the levee system, did any party, agency, or tribal group identify 

or assert that Lake Elsinore should be considered eligible for listing in the National Register or that 

management measures for this property should be developed. It comments that the minimum intrusion 

into the lake associated with the project and the cycling operation should not predicate the need for a 

National Register determination. Nevada Hydro agrees with the conclusion in the draft EIS that the 

proposed project would not likely adversely affect this potential TCP, but disagrees with the statement 

that there is insufficient information about the TCP to determine whether this aspect of the proposed 

project (construction of the intake/outlet structure) would alter any characteristics contributing to the 

importance or cultural value of this resource. 

Response: In its March 24, 2005, comments on Nevada Hydro’s draft HPMP, the USFS stated 

(Comment no. 22) that resource 33-11009 (Lake Elsinore) was eligible for inclusion in the National 

Register and that any measures to mitigate adverse effects to this resource should be developed in 

consultation with the USFS, Tribes, and the SHPO. The analyses on pages 3-283 and 3-284 have been 

revised to clarify the discussion regarding effects to Lake Elsinore as a TCP and we continue to conclude 

that construction of the intake/outlet structure and operation of the project would have no effect on the 

characteristics contributing to the National Register eligibility of Lake Elsinore as a traditional cultural 

property. 

Comment 234: Nevada Hydro disagrees with the statement on page 3-281 that the APEs for the 

Evergreen powerhouse site, both the proposed and alternative transmission alignments, and the access 

roads remain to be surveyed. It refers the authors to the performance of cultural resource surveys 

contained in the draft HPMP. 

Response: On page 2-3 of its draft HPMP, Nevada Hydro states that the locations of access roads from 

existing roads to the transmission line corridors are not yet known, leading us to conclude that no 

archaeological surveys have been conducted along access roads. The HPMP’s description of cultural 

resources field studies (p. 2-4) does not specify precisely what areas were surveyed either in 1996-97 or in 

January 2005. 

Comment 235: John and Soma Stickler raise concerns about the effects of the proposed and alternative 

transmission line alignments along the Cleveland National Forest in the vicinity of Tenaja would have on 

archaeological sites. They indicate that transmission line alternative 4 would avoid this area. 

Response: The co-applicants’ revised and staff alternative alignments now includes alternative 4. For all 

alignment alternatives, the HPMP, revised and finalized in consultation with the SHPO, Tribes, and the 

USFS and the Lake Elsinore Historical Society, would provide for processes to determine effects of 

construction and operation of transmission lines on significant archaeological sites, and to appropriately 

resolve any adverse effects.

Comment 236: Pacific Clay states there is no way to know the potential extent of effects on cultural 

resources from the staff’s recommendations because no cultural resource surveys have been done since 

project facilities have not been sited. 

Response: We recommend that the co-applicants, in consultation with the SHPO, the USFS, Tribes, and 

the Lake Elsinore Historical Society to conduct any additional surveys necessary to identify cultural 

resources in proposed locations of project facilities, determine effects of the project on such resources, 

and to develop and implement measures to resolve any adverse effects prior to any construction activities 

at those locations. 

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Comment 237: The Pechanga Tribe provides confidential information concerning its history in the 

project area. 

Response: We thank the Tribe for providing this information.

Comment 238: The Pechanga Tribe recommends further evaluation, testing and/or avoidance at several 

archeological sites in the Morrell Canyon area. 

Response: The co-applicants’ revised and finalized HPMP would contain provisions for consultation 

with the Tribes regarding measures to resolve any adverse effects to these archaeological sites arising 

from project construction or operation.

Comment 239: The Pechanga Tribe requests applicable agencies consult with the Tribe in person 

regarding the specific locations and details of the project effects on cultural resources because the Tribe 

can not disclose specific details in letter. 

Response: The co-applicants’’ revised and finalized HPMP would contain explicit protocols through 

which appropriate tribal liaison would coordinate with the co-applicants, the USFS, and Commission staff 

regarding communication with the Tribes. 

Comment 240: The Pechanga Tribe requests assessments be made according to section 106 review 

process and that the Pechanga Tribe be a consulting party on a government-to-government basis. 

Response: The co-applicants’ revised and finalized HPMP would contain measures to ensure that 

evaluation of cultural resources would be accomplished through application of the National Register 

Criteria for Evaluation and in consultation with the SHPO, the USFS, Tribes, and the Lake Elsinore 

Historical Society. 

Comment 241: The Pechanga Tribe intends to assert its right pursuant to California law with regards to 

any human remains or items discovered in the course of the project in the Tribe’s traditional territory and 

it requests that all permitting agencies work with the Tribe to draft an agreement that would address this 

issue. The Pechanga Tribe also requests all Luiseno cultural resources uncovered in the Tribe’s 

traditional territory and not located on federal properties be relinquished to the Tribe for proper treatment 

Response: As indicated in its draft HPMP, the co-applicants would follow applicable California law 

regarding discovery of human remains on state or private land. The co-applicants would also notify 

USFS of any such discoveries on USFS property; USFS would then be responsible for treatment and 

disposition under federal law. The draft HPMP also specifies that the co-applicants would consult with 

the Tribes regarding treatment and disposition of cultural resources of importance to the Tribes that are 

identified on private or state land.

Comment 242: The Pechanga Tribe is concerned no APEs have been set for the project tunnels and 

believes that the APE for the tunnel portions of the project should be reevaluated in consultation with the 

Tribe. It further states that wherever the HPMP notes that it would address future decisions regarding 

APEs or amendments, it should acknowledge that the lead agency would consult with the Tribe as well as 

the SHPO. 

Response: The revised and finalized HPMP would provide for consultation with the Tribes as well as the 

SHPO and USFS regarding identification or modification of APEs.

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Comment 243: The Pechanga Tribe states that further archeological surveys will need to be completed to 

meet the legal requirements for the project. It asks that it be allowed to participate in those surveys and 

be consulted about field and lab methodologies and how surface collections should proceed. The 

Pechanga Tribe further requests that culturally appropriate evaluation methods be incorporated into the 

HPMP and that no public interpretations are created for Native American cultural resources. The 

Pechanga Tribe also requests that the lead agency or its designated agent allow the Tribe to monitor all 

grading and ground-disturbing activities in culturally sensitive areas within the Tribe’s traditional 

territories and tribal monitors be present during all archeological testing. It also requests that it be 

allowed to review and comment on any Native American monitoring plans. 

.

Response: We recommend that the co-applicants, in consultation with the SHPO, the USFS, Tribes, and 

the Lake Elsinore Historical Society to conduct any additional surveys necessary to identify cultural 

resources in proposed locations of project facilities, determine effects of the project on such resources, 

and to develop and implement measures to resolve any adverse effects prior to any construction activities 

at those locations. In the HPMP, the co-applicants have proposed to appoint a tribal liaison who would 

consult with the tribes regarding construction monitoring, archaeological survey, and resource protection 

measures. 

Comment 244: The Pechanga Tribe requests the lead agency commit to avoidance and preservation of 

Native American sacred sites.

Response: NHPA does not require federal agencies to avoid effects to cultural resources; it requires 

federal agencies to consider a variety of measures to resolve adverse effects, among them avoidance, 

minimization or mitigation. Nevertheless, whenever possible, avoidance is always the best approach for 

resolving potential adverse effects to cultural resources. 

Comment 245: SDG&E comments that the draft EIS does not include a discussion of an alternative 

substation site that may avoid impacts to cultural resources and generally does not contain any on-theground surveys for cultural resources. SDG&E states that the extent and significance of any cultural 

resources is unknown, could affect the routing of the transmission line, and should be disclosed in the 

EIS. 

Response: The co-applicants’ revised alignment now includes alternative 4 that avoids areas of 

archaeological sensitivity. However, the co-applicants would need to complete surveys along the final 

transmission alignment prior to commencing construction.

Comment 246: Ruth Atkins comments that the two most prominent historic properties in close 

proximity of the proposed project are the Elsinore Naval and Military Academy and the Machado Adobe. 

The former was never used as a club, as indicated on page 3-281 of the draft EIS, and the later was built 

in 1858 and, when the Butterfield Stage Line was commissioned, used as a stage coach stop. She also 

comments that in the area there is a marker of the tanning vats built in 1891 by the Luiseno Indians that is 

a California Registered Historical Landmark. She and Linda and Martin Ridenour would also like 

assurances that the historic properties near the Santa Rosa powerhouse site, including the naval academy 

building, would not be adversely affected by ground vibration during construction. 

Response: We have revised the text in the final EIS to indicate that the Elsinore Naval and Military 

Academy property was not used as a club, although originally intended as such. Nevada Hydro’s draft 

HPMP contains measures to address potential effects of construction-related ground vibration on 

significant buildings prior to initiation of heavy construction or blasting near such buildings. 

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Comment 247: Linda and Martin Ridenour state that the Lake Elsinore Historical Society and the 

Riverside County Office of Historic Preservation were not notified by Elsinore Valley MWD of the filing 

of a revised HPMP. They ask that the Lake Elsinore Historical Society be invited to participate in the 

HPMP. 

Response: We recommend that the Lake Elsinore Historical Society be included as a consulting party to 

the Programmatic Agreement and will afford this organization opportunity to comment on the revised 

HPMP. 

AIR QUALITY AND NOISE 

Comment 248: Nevada Hydro comments that the LEAPS Project’s ability to store generated energy, 

including nuclear energy produced at the San Onofre Nuclear Generating Station, results in the more 

efficient use of energy resources and diminishes the need construct new and operate existing fossil-fuel 

burning generating facilities within non-attainment basin. 

Response: We agree that hydropower generation produces less air pollutant emissions compared to 

natural gas or coal-fuel plants. However, we find the statement about storing nuclear energy to be 

misleading because nuclear power is a baseload generating resource rather than being used on the margin, 

and is not used for pumping. 

Comment 249: Nevada Hydro cites a reference on page 3-294 to the Mojave Desert Air Basin and 

Salton Sea Air Basin and states that it does not believe that any portion of the proposed project is located 

within these two air basins and questions why they are included in the draft EIS. 

Response: The LEAPS Project area is located principally within the South Coast Air Basin which is in 

Riverside County; however, the proposed transmission alignments extend to Orange and San Diego 

Counties. Riverside County is partitioned into three air basins: South Coast Air Basin, Salton Sea Air 

Basin, and Mojave Desert Air Basin. According to CARB, an air basin generally follows political 

boundary lines and is defined to include both source areas and receptor areas. However, because air 

masses can move freely from basin to basin, interbasin transport of pollutants is unavoidable. It is for this 

reason that the Mojave Desert Basin and Salton Sea Air Basin were included in the EIS.

Comment 250: Nevada Hydro points out that the San Mateo Wilderness Areas should be included in the 

list on page 3-302 of areas located within 100 kilometers of a federal Class I area. 

Response: We have added the San Mateo Wilderness Area to the list of areas located within 100 

kilometers of a Federal Class I area in the final EIS. 

Comment 251: Nevada Hydro provides updated information about the state of California laws pertaining 

to air emissions and provides an exhibit (Exhibit 4 in the April 25, 2006 filing) the compares LEAPS to 

other generation technologies for ancillary services and RMR value. It requests that the final EIS 

augment the existing air quality analysis to describe the beneficial effects of the LEAPS Project. It 

requests that the final EIS also include an analysis of the project’s compliance with the general 

conformity rule (40 CFR Part 51, Subpart W, and 40 CFR Part 93, Subpart B). 

Response: We have included information on beneficial effects of the LEAPS Project in the final EIS. As 

described in section 3.3.10.2 of the draft EIS, the general conformity rule applies to federal actions in 

non-attainment areas. The LEAPS Project is located in Riverside County, but the proposed transmission 

alignments extend to Orange and San Diego Counties. The air basins in these three counties are classified 

as attainment for NOx, SO2 and CO, and non-attainment for Ozone and PM10/PM2.5. Therefore, a 

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conformity determination would only be applicable for Ozone (NOx/VOCs being the pre-cursors) and 

PM10/PM2.5. An emission estimate including construction worker’s commutes, construction equipment 

and use of delivery, hauling and work trucks in pounds per day per pollutant has been included in the EIS 

as presented in Tables 36 and Table 37. These values can be converted into tons/year based on the 

expected amount of project days/year and compared with de minimus levels in order to make a conformity 

determination and comply with the general conformity rule. Based upon the proposed construction 

schedule, it is anticipated that these values could exceed the de minimus levels and be applicable to 

conformity requirements. However, these values are less than the SCAQMD “significant thresholds” for 

construction activities. Therefore, none of these activities are anticipated to have a significant effect on 

the surrounding air quality and additional mitigation would likely not be required. A preliminary 

conformity analysis will be completed prior to the issuance of any license for the proposed project. 

 

Comment 252: EPA states the draft EIS does not include mitigation measures to minimize air pollutant 

emissions from project activities. It recommends the following measures to minimize construction 

emissions at the reservoir site, the powerhouse site, and along the transmission lines: (1) consult with the 

South Coast Air Quality Management District and prepare a fugitive dust mitigation plan; and, (2) 

develop and implement a plan complying with best practices for mitigating exhaust emissions from 

construction equipment and evaluate the feasibility of measures to reduce construction emissions. 

Response: We have addressed the need for fugitive dust mitigation in the final EIS. If a license is issued 

for the proposed project, we recommend that the licensees consult with South Coast AQMD to comply 

with best practices for mitigating exhaust emissions from construction equipment and evaluate the 

feasibility of measures to reduce construction emissions. 

Comment 253: The Center for Biological Diversity comments that the significance of exceedances of 

carbon monoxide, particulate matter, and ozone standards in the project area and the potential effects of 

the construction and operation of the project relative to these standards is not addressed in the draft EIS. 

It states that the draft EIS must fully discuss the proposed project’s production of ozone precursor 

emissions and particulate matter, and the direct, indirect, and cumulative impact both on human health 

and on vegetation and wildlife habitat, especially for threatened and endangered species. 

Response: We discuss the air emissions and fugitive dust that could be generated by the construction and 

operation of the proposed project relative to the appropriate standards and thresholds in section 3.3.10.3 

of the draft EIS and conclude that air emissions and fugitive dust would not exceed the current 

significance thresholds. 

Comment 254: Lake Elsinore Unified School District indicates that blasting could present a public 

safety risk and affect the learning environment at schools in the project area. It recommends the final EIS 

include a detailed disclosure of planned blasting activities, anticipated environmental effects, and 

appropriate mitigation measures. Lake Elsinore Unified School District also is critical of the fugitive dust 

discussion in the draft EIS and states that the final EIS should include a greater analysis of local air 

quality effects created by construction activities in the immediate vicinity of the project. It also states that 

localized effects should be analyzed and schools viewed as sensitive receptors. John Pecora is also 

concerned about the effects of dust on his family and home. 

Response: We address fugitive dust in section 3.3.10.3 of the draft EIS and have added information 

about the potential effects of blasting. If licensed, we would require the licensee to comply with local and 

state laws to control fugitive dust and noise from blasting. 

Comment 255: Pacific Clay and Lake Elsinore Unified School District are critical that the draft EIS does 

not recommend any mitigation for the potential release of smelly gasses into the atmosphere which could 

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affect distant communities and individuals who commute along Ortega Highway daily. Linda and Martin 

Ridenour request CARB data to support staff's statements that gases released from the lakebed during 

construction are not expected to be toxic. 

Response: We do not expect that large quantities of smelly gases would be emitted from the lakebed 

during construction. Mitigation recommendations for any of these gases which could potentially affect 

distant communities and individuals commuting along the Ortega highway would be taken if it is 

determined that there may be a significant impact on these areas. 

Comment 256: Linda and Martin Ridenour state that the discussion of state and national area 

designations in the draft EIS is hard to read. They request a clear statement in the final EIS about whether 

the city of Lake Elsinore has air quality problems and whether the project-related emissions are 

considered significant under NEPA and CEPA. 

To control air emissions they recommend compliance with SCAQMD rules governing low sulfur fuels 

and use of filter traps on truck tailpipes. To control dust they recommend the use of non-potable water to 

control dust, that all haul truck be covered, 2 feet of freeboard be left between the top of the load and the 

top of the trail bed, and that construction be halted when wind speeds reach 25 miles per hours in order to 

reduce the amount of dust released into the air. 

Response: As noted in our response to comment 252, we address fugitive dust in section 3.3.10.3 of the 

draft EIS and have added information about the potential effects of blasting. If licensed, the co-applicants 

would comply with local and state air emissions rules and regulations including those to control sulfur 

levels, fugitive dust, and noise from blasting. 

Comment 257: Lake Elsinore Unified School District is critical of the noise discussion in the draft EIS 

and should consider the effects of construction noise and truck traffic on schools including taking the 

school schedule into account.

Response: The noise analysis presented in the EIS does consider and evaluate project-related impacts 

from construction and operational activities. As part of the construction impact analysis, noise from truck 

traffic and mobile/stationary equipment noise were examined. Both morning and afternoon peak traffic 

conditions were considered. The results of the analysis show that construction traffic would not result in 

significant noise impacts. Rock drilling activity may generate loud noises during early stages of the 

construction, but would be substantially attenuated when the excavation goes deep into the ground. 

Mitigation measures, if required, would be employed to ensure conformance with applicable City or 

County noise codes. 

Comment 258: La Cresta Property Owners Association and John Pecora inquire about how the effect of 

a constant loud humming noise from the transmission lines on residents would be mitigated. 

Response: The nearest residential sensitive land uses are at distances of 100 feet or more from the 

proposed transmission alignment. However, the effect of a humming noise from the transmission lines on 

residents would be minimal because the intensity of noise in decibels (dBA) would be attenuated over 

distance. The “hum”, also referred to as “low frequency sound”, is not clearly defined but is generally 

considered as noise at frequencies below 150 Hz. Exposure to low frequency noise at low intensity noise 

levels resulting from distance attenuation loses would not be noticed by most receptors as humans are less 

sensitive to these tonal sounds. Section 3.3.7.2 of the EIS describes precautionary measures that will be 

undertaken during construction of the power lines to help protect humans from uncertain risks 

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Comments 259: Linda and Martin Ridenour request information on the effects of the use of helicopters 

to install transmission lines on noise quality in the project area. They inquire about the echo effect from 

living on the mountain. They state that much of the description in the Affected Environment is unclear. 

For instance, is the noise environment of Lake Elsinore describing the noise in the city of Lake Elsinore 

or on the lake? What does “except at locations affected by transportation, recreation, and industrial 

sources” mean? 

Response: The use of helicopters to install the transmission lines would be temporary in nature. As a 

result, the impacts on noise quality in the project area are not anticipated to be significant. The Ldn noise 

descriptor is commonly used to monitor the anticipated increase in the ambient noise levels within the 

community. Construction activity will be monitored to ensure conformance with applicable local 

government regulations, including the 60 Ldn recommended in city of Lake Elsinore General Plan. 

Noise (sound waves) traveling in a direct path to the Santa Ana Mountains may reflect back toward the 

residential community; however, the sound wave energy intensity would be very much reduced due to 

transmission loses anticipated as it passes through the mountainous terrain. In addition, any reflected 

sound wave would be further attenuated over distance and thus would not significantly impact the 

residential sensitive land uses. The noise environment in city of Lake Elsinore is generally typical of a 

rural setting (e.g., 47 to 57 dBAs); however, elevated noise levels may be experienced during the daytime 

at locations influenced by vehicle traffic on Interstate-15 and the arterials roads servicing the community, 

intermittent power boat and jet ski activities, and aircraft operations from the Skylark Airstrip. 

Comment 260: Linda and Martin Ridenour point out that there are more sensitive land uses than 

described in the draft EIS, including Lakeside High School, a soon to be opened Middle School, and 

Butterfield School, four churches in Lakeland Village, a ball park, and Perret Park. 

 

Response: The noise impact analysis presented in section 3.3.10, Air Quality and Noise, only considers 

the nearest sensitive land uses that may be impacted by noise-producing activity associated with the 

proposed and alternative actions. As such, it was considered to be the worst-case scenario. If no 

significant impacts were anticipated from this worse-case evaluation, it is reasonable to conclude there 

would be no significant impacts for sensitive land uses located at further distances from the projectrelated noise sources. A list of the sensitive land uses is provided in figures 16 and 18 in section 3.3.6 

under the subtitles Recreational Resources and Land Use and Aesthetic Resources; respectively. There 

are other sensitive land uses further north, east and west of the proposed powerhouse sites, including 

Lakeside High School located on Riverside Drive. We have revised the text in section 3.3.10 to 

recognize these other receptors. 

DEVELOPMENTAL ANALYSIS 

Comment 261: Nevada Hydro provides a cost estimate of $5 million per mile for 500-kV gas-insulated 

lines as quoted by Seimens Power Transmission & Distribution Inc., and that the projected cost for 

placing a 1.5 mile segment of the transmission line underground would be less than $10 million. 

Response: We have considered your cost estimate in our developmental analysis. 

Comment 262: SDG&E comments that the draft EIS cost estimate is low and does not fully account for 

the current level of 500-kV construction costs. It cites recent substantial changes in the cost of steel and a 

shortage of skilled labor in the construction of high-voltage electric transmission. SDG&E questions the 

economic benefits of operating the project and asks that the final EIS include an explanation of the 

methodology used to determine the number of hours and time periods during the typical week in which 

the Proposed Project was assumed to be in a pumping mode. SDG&E also notes that table note “a” in 

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table 48 conflicts with the information in table 47 concerning when pumping hours would occur. Finally, 

SD&E comments that use of a single typical week is unlikely to be representative of the varied system 

conditions that occur throughout the year and recommend an hour-by-hour simulation of the facility for a 

full year using actual hourly market clearing prices for energy in southern California from a recent year, 

accounting for the storage capacity of the upper reservoir and incorporating the pumping/generation 

efficiency loss. The final EIS should acknowledge that any simulation would likely overstate the 

benefits. 

Response: We added a significant contingency to the co-applicants’ costs in the final EIS reflecting 

some of this uncertainty. We have corrected footnote a on table 48, Summary of Projected Annual Costs 

and Capital Costs under the Co-Applicants’ Proposal, to read “Pumping energy is based on average 

energy values at SP-15 for August 2004 through July 2005 assuming pumping during all off peak hours 

(10 p.m. through 6 a.m., Monday through Friday) and assumed additional pumping operations during 16 

hours (four hours Monday through Thursday) of regular peak hours in the final EIS. 

Comment 263: SDG&E requests that the statement on page 4-30 the TE/VS transmission line would 

provide “wheeling” benefits to regional utilities, and any other reference to “wheeling,” be deleted 

because under the cost recovery regime proposed by the co-applicants in their March 20, 2006, additional 

information response, the operational control of the TE/VS transmission would be turned over to the 

California Independent System Operator Corporation. 

Response: We have deleted the reference to wheeling in section 4.6. 

Comment 264: SDG&E suggests that table 52 and the associated discussion be deleted from the final 

EIS, also citing the March 20, 2006, filing by the co-applicants. 

Response: We note the March 20, 2006, filing was by Nevada Hydro under a separate proceeding and 

was later withdrawn from the LEAPS Project proceeding; however, we consider it important to evaluate 

the incremental cost of key project components such as the pumped storage element and continue to 

evaluate the economics of the LEAPS Project both as stand-alone project and in combination with the 

TE/VS Interconnection.

Comment 265: Mr. Pinnow provides an analysis of whether the LEAPS Project makes sense from an 

economic point of view. He comments that the assumption in table 42 that the return on equity rate for 

investors of 12 percent would be impossible to achieve without subsidization from California rate payers. 

He questions whether the $40.00/MWh for off-peak energy value south of path 15 includes the power 

transportation costs to get power to the LEAPS plant. If not, the final EIS should include this cost. He 

asks that information about the gross annual profit of the stand-alone pumped storage project be presented 

in the final EIS. He also concludes that there is insufficient information in the draft EIS to determine if 

the pumped storage facility in combination with the proposed transmission line would result in a net 

benefit to rate payers. He asks why the economics for the transmission line have not been included in the 

draft EIS for public review. 

Response: Since the Mead Decision of 1995, the Commission no longer evaluates the internal rate of 

return for a project and leaves the financials analysis and risk in the hands of the co-applicants. Typically, 

in order to obtain bonds or other financing, an applicant must have an independent engineer certify the 

economics and feasibility of the project to move forward and procure financing. We do not typically 

evaluate profits associated with any project; however, we continue to present the annualized costs, 

benefits and net benefits for both the stand-alone pumped storage project and the combined transmission 

line and pumped storage project. Transmission benefits in the final EIS are based on additional 

information provided by the co-applicants in their comments on the draft EIS. 

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Comment 266: Mr. Pinnow provides cost estimates for underground cable (cost of cable and 

installation) through the Cleveland National Forest of about $157 million based on current technologies 

including the use of tight polymer insulation jackets rather than oil-filled jackets and recommends that 

underground technology be used for any transmission cable routed through the Cleveland National Forest. 

Response: We have reviewed Mr. Pinnow’s and other cost estimates for underground transmission 

cables and have lowered our estimate accordingly. 

Comment 267: Mr. Pinnow comments that the configuration of transmitting the power from the LEAPS 

Project to the TE/VS transmission line must be modified to be brought into conformance with section 

71663.5(b) of the California Water Code that requires that any electrical power generated within a water 

district be used within the district for its own purpose and that only surplus power may be sold over the 

high voltage transmission line. He asks that the cost of any reconfiguration be included in the final EIS. 

Response: The co-applicants are required to comply with state laws and regulations. 

Comment 268: Mr. Pinnow comments that neither the LEAPS Project nor the TE/VS transmission line 

can be considered reliability must run (RMR) resource because this term is limited to power plants that 

are available to run hours per day for 7 days per week. He comments that the LEAPS Project would not 

meet this definition and instead should be categorized under the default qualifying capacity criteria under 

section 40.13.2 of the CAISO tariff language. He questions whether any RMR value is ascribed to the 

LEAPS Project in the draft EIS. 

Response: We did not explicitly consider RMR benefits in conducting our benefits analysis. We noted 

that pumped storage includes many ancillary benefits and included both a higher energy cost during super 

peak hours and a dependable capacity benefit in our economic approach. We did review CAISO’s RMR 

units and note that PG&E’s Helms Pumped Storage Project units are included as RMR units.

Comment 269: Francis Hoffman, on behalf of the Elsinore Testing of Experimental Aircraft Mechanism, 

disagrees with Commission staff that sufficient costs for eminent domain are provided in the coapplicants’ proposal. Douglas Pinnow, Edith Stafford, and Linda and Martin Ridenour point out that 

Elsinore Valley MWD does not have the power of eminent domain to acquire property for the LEAPS 

Project as assumed in the draft EIS. Rather, Elsinore Valley MWD must acquire property by direct 

negotiation with each affected property owner in accordance with section 71663.5(d) in the California 

Water Code. Mr. Smith indicate that his parcel in the La Cresta area would need to taken by eminent 

domain should the project proceed and questions whether costs associated with eminent domain 

proceeding have been included in the cost estimates in the draft EIS. Pacific Clay states that the 

construction budget in the draft EIS is not large enough to have included costs for involuntary acquisition 

of the necessary properties. Edwin Thorell notes that measure 64, the acquisition of property though 

purchase of fee simple or through lease by voluntary sale, has a 0 cost in the measure table. He states that 

the failure to address the costs of property acquisition increases the cost of the project beyond the $931 

million construction cost indicated. 

Response: We have modified the cost associated with property acquisition and reflect those changes in 

section 4 of the final EIS. 

Comment 270: Francis Hoffman, on behalf of the Elsinore Testing of Experimental Aircraft Mechanism, 

states that there are no costs included to provide an alternative landing zone during construction. 

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Response: The co-applicants propose to provide funds for an appropriate landing zone if the 

Commission selected the Ortega Oaks powerhouse site. Both the co-applicants’ proposal and the staff 

recommended alternative would site the powerhouse at the Santa Rosa location. Construction of the 

underground powerhouse at the Santa Rosa location would not disrupt the continued use of the landing 

zone at Ortega Oaks. 

STAFF CONCLUSIONS 

Comment 271: Nevada Hydro comments that the staff conclusions on page 5-5 of the draft EIS that the 

co-applicants’ proposed transmission alignment could interfere with USFS fire suppression activities and 

that staff alternative mid-slope transmission line would avoid interference with USFS fire fighting 

suppression activities is a mischaracterization of the of the two alternatives. It points out that both 

alignments would traverse plant communities with similar fuel loading characteristics and that because 

the staff alternative mid-slope alignment is 1.2 miles longer, it would produce incrementally more effects. 

Further, Nevada Hydro requests the presence of beneficial impacts, such as the availability of an upper 

reservoir as a source of water for fire fighting as well as the additional potable water that the co-applicants 

would provide to the Rancho Capistrano area. 

Response: We have revised the staff alternative transmission alignment to include an underground 

segment in the vicinity of the launch sites and for the connection to the Santa Rosa powerhouse. The use 

of underground lines in these two locations reduces interference with fire suppression activities. 

Comment 272: Nevada Hydro notes that the draft EIS on page 3-189 states that recreational use during 

2001 within the Cleveland National Forest was estimated at 790,000 visits. It comments that in that 

context, with an estimated 500 users per year that it may not be accurate to state that hang gliding is a 

very popular activity in Lake Elsinore on page 5-32). 

Response: We agree that 500 hang gliding users per year is a small percentage of the overall visitation at 

Cleveland National Forest. However, we find that Lake Elsinore is a unique and popular destination for 

hang gliders. We have revised the text in section 5.2.8 to read that Lake Elsinore is a very popular and 

unique location for hang gliding. 

Comment 273: Nevada Hydro requests the factual documentation, other than the suggestion by Mike 

Hilberath, for the need for a 12-acre landing area. It points out that a 12-acre area would constitute 20 

percent of the 58-acre Ortega Oaks powerhouse site and request clarification of why a well-planned 5-

acre landing area, as now proposed by the co-applicants, would be inadequate. 

Response: We have revised the staff recommended alternative in the final EIS to include a powerhouse 

at the Santa Rosa location. Since the provision of the co-applicants’ 5-acre or the staff’s 12-acre landing 

site was tied to selection of the Ortega Oaks location for the powerhouse, we no longer include this 

measure in the staff alternative. 

Comment 274: Nevada Hydro disagrees with the staff conclusion on page 5-34 that co-applicants should 

provide O&M funding for developed sites if such funding is not available the intended sources. 

Response: Nevada Hydro proposed to provide recreational amenities as part of its proposed 

environmental measures for the licensing of the LEAPS Project. Therefore, O&M for ongoing 

maintenance of project-related recreational facilities would be appropriate. 

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Comment 275: Nevada Hydro disagrees with the staff conclusion on page 5-36 of the draft EIS that 

long-term monitoring, reporting, and changes are necessary provisions of the road and traffic 

management plan because there would only be limited number of employees once the construction period 

had ended. 

Response: We concluded in section 3.3.7.2 that operation of the project with its limited number of 

employees and limited recreational use would have minor effects on local traffic on Grand Avenue. We 

have revised section 5.6 of the final EIS to make clear our intention that the majority of effects on local 

roads would result from project construction activities. Therefore, the monitoring, reporting, and changes 

to the non- USFS road and traffic management plan be confined to the project construction period. We 

recommend that the co-applicants consult with USFS as part of the road and traffic management plan for 

USFS roads on responsibilities for post-construction road maintenance resulting any increase in projectrelated road use to access project-related recreational facilities. 

Comment 276: EPA recommends the final EIS describe the monitoring and reporting that would be 

required of the co-applicants, identify all terms and conditions of the FERC license related to the 

monitoring requirements, and discuss all implementation and effectiveness monitoring that would be 

conducted by the appropriate agencies.

Response: We have added text to section 5 of the final EIS to provide more guidance on the monitoring 

activities. 

Comment 277: SDG&E questions the conclusion that the TE/VS transmission line could provide 1,000 

MW of import capability into the San Diego area. SDG&E requests that the final EIS either cite studies 

that support the 1,000-MW increase in import capability or acknowledge the uncertainty surrounding this 

number and that a lower number would necessarily mean reduced benefits for customers. 

Response: We have reviewed the available system studies and acknowledge the uncertainty surrounding 

a 1000 MW increase in import capability. The final EIS now uses a value of 750 MW (testimony of L.P. 

Brown, Long-Term Resource Plan of SDG&E July 9, 2004) 

CUMULATIVE EFFECTS ANALYSIS 

Comment 278: The Center for Biological Diversity comments that the draft EIS does not include an 

adequate cumulative effects analysis on water, soil, and biological resources in the project planning area. 

Response: In response to your comment, we have added information about several other regional 

activities, including the Special Area Management Plan, to the appropriate Cumulative Effects sections. 

APPENDIX B 

Comment 279: Mr. Pinnow points out that the statement on page B-13 “A new 30-mile-long, 500-kV 

transmission line with an approximate 1,000 MW rating” is inconsistent with the capacity information 

shown graphically on page B-10 and with notice of the application that states that the TE/VS transmission 

line is to transmit and manage grid flow of approximately 1,600 MW of electricity. 

Response: We agree that the information on pages B-10 and B-13 is inconsistent. The LEAPS Project 

transmission line is being proposed as having a maximum thermal rating of 1,600 MW. This is the 

maximum power that can flow over the line due to the thermal limitations of the substation equipment 

associated with it and to the possibility of it violating National Electric Code (NEC) minimum ground 

clearances due to excessive conductor sag. A line’s rating is almost always higher than its expected 

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loading. We have revised the text on page B-13 to clarify that the proposed 32-mile 500 kV line has a 

1,600 MW rating. 

COMMENTS ON THE PUBLIC NOTICE OF OCTOBER 3, 2006 FOR THE REVISED 

PROPOSES AND STAFF ALTERNATIVE TRANSMISSION ALIGNMENTS 

On October 3, 2006, the Commission issued a public notice to landowners of property crossed by 

or near either the proposed or alternative routes for the transmission line and other interested parties to the 

proceeding. The maps attached to this notice showed two transmission alignments: (1) the co-applicants’ 

current proposal, modified in response to staff’s draft EIS and filed with the Commission on June 12, 

2006; and (2) the staff alternative alignment being considered for the final EIS. The notice invited 

comments within 30 days of the date of the letter. The following entities filed comments in reply to this 

public notice: 

Entity Date 

Roy Salameh October 11, 2006 

John and Vera Kalachian October 12, 2006 

Theordore and Katie Miller October 18, 2006 

San Bernardino Valley Audubon Society October 18, 2006 

John Willet October 23, 2006 

Christopher Wills October 25, 2006 

Michael Hilberath October 31, 2006 

Bryan Groth October 31, 2006 

Richard and Victoria Bogard October 31, 2006 

Fieldstone Communities November 1, 2006 

Sycamore Creek Homeowners Association November 1, 2006 

Harvey and Lucy Miles November 2, 2006 

Katy Miles November 2, 2006 

Orba Smith November 2, 2006 

Christopher Oates November 2, 2006 

Lois Nosporic November 2, 2006 

Matthew Miles November 2, 2006 

Sandra Weaver November 2, 2006 

Fernandez Parties November 2, 2006 

Jacqueline Ayer November 2, 2006 

James Diamond November 2, 2006 

Sharon West November 2, 2006 

Pacific Clay Products November 2, 2006 

Cheri Phelps November 3, 2006 

Sycamore Creek Marketplace, LLC November 3, 2006 

Center for Biological Diversity and Sierra Club November 3, 2006 

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Entity Date 

City of Lake Elsinore November 3, 2006 

County of Riverside November 3, 2006 

Bridgette Moore November 6, 2006 

Ellen Hazinski November 7, 2006 

John Hazinski November 7, 2006 

Marty Kreisler November 7, 2006 

Edwin Thorell November 7, 2006 

Michelle Randall November 8, 2006 

In additional 47 individuals file a form letter in opposition to the proposed transmission alignment 

expressing concerns about the proposed and alternative transmission lines will run along the border of the 

Glen Eden community. They cite the potential effect of the construction and operation of the line on the 

health and beauty of the Glen Eden Sun Club community. They state that the proposed transmission line 

will mar the landscape, run directly through a wildlife corridor, and destroy the area’s vegetation and 

wildlife. They also comment that the draft EIS makes no reference to the Glen Eden Sun Club 

community. Using the same form letter, another 20 individuals and the Sycamore Creek Homeowners 

Association expressed similar concerns about the effects of the proposed LEAPS Project transmission 

lines on the health and beauty of the Sycamore Creek community. 

We have summarized and responded to any new issues raised in the above letters. We have not 

summarized issued that have already been addressed in the responses to comments on the draft EIS. 

PROCEDURAL 

Comment 280: The Center for Biological Diversity comments on the co-applicants’ alternative 4(e) 

condition no. 5, indicating that the suggested new language concerning the co-applicants’ right to a 

hearing and to propose alternative 4(e) conditions is unnecessary as the applicable regulations already 

provide for this. 

Response: The USFS revised preliminary 4(e) condition no. 5 does not include the co-applicants’ 

suggested language. The revised USFS preliminary 4(e) conditions are found in appendix C to this final 

EIS. 

Comment 281: The Center for Biological Diversity and Sierra Club comment that the draft EIS does not 

include sufficient information to evaluate the environmental effects of placing the transmission line 

underground in the Cleveland National Forest. 

Response: We did not consider placing lines underground in the alternatives presented in the draft EIS. 

We eliminated the underground alternatives based on cost; therefore, we did not discuss the effects of 

placing the transmission lines underground construction on environmental resources. However, we 

disclose the effects of placing segments of the transmission alignments underground on the environmental 

resources in the final EIS. 

Comment 282: The Phillips Development Company reports that it did not receive notification of the 

modified transmission alignment even though its properties are within 0.25 mile of the proposed 

alternative alignments. According to Phillips Development Company, parcel number 125-120-38 as 

shown on the map included with the public notice is incorrect. The map should show two properties—

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125-120-38 on the west side and 125-120-37 on the east side—adjacent to parcel number 125-120-004. 

The new alignments would be in closer to private property owners with El Cariso Village. The Company 

is also concerned about the possibility of a 3,500-foot-wide Federal Energy Corridor that could allow 

more than just electrical transmission lines. 

Response: We obtained parcel information from the Elsinore Valley MWD and made a good faith effort 

to notify every property owner within 0.25 mile of the two transmission alignments being considered in 

the final EIS. The parcel information available to us did not show parcel 125-120-37. This proceeding is 

not considering the TE/VS Interconnect as a Federal Energy Corridor. 

Comment 283: Jacqueline Ayer comments that when transmission alignments are substantially relocated 

that the lead Federal agency is required to re-evaluate all of the environmental impacts. In the case of the 

TE/VS Interconnect a new analysis of land use impacts is warranted. She states that existing develop 

densities in areas such as El Cariso Village are as high as 5 dwelling units per acre, which, is 100 times 

more than the .05 dwelling units acre cited on page 3-273 of the draft EIS. 

Response: The effects of the new transmission alignments on land use and other environmental resources 

are disclosed in the final EIS. Our characterization of densities ranging from 5- to 20-acre minimum lot 

size in the rural areas in the draft EIS is correct; however we have added language to section 3.3.7.2 of the 

final EIS to indicate that some of these areas, such as El Cariso Village, may be rezoned for development 

at much great densities. Nowhere in the draft EIS do we cite .05 dwellings per acres in rural areas

Comment 284: Ms. Ayer comments that the potential effect of the new transmission alignments would 

be devastating to property values and that the draft EIS trivializes property value impacts. 

Response: We provide considerable discussion in section 3.3.8.2 of the draft and final EIS about the 

affects of transmission lines on property values, citing numerous studies on the potential effect of 

transmission lines on property values. 

Comment 285: Ms. Ayer states that the NEPA analysis is improperly deferred commenting that the 

deferral of specific plans to address environmental impacts is inconsistent with NEPA requirements. For 

instance, she notes that traffic concerns would be addressed in the traffic and management control plan 

that would be developed after the project is licensed. She also states that the co-applicants are 

sidestepping any obligation to mitigate impacts to local roads during project construction. 

Response: With regard to traffic impacts, the traffic and management control plan would be developed 

prior to construction and would be implemented before the construction and operation of the project. 

This plan would be developed in consultation with the appropriate local agencies and would address the 

co-applicants' obligations for pavement repair during and following construction. Our responses to 

comments 3 through 13 above address concerns about the statement of purpose and need in the EIS. 

Comment 286: Ms. Ayer comments that contrary to the statement in section 2 of the draft EIS the 

pumped storage project would depend on fossil fuels. 

Response: We agree that the pumped storage project would depend on fossil fuels unless the coapplicants are successful in obtaining power sales agreements for geothermal, wind, or other non-fossil 

based sources of energy and have revised the text in section 2 of the final EIS accordingly. 

Comment 287: Ms. Ayer comments that the draft EIS insists that the LEAPS Project and TE/SV 

Interconnect are stand alone projects and that the draft EIS focuses on the LEAPS Project and does not 

address the TE/SV Interconnect in any substantial detail. 

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Response: We consider the LEAPS Project to consist of the co-applicants’ proposal for a pumped 

storage facility and associated transmission lines. The draft and final EIS disclose the effects of the 

proposed and alternative project configurations including the effects of the proposed 32 miles of 

transmission lines on environmental resources. We note that a substantial amount of the analysis in the 

EIS pertains to ground-disturbing activities, land use, and aesthetics associated with the construction and 

operation of the transmission line. An effect analysis for the co-applicants’ and staff alternative 

transmission alignments is carried through each environmental resource area addressed in the EIS. 

Comment 288: Ms. Ayers comments that the draft EIS fails to identify reasonably foreseeable 

cumulative effects associated with the potential designation of a 3,500-foot-wide TE/SV corridor as a 

Federal Energy Corridor under the Energy Policy Act of 2005. 

Response: The Commission has not taken any action on the designation of the TE/SV line corridor and 

we have no action against which to evaluate cumulative effects. 

Comment 289: Ms. Ayer raises numerous other issues about the scope and adequacy of the draft EIS 

including her views that the no-project (action) analysis is flawed and the final EIS should consider 

additional no-action alternatives, that the discussion of FERC’s licensing authority is faulty, that Elsinore 

Valley MWD does not have eminent domain authority, and that the economics of the new alignments are 

not justified. 

Response: As discussed in response to comment 53 above, the draft and final EIS include a sufficient 

level of detail to assess the potential effects of the proposed project on environmental resources in the 

project area. We address eminent domain authority in our response to comment 50 above. In appendix 

B, we address previous studies of proposed transmission systems in southern California and note that 

these studies do not address some of the strategic benefits (reliability, load diversity, fuel diversity, access 

to lower cost power plants, firm power purchase, economy energy and surplus hydropower purchases, 

power exchange, and reserve sharing) which could improve the economics of an interconnection project, 

especially when combined with pumped storage capacity. We continue to conclude that the power from 

the LEAPS Project would be useful in meeting part of the regional need for on-peak power and that the 

TV/SE Interconnect Project would be an appropriate long-term solution to southern California’s 

transmission congestion and transmission-constrained, generation-deficient San Diego area. 

LAND USE 

Comment 290: The Center for Biological Diversity and the Fernandez Parties comment that the 

September 2006 decision in the California v. U.S. Department of Agriculture (N.D. Ca. Case No. C05-

03508 EDL) reinstated the Roadless Area Conservation Rule (66 FR 3,244 (January 12, 2001). This rule 

disallows any road construction and reconstruction, subject to certain limited exceptions, in Inventoried 

Roadless Areas. This would apply to the Wildhorse/Morrell Inventoried Roadless Area and this must be 

disclosed in the final EIS. 

Response: As noted in our response to comment 210, according to the current Cleveland National Forest 

Land Management Plan, the areas of the forest where Morrell and Decker reservoirs are proposed is 

designated as an Inventoried Roadless Area that allows consideration for road construction or 

reconstruction. Contrary to the Center for Biological Diversity’s claims, the Final Land Management 

Plan does not specify a Wildhorse Inventoried Roadless Area. Therefore the cited court decision does not 

apply. 

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Comment 291: Mr. and Mrs. Hazinski and Mr. Kreisler, residents of Horsethief Canyon, comment that 

the proposed transmission line would cross Temescal Valley, west of Horsethief Canyon, over and 

adjacent to proposed residential projects recreation areas, and a shopping center on the Sycamore Creek 

property. They had been led to believe that any project transmission lines located within one mile of 

residential communities would be underground. They specifically recommend that the transmission line 

be placed underground for about 2 miles between parcel #391210014 extending north under Interstate 15 

and the proposed northern substation. Ms. Randall objects to the placement of above ground transmission 

lines. She recommends placing the line underground between the Glen Eden Sun Club and the planned 

Sycamore Creek residential community and asks that costs associated with an additional 2-mile 

underground segment in this area be included in the final EIS. The Sycamore Creek Marketplace, LLC, 

objects to the location of the co-applicants’ proposed and staff alternative transmission alignments due the 

proximity to a planned residential developments. The owner request the location of the proposed 

transmission line be a minimum of one mile away from the boundary of the Sycamore Creek development 

and that the towers be at least one and one half miles away from the Sycamore Creek property. The 

Fernandez Parties, Orba Smith and numerous other individuals continue to oppose the project and also 

request consideration of additional underground segments in areas near residential developments. 

Response: The co-applicants do not propose to place transmission lines underground within 1 mile of 

residential communities. The draft EIS considered but eliminated from detailed study installation of 

underground lines based on costs. In the final EIS, both the co-applicants’ proposed transmission 

alignment and the staff alternative transmission alignment include underground segments in the vicinity 

of the launch areas along South Main Divide Road and the powerhouse. We include the costs associated 

with additional underground segments in the final EIS. 

Comment 292: Mr. Hazinski reports that the co-applicants’ modified transmission alignment ensures 

that the line would not be built within a mile of the Horsethief Canyon community north of the city. He 

states that the Elsinore Valley MWD secured a guarantee from Nevada Hydro that if it were to go within 

a mile of the community, that section would go underground (The Californian, October 5, 2006). He 

comments that this discriminates against landowners with private wells outside of the water district. He 

suggests that a more appropriate route would be along Lake Street and Temescal Canyon Road 

Response: The license application and subsequent filings by the co-applicants made no reference to a 

commitment made by either applicant to place transmission lines underground within 1 mile of the 

Horsethief Canyon community. We have considered the environmental effects of the proposed 

transmission line relative to all parcels regardless of whether they are located within or outside of the 

water district’s jurisdiction. 

Comment 293: The city of Lake Elsinore and Pacific Clay products state that on balance the coapplicants’ modified transmission alignment is preferred because it results in lesser visual impacts on the 

Lake Elsinore community and adjacent residents, but the city would also support the staff alternative 

transmission alignment as long as the underground segment to the powerhouse is included. 

Response: In the final EIS, we include the underground segment from the vicinity of South Main Divide 

Road to the powerhouse in the staff alternative transmission alignment. 

Comment 294: The San Bernardino Valley Audubon Society indicates that while putting the entire 

transmission line underground would protect raptors it would also foster the growth of non-native plants. 

It comments that the notice implies that Morrell Canyon has been selected over Decker Canyon. 

Response: The maps included with the notice for the two transmission lines being considered for 

discussion in the final EIS contain legends that show underground segments of several miles. We do not 

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propose to place the entire 32-mile transmission line underground. We note that the staff alternative in 

the final EIS still includes an upper reservoir at Decker Canyon. 

Comment 295: The Fieldstone Company states that it did not comment on the LEAPS Project before 

because it recognizes the need for growth must be balance with the imperative for safe and 

environmentally sound energy. Fieldstone recommends that the Commission reconsider the mid-slope 

alternative as being more environmentally sensitive than the modified staff alternative and having the 

least impact to existing residential developments. Fieldstone comments that the draft EIS failed to review 

the contents of the County of Riverside General Plan, which would be greatly impacted by the coapplicants’ modified transmission and the two alignments being considering for the final EIS. Fieldstone 

comments that only the mid-slope alignment avoids the impacts to approved residential communities. 

Response: We have reviewed the merits of the mid-slope transmission alignment and concluded that its 

close proximity to private properties, including two large residential developments in Horsethief Canyon 

and interference with hang gliding activities created more adverse effects than the revised staff alternative 

alignment. We did review the County of Riverside General Plan in the draft EIS and reviewed it in 

relation to the revised staff alternative alignment in the final EIS and conclude that the our revised 

alternative would have less effect overall on residential communities and would significantly reduce 

effects on hang gliding activities at Lake Elsinore. 

Comment 296: Fieldstone states that the draft EIS omits consideration of the Riverside Multi-Species 

Habitat Conservation Plan approved by the FWS. It comments that the northern segment of the coapplicants’ alignment and the new alignments would adversely impact a significant wildlife corridor. 

Response: We addressed, in section 3.3.4.2 of the draft EIS, the potential effects of the proposed project 

of wildlife corridors identified in the Western Riverside County Multi-Species Habitat Conservation Plan. 

Individuals who filed letters in response to the draft EIS and public notice of October 3, 2006: 

Christopher A. Wills, M.D. March 1, 2006 

Elsinore Hang Gliding Association March 20, 2006 

Linda Hale March 27, 2006 

James Provenzano March 28, 2006 

J. Capozzelli April 12, 2006 

Alan L. White April 12, 2006 

Susan Frommer April 12, 2006 

Risser C. Estes April 18, 2006 

Gregory Angsten April 18, 2006 

Jim Shaw April 18, 2006 

Frederick T. Pishotta April 18, 2006 

Dora D. Labellarti April 18, 2006 

Devonne L. Fisher April 18, 2006 

Dennis R. Fisher April 18, 2006 

Lynice Spangler April 18, 2006 

Karen Gilbert April 19, 2006 

Doris J. Singleterry April 19, 2006 

Saul L. Frommer April 19, 2006 

Fred Blaskovich April 19, 2006 

Charles & Yolanda Hoelscher April 19, 2006 

Allyn Cooksey April 19, 2006 

Hansen Family April 19, 2006 

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Joan H. Adkins April 19, 2006 

Debbie & Raymond Badham April 19, 2006 

Eric Gilbert April 20, 2006 

Tom Hazelleaf April 20, 2006 

United States Hang Gliding Association April 20, 2006 

Bret M. Daniel April 20, 2006 

John W. Kirk April 20, 2006 

Kriss Larson April 20, 2006 

Bernard M. Lipman April 20, 2006 

James Gaar April 21, 2006 

Bud Mathurin April 24, 2006 

James Flack April 24, 2006 

Eric Gilbert April 24, 2006 

Elsinore Hang Gliding Association April 24, 2006 

Lynn Perry April 24, 2006 

Peter J. & Tina M. Cutuli April 24, 2006 

Martin Kreisler April 24, 2006 

Vance Litchfield April 24, 2006 

Jim Appleby, Sr. April 24, 2006 

Harold Burgess April 24, 2006 

Mitch Frisch April 24, 2006 

Gena Osborne April 24, 2006 

Jeff & Irene Johnson April 24, 2006 

Dawn Swett April 24, 2006 

Anna Marx April 24, 2006 

Susan Cash April 24, 2006 

Karen Snyder April 24, 2006 

Jorgen Moller April 24, 2006 

Patricia Barnes April 24, 2006 

Melody Barnett & Family April 24, 2006 

Dia Peters April 24, 2006 

Linda Nielsen April 24, 2006 

Elizabeth L. Bostian April 25, 2006 

Ray Stinnett April 25, 2006 

Mike Harper April 25, 2006 

Sierra Club, San Diego Chapter, Forest & Wilderness Committee April 25, 2006 

C&C Parties April 25, 2006 

Doug Koch April 25, 2006 

Asher Chapman April 25, 2006 

Michael Estrada April 25, 2006 

Wilmer I. Rohr. IV April 25, 2006 

Mark Mallett April 25, 2006 

John Pitt April 25, 2006 

Robert Carmichael April 25, 2006 

James Wood April 25, 2006 

David W. Biddle April 25, 2006 

Marc Johnson April 25, 2006 

John C. Mulyana April 25, 2006 

John Heiney April 25, 2006 

Brian Dahl April 25, 2006 

David Freman April 25, 2006 

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Erik Delf April 25, 2006 

LaCresta Development April 26, 2006 

Kelly Smith, Keller Williams Realty April 26, 2006 

Richard Nakai April 26, 2006 

Melanie Parker and 199 Other Individuals April 26, 2006 

Jo Ann McCracken April 26, 2006 

Marianne & Gerald Cline April 26, 2006 

Patrick & Camilla Davenport April 26, 2006 

Patricia Barnes April 26, 2006 

Linda & Scott Pyle April 26, 2006 

Kathleen Dickey April 26, 2006 

Craig A. Sherman, Esq. April 26, 2006 

Michael Gordon April 26, 2006 

Gordon Kane April 26, 2006 

Albert Temmins April 26, 2006 

Dennis Keith April 26, 2006 

Laurra Maddock April 26, 2006 

Janet Maker April 26, 2006 

Paget Reid April 26, 2006 

Dan Abrams April 26, 2006 

Bill Holmes April 26, 2006 

Jerry Hughes April 26, 2006 

Robert Rocco April 26, 2006 

Casey Hudson April 26, 2006 

Christopher & Mary Louise Muller April 26, 2006 

Philip Glaser, D.D.S. April 26, 2006 

Jennifer Cochrane-Schultz April 26, 2006 

Mikko Helenius, M.D. April 26, 2006 

Brook Bryant April 26, 2006 

Scott Quinnell April 26, 2006 

C. Mollie Bigger, Ph.D. April 26, 2006 

Sharon Connor April 26, 2006 

Karen Thordarson April 26, 2006 

Patricia Bleha April 26, 2006 

Mark Gauthier April 26, 2006 

Mark Sorensen April 26, 2006 

Stephanie Adams April 26, 2006 

Ellen L. Trumpler April 26, 2006 

Claire Frogman April 26, 2006 

Nira Trock April 26, 2006 

Tessa Kershnar April 26, 2006 

Don Bremmer April 26, 2006 

Brittany McKee April 26, 2006 

H.E. Kershnar April 26, 2006 

Phyllis Watson April 26, 2006 

Lisa R. Marks April 26, 2006 

Marni Majda April 26, 2006 

Samam Dabin April 26, 2006 

Melissa Weyek April 26, 2006 

Barbara Meyer April 26, 2006 

Eugene St. Laurent April 26, 2006 

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Jason Hashimoto April 26, 2006 

Lynn Fleischer April 26, 2006 

Stephen E. Rudolph April 26, 2006 

Melba Simms April 26, 2006 

Theresa Brady April 26, 2006 

Dorothy Boberg April 26, 2006 

Betty Schnaar April 26, 2006 

Willis Simms April 26, 2006 

J. Water April 26, 2006 

Michael Stevenson April 26, 2006 

Barry Katzen April 26, 2006 

Julie R. Szende April 26, 2006 

Randy Steinberg April 26, 2006 

Elizabeth G. McMahon April 26, 2006 

John M. Rountree April 26, 2006 

Linda Kleer April 26, 2006 

Jeff Fromberg April 26, 2006 

Clif Potts April 26, 2006 

Barbara & Jacob Rubin April 26, 2006 

Michael Karp April 26, 2006 

Mark Carrow April 26, 2006 

Barbara Gable April 26, 2006 

Trish Tuley April 26, 2006 

Joan Weaver April 26, 2006 

Sierra Club, San Gorgonio Chapter April 26, 2006 

Irene Dunny April 26, 2006 

Lori Kessler April 26, 2006 

Debby McAllister April 26, 2006 

Jim McKnight April 26, 2006 

Ralph Bocchetti April 26, 2006 

Jane Affonso April 26, 2006 

Martha Hess April 26, 2006 

Kyle Daniels April 26, 2006 

Lori Whalen April 26, 2006 

Angela M. Woodcock April 26, 2006 

Guy L. Kirkpatrick April 26, 2006 

Ned Boyer April 26, 2006 

Lynne Jeffries April 26, 2006 

Stacy Brady April 26, 2006 

Gregg Oelker April 26, 2006 

Cathy Sellitto April 26, 2006 

Shirley Ann Szalkowski April 26, 2006 

Thomas & Beatriz Ferguson April 26, 2006 

Adrienne Kligman April 26, 2006 

Andrew Sutphin April 26, 2006 

Robin & Tony Applegarth April 26, 2006 

Kris Ockershauser April 26, 2006 

Mark Watt April 26, 2006 

Ed Amador April 26, 2006 

Susan Shields April 26, 2006 

Andrew Reich April 26, 2006 

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Sharon Wright April 26, 2006 

Johanna E. Howard April 26, 2006 

Andrea & Charles Sims April 27, 2006 

Donna Gould April 27, 2006 

Garry & Cheryl Chaban April 27, 2006 

David Perlman April 27, 2006 

Paul Carlton April 27, 2006 

Tom Randel April 27, 2006 

Donald R. Gates April 27, 2006 

Julie A. Gates April 27, 2006 

J.D. & Shirley Sooter April 27, 2006 

Lake Elsinore Soaring Club April 27, 2006 

Eileen R. Baldwin April 27, 2006 

Shawn Rogers April 27, 2006 

House Family April 27, 2006 

Edward & Gert La Faso April 27, 2006 

Damien Schlitt April 27, 2006 

Peter H. Dawson April 27, 2006 

Jane Rice & over 400 Other Individuals of the Sierra Club April 27, 2006 

Debbie Chaddock April 28, 2006 

Kim F. Floyd April 28, 2006 

Susan B., Kay, M.D. April 28, 2006 

Chris Warren April 28, 2006 

Rev. Michael Agliardo, SJ April 28, 2006 

Nolan Farkas April 28, 2006 

Ed Van den Bossche April 28, 2006 

Karen Horn April 28, 2006 

Angeles Chapter, Sierra Club April 28, 2006 

Gary W. Feemster April 28, 2006 

Gabriele Rau April 28, 2006 

Darryl Mar April 28, 2006 

Gabi Dendinger April 28, 2006 

Charles L. Polep April 28, 2006 

Walid Soussou April 28, 2006 

Albert A. Rossi April 28, 2006 

Len Gardner April 28, 2006 

Carolyn Olney April 28, 2006 

Yvetta Williams April 28, 2006 

Greg Bell April 28, 2006 

Cynthia Tuell April 28, 2006 

Lynda Warren April 28, 2006 

Ann McKibben April 28, 2006 

Ann Cantrell April 28, 2006 

Dorrit Ragosine April 28, 2006 

Theresa Brady April 28, 2006 

Ralph Bocchetti April 28, 2006 

David A. Miller April 28, 2006 

Rev. Sarah I. Gibb April 28, 2006 

Bob Faulkner April 28, 2006 

Dr. Lyle C. Henry April 28, 2006 

Tom Hazelleaf April 28, 2006 

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Dr. Jack Paxton April 28, 2006 

Kris Ockershauser April 28, 2006 

Jeanette McKinley April 28, 2006 

Ruth Hall April 28, 2006 

Dr. W.D. Botch April 28, 2006 

Marlene L. Brown April 28, 2006 

Steven C. Huskey, Esquire April 28, 2006 

Valerie Zachary April 28, 2006 

Sue Kuramoto April 28, 2006 

Gary Hoover April 28, 2006 

Richard Sanders April 28, 2006 

Kenneth N. Howard May 1, 2006 

Dawn Swett May 3, 2006 

Elizabeth L. Bostian May 3, 2006 

Craig Perkins May 3, 2006 

David Perlman May 3, 2006 

Katharine Gring May 3, 2006 

Stephanie Remington May 3, 2006 

Jim Cokas May 3, 2006 

Van Collinsworth May 3, 2006 

Charles David Stout, Ph.D. May 3, 2006 

Mary Ann Kiger May 3, 2006 

Merri B. Levy May 3, 2006 

Rick Farber May 8, 2006 

Don Bremner May 8, 2006 

Robert Ives May 8, 2006 

Jose Henriquez May 8, 2006 

Erik Counseller May 8, 2006 

Inland Empire Waterkeeper May 31, 2006 

US Fish and Wildlife Service June 21, 2006 

USDA-FS PSW Region June 23, 2006 

Elsinore Valley Municipal Water District July 6, 2006 

State Senator Dennis Hollingsworth and Ray Haynes, 

 Assemblyman, 66th District August 2, 2006 

John Pecora September 6, 2006 

Chris Hyland, Doug Pinnow, and John Lloyd September 14, 2006 

Jay Scott October 2, 2006 

Elsinore Valley Municipal Water District October 30, 2006 

Roxanne Salazar October 31, 2006 

Edna Vallecillo Garcia & Family October 31, 2006 

C & C Parties November 2, 2006 

Louise Hurt November 2, 2006 

Eleanor Haile November 2, 2006 

Jenny Flack November 2, 2006 

Gary Nazaroff November 2, 2006 

Dr. Lisa White November 2, 2006 

Tom Saldana November 2, 2006 

Anne Clendinning November 2, 2006 

Margaret Buttner November 2, 2006 

Erlene Kuentzler November 2, 2006 

Harvey Ailport November 2, 2006 

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Ruth Sizemore November 2, 2006 

Ed Littlewort November 2, 2006 

David Gilmore November 2, 2006 

Sherrie Fabian November 2, 2006 

Robert Lemke November 2, 2006 

Heath Friedman and Family November 3, 2006 

Linda Sulkamer November 7, 2006 

Reginald & Aleta Thompson November 7, 2006 

Ben Gradias November 7, 2006 

Krista Bradias November 7, 2006 

Mila Escano November 7, 2006 

Debra Nisporic November 7, 2006 

Josh Miles November 7, 2006 

Bryan Groth November 7, 2006 

John Sheppard November 7, 2006 

David Clarkson November 7, 2006 

Vicki Rembock November 7, 2006 

Minervia Nisporic November 7, 2006 

Justin Merkys November 7, 2006 

Gloria Carrillo November 7, 2006 

Robert & Jackie Albaugh November 7, 2006 

Donna Parrish November 7, 2006 

Victoria Bobard November 7, 2006 

Jeremy Marsh November 7, 2006 

Clara Bernice Sheppard November 7, 2006 

Pam Harris November 8, 2006 

Anne Rendeiro November 8, 2006 

Mike Mrak November 8, 2006 

David Rendeiro November 8, 2006 

Gregory S. Brintle November 8, 2006 

Marlene L. Brintle November 8, 2006 

Kent Carlsen November 8, 2006 

Alolen W. Brumbaugh November 8, 2006 

Lucy Mikj November 8, 2006 

Richard Bogert November 8, 2006 

Gary Goldberger November 8, 2006 

David Leal November 9, 2006 

Dawn R. Carrozzo November 9, 2006 

Fred L. Carrozzo November 9, 2006 

Lois Perez November 9, 2006 

Patsy & Robert Duchesne November 9, 2006 

Yvonne Valasek November 9, 2006 

Jon Basel November 9, 2006 

Peter & Janice Daniello November 9, 2006 

Dale & Carol Hook November 9, 2006 

Eldon H. Gloor November 9, 2006 

Sherrie Fabian November 9, 2006 

JoAnn Brown November 9, 2006 

David Gross November 9, 2006 

Sharon Seidman November 9, 2006 

Ross Edmonds November 9, 2006 

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Peggy M. O’Donnell November 9, 2006 

Michael P. Johns November 9, 2006 

Shirley Gross November 9, 2006 

Linda Farley November 9, 2006 

John Farley November 9, 2006 

Carmen D. Calco November 9, 2006 

Gerry Stevenson November 9, 2006 

James C. Zack November 9, 2006 

Joalene Rollison November 9, 2006 

Larry Barnett November 9, 2006 

Laurie Fitzgerrell November 9, 2006 

Robert Hills November 9, 2006 

Regina Zasadzuvusju November 9, 2006 

Nancy Leefe November 9, 2006 

Heidi Dietschi November 9, 2006 

William B. Crosman November 9, 2006 

Brian G. Cleary November 9, 2006 

Wendy J. Crosman November 9, 2006 

Norman Gundenheim November 9, 2006 

Susan Troxler November 20, 2006 

Kathy A. Pierce December 14, 2006 

Document Accession #: 20070130-4000 Filed Date: 01/30/2007
COVER SHEET 

FEDERAL ENERGY REGULATORY COMMISSION 

FINAL ENVIRONMENTAL IMPACT STATEMENT 

FOR HYDROPOWER LICENSE 

Lake Elsinore Advanced Pumped Storage Project 

Docket No. P-11858-002 

Appendix F 

Maps of the Co-applicants’ Proposed and Staff Alternative 

Transmission Alignment 

Tiles 1 through 4 

FEIS 

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APPENDIX F 

Maps of the Co-applicants’ Proposed and Staff Transmission Alignments 

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Document Accession #: 20070130-4000 Filed Date: 01/30/2007
Document Accession #: 20070130-4000 Filed Date: 01/30/2007
Document Accession #: 20070130-4000 Filed Date: 01/30/2007
COVER SHEET 

FEDERAL ENERGY REGULATORY COMMISSION 

FINAL ENVIRONMENTAL IMPACT STATEMENT 

FOR HYDROPOWER LICENSE 

Lake Elsinore Advanced Pumped Storage Project 

Docket No. P-11858-002 

Appendix G 

Management Indicator Species (MIS) Analysis 

Pages G-1 to G-12 

FEIS 

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APPENDIX G 

Management Indicator Species Analysis 

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APPENDIX G 

MANAGEMENT INDICATOR SPECIES ANALYSIS 

1. INTRODUCTION 

The purpose of this assessment is to evaluate the effects of the Lake Elsinore Advanced Pumped 

Storage Project (LEAPS Project) on Management Indicator Species (MIS) identified in the Land 

Management Plan (LMP) for the southern California forests (USFS, 2005a). 

2. PROJECT DESCRIPTION 

In February, 2004, the Elsinore Valley Municipal Water District (Elsinore Valley MWD) and the 

Nevada Hydro Company, Inc. (Nevada Hydro), or co-applicants, filed an application for an original 

license with the Federal Energy Regulatory Commission (Commission or FERC) for the construction and 

operation of a 500-MW pumped storage project. The project would use Lake Elsinore as a lower 

reservoir, and would require construction of an upper reservoir within the boundaries of the Cleveland 

National Forest. The project, including an approximately 30-mile-long transmission line, would occupy 

about 2,412 acres of federal lands, including National Forest System lands. The co-applicants filed a 

special use permit application for the TE/VS Interconnect Project with the U.S. Forest Service (USFS) in 

July 2003. Under the Federal Land Policy and Management Act, the USFS must decide whether to grant 

an easement for rights of way over, across, and upon National Forest System lands for electrical poles and 

lines for the transmission and distribution of electrical power. 

The proposed action consists of an upper reservoir in Morrell Canyon, a powerhouse at the Santa 

Rosa location, and a transmission line that crosses the Cleveland National Forest. The staff alternative 

consists of an upper reservoir at the Decker Canyon site, a powerhouse at the Santa Rosa location, and a 

transmission line with an alignment similar to the proposed route. For a detailed description of the 

proposed action and the staff alternative and maps of the project area, refer to the LEAPS Project final 

environmental impact statement (final EIS). 

3. MIS SELECTED FOR THE PROJECT 

Table G-1 shows the MIS selected for the four southern California forests, what each is intended 

to represent, and whether they occur in the LEAPS Project area. As shown in the table, blue oak, 

Englemann oak, valley oak, bigcone Douglas-fir, Coulter pine, California black oak and white fir do not 

occur in the project area. The remaining five MIS (mountain lion, mule deer, arroyo toad, song sparrow 

and California spotted owl) are relevant to the LEAPS Project, and could be affected by construction and 

operation. 

Table G-1. Management Indicator Species selected for the four southern California forests. 

Species Indicators of Management Relevance to LEAPS Project 

Mountain lion Fragmentation Known to occur in the project area 

Mule deer Healthy, diverse habitats Known to occur in the project area 

Arroyo toad Aquatic habitat Potential habitat in the project area, but 

not documented to occur 

Song sparrow Riparian habitat Known to occur in the project area 

California spotted owl Montane conifer forest Known to occur near the project area 

Blue oak Oak regeneration Does not occur in the project area 

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G-2 

Species Indicators of Management Relevance to LEAPS Project 

Engelmann oak Oak regeneration Does not occur in the project area 

Valley oak Oak regeneration Does not occur in the project area 

Bigcone Douglas-fir Bigcone Douglas fir forest Does not occur in the project area 

Coulter pine Coulter pine forest Does not occur in the project area 

California black oak California black oak forest Does not occur in the project area 

White fir Montane conifer forest Does not occur in the project area 

In the following sections, we summarize the environmental baseline and potential environmental 

effects of the LEAPS Project on MIS. Most of the baseline information is taken from species accounts 

that were developed to provide technical support for the LMP (USFS, 2005b). Detailed information 

about the environmental baseline for each species (general distribution, distribution in the national forests 

of southern California, natural history, population and /or habitat status and trends on National Forest 

System lands, predicted viability outcomes, and threats and conservation considerations) is available online in the “reading room” associated with the LMP (USFS, 2006b). 

For each species, the discussion of environmental effects focuses on project elements that would 

be located on National Forest System lands. The FEIS for the LEAPS Project contains additional analysis 

about potential effects within the broader project area, which also includes non-National Forest System 

lands. Section 3.3.4.2, Terrestrial Resources, of the final EIS discusses effects on mountain lion, mule 

deer, song sparrow and California spotted owl. Section 3.3.5.2, Threatened and Endangered Species, 

addresses effects on the arroyo toad. 

4. MIS ENVIRONMENTAL BASELINE AND ENVIRONMENTAL EFFECTS 

4.1 Mountain Lion 

The Cleveland National Forest chose the mountain lion as an MIS to evaluate planning and 

management of habitat fragmentation and habitat linkages (USFS, 2005a). The USFS management goal 

for this species is to ensure functional landscape linkages and ensure the population is well-distributed. 

4.1.1 Environmental Baseline 

Mountain lions are habitat generalists, inhabiting a variety of habitat types throughout California. 

They use any area with predominantly native, woody vegetation; ample prey (especially mule deer); and 

low density of human inhabitants (Dickson et al., 2005). They are rare at higher elevations in pure stands 

of conifers and at lower elevations in pure stands of chamise chaparral. 

While mountain lions may be thriving in some areas of northern California, they are considered 

imperiled in some of southern California's highly fragmented wildlands (Stephenson and Calcarone 

1999). Beier (1991) estimates a population of about 20 mountain lions in the Santa Ana Mountains of the 

Cleveland National Forest. This population is isolated as a result of habitat fragmentation, and is likely to 

be extirpated unless adequate movement corridors are established and protected between the Santa Anas 

and the Palomar Range to the east. 

A 5-year study of mountain lions in the Santa Ana Mountains showed that two animals occupied 

home ranges that included sites where LEAPS Project features would be constructed (Beier and Barrett, 

1993). One of these animals (a young male) was documented several times in upper Morrell Canyon. 

Radio-tracking of both this individual and one other mountain lion (an adult female) showed frequent 

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movements near the northern segment of the proposed transmission alignment route, parallel with the 

ridgeline (a northwest-southeast orientation). 

4.1.2 Environmental Effects 

Effects of the Proposed Action on Mountain Lion Habitat 

Construction of an upper reservoir at Morrell Canyon would temporarily disturb about 140 acres 

of suitable mountain lion habitat and convert about 100 acres, including 20 acres of riparian oak 

woodland, to project use. The reservoir would be located on top of Lion Spring. Water from the upper 

drainage area would be collected and conveyed under the reservoir, and returned to the creek downstream 

of the dam. 

Construction would affect about 0.25 acre at each of 85 transmission tower sites, and would 

convert about 21.25 acres of suitable mountain lion habitat to project use. Some temporary access roads 

would be constructed, and then obliterated and revegetated, but many of the towers would be installed 

using helicopters to avoid road construction on steep slopes. Locations of any access roads that may be 

constructed are not known at this point in the design process. 

Construction of the underground transmission line segment would temporarily disturb about 

23.2 acres within suitable mountain lion habitat, and convert about 5.8 acres to permanent maintenance 

road. 

Noise disturbance would occur during construction. Maintenance activities during project 

operation would cause localized disturbance at the reservoir site, but disturbance levels would not be 

substantially greater than those that occur under existing conditions along the South Main Divide Road 

and Morgan Trail. The co-applicants would use helicopters to maintain the transmission line, which 

would cause temporary, localized disturbance. 

Effects of the Staff Alternative on Mountain Lion Habitat 

Construction of an upper reservoir at Decker Canyon would temporarily disturb about 140 acres 

of suitable habitat, and convert about 100 acres, including 5 acres of riparian oak woodland, to project 

use. No springs or seeps would be affected by construction, and no water conveyance system is thought 

to be necessary. 

Construction would affect about 0.25 acre at each of an estimated 85 transmission tower sites and 

would convert about 21.25 acres to project use. The southern segment of the alternative alignment is 

located east of the proposed alignment and closer to the edge of the National Forest System boundary 

over several miles of the route, or follows immediately along the edge of the National Forest System 

boundary. Any temporary access roads needed for this alignment would presumably also be closer to the 

edge of the National Forest System boundary. Many of the towers would be installed using helicopters to 

avoid road construction on steep slopes. Locations of any access roads that may be constructed are not 

known at this point in the design process. 

Construction of the underground transmission line segment would temporarily disturb about 

15.1 acres within suitable mountain lion habitat, and convert about 3.4 acres to permanent maintenance 

road. 

Noise disturbance would occur during construction. Maintenance activities during project 

operation would cause localized disturbance at the reservoir site. Disturbance levels would be slightly 

greater than those that occur under existing conditions along the South Main Divide Road, because 

construction would occur at a site that does not support any recreation activity. The co-applicants would 

use helicopters to maintain the transmission line, which would cause temporary, localized disturbance. 

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Effects on Mountain Lion Habitat and/or Population Trends 

Construction of either project alternative would contribute to the downward trend in habitat 

availability for mountain lions in southern California, and would likely contribute to downward 

population trends for this species in the Santa Ana Mountains. Effects associated with Morrell Canyon 

would be more substantial than those that would occur at Decker Canyon, due to the loss of more oak 

woodland. Based on radio-tracking studies (Beier and Barrett, 1993), upper Morrell Canyon (and Lion 

Spring) may provide an important habitat element for mountain lions. Lion Spring may also be important 

for mule deer, their primary prey. 

The transmission line itself would not likely block mountain lion movement or interfere with 

existing or proposed linkages, because transmission towers typically would be spaced at intervals of 

1,000 to over 1,700 feet, and vegetation would not be removed beneath the line, except as needed for fuel 

management during project operation. The staff alternative alignment is closer to the edge of the National 

Forest System boundary, and intrudes less into mountain lion habitat. Access roads would also likely 

intrude less into mountain lion habitat under the staff alternative alignment. For this reason, the staff 

alternative transmission alignment should have less effect on mountain lion habitat or population trends. 

Permanent maintenance or temporary access roads would not likely block mountain lion 

movement, since mountain lions often travel along lightly used dirt roads, but would increase the risk of 

disturbance (including illegal harvest) and damage to habitat, if public access is not controlled. 

Implementation of weed management and road management plans would reduce the potential for adverse 

effects. 

4.2 Mule Deer 

The Cleveland National Forest uses mule deer as an indicator of healthy, diverse habitats with 

low to moderate levels of human disturbance (USFS, 2005a). The USFS management goal for mule deer 

is to maintain stable or increasing well-distributed populations. 

4.2.1 Environmental Baseline 

In low-elevation mountain ranges of southern California, such as the Santa Ana Mountains, mule 

deer reach their highest densities in oak woodlands, riparian areas, and meadow and grassland margins. 

They also occur in open scrub and young chaparral. 

The LMP indicates that the four southern California national forests support most of the deer in 

the southern part of California (USFS, 2005b). The USFS (2005b) reports that the Santa Ana population 

is estimated at about 950 deer. Based on analysis of trends between 1990 and 1996, CDFG believes that 

populations are stable in the South Coast Deer Analysis Unit (DAU 7), which includes the Santa Ana 

Mountains (CDFG, 1998). More recently, the USFS estimated the population in hunt zones D-15 and 

D-16 of DAU 7, which are located in the Cleveland National Forest, at 3,360 (USFS, 2005b). 

Effects of the Proposed Action on Mule Deer Habitat 

Construction of an upper reservoir at Morrell Canyon would temporarily disturb about 140 acres 

of suitable mule deer habitat and convert about 100 acres, including 20 acres of riparian oak woodland, to 

project use. The reservoir would be located on top of Lion Spring, which may be important as a water 

source for mule deer. However, water from the upper drainage area would be collected and conveyed 

under the reservoir, and returned to the creek downstream of the dam. 

Construction would affect about 0.25 acre at each of 85 transmission tower sites, and would 

convert about 21.25 acres of suitable mule deer habitat to project use. Some temporary access roads 

would be constructed, and then obliterated and revegetated, but many of the towers would be installed 

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using helicopters to avoid road construction on steep slopes. Locations of any access roads that may be 

constructed are not known at this point in the design process. 

Construction of the underground transmission line segment would temporarily disturb about 

23.2 acres within suitable mule deer habitat, and convert about 5.8 acres to permanent maintenance road. 

Noise disturbance would occur during construction. Maintenance activities during project 

operation would cause localized disturbance at the reservoir site, but disturbance levels would not be 

substantially greater than those that occur under existing conditions along the South Main Divide Road 

and Morgan Trail. The co-applicants would use helicopters to maintain the transmission line, which 

would cause temporary, localized disturbance. 

Effects of the Staff Alternative on Mule Deer Habitat 

Construction of an upper reservoir at Decker Canyon would temporarily disturb about 140 acres 

of suitable mule deer habitat and convert about 100 acres, including 5 acres of riparian oak woodland, to 

project use. No springs or seeps would be affected by construction, and no water conveyance system is 

thought to be necessary. 

Construction would affect about 0.25 acre at each of an estimated 85 transmission tower sites and 

would convert about 21.25 acres to project use. Temporary access roads would likely be constructed to 

provide access to the transmission line route, but many of the towers would be installed using helicopters 

to avoid road construction on steep slopes. Locations of any access roads that may be constructed are not 

known at this point in the design process. 

Construction of the underground transmission line segment would temporarily disturb about 

15.1 acres within suitable mule deer habitat and convert about 3.4 acres to permanent maintenance road. 

Noise disturbance would occur during construction. Maintenance activities during project 

operation would cause localized disturbance at the reservoir site. Disturbance levels are currently low, 

because the Decker Canyon site does not provide trail access. For this reason, maintenance activity 

would represent a small incremental increase in Decker Canyon. The co-applicants would use helicopters 

to maintain the transmission line, which would cause temporary, localized disturbance. 

Effects of the Project on Mule Deer Habitat and/or Population Trends 

Construction of either project alternative would contribute to downward trends in habitat for mule 

deer that have occurred as a result of residential and urban development in southern California. Loss of 

habitat would eventually also contribute to downward trends in population, although a 1998 CDFG report 

indicated the population trend in DAU 7 is stable. Riverside County is one of the five counties 

anticipated to be most affected by loss of habitat for deer between 2000 and 2020 (CDFG, 2004). Loss of 

a larger area of oak woodland at Morrell Canyon would have a more substantial effect than loss of habitat 

at Decker Canyon, because mule deer use oak woodlands for thermal and hiding cover, and rely heavily 

on acorns as a food resource in the fall (Zeiner et al., 1990). 

Road densities would slightly increase under either alternative, and increase the risk of 

disturbance (including illegal harvest) and habitat damage during project operation, if public access is not 

controlled. Implementation of weed management and road management plans would reduce the potential 

for adverse effects. 

4.3 Arroyo Toad 

The arroyo toad is an indicator of aquatic habitat quality. The Cleveland National Forest 

anticipates that long term trends in arroyo toad abundance, distribution and habitat condition will reflect 

the effectiveness of protection and improvement measures for arroyo toads and other riparian dependent 

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species on National Forest System lands. The USFS management goal for this species is to maintain 

properly functioning streams and stable or increasing populations (USFS, 2005a). 

4.3.1 Environmental Baseline 

The arroyo toad is endemic to the coastal plains, mountains, and desert slopes of central and 

southern California and northwestern Baja California from near sea level to about 8,000 feet. Within 

these areas, arroyo toads are found in both perennial and intermittent rivers and streams with shallow, 

sandy to gravelly pools adjacent to sand or fine gravel terraces. 

Arroyo toads occur in most of the major stream systems on the Cleveland National Forest. While 

populations on the Cleveland National Forest and surrounding lands are more numerous than on the other 

forests, many appear to be small. Most of the populations occur right along the national forest boundary, 

with the bulk of prime breeding habitat often lying just off National Forest System lands. 

The FWS recovery plan indicates the arroyo toad is present in the headwaters of San Mateo Creek 

and some of its tributaries, and identifies San Juan Creek from Decker Canyon to the Orange County line 

as being within Recovery Unit 10 (FWS, 1999). In April 2005, FWS revised the boundaries of 

designated critical habitat for the arroyo toad (70 FR 70). No critical habitat is now designated within the 

San Juan Creek or San Mateo Creek drainages in Riverside or Orange County. 

Essential habitat for this species is located in the San Juan Creek drainage downstream of the 

Riverside/Orange County line, about 4 miles south of Morrell and Decker canyons (70 FR 70). 

The co-applicants’ consultant, MBA, identified potential habitat for the arroyo toad at one 

location on the northern segment of the proposed transmission alignment (Temescal Wash), outside 

National Forest System lands, and at two locations along the southern segment (Los Alamos Canyon and 

Tenaja Creek), where the transmission alignment would cross streams and associated riparian habitat. 

MBA conducted surveys for the arroyo toad at each of these sites but did not observe any evidence of this 

species (MBA, 2004). 

4.3.2 Environmental Effects 

Effects of the Proposed Action on Arroyo Toad Habitat 

Construction of an upper reservoir at Morrell Canyon would not affect arroyo toad habitat. 

Construction of two transmission towers could affect about 0.5 acre of essential habitat at Los 

Alamos Canyon and Tenaja Creek crossings, if they are constructed within 1,640 feet of riparian habitat. 

Construction of two towers at Temescal Wash could affect 0.5 acre of potential habitat. However, towers 

generally would be constructed at the tops of slopes and along ridgelines, rather than in canyon draws or 

stream bottoms that would support riparian habitat. 

Temporary road construction could affect the suitable toad habitat, including tributaries to the San 

Mateo Creek watershed. Locations of any access roads that may be constructed are not known at this 

point in the design process. However, existing roads or helicopters would be used to install most 

transmission line towers to avoid road construction on steep slopes. 

Construction of the underground segment of the transmission line would not affect arroyo toad 

habitat. 

Effects of the Staff Alternative on Arroyo Toad Habitat 

Construction of an upper reservoir at Decker Canyon would not affect arroyo toad habitat. 

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Construction of two transmission towers could affect about 0.5 acre of essential habitat at Los 

Alamos Canyon and Tenaja Creek crossings, if they are constructed within 1,640 feet of riparian habitat. 

Construction of two towers at Temescal Wash could affect 0.5 acre of potential habitat. However, towers 

generally would be constructed at the tops of slopes and along ridgelines, rather than in canyon draws or 

stream bottoms that would support riparian habitat. 

Temporary road construction could affect the suitable toad habitat, including tributaries to the San 

Mateo Creek watershed. Locations of any access roads that may be constructed are not known at this 

point in the design process. However, existing roads or helicopters would be used to install most 

transmission line towers to avoid road construction on steep slopes. 

Construction of the underground segment of the transmission line would not affect arroyo toad 

habitat. 

Effects on Arroyo Toad Habitat and/or Population Trends 

Construction of an upper reservoir at either Morrell Canyon or Decker Canyon would not affect 

arroyo toad habitat or population trends. No habitat is present at the site, and the risk of adverse effects 

occurring downstream in the event of a dam failure is small. High hazard dams (such as would be 

constructed at either location) must be designed to withstand the probable maximum flood and the 

maximum credible earthquake, and are subject to regular federal and state inspections. 

Construction of transmission towers and access roads is anticipated to avoid riparian habitat, for 

the most part. Construction of either transmission alignment could cause a small reduction (i.e., 0.5 to 

1.0 acre) in potential habitat, but would not likely contribute to downward population trends, since no 

arroyo toad populations are known in the project area. 

If located in riparian habitats, temporary access roads could increase the risk of erosion and 

sedimentation during construction. Implementation of best management practices to prevent erosion and 

sedimentation would reduce the potential for adverse effects on streambank stability and water quality. 

If located in riparian habitats, temporary access roads could also increase the risk of disturbance 

and habitat damage during project operation, unless public access is controlled. Implementation of weed 

management and road management plans reduce the potential for adverse effects. 

4.4 Song Sparrow 

The Cleveland National Forest selected the song sparrow as an MIS for the health of riparian 

habitat (USFS, 2005a). The USFS management goal for this species is to maintain stable or increasing 

populations and healthy riparian habitat. 

4.4.1 Environmental Baseline 

In California, this species breeds primarily in riparian habitat or wetlands, where it typically nests 

in herbaceous vegetation or shrubs. The LMP describes song sparrows as being well distributed in 

southern California forests; surveyors documented song sparrows at 197 out of 206 point count stations 

during an 8-year period of forest riparian bird count surveys. 

The Partners in Flight Species Assessment (Panjabi et al., 2005) indicates population trends are 

highly variable or unknown within the species’ range, and predicts a slight to moderate decline in future 

suitability of breeding conditions. The LMP describes a significant negative trend in populations on 

National Forest System lands, and a slight downward (but insignificant) trend on non-National Forest 

System lands in the California foothills (USFS, 2005b). However, the LMP also emphasizes protection 

and enhancement of riparian condition, and indicates the trend for this habitat type should be stable or 

improving. 

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Effects of the Proposed Action on Song Sparrow Habitat 

Construction of an upper reservoir at Morrell Canyon would convert about 20 acres of riparian 

oak woodland to project use. The reservoir would be located on top of Lion Spring. Water from the 

upper drainage area would be collected and conveyed under the reservoir, and returned to the creek 

downstream of the dam. 

Tower construction would affect some song sparrow habitat where the alignment crosses streams, 

but towers generally would be sited along ridgelines and at the tops of slopes, rather than in canyon draws 

or stream bottoms that might support riparian forest or shrub. Temporary access roads would presumably 

also avoid steep canyon draws and riparian habitat, and should not affect song sparrow habitat during 

either construction or operation. Locations of any access roads that may be constructed are not known at 

this point in the design process. However, existing roads or helicopters would be used to install most 

transmission line towers to avoid road construction on steep slopes. 

Construction of the underground transmission line segment and the permanent maintenance road 

alongside it would be located primarily in chaparral and would not affect song sparrow habitat. 

Noise disturbance would occur during construction. Maintenance activities during project 

operation would cause localized disturbance at the reservoir site, but disturbance levels would not be 

substantially greater than those that occur under existing conditions along the South Main Divide Road 

and Morgan Trail. The co-applicants would use helicopters to maintain the transmission line, which 

would cause temporary, localized disturbance. 

Effects of the Staff Alternative of Song Sparrow Habitat 

Construction of an upper reservoir at Decker Canyon would convert about 5 acres of riparian oak 

woodland to project use. No seeps or springs are present, and no water conveyance system is thought to 

be needed. 

Tower construction would affect some song sparrow habitat, but towers generally would be sited 

along ridgelines and at the tops of slopes, rather than in canyon draws or stream bottoms that might 

support riparian forest or shrub. Locations of any access roads that may be constructed are not known at 

this point in the design process. Temporary access roads would presumably also avoid steep canyon 

draws and riparian habitat, and should not affect song sparrow habitat during either construction or 

operation. 

Construction of the underground transmission line segment and the permanent maintenance road 

alongside it would be located primarily in chaparral and would not affect song sparrow habitat. 

Noise disturbance would occur during construction. Maintenance activities during project 

operation would cause localized disturbance at the reservoir site. Disturbance levels are currently low, 

because the Decker Canyon site does not provide trail access. Maintenance activities could represent a 

small incremental increase in disturbance. The co-applicants would use helicopters to maintain the 

transmission line, which could cause temporary, localized disturbance near some riparian areas. 

Effects on Song Sparrow Habitat and/or Population Trends 

Construction of a reservoir at either Morrell Canyon or Decker Canyon would reduce available 

habitat for song sparrows. Effects would be greater at Morrell Canyon, which carries more water and 

supports more hydrophytic vegetation than Decker Canyon. Construction at either site could contribute to 

downward trends in song sparrow populations, which the LMP describes as significantly negative on 

National Forest System lands, and slightly downward (but insignificant) on non-National Forest System 

lands. 

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Construction of transmission towers and access roads is anticipated to avoid riparian habitat, for 

the most part. If located in riparian habitats, temporary access roads could increase the risk of erosion 

during construction. Implementation of best management practices would reduce the potential for 

adverse effects on streambank stability. 

If located in riparian habitats, temporary access roads could increase the risk of disturbance and 

habitat damage during project operation, unless public access is controlled. Implementation of weed 

management and road management plans would reduce the potential for adverse effects. 

4.5 California Spotted Owl 

The California spotted owl is an MIS for montane conifer forest habitat (USFS, 2005a). The 

Cleveland National Forest anticipates that monitoring for this species would provide information about 

whether USFS management is maintaining enough mature, large-diameter, high-canopy cover stands with 

densely shaded understories to provide sufficient habitat for interior forest species. The USFS 

management goal for this species is to maintain/increase numbers and distribution (USFS, 2005a). 

4.5.1 Environmental Baseline 

California spotted owls in the Santa Ana Mountains, and in other southern California forests, are 

clustered in islands of suitable habitat, surrounded by habitat that is not suitable (USFS, 2005b). The 

LMP indicates that in southern California, owls may use home ranges as small as 98 to 243 acres when 

they are located in riparian/hardwood forests, because they use narrow stringers of dense forest along 

steep canyons in areas otherwise dominated by chaparral (USFS, 2005b). Small oak stands may also 

serve as important stepping stones in dispersal. 

As of 1992, surveys confirmed 114 pairs in the San Bernardino Mountains, the largest 

subpopulation in southern California, and 11 in the Santa Ana Mountains (Beck and Gould, 1992). The 

results of a 2003 report on range-wide population trends were inconclusive, but USFS (2005b) indicates 

there is a high risk that the southern California metapopulation will go extinct within the next 30 to 

40 years. 

Effects of the Proposed Action on California Spotted Owl Habitat 

Construction of an upper reservoir at Morrell Canyon would convert about 20 acres of oak 

woodland to project use. 

Tower construction could affect some owl habitat, but towers generally would be sited along 

ridgelines and at the tops of slopes, rather than in canyon draws that might support riparian forest. 

Locations of any access roads that may be constructed are not known at this point in the design process. 

Temporary access roads would presumably also avoid steep canyon draws and riparian habitat, and 

should not affect owl habitat during either construction or operation. 

Construction of the underground transmission line segment and the permanent maintenance road 

alongside it would be located primarily in chaparral and would not affect owl habitat. 

Noise disturbance during construction or operation would be unlikely, because the closest 

documented owl site is located about 2 miles from the proposed transmission alignment. 

Effects of the Staff Alternative on California Spotted Owl Habitat 

Construction of an upper reservoir at Decker Canyon would convert about 5 acres of oak 

woodland to project use. 

Tower construction could affect some owl habitat, but towers generally would be sited along 

ridgelines and at the tops of slopes, rather than in canyon draws that might support riparian forest. 

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Construction of the underground transmission line segment and the permanent maintenance road 

alongside it would be located primarily in chaparral and would not affect owl habitat. Locations of any 

access roads that may be constructed are not known at this point in the design process. Temporary access 

roads would presumably also avoid steep canyon draws and riparian habitat, and should not affect owl 

habitat during either construction or operation. 

Noise disturbance would be unlikely during project construction or operation, because the closest 

documented owl site is located about 2 miles from the staff alternative transmission alignment. 

Effects on California Spotted Owl Habitat and/or Population Trends 

The loss of oak woodland habitat at Morrell Canyon or Decker Canyon would contribute to 

downward habitat trends for the California spotted owl in southern California. Effects associated with 

Morrell Canyon would be more substantial than those that would occur at Decker Canyon, due to the loss 

of more oak woodland that could serve as a stepping stone for owl dispersal. USFS assigns the highest 

habitat value rating to coast live oak forest with 80 to 100 percent canopy cover (USFS, 2005b). 

No California spotted owls are known to be present in any areas that would be affected by project 

construction, and no direct loss of nest sites, pairs or individuals would be expected. However, loss of 

habitat at either Morrell or Decker Canyon would likely contribute to downward trends in population and 

further impede recovery of populations in the Santa Ana Mountains. 

LITERATURE CITED 

Beck, T.W. and G.I. Gould. 1992. Background and the current management situation for the California 

spotted owl. In: The California Spotted Owl: A Technical Report of its Current Status, 

Chapter 3. J. Verner, K.S. McKelvey, B.R. Noon, R.J. Gutierrez, G.I. Gould and T.W. Beck 

(eds.). USDA Forest Service General Technical Report PSW-GTR-133. U.S. Forest Service, 

Albany, CA. 

Beier, P. 1993. Determining minimum habitat areas and habitat corridors for cougars. Conservation 

Biology 7(1):94–108. 

Beier, P. and R.H. Barrett. 1993. The cougar in the Santa Ana Mountain Range, California. Final 

Report. Orange County Cooperative Mountain Lion Study, June 1, 1993. 

CDFG (California Department of Fish and Game). 2004. Deer hunting draft environmental document. 

State of California, The Resources Agency, Department of Fish and Game. February 6, 2004. 

CDFG. 1998. An assessment of mule deer and black-tailed deer habitats and populations in California: 

With special emphasis on public lands administered by the Bureau of Land Management and the 

United States Forest Service. Sacramento, CA. California Department of Fish and Game, 

Wildlife Management Division. 

Dickson, B.G., J.S. Jenness, and P. Beier. 2005. Influence of vegetation, topography, and roads on 

cougar movement in southern California. Journal of Wildlife Management 69(1):264–276. 

FWS (U.S. Fish and Wildlife Service). 1999. Arroyo southwestern toad (Bufo microscaphus 

californicus) recovery plan. U.S. Fish and Wildlife Service, Region 1, Portland, OR. 

MBA (Michael Brandman Associates). 2004. Terrestrial biological resources study Lake Elsinore 

Advanced Pump Storage/Talega-Escondido/Valley-Serrano Interconnect Project. Prepared for 

Elsinore Valley Municipal Water District, Lake Elsinore, CA. Prepared by Michael Brandman 

Associates, Irvine, CA. November, 2004. 

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Panjabi, A.O., E.H. Dunn, P.J. Blancher, W.C. Hunter, B. Altman, J. Bart, C.J. Beardmore, H. Berlanga, 

G.S. Butcher, S.K. Davis, D.W. Demarest, R. Dettmers, W. Easton, H. Gomez de Silva Garza, 

E.E. Inigo-Elias, D.N. Pashley, C.J. Ralph, T.D. Rich, K.V. Rosenberg, C.M. Rustay, J.M. Ruth, 

J.S. Wendt, and T.C. Will. 2005. The partners in flight handbook on species assessment. 

Version 2005. Partners in Flight Technical Series No. 3. Rocky Mountain Bird Observatory 

website: http://www.rmbo.org/pubs/downloads/Handbook2005.pdf, accessed November 17, 

2005. 

Stephenson, J.R. and G.M. Calcarone. 1999. Southern California mountain and foothills assessment: 

Habitat and species conservation issues. General Technical Report PSW-GTR-172. Albany, CA: 

Pacific Southwest Research Station, Forest Service, U.S. Department of Agriculture. 

USFS (U.S. Forest Service). 2005a. Cleveland National Forest land management plan. Available at 

http://www.fs.fed.us/r5/scfpr/projects/lmp/index.htm, accessed September 28, 2005. U.S. Forest 

Service, Pacific Southwest Region. 

USFS. 2005b. USFS species accounts web page. 

http://www.fs.fed.us/r5/scfpr/projects/lmp/docs/species-animals.pdf, accessed November 17, 

2006. U.S. Forest Service, Pacific Southwest Region. 

Zeiner, D.C., W.F. Laudenslayer, Jr., K.E. Meyer, M. White (eds). 1990. California’s wildlife. 

Volume III: Mammals. California statewide wildlife habitat relationships system. California 

Department of Fish and Game, Sacramento, CA. 

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Document Accession #: 20070130-4000 Filed Date: 01/30/2007
Document Content(s)

01 LEAPS Cover.PDF........................................................1

02 LEAPS Spine.PDF........................................................2

03 LEAPS Cover Letter.PDF.................................................3

04 LEAPS Table of Contents.PDF...........................................12

05 LEAPS Executive Summary.PDF...........................................23

06 LEAPS Section 1 Purpose of Action.PDF.................................34

07 LEAPS Section 2 Proposed Action.PDF...................................35

08 LEAPS Section 3 Environmental Analysis.PDF............................36

09 LEAPS Section 4 Developmental Analysis.PDF............................37

10 LEAPS Section 5 Staff Conclusions.PDF.................................66

11 LEAPS Section 6 Literature Cited.PDF.................................109

12 LEAPS Section 7 List of Preparers.PDF................................124

13 LEAPS Section 8 List of Recipients.PDF ..............................127

14 LEAPS Appendix A, USFS Special Use Permit.PDF .......................156

15 LEAPS Appendix B, Need Determination.PDF ............................161

16 LEAPS Appendix C, Revised USFS 4e.PDF................................162

17 LEAPS Appendix D, Visual Simulations.PDF ............................189

18 LEAPS Appendix E, Comment and Response Summary.PDF ..................214

19 LEAPS Appendix F, Maps of Transmission Alignments.PDF ...............309

20 LEAPS Appendix G, MIS Summary.PDF ...................................315

Document Accession #: 20070130-4000 Filed Date: 01/30/2007