Federal Energy

Regulatory

Commission

FERC/FEIS – 0199F

August 2007

Energy

Projects

Hells Canyon Hydroelectric Project

Idaho/Oregon

(FERC Project No. 1971-079)

888 First Street N.E., Washington, DC 20426

Final 

Environmental Impact Statement
FERC/FEIS-0199F 

FINAL ENVIRONMENTAL IMPACT STATEMENT 

FOR HYDROPOWER LICENSE 

Hells Canyon Hydroelectric Project 

FERC Project No. 1971-079 

Idaho and Oregon 

Federal Energy Regulatory Commission 

Office of Energy Projects 

Division of Hydropower Licensing 

888 First Street, NE 

Washington, DC 20426 

August 2007 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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 Hells Canyon Hydroelectric 

Project, located on the Snake River in Washington and Adams counties, Idaho, and Wallowa and Baker 

counties, Oregon. 

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

affected Indian tribes, the public, the license applicant, and Federal Energy Regulatory Commission 

(Commission) staff. It contains evaluations on Idaho Power Company’s proposal and the alternatives for 

licensing the Hells Canyon Project. 

A copy of the final EIS is 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 Commission’s web site at http://www.ferc.gov under the eLibrary link. Enter the docket number 

excluding the last three digits in the docket number field to access the document. For assistance, contact 

FERC Online Support at FERCOnlineSupport@ferc.gov or toll-free at 1-866-208-3676, or for TTY, 

(202) 502-8659. 

Attachment: Final Environmental Impact Statement 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
Document Accession #: 20070831-4002 Filed Date: 08/31/2007
v 

COVER SHEET 

a. Title: Licensing for the continued operation of Idaho Power Company’s Hells Canyon 

Project, located on the Snake River in Washington and Adams counties, Idaho, 

and Wallowa and Baker counties, Oregon, Federal Energy Regulatory 

Commission (Commission or FERC) Project No. 1971-079. 

b. Subject: Final Environmental Impact Statement 

c. Lead Agency: Federal Energy Regulatory Commission 

d. Abstract: Idaho Power Company filed an application for license with the Commission for 

a new license for the Hell’s Canyon Project,1

 FERC Project No. 1971, located 

on the Snake River in Washington and Adams counties, Idaho, and Wallowa and 

Baker counties, Oregon. The Hells Canyon Project consists of three 

developments (dams, reservoirs, and powerhouses) on the segment of the Snake 

River forming the border between Idaho and Oregon. The three developments 

are Brownlee, Oxbow, and Hells Canyon. The project affects lands included 

within the Payette National Forest, Wallowa-Whitman National Forest, Hells 

Canyon National Recreation Area, and lands administered by the Bureau of 

Land Management. 

e. Contact: Alan Mitchnick 

Federal Energy Regulatory Comm. 

Office of Energy Projects 

888 First Street, N.E. 

Washington, DC 20426 

202-502-6074

Emily Carter 

Federal Energy Regulatory Comm. 

Office of Energy Projects 

888 First Street, N.E. 

Washington, DC 20426 

202-502-6512

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

on the hydroelectric license application filed by the Idaho Power Company for 

the proposed Hells Canyon Project, FERC Project No. 1971, is being made 

available to the public on or about August 31, 2007, as required by the National 

Environmental Policy Act of 19692

 

1

 Referred to in Idaho Power’s application as the Hells Canyon Complex. 

2

 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)3

 and the U.S. Department of Energy Organization Act4 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)...5

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.6

 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.7

 

3

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

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

Act of 2005, Public Law 109-58 (2005). 

4

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

5

 16 U.S.C. § 803(a). 

6

 16 U.S.C. § 803(g). 

7

 18 C.F.R. § 385.206 (1987). 

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TABLE OF CONTENTS 

LIST OF FIGURES ................................................................................................................................... xix

LIST OF TABLES..................................................................................................................................xxvii

ACRONYMS AND ABBREVIATIONS ..............................................................................................xxxiii

EXECUTIVE SUMMARY .................................................................................................................... xxxv

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

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

1.2 NEED FOR POWER .......................................................................................................... 4

1.3 INTERVENTIONS............................................................................................................. 5

1.4 SCOPING PROCESS ......................................................................................................... 6

1.5 CONSULTATION.............................................................................................................. 7

1.6 COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT............ 8

2.0 PROPOSED ACTION AND ALTERNATIVES ............................................................................ 9

2.1 NO-ACTION ALTERNATIVE.......................................................................................... 9

2.1.1 Existing Project Facilities................................................................................... 9

2.1.1.1 Brownlee Development................................................................... 9

2.1.1.2 Oxbow Development .................................................................... 12

2.1.1.3 Hells Canyon Development .......................................................... 12

2.1.1.4 Transmission Facilities ................................................................. 12

2.1.1.5 Fish Hatcheries and Related Facilities .......................................... 12

2.1.1.6 Recreation Facilities...................................................................... 16

2.1.1.7 Project Safety................................................................................ 16

2.1.2 Current Project Operations ............................................................................... 16

2.1.2.1 Brownlee Development................................................................. 16

2.1.2.2 Oxbow Development .................................................................... 18

2.1.2.3 Hells Canyon Development .......................................................... 19

2.1.3 Current Environmental Measures..................................................................... 19

2.1.4 Current Project Boundary................................................................................. 20

2.2 IDAHO POWER’S PROPOSAL...................................................................................... 20

2.2.1 Proposed Project Facilities ............................................................................... 20

2.2.2 Proposed Project Operations ............................................................................ 20

2.2.3 Proposed Environmental Measures .................................................................. 21

2.2.4 Proposed Project Boundary .............................................................................. 29

2.3 MODIFICATIONS TO IDAHO POWER’S PROPOSAL............................................... 29

2.3.1 Mandatory Conditions ...................................................................................... 29

2.3.1.1 Water Quality Certification........................................................... 29

2.3.1.2 Section 18 Fishway Prescriptions ................................................. 29

2.3.1.3 Section 4(e) Federal Land Management Conditions and 

Alternative Conditions .................................................................. 31

2.3.2 Other Recommendations by Agencies and Interested Parties .......................... 34

2.3.2.1 Section 10(j) Recommendations ................................................... 34

2.3.2.2 Section 10(a) Recommendations .................................................. 34

2.3.3 Staff Alternative ............................................................................................... 35

2.3.4 Staff Alternative with Mandatory Conditions .................................................. 44

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2.4 OTHER ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED 

STUDY ............................................................................................................................. 44

2.4.1 Federal Government Takeover of the Project................................................... 44

2.4.2 Issuance of Nonpower License......................................................................... 44

2.4.3 Project Retirement ............................................................................................ 45

3.0 ENVIRONMENTAL ANALYSIS ................................................................................................ 47

3.1 GENERAL DESCRIPTION OF THE AREA .................................................................. 47

3.2 CUMULATIVELY AFFECTED RESOURCES.............................................................. 49

3.2.1 Geographic Scope............................................................................................. 49

3.2.1.1 Sediment Transport....................................................................... 49

3.2.1.2 Water Quality................................................................................ 50

3.2.1.3 Anadromous Fish .......................................................................... 50

3.2.1.4 Resident Fish................................................................................. 51

3.2.1.5 Federally Listed Aquatic Mollusks............................................... 52

3.2.1.6 Riparian/Wetland Habitat ............................................................. 52

3.2.1.7 Native Grasslands and Shrublands................................................ 52

3.2.1.8 Noxious Weeds and Invasive Exotic Plants.................................. 53

3.2.1.9 MacFarlane’s Four-o’clock........................................................... 53

3.2.1.10 Bald Eagles and Peregrine Falcons............................................... 53

3.2.1.11 Recreational Resources................................................................. 54

3.2.2 Temporal Scope................................................................................................ 54

3.3 WATER QUANTITY....................................................................................................... 55

3.3.1 Affected Environment ...................................................................................... 55

3.3.1.1 Surface Water................................................................................ 56

3.3.1.2 Flood Storage................................................................................ 62

3.3.1.3 Navigation..................................................................................... 65

3.3.1.4 Water Rights ................................................................................. 66

3.3.2 Environmental Effects ...................................................................................... 68

3.3.2.1 Proposed Operations ..................................................................... 69

3.3.2.2 Operational Recommendations and Alternative Evaluation 

Scenarios....................................................................................... 69

3.3.2.3 Flood Storage................................................................................ 79

3.3.2.4 Brownlee Reservoir Levels........................................................... 79

3.3.2.5 Oxbow and Hells Canyon Reservoir Levels ................................. 83

3.3.2.6 Project Outflows ........................................................................... 83

3.3.2.7 Downstream Flows Important to Navigation................................ 86

3.3.2.8 Flow Fluctuations Downstream of Hells Canyon Dam ................ 88

3.3.2.9 Operations Compliance Measurement Location........................... 89

3.3.2.10 Water Uses and Water Rights ....................................................... 90

3.3.3 Unavoidable Adverse Effects ........................................................................... 90

3.4 SEDIMENT SUPPLY AND TRANSPORT .................................................................... 91

3.4.1 Affected Environment ...................................................................................... 91

3.4.1.1 Sediment Budget........................................................................... 91

3.4.1.2 Beaches and Terraces.................................................................... 96

3.4.1.3 Spawning Gravel........................................................................... 98

3.4.2 Environmental Effects ...................................................................................... 99

3.4.2.1 Effects of Project Operations on Sediment Transport................... 99

3.4.2.2 Sediment Augmentation and Monitoring.................................... 106

3.4.3 Cumulative Effects ......................................................................................... 109

3.4.4 Unavoidable Adverse Effects ......................................................................... 109

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3.5 WATER QUALITY ....................................................................................................... 111

3.5.1 Affected Environment .................................................................................... 111

3.5.1.1 Water Quality Standards ............................................................. 111

3.5.1.2 Temperature ................................................................................ 117

3.5.1.3 Biological Productivity ............................................................... 128

3.5.1.4 Total Dissolved Gas.................................................................... 132

3.5.1.5 Turbidity ..................................................................................... 135

3.5.1.6 Hazardous Materials ................................................................... 137

3.5.1.7 Coliform Bacteria........................................................................ 138

3.5.2 Environmental Effects .................................................................................... 138

3.5.2.1 Effects of Project Operations on Water Quality ......................... 138

3.5.2.2 Dissolved Oxygen....................................................................... 152

3.5.2.3 Total Dissolved Gas.................................................................... 163

3.5.2.4 Water Temperature ..................................................................... 168

3.5.2.5 Oxbow Bypassed Reach Flows................................................... 177

3.5.2.6 Effects of Other Measures on Water Quality.............................. 179

3.5.3 Cumulative Effects ......................................................................................... 181

3.5.4 Unavoidable Adverse Effects ......................................................................... 182

3.6 AQUATIC RESOURCES .............................................................................................. 183

3.6.1 Affected Environment .................................................................................... 183

3.6.1.1 Aquatic Habitat Conditions......................................................... 183

3.6.1.2 Primary Production and Aquatic Macroinvertebrates................. 188

3.6.1.3 Anadromous Fish Species........................................................... 190

3.6.1.4 Native Resident Salmonids ......................................................... 195

3.6.1.5 White Sturgeon ........................................................................... 214

3.6.1.6 Reservoir Fisheries...................................................................... 216

3.6.1.7 Hells Canyon Riverine Fishery................................................... 217

3.6.1.8 Hatchery Operations ................................................................... 221

3.6.2 Environmental Effects .................................................................................... 228

3.6.2.1 Effects of Project Operations on Aquatic Resources .................. 228

3.6.2.2 Dissolved Oxygen....................................................................... 310

3.6.2.3 Total Dissolved Gas.................................................................... 313

3.6.2.4 Water Temperature ..................................................................... 320

3.6.2.5 Oxbow Bypassed Reach Flows................................................... 324

3.6.2.6 Anadromous Fish Restoration..................................................... 325

3.6.2.7 Fish Passage Facilities ................................................................ 337

3.6.2.8 Resident Salmonid Passage......................................................... 340

3.6.2.9 Fish Pathogen Assessment.......................................................... 344

3.6.2.10 Tributary Habitat Improvements................................................. 345

3.6.2.11 Marine-Derived Nutrients........................................................... 350

3.6.2.12 Hatchery Production ................................................................... 352

3.6.2.13 Sturgeon Conservation Measures................................................ 363

3.6.2.14 Sediment Augmentation.............................................................. 372

3.6.2.15 Benthic Community Monitoring................................................. 374

3.6.2.16 Effects of Other Measures on Aquatic Resources....................... 375

3.6.3 Cumulative Effects ......................................................................................... 375

3.6.3.1 Pacific Lamprey .......................................................................... 376

3.6.3.2 Redband Trout and White Sturgeon............................................ 376

3.6.4 Unavoidable Adverse Effects ......................................................................... 377

3.7 TERRESTRIAL RESOURCES...................................................................................... 379

3.7.1 Affected Environment .................................................................................... 379

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3.7.1.1 Terrestrial Habitat Conditions..................................................... 379

3.7.1.2 Special Status Plants and Plant Communities............................. 381

3.7.1.3 Plants of Cultural Importance ..................................................... 383

3.7.1.4 Noxious Weeds and Invasive Exotic Plants................................ 383

3.7.1.5 Key Wildlife Species .................................................................. 383

3.7.1.6 Special Status Wildlife Species................................................... 387

3.7.1.7 Game Species of Cultural Importance ........................................ 390

3.7.1.8 Land Management Practices ....................................................... 390

3.7.2 Environmental Effects .................................................................................... 392

3.7.2.1 Effects of Project Operations on Terrestrial Resources .............. 392

3.7.2.2 Special Status Plant Protection ................................................... 406

3.7.2.3 Noxious Weed and Exotic Invasive Plant Management ............. 409

3.7.2.4 Road, Transmission Line, and Right-of-Way Management ....... 410

3.7.2.5 Upland and Riparian Habitat Acquisition................................... 412

3.7.2.6 Cooperative Wildlife Management Projects ............................... 423

3.7.2.7 Wildlife Management on Idaho Power Lands ............................ 426

3.7.2.8 Special Status Wildlife................................................................ 429

3.7.2.9 Effects of Other Measures on Terrestrial Resources................... 433

3.7.3 Cumulative Effects ......................................................................................... 434

3.7.3.1 Riparian and Wetland Habitats ................................................... 434

3.7.3.2 Native Grasslands and Shrublands.............................................. 434

3.7.3.3 Noxious Weeds and Invasive Exotic Plants................................ 435

3.7.3.4 Peregrine Falcons........................................................................ 435

3.7.4 Unavoidable Adverse Effects ......................................................................... 435

3.8 THREATENED AND ENDANGERED SPECIES........................................................ 437

3.8.1 Affected Environment .................................................................................... 437

3.8.1.1 Fall Chinook Salmon .................................................................. 437

3.8.1.2 Spring/Summer Chinook Salmon ............................................... 439

3.8.1.3 Sockeye Salmon.......................................................................... 440

3.8.1.4 Steelhead..................................................................................... 441

3.8.1.5 Bull Trout.................................................................................... 442

3.8.1.6 Bliss Rapids Snail ....................................................................... 443

3.8.1.7 Idaho Springsnail ........................................................................ 444

3.8.1.8 MacFarlane’s Four-o’clock......................................................... 444

3.8.1.9 Howell’s Spectacular Thelypody................................................ 445

3.8.1.10 Spalding’s Catchfly..................................................................... 445

3.8.1.11 Gray Wolf ................................................................................... 445

3.8.1.12 Canada Lynx ............................................................................... 446

3.8.1.13 Northern Idaho Ground Squirrel................................................. 447

3.8.1.14 Bald Eagle................................................................................... 447

3.8.2 Environmental Effects on Threatened and Endangered Species .................... 450

3.8.2.1 Snake River Fall Chinook Salmon.............................................. 450

3.8.2.2 Snake River Spring/Summer Chinook Salmon........................... 453

3.8.2.3 Snake River Sockeye Salmon ..................................................... 455

3.8.2.4 Snake River Steelhead ................................................................ 456

3.8.2.5 Other Columbia River Basin Salmon and Steelhead ESUs ........ 458

3.8.2.6 Bull Trout.................................................................................... 463

3.8.2.7 Idaho Springsnail ........................................................................ 466

3.8.2.8 MacFarlane’s Four-o’clock and Spalding’s Catchfly ................. 466

3.8.2.9 Gray Wolf ................................................................................... 467

3.8.2.10 Canada Lynx ............................................................................... 467

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3.8.2.11 Northern Idaho Ground Squirrel................................................. 468

3.8.2.12 Bald Eagle................................................................................... 468

3.8.3 Cumulative Effects ......................................................................................... 475

3.8.3.1 Snake River Fall Chinook Salmon.............................................. 476

3.8.3.2 Snake River Steelhead and Spring/Summer Chinook Salmon.... 477

3.8.3.3 Snake River Sockeye Salmon ..................................................... 478

3.8.3.4 Other Columbia River Basin Salmon and Steelhead ESUs ........ 478

3.8.3.5 Bull Trout.................................................................................... 479

3.8.3.6 MacFarlane’s Four-o’clock......................................................... 480

3.8.3.7 Bald Eagle................................................................................... 480

3.8.4 Unavoidable Adverse Effects ......................................................................... 481

3.9 CULTURAL RESOURCES ........................................................................................... 483

3.9.1 Affected Environment .................................................................................... 483

3.9.1.1 Area of Potential Effect............................................................... 483

3.9.1.2 Cultural History Overview.......................................................... 484

3.9.1.3 Previous Cultural Resource Investigations ................................. 486

3.9.1.4 Prehistoric and Historic Archeological Resources...................... 486

3.9.1.5 Historic Buildings and Structures ............................................... 489

3.9.1.6 Traditional Cultural Properties, Sacred Sites, and Rock Art ...... 490

3.9.2 Environmental Effects .................................................................................... 491

3.9.2.1 Effects of Project Operations on Cultural Resources.................. 491

3.9.2.2 Site Treatment............................................................................. 494

3.9.2.3 Cultural Resources Interpretation ............................................... 497

3.9.2.4 Support for Native American Programs...................................... 498

3.9.2.5 Management of Cultural Resources............................................ 500

3.9.2.6 Effects of Other Measures on Cultural Resources ...................... 503

3.9.3 Unavoidable Adverse Effects ......................................................................... 504

3.10 RECREATION RESOURCES ....................................................................................... 505

3.10.1 Affected Environment .................................................................................... 505

3.10.1.1 Regional Recreational Setting..................................................... 505

3.10.1.2 Recreational Facilities within the Project Boundary................... 506

3.10.1.3 Recreational Use within the Project Boundary ........................... 510

3.10.1.4 Recreational Activities................................................................ 514

3.10.1.5 Recreational Visitor Concerns .................................................... 515

3.10.1.6 Boating Use Downstream of the Project..................................... 517

3.10.2 Environmental Effects .................................................................................... 520

3.10.2.1 Effects of Project Operations on Recreation Resources ............. 520

3.10.2.2 Recreation Plan ........................................................................... 525

3.10.2.3 Recreation Site Improvements.................................................... 527

3.10.2.4 Litter and Sanitation Plan............................................................ 540

3.10.2.5 Information and Education.......................................................... 543

3.10.2.6 Trails ........................................................................................... 544

3.10.2.7 Operation and Maintenance at Forest Service and BLM Sites ... 546

3.10.2.8 Flow Information and Coordination Downstream of Hells Canyon 

Dam............................................................................................. 547

3.10.2.9 Adaptive Management ................................................................ 548

3.10.2.10 Hells Canyon Visitors Center Staffing........................................ 551

3.10.2.11 Warmwater Fisheries Management Plan .................................... 551

3.10.2.12 Effects of Other Measures on Recreation ................................... 552

3.10.3 Cumulative Effects ......................................................................................... 553

3.10.4 Unavoidable Adverse Effects ......................................................................... 553

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3.11 AESTHETICS ................................................................................................................ 555

3.11.1 Affected Environment .................................................................................... 555

3.11.1.1 Brownlee Development............................................................... 556

3.11.1.2 Oxbow Development .................................................................. 556

3.11.1.3 Hells Canyon Development ........................................................ 557

3.11.1.4 Snake River Downstream of Hells Canyon Dam........................ 558

3.11.2 Environmental Effects .................................................................................... 558

3.11.2.1 Effects of Project Operations on Aesthetics................................ 558

3.11.2.2 Aesthetic Improvements and Resource Management ................. 561

3.11.2.3 Effects of Other Measures on Aesthetics.................................... 563

3.11.3 Unavoidable Adverse Effects ......................................................................... 564

3.12 LAND MANAGEMENT AND USE ............................................................................. 565

3.12.1 Affected Environment .................................................................................... 565

3.12.1.1 Project Boundary ........................................................................ 565

3.12.1.2 Land Ownership and Management Jurisdictions ........................ 565

3.12.1.3 Land and Water Uses .................................................................. 568

3.12.1.4 Road Management ...................................................................... 570

3.12.2 Environmental Effects .................................................................................... 571

3.12.2.1 Land Use Management ............................................................... 571

3.12.2.2 Coordination with State and Federal Land Management 

Agencies...................................................................................... 573

3.12.2.3 Law Enforcement........................................................................ 575

3.12.2.4 Fire Protection............................................................................. 576

3.12.2.5 Boundary Modifications ............................................................. 577

3.12.2.6 Road Management Plan .............................................................. 578

3.12.2.7 Effects of Other Measures on Land Management....................... 580

3.12.3 Unavoidable Adverse Effects ......................................................................... 581

3.13 SOCIOECONOMIC RESOURCES ............................................................................... 583

3.13.1 Affected Environment .................................................................................... 583

3.13.1.1 Idaho Power Electricity Generation and Rates ........................... 583

3.13.1.2 Relationship of the Hells Canyon Project to Local 

Governments............................................................................... 584

3.13.1.3 Commercial Enterprises in the Project Area............................... 585

3.13.1.4 Minority and Low-income Communities.................................... 586

3.13.1.5 Native American Tribes.............................................................. 588

3.13.2 Effects of Project Operations on Socioeconomic Resources.......................... 589

3.13.2.1 Effects on Power Costs ............................................................... 589

3.13.2.2 Net Cost to Local Government ................................................... 590

3.13.2.3 Effects on Commercial Enterprises............................................. 590

3.13.2.4 Effects on Minority and Low-income Communities .................. 592

3.13.2.5 Effects on Native Americans ...................................................... 592

3.13.2.6 Effects of Other Measures on Socioeconomics .......................... 593

3.13.3 Unavoidable Adverse Effects ......................................................................... 593

3.14 EFFECTS OF NO-ACTION ALTERNATIVE.............................................................. 593

3.15 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES........ 594

3.16 RELATIONSHIP BETWEEN SHORT-TERM USES AND LONG-TERM 

PRODUCTIVITY........................................................................................................... 594

4.0 DEVELOPMENTAL ANALYSIS.............................................................................................. 595

4.1 BASIS FOR POWER, COSTS AND ECONOMIC BENEFITS OF THE PROJECT... 595

4.2 COST OF ENVIRONMENTAL MEASURES .............................................................. 597

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4.2.1 Reduced Benefits Associated with Operational Changes............................... 597

4.2.2 Cost of Environmental Measures under the Applicants’ Proposal, Staff 

Alternative, and Staff Alternative with Mandatory Conditions...................... 600

4.3 COMPARISON OF ALTERNATIVES ......................................................................... 600

5.0 STAFF’S CONCLUSIONS......................................................................................................... 606

5.1 SUMMARY COMPARISON OF IDAHO POWER’S PROPOSAL AND STAFF 

ALTERNATIVE............................................................................................................. 606

5.1.1 Description of Alternatives............................................................................. 606

5.1.1.1 Idaho Power’s Proposal .............................................................. 606

5.1.1.2 Staff Alternative.......................................................................... 606

5.1.1.3 Staff Alternative with Mandatory Conditions............................. 622

5.1.2 Summary of Effects........................................................................................ 622

5.2 DISCUSSION OF KEY ISSUES ................................................................................... 635

5.2.1 Sediment Augmentation and Monitoring ....................................................... 635

5.2.2 Water Supply—Operational Measures........................................................... 637

5.2.2.1 Flood Storage.............................................................................. 637

5.2.2.2 Navigation Target Flow Levels................................................... 638

5.2.2.3 Flow Augmentation for Anadromous Fish Juvenile Migration .. 641

5.2.2.4 Water Rights ............................................................................... 645

5.2.3 Water Quality ................................................................................................. 645

5.2.3.1 Dissolved Oxygen Measures....................................................... 645

5.2.3.2 Water Temperature Measures ..................................................... 649

5.2.3.3 Total Dissolved Gas Abatement ................................................. 651

5.2.3.4 Water Quality Monitoring........................................................... 653

5.2.4 Aquatic Resources .......................................................................................... 654

5.2.4.1 Fall Chinook Spawning and Incubation Flows ........................... 654

5.2.4.2 Flow Fluctuations Outside of the Fall Chinook Spawning and 

Incubation Period ........................................................................ 656

5.2.4.3 Anadromous Fish Restoration..................................................... 659

5.2.4.4 Resident Salmonid Passage......................................................... 665

5.2.4.5 Tributary Habitat Improvements................................................. 668

5.2.4.6 Fish Pathogen Assessment.......................................................... 670

5.2.4.7 Oxbow Bypassed Reach Flows................................................... 671

5.2.4.8 Hatchery Production ................................................................... 672

5.2.4.9 Warmwater Fisheries .................................................................. 675

5.2.4.10 Sturgeon Conservation Measures................................................ 677

5.2.4.11 Invertebrate Monitoring .............................................................. 680

5.2.5 Terrestrial Resources ...................................................................................... 681

5.2.5.1 Special Status Plant and Wildlife Protection .............................. 681

5.2.5.2 Noxious Weed and Exotic Invasive Plant Management ............. 687

5.2.5.3 Road, Transmission Line, and Right-of-Way Management ....... 688

5.2.5.4 Upland and Riparian Habitat Acquisition................................... 689

5.2.5.5 Cooperative Wildlife Management Projects ............................... 694

5.2.5.6 Wildlife Management on Project Lands ..................................... 695

5.2.6 Cultural Resources.......................................................................................... 697

5.2.6.1 Finalization of the Historic Properties Management Plan .......... 697

5.2.6.2 Cultural Resources Monitoring................................................... 697

5.2.6.3 Cultural Resource Site Stabilization ........................................... 698

5.2.6.4 Ethnographic and Oral History Studies ...................................... 699

5.2.6.5 Tribal Participation, Education, and Training............................. 699

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5.2.6.6 Cultural Resources Interpretation ............................................... 700

5.2.6.7 Other Cultural Resource Management Issues............................. 701

5.2.7 Recreation Resources ..................................................................................... 703

5.2.7.1 Recreation Plan ........................................................................... 703

5.2.7.2 Recreation Site Improvements.................................................... 704

5.2.7.3 Sanitation and Litter Management.............................................. 706

5.2.7.4 Information and Education.......................................................... 707

5.2.7.5 Trails ........................................................................................... 707

5.2.7.6 Operation and Maintenance at Forest Service and BLM Sites ... 708

5.2.7.7 Adaptive Management ................................................................ 709

5.2.8 Land Management and Aesthetics.................................................................. 709

5.2.8.1 Land Use Management ............................................................... 709

5.2.8.2 Law Enforcement and Fire Protection ........................................ 711

5.2.8.3 Boundary Modifications ............................................................. 712

5.2.8.4 Road Management Plan .............................................................. 713

5.2.8.5 Aesthetic Resource Management................................................ 714

5.3 SUMMARY OF 10(J) RECOMMENDATIONS AND 4(E) CONDITIONS................ 714

5.3.1 Fish and Wildlife Agency Recommendations ................................................ 714

5.3.2 Interior and Forest Service 4(e) Conditions.................................................... 715

5.4 CONSISTENCY WITH COMPREHENSIVE PLANS ................................................. 742

5.4.1 Section 10(a)(2) Comprehensive Plans .......................................................... 742

5.4.1.1 Plans Applicable to Both Idaho and Oregon............................... 742

5.4.1.2 Plans Applicable to Idaho ........................................................... 743

5.4.1.3 Plans Applicable to Oregon ........................................................ 743

5.4.2 Other Plans ..................................................................................................... 745

5.5 RELATIONSHIP OF LICENSE PROCESS TO LAWS AND POLICIES ................... 746

5.5.1 Section 401 of the Clean Water Act—Water Quality Certification ............... 746

5.5.2 Coastal Zone Management Act—Consistency Certification.......................... 746

5.5.3 Section 18 of the Federal Power Act—Authority to Prescribe Fishways....... 746

5.5.4 Endangered Species Act ................................................................................. 746

5.5.5 Essential Fish Habitat ..................................................................................... 750

5.5.6 National Historic Preservation Act................................................................. 750

5.5.7 Pacific Northwest Electric Power Planning and Conservation Act, Columbia 

River Basin Fish and Wildlife Program, and Mainstem and Subbasin Plan 

Amendments to the Columbia River Basin Fish and Wildlife Program......... 751

5.5.8 Wild and Scenic Rivers Act............................................................................ 752

6.0 LITERATURE CITED ................................................................................................................ 758

7.0 LIST OF PREPARERS................................................................................................................ 790

8.0 LIST OF RECIPIENTS ............................................................................................................... 792

APPENDIX A Agency Identifiers for Measures Addressed in the EIS 

APPENDIX B Comments on the Draft Environmental Impact Statement for the Hells Canyon Project, 

Project No. 1171-079 

APPENDIX C Mandatory Conditions 

APPENDIX D Modeled Constraints for Idaho Power Company’s Proposed Operation and Operational 

Alternatives 

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APPENDIX E Flow Fluctuations Downstream of Hells Canyon Dam—Figures 

APPENDIX F Information about the Status Bull Trout from the FWS 2005 Upper Snake River 

Biological Opinion 

APPENDIX G Information about the Status of Columbia River Salmon and Steelhead ESUs from the 

NMFS 2005 Upper Snake River Biological Opinion 

APPENDIX H Developmental Analysis of New Environmental Measures Proposed by Idaho Power 

APPENDIX I Developmental Analysis of Other Measures Included in the Staff Alternative 

APPENDIX J Developmental Analysis of Mandatory Measures That Are Not Included in the Staff 

Alternative 

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LIST OF FIGURES 

Figure 1. Location of the Hells Canyon Project .......................................................................................3

Figure 2. Hydroelectric developments of the Hells Canyon Project.......................................................10

Figure 3. Brownlee Development...........................................................................................................11

Figure 4. Oxbow Development...............................................................................................................13

Figure 5. Hells Canyon Development.....................................................................................................14

Figure 6. Transmission line associated with the Hells Canyon Project ..................................................15

Figure 7. Simulated Brownlee reservoir levels for proposed operations under medium water 

conditions ................................................................................................................................17

Figure 8. Selected USGS gage locations downstream from Hells Canyon dam ....................................57

Figure 9. Comparison of Brownlee reservoir inflows under extremely high (1997), medium (1995), 

extremely low (1992), medium-high (1999) and medium-low (1994)a

 water conditions.......58

Figure 10. Comparison of Brownlee reservoir average daily elevations under extremely high (1997), 

medium (1995), extremely low (1992), medium-high (1999) and medium-low (1994)a

 water 

conditions ................................................................................................................................61

Figure 11. Comparison of Hells Canyon outflows (USGS Gage No. 13290450, Snake River at Hells 

Canyon dam, Idaho-Oregon state line) under extremely high (1997), medium (1995), 

extremely low (1992), medium-high (1999) and medium-low (1994)a

 water conditions.......63

Figure 12. Simulated Brownlee reservoir levels for extremely low water conditions..............................80

Figure 13. Simulated Brownlee reservoir levels for medium-low water conditions ................................80

Figure 14. Simulated Brownlee reservoir levels for medium water conditions........................................81

Figure 15. Simulated Brownlee reservoir levels for medium-high water conditions ...............................81

Figure 16. Simulated Brownlee reservoir levels for extremely high water conditions.............................82

Figure 17. Simulated project outflows for extremely low water conditions.............................................84

Figure 18. Simulated project outflows for medium-low water conditions ...............................................84

Figure 19. Simulated project outflows for medium water conditions.......................................................85

Figure 20. Simulated project outflows for medium-high water conditions ..............................................85

Figure 21. Simulated project outflows for extremely high water conditions............................................86

Figure 22. Summary of estimated sediment yield from tributaries using various techniques, sediment 

gaging at Weiser, and the four regional reservoirs..................................................................95

Figure 23. Estimated cumulative annual area of sandbars that would be subject to sand mobilization 

under Proposed Operations and five alternative scenarios for an extremely low water year 102

Figure 24. Estimated cumulative annual area of sandbars that would be subject to sand mobilization 

under Proposed Operations and five alternative scenarios for a medium water year............102

Figure 25. Estimated cumulative annual area of sandbars that would be subject to sand mobilization 

under Proposed Operations and five alternative scenarios for an extremely high water year

...............................................................................................................................................103

Figure 26. Recent (1990s) RM 345a and Brownlee reservoir outflow and pre-project (1957) 

Brownlee dam site mean monthly water temperatures for the Brownlee reservoir ..............122

Figure 27. Reaches, zones, and strata of Brownlee, Oxbow, and Hells Canyon reservoirs ...................123

Figure 28. Vertical profiles of water temperature (open symbols) and DO concentrations (solid shaded 

symbols) in Brownlee reservoir (top), Oxbow reservoir (middle), and Hells Canyon 

reservoir (bottom), July and September 1995 .......................................................................124

Figure 29. Average daily 7-day average maximum temperatures of Snake River inflow to Brownlee 

reservoir (1996–2004) and outflow from Hells Canyon dam (1991–2004)..........................127

Figure 30. Adjusted measured 7-day average maximum temperatures of outflow from Hells Canyon 

dam for a portion of the fall Chinook spawning period ........................................................ 128

Figure 31. DO concentrations at the Brownlee reservoir inflow and downstream of Hells Canyon 

dam for 1992, 1995, and 1997 (low-, average-, and high-flow years) ..................................130

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Figure 32. DO concentration time series for the Snake River downstream of Hells Canyon dam, late 

August through December 2000............................................................................................132

Figure 33. Relationship between spill rate at Hells Canyon dam and TDG approximately 1.5 miles 

downstream of the dam, 1997–1999 .....................................................................................134

Figure 34. Dissipation of elevated TDG downstream of Hells Canyon dam relative to the 110 percent 

of saturation criterion, 1997–1999 ........................................................................................135

Figure 35. Map of the Swan Falls to Brownlee reach of the Snake River..............................................185

Figure 36. Map of the Brownlee to Hells Canyon reach of the Snake River..........................................187

Figure 37. Map of the Hells Canyon to Lower Granite reach of the Snake River..................................189

Figure 38. Passage timing of wild subyearling fall Chinook salmon smolts (PIT-tagged in the upper 

and lower Hells Canyon reaches) at Lower Granite dam......................................................194

Figure 39. Time series of bull trout habitat suitability indices for temperature, dissolved oxygen and a 

composite score for temperature and dissolved oxygen at Brownlee reservoir during an 

extreme low flow hydrologic year (1992) and two operational scenarios (proposed and 

run-of-river full pool) ............................................................................................................199

Figure 40. Time series of bull trout habitat suitability indices for temperature, dissolved oxygen and a 

composite score for temperature and dissolved oxygen at Oxbow reservoir during an extreme 

low flow hydrologic year (1992) and two operational scenarios (proposed and run-of-river 

full pool)................................................................................................................................200

Figure 41. Time series of bull trout habitat suitability indices for temperature, dissolved oxygen and a 

composite score for temperature and dissolved oxygen at Hells Canyon reservoir during an 

extreme low flow hydrologic year (1992) and two operational scenarios (proposed and runof-river full pool)...................................................................................................................201

Figure 42 Time series of bull trout habitat suitability indices for temperature, dissolved oxygen and a 

composite score for temperature and dissolved oxygen at Brownlee reservoir during a 

medium flow hydrologic year (1995) and two operational scenarios (proposed and run-ofriver full pool) .......................................................................................................................202

Figure 43. Time series of bull trout habitat suitability indices for temperature, dissolved oxygen and a 

composite score for temperature and dissolved oxygen at Oxbow reservoir during a medium 

flow hydrologic year (1995) and two operational scenarios (proposed and run-of-river full 

pool) ......................................................................................................................................203

Figure 44. Time series of bull trout habitat suitability indices for temperature, dissolved oxygen and a 

composite score for temperature and dissolved oxygen at Hells Canyon reservoir during a 

medium flow hydrologic year (1995) and two operational scenarios (proposed and run-ofriver full pool) .......................................................................................................................204

Figure 45. Time series of bull trout habitat suitability indices for temperature, dissolved oxygen and a 

composite score for temperature and dissolved oxygen at Brownlee reservoir during an 

extreme high flow hydrologic year (1997) and two operational scenarios (proposed and 

run-of-river full pool) ............................................................................................................205

Figure 46. Time series of bull trout habitat suitability indices for temperature, dissolved oxygen and a 

composite score for temperature and dissolved oxygen at Oxbow reservoir during an extreme 

high flow hydrologic year (1997) and two operational scenarios (proposed and run-of-river 

full pool)................................................................................................................................206

Figure 47. Time series of bull trout habitat suitability indices for temperature, dissolved oxygen and a 

composite score for temperature and dissolved oxygen at Hells Canyon reservoir during an 

extreme high flow hydrologic year (1997) and two operational scenarios (proposed and runof-river full pool)...................................................................................................................207

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Figure 48. Dissolved oxygen suitability for all salmonids during the extreme low flow year of 1992 

modeled under proposed operations and run-of-river full pool operations. Suitability time 

series are shown for RM 242 (near Hells Canyon dam), RM 239 (below Granite Rapids), 

RM 222, (near Salt Creek), RM 191 (above Salmon River), and RM 152 (near Asotin) 

of the Hells Canyon reach .....................................................................................................208

Figure 49. Dissolved oxygen suitability for all salmonids during the medium flow year of 1995 modeled 

under proposed operations and run-of-river full pool operations. Suitability time series are 

shown for RM 242 (near Hells Canyon dam), RM 239 (below Granite Rapids), RM 222, 

(near Salt Creek), RM 191 (above Salmon River), and RM 152 (near Asotin) of the Hells 

Canyon reach.........................................................................................................................209

Figure 50. Dissolved oxygen suitability for all salmonids during the extreme high flow year of 1997 

modeled under proposed operations and run-of-river full pool operations. Suitability time 

series are shown for RM 242 (near Hells Canyon dam), RM 239 (below Granite Rapids), 

RM 222, (near Salt Creek), RM 191 (above Salmon River), and RM 152 (near Asotin) 

of the Hells Canyon reach .....................................................................................................210

Figure 51. Time series of temperature suitability for bull trout during the extreme low flow year of 

1992 modeled under proposed operations and run-of-river full pool operations. Suitability 

times series are shown for RM 242 (near Hells Canyon dam) RM 191 (above Salmon 

River), and RM 152 (near Asotin) of the Hells Canyon reach ..............................................211

Figure 52. Time series of temperature suitability for bull trout during the medium flow year of 1995 

modeled under proposed operations and run-of-river full pool operations. Suitability times 

series are shown for RM 242 (near Hells Canyon dam) RM 191 (above Salmon River), 

and RM 152 (near Asotin) of the Hells Canyon reach ..........................................................212

Figure 53. Dissolved oxygen suitability for all salmonids during the extreme high flow year of 1997 

modeled under proposed operations and Run-of River Full Pool operations. Suitability time 

series are shown for RM 242 (near Hells Canyon dam), RM 239 (below Granite Rapids), 

RM 222, (near Salt Creek), RM 191 (above Salmon River), and RM 152 (near Asotin) 

of the Hells Canyon reach .....................................................................................................213

Figure 54. Mean catch per unit effort for all years combined and selected species ...............................219

Figure 55. Location of Idaho Power hatchery facilities..........................................................................222

Figure 56. Hourly total wetted stream area predicted for the upper Hells Canyon reach (Hells Canyon 

dam to the Salmon River confluence) modeled under the Proposed Operations during the 

extremely low flow year of 1992 (top), the medium flow year (middle) and the extremely 

high flow year of 1997 (bottom) ...........................................................................................232

Figure 57. Hourly total wetted stream area predicted for the upper Hells Canyon reach (Hells Canyon 

dam to the Salmon River confluence) modeled under Scenario 1b, Year-round 2-InchesPer-Hour Ramping Rate, during the extremely low flow year of 1992 (top), the medium 

flow year (middle) and the extremely high flow year of 1997 (bottom)...............................233

Figure 58. Hourly total wetted stream area predicted for the upper Hells Canyon reach (Hells Canyon 

dam to the Salmon River confluence) modeled under Scenario 1c, Year-round 6-InchesPer-Hour Ramping Rate, during the extremely low flow year of 1992 (top), the medium 

flow year (middle) and the extremely high flow year of 1997 (bottom)...............................234

Figure 59. Hourly total wetted stream area predicted for the upper Hells Canyon reach (Hells Canyon 

dam to the Salmon River confluence) modeled under the Flow Augmentation Scenario during 

the extremely low flow year of 1992 (top), the medium flow year (middle) and the extremely 

high flow year of 1997 (bottom) ...........................................................................................235

Figure 60. Hourly total wetted stream area predicted for the upper Hells Canyon reach (Hells Canyon 

dam to the Salmon River confluence) modeled under the Navigation Scenario during the 

extremely low flow year of 1992 (top), the medium flow year (middle) and the extremely 

high flow year of 1997 (bottom) ...........................................................................................236

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Figure 61. Hourly total wetted stream area predicted for the lower Hells Canyon reach (Salmon River 

confluence to Lower Granite reservoir) modeled under Proposed Operations during the 

extremely low flow year of 1992 (top), the medium flow year (middle) and the extremely 

high flow year of 1997 (bottom) ...........................................................................................237

Figure 62. Hourly total wetted stream area predicted for the lower Hells Canyon reach (Salmon River 

confluence to Lower Granite reservoir) modeled under Scenario 1b, Year-round 2-InchesPer-Hour Ramping Rate, during the extremely low flow year of 1992 (top), the medium 

flow year (middle) and the extremely high flow year of 1997 (bottom)...............................238

Figure 63. Hourly total wetted stream area predicted for the lower Hells Canyon reach (Salmon River 

confluence to Lower Granite reservoir) modeled under Scenario 1c, Year-round 6-InchesPer-Hour Ramping Rate, during the extremely low flow year of 1992 (top), the medium 

flow year (middle) and the extremely high flow year of 1997 (bottom)...............................239

Figure 64. Hourly total wetted stream area predicted for the lower Hells Canyon reach (Salmon River 

confluence to Lower Granite reservoir) modeled under the Flow Augmentation Scenario 

during the extremely low flow year of 1992 (top), the medium flow year (middle) and the 

extremely high flow year of 1997 (bottom) ..........................................................................240

Figure 65. Hourly total wetted stream area predicted for the lower Hells Canyon reach (Salmon River 

confluence to Lower Granite reservoir) modeled under the Navigation Scenario during the 

extremely low flow year of 1992 (top), the medium flow year (middle) and the extremely 

high flow year of 1997 (bottom) ...........................................................................................241

Figure 66. Weighted useable area versus discharge for fall Chinook juvenile habitat above the 

Salmon River (Hells Canyon dam to the Salmon River confluence) and below the Salmon 

River (Salmon River confluence to Lower Granite reservoir) predicted using the 2D 

habitat model .........................................................................................................................251

Figure 67. Weighted useable area versus discharge for fall Chinook juvenile habitat upstream of the 

Salmon River (Hells Canyon dam to the Salmon River confluence) and downstream of the 

Salmon River (Salmon River confluence to Lower Granite reservoir) predicted using the 

1D habitat model ...................................................................................................................252

Figure 68. Hourly weighted useable area for fall Chinook juveniles upstream of the Salmon River 

simulated for proposed operations using the 2D model for three water year types ..............253

Figure 69. Hourly weighted useable area for fall Chinook juveniles upstream of the Salmon River 

simulated for proposed operations using the 1D model for three water year types ..............254

Figure 70. Flow augmentation water provided from Brownlee reservoir and total flow augmentation 

water provided from the Snake River basin ..........................................................................264

Figure 71. Estimated survival probabilities (with standard errors) from the point of release in the Snake 

River (Billy Creek [RM 164.7] or Pittsburg Landing [RM 215]) to the tailrace of Lower 

Granite dam for PIT-tagged hatchery fall Chinook salmon, 1995–2000 ..............................266

Figure72. Relations between the estimated probability of survival to Lower Granite dam and indices of 

discharge, temperature, and transparency and release date for groups of PIT-tagged hatchery 

fall Chinook salmon released at Pittsburg Landing and Billy Creek on the free-flowing 

Snake River, 1995–2000. ......................................................................................................267

Figure 73. Detection rate of PIT-tagged Snake River subyearling Chinook salmon at Lower Granite 

dam, 1992–1995 and its relation to mean summer flow (top) and maximum summer water 

temperature (bottom) in Lower Granite reservoir. Ninety-five percent simultaneous 

confidence intervals are shown on either side of the regression lines...................................268

Figure 74. Survival (with 95 percent confidence intervals) to the tailrace of Lower Granite dam for PITtagged wild subyearling fall Chinook salmon in 1998 (top), 1999 (center), and 2000 (bottom), 

predicted from mean flows and water temperatures with and without summer flow 

augmentation .........................................................................................................................269

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Figure 75. Estimated survival between McNary dam tailrace and John Day dam tailrace plotted against 

various river condition indices for run-of-river subyearling Chinook salmon released in 

tailrace of McNary dam, 1999, 2001, and 2002. Flow index panel illustrates simple linear 

regression line without year effects. Temperature index panel illustrates constant mean 

survival above and below 20°C.............................................................................................270

Figure 76. 1992 simulated hourly Hells Canyon outflow temperatures for the Flow Augmentation 

Scenario and Proposed Operations........................................................................................272

Figure 77. Total adult fall Chinook salmon passing Lower Granite dam and total flow augmentation 

volume provided from the Snake River basin during the primary year of outmigration 

(4 years prior to adult return data).........................................................................................273

Figure 78. Total adult fall Chinook salmon passing Lower Granite dam and total flow augmentation 

volume provided from Brownlee reservoir during the primary year of outmigration 

(4 years prior to adult return data).........................................................................................274

Figure 79. Weighted useable area versus discharge relationships for bull trout (upper plot) and redband 

trout (lower plot) in the upper and lower Hells Canyon reaches...........................................279

Figure 80. Hourly weighted useable area for bull trout adults in the upper Hells Canyon reach (Hells 

Canyon dam to the Salmon River confluence) simulated for Proposed Operations for three 

water year types.....................................................................................................................281

Figure 81. Hourly weighted useable area for bull trout adults in the upper Hells Canyon reach (Hells 

Canyon dam to the Salmon River confluence) simulated for the Flow Augmentation 

Scenario for three water year types .......................................................................................282

Figure 82. Hourly weighted useable area for redband trout adults in the upper Hells Canyon reach (Hells 

Canyon dam to the Salmon River confluence) simulated for Proposed Operations for three 

water year types.....................................................................................................................283

Figure 83. Hourly weighted useable area for redband trout adults in the upper Hells Canyon reach (Hells 

Canyon dam to the Salmon River confluence) simulated for the Flow Augmentation 

Scenario for three water year types .......................................................................................284

Figure 84. Hourly weighted useable area for white sturgeon spawning in the upper Hells Canyon reach 

(Hells Canyon dam to the Salmon River confluence) simulated for Proposed Operations 

for three water year types ......................................................................................................287

Figure 85. Hourly weighted useable area for white sturgeon spawning in the upper Hells Canyon reach 

(Hells Canyon dam to the Salmon River confluence) simulated for the Flow Augmentation 

Scenario for three water year types .......................................................................................289

Figure 86. Hourly weighted useable area for white sturgeon incubation in the upper Hells Canyon reach 

(Hells Canyon dam to the Salmon River confluence) simulated for Proposed Operations 

for three water year types ......................................................................................................290

Figure 87. Hourly weighted useable area for white sturgeon incubation in the upper Hells Canyon reach 

(Hells Canyon dam to the Salmon River confluence) simulated for the Flow Augmentation 

Scenario for three water year types .......................................................................................291

Figure 88. Hourly weighted useable area for white sturgeon larvae in the upper Hells Canyon reach 

(Hells Canyon dam to the Salmon River confluence) simulated for Proposed Operations for 

three water year types............................................................................................................292

Figure 89. Hourly weighted useable area for white sturgeon larvae in the upper Hells Canyon reach 

(Hells Canyon dam to the Salmon River confluence) simulated for the Flow Augmentation 

Scenario for three water year types .......................................................................................293

Figure 90. Hourly weighted useable area for white sturgeon young-of-year in the upper Hells Canyon 

reach (Hells Canyon dam to the Salmon River confluence) simulated for Proposed 

Operations for three water year types....................................................................................294

Figure 91. Hourly weighted useable area for white sturgeon young-of-year in the upper Hells Canyon 

reach (Hells Canyon dam to the Salmon River confluence) simulated for the Flow 

Augmentation Scenario for three water year types ...............................................................295

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Figure 92. Hourly weighted useable area for white sturgeon juveniles in the upper Hells Canyon reach 

(Hells Canyon dam to the Salmon River confluence) simulated for Proposed Operations 

for three water year types ......................................................................................................296

Figure 93. Hourly weighted useable area for white sturgeon juveniles in the upper Hells Canyon reach 

(Hells Canyon dam to the Salmon River confluence) simulated for the Flow Augmentation 

Scenario for three water year types .......................................................................................297

Figure 94. Hourly weighted useable area for white sturgeon adults in the upper Hells Canyon reach 

(Hells Canyon dam to the Salmon River confluence) simulated for Proposed Operations 

for three water year types ......................................................................................................298

Figure 95. Hourly weighted useable area for white sturgeon adults in the upper Hells Canyon reach 

(Hells Canyon dam to the Salmon River confluence) simulated for the Flow Augmentation 

Scenario for three water year types .......................................................................................299

Figure 96. Length-frequency distributions (adjusted for gear selectivity) of white sturgeon sampled 

with setlines in the Snake River reaches from Swan Falls to Lower Granite dams ..............303

Figure 97. Smallmouth bass spawning period and Brownlee reservoir elevations predicted for three 

water year types for Proposed Operations and for Scenario 2, Flow Augmentation ............305

Figure 98. Crappie spawning period and Brownlee reservoir elevations predicted for three water year 

types for Proposed Operations and for Scenario 2, Flow Augmentation ..............................306

Figure 99. Channel catfish spawning period and Brownlee reservoir elevations predicted for three 

water year types for Proposed Operations and for Scenario 2, Flow Augmentation ............307

Figure 100. Elevation change during an estimated active nest duration of 16 days for channel catfish 

nests constructed between June 15 and July 31.....................................................................309

Figure 101. Percent occurrence of fish with severe gas bubble trauma (GBT) and percent saturation of 

TDG taken during weekly sampling in the Brownlee tailwater in the spring of 2006..........316

Figure 102. Percent occurrence of fish with severe gas bubble trauma (GBT) and percent saturation of 

TDG taken during weekly sampling in the Oxbow forebay/pool in the spring of 2006 .......317

Figure 103. Percent occurrence of fish with severe gas bubble trauma (GBT) and percent saturation of 

TDG taken during weekly sampling in the Oxbow bypassed reach in the spring of 2006 ...318

Figure 104. Percent occurrence of fish with severe gas bubble trauma (GBT) and percent saturation of 

TDG taken during weekly sampling in Hells Canyon reservoir near the Oxbow powerhouse 

discharge in the spring of 2006 .............................................................................................319

Figure 105. Final fall Chinook salmon fry mortality relative to the highest water temperature (oC) that 

embryos were exposed to during natural/variable temperature experiments (data from Olson 

and Foster [1955] shown in square symbols, Olson et al. [1970] shown in diamonds, and 

Geist et al. [2006] shown in triangles)...................................................................................322

Figure 106. Plan view of Hells Canyon trap modification Alternative 3 revised.....................................339

Figure 107. Catch rates and hours of effort expended sampling for white sturgeon with setlines in the 

Snake River between Shoshone Falls and the confluence with the Salmon River................369

Figure 108. Estimated total and wild escapement of fall-run Chinook salmon at Lower Granite dam, 

1975–2003.............................................................................................................................439

Figure 109. Estimated total and wild escapement of spring/summer Chinook salmon at Lower Granite 

dam, 1975–2003 ....................................................................................................................440

Figure 110. Sockeye salmon passage counts at Lower Granite dam for years 1975–2004...................... 441

Figure 111. Estimated total and wild escapement of steelhead at Lower Granite dam for the 1984–1985 

through 2003–2004 run years................................................................................................442

Figure 112. Simulated flows below Hells Canyon dam and at Anatone, WA for a representative extreme 

low flow year (1992) for proposed operations (scenario 1d used as surrogate) and with 

Brownlee reservoir held at minimum operating pool (scenario 5). Scenario 1d was used to 

remove diurnal fluctuations caused by load following operations to facilitate the visual 

comparison of daily average flows........................................................................................460

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Figure 113. Simulated flows below Hells Canyon dam and at Anatone, WA for a representative medium 

flow year (1995) for proposed operations (scenario 1d used as surrogate) and with Brownlee 

reservoir held at minimum operating pool (scenario 5). Scenario 1d was used to remove 

diurnal fluctuations caused by load following operations to facilitate the visual comparison 

of daily average flows ...........................................................................................................461

Figure 114. Simulated flows below Hells Canyon dam and at Anatone, WA for a representative extreme 

high flow year (1997) for proposed operations (scenario 1d used as surrogate) and with 

Brownlee reservoir held at minimum operating pool (scenario 5). Scenario 1d was used to 

remove diurnal fluctuations caused by load following operations to facilitate the visual 

comparison of daily average flows........................................................................................462

Figure 115. Hells Canyon Project recreational sites.................................................................................507

Figure 116. Hours of recreational use by year and zone...........................................................................512

Figure 117. Average percentage of total warm-season hours of recreational use by activity. ................514

Figure 118. Total hours of warm-season recreational use by primary activity.........................................515

Figure 119. Annual number of boaters by status (commercial or private) and type (float or power) 

registered as entering the HCNRA through Hells Canyon Creek portal...............................517

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LIST OF TABLES 

Table ES-1.Summary of effects of Idaho Power’s Proposal and Staff Alternative....................................xli

Table 1. Summary of Idaho Power’s preferred portfolio summary and timeline....................................5

Table 2. Summary of operating constraints for Idaho Power’s Proposed Operations...........................20

Table 3. Mainstem hydroelectric projects on the Snake River from Shoshone Falls downstream and 

on the lower Columbia River ..................................................................................................51

Table 4. Key features along the main stem of the Snake River.............................................................55

Table 5. Frequency of annual inflows to Brownlee reservoir for five representative years.................. 57

Table 6. Physical characteristics of Brownlee, Oxbow, and Hells Canyon reservoirs..........................59

Table 7. Required flood control draft at Brownlee reservoir based on November 1998 rule curve......64

Table 8. Project-related water rights for the Hells Canyon Project.......................................................66

Table 9. Operational recommendations.................................................................................................70

Table 10. Sediment budget......................................................................................................................93

Table 11. Estimated cumulative annual area of sandbars that would be subject to inundation under 

Proposed Operations and five alternative scenarios..............................................................100

Table 12. Estimated cumulative annual area of sandbars that would be subject to sand mobilization 

under Proposed Operations and five alternative scenarios....................................................101

Table 13. Estimated percent change in cumulative annual area of sandbars that would be subject to 

sand mobilization under five alternative scenarios. Percentages are given relative to the 

area of sand mobilization for Proposed Operations...............................................................103

Table 14. Percent exceedance for selected flows based on flow-duration curves for Proposed 

Operations and five alternative scenarios..............................................................................105

Table 15. Idaho designated beneficial uses and most recent EPA-approved 303(d) listings for the 

Snake River ...........................................................................................................................111

Table 16. Oregon designated beneficial uses and most recent EPA-approved 303(d) listings for the 

Snake River ...........................................................................................................................112

Table 17. TMDL water quality targets for the Snake River–Hells Canyon and applicable Idaho and 

Oregon water quality criteria.................................................................................................113

Table 18. Summary of Snake River tributary flows, water temperatures, and total phosphorus 

loadings, 1980–2003 .............................................................................................................118

Table 19. Percent of days that Hells Canyon Project water temperatures exceeded applicable numeric 

criteria....................................................................................................................................126

Table 20. Summary of turbidity data for various reaches of the project, 1992–1997 ...........................136

Table 21. Summary of total suspended solids data available for the Snake River and its tributaries 

near their terminus, 1970–1997.............................................................................................136

Table 22. Summary comparison of Brownlee reservoir simulated temperatures for Proposed 

Operations and Scenario 2 (Flow Augmentation) .................................................................140

Table 23. Summary comparison of simulated Hells Canyon outflow hourly water temperatures for 

Proposed Operations and Scenario 2 to TMDL water temperature targets...........................142

Table 24. Summary comparison of Brownlee reservoir simulated DO concentrations for Proposed 

Operations and Scenario 2 (Flow Augmentation) .................................................................144

Table 25. Summary comparison of simulated Hells Canyon outflow hourly DO concentrations for 

Proposed Operations and Scenario 2 (Flow Augmentation) to applicable criteria and 

TMDL targets........................................................................................................................146

Table 26. Summary of the occurrence of hourly modeled Brownlee outflows of greater than 38,000 

cfs,a

 which likely would result in TDG exceeding the 110-percent of saturation criterion 

with current spillway structures and operations ....................................................................148

Table 27. Summary of the occurrence of hourly modeled Hells Canyon dam gage (No. 13290450) 

flows of greater than 30,500 cfs, which likely would result in TDG exceeding the 

110 percent of saturation criterion with current spillway structures and operations.............148

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Table 28. Summary comparison of Brownlee reservoir simulated DO concentrations for Proposed 

Operations with and without proposed reservoir DO supplementation.................................157

Table 29. Principal tributaries to the Snake River that historically supported anadromous fish, with 

the location of Brownlee, Oxbow and Hells Canyon dams shown for reference..................184

Table 30. Number of rainbow trout stocked by IDFG and ODFW at project reservoirs and at major 

tributaries from 1987 to 1997................................................................................................197

Table 31. Abundance estimates for white sturgeon populations in Snake River reaches from Shoshone 

Falls to Lower Granite dam...................................................................................................215

Table 32. Fish sampled in project reservoirs listed by species code, common and scientific names, 

and native or nonnative status ...............................................................................................218

Table 33. Estimated average annual angling effort, catch and harvest rates by species for 1994 

through 1998, and 2000.........................................................................................................220

Table 34. Distribution of steelhead smolts produced at Niagara Springs hatchery for brood years 

1965 through 1999.................................................................................................................223

Table 35. Estimated adult contribution of steelhead produced at Niagara Springs hatchery from 1979 

through 1998 .........................................................................................................................225

Table 36. Distribution of spring Chinook smolts released for mitigation purposes from the Rapid 

River hatchery for brood years 1964 through 1998...............................................................226

Table 37. Distribution of summer and spring Chinook smolts released for mitigation purposes from 

the Pahsimeroi hatchery for brood years 1981 through 2000................................................227

Table 38. Estimated adult contribution of spring Chinook produced at the Rapid River hatchery from 

1978 through 1998.................................................................................................................229

Table 39. Distribution of fall Chinook smolts produced at the Oxbow hatchery for brood years from 

1961 through 2000.................................................................................................................229

Table 40. Estimated maximum seasonal percentage of streambed that would be subject to daily 

dewatering upstream and downstream of the Salmon River under Proposed Operations 

and four alternative scenarios................................................................................................242

Table 41. Fall Chinook spawning flow, incubation flow, and spawner survey recommendations. ......244

Table 42. Estimated redd capacity for the Snake River at selected discharge levels from Hells 

Canyon dam...........................................................................................................................246

Table 43. Ramping rate and minimum flow recommendations outside of the fall Chinook spawning 

season. ...................................................................................................................................248

Table 44. Estimated minimum, maximum, and maximum percent daily fluctuation in WUA during 

the fall Chinook rearing period (March 15 to June 15), based on 2D modeling of fall 

Chinook rearing habitat in the Hells Canyon reach upstream and downstream of the 

Salmon River.........................................................................................................................255

Table 45. Estimated minimum, maximum, and maximum percent daily fluctuation in WUA during 

the fall Chinook rearing period (March 15 to June 15) based on 1D modeling of fall 

Chinook rearing habitat in the Hells Canyon reach upstream and downstream of the 

Salmon River.........................................................................................................................255

Table 46. Estimated maximum seasonal percentage of streambed that would be subject to daily 

dewatering during the fall Chinook rearing period (March 15 to June 15) upstream and 

downstream of the Salmon River under Proposed Operations and four alternative 

scenarios ................................................................................................................................257

Table 47. Entrapment site locations, flows at which sites disconnect from the river (entrapment flow), 

number of entrapment events, and numbers of age-0 fall Chinook salmon estimated to be 

entrapped and killed between March 15 and June 15, 2005 in the upper Hells Canyon 

reach of the Snake River .......................................................................................................260

Table 48. Total number of fish other than wild age-0 fall Chinook salmon encountered during 

entrapment pool surveys conducted in the upper Hells Canyon reach of the Snake River 

in 2005...................................................................................................................................261

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Table 49. Estimated age-0 fall Chinook salmon entrapment losses under the 2005 minimum flow 

(8,700 cfs) and three alternative modeled flows released from Hells Canyon dam ..............261

Table 50. Estimated age-0 fall Chinook salmon entrapment losses under the 2005 ramping rate 

(12-inches-per-hour) and three alternative ramping rates applied to Hells Canyon dam 

operations at an inflow of 11,340 cfs (observed April 26, 2005)..........................................262

Table 51. Total number of yearling and subyearling fall Chinook salmon released from acclimation 

sites in the Hells Canyon reach (Pittsburg Landing and Captain John Rapids) and in the 

Clearwater River (Big Canyon), fall Chinook returns over Lower Granite dam, and redd 

counts in the Clearwater and Snake rivers. ...........................................................................275

Table 52. Estimated minimum, maximum, and maximum percent daily fluctuation in WUA for bull 

trout and redband trout adults in the upper Hells Canyon reach (Hells Canyon dam to the 

Salmon River)........................................................................................................................280

Table 53. Estimated minimum, maximum, and maximum percent daily fluctuation in WUA for white 

sturgeon in the upper Hells Canyon reach (Hells Canyon dam to the Salmon River) ..........300

Table 54. Spawning seasons, nesting duration and nest depths of smallmouth bass, crappie, and 

channel catfish in Brownlee reservoir ...................................................................................304

Table 55. The ercentage of each species collected during the 2006 sampling season (January–June) 

by the rank of GBT. Ranks 1 through 4 represent percentages of skin area covered with 

bubbles of 0. 1 to 5, 6 to 25, 26 to 50, and >50.....................................................................315

Table 56. Anadromous fish restoration recommendations....................................................................327

Table 57. Water quality improvement recommendations related to anadromous fish restoration ........329

Table 58. Incremental smolt yields with fish passage provided at Idaho Power’s mainstem Snake 

River dams under various passage scenarios......................................................................... 333

Table 59. Phased anadromous fish passage plan...................................................................................334

Table 60. Estimated smolt production and adult returns from habitat made accessible under the 

phased restoration approach (assumes that no passage is provided at other dams in 

tributary streams)...................................................................................................................336

Table 61. Tributary habitat enhancement recommendations.................................................................346

Table 62. Recommendations for providing marine-derived nutrients...................................................350

Table 63. Hatchery recommendations...................................................................................................354

Table 64. Additional hatchery/surplus fish recommendations. .............................................................357

Table 65. Recommended measures related to white sturgeon conservation .........................................365

Table 66. Percentage of fall Chinook redds observed in the mainstem Snake River, by reach, 1991 

to 2000...................................................................................................................................373

Table 67. Special status species and species groups used to focus evaluations of project effects ........387

Table 68. Acres of existing upland and riparian cover types along the Snake River downstream of 

Hells Canyon dam, and the change in acreage that would result from implementation of 

various flow scenarios ...........................................................................................................398

Table 69. Minimum acreage proposed or recommended for acquisition to address project effects 

on terrestrial resources...........................................................................................................414

Table 70. Acreage of current project effects, by habitat type................................................................416

Table 71. Acreage of anticipated project effects resulting from change in flow regime and shoreline 

erosion)..................................................................................................................................417

Table 72. Releases of fall Chinook hatchery smolts into the Snake River basin .................................. 438

Table 73. Bald eagle nests in the Hells Canyon Project area, as of 2005..............................................448

Table 74. Annual productivity for bald eagle nests in the Hells Canyon Project vicinity.....................449

Table 75. Bald eagle nest sites, potential noise disturbance, and potential buffers...............................470

Table 76. Number of registered boaters entering the HCNRA through Hells Canyon Creek, 

Pittsburg Landing, Dug Bar, and Cache Creek portals combined, by year...........................505

Table 77. Formal and semi-formal public recreational facilities within the Hells Canyon Project 

boundary................................................................................................................................508

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Table 78. Descriptive statistics of dispersed, undeveloped, and informal recreational sites within 

the project boundary..............................................................................................................510

Table 79. Total annual recreation days by development and season..................................................... 511

Table 80. Percent of warm-season recreation days by development.....................................................511

Table 81. Physical capacity of project sites developed for RVs and tents ............................................513

Table 82. Percentage of comments by major category and reservoir....................................................515

Table 83. Snake River fluctuation-related problems experienced by boaters .......................................519

Table 84. Typical source of flow information for boaters who checked flows before their trip 

(% using various sources)......................................................................................................519

Table 85. Elevation of the toe of boat ramps at Brownlee reservoir parks compared to full pool 

elevation ................................................................................................................................521

Table 86. Proposed and recommended recreational facility improvement measures............................529

Table 87. Range of drawdown zone (feet) for Brownlee reservoir under Proposed Operations and 

the Flow Augmentation Scenario during July to October representing the following water 

conditions: extremely low flow (1992), medium flow (1995) and extremely high flow 

(1997) ....................................................................................................................................559

Table 88. Land ownership and management by development within the Hells Canyon Project 

proposed project boundary, in acres...................................................................................... 566

Table 89. Idaho Power’s sales of electricity in 2004.............................................................................583

Table 90. Idaho Power’s average electricity rates compared to Idaho, Oregon, and U.S. averages in 

cents/kWh, 2004....................................................................................................................584

Table 91. Annual property taxes paid by Idaho Power to counties bordering the Hells Canyon 

Project in 2000.......................................................................................................................585

Table 92. Donations by Idaho Power to counties bordering the Hells Canyon Project for enhanced 

services in 2002 and 2003 .....................................................................................................585

Table 93. Total visitor spending by county ...........................................................................................586

Table 94. Total population and population percentage by race categories............................................587

Table 95. Poverty statistics and housing affordability statistics...........................................................587

Table 96. Descriptive statistics of reservations in the project vicinity ..................................................588

Table 97. Cost and net annual generation of the proposed and Staff Alternative measures .................589

Table 98. Estimated change in Idaho Power rates by rate class for the proposed and Staff Alternative 

measures ................................................................................................................................590

Table 99. Contingent valuation study results for recreational expenditures in Oregon, Washington 

and Idaho (n = 143) and estimated project-related expenditures for recreational activities..591

Table 100. Summary of key parameters for economic analysis of the Hells Canyon Hydroelectric 

Project....................................................................................................................................595

Table 101. Costs associated with the No-action Alternative for the Hells Canyon Project .................... 596

Table 102. Annualized lost benefits associated with supplemental operational measures included in 

the Staff Alternative or recommended by the Corps for navigation purposes ......................598

Table 103. Summary by resource area of capital and one-time costs, annual operation and maintenance 

costs, and total annualized costs of additional environmental measures included in Idaho 

Power’s Proposal and the Staff Alternative...........................................................................601

Table 104. Summary of the annual cost, power benefits, and net benefits for the No-action Alternative, 

Idaho Power’s Proposal, the Staff Alternative, and the Staff Alternative with Mandatory 

Conditions .............................................................................................................................603

Table 105. Summary of effects of Idaho Power’s Proposal and Staff Alternative..................................623

Table 106. Special status and rare endemic plants identified for inclusion in management and 

monitoring plans by agencies, tribes, or staff in relation to Staff Alternative.......................684

Table 107. Special status wildlife identified for inclusion in monitoring and management plans, or for 

which agencies, tribes or staff recommended specific management measures, in 

relationship to Staff Alternative ............................................................................................684

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Table 108. Fish and wildlife agency recommendations for the Hells Canyon Project............................716

Table 109. Interior and Forest Service modified 4(e) conditions for the Hells Canyon Project. ............739

Table 110. Summary of effect determinations for fish, plants, and wildlife ...........................................747

Table 111. Measures included in the Staff Alternative relevant to objectives of Columbia River Fish 

and Wildlife Program subbasin plans....................................................................................753

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Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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ACRONYMS AND ABBREVIATIONS 

ACEC area of critical environmental concern 

ADA Americans with Disabilities Act 

Advisory Council Advisory Council of Historic Preservation 

AIR additional information request 

aMW average megawatt 

APE Area of Potential Effect 

AR American Rivers 

BLM Bureau of Land Management 

BMP best management practices 

BOR Bureau of Reclamation 

°C degrees Celsius 

cfs cubic feet per second 

CFR Code of Federal Regulations 

Commerce U.S. Department of Commerce 

Commission Federal Energy Regulatory Commission 

Corps U.S. Army Corps of Engineers 

CRMP Cultural Resources Management Plan 

CWA Clean Water Act 

CWMA Cooperative Weed Management Area 

DO dissolved oxygen 

EA environmental assessment 

EIS environmental impact statement 

EPA U.S. Environmental Protection Agency 

EPAct Energy Policy Act of 2005 

ESA Endangered Species Act 

°F degrees Fahrenheit 

FERC Federal Energy Regulatory Commission 

FMR fire modified rock 

Forest Service U.S. Forest Service 

FPA Federal Power Act 

FWS U.S. Fish and Wildlife Service 

GBT gas bubble trauma 

HART Hydropower Application Review Team 

HCNRA Hells Canyon National Recreation Area 

HCRMP Hells Canyon Resource Management Plan 

HEP Habitat Evaluation Procedure 

HGMP Habitat and Genetic Management Plan 

HPMP Historic Properties Management Plan 

I&E information and education 

Idaho Power Idaho Power Company 

IDEQ Idaho Department of Health and Welfare, Division of Environmental Quality 

IDFG Idaho Department of Fish and Game 

IDPR Idaho Department of Parks and Recreation 

Interior U.S. Department of the Interior 

IRU Idaho Rivers United 

ISAB Independent Scientific Advisory Board 

IWHP Integrated Wildlife Habitat Program 

kaf thousand acre-feet 

kV kilovolt 

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kWh kilowatt-hour 

mg/L milligram per liter 

MHWM mean high water mark 

msl msl 

MW megawatt 

MWh megawatt-hours 

National Register National Register of Historic Places 

NEPA National Environmental Policy Act 

NGO non-governmental organization 

NHPA National Historic Preservation Act 

NMFS National Marine Fisheries Service 

NPDES National Pollutant Discharge Elimination System 

NPPVA Northwest Professional Power Vessel Association 

NTU nephelometric turbidity unit 

O&M operation and maintenance 

ODEQ Oregon Department of Environmental Quality 

ODFW Oregon Department of Fish and Wildlife 

ODSL Oregon Department of State Lands 

OPRD Oregon Parks and Recreation Department 

ORV outstanding remarkable value 

OSMB Oregon State Marine Board 

OWRD Oregon Water Resources Department 

PA Programmatic Agreement 

pH potential hydrogen (a measure of acidity and alkalinity) 

PME protection, mitigation, and enhancement 

RAMP Recreation Adaptive Management Plan 

RARWG Recreation and Aesthetics Resource Work Group 

RM river mile 

ROS Recreation Opportunity Spectrum 

RRWG Recreation Resource Work Group 

RV recreational vehicle 

SHPO State Historic Preservation Officer 

SMA special management area 

SRBA Snake River Basin Adjudication 

TCP traditional cultural property 

TDG total dissolved gas 

TESSMP Threatened, Endangered, and Sensitive Species Management Plan 

TMDL total maximum daily load 

TRWG Terrestrial Resources Work Group 

TSS total suspended solids 

TSS/L total suspended solids per liter 

μg/L microgram per liter 

USGS U.S. Geological Survey 

VRMP Visual Resource Management Plan 

WMA wildlife management area 

WMMP Wildlife Mitigation and Management Plan 

WUA weighted useable area 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
xxxv 

EXECUTIVE SUMMARY 

This final environmental impact statement (EIS) for relicensing the Hells Canyon Hydroelectric 

Project has been prepared by the staff of the Federal Energy Regulatory Commission (Commission or 

FERC) to fulfill the requirements of the National Environmental Policy Act (NEPA); the Commission’s 

implementing regulations under Title 18, Code of Federal Regulations (CFR), Part 380; and the Council 

on Environmental Quality regulations for implementing NEPA (40 CFR Parts 1500–1508). The purpose 

of this document is to inform the Commission, the public, and the various federal and state agencies, 

tribes, and non-governmental organizations about the potential environmental effects of the proposed 

project and its reasonable alternatives. 

The Commission must decide whether to relicense the Hells Canyon Project and, if so, what 

conditions to place on any license issued. In deciding whether to authorize the continued operation of the 

hydroelectric project, the Commission must determine that the project will be best adapted to a 

comprehensive plan for improving or developing a waterway. In addition to the power and 

developmental purposes for which licenses are issued (e.g., flood control, irrigation, and water supply), 

the Commission must give equal consideration to the purposes of energy conservation; the protection of, 

mitigation of damage to, and enhancement of fish and wildlife (including related spawning grounds and 

habitat); the protection of recreational opportunities; and the preservation of other aspects of 

environmental quality. This final EIS evaluates the potential natural resource benefits, environmental 

effects, and economic costs associated with granting a new FERC license for the Hells Canyon Project. 

The alternatives examined include the following: (1) No Action; (2) Idaho Power’s Proposal; (3) the 

Staff Alternative; and (4) the Staff Alternative with Mandatory Conditions, which includes conditions 

required by agencies under section 18 and section 4(e) of the Federal Power Act and section 401 of the 

Clean Water Act. 

Idaho Power’s Proposal 

On July 21, 2003, Idaho Power Company (Idaho Power or Applicant) filed an application for 

license with the Commission for a new license for the Hells Canyon Project, located on the Snake River 

in Washington and Adams counties, Idaho, and Wallowa and Baker counties, Oregon. The current 

license expired on July 31, 2005, and the project is operating under an annual license. 

The Hells Canyon Project consists of three developments (dams, reservoirs, and powerhouses) on 

the segment of the Snake River forming the border between Idaho and Oregon. The three developments 

are Brownlee, Oxbow, and Hells Canyon, which, combined, provide 1,167 megawatts (MW) of power 

generating capacity. 

The Hells Canyon Project is Idaho Power’s largest power generating resource, providing 

approximately 70 percent of Idaho Power’s annual hydroelectric generation and about 40 percent of the 

company’s total annual generation. With extensive reservoir storage capacity at the Brownlee 

development, the Hells Canyon Project provides the major portion of Idaho Power’s peaking and loadfollowing capability. In the absence of the Hells Canyon Project, Idaho Power’s estimated requirements 

for new power generating resources over the 2004–2013 planning horizon would more than double to 

2,143 MW, and we conclude in this final EIS that there is a continuing need for the project’s power 

generating capacity. 

Specifically, Idaho Power’s Proposal has four aspects: 

1. Continuing to operate and maintain the existing project facilities, which consist of the 

following: 

 The Brownlee development, completed in 1958, with facilities that include: (1) a 

1,380-foot-long, 395-foot-high, clay-core, earth and rockfill dam; (2) an impoundment 

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xxxvi 

approximately 57 miles long with a surface area of 14,621 acres and a total volume of 

1,420,062 acre-feet; and (3) a reinforced concrete powerhouse containing five vertical 

Francis turbine generators, having a combined rated capacity of 585.4 MW. 

 The Oxbow development, completed in 1961, with facilities that include: (1) a 960-

foot-long, 209-foot-high, clay-core earth and rockfill dam; (2) a 12-mile-long 

impoundment, with a surface area of 1,150 acres and a total volume of 58,385 acrefeet; (3) a reinforced concrete powerhouse containing four vertical Francis generators, 

having a combined rated capacity of 190 MW; and (4) a 2-mile-long bypassed reach 

during low-flow conditions. 

 The Hells Canyon development, completed in 1967, with facilities that include: (1) a 

910-foot-long, 330-foot-high, cast-in-place concrete gravity dam with integral spillway, 

intake, and powerhouse sections; (2) a 25-mile-long impoundment, with a surface area 

of 2,412 acres and a total volume of 167,720 acre-feet; and (3) a reinforced concrete 

powerhouse constructed against the downstream face of the dam, containing three 

vertical Francis generators, having a combined rated capacity of 391.5 MW. 

 One 19-mile-long, 69-kilovolt transmission line (transmission line 945) running from 

the Oxbow switchyard to the Pine Creek substation and then to the Hells Canyon 

substation. 

 Four fish hatcheries and three adult fish traps. 

 Idaho Power-owned recreational facilities, including: (1) Woodhead Park, 

(2) McCormick Park, (3) McCormick overflow, (4) Old Carters Landing, (5) Hibbards 

Landing, (6) Copperfield Park, (7) the Copperfield boat launch, (8) Hells Canyon Park, 

(9) Airstrip B, and (10) several informal camping and access sites. 

2. Continuing to operate the project under essentially the same constraints as those that 

characterize current operations. The project is currently operated to optimize its power and 

energy production value, subject to compliance with license requirements, flood control 

mandates, and certain discretionary criteria adopted by Idaho Power. Because most of the 

usable reservoir capacity in the Hells Canyon Project is contained in the reservoir farthest 

upstream (Brownlee), operations of all three powerhouses and dams are driven by 

operations at the Brownlee development. In summary, typical Brownlee operation over the 

course of a year consists of the following: 

 Starting in mid-January, Brownlee reservoir is drafted (lowered), under the direction of 

the U.S. Army Corps of Engineers (Corps), to provide storage space for springtime 

flood waters. 

 The reservoir refills in late spring, and Idaho Power tries to achieve a near-full 

condition [elevation 2,069 feet mean sea level (msl)] by early June, while maintaining 

releases from Hells Canyon dam sufficient to keep the river downstream of Hells 

Canyon dam above the target flow selected the previous fall for protection of fall 

Chinook salmon spawning and incubation. 

 Once the reservoir refills, Idaho Power initiates a 30-day period of stable water levels 

for protection of Brownlee resident fish spawning. 

 During July, Idaho Power typically tries to keep Brownlee reservoir nearly full 

throughout the month to conserve storage for August, which usually has an aboveaverage monthly system power load, lower market energy availability, and higher 

average market energy prices. High reservoir levels are also advantageous for 

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xxxvii 

reservoir-oriented recreation activities. During August, Idaho Power typically drafts 

Brownlee reservoir to meet system power loads. 

 During late August and through September, Idaho Power adjusts Brownlee reservoir’s 

draft rate so as to be able to achieve the necessary starting elevation for the fall 

Chinook program. This starting elevation ensures a stable spawning flow during the 

spawning period and a nearly full reservoir at the end of the spawning period around 

the first week of December. 

 Beginning in mid-October and lasting through early December, Idaho Power maintains 

a constant outflow from the project, normally between 8,000 and 13,000 cubic feet per 

second (cfs), to ensure that fall Chinook construct their redds (nests) below a certain 

target flow elevation. 

 Throughout the year, flows are managed to meet a year-round 5,000-cfs minimum flow 

and a maximum 1-foot-per-hour ramping rate at Johnson Bar, 18 miles downstream of 

Hells Canyon dam. Also under the current license, Idaho Power operates the project in 

the interest of navigation to maintain a target flow of 13,000 cfs in the Snake River at 

Lime Point (downstream of the Salmon River confluence at River Mile 172), at least 

95 percent of the time. 

3. Implementing a set of 94 environmental measures, the purposes of which include the 

following: 

 Maintain or improve the quality of project waters; 

 Improve hatchery facilities and operations; 

 Protect fall Chinook salmon; 

 Improve the white sturgeon population; 

 Enhance native salmonid populations in project tributaries; 

 Protect resident warm-water fish; 

 Acquire and improve approximately 22,761 acres of upland and 821 acres of riparian 

habitat to benefit wildlife affected by project operation; 

 Control noxious weeds; 

 Protect and interpret archeological and historic resources; 

 Improve recreational sites and facilities; and 

 Improve the appearance of project facilities and minimize visual contrast. 

4. Changing the project boundary to exclude 3,800 acres of federal land surrounding the 

reservoirs above an established reservoir elevation that Idaho Power believes are no longer 

needed for project purposes. 

Staff Alternative 

After evaluating Idaho Power’s Proposal, along with terms and conditions, prescriptions, and 

recommendations from resource agencies, tribes, and other interested parties, we compiled a set of 

environmental measures that we consider appropriate for addressing the resource issues raised in this 

proceeding. We call this the “Staff Alternative.” 

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xxxviii 

Under the Staff Alternative, the project would be operated as proposed by Idaho Power, but with 

the following additional operational constraints: 

• Stricter reservoir refill targets after the flood control season; 

• Releases from the project to augment downstream flows for the purpose of enhancing 

juvenile fall Chinook salmon migration conditions; 

• Additional ramping restrictions during the fall Chinook salmon rearing period; 

• An 8,500-cfs minimum flow downstream of Hells Canyon dam in medium-high and 

extremely high water years; and 

• Warmwater fish spawning protection levels in Brownlee reservoir; 

In addition to the foregoing operation-related measures, the Staff Alternative incorporates most of 

Idaho Power’s proposed environmental measures, but with certain modifications. The Staff Alternative 

also includes 35 environmental measures additional to those proposed by Idaho Power. In recognition of 

the substantial cumulative effects that Idaho Power’s mid-Snake and Hells Canyon projects have had on 

fisheries upstream of the project, including the elimination of anadromous fish runs upstream of Hells 

Canyon dam, numerous measures to benefit resident and anadromous fisheries are included in the Staff 

Alternative. Measures that are focused on enhancing fisheries downstream of the project include 

providing flow augmentation water from Brownlee reservoir to benefit outmigrating juvenile fall Chinook 

salmon, continued management of flows to benefit spawning and incubating fall Chinook salmon, 

restricted ramping rates during the fall Chinook salmon rearing season, and several measures that would 

improve water quality downstream of the project. Measures that would benefit resident fisheries and may 

contribute toward the eventual restoration of anadromous fish to habitat upstream of the project include 

habitat enhancement measures to be implemented in the Pine and Indian creeks and Wildhorse, Powder, 

and Burnt river basins; modification and improvement of the adult fish trap at Hells Canyon dam; 

stocking of surplus hatchery spring Chinook salmon and steelhead in Hells Canyon reservoir and 

construction of a monitoring weir at Pine Creek; the future construction of an adult trap at Oxbow dam 

and weirs at Indian Creek and on the Wildhorse River; and measures designed to meet Idaho Power’s 

share of responsibility for nutrient and temperature loads under the TMDL. Because we conclude that 

resolving water quality and stakeholder issues would require considerable time, we also include measures 

designed to support tribal ceremonial and subsistence fisheries in the near term by developing a plan to 

transplant surplus hatchery spring Chinook salmon and steelhead into select tributaries, constructing 

hatchery facilities to support the streamside incubation box program on the Yankee Fork of the Salmon 

River, and investigating the potential for augmenting populations of white sturgeon by implementing a 

conservation hatchery program. 

Conditions and Recommendations 

Section 4(e) of the Federal Power Act gives the Secretaries of the Interior and Agriculture 

authority to impose conditions on a license issued by the Commission for hydropower projects located on 

“reservations” under the respective Secretary’s supervision. See 16 U.S.C. §§ 796(2), 797(e). 

In a January 26, 2006, filing with the Commission, the U.S Department of the Interior (Interior), 

on behalf of the Bureau of Land Management, submitted 19 preliminary terms and conditions pursuant to 

section 4(e). On February 27, 2006, Idaho Power filed alternative conditions, under section 241 of the 

Energy Policy Act of 2005 (EPAct), for all 19 Interior preliminary conditions. In a May 15, 2006, filing, 

Interior withdrew six of its preliminary conditions, replacing five of them and withdrawing one without 

substitution. On January 3, 2007, Interior filed modified conditions numbered 1–18 pursuant to FPA 

section 4(e). 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
xxxix 

In a January 26, 2006, filing, the U.S. Forest Service (Forest Service) provided 27 preliminary 

section 4(e) terms and conditions. On February 27, 2006, also under section 241 of EPAct, Idaho Power 

filed alternative conditions for 20 of the Forest Service preliminary conditions. The Forest Service 

withdrew and replaced nine of its preliminary conditions in a filing on May 10, 2006, and withdrew and 

replaced a tenth preliminary condition in a June 9, 2006, filing. The remaining 10 alternative conditions 

were subsequently resolved in an agreement between Idaho Power and the Forest Service dated October 

6, 2006. Consistent with the agreement, Idaho Power filed a statement amending its alternative 

conditions on October 6, 2006, and the Forest Service filed its modified conditions on November 2, 2006. 

For a summary of the Interior and Forest Service modified conditions, see section 2.3.1.3. 

Section 18 of the Federal Power Act, 16 U.S.C. § 811, states that the Commission shall require 

construction, maintenance, and operation by a licensee of such fishways as the Secretaries of the U.S. 

Department of Commerce (Commerce) and Interior may prescribe. 

In a January 26, 2006, filing, Interior (for the U.S. Fish and Wildlife Service) provided 

preliminary prescriptions for fishways for bull trout, and in a February 27, 2006, filing, Idaho Power, 

under section 241 of EPAct, presented an alternative to Interior’s prescription. Interior’s January 26, 

2006, filing also requests that the Commission include as a license condition a general reservation of 

authority to prescribe fishways during the term of a new license. In its January 26, 2006, filing, 

Commerce (for the National Marine Fisheries Service) elected not to use its fishway authority to require 

fish passage at any of the project’s dams, but, like Interior, requested that the Commission include as a 

license condition a general reservation of authority to prescribe fishways during the term of a new license. 

On January 3, 2007, Interior filed its modified fishway prescription. For a summary of these 

prescriptions, see section 2.3.1.2. 

The Staff Alternative includes many measures included in Idaho Power’s proposal and its 

application for section 401 water quality certification as well as some of the section 18 fishway 

prescriptions, section 4(e) conditions, section 10(j) recommendations, section 10(a) recommendations, 

and measures developed by the staff. We did not include measures in the Staff Alternative that we find 

are not justified, are unrelated to the project, or would not provide benefits over the staff-developed 

measures. We address all recommendations throughout this final EIS and specifically in section 5.2, 

Discussion of Key Issues. 

The Staff Alternative with Mandatory Conditions includes all the measures in the Staff 

Alternative plus three 4(e) conditions related to recreation and land management that we do not include in 

the Staff Alternative because we conclude that they are not related to the project or are not Idaho Power’s 

responsibility. 

Other Alternatives Considered 

Under the No-action Alternative, the project would continue to operate under the terms and 

conditions of the existing license and of existing settlement agreements or memoranda of understanding 

or agreement. No new environmental measures would be implemented. We use this alternative to 

establish baseline conditions for comparison with Idaho Power’s Proposal and the Staff Alternative, and 

to judge the benefits and costs of any measures that might be required under a new license. 

We also considered federal takeover, issuance of a nonpower license, and project retirement, but 

concluded that none of these alternatives are reasonable in the context of this proceeding. 

Project Effects 

We summarize the more significant differences between Idaho Power’s Proposal and the Staff 

Alternative in table ES-1. Because the Staff Alternative with Mandatory Conditions is so similar to the 

Staff Alternative, we do not list it separately in this summary table. Idaho Power’s proposed operation is 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
xl 

similar to current operations. Therefore, unless otherwise noted, the ongoing effects of project operation 

under Idaho Power’s Proposal are similar to current conditions. 

Based on our independent analysis of the Hells Canyon 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. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
xli 

Table ES-1. Summary of effects of Idaho Power’s Proposal and Staff Alternative. (Source: Staff) Resource Idaho Power’s Proposal Staff AlternaPower Benefits Annual generation (MWh) 6,562,244 6,549,344 Net annual benefits $297,050,500 $283,876,80Sediment Supply and Transport

Effects of Operations Compared to without project conditions: 

• Beach and terrace erosion would continue 

downstream of Hells Canyon dam. 

• The quantity and quality of spawning gravels 

downstream of Hells Canyon dam would continue to be affected by project reservoirs trapping sand and gravel. 

Compared to Idaho Power’s Proposal: • Little or no change in beach and te

Idaho Power’s Proposal. 

• Little or no change in spawning gr

compared to Idaho Power’s Propos

Effects of Environmental Measures

• The quantity, quality, and usage of spawning gravels 

downstream of Hells Canyon dam would be monitored. 

• Restoration of 14 acres on sandbar downstream of 

Hells Canyon dam would help mitigate for reservoir trapping of sand and gravel. 

• Monitoring beach and terrace erosi

information about the effectivenessupport development of possible ad

• Gravel augmentation program wou

reduction in the quantity or quality to adversely affect production of fa

• Restoration of 14 acres of sandbar 

beneficial effect as Idaho Power’s 

Water Quality Effects of Operations • Water temperatures would continue to be cooler in 

spring and summer and warmer in the fall and winter, potentially resulting in reduced viability of fall Chinook salmon eggs and reduced growth potential of fry. 

• The project would continue to lower dissolved 

oxygen (DO) concentrations in and downstream of Brownlee reservoir affecting habitat suitability for fish. 

• The temperature of water released 

during the flow augmentation perioincreased in extreme low flow yearwould occur as flow passes througvolumes. These temperature changeffects on Chinook salmon and othCanyon dam. 

• DO concentrations would be slight

Hells Canyon dam during the flow extremely low flow years. 

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xlii 

Resource Idaho Power’s Proposal Staff Alterna

• Total dissolved gas levels downstream of Brownlee 

dam would continue to exceed the 110-percent of saturation criterion when spill exceeds 3,000 cfs. 

• Total dissolved gas levels downstream of Oxbow dam 

would continue to exceed the 110-percent of saturation criterion coinciding with most Brownlee spill events of more than 3,000 cfs and independent spills at Oxbow dam. 

• Total dissolved gas levels downstream of Hells 

Canyon dam would continue to exceed the 110-percent of saturation criterion during virtually all spill conditions increasing the likelihood of gas bubble trauma. 

• Project operation would continue to result in 

ammonia and trace metal concentration in the reservoirs and bioaccumulation in fish. 

• Ammonia and trace metals would b

more frequently, but bioaccumulatabout the same. 

Effects of Environmental Measures 

• DO supplementation would improve DO levels in the 

immediate vicinity of the proposed oxygen diffuser system in Brownlee reservoir or upstream phosphorus trading would improve water quality in affected tributaries and downstream reaches. 

• Hells Canyon turbine aeration would increase 

summer/fall DO levels downstream of the dam and thereby improve conditions for fall Chinook salmon. 

• Destratification of the deep pool in the Oxbow 

bypassed reach would increase DO levels in this pool and thereby improve native resident salmonid habitat. 

• Installation of spillway flow deflectors at Brownlee 

and Hells Canyon dams combined with total dissolved gas abatement measures at Oxbow dam, and an adaptive total dissolved gas abatement program would reduce the frequency and magnitude of total dissolved gas levels exceeding the 110 percent of saturation criterion and thereby reduce the potential for gas bubble trauma in Oxbow and Hells 

• Monitoring the effectiveness of me

the DO enhancement plan, annual 

interested tribes, and filing of monreports should improve the decisioaddressing project effects on DO a

of associated measures. 

• Establishing a flow and water qual

miles downstream of Hells Canyon monitoring of project effects on wa

• Collection of tissue samples from w

species in Brownlee reservoir for mbioaccumulation of contaminants cprotection of public health and pro

• Monitoring the effectiveness of me

the Temperature Adaptive Managewith agencies and interested tribesimplementation reports should impprocess for addressing project effe

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
xliii 

Resource Idaho Power’s Proposal Staff Alterna

Canyon reservoirs, Oxbow bypassed reach, and the Snake River downstream of Hells Canyon dam. 

• Implementation of a Brownlee bubble upwelling 

system or watershed measures as part of a Temperature Adaptive Management Plan would reduce water temperatures early in the fall Chinook salmon spawning period and improve production potential. 

Aquatic Resources Effects of Operations • Daily flow fluctuations downstream of Hells Canyon 

dam would continue to reduce the abundance of aquatic invertebrates, the primary food base for fish, by about 10 percent. 

• The reduction in aquatic invertebrates would 

especially affect fall Chinook juveniles, which rear in shallow areas that are subject to frequent dewatering. 

• Migration conditions for juvenile fall Chinook salmon 

would remain the same as years when flow augmentation water has not been provided from Brownlee reservoir, but would be less favorable than conditions in most of the past 14 years when flows were voluntarily augmented. 

• More restrictive ramping rates duri

as provisions for monitoring and adon monitoring results, could substasalmon mortalities due to stranding improve the food base during the f

• Invertebrate monitoring would help 

peaking operations affect rare and and invertebrate production, and cooperational modifications to reduce adaptive management. 

• Most available information suppor

augmentation should enhance migrfall Chinook salmon in the Snake arivers, likely increasing adult returinformation on the efficacy of flow license issuance would allow the tidelivered from Brownlee reservoir 

• A fall Chinook spawning flow man

augmentation evaluation report, ansalmon entrapment and stranding smanagement decision process and Chinook salmon in the Snake RiveCanyon. 

Effects of Hatchery Measures • Improved hatchery facilities and a monitoring and 

evaluation program would maintain anadromous fish production at current levels and improve information 

• Consulting with the fisheries mana

interested tribes to define approprihatchery program would help ensu

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
xliv 

Resource Idaho Power’s Proposal Staff Alterna

on the effects of hatchery production on listed species. 

management plans are consistent wresponsibilities under the new licenmanagement goals of the agencies 

• Constructing and operating facilitie

steelhead and Chinook salmon on thelp rebuild, and facilitate the delis

(2) support ceremonial, subsistencethe project area and Snake River b

• Developing and implementing a pl

surplus anadromous fish that return system or the Hells Canyon trap to tributaries in the project area, as win the Snake River basin, would prbenefits because distributing surplusource of marine nutrients; (2) imp(3) provide an opportunity to evalu

viability and survival, as well as smsurvival in Pine Creek; and (4) supand recreational fisheries in the probasin. 

Effects of Other Environmental Measures 

• DO supplementation would improve fish habitat in 

the vicinity of the oxygen diffuser system, if implemented, in the upper end of Brownlee reservoir. 

• Phosphorus trading and watershed measures, if 

implemented, would provide broad benefits to water quality and habitat conditions for fish species within and downstream of the project, and in the tributaries where measures are implemented. 

• Hells Canyon turbine aeration would increase 

summer/fall DO levels downstream of the dam, improving habitat conditions for aquatic resources, including fall Chinook salmon. 

• Reductions in total dissolved gas exceedances 

downstream of Brownlee, Oxbow, and Hells Canyon dams, at low and moderate spill rates, would benefit aquatic resources by reducing gas bubble trauma. 

• Potentially greater temperature and 

provided if additional watershed or measures are implemented based o

• Annual meetings with agencies and 

of monitoring and implementation implementation of additional meassupersaturation, if needed, and redububble trauma within, and downstr

• Implementation of upstream and d

resident salmonids would increase among populations in Pine Creek, Wildhorse River. 

• Construction of weir and trap fishw

Creek and the Wildhorse River wotrout population trends and effectivtrout control and tributary enhance

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
xlv 

Resource Idaho Power’s Proposal Staff Alterna

• Improvement of Hells Canyon dam fish trap would 

reduce stress and injury to fish by allowing onsite sorting and allow fish tagging activities. 

• Implementation of upstream passage for native 

resident salmonids could improve gene flow to some populations, but downstream populations may be reduced due to upstream migration. 

• Construction of a monitoring weir on Pine Creek 

would allow further monitoring of bull trout migration and enable downstream transfer of outmigrants past Hells Canyon dam. 

• Pathogen risk assessment would help manage 

increased risk of pathogen transfer associated with fish transfers. 

• Tributary enhancements and carcass outplants or 

other nutrient supplementation would benefit bull trout and redband trout within the Pine Creek, Indian Creek, and Wildhorse River basins and smaller tributaries to the project. 

• Brook trout suppression efforts could reduce 

competition and hybridization with bull trout in Indian Creek. 

• Implementation of the proposed White Sturgeon 

Conservation Plan and related measures would help rebuild the white sturgeon population in the Swan Falls to Brownlee reach. 

• Construction of the Pine Creek we

would improve monitoring of bull enable assessment of spawning sucsteelhead and spring Chinook salmCanyon reservoir. 

• Benefits of Hells Canyon trap mod

assessment, and nutrient supplemeIdaho Power’s Proposal. 

• Additional tributary enhancement m

native resident salmonids in the Po

• Brook trout suppression efforts, if 

expanded to include the Wildhorse methods proven to be successful in 

• Sturgeon stocking, if determined to 

white sturgeon populations in all reand Hells Canyon dams, benefiting fisheries. 

Terrestrial Resources Effects of Operations • Slightly increased potential for negative effects on 

special status plants. 

• Slightly increased occurrence and expansion of 

puncture vine at Brownlee reservoir. 

• Daily flow fluctuations would reduce riparian habitat 

at Hells Canyon and Oxbow reservoirs by <1 acre and by about 15 acres downstream of Hells Canyon dam. 

• Effects on special status plants esse

Power’s Proposal. 

• Effects on noxious weeds similar t

but slightly more weed occurrence slightly less occurrence downstream 

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xlvi 

Resource Idaho Power’s Proposal Staff Alterna

• Conditions would remain about the same for fisheating wildlife such as river otters, black bears, and 

bald eagles. 

• Brownlee reservoir would continue to pose a small 

risk to mule deer trying to cross it. 

• Continued erosion would be likely to affect about 70 

additional acres over the term of the license. 

• Daily flow fluctuations would redu

at Hells Canyon reservoir, about 1.and about 13 acres downstream of 

• More stable flows benefiting fish w

fish-eating wildlife, such as river oeagles. 

• Risks to mule deer crossing Brown

same as Idaho Power’s Proposal. 

• Continued erosion would be simila

Effects of Environmental Measures 

• Coordination and planning would improve protection 

of rare plants and control of noxious weeds. 

• Transmission line operation and maintenance plans 

for wildlife and botanical resources would reduce potential adverse operation and maintenance effects on terrestrial resources. 

• Management of 20,592 acquired acres and 2,990 

Idaho Power acres for wildlife habitat would benefit terrestrial resources affected by operation of the project based on a 1:1 replacement ratio. 

• Habitat enhancement at four Snake River islands 

would improve habitat for waterfowl, nesting waterbirds, raptors, neotropical migrant songbirds, and aquatic furbearers. 

• Coordination with agencies to enhance mountain 

quail habitat and/or participate in relocation projects would benefit mountain quail. 

• Implementation of the Integrated Wildlife Habitat 

Program and Wildlife Mitigation and Management Plan would improve coordination and management of wildlife habitat in Idaho Power’s ownership. 

• Threatened, endangered, and sensitive species would 

continue to be managed on a case-by-case basis. 

• Rare plant protection and noxious 

essentially the same as Idaho Poweadditional measures to improve effincreased emphasis on surveys prioground-disturbing activities. 

• Transmission line operation and m

resources would be essentially the Proposal, with some improved effiincreased raptor protection. 

• Acquisition and management of w

essentially the same effects as Idahwould also include measures to addsandbar willow establishment; erosduring new license period; and the resulting from implementation of s

• Provision of funding for capital im

implementation of habitat enhanceislands would yield greater habitat Power’s Proposal. 

• Improvements to mountain quail h

relocation projects would be about Proposal. 

• Application of project-wide wildlif

improve coordination of habitat mathe project boundary compared to I

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xlvii 

Resource Idaho Power’s Proposal Staff Alterna

• Development of project-wide Thre

Sensitive Species Management Plaand coordination of protective meacovered by the plan, compared to I

Cultural Resources Effects of Operations • Restoration of 14 acres of sandbar downstream of 

Hells Canyon dam would help protect some cultural sites from erosion damage. 

• Beach and terrace erosion would continue to put some 

cultural sites at risk. 

• Restoration of 14 acres of sandbar 

beneficial effect as Idaho Power’s 

• More restrictive ramping rates duri

a minor increase in cultural resourcIdaho Power’s Proposal. 

Effects of Environmental Measures 

• Site monitoring would improve protection of 

monitored sites. 

• Site stabilization would protect 7 sites on Brownlee 

reservoir and 20 sites downstream of Hells Canyon dam, and data recovery at 4 sites would prevent possible future damage. 

• Establishment of Native American, EuropeanAmerican, and Asian-American interpretive sites 

could contribute to resource protection through visitor education. 

• Support for local museums would enhance cultural 

resources protection and education in the local area. 

• Support for Native American programs would 

enhance the tribes’ informed participation in the management and protection of project resources. 

• Measures to improve the condition of aquatic 

resources would benefit culturally important species, including white sturgeon and native resident and anadromous salmonids. 

• Development of a plan to implement the deferred 

study of reservoir water level fluctuation effects on cultural resources would enhance understanding of those effects and form the basis for further protective measures, if needed. 

• Development of site monitoring pl

and consistency of monitoring effo

• Site stabilization, data recovery, an

interpretive sites would achieve the Power’s Proposal. 

• Support for Native American progr

benefits than Idaho Power’s Propowould not be provided. 

• Renewed offer to prepare oral histo

and Shoshone-Paiute Tribes would understanding. 

• Development of a plan to impleme

reservoir water level fluctuation efwould enhance understanding of thbasis for further protective measur

• Continuation of flow augmentation

habitat improvements to the Powdeimplementation of the FWS fishwawith agencies and tribes to determiadult hatchery steelhead and spring construction of spawning and incubYankee Fork, and potential expansmeasures to include stocking in pro

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xlviii 

Resource Idaho Power’s Proposal Staff Alterna

provide additional benefits to tribaimportant species. 

• Revision of the HPMP to meet For

25 would improve the plan overalladaptive management strategy to achallenges and conditions, and also when and under what circumstancepreviously examined areas, may be 

Recreation Effects of Operations • Brownlee reservoir level would continue to support 

flat-water boating and crappie fishing in the late summer and early fall. 

• Similar to current conditions, flows downstream of 

Hells Canyon dam would routinely fall below the Corps’ recommended 8,500-cfs safe navigation flow. 

• Flow fluctuations downstream of Hells Canyon dam 

would continue to adversely affect boaters and campers. 

• Flow augmentation would adverse

opportunities and crappie fishing cconditions and Idaho Power’s Prop

• Implementing an 8,500-cfs minimu

Hells Canyon dam in medium-high years would increase boaters’ certaavailable. 

• Flow augmentation would slightly 

boating opportunities downstream 

• More stabilized flows during the sp

Canyon dam would enhance the quexperience. 

Effects of Environmental Measures 

• Preparation and implementation of a Recreation Plan 

would benefit recreational visitors by providing improved management of recreational programs. 

• Numerous proposed improvements would benefit 

recreational visitors by improving boat moorage, road maintenance, developed and dispersed recreation sites, and boat access in low water years, and would benefit cultural and natural resources by providing additional protection near recreation uses. 

• Proposed changes in the litter and sanitation 

management program would substantially improve upon existing conditions. 

• Adding specificity to the implemen

Recreation Plan would clarify planintended benefits. 

• Expansion of Recreation Plan to in

Oasis, Steck recreation site, FarewJennifer’s Alluvial Fan, Deep Creelaunch would provide additional reto Idaho Power’s Proposal. 

• Expansion of the litter and sanitatio

include a gray water and sanitary cCanyon Creek put-in/take-out wousystem and disposal of human was

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xlix 

Resource Idaho Power’s Proposal Staff Alterna

• The I&E Plan would promote protection and 

preservation of cultural, natural, and historic resources. 

• Funding O&M at its recreation sites and those of 

BLM and the Forest Service that Idaho Power upgrades would benefit recreational visitors and resource protection by improving maintenance and management at most of the primary recreation sites in the project boundary. 

• Continuing to provide flow information for flows 

downstream of Hells Canyon dam would continue to benefit recreational visitors by providing timely information to be used in trip planning. 

• Continuance of the Memorandum of Understanding 

for staffing the Hells Canyon Visitor Center would continue to benefit visitors at the center. 

• Preparation of a Recreation Adaptive Management 

Plan would provide a framework for responding to changes in recreational needs. 

• Implementation of the White Sturgeon Conservation 

Plan should lead to an improved sturgeon fishery in the Swan falls to Brownlee Reach. 

• Implementation of the native salmonid plan and 

tributary enhancements should improve redband trout fisheries in the Pine, Indian and Wildhorse basins. 

• Increasing the specificity of the I&

information on aquatic invasive spwould promote additional understaproject resources. 

• Clarifying O&M funding and respo

and BLM recreational sites at the pas part of the final Recreation Plan the intended plan benefits.

• Preparing and implementing the na

the benefits of the flow information amount and timeliness of flow info

• Hells Canyon Visitor Center staffin

under Idaho Power’s Proposal. 

• Adding details to the Recreation A

concerning the minimum level of rand consultation every 6 years relaimprove the responsiveness of the conditions. 

• Expanded tributary enhancement m

redband trout fisheries in the Powd

• Sturgeon stocking, if determined to 

the sturgeon fishery between Swan dams more rapidly than under Idah

Land Management and AestheticsEffects of Operations • The adverse visual effects of Brownlee reservoir 

drawdown would continue to occur from about July through October. 

• Visual effects on the shoreline downstream of Hells 

Canyon dam would continue due to periodic dewatering of the shoreline, beach and terrace erosion, and loss of riparian habitat. 

• Flow augmentation would lead to e

drafting of Brownlee reservoir starexacerbating the negative visual efdrawdowns. 

• Negative visual effects downstream 

would be reduced somewhat compProposal due to more stable water 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
l 

Resource Idaho Power’s Proposal Staff AlternaEffects of Environmental Measures 

• Implementation of the Hells Canyon Resource 

Management Plan on project lands would enhance the management, conservation, and protection of natural and cultural resources. 

• Continuation of the project’s law enforcement and 

fire protection programs and sponsorship of biannual law enforcement coordination meetings would help maintain and improve public safety and resource protection at the project. 

• Proposed boundary modifications to exclude 3,800 

acres of federal lands from the project boundary would exclude some lands used for project-related purposes. 

• Development of a road management plan, application 

of the Common Policies of the Hells Canyon Resource Management Plan, and continued maintenance of 40 miles of road would lead to improved access, public safety, and resource protection related to those roads 

• Application of the aesthetic resource elements of the 

Hells Canyon Resource Management Plan would improve the aesthetic appearance of the project. 

• Reducing the visual contrast of transmission line 945 

would enhance the visual experience of visitors. 

• Adding specific details to the Hells 

Management Plan to identify whicmanagement plans and implementaimprove delivery of the intended b

• Adding specific agency coordinatio

Canyon Resource Management Plaof resources on BLM and Forest Sboundary. 

• Adding specific components of the 

protection programs to the Hells CPlan would improve delivery of the programs. 

• Amending the project boundary to 

wildlife mitigation, dispersed recreof the shoreline, and the Airstrip, Sand Westfall recreation sites would at those sites; other federally manafrom the boundary without adversethose lands. Providing the Forest Smarked aerial photographs would eresource protection on Forest Serv

• Including additional consultation in 

planning process and integrating thCanyon Resource Management Plaproject-related roads are appropria

• Adding specificity to the aesthetic 

Canyon Resource Management Pladeveloped, project-wide standards formalizing it into an aesthetic impwould improve delivery of the inte

• Adding aesthetic improvements to 

enhance the visual experience for v

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
li 

Resource Idaho Power’s Proposal Staff Alterna

• Including transmission line aesthet

aesthetic elements of the Hells CanPlan would help ensure consistency resource management. 

SocioeconomicsEffects of Operations • Potential increase in electricity rates to pay increased 

cost of producing project power. 

• Potentially greater increase in elect

cost of producing project power. 

• Flow augmentation could lead to a 

away from warmwater fishing at Bimprove tribal and commercial fishsalmon, affecting related businesse

Effects of Environmental Measures 

• Spending on environmental measures and increased 

visitor use could increase local business income, but also increase cost to counties to provide services in the project area. 

• Wildlife habitat restoration and improved conditions 

for some aquatic resources would benefit tribal cultures compared to current conditions. 

• Greater spending on environmenta

greater increase in local business in

• Additional measures to benefit dow

populations and resident fish popuof the project could lead to greater compared to Idaho Power’s Propos

• Constructing and operating facilitie

steelhead and Chinook salmon on timplementing a plan to transport ananadromous fish would provide cefisheries for the tribes. 

a The Staff Alternative with Mandatory Conditions is not listed in this table, and differs from the Staff Alternative only by the inclus

of three measures related to trail development and maintenance, road maintenance, and law enforcement 

Notes: BLM – U.S. Bureau of Land Management MOU – memorandum of understanding 

 DO – dissolved oxygen MWh – megawatt hours  Forest Service – U.S. Forest Service O&M – operation and maintenance  GBT – gas bubble traum TDG – total dissolved gas  HCRMP – Hells Canyon Resource Management Plan TMDL – total maximum daily load  HPMP – Historic Properties Management Plan WMMP – Wildlife Mitigation and Management Plan  IWHP – integrated wildlife habitat program 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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595 

4.0 DEVELOPMENTAL ANALYSIS 

In this section, we analyze the project’s use of the available water resources to generate 

hydropower, estimate the economic benefits of the project, estimate the cost of various environmental 

enhancement measures and operational changes, and assess the effects of these measures on project 

operations. Idaho Power does not propose any modifications to the project generation facilities, but it 

does propose numerous environmental measures that would affect project costs. 

4.1 BASIS FOR POWER, COSTS AND ECONOMIC BENEFITS OF THE PROJECT 

The main purpose of the Hells Canyon Project is to provide power for Idaho Power’s customers. 

Idaho Power has studied the existing project facilities, operation, and utilization of flows and concludes 

that the project, as proposed, would be developed to its optimal capacity. 

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 current costs to compare the costs of the project and likely alternative power 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 

a project and reasonable alternatives to project-generated power. The estimate helps to support an 

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

To determine the value of project power benefits, we assumed the value of generation is similar 

to the cost of Mid-Columbia forward pricing values, which vary by month and time of day. We use a 

value of dependable capacity of $114,000 per MW per year (MW-yr). We use these values to provide: 

(1) a basis for measuring the economic benefits of continued project operation; and (2) a basis for 

estimating the cost of replacing power for any environmental enhancements that would reduce project 

generation. 

The current-cost economic analysis is not entirely a first-year analysis in that certain costs, such 

as major capital investments, would not be expended in a single year. Also, some future expenses, such 

as taxes and depreciation, are known and measurable and are, therefore, incorporated in the cost analysis. 

Table 100 summarizes the values that we use for key parameters in our analysis; these values were either 

obtained from Idaho Power’s final license application and AIR responses or developed by staff. 

Table 101 summarizes the annualized costs associated with the project under existing conditions (noaction), which total $41,966,200. 

Table 100. Summary of key parameters for economic analysis of the Hells Canyon Hydroelectric 

Project. (Source: Idaho Power, 2004, as modified by staff) 

Parameter Value Source 

Period of analysis 30 years Staff 

Term of financing 20 years Staff 

Discount rate 7.13 percent Idaho Power 

Cost of money 8.48 percent Idaho Power 

General inflation and real growth rate 0 percent Staff 

Depreciation MACRS Staff 

Taxes and Insurance (%) 

Federal income tax rate 39.1% Idaho Power 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
596 

Parameter Value Source 

Property tax rate 0.5% Idaho Power 

Insurance 0.07% Idaho Powera

Capacity Value ($/MW-year) $114,000 Staff 

Energy Value ($/MWh) ($2006) from 

Idaho Power 

Heavy Load Period 

($) 

Light Load Period 

($) 

January 70.09 60.00 

February 64.25 55.00 

March 58.41 50.00 

April 44.03 35.12 

May 39.81 31.76 

June 45.90 36.62 

July 53.59 43.70 

August 62.04 50.59 

September 59.12 48.21 

October 58.18 48.81 

November 56.54 47.44 

December 62.28 52.25 

Note: MACRS = Modified Accelerated Cost Recovery System 

a

 Computed from Idaho Power data. 

Table 101. Costs associated with the No-action Alternative for the Hells Canyon Project. 

 No Inflation 

Capital Cost Annual Expense Total Annualized Cost 

Total original net investmenta $162,722,900 $18,428,500 

Committed construction costb $2,477,100 $270,600 

Total relicensing costc

 $80,700,000 $8,354,300 

Ongoing environmental measuresa

 $11,600,000 $1,267,000 

Total net investment $28,320,400 

Plant O&M d $5,480,000 $5,480,000 

O&M for current environmental measures $5,542,500 $5,542,500 

KWh Taxe

 $903,300 $903,300 

FERC feesf

 $1,720,000 $1,720,000 

Subtotal annual expenses $13,645,800 

Total annualized cost $41,966,200 

a

 We include property tax and insurance considerations in our annualized capital costs, while Idaho Power 

accounts for these costs separately. We revised this figure and subsequent subtotals in the final EIS based on a 

September 25, 2006, communication between Idaho Power and FERC staff. 

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b

 We estimated the committed construction cost by applying the ratio of the cash flow for a known cost to Idaho 

Power’s cost of capital in table 1 of Idaho Power’s response to AIR DR-4. 

c

 We do not include property tax and insurance in annualizing the relicensing costs. 

d

 We computed the plant O&M cost by dividing the 30-year total cost of $164.4 million by 30, based on Idaho 

Power's response to AIR DR-4. 

e

 Based on Idaho Power’s response to AIR DR-4 and computed by dividing $27.1 million by 30 years. 

f

 Based on Idaho Power’s response to AIR DR-4 and computed by dividing $51.6 million by 30 years. A higher 

figure was published in exhibit D of the final license application (Idaho Power, 2003a). 

4.2 COST OF ENVIRONMENTAL MEASURES 

Certain measures proposed by Idaho Power, recommended by agencies and other parties and/or 

considered by staff for inclusion in a Staff Alternative could affect project economics through costs 

(capital, O&M, plan development, etc.) or effects on power generation. Since several hundred measures 

have been put forward in this proceeding, we have placed the cost information for the developmental 

analysis in a set of three cost appendices. Appendix H provides detailed costs for measures included in 

Idaho Power’s Proposal, while appendix I addresses other measures included in the Staff Alternative. 

Appendix J addresses section 4(e) mandatory measures not included in the Staff Alternative. 

4.2.1 Reduced Benefits Associated with Operational Changes 

In this final EIS we evaluate alternative operations, which include changes to ramping rates, 

reregulation of the reservoirs for flow augmentation, and flow management changes to provide minimum 

navigational flows downstream of Hells Canyon dam. These operational changes, if implemented, would 

affect both energy generation and dependable capacity, as well as the ancillary benefits of the project. 

Additional effects could include a loss in generation flexibility and transmission system modifications. 

We base our estimates of energy impacts on data provided by Idaho Power’s CHEOPS model, a 

hydropower operations computer optimization model.108 

We determine dependable capacity impacts by estimating project capacity during a critical 

hydrologic period, which is defined by Idaho Power as July 1994 (a below-normal flow year). In the case 

of the seasonal 4-inch-per-hour ramping rate measure, capacity losses are associated with Idaho Power’s 

estimated loss of 113 MW of peaking capacity from June 1 through June 15.109 Table 102, which is based 

on Idaho Power’s response to AIR OP-1(a) (Bowling and Whittaker, 2005) and subsequent Idaho Power 

comments on the draft EIS, summarizes the effects on power benefits of the environmental measures that 

would affect generation. 

 

108 The CHEOPS model and input files are proprietary tools of Idaho Power. Staff reviewed the model 

during earlier project proceedings. In response to our AIR OP-1(a), Idaho Power made a number of 

model runs to simulate certain flow scenarios (see section 3.3.2). Some operational measures, 

submitted in response to the Commission’s Notice of Ready for Environmental Analysis, have not 

been modeled. 

109 This measure would be effective from March 15 through June 15 each year; however, Idaho Power 

estimates that it would affect capacity only during June. 

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Table 102. Annualized lost benefits associated with supplemental operational measures included in the Staff Alte

recommended by the Corps for navigation purposes. 

Measure 

Change in 

Heavy Load 

Period 

Energy 

Generation 

(MWh) 

Change in 

Light Load 

Period 

Energy 

Generation 

(MWh)

Lost 

Energy 

Benefits 

Reduction in 

Dependable 

Capacity 

(MW) 

Lost Capacity 

Benefits 

Lost Ancilla

Transmission 

Flexibility 

Benefits 

Staff Alternative Measures 

Implement a 4-inch-per-hour ramping rate measured at Johnson Bar from March 15 through June 15, to be adjusted if warranted based on monitoring studies 

–10,019 11,034 $76,000 0.0 $1,261,000a $494,000 

For flow augmentation, refill Brownlee reservoir to full pool by June 20, release 237 kaf of stored water from Brownlee reservoir between June 21 and July 31 (release at least 150 kaf of this water by July 15) and not refill until after August 31

–53,649 39,508 $2,411,000 18.1 $2,056,000b $4,561,000 

Totalc –63,652 50,751 $2,459,000 18.1 $3,317,000 $4,702,000 

Corps-recommended Measure 

Operate the project in the interest of navigation to maintain a flow of 8,500 cfs above the mouth of the Salmon Riverd

–6,442 6,324 $179,800 100.3 $11,437,600e $931,500 

a This represents replacement of lost spring capacity as estimated by Idaho Power on April 25, 2007. b If Idaho Power were able to use simple cycle combustion turbines rather than combined cycle turbines to replace lost dependable c

impact on dependable capacity would be $1,329,200, or $726,800 less than using combined cycle. The resulting total annualized rfor both staff measures would be $9,751,200 instead of $10,478,000. 

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c The entries in the rows above represent the cost of each measure on its own, not in combination with the other flow measures. The 

effect of all measures and does not necessarily equal the sum of rows 1 (ramping rate) and 2 (flow augmentation) because when memeasure may partially offset another. 

d The incremental cost of the Corp’s navigation measure would have minimal effect on dependable capacity in July when the measu

operational scenario that includes flow augmentation. Dependable capacity is estimated based on typical July flows during the sec(1994). Under the flow augmentation scenario, simulated July 1994 releases from Hells Canyon dam never fall below the 8,500-cf

because water is being released from storage during this month to augment downstream fish flows. However, there would still be 

dependable capacity later in the summer once the augmentation flows end. Additionally, an instantaneous minimum of 11,500 cfs Salmon River as measured at the Snake River below McDuff Rapids gaging station is required. The measure also requires that the release from Hells Canyon dam for the current day be equal to the previous 3-day moving average for Brownlee reservoir inflow waverage for Brownlee reservoir inflow is less than 8,500 cfs. 

e If Idaho Power were able to use simple cycle combustion turbines rather than combined cycle turbines to replace lost dependable c

impact on dependable capacity would be $7,394,300, or $4,043,300 less than using combined cycle. The resulting annualized reduwould be $8,505,600 instead of $12,548,900. 

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4.2.2 Cost of Environmental Measures under the Applicants’ Proposal, Staff 

Alternative, and Staff Alternative with Mandatory Conditions 

Idaho Power provided cash flows for capital and O&M costs associated with their environmental 

measures in their response to AIR DR-4 (Bowling and Whittaker, 2005) or in subsequent filings.110 

Based on our review, we largely adopted these costs and applied the parameters summarized in table 100 

to compute annualized costs. The annualized cost of the new environmental measures included in Idaho 

Power’s Proposal is $12,529,900. The distribution of these costs by resource area is summarized in table 

103, including capital costs, annualized O&M costs, and total annualized costs. 

We created the cash flows for capital and O&M costs for environmental measures that were 

recommended by agencies and other parties or that we developed. In some cases, we estimated costs by 

extrapolating costs provided by Idaho Power in its application or response to AIR DR-4. The total 

annualized cost of the new environmental measures included in the Staff Alternative is $15,225,600 

(table 103). The total annualized cost of the new environmental measures included in the Staff 

Alternative with Mandatory Conditions is $15,255,800 (table 103). 

4.3 COMPARISON OF ALTERNATIVES 

Based on Idaho Power’s computer model and hydrologic data for the project, the estimated 

average annual output of the project under the No-action Alternative (current conditions) is 6,562,244 

MWh. This would provide annual power benefits of $351,546,600. Subtracting current costs of 

$41,966,200 (see table 101) yields an annual net benefit of $309,580,400. This serves as the basis for the 

analysis of project economic benefits under Idaho Power’s Proposal and the Staff Alternative. The 

project’s output is sold to Idaho Power’s ratepayers or to other utilities in the northwest region. Idaho 

Power is an Idaho corporation and is a publicly regulated investor owned utility. Its rates and charges are 

set by the Idaho Public Utilities Commission in a manner to cover its operating expenses, debt service, 

and other costs and to provide appropriate operating, capital and other reserves, as well as a regulated 

return on investment to shareholders. 

Table 104 compares the power value, annualized costs, and net benefits of the No-action 

Alternative, Idaho Power’s Proposal, the Staff Alternative, and the Staff Alternative with Mandatory 

Conditions. In section 5.0, Staff’s Conclusions, we discuss our reasons for developing the Staff 

Alternative and explain why we conclude the environmental benefits may be worth these cost increases 

and benefit reductions. Net benefits would decrease from 47.18 mills/kWh under the No-action 

Alternative to 45.27 mills/kWh under Idaho Power’s Proposal, a drop of 4.05 percent. The decrease in 

net benefits from 47.18 mills/kWh under Idaho Power’s Proposal to 43.34 mills/kWh under the Staff 

Alternative represents an additional drop of 4.43 percent. Compared to Idaho Power’s Proposal, the Staff 

Alternative causes a greater reduction in net benefits because of measures that would reduce generation 

and annual power values as well as measures that would increase project costs. If other mandatory 

measures not included by staff were included in any final license, the results would be almost identical to 

the Staff Alternative (about $0.005 mills/kWh less net benefit). 

 

110 Idaho Power provided costs associated with certain water quality measures in its responses to AIRs 

for WQ-1 and WQ-2 (Idaho Power, 2005e,g,h). 

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Table 103. Summary by resource area of capital and one-time costs, annual operation and maintenance costs, and 

costs of additional environmental measures included in Idaho Power’s Proposal, the Staff Alternative

Alternative with Mandatory Conditions. 

IDAHO POWER’S PROPOSALA STAFF ALTERNATIVEA,B 

STAFF ALTERNATIVE WITH ACONDITIONSC 

RESOURCE AREA 

CAPITAL 

COST 

ANNUALIZED 

O&M COST 

TOTAL 

ANNUALIZ

ED COST CAPITAL COST 

ANNUALIZ

ED O&M 

COST 

TOTAL 

ANNUALIZED 

COST 

CAPITAL 

COST 

ANNUALIZED 

O&M COST 

SEDIMENT TRANSPORT 

$0 $814,100 $814,100 $720,400 $842,900 $921,600 $720,400 $842,900 

WATER QUALITY 

$15,734,400 $623,100 $1,798,100 $15,824,400 $650,100 $1,835,000 $15,824,400 $650,100 

AQUATIC RESOURCES 

$17,000,000 $954,900 $2,811,700 $34,328,000 $1,141,400 $3,921,900 $34,328,000 $1,141,400 

HATCHERIES 

$17,006,000 $469,200 $2,326,700 

$17,381,000 $697,000 $2,591,600 

$17,381,000 $697,000 

OPERATIONAL MEASURES 

$0 $0 $0 $1,600,000 $68,000 $242,800 $1,600,000 $68,000 

TERRESTRIAL RESOURCES 

$16,953,900 $1,046,000 $2,896,400 $18,709,000 $1,403,700 $3,445,500 $18,709,000 $1,403,700 

CULTURAL RESOURCES 

$77,000 $499,800 $508,200 $77,000 $527,500 $535,900 $77,000 $527,500 

Recreation $9,929,800 $358,900 $1,207,900 $10,899,800 $543,000 $1,486,900 $10,899,800 $553,000 Land Use and Aesthetics 

$840,000 $83,000 $166,800 

$950,000 $149,000 $244,400 

$1,050,000 $159,000 

Total $77,541,100 $4,849,000 $12,529,900 $100,489,600 $6,022,600 $15,225,600 $100,589,600 $6,042,600 

a Source: Idaho Power, response to AIR DR-4 and staff estimates. b Sum of all measures included in the Staff Alternative, including those proposed by Idaho Power (see appendix H) and those recom

developed by staff (see appendix I). 

c Sum all measures included in the Staff Alternative plus mandatory measures specified by agencies but not included by staff (see ap

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Table 104. Summary of the annual cost, power benefits, and net benefits for the No-action 

Alternative, Idaho Power’s Proposal, the Staff Alternative, and the Staff Alternative 

with Mandatory Conditions.a

Hells Canyon No Action 

Idaho Power’s 

Proposal Staff Alternative 

Staff Alternative 

with Mandatory 

Conditions 

Capacity 

Dependable capacity (MW) 1,277.8 1,277.8 1,259.7 1,259.7 

Generation 

Effect on heavy load 

generation (MWh) 

 –63,652 –63,652 

Effect on light load generation 

(MWh) 

 50,751 50,751 

Total Generation (MWh) 6,562,244 6,562,244 6,549,344 6,549,344 

Changes in Capacity and Power Values 

Dependable capacity effectsb

 –$2,056,000 –$2,056,000 

Spring capacity effects –$1,261,000 –$1,261,000 

Generation effects –$2,459,000 –$2,459,000 

Ancillary benefits effects –$474,000 –$474,000 

Transmission effects –$2,028,000 –$2,028,000 

Flexibility effects –$2,200,000 –$2,200,000 

Total Costs and Benefits 

Annual power value $351,546,600 $351,546,600 $341,068,600 $341,068,600 

($/MWh and mills/kWh) 53.57 $53.57 $52.08 $52.08 

Annual cost $41,966,200 $54,496,100 $57,191,800 $57,222,000 

($/MWh and mills/kWh) $6.40 $8.30 $8.73 $8.74 

Annual net benefit $309,580,400 $297,050,500 $283,876,800 $283,846,600 

($/MWh and mills/kWh) $47.18 $45.27 $43.34 $43.34 

a Small round-off differences of $100 to $200 may carry forward from earlier tables as values are recombined. 

b If Idaho Power were able to replace lost dependable capacity with simple cycle turbines instead of combined 

cycle turbines, the dependable capacity effect would drop to $1,329,200. This would add 726,800, or about 

$0.11/MWh, to annual net benefits. 

The measures that Idaho Power proposes, as summarized in table 104, would increase annualized 

costs from $41,966,200 to $54,496,100 relative to the No-action Alternative. Idaho Power does not 

propose any significant operational changes and annual generation would remain unchanged at 6,562,244 

MWh. This would provide annual power benefits of $351,546,600 and an annual net benefit of 

$297,050,500. This equals an overall reduction in annual net benefits of $12,529,900 relative to the Noaction Alternative. 

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The measures included in the Staff Alternative, as summarized in table 104, would increase 

annualized costs from $41,966,200 to $57,191,800 relative to the No-action Alternative. Operational 

changes would reduce annual generation, which would decrease by 12,900 MWh to 6,549,344 MWh. 

The Staff Alternative would provide annual power benefits of $341,068,600 and an annual net benefit of 

$283,876,800. This represents an overall reduction in annual net benefits of $25,703,600 relative to the 

No-action Alternative. If mandatory measures not included by staff were ultimately made a part of the 

license, the costs would increase by $30,200 and annual net benefits would decrease accordingly to 

$283,846,600. 

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5.0 STAFF’S CONCLUSIONS 

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. In this section, we examine the environmental effects and project costs and 

explain how we decided on the environmental measures we include in a Staff Alternative. 

5.1 SUMMARY COMPARISON OF IDAHO POWER’S PROPOSAL AND STAFF 

ALTERNATIVE 

In this section, we outline Idaho Power’s Proposal, the Staff Alternative, and the Staff Alternative 

with Mandatory Conditions, and summarize the key differences of the potential effects among 

alternatives. 

5.1.1 Description of Alternatives 

5.1.1.1 Idaho Power’s Proposal 

Idaho Power’s Proposal consists of a proposed operating regime and 94 environmental measures 

summarized previously in section 2.2, Idaho Power’s Proposal. 

5.1.1.2 Staff Alternative 

After evaluating Idaho Power’s Proposal and recommendations from resource agencies, tribes 

and other interested parties, we compiled a set of environmental measures that we consider appropriate 

for addressing the resource issues raised in this proceeding. We call this the “Staff Alternative.” The 

Staff Alternative includes some measures included in Idaho Power’s Proposal, as described below, 

Interior’s modified section 18 prescription (see section 5.2.4.4), some section 4(e) and alternative section 

4(e) conditions (see section 5.3.2), section 10(j) recommendations (see section 5.3.1), section 10(a) 

recommendations, and measures developed by the staff. 

Project Operation 

Under the Staff Alternative, the project would be operated as proposed by Idaho Power (see 

section 2.2.2, table 1), but with the following operational changes: (1) reservoir refill targets after the 

flood control season, (2) flow augmentation to enhance juvenile fall Chinook salmon migration 

conditions, (3) additional ramping restrictions during the fall Chinook salmon rearing period, (4) revised 

minimum flow during medium-high and extremely high flow years; and (5) warmwater fish spawning 

protection levels in Brownlee reservoir. The operational modifications included in the Staff Alternative 

are as follows: 

1. Idaho Power would consult with the Corps to develop a flood control plan for operating 

Brownlee reservoir consistent with regional and local requirements. Consistent with the 

flood control plan, Idaho Power would refill Brownlee reservoir to a level between: (a) 1 

foot below the April 15 and April 30 required flood control draft; and (b) the required flood 

control draft on those dates. After April 30, Idaho Power would coordinate the refill of 

Brownlee reservoir with the Corps, NMFS, ODFW, IDFG, and the interested tribes to 

ensure that the refill of Brownlee reservoir does not result in unnecessary reductions of 

spring flows as measured at Lower Granite dam. This measure would not in any way 

diminish the Corps’ discretion over the project’s flood control operation. 

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2. Consistent with flood control requirements, Idaho Power would refill Brownlee reservoir to 

full pool (elevation 2,077 feet msl) by June 20 of each year and, in order to enhance 

migration conditions for juvenile fall Chinook salmon, would release 237 thousand acrefeet of stored water from Brownlee reservoir (draft to elevation 2,059 feet msl) between 

June 21 and July 31, except as may be restricted by the Corps for system flood control 

between June 20 and July 1111. Idaho Power would release at least 150 kaf of this water 

(draft to elevation 2,066 feet msl) no later than July 15 of each year, but would maintain 

Brownlee elevations through the Fourth of July holiday to enhance recreational use of the 

reservoir. Idaho Power would not refill Brownlee reservoir at any time between June 21 

and August 31 

3. The maximum variation in river stage would not exceed 1 foot per hour as measured at the 

Snake River at Johnson Bar gaging station 13290460 (RM 230), except during the March 

15 to June 15 fall Chinook rearing period when the maximum variation in river stage would 

not exceed 4 inches per hour. 

4. From Memorial Day weekend to September 30 in medium-high and extremely high flow 

years, Idaho Power would provide an instantaneous minimum flow of 8,500 cfs upstream 

of the mouth of the Salmon River, as measured at the Hells Canyon dam gaging station.112 

If the 3-day moving average inflow to Brownlee reservoir is less than 8,500 cfs, the 

instantaneous minimum release required from Hells Canyon dam for the current day would 

be equal to the previous 3-day moving average. 

5. Idaho Power would protect warmwater fish spawning locations in Brownlee reservoir from 

May 21 through July 4. For the initial 30-day period beginning May 21, Brownlee 

reservoir would not be drafted more than 1 foot from the highest elevation reached during 

the 30-day period. From the end of the 30-day period though July 4, the reservoir could be 

drafted more than 1 foot, but an elevation of at least 2,069 feet above mean sea level would 

be maintained.113

Measures Proposed by Idaho Power

In the Staff Alternative, we also include the following environmental measures proposed by Idaho 

Power, based on our analyses included in sections 3 and 4. In some cases (italicized), we have deleted, 

modified, or supplemented Idaho Power’s proposed measures. As noted in section 2.2.3, Proposed 

Environmental Measures, measures numbered 1P through 81P reflect Idaho Power’s original proposal; 

measures 101P through 113P reflect changes to Idaho Power’s proposal filed between the draft EIS and 

the final EIS. 

 

111 Staff measure 8S would require Idaho Power to prepare a report 6 years after license issuance that 

summarizes available information on the effectiveness of this measure for improving the migration 

survival of juvenile salmon and steelhead, and evaluating whether any changes in the timing or 

quantity of flow augmentation water released from Brownlee reservoir are warranted. 

112 Staff measure 4S would require Idaho Power to install a new flow compliance gage within 5 miles 

downstream of Hells Canyon dam. Once it is operational, compliance for the minimum navigation 

flow would be measured at the new gage. 

113 The requirement for warmwater fish spawning protection (item 4, above) would be secondary to any 

conflicting operational requirement. 

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Sediment Supply and Transport 

101P. Develop and implement a program to monitor beach and terrace erosion, substrate, and 

gravel. We modified Idaho Power’s proposed measures to include development and 

implementation of a 5-year volumetric monitoring of sand and gravel.

102P. Create a mitigation fund to be used by the Forest Service to restore and maintain 14 acres 

of sandbars on or adjacent to National Forest System lands between Hells Canyon dam and 

the confluence of the Snake and Salmon rivers. 

Water Use and Quality 

1P. Continue 100-cfs minimum flow in Oxbow bypass to help maintain water quality in the 

bypassed reach. 

2P. Continue recreation waste disposal to prevent waste from contaminating the river. 

3P. Continue preferential use of the upper spillgates at Brownlee dam during spill periods to 

minimize elevated total dissolved gas as an interim measure until spillway flow deflectors 

are installed at Brownlee dam. 

4P. Implement one of two measures (in-reservoir aeration or upstream phosphorus trading) to 

fully meet the Snake River-Hells Canyon TMDL Brownlee reservoir dissolved oxygen 

allocation (an average of 1,125 tons of oxygen during the summer into the transition zone 

of Brownlee reservoir). We modified Idaho Power’s proposed measure to include 

development and implementation of a dissolved oxygen enhancement plan that documents 

consultation with IDEQ and ODEQ regarding the appropriate dissolved oxygen load 

allocation for the project, documents efforts to identify upstream phosphorus trading 

partner(s), evaluates whether reservoir dissolved oxygen supplementation or phosphorus 

trading is the preferred method for meeting Idaho Power’s Brownlee reservoir TMDL 

dissolved oxygen allocation, evaluates the feasibility and effectiveness of turbine aeration 

measures at Hells Canyon and Brownlee dams, evaluates the potential for each measure to 

elevate total dissolved gas to greater than the applicable water quality criterion (i.e., 110 

percent of saturation); (2) monitoring the effectiveness of implemented measures; (3) 

holding annual meetings with ODEQ, IDEQ, ODFW, IDFG, FWS, NMFS, and interested 

tribes to evaluate whether measures need to be modified or additional measures 

implemented to meet the dissolved oxygen load allocation for the project; and (4) filing an 

annual monitoring and implementation report with the Commission that summarizes 

monitoring results and outlines any modifications or new measures that warrant 

consideration and/or are proposed for implementation

103P. Aerate Hells Canyon outflows using a forced air (blower) system at Hells Canyon 

powerhouse that would add 1,500 tons of oxygen per year. 

104P. Install and operate a destratification system in the Oxbow bypassed reach at the deep pool 

just upstream of the Indian Creek confluence to prevent anoxic conditions at this location. 

5P. Install Hells Canyon dam spillway flow deflectors to reduce total dissolved gas levels in the 

tailrace of Hells Canyon dam and the Snake River downstream of the dam. 

105P. Install Brownlee dam spillway flow deflectors to reduce total dissolved gas levels in 

Oxbow and Hells Canyon reservoirs and the Snake River downstream of Hells Canyon 

dam. 

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106P. Evaluate and implement measures on the Oxbow dam spillway or bypassed reach to reduce 

total dissolved gas levels as necessary to meet the Snake River-Hells Canyon TMDL load 

allocation. 

107P. Adaptively manage total dissolved gas abatement measures to ensure that Idaho Power 

meets its total dissolved gas load allocation below each of the project dams. We modified 

Idaho Power’s proposed measure to include: (1) annual meetings with ODEQ, IDEQ, 

ODFW, IDFG, FWS, NMFS, and interested tribes to evaluate whether measures need to be 

modified or additional measures implemented to meet TDG responsibility for the project; 

and (2) filing of an annual report with the Commission that summarizes monitoring results 

and any modifications or new measures that warrant consideration and/or are proposed 

for implementation.

108P. Work with ODEQ and IDEQ to develop a total dissolved gas monitoring plan that would 

include monitoring during spill to determine compliance with the TMDL load allocation 

assigned to Idaho Power. 

109P. Implement Idaho Power’s Temperature Adaptive Management Plan, which would: 

(1) define the extent of appropriate project temperature responsibility; (2) include an 

evaluation of potential measures; and (3) identify an appropriate measure(s) for 

implementation. We modified Idaho Power’s proposed measure to include: (1) monitoring 

of the effectiveness of implemented measures; (2) annual meetings with ODEQ, IDEQ, 

ODFW, IDFG, FWS, and NMFS to evaluate whether measures need to be modified or 

additional measures implemented to meet the project’s temperature responsibility; and (3) 

filing of an annual report with the Commission that summarizes monitoring results and any 

modifications or new measures that warrant consideration and/or are proposed for 

implementation.

Fish and Snails 

6P. Continue the fall Chinook plan. 

6Pa. Continue reservoir operations in the fall, winter, and early spring for protection of fall 

Chinook salmon spawning and salmon incubation. We modified Idaho Power's 

proposed measure to indicate that the stable flows to be maintained below Hells 

Canyon dam during the fall Chinook spawning season must be between 8,500 and 

13,500 cfs, at a level selected (based on runoff forecasts) to ensure that spawning fall 

Chinook salmon redds are created at elevations that are protected during the winter 

peak load period.

6Pb. Measure 6b in the draft EIS (concerning fall Chinook salmon redd and temperature 

monitoring) has been replaced by measures 110P and 10S. 

110P. Implement the Fall Chinook Salmon Spawning and Gravel Monitoring Plan 

described in appendix B of Idaho Power’s comments on the draft EIS. We 

supplemented this measure to include: (1) annual consultation with NMFS, Interior, 

IDFG, ODFW, and interested tribes to report on monitoring results to date and to 

guide monitoring efforts in the coming year; and (2) the development and 

implementation of a gravel augmentation program if monitoring results indicate that 

project-related effects on the quantity or quality of spawning habitat are adversely 

affecting the spawning or incubation success of fall Chinook salmon.

7P. Implement the warmwater fish plan. 

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7Pa. Protect peak spawning periods for smallmouth bass and crappie by limiting Brownlee 

reservoir drafts to no more than 1 foot from the highest elevation reached during a 

30-day period starting on May 21, and by maintaining an elevation of at least 2,069 

feet msl from the end of the 30-day period through July 4. 

7Pb. Continue warmwater fish population monitoring to detect long-term effects on fish 

populations. We modified Idaho Power's proposed measure to include gill netting or 

other measures to monitor the abundance of channel catfish in project reservoirs; 

filing of an annual report on the results of warmwater fisheries monitoring including 

an assessment of any operational effects on warmwater fisheries; and consultation 

with ODFW, IDFG and BLM on any feasible means to minimize or avoid adverse 

effects on the warmwater fishery in Brownlee reservoir.

8P. Implement the native salmonid plan. 

8Pa. Conduct pathogen survey in the Pine-Indian-Wildhorse core area to support 

development of a pathogen risk assessment plan. In the Staff Alternative, we 

incorporated this measure in the description of Idaho Power measure 8Pb. 

8Pb. Prepare and implement a plan to allow for the capture of resident salmonids and other 

species migrating upstream and for their transfer to areas upstream of Hells Canyon 

and Oxbow dams. The plan would include modification of the Hells Canyon fish 

trap to capture juvenile salmonids, construction of facilities for sorting and holding 

fish and for scanning PIT-tag returns, and potentially expansion to year-round 

operation. The plan also would include a provision to construct a fish trap at Oxbow 

dam a minimum of 5 years after the Hells Canyon trap has been modified. We 

modified Idaho Power's proposed measure to incorporate the FWS modified fishway 

prescription, which prescribes that Idaho Power prepare a bull trout passage plan 

that would include: (1) final design plans for the Hells Canyon trap modifications; 

(2) final engineering design plans for the Pine Creek monitoring weir and trap 

fishway, and construction of the weir and trap fishway within 2 years of license 

issuance; (3) specific protocols for the period of operation,114 location of release 

point, and handling of all life-stages of bull trout and other fish captured at these two 

facilities; (4) provisions for transport of bull trout between Pine Creek and Hells 

Canyon dam; (5) an assessment of monitoring necessary to evaluate the potential 

and risk of introducing deleterious pathogens; and (6) a post-construction 

monitoring plan.115 Under this modified prescription, the plan would include a 

description of specific triggers related to the timeline of construction and 

implementation of the Oxbow upstream trap fishway, the Indian Creek permanent 

weir and trap fishway, and the Wildhorse River weir and trap fishway. The plan 

would also include the specific monitoring necessary to determine when established 

triggers have been satisfied. 

8Pc. Prepare and implement a tributary habitat enhancement plan within the Pine Creek, 

Indian Creek, and Wildhorse River basins and smaller tributaries to the Hells Canyon 

 

114 The period of operation would be determined in consultation with the agencies and tribes, but may 

include year-round operation. 

115 The post-construction monitoring plan for the fish trap at Oxbow dam, if constructed, would include 

evaluation of flows needed to provide effective passage through the Oxbow bypassed reach. 

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Project reservoirs. We modified Idaho Power's proposed measure to include 

enhancement measures to support redband and bull trout restoration in portions of 

the Powder and Burnt River basins where such measures would provide substantial 

benefits to native resident salmonids.

8Pd. Supplement marine-derived nutrients to enhance the forage base within bull trout 

rearing areas (Pine, Indian, and Wildhorse core area). 

8Pe. Conduct Eagle Creek presence/absence survey to determine, with statistical 

probability, the presence or absence of bull trout within the Eagle Creek Basin. 

8Pf. Design, construct, and monitor a permanent monitoring weir at Pine Creek to 

establish a long-term monitoring program of fluvial fish migrating upstream and 

downstream in the Pine Creek System. In the Staff Alternative, we incorporated this 

measure in the description of Idaho Power measure 8Pb.

8Pg. Evaluate the feasibility of, and possibly implement, an experimental brook trout 

suppression program in Indian Creek. We modified Idaho Power’s proposed 

measure to include implementation of brook trout suppression in the Wildhorse River 

and possibly Pine Creek using techniques proven effective in Indian Creek. 

9P. Continue anadromous fish production at hatchery facilities. This Idaho Power measure is 

modified to note that hatchery operations are to be in keeping with any hatchery and 

genetic management plans 116 that are developed for these hatcheries. We recommend that 

Idaho Power’s obligation to fund the hatchery genetic management plans be based on 

continuation of current smolt production targets, but may include improvements that are 

needed to better attain goals for adult returns and societal use.

9Pa. Continue to operate the Oxbow fish hatchery. 

9Pb. Continue to operate the Rapid River fish hatchery. 

9Pc. Continue to operate the Niagara Springs fish hatchery. 

9Pd. Continue to operate the Pahsimeroi fish hatchery. 

10P. Upgrade and enhance anadromous mitigation hatchery facilities.

10Pa. Make improvements to the Pahsimeroi fish hatchery to control pathogens, develop a 

locally adapted steelhead broodstock, and monitor and evaluate hatchery 

performance. 

10Pb. Make improvements to the Oxbow fish hatchery by constructing adult holding pond 

and spawning facilities, expanding the fall Chinook rearing program, distributing 

carcasses, generally upgrading the hatchery facilities, and monitoring and evaluating 

hatchery performance. 

 

116 Because the hatcheries are operated by IDFG, hatchery and genetic management plans would be 

developed by IDFG in consultation with NMFS. 

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10Pc. Make improvements to the Niagara Springs fish hatchery by expanding the hatchery 

building, acquiring an additional smolt tanker, acquiring a fish marking unit, 

upgrading employee housing, and monitoring and evaluating hatchery performance. 

10Pd. Make improvements to the Rapid River fish hatchery by constructing an adult 

holding pond and spawning facilities, distributing carcasses, upgrading employee 

housing, generally upgrading the hatchery facilities, constructing an offsite smolt 

acclimation/adult collection facility, and monitoring and evaluating hatchery 

performance. 

11P. Implement Snake River White Sturgeon Conservation Plan. 

11Pa. Assess water quality-related effects on early life stages of white sturgeon in the Swan 

Falls-Brownlee reach.

11Pb. Translocate reproductive-sized white sturgeon into the Swan Falls-Brownlee reach to 

increase spawner abundance and population productivity, if water quality is found to 

be adequate. We modified Idaho Power’s proposed measure to be dependent upon 

the findings of an evaluation of alternative approaches for rebuilding white sturgeon 

populations in affected reaches (part of modified Idaho Power measure 11Pc).

11Pc. Develop an experimental conservation aquaculture plan to maintain adequate 

population size and genetic variability of white sturgeon in the Swan Falls-Brownlee 

reach, if approved by IDFG and ODFW. We modified Idaho Power’s proposed 

measure to include a feasibility assessment of alternative approaches for rebuilding 

sturgeon populations in reaches of the Snake River between Swan Falls and Hells 

Canyon dams, to include comparison of the risks and benefits of hatchery 

supplementation with the translocation of juvenile or adult sturgeon. 

11Pd. Make periodic population assessments to monitor white sturgeon populations in the 

Swan Falls-Brownlee, Brownlee-Hells Canyon, and Hells Canyon-Lower Granite 

reaches of the Snake River. 

11Pe. Monitor genotypic frequencies of white sturgeon between Shoshone Falls and Lower 

Granite dams. We modified Idaho Power’s proposed measure to exclude genetics 

monitoring upstream of Swan Falls dam, which is addressed in the licenses for the 

mid-Snake and C.J. Strike projects.

Wildlife 

12P. Acquire, enhance, and manage approximately 22,761 acres of upland and 821 acres of 

riparian habitat in the vicinity of the Hells Canyon Project reservoirs to mitigate for the 

estimated effects of project operations on wildlife. 

13P. In cooperation with ODFW and IDFG, enhance habitat on four Snake River islands (Gold, 

Hoffman, Patch, and Porter) for waterfowl and for threatened, endangered, candidate, and 

special status species. We modified Idaho Power's proposed measure to include support 

for capital improvements needed to implement enhancement projects, as recommended by 

ODFW and IDFG. 

14P. Cooperate with state and federal wildlife management agencies to enhance low-elevation 

riparian habitat and reintroduce mountain quail in areas adjacent to the project reservoirs. 

We modified Idaho Power's proposed measure to include consultation with state and 

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federal wildlife management agencies to develop and implement habitat improvements or 

relocation projects. 

15P. Through an interdisciplinary team, develop and implement an Integrated Wildlife Habitat 

Program and a Wildlife Mitigation and Management Plan to manage wildlife resources on 

Idaho Power-owned lands associated with the project to ameliorate identified impacts and 

provide general land stewardship. This measure is clarified to indicate that Idaho Power 

would establish a terrestrial resource work group to provide consultation in finalizing and 

implementing the management plan and implementing other measures to prevent wildlife 

disturbance.

16P. Develop and implement an operation and maintenance plan for the Pine Creek-Hells 

Canyon transmission line to minimize effects on wildlife, protect wildlife resources, and 

enhance habitat conditions. In the Staff Alternative, we combined this measure with Idaho 

Power measure 20P and included it in staff measure 13S, below.

Botanical Resources 

17P. Acquire, enhance, and manage upland and riparian habitat to mitigate for the estimated 

effects of project operations on botanical resources. 

18P. Formalize cooperative relationships to accomplish noxious weed control and non-native 

invasive weed management, site monitoring, and re-seeding along the Snake River corridor 

from Weiser downstream to the confluence of the Salmon River. In the Staff Alternative, 

we supplemented this Idaho Power measure to include agency consultation in the 

development and implementation of a project-wide integrated weed management plan 

to cover National Forest System and BLM-administered lands within the project boundary 

and lands affected by the project, as well as Idaho Power’s ownership, and establishment 

of a Cooperative Weed Management Area as specified by the Forest Service. The plan 

would cover pesticide reporting to BLM. 

19P. Formalize cooperative relationships, including establishment of a rare plant advisory board, 

to protect and monitor sensitive plant sites along the Snake River corridor from the 

headwaters of Brownlee reservoir downstream to the confluence of the Salmon River. In 

the Staff Alternative, we supplemented this Idaho Power measure to include agency 

consultation in the development and implementation of a project-wide threatened, 

endangered, and sensitive species management plan for plants and animals to cover 

National Forest System and BLM-administered lands within the project boundary and 

lands affected by the project, as well as Idaho Power’s lands, as described in staff measure 

12S, below.

20P. Develop and implement an operation and maintenance plan for the Pine Creek-Hells 

Canyon transmission line and service road and adaptively manage operation and 

maintenance activities to minimize adverse effects on botanical resources and to manage 

noxious weeds. In the Staff Alternative, we combined this measure with Idaho Power 

measure 16P and included it in staff measure 13S, below.

21P. Implement cooperative projects recommended by agencies and included in the 

Transmission Line Operation and Management Plan. In the Staff Alternative, we clarified 

this measure to indicate that it includes agency consultation in the development of the 

operation and maintenance plan.

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Historical and Archaeological Resources 

22P. Monitor sites along transmission line 945 that are eligible for inclusion on the National 

Register. 

23P. Monitor the known burial site on Oxbow reservoir. 

24P. Monitor known eligible sites on Oxbow and Hells Canyon reservoirs. In the Staff 

Alternative, we expanded this measure to include all known eligible resources in the areas 

of potential effect of these reservoirs. 

25P. Monitor known eligible sites on Brownlee reservoir. In the Staff Alternative, we expanded 

this measure to include all known eligible resources within the area of potential effect of 

the reservoir.

26P. Monitor known eligible sites downstream of Hells Canyon dam. We expanded this 

measure to include all known eligible resources in the area of potential effect.

27P. Stabilize approximately 20 archaeological sites below Hells Canyon dam after identifying 

sites requiring stabilization. 

28P. Stabilize seven archaeological sites on Brownlee reservoir. 

29P. Recover archaeological data at four archaeological sites on Brownlee reservoir to prevent 

possible damage by reservoir operations. 

30P. Establish Native American interpretive sites on Brownlee reservoir to enhance visitors’ 

awareness of Native American presence and land use in the project area. 

31P. Establish Native American interpretive sites on Oxbow and Hells Canyon reservoirs to 

enhance visitors’ awareness of Native American presence and land use in the project area. 

32P. Establish European-American interpretive sites on Brownlee, Oxbow, and Hells Canyon 

reservoirs to enhance visitors’ awareness of European-American presence and land use in 

the project area. 

33P. Establish Asian-American interpretive sites on Brownlee, Oxbow, and/or Hells Canyon 

reservoirs to enhance visitors’ awareness of Asian-American presence and land use in the 

project area. 

34P. Support European-American and Asian-American interpretive projects by assisting local 

community museums with collections acquisition, display, and curation related to Hells 

Canyon area trappers, miners, homesteaders, ranchers, and river runners of European and 

Asian descent. 

35P-40P. Provide support for Native American programs of the Burns Paiute Tribe, 

Confederated Tribes of the Warm Springs Indian Reservation, Nez Perce Tribe, 

Confederated Tribes of the Umatilla Indian Reservation, Shoshone-Paiute Tribes, and 

Shoshone-Bannock Tribes in its efforts to obtain funding for participating in and/or 

administering cultural resources environmental measures, educating their youth by 

providing scholarship/training funds, and providing funds to facilitate several cultural 

enhancement programs. We modified Idaho Power's proposed measure to delete the 

funding of scholarships and clarify that support for tribal programs is intended to support 

the tribes’ participation in natural and cultural resource management.

41P. Fund additional section 106 projects to protect sites and mitigate for any unforeseen 

adverse effects attributed to Hells Canyon Project operations. 

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Recreational Resources 

42P. Continue to operate and maintain monitors to provide flow information about river flows 

downstream of Hells Canyon dam. 

43P. Continue the Memorandum of Understanding between the Forest Service and Idaho Power 

with regard to staffing the Hells Canyon Visitor Center. 

44P. Continue existing general measures for all zones. 

44Pa. Continue litter and sanitation program. 

44Pb. Continue public safety programs. 

44Pc. Continue aid to local law enforcement in Adams County. 

44Pd. Continue road maintenance. 

44Pe. Continue operation and maintenance of Idaho Power-managed parks and recreation 

facilities. 

45P. Provide additional boat moorage on Hells Canyon Project reservoirs to improve angling 

access. We modified Idaho Power's proposed measure to include details of the boat 

moorage plan as part of the final Recreation Plan.

46P. Enhance the existing Litter and Sanitation Plan to improve litter cleanup and access to 

portable and vault toilets at dispersed recreational sites. We modified Idaho Power's 

proposed measure to address the need for, location of, and maintenance standards for 

floating restrooms; to develop maintenance and service standards for trash receptacles; 

and to design, install, and maintain a graywater carryout system in the vicinity of the Hells 

Canyon Creek put-in/take-out area. 

47P. Develop and implement an integrated Information and Education Plan to promote 

protection and preservation of cultural, natural, and historical resources through education. 

We modified Idaho Power's proposed measure to have the I&E Plan indicate the location 

and type of information materials to be provided and include information about 

anadromous fish, invasive species, and sensitive wildlife.

48P. Coordinate the prioritization of law enforcement resource use among appropriate law 

enforcement agencies to address public safety issues. We modified Idaho Power's 

proposed measure to have Idaho Power provide coordination by planning and hosting 

biannual meetings of the parties responsible for law enforcement in the project, but not 

funding law enforcement by third parties. In the Staff Alternative, we re-designate this as a 

“Land Management” measure. 

49P. Develop and implement a Recreation Adaptive Management Plan to identify and address 

the adequacy of Idaho Power’s Recreation Plan over the life of a new license. In the Staff 

Alternative, we supplemented this measure to indicate that the recreation adaptive 

management plan should address dispersed site management and procedures for 

recreational use monitoring and reporting and should be part of the overall Recreation 

Plan.

50P. Enhance road maintenance to improve public safety and further protect at-risk cultural and 

natural resources. In the Staff Alternative, we re-designate this as a “Land Management” 

measure.

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51P. Perform operation and maintenance at Idaho Power-enhanced BLM sites and all Forest 

Service reservoir-related recreation sites consistent with the settlement (FS modified 4(e) 

condition no. 18) to benefit recreation, provide public access, enhance visitor services and 

user satisfaction, and reduce the responsibilities of federal agencies to provide operations 

and maintenance services. This measure includes a safety review and improvements of the 

Deep Creek Trail (FS modified 4(e) condition no. 16), and brings the Deep Creek Trail into 

the project boundary. We modified Idaho Power's proposed measure to bring into the 

project boundary dispersed recreation sites that are within 200 yards of project waters as 

well as Airstrip, Steck Park, Swedes Landing, and Westfall recreation sites and the trail to 

Deep Creek (see staff measure 23S below). 

52P. Enhance Eagle Bar dispersed recreation site and improve boat ramp access to Hells Canyon 

reservoir. 

53P. Develop site plan for Big Bar recreation site consistent with the settlement (FS modified 

4(e) condition no. 13). 

54P. Measure 54 in the draft EIS (boat ramp and associated facilities at Big Bar section D) has 

been incorporated into Idaho Power measure 52P. 

55P. Develop site plan and enhance Eckels Creek dispersed recreation site to benefit recreation 

and provide cultural and natural resource protection. 

56P. Supplement the existing O&M budget to accommodate enhancements at Idaho Powermanaged parks and recreational facilities. 

57P. Develop and implement a site plan for the Copper Creek dispersed recreation site to benefit 

recreation and provide cultural and natural resource protection. 

58P. Reconstruct Hells Canyon Park to benefit recreation, improve public access, and protect 

cultural and natural resources. 

59P. Develop Airstrip A&B dispersed recreational site to benefit recreation, improve public 

access, and protect cultural and natural resources. 

60P. Develop and implement a site plan for Bob Creek Section A dispersed recreational site to 

benefit recreation, improve public access, and protect cultural and natural resources. 

61P. Develop and implement a site plan for Bob Creek Section B dispersed recreational site to 

benefit recreation, improve public access, and protect cultural and natural resources. 

62P. Develop and implement a site plan for Bob Creek Section C dispersed recreational site to 

benefit recreation, improve public access, and protect cultural and natural resources

63P. Develop and implement a site plan for Westfall dispersed recreational site to benefit 

recreation, improve public access, and protect cultural and natural resources. 

64P. Enhance Copperfield boat launch area to benefit day-use activities. 

65P. Implement a site plan for Oxbow boat launch to benefit recreation, improve public access, 

and protect cultural and natural resources. 

66P. Implement a site plan for Carters Landing and Old Carters Landing recreational sites to 

benefit recreation, improve public access, and protect cultural and natural resources. 

67P. Reconstruct McCormick Park to meet current standards of services, benefit recreation, 

improve public access, and protect cultural and natural resources. 

68P. Develop and implement a site plan for Hewitt and Holcomb Parks to accommodate 

recreational use and provide cultural and natural resource protection. 

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69P. Develop and implement a site plan for a low-water boat launch at or near Swedes Landing 

to improve boat access to Brownlee reservoir during seasonal reservoir drawdowns and 

periods of low reservoir levels. 

70P. Develop and implement a site plan for Swedes Landing to benefit recreation, improve 

public access, and protect cultural and natural resources. 

71P. Develop and implement a site plan for Spring recreational site to enhance recreational 

facilities and improve boat ramp access to Brownlee reservoir. 

Land Management and Aesthetics 

72P. Implement the Hells Canyon Resource Management Plan, creating virtual buffer zones 

between some otherwise incompatible uses, to establish or maintain compatibility between 

and among the various land and water uses in the vicinity of the Hells Canyon Project. In 

the Staff Alternative, we supplemented this measure to include clarifications regarding 

consultation, coordination, and reporting and to include resource maps, maps depicting 

road maintenance responsibilities, and maps for public use as part of the proposed GIS

atlas of critical and sensitive resources. 

73P. Incorporate aesthetic concerns when upgrading or repairing the existing transmission line 

945. In the Staff Alternative, we supplemented this measure to include a monitoring 

strategy to analyze future modifications to the line, incorporating all viewpoints identified 

in the Technical Report on Aesthetics from which the line is visible, and a schedule for 

implementing aesthetic improvements on the line. 

111P. Implement the aesthetic improvements to the Hells Canyon dam site and recreational 

portal, consistent with the settlement (FS modified 4(e) condition no. 22). 

112P. Implement the Scenery Management Plan, consistent with the settlement (FS modified 4(e) 

condition no. 24). 

74P. Measure 74 in the draft EIS (standards and guidelines for physical structures) is 

incorporated in measure 112P. 

75P. Measure 75 in the draft EIS (transmission line aesthetics) is incorporated in measure 112P. 

76P. Measure 76 in the draft EIS (general aesthetic clean-up plan) is incorporated in measure 

112P. 

77P. Measure 77 in the draft EIS (guard rails and Jersey barriers) is incorporated in measure 

112P. 

78P. Measure 78 in the draft EIS (visual contrast) is incorporated in measure 112P. 

79P. Cooperate with BLM and the Forest Service to develop and assist them with implementing 

proposed design standards and guidelines at specific BLM and Forest Service facilities, 

including the Spring recreational site on Brownlee reservoir (BLM), Copper Creek 

trailhead on Hells Canyon reservoir (BLM), and Big Bar and Eagle Bar on Hells Canyon 

reservoir (Forest Service). 

80P. Provide signs and/or facilities that interpret some elements of the Hells Canyon Project that 

cannot be effectively modified to reduce their visual contrast. 

81P. Implement the common policies of the Hells Canyon Resource Management Plan to 

provide for the management, protection, and/or conservation of natural and cultural 

resources. In the Staff Alternative, we supplemented this measure to address law 

enforcement, fire prevention, and road management in the Common Policies.

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113P. Provide the Forest Service with a map and aerial photos depicting the approximate location 

of the project boundary, together with GIS shapefiles with Metadata for the project 

boundary on National Forest System lands. The project boundary GIS data would be 

compatible with Forest Service GIS and would be positionally accurate to ±40 feet in order 

to comply with National Map Accuracy Standards for maps at a 1:24,000 scale. This 

measure is consistent with the settlement (FS modified 4(e) condition no. 26). 

Additional Measures Proposed by Staff 

Finally, the Staff Alternative also includes the following additional measures identified by staff 

based on agency, tribal, and NGO recommendations and our analysis. Measures numbered 2S through 

27S reflect original staff measures presented in the draft EIS; measures 101S through 108S reflect staff 

measures added between the draft EIS and final EIS. 

Sediment Supply and Transport 

1S. Staff measure 1 in the draft EIS (beach and terrace erosion, substrate, and gravel 

monitoring) has been incorporated into Idaho Power’s proposal (measure 101P). 

Water Use and Quality 

2S. Staff measure 2 in the draft EIS (develop and implement a temperature management plan) 

has been incorporated in Idaho Power’s proposal (measure 109P). 

3S. Staff measure 3 in the draft EIS (develop and implement a total dissolved gas abatement 

plan) has been incorporated into Idaho Power’s proposal (measure 107P). 

4S. Develop and implement an operational compliance and water quality monitoring plan to 

monitor compliance with minimum flows, reservoir levels, and ramping rates specified in 

the license, and to monitor water quality downstream of Hells Canyon dams. Develop the 

plan in consultation with IDEQ, ODEQ, IDFG, ODFW, NMFS, FWS, USGS, and 

interested tribes. The plan should, at a minimum, include: 

 Identification of an appropriate location for continuous monitoring of river flow, stage, 

water temperature, dissolved oxygen, and total dissolved gas within 5 miles 

downstream of Hells Canyon dam, preferably within 3 miles of the dam; 

 A schedule for the construction of a flow measurement gage at the selected site, and 

for the installation of water quality monitoring equipment; 

 A description of procedures that would be followed to determine a ramping rate at the 

new gage site that is equivalent to any ramping rate specified for other locations in the 

new license; 

 A description of the method that would be used to measure water surface elevations at 

Brownlee, Oxbow and Hells Canyon reservoirs, as well as flow rates in the Oxbow 

bypassed reach; and 

 The time steps for which real-time and historical flow, water surface elevation and 

water quality information from each location would be posted on the Internet and 

annually reported to the Commission. 

5S. If requested by IDEQ or ODEQ, make available tissue samples from white sturgeon within 

and downstream of the project area and from Brownlee reservoir fish for the purpose of 

monitoring toxic bioaccumulants. These samples would be collected during the routine 

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population monitoring efforts proposed by Idaho Power (Idaho Power measures 7Pb and 

11Pd). 

Aquatic Resources 

6S. Every 5 years, file a report that summarizes water quality changes in response to TMDL 

implementation upstream of Brownlee dam to determine when habitat becomes suitable to 

support any future reintroduction efforts. 

7S. Staff measure 7 in the draft EIS (gravel augmentation pilot program) has been deleted. 

8S. Six years after license issuance, prepare a flow augmentation evaluation report that 

evaluates the efficacy of flow augmentation water provided from Brownlee reservoir for 

aiding the downstream migration of juvenile salmon and steelhead; to include consideration 

of how these releases are coordinated with flow augmentation water contributed from the 

Snake River basin upstream from Brownlee dam and from Dworshak reservoir; and to 

include any recommendations, for Commission approval, for modifying flow augmentation 

releases from Brownlee reservoir. 

9S. Develop and implement a stranding and entrapment monitoring plan to evaluate, and if 

needed develop and implement approaches to protect and enhance rearing juvenile fall 

Chinook salmon and bull trout downstream of Hells Canyon dam. 

101S. Develop and implement an invertebrate monitoring plan to evaluate trends in the 

abundance and distribution of rare and sensitive species of mollusks, as well as to evaluate 

the effects of load following operations on rare and sensitive mollusks and the food supply 

available to fall Chinook salmon and to bull trout. As part of the plan, prepare annual 

monitoring reports and provide for updates to the monitoring plan every 5 years, addressing 

the need to alter project operations or implement other measures to address project effects 

based on monitoring results. 

10S. Develop and implement a fall Chinook spawning and incubation flow management plan to 

determine appropriate monitoring methods to assist with determining flow levels to be 

maintained downstream of Hells Canyon dam during the fall Chinook salmon spawning 

and incubation season. The plan would be developed in consultation with NMFS, FWS, 

IDFG, ODFW, and the interested tribes. 

102S. Fund the development and implementation of a hatchery and genetics management plan for 

each mitigation hatchery, including establishment of mitigation goals, but retaining current 

smolt production targets. As part of the plan, prepare annual reports on the hatchery 

program, including data on adult returns, to ensure the goals and objectives of the plan are 

being met. 

103S. Develop a plan, in consultation with the Shoshone-Bannock Tribes, IDFG, NMFS, and 

FWS, to design, construct, and operate facilities on the Yankee Fork to collect, spawn and 

incubate 1,000,000 steelhead or Chinook salmon eggs to support the Shoshone-Bannock 

Tribe’s existing streamside incubator program. The facilities would need to be operated in 

compliance with a Hatchery and Genetic Management Plan117 approved by NMFS. 

 

117 Because the facilities would be operated by the Shoshone-Bannock Tribes, the HGMP would be 

developed by the tribes in consultation with NMFS. 

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Production numbers from the Yankee Fork hatchery should be included in the annual 

reports on the hatchery program prepared by Idaho Power (102S). 

104S. In consultation with ODFW, IDFG, FWS, NMFS, and interested tribes, develop and 

implement a plan to use surplus adult hatchery spring Chinook salmon and steelhead to: 

(1) provide marine nutrients and improve forage for bull trout in tributaries within the 

project area; (2) facilitate the evaluation of spawning success, egg viability and survival, 

and smolt outmigration and survival in Pine Creek; and (3) support ceremonial, 

subsistence, and recreational fisheries in select tributaries to the Snake River, including the 

Salmon River basin where appropriate. 

105S. Participate in regional forums on lamprey restoration in the Snake River basin, file a 

summary of the activities with the Commission every 3 years, and identify and implement 

any feasible measures to address project effects on Pacific lamprey. 

106S. Hold annual meetings of the White Sturgeon Technical Advisory Committee to review the 

results of past monitoring and enhancement efforts, and to guide such efforts in the 

upcoming year, and file with the Commission an annual report on the results from the 

previous year of monitoring and enhancement efforts, and any recommendations for 

revising the monitoring or enhancement measures. 

Wildlife and Botanical Resources 

11S. Develop and implement a plan to assess the feasibility of stabilizing/revegetating erosion 

sites around project reservoirs and along the river downstream of Hells Canyon dam; 

implement a pilot project and monitor results to determine the feasibility of implementing a 

long-term stabilization/revegetation program; and, if erosion predicted to occur during the 

new license period cannot be stabilized, acquire up to 70 acres of riparian habitat in 

coordination with Idaho Power measure 12P.

12S. Develop and implement a project-wide Threatened, Endangered, and Sensitive Species 

Management Plan to address plants (in coordination with Idaho Power measure 19P, 

above) and animals, including bald eagles, southern Idaho ground squirrel, bats, 

amphibians, and reptiles. 

13S. Develop and implement a Transmission Line Operation and Maintenance Plan for 

transmission line 945 to address protection and enhancement of wildlife and botanical 

resources, including monitoring electrocution and collision mortality and scheduling 

operation and maintenance to minimize disturbance to wintering mule deer. 

14S. In coordination with Idaho Power measure 12P, above, acquire 13.2 acres of riparian 

habitat to mitigate for the loss of riparian habitat predicted to occur as the result of 

implementing the staff’s alternative flow measures; and 49 acres of riparian habitat to 

address the loss of suitable substrate for native willows along the Snake River downstream 

of Hells Canyon dam. 

15S. Extend the Wildlife Mitigation and Management Plan to apply to all lands within the 

project boundary, including National Forest System and BLM-administered lands, as well 

as Idaho Power lands. As part of the Wildlife Mitigation and Management Plan, develop 

and implement an I&E program to minimize risk of wildlife disturbance. As part of the 

plan, schedule operation and maintenance to minimize disturbance on deer winter range. 

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Historical and Archaeological Resources 

16S. Renew the licensee’s offer to arrange for oral histories for the Shoshone-Bannock and 

Shoshone-Paiute Tribes. 

17S. Develop and implement a monitoring plan for archaeological sites, rock art, and traditional 

cultural properties. 

18S. Develop a plan to implement Idaho Power’s deferred monitoring program concerning 

effects of reservoir water level fluctuations on cultural resources. 

19S. Staff measure 19 in the draft EIS (file the final Historic Properties Management Plan within 

1 year of license issuance) has been dropped because the Commission has ordered the plan 

filed by August 3, 2008. 

20. Develop and implement a program to re-evaluate buildings and structures within the project 

boundary as they reach 50 years old. 

Recreational Resources 

21S. Finalize the proposed Recreation Plan to add specificity to implementation standards and 

expand the scope of the plan to address the following additional elements: 

21Sa. Oasis recreation site improvements; 

21Sb. Improved Brownlee reservoir communication system and, if recreational use 

demonstrates the need, expand Steck Park; 

21Sc. Control and removal of sediment accumulation at Farewell Bend State Park; 

21Sd. Improvements at Jennifer’s Alluvial Fan, including toilet facilities, vehicular barriers, 

signage, and regular maintenance; 

21Se. Staff measure 21e in the draft EIS (Deep Creek Trail improvements and 

incorporation in the project boundary) has been included in Idaho Power’s proposal 

(measure 51P); 

21Sf. Improvements at Hells Canyon launch to enhance access and safety, provide potable 

water, and provide a portable human waste disposal system; and 

21Sg. O&M at primary recreational sites within the project boundary and clarification of 

O&M standards and responsibilities. 

107S. Consult with ODFW to coordinate and provide form 80 recreational use data on 

recreational fishing effort in the project vicinity. 

108S. As part of the Recreation Plan, consult with the Corps, NPPVA, the Forest Service, and 

other interested parties to prepare a navigation plan that addresses non-flow measures that 

could be implemented to improve boating safety downstream of Hells Canyon dam, 

including the installation of additional stream gages. 

Land Management and Aesthetics 

22S. Develop an Aesthetics Management Plan as part of the Hells Canyon Resource 

Management Plan to be applied to all lands within the project boundary, including 

transmission line 945 and the right-of-way, and to include Idaho Power's proposed aesthetic 

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measures (see Idaho Power’s proposed aesthetic measures, items 73 through 80 above), a 

monitoring strategy for all viewpoints established in the Technical Report on Aesthetics, 

and an estimated maintenance schedule and schedule for implementing aesthetic 

improvements.

23S. Include within Idaho Power’s proposed boundary modification to include dispersed 

recreation sites that are within 200 yards of project waters; Airstrip, Steck Park, Swedes 

Landing, and Westfall recreational sites; Hells Canyon Creek launch area; Deep Creek 

trail; and all lands acquired for wildlife mitigation. 

24S. Provide the Forest Service with aerial photographs at a scale acceptable to the Forest 

Service showing the approximate location of the project boundary throughout Forest 

Service-managed lands. 

25S. Coordinate with BLM and the Forest Service concerning activities on lands managed by 

those agencies. 

26S. Staff measure 26 in the draft EIS (aesthetics improvement plan for the upper deck, 

entrance, and egress of Hells Canyon dam) has been included in measure 111P, above. 

Oversight and Adaptive Management 

27S. Establish technical advisory subcommittees to facilitate consultation on the development 

and implementation of plans required by the new license and to provide consultation on the 

ongoing implementation of license requirements using adaptive management principles. 

5.1.1.3 Staff Alternative with Mandatory Conditions 

The Department of Commerce (for NMFS) has filed preliminary fishway prescriptions for the 

project and Interior (for FWS) has filed preliminary and modified fishway prescriptions (see section 

2.3.1.2, Section 18 Fishway Prescriptions) which, when finalized, the Commission may need to include 

in a new license for this project. Similarly, Interior (for BLM) and the Forest Service have specified 

preliminary and modified 4(e) conditions (see section 2.3.1.3, Section 4(e) Federal Land Management 

Conditions) which, when finalized, the Commission may also need to include in a new license for this 

project. Incorporation of these mandatory conditions into a new license would add three measures that 

are not included in the Staff Alternative, as follows (see section 2.3.1.3 for the numerical designation of 

these measures): 

• Interior-3—Development and implementation of a Travel and Access Management Plan; 

• Interior 4—Development and implementation of a Law Enforcement and Emergency Services 

Plan; and 

• FS-20—Trail maintenance on nine specified trails. 

Except for these three measures, all of the mandatory conditions are included in the Staff Alternative. 

5.1.2 Summary of Effects 

We summarize distinguishable differences between Idaho Power’s Proposal and the Staff 

Alternative in table 105, and briefly note the differences associated with the Staff Alternative with 

Mandatory Conditions. Idaho Power’s proposed operation is similar to current operations. Therefore, 

unless otherwise noted, the ongoing effects of project operation under Idaho Power’s Proposal are similar 

to current conditions. 

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Table 105. Summary of effects of Idaho Power’s Proposal and Staff Alternative. (Source: Staff) Resource Idaho Power’s Proposal Staff AlternatiPower Benefits Annual generation (MWh) 6,562,244 6,549,344 

Net annual benefits $297,050,500 $283,876,80Sediment Supply and TransportEffects of Operations • Beach and terrace erosion would continue downstream 

of Hells Canyon dam. 

• The quantity and quality of spawning gravels 

downstream of Hells Canyon dam would continue to be affected by project reservoirs trapping sand and gravel. 

• Little or no change in beach and 

compared to Idaho Power’s Prop

• Little or no change in spawning 

compared to Idaho Power’s Prop

Effects of Environmental Measures

• The quantity, quality, and usage of spawning gravels 

downstream of Hells Canyon dam would be monitored. 

• Restoration of 14 acres on sandbar downstream of Hells 

Canyon dam would help mitigate for reservoir trapping of sand and gravel. 

• Monitoring beach and terrace ero

information about the effectivenstrategies and support developmmeasures. 

• Gravel augmentation program w

reduction in the quantity or qualishown to adversely affect producsalmon. 

• Restoration of 14 acres of sandb

beneficial effect as Idaho Power

Water Quality Effects of Operations Compared to without project conditions: 

• Water temperatures would continue to be cooler in 

spring and summer and warmer in the fall and winter potentially resulting in reduced viability of fall Chinook salmon eggs and reduced growth potential of fry. 

• The project would continue to lower dissolved oxygen 

concentrations in and downstream of Brownlee reservoir affecting habitat suitability for fish. 

• Total dissolved gas levels downstream of Brownlee dam 

would continue to exceed the 110-percent of saturation 

Compared to Idaho Power’s Proposa• The temperature of water release

dam during the flow augmentatioslightly increased in extreme low warming would occur as flow padue to higher flow volumes. Thewould result in negligible effects other fish downstream of Hells C

• Dissolved oxygen concentration

improved downstream of Hells C

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Resource Idaho Power’s Proposal Staff Alternati

criterion when spill exceeds 3,000 cfs. 

• Total dissolved gas levels downstream of Oxbow dam 

would continue to exceed the 110-percent of saturation criterion coinciding with most Brownlee spill events of more than 3,000 cfs and independent spills at Oxbow dam. 

• Total dissolved gas levels downstream of Hells Canyon 

dam would continue to exceed the 110-percent of saturation criterion during virtually all spill conditions increasing the likelihood of gas bubble trauma. 

• Project operation would continue to result in ammonia 

and trace metal concentration in the reservoirs and bioaccumulation in fish. 

flow augmentation period in extr

• Ammonia and trace metals woul

reservoirs more frequently, but bwould remain about the same. 

Effects of Environmental Measures 

• Dissolved oxygen supplementation would improve 

dissolved oxygen levels in the immediate vicinity of the proposed oxygen diffuser system in Brownlee reservoir or upstream phosphorus trading would improve water quality in affected tributaries and downstream reaches. 

• Hells Canyon turbine aeration would increase 

summer/fall dissolved oxygen levels downstream of the dam and thereby improve conditions for fall Chinook salmon. 

• Destratification of the deep pool in the Oxbow bypassed 

reach would increase dissolved oxygen levels in this pool and thereby improve native resident salmonid habitat. 

• Installation of spillway flow deflectors at Brownlee and 

Hells Canyon dams combined with total dissolved gas abatement measures at Oxbow dam, and an adaptive total dissolved gas abatement program would reduce the frequency and magnitude of total dissolved gas levels exceeding the 110 percent of saturation criterion and thereby reduce the potential for gas bubble trauma in Oxbow and Hells Canyon reservoirs, Oxbow bypassed reach, Hells Canyon tailrace, and the Snake River 

• Monitoring the effectiveness of m

under the dissolved oxygen enhameetings with agencies and intermonitoring and implementation the decision-making process for effects on dissolved oxygen and of associated measures. 

• Establishing a flow and water qu

within 5 miles downstream of Himprove monitoring of project ef

• Collection of tissue samples from 

other fish species in Brownlee reof bioaccumulation of contaminaimproved protection of public hebald eagles. 

• Monitoring the effectiveness of m

under the Temperature Adaptive annual meetings with agencies afiling of monitoring and implemimprove the decision-making proproject effects on water tempera

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Resource Idaho Power’s Proposal Staff Alternati

downstream of Hells Canyon dam. 

• Implementation of a Brownlee bubble upwelling system 

or watershed measures as part of a Temperature Adaptive Management Plan would reduce water temperatures early in the fall Chinook salmon spawning period and improve production potential. 

Aquatic Resources Effects of Operations • Daily flow fluctuations downstream of Hells Canyon 

dam would continue to reduce the abundance of aquatic invertebrates, the primary food base for fish, by about 10 percent. 

• The reduction in aquatic invertebrates would especially 

affect fall Chinook juveniles, which rear in shallow areas that are subject to frequent dewatering 

• Migration conditions for juvenile fall Chinook salmon 

would remain the same as years when flow augmentation water has not been provided from Brownlee reservoir, but would be less favorable than conditions in most of the past 14 years when flows were voluntarily augmented. 

• More restrictive ramping rates du

as well as provisions for monitormanagement based on monitorinsubstantially reduce fall Chinook to stranding and entrapment and during the fall Chinook rearing s

• Invertebrate monitoring would h

that peaking operations affect rarof mollusks and invertebrate proin identifying operational modifiadverse effects through adaptive 

• Most available information supp

flow augmentation should enhanfor juvenile fall Chinook salmon lower Columbia rivers, likely incReview of new information on thaugmentation 6 years after licensthe timing and quantity of water Brownlee reservoir to be adjuste

• A fall Chinook spawning flow m

augmentation evaluation report, Chinook salmon entrapment and improve the flow management doverall survival of fall Chinook River downstream from Hells Ca

Effects of Hatchery Measures • Improved hatchery facilities and a monitoring and 

evaluation program would maintain anadromous fish production at current levels. 

• Consulting with the fisheries ma

interested tribes to define appropobjectives of its hatchery program 

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Resource Idaho Power’s Proposal Staff Alternati

Hatchery and Genetic Managemwith Idaho Power’s responsibilitlicense, as well as reflect the maagencies and tribes. 

• Constructing and operating facil

incubate steelhead and Chinook Fork would (1) help rebuild, and of, listed ESUs, and (2) support and recreational fisheries in the pRiver basin. 

• Developing and implementing a 

distribute surplus anadromous fiPower’s hatchery system or the Hproject reservoirs and tributaries well as other select tributaries in would provide several resource bdistributing surplus fish would (marine nutrients for the system; bull trout; (3) provide an opportuspawning success, egg viability smolt outmigration and survival support ceremonial, subsistence, fisheries in the project area and S

Effects of Other Environmental Measures 

• Dissolved oxygen supplementation would improve fish 

habitat in the vicinity of the oxygen diffuser system, if implemented, in the upper end of Brownlee reservoir. 

• Phosphorus trading and watershed measures, if 

implemented, would provide broad benefits to water quality and habitat conditions for resident fish species within and downstream of the project, and in the tributaries where measures are implemented. 

• Hells Canyon turbine aeration would increase 

summer/fall dissolved oxygen levels downstream of the dam, improving habitat conditions for aquatic resources, including fall Chinook salmon. 

• Reductions in total dissolved gas exceedances 

• Potentially greater temperature a

would be provided if additional wreduction measures are implememonitoring results. 

• Annual meetings with agencies a

filing of monitoring and implemexpedite the implementation of areduce gas supersaturation, if nelikelihood of gas bubble trauma from, the project. 

• Implementation of upstream and 

native resident salmonids would and gene flow among population

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Resource Idaho Power’s Proposal Staff Alternati

downstream of Brownlee, Oxbow, and Hells Canyon dams, at low and moderate spill rates, would benefit aquatic resources by reducing gas bubble trauma. 

• Improvement of Hells Canyon dam fish trap would 

reduce stress and injury to fish by allowing onsite sorting and allow fish tagging activities. 

• Implementation of upstream passage for native resident 

salmonids could improve gene flow to some populations, but downstream populations may be reduced due to upstream migration. 

• Construction of a monitoring weir on Pine Creek would 

allow further monitoring of bull trout migration and enable downstream transfer of outmigrants past Hells Canyon dam. 

• Pathogen risk assessment would help manage increased 

risk of pathogen transfer associated with the proposal. 

• Tributary enhancements and carcass outplants or other 

nutrient supplementation would benefit bull trout and redband trout within the Pine Creek, Indian Creek, and Wildhorse River basins and smaller tributaries to the project. 

• Brook trout suppression efforts could reduce 

competition and hybridization with bull trout in Indian Creek. 

• Implementation of the proposed White Sturgeon 

Conservation Plan and related measures would help rebuild the white sturgeon population in the Swan Falls to Brownlee reach. 

Creek, and the Wildhorse River. 

• Construction of weir and trap fis

Indian Creek and the Wildhorse tracking of bull trout population monitoring of brook trout controenhancement efforts. 

• Construction of the Pine Creek w

round would improve monitoring movements and would enable assuccess of surplus adult steelheasalmon released into Hells Cany

• Benefits of Hells Canyon trap m

risk assessment, and nutrient supthe same as Idaho Power’s Propo

• Additional tributary enhancemen

benefit native resident salmonids Burnt River basins. 

• Brook trout suppression efforts, 

expanded to include the Wildhorusing methods proven to be succ

• Sturgeon stocking, if determined 

augment white sturgeon populatibetween Swan Falls and Hells Ctribal and recreational fisheries. 

Terrestrial Resources Effects of Operations • Slightly increased potential for negative effects on 

special status plants. 

• Slightly increased occurrence and expansion of puncture 

vine at Brownlee reservoir. 

• Daily flow fluctuations would reduce riparian habitat at 

• Effects on special status plants e

Idaho Power’s Proposal. 

• Effects on noxious weeds simila

Proposal, but slightly more weed reservoir and slightly less occurr

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Resource Idaho Power’s Proposal Staff Alternati

Hells Canyon and Oxbow reservoirs by <1 acre and by about 15 acres downstream of Hells Canyon dam. 

• Conditions would remain about the same for fish-eating 

wildlife such as river otters, black bears, and bald eagles. 

• Brownlee reservoir would continue to pose a small risk 

to mule deer trying to cross it. 

• Continued erosion would be likely to affect about 70 

additional acres over the term of the license. 

Hells Canyon dam. 

• Daily flow fluctuations would re

<1 acre at Hells Canyon reservoOxbow reservoir, and about 13 aHells Canyon dam. 

• More stable flows benefiting fish 

conditions for fish-eating wildlifblack bears, and bald eagles. 

• Risks to mule deer crossing Brow

the same as Idaho Power’s Propo

• Continued erosion would be sim

Proposal. 

Effects of Environmental Measures 

• Coordination and planning would improve protection of 

rare plants and control of noxious weeds. 

• Transmission line operation and maintenance plans for 

wildlife and botanical resources would reduce potential adverse operation and maintenance effects on terrestrial 

resources. 

• Management of 20,592 acquired acres and 2,990 Idaho 

Power acres for wildlife habitat would benefit terrestrial resources affected by operation of the project based on a 1:1 replacement ratio. 

• Habitat enhancement at four Snake River islands would 

improve habitat for waterfowl, nesting waterbirds, raptors, neotropical migrant songbirds, and aquatic furbearers. 

• Coordination with agencies to enhance mountain quail 

habitat and/or participate in relocation projects would benefit mountain quail. 

• Implementation of the Integrated Wildlife Habitat 

Program and Wildlife Mitigation and Management Plan would improve coordination and management of wildlife habitat in Idaho Power’s ownership. 

• Threatened, endangered, and sensitive species would 

• Rare plant protection and noxiou

essentially the same as Idaho Posome additional measures to impcoordination and increased emphimplementation of ground-distur

• Transmission Line Operation an

terrestrial resources would be esIdaho Power’s Proposal, with soand coordination and increased r

• Acquisition and management of 

have essentially the same effects Proposal, but would also include ongoing effects on sandbar willoanticipated to occur during new loss of riparian habitat resulting staff flow alternative. 

• Provision of funding for capital i

implementation of habitat enhanRiver islands would yield greatethan Idaho Power’s Proposal. 

• Improvements to mountain quail 

participation in relocation projec

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Resource Idaho Power’s Proposal Staff Alternati

continue to be managed on a case-by-case basis. same as Idaho Power’s Proposal

• Application of project-wide wild

would improve coordination of hlands within the project boundarPower’s Proposal. 

• Development of project-wide Th

and Sensitive Species Managemefficiency and coordination of prthose species covered by the planPower’s Proposal. 

Cultural Resources Effects of Operations • Restoration of 14 acres of sandbar downstream of Hells 

Canyon dam would help protect some cultural sites from erosion damage. 

• Beach and terrace erosion would continue to put some 

cultural sites at risk. 

• Restoration of 14 acres of sandb

beneficial effect as Idaho Power

• More restrictive ramping rates du

provide a minor increase in cultucompared to Idaho Power’s Prop

Effects of Environmental Measures 

• Site monitoring would improve protection of monitored 

sites. 

• Site stabilization would protect 7 sites on Brownlee 

reservoir and 20 sites downstream of Hells Canyon dam, and data recovery at 4 sites would prevent possible future damage. 

• Establishment of Native American, EuropeanAmerican, and Asian-American interpretive sites could 

contribute to resource protection through visitor education. 

• Support for local museums would enhance cultural 

resources protection and education in the local area. 

• Support for Native American programs would enhance 

the tribes’ informed participation in the management and protection of project resources. 

• Measures to improve the condition of aquatic resources 

would benefit culturally important species, including 

• Development of site monitoring 

efficiency and consistency of mo

• Site stabilization, data recovery, 

interpretive sites would achieve Idaho Power’s Proposal. 

• Support for Native American pro

fewer benefits than Idaho Powerscholarships would not be provid

• Renewed offer to prepare oral hi

Bannock and Shoshone-Paiute Tenhance cultural understanding. 

• Development of a plan to implem

of reservoir water level fluctuatiresources would enhance undersand form the basis for further proneeded. 

• Continuation of flow augmentati

tributary habitat improvements t

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Resource Idaho Power’s Proposal Staff Alternati

white sturgeon and native resident salmonids. 

• Development of a plan to implement the deferred study 

of reservoir water level fluctuation effects on cultural resources would enhance understanding of those effects and form the basis for further protective measures, if needed. 

River basins, implementation of prescription, consultation with adetermine the best use of surplus and spring Chinook salmon, and white sturgeon measures to inclureservoirs would provide additiofisheries and to culturally import

• Revision of the HPMP to meet F

condition no. 25 would improve including provision for an adaptito accommodate unforeseen chaland also provisions for determincircumstances new survey, or reexamined areas, may be required

Recreation Effects of Operations • Brownlee reservoir level would continue to support flatwater boating and crappie fishing in the late summer 

and early fall. 

• Similar to current conditions, flows downstream of 

Hells Canyon dam would routinely fall below the Corps’ recommended 8,500-cfs safe navigation flow. 

• Flow fluctuations downstream of Hells Canyon dam 

would continue to adversely affect boaters and campers. 

• Flow augmentation would adver

boating opportunities and crappicurrent conditions and Idaho Pow

• Implementing an 8,500-cfs minim

from Hells Canyon dam in medihigh flow years would increase bhaving those flows available. 

• Flow augmentation would slight

boating opportunities downstrea

• More stabilized flows during the 

Hells Canyon dam would enhancboating experience. 

Effects of Environmental Measures 

• Preparation and implementation of a Recreation Plan 

would benefit recreational visitors by providing improved management of recreational programs. 

• Numerous proposed improvements would benefit 

recreational visitors by improving boat moorage, road maintenance, developed and dispersed recreation sites, and boat access in low water years, and would benefit cultural and natural resources by providing additional 

• Adding specificity to the implem

Recreation Plan would clarify pldelivery of the intended benefits

• Expansion of Recreation Plan to 

improvements at Oasis, Steck reBend State Park, Jennifer’s Allu

and the Hells Canyon launch worecreation benefits compared to 

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Resource Idaho Power’s Proposal Staff Alternati

protection near recreation uses. 

• Proposed changes in the litter and sanitation 

management program would substantially improve upon existing conditions. 

• The I&E Plan would promote protection and 

preservation of cultural, natural, and historic resources. 

• Funding O&M at its recreation sites and those of BLM 

and the Forest Service that Idaho Power upgrades would benefit recreational visitors and resource protection by improving maintenance and management at most of the primary recreation sites in the project boundary. 

• Continuing to provide flow information for flows 

downstream of Hells Canyon dam would continue to benefit recreational visitors by providing timely information to be used in trip planning. 

• Continuance of the Memorandum of Understanding for 

staffing the Hells Canyon Visitor Center would continue to benefit visitors at the center. 

• Preparation of a Recreation Adaptive Management Plan 

would provide a framework for responding to changes in recreational needs. 

• Implementation of the White Sturgeon Conservation 

Plan should lead to an improved sturgeon fishery in the Swan falls to Brownlee Reach. 

• Implementation of the native salmonid plan and 

tributary enhancements should improve redband trout fisheries in the Pine, Indian and Wildhorse basins. 

• Expansion of the litter and sanita

program to include a gray water system at the Hells Canyon Creeimprove the sanitation system anwaste for boaters. 

• Increasing the specificity of the I

information on aquatic invasive fish would promote additional unprotection for project resources. 

• Clarifying O&M funding and res

Service and BLM recreational siconsultation as part of the final Rimprove delivery of the intended 

• Preparing and implementing the 

increase the benefits of the flow increasing the amount and timeliinformation. 

• Hells Canyon Visitor Center staf

as under Idaho Power’s Proposa

• Adding details to the Recreation 

Plan concerning the minimum lemonitoring and consultation eveForm 80 filing would improve thPlan to changing recreational con

• Expanded tributary enhancemen

redband trout fisheries in the Powbasins. 

• Sturgeon stocking, if determined 

improve the sturgeon fishery beHells Canyon dams more rapidly Power’s proposal. 

Land Management and AestheticsEffects of Operations • The adverse visual effects of Brownlee reservoir 

drawdown would continue to occur from about July 

• Flow augmentation would lead t

drafting of Brownlee reservoir stexacerbating the negative visual 

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Resource Idaho Power’s Proposal Staff Alternati

through October. 

• Visual effects on the shoreline downstream of Hells 

Canyon dam would continue due to periodic dewatering of the shoreline, beach and terrace erosion, and loss of riparian habitat. 

reservoir drawdowns. 

• Negative visual effects downstre

would be reduced somewhat comProposal due to more stable watespring. 

Effects of Environmental Measures 

• Implementation of the Hells Canyon Resource 

Management Plan on project lands would enhance the management, conservation, and protection of natural and cultural resources. 

• Continuation of the project’s law enforcement and fire 

protection programs and sponsorship of biannual law enforcement coordination meetings would help maintain and improve public safety and resource protection at the project. 

• Proposed boundary modifications to exclude 3,800 

acres of federal lands from the project boundary would exclude some lands used for project-related purposes. 

• Development of a road management plan, application of 

the Common Policies of the Hells Canyon Resource Management Plan, and continued maintenance of 40 miles of road would lead to improved access, public safety, and resource protection related to those roads 

• Application of the aesthetic resource elements of the 

Hells Canyon Resource Management Plan would improve the aesthetic appearance of the project. 

• Reducing the visual contrast of transmission line 945 

would enhance the visual experience of visitors. 

• Adding specific details to the He

Management Plan to identify whspecific management plans and iwould improve delivery of the inplan. 

• Adding specific agency coordina

Hells Canyon Resource Manageimprove protection of resources Service lands in the project boun

• Adding specific components of t

fire protection programs to the HManagement Plan would improvintended benefits of those progra

• Amending the project boundary 

for wildlife mitigation, dispersed 200 yards of the shoreline, and thSwedes Landing, and Westfall reimprove resource protection at thmanaged lands could be removewithout adversely affecting resouProviding the Forest Service witaerial photographs would enhancresource protection on Forest Se

• Including additional consultation 

management planning process anprocess with the Hells Canyon RPlan would help ensure that all pappropriately maintained. 

• Adding specificity to the aesthet

the Hells Canyon Resource Manpreviously developed, project-w

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Resource Idaho Power’s Proposal Staff Alternati

guidelines, and formalizing it intimprovement management plan of the intended benefits. 

• Adding aesthetic improvements 

would enhance the visual experi

• Including transmission line aesth

the aesthetic elements of the HelManagement Plan would help enapproach to visual resource man

SocioeconomicsEffects of Operations • Potential increase in electricity rates to pay increased 

cost of producing project power. 

• Potentially greater increase in el

increased cost of producing proj

• Flow augmentation could lead to 

spending away from warmwater reservoir, affecting related busin

Effects of Environmental Measures 

• Spending on environmental measures and increased 

visitor use could increase local business income, but also increase cost to counties to provide services in the project area. 

• Wildlife habitat restoration and improved conditions for 

some aquatic resources would benefit tribal cultures compared to current conditions. 

• Greater spending on environmen

to greater increase in local busin

• Additional measures to benefit d

fish populations and resident fish upstream of the project could leatribal cultures compared to Idaho 

• Constructing and operating facil

incubate steelhead and Chinook Fork and implementing a plan to surplus anadromous fish would psubsistence fisheries for the tribe

a The Staff Alternative with Mandatory Conditions is not listed in this table, and differs from the Staff Alternative only by the inclus

related to trail development and maintenance, road maintenance, and law enforcement 

Notes: BLM – U.S. Bureau of Land Management  DO – dissolved oxygen  Forest Service – U.S. Forest Service  GBT – gas bubble trauma  HCRMP – Hells Canyon Resource Management Plan  IWHP – integrated wildlife habitat program 

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 MOU – memorandum of understanding  MWh – megawatt hours  O&M – operation and maintenance  TDG – total dissolved gas  TMDL – total maximum daily load  WMMP – Wildlife Mitigation and Management Plan 

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5.2 DISCUSSION OF KEY ISSUES 

The measures proposed by Idaho Power and those included in the Staff Alternative would help 

protect and enhance water quality, fisheries, and terrestrial, recreational, aesthetic, and cultural resources 

in the project area, but would reduce the net power benefits of the project. In this section, we discuss our 

rational for including some measures in our Staff Alternative and not including others. 

5.2.1 Sediment Augmentation and Monitoring 

The supply and movement of sediment in the free-flowing section of the Snake River downstream 

of Hells Canyon dam provide habitat for aquatic life, support recreational activities, and maintain 

important cultural resources. Sediment trapping within the project’s reservoirs and flow fluctuations 

caused by project operations may contribute to the erosion of sandbars, beaches, and terraces downstream 

of Hells Canyon dam. Beach erosion may adversely affect aquatic resources by reducing the availability 

of gently sloping shorelines favored by rearing juvenile fall Chinook salmon and reduce the extent of 

beaches available for recreation (beaches are used for boat landing, swimming, and camping). Beach and 

terrace erosion may also affect important archaeological sites. 

In its license application, Idaho Power proposes to stabilize terraces containing culturally 

important sites but does not propose any measures to stabilize or restore sandbars. Forest Service 

condition FS-4 specifies that Idaho Power fund a sandbar maintenance and restoration program consisting 

of sand augmentation and monitoring. To fund the program, Idaho Power would establish and maintain 

an interest-bearing account, with the Forest Service as the beneficiary. Under this condition, the Forest 

Service would use the fund to restore 14 acres of sandbars on or adjacent to National Forest System lands, 

placing sand above the level of the average annual maximum flow at selected sites, but within the levels 

of flows with annual recurrence frequencies of approximately 2.3 to 30 years. Due to the remoteness of 

most sandbars, sand augmentation would most likely include stockpiling and loading sand to a river barge 

at the Pittsburg Landing and unloading and spreading sand using a small loader, which would be carried 

on the barge. Idaho Power has agreed to implement this measure a condition of the license. 

In section 3.4.2.2, we conclude that sand augmentation to restore sandbars could slightly increase 

rearing habitat for juvenile fall Chinook salmon, maintain beaches used for recreation, improve the 

aesthetic appearance of the riverscape, and potentially reduce losses to archaeological resources from 

beach erosion. We also note that implementing the measure has some potential to disrupt eagle nesting 

activity and to interfere with or present a hazard to recreational boaters if sand placement occurs in an 

inappropriate season. The funding for condition FS-4 specified by the Forest Service, $937,000 per year 

for 10 years (equal to an annualized cost of $545,100 over 30 years), would provide 2,500 cubic yards of 

sand per year. In the draft EIS, we did not include this measure in the Staff Alternative because of these 

potential negative effects on boating and wildlife and because we estimated that the proposed 25,000 

cubic yards of sand (2,500 cubic yards per year for 10 years) would replace less than 1 percent of the total 

volume of sand retained annually in the three project reservoirs. 

However, comments on the draft EIS led us to conclude that 25,000 cubic yards of sand would 

actually represent approximately 7 to 24 percent of the average annual rate of sand loss that was estimated 

by Wilcock et al. (2002) for all sandbars below Hells Canyon dam between 1964 and 1990. We conclude 

that the benefits of the sand augmentation and beach restoration program would be worth the cost, and 

that risks associated with potential adverse effects could be satisfactorily addressed. For these reasons, 

we include the sand augmentation and beach restoration fund in the Staff Alternative. 

The Forest Service (FS-31) also recommends that Idaho Power prepare a gravel monitoring plan. 

The plan would include: (1) weekly aerial redd surveys; (2) mapping of reach-scale spawning substrate; 

(3) identification of representative reaches for intensive annual substrate monitoring (riverbed elevations, 

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636 

bed scour and deposition, and bedload sampling); and (4) a requirement for Idaho Power to provide an 

annual report of results to the Forest Service. 

Under Interior-68 and Interior-69, Interior recommends that Idaho Power monitor selected 

beaches and gravel bars to determine rates of sediment depletion on exposed and submerged sediment 

deposits and the quantity and quality of gravel material used by aquatic species in the Snake River 

downstream of Hells Canyon dam. 

NMFS-6 recommends that Idaho Power, in cooperation with various resource agencies, design 

and carry out monitoring of fall Chinook salmon spawning gravel between Hells Canyon dam and its 

confluence with the Salmon River. The recommendation calls for the study to be repeated every 5 years 

and to employ high-resolution, multi-beam bathymetry, reach-scale substrate mapping using Idaho 

Power’s GIS database, and substrate monitoring using scour chains or sliding bead monitors. NMFS-7 

recommends that Idaho Power evaluate fall Chinook salmon egg-to-fry survival in at least two 

representative spawning areas downstream of Hells Canyon dam in 2015 and every 5 years thereafter. 

The Nez Perce Tribe (NPT-20) recommends that Idaho Power be required to monitor the 

movement of sand, silt, and gravel to accurately quantify the composition and rate of movement of 

sediment. The tribe (NPT-21) also recommends that Idaho Power be required to restore sandbars to their 

pre-project number and size, through the use of sand augmentation practices developed in consultation 

with resource agencies, to protect tribal cultural sites at risk of degradation from the erosion of sand bars 

and terraces. 

ODFW-53 recommends that Idaho Power implement a gravel monitoring program to assess 

spawning gravel for fall Chinook salmon downstream of Hells Canyon dam. ODFW also recommends 

that Idaho Power develop a bedload augmentation program if monitoring indicates project operations are 

adversely affecting the quantity and quality of spawning gravel. 

Finally, AR/IRU (AR/IRU-21) recommend that Idaho Power develop a plan to replenish an 

appropriate portion of sand and gravel to the Snake River downstream of Hells Canyon dam that have 

been diminished due to project operations and base the quantity and composition of the sediment on 

specific habitat needs of anadromous and resident fish species and benthic organisms. Additionally, 

AR/IRU-21 would require Idaho Power to estimate sediment volumes and water energy available for 

sediment transport, address monitoring and reporting, and develop an adaptive management protocol for 

sediment augmentation. 

Idaho Power filed a Fall Chinook Spawning and Gravel Monitoring Plan with its draft EIS 

comments, and during the 10(j) meeting, Idaho Power stated that the plan should be considered part of its 

relicensing proposal. The plan includes the following elements: (1) continuation of aerial redd surveys 

from Hells Canyon dam to Asotin, Washington (RM 145), and deep-water redd surveys at approximately 

35 sites; (2) high resolution bathymetry monitoring to estimate bed scour or deposition at selected reaches 

every 3 to 5 years; (3) ground surveys to cover shallow areas at the selected sites that are not covered by 

bathymetry monitoring; (4) reach-scale mapping of spawning substrate in potential high-use spawning 

index sites upstream of the Salmon River every 5 years; (5) substrate classification by photography at 

approximately 650 locations between Hells Canyon dam and the Salmon River every 3 to 5 years and 

after high runoff events; (6) assessment of gravel quality by monitoring incubation and emergence at four 

sites between Hells Canyon dam and the Salmon River at 5-year intervals; and (7) the use of scour chains 

or sliding bead monitors to assess gravel movement or displacement at selected known and potential 

spawning areas. 

In the draft EIS, we concluded that the number of fall Chinook salmon spawning in the Hells 

Canyon reach may be approaching the capacity of available spawning and rearing habitat, and we 

recommended that Idaho Power undertake a pilot study to assess the potential benefits of gravel 

augmentation. Comments received from the resource agencies questioned whether the volume of gravel 

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that we recommended would provide a detectable increase in spawning habitat. Also, in its comments on 

the draft EIS, Idaho Power questioned the need for even a pilot scale gravel augmentation program. 

Idaho Power reported that in each year of spawning surveys, it finds new areas being used for spawning 

that were not used in previous years, and also some areas that were used heavily in previous years that are 

receiving little or no use. It also notes that neither Idaho Power nor FWS has observed significant redd 

superimposition during their weekly aerial and ground surveys of spawning sites. 

Based on the Idaho Power and FWS observations from redd surveys, we conclude that it is 

unlikely that spawning habitat is currently limiting fall Chinook salmon production, and that 

implementing a gravel augmentation program at this time would be premature. However, given recent 

increases in the number of fall Chinook salmon spawning in the Hells Canyon reach, it is possible that the 

quantity of spawning habitat could constrain production in the near future if the increasing trend 

continues. Accordingly, we conclude that the benefits of the Fall Chinook Spawning and Gravel 

Monitoring Plan proposed by Idaho Power warrants the estimated annualized cost of $280,000. However, 

we recommend modifying Idaho Power’s proposal to include annual consultation with NMFS, Interior, 

IDFG, ODFW, and the interested tribes to report on monitoring results to date, guide monitoring efforts in 

the coming year, and determine whether gravel augmentation is warranted. 

5.2.2 Water Supply—Operational Measures 

5.2.2.1 Flood Storage 

From December 1 to June 30, the Corps directs flood control operations of Brownlee reservoir as 

part of system flood control operations for the Columbia River projects to contain winter, spring, and 

early summer flood waters from inundating the main downstream flood damage center located in the 

Portland-Vancouver metropolitan area. Under the current license, Brownlee reservoir may be drawn 

down to elevation 2,034 feet msl by February 28 to provide a maximum storage space of 500,000 acrefeet for system flood control. By April 30, Brownlee reservoir may be drawn down further to elevation 

1,976 feet msl to provide an additional storage space of 480,000 acre-feet to contain flood waters. This 

maximum draft of 980,000 acre-feet of storage space pertains to the most severe combination of 

forecasted hydrologic conditions for the Columbia River at The Dalles and Snake River above Brownlee 

reservoir. Following a period of analysis and revision to flood control rule curves in the 1980s, the Corps 

implemented a modified rule curve procedure in 1998. Flood storage requirements for Brownlee 

reservoir can extend through June, and Idaho Power may have to spill at any or all three project 

developments to achieve flood control storage objectives. 

The Corps recommends that Brownlee reservoir continue to be operated in accordance with the 

Corps’ November 1998 Procedure for Determining Flood Control Draft at Brownlee reservoir, which 

requires a drawdown sufficient to provide up to 1 million acre-feet of flood storage. Because this 

recommendation is the same as current operation, there is no incremental cost associated with it. In 

addition, the Corps recommends handling winter flood control operations on a case-by-case basis, subject 

to certain specified maximum draft rates. As we point out in section 3.3.2.3, Flood Storage, the Corps’ 

recommendation specifies that the request for winter flood storage would occur only during the months of 

December and January, and that Idaho Power would not be required to spill to meet the Corps request. 

Because of these limitations, and because any such request would occur only occasionally, the potential 

impact on power benefits would be inconsequential. Idaho Power’s proposed operations incorporate 

these two recommendations from the Corps, and we have also included them in the Staff Alternative. 

NMFS recommends that Idaho Power control the level of Brownlee reservoir so as to be within 

1 foot of the Corps’ April 15 and April 30 target flood control elevations and then, after April 30, 

coordinate the refill of Brownlee reservoir with NMFS to ensure that the refill does not result in any 

drastic reductions of spring flows as measured at Lower Granite dam. Similarly, the Umatilla Tribes and 

the Nez Perce Tribe recommend that Idaho Power maintain Brownlee reservoir at its upper flood control 

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rule curve elevation from February 28 through April 15 each year so as to accrue additional storage to 

assist in meeting spring target flows for anadromous fish. 

Recommendations pertaining to closely tracking the Corps flood control elevation targets and 

refilling Brownlee reservoir as early as possible are directed toward avoiding excessive reductions in 

outflows from the project during the spring migration season for yearling steelhead and Chinook salmon 

smolts. Preventing such flow reductions would help to maintain suitable migration flows for springmigrating yearling Chinook salmon and steelhead produced in the Salmon River, other Snake River 

tributaries, and to a lesser extent, spring migrants passing through the lower Columbia River. These 

flows would also benefit yearling fall Chinook salmon that are produced in the Clearwater River and the 

portion of the fall Chinook migrants that overwinter in the Snake River before migrating as yearlings. 

While closely tracking, and not exceeding, the Corps’ Brownlee reservoir drawdown requirement would 

be beneficial in support of outmigration, Idaho Power operators require a certain degree of operational 

flexibility to ensure that the Corps’ target flood control elevations are met. Further, during medium to 

high flow years, Brownlee reservoir is typically filling after April 30, capturing inflows as part of the 

springtime flood control operation. Under these circumstances, the Corps directs the rate of Brownlee 

reservoir’s refill. In the Staff Alternative, we include an operational scenario consistent with the NMFS 

and tribal recommendations but indicate that the Brownlee reservoir refill during the flood storage season 

would continue to be accomplished under the direction of the Corps to ensure that the flood control 

purpose is not compromised. We do not have an estimate of the cost of this measure but conclude that it 

is likely to be inconsequential. 

The Umatilla Tribes and the Nez Perce Tribe also recommend that Idaho Power, in consultation 

with the Corps, interested tribes, and other appropriate agencies, revise flood control operations to shift a 

minimum of 110,000 acre-feet of flood storage space from Brownlee reservoir to Lake Roosevelt 

reservoir on the Columbia River in the March-through-May period during low to average flow. NMFS 

makes a similar recommendation but specifies that the Corps determine the timing and amount of the 

flood storage shift. 

Any long-term modification of the project’s flood control operation involving transfer of storage 

capacity from Brownlee reservoir to other storage reservoirs in the Columbia River basin would be under 

the purview of the Corps. The Corps has neither recommended any changes to flood control at the project 

nor undertaken any basin-wide review of its flood control rule curves. Such an effort would require a 

separate environmental evaluation conducted by the Corps. Accordingly, we do not include this measure 

in the Staff Alternative. However, the Corps regularly evaluates short-term opportunities to shift flood 

control from Brownlee reservoir, and nothing in the Staff Alternative would affect that activity. 

5.2.2.2 Navigation Target Flow Levels 

Safe navigation for all of the boats currently using the Snake River downstream of Hells Canyon 

dam requires minimum flows sufficient to effectively cover rocks and create navigable channels through 

important rapids. Of particular importance for navigation are flows measured at the Hells Canyon dam 

gage (0.6 mile downstream of the dam at RM 247) and China Gardens Rapids gage (also known as the 

Snake River below McDuff Rapids gage) at RM 175.5. The latter gage is downstream of the confluence 

of the Snake and Salmon rivers. 

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Under Proposed Operations, Idaho Power would continue to operate the project for navigation 

purposes by maintaining 13,000 cfs in the Snake River at Lime Point118 (RM 172, 2.5 miles downstream 

of the China Gardens Rapids gage) at least 95 percent of the time. Flows of less than 13,000 cfs would 

occur during July, August, and September, and Idaho Power would not use reservoir storage to meet the 

13,000-cfs requirement. 

To meet safe navigational flow targets during the new license term, the Corps recommends that 

Idaho Power operate the project to maintain a year-round instantaneous minimum flow of 8,500 cfs as 

measured at the Hells Canyon dam gage and 11,500 cfs as measured at the Snake River below McDuff 

Rapids (China Gardens Rapids) gage. If daily inflows to Brownlee reservoir fell below 8,500 cfs; 

however, the Corps suggests that Idaho Power would not have to meet these minimum flows. Instead, the 

Corps recommends that Idaho Power be required to release from Hells Canyon dam a flow equal to the 

previous 3-day moving average Brownlee reservoir inflow. NPPVA, representing power vessel owners 

that provide recreational trips on the river, concurs with the Corps’ recommendation. The Forest Service 

(FS-29) provides a similar recommendation for a year-round minimum flow downstream of Hells Canyon 

dam of 8,500 cfs or project inflow (whichever is less). 

The Umatilla and Nez Perce Tribes recommend that Idaho Power maintain a minimum flow of 

6,500 cfs immediately downstream of Hells Canyon dam and 13,000 cfs at Lime Point. These tribes state 

that higher minimum flows would use limited water resources and jeopardize fish flows during low water 

years. The tribes’ recommended flow levels are consistent with the current, and Idaho Power’s proposed, 

Hells Canyon dam release regime. 

In section 3.10.1.6, Boating Use Downstream of the Project, we point out that minimum safe 

boating flows vary by type of boat. For float boaters, the key rapids (Granite Creek and Wild Sheep 

rapids) are navigable at 5,000 cfs. Experienced operators can take 24-foot power boats through these 

rapids at flows much lower than 8,500 cfs. It is the larger (40-foot) power boats, fully loaded, that require 

flows in the 8,500-cfs range. In its comments on the draft EIS, NPPVA makes this same point, stating 

that 7,500 cfs does not provide an adequate margin of safety for fully loaded larger boats, but that 8,500 

cfs is adequate for all boating. 

With Idaho Power’s proposed operations, modeled flows downstream of Hells Canyon dam 

routinely fall below the 8,500-cfs boating target from early June through late September under extremely 

low and medium-low water conditions and from late July through early September under medium water 

conditions. Flows seldom or never fall below the 8,500-cfs target under medium-high or extremely high 

water conditions (section 3.3.2.7, Downstream Flows Important to Navigation). 

With the Staff Alternative, which includes 237 kaf of flow augmentation for salmon, Brownlee 

reservoir storage water would be released downstream starting in mid-June. Supplemental CHEOPS 

model data filed by Idaho Power in its comments on the draft EIS indicate that flow augmentation at the 

237-kaf level would have little effect on navigation flows. For the June 1 through September 30 122-day 

period, Idaho Power’s model simulations show that, even with the 237-kaf flow augmentation, there 

would still be 40 days with flows below 8,500 cfs in medium water years, 120 days in medium-low water 

years, and 116 days in extremely low water years. 

 

118 Idaho Power does not explicitly propose 13,000 cfs at Lime Point, but this value is consistent with the 

flow releases from Hells Canyon dam assumed by Idaho Power for modeling purposes. In the 

absence of an explicit alternative proposal, we consider it part of Idaho Power’s proposed operation. 

Idaho Power proposes that any navigation flow requirement for the Snake River reach from the 

Salmon River confluence to Lewiston be measured at McDuff Rapids (RM 175.5), 4 miles upstream 

of Lime Point. 

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In contrast, adding the Corps’ navigation minimum flow recommendation (described above) to 

the flow augmentation scenario included in the Staff Alternative would reduce the frequency of 

occurrences when flows downstream of Hells Canyon dam fall below the 8,500-cfs boating target, 

thereby increasing the margin of safety at critical rapids and providing increased predictability for boat 

operators. Based on Idaho Power data, the incremental effect of adding the Corps’ minimum flow 

recommendation to the Staff Alternative would result in zero days below 8,500 cfs under medium water 

conditions, 32 days under medium-low water conditions, and 100 days under extremely low water 

conditions. 

These improved frequencies of meeting desirable boating flow levels would come with 

substantial costs, however. We estimate the cost of adding the Corps’ recommended minimum flow 

requirement to the Staff Alternative, in terms of foregone power benefits, at $12.5 million annually. Of 

this loss in power benefits, $11.4 million is accounted for by the reduction in peaking capacity and the 

need to replace it. Losing this peaking capability would likely result in Idaho Power’s having to construct 

replacement capacity using either simple cycle or combined cycle combustion turbines. 

Currently, by reducing releases overnight at the Hells Canyon development during non-peak 

periods, Idaho Power is able to increase releases, and hence generation, during critical daytime hours. 

Due to the travel time of the peaking releases, however, the higher flow periods do not coincide with 

boating needs at downstream locations. Higher minimum flows provided for boating would constrain the 

ability of the Hells Canyon development to peak in response to high summertime power demands. 

Augmenting flows by 2,000 cfs (that is, going from a 6,500-cfs minimum flow to 8,500 cfs) in a mediumlow water year, for example, would limit peaking capability for most of the period from June through 

September. July is the critical period for dependable capacity in Idaho Power’s system, although similar 

needs can also exist in August and September, and the medium-low water year is the type of year (70th

percentile water condition) used in Idaho Power’s integrated resource planning to define dependable 

capacity requirements. Thus, application of Idaho Power’s standard integrated resource planning strategy 

would require the replacement of any dependable capacity lost due to a higher minimum flow 

requirement. 

During the past 20 years, project operations have included a minimum release (when inflows 

allowed) of 6,500 cfs, augmented in some years by a program of pulses, or timed releases, as described in 

section 3.3.1.3, Navigation. Over that time, boating accidents have occurred at multiple locations for 

many reasons, including low flows, high flows, operator inexperience, inappropriate watercraft size and 

weight for the flow levels, and, possibly, weather or other environmental conditions. Despite these 

potential risks, a very robust private and commercial outfitting industry has evolved, with advanced boat 

designs that allow for larger and heavier watercraft. We recognize that flow levels are just one aspect of 

overall boater safety, and acknowledge that without higher flows some boating companies may choose 

not to operate during low flows or may choose to adjust operations through use of smaller boats or 

reduced passenger loads. We conclude that improving boating conditions by imposing the Corps’ 

minimum flow recommendation is not worth the substantial reduction in power benefits. Accordingly, 

we do not include the Corps’ navigation flow recommendation in the Staff Alternative. However, to 

ensure that the Corps’ recommended navigation flow is provided in a way that would not reduce the 

project’s dependable capacity, we include in the Staff Alternative a recommendation that the minimum 

flow be set at 8,500 cfs from the start of Memorial Day weekend to September 30 in medium-high and 

extremely high water years. We also recommend that, if the 3-day moving average inflow to Brownlee 

reservoir is less than 8,500 cfs, the instantaneous minimum release required from Hells Canyon dam for 

the current day would be equal to the previous 3-day moving average. 

Additionally, we recommend that Idaho Power consult with the Corps, NPPVA, the Forest 

Service, and other interested parties to prepare a navigation plan that addresses non-flow measures that 

could be implemented to improve boating safety downstream of Hells Canyon dam. This navigation plan 

would be a component of Idaho Power’s proposed Recreation Plan. In a letter to the Corps dated June 26, 

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2007, and filed with the Commission on July 3, 2007, Idaho Power outlined a number of non-flow 

measures that it is currently investigating and that we recommend be included in the navigation plan. 

They include: (1) signage/navigation aids/channel markings to help boaters identify the best course 

through difficult stretches of the river; (2) training opportunities where boaters could learn the best route 

through specific river reaches; and (3) the potential for rock movement and other in-river channel 

modifications. 

We also recommend that the plan include several measures that Idaho Power is pursuing with 

respect to improved flow information, including: (1) emphasizing the importance of the Hells Canyon 

discharge information that is posted on flow monitors located at 6 sites (Hells Gate Marina in Lewiston, 

Idaho; the Forest Service office in Clarkston, Washington; Heller Bar in Washington; the Cache Creek 

HCNRA portal in Oregon; Pittsburg Landing in Idaho; and the Hells Canyon Launch site in Oregon); (2) 

ensuring the accuracy of information posted on Idaho Power’s web site and 1-800 phone number; (3) 

providing timely and accurate press releases; (4) providing a common data source for the flow monitors, 

website, and 1-800 number to ensure that accurate and timely information is provided via all three media 

and that the information is consistent among the three media; (5) continuing to evaluate the feasibility of 

developing a text messaging system that would send the current Hells Canyon discharge each hour to a 

list of subscribers with satellite phones that could be reached on the river; (6) evaluating the feasibility of 

installing additional stream flow gaging facilities on the river or important tributaries so that boaters 

would have access to additional real time information regarding measured flows, in addition to the 

information already provided on dam releases; and (7) developing a forecasting method for determining 

when monthly flow conditions in May, June, July, August, and September are likely to be in the mediumhigh range or greater. 

We recommend that under the plan and in consultation with the other parties, Idaho Power 

evaluate the pulsing flow program that it has followed in the recent past. The program should have a 

sound basis in the underlying hydraulics/hydrology of the river with respect to the lag time between flow 

releases at Hells Canyon dam and flow response at key points along the river. Because Idaho Power has 

the necessary models and has done a significant amount of hydraulic modeling on the river already, 

primarily to address aquatic resource issues, it should be able to adapt the models to evaluate the 

attenuation effects of different navigation flow scenarios. Hydraulic or hydrologic factors to be 

considered in developing a flow regime and navigation flow plan should account for: (1) the travel time 

of flow from Hells Canyon dam to points downstream as far as just above the Salmon River confluence 

with the Snake River; (2) the attenuation effect on flow between Hells Canyon dam and points 

downstream as far as just above the Salmon River confluence with the Snake River; and (3) tributary 

inflow downstream of Hells Canyon dam; and (4) should include maintaining accurate stream gage rating 

curves of the relationship between flow and stage. 

Because we conclude that development of a navigation plan that includes these elements is 

essential to providing a safe boating environment on the Snake River downstream of Hells Canyon dam, 

we consider the preparation and implementation of a navigation plan to be worth the estimated cost of 

$36,300, including the installation and maintenance of two additional stream gages. 

5.2.2.3 Flow Augmentation for Anadromous Fish Juvenile Migration 

Juvenile fall Chinook salmon historically migrated from the Snake River in May and June, but 

impoundment of the river and blocked access to historical habitats has led to delayed migration in late 

June, July, and early August. Current spawning locations are generally cooler compared to the historical 

production area because they are farther removed from the Thousand Springs reach near Upper Salmon 

Falls, where spring-inflows provided a warmer incubation and early rearing environment. Loss of access 

to these spring-influenced production areas resulted in reduced growth potential and delayed emigration 

of juvenile fall Chinook salmon; this is associated with reduced survival. These adverse effects have been 

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compounded by the construction of additional dams on the lower Snake and Columbia rivers, which 

contributed to increased water temperatures, increased predation, and slower migration. 

From 1989 to 2000, as part of a comprehensive Snake River flow augmentation effort, Idaho 

Power released an average of 224 kaf from Brownlee reservoir to enhance migration of juvenile fall 

Chinook salmon. Flows from 1996 through 2000 were made as part of an energy exchange agreement 

between Idaho Power and BPA. That agreement expired in April 2001 and was not renewed by BPA. 

For the period 2002 through 2004, at the request of the Idaho Governor, Idaho Power cooperated with a 

rental program initiated by BOR to assist BOR in meeting its commitment to provide 427 kaf of water for 

flow augmentation purposes. Idaho Power leased the natural flow water rights that were acquired by 

BOR from the state water bank for power purposes to ensure that BOR rentals complied with state law 

and passed that water through the project. BOR and BPA were responsible for these costs. Additional 

augmentation flows were resumed in 2005 as part of an interim agreement to protect federally listed fall 

Chinook salmon (see figure 70). 

In its license application, Idaho Power does not propose any measures to enhance migration 

conditions for juvenile fall Chinook salmon, but several resource agencies, tribes, and other interested 

parties recommend flow augmentation, or flow shaping, as a method to enhance migration by increasing 

flow through the lower Snake and Columbia River projects (NMFS-8, 9, and 18; CTUIR-6, 7, 8, and 9; 

NPT-2, 5, 6, and 7; AR/IRU-22; ODFW-32; and Interior-22). Most notably, NMFS recommended 

release of 237 kaf of flow augmentation water from Brownlee reservoir during the summer subyearling 

fall Chinook outmigration season, and the Nez Perce Tribe recommends that Brownlee reservoir be 

managed to maximize flow augmentation during the spring and summer smolt migration seasons, 

including the use of real-time adjustments to account for changes in runoff forecasts. 

Increasing flows during the fall Chinook subyearling smolt outmigration may increase migration 

speed and improve survival (refer to our analysis in section 3.6.2.1, Effects of Project Operations on 

Aquatic Resources). In section 3.6.2.1, we identified no fewer than four studies indicating that summer 

flow augmentation downstream of the project would benefit outmigrating fall Chinook salmon by 

increasing flow volume and reducing travel time. Further, a review of trends in adult fall Chinook returns 

indicates that there is a generally positive relationship between flow and survival for outmigrating fall 

Chinook salmon. Our analysis in section 3.6.2.1 indicates that there has been a substantial increase in 

adult fall Chinook returns past Lower Granite dam that tracks closely with both the total flow 

augmentation provided from the Snake River basin and the volume of flow augmentation provided from 

Brownlee reservoir during the year of outmigration (see figure 77). We note that many other factors 

influence the number of adult salmon that return to the Snake River, especially a substantial increase in 

the number of hatchery fall Chinook salmon that have been released from acclimation sites in the Salmon 

and Snake rivers upstream from Lower Granite dam. 

In its April 11, 2006, reply comments on recommended terms and conditions, Idaho Power cites 

recent testimony from NMFS and other scientists indicating that there is considerable disagreement on the 

benefits of flow augmentation for Snake River fall Chinook salmon. Part of this uncertainty relates to a 

recent analysis of the scales taken from adult fall Chinook in 2004, which indicates that a small 

proportion of the fall Chinook juveniles that overwinter in the river/reservoir environment before 

completing their migration may contribute more than half of the adult returns. The effects of summer 

flow augmentation on this portion of the population are poorly understood because these yearling fish 

typically migrate in the following spring, before flow augmentation water is released from Brownlee 

reservoir. 

In 2003, the Independent Scientific Advisory Board (ISAB) completed a review of flow 

augmentation at the request of the Northwest Power Planning Council. ISAB (2003) concluded “that 

there is a range of flow over which survival of PIT-tagged smolts increase with increasing flow and a 

range of higher flows in which fish survival appears to be independent of incremental changes in flow.” 

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ISAB further concluded that several parameters that may affect survival are correlated with flow, and that 

deliberately designed experiments may be needed to determine the effects of these variables. Variables 

identified by the ISAB include water temperature, water clarity, fluctuations in dam discharges, gas 

supersaturation, the timing of entry to the estuary and the ocean, and ocean conditions. In section 3.6.2.1, 

Effects of Project Operations on Aquatic Resources, we discuss how the weak relationship between flow 

and survival at higher flows (for both the spring and summer smolt outmigrations) described by the ISAB 

suggests that increasing the amount of flow augmentation water released in moderate and high water 

years, as recommended under measures recommended by the Nez Perce Tribe (NPT-7), may provide little 

survival benefit. We note, however, that the recent advent of 24-hour summer spills at the downstream 

federal Columbia River mainstem and Lower Snake River projects may alter the flow/survival 

relationships at higher flows, and that this relationship may warrant re-evaluation of the benefits of 

increased augmentation in medium and high flow years. 

Based on the available information in the record, we conclude that continuation of the Snake 

River flow augmentation from Brownlee reservoir would continue to enhance migration of juvenile fall 

Chinook. We acknowledge, however, that there remains much to learn about the effects of flow 

augmentation on juvenile fall Chinook salmon migration and that there are other factors that contribute to 

the observed increase in adult returns, including increased supplementation with hatchery fish, favorable 

flows provided by Idaho Power during the fall Chinook spawning and incubation season, and favorable 

ocean conditions. In the draft EIS, we concluded that the benefits of releasing water from Brownlee 

reservoir as part of the summer flow augmentation program should be re-evaluated in 2009, after data 

from adult returns through 2008 are available. Comments received on the draft EIS reflected a consensus 

that it is unlikely that there would be sufficient information to allow the benefits of flow augmentation to 

be reevaluated in 2009, and that the evaluation that we proposed would be impeded by the wide range of 

factors that can affect adult returns. In addition, NMFS expressed concern that the measure introduced 

uncertainty about whether the measure would be continued beyond 2008, which it indicated would 

impede consultation on effects to federally listed ESUs of salmon and steelhead. 

Although we understand the concerns expressed in these comments, we also conclude that it is 

likely that additional information will become available over the next license term that will improve our 

understanding of the effects of flow augmentation, and of how water contributed from Brownlee reservoir 

can be managed to maximize benefits to outmigrating juvenile salmon and steelhead. Therefore, we 

include in the Staff Alternative a measure that would require Idaho Power to prepare a flow augmentation 

evaluation report 6 years after license issuance, in consultation with the fisheries management agencies 

and treaty tribes, that evaluates available information on the benefits of providing flow augmentation 

water from Brownlee reservoir and whether any changes in the timing or amount of water delivered from 

Brownlee reservoir is warranted. The report should also: (1) consider and evaluate the effects of flow 

augmentation water contributed from the Snake River basin upstream from Brownlee dam and from 

Dworshak reservoir; and (2) include any recommendations, for Commission approval, for continuing flow 

augmentation releases. We conclude that in the interim, Idaho Power should continue to release 237 kaf 

from Brownlee reservoir as it did voluntarily in 2005 and 2006. Continuation of this release would be 

consistent with the average volume that has been released from Brownlee reservoir between 1989 and 

2000, during which time the number of adult fall Chinook returning past lower Granite dam substantially 

improved. We conclude that continuation of the 237-kaf flow augmentation release is warranted to avoid 

adverse effects on this federally listed ESU. To address the concern expressed by NMFS regarding 

introducing uncertainty into the section 7 consultation, prior to implementing any changes in Idaho 

Power’s participation in the flow augmentation program, we would consult with NMFS regarding the 

need to re-initiate formal consultation on potential effects on listed ESUs of salmon and steelhead. 

We estimate the annualized cost of the continued release of 237 kaf of flow augmentation water 

from Brownlee reservoir, in terms of foregone power benefits, would be about $9.0 million, and the 

annualized cost of preparing the flow augmentation evaluation report would be $1,800. We consider 

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these to be incremental costs, not part of the economic baseline because Idaho Power was reimbursed by 

BPA for its participation in the program from 1995 through 2001, and its participation in 2005 and 2006 

was voluntary. In addition to the developmental cost, flow augmentation would result in an earlier and 

more rapid drafting of Brownlee reservoir than under Idaho Power’s proposed operation. In the medium 

water year, for example, the 2,050-foot-msl reservoir elevation (27 feet below full pool) would be reached 

by the end of July under flow augmentation, in contrast to reaching the same point in mid-October under 

Proposed Operations (section 3.3.2.4, Brownlee Reservoir Levels). This earlier drawdown would 

adversely affect the aesthetic appearance of Brownlee reservoir during peak-use summer months (section 

3.11.2.1, Effects of Project Operations on Aesthetic Resources) and adversely affect flat-water boating, 

reservoir access, and crappie fishing opportunities (section 3.10.2.1, Effects of Project Operations on 

Recreation Resources). Despite the cost and these anticipated adverse effects, we include flow 

augmentation as an operational provision of the Staff Alternative. We do so because flow augmentation 

is an inextricable part, along with spawning/incubation flow management and supplementation, of an 

overall management program that has recently shown a substantial increase in adult returns of fall 

Chinook salmon, a federally listed threatened species (ESU). 

Interior-26 recommends that Idaho Power maximize use of recreation access sites by holding 

Brownlee reservoir at or near full elevation through June 20. Interior also recommends that the flow 

augmentation draft from Brownlee stop during the Fourth of July holiday or begin after the holiday. 

Similarly, the Forest Service (FS-19) specifies that Idaho Power manage the Hells Canyon reservoir level 

to minimize impacts on recreation during the summer. The Staff Alternative flow augmentation measure 

accommodates both Interior recommendations. With regard to the Forest Service, we concluded in the 

draft EIS that establishing Brownlee summer reservoir levels to support levels in Hells Canyon reservoir 

on the basis of recreation potential alone would conflict with aquatic resource protection measures that we 

have included in the Staff Alternative. However, in its comments on the draft EIS, the Forest Service 

clarified that the primary purpose of measure FS-19 would be to extend boat ramps on Hells Canyon 

reservoir if proposed operations interfere with a reasonable level of boat access. We now agree with the 

Forest Service on the need for this measure, as clarified, and recommend it as part of the Staff 

Alternative. 

Finally, as part of our analysis, we also assessed the effects of a 350 kaf flow augmentation 

release from Brownlee reservoir. This scenario is roughly equivalent to recommendations AR/IRU-22 

and ODFW-32, which would require 100 kaf of flow shaping119 in addition to 237 kaf of flow 

augmentation water to be released from Brownlee reservoir. 

Modeling conducted by Idaho Power shows that 350 kaf of storage from Brownlee reservoir 

during the summer would increase water temperatures directly downstream of Hells Canyon dam, 

especially in low water years. This effect may be balanced by reduced warming as the larger flow 

volume moved downstream through the reach between Hells Canyon dam and lower Granite reservoir, 

and could be compensated for by the release of cool water from Dworshak dam. However, as we note in 

section 3.6.2.1, Effects of Project Operations on Aquatic Resources, a recent study funded by BPA (Cook 

et al., 2006) indicates that releasing too large a volume of water from Brownlee reservoir may reduce 

stratification in Lower Granite reservoir, which would increase water temperatures in the hypolimnion 

and affect the temperature of outflows from Lower Granite reservoir. Because of this potential adverse 

effect on rearing and migration conditions within and downstream of Lower Granite reservoir, and its 

slightly higher annualized cost ($9.7 million for a 350-kaf release versus $9.0 million for the 237-kaf 

release), we do not include the 350-kaf release in the Staff Alternative. However, we note that our 

 

119 Flow shaping involves the pre-release of BOR augmentation water that cannot be delivered to 

Brownlee reservoir and then refilling Brownlee Reservoir with an equivalent amount of BOR water 

when that water reaches Brownlee reservoir. 

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recommended flow augmentation evaluation report would allow the amount and timing of flow 

augmentation releases from Brownlee reservoir to be re-evaluated 6 years after license issuance. 

5.2.2.4 Water Rights 

Lower Valley Electric recommends that Idaho Power compensate the state of Wyoming and the 

Wyoming public in the upper Snake River watershed in Wyoming, as represented by Lower Valley 

Electric, for the use of Wyoming’s unused allocation under the Snake River Compact. However, the 

Wyoming State Engineer’s Office is responsible for administering water resources in the state of 

Wyoming and would normally be the party expected to deal with water right issues between Wyoming 

and neighboring states. This agency has not made any comments on water rights in this proceeding. We 

note that there is extensive water storage and diversion between the Wyoming state line and the Hells 

Canyon Project. The Snake River basin is substantially allocated; therefore, it seems unlikely that surplus 

water would be available as far downstream as the Hells Canyon Project. In any event, this issue is 

outside the scope of the Commission’s jurisdiction, and the relicensing, and we do not address it further. 

5.2.3 Water Quality 

5.2.3.1 Dissolved Oxygen Measures 

Currently, low dissolved oxygen levels regularly occur in the transition zone and much of the 

lacustrine zone of Brownlee reservoir during late spring and summer, and downstream of Hells Canyon 

dam in spring through fall. These dissolved oxygen conditions are primarily a result of the high nutrient 

(phosphorus) loads to the project and the reduction in assimilative capacity caused by converting the 

riverine system into a reservoir system. 

Low dissolved oxygen levels greatly reduce habitat suitability for both cold and warmwater 

species in the project reservoirs during the summer months, and dissolved oxygen levels in the first 6 to 

7 river miles downstream of Hells Canyon dam are below optimal during the first month of the fall 

Chinook spawning season. Increasing dissolved oxygen levels in project reservoirs and downstream of 

Hells Canyon dam could greatly increase the usable fish habitat in the project reservoirs, reduce the 

incidence of fish kills, and improve conditions for fall Chinook spawning downstream of Hells Canyon 

dam. 

In its license application, Idaho Power proposed to install an oxygen diffuser system in the 

transition zone of Brownlee reservoir to meet its TMDL obligation for Brownlee reservoir, which was 

estimated at 1,450 tons per year at that time but was revised to 1,125 tons oxygen per year in the final 

TMDL. Because of the significant annual variability in Brownlee water quality conditions, Idaho Power 

proposed to maximize benefits of the aeration system by varying injection rates and periods depending on 

conditions. Idaho Power also proposed to install and operate turbine venting systems in Brownlee units 1 

through 4 and to evaluate the feasibility of implementing turbine-venting technology at Brownlee unit 5, 

but later withdrew this proposal. 

The agencies, tribes, and NGOs made numerous recommendations to increase dissolved oxygen 

levels in the project reservoirs and in the Snake River downstream of Hells Canyon dam. Interior-61 

recommends that Idaho Power install and operate a turbine-venting system on Brownlee units 1 through 

4, and potentially on Brownlee unit 5 and on the units at Hells Canyon dam. NMFS-12 recommends that 

Idaho Power evaluate and design the most effective means of increasing late summer and fall dissolved 

oxygen levels in outflows of the Hells Canyon Project to exceed 6 mg/L to the extent that current 

technologies allow. The Umatilla Tribes (CTUIR-21) and Nez Perce Tribe (NPT-16) recommend that 

Idaho Power construct structures on Hells Canyon dam to add dissolved oxygen to the Snake River 

downstream of the project, and inject oxygen in Brownlee reservoir to meet the 6.5-mg/L dissolved 

oxygen target designated in the Snake River-Hells Canyon TMDL. AR/IRU-17 recommend an adaptive 

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management approach using real-time monitoring results to trigger aeration/oxygenation of reservoir 

outflows. ODFW-55 recommends that Idaho Power consult with ODEQ to develop and implement a plan 

to ensure that the project does not contribute to violation of Oregon’s dissolved oxygen standard within or 

downstream of the project. In addition, ODFW-58 recommends that Idaho Power consult with ODEQ 

and ODFW to develop appropriate water quality monitoring, including dissolved oxygen, and that the 

monitoring measures be approved by ODEQ. Interior also recommends that Idaho Power be required to 

meet water quality standards in Oxbow and Hells Canyon reservoirs (Interior-42), and monitor water 

quality twice per month at six locations downstream of Hells Canyon dam (Interior-67). AR/IRU-16 

recommend that the Commission require Idaho Power to locate, fund, construct, and oversee operations 

of projects to reduce nutrient and suspended particle delivery from on-land sources to the Snake River and 

its tributaries above and within the project, in lieu of Idaho Power’s dissolved oxygen supplementation 

proposal for Brownlee reservoir. 

In the draft EIS, we concluded that Idaho Power is responsible for addressing the project’s 

contribution to degraded water quality, although there was considerable uncertainty about the cost 

effectiveness of both reservoir dissolved oxygen supplementation and potential turbine aeration measures. 

Therefore, we recommended that Idaho Power develop a dissolved oxygen supplementation plan in 

consultation with IDEQ, ODEQ, tribes, and federal and state agencies responsible for managing fish and 

wildlife to reduce the uncertainty associated with potential measures to increase dissolved oxygen levels 

prior to implementing any of them. Our concept was that during development of this plan, the project’s 

dissolved oxygen load allocation beyond that set in the TMDL would be determined and practical 

measures for meeting all of the project’s load allocations would be selected. These measures would be 

implemented following approval by the Commission and a monitoring program would be implemented to 

aid in selecting appropriate times for reservoir oxygen supplementation, if appropriate, and to document 

the effectiveness of measures aimed at improving dissolved oxygen in the lower river. 

As part of the water quality certification process, Idaho Power focused considerable effort on 

reducing uncertainty associated with its proposed measures to address low dissolved oxygen levels and 

increasing the environmental benefits of meeting its TMDL dissolved oxygen allocation, as well as 

adding a measure to address low dissolved oxygen levels in the Oxbow bypassed reach. Based on the 

reduced uncertainty associated with the measures now being proposed by Idaho Power and the potential 

for greater environmental benefits, we have revised our draft EIS recommendation as described below. 

In its April 26, 2007, filing with the Commission and its January 31, 2007, application for water 

quality certification (Idaho Power, 2007a), Idaho Power now proposes measures that supersede the 

measures proposed in the license application. This includes a proposal to meet its TMDL dissolved 

oxygen load allocation in Brownlee reservoir either by installing an oxygen diffuser system in Brownlee 

reservoir as it proposed in its license application, or through upstream phosphorus trading.120 Because 

phosphorus trading offers the potential for enhanced resource benefits over an oxygen diffuser system, 

Idaho Power proposes to devote a limited period of time (i.e., up to 1 year after license issuance) to 

identifying appropriate trading partner(s) first and, if that fails, to proceed with design and installation of 

the reservoir diffuser system. In its application for water quality certification, Idaho Power also proposes 

to aerate Hells Canyon outflows using a forced air (blower) system at the Hells Canyon powerhouse to 

add 1,500 tons per year of dissolved oxygen downstream during summer and fall, or to install a similar 

 

120 Phosphorus trading refers to Idaho Power developing/implementing a legal agreement in lieu of 

supplementing oxygen in Brownlee reservoir to meet its TMDL dissolved oxygen allocation. This 

agreement would be made with a party located upstream of Brownlee reservoir that has accumulated 

phosphorus credits by providing benefits beyond what is required under that party’s phosphorus load 

allocation (refer to section 3.5.2.2, Dissolved Oxygen, Upstream Watershed Phosphorus Trading, for 

further details). 

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system or aerating runners at Brownlee dam if it can provide reasonable assurance that the dissolved 

oxygen targets downstream from Hells Canyon dam would be met. Idaho Power’s preliminary 

evaluations indicate that measures at Brownlee dam may be feasible to meet the proposed 1,500 tons per 

year below Hells Canyon dam. In its application for water quality certification, Idaho Power also 

proposes to install and operate a destratification system in the Oxbow bypassed reach at the deep pool just 

upstream of the Indian Creek confluence to prevent anoxic conditions that were found to occur in the 

deeper portions of the pool. 

Our analysis indicates that the approach proposed by Idaho Power in its January 31, 2007 

application for water quality certification has the potential to provide substantive benefits to water quality 

conditions within and downstream of the project. Phosphorus inputs to Brownlee reservoir could be 

reduced by Idaho Power’s implementation of phosphorus trading, if an appropriate trading partner can be 

found. To accomplish this, another party would need to reduce its point and/or nonpoint loadings beyond 

its allocated level so that it could accumulate pollutant trading credits, which it could “trade” with Idaho 

Power to meet the TMDL allocation set for Brownlee reservoir. This reduction in phosphorus loads could 

provide environmental benefits that extend to all three project reservoirs and to the Oxbow bypassed 

reach. Our analysis indicates that an oxygen diffuser system in Brownlee reservoir would provide only 

localized benefits. If aeration measures at Brownlee dam can meet Idaho Power’s responsibility for 

improving dissolved oxygen levels downstream of Hells Canyon dam without violating the 110-percent 

of saturation total dissolved gas criterion, this approach would provide additional benefits in the Oxbow 

reservoir and bypassed reach, as well as in Hells Canyon reservoir. Implementation of phosphorus 

trading and aeration measures at Brownlee dam would also be consistent with recommendations by the 

agencies and tribes to improve water quality conditions both within and downstream of the project. Our 

analysis indicates that destratifying the deep pool in the Oxbow bypassed reach would reduce anoxic 

conditions that currently occur in the pool, and has the potential to benefit aquatic resources that use the 

bypassed reach, including bull trout and redband trout. 

Although we recognize that a phosphorus trading arrangement would address project effects on 

nutrients and dissolved oxygen only indirectly, this measure has the potential to provide a greater overall 

benefit than the reservoir oxygen diffuser system proposed in the application. Therefore, we conclude 

that this approach warrants further evaluation before an approach for meeting TMDL targets and 

applicable dissolved oxygen standards within Brownlee reservoir and downstream of Hells Canyon dam 

is selected. Such an approach would be in keeping with the adaptive approach reflected in many of the 

agency and tribal recommendations. Accordingly, we recommend that Idaho Power develop a dissolved 

oxygen enhancement plan, including appropriate provisions for monitoring, in consultation with IDEQ, 

ODEQ, NMFS, Interior, IDFG, ODFW, and interested tribes. The plan should document the process of 

identifying appropriate upstream phosphorus trading partner(s), document whether reservoir 

supplementation is cost effective, and provide a mechanism to evaluate the effectiveness and feasibility of 

alternative or additional measures. Such alternative measures should, at a minimum, include reducing 

nutrient and organic matter loadings from tributaries, injecting atmospheric air or oxygen into forebay 

waters or turbines, and installing/using aerating runners to increase dissolved oxygen in Brownlee turbine 

flows. We recommend that the plan be filed for approval with the Commission within 1 year of license 

issuance. 

During development of this dissolved oxygen enhancement plan, Idaho Power would consult with 

IDEQ and ODEQ on the estimate of project effects that contribute to low dissolved oxygen levels in the 

Snake River downstream of Hells Canyon dam. Once the appropriate dissolved oxygen load allocation 

for the project has been determined, Idaho Power would evaluate the feasibility of implementing its 

proposed turbine aeration measures and assess the potential for the measures to cause total dissolved gas 

to exceed the 110-percent of saturation criterion. This evaluation would be conducted for installing 

forced-air systems at Hells Canyon and Brownlee, aerating runners at Brownlee, and implementing other 

measures if necessary. The dissolved oxygen enhancement plan would include a monitoring provision to: 

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(1) evaluate the quality of inflows to the project; (2) confirm that Idaho Power is meeting its obligations 

for aeration and phosphorus trading if appropriate; (3) evaluate the effectiveness of the measures 

implemented; and (4) evaluate any adverse effects of the aeration on total dissolved gas downstream of 

Brownlee, Oxbow or Hells Canyon dams. As a provision of the dissolved oxygen enhancement plan, we 

recommend that Idaho Power annually develop and file a draft monitoring and implementation report, 

which would include monitoring results and describe actions taken in the past year along with actions 

proposed for the coming year. The report would also be provided to the agencies for comment. 

We estimate the annualized cost of developing the dissolved oxygen enhancement plan through 

the evaluation phase at $2,200. Because of its potential substantive benefits to aquatic resources, we 

include it as part of the Staff Alternative. The cost of implementing the measures identified in the plan 

and approved by the Commission would be determined as part of the plan. We estimate that the 

annualized cost of potential mechanical measures to address the low dissolved oxygen levels in the three 

project reservoirs and the river downstream of Hells Canyon dam likely would total $648,500. This is 

based on our estimated annualized costs of $447,800 for a Brownlee reservoir oxygen diffuser system, 

$184,700 for a forced air system at the Hells Canyon powerhouse, and $16,000 for a destratification 

system at the deep pool just upstream of the Indian Creek confluence. Although we do not directly 

include in the Staff Alternative Interior-61, the recommendation that Idaho Power install and operate a 

turbine-venting system at Brownlee units 1, 2, 3, 4, and possibly Brownlee unit 5 and the three Hells 

Canyon units, our recommended dissolved oxygen enhancement plan may determine that all or part of 

this recommendation would provide a reasonable approach for Idaho Power to meet its obligation to 

improve water quality. Therefore, Interior-61, for which we estimate an annualized cost of $17,000, 

could eventually be implemented under the Staff Alternative. 

We do not fully include in the Staff Alternative Interior-67, the recommendation that Idaho 

Power monitor water quality at six or more sites downstream of Hells Canyon dam twice per month, and 

more frequently during low dissolved oxygen periods and when dissolved oxygen enhancement is being 

done. In the draft EIS, we concluded that monitoring at the level of intensity recommended by Interior, at 

an estimated annualized cost of $200,000, would not be warranted because it would provide little 

additional information compared to routine monitoring at a single site downstream of Hells Canyon dam. 

During the 10(j) meeting, Interior indicated that its intent was to collect sufficient data to determine the 

downstream extent of water quality effects, but that the frequency, timing and location of measurement 

sites could be developed in consultation with Idaho Power. We recommend that these aspects of 

monitoring be developed during consultation on the dissolved oxygen enhancement plan. 

We do not include in the Staff Alternative Interior-42, the recommendation that Idaho Power be 

required to satisfy existing water quality standards in Oxbow and Hells Canyon reservoirs. As discussed 

above, Idaho Power is not solely responsible for dissolved oxygen deficits that occur within and 

downstream of the project, so it is not appropriate to hold Idaho Power responsible for addressing impacts 

that are beyond its responsibility as determined through the TMDL process and in its water quality 

certificate. Idaho Power’s plan to evaluate phosphorus trading, as described above, would be limited to 

addressing Idaho Power’s nutrient responsibility under the TMDL. 

We do not include in the Staff Alternative the Interior and the Forest Service recommendations 

(Interior-66 and FS-30) to study the effect of dissolved oxygen additions below Hells Canyon dam on bull 

trout, invertebrates, macrophytes, and algae. We conclude that Idaho Power has conducted sufficient 

studies to evaluate the benefits of increasing dissolved oxygen levels downstream of the project. We 

cannot estimate the full costs of Interior’s recommended measures because Interior has not described the 

scope of the measures to increase dissolved oxygen levels. 

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5.2.3.2 Water Temperature Measures 

Brownlee reservoir, which has an average hydraulic retention time of about one month, 

substantially alters Snake River temperatures. Storage of water in the reservoir and the depth of the 

powerhouse intake result in cooler downstream water temperatures in spring and summer and warmer 

temperatures in the fall than would be the case in the absence of the project. This seasonal shift in water 

temperature may adversely affect fall Chinook salmon by causing water temperatures to be above optimal 

while adults are holding prior to and during the spawning period, and by causing juvenile fish to emerge 

into a cooler environment with reduced growth potential (see section 3.6.2.4, Water Temperature). High 

water temperatures immediately before and during the spawning season are of particular concern because 

they may lead to higher levels of pre-spawning mortality and reduced egg viability. However, later in the 

spring and early summer, juvenile fall Chinook salmon and other aquatic resources actually may benefit 

from delayed warming, which delays the onset of stressfully high water temperatures. 

Idaho Power’s proposed operations would be the same as the current operations, resulting in 

thermal regimes similar to current regimes within and downstream of the project. In its license 

application, Idaho Power did not propose any measures to modify the existing temperature regime. 

However, in its April 26, 2007, filing with the Commission and its application for water quality 

certification (Idaho Power, 2007a), Idaho Power proposed to implement a Temperature Adaptive 

Management Plan (through the implementation of appropriate measures) to meet the project’s 

temperature responsibility under the TMDL. Under this plan, Idaho Power would: (1) define the extent 

and nature of the project’s temperature responsibility; (2) evaluate potential measures; and (3) identify 

any appropriate measure(s) for implementation. The potential measures identified by Idaho Power 

include a bubble upwelling system that would be designed to lift cool water from the depths of Brownlee 

reservoir to be entrained into the project intake and implementing watershed measures to reduce the 

temperature of inflows to the project (e.g., increasing stream shading, restoring channels, increasing 

streamflows or groundwater inflows, or reducing heat loads contributed from agricultural return flows and 

other point sources). 

ODFW-56 recommends that Idaho Power consult with ODEQ to develop and implement a 

temperature management plan to be approved by ODEQ as part of its section 401 certification for the 

project. This plan would include implementing measures, a timeframe for implementing measures, and 

an effectiveness monitoring plan. The Nez Perce and Umatilla Tribes (NPT-13 and CTUIR-22) and 

AR/IRU-19 recommend that Idaho Power, in consultation with appropriate state and federal agencies and 

interested tribes, investigate the installation of a temperature control structure at Brownlee reservoir to 

meet Clean Water Act numeric and narrative criteria to support the beneficial use of fisheries. They also 

recommend that Idaho Power work with a Technical Advisory Committee to identify and implement 

other possible remedies for achieving temperature control of outflows at Brownlee, Oxbow, and Hells 

Canyon dams. 

Based on our analysis in section 3.6.2.4, Water Temperature, we conclude that increased 

temperatures in the fall that are attributable to the project likely cause reduced survival of fall Chinook 

salmon eggs that are spawned in the early part of the spawning season. We further conclude that this 

effect could be reduced with the implementation of watershed measures (e.g., temperature trading), 

through the installation of a bubble upwelling system in Brownlee reservoir, or through the installation of 

a temperature control structure in Brownlee reservoir. Notwithstanding those results, we also conclude 

that the latter two approaches involve potential adverse effects from releasing hypolimnetic water that is 

low in dissolved oxygen and may have elevated concentrations of ammonia, mercury, and organochlorine 

compounds. Using a temperature control structure to reduce water temperatures in the fall could also 

cause adverse effects by warming water temperatures during the summer outmigration period. Storing 

cool water for release in the fall would require summer releases to be drawn from higher elevations in the 

reservoir, which would increase the temperature of outflows from the project during the summer months. 

Such an outcome may adversely affect migration survival through Lower Granite reservoir. 

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Our analysis in section 3.6.2.4, Water Temperature, shows that releasing warm water via a 

temperature control structure has the potential to benefit fall Chinook salmon by counteracting delayed 

warming caused by the project, thereby increasing growth rates in the spring. This outcome may improve 

outmigration survival by fostering early outmigration or attainment of a larger size prior to outmigration. 

However, the modeling conducted by Idaho Power indicates that the ability to increase temperatures in 

the spring is limited in average and high water years, and there would be little effect prior to mid-March 

in all water years. Our review of Idaho Power’s modeling results indicates that this finding is due to the 

limited degree of stratification that occurs in Brownlee reservoir in the early spring in low flow years, and 

that stratification is delayed until the late spring in higher flow years. Furthermore, increasing water 

temperatures in the spring could reduce the migration survival of yearling spring Chinook salmon and 

steelhead emigrating from tributaries downstream of the project. 

Our evaluation of the preliminary simulation results for the bubble upwelling system leads us to 

conclude that the upwelling system, by itself, may not be sufficient to meet the project’s temperature load 

allocation. While implementing watershed measures, such as increasing stream shading, would address 

project effects on water temperature only indirectly, this approach has the potential to provide a greater 

overall benefit than a bubble upwelling system. Such benefits could include improving water quality 

conditions within, and downstream from, the tributary streams where the watershed measures are 

implemented. This would provide benefits to native resident salmonids, white sturgeon, and other aquatic 

species. Accordingly, we conclude that watershed measures show substantial promise as a highly 

beneficial means for addressing the project’s temperature responsibility, either alone or in combination 

with a bubble upwelling system. 

We estimate that the annualized cost of developing and implementing Idaho Power’s proposed 

Temperature Adaptive Management Plan would be $452,000, based on the costs for a Brownlee bubble 

upwelling system. Because the watershed measures and a bubble upwelling system could provide 

substantial benefits to fall Chinook salmon and other aquatic resources, we conclude that Idaho Power’s 

proposed Temperature Adaptive Management Plan is warranted and would be worth the cost. Therefore, 

we include it as part of the Staff Alternative. 

With regard to the temperature control structure, we continue to conclude that installing such a 

structure is not warranted. We base our conclusion on the high cost of this measure,121 as well as the 

potential adverse effects on (1) fall Chinook salmon from increased water temperatures downstream of 

the project during the summer outmigration season, and (2) other water quality parameters including 

reduced dissolved oxygen and increased concentrations of ammonia, mercury, and organochlorine 

compounds in waters downstream from Brownlee reservoir. 

In addition to the Temperature Adaptive Management Program, we recommend that Idaho 

Power: (1) monitor the effectiveness of implemented measures; (2) hold annual meetings with ODEQ, 

IDEQ, ODFW, IDFG, FWS, NMFS, and interested tribes to evaluate whether measures need to be 

modified or additional measures implemented to meet the project’s temperature responsibility, and (3) 

file an annual monitoring and implementation report with the Commission that summarizes monitoring 

results and outlines any modifications or new measures that warrant consideration and/or are proposed for 

implementation. These steps would provide better information on the effectiveness of implemented 

measures and provide a greater level of assurance that the implemented measures meet the project’s 

temperature responsibility. 

 

121 In its response to AIR WQ-2, Idaho Power (2005e) estimated that the annualized cost for the 

construction and operation of five alternative water temperature control structures at the Brownlee 

intake ranged from $3.7 million for an overflow stoplog weir in the existing intake channel to $40.6 

million for a new 35,000 cfs capacity variable-height-gated intake tower. 

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5.2.3.3 Total Dissolved Gas Abatement 

Water flowing through dam spillways and plunging to depth in pools below dams causes air to be 

driven into solution, resulting in supersaturation of gasses in the water. Total dissolved gas levels above 

110 percent of saturation can be injurious to fish by causing gas bubble trauma. Sampling conducted by 

Idaho Power in the project reservoirs and in the Oxbow bypassed reach found evidence of gas bubble 

trauma in some fish when total dissolved gas levels exceeded 120 percent of saturation. In addition, a 

wide range of fish species showed evidence of gas bubble trauma when total dissolved gas levels 

exceeded 125 percent (see section 3.6.2.3, Total Dissolved Gas). Gas bubble trauma causes increased 

stress in fish and other aquatic organisms, and severe gas bubble trauma can cause substantial levels of 

mortality. 

Spills greater than 3,000 cfs at Brownlee dam currently result in total dissolved gas levels that 

exceed the 110-percent of saturation criterion downstream of the Brownlee dam spillway, and have 

substantial effects on total dissolved gas levels in Oxbow and Hells Canyon reservoirs. Nearly all spills 

at Hells Canyon dam result in exceedance of the 110-percent criterion, and at spills of 19,000 cfs and 

greater, the entire Hells Canyon reach down to the Salmon River confluence exceeds this criterion. 

Limited sampling at Oxbow dam indicates that spills at this facility also cause total dissolved gas to 

exceed 110 percent of saturation, independent of spills at Brownlee dam. With continued project 

operation, spills that cause exceedance of the 110-percent criterion would occur for prolonged periods in 

medium high to extreme high flow years, less frequently in medium flow years, and seldom if ever in low 

flow years. 

In its license application, Idaho Power proposed to continue preferential use of crest (upper 

spillway) gates for passing spills at Brownlee dam. It also proposed to install flow deflectors on the Hells 

Canyon dam spillway that would alter the flow characteristics from the spillway to reduce air entrainment 

deep in the tailrace during spill episodes of up to approximately 30,000 cfs. In addition, Idaho Power 

proposed to develop a schedule for constructing and installing flow deflectors and an effectiveness 

monitoring plan in consultation with ODEQ and IDEQ. 

ODFW-54 recommends that Idaho Power develop and implement a plan, in consultation with and 

approved by ODEQ, to satisfy Idaho Power’s total dissolved gas allocation of less than 110 percent of 

saturation at the edge of the aerated zone below each project dam for all flows not exceeding the 10-year, 

7-day average flood flow. Under this plan, Idaho Power would develop and monitor measures to assure 

compliance with Oregon’s total dissolved gas standard below all three dams as required by the TMDL, 

Oregon water quality standards, and the Clean Water Act. 

NMFS (NMFS-10 and NMFS-11), Interior-62, the Umatilla Tribes (CTUIR-20), and the 

Nez Perce Tribe (NPT-15) recommend that Idaho Power design and install gas abatement structures at 

Hells Canyon and Brownlee dams. In the event that the resulting structures do not meet total dissolved 

gas standards, the Umatilla and Nez Perce Tribes recommend that Idaho Power re-consult with the 

agencies to develop and implement other structural approaches to meet water quality standards within 5 

years of the issuance of a new license. Each of these measures would reduce total dissolved gas levels in 

Oxbow and Hells Canyon reservoirs and in the free-flowing Snake River downstream of Hells Canyon 

dam. 

AR/IRU (AR/IRU-18) recommend that the Commission require Idaho Power to use a 6-step 

adaptive management approach to eliminate or minimize total dissolved gas levels in excess of 110 

percent of saturation. Idaho Power would conduct real-time total dissolved gas monitoring, either during 

periods of high spill or consistent with Idaho Power’s water quality certificate once it is issued to detect 

and quantify total dissolved gas violations below each of the project dams. 

Comments on the draft EIS emphasized the adverse effects of total dissolved gas on aquatic 

resources (Interior, AR/IRU), and included recommendations for additional evaluation of the effects of 

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Oxbow dam spills on total dissolved gas (ODEQ), clarification of the staff-recommended total dissolved 

gas measures (Interior and AR/IRU), development of a monitoring plan (ODEQ), and refinement of an 

adaptive approach to manage total dissolved gas (ODEQ, Forest Service, Umatilla Tribes, and Nez Perce 

Tribe). 

In its April 26, 2007, filing with the Commission and its January 31, 2007, application for water 

quality certification, Idaho Power (2007a) now proposes to: (1) continue preferential use of crest gates 

for passing spills at Brownlee dam as an interim measure until the Brownlee spillway deflectors are 

constructed; (2) install flow deflectors at both the Hells Canyon and Brownlee dam spillways; (3) 

evaluate total dissolved gas reduction structures for Oxbow dam and install the most effective, safe, and 

economically feasible measure designed to reduce total dissolved gas at the dam; (4) adaptively manage 

uncertainties associated with its proposed total dissolved gas-abatement measures to ensure that it 

satisfies is total dissolved gas load allocation; (5) work with ODEQ and IDEQ to develop a total dissolved 

gas monitoring plan that would include monitoring during spill to determine compliance with the TMDL 

load allocation assigned to Idaho Power; and (6) if monitoring indicates that the implemented measures 

fail to meet the TDG criterion or protect aquatic life, adaptively manage TDG in the project through 

evaluation and implementation of additional measures designed to further reduce TDG levels.. 

In section 3.5.2.3, Total Dissolved Gas, we conclude that Idaho Power’s proposal to continue 

preferential use of the upper spillway gates at Brownlee dam, along with the proposed installation of 

deflectors at Hells Canyon and Brownlee dams, would reduce the frequency of spill events that exceed 

the total dissolved gas standard. The 110-percent of saturation criterion would be exceeded less 

frequently, and the magnitude of exceedances would be reduced at flows up to at least the 10-year, 7-day 

average flood flow at Brownlee and Hells Canyon dams. This would reduce the potential for fish and 

other aquatic organisms to be exposed to high total dissolved gas levels in Oxbow and Hells Canyon 

reservoirs, as well as downstream of Hells Canyon dam. We estimate the annualized cost of Idaho 

Power’s proposed total dissolved gas abatement measures at Hells Canyon at $182,700 and the additional 

annualized cost of deflector installation at Brownlee at $197,500. We include these measures in the Staff 

Alternative because the reduced frequency of elevated total dissolved gas would reduce the risk of gas 

bubble trauma in fish, especially to federally listed fall Chinook salmon.122

Since issuance of the draft EIS, monitoring conducted by Idaho Power indicates that spills at 

Oxbow dam, which do not coincide with Brownlee dam spills, can elevate total dissolved gas above 

allowable limits. Monitoring conducted by Idaho Power also determined that gas bubble trauma occurs in 

fish collected below the Brownlee and Oxbow spillways when total dissolved gas levels exceed 120 

percent, and severe gas bubble trauma was observed when total dissolved gas levels exceeded 125 percent 

of saturation. Idaho Power is currently evaluating total dissolved gas reduction structures for Oxbow 

dam, and proposes to install the most effective, safe, and economically feasible measure to reduce total 

dissolved gas at the dam. Based on these recent study results, we have amended the Staff Alternative to 

include Idaho Power’s proposed evaluation of total dissolved gas abatement measures for Oxbow dam 

and implementation of the most effective, safe and economically feasible measure for reducing total 

dissolved gas below the dam. Assuming that spillway deflectors would be installed, we estimate that the 

annualized cost of Oxbow dam total dissolved gas abatement measures would be $278,200. Because this 

measure could substantially reduce adverse effects on aquatic resources downstream of Oxbow and Hells 

Canyon dams, we conclude that the cost is warranted and include this measure in the Staff Alternative. 

 

122 In the draft EIS, we based our annualized cost estimates of $407,600 for Hells Canyon spillway 

deflectors and $354,700 for Brownlee spillway deflectors on the contracted cost for construction of 

spillway deflectors at Ice Harbor dam. In this final EIS, we revised these estimates based on sitespecific information that Idaho Power filed with the Commission on April 26, 2007. 

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Because the effects of the deflectors cannot be accurately predicted, and the specific measure to 

be implemented at Oxbow dam has yet to be determined, it is not known to what extent the combination 

of Idaho Power’s proposed operational changes and the installation of Brownlee and Hells Canyon 

spillway deflectors would satisfy the applicable total dissolved gas standards downstream of each of the 

project dams. Measures included in Idaho Power’s application for water quality certification to monitor 

total dissolved gas levels and adaptively manage uncertainties associated with its proposed total dissolved 

gas-abatement measures would help ensure that it satisfies its total dissolved gas load allocation and 

minimizes adverse effects on aquatic resources. We estimate that the total dissolved gas monitoring effort 

proposed by Idaho Power would have an annualized cost of $37,200. The cost of adaptive management 

depends on whether additional measures are required, but we estimate that consultation with the agencies 

would have an annualized cost of $2,000. Because high total dissolved gas levels can cause substantial 

adverse effects on aquatic resources, monitoring and adaptive management would help ensure that 

adverse effects on aquatic resources are reduced. We further recommend that the monitoring effort 

include the development of an annual monitoring and implementation report, which would include 

monitoring results and describe actions taken in the past year along with actions proposed for the coming 

year. The report would be developed in consultation with IDEQ, ODEQ, NMFS, Interior, IDFG, ODFW, 

and interested tribes. Idaho Power would provide a draft of the report to the consulted parties for 

comment; and subsequently file the report with the Commission. 

5.2.3.4 Water Quality Monitoring 

Although several of Idaho Power’s proposed water quality measures include monitoring 

components, Idaho Power does not propose to develop or maintain any permanent water quality 

monitoring stations. 

NMFS (NMFS-14) recommends that Idaho Power fund and maintain six permanent water quality 

monitoring stations in the mainstem Snake River to document trends in water quality (temperatures, 

dissolved oxygen, total dissolved gas, and pH) and collect additional water quality samples twice each 

month to assess progress in reducing nutrient and fine sediment loads in the Snake River. Water quality 

monitoring stations would be located below Hells Canyon dam, below Brownlee dam, between Brownlee 

reservoir and the Weiser River confluence, below Swan Falls dam, below C.J. Strike dam, and below 

Bliss dam. 

In the draft EIS, we did not adopt the NMFS recommendation to install monitoring stations 

upstream of the project because these gages would be located upstream of the influence of the project and 

would not provide data relevant to Idaho Power’s management of the Hells Canyon Project. In its 

comments on the draft EIS, however, NMFS expressed interest in developing a permanent flow and water 

quality monitoring site downstream of Hells Canyon dam that would allow for a common monitoring 

platform by which to more realistically evaluate operations, flows, and their interactions with measures to 

improve important water quality parameters. 

During the 10(j) meeting, Idaho Power indicated that the installation of spillway deflectors at 

Hells Canyon dam would direct more energy downstream during spill periods and would likely cause 

inaccurate flow and stage measurements at the former USGS gage site located 0.6 miles downstream of 

the dam. However, Idaho Power also indicated that it had identified several potentially feasible flow 

measurement sites located between 2.5 miles and 5 miles downstream of Hells Canyon dam. We 

conclude that establishing a new gage site closer to Hells Canyon dam would provide more useful data on 

water quality, as well as flow. We also conclude that measuring flow and water quality conditions at the 

same site would improve the evaluation of any relationship between flow and water quality parameters, 

which would be useful for evaluating and refining measures implemented to improve dissolved oxygen 

and to manage total dissolved gas levels. Therefore, we include within the Staff Alternative the 

development of an operational compliance and water quality monitoring plan, which would encompass 

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the development of a new flow gaging and water quality monitoring site within 5 miles downstream of 

Hells Canyon dam. 

Idaho Power should develop the plan in consultation with IDEQ, ODEQ, IDFG, ODFW, NMFS, 

FWS, USGS, and interested tribes. The plan should, at a minimum, include: 

• Identification of an appropriate location for continuous monitoring of river flow, stage, water 

temperature, dissolved oxygen, and total dissolved gas downstream of Hells Canyon dam, 

preferably within 5 miles of the dam; 

• A schedule for construction of a flow measurement gage at the selected site, and installation 

of water quality monitoring equipment; 

• A description of the procedures that would be followed to determine a ramping rate at the 

new gage site that is equivalent to any ramping rate specified in the new license for other 

locations; 

• A description of the method that would be used to measure water surface elevations at 

Brownlee, Oxbow and Hells Canyon reservoirs, as well as flow rates in the Oxbow bypassed 

reach; and 

• The time steps for which real-time and historical flow, water surface elevation and water 

quality information from each location would be posted on the Internet and annually reported 

to the Commission. 

We estimate that the annualized cost of developing and implementing the operational compliance 

and water quality monitoring plan, including establishing a new flow gaging site, would be $30,500. The 

plan would include provisions for making water quality, flow data, and reservoir levels available on the 

Internet to facilitate verification of compliance with operational conditions specified in the new license 

and to facilitate adaptive management. 

5.2.4 Aquatic Resources 

5.2.4.1 Fall Chinook Spawning and Incubation Flows 

Flows released from Hells Canyon dam affect the quality and quantity of spawning habitat 

available to fall Chinook salmon in the Snake River between Hells Canyon dam and Lower Granite 

reservoir, a reach that contains most of the spawning habitat that is currently accessible to fall Chinook 

salmon in the Snake River System. The reach is not known to be a major spawning area for any other 

anadromous fish species. 

Since 1991, Idaho Power has voluntarily implemented a flow program to enhance spawning and 

incubation conditions for fall Chinook salmon in the Hells Canyon reach. To prevent redds from 

becoming dewatered during the spawning season, Idaho Power maintains steady flow conditions from 

mid-October through early December to keep spawning activity below a water level that can be 

maintained throughout the incubation and fry emergence stages. The spawning flow, which has typically 

been between 9,000 and 13,000 cfs, is determined each year before spawning begins based on forecasted 

inflows to Brownlee reservoir, predicted hydrologic-year type (low, medium, or high), and availability of 

habitat. After spawning has ended, Idaho Power maintains a minimum flow that protects the shallowest 

redd from being dewatered until fry have emerged from the gravel. Idaho Power proposes to continue the 

fall Chinook spawning flow program, although with the suggestion that some degree of flow fluctuation 

be allowed during the spawning period without reducing the availability of spawning habitat or hindering 

spawning behavior. 

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NMFS, the Nez Perce Tribe, ODFW, IDFG, and the Umatilla Tribes provided recommendations 

relating to the fall Chinook spawning flow program. We summarize these in section 3.6.2.1, Effects of 

Project Operations on Aquatic Resources. 

The spawning flow program benefits fall Chinook salmon by maintaining near-optimal flow 

levels during the spawning period and by preventing dewatering of redds during the incubation period. 

Since the flow program was first implemented in 1991, the number of adult fall Chinook salmon returning 

to the Snake River has increased substantially. While other factors such as hatchery supplementation, 

improved migration survival, and favorable ocean conditions have contributed to this trend, there is little 

doubt that protecting redds from dewatering has improved incubation survival. NMFS, ODFW, IDFG, 

the Nez Perce Tribe, and the Umatilla Tribes all recommend that the fall Chinook flow program be 

continued, and we include it as an operational provision in the Staff Alternative. Since the flow program 

is part of the current operation, we do not attribute any incremental cost to its continuation. 

In its description of this proposed measure, Idaho Power states that modifications of the flow 

program are being evaluated and explored in cooperation with interested agencies, including discussion of 

the potential for allowing some flow variation during the spawning season. Any flow variation that 

occurs during the spawning period could result in redds being constructed at higher elevations, which 

would require higher flows to be maintained during the egg incubation season to avoid dewatering redds. 

Redds that are constructed at higher elevations would be more vulnerable to exposure (and exposurerelated mortality of eggs and fry), especially when inflows to Brownlee reservoir are lower than was 

forecast at the start of the spawning season. We conclude in section 3.6.2.1 that maintaining a stable flow 

during the spawning season is more protective than a variable flow regime would be, and, in the Staff 

Alternative, we do not amend the current program to allow variation during the season. 

The spawning flow that is selected each year affects the quantity of habitat that will have suitable 

depths and velocities for spawning. Idaho Power proposes that a spawning flow between 8,000 and 

13,000 cfs be determined each year based on forecasted inflows to Brownlee reservoir, predicted 

hydrologic-year type (low, medium, or high), and availability of habitat. NMFS (NMFS-1) recommends 

that the stable spawning flow be between 8,500 and 13,500 cfs, the Nez Perce Tribe (NPT-14) 

recommends a flow between 8,500 and 13,000 cfs, ODFW (ODFW-34) recommends that the spawning 

flow be at least 8,000 cfs, and the Umatilla Tribes (CTUIR-9) recommend a spawning flow of at least 

9,000 cfs. 

Our analysis indicates that flows between 8,000 and 15,000 cfs should provide near-optimal 

conditions for spawning fall Chinook salmon, and providing stable flows anywhere in this range should 

minimize the potential for redd superimposition, especially in years when large numbers of fall Chinook 

spawn in the Hells Canyon reach. In the Staff Alternative, we include NMFS’s recommended flow range 

of 8,500 to 13,500 cfs as the range from which to select spawning flows for any given year. However, 

there is not likely to be any difference in the cost or benefit from specifying an upper limit of 13,000 or 

13,500 cfs, since Idaho Power would not be precluded from selecting a spawning flow less than 13,000 

cfs in any given year and the amount of habitat that would be provided is essentially unchanged over this 

range of flows. 

Other recommendations made by the agencies and tribes relate to consultation and monitoring 

requirements for establishing spawning flow levels, in-season consultation on adjustments to flow levels 

due to changes in flow forecasts, establishing the flow level that is required to protect redds until fry have 

emerged from the gravel, determining the number and location of temperature monitors that are needed to 

track water temperatures and estimate the timing of fry emergence, determining the frequency of both 

shallow and deep-water redd surveys, and reporting requirements. Consultation with the resource 

agencies and tribes to determine appropriate monitoring efforts and to improve the efficiency of the flow 

management decision process would help to maximize resource benefits and avoid imposing any 

unnecessary constraints on project operations. This consultation could be accomplished through the 

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development of a fall Chinook spawning and incubation flow management plan. We estimate the 

annualized cost of developing and implementing a fall Chinook flow management plan at $2,700, and we 

include it in the Staff Alternative. 

5.2.4.2 Flow Fluctuations Outside of the Fall Chinook Spawning and Incubation 

Period 

Flow fluctuations and changes in the seasonal flow regime caused by project operations can affect 

the quality and quantity of rearing habitat and the food supply that is available to rearing juvenile fall 

Chinook salmon and has the potential to cause juvenile fall Chinook salmon to become stranded on bars 

or trapped in pools that become isolated from the stream channel. Losses of fry that are trapped in pools 

may occur due to high water temperatures, increased vulnerability to predation, or stranding if the pools 

drain before they are reconnected to the river. The Hells Canyon reach is not known to provide important 

rearing habitat for other anadromous species, but it is the most important production area in the Snake 

River basin that is still accessible to fall Chinook salmon. Flow fluctuations may also affect the available 

food supply and has the potential to cause mortality due to stranding and entrapment of other fish species, 

including bull trout and redband trout. 

Although the fall Chinook flow program (which we discuss immediately above) provides stable 

flows during the fall Chinook spawning season and maintains flows sufficient to keep redds watered until 

emergence is complete, Idaho Power’s proposed operations would allow substantial flow fluctuations to 

occur during the fall Chinook rearing period (approximately March 15 through June 15), and at other 

times of the year, when bull trout and redband trout may be present. Idaho Power proposes to continue its 

current maximum up- and down-ramping rate of 12 inches per hour as measured at Johnson Bar, 17.6 

miles downstream of Hells Canyon dam. This ramping rate causes stage fluctuations of about 16 inches 

per hour below Hells Canyon dam. Under typical operating conditions, Idaho Power proposes to limit the 

maximum daily change in flow to 10,000 cfs, and to maintain a minimum flow of 6,500 cfs from June 1 

through September 30, and to maintain a minimum flow of 5,000 cfs for the remainder of the year. 

NMFS, Interior, the Forest Service, ODFW, IDFG, the Nez Perce Tribe, the Umatilla Tribes, and 

AR/IRU recommend measures related to ramping rates and minimum flows outside of the fall Chinook 

spawning period. We describe these recommendations in section 3.6.2.1, Effects of Project Operations 

on Aquatic Resources. These include a recommendation by NMFS (NMFS-4) that sufficient flow be 

released to ensure that the largest juvenile entrapment areas are reconnected to the Snake River for at least 

2 hours on a daily basis; ODFW’s recommendation (ODFW-33) that Idaho Power be required to meet a 

specified seasonal schedule of ramping rates, minimum flows, and maximum daily flow change 

restrictions; Interior’s recommendation (Interior-54) that Idaho Power implement seasonal run-of-river 

operations downstream of Hells Canyon dam during the white sturgeon spawning, incubation, and early 

life history stages; and recommendations by ODFW (ODFW-33), Interior (Interior-65) and NMFS 

(NMFS-15) that river flow and ramping rates be monitored within 1 mile downstream of Hells Canyon 

dam. 

Based on our analysis in section 3.6.2.1 of habitat area, food supply, and the potential for 

entrapment and stranding, we conclude that reducing ramping rates during the fall Chinook rearing season 

would provide several benefits to juvenile fall Chinook salmon. Based on our analysis of Idaho Power’s 

habitat modeling studies, restricting ramping rates would increase habitat stability, which would reduce 

energy expenditures from fish having to repeatedly move to find optimal rearing habitats or reduce food 

intake from residing in sub-optimal habitat. From our analysis of effects on invertebrate production, we 

conclude that Idaho Power’s proposed ramping rate could result in complete dewatering of favored 

rearing habitats (<1.5 meters deep), which would substantially reduce macroinvertebrate abundance and 

the food base that is available to fall Chinook salmon in their preferred rearing habitat. 

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From our analysis of Idaho Power’s entrapment monitoring work, we conclude that implementing 

more restrictive ramping rates could substantially reduce the number of fish entrapped, and reduce 

mortalities due to stranding and from entrapment. Data from Idaho Power’s 2005 entrapment surveys 

indicate that implementing a 6-, 4-, or 2-inch-per-hour ramping rate in 2005 would have reduced the 

estimated stranding mortality of 2,643 fall Chinook salmon juveniles by 8.9 percent, 92.9 percent, and 

95.4 percent, respectively (see table 50). We conclude that both the 2- and 4-inch-per-hour ramping rates 

would provide a high level of protection, compared to less restrictive rates, in conjunction with annual 

monitoring to determine whether additional operational adjustments or fish salvage operations were 

warranted to account for differences in seasonal flows or in channel topography between years. 

Idaho Power identifies the primary fall Chinook salmon rearing season to be from March 15 to 

June 15, although ramping rate restrictions recommended by other stakeholders to protect rearing fall 

Chinook salmon would apply from March 1 to May 31 (AR/IRU-23b), April and May (NPT-3), and 

March 21 to June 21 (ODFW-33). We conclude in section 3.6.2.1 that implementing restrictive ramping 

rates as early as March 15 would benefit rearing fall Chinook salmon by allowing macroinvertebrates 

time to start colonizing shoreline rearing habitats before fall Chinook fry emerge from the gravel and take 

up residence in these areas. We also conclude that maintaining a ramping rate restriction until June 15 

would protect the great majority of fall Chinook salmon from the risk of entrapment and stranding losses 

associated with load following operations. 

In its response to AIR OP-1, Idaho Power estimated the annualized cost of changing the ramping 

rate compliance point from Johnson Bar to Hells Canyon dam, as recommended by NMFS-15, in 

conjunction with a reduced ramping rate from March 15 to May 31, would range from $6.6 million for a 

seasonal 6-inches-per-hour limit to $6.9 million for a seasonal 2-inches-per-hour limit. In the draft EIS, 

we adopted a provision that the maximum variation in river stage, as measured at the Snake River at 

Johnson Bar gaging station, not exceed 4 inches per hour during the March 15 to June 15 fall Chinook 

salmon rearing period. This measure would have a much lower cost than the scenarios evaluated by 

Idaho Power and the measures recommended by the agencies because the existing ramping rate and 

compliance point would be maintained outside of the March 15 to June 15 period, and would not affect 

the generating capacity available during high demand periods of the year. In the draft EIS, we concluded 

that this seasonal ramping rate limitation, implemented in conjunction with monitoring to adaptively 

manage stranding and entrapment losses of fall Chinook salmon, would provide a substantial level of 

protection for this threatened species, and we include this measure in the Staff Alternative. 

In its comments on the draft EIS, NMFS expressed concern that imposing a fixed ramping rate 

would not take into account prevailing flow levels in a given year, and as a result may not reconnect some 

pools where substantial levels of entrapment and mortality could occur. Interior also expressed concern 

over the lack of information and the potential for stranding impacts on bull trout, another federally listed 

threatened species. During the 10(j) meeting, Idaho Power indicated that it had developed a draft 

stranding and entrapment management plan to address stranding risks to fall Chinook salmon, and that it 

was in the process of developing a stranding and entrapment management plan to address effects on bull 

trout. 

We continue to conclude that available information indicates that a seasonal 4-inch-per-hour 

ramp rate would provide substantial benefits to rearing fall Chinook salmon compared to current 

operations. At an annualized cost of $2.07 million, we conclude that these benefits would be worth the 

cost and retain this measure in the Staff Alternative. However, we recognize that the effectiveness of this 

seasonal ramp rate for preventing losses of juvenile fall Chinook salmon may vary between years, 

depending on differences in hydrologic and meteorological conditions, and that there is little information 

available on the potential for losses of bull trout from stranding and entrapment. Accordingly, we expand 

our recommended monitoring study to address potential effects on bull trout, which would require 

monitoring to be expanded to include the winter season when fluvial bull trout are present in the 

mainstem Snake River. We recommend that Idaho Power consult with NMFS, Interior, IDFG, ODFW, 

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and the interested tribes to develop a stranding and entrapment management plan. The plan would 

include a detailed description of how entrapment and stranding of juvenile fall Chinook salmon and bull 

trout would be monitored, any studies that are needed to quantify mortality or assess sublethal adverse 

effects, and provisions for implementing salvage operations or modifying project operations as needed to 

minimize losses from stranding and entrapment. We estimate that the annualized cost of implementing 

the expanded stranding and entrapment management plan would be $107,000. We conclude that its 

potential to improve flow management to protect fall Chinook salmon and bull trout warrant the costs of 

developing and implementing the plan. 

NMFS (NMFS-4) also recommends that minimum flows be increased to 11,500 cfs if water 

temperatures in entrapment pools exceed 16°C for more than 3 days or when peak water temperatures in 

any pool exceed 18°C for more than 4 hours. We see little benefit to this recommendation, since most of 

the 2005 mortalities occurred at the middle Pine Bar pools, which Brink (2006) reports were disconnected 

from the river at a flow of 15,735 cfs and below (table 47). This high a minimum flow would essentially 

preclude load following while it was in effect, and would likely have an annual cost in excess of 

$2 million in lost power benefits. We do not include NMFS’s recommendation that sufficient flow be 

released to ensure that the largest juvenile entrapment areas are reconnected to the Snake River for at least 

2 hours on a daily basis. While we cannot estimate a cost of this NMFS proposal, we conclude that 

ramping flows to reconnect entrapment areas could increase losses from stranding. We note that Idaho 

Power’s studies focused on entrapment in pools, and did not address fish stranding in dewatered cobble 

bars, where it is difficult to detect small fish between or under cobbles. As a result, the mortality from 

stranding may be higher than it appears from the 2005 study results, and this risk could be increased by 

implementing the NMFS recommendation, which would cause more cobble bars to be dewatered on a 

daily basis. We conclude that the 4-inch-per-hour ramping rate that we include in the Staff Alternative, in 

conjunction with monitoring to determine whether additional measures are necessary, would be more 

effective in reducing potential losses from stranding and mortality. Additional measures could include 

implementing a higher minimum flow under certain conditions. However, we conclude that the available 

information is insufficient to support NMFS’s proposed temperature-dependent minimum flow of 11,500 

cfs. 

We do not include in the Staff Alternative ODFW’s recommendation (ODFW-33) that Idaho 

Power be required to meet a specified seasonal schedule of ramping rates, minimum flows, and maximum 

daily flow change restrictions. Based on our evaluation of the effects of project ramping on aquatic 

resources, we include Idaho Power’s proposed operating restrictions during the fall Chinook spawning 

and incubation period, the additional ramp rate restriction of 4 inches per hour during the fall Chinook 

rearing period, and the stranding and entrapment plan in the Staff Alternative discussed above. However, 

we found no evidence to suggest that substantive adverse effects were being caused to aquatic resources 

by Idaho Power’s current ramping rate outside of these time periods. We estimate that the annualized 

cost associated with ODFW’s proposed measure would be about $17.6 million in lost power benefits. 

We see little benefit to the multi-year ramping rate study recommended by Interior (Interior-44 

and -66) and the Forest Service (FS-30). We conclude that there is already sufficient site-specific 

information to determine appropriate operational constraints to protect rearing fall Chinook juveniles in 

conjunction with appropriate monitoring and provisions for limited adaptive management. The lost 

power benefits from implementing run-of-river operation for an estimated 6-year test period would have 

an annualized cost exceeding $5 million. To facilitate adaptive management of flows, if needed to 

support the food supply available to juvenile fall Chinook salmon, we adopt an invertebrate monitoring 

plan in the Staff Alternative. We discuss this plan in section 5.2.4.11, Invertebrate Monitoring. 

We also do not adopt Interior’s recommendation (Interior-54) that Idaho Power implement 

seasonal run-of-river operations downstream of Hells Canyon dam during the white sturgeon spawning, 

incubation, and early life history stages. Idaho Power’s studies demonstrate that the sturgeon population 

in this reach benefits from regular recruitment, so there is no indication that load following is causing any 

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adverse effects to white sturgeon spawning and recruitment. We estimate that the annualized cost of 

Interior’s recommendation would be on the order of $2 million in lost power benefits. 

In the draft EIS, we did not adopt recommendations made by ODFW (ODFW-33), Interior 

(Interior-65) and NMFS (NMFS-15) that river flow and ramping rates be monitored within 1 mile 

downstream of Hells Canyon dam. We based this decision on the difficulty of monitoring compliance at 

that point due to a reactive relationship between stage and discharge near the dam, and the fact that the 

existing monitoring location at Johnson Bar was used as the reference point in Idaho Power’s licensing 

studies, which form the basis for the ramping rate restriction that we have included in the Staff 

Alternative. During the 10(j) meeting, however, the agencies expressed interest in identifying a single 

site for collecting flow and water quality information closer to the dam, where the influence of the project 

on dissolved oxygen and total dissolved gas levels could be monitored more effectively. Idaho Power 

indicated that the installation of spillway deflectors at Hells Canyon dam would direct more energy 

downstream during spill periods and would likely cause inaccurate stage and flow measurements if the 

gage used to monitor compliance were located too close to the dam. Idaho Power also stated that it had 

identified several potentially feasible flow measurement sites located between 2.5 miles and 5 miles 

downstream of Hells Canyon dam. 

We conclude that establishing a new monitoring site closer to the dam would provide more useful 

data on water quality and that measuring flow and water quality conditions at the same site would 

improve evaluation of the relationship between flow and water quality parameters. This information 

would be useful for evaluating and refining measures implemented to address the dissolved oxygen deficit 

that currently extends for several miles downstream of the dam during the summer. It would also be more 

useful for measuring and managing total dissolved gas levels, which are more likely to exceed state 

standards in areas that are closer to the dam. Therefore, as part of the Staff Alternative, we recommend 

that Idaho Power develop an operational compliance and water quality monitoring plan. The plan, which 

we describe further in section 5.2.3.4, Water Quality Monitoring, should include an evaluation and 

development of a new flow gaging and water quality monitoring site within 5 miles downstream of Hells 

Canyon dam. The plan should also include provisions for determining a ramping rate at the new gage site 

that is equivalent to any ramping rate specified in the new license that is based on measurements at the 

existing compliance point at Johnson Bar. We estimate that the annualized cost of developing and 

implementing the flow compliance and water quality monitoring plan, including establishing a new flow 

gaging site, would be $30,500. Also, the plan should include provisions for making water quality, flow 

data, and reservoir levels available on the Internet, as well as through other appropriate reporting 

mechanisms, to facilitate verification of compliance with operational conditions specified in the new 

license and to facilitate adaptive management. 

5.2.4.3 Anadromous Fish Restoration 

The Hells Canyon Project has blocked anadromous fish from accessing spawning and rearing 

habitats upstream of Hells Canyon dam since initial attempts to provide passage were discontinued 

several years after Brownlee dam was constructed. A successful anadromous fish restoration effort above 

Hells Canyon dam would restore self-supporting runs in historically available habitat and increase the size 

and maintain the genetic diversity of Snake River populations. 

Idaho Power proposes measures that are targeted toward the restoration of passage and habitat for 

bull trout. However, Idaho Power does not propose to restore passage for anadromous fish to habitat 

within and upstream of the project at this time. 

State and federal agencies, tribes, and NGOs propose a range of approaches for restoring 

anadromous fish to areas upstream of Hells Canyon dam. We summarize these specific 

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recommendations123 and related general recommendations directed at improving water quality and habitat 

conditions to support anadromous fish restoration in sections 3.6.2.6, Anadromous Fish Restoration, 

2.6.2.7, Fish Passage Facilities, and 3.6.2.8, Resident Salmonid Passage. Among the recommendations 

are suggestions for habitat improvement and the restoration of anadromous fish to historical habitat filed 

by the Burns Paiute and Shoshone-Paiute tribes (BPT-7 and SPT-3). ODFW (ODFW-2) recommends 

that specific target sizes be established for anadromous fish runs to areas upstream of the project. 

Idaho Power conducted extensive studies to evaluate the potential for anadromous fish 

restoration, and concluded that restoring self-supporting runs was possible only in certain tributaries and 

under the most optimistic assumptions. In most of the major tributaries upstream of the project, they 

report that habitat and water quality conditions have been degraded by land use practices and 

development of the basins to support irrigated agriculture, and to provide municipal water supply. Water 

quality in the mainstem of the Snake River upstream of the project is also severely degraded, and the 

existence of eight mainstem dams in the downstream migratory corridor cause mortality during the 

upstream and downstream migration of all anadromous species. NMFS chose not to issue a specific 

section 18 fishway prescription at this time, stating that poor water quality severely limits the potential for 

fall Chinook salmon to incubate through emergence, and the degraded habitat in most tributaries would 

similarly limit the possibilities for successful reintroduction of spring Chinook salmon and steelhead into 

most areas upstream of the project. 

Notwithstanding the aforementioned habitat limitations, state and federal resource agencies, 

tribes, and NGOs recommend numerous measures for upstream and downstream passage, mainstem 

passage studies, and habitat and water quality improvements as part of an overall restoration effort. 

Accordingly, after assessing the various agency, tribe, and NGO recommendations, we present and 

evaluate in section 3.6.2.6 a phased restoration approach (see table 59) that incorporates many of the 

agency, tribe, and NGO recommendations. This program would focus on tributaries within the project 

area that currently support resident salmonids without requiring passage at any major dams or reservoirs 

within the tributary. Based on our review of Idaho Power’s reintroduction studies, tributaries that meet 

these criteria include Pine Creek, Indian Creek, the Wildhorse River, and several tributaries to the Powder 

River, especially Eagle Creek. These tributaries were also identified by many of the stakeholders as being 

suitable targets for an anadromous fish restoration effort. 

Regarding fall Chinook restoration, in section 3.6.2.6, Anadromous Fish Restoration, we 

conclude that water quality conditions in the historical fall Chinook production area between Swan Falls 

and Brownlee dams are not sufficient to support restoration at this time. Specifically, low dissolved 

oxygen levels and the presence of hydrogen sulfide in the incubation environment are not likely to allow a 

sufficient hatch rate to support a self-sustaining run of fall Chinook salmon. However, there is potential 

that conditions will gradually improve over the term of the next license through implementation of the 

Snake River-Hells Canyon TMDL. 

AR/IRU (AR/IRU-8b), IDFG (IDFG-9), NMFS (NMFS-14), and the Nez Perce Tribe (NPT-8b) 

recommend that the condition of historical spawning habitat in the mainstem Snake River, upstream from 

Brownlee reservoir, be monitored by evaluating the hatch rate of fall Chinook eggs using artificial redds. 

We estimate that this monitoring effort would have an annualized cost of $20,000. In the draft EIS, we 

concluded that substantial water quality improvement would be required before reintroduction of fall 

Chinook salmon to the Swan Falls to Brownlee reach proceeds, and that existing water quality monitoring 

efforts underway in the basin should provide adequate information for determining when it would be 

appropriate to initiate reintroduction studies. 

 

123 A breakdown of anadromous fish restoration recommendations, including AR/IRU-1 through 7; 

CTUIR-11 and 12; IDFG-9; Interior-46, 47, 49, and 60; NMFS-14, 16 and 17; NPT-8; and ODFW-1 

through 17, 22, 24 and 40, is provided in table 56 in section 3.6.2.6, Anadromous Fish Restoration. 

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Comments from agencies and tribes on the draft EIS outlined their view that conditions in the 

water column are a poor predictor of water quality conditions within the intragravel incubation 

environment, which is influenced by other factors such as the amount of fine sediment that is present in 

the substrate. Comments filed by the Shoshone-Bannock Tribes also pointed to a study (Keller-Bliesner 

Engineering, 2005) that indicates water quality conditions in the Snake River upstream of Brownlee 

reservoir have not deteriorated substantially since the 1960s when fall Chinook salmon were successfully 

spawning upstream of Brownlee reservoir. This study also suggests that water quality may already be 

improving in the reach between C.J. Strike and Swan Falls dams. 

We agree that the amount of sediment in the substrate affects dissolved oxygen levels within the 

gravel by affecting the flow of water through the substrate and through biological oxygen demand from 

decomposing organic material. Also, we point out that a reduction in seasonal peak flows caused by 

water storage at upstream reservoirs operated by the Bureau of Reclamation has likely contributed to the 

build-up of fine sediment in the intragravel environment and the establishment of rooted aquatic 

vegetation. Because of these factors, we conclude that, in addition to a substantial improvement in 

overall water quality (i.e., reduced nutrient and silt loading), substantial improvements in the condition of 

the intragravel incubation environment in the upstream Swan Falls to Brownlee reach would require one 

or more substantial high flow events to dislodge rooted aquatic vegetation and cleanse fine sediments 

from potential spawning areas. This same conclusion applies to the reach between C.J. Strike and Swan 

Falls dam, although the Keller-Bliesner report cited above suggests that less time may be required to 

restore spawning habitat in this reach. It is important to understand that Idaho Power’s upstream projects 

on the mid-Snake have little if any effect on the nutrient loading that occurs upstream of the project, and 

unlike the Bureau of Reclamation projects, they have almost no effect on the magnitude of spring flushing 

flows due to their limited storage. Based on the discussion above and our analysis of the issue, we 

maintain that the nexus to project effects for the artificial redd studies proposed by the agencies is not 

sufficient, and we do not adopt this measure in the Staff Alternative. Restoring fall Chinook salmon to 

areas upstream of Swan Falls or C.J. Strike dams would require that downstream passage be implemented 

at those dams. Accordingly, the potential for restoration of fall Chinook salmon to areas upstream of 

either dam would need to be addressed through the upcoming Swan Falls relicensing proceeding for the 

C.J. Strike reach or through re-opening the C.J. Strike license for the Bliss reach. 

As a means to improve water quality in the Brownlee to Swan Falls reach and other mainstem 

reaches, NMFS (NMFS-14) and the Nez Perce Tribe (NPT-8a) recommend that Idaho Power provide 

funding to support TMDL implementation, as developed by ODEQ and IDEQ. Implementation of the 

phosphorus TMDL would reduce the high nutrient loads that currently result from anthropogenic factors, 

and thereby act to alleviate toxic hydrogen sulfide and low dissolved oxygen levels. Providing $5 million 

to $6 million annually to fund TMDL implementation as recommended by NMFS and the Nez Perce 

Tribe would likely expedite improvements in water quality. These improvements would help to create 

conditions in the historical fall Chinook spawning habitat upstream of the project that would be suitable 

for reintroduction, and would have ancillary benefits to other aquatic species including resident native 

salmonids and white sturgeon. However, nutrient loads delivered from sources upstream of the project 

are not related to the continuing operation of the Hells Canyon Project or to the operation of Idaho 

Power’s upstream hydroelectric projects. In addition, the funding levels proposed by the agencies appear 

to go far beyond the amount that would be required to meet Idaho Power’s nutrient responsibility under 

the TMDL. Because of this lack of nexus to project effects, we do not include Idaho Power funding of 

TMDL implementation in upstream reaches as part of the Staff Alternative. We note that Idaho Power 

has committed to the removal and disposal of aquatic vegetation that accumulates on the trashracks of its 

upstream Upper Salmon Falls, Lower Salmon Falls and Bliss projects,124 which would help reduce 

 

124 Idaho Power’s proposal to remove and dispose of aquatic vegetation that gathers at the project intake 

was incorporated into the licenses issued for these projects. 

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nutrient loads delivered to downstream areas. Additionally, we note that unlike the rather broad TMDL 

funding measure recommended by the agencies, the evaluation of phosphorus trading included in Idaho 

Power’s application for water quality certification, which we adopt as part of the Staff Alternative, would 

be specifically designed to meet the project’s nutrient responsibility determined under the TMDL. 

Restoring fall Chinook salmon to areas upstream of Brownlee reservoir may be warranted under 

the appropriate circumstances. However, water quality and other habitat issues in the Snake River make 

such an effort premature at this time. Because restoring fall Chinook salmon to areas upstream of 

Brownlee depends on the future improvement in water quality, we must have a mechanism for monitoring 

those events, to determine when restoration activities for fall Chinook salmon should be initiated. 

Therefore, as part of the Staff Alternative, and in lieu of the NMFS and Nez Perce recommended funding, 

we include a fish habitat monitoring plan whereby Idaho Power would develop and file a report on 

TMDL efforts in the basin that includes: (1) a schedule and format for filing a status report with the 

Commission every 5 years, reporting on the water quality monitoring data collected in the basin (with an 

assessment of how the data relates to the condition of the fall Chinook incubation environment in 

historical production areas and whether conditions indicate that survival rates may be high enough to 

support reintroduction); and (2) a description of the specific criteria (e.g., dissolved oxygen levels, 

phosphorus levels, etc.) that would trigger restoration planning for fall Chinook salmon in the Snake 

River between Brownlee reservoir and Swan Falls. Idaho Power would consult with NMFS, IDFG, 

ODFW, ODEQ, IDEQ and the tribes to develop this plan. The Staff Alternative also includes a specific 

provision that would afford the Commission an opportunity to reconsider restoration of fall Chinook 

salmon to historical habitat above Brownlee in the future.

Regarding restoration of other anadromous species, habitat in many of the tributaries that 

steelhead and spring Chinook salmon would potentially be able to access has been degraded through 

various land and water use activities, particularly in basins above Brownlee dam in which irrigation is 

extensive (Chandler and Chapman, 2003a). We share NMFS’s view that the degraded habitat in many 

tributaries would limit the potential for successful reintroduction of spring Chinook and steelhead above 

the project. Because degraded tributary habitat could limit the restoration of spring Chinook salmon and 

steelhead, state and federal agencies, tribes, and NGOs recommend a variety of tributary habitat 

enhancement measures. As part of a plan to benefit native resident salmonids, Idaho Power proposes 

many similar measures in Pine Creek, Indian Creek, the Wildhorse River, and other smaller tributaries to 

the project. In their draft EIS comments, ODFW, IDFG, and the Shoshone-Bannock Tribes filed 

information indicating that several other tributaries show potential for anadromous fish restoration or 

expansion of populations of native resident salmonids. Accordingly, we have expanded Idaho Power’s 

proposed plan to include suitable tributaries in the Powder and Burnt River basins (see section 3.6.2.10, 

Tributary Habitat Improvements). 

In the draft EIS, we expressed concern about the apparent lack of comprehensive planning that 

would be required to reintroduce anadromous fish into the upper Snake River basin. We noted that no 

resource agency had provided us with any comprehensive resource or recovery plan that clearly defined 

management goals and strategies, similar to the plan developed for reintroduction of Atlantic salmon into 

the rivers and streams of New England. We concluded that such a planning effort would be key to the 

success of a fish reintroduction program of this magnitude, and to fully weigh the costs and benefits of 

such an undertaking on all stakeholders, including the land owners and water users in the basin. 

Numerous parties objected to this rationale for deferring the restoration of anadromous fish to 

areas upstream of the project. The Forest Service commented that in other proceedings, the utility 

involved has recognized the lack of passage as being a major project effect, and has worked with the other 

parties to develop a fish passage plan that is acceptable to all those involved. ODFW commented that the 

reintroduction of salmonids into Pine, Eagle, Goose, and Daly creeks is of a much smaller scale and scope 

than the restoration of Atlantic salmon in the northeast, and should not require an extensive, 

comprehensive reintroduction plan that has region-wide consensus. They further recommended that 

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Idaho Power be required to develop a fish reintroduction plan with clearly defined management goals and 

strategies as an article in the new license. NMFS stated that rather than developing a comprehensive 

reintroduction plan, NMFS did what it typically does in FERC relicensing proceedings by providing its 

resource management goals and objectives for this relicensing. These include the general goals of 

avoiding extinction and fostering the long term survival and recovery of Columbia River basin salmon 

and steelhead and other species, and conserving the ecosystems upon which salmon and steelhead depend, 

including watershed health. NMFS also offered its specific goals for this relicensing proceeding, 

including the goal to improve water quality to restore spawning and rearing habitat in historically 

accessible areas as a vital step toward successfully restoring salmon and steelhead to historically 

important spawning and rearing habitat upstream of the project. 

We recognize that a comprehensive plan is not always needed before implementing measures to 

restore anadromous fish to areas upstream of a project, and that a proposal to restore passage to a small 

number of tributaries would not require regional consensus. We also recognize that applicants and 

stakeholders are often able to attain some degree of consensus and address restoration issues as part of the 

licensing process. However, we maintain that in this case, there is substantial uncertainty regarding the 

feasibility of restoring anadromous fish to areas upstream of the project, and that there are substantial 

stakeholder concerns that would need to be considered and addressed before even a limited reintroduction 

program could be undertaken. Accordingly, we maintain that until such a plan is developed, it would not 

be prudent to advocate for the reintroduction of steelhead, spring Chinook salmon, or fall Chinook salmon 

upstream of the Hells Canyon Project. 

We note that many of the measures that we include as part of the Staff Alternative could help lay 

the groundwork for the eventual restoration of anadromous fish to areas upstream of the project by: (1) 

providing relevant information; (2) improving habitat conditions in potential restoration areas; (3) 

constructing facilities that could be used to pass anadromous fish; and (4) increasing the number of fish 

available for restoration efforts. Measures in the first category include establishing a water quality 

monitoring station at the head of Brownlee reservoir; compiling water quality data from upstream parts of 

the basin; monitoring tributary habitat enhancements in the Burnt, Powder, Wildhorse, Indian, and Pine 

basins; monitoring habitat use by surplus hatchery steelhead and spring Chinook salmon in Pine and 

Indian creeks; and observing behavior and habitat use, as well as reproductive success, of surplus adult 

salmon and steelhead released in tributaries to support tribal and recreational harvest fisheries. Measures 

in the second category include tributary enhancements in the five basins listed above and dissolved 

oxygen enhancement measures that are implemented upstream of Hells Canyon dam. Measures in the 

third category include improvement of the adult trapping facility at Hells Canyon dam; installation of a 

trap and weir (operable year-round) in Pine Creek; and eventual installation of additional passage 

facilities at Oxbow dam, Indian Creek, and the Wildhorse River. Measures in the fourth category include 

flow augmentation, continuation of the fall Chinook spawning and incubation flow program, measures to 

improve dissolved oxygen and total dissolved gas levels, implementation of seasonal ramp rate 

restrictions, and construction of a new spawning and incubation facility for steelhead and Chinook salmon 

on the Yankee Fork in the Salmon River basin. 

In section 3.6.2.6, Anadromous Fish Restoration, we present a phased fish passage plan that 

would lead to the reintroduction of steelhead and spring Chinook into the tributaries of the project 

reservoirs. We estimate the annualized cost of developing and implementing this plan at $1.7 million, 

assuming that all phases are implemented in a sequential manner over a 32-year period.125 We received 

 

125 Our cost estimate assumed that 5 years would elapse between the construction of each major 

upstream and downstream passage facility. Under this timeline, installation of the Powder River 

smolt trap would not occur within the next 30 years, so the cost of this facility is not included in our 

estimate. 

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few comments on the approach that we described. ODFW commented that the timeline for restoring 

anadromous fish to the Powder River tributaries was too long. ODFW and other parties also provided 

information indicating that habitat within some tributaries, especially in Pine Creek and some tributaries 

to the Powder River, currently support native resident salmonids and are currently suitable to support 

anadromous fish. However, given the potential effects of anadromous fish restoration on other water 

users in these tributaries, we maintain that the concerns of these stakeholders would need to be addressed 

before restoration of anadromous fish to project tributaries is undertaken. This effort would also need to 

include consideration of the number of adult salmon and steelhead that such an effort would be likely to 

produce, given current or future survival rates that can be expected to occur in the migratory corridor 

downstream of Hells Canyon dam. Although efforts to improve the downstream migration survival of 

anadromous salmonid smolts through the lower Snake and Columbia rivers are ongoing, mortality during 

migration would likely continue to affect the potential benefits of undertaking a restoration, even in 

streams where habitat is in relatively good condition. Accordingly, we do not include this phased fish 

passage plan in the Staff Alternative. 

Many agencies, tribes, and NGOs also filed recommendations associated with reintroduction of 

anadromous fish above the project. These recommendations include specific monitoring and evaluation 

measures, evaluation of reservoir drawdowns for downstream passage (CTUIR-11a and 11c; 

AR/IRU-8e), developing alternative mitigation if reintroduction efforts fail (ODFW-20), a downstream 

passage and collection facility at Hells Canyon dam (ODFW-12), survival studies of downstream 

migrants (ODFW-14), and establishment of specific reintroduction targets (ODFW-2; BPT-7; SPT-3). 

For the reasons outlined above, we conclude that these recommended measures and their associated costs 

are premature and, accordingly, we do not include them in the Staff Alternative. 

Finally, we do not include recommendations made by the agencies, tribes and NGOs that relate to 

Pacific lamprey passage or restoration (AR/IRU-13, CTUIR-17, 18 and 19, IDFG-10, Interior-56 and 57, 

NPT-19 and ODFW-17 and 49). Although we recognize that the counting stations at downstream fish 

ladders are not fully effective for monitoring lamprey abundance, it appears that very few Pacific lamprey 

succeed in migrating upstream past the Lower Columbia River and Lower Snake River dams to reach the 

project area. Accordingly, we do not consider restoration of this species to the project area to be feasible 

in the near future, and we also conclude that the scarcity of the species is not caused by the existence or 

operation of the project. Also, it appears that existing screening technology may not be effective for 

providing downstream passage for lampreys, and as a result we are not able to estimate the cost of 

providing effective downstream passage for this species. 

We consider the effects of the Hells Canyon Project on the population size of Pacific lamprey to 

be limited. However, it is clear that the project blocks access to a substantial amount of habitat that was 

historically used by this species, and because larval lamprey burrow in fine sediment deposits, trapping of 

fine sediments in the project reservoir likely reduces the quantity and quality of rearing habitat 

downstream of the project. Accordingly, we consider it to be appropriate for Idaho Power to participate 

in regional forums on Pacific lamprey restoration to keep abreast of new information on the number of 

lamprey that are returning to use rearing habitat downstream of the project, and information on methods 

and approaches being developed to conserve and enhance this culturally and ecologically important 

species. In addition, we recommend that Idaho Power file a report with the Commission every 3 years 

summarizing the results of research activities that may affect the future potential for implementing 

measures to benefit Pacific lamprey in habitat that is blocked by the project or that is affected by its 

operation. The report should include information on the number of Pacific lampreys that have been 

collected in the Hells Canyon fish trap over the past 5 years and a description of any studies or measures 

to benefit Pacific lamprey that Idaho Power proposes to undertake in the next 5 years. We estimate the 

annualized cost of participation in regional forums and the recommended reporting effort to be $5,000, 

and recommend this measure in the Staff Alternative. 

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5.2.4.4 Resident Salmonid Passage 

Construction of the Hells Canyon Project has blocked upstream passage and impeded 

downstream movement of native resident salmonids, thereby isolating local populations, inhibiting fluvial 

life histories, and reducing access to additional habitat and thermal refugia. The primary native resident 

salmonid species of concern are redband trout and the federally listed bull trout. 

Idaho Power proposes a two-phased fish passage plan for transporting resident salmonids above 

Hells Canyon and Oxbow dams. The first phase would involve collecting bull trout, redband trout, and 

possibly other species in the Hells Canyon trap after it is modified (see section 3.6.2.7, Fish Passage 

Facilities) and transporting them to areas upstream of Hells Canyon dam. The second phase would 

involve the construction of a new trap, similar in operation and design to the Hells Canyon trap, at the 

base of the Oxbow dam to collect fish for transport upstream. However, because of uncertainty 

surrounding the intent of fish collected in the trap and the status of habitat in tributaries such as the 

Wildhorse River, Idaho Power proposes delaying construction of the Oxbow trap for a minimum of 5 

years following completion of the Hells Canyon trap modifications. Idaho Power also proposes to design, 

construct, and operate a permanent weir in Pine Creek to monitor the fluvial component of resident 

salmonid populations. 

Interior (Interior-45 and -59), the Forest Service (FS-32), IDFG (IDFG-11 and -13), and ODFW 

(ODFW-18 and -36a) make recommendations that are consistent with Idaho Power’s proposal to develop 

and implement a passage plan that would use the modified Hells Canyon trap and a newly constructed 

Oxbow trap to provide upstream passage for resident salmonids. The agencies, tribes, and AR/IRU also 

recommend that Idaho Power design, construct, and operate tributary weirs additional to the proposed 

Pine Creek weir (see section 3.6.2.6, Anadromous Fish Restoration). Prospective weir sites include 

Indian Creek, the Wildhorse River, and Eagle Creek. While it is the intent of these agencies, tribes, and 

NGOs that these weirs would be used to collect juvenile anadromous salmonids, they would also collect 

migrating native resident salmonids for transport to appropriate locations, as determined in a resident 

salmonid plan developed in consultation with the agencies and other stakeholders. The agencies also 

stipulate that the implementation of various plan components should be contingent upon the feasibility of 

passage measures and the suitability of habitat to which fish would gain access, as determined in 

consultation with the agencies and other stakeholders. To improve tributary habitat such that the 

translocation of resident salmonids would be beneficial, Idaho Power proposes, and the agencies and 

AR/IRU recommend, specific tributary habitat enhancement measures, which we address in the following 

section and describe in detail in section 3.6.2.10, Tributary Habitat Improvements. 

ODFW (ODFW-18) further recommends that Idaho Power conduct a population viability risk 

analysis of genetic and demographic costs incurred by donor and recipient bull trout populations. ODFW 

(ODFW-36b and 37) also recommends that Idaho Power investigate bull trout mortality associated with 

spill or turbine passage. 

In its preliminary fishway prescription, Interior (Interior-87) prescribed that Idaho Power develop 

a passage plan within 6 months of the issuance of a new license that would provide for the modification 

of the Hells Canyon fish trap to allow the collection of bull trout and the construction and operation of a 

weir at the mouth of Pine Creek, and identify specific habitat conditions that would trigger 

implementation of passage-related actions in Indian Creek, the Wildhorse River, and the Oxbow bypassed 

reach. Interior prescribes that the plan: (1) include specifications for construction and operation of 

permanent weirs and trap-and-haul fishways on these tributaries; (2) establish suitable upstream and 

downstream release points for adult and juvenile fish; (3) describe the location, functional design, and 

operating characteristics of all upstream and downstream fishways; and (4) include schedules and 

milestones for their timely modification, operation, and evaluation. Interior also prescribes that, within 

1 year of license issuance, Idaho Power develop a post-construction monitoring plan and implementation 

schedule to monitor fishway effectiveness. 

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In response, Idaho Power submitted an alternative section 18 prescription that, like Interior’s 

prescription, would proceed with modifying the Hells Canyon fish trap and construction of the Pine Creek 

weir. For the Oxbow fish trap and the Indian Creek and Wildhorse River weir and trap fishways, 

however, Idaho Power specifically identified the types of triggers that would be included in its passage 

plan to control the timeline of construction. Under Idaho Power’s alternative prescription, these triggers 

would be based on the status of bull trout within these tributaries in terms of their abundance, the 

potential for hybridization with non-native brook trout, the potential of the fishways to contribute toward 

recovery, and habitat conditions necessary to support bull trout. Idaho Power’s alternative prescription 

also specifies that development of functional designs and monitoring plans would not be initiated until the 

trigger criteria for a facility have been met. The plan would also include: (1) final engineering design 

plans for modification of the Hells Canyon fish trap and the Pine Creek monitoring weir and trap, as well 

as operating protocols; (2) locations of release points and handling of all lifestages of bull trout and other 

fish collected at the two facilities; (3) provisions for bull trout transport between Pine Creek and Hells 

Canyon dam; (4) an assessment of monitoring needed to evaluate the risk of introducing deleterious 

pathogens; and (5) a post-construction monitoring plan. 

Interior incorporated the trigger elements from Idaho Power’s alternative section 18 prescription 

in its modified fishway prescription filed with the Commission on January 3, 2007. The three primary 

differences from Idaho Power’s alternative and Interior’s modified prescription that remain are: 

(1) Interior’s modified prescription maintains language regarding the need for appropriate attraction flows 

in the Oxbow bypassed reach when the Oxbow dam fish passage facility is constructed; (2) the modified 

prescription specifies that the Pine Creek weir and fish trap would be constructed within 2 years of license 

issuance; and (3) Interior states that the period of operation for downstream passage facilities would be 

developed based on further monitoring efforts. 

We agree with the approach identified by Idaho Power and included in Interior’s modified 

prescription of establishing a more detailed set of triggers that must be met before the Oxbow fish trap 

and the Indian Creek and Wildhorse River weirs would be constructed. Inclusion of these more detailed 

trigger points would be more cost-effective and help ensure that the facilities would provide a biological 

benefit. In addition, developing functional designs and monitoring plans after trigger criteria for a facility 

have been met would allow experience and knowledge gained from early phases of the program to be 

applied to maximize the effectiveness of any facilities that would be constructed. In addition, we agree 

that there is a need to ensure that flows in the Oxbow bypassed reach are sufficient to allow upstream 

migrating bull trout to access the upstream passage facility at Oxbow dam after it has been constructed. 

We agree with Interior that there is no need to delay construction of the Pine Creek weir beyond 2 years 

after license issuance, and that information on the timing of bull trout movements gained from monitoring 

at the Pine Creek weir would help determine appropriate periods of operation for the facilities that would 

be constructed later based on the trigger criteria. Finally, we note that there is insufficient information at 

this time about the migration timing of bull trout to identify the period of operation prior to construction 

of the Pine Creek weir and trap fishway. 

Interior’s modified prescription includes a provision that the licensee employ all measures 

necessary and appropriate to facilitate effective upstream and downstream fish passage over the full range 

of river flows for which the project maintains operational control. However, it is unclear what flow range 

the weir and trap fishway on Pine Creek would be designed under, since Idaho Power does not have 

operational control over the flows in Pine Creek. Because there is limited information available on the 

timing of bull trout movements into and out of Pine Creek, we recommend that the Pine Creek weir and 

trap fishway be designed to provide effective downstream passage over a wide range of flows 

(encompassing the range of flows that occur at least ninety percent of the time in an average water year). 

This would also allow monitoring of the reproductive success of surplus hatchery steelhead and spring 

Chinook that enter Pine Creek, which would help to evaluate the efficacy of this measure for improving 

forage for bull trout. 

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667 

As recommended by ODFW (ODFW-18), a risk analysis that considered the genetic and 

demographic effects of increased immigration and emigration would be useful in developing procedures 

for translocation within the fish passage plan. However, we conclude that the demographic and genetic 

benefits of transferring fish that are collected in adult traps or tributary weirs to upstream or downstream 

populations can be considered based on the population data collected by Idaho Power in its licensing 

studies, which includes information on the distribution and abundance of bull trout populations and the 

abundance of brook trout and brook trout hybrids. Furthermore, Idaho Power would collect additional 

information on population demographics through trigger-related monitoring efforts under Interior’s 

modified fishway prescription, which we include in the Staff Alternative. 

ODFW also recommends (ODFW-36b and 37) that Idaho Power evaluate mortality associated 

with spill and turbine passage. Depending on the release locations of bull trout collected in the dam traps 

or tributary weirs, evaluating turbine or spill mortality would help to quantify any losses associated with 

these passage routes. This information would be useful for guiding decisions on optimal release locations 

for fluvial fish that are collected as they emigrate from project tributaries. For example, radio telemetry 

studies conducted by Idaho Power found that dam passage was not observed for any of the six radiotagged bull trout that were released into the project reservoirs, and all six of the redband trout that passed 

a project dam did so during periods when the project was spilling.126 Nonetheless, we add the cost of 

additional radio telemetry studies as a component of the post-construction facility evaluations and triggerrelated monitoring associated with Interior’s modified fishway prescription, which we include in the Staff 

Alternative. 

The provision of passage for native resident salmonids within the project would reestablish 

connectivity among currently isolated populations. Due to small population sizes and obstructed 

immigration and gene flow between populations, bull trout populations are particularly vulnerable to the 

effects of environmental variations such as low water years and hot meteorological conditions. Providing 

passage between isolated tributaries and the Snake River would enhance fluvial life histories. Likewise, 

providing passage would allow bull trout to access additional thermal refugia and forage, as well as 

spawning and rearing habitat. Collectively, these additional resources could result in increased growth, 

fecundity, and egg deposition and, consequently, abundance. Although redband trout populations are less 

sensitive to environmental variation, they would similarly benefit from increased connectivity. 

We estimate the annualized cost of the FWS modified fishway prescription to be $1,974,300, and 

the cost of Idaho Power’s alternative fishway prescription to be $1,464,900.127 The cost of the FWS 

modified prescription is greater than Idaho Power’s alternative because we have assumed that the Pine 

Creek weir and trap fishway would be designed to function over a wider range of flows than the weir that 

would be constructed under Idaho Power’s alternative prescription. Constructing the Pine Creek weir and 

trap to function at a greater range of flows would enable monitoring of bull trout emigration to occur over 

most of the year, and would also enable the weir to be used to evaluate the reproductive success of any 

surplus hatchery steelhead and spring Chinook that enter Pine Creek to spawn. We conclude that these 

benefits would warrant the cost difference of $509,400 in annualized costs, so we include Interior’s 

modified fishway prescription in the Staff Alternative. 

 

126 In the final EIS, we expanded the text of section 3.6.1.4, Native Resident Salmonids, to include the 

results of this study. 

127 For Idaho Power’s alternative condition and Interior’s modified prescription, we assume that the Pine 

Creek weir and trap fishway would be constructed 2 years after license issuance, that the Indian Creek 

weir and trap fishway would be constructed 10 years after license issuance, and the Oxbow adult trap 

and the Wildhorse River weir and trap fishway would all be constructed 20 years after license 

issuance. 

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5.2.4.5 Tributary Habitat Improvements 

As discussed in the preceding section, construction and operation of the Hells Canyon Project has 

adversely affected bull trout and redband trout populations in the project area, primarily through a loss of 

habitat connectivity. These species require access to high quality tributary habitat for every life stage and 

life history. Through a variety of causes, resident salmonid habitat in tributaries to the project has been 

degraded. The project has contributed to the degradation of habitat quality and ecological function by 

inundating low-gradient sections of the tributaries, precluding anadromous fish from contributing 

nutrients and forage important for supporting bull trout, and reducing connectivity among bull trout 

populations due to adverse water quality conditions in project reservoirs. 

As part of its proposed native salmonid plan, Idaho Power proposes to prepare and implement a 

Tributary Enhancement Plan targeted to benefit bull trout within the project area (Pine Creek, Indian 

Creek, and Wildhorse River basins and smaller tributaries to project reservoirs). This plan would include 

a Technical Advisory Committee that would work with landowners adjacent to the tributaries to identify, 

prioritize, and recommend actions needed to improve bull trout habitat. Specific measures that would be 

considered in the plan include: (1) construction of irrigation diversion screens; (2) conservation easement 

agreements; (3) construction of riparian corridor fences (implementation of this measure would also 

depend on landowner maintenance agreements); (4) purchase or lease of water rights from willing sellers 

(these water rights would have to be those that can be demonstrated to provide improved instream flow in 

critical areas, especially those extending the coldwater refuge potential near the upper portions of streams 

that serve as spawning and rearing areas, and would apply only in Oregon tributaries); (5) land acquisition 

along key riparian corridors; and (6) instream habitat enhancement measures in critical spawning and 

rearing areas. The native salmonid plan would also include provisions for brook trout eradication in 

Indian Creek, a presence/absence survey in Eagle Creek (Powder River basin), and restoration of stream 

nutrients through distribution of salmon carcasses or alternative nutrient supplements within known 

rearing areas in the Pine-Indian-Wildhorse core area. We evaluate Idaho Power’s proposed measures in 

more detail, along with related recommendations received from ODFW, IDFG, Interior, and AR/IRU, in 

section 3.6.2.10, Tributary Habitat Improvements, and in section 3.3.2.11, Marine-Derived Nutrients. 

Bull trout are extremely sensitive to environmental change because of their specific habitat 

requirements. Water temperature, in particular, may be the most critical factor affecting the suitability of 

habitat for bull trout. The prospective habitat enhancement measures proposed by Idaho Power and 

recommended by the agencies would reduce the effects of water- and land-use practices that alter stream 

temperatures. Depending on the scope of the measures taken, curtailing certain land-use practices and 

increasing instream flow would also indirectly enhance physical instream habitat by increasing woody 

debris contribution and vegetative cover, reducing erosion and sedimentation, enhancing natural 

geomorphological processes, and increasing wetted area. Measures targeted directly at enhancing 

physical habitat have the potential to increase population abundance by increasing the amount of 

spawning, rearing, and adult habitat available to bull trout. Although redband trout have generally lessspecific habitat requirements, the proposed and recommended physical habitat enhancement measures 

would similarly enhance habitat for this species as well. Reestablishing connectivity among tributary 

populations by eliminating barriers and reducing entrainment by screening irrigation diversions would 

improve the health of the fluvial component and increase the viability of resident bull trout 

subpopulations. 

The bull trout populations that constitute the Hells Canyon Recovery Unit include the Pine-, 

Indian-, and Wildhorse core area and the Powder River core area. These core areas contain local 

populations, and are areas identified as containing potential spawning and rearing habitat. ODFW 

(ODFW-38) recommends that the habitat enhancement efforts include the Pine, Powder and Burnt river 

basins, and IDFG (IDFG-16) recommends that tributary habitat enhancement measures include the 

Weiser River. Idaho Power’s Tributary Enhancement Plan would include improvements in the Pine 

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Creek, Indian Creek, and Wildhorse River basins, but would not include measures in the Burnt, Powder 

or Weiser river basins. 

In the draft EIS, we adopted Idaho Power’s proposed Tributary Enhancement Plan, on the basis 

that the three basins identified by Idaho Power have the greatest potential for restoring connectivity 

among bull trout populations among the basins that are directly affected by the project. We did not 

recommend that the measure extend into the Weiser, Powder, or Burnt River basins based on our 

understanding of a limited potential for restoring connectivity among bull trout populations and the more 

limited effect of the project on habitat in tributaries upstream of the project. 

During the 10(j) meeting, ODFW expressed strong interest in the restoration of redband trout in 

the Burnt and Powder River basins, and stated that they anticipate bull trout would be found in Eagle 

Creek (a Powder River tributary) during Idaho Power’s proposed presence/absence survey. Also, a tribal 

representative present at the meeting outlined the cultural importance of native resident salmonids, 

including redband trout, which were relied on by the tribes when anadromous fish were not available. 

Impacts of the project on redband trout in the Powder and Burnt rivers are similar to the impacts on bull 

trout in the Pine, Indian and Wildhorse basins, through inundation of part of each stream and reduced 

connectivity between populations due to poor water quality conditions in Brownlee reservoir. Based on 

these considerations, we revised the Staff Alternative to include enhancement efforts in portions of these 

river basins where there is strong potential for rebuilding populations of redband and/or bull trout. We 

recognize that streams upstream of Brownlee reservoir, including the Weiser River, have been affected by 

the loss of anadromous fish, but the physical habitat in these streams has not been directly affected by 

project construction. Consequently, we find that there is less justification to include the Weiser River in 

the program. 

Idaho Power’s proposed tributary enhancement program would have a total capital cost of 

$8.5 million. Although Idaho Power did not specify a time frame for implementation, its response to AIR 

DR-4 indicates that the funding would be allocated in year 1, which equates to an annualized cost of 

$928,400. ODFW recommends that Idaho Power contribute $750,000 annually over the term of the 

license. IDFG does not specify a recommended amount of funding. To estimate the cost of staff’s 

recommendation, which would include enhancement efforts in the Pine, Indian, Wildhorse, Powder, and 

Burnt river basins, we used Idaho Power’s proposed funding level to estimate an average cost per square 

mile of drainage area for the Pine, Indian and Wildhorse basins, and for the Powder River we applied that 

cost per square mile to the drainage area of key tributaries identified by the agencies for restoration efforts 

(Eagle, Goose and Daly Creeks). We assumed that enhancement efforts in the Burnt River basin would 

be focused in tributaries with a similar drainage area as the Powder River tributaries. For five basins we 

assumed that expenditures would be spread out over a 10 year period, resulting in a total annualized cost 

of $1,466, 700. We have also assumed that this funding level would encompass a level of monitoring 

appropriate for guiding future enhancement efforts. 

Implementing staff’s recommended tributary habitat enhancement program would help 

reestablish connectivity among redband and bull trout populations, increase available habitat and 

population sizes, and increase the viability of subpopulations of native resident salmonids within the Pine, 

Indian, Wildhorse, Powder and Burnt river basins. Because of the substantial benefits that would be 

provided to these valuable resources, we conclude that the benefits of implementing the staff-developed 

measure would justify its costs. 

Idaho Power proposes to assemble an interagency and landowner team to help identify 

opportunities to enhance bull and redband trout populations within these basins, prioritize measures, 

develop an implementation plan, and monitor the effectiveness of implemented measures. The committee 

should include landowners and representatives from any state or federal agencies involved in the 

management of areas selected for enhancement, fisheries management agencies (ODFW, IDFG, FWS and 

NMFS), interested tribes, and a representative from the conservation groups.

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Idaho Power’s proposed bull trout presence/absence survey in Eagle Creek would have an 

annualized cost of $42,700. Such a measure would further bull trout conservation efforts by improving 

knowledge of the species distribution and assist with identifying appropriate enhancement measures that 

could be implemented through the Tributary Enhancement Plan. We conclude that the benefits of the 

survey would justify its cost. 

AR/IRU (AR-IRU-11b) and Interior (Interior-41) recommend that anadromous fish be 

reintroduced upstream of Hells Canyon dam as a means to increase forage opportunities for bull trout. 

ODFW (ODFW-39) and IDFG (IDFG-17) recommend that nutrient supplementation be implemented in 

tributaries to improve forage opportunities for bull trout. As we discuss in section 5.2.4.3, Anadromous 

Fish Restoration, we conclude that until a comprehensive resource or recovery plan is put forward for 

restoring anadromous fish upstream of Hells Canyon dam, it would not be prudent to advocate for the 

restoration of steelhead, spring Chinook salmon, or fall Chinook salmon populations upstream of the 

Hells Canyon Project. 

As discussed in section, 5.2.4.8, Hatchery Production, and section 5.2.4.3, Anadromous Fish 

Restoration, we recommend that Idaho Power consult with the agencies and tribes to determine how to 

make the best use of surplus hatchery steelhead and spring Chinook salmon, which may include 

transporting fish for release into the project reservoirs to improve forage opportunities for bull trout, to 

evaluate anadromous fish production potential in Pine Creek, and to support tribal and recreational 

harvest fisheries. 

Idaho Power’s proposal and the resource agency recommendations to supplement nutrients in 

tributaries using spawned salmon carcasses or nutrient analogs would serve to replace much needed 

nutrients lost from the system and would increase growth rates, and consequently fecundity, of bull trout 

and redband trout. Idaho Power’s proposed plans for nutrient enhancement would have an annualized 

cost of $40,000. Because the measure would provide substantial benefits to bull trout at a reasonable 

cost, we include this measure in the Staff Alternative. Also, carcass plants could be included in the 

tributary enhancement program for Eagle Creek if bull trout are found there during the proposed 

presence/absence survey. 

Hybridization and competition with nonnative brook trout poses a serious risk to overlapping bull 

trout populations. Hybridization reduces the fertility and survival of progeny, and brook trout may outcompete and displace bull trout when resources are limited. Any action that limits hybridization by 

eliminating or reducing brook trout numbers could reduce the risk of extirpation of bull trout populations. 

Idaho Power’s proposed brook trout eradication effort could allow brook trout populations in Indian 

Creek to be brought under control before bull trout passage to this tributary is restored, which would 

substantially improve the benefits of providing passage. Idaho Power’s proposed plans for brook trout 

eradication in Indian Creek would have an annualized cost of $51,700. Because of the benefits to be 

derived by the federally listed bull trout at a reasonable cost, we include Idaho Power’s proposed brook 

trout suppression efforts in the Staff Alternative. 

5.2.4.6 Fish Pathogen Assessment 

Prospective measures to restore anadromous fish, improve connectivity among resident fish 

populations, and supplement marine-derived nutrients through carcass outplants have the potential to 

introduce fish pathogens to areas within and upstream of the project. These pathogens could adversely 

affect resident fish populations, including the federally listed bull trout. 

Before implementing prospective passage measures, Idaho Power proposes to develop, fund, and 

implement a pathogen risk assessment plan for the Pine, Indian, and Wildhorse Core areas, after 

consultation with ODFW and IDFG fish pathologists. Following an initial assessment of pathogen risks, 

Idaho Power proposes follow-up surveys at 5-year intervals if the initial risks associated with upstream 

passage were deemed acceptable and passage was provided. 

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IDFG, AR/IRU, and the Shoshone-Bannock Tribes (IDFG-12 and AR/IRU-7d and 9c) support 

Idaho Power’s proposal, but IDFG recommends that Idaho Power begin consultation with the IDFG Fish 

Health Laboratory prior to issuance of a new license to discuss potential pathogens, sampling protocols, 

and priority sampling locations. Although supporting the measures proposed by Idaho Power, ODFW 

(ODFW-21) recommends the expansion of pathogen surveying and monitoring to both native resident and 

anadromous populations above, within, and below the project. In addition, ODFW recommends that the 

development of a pathogen assessment plan take place in the first year, and initial assessment in the third 

year, following issuance of a new license. ODFW also recommends that Idaho Power provide funding for 

a fish health specialist, supplies, and services associated with production of hatchery fish and the fish 

passage program, as well as fish health examination and storage areas. In its April 10, 2006, submittal to 

the Commission, Idaho Power defines the scope of the proposed pathogen assessment as including the 

Snake River downstream of Hells Canyon dam (including the Imnaha River), Hells Canyon reservoir, and 

Oxbow reservoir during initial passage and restoration efforts. 

By increasing the connectivity among currently isolated native resident salmonid populations, 

fish passage measures proposed by Idaho Power would increase the risk of pathogen transfer among these 

populations. As part of Interior’s modified fishway prescription, which we include in the Staff 

Alternative, the bull trout passage plan would include an assessment of monitoring needed to evaluate the 

risk of introducing deleterious pathogens. We assume that the effort would include monitoring of 

pathogens among salmonid populations every 5 years, as proposed by Idaho Power. The annualized cost 

of this expanded measure is estimated at $107,100, $72,400 more than Idaho Power’s proposed plan. We 

include this cost within our estimate of the cost of Interior’s modified prescription, and we conclude that 

the increased cost is justified by the expected benefits. 

5.2.4.7 Oxbow Bypassed Reach Flows 

Diversion of flow through the Oxbow powerhouse reduces flow in the 2.5-mile-long bypassed 

reach immediately downstream of the dam, affecting the quantity and quality of habitat available to bull 

trout. Idaho Power currently releases a minimum flow of 100 cfs through the bypassed reach, and 

proposes to continue this release over the term of a new license. 

Interior (Interior-43) recommends that, within 1 year of issuance of a new license, Idaho Power 

develop and implement a plan to provide sufficient flow in the Oxbow bypassed reach to meet water 

quality standards and life history requirements for bull trout. The plan would focus on the duration, 

timing, and quantity of flow necessary to provide for the movement, foraging, and rearing of adult and 

sub-adult bull trout in the Oxbow bypassed reach, including unrestricted access to Pine and Indian creeks. 

Interior (Interior-63) also recommends that Idaho Power provide adequate flows and oxygen 

supplementation to maintain water quality parameters in the Oxbow bypassed reach. 

AR/IRU (AR/IRU-11c) recommend that Idaho Power provide sufficient flows in the Oxbow 

bypass to allow physical access to the proposed Oxbow fish trap, as well as to maintain adequate water 

quality for bull trout. 

The Oxbow bypassed reach currently provides overwintering habitat for bull trout and redband 

trout. However, high temperatures and low dissolved oxygen concentrations render this area unsuitable 

for native resident salmonids during warmer months when they typically seek refuge in Pine and Indian 

creeks. In section 3.5.2.5, Oxbow Bypassed Reach Flows, we note that the poor water quality conditions 

in this reach are largely a result of the water released from Oxbow reservoir and, at higher reservoir 

elevations, inundation from the upper end of Hells Canyon reservoir. Study results indicate that 

increasing flow would provide little improvement in water quality conditions in the bypassed reach. 

Further, we conclude that increasing bypass flow would not substantially increase the amount of habitat 

suitable for native resident salmonids because, although increasing flow would increase the wetted width 

of the bypassed reach, study results indicate that corresponding increases in velocity reduced the 

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suitability of available habitat. We estimate the effect of providing Interior’s recommended bypass flows 

to include a reduction in power benefits of $1.6 million per year.128 The annualized cost of providing 

oxygen supplementation, as recommended by Interior, would be $447,800. The overall net power benefit 

reduction would be $2.05 million. We do not include Interior’s recommendation in the Staff Alternative 

because the limited benefits to native resident salmonids do not warrant the high cost of this measure. 

We also conclude that increasing flows in the Oxbow bypassed reach would be unlikely to 

substantially improve water temperatures for native resident salmonids during the summer months. Also, 

based on the habitat modeling results from the instream flow study conducted by Idaho Power, we 

conclude that the proposed minimum flow release of 100 cfs maximizes the amount of overwintering 

habitat that is available for these species. Accordingly, we include Idaho Power’s proposed 100-cfs 

Oxbow bypass flow in the Staff Alternative. There is no incremental cost of this measure because it is 

part of the current operation. 

As we discuss in section 5.2.3.1, Dissolved Oxygen Measures, we adopt the installation and 

operation of a destratification system to reduce anoxic conditions that currently occur in a deep pool in 

the Oxbow bypassed reach. Although bull trout are unlikely to use the bypassed reach when temperatures 

become warm, it is possible that they could hold in deeper areas of the pool and be subjected to mortality 

when anoxic conditions occur. Destratifying the pool would reduce this potential source of mortality at a 

low annualized cost of $16,000. Accordingly, we adopt this measure in the Staff Alternative. As part of 

its modified section 18 fishway prescription, Interior (Interior-87) prescribed measures and operations 

necessary to provide adequate attraction flow to safely and rapidly attract bull trout into the Oxbow trap 

for collection and transport. We conclude that following construction of the Oxbow trap, radio-tracking 

studies would be necessary to demonstrate accessibility, and to ensure that a high percentage of fish are 

able to locate and enter the trap. We included costs for these types of post-construction facility 

evaluations along with monitoring related to triggers for their construction in Interior’s modified 

prescription, which we include in the Staff Alternative. Interior also expressed concern regarding the 

accessibility of Pine and Indian creeks to bull trout seeking refuge from the bypassed reach. These types 

of passage obstructions would be evaluated and addressed as part of Idaho Power’s proposed tributary 

habitat improvements, which we also include in the Staff Alternative. 

5.2.4.8 Hatchery Production 

Idaho Power’s hatchery system has been in operation since initial attempts to provide passage 

were discontinued several years after Brownlee and Oxbow dams were constructed. The intent of the 

hatchery production was to mitigate for the loss of upstream production of salmon and steelhead and 

provide fish for harvest. 

Idaho Power proposes to continue anadromous fish production at its hatchery facilities at the 

same levels specified in the 1980 Hells Canyon Settlement Agreement and the current license. This 

includes producing 3 million spring Chinook salmon smolts at the Rapid River Hatchery, 1 million 

summer Chinook salmon smolts at the Pahsimeroi Hatchery, 1 million fall Chinook smolts at the Oxbow 

hatchery, and 400,000 pounds of steelhead smolts. Idaho Power also proposes to make improvements to 

their hatchery facilities and to hire a full-time biologist to conduct monitoring and evaluation studies of 

their hatcheries’ performance. We summarize the proposed improvements and agency recommendations 

pertinent to hatchery production and operations in section 3.6.2.12, Hatchery Production. 

 

128 Our estimate is based on the following assumptions: (1) an additional 900 cfs would be required from 

May through October; (2) Idaho Power’s power factor of 0.0072 MW/cfs (Bowling and Whittaker, 

2005) would apply; and (3) the overall power value is $53 per MWh. 

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Idaho Power’s proposals and agency and tribal recommendations to upgrade, modify, and in 

some cases expand, its hatchery facilities or operations would increase efficiencies, capacities, and staff 

safety to better meet current and future production goals, as well as monitoring and evaluation 

requirements. Updating facilities with more current technology could also decrease fish handling stress 

and mortality. 

In the draft EIS, we recommended that Idaho Power develop a hatchery management plan. In 

final EIS section 3.6.2.12, Hatchery Production, we note that to conform with the requirements of the 

ESA, Idaho Power’s hatcheries need to be operated in compliance with Hatchery and Genetic 

Management Plans that would be developed by IDFG and NMFS. Under NMFS’s final 4(d) rule, the 

plans are required to include clearly stated goals, performance objectives, and performance indicators that 

define the purpose of the program, its intended results, and measurement of performance in achieving 

those results. Consultation among Idaho Power, the fisheries management agencies, and interested tribes 

to outline the goals and objectives for each hatchery would help ensure that such goals and objectives are 

accurately reflected in the Hatchery and Genetic Management Plans. This consultation also would help 

ensure that the Hatchery and Genetic Management Plans are consistent with Idaho Power’s 

responsibilities under a new license, as well as reflect the management goals of the agencies and tribes. 

Accordingly, we recommend that Idaho Power consult with these parties to define the goals and 

performance objectives for the plans that would govern operation of Idaho Power’s hatchery program. 

We also recommend that Idaho Power file the results of this consultation, annual reports on the hatchery 

program (including adult returns), as well as the draft and final Hatchery and Genetic Management Plans, 

with the Commission so that we can ensure that the plans and the overall hatchery program conform to 

license requirements. Because the 4(d) rule requires that hatcheries be operated in compliance with the 

plans approved by NMFS, we conclude that funding the implementation of measures included in the 

Hatchery and Genetic Management Plans is an appropriate component of Idaho Power’s responsibility. 

We estimate the incremental annualized cost of funding the development and implementation of the four 

Hatchery and Genetic Management Plans at $66,700. This would be in addition to the estimated $2.33 

million annual cost of Idaho Power’s hatchery proposals. We include Idaho Power’s hatchery proposals 

in the Staff Alternative, along with funding for the development and implementation of the Hatchery and 

Genetic Management Plans. 

We do not include recommendations made by Interior (Interior-48), and ODFW (ODFW-26) that 

would require Idaho Power to replace hatchery production goals based on smolt production with goals 

based on adult escapement or returns to sport and commercial fisheries. Replacing hatchery production 

goals with escapement goals to the hatchery or to fisheries would be difficult, given the external 

management and environmental factors that affect escapement success in any given year. As a result, we 

are not able to estimate the cost of Interior or ODFW’s recommended measures. 

The Shoshone-Bannock Tribes (SBT-4) recommend that Idaho Power develop two hatcheries in 

Yankee Fork and Panther Creek for the purpose of recovering wild stocks of sockeye and Chinook 

salmon and steelhead. Although the cost of these facilities would depend upon their size and production 

capacity, we concluded in the draft EIS that the annualized costs would likely exceed $1 million even for 

modest-sized hatcheries. The Yankee Fork, a tributary to the Salmon River near Sunbeam, Idaho, 

historically supported populations of spring/summer Chinook salmon. Panther Creek flows into the 

Salmon River east of the confluence of the Middle Fork Salmon River. Runs of Chinook salmon and 

steelhead in Panther Creek were largely eliminated as a result of mining activities in the drainage 

beginning in the 1940s. The tribes report that restoration activities have resulted in near complete 

restoration of these tributaries, and that they could again support native fish populations. Although we 

concluded in the draft EIS that habitat in the Yankee Fork and Panther Creek has not been directly 

affected by construction or operation of the Hells Canyon Project, we did not consider the fact that the 

project affects river flows and water quality conditions in the migratory corridor of Yankee Fork and 

Panther Creek salmonids downstream of the confluence of the Salmon and Snake rivers. These effects 

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include elevated total dissolved gas levels during high spill periods and reduced flows during the smolt 

outmigration period caused by flood control operations. 

During tribal consultation meetings held in March 2007 with the Shoshone-Bannock Tribes, the 

tribes indicated that they have been involved in extensive habitat restoration work on the Yankee Fork, 

including some out-planting of steelhead and Chinook salmon using streamside incubation boxes. The 

tribes also indicated that the state and federal hatcheries frequently do not have eggs available to support 

these efforts. They stated that of the two streams, the Yankee Fork is the stream where enhancement 

efforts would be most important to them. They also clarified that the focus of their program is on 

rebuilding the ESU, using low-tech techniques such as stream-side egg incubators to rebuild the number 

of wild-reared fish that return to the stream. We estimate that constructing and operating the facilities 

needed to spawn and incubate 1,000,000 salmon and steelhead eggs per year on the Yankee Fork would 

have an annualized cost of approximately $89,600.129 Based on survival rates estimated by Galindo and 

Rinehart (1998) for steelhead produced by the streamside incubator program, 1,000,000 eggs would result 

in the return of 2,060 adult salmon or steelhead to the Yankee Fork, contributing to rebuilding the ESU. 

In section 3.6.2.12, Hatchery Production, we discuss some of the benefits of the tribes’ 

streamside incubator program, which takes advantage of available instream habitat to cost-effectively rear 

smolts that are hardier and more fit to survive outmigration. Because of this improved migration survival 

and the relatively low cost of streamside incubators, the tribes’ program is likely to produce adult returns 

more cost-effectively than a program that produces hatchery-reared smolts. The fish that are produced 

through the tribes’ program are also more suitable for rebuilding the listed ESUs, and may contribute to 

their eventual delisting. Providing facilities for spawning and incubating eggs to the eyed stage would 

provide a more reliable source of eggs than existing sources, and thus improve the success of the tribes’ 

existing streamside incubator program. Because of the project’s effects on the migratory corridor, the 

cost-effectiveness of the measure, its potential for rebuilding the listed ESUs, and the cultural benefits to 

the Shoshone-Bannock Tribes, we conclude that construction and operation of low-tech spawning and 

incubation facilities on the Yankee Fork is warranted, and we include it in the Staff Alternative.130 We 

also recommend that Idaho Power include Yankee Fork hatchery production numbers in the annual report 

on its hatchery program. 

During tribal consultation meetings held on March 29 and March 30, 2007, the Burns Paiute and 

Shoshone-Paiute tribes expressed concern about the long-time line associated with restoration of 

anadromous fish to their ancestral fishing grounds upstream of the project. The Burns Paiute are 

particularly interested in anadromous fish restoration efforts on the Malheur River, and the ShoshonePaiute are interested in restoration efforts in the Owyhee River to establish subsistence and ceremonial 

fisheries. 

In the past, surplus adult spring Chinook salmon and steelhead returning to Idaho Power’s 

hatchery system have been used to support tribal and recreational fisheries. Between 1985 and 1990, a 

total of 6,617 surplus adult spring Chinook salmon were released into tributaries in the Salmon River 

basin including the Yankee Fork, Panther Creek, and the Lemhi River (Abbott and Stute, 2003). Between 

1966 and 2000, IDFG released a total of 45,588 surplus adult steelhead to support recreational fisheries in 

Hells Canyon reservoir and in the Boise and Payette rivers (Abbott and Stute, 2003). We have found no 

 

129 The $1 million cost estimate that we provided in the draft EIS was an order-of-magnitude estimate for 

a traditional hatchery that includes facilities for adult collection and holding, incubation, and concrete 

raceways for rearing fish to smolt size. Our revised cost does not include the facilities or operational 

costs associated with rearing, which occurs in the stream environment in the tribe’s streamside 

incubator program. 

130 We note that like Idaho Power’s other mitigation hatcheries, the Yankee Fork facilities would need to 

be operated in compliance with a NMFS-approved HGMP. 

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information in the record that indicates whether these practices have continued since 2000, or whether 

Idaho Power has borne the cost of transporting and releasing surplus hatchery spring Chinook salmon and 

steelhead in the past. Using surplus hatchery fish to provide fisheries to the tribes that historically fished 

in areas upstream of Hells Canyon dam would allow the tribes to resume subsistence and ceremonial 

fisheries that are clearly of substantial cultural importance.131 Idaho Power has indicated that it is 

prepared to make fish available, based on consensus reached among agencies and the tribes. We estimate 

that developing and implementing a plan to collect surplus anadromous fish that return to Idaho Power’s 

hatchery system or the Hells Canyon trap and to transport and distribute them to select tributaries in the 

project area and Snake River basin would have an annualized cost of $80,900.132 

Given the reasonable cost of the measure and the substantial benefits to be derived, we conclude 

that a plan to distribute surplus hatchery fish is warranted. Moreover, we realize there are many demands 

for these fish. In the draft EIS, we recommended that the hatchery management plans, as described 

above, address the distribution of surplus fish. We now recommend the development of a separate plan 

that addresses the use of surplus fish, and include the measure in the Staff Alternative. We recommend 

that the plan be developed in consultation with the Shoshone-Paiute, Burns Paiute, Shoshone-Bannock, 

and Nez Perce tribes. ODFW, IDFG, NMFS and Interior should also be consulted to ensure that actions 

implemented through the plan are consistent with fisheries management objectives, bull trout recovery, 

and other ongoing restoration efforts. 

5.2.4.9 Warmwater Fisheries 

Seasonal changes in water levels in Brownlee reservoir may affect the reproductive success of 

warmwater fish species including smallmouth bass, black crappie, white crappie, and channel catfish. 

These species support a substantial recreational fishery that is important to the economy of local 

communities. 

To promote spawning success for warmwater fish species, Idaho Power proposes to limit the 

drawdown of Brownlee reservoir during the spawning period. Beginning on May 21, reservoir spawning 

habitat would be protected for a 30-day period, during which time the reservoir would not be drafted more 

than 1 foot from the highest elevation reached during the 30-day period, although exceptions would be 

allowed for system or economic emergencies. From the end of the 30-day period though July 4, the 

reservoir could be drafted more than 1 foot, but an elevation of at least 2,069 feet msl would be 

maintained through July 4. Idaho Power also proposes to continue warmwater fish population monitoring 

to detect long-term effects on fish populations, including annual electrofishing surveys in all three project 

reservoirs and surveys in the Swan Falls-to-Brownlee reach every fifth year. 

ODFW (ODFW-51) and IDFG (IDFG-27) recommend the same operating constraints that Idaho 

Power proposes to protect warmwater fish spawning, although ODFW recommends that drawdown of 

Brownlee reservoir to levels below elevation 2,069 msl be allowed if flow augmentation (for salmon 

migration) occurs before July 4. ODFW also recommends that Idaho Power conduct annual creel surveys 

in all three project reservoirs (ODFW-50) and studies of the food habits of warmwater fish species, 

including the effects of reservoir operations on zooplankton production (ODFW-52). 

 

131 As identified in section 3.6.2.12, Hatchery Production, there are likely to be other benefits to outplanting surplus hatchery fish, including those associated with (1) adding marine nutrients to the 

system; (2) improving foraging opportunities for bull trout; (3) evaluating spawning success, egg 

viability and survival, and smolt outmigration and survival in Pine Creek; and (4) supporting 

recreational fishing opportunities in the project area. 

132 This estimate was based on the delivery of up to 30 truck loads of 50 to 300 adult spring Chinook 

salmon or steelhead to select tributaries in the project area from the Hells Canyon dam fish trap or 

from other traps that are part of Idaho Power’s hatchery system in the Salmon River basin. 

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In section 3.6.2.1, Effects of Project Operation on Aquatic Resources, we conclude that limiting 

reservoir fluctuation to a maximum of 1 foot from May 21 through June 20, as proposed by Idaho Power 

and recommended by ODFW and IDFG, would minimize adverse effects to smallmouth bass over their 

entire spawning season and limit adverse effects to crappie in the latter half of their spawning season. 

Limiting drawdown to elevation 2,069 (an 8-foot drawdown from full pool) through July 4 should protect 

early-spawning channel catfish but would afford little protection to later spawning fish, since their 

spawning period extends to the end of July and nests may remain active until mid-August. Our analysis 

of proposed and alternative operating scenarios, however, indicates that there is a relatively small 

potential for adversely affecting channel catfish, even with the drawdown associated with flow 

augmentation. 

Because the proposed limitations are similar to current operations, any incremental cost of this 

restriction would be negligible. Therefore, we include this Brownlee reservoir warmwater fish spawning 

protection measure in the Staff Alternative. 

To address the potential for conflict between this measure and other operating requirements in the 

Staff Alternative, and to address ODFW’s (ODFW-51) concern that the limitation not restrict flow 

augmentation releases, we also indicate in the Staff Alternative that the requirement for warmwater fish 

spawning protection would be secondary to any conflicting operational requirements. 

We do not include ODFW’s recommendations (ODFW-50 and ODFW-52) to conduct annual 

creel surveys in all three project reservoirs and to conduct studies of the food habits of warmwater fish 

species, including the effects of reservoir operations on zooplankton production. We conclude that, due 

to the inherent variability in creel surveys, Idaho Power’s proposed fish population monitoring effort 

using electrofishing techniques would provide more reliable information on the status of warmwater 

fisheries at a substantially lower cost. We also see no benefit to conducting a food habits study of 

warmwater fish species. Based on fish condition factors measured in Idaho Power’s studies, it appears 

that warmwater fish populations are not limited by food supply. We do not see how either of these 

measures would provide any benefit to reservoir fisheries beyond the measures that are already proposed 

by Idaho Power. We estimate that ODFW’s recommendations would have an annualized cost of 

$278,500. 

In its comments on the draft EIS, ODFW expresses support for staff’s recommendation for 

warmwater fish monitoring, as long as Idaho Power coordinates annually with ODFW and includes 

appropriate sampling techniques for monitoring the abundance of channel catfish, a species identified in 

Idaho Power’s angler survey effort as important for anglers. During the 10(j) meeting, Idaho Power 

indicated that its sampling effort could be modified to include gill netting to sample catfish at minimal 

additional cost. This is a minor adjustment in staff’s recommendation for warmwater fish monitoring that 

would yield valuable information on the project’s fisheries. The measure could be implemented at little 

additional expense. 

In its comments on the draft EIS, Interior reiterates its recommendation (which we discuss in 

section 3.10.2.11, Warmwater Fisheries Management Plan) that Idaho Power be required to: (1) 

implement an adaptive management program to identify impacts of project operations on the warmwater 

fishery; (2) develop a mitigation plan for any impacts as the result of project operations; and (3) consult 

with BLM to ensure that recreational fisheries are provided wherever possible. Based on our analysis in 

sections 3.6.2.1, Effects of Project Operations on Aquatic Resources, and 3.10.2.1, Effects of Project 

Operations on Recreation Resources, we conclude that the warmwater fishery (especially for crappie) is 

affected primarily by the type of water year due to flushing of fish from the reservoirs in high flow years. 

In addition, our analysis indicates that drawdowns for flow augmentation and power generation purposes 

have only a minor effect on the warmwater fishery. Moreover, our analysis shows that drawdowns for 

power generation purposes are relatively minor compared to those that occur for flood control, flow 

augmentation, or for the fall Chinook salmon spawning flow program. Drawdowns for each of these 

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purposes are necessary to support important project functions, including the protection and enhancement 

of federally listed fall Chinook salmon downstream of Hells Canyon dam. As noted above, we adopt in 

the Staff Alternative Idaho Power’s proposal to limit drawdowns during the crappie spawning period to 

avoid nest dewatering. We conclude that limiting drawdowns during the crappie spawning period appears 

to be the only feasible operational measure that could improve the warmwater fishery without adversely 

affecting other major project purposes. However, annual consultation with the agencies on the results of 

warmwater fisheries monitoring efforts would provide a forum for the effects of project operations on the 

warmwater fishery to be considered, and may identify opportunities for reservoir levels to be managed in 

ways that reduce adverse effects on the warmwater fishery. 

5.2.4.10 Sturgeon Conservation Measures 

Construction of the Hells Canyon Project, 10 other dams on the Snake River downstream from 

Shoshone Falls, and other mainstem dams on the Columbia River has eliminated upstream connectivity 

and gene flow among sturgeon populations over most of their historical range in the basin. Idaho Power’s 

monitoring studies indicate that little or no recent recruitment has occurred in seven of the nine 

populations that are isolated by mainstem dams between Shoshone Falls and Lower Granite dam (refer to 

section 3.6.2.13, Sturgeon Conservation Measures). 

Idaho Power established a technical committee to address sturgeon conservation issues associated 

with its mainstem hydroelectric projects within the historical range of the white sturgeon, which includes 

the Hells Canyon Project and five upstream developments (Upper Salmon Falls, Lower Salmon Falls, 

Bliss, C.J. Strike, and Swan Falls). In consultation with the technical committee, Idaho Power developed 

a conservation plan that identifies the following conservation measures, which are part of Idaho Power’s 

proposal for the Hells Canyon Project: (1) assessment of water quality-related impacts on early life stages 

of white sturgeon in the Swan Falls to Brownlee reach; (2) translocation of reproductive-sized white 

sturgeon to the Swan Falls to Brownlee reach to increase spawner abundance and population productivity; 

(3) development of an experimental conservation aquaculture plan; (4) periodic population assessments; 

and (5) monitoring of genotypic frequencies. 

Recommendations by agencies, tribes, and NGOs relating to sturgeon conservation are 

summarized in section 3.6.2.13, Sturgeon Conservation Measures. The recommendations address Idaho 

Power’s proposed measures, but also identify several additional measures, including evaluating the need 

for passage or anti-entrainment measures, measures to improve water quality, monitoring of contaminant 

bioaccumulation, and changes in operations to improve reproduction at Idaho Power’s upstream projects. 

Regarding actions associated with the upstream Idaho Power projects, Article 407 of the licenses 

issued for the Upper Salmon Falls, Lower Salmon Falls and Bliss Projects and Article 408 of the license 

issued for the C.J. Strike Project require Idaho Power to develop a white sturgeon conservation plan to 

include appropriate measures for the protection and enhancement of white sturgeon in the Snake River. 

Idaho Power filed an updated version of the plan in compliance with these license articles in August 2005, 

which identified measures that would be implemented as part of Idaho Power’s mid-Snake projects. The 

Commission accepted the plan on May 31, 2006, with the addition of a requirement for filing annual 

reports on activities undertaken in the previous year. Accordingly, we do not include any measures 

associated with the upstream projects in the Staff Alternative. 

The results of Idaho Power’s sampling program indicates that the sturgeon population is 

particularly depressed in the Swan Falls dam to Brownlee segment and in all three of the Hells Canyon 

Project reservoirs. The lack of recruitment in the Swan Falls reach despite the presence of adult sturgeon 

and appropriate spawning habitat suggests that water quality conditions may be affecting spawning 

success or the survival of early lifestages. Idaho Power proposes a phased approach to rebuilding the 

white sturgeon population in the Swan Falls to Brownlee reach, which would start with studies to evaluate 

the effects of water quality conditions on spawning success and survival of early life-stages. Based on the 

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results of these studies, adult sturgeon would be translocated from a donor population, or, if current water 

quality conditions would not support natural reproduction, a conservation aquaculture program would be 

implemented to rebuild white sturgeon populations in the Swan Falls to Brownlee reach. Idaho Power 

does not propose any measures to rebuild sturgeon populations in the project reservoirs. 

In section 3.6.2.13, Sturgeon Conservation Measures, we conclude that implementation of a 

conservation hatchery program has the potential to rebuild sturgeon populations in the reaches between 

Swan Falls and Hells Canyon dams more rapidly than the translocation program proposed by Idaho 

Power. In the draft EIS, we did not include Idaho Power’s proposed translocation plan in the Staff 

Alternative. However, based on their comments on the draft EIS, we recognize that IDFG and ODFW 

have concerns about potential genetic implications of stocking hatchery fish. Thus, so that both 

approaches are fully considered, we include in the Staff Alternative a measure that would require Idaho 

Power to conduct a feasibility assessment to assess the risks and benefits of both the translocation and 

conservation aquaculture approaches, and to select the most appropriate approach for restoring white 

sturgeon populations in the reaches between Swan Falls and Hells Canyon dams. The feasibility 

assessment would be prepared in consultation with IDFG, ODFW, FWS and interested tribes, and would 

be filed with the Commission for approval. We estimate that the annualized cost of preparing the 

feasibility assessment would be $2,200. Because the aquaculture approach has the potential to provide 

greater benefits to tribal and recreational fisheries, we conclude that the cost of preparing the feasibility 

assessment is justified. If an aquaculture program appears feasible, Idaho Power would develop an 

aquaculture implementation plan that describes: (1) a schedule and an approach for broodstock 

collection; (2) rearing facilities and rearing methods; and (3) a release schedule. If the translocation 

approach appears to be more feasible, Idaho Power would develop a translocation implementation plan 

that describes the schedule and details of the program, including the number, size, and source of sturgeon 

to be translocated between reaches. In either case, the implementation plan would be developed in 

consultation with the fisheries management agencies and interested tribes, and would be filed with the 

Commission for approval. 

We estimate the annualized costs of implementing a sturgeon aquaculture plan to be between 

$28,000 and $42,000, depending on whether stocking is focused on the Swan Falls to Brownlee reach, or 

whether stocking in Oxbow and Hells Canyon reservoirs is included. We estimate the annualized cost of 

implementing Idaho Power’s proposed sturgeon translocation program to be $20,600. Implementing 

either approach would assist with rebuilding sturgeon populations in the reaches between Swan Falls and 

Hells Canyon dams, where populations are currently depressed. Because rebuilding sturgeon populations 

in these reaches would contribute to restoring valuable sturgeon fisheries, we conclude that implementing 

the approach that is selected based on a feasibility study is warranted. Therefore, we include such 

measures in the Staff Alternative. Idaho Power proposes to conduct population monitoring in each of the 

reaches between Swan Falls and Lower Granite dams at 10-year intervals. The population monitoring 

effort proposed by Idaho Power would help determine the effectiveness of implemented measures, as well 

as facilitate an assessment of whether any changes in approach are warranted for rebuilding populations 

of white sturgeon in reaches affected by the Hells Canyon Project. Accordingly, we conclude that the 

sturgeon population monitoring effort proposed by Idaho Power, which would have an estimated 

annualized cost of $95,900, is warranted, and we include it in the Staff Alternative. 

Idaho Power also proposes to assess the effects of water quality conditions on the early lifestages 

of sturgeon and to monitor the genetic makeup of sturgeon sampled during population monitoring. In the 

draft EIS, we concluded that these measures would not be needed if Idaho Power were to proceed directly 

with an aquaculture program. However, these studies would help to determine the feasibility, and guide 

the implementation, of a translocation approach for rebuilding white sturgeon populations. The water 

quality study would help Idaho Power, the resource agencies, and tribes assess the potential for achieving 

successful reproduction in the Swan Falls to Brownlee reach. Genetic monitoring would aid in assessing 

any effects of translocation on the genetics of sturgeon populations in each reach, and guiding any 

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adjustments that are needed. Although we typically view genetic studies to be a responsibility of the 

management agencies, in this case we recognize that genetic monitoring is an integral component of 

Idaho Power’s proposal, and would help guide the implementation of measures to address project effects 

on white sturgeon. We estimate that the annualized cost of conducting the study of water quality effects 

on early lifestages of sturgeon would be $24,000. The annualized cost of genetic monitoring would add 

$2,300 to the cost of the proposed population monitoring effort. Because these measures would assist 

with implementing and guiding measures designed to rebuild sturgeon populations and their cost would 

be relatively minor, we conclude that these measures are warranted and include them in the Staff 

Alternative. 

Several parties also recommended that the conservation plan be updated to include their 

recommendations (CTUIR-13, IDFG-24, Interior-51, NPT-18, ODFW-42), and Interior (Interior-52) 

recommended that Idaho Power develop an action plan to coordinate implementation. However, as 

discussed above, we recommend that Idaho Power prepare a feasibility assessment to assess the risks and 

benefits of translocation and conservation aquaculture approaches for restoring white sturgeon 

populations in the reaches between Swan Falls and Hells Canyon dams. We also recommend that as part 

of the sturgeon monitoring effort, Idaho Power hold annual meetings of the white sturgeon Technical 

Advisory Committee to review the results of monitoring and enhancement efforts, which we expect 

would guide future management efforts. Also, we recommend that Idaho Power file with the 

Commission an annual report on the approved monitoring and enhancement efforts, as well as any 

recommendations for revising the monitoring or enhancement measures, based on monitoring results. We 

conclude that these annual meeting and reporting efforts would be sufficient to guide and coordinate the 

implementation of appropriate sturgeon conservation measures at the Hells Canyon Project. Accordingly, 

we do not recommend that the white sturgeon conservation plan be updated or an action plan be 

developed at this time. 

We do not include AR/IRU (AR/IRU-12e) and Interior’s (Interior-50b) recommendations that 

Idaho Power evaluate the potential need for, and benefits of, implementing measures to protect sturgeon 

from entrainment and impingement. The potential for impinging juvenile sturgeon could increase 

substantially if trash rack spacing were reduced in an attempt to limit entrainment. Installing a fish 

screening system that provided sufficiently low velocities to limit the impingement of juvenile sturgeon 

would involve modifications with costs on the order of tens of millions of dollars for each development. 

We conclude that the conservation aquaculture program would provide a far more cost-effective means 

for rebuilding sturgeon populations to levels that would support viable recreational and tribal fisheries 

throughout the species’ historical range in the Snake River. 

We do not include AR/IRU or ODFW’s (AR/IRU-12d and ODFW-19) recommendations to 

conduct a study to determine whether white sturgeon passage is feasible and desirable. We conclude in 

section 3.6.2.13 that, due to a lack of proven technology, the construction of upstream passage facilities is 

not currently a viable means of restoring Snake River sturgeon populations or for maintaining the genetic 

variability. Further, we conclude that providing sturgeon passage, even if it were to become technically 

feasible, would not be as effective as a conservation aquaculture program for rebuilding sturgeon 

populations. 

In the draft EIS, we did not adopt ODFW’s recommendation (ODFW-43) that Idaho Power 

evaluate bioaccumulation of contaminants in white sturgeon in Hells Canyon and Oxbow reservoirs and 

between Brownlee and Swan Falls dams. We concluded that determining whether bioaccumulants are 

likely to inhibit sturgeon reproduction was not needed if sturgeon populations were to be rebuilt by 

stocking. We also concluded that monitoring contaminants in shorter-lived species would provide a 

better means of monitoring contaminant levels in the environment and assessing risks to the angling 

public and fish-eating wildlife. During the 10(j) meeting, however, the agencies and tribes noted that 

contaminant levels in sturgeon are a concern because the Nez Perce Tribe has a consumptive fishery, and 

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the potential effects on reproduction are important if a translocation approach for restoring sturgeon is 

considered. 

Although we acknowledge the potential benefits of monitoring bioaccumulants in sturgeon and 

warmwater fish species in Brownlee reservoir, we note that Idaho Power should not bear the full cost of 

this monitoring effort because they are not responsible for the introduction of these contaminants into the 

environment. However, it would require minimal effort for Idaho Power to collect tissue samples for 

analysis during its proposed monitoring of white sturgeon populations and warmwater fish species in 

Brownlee reservoir. Accordingly, we recommend that Idaho Power, if requested by IDEQ or ODEQ, 

collect tissue samples during the proposed sturgeon population monitoring efforts and make the samples 

available to the state agencies for their use in analyzing contaminant bioaccumulation. 

5.2.4.11 Invertebrate Monitoring 

The invertebrate community downstream of Hells Canyon dam includes a number of special 

status mollusk species. The composition of the aquatic invertebrate, periphyton and macrophyte 

communities serve as an indicator of water quality conditions as well as a food resource that is available 

to native species of fish, including juvenile fall Chinook salmon, bull trout, redband trout, and white 

sturgeon. Long-term monitoring can be useful for tracking ecological responses to changes in basin 

conditions and project operations, and the implementation of aquatic resource enhancement measures. 

Idaho Power does not propose any such monitoring efforts. 

AR/IRU (AR/IRU-14) recommend that an adaptive management approach be employed to assess 

and mitigate project effects to the benthic community in the Snake River within and downstream of the 

project. Interior (Interior-70, -71, -72 and -73) recommends several monitoring programs associated with 

a recommendation to evaluate a series of three operational modes. Interior also recommends 

establishment and monitoring of experimental populations of Hells Canyon rapids snail and short-faced 

limpet within 10 miles downstream of Hells Canyon dam (Interior-74), and of western ridged mussel in 

appropriate habitat (Interior-75). Monitoring of the experimental populations would be conducted during 

the three operational test periods and continued for the term of the license or as determined to be 

appropriate. 

We find it difficult to assess the potential benefits of AR/IRU’s recommendation without 

knowing what specific measures would be implemented. For this reason, we do not include this measure 

in the Staff Alternative. 

In the draft EIS, we concluded that Idaho Power had provided sufficient information to allow us 

to assess the effects of load following and other operations on aquatic resources, so we did not include 

Interior’s recommended multi-year study of operating modes in the Staff Alternative. However, 

comments received on the draft EIS include information suggesting the shallow water habitats that are 

most affected by load following operations may include areas that are especially important for some rare 

and sensitive species of mollusks and for invertebrate production. This information also suggests that 

dewatering of these areas may have a disproportionately large effect on the food supply that is available 

to fall Chinook salmon juveniles and bull trout. 

Idaho Power’s studies did not evaluate the effects of project operations on invertebrates in 

shallow areas along the Snake River downstream from Hells Canyon dam. If exposure of these shallow 

areas during load following operations adversely affects invertebrate production, as available literature 

suggests, this would affect the food supply for rearing fall Chinook salmon and other fish species 

including redband and bull trout. The reduction in growth rates of fall Chinook salmon observed in the 

Hells Canyon reach in recent years suggests that any reduction in the available food supply is likely to 

affect growth rates and survival of fall Chinook salmon. In addition, flow fluctuations could adversely 

affect habitat conditions for several sensitive species of mollusks. For these reasons, we recommend, as 

part of the Staff Alternative, that Idaho Power develop and implement an invertebrate monitoring plan. 

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The plan should be developed in consultation with state and federal fisheries agencies, and should include 

annual monitoring efforts in order to encompass a wide range of hydrologic and operating conditions. 

The plan should include annual reporting of the results of monitoring efforts, a description of any 

recommended adjustments to the monitoring effort, and a description of any measures that are identified 

by Idaho Power, the resource agencies, or tribes to address project effects on invertebrates, including 

sensitive mollusks. We estimate that the annualized cost of implementing the staff-recommended 

invertebrate monitoring plan would be $57,000. Because implementing the plan would improve our 

understanding of project effects and could lead to improved management of project operations in a way to 

benefit important natural resources, we conclude that the benefits of implementing the invertebrate 

monitoring plan warrants its cost. 

We do not concur, however, with the Interior and the Forest Service recommendations (Interior44 and -66 and FS-30) to establish specific study durations for baseline invertebrate sampling and for 

sampling with dissolved oxygen enhancement measures in place and with run-of-river operations. We 

conclude that a well-designed study program, with a year or more of baseline data, should be sufficient to 

document changes in the invertebrate community prior to dissolved oxygen implementation, and we 

expect that the schedule for implementing dissolved oxygen enhancement measures would be established 

in the 401 water quality certificate. We also conclude that a well-designed monitoring program could 

assess the effects of load following operations without imposing a multi-year test period of run-of-river 

operations. This can be accomplished by comparing and evaluating species composition and abundance 

in areas that have been dewatered at different frequencies over a range of hydrologic year-types, as part of 

the invertebrate monitoring plan included in the Staff Alternative. 

We see little benefit in Interior’s recommendation that Idaho Power establish experimental 

populations of Hells Canyon rapids snail, short-faced limpet, and western ridged mussel downstream of 

Hells Canyon dam. In section 3.6.2.15, Benthic Community Monitoring, we point out that a wide range of 

variables could affect the success or failure of an experimental population, and this approach is premature 

and would not be an effective or efficient way to monitor trends in habitat condition over time. However, 

staff‘s recommended invertebrate monitoring plan could include provisions for the reintroduction of rare 

and sensitive mollusks if the results of water quality monitoring indicate that habitat downstream of Hells 

Canyon dam has improved to a point where it is likely to support their reintroduction. 

5.2.5 Terrestrial Resources 

5.2.5.1 Special Status Plant and Wildlife Protection 

Idaho Power has documented the presence of a number of special status plants and animals in the 

project area.133 In section 3.7.2.2, Special Status Plant Protection, we conclude that project operations, 

project-related maintenance, management activities, and recreational activities have the potential to 

disturb rare plant populations or to disturb the habitat that supports them. Idaho Power proposes to 

establish a rare plant advisory board that would coordinate the efforts of resource management agencies, 

local landowners and land managers, and other interested individuals and organizations in protecting 

sensitive species within the river corridor between the headwaters of Brownlee reservoir and the Salmon 

River confluence. 

Additionally, Idaho Power identified 68 special status wildlife species in the project vicinity 

(section 3.7.2.8, Special Status Wildlife). Idaho Power does not propose to develop focused management 

plans for any special status wildlife species, but proposes to implement cooperative measures for 

 

133 Species with special status includes those that federal or state agencies have listed as threatened, 

endangered, proposed, or candidates for listing, and those designated as sensitive, rare, or in need of 

special management. 

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mountain quail and waterfowl, and has identified several specific projects needed to protect wintering big 

game, bald eagle nests and roosts, bat hibernacula, neotropical migrant songbirds, and colonial nesting 

waterbirds. 

Federal land managers (Interior and the Forest Service) and other parties provide numerous 

recommendations regarding the protection and management of special status species. We review these in 

sections 3.7.2.2, 3.7.2.8, and 3.8.2.8 through 3.8.2.12. They include Interior-34, a plan to manage 

threatened, endangered, and special status plants and wildlife on BLM-administered lands; Interior-78, a 

plan for sensitive plant species management; Interior- 80, a plan to manage mountain quail; Interior-81, a 

plan to manage bald eagles; Interior- 82, a plan to manage southern Idaho ground squirrels; Interior- 83, 

incorporating bat protection measures into the Integrated Wildlife Habitat Program and Wildlife 

Mitigation and Management Plan; Interior-84, a plan to manage northern Idaho ground squirrels; and 

Interior-85, incorporating amphibian and reptile protection measures into the Integrated Wildlife Habitat 

Program and Wildlife Mitigation and Management Plan. 

The Forest Service also provided conditions to guide protection of special status plants and 

animals. Forest Service preliminary 4(e) condition no. 8 specifies a strategy for managing and monitoring 

threatened and endangered species on National Forest System lands affected by the project. Forest 

Service modified 4(e) condition no. 9 specifies a plan for managing sensitive species on National Forest 

System lands affected by the project. 

Additionally, IDFG-33 indicates support of Idaho Power’s approach to special status plants. 

ODFW-65 addresses a plan to manage threatened, endangered and sensitive plants and wildlife. ODFW34 calls for a bald eagle management strategy.

Based on our analysis of Idaho Power’s proposals and agency recommendations, we identified in 

the draft EIS the need to consolidate the various proposals into a single project-wide Threatened, 

Endangered, and Sensitive Species Management Plan covering Forest Service, BLM, and Idaho Power 

lands within the project boundary and at locations directly affected by project operations, including along 

the river downstream of Hells Canyon dam. The Threatened, Endangered, and Sensitive Species 

Management Plan would have both plant and wildlife elements. 

In the draft EIS, we recommended that Idaho Power consult with FWS, the Forest Service, IDFG, 

ODFW, the tribes, and other interested parties to develop and implement a Threatened, Endangered, and 

Sensitive Species Management Plan. Our recommendation remains the same in this final EIS. The 

purpose of the plan would be to protect and manage threatened, endangered, and sensitive species and 

their habitats that may be affected by project operation or project-related activities. Idaho Power has 

already completed a literature review, including searches of agency databases; compiled a large amount 

of information about threatened, endangered, and sensitive species in the vicinity; conducted extensive 

field surveys; analyzed and rated threats to threatened, endangered, and sensitive species resulting from a 

variety of factors; developed preliminary recommendations for many project-wide BMPs and site-specific 

protective measures; and is in the process of developing a GIS database to track threatened, endangered, 

and sensitive species and habitat in relationship to project facilities and activities. The Threatened, 

Endangered, and Sensitive Species Management Plan should bring this information together to serve as a 

foundation for future monitoring and management efforts. 

In their comments on the draft EIS, several agencies requested that we clarify the nature of the 

plan envisioned in the Staff Alternative and indicate which species we intend for the plan to address. The 

paragraphs below respond to these comments, providing additional framework and detail for the plan. At 

a minimum, we recommend that the plan include the following elements: 

• Initial species list—The initial list should include threatened, endangered and sensitive 

species that occur within the project boundary or on lands affected by project operation or 

project-related activities, as shown in table 106. For each species, the list should reference 

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the relicensing studies that documented occurrence and/or evaluated project effects. The list 

should be accompanied by maps showing locations of threatened, endangered, and sensitive 

species and habitats in relation to project features. 

• Updating the species list—The plan should provide for annual consultation, review, and 

updating of the list. Species would be added or removed according to changes in their status 

or changes in the potential for project effects (e.g., construction of new facilities). 

• Conducting baseline surveys—The plan should provide for baseline surveys of species 

currently on the list if no surveys have been completed at sites where project operations or 

project-related activities could affect them. Baseline surveys should also be conducted for 

species that may be added to the list if they occur at sites where the project could affect them. 

• Preparing biological evaluations—Where Forest Service Sensitive species may be affected, 

Idaho Power should consult with the Forest Service to prepare a draft biological evaluation, 

in accordance with modified 4(e) condition no. 1 (Implementation of Activities on National 

Forest System Lands). 

• Monitoring project effects—For Forest Service Sensitive species, the plan should include 

monitoring to identify project effects at confirmed sensitive species sites every 2 years for 

6 years following license issuance and at 3-year intervals thereafter, unless a determination 

can be made at year 6 that no additional monitoring is necessary. For bald eagles, Idaho 

Power should conduct annual nesting, productivity, and winter surveys. For other threatened, 

endangered, and sensitive species, Idaho Power should consult with the agencies and tribes to 

determine an appropriate monitoring frequency, based on site-specific conditions. 

• Implementing protective measures—The plan should provide for designing and implementing 

protection, mitigation, enhancement or restoration measures if monitoring results show 

project-related effects. 

• Effectiveness monitoring and adaptive management—The plan should include follow-up 

monitoring to measure the effectiveness of any protective measures that are implemented, and 

use of this information to modify and improve the Threatened, Endangered, and Sensitive 

Species Management Plan. 

• Consultation, reporting, and updating the Threatened, Endangered, and Sensitive Species 

Management Plan—The plan should provide for annual reporting and consultation, with 

updates to the plan as needed. 

• Coordination and cooperation—We anticipate that many measures identified as being 

necessary for species or habitat protection would involve not only Idaho Power, but also 

adjacent land owners and managers, and the plan should include a mechanism for formalizing 

coordination and cooperation between the Forest Service, BLM, and private landowners. We 

recommend Idaho Power establish an advisory board, like the rare plant advisory board, to 

help implement cooperative wildlife measures. 

The Staff Alternative calls for Idaho Power to address all the special status species for which 

agencies or tribes filed recommendations, with the exception of osprey and peregrine falcon. Species 

included in the Staff Alternative are shown in tables 106 and 107. 

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Table 106. Special status and rare endemic plants identified for inclusion in management and 

monitoring plans by agencies, tribes, or staff in relation to Staff Alternative. 

Species Staff Alternative 

American wood sage (Teucrium canadense var. occidentale) 

Bartonberry (Rubus bartonianus) 

Hazel’s prickly phlox (Leptodactylon pungens ssp. hazeliae) 

MacFarlane’s four-o’clock (Mirabilis macfarlanei) 

Membrane-leaved monkeyflower (Mimulus hymenophyllus) 

Oregon bolandra (Bolandra oregana) 

Porcupine sedge (Carex hystricina) 

Schweinitz flatsedge (Cyperus schweinitzii) 

Shining flatsedge (Cyperus rivularis) 

Spacious monkeyflower (Mimulus ampliatus) 

Spalding’s catchfly (Silene spaldingii) 

Stalk-leaved monkeyflower (Mimulus patulus) 

For Forest Service Sensitive species, monitor 

known sites every 2 years for the first 6 years 

following license issuance; determine after year 6 

whether surveys should continue at 3-year 

intervals. For other species, consult with 

agencies, tribes, and other stakeholders to 

determine a monitoring schedule, based on sitespecific information (i.e., risk of disturbance). For 

all species, identify and implement protective 

measures, as needed, and monitor effectiveness. 

For all species, survey if new ground-disturbance 

is proposed in suitable habitat. 

Table 107. Special status wildlife identified for inclusion in monitoring and management plans, 

or for which agencies, tribes or staff recommended specific management measures, in 

relationship to Staff Alternative. 

Species Staff Alternative 

Bald eagle (Haliaeetus leucocephalus) Develop and implement cooperative nest site management plans for 

nests associated with project reservoirs; conduct 1 annual nesting 

(March/April) and 1 annual productivity (June/July) survey at these 

nest sites. Conduct 1 annual fall (October/November) and 1 annual 

winter (February/March) roost survey and develop cooperative roost 

site management plans. Conduct 1 annual winter survey to cover all 

project reservoirs, timed to match regional surveys. Use existing 

information (GIS overlays of project facilities, project-related 

activities, nest sites, and HCRMP protective designations) to evaluate 

whether new protective measures are needed, and re-evaluate when 

activities are planned that would affect habitat or cause noise 

disturbance. Habitat enhancement is not necessary because HCRMP 

BMPs would protect nest sites, and no evidence has been filed that 

habitat is limiting. 

Mountain quail 

(Oreortyx pictus) 

Implement cooperative management measures identified by Interior, 

ODFW and IDFG. 

Great blue heron nesting 

(Ardea herodias) 

Design and implement site-specific protective measures as part of 

Powder River Wildlife Management Area Plan. 

Columbia spotted frog 

(Rana luteiventris) 

Monitor known site; develop and implement site-specific protection, 

management, enhancement, restoration measures as needed; monitor 

effectiveness. 

Other special status amphibians and 

reptiles 

Implement Interior-85 regarding mapping and protection of snake dens 

as encountered; continued protection of springs and seeps; acquisition 

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Species Staff Alternative 

of wetlands and springs as part of riparian habitat; mapping of 

bullfrogs encountered; bullfrog management on a site-specific basis. 

Townsend’s big-eared bat 

(Corynorhinus townsendii pallescens) 

Survey project facilities, develop and implement site-specific 

protection, management, enhancement, restoration measures as needed, 

including Interior-82; monitor effectiveness. 

Spotted bat 

(Euderma maculatum) 

Survey project facilities, develop and implement site-specific 

protection, management, enhancement, restoration measures as 

needed; monitor effectiveness. 

Other special status bats Survey project facilities, develop and implement site-specific 

protection, management, enhancement, restoration measures as 

needed; monitor effectiveness. 

Northern Idaho ground squirrel 

(Spermophilus brunneus brunneus) 

Survey if suitable habitat occurs on lands acquired for wildlife habitat 

mitigation; if present, implement protective measures. 

Southern Idaho ground squirrel 

(Spermophilus brunneus endemicus) 

Survey if suitable habitat occurs on lands acquired for wildlife habitat 

mitigation; monitor known sites; implement Interior-83. 

We incorporated most aspects of the recommendations into the Staff Alternative’s more 

comprehensive plan, but rejected a few. 

Our review of federal and state databases does not indicate any special status designation for 

osprey. Surveys found them to be uncommon in the project area (Turley and Holthuijzen, 2003b), and 

osprey were not identified as being of concern in evaluations of project operations and project-related 

activities (Dumas et al., 2003b; Edelmann et al., 2003b). This species would continue to be protected by 

the Migratory Bird Treaty Act. Also, Idaho Power’s HCRMP includes BMPs and habitat designations 

that would protect habitat for the osprey. 

One peregrine falcon eyrie is located in the vicinity of the Hells Canyon boat launch (Akenson, 

2000), but no project effects were identified (Dumas et al., 2003b; Edelmann et al., 2003b). Like the 

osprey, existing laws would continue to apply to this species. 

In the draft EIS, we rejected elements of Forest Service preliminary 4(e) condition no. 9, which 

specified that Idaho Power should conduct surveys for sensitive species on all National Forest System 

lands within one-fourth mile of the project boundary and within 50 meters of the shoreline along the 

Snake River between Hells Canyon dam and the confluence of the Salmon River. The preliminary 

condition specified that Idaho Power conduct the surveys annually for the first 5 years of any new license 

and at 2-year intervals thereafter. We also rejected the specification for development of a separate plan 

for the Forest Service. The Forest Service subsequently submitted modified 4(e) condition no. 9. While 

still calling for a separate plan for Forest Service Sensitive species, modified FS-9 specifies surveys on 

National Forest System lands affected by the project only if activities are proposed that could adversely 

affect sensitive species, without specifying an arbitrary distance. It also reduces the survey schedule, 

calling for surveys of confirmed Forest Service Sensitive species sites every 2 years for the first 6 years of 

any new license period, and then every 3 years thereafter, with a determination after year 6 of whether 

surveys need to be continued. We now include FS-9 in the Staff Alternative because it would benefit 

Forest Service sensitive species, could be accomplished at a reasonable cost, and would ensure 

consistency with the HCNRA Comprehensive Management Plan and Wallowa-Whitman and Payette 

National Forest Land and Resource Management Plans. 

For non-National Forest System lands and other special status species, we recommend that Idaho 

Power consult with the agencies to determine appropriate monitoring schedules. 

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We do not include in the Staff Alternative ODFW-64, which recommends bald eagle habitat 

enhancement, because we could find no evidence in the record that habitat is limiting. Also, Idaho 

Power’s HCRMP provides BMPs and habitat designations that should be protective of large trees and 

riparian habitat. 

We do not include ODFW-65, which recommends that Idaho Power protect and monitor sensitive 

flora and fauna within 0.25 mile of the Snake River between Hells Canyon dam and the Salmon River, 

and within 0.5 mile of the project boundary along the reservoirs. We recognize that project effects on 

some habitats and some species may extend outside the project boundary, but conclude that effects would 

vary depending on factors such as site-specific conditions and species’ habitat requirements and life 

histories, rather than extending an arbitrary distance. 

We do not include Interior-80, because we conclude that the objectives for mountain quail could 

be more effectively addressed through implementation of other measures (ODFW-63, IDFG-30). 

With the plan we include in the Staff Alternative, additional surveys and monitoring would focus 

on identifying and preventing adverse project effects, not on inventory or trend evaluation. In the case of 

plants, additional surveys would be conducted at sites where ground disturbance regularly occurs or is 

planned in order to provide information useful in planning and implementing projects during any new 

license period, and to support Idaho Power’s preparation of biological evaluations to address potential 

effects of any proposed actions on federal lands. For wildlife, additional surveys would be conducted if 

sites are affected by ongoing project activities or if proposed measures would cause ground disturbance or 

habitat loss or alteration (or noise disturbance, in the case of wildlife). 

Addressing federally listed species within the same plan as other special status species would 

result in a more coherent, comprehensive plan for rare plants, maximize the efficiency of field efforts, and 

minimize the need for consultation that might otherwise be duplicative. Limiting the scope of the plan to 

areas within the project boundary and locations directly affected by project operations would address 

agency provisions for protection of threatened and endangered species, while assuring that the plan has a 

nexus to the project and its direct effects. Relying on a flexible schedule based on site-specific threats to 

rare plant populations and special status wildlife would be both more effective and more economical than 

relying on a pre-determined surveying and monitoring schedule. 

The consolidated, project-wide Threatened, Endangered, and Sensitive Species Management Plan 

included in the Staff Alternative would specifically address timing restrictions to prevent disturbance to 

bald eagles and monitoring of nesting, productivity, roosting, and winter use. Although the plan would 

not include as many winter surveys as Interior recommends or as much habitat enhancement as ODFW 

recommends, it is otherwise consistent with agency goals of protecting this listed species. 

Additionally, the plan would include measures to protect the northern Idaho ground squirrel if 

this species is found to occur on lands Idaho Power proposes to acquire as mitigation for project effects. 

The plan also would include measures to protect habitat and reduce disturbance to southern Idaho ground 

squirrels, bats, amphibians and reptiles, as recommended by Interior. Finally, we recommend bat surveys 

because no information about their use of project facilities is available, and O&M and project-related 

recreation have the potential to adversely affect bats. 

We estimate the annualized cost of developing and implementing this consolidated Threatened, 

Endangered, and Sensitive Species Management Plan at $132,500. The increase over our estimate of 

$28,900 in the draft EIS reflects new cost information provided by Idaho Power in its April 30, 2007, 

filing and our adoption of the survey planning, scope, and frequency identified in FS-9 for sensitive 

species on National Forest System lands within the project boundary and on National Forest System lands 

affected by the project. This cost also includes Idaho Power’s proposed cooperative measures for rare 

plants and agency consultation and reporting, as well as planning and field efforts for species-specific 

surveys and management where such species are known to occur (e.g., bald eagles) or where they may be 

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detected (e.g., special status bats). We include the plan in the Staff Alternative because our assessment 

indicates that the benefits to wildlife species would outweigh the cost of developing and implementing the 

plan. 

5.2.5.2 Noxious Weed and Exotic Invasive Plant Management 

Reservoir fluctuations and flow fluctuations can cause soil disturbance that creates conditions that 

promote the establishment and spread of noxious weeds and invasive exotic plants. Project maintenance, 

management activities, and project-related recreation can also cause soil disturbance and act as vectors for 

the spread of weeds. 

Idaho Power proposes to develop an integrated management plan to coordinate priorities and 

actions for preventing, eradicating, containing, and controlling non-native invasive plants and noxious 

weeds along the Snake River corridor from Weiser to the Salmon River confluence, focusing on riparian 

species and habitats in particular. Idaho Power proposes to establish a noxious weed advisory board as 

the primary mechanism for coordination and implementation of weed management measures. Idaho 

Power would consult with federal and state resource management agencies in developing and 

implementing the plan, and would participate in cooperative efforts with existing Cooperative Weed 

Management Areas, landowners, land managers, and other interested individuals and organizations. 

IDFG supports Idaho Power’s proposed weed management measures, and indicates that the 

agency would cooperate with Idaho Power and other stakeholders to implement the weed management 

plan. Interior recommends a similar plan, further specifying a full inventory of project-affected and Idaho 

Power-owned lands, to be completed within 3 years of license issuance. Interior also recommends that 

Idaho Power submit to BLM a plan for use or application of pesticides on project lands or non-project 

lands adjacent to BLM-administered lands, and prepare an annual report detailing the use of pesticides. 

The Forest Service modified 4(e) condition no.7 and ODFW-66 are also similar to Idaho Power’s 

proposal, except that they call for Idaho Power to establish a new Hells Canyon Cooperative Weed 

Management Area as part of an integrated weed management plan. The Forest Service and ODFW 

outline specific elements to be included in the plan to address goals and objectives, responsibilities, 

schedules, lands for cooperative efforts, data gaps, 5-year updates, and other subjects. 

In section 3.7.2.3, Noxious Weed and Exotic Invasive Plant Management, we point out that 

noxious weeds and invasive non-native plants are a growing threat throughout the west. Project 

operations and human activity, in addition to wind, water, and animal transport, would continue to serve 

as vectors for weeds. Weeds will likely continue to spread, even with an appropriate management plan in 

place, but ongoing, coordinated efforts would help to slow this process.

In the Staff Alternative, we include Idaho Power’s proposed noxious weed control and non-native 

invasive weed management plan, including establishment of a Noxious Weed Advisory Board. The 

integrated, project-wide plan would address monitoring and management of weeds on Idaho Power, 

Forest Service and BLM-administered lands within the project boundary (including an annual pesticide 

report to BLM). It would also have Idaho Power participate in cooperative projects implemented outside 

the project boundary, if such projects are shown to address project effects or protect project resources. 

As specified in FS-7, the Staff Alternative includes establishment of a Cooperative Weed 

Management Area as a mechanism for building cooperative relationships among agencies, landowners, 

land managers and other individuals and organizations involved in managing weeds, while a Noxious 

Weed Advisory Board (which could include members who are also involved in the Cooperative Weed 

Management Area) would develop and implement the Integrated Weed Management Plan. Under the 

Staff Alternative, Idaho Power would allow for a 60-day review and comment period by the agencies and 

tribes before filing the plan with the Commission. Agencies to be consulted should include Forest 

Service, FWS, IDFG, IDPR, ODFW, county weed boards, and concerned tribes. As part of the plan, 

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Idaho Power would be consulting frequently, but informally, with cooperating agencies and tribes 

regarding additions/deletions to the list of weed species likely or known to occur in the project area; 

results of monitoring; outcomes of any treatments that were implemented; and plans for additional 

management measures. The plan would be formally updated at 5-year intervals to identify new species or 

areas of concern, evaluate program success, and consider new or alternative treatments. 

Except in one respect, the Staff Alternative would be consistent with agency recommendations. 

The Staff Alternative does not include a full inventory of project-affected and Idaho Power-owned lands 

within 3 years of license issuance, as recommended by Interior. Relicensing studies (Krichbaum, 2000) 

provide information about weed species that are present, their density and distribution, and the factors that 

are contributing to their spread, and serves as an adequate starting point for prioritizing and then 

implementing weed control projects without a 3-year delay. Idaho Power’s proposal would address 

inventories through its focus on weed prevention as the most effective, economical approach to weed 

management. Prevention requires early detection, which requires regular surveys of high-risk areas. The 

outcome of this approach should be consistent with Interior’s recommendation. 

We estimate the annualized cost of this measure at $167,200. The increase over our estimate of 

$55,000 in the draft EIS is based on new cost information provided by Idaho Power in its April 30, 2007, 

filing. It is also based on explanations the Forest Service provided with its modified 4(e) conditions, 

which led us to adopt FS-7 regarding survey and management of weeds on National Forest System lands 

within the project boundary and on National Forest System lands affected by the project. We conclude 

that it is reasonable for Idaho Power to address project effects where they occur, rather than limiting 

mitigation measures to lands within an administrative boundary. Forest Service comments also explained 

that a Cooperative Weed Management Area would complement, rather than duplicate, the functions of the 

Noxious Weed Advisory Board, and consequently, we include it in the Staff Alternative. 

In addition to the items above, the total annualized cost of $167,200 includes Idaho Power’s 

proposed establishment of an advisory board and implementation of cooperative weed projects, as well as 

development and implementation of a comprehensive plan. It also includes agency consultation and 

reporting, and establishment of a Cooperative Weed Management Area. We include this plan in the Staff 

Alternative because we find that the benefits in terms of noxious weed and invasive species management 

would outweigh the cost. 

5.2.5.3 Road, Transmission Line, and Right-of-Way Management 

The project’s road and transmission line rights-of-way must be managed to maintain safe and 

efficient operating conditions, but management activities (e.g., brushing, mowing, herbicide treatment, 

removal of hazard trees) may adversely affect native plant communities and the wildlife species that use 

them. In section 3.7.2.4, Road, Transmission Line, and Right-of Way Management, we note that Idaho 

Power’s management activities may also promote the establishment and spread of noxious weeds and 

exotic plants, which, in turn, also adversely affect native plant communities. Further, management 

activities have the potential to disturb wildlife. Disturbance during the winter can cause physiological 

stress to big game and communally roosting bald eagles. Disturbance during the breeding season can 

impair reproductive success of many bird species. 

As a result of the Commission’s orders dated March 31, 2005, and October 25, 2005, the only 

transmission line remaining within the Hells Canyon Project boundary is transmission line 945.134 

Transmission line 945 is located entirely within Hells Canyon. It runs along the eastern shore of Hells 

 

134 The Staff Alternative does not include agency recommendations that address non-jurisdictional 

transmission lines, because they are outside the scope of this relicensing. For this reason, we do not 

discuss these recommendations further. 

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Canyon reservoir from Oxbow dam to Hells Canyon dam, a distance of about 22 miles. The line runs 

parallel to a paved road (Hells Canyon Road). Several short spur roads lead off the Hells Canyon Road to 

provide maintenance access to transmission line 945. 

Idaho Power, in separate measures for botanical and wildlife resources (shown in section 5.1.1 as 

Idaho Power measure nos. 16P, 20P, and 21P), proposes to develop transmission line operation and 

maintenance plans to address the effects of right-of-way management. The primary components of the 

plans would include: (1) development of BMPs for O&M activities along transmission line 945 and 

service roads, including scheduling the timing and location of O&M activities so that they would occur 

outside critical periods for plants, raptors, nesting neotropical migrant birds and wintering big game; 

(2) restoring and revegetating disturbed sites; and (3) managing noxious weeds and invasive exotic plants. 

Idaho Power would consult with the Forest Service on the development of BMPs because transmission 

line 945 and the service roads traverse National Forest System lands. 

In section 3.7.2.4, Road, Transmission Line, and Right-of Way Management, we review 

recommendations from ODFW and preliminary conditions from the Forest Service relating to various 

aspects of Idaho Power’s proposals, and conclude that Idaho Power’s proposals would generally meet the 

objectives of the agencies, including FS-11, ODFW-67, ODFW-69, ODFW-70, and ODFW-72. 

Accordingly, we include Idaho Power’s proposed measures in the Staff Alternative, but combine them 

into a single measure requiring Idaho Power to develop and implement a transmission line operation and 

maintenance plan for transmission line 945 to address protection and enhancement of wildlife and 

botanical resources, including those that occur on any National Forest System lands crossed by the 

transmission line. 

As included in the Staff Alternative, the plan would include a provision to monitor raptor 

electrocution and evaluate collision potential, and to retrofit as needed. It also includes Idaho Power’s 

proposed measures to protect wildlife and botanical resources, as well as agency consultation and 

reporting. We include this plan in the Staff Alternative because we find that the benefits of improved 

transmission line and right-of-way management would outweigh the estimated annualized cost of 

$11,900. 

5.2.5.4 Upland and Riparian Habitat Acquisition 

Continued operation of the Hells Canyon Project would adversely affect more than 20,000 acres 

of wildlife habitat. Idaho Power’s studies indicated that most impacts would be associated with reservoir 

fluctuations that reduce the abundance and connectivity of riparian habitat, limit waterfowl brooding 

habitat, decrease the suitability of shoreline areas for many wildlife species, and contribute to shoreline 

erosion. 

The presence and operation of the reservoirs also reduces the habitat capability of mule deer 

winter range and increases annual winter mortality. Mule deer are very important in the region, in terms 

of their ecological role, as a cultural resource, and for the hunting, viewing, and wildlife appreciation 

opportunities they provide. They are also an important economic resource for Oregon and Idaho. ODFW 

stated that hunting in Baker County likely yielded between $1.43 and $2.9 million in 2005, based on 12 

days per hunter, each spending between $30 and $60 per day (ODFW, February 21, 2007). IDFG 

estimated the economic value of mule deer hunting over the past 10 years at $335,645 to $1,512,632 

annually, based on about 4 to 5 days per hunter, each spending approximately $101 per day (IDFG, 

January 27, 2007). 

In section 3.7.2.5, Upland and Riparian Habitat Acquisition, we review the preliminary terms, 

conditions, or recommendations submitted by agencies and tribes regarding acquisition of mitigation 

lands. While similar in some respects, the recommendations reflect different conclusions about the 

amount of land the project affects and the amount of land needed for mitigation. In section 3.7.2.5, we 

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summarize Idaho Power’s proposal and the minimum acreage that would be acquired under each agency 

or tribal recommendation. 

Idaho Power’s proposal would bring a minimum of 20,592 acres of land into the project boundary 

for management as wildlife habitat through any new license period, together with 2,990 acres already in 

Idaho Power’s ownership, at an estimated annualized cost of $1.8 million. It would provide mitigation 

for the ongoing project effects on terrestrial resources identified in relicensing studies. Idaho Power 

would acquire (and at this time, has acquired) parcels of private land that are located adjacent to or near 

the project reservoirs, at relatively low elevations. These parcels would provide on-site, in-kind habitat, 

similar to uplands and riparian areas affected by project operation, and would benefit the species 

identified by the Terrestrial Resources Work Group as having high priority (e.g., big game, raptors, and 

threatened, endangered, candidate, and sensitive species). 

Idaho Power proposes to finalize and implement the plan described in its response to AIR 

TR-1(a)(i)—Options for Meeting Acreage Targets and TR-1(a)(ii)—Characteristics of IPC’s Preferred 

Options (Edelmann and Huck, 2005) to acquire, enhance and manage approximately 22,761 acres of 

upland and 821 acres of riparian habitat in the vicinity of the Hells Canyon Project reservoirs. 

Components of this plan include finalizing and implementing the Integrated Wildlife Habitat Program and 

Wildlife Mitigation and Management Plan. 

We include this measure in the Staff Alternative for the previously mentioned reasons that the 

plan provides appropriate on-site, in-kind mitigation for effects of project operation, and the proposed 

parcels address current resource needs as identified during consultation with the Terrestrial Resources 

Work Group. All four of the major land parcels included in Idaho Power’s proposal are located adjacent 

to Brownlee reservoir, where project effects are most evident. Proposed parcels are about evenly divided 

between the west and east sides of the reservoir, with adjustments to take advantage of specific 

opportunities (e.g., presence of high priority habitats, extending habitat connectivity). This measure 

would be consistent with Forest Service preliminary 4(e) condition no. 6 and IDFG-28. 

To date, Idaho Power has acquired 18,298 acres of the first tier parcels. This acreage, plus 2,990 

acres already in Idaho Power’s ownership, includes 777 acres of riparian habitat, leaving a minimum of 

44 acres yet to be acquired. 

The total acreage to date includes 12,156 acres in Oregon and 9,132 acres in Idaho. IDFG 

commented that if the fourth target parcel (the 2903-acre Rocking M Ranch, located in Idaho) cannot be 

acquired, priority should be given to selecting lands with the highest value for mitigation, whether they 

are located in Oregon or Idaho (letter from T. Trent, Chief, Natural Resources Policy Bureau, IDFG, to 

T.J. Welch, Chief, Hydro West Branch 2, Commission, Washington, DC, dated January 27, 2007).

In their comments on the draft EIS and during the 10(j) meetings, Interior and IDFG indicated 

that the Staff Alternative should provide for acquisition of additional lands at a mitigation ratio higher 

than 1:1 if target parcels within the “first tier” (the nine parcels identified as the highest priorities by 

Idaho Power and the TRWG) are unavailable or cannot be acquired within a reasonable amount of time 

following license issuance. The higher mitigation ratio is intended to compensate for the lower values of 

replacement parcels (i.e., these parcels could be farther from the project, higher in elevation, more 

isolated from other lands managed for wildlife, or less capable of supporting high value habitats or 

species), and/or a longer period of time before Idaho Power could secure the lands and begin to 

implement enhancement measures. 

To address agency concerns about the timely progress of acquiring high value lands, we include a 

contingency plan in the Staff Alternative. Under the contingency plan, if Idaho Power cannot acquire the 

remaining acreage of upland and riparian habitat within the “first tier” parcels within 5 years after license 

issuance, Idaho Power would acquire 5,805 acres (including at least 88 acres of riparian habitat) within 

the “first tier” within 10 years after license issuance. If this acreage cannot be acquired within 10 years 

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after license issuance, Idaho Power would acquire 8,709 acres (including at least 132 acres of riparian 

habitat) within the “second tier” parcels. 

With FS-6, the Forest Service specifies that within 1 year of license issuance, Idaho Power should 

consult with the Forest Service to prepare a Land Acquisition and Management Plan that would be 

incorporated into the IWHP/WMMP. Although Idaho Power has already acquired three of four target 

parcels, implementation of this measure would be useful in identifying additional parcels to mitigate for 

project effects on riparian habitat along the Snake River downstream of Hells Canyon dam. These 

additional parcels would include 49 acres of riparian habitat to mitigate for ongoing project effects 

(interruption of sediment supply, flow fluctuations) on sandbar willow in shore and bottomland wetland, 

consistent with FS-6. We did not include this aspect of FS-6 in the Staff Alternative in the draft EIS, but 

now adopt it based on calculations the Forest Service provided in its justification for modified 4(e) 

conditions. Although we conclude that high flows, rather than project operations, are the primary factor 

that limits the development of riparian vegetation within shore and bottomland wetland, we accept the 

Forest Service estimate that project operations may prevent the establishment of native willows on 49 

acres within this zone. 

The additional parcels would also include 13.2 acres of riparian habitat to mitigate for anticipated 

effects (reduced hydrologic support) of the Staff Alternative flow regime on riparian habitat. In the draft 

EIS, we recommended that Idaho Power enhance 13.2 acres of riparian habitat downstream of Hells 

Canyon dam. We now recommend Idaho Power acquire the land needed to mitigate for project effects on 

this habitat, as well as the 49 acres mentioned above, as part of the larger acquisition package. We 

conclude that long-term management would be most efficient and effective if this additional acreage is 

consolidated with other lands that Idaho Power would manage under the IWHP/WMMP. 

Acquisition, protection and management of 62.2 acres of riparian habitat would exceed the 56.3 

acres specified in FS-6, which was based on the assumption that Idaho Power’s proposed flow regime 

would be implemented, with slightly less impact on riparian habitat. Idaho Power estimates that it must 

acquire about 25 acres of upland habitat for every acre of riparian habitat. Thus, acquisition of an 

additional 62.2 acres of riparian habitat would add approximately 1,493 acres of upland to the Staff 

Alternative. The Staff Alternative’s contingency plan would apply to this acreage, as well. We estimate 

the annualized cost of acquiring 62.2 acres (56.3 acres specified by the Forest Service, plus 5.9 additional 

acres to account for effects of implementing the staff-recommended flow regime) would be $177,300, 

which we conclude would provide sufficient benefits in terms of riparian habitat mitigation to be worth 

the cost. 

We do not include ODFW-61 or Interior-76 regarding acquisition of mitigation lands because 

they call for land acquisition greater than is needed to mitigate for ongoing impacts. Our analysis (section 

3.7.2.5, Upland and Riparian Habitat Acquisition) indicates that mitigation ratios of greater than 1:1 are 

not appropriate, given that Idaho Power’s proposal provides on-site, in-kind habitat, similar to uplands 

and riparian areas affected by project operation. Idaho Power’s proposal would benefit species affected 

by project operations and those identified by the Terrestrial Resources Work Group as having high 

priority. 

Part of the justification given by Interior and ODFW for higher mitigation ratios is based on 

typical wetland mitigation provisions imposed by federal and state regulatory agencies to account for the 

difficulty in creating or re-establishing wetland functions and values. We note that these concerns do not 

apply to Idaho Power’s proposal, which does not involve wetland creation or re-establishment. 

ODFW states that ODFW and Oregon Department of State Land policies call for no net loss of 

upland habitat quantity or quality, and net benefits for riparian habitat. We recognize that the Staff 

Alternative may not be consistent with the state’s policy. However, the FPA does not require mitigation 

of all project impacts. We conclude that the Staff Alternative provides substantial benefits by protecting 

parcels that have high value because of physical factors (relatively low elevation and location adjacent to 

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the reservoirs and adjacent to other lands that are or will be managed for wildlife), and by improving their 

ecological values through implementation of enhancement measures. Under this alternative, Idaho Power 

would work with the Integrated Wildlife Habitat Program workgroup to develop site-specific plans for the 

acquired lands as part of the Wildlife Mitigation and Management Plan. Idaho Power would measure 

baseline conditions, identify desired conditions and implement treatments to improve habitat values (e.g., 

by managing livestock; excluding livestock from riparian areas; controlling weeds; seasonally restricting 

recreation to reduce disturbance; and planting native trees, shrubs and herbaceous species). Idaho Power 

would monitor the effectiveness of treatments over time, using the results to adaptively manage each site 

and update the plans as needed. 

Interior states that BLM has limited formal guidance for mitigation. Mitigation ratios may be 1:1 

or higher, depending on the resource and the distance of acquired lands from the project. Interior’s 

guidance also indicates that it is important to acquire lands that serve a similar functional component, and 

that the suitability of a site may outweigh the parcel size. The Staff Alternative would be in keeping with 

this guidance because the target parcels are as close as possible to the project, provide the same acreage of 

riparian and upland habitat as is affected by ongoing project operations, and serve similar functions 

(e.g., they provide big game winter range, habitat connectivity, and support for special status species). 

We estimate that the annualized cost of implementing ODFW-61, Interior-76, or IDFG-29 would 

be about $2.5 million, $2.9 million, or $3.3 million, respectively. By contrast, the annualized cost of 

implementing Idaho Power’s proposal would be about $1.8 million. Because Idaho Power’s proposal 

addresses ongoing project effects at a reasonable cost, we include it in the Staff Alternative, noting that 

higher costs may be associated with the contingency plan. 

As we note in section 3.7.2.5, Upland and Riparian Habitat Acquisition, Idaho Power points out 

that the project reservoirs are relatively recent features, and predicts that banks will continue to erode 

until shorelines reach equilibrium. Idaho Power’s proposal would provide 1:1 mitigation for the acreage 

of erosion that has been documented to date along reservoir shorelines. Interior recommends Idaho 

Power conduct a study to determine the feasibility of using riparian plantings to stabilize existing erosion 

sites, and reduce the acreage of acquisition if plantings are successful. The Forest Service specifies that 

within 2 years of license issuance, Idaho Power should assess erosion sites already identified, and where 

warranted and feasible, design and install control measures and then monitor their effectiveness. Where 

control measures are deemed infeasible, the acreage of these sites would be added to Idaho Power’s 

riparian acquisition program. Idaho Power would then survey for new erosion sites every 5 years and 

implement control measures when deemed warranted and feasible. 

We conclude that Idaho Power’s proposed land acquisition would help to mitigate for 90 acres of 

existing erosion, but would not address erosion control onsite and does not take into account the acreage 

of erosion that is likely to occur during any new license period. Based on the age of each reservoir, the 

acreage of existing erosion, and an assumed constant rate of erosion, another 70 acres could be affected 

during the next 30 years. We therefore include in the Staff Alternative a provision that expands on FS-6, 

i.e., Idaho Power would develop and implement a long-term stabilization/revegetation program to address 

erosion sites around project reservoirs. Development of the plan would be preceded by a feasibility 

assessment and 5-year pilot project. If the results of the pilot project indicate a high likelihood of success 

at other sites, Idaho Power would implement the program; if not, Idaho Power would acquire 70 acres of 

riparian habitat and manage them under the Integrated Wildlife Habitat Program/Wildlife Mitigation and 

Management Plan. Again, the contingency plan would apply to any land acquired to mitigate for erosion. 

In the draft EIS, we did not recommend implementation of a 5-year pilot project as part of the 

feasibility assessment. We have added this recommendation to the Staff Alternative in the final EIS 

because we concluded that the results of field testing would provide the best basis for decisions about if 

and how to undertake additional stabilization/revegetation efforts. For the purpose of estimating costs, we 

assume the pilot project would be successful and a long-term stabilization/revegetation program would be 

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implemented. We estimate the annualized cost of this staff-developed measure at $52,800. We do not 

include an estimated cost of acquiring additional acreage if the pilot project indicates the program would 

not be successful. 

ODFW-61, Interior-76, and NPT-22 provide for the mitigation of effects of original project 

construction. We do not include these measures in the Staff Alternative because original project 

construction is not the focus of relicensing; Commission policy establishes current conditions as the 

baseline for environmental analysis. 

Idaho Power’s proposal addresses project effects on 86,408 acres of mule deer winter range 

between full pool and 2,700 feet elevation, where mule deer winter ecology studies (Edelmann, 2003) 

indicated that most deer were concentrated and where interactions with the reservoir occurred, and 

applied a habitat coefficient of 0.19 to estimate project effects on habitat capability and mortality. 

ODFW-61 provides for mitigation of project effects on a larger area of mule deer winter range than Idaho 

Power’s proposal addresses. ODFW estimates the area of crucial mule deer winter range at 121,337 acres 

between full pool and 3,200 feet. ODFW states that a habitat coefficient of higher than 0.19 should be 

applied to account for higher mortality in extremely harsh winters. However, in its comments on the draft 

EIS, ODFW applies the 0.19 habitat coefficient to 121,337 acres, concluding that the Staff Alternative 

should include acquisition and management of 23,054 acres of mule deer winter range (1,452 acres of 

riparian habitat and 21,602 acres of uplands). Staff concludes that Idaho Power’s proposed mitigation 

package, which would total a minimum of 23,582 acres and would likely total at least 24,191 acres, 

should help to address ODFW’s concerns, because most of the lands are located within areas mapped as 

crucial mule deer winter range (Christensen, 2003) or function as a major migration route for mule deer 

moving between summer range in Oregon and winter range near Brownlee reservoir. The Staff 

Alternative would add a minimum of 1,555 acres (62.2 acres of riparian habitat; 1,493 acres of uplands) 

to this package. While the package includes less riparian habitat than ODFW believes is needed, the mule 

deer winter ecology studies (Edelmann, 2003) indicate that high quality forbs, low-stature green grasses, 

bitterbrush, and sagebrush at low elevations on south and southwest facing aspects are most important in 

harsh winters. Thus, low elevation uplands may be as important, if not more important, than riparian 

habitats for mule deer during the winter in this area. 

Although not included as terrestrial resource measures, the Staff Alternative calls for 

enhancement of riparian habitat in several tributaries to the project reservoirs. Riparian habitat protection 

and management aimed at improving fish habitat would also benefit wildlife, including mule deer. 

Enhancement measures are recommended for Pine, Indian, and Wildhorse creeks and several smaller 

tributaries, and may be expanded to include the Powder and Burnt River basin tributaries. 

In the Staff Alternative, we do not include SPT-5, which calls for Idaho Power to acquire 10,000 

acres near the Duck Valley Indian Reservation and transfer title to the Shoshone-Paiute Tribes. The 

project does not affect this area, and property located at this distance from the project (more than 100 

miles) would not meet the TRWG criteria for on-site, in-kind mitigation. 

Interior-79, BPT-9, and SPT-7 call for Idaho Power to conduct a HEP to establish pre-dam 

baseline conditions and/or to determine suitable habitat units for mitigation. We do not include these 

measures in the Staff Alternative because we conclude that studies completed to date provide a sufficient 

basis for determining ongoing project effects and mitigation needs. 

We estimate the total annualized cost of habitat acquisition (including riparian habitat to mitigate 

ongoing project effects downstream of Hells Canyon dam and predicted effects of implementing the staffrecommended flow regime) at $1,945, 700. This cost includes preparation of a Land Acquisition and 

Management Plan, as specified by the Forest Service (FS-6). The increase over our estimate of 

$1,651,100 in the draft EIS reflects new cost information provided in Idaho Power’s filing on April 30, 

2007, which indicates additional capital improvements and more intensive management of acquired lands. 

It also reflects the cost of additional acreage that would be purchased in accordance with FS-6, and 

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implementation of a 5-year pilot project to investigate the feasibility of stabilizing and revegetating 

eroding shorelines and riverbanks. We include this measure in the Staff Alternative because we conclude 

that the benefits of this habitat acquisition and management would outweigh the cost. 

5.2.5.5 Cooperative Wildlife Management Projects 

Reservoir fluctuations at Brownlee reservoir adversely affect riparian habitats along the shoreline 

and on several small islands at the upper end of Brownlee reservoir, reducing their ability to support 

nesting and brooding waterfowl. Reservoir fluctuations also contribute to riparian habitat fragmentation 

along the shoreline, reducing its suitability for mountain quail. 

To address project effects on waterfowl, Idaho Power proposes to provide funding, equipment, 

personnel, logistical support, and expertise to IDFG and ODFW to support habitat enhancement projects 

on four Snake River islands. Idaho Power purchased the islands as mitigation for the effects of project 

construction on waterfowl and then conveyed title to the states to manage them. IDFG owns and manages 

Gold Island (331 acres), while ODFW owns and manages Patch (about 100 acres), Porter (about 

70 acres), and Hoffman (60 acres) islands. The states have managed the islands primarily to provide 

waterfowl and upland game bird habitat, but lack of funding for management activities has resulted in a 

gradual decline of habitat values. Currently, non-native invasive weeds are the dominant vegetation on 

all four islands. 

IDFG and ODFW make various recommendations regarding funding levels, funding mechanisms, 

habitat improvement projects, and cooperative management for the islands. These measures recommend 

that Idaho Power fund the capital cost of equipment purchase ($298,800) and provide $32,000 per year 

(approximately $57 per acre) during the term of a new license to support habitat management on four 

islands. 

In the draft EIS, we rejected agency recommendations to include Patch and Gold islands in the 

Staff Alternative because they are located outside the project boundary and are not affected by project 

operations. We also rejected agency recommendations to provide support for capital improvements 

because we concluded that while it would be reasonable for Idaho Power to contribute to ongoing agency 

management efforts, Idaho Power should not be responsible for initiating those efforts. In this final EIS, 

we modify the Staff Alternative to include all four islands, based on continuing effects of the reservoir 

fluctuations on waterfowl habitat and further review of onsite opportunities for enhancement (see section 

3.7.2.6, Island Habitat Enhancement Projects). We now also include a recommendation for Idaho Power 

to support capital improvements on the island, because we find that Idaho Power could not implement or 

maintain the enhancement projects without those improvements. 

The Staff Alternative would have Idaho Power consult with ODFW and IDFG to identify and 

implement habitat improvement projects on Porter, Hoffman, Patch, and Gold islands. On Porter, 

Hoffman, and Patch islands, projects would include purchasing and installing nest platforms and boxes, 

seeding grain to provide waterfowl forage, enhancing willows and other shrubs, and controlling weeds 

(ODFW, February 21, 2007). IDFG indicates funding is needed for irrigation and restoration projects on 

Gold Island (IDFG, January 27, 2007). Idaho Power could contract with the agencies to implement the 

improvement projects, but Idaho Power would retain ultimate responsibility for complying with the terms 

of the license. ODFW and IDFG describe the overall cost of managing the islands, but do not explain the 

basis for determining what Idaho Power’s level of support should be. We include in the Staff Alternative 

support for capital improvements ($298,800), which is consistent with ODFW and IDFG 

recommendations and would equal an annualized cost of $32,600. We also include in the Staff 

Alternative an annual funding level of $26,000, as Idaho Power proposes. This cost is slightly higher 

than O&M costs Idaho Power anticipates it would be applying to other lands it would acquire and 

manage. A higher level of funding for these islands would account for intensive management and 

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difficult access. The total annualized cost of this measure would be $58,600 under the Staff Alternative. 

We include this measure because we find that the benefits would outweigh the cost. 

Project operation affects potential habitat for the mountain quail by preventing establishment of 

riparian vegetation along the Brownlee reservoir shoreline and limiting its extent along the shorelines of 

Oxbow and Hells Canyon reservoirs. Also, grazing on Idaho Power lands could reduce the cover of 

woody shrubs that provide important cover and forage for mountain quail, and project-related 

maintenance activities and recreation may cause some disturbance to this reclusive bird. 

Idaho Power proposes to cooperate with state and federal wildlife management agencies to 

develop and implement a mountain quail restoration project by participating in enhancing low-elevation 

riparian habitat and reintroducing a mountain quail population. Idaho Power anticipates that state and 

federal wildlife management agencies would take the lead in identifying projects, and Idaho Power would 

provide funding, equipment, personnel, logistical support, and expertise to support them. ODFW’s 

comments on the 10(j) meetings identified Spring, McGraw, and Fox creeks as potential translocation 

sites (ODFW, February 21, 2007). IDFG indicated that Indian, Eckels, Allison, and Deep creek drainages 

are priority areas for translocation projects (IDFG, January 27, 2007). During the 10(j) meetings, Interior 

suggested that potential sites may be located in the Burnt and Powder River drainages. We analyze Idaho 

Power’s proposal and related recommendations from the Forest Service, Interior, ODFW, and IDFG in 

section 3.7.2.6, Cooperative Wildlife Management Projects. 

Idaho Power identified 2,500 acres of scrub-shrub wetland and forested wetland that could 

provide high-quality mountain quail habitat. Most of this is located along steep tributaries to Oxbow 

reservoir. Enhancement of existing riparian vegetation in the lower reaches of tributaries and along the 

reservoir shoreline could improve habitat quality and allow for secure movement of quail, if present, 

between tributaries. We include in the Staff Alternative a measure whereby Idaho Power would consult 

with state and federal wildlife management agencies to determine the highest priority for mountain quail 

projects, i.e., habitat enhancement or translocation. 

We do not include Interior-80 in the Staff Alternative, regarding development of a Mountain 

Quail Management Plan. Under this measure, Idaho Power would fund analysis of pre-project conditions, 

mitigate for limiting factors that are not related to project operation, and meet population targets that are 

based on unreliable historical population data. The Commission has established current conditions as the 

baseline for analysis related to relicensing decisions, and data that could be obtained from a study of preproject conditions are not necessary to guide the development of measures to mitigate for ongoing project 

effects. Interior-80 would also have Idaho Power fund planning-level activities that would duplicate state 

efforts that are already underway, as described in the Idaho Mountain Quail Conservation Plan (Sands et 

al., 1998). The conservation plan addresses existing conditions and calls for IDFG to establish local 

working groups to identify and coordinate projects aimed at recovery of this species. Idaho Power’s 

proposal to participate in projects coordinated by the state or by federal agencies would be consistent with 

this conservation plan. Idaho Power’s proposal would also be consistent with IDFG-30 and ODFW-63 

recommendations, and may partially meet Interior’s objectives for mountain quail management in the 

Hells Canyon Project area. 

Activities included in the Staff Alternative would address on-the-ground habitat improvements, 

collection of new information about quail habitat requirements and behavior, and/or establishment of new 

populations in the project area. The estimated annualized cost of this measure is $9,600, which we 

include in the Staff Alternative because we conclude that the benefit to quail would outweigh the cost. 

5.2.5.6 Wildlife Management on Project Lands 

In addition to project-related operation and maintenance, Idaho Power manages a variety of other 

activities on project lands, including residential areas for employees, recreation sites, and specific leases 

and permits for agriculture and livestock grazing. These activities influence the abundance, distribution, 

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and quality of wildlife habitat. Livestock grazing, in particular, has the potential to damage soils and 

native plant communities, promote the establishment and spread of invasive weeds, and increase 

competition with native ungulates for forage. 

To address these project effects, Idaho Power proposes to consult with agencies, tribes, 

nongovernmental organizations, and other entities (which together would function as a work group, 

similar to the Terrestrial Resources Work Group) to develop and implement an integrated wildlife habitat 

program. The program would provide guidelines for general stewardship, including restrictions on 

grazing, recreation, and maintenance activities that would help protect habitat and minimize disturbance 

to wildlife. The program would tier to the Hells Canyon Resource Management Plan (see section 3.12, 

Land Management and Use) and would be the mechanism for administering Idaho Power’s wildlife 

management policies, environmental measures, and stewardship activities. Idaho Power also proposes to 

develop a wildlife mitigation and management plan to implement the programmatic goals and objectives 

and BMPs outlined in the overall program, and to develop site-specific management plans and 

cooperative projects. Monitoring protocols would be developed as part of the management plans, and 

would be tailored to the specific management needs identified in the plans. 

In section 3.7.2.7, Wildlife Management on Idaho Power Lands, we review various 

recommendations made by resource agencies and tribes regarding wildlife management. All of the 

recommendations contain similar goals and objectives for protection, management and enhancement; 

recognize the need for effectiveness monitoring; and propose to use the results of monitoring to 

adaptively manage habitat. All of the measures indicate that schedules for work planning, 

implementation, and reporting should be included in the management plan, and all of the measures 

provide for establishment of a cooperative work group. 

In section 3.7.2.7, we conclude that Idaho Power’s proposal to implement the resource 

management plans would benefit wildlife and botanical resources on lands in its ownership and lands the 

company would acquire as mitigation for project effects. Idaho Power’s proposal would help support 

biodiversity; restore and enhance native shrub-steppe, grassland, and riparian habitat; improve riparian 

habitat connectivity; and reduce traffic and noise disturbance at sensitive sites. To further minimize 

disturbance to wildlife, we recommend that Idaho Power include, as part of its WMMP, specific measures 

regarding scheduling of O&M and implementing a program to inform and educate visitors about 

protection of sensitive species and habitats. This measure would be consistent with agency 

recommendations and conditions, including Forest Service modified 4(e) condition no. 5, FS-34, IDFG28, habitat management aspects of Interior-79 (but not the recommendation regarding HEP), ODFW-59, 

ODFW-60, ODFW-72, ODFW-73, and SPT-9. It would not necessarily be consistent with NPT-23, 

which calls for Idaho Power to hold any parcels acquired for mitigation as open and unclaimed lands, to 

be open to the Tribe’s hunting, gathering, and pasturing treaty rights. We conclude that this aspect of 

management would best be determined on a site-by-site basis. 

In the Staff Alternative, we include a provision that Idaho Power establish a terrestrial resource 

work group to assist in finalizing and implementing the management plans, as described in Idaho Power’s 

response to AIR TR-1. This measure would also be consistent with agency and tribal recommendations, 

with some exceptions. We do not include certain aspects of BPT-9 because it defines tasks for the work 

group that have already been completed (e.g., quantifying habitat losses and identifying criteria for land 

acquisitions). 

BPT-9 and SPT-6 call for Idaho Power to fund the tribes’ participation in the work group, and we 

do include that funding in the Staff Alternative. In our analysis in section 3.9.2.4, Support for Native 

American Programs, we find that tribal participation in designing and implementing measures for 

protection and management of natural resources would be valuable in meeting the natural resource goals, 

as well as cultural resource goals, identified in the Hells Canyon Resource Management Plan. The cost of 

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this tribal participation is reflected in the estimates we provide below in section 5.2.6.5, Tribal 

Participation, Education, and Training. 

Under the Staff Alternative, the IWHP/WMMP would include all lands within the project 

boundary (including National Forest System and BLM-administered lands, as well as Idaho Power lands) 

and lands acquired for mitigation. We estimate the total annualized cost of managing these lands would 

be $1,120,000. This estimate is higher than that shown in the draft EIS, based on new cost information 

filed by Idaho Power on April 30, 2007. Management costs also include the Land Acquisition and 

Management Plan identified in FS-5, establishment of a terrestrial resources working group (and longterm coordination with this group), finalizing the IWHP and WMMP, capital improvements and O&M, 

and measures to prevent or minimize disturbance to wildlife (scheduling O&M; developing and 

implementing an I&E program). We include these measures in the Staff Alternative because we find the 

benefits of improved habitat management would be worth the cost. 

5.2.6 Cultural Resources 

5.2.6.1 Finalization of the Historic Properties Management Plan 

Project operations and project-related activities such as recreation can affect cultural resources by 

exposing sites to natural forces such as water and wind erosion and air pollution, as well as to accidental 

or intentional destruction by people. To address these issues, the Commission typically requires 

applicants to prepare and submit draft Historic Properties Management Plans (HPMP) with their license 

applications. An HPMP contains measures, strategies, and procedures for resource management and 

protection, and for resolving known or potential project-related adverse effects to historic properties over 

the term of the license. Idaho Power’s license application includes a draft HPMP. The tribes, Idaho State 

Historical Society, Forest Service, and BLM have all recommended that Idaho Power revise, finalize, and 

implement the HPMP. 

We include in the Staff Alternative a measure documenting the need for Idaho Power to finalize 

the HPMP, incorporating all provisions of Forest Service 4(e) condition no. 25, and all provisions of 

Interior 4(e) condition no. 5, in consultation with the SHPOs, tribes, agencies, and Commission within 

1 year of license issuance. The Commission is requiring Idaho Power to finalize the HPMP prior to 

issuance of a new license. The final HPMP must address the issues outlined in the following subsections. 

In accordance with section 106 of NHPA, the Commission would execute, prior to issuance of a license, a 

Programmatic Agreement with the SHPOs and Advisory Council (if it chooses to participate) to formally 

implement the HPMP, with Idaho Power, the tribes, BLM, and the Forest Service as consulting parties to 

the agreement. The final HPMP would be attached to the final Programmatic Agreement. The estimated 

annualized cost of the measure is $800. In the following subsections, we discuss various 

recommendations about what should be included in the final HPMP, and indicate what elements we 

include in the Staff Alternative. 

5.2.6.2 Cultural Resources Monitoring 

As noted above, the potential for adversely affecting cultural resources is generally addressed in 

an HPMP that includes, among other things, site treatment measures designed to avoid, mitigate for, or 

repair resource damage. In section 3.9.2.2, Site Treatment, we point out that a first step in treatment of 

cultural resources is assessment of their existing condition and periodic monitoring thereafter to 

determine whether the condition of a given resource has changed, and if so, why. Monitoring may 

indicate that project operations adversely affect, or are likely to adversely affect, the condition of a 

resource. In that case, the next step is to develop and implement treatments to repair damage where 

possible, and prevent further deterioration or loss. 

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Idaho Power proposes to monitor the condition of selected eligible archaeological sites in the 

areas of potential effect of the project’s three reservoirs, as well as the known burial site at Oxbow 

reservoir. In the APE downstream of Hells Canyon dam, Idaho Power proposes an initial 3-year program, 

at the end of which the condition of historic properties sites in this portion of the APE would have been 

verified and, as necessary, updated. Idaho Power would use results of this initial program to determine 

appropriate schedules for monitoring over the next three years. This pattern would continue throughout 

the license term, with the monitoring program being reviewed and revised as needed every 3 years. We 

include Idaho Power’s proposed monitoring in the Staff Alternative, concluding that the protection 

afforded by monitoring these sites would be worth the annualized cost of $109,100 

Forest Service 4(e) condition no. 25 specifies, among other provisions, that Idaho Power’s HPMP 

should provide for periodic monitoring of all identified historic properties, including traditional cultural 

properties, within the areas of potential effect, with special provisions for photographic documentation of 

selected rock image sites. Interior 4(e) condition no. 5 specifies that 13 sites on BLM land within the 

APE be included in the initial monitoring effort. 

The Umatilla Tribes and the Forest Service recommend that Idaho Power monitor the condition 

of traditional cultural properties, including rock art (CTUIR-35b, FS-25), and the Umatilla Tribes also 

recommend that Idaho Power develop a framework for monitoring traditional cultural properties in 

consultation with the tribes (CTUIR-35d). 

The Nez Perce Tribe’s recommendation (NPT-28) that all known historic properties in the area of 

potential effect be monitored to identify project-related effects is similar to the Forest Service’s 

preliminary 4(e) condition no. 25. 

The Idaho State Historical Society (ISHS-2) recommends that the monitoring program include 

confirmation of information on the archaeological site records Idaho Power submitted in association with 

relicensing, and that Idaho Power ensure that its cost estimates for monitoring are sufficient to cover this 

additional work. 

We conclude in section 3.9.2.2, Site Treatment, that an initial 3-year program during which the 

conditions of all National Register listed and eligible resources (including not only archaeological sites 

but also rock art and other traditional cultural properties) are assessed, verified and updated as appropriate 

(which is consistent with Forest Service 4(e) condition no. 25 and also with Interior 4(e) condition no. 5) 

and existing site data are corrected or brought up to current conditions (as recommended by the Idaho 

Historical Society) would provide an informed starting point for the program. Review of the program and 

its findings every 3 years, as proposed by Idaho Power, would provide Idaho Power with an opportunity 

to make any necessary adjustments to monitoring methods and the frequencies with which various sites 

are monitored based on ongoing review of site conditions and project-related effects. We therefore 

include these measures, extended to the entire APE, in the Staff Alternative and conclude that they are 

worth the estimated annualized cost of $187,800. 

5.2.6.3 Cultural Resource Site Stabilization 

Water level fluctuations can destabilize soils and lead to seepage failure that affects not only 

shorelines but also archaeological materials that may be present in those soils. Erosion of soils containing 

archaeological materials can result in displacement or loss of artifacts, and also to exposure of artifacts 

where they may be vulnerable to unauthorized collecting or inadvertent damage. 

Idaho Power proposes to stabilize 7 archaeological sites on Brownlee reservoir that are affected 

by project operations and approximately 20 sites between Hells Canyon dam and the confluence with the 

Salmon River that show evidence of active erosion potentially attributable to project operation. Idaho 

Power also proposes to recover archaeological data at four sites on Brownlee reservoir to prevent possible 

erosion damage. We include these measures in the Staff Alternative, concluding that the protection they 

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would afford these sites would be worth the combined annualized cost of $176,800. Idaho Power 

proposes to coordinate with the appropriate SHPO, land management agency (or other landowner), and 

tribes to develop stabilization measures appropriate to each individual site. 

Over the license term, periodic monitoring of all eligible cultural resources in the area of potential 

effect (as discussed in the preceding section) would ensure that if project-related effects to other resources 

(additional to the 27 archaeological sites proposed by Idaho Power) are identified, appropriate treatments 

could be developed and implemented in consultation with the tribes, agencies, and SHPOs. 

We conclude in section 3.9.2.1, Effects of Project Operations on Cultural Resources, that 

continued project operation presents the possibility that sites on all three project reservoirs could 

experience erosion from water level fluctuations in the future. Idaho Power recognized this possibility 

early in its pre-application process when it proposed in its Formal Consultation Package to examine the 

effects of reservoir water level fluctuations on cultural resources. Consultation with the Cultural 

Resources Work Group led to Idaho Power’s deferral of this work, which we estimate to cost $1,900 on 

an annualized basis. In its draft HPMP, Idaho Power indicates its plan to obtain information to complete 

this analysis during its periodic monitoring of archaeological sites on the reservoirs. To avoid any doubt 

about this proposed step, we include in the Staff Alternative a provision that Idaho Power develop and 

implement the deferred monitoring and analysis, and then integrate the results into subsequent monitoring 

and management efforts to be undertaken over the license term under the provisions of a finalized HPMP. 

5.2.6.4 Ethnographic and Oral History Studies 

The Shoshone-Paiute, Nez Perce, Burns Paiute, and Shoshone-Bannock Tribes have made 

generally similar recommendations that Idaho Power provide funding to undertake, expand or complete 

ethnographic and oral histories of these tribes (SPT-9, NPT-25, BPT-16, and SBT-3). 

As part of relicensing activities, Idaho Power funded a Hells Canyon-area ethnographic overview 

as well as oral history studies for each of the tribes. Oral histories from the Warm Springs Tribes, 

Umatilla Tribes, and Burns Paiute Tribe were included as technical report appendices in the draft and 

final license applications. The Nez Perce Tribe submitted its oral history to Idaho Power in 2005; the 

document was filed with the Commission in February 2007. Idaho Power’s funding of the ethnography 

and oral history studies offered the tribes the opportunity to identify traditional cultural properties and to 

provide information that Idaho Power could use in its management and protection of resources and places 

in the project that are of importance in the area’s Native American cultural traditions (refer to section 

3.9.2.4, Support for Native American Programs). Completion of oral history studies by the ShoshonePaiute and Shoshone-Bannock Tribes would complement the studies already completed by the other 

tribes, and would contribute additional information toward effective and appropriate management of 

traditional cultural properties and sacred sites in the project. 

Accordingly, we include in the Staff Alternative a measure whereby Idaho Power would renew its 

offer to arrange for and fund the development of oral histories for the Shoshone-Bannock and ShoshonePaiute Tribes, in amounts comparable with the funding Idaho Power allocated for the other tribes’ studies. 

The estimated one-time cost of this measure is $100,000 ($50,000 for each oral history). 

5.2.6.5 Tribal Participation, Education, and Training 

In consultation with each of the tribes, Idaho Power proposes to provide support for tribal 

programs and tribal participation in resource management in the project. Specifically, Idaho Power 

proposes to: (1) fund costs of tribal staff time and travel costs associated with tribal-related 

implementation of environmental measures; (2) support educational development programs, including 

scholarships/training; and (3) support ongoing and future cultural enhancement projects in consultation 

with each tribe. Idaho Power proposes to allocate $1 million in support of each tribe (total $6 million) 

over the term of the license, equating to a total annualized cost of $200,400. 

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The Burns Paiute, Shoshone-Paiute, and Shoshone-Bannock Tribes have recommended generally 

that Idaho Power support tribal participation in natural and cultural resource management of the Snake 

River and its tributaries (BPT-16, SPT-12, and SBT-3). The Umatilla Tribes recommend that Idaho 

Power provide $1 million to the tribes to facilitate consultation and coordination on matters pertaining to 

cultural resources (CTUIR-35j). The Burns Paiute Tribe recommends establishment and continued 

funding of a tribal education scholarship fund that would be administered by the tribe, and also 

recommends that Idaho Power provide annual funding to support the tribe’s participation in cultural 

resources management in the project (BPT-11 and BPT-15). The Shoshone-Paiute Tribe recommends 

that the funding measures for each tribe be increased to $10 million (SPT-15). The Nez Perce Tribe 

recommends that Idaho Power grant each tribe its share of the funds in a lump sum at the beginning of the 

license term, for the tribe to use for license-related programs (NPT-31). 

In section 3.9.2.4, Support for Native American Programs, we conclude that informed 

participation by groups for whom project-area resources are of both historic and ongoing cultural 

importance could contribute significantly to management and protection of such resources. To that end, 

we have included in the Staff Alternative Idaho Power’s six proposed measures to promote tribal 

participation in cultural resource management and to support cultural enhancement and interpretation 

projects of the tribes. However, we delete the funding of scholarships from the Staff Alternative because 

of the lack of nexus with project effects. Although we recognize the benefit to the tribes that would result 

from Idaho Power’s commitment to tribal programs, there is no nexus between that funding and the 

project and its effects. The resulting cost impact is to reduce the annualized cost of Idaho Power’s 

proposed measures by $70,200. We note, however, that if this commitment of funding is not included in 

a new license, it would in no way preclude Idaho Power from fulfilling this commitment outside the 

license. We also do not include in the Staff Alternative recommendations to increase the funding to 

$10 million per tribe or to pay the funds in a lump sum because those measures cannot be tied to project 

effects and thus lack nexus to the project. 

5.2.6.6 Cultural Resources Interpretation 

Idaho Power proposes to create, install and maintain 14 informational kiosks at various locations 

throughout the project, focusing on the Native American presence and land use in the project area 

(6 kiosks), European-American occupation (4 kiosks), and the Asian-American experience (4 kiosks). 

Idaho Power also proposes to provide financial assistance in the form of grants to local communities and 

organizations to support the acquisition, display, and curation of museum collections, and for other public 

information and outreach projects focusing on the European-American and Asian-American presence in 

the Hells Canyon area. 

Informational/interpretive kiosks proposed by Idaho Power, placed in appropriate locations in the 

landscape, would be an effective way to introduce visitors to the cultural history and resources of the 

Hells Canyon area (see section 3.9.2.3, Cultural Resources Interpretation). They also could potentially 

contribute to resource protection by noting legal penalties for vandalism and looting, and by making 

visitors aware of activities that could inadvertently damage or destroy resources. Accordingly, we include 

the kiosk installation measures proposed by Idaho Power in the Staff Alternative. We also include Idaho 

Power’s proposed grant program to assist local community museums as a measure to enhance public 

appreciation of the area’s European-American and Asian-American cultural heritage and resources. We 

conclude that these measures would provide sufficient benefits to be worth the combined annualized cost 

of $21,900. Similar grant programs to the tribes, as proposed by Idaho Power and discussed above, 

would provide effective support for interpretation of Native American traditions and resources without 

the need for Idaho Power to build and operate a Native American cultural center as recommended by the 

tribes. 

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5.2.6.7 Other Cultural Resource Management Issues 

The Umatilla Tribes (CTUIR-24) recommend that the area of potential effect be expanded to the 

confluence of the Snake and Clearwater rivers, and that the added land be surveyed for cultural resources. 

The Nez Perce Tribe (NPT-30) recommends that the area of potential effect extend beyond the confluence 

of the Snake and Salmon rivers to the upper limit of the next downstream reservoir, near Asotin, 

Washington. The Idaho State Historical Society (ISHS-5) recommends that archaeological surveys be 

conducted along the reach of the Snake River between the Salmon and Grande Ronde rivers. The 

Shoshone-Paiute Tribe (SPT-11) recommends that the area of potential effect, and therefore the 

provisions of the HPMP, include all lands between the confluence of the Snake and Salmon rivers 

upstream to Shoshone Falls. We do not include expansion of the area of potential effect in the Staff 

Alternative because: (1) the recommendations of the tribes and the Idaho State Historical Society to 

expand the area of potential effect do not provide an empirical basis for attributing erosional impacts to 

cultural resources below the Salmon River to project operations and (2) extension of the Hells Canyon 

Project’s area of potential effect to Shoshone Falls would not afford historic properties upstream of this 

project any greater protection than they now receive. However, we recognize that new information or 

changing circumstances over the term of a new license could make it necessary or desirable to revise the 

APE, as well as the HPMP in which the APE is defined. Idaho Power’s draft HPMP does not provide for 

such a revision, although it does state that the archaeological monitoring program would be reviewed 

every 3 years. To clarify our intent that the HPMP should be a “living document” that responds to 

circumstances that will inevitably change over time, we therefore include in the Staff Alternative a 

recommendation that the final HPMP include provisions for review, and as necessary revision, of the 

HPMP in consultation with the SHPOs, tribes, Forest Service, and BLM every 6 years over the license 

term. This measure is also consistent with Forest Service 4(e) condition no. 25. We estimate the 

annualized cost of this measure at $1,700. 

The Idaho State Historical Society (ISHS-7) and the Umatilla (CTUIR-27), Nez Perce (NPT-32), 

Shoshone-Paiute (SPT-12), and Burns Paiute (BPT-15) Tribes recommend formation of a standing 

organization (variously called a task force, advisory committee, or work group) specifically concerned 

with implementation of the HPMP for the project. Such an organization composed of representatives 

from all the tribes, land management agencies, other landowners, and SHPOs would give these directly 

concerned parties a voice in the management and protection of cultural resources in the project over the 

license term. There are many kinds of cultural resources in the project area, and committee members’ 

contributions of knowledge and recommendations would inform Idaho Power’s decision-making and 

would facilitate Idaho Power’s adaptation, as necessary, of the HPMP to address the changing 

circumstances inevitable over the period of any new license. We therefore include this measure as part of 

the Staff Alternative. The cost for this measure is included in the $50,000 annualized estimate for 

Technical Advisory Committees given in section 5.2.8.1, Land Use Management. 

The Umatilla Tribes (CTUIR-35h) recommend that Idaho Power conduct periodic training 

sessions to enhance staff understanding of cultural resources and their importance to the tribes. In its 

draft HPMP, Idaho Power has already proposed to develop a company-wide education program, 

particularly for departments involved in construction and other potentially ground-disturbing activities. 

Such a program would appropriately include discussion of the different kinds and significance of cultural 

resources in the project area as a way of enhancing employees’ understanding of issues that would 

influence planning and implementation of project-related activities. We therefore do not include the 

Umatilla Tribes’ recommendation in the Staff Alternative. 

The Umatilla Tribes (CTUIR-35i) recommend that Idaho Power re-survey the area of potential 

effect every 10 years to identify cultural resources beyond those identified to date. Recognizing the 

possibility that additional archaeological sites may be discovered in the area of potential effect over the 

license term, Idaho Power in its draft HPMP has already specified the actions it would take, and the 

guidelines it would follow, should previously unidentified resources be encountered in the course of 

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project operations. An HPMP revised in accordance with Forest Service 4(e) condition no. 25 would also 

include provisions for adaptive management strategies and also for determining when and under what 

circumstances re-survey may be necessary. We therefore do not include the Umatilla Tribes’ 

recommendation in our Staff Alternative.

The Umatilla Tribes (CTUIR-33) recommend that artifacts recovered in the area of potential 

effect as a result of project operations be reburied on site or curated at a federally recognized repository. 

Under federal law, disposition of archaeological materials recovered on federal land is the responsibility 

of the land-managing agency. Because Idaho Power has not indicated how it would treat archaeological 

materials recovered from state, county and private land, we include in the Staff Alternative a requirement 

that Idaho Power include in the final HPMP a policy, developed in consultation with the SHPOs and 

tribes, regarding disposition of archaeological materials recovered from non-federal land. The cost of this 

measure would be included in the overall cost for finalization and implementation of the HPMP. 

BLM (Interior-36) recommends that Idaho Power evaluate, and then protect or mitigate, 

scientifically important paleontological resources discovered in the course of project operations. Idaho 

Power’s draft HPMP already provides for development and implementation of site-specific treatment 

plans for newly-discovered paleontological resources in consultation with BLM and in accordance with 

BLM’s Paleontological Resources Manual. Because we find no reason to recommend exclusion or 

modification of the HPMP’s existing provisions regarding paleontological resources, we therefore do not 

include BLM’s recommendation in the Staff Alternative. 

The Idaho State Historical Society recommends that Idaho Power provide funding to student and 

professional/academic researchers to support study of archaeological materials recovered during previous 

investigations in the project area that have not been analyzed or formally reported on (ISHS-2-1). While 

we recognize that such study could potentially enhance the state of knowledge concerning the cultural 

history of the project area, we conclude that it would not contribute materially toward management and 

protection of those resources extant and still in place within the project, and do not include this measure 

in the Staff Alternative. However, this would not preclude Idaho Power from collaborating on its own 

with institutions, students, and professional/academic researchers and allowing them access to 

archaeological materials in its possession. 

The Idaho State Historical Society and the Nez Perce Tribe recommend that Idaho Power update 

the 1984 National Register nomination for the Hells Canyon Archaeological District, to incorporate the 

numerous additional sites identified during the relicensing surveys (ISHS-6 and NPT-27). In the draft 

EIS, we included this measure in the Staff Alternative because a number of new sites have been recorded 

since 1984 and implementing the measure would not add significantly to Idaho Power’s costs over the 

term of a new license. However, we have reconsidered our position on this measure. We recognize that 

section 106 of NHPA requires the Commission to identify historic properties (resources already listed in 

or eligible for inclusion in the National Register) that may be affected by its actions. However, as noted 

by Idaho Power in its comments on the draft EIS, NHPA does not require the Commission, or a licensee, 

to nominate historic properties to the National Register. Section 110 of NHPA does require federal 

agencies that own or manage land to identify historic properties on that land and to nominate them for 

listing in the National Register. Because the Commission does not own or manage land, the requirements 

of section 110 are not applicable to relicensing of the Hells Canyon Project. Thus, we do not include this 

measure in the Staff Alternative. 

In the draft EIS, we also considered the fact that over time, buildings evaluated in 2003 as 

ineligible for the National Register because they were at that time under 50 years of age would need to be 

reexamined to determine their eligibility under the standard National Register Criteria, potentially 

resulting in a large number of historic buildings that could be affected by project operations. Through an 

oversight, that document’s Staff Alternative did not include a measure regarding future evaluation of 

buildings in the project. We therefore include in the Staff Alternative a measure for developing and 

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implementing a schedule and methodology for re-evaluating buildings and structures as they reach 50 

years of age. The estimated annualized cost of the measure is $3,000. 

5.2.7 Recreation Resources 

5.2.7.1 Recreation Plan 

The Hells Canyon Project includes some of the most important recreational resources in the 

region, and acts as a gateway to the upstream end of the nationally significant Hells Canyon whitewater 

boating run. Idaho Power proposes to implement a project Recreation Plan designed to achieve 10 

objectives that we list in section 3.10.2.2, Recreation Plan. 

The proposed Recreation Plan would formalize Idaho Power’s responsibilities to provide and 

maintain recreational resources throughout the project area, including those formal and dispersed 

recreational sites managed by others that provide public access to the project. The plan would provide a 

framework for Idaho Power to implement the recreational site improvements (discussed in section 

3.10.2.3, Recreational Site Improvements) and coordinate management of recreational resources with the 

many land managers that have jurisdiction over project lands, and monitor recreational use and needs over 

the term of any new license. In section 3.10.2.2, we find that these measures would provide substantial 

improvements to management and delivery of recreational resources and would substantially expand 

recreational opportunities within the project. We estimate the annualized cost of implementing all the 

components and site-specific enhancements of the Recreation Plan would be about $1.2 million. 

In section 3.10.2.2, we find that some of the standards and procedures included in Interior’s 

preliminary 4(e) condition no. 6 would improve the proposed Recreation Plan and benefit recreational 

opportunities by establishing procedures for communication and consultation with other land managers. 

Interior’s condition to establish a stakeholder workgroup would help ensure that appropriate consultation 

occurs as the plan is being developed and implemented without including too many stakeholders in a 

manner that slows planning and delivery of the plan. Similarly, Interior’s specification regarding 

protocols for consultation with agencies would ensure that Interior and other agencies have reasonable 

opportunities to provide input into the finalization and implementation of the plan. Interior’s 

specification with respect to including an ADA discussion in the proposed Recreation Plan would help 

ensure that an appropriate level of barrier-free access is achieved and maintained for the term of any new 

license. We also find in section 3.10.2.2 that several of the administrative components of Forest Service 

4(e) condition FS-12 would help ensure that the proposed Recreation Plan addresses Forest Service 

standards for any improvements constructed on National Forest System lands. 

Based on our analysis in section 3.10.2.2 and our review of agency and tribal conditions and 

recommendations, we include Idaho Power’s proposed Recreation Plan in the Staff Alternative, but we 

modify it to include standards for construction that meet the disparate agency requirements; consideration 

of ADA standards; a description of how Idaho Power would plan, design, and construct new facilities 

(including a detailed description of each measure to the conceptual design level); and a description of how 

Idaho Power would comply with various federal and state standards for site development, help define 

appropriate procedures for implementing the plan, and help ensure that adequate standards are met for all 

recreational improvements over the term of any license issued. Also, we indicate that the plan would be 

finalized in consultation with the primary land managers, including the Forest Service, BLM, IDPR, 

IDFG, ODFW, OPRD, and the Oregon and Idaho counties around the Hells Canyon Project. The staff 

modifications would add an estimated annualized cost of $7,600 to Idaho Power’s proposed plan. 

The Burns Paiute Tribe (BPT-19) recommends that Idaho Power prepare an Integrated 

Comprehensive Recreational Plan, subject to approval by the federal agencies and the Burns Paiute Tribe. 

The plan recommended by the Burns Paiute Tribe appears to be generally consistent with Idaho Power’s 

proposal and would include measures to provide interpretive signage for education and information that 

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would be developed in consultation and with approval of the Tribe. The Tribe also recommends that it 

have the authority to review and approve the selection of all contractor(s) and sub-contractor(s), and, 

whenever possible, that tribal preference would be exercised to develop and increase competencies and 

capacities of the tribe. 

In implementing its Recreation Plan, Idaho Power may select any contractor to do the work. 

However, we note that Idaho Power’s proposed plan would include consultation with agencies, tribes, and 

other stakeholders prior to implementing the measure, which would be the appropriate time for Interior 

and/or the Burns Paiute Tribe to comment on the plan and any proposed contractors. 

5.2.7.2 Recreation Site Improvements 

As part of the proposed Recreation Plan (discussed immediately above), Idaho Power proposes to 

improve existing recreational sites and upgrade some informal recreational facilities to provide an 

improved level of service. These proposed measures are summarized in section 3.10.2.3, Recreation Site 

Improvements, as are the various agency recommendations regarding Idaho Power’s proposal. 

Idaho Power’s proposal is consistent with Forest Service 4(e) conditions FS-13, 14, 15, 16, and 

17, which specify site improvements at Big Bar, Eagle Bar, Eckles Creek, Deep Creek Stairway, and 

pullouts and signage along the Hells Canyon Road. 

Idaho Power’s proposal is also consistent with Interior 4(e) conditions Interior-8, 9, 10, 11, 15, 

and 17, which specify a boat moorage plan as well as site improvements to Airstrip, Bob Creek, Westfall, 

Swedes Landing, Spring, Oxbow, and Copper Creek recreational sites. Idaho Power’s proposal is also 

consistent with Interior-18, which specifies development of a low-water boat launch at or in the vicinity 

of Swedes Landing. We estimate the incremental annualized cost for these measures is $39,600. 

In section 3.10.2.3 we find that, overall, Idaho Power’s proposed site improvement measures at 

existing sites would increase recreational opportunities by providing new facilities and would enhance 

visitors’ recreational experiences. These measures represent a substantial improvement over existing 

conditions and would provide additional capacity in an area where existing project recreational facilities 

would continue to receive heavy recreational use, particularly on some weekends and holidays. We find 

that these measures would address recreational needs associated with growing recreational demand, 

changing recreational needs, and, in cases, deferred maintenance. Accordingly, we include in the Staff 

Alternative Idaho Power’s proposed recreation site improvements. We estimate that the annualized cost 

of implementing Idaho Power’s proposed site improvements (as a component of the total Recreation Plan 

costs described above) would be about $635,900. 

We supplement Idaho Power’s proposal in six specific areas, summarized in the following 

paragraphs and discussed more fully in section 3.10.2.3. Interior’s modified 4(e) condition no. 16 

specifies site planning and enhancements at the Oasis recreation site. The Oasis site is the most southern 

recreational site within the project boundary that provides access to project lands and waters. It is within 

the backwater influence of Brownlee reservoir, and lies within the project boundary. Unlike the more 

remote sites within the project, Oasis is near Interstate 84 and is easily accessible by road from Weiser 

and other nearby population centers. It provides unique recreational access to both riverine and lake 

areas, a characteristic that is somewhat limited in the area, and we therefore anticipate growing use. In 

the Staff Alternative, we include a provision that the Recreation Plan include development and 

implementation of a plan for an initial round of site improvements that would define and contain parking 

and formalize areas for other recreational uses, and, if needed, install improved toilets. We estimate the 

additional annualized cost of the measure to be $4,400. 

Interior’s modified 4(e) condition no. 12 specifies site planning and enhancements at the Steck 

recreation site. Interior’s specification to expand Steck recreation site in anticipation of future 

recreational use does not appear to be needed at this time, since facilities at the site have substantial 

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capacity to meet current use. However, we find in section 3.10.2.3 that it is likely that growing future use 

would degrade the existing facilities and ultimately require expansion and upgrades. Therefore, we 

include in the Staff Alternative Idaho Power’s proposal to include Steck recreation site in the Recreation 

Adaptive Management Plan (see section 3.10.2.9). We find that it would allow Idaho Power and BLM to 

address future recreational requirements, including expansion of the site if needed, over the term of any 

new license issued. We estimate that the additional annualized cost of the measure would be $3,800. 

During the spring freshet, sediment deposition occurs where inflow meets the backwater from 

Brownlee reservoir adjacent to Farewell Bend State Park. Developing and implementing a plan to 

remove the sediments in a systematic manner would improve public access to the reservoir, improve 

aesthetics of the docks, and address project-related effects on the park’s irrigation pumps. In section 

3.10.2.3, we find that seasonal fluctuations of Brownlee reservoir and boat wave action cause erosion 

along almost 80 percent of the Farewell Bend State Park shoreline. Therefore, we include in the Staff 

Alternative measures to harden and protect the shoreline as part of the final Recreation Plan (OPRD-2). 

We conclude that these measures would help reduce project-related losses of recreational land and 

infrastructure, help protect riparian habitats from further degradation, and improve aesthetic 

characteristics of the site. We estimate that the additional annualized cost of the measure would be 

$4,200. 

In modified 4(e) condition no. 13, Interior specifies an enhancement plan for Jennifer’s Alluvial 

Fan. Currently, the informal recreational site is about 6 acres with no facilities, and it is used for projectrelated camping and fishing activities. Interior indicates that recreational use of the area has created 

problems with litter, disposal of human waste, vehicle damage to shoreline areas, and erosion damage at 

the entry/exit point of the site. Given the type of project-related use at the site, and the impact from 

existing use patterns, we find that the site needs a certain amount of formalization to meet existing and 

projected future use. Therefore, we include in the Staff Alternative a measure to develop and implement 

a site plan that includes basic infrastructure such as toilet facilities, vehicular barriers, signage, and 

regular maintenance. This measure would help improve the site condition and would help protect the 

surrounding area from prohibited recreational activities. We estimate that the additional annualized cost 

of the measure would be $9,800. 

As part of its modified 4(e) condition no. 19, the Forest Service specifics lengthening the boat 

ramps at its recreational sites on Hells Canyon reservoir if proposed project operations that would extend 

the lower drawdown level another 5 feet under existing conditions would adversely affect reasonable boat 

access. In section 3.10.2.3, we find that the measure would help ensure that reasonable public access to 

Hells Canyon reservoir continues from Big Bar and Eagle Bar, the only Forest Service-managed sites on 

Hells Canyon reservoir that provide boat access. We note that the condition does not define “prolonged” 

drawdown. We recommend that Idaho Power, as part of the Recreation Plan, define the conditions under 

which boat ramp extensions would be needed. We also recommend that, as part of the Recreation Plan, 

Idaho Power assess the need for extending other public boat ramps at Hells Canyon reservoir, including 

systematic evaluation of existing boat ramps based on the elevation at the bottom of each primary boat 

ramp, the amount of time that boat access would be limited under atypical conditions, and whether 

extending the boat ramp is needed to support public access to the reservoir. Given the uncertainty of 

whether boat ramp extensions would actually need to be constructed, the Staff Alternative does not 

include the cost of such construction. 

As part of its modified 4(e) condition no. 21, the Forest Service specifies enhancements to the 

Hells Canyon Creek boat launch to improve safety and meet recreational needs. The Hells Canyon Creek 

boat launch site is the only area for boaters, and the primary area for anglers, to access the Snake River 

immediately downstream of the project. Given the national significance of the boating run downstream of 

the project, the launch site represents minimal and reasonable access to the Snake River downstream of 

the project, and we conclude that improving the site to enhance access and safety, provide potable water, 

and provide a portable waste disposal system is required for project recreation purposes. Accordingly, we 

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include these improvements in the Staff Alternative, with the provision that the project boundary be 

adjusted to include the launch site and access thereto. We estimate that the additional annualized cost of 

the measure would be $36,100 

We do not include two recommended measures in the Staff Alternative that do not appear to have 

a project nexus. Interior-28 recommends that Idaho Power develop and implement a plan for major 

facility upgrades at Heller Bar, a site considerably downstream and outside of the project boundary. 

IDFG-8 recommends that Idaho Power fund development of angler access sites that would also be 

downstream and outside of the project boundary, with no clear nexus to the project’s recreational 

resources. In section 3.10.2.3, we find that although the recommended measures could improve site 

conditions outside the project, there is no indication that recreational use of these sites is project related or 

that project operations adversely affect the site. We estimate the annualized cost for the Heller Bar 

measure would be $38,000. IDFG did not recommend any particular level of access site development in 

its recommendation (IDFG-8), but we estimate a minimum annualized cost of $20,000 to develop and 

maintain each site. 

5.2.7.3 Sanitation and Litter Management 

The project provides recreational opportunities for many thousands of visitors from the region. 

Due to this intense use, litter and human waste problems occur along the project shorelines, which can 

create public health and safety impacts and aesthetic impacts, and can detract from recreational 

experiences. 

In section 3.10.2.4, Sanitation and Litter Management, we discuss Idaho Power’s proposal to 

enhance its existing Litter and Sanitation Plan for the project by providing additional portable and vault 

toilets at appropriate dispersed recreational sites and by implementing a biannual litter pickup program 

throughout the project area. Idaho Power would develop the plan in consultation with the appropriate 

parties and would implement the Litter and Sanitation Plan for the term of any new license. We conclude 

there that Idaho Power’s litter and sanitation proposal would address an important recreational issue that 

affects both the quality of the recreational experience and the environmental attributes of the dispersed 

sites. Accordingly, we include Idaho Power’s proposed measure in the Staff Alternative. We estimate 

that the annualized cost of the measure would be $61,600. 

Additionally, however, we supplement the proposal in two ways. Idaho Power proposes, and 

Interior’s 4(e) condition no. 7 specifies, the installation of floating restrooms on Brownlee and Oxbow 

reservoirs. Although it is not entirely clear from the record, we assume that these recommendations are 

associated with Idaho Power’s proposal to install moorings for overnight camping, which is also 

consistent with Interior-8, the boat moorage plan. If the final locations of the mooring sites are associated 

with shoreline facilities, the recommended floating restrooms do not appear to be needed. If the location 

of the moorings is more than 1 mile from a developed public access site, then floating restrooms would 

provide an appropriate level of service. Accordingly, in the Staff Alternative we include a provision that 

Idaho Power consult with the appropriate parties to confirm the need for, location of, and maintenance 

standards for floating restrooms. The estimated annualized cost for this measure is $66,800. 

Lastly, modified Forest Service 4(e) condition no. 21 specifies that Idaho Power design, construct 

and maintain a gray water and sanitary cleaning system capable of cleaning portable human waste carryout systems at the Hells Canyon Creek area, which is the only area for boaters and anglers to access the 

Snake River immediately downstream of the project. The area is very remote and is accessible only along 

one project road. The specified sanitation measures appear to be necessary infrastructure to support 

reasonable public access to trips into the HCNRA. We conclude that this measure would benefit project 

purposes, and include it as an element of the Litter and Sanitation Plan in the Staff Alternative. The 

estimated annualized cost is reflected in the cost estimate for other improvements at the Hells Canyon 

Creek boat launch (see section 5.2.7.2, Recreation Site Improvements). 

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We do not include one recommended measure in the Staff Alternative because it does not appear 

to have a project nexus. In section 3.10.2.4, we find that there is no indication in the record that Oregon 

State Marine Board’s recommendation (OSMB-5) to develop a dump station for boat holding tanks at the 

upstream end of the project is needed. Boaters and recreational vehicle campers have options to pump 

holding tanks along major highways throughout the region, and there is no evidence in the record to 

suggest that these regional facilities are insufficient to meet project-related visitor demand for such 

services. We estimate the cost for this measure to be $41,800. 

5.2.7.4 Information and Education 

Idaho Power proposes to develop an Information and Education Plan that includes: (1) review 

and selection of appropriate themes; (2) review and selection of appropriate interpretive media to be used; 

(3) development of a web site and toll-free phone number accessing pertinent recreation-related 

information; and (4) review and selection of prioritized sites where the interpretive media would be 

located. Idaho Power would implement the plan in consultation with the appropriate parties, and operate 

and maintain the facilities and amenities resulting from the plan. Agency and tribal recommendations 

generally support Idaho Power’s proposal (refer to section 3.10.2.5, Information and Education). 

The proposed Information and Education Plan would promote protection and preservation of 

cultural, natural, and historical resources by providing educational and interpretation materials at primary 

recreational sites. The plan would also provide consistency of information and education materials 

between recreational sites, which would help give recreational users the sense of coherent management 

throughout the project area. As described by Idaho Power, the plan does not specify the location or type 

of materials that would be developed. Including this information in the plan, as well as operational and 

maintenance activities and any scheduled updates to the information and education materials, would help 

ensure that the plan can be successfully managed over the term of any new license. We include Idaho 

Power’s development and implementation of an Information and Education Plan in the Staff Alternative. 

The estimated annualized cost of developing and implementing the plan is $149,800. 

In the Staff Alternative, we modify the proposed measure to require that the plan include 

specification of the location and types of information materials to be provided at each location. 

Additionally, in section 3.10.2.5, we agree with NMFS-20 and OSMB-6 that the plan should include the 

provision of information about anadromous fish and invasive species. In the Staff Alternative, therefore, 

we supplement Idaho Power’s proposal to include this provision. Idaho Power contributes substantial 

resources annually toward the improvement of anadromous fish runs, without which certain populations 

of salmon would be further stressed. Including in the plan information about the effects of hydroelectric 

projects and other human activities on anadromous fish runs, and the efforts underway to improve and 

protect these runs within the context of modern energy demands, would help place this issue in a 

contemporary context. Including information about invasive species would help inform visitors about the 

incremental role individual boaters play in spreading non-native species and about the potential harm 

these plants and animals can cause. The estimated annualized cost of these staff modifications is $1,400. 

5.2.7.5 Trails 

Of the numerous recreational and hiking trails that provide access to public lands managed by 

federal agencies near the project, many begin along project roads or at project-related recreational sites. 

Idaho Power proposes to maintain trailheads within the project, but does not propose any specific 

measures for trails outside the project boundary. Idaho Power states that funding for trail improvements 

and maintenance of trails located on federal lands outside the project boundary should remain the 

responsibility of the Forest Service. 

In its modified 4(e) condition no. 20, the Forest Service specifies that Idaho Power perform trail 

maintenance on Forest Service trails accessed from the Hells Canyon reservoir and Hells Canyon Creek 

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launch site. In section 3.10.2.6, Trails, we find that recreational use within the project boundary is 

primarily associated with the project reservoirs, including boating, fishing and camping. With the 

exception of a few specific trails within the project boundary, little evidence in the record suggests that 

use of hiking trails originating at the project are related to a project purpose. In our analysis in section 

3.10.2.6, we do not find a clear nexus between project operations and recreational use of Forest Servicemanaged trails outside of the project boundary. We conclude that Idaho Power addresses the primary 

project-related effects on Forest Service managed trails originating within the Hells Canyon Project by 

proposing to maintain pull-out and parking areas along Hells Canyon Road and improving sanitation and 

increasing litter patrols throughout the project. Therefore, we do not include this Forest Service condition 

in the Staff Alternative. The estimated annualized cost of this condition is $3,000. 

Interior, in its modified 4(e) condition no. 3, specifies that, as part of an integrated travel and 

access management plan for BLM-administered lands, Idaho Power develop and implement a plan for 

non-motorized use of trails connecting recreation sites along the Oregon side of Hells Canyon reservoir 

and conduct a feasibility study for developing a trail system along the Hells Canyon, Brownlee, and 

Oxbow reservoirs connecting Farewell Bend State Park to the HCNRA. We conclude that Interior has 

not established a clear need for the recommended trail system to provide reasonable public access to the 

project or between project facilities, and we do not include this measure in the Staff Alternative. The 

estimated annualized cost if this measure is included in the cost of measures discussed below under Road 

Management Plan. 

5.2.7.6 Operation and Maintenance at Forest Service and BLM Sites 

In section 3.10.2.7, Operation and Maintenance of Forest Service and BLM Sites, we discuss 

Idaho Power’s proposal to continue operation and maintenance of its parks and recreation facilities and to 

perform operation and maintenance at Idaho Power-enhanced BLM and Forest Service reservoir-related 

recreational sites within the project boundary. This proposal would ensure that these facilities are 

adequately maintained for the license term and we include this measure in the Staff Alternative at an 

estimated annualized cost of $85,300. 

Forest Service modified 4(e) condition no. 18 specifies that Idaho Power perform O&M 

necessary to meet Forest Service Standards. In section 3.10.2.7, we find that the condition appears to be 

primarily concerned with Idaho Power developing O&M standards in consultation with the Forest Service 

as part of the Recreation Plan. Idaho Power has agreed to implement FS-18 under its Settlement 

Agreement with the Forest Service. We include FS-18 in the Staff Alternative; the cost is reflected in the 

$85,300 annualized cost of Idaho Power’s proposed operation and maintenance plan. 

Forest Service modified 4(e) condition no. 21 specifies that, among other things, Idaho Power 

perform 100 percent of the O&M necessary to maintain the Forest Service-specified improvements at the 

Hells Canyon launch and 50 percent of the remaining O&M needs at the Hells Canyon Creek launch. As 

discussed in section 3.10.2.3, Recreation Site Improvements, we find a clear nexus between the project 

and providing reasonable public access to the Snake River downstream of the project. For that reason, we 

recommend including the site in the project boundary (see section 5.2.8.3). However, we also 

acknowledge that the launch is on Forest Service-managed lands and many of the activities that occur at 

the launch may not be project related. Because of the importance of the launch area and to ensure that the 

site is adequately maintained for the term of any new license, we include in the Staff Alternative a 

provision for Idaho Power to develop a detailed agreement with the Forest Service regarding O&M as 

part of the final Recreation Plan. It is, however, Idaho Power’s responsibility to ensure that the site is 

maintained. 

Interior specifies as part of its site-specific modified 4(e) measures that Idaho Power perform 

O&M at all BLM-administered recreational sites. Idaho Power does not propose to handle O&M at BLM 

sites within the project boundary except where Idaho Power is proposing site enhancements. In section 

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3.10.2.7 we note that, regardless of which party provides or funds O&M services, the Commission would 

hold Idaho Power, as the licensee, responsible for the proper implementation of any measure included in 

any license for the project. Therefore, the Staff Alternative indicates that Idaho Power should prepare an 

O&M plan for each site within the project boundary that describes the maintenance standard applicable to 

the site and indicate how that standard will be met, to ensure an appropriate level of O&M at all 

developed Forest Service and BLM sites within the project boundary. Idaho Power may enter agreements 

with the agencies to cost-share O&M and other capital measures, but it is ultimately the licensee’s 

responsibility to ensure that recreational resources that provide public access to the project are maintained 

at an adequate level. 

5.2.7.7 Adaptive Management 

Idaho Power proposes to develop a Recreation Adaptive Management Plan to identify and 

address recreation management, measures, and facility needs for the project over the term of any new 

license. Idaho Power would use recreational monitoring as the basis for evaluating and recommending 

any changes to the Recreation Plan that may be needed. Proposed monitoring would include annual 

informal onsite observations and traffic counters, as well as a more detailed recreational survey of social 

indicators and general recreational use every 6 years. Idaho Power would prepare summary reports for 

stakeholders annually and a comprehensive report every 6 years in coordination with FERC Form 80 

(Licensed Hydropower Development Recreation Report) filing. Consultation with agencies and entities 

would occur in coordination with FERC Form 80 filing. 

We review numerous conditions, alternative conditions, and recommendations pertaining to 

ongoing recreation management in section 3.10.2.9, Adaptive Management. In that section, we conclude 

that Idaho Power’s proposed Recreation Adaptive Management Plan would provide a flexible tool that 

could accommodate changing use over time, and we include it in the Staff Alternative. Idaho Power’s 

consultation list includes the primary recreational managers in the project area, and the plan would 

provide a substantial level of coordination and consultation. The estimated annualized cost of developing 

and implementing the Recreation Adaptive Management Plan is $108,100. 

Interior modified 4(e) condition no. 14 specifies development of a management plan for dispersed 

sites, which are undeveloped or informal sites. We note that Idaho Power’s proposed Recreation 

Adaptive Management Plan does not include the numerous dispersed recreational sites throughout the 

project area. These sites may be the appropriate locations for further development if the Recreation 

Adaptive Management Plan identifies a need for more development in the future. Therefore, and based 

on our analysis in section 3.10.2.9, we include in the Staff Alternative a modification of Idaho Power’s 

measure, indicating that the Recreation Adaptive Management Plan’s scope should include dispersed site 

management, and that it include detailed procedures for recreational use monitoring and reporting. The 

estimated annualized cost of the staff additions is $69,000. 

5.2.8 Land Management and Aesthetics 

5.2.8.1 Land Use Management 

Project facilities and operations can be incompatible with other land and water uses within the 

project boundary, such as when development of a recreation facility leads to shoreline erosion or adverse 

effects on wildlife habitat or cultural resources. Land management issues also include the adequacy of 

buffers that separate incompatible uses, and the adequacy of management measures designed to protect 

natural and cultural resources. 

Idaho Power proposes to implement the Hells Canyon Resource Management Plan (HCRMP) to 

guide land management decisions within the project boundary. The plan has already been developed and 

includes defining buffers between incompatible uses and establishing and maintaining compatibility 

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between and among the various land and water uses in the project. Various policies within the plan 

require the development of implementation tools and programs as well as management plans specific to a 

resource or issue, and would include an information and education program; evaluation of dispersed 

recreation sites; evaluation of recreation/riparian interfaces; establishment of O&M standard practices; a 

GIS atlas; land and water use classifications; an Idaho Power interdisciplinary team; a program for 

coordinating with other parties, including forums for coordination and evaluation of existing agreements 

and new agreements and partnerships with agencies; and establishment of best management practices. 

The Forest Service (FS-1) specifies that Idaho Power obtain approval for site-specific project 

designs prior to any habitat or ground-disturbing activities on Forest Service lands and that if any Forest 

Service lands are added to the project boundary that Idaho Power obtain special-use authorization for 

occupancy and use of these lands. FS-2 specifies that Idaho Power prepare a resource coordination plan 

to establish a process for information exchange and to coordinate efforts for implementing license 

conditions, such as any required management plans, and ongoing project O&M activities potentially 

affecting Forest Service lands. This plan would include annual Forest Service consultation requirements; 

documentation of efforts to monitor project effects on other resources and effectiveness of required 

enhancement measures; means for revising or improving implementation strategies as needed; and 

standard operating procedures for activities on Forest Service lands. 

Interior-1 specifies that Idaho Power consult and cooperate with BLM prior to initiating activities 

on BLM-administered lands within the project boundary. Interior’s condition would require Idaho Power, 

among other things, to prepare site-specific plans for approval by BLM, including a safety-duringconstruction plan and a spoils disposal plan prior to any ground disturbing activities on BLMadministered lands. Interior-2 specifies that Idaho Power prepare and provide a written report in 

consultation with BLM documenting and/or evaluating measures necessary for the continued protection 

and utilization of BLM-administered lands and resources within the project boundary. 

The Burns Paiute Tribe (BPT-3) recommends that Idaho Power establish and fund a resource 

coordinating committee comprising involved stakeholders to review and maintain oversight over the 

implementation of project activities, including the implementation of mitigation, adaptive management, 

and license implementation decision-making. AR/IRU recommend (AR/IRU-3) that the final license 

include an adaptive management approach and that a Technical Advisory Committee be convened to 

oversee adaptive management in the license. The Technical Advisory Committee, which would include 

the various stakeholders, would oversee study design and implementation, develop mitigation measures 

based on those studies, and oversee implementation and monitoring of the measures. 

Including the proposed HCRMP and its common policies and including the proposed 

implementation tools in consultation with stakeholders would help ensure that compatibility among land 

uses is achieved and maintained by determining appropriate land and water uses and applying standard 

approaches to managing human use and resource protection. However, the proposed HCRMP includes 

only a few details about how the plan would be implemented. Including additional details regarding 

implementation of the HCRMP, such as identifying which policies require the development of specific 

management plans, and identifying additional implementation programs that might be necessary to 

address project effects on other resources, would help ensure that policies are acted upon, stakeholders 

understand Idaho Power’s intent, and resources are protected while allowing for human use and necessary 

project operations. We include Idaho Power’s proposed HCRMP in the Staff Alternative, and indicate 

that the additional details should be provided. We estimate the extra cost of the staff modifications to be 

$1,500 on an annualized basis. 

The HCRMP calls for development of several programs to facilitate coordination and 

consultation between Idaho Power and local, state and federal agencies as well as other stakeholders. 

Post-license consultation is also required in the development and implementation of plans for aquatic, 

terrestrial, cultural, and recreation resources. Formation of an oversight committee, as recommended by 

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the Burns Paiute Tribe (BPT-3) and AR/IRU (AR/IRU-3), would provide a standing forum for 

consultation and coordination. Similarly, formation of resource-specific Technical Advisory Committees 

would facilitate ongoing consultation on resource plans and programs required by a new license. We 

include the creation and support of an advisory oversight committee and resource-specific Technical 

Advisory Committees by Idaho Power in the Staff Alternative to facilitate the normal FERC consultation 

process on the development and implementation of plans required by the new license and to provide a 

forum for consultation on the ongoing implementation of license provision using adaptive management 

principles. We estimate the annualized cost of this measure to be $50,000. FS-1 and FS-2 specify a 

separate plan to address consultation with the Forest Service. We include these measures in the Staff 

Alternative, but find that this condition would be better met through development and implementation of 

the HCRMP, including details on consultation, coordination, and reporting. The scope of activities would 

be limited to Forest Service lands within the project boundary. We estimate that the annualized cost to 

Idaho Power in addition to implementing the proposed HCRMP is $1,000 for FS-1 and $6,100 for FS-2. 

Interior-1 and -2, which we include in the Staff Alternative, appear to be generally consistent with 

the consulting and coordination measures in Idaho Power’s HCRMP, but may require additional study 

analysis in the plan and may require additional time to implement. We estimate the annualized cost of 

these measures to be $4,400, and $5,000 respectively. 

5.2.8.2 Law Enforcement and Fire Protection 

Disturbances requiring law enforcement at the project occur throughout the year and peak during 

the summer recreational season. Issues include conflicts between users and the timeliness of response to 

safety-related incidents in remote areas such as the HCNRA. Various stakeholders have commented that 

the level of resources for and support of emergency services provided by Idaho Power is not sufficient to 

provide for visitor safety. 

Idaho Power proposes to continue to support local law enforcement, indicating that such support 

improves public safety in the project area by decreasing emergency response times and increasing law 

enforcement presence. Additionally, Idaho Power proposes to sponsor biannual meetings regarding law 

enforcement issues, resources, and responsibilities; provide access to its property and facilities; and 

contribute to the O&M costs associated with this measure. 

In section 3.12.2.3, Law Enforcement, we describe preliminary conditions and recommendations 

of Interior (Interior-4), ODFW (ODFW-85), and the Oregon State Marine Board (OSMB-1, -2, and -3). 

In that section, we point out that the responsibility of funding law enforcement activities on private, state, 

and federal lands, including the funding of law enforcement personnel as specified by Interior and 

recommended by the Oregon State Marine Board and ODFW, lies with the county, state, and federal 

agencies having jurisdiction over those areas. Therefore, we do not include Idaho Power funding of third 

parties for law enforcement activities in the Staff Alternative. 

Because several state and federal agencies and counties have land management and law 

enforcement responsibilities within the project area, we see the merit of Idaho Power coordinating these 

efforts through biannual meetings, as specified by Interior (Interior-4) and recommended by the Oregon 

State Marine Board and ODFW. Including such meetings in a law enforcement plan would assist in 

evaluating and coordinating law enforcement activities. We modify Idaho Power’s Policy 6.3.8.4 of the 

HCRMP to state that Idaho Power will sponsor biannual meetings and continue to coordinate with law 

enforcement agencies with jurisdiction within the planning area on a regular basis. We estimate that the 

additional annualized cost of this measure would be $5,000. 

The project includes a mix of private and public lands adjacent to large tracts of undeveloped 

lands. Fires started on Idaho Power-owned lands within the project could rapidly spread to adjacent 

properties or onto the large public tracts. Fire suppression is the responsibility of the counties and the 

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federal land managers, but, given the rural character of the project, it is unclear whether this is sufficient 

to protect the health, safety, and welfare of project visitors. 

Idaho Power proposes as part of the HCRMP to continue to coordinate with public agencies 

regarding the occurrence of controlled and uncontrolled fires, to suppress fires on its property, and to 

cooperate with agencies to manage visitor access during uncontrolled fires. In section 3.12.2.4, Fire 

Protection, we review Interior preliminary 4(e) condition no. 4 and Forest Service preliminary 4(e) 

condition no. 3 and conclude that the HCRMP lacks sufficient detail in the area of fire protection. 

Accordingly, we include in the Staff Alternative a provision that, in finalizing the HCRMP, Idaho Power 

include fire protection plan details including how Idaho Power would suppress fires on its lands and how 

it would manage and communicate with project visitors during evacuations. Also, developing a fire 

prevention plan for lands within the project boundary as specified by Interior and the Forest Service could 

help prevent potential fires from spreading beyond project lands and would aid county and agency 

personnel if a fire were to move beyond the project boundary. The plan would cover all lands within the 

project boundary, including private and public recreational sites. Idaho Power would be the appropriate 

entity to coordinate fire prevention efforts on project lands, but Idaho Power would bear the responsibility 

for funding only efforts required within the project boundary. The cost of these measures is included in 

the overall cost of developing and implementing the HCRMP. 

5.2.8.3 Boundary Modifications 

The FPA requires the project licensee to provide safe public access to project lands and waters 

and include those lands necessary for project purposes in the project boundary. In accordance with this 

law, the Commission requires that the project boundary contain the primary recreational facilities used to 

access project waters, as well as the lands necessary to ensure access for the term of the license, and the 

lands necessary to ensure an appropriate buffer between the project and neighboring lands. 

Idaho Power proposes to remove 3,800 acres of federal land from the existing boundary. The 

new boundary would follow the same contour line as that followed on private lands, rather than following 

the metes and bounds system that was used to determine the project boundary on federal lands. We 

discuss this issue in section 3.12.2.5, Boundary Modifications. 

We conclude there that standardizing the boundary at the same contour line on both private and 

federal lands appears to be a sound approach to setting the project boundary. Including all dispersed 

recreation sites within 200 yards of project waters in the proposed project boundary and defining them on 

a map that includes the project boundary would clarify which sites would be included within the project 

boundary and would help ensure that dispersed sites are maintained in place to provide project access. 

The recreation sites that Interior recommends for inclusion in the project boundary—Airstrip, Steck Park, 

Swedes Landing, and Westfall recreation sites—are currently at least partially located within the project 

boundary and provide access to the reservoirs. As discussed above, we also recommend including the 

Hells Canyon Launch area and the Deep Creek trail in the project boundary. Including these recreation 

sites within the project boundary is appropriate. Additionally, all lands acquired for wildlife mitigation 

purposes should be included within the project boundary. We estimate that the annualized costs of 

mapping and monitoring these additional lands would be $1,000. 

As part of any new license, Idaho Power would provide a revised exhibit G (project boundary 

map) that would include a detailed description and maps of the project boundary. We conclude that this 

information, supplemented by Idaho Power’s plan and the Forest Service’s condition (FS-26) to provide 

aerial photos marked with the project boundary, would provide sufficient definition of the boundary. 

Surveys may be necessary before any ground disturbing activities are undertaken to verify the boundary 

on the ground. This is true for all project lands, not just Forest Service lands. Such surveys would ensure 

that natural and cultural resources are not compromised and that ground disturbing activities occur only 

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within the project boundary. We do not estimate a cost for this measure because it requires a one-time 

effort associated with Idaho Power’s filing of a revised exhibit G. 

5.2.8.4 Road Management Plan 

Idaho Power-owned or maintained roads within the project area provide both public access to 

project lands and waters and Idaho Power access to project developments. Project roads may have 

adverse effects on cultural and natural resources by allowing public access to areas where these resources 

occur. Appropriate project road management provides for safety and protection of environmental 

resources while continuing to provide reasonable public access to the project. 

Idaho Power proposes to continue maintenance of roads that it owns and/or maintains: OxbowHells Canyon Road, 22 miles; Homestead Road from Oxbow, Oregon, to Ballard Creek, 6 miles; and 

Brownlee-Oxbow Road, 12 miles. In addition, Idaho Power proposes to develop a Road Management 

Plan as an element of the HCRMP to increase the effectiveness and efficiency of efforts to manage, 

maintain, and enhance travel and access to not only project lands but also lands within the vicinity of the 

project and assist in the assessment of Idaho Power's role and responsibilities with regard to travel and 

access to the Project. The plan is also intended to foster coordination, cooperation and integration of 

efforts between the Licensee and the various entities with jurisdiction for roads. 

As proposed by Idaho Power and recommended by ODFW (ODFW-76) and specified by the 

Forest Service as part of its modified 4(e) condition no. 12, a Road Management Plan would improve 

access management by considering appropriate traffic levels to protect natural and cultural resources 

while providing reasonable public access. Such a plan would increase public safety by providing for road 

maintenance and management consistent with recreational demand and the goals of the HCRMP on those 

roads within the project boundary. We include the Road Management Plan in the Staff Alternative and 

estimate that the annualized cost of Idaho Power’s proposed plan is $27,800. This cost is included in the 

total HCRMP costs. We estimate minor additional annualized costs associated with fulfilling ODFW-76 

to be $1,100. 

Idaho Power’s proposed plan lacks certain details that would be necessary to ensure public access 

and protect project-related environmental resources. In its comments on the draft EIS, Idaho Power 

clarifies that the Road Management Plan would include an atlas as part of the GIS system. To ensure that 

road management measures are part of the GIS system, we continue to include in the Staff Alternative 

additional measures to be included in the plan. The first is a provision that Idaho Power include in the 

Road Management Plan development of a road atlas as part of the proposed GIS system that depicts 

locations of natural areas and describes cultural resources designed to limit conflicts between human use 

and valuable resources. The second staff-developed provision is that Idaho Power, in consultation with 

federal land managers and adjacent local governments, provide as part of the plan information detailing 

which roads are required for project purposes. We note that any such roads would need to be included 

within the project boundary. Finally, the road management plan, as modified by staff, would include a 

maintenance schedule describing Idaho Power’s maintenance responsibilities on all project roads. We 

estimate the annualized cost of these extra Road Management Plan provisions to be $1,500. 

Interior’s modified 4(e) condition no. 3 specifies that Idaho Power develop an integrated travel 

and access management plan for BLM-administered lands affected by the project, to be incorporated into 

the Interior-recommended comprehensive recreation management plan and coordinated with the Interiorrecommended integrated wildlife habitat program and wildlife mitigation and management plan. 

However, most of the roads listed in the condition are outside of the project boundary and are managed by 

county and state governments. Interior has not established in the record a clear nexus between project 

operations and the need for road maintenance on all of the county and state roads outside of the project 

boundary. Given the numerous roads that provide access to the project, it appears that this measure 

overstates the licensee’s responsibility to provide reasonable public access to the project. Further, it is the 

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responsibility of state and county governments to maintain roads that are within their jurisdiction and that 

are used for non-project purposes. Therefore, we do not include this measure in the Staff Alternative. 

We estimate the additional annual cost of this measure, if included in the Staff Alternative, would be 

$15,100. 

5.2.8.5 Aesthetic Resource Management 

As part of its settlement with the Forest Service and consistent with modified terms and 

conditions FS-22, Idaho Power also proposes to develop an aesthetic improvement plan for the Hells 

Canyon Dam Site and Recreational Portal. The proposal and FS-22 call for Idaho Power to enhance the 

upper deck, entrance, and egress areas of Hells Canyon dam that will be incorporated into the Scenery 

Management Plan and file the aesthetic improvement plan with the Commission for approval. Alterations 

may include changes in fencing material, color of materials, screening of stop blocks, parking, signage, 

pedestrian walkways, interpretation, viewing areas and landscaping provided that such alterations are 

consistent with the FERC approved security plan for the Dam. A schedule for implementation, to be 

conducted by the Licensee, would be included in the aesthetic improvement plan. 

Idaho Power originally proposed to implement aesthetic measures as part of the HCRMP (see 

section 3.12.2.1, Land Use Management Plan) in which goals and objectives as well as policies and 

guidelines for aesthetic standards are discussed. Now, as part of its settlement with the Forest Service and 

consistent with modified terms and condition FS-24, Idaho Power proposes to prepare a Scenery 

Management Plan for project facilities and operations on Forest Service lands within the project boundary 

and adjacent to the project boundary within 1 year of license issuance. This plan would include: existing 

transmission lines and associated service roads; design standards and guidelines for physical structures 

and landscaping; general aesthetic clean-up and implementation; replacement of guardrails and jersey 

barriers; mitigation of contrast from project facilities; and enhancement of other facilities. 

Interior-25 recommends that Idaho Power develop a visual resource management plan (VRMP) 

for project facilities to address the design, maintenance, and construction of project facilities (both 

existing and future) in order to preserve or enhance visual resource values. Interior would have the 

VRMP apply to the following facilities: (1) dams, bypass canals, spillways (concrete structures); 

(2) switch yards, power houses, buildings, penstocks, powerlines (metal structures); (3) project recreation 

facilities including campgrounds and day-use sites; and (4) powerline access corridors and cutbanks. The 

annualized cost of this measure, which we include in the Staff Alternative, would be $2,500. 

Based on our analysis presented in section 3.11.2.2, Aesthetic Improvements and Resource 

Management, we conclude that development and implementation of an aesthetics improvement measures 

would improve the aesthetic character of the Hells Canyon Project by creating a framework of aesthetic 

design standards and guidelines under which Idaho Power would plan, develop and rehabilitate project 

facilities over the term of a new license. Including the aesthetic measures proposed by Idaho Power 

would improve the scenic integrity of the landscape within the project vicinity, and we include them in 

the Staff Alternative. We estimate the annualized cost of Idaho Power’s proposal to be $168,800. 

5.3 SUMMARY OF 10(j) RECOMMENDATIONS AND 4(e) CONDITIONS 

5.3.1 Fish and Wildlife Agency Recommendations 

Under the provisions of the FPA, each hydroelectric license issued by the Commission shall 

include conditions based on recommendations provided by federal and state fish and wildlife agencies for 

the protection, mitigation, or enhancement of fish and wildlife resources affected by the project. In 

response to our REA notice, the following fish and wildlife agencies submitted recommendations for the 

project: NMFS (letter filed January 25, 2006), Interior (letter filed January 27, 2006), ODFW (letter filed 

January 25, 2006) and IDFG (letter filed January 26, 2006). 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
715 

Section 10(j) of the FPA states that whenever the Commission believes that any fish and wildlife 

agency recommendation is inconsistent with the purposes and the requirements of the FPA or other 

applicable law, the Commission and the agency shall attempt to resolve any such inconsistency, giving 

due weight to the recommendations, expertise, and statutory responsibilities of such agency. Table 108 

lists the federal and state recommendations filed pursuant to section 10(j) and indicates whether the 

recommendations are included under the Staff Alternative. Environmental recommendations that we 

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. 

In the draft EIS, of the 173 recommendations that we considered to be within the scope of section 

10(j), we wholly included 92 measures in the Staff Alternative, included 27 in part, and did not include 

54. Following publication of the draft EIS, we held a meeting with the fish and wildlife agencies to try to 

resolve inconsistencies with the FPA and to provide both agency personnel and FERC staff the 

opportunity to clarify their positions on various measures that we did not adopt as part of the Staff 

Alternative. The 10(j) meeting was held in Boise, Idaho, on December 5 to December 7, 2006; other 

interested parties, including representatives of Idaho Power, several tribes, and other organizations, also 

participated. We filed a meeting summary on January 12, 2007. Comments on the meeting summary 

were filed by IDFG (January 30, 2007), NMFS (February 8, 2007), the Forest Service (February 12, 

2007), ODFW (February 21, 2007), and Interior (March 15, 2007). As a result of the meeting and 

subsequent clarifications, as well as, the agencies’ comments on the draft EIS, we revised our 

recommendation concerning several 10(j) measures. Among the measures we now adopt as part of the 

Staff Alternative are: (1) the FWS modified fishway prescription; (2) enhancement measures to support 

redband and bull trout restoration in portions of the Powder and Burnt River basins; (3) funding for the 

development and implementation of Hatchery and Genetic Management Plans for each mitigation 

hatchery; (4) development and implementation of an invertebrate monitoring plan to evaluate trends in the 

abundance and distribution of rare and sensitive species of mollusks; (5) assessment of water qualityrelated effects on white sturgeon, genetic monitoring, and translocation of reproductive-sized white 

sturgeon into the Swan Falls-Brownlee reach; (6) evaluation of fall Chinook salmon egg-to-fry survival; 

and (7) habitat management of 4 state-owned islands rather than 2 islands. 

In this final EIS, of the 173 recommendations that we consider to be within the scope of section 

10(j), we wholly include 110 in the Staff Alternative, include 18 in part, and do not include 45. We 

discuss the reasons for not including those recommendations in section 5.2, Discussion of Key Issues. 

Table 108 indicates the basis for our preliminary determinations concerning measures that we consider 

inconsistent with section 10(j). 

5.3.2 Interior and Forest Service 4(e) Conditions 

In section 2.3.1.3, Section 4(e) Federal Land Management Conditions, we list the modified 4(e) 

conditions submitted by Interior and the Forest Service, and note that section 4(e) of the FPA, 16 U.S.C. § 

797(e), provides that any license issued by the Commission “for a project within a federal reservation 

shall be subject to and contain such conditions as the Secretary of the responsible federal land 

management agency deems necessary for the adequate protection and use of the reservation.” Thus, any 

4(e) condition that meets the requirements of the law must be included in any license issued by the 

Commission, regardless of whether we include the condition in our Staff Alternative. Table 109 

summarizes our staff conclusion with respect to the modified 4(e) conditions. Of the 44 modified 4(e) 

conditions submitted by Interior and the Forest Service, we include in the Staff Alternative 36 conditions 

as specified by the agency and include 4 slightly modified to adjust the scope of the measure. We note 

that one condition (regarding reservation of authority) would be addressed in the license order, and do not 

include the remaining 3 conditions for reasons summarized in table 109 and discussed in more detail in 

section 5.2, Discussion of Key Issues. 

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Table 108. Fish and wildlife agency recommendations for the Hells Canyon Project. (Source: Staff). 

Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

IDFG-1a Continue Idaho Power’s fall Chinook spawning 

program, which includes providing stable flows. 

Yes $0a Adopted 

IDFG-1b Conduct juvenile entrapment and stranding study to 

assess effects of load following on juvenile fall Chinook salmon, establish long-term monitoring sites and operating protocols. 

Yes $28,700 Adopted, except th

of 4 inches per houadditional operatindeveloped through 

IDFG-2 Continue to conduct shallow redd surveys and monitor 

temperature; distribute temperature monitors broadly so that differences in emergence timing between reaches can be predicted. 

Yes $0a Adopted; temperat

would be addressespawning and incuplan. 

IDFG-3a Investigate effects of hatchery steelhead on federally 

listed steelhead. 

Yes $46,200 Adopted 

IDFG-3b Develop locally adapted steelhead broodstock. Yes $10,500 Adopted IDFG-3c Expand Oxbow hatchery Chinook rearing. Yes $293,500 Adopted IDFG-3d Make improvements to Niagara Springs Hatchery. Yes $136,600 Adopted IDFG-4 Establish anadromous fish hatchery goals, based on 

adult returns and societal use. 

Yes $0 Adopted, cost is in

IDFG-5a Fund fish hatchery performance evaluations. Yes Not 

estimated 

Adopted 

IDFG-6a Purchase a new fish marking unit. Yes $81,400 Adopted IDFG-6b Upgrade facility to reduce pathogens at Pahsimeroi 

hatchery. 

Yes $649,000 Adopted 

IDFG-7 Purchase new adult fish transport vehicle. Yes $18,300 Adopted IDFG-8 Provide fund to improve public angler access to several 

fisheries. 

No, recreation 

measure 

Not 

estimated 

Not adopted 

IDFG-9 Fall Chinook incubation survival monitoring upstream 

of Brownlee reservoir. 

Yes $20,000 Not adoptedd (see 

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Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

IDFG-10a Monitor Pacific lamprey population status downstream 

of the project. 

Noc $8,300 Not adopted 

IDFG-10b Participate in the Columbia River basin Lamprey 

Technical Work Group 

No $5,000 Adopted 

IDFG-11 Develop a native salmonid plan. Yes $2,500 Adopted 

IDFG-12 Implement a pathogen risk assessment. Yes $40,000 Adopted IDFG-13 Initiate a fish passage program, but do not translocate 

adult bull trout into Indian Creek or Wildhorse River unless adverse effects from brook trout can be addressed. 

Yes Not 

estimated 

Adopted 

IDFG-14 Design, construct and operate improved adult 

collection facilities at Hells Canyon dam. 

Yes $658,500 Adopted 

IDFG-15 If the Oxbow trap is not constructed reallocate funds 

($7 million) to alternative habitat enhancement projects. 

Noc $270,200 Not adopted 

IDFG-16 Expand tributary habitat enhancement program to 

include the Weiser River drainage and include a mechanism for re-allocating funds not used for fish passage or other measures. 

No, no nexus to 

project 

Not 

estimated 

Not adopted 

IDFG-17 Supplement nutrients for resident salmonids using 

spawned carcasses or carcass analogs, consider supplementing nutrients in the Weiser River recovery subunit until brook trout suppression efforts in Indian Creek and the Wildhorse River have been effective. 

Yes $40,000 Adopted, except fo

Riverd (see section 

IDFG-18 Conduct Eagle Creek presence/absence survey to 

determine, with statistical probability, the presence or absence of bull trout within the Eagle Creek Basin. 

Noc $42,700 Adopted 

IDFG-19 Design, construct, and monitor a weir facility at Pine 

Creek designed to collect bull trout (sized for fall flows). 

Yes $365,500 Adopted 

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Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

IDFG-20 Explore feasibility of methods to control brook trout in 

Indian Creek, reallocate funding to other measures if not feasible. 

Yes $50,000 Adopted, except fo

IDFG-21 Use the White Sturgeon Conservation Plan to 

contribute to the long-term goal of restoring healthy white sturgeon populations. 

Yes Not 

estimated 

Adopted 

IDFG-22 Assess water quality-related effects on early life stages 

of white sturgeon in the Swan Falls-Brownlee reach. 

Noc $24,000 Adopted 

IDFG-23 Translocate reproductive-sized white sturgeon into the 

Swan Falls-Brownlee reach to increase spawner abundance and population productivity, if water quality is found to be adequate. 

Yes $20,600 Adopted 

IDFG-24 Evaluate the genetic implications of hatchery 

supplementation on wild stocks of white surgeon before developing an experimental conservation aquaculture program. 

Noc $1,080 Adopted; evaluatio

would be addressethe Conservation A

IDFG-25 Make periodic population assessments to monitor 

white sturgeon populations in the Swan FallsBrownlee, Brownlee-Hells Canyon, and Hells CanyonLower Granite reaches of the Snake River. 

Yes $82,100 Adopted 

IDFG-26 Monitor genotypic frequencies of white sturgeon 

between Shoshone Falls and Lower Granite dams. 

Noc $2,300 Adopted, except th

genotypic frequenFalls dam is not inaddressed in licensPower’s upstream 

IDFG-27 Implement proposed reservoir level restrictions to 

benefit warmwater fish; if economic or system emergencies occur that require changes in the operational regime, consult IDFG and ODFW to evaluate alternative strategies to protect warmwater fisheries. 

Yes (except for 

the consultation 

requirement) 

$1,080 Adopted 

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719 

Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

IDFG-28 Acquire and manage 23,582 acres as mitigation for 

project effects. 

Yes $1,651,100 Adopted 

IDFG-29 Acquire and manage 47,164 acres if initial target lands 

are unavailable. 

Yes $3,323,100 Not adoptedd (see 

IDFG-30 Enhance low-elevation riparian habitat and participate 

in mountain quail projects for 5 years. 

Yes $9,600 Adopted 

IDFG-31 Fund habitat management on four state-owned islands. Yes $42,900 Adopted IDFG-32 Implement cooperative weed control, site monitoring, 

and reseeding. 

Yes $50,000 Adopted 

IDFG-33 Implement cooperative protection and monitoring of 

rare plant sites. 

Noc $6,000 Adopted; included 

endangered, and semanagement 

Interior-37a Develop and implement a plan to improve habitat 

conditions in Pine Creek and associated tributaries. 

Yes $535,200 Adopted 

Interior-37b Design, construct, and monitor a weir facility at Pine 

Creek designed to collect bull trout (sized for fall flows) 

Yes $365,500 Adopted 

Interior-37c Conduct population monitoring activities, including 

periodic weir monitoring or radio telemetry studies of bull trout in Pine Creek. 

Yes $20,000 Adopted; cost is in

Interior-37d Explore and implement, if necessary, measures to 

control brook trout in Pine Creek 

Yes $50,000 Adopted 

Interior-38a Develop and implement a plan to improve habitat 

conditions in Indian Creek and associated tributaries 

Yes $76,500 Adopted 

Interior-38b Operate and maintain a permanent weir structure at the 

mouth of Indian Creek if trigger criteria identified in Interior’s modified fishway prescription are met. 

Yes $182,700 Adopted 

Interior-38c Conduct population monitoring activities, including 

periodic weir monitoring or radio telemetry studies of bull trout in Indian Creek. 

Yes $20,000 Adopted; cost is in

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720 

Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

Interior-38d Explore and implement, if necessary, measures to 

control brook trout in Indian Creek. 

Yes $50,000 Adopted 

Interior-39a Develop and implement a plan to improve habitat 

conditions in the Wildhorse River and associated tributaries. 

Yes $316,700 Adopted 

Interior-39b Operate and maintain a permanent weir structure at the 

mouth of the Wildhorse River if trigger criteria identified in Interior’s modified fishway prescription are met. 

Yes $365,500 Adopted 

Interior-39c Conduct population monitoring activities, including 

periodic weir monitoring or radio telemetry studies of bull trout in the Wildhorse River. 

Yes $20,000 Adopted; cost is in

Interior-39d Explore and implement, if necessary, measures to 

control brook trout in the Wildhorse River. 

Yes $50,000 Adopted 

Interior-40 Conduct presence absence surveys for bull trout and 

evaluate habitat conditions within Eagle Creek, and depending on survey results, determine the feasibility of introducing bull trout into suitable habitats in Eagle Creek. 

Yes $42,700 Adopted 

Interior-41 Reintroduce anadromous salmon and steelhead to 

restore marine-derived nutrients. 

Yes $50,000 Adopted, but woul

fish from unlisted 

Interior-42 Satisfy existing water quality standards in Oxbow and 

Hells Canyon reservoirs. 

Yes Not 

estimated 

Not adoptedb (see 

Interior-43a Develop Oxbow Bypassed Reach conservation flow 

plan. 

Yes $5,500 Not adoptedd (see 

Interior-43b Implement Oxbow Bypassed Reach conservation flow 

plan to meet state water quality standards and life history requirements for bull trout. 

Yes $1,600,000e Not adoptedd (see 

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721 

Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

Interior-44 Conduct two-phased study of operational effects on 

bull trout with 12-inch-per-hour ramping rate measured within 1 mile downstream of Hells Canyon dam in Phase 1 and ROR operation in Phase 2 

Yes $5,000,000 Not adoptedd (see 

Interior-45 Develop a plan for providing bull trout passage past 

Hells Canyon and Oxbow dams, operating permanent monitoring weirs on Pine and Indian Creeks. 

Yes $2,700 Adopted 

Interior-46a Develop a phased plan for restoring passage of 

anadromous fish to Pine Creek, Indian Creek, the Wildhorse River, and Eagle Creek. 

Yes $2,700 Not adoptedd (see 

Interior-46b Design, construct and operate improved adult 

collection facilities at Hells Canyon dam. 

Yes $658,500 Adopted 

Interior-46c Design, construct and operate a juvenile spring 

Chinook collection facility on Eagle Creek. 

Yes $411,200 Not adoptedd (see 

Interior-47a Fall Chinook incubation survival monitoring upstream 

of Brownlee reservoir. 

Noc $20,000 Not adoptedd (see 

Interior-47b Develop and refine plans to provide downstream 

passage of fall Chinook salmon around the project reservoirs. 

Yes $10,000 Not adoptedd (see 

Interior-48 Establish hatchery production goals based on adult 

returns. 

Yes $16,700 Not adopted b (see 

Interior-49 Transfer surplus hatchery fish for put-and-take 

fisheries. 

No, recreation 

measure 

$80,900 Adopted 

Interior-50a Implement water quality improvement measures 

elsewhere in the basin to aid in sturgeon recovery. 

No, no nexus to 

project 

Not 

estimated 

Not adopted 

Interior-50b Determine which Idaho Power facilities need to have 

their trashracks replaced to protect juvenile sturgeon from entrainment. 

Yes Not 

estimated 

Not adoptedb (see 

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722 

Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

Interior-50c Implement ROR operations at Lower Salmon Falls, 

Bliss, C.J. Strike projects during sturgeon spawning, incubation and early life stages. 

No, no nexus to 

project 

Not 

estimated 

Not adopted 

Interior-51 Update and implement White Sturgeon Conservation 

Plan including specific measures endorsed by Interior including assessment of water quality impacts on early lifestages, sturgeon translocation, experimental conservation aquaculture program, population monitoring and monitoring of genotypic frequencies. 

Yes $170,800 Adopted 

Interior-52 Complete and implement a White Sturgeon 

Conservation and Action Plan. 

Yes $2,700 Not adoptedb (see 

Interior-53 Construct and operate a white sturgeon hatchery 

facility for supplementing sturgeon populations from Shoshone Falls to Hells Canyon dam. 

Yes $259,200 Adopted, except th

have the discretion hatchery or lease hneed for hatchery determined via a f

Interior-54 Seasonal run-of-river operations to protect sturgeon 

spawning and early lifestages below Hells Canyon dam. 

Yes Not 

estimated 

Not adoptedb (see 

Interior-55 Install protective trash racks at CJ Strike and Bliss 

dams to protect white sturgeon. 

No, no nexus to 

project 

Not 

estimated 

Not adopted 

Interior-56 Complete and implement a Pacific lamprey 

management plan including monitoring and evaluation to determine the downstream passage routes and timing, estimate survival through the project, and effects of reservoir and river fluctuations on rearing habitat. 

Yes $10,000 Not adoptedd (see 

Interior-57 Determine structural measures needed to mitigate for 

project effects to Pacific lamprey. 

Yes $2,624,900f Not adoptedd (see 

Interior-58 Develop and implement a Native Fish Management 

Plan for native resident and anadromous fish. 

Yes Not 

estimated 

Adopted; the measare included in Idanative salmonid pl

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
723 

Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

Interior-59 Complete an action plan and implementation schedule 

to correct fish passage barriers at road crossings and culverts. 

Yes Not 

estimated 

Adopted, but in deenhancement plantributary barriers fprovide access to utrout and/or redbanbarrier removal shhabitat conditions where the barrier raccess to useable h

Interior-60 Complete a stock assessment of anadromous and 

resident fish populations. 

Yes $1,080 Not adoptedd (see 

Interior-61 Turbine vent Brownlee units 1, 2, 3, 4, and possibly 

Brownlee unit 5 and the three Hells Canyon units. 

Yes $17,000 Not adoptedb (see 

Interior-62ai Construct total dissolved gas-abatement structures on 

Hells Canyon dam. 

Yes $407,600 Adopted 

Interior-62aii Construct total dissolved gas-abatement structures on 

Brownlee dam. 

Yes $354,700 Adopted 

Interior-62b Monitor effectiveness of total dissolved gas-abatement 

measures. 

Yes $14,100 Adopted 

Interior-63 Oxbow Bypassed Reach flow and DO supplementation 

to support primary production, native invertebrates, and resident fishes. 

Yes $2,048,000g Not adoptedd (see 

Interior-64 Comply with IDEQ and ODEQ water quality 

certifications. 

Noc Not 

estimated 

Adopted 

Interior-65 Take river flow and stage measurements for licensed 

operations and compliance for the Snake River in Hells Canyon within 1 mile below Hells Canyon dam or at U.S. Geological Survey Gage No. 13290450. 

Yes Not 

estimated 

Not adoptedb (see 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
724 

Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

Interior-66 Monitor a series of modified operations to determine 

effects on aquatic species downstream of the Hells Canyon dam including : (1) peak-loading with 12 inches per hour ramping rate; (2) same but with DO enhancement measures; and (3) year-round run-ofriver. 

Yes $5,000,000 Not adoptedd (see 

Interior-67 Monitor water quality downstream of Hells Canyon 

dam twice per month. 

Yes $200,000 Not adoptedd (see 

Interior-68 Monitor beaches, cobble bars, and sand bars to 

determine rate of depletion. 

Yes $28,800 Adopted 

Interior-69 Monitor the quantity and quality of all known gravel 

deposits. 

Yes $40,000 Adopted, except th

monitoring sites wspecified in Idaho spawning and grav

Interior-70 Conduct biannual monitoring of benthic 

macroinvertebrates to assess changes in the composition of benthic macroinvertebrates, with emphasis on species and taxonomic groups useful in determining water quality. 

Yes $57,000 Adopted; DO mea

implemented consspecified in the wamonitoring should operational effects restrictions identif

Interior-71 Conduct biannual monitoring of benthic macrophytes 

and algae. 

Yes $14,200 Adopted with sam

70. 

Interior-72 Conduct zonal distribution surveys and monitoring of 

keystone and sensitive benthic species to assess the effects of peak-loading operations on the benthic community. 

Yes $28,500 Adopted with sam

70. 

Interior-73 Monitor known colonies of the Hells Canyon rapids 

snail and the short-faced limpet to assess the species response to dissolved oxygen enhancement and operational modifications. 

Yes $14,200 Adopted with sam

70. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
725 

Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

Interior-74 Establish and monitor experimental populations of 

Hells Canyon rapids snail and/or the short-faced limpet in the 10-mile reach immediately below Hells Canyon dam. 

Yes $14,200 Not adopted, but w

measure may be inplan if the parties monitoring results

Interior-75 Establish and monitor experimental populations of the 

western ridged mussel in appropriate habitat in the Snake River below Hells Canyon dam 

Yes $14,200 Not adopted, but w

measure may be inplan if the parties monitoring results 

Interior-76 Acquire and manage 41,747 acres as mitigation for 

project effects on wildlife. 

Yes $2,941,400 Not adoptedd (see 

Interior-77 Develop and implement Integrated Weed Management 

Plan for project lands, including cooperative projects on adjacent lands. 

Yes $136,700 Adopted, except th

not be conducted wissuance 

Interior-78 Develop and implement Sensitive Plant Species 

Management Plan, survey and monitor sensitive plants. 

No, plant species 

measure 

$6,100 Not adopted, but m

incorporated into Tand Sensitive Spec

Interior-79 Develop and implement IWHP and WMMP, including 

establishment of pre-dam baseline conditions. 

Yes $1,026,700 Adopted, except fo

dam conditions. 

Interior-80 Develop and implement Mountain Quail Management 

Plan. 

Yes $31,800 Not adopted,d but 

included in CoopeManagement Proje

Interior-81 Develop and implement Bald Eagle Management Plan 

for some project lands and reservoirs. 

Yes $10,500 Adopted, except th

be extended, and tsurveys would be r

Interior-82 As part of Threatened, Endangered, and Sensitive 

Species Management Plan, implement measures to protect Townsend's big-eared bat maternity sites and hibernacula. 

Yes $1,500 Adopted 

Interior-83 As part of Threatened, Endangered, and Sensitive 

Species Management Plan, implement measures to protect southern Idaho ground squirrel. 

Yes $1,200 Adopted 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
726 

Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

Interior-84 Develop and Implement Northern Idaho Ground 

Squirrel Management Plan. 

No, no nexus to 

project 

$6,100 Not adopted, but w

Idaho Power acquispecies 

Interior-85 As part of Threatened, Endangered, and Sensitive 

Species Management Plan, implement measures to protect special status amphibians and reptiles. 

Yes $1,000 Adopted 

NMFS-1 Provide stable flows between 8,500 and 13,500 cfs 

below Hells Canyon dam throughout fall Chinook spawning season. 

Yes Not 

estimated 

Adopted 

NMFS-2 Provide instantaneous minimum flows below Hells 

Canyon dam that are equal to, or greater than, the stable flows provided during the preceding fall Chinook spawning period throughout the incubation period. 

Yes Not 

estimated 

Adopted 

NMFS-3 Monitor the natural construction of fall Chinook 

salmon redds in the mainstem Snake River between Lower Granite reservoir and Hells Canyon dam. 

Yes $125,000 Adopted 

NMFS-4 Release flows sufficient to ensure that the largest 

juvenile entrapment areas are reconnected with the 

mainstem Snake River for at least 2 hours on a daily basis. 

Yes Not 

estimated 

Not adoptedb (see 

NMFS-5 Develop and implement a stranding and entrapment 

monitoring plan. 

Noc $28,700 Adopted 

NMFS-6 Complete study of fall Chinook spawning gravel. Noc $20,000 Adopted NMFS-7 Evaluate fall Chinook egg-to-fry survival in at least 

two representative spawning areas downstream of Hells Canyon dam in 2015 and every 5 years thereafter. 

Noc $20,000 Adopted (compon

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
727 

Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

NMFS-8 Refill Brownlee reservoir to within 1 foot of the April 

15 and April 30 minimum elevations necessary to meet 

the Corps flood control requirements and coordinate refill with NMFS. 

Yes Not 

estimated 

Adopted 

NMFS-9 Refill Brownlee reservoir to full pool by June 20, 

release 237 kaf of stored water from Brownlee reservoir between June 21 and July 31 (release at least 150 kaf of this water by July 15) and not refill until after August 31. 

Yes Not 

estimated 

Adopted 

NMFS-10 Construct total dissolved gas-abatement structures on 

Hells Canyon dam. 

Yes $407,600 Adopted 

NMFS-11 Construct total dissolved gas-abatement structures on 

Brownlee dam. 

Yes $354,700 Adopted 

NMFS-12 Evaluate and implement the most effective methods to 

augment Hells Canyon outflow DO levels in late summer and fall. 

Yes $10,900 Adopted 

NMFS-13a Make improvements to the Oxbow fish hatchery Yes $331,000 Adopted NMFS-13b Expand fall Chinook rearing program at Oxbow 

hatchery. 

Yes $282,300 Adopted 

NMFS-13c Monitor and evaluate hatchery performance at Oxbow 

hatchery. 

Yes $46,200 Adopted 

NMFS-13d Make improvements to the Pahsimeroi fish hatchery to 

control pathogens. 

Yes $690,300 Adopted 

NMFS-13e Develop a locally adapted steelhead broodstock at 

Pahsimeroi hatchery. 

Yes $690,300 Adopted 

NMFS-13e Complete upgrades to the Niagara Springs fish 

hatchery, acquire additional smolt tanker, acquire a fish marking unit. 

Yes $251,200 Adopted 

NMFS-13f Monitor and evaluate hatchery performance at 

Pahsimeroi hatchery. 

Yes $690,300 Adopted 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
728 

Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

NMFS-13g Monitor and evaluate hatchery performance at Niagara 

Springs hatchery. 

Yes $46,200 Adopted 

NMFS-13h Complete upgrades to Rapid River fish hatchery 

facilities, distribute carcasses, construct offsite smolt acclimation/adult collection facility. 

Yes $336,700 Adopted 

NMFS-13i Monitor and evaluate hatchery performance at Rapid 

River hatchery. 

Yes $46,200 Adopted 

NMFS-13j Provide funding to develop and implement Hatchery 

Genetic Management Plans and hatchery program evaluations 

Nob $66,700 Adopted 

NMFS-13k Mark all releases with adipose clip. Yes Not 

estimated 

Adopted 

NMFS-13l Screen hatchery water intakes to meet NMFS juvenile 

fish screen criteria. 

Yes $1,100 Adopted 

NMFS-13m Assess and minimize impacts of Hatchery steelhead to 

listed ESUs. 

Yes $8,300 Adopted 

NMFS-14a, b, c, and f 

Contribute $10 million annually for 5 years and $5 million annually thereafter to fund water quality improvement projects in the Snake River basin upstream of Hells Canyon dam. Fund an aquatic resources committee to evaluate and prioritize projects and redirect funding if necessary to achieve water quality and egg-to-fry survival goals. 

No, no nexus to 

project 

$9,278,400 Not adopted 

NMFS-14d Monitor Snake River water quality downstream of 

Brownlee and Hells Canyon dams along with four sites between Bliss dam and Brownlee reservoir. 

Yes, except the 

upper sites have 

no nexus to 

project 

$150,000 Adopted, with exc

downstream of BliFalls dams 

NMFS-14e Fall Chinook incubation survival monitoring upstream 

of Brownlee reservoir. 

Yes $20,000 Not adoptedd (see 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
729 

Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

NMFS-15 Measure flows and ramping rates within 1 mile 

downstream of Hells Canyon dam. 

Yes $10,000 Not adoptedb, but f

developed to implequality monitoring Canyon dam 

NMFS-16 Within 20 years, begin passage and reintroduction 

studies of fall Chinook salmon in the Snake River downstream of Bliss, C.J. Strike and Swan Falls dams. 

Yes $17,300 Not adoptedd (see 

NMFS-17 Within 20 years, begin passage and reintroduction 

studies of spring/summer Chinook salmon and steelhead in three tributaries to be selected in consultation with agencies. 

Yes $54,600 Not adoptedd (see 

ODFW-1 Establish and convene a Hells Canyon Project 

Coordinating Committee upon license issuance. 

Noc $500 Not adopted 

ODFW-2 Develop, fund and implement a long-term program to 

achieve specified target population sizes of anadromous fish above the project and to reconnect resident fish populations isolated below, within, and above the project. 

Yes $6,127,200 Not adoptedd (see 

ODFW-3 Develop and implement a fish passage plan for native 

migratory resident and anadromous species to include spring, summer and fall Chinook salmon, summer steelhead, Pacific lamprey, bull trout, redband trout and white sturgeon. 

Yes $6,127,200 Not adoptedd (see 

ODFW-4 Establish a Fish Passage and Reintroduction 

Committee. 

Noc $500 Not adopted 

ODFW-5 Consult with ODFW in development of fishway and 

trap designs. 

Noc $0 Adopted; costs wo

facility design pro

ODFW-6 Prepare and implement a written post-construction 

evaluation plan for the construction and modification of the Hells Canyon dam fish trap. 

Yes $0 Adopted; costs wo

facility design pro

ODFW-7 Maintain all fishways and traps in proper order. Yes $0 Adopted; costs wo

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
730 

Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

ODFW-8 Develop a fishway and trap operation and maintenance 

plan. 

Yes $0 Adopted; costs wo

ODFW-9 Provide ODFW personnel access to the Hells Canyon 

Project site and pertinent project records to inspect fishways and traps. 

Noc $0 Adopted; costs wo

ODFW-10 Design, construct and operate improved adult 

collection facilities at Hells Canyon dam. 

Yes $658,500 Adopted 

ODFW-11 Design and construct a fish trap and sorting facility at 

Oxbow dam for passing anadromous and resident fish within 10 years, and evaluate whether delay, injury, or mortality of adult salmonids occurs at the Oxbow powerhouse or bypassed reach. The facility would be similar in design and operation to the Hells Canyon trap. 

Yes $270,200 Adopted, except th

occur after trigger Interior’s modified have been attained

ODFW-12 Install and maintain a downstream fish passage and 

collection facility at Hells Canyon dam within 10 years. 

Yes $2,624,900 Not adoptedd (see 

ODFW-13 Design and implement a study of fish predators in 

Hells Canyon reservoir. 

Noc $48,000 Not adopted 

ODFW-14 Initiate studies of spring Chinook salmon and summer 

steelhead migration into and from Pine Creek, and egg to fry, in-reservoir, turbine and spill survival. Initiate studies within 1 year, install smolt collection facility in 2009 if warranted. 

Yes $837,300 Not adoptedd (see 

ODFW-15 Initiate studies of spring Chinook salmon and summer 

steelhead juvenile and adult migration behavior and survival in Eagle, Daly and Goose creeks. Initiate studies by 2012, design and install smolt collection facility in 2017 if warranted. 

Yes $485,100 Not adoptedd (see 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
731 

Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

ODFW-16 Monitor fall Chinook egg survival in Swan Falls reach 

every 5 years, starting in year 15 initiate adult and juvenile fall Chinook migration studies, design and construct smolt collection facilities once egg survival is sufficient, assess facility efficiency and performance and implement necessary modifications. 

Yes $1,203,200 Not adoptedd (see 

ODFW-17 Develop a detailed upstream and downstream passage 

plan for Pacific lamprey mid-way through the license term and a schedule for implementation. 

Yes $2,624,900f Not adoptedd (see 

ODFW-18 Develop fish passage plan for bull trout and/or redband 

trout, conduct bull trout population viability analysis, conduct radio tag studies of bull trout collected in the Hells Canyon trap, develop and implement protocols for capturing and managing bull trout at Pine and Eagle Creek weirs, if constructed. 

Yes $54,900 Adopted 

ODFW-19 Develop and implement a fish passage plan for white 

sturgeon if this is determined to be feasible. 

Yes $4,756,800h Not adoptedd (see 

ODFW-20 Develop and implement measures to address key 

limiting factors if passage and reintroduction efforts are terminated for a species in a selected tributary or reach (develop alternative mitigation measures in these cases). 

Yes $5,000,000 Not adoptedb (see 

ODFW-21 Implement a pathogen risk assessment. Yes $40,000 Adopted ODFW-22 Evaluate anadromous and resident fish populations to 

pass for reintroduction, review stock performance every 5 years. 

Yes $7,700 Not adoptedd (see 

ODFW-23 Fund fish habitat enhancement measures to mitigate for 

ongoing and unavoidable losses. 

Noc Not 

estimated 

Not adopted 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
732 

Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

ODFW-24 Monitor bull trout emigration and immigration from 

tributaries, redband trout abundance and redd surveys assess proportion of resident and anadromous forms of rainbow trout, conduct steelhead and Chinook spawning surveys to assess spawning escapement, distribution and timing of spawning. 

Yes $50,000 Not adoptedd (see 

that bull trout and would be conductepassage plan identfishway prescriptio

ODFW-25a Implement monitoring and evaluation program for 

Pahsimeroi hatchery. 

Yes $46,200 Adopted 

ODFW-25b Implement monitoring and evaluation program for 

Oxbow hatchery. 

Yes $46,200 Adopted 

ODFW-25c Implement monitoring and evaluation program for 

Niagara Springs hatchery. 

Yes $46,200 Adopted 

ODFW-25d Implement monitoring and evaluation program for 

Rapid River hatchery. 

Yes $46,200 Adopted 

ODFW-26 Develop a Hatchery Production Plan. Yes $42,700 Adopted, except fo

production goals wsection 5.2.4.8). 

ODFW-27 Investigate and supply alternative fisheries in Oregon. Yes $0 Adopted. As part 

management plan, consult with resoudetermine the best fish, and tributary improve or restore the Wildhorse RivPowder River. 

ODFW-28 Expand Oxbow Hatchery for fall Chinook rearing. Yes $282,300 Adopted ODFW-29 Expand Oxbow Hatchery for fall Chinook broodstock 

collection, spawning, and upgrading hatchery facilities. 

Yes $282,300 Adopted 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
733 

Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

ODFW-30 Continue hatchery operations at Oxbow, Rapid River, 

Pahsimeroi, and Niagara Springs hatcheries to meet target goals and added responsibilities related to anadromous fish reintroduction (fund). 

Yes Not 

estimated 

Adopted 

ODFW-31 Manage project operations to meet objectives for 

anadromous fish migration, fall Chinook spawning and rearing, redband and bull trout rearing, white sturgeon spawning, and reservoir fisheries. 

Yes Not 

estimated 

Adopted 

ODFW-32 Shape BOR flow augmentation releases by prereleasing 100 kaf of storage from Brownlee reservoir 

from June 21 to August 31 and refilling Brownlee reservoir with an equivalent of BOR water when that water reaches Brownlee reservoir. Attempt to hold Brownlee reservoir full through July 4, and thereafter coordinate releases from Brownlee reservoir, up to 237 kaf, by August 7. Consult with the Corps for a Brownlee reservoir target refill date of June 20 after flood season. 

Yes $9.29 million Not adopted (see s

ODFW-33 Implement 6-inch-per hour ramping rate from 

December 12th through March 20th, four inch-per-hour ramp rate and minimum flow of 11,500 cfs from March 21st through June 21st, 6-inch-per-hour ramp rate with a maximum 10,000 cfs daily flow change limit from June 22nd through September 30th, 6-inch-per-hour ramp rate from October 1st through October 20th, and no ramping from October 21 through December 11. 

Yes $17.6 million Not adoptedd (see 

ODFW-34 Continue fall Chinook spawning flow program. Yes Not 

estimated 

Adopted 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
734 

Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

ODFW-35 Fund and participate in annual spawning surveys for 

fall Chinook salmon in the Snake River downstream of Hells Canyon dam, conduct deep-water surveys every 5 years or when escapement exceeds 10,000, 15,000, and 20,000 adults, whichever comes first, consult with ODFW and ODEQ on location and frequency of temperature monitoring. 

Yes $125,000 Adopted; temperat

and frequency of dwould be addressespawning and incuplan. 

ODFW-36a Develop, fund, and implement a native salmonid plan 

including a habitat enhancement program, a permanent monitoring weir at Pine Creek, a bull trout survey in Eagle Creek, input of nutrients, and passage measures. 

Yes $520,000 Adopted 

ODFW-36b/37 Investigation of turbine and spill related mortality. Noc $85,500 Not adopted 

ODFW-38 Develop and implement a plan to improve habitat 

conditions in the Pine, Powder and Burnt River basins. 

Yes $750,000 Adopted 

ODFW-39 Investigate, fund and implement nutrient 

supplementation in all tributaries to the project. 

Yes $80,000 Adopted 

ODFW-40 Design, construct and operate a weir/trap on Pine 

Creek designed to collect anadromous smolts (sized to accommodate spring flows) within 3 years. 

Yes $783,000 Adopted 

ODFW-41 Conduct Eagle Creek presence/absence survey to 

determine, with statistical probability, the presence or absence of bull trout within the Eagle Creek Basin. 

Noc $42,700 Adopted 

ODFW-42 Update and implement White Sturgeon Conservation 

Plan including evaluating bioaccumulation of contaminants in sturgeon, assessment of water quality impacts on early lifestages, sturgeon translocation, funding habitat enhancement, population monitoring, and monitoring of genotypic frequencies. 

Yes $274,900 Adopted, with the 

measures ODFW-described below. 

ODFW-43 Evaluate bioaccumulation of contaminants in white 

sturgeon in Hells Canyon and Oxbow reservoirs and upstream of Brownlee reservoir. 

Noc $32,100 Adopted, except Id

responsible only fosamples for analys

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
735 

Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

ODFW-44 Provide a minimum of $100,000 annually to fund water 

quality and habitat improvement measures elsewhere in 

the basin to aid in sturgeon recovery 

No, no nexus to 

project 

$100,000 Not adopted. Alth

specific funding leODFW, we adopt 

that would improvand improve sturgarea (measures 4P

ODFW-45 Make periodic population assessments to monitor 

white sturgeon populations in the Swan FallsBrownlee, Brownlee-Hells Canyon, and Hells CanyonLower Granite reaches of the Snake River. 

Noc $82,100 Adopted 

ODFW-46 Assess water quality-related effects on early life stages 

of white sturgeon in the Swan Falls-Brownlee reach. 

Noc $24,000 Adopted 

ODFW-47 Translocate reproductive-sized white sturgeon into the 

Swan Falls-Brownlee reach to increase spawner abundance and population productivity, if water quality is found to be adequate and if genetic and demographic risks to the donor population are found to be acceptable. 

Yes $20,600 Adopted 

ODFW-48 Monitor genotypic frequencies of white sturgeon 

between Shoshone Falls and Lower Granite dams. 

Noc $2,300 Adopted, except th

genotypic frequenFalls dam is not inaddressed in licensPower’s upstream 

ODFW-49 Develop, fund and implement Pacific lamprey habitat 

enhancement measures and lamprey monitoring. 

Yes $105,000 Not adoptedd (see 

ODFW-50 Monitor warmwater fish populations including 

sampling techniques appropriate for monitoring catfish abundance (recommendation modified during 10(j) meeting). 

Yes $250,000 Adopted 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
736 

Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

ODFW-51 Brownlee target refill date of June 30, beginning on 

May 21 the reservoir would not be drafted by more than one foot for the next 30 days and will not be drafted below 2069 msl through July 4 unless flow augmentation occurs before July 4. 

Yes Not 

estimated 

Adopted 

ODFW-52 Conduct studies of food habits of Brownlee reservoir 

warmwater fish species, including effects of reservoir operations on zooplankton production. 

Noc $28,500 Not adopted 

ODFW-53 Implement a gravel monitoring program and 

implement a gravel augmentation program if effects are detected. 

Yes $27,600 Adopted, except th

would occur only Chinook productio

ODFW-54a Develop total dissolved gas-abatement plan. Yes $2,200 Adopted 

ODFW-54b Monitor effectiveness of total dissolved gas-abatement 

measures. 

Yes $14,100 Adopted 

ODFW-54c Construct total dissolved gas-abatement structures on 

Hells Canyon dam. 

Yes $407,600 Adopted 

ODFW-54d Construct total dissolved gas-abatement structures on 

Brownlee dam. 

Yes $354,700 Adopted 

ODFW-54e Construct total dissolved gas-abatement structures on 

Oxbow dam, if necessary to satisfy water quality standard. 

Yes $287,900 Adopted, except th

not occur until Broare constructed an

ODFW-55 Develop and implement plan to avoid project-caused 

exceedances of Oregon's dissolved oxygen standards. 

Yes $2,200 Adopted 

ODFW-56 Develop and implement temperature management plan. Yes $5,500 Adopted ODFW-57 Evaluate bioaccumulation of mercury, dieldrin, and 

DDT/DDE in Brownlee reservoir fish. 

Noc $21,400 Adopted, except th

would be responsibioacccumulants in Idaho Power. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
737 

Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

ODFW-58 Develop and implement a plan to monitor temperature, 

total dissolved gas, dissolved oxygen, and other water quality parameters. 

Yes $4,400 Adopted 

ODFW-59 Develop and implement Terrestrial Resources 

Management and Mitigation Plan. 

Yes $0 Adopted; included 

ODFW-60 Establish a Terrestrial Resources Work Group, with 

pre-defined roles, responsibilities, and schedules. 

Noc $12,500 Adopted, except th

roles, responsibilit

ODFW-61 Acquire and manage 35,739 acres as mitigation for 

project effects on wildlife. 

Yes $2,518,100 Not adoptedd (see 

ODFW-62 Fund habitat management on four state-owned islands. Yes $58,600 Adopted, with OD

cost, Idaho Power-funding. 

ODFW-63 Enhance low-elevation riparian habitat and participate 

in mountain quail projects for 5 years. 

Yes $9,600 Adopted 

ODFW-64 Develop and implement Bald Eagle Management Plan 

and enhance eagle habitat. 

Yes $10,500 Adopted, except th

enhanced. 

ODFW-65 Protect and monitor sensitive flora and fauna species 

within 1/4 to 1/2 mile of reservoirs and river downstream to Salmon River confluence. 

No, no nexus to 

project (includes 

lands and species 

not affected by 

project). 

$21,100 Not adopted, but s

affected by the proin Threatened, EndSpecies Managem

ODFW-66 Control and monitor exotic and invasive vegetation, 

and establish a Cooperative Weed Management Area. 

Yes $136,100 Adopted 

ODFW-67 Develop and implement an Integrated Transmission 

Line Operation and Maintenance Plan for 700 miles of transmission lines. 

No, no nexus to 

project (lines not 

jurisdictional) 

$310,900 Not adopted 

ODFW-68 Develop and implement T-Line Management Plan for 

Line #907. 

No, no nexus to 

project (line not 

jurisdictional) 

$10,500 Not adopted 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
738 

Agency/ Recommendation Number Recommendation Within the Scope of 10(j)? Annualized Cost 

Adoption Status 

Basis for Prelim

Inc

ODFW-69 Develop and implement a detailed bird electrocution 

monitoring plan for transmission line 945 and implement measures to minimize risk of electrocution. 

Yes $1,000 Adopted, except th

included in transminstead of requirin

ODFW-70 Monitor bird collisions on transmission lines 923 and 

951 and implement measures to minimize risk of collision. 

No, no nexus to 

project (lines not 

jurisdictional). 

$1,000 Not adopted 

ODFW-71 Conduct study of harsh winter effects on mule deer. Noc $18,600 Not adoptedb

ODFW-72 As part of WMMP, schedule O&M to minimize 

disturbance on deer winter range. 

Yes $1,000 Adopted 

ODFW-73 As part of WMMP and Transmission Line 

Management Plan, develop and implement I&E program to minimize risk of wildlife disturbance. 

Yes $1,500 Adopted 

ODFW-74 Protect wildlife under emergency conditions. Noc $0 Not adopted 

a Continuation of existing measure; no incremental cost. b Preliminary findings that recommendations found to be within the scope of section 10(j) are inconsistent with the substantial evide

313(b) of the FPA are based on a lack of evidence to support the reasonableness of the recommendation or a lack of justification fo

c Not a specific measure to protect, mitigate, or enhance fish and wildlife resources. This includes studies that could have been com

research studies, personnel access, consultation, administrative conditions, or measures that lack specific details. 

d Preliminary findings that recommendations found to be within the scope of section 10(j) are inconsistent with the comprehensive p

section 10(a) of the FPA, including the equal consideration provision of section 4(e) of the FPA, are based on staff’s determination measures outweigh the expected benefits. 

e Cost estimate assumes a minimum bypass flow of 1,000 cfs to improve water quality. f Cost estimate assumes that a downstream passage facility would be required at Hells Canyon dam. g Cost estimate assumes 1,000 cfs bypassed flow and oxygenation supplementation. h Cost estimate assumes upstream and downstream passage facilities would be installed at Hells Canyon and Brownlee dams. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
739 

EPAct provides parties to this licensing proceeding the opportunity to propose alternatives to 

preliminary conditions. In the draft EIS, we included in the Staff Alternative 19 of Idaho Power’s 23 

alternative conditions. Both Interior and the Forest Service submitted modified conditions. In its 

comments on the draft EIS, Idaho Power recommended that we adopt the modified conditions as filed by 

Interior and the Forest Service. Table 109 summarizes our position on the modified conditions. 

Table 109. Interior and Forest Service modified 4(e) conditions for the Hells Canyon Project. 

(Source: Staff) 

4(e) Conditions Agency 

Annualized 

Cost Included in Staff Alternative?a

1. Follow BLM requirements for Idaho 

Power activities on or affecting BLMadministered lands 

Interior-1 $4,400 Yes 

2. Prepare a report documenting and/or 

evaluating measures for the protection 

and use of BLM lands 

Interior-2 $5,000 Yes 

3. Develop and implement a travel and 

access management plan 

Interior-3 $15,100 No; project provides adequate public 

access without the specified trail 

system, and the applicant is not 

responsible for maintaining county and 

state roads outside the project boundary 

(see section 5.2.7.5). 

4. Develop and implement a Law 

Enforcement and Emergency Services 

Plan 

Interior-4 $5,100 No; law enforcement is an agency 

responsibility (see section 5.2.8.2). 

5. Review and adapt the Historic 

Properties Management Plan, with 

special conditions for BLM resources 

Interior-5 Costs 

included in 

specific 

measures 

Yes 

6. Develop and implement an integrated 

Comprehensive Recreation Management 

Plan 

Interior-6 $7,600 Yes. 

7. Develop and implement a Litter and 

Sanitation Plan 

Interior-7 $66,800 Yes 

8. Develop and implement a Project 

Boat Moorage Plan 

Interior-8 $5,000 Yes. 

9. Develop and implement a Site 

Enhancement Plan for BLM’s Airstrip, 

Bob Creek Section C, and Westfall sites 

Interior-9 $4,600 Yes. 

10. Develop and implement a Swedes 

Landing Enhancement Plan 

Interior-10 $5,000 Yes 

11. Develop and implement a Spring 

Recreation Site Enhancement Plan 

Interior-11 $5,000 Yes 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
740 

4(e) Conditions Agency 

Annualized 

Cost Included in Staff Alternative?a

12. Develop and implement a Steck 

Recreation Site Enhancement Plan 

Interior-12 $3,800 Yes. 

13. Develop and implement a Jennifer’s 

Alluvial Fan Site Enhancement Plan 

Interior-13 $9,800 Yes 

14. Develop and implement an Idaho 

Dispersed Sites Plan 

Interior-14 $69,000 Yes 

15. Develop and implement an Oxbow 

Boat Launch and Carter’s Landing 

Enhancement Plan 

Interior-15 $10,000 Yes. 

16. Develop and implement an Oasis 

Site Enhancement Plan 

Interior-16 $4,400 Yes 

17. Develop and implement a Copper 

Creek Site Enhancement Plan 

Interior-17 $5,000 Yes 

18. Develop and implement a Low 

Water Boat Launch Plan 

Interior-18 $5,000 Yes 

19. Obtain Forest Service approval of 

site-specific designs prior to start of 

Idaho Power activities on National 

Forest System lands 

FS-1 $1,000 Yes, except we limit scope to Forest 

Service lands in the project boundary. 

20. Prepare and implement a Resource 

Coordination Plan 

FS-2 $6,100 Yes, except we limit scope to Forest 

Service lands in the project boundary. 

21. Prepare and implement a Fire 

Prevention Plan 

FS-3 $2,000 Yes 

22. Create a Sandbar Maintenance and 

Restoration Fund 

FS-4 $545,100 Yes 

23. Prepare an Integrated Wildlife 

Habitat Program and a Wildlife 

Mitigation and Management Plan 

FS-5 $25,000 Yes 

24. Prepare and implement a Land 

Acquisition and Management Program 

FS-6 $160,500 Yes 

25. Prepare an Integrated Weed 

Management Plan 

FS-7 $30,500 Yes 

26. Prepare a Threatened and 

Endangered Species Management and 

Monitoring Strategy 

FS-8 $100 Yes 

27. Prepare and implement a Sensitive 

Species Management Plan 

FS-9 $62,500 Yes 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
741 

4(e) Conditions Agency 

Annualized 

Cost Included in Staff Alternative?a

28. Implement the Mountain Quail 

Habitat Enhancement Program 

FS-10 $9,600 Yes 

29. Develop and implement a 

Transmission Line Operation and 

Maintenance Plan 

FS-11 $1,200 Yes 

30. Finalize and implement the Hells 

Canyon Complex Comprehensive 

Recreation Management Plan 

FS-12 $46,500 Yes 

31. Develop and implement a Big Bar 

Site Development Plan 

FS-13 $10,000 Yes 

32. Implement the Eagle Bar Site 

Development Plan 

FS-14 $28,600 Yes 

33. Implement the Eckels Creek 

Dispersed Site Development Plan 

FS-15 $5,700 Yes 

34. Conduct condition and safety 

inspection of Deep Creek Stairway/Trail 

#218 and correct any deficiencies 

FS-16 $11,700 Yes 

35. Improve and maintain parking and 

signage at four Forest Service roadside 

parking areas along the reservoir 

FS-17 $75,000 Yes 

36. Operate and maintain Eagle Bar, 

Eckels Creek, Big Bar, Hells Canyon 

reservoir parking areas, Black Point 

Viewpoint, and dispersed areas pursuant 

to the Recreation Plan 

FS-18 Costs 

included in 

site-specific 

measures 

Yes 

37. Extend boat ramps on Hells Canyon 

reservoir if needed to provide reasonable 

public access under proposed operations. 

FS-19 $100,000 

total onetime cost 

Yes 

38. Perform trail maintenance on nine 

specified trails 

FS-20 $10,000 No; no clear nexus between project 

operations and recreational use of 

Forest Service-managed trails outside 

of the project boundary (see section 

5.2.7.5). 

39. Design, construct, and maintain 

facility enhancements at the Hells 

Canyon Creek launch site and Visitor 

Center 

FS-21 $36,100 Yes 

40. Develop and implement an aesthetic 

improvement plan for the upper deck, 

entrance, and egress areas of Hells 

Canyon dam 

FS-22 $0b

 Yes, except we limit measures to Forest 

Service lands and exclude restroom and 

measures that could compromise 

security. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
742 

4(e) Conditions Agency 

Annualized 

Cost Included in Staff Alternative?a

41. Condition 23 in draft EIS (design 

standards and landscaping) has been 

incorporated into FS-24 

FS-23 NA NA. 

42. Prepare and implement a Scenery 

Management Plan for Forest Service 

lands 

FS-24 $1,000 Yes, except we adopt standards 

developed by Aesthetics Subgroup. 

Included in Idaho Power’s proposed 

measure 75P. 

43. Finalize and implement the Historic 

Properties Management Plan 

FS-25 $800 Yes 

44. Provide Forest Service with a map 

and aerial photos depicting the 

approximate location of the project 

boundary in a form compatible with the 

Forest Service GIS 

FS-26 $2,000 Yes. 

45. Reserve authority by the 

Commission to require any additional 

measures necessary for protection and 

use of public land reservations under 

Forest Service authority 

FS-27 $0 Not applicable; would be addressed in 

license order. 

a Measures noted as “Yes, except...” indicate that we include a modified version of the condition in the Staff 

Alternative. Modifications are based on our staff analysis, and may reflect points raised in Idaho Power’s 

alternative conditions. 

b Included in the Hells Canyon Resource Management Plan; no incremental cost. 

a Included in HCRMP; no incremental cost. 

5.4 CONSISTENCY WITH COMPREHENSIVE PLANS 

5.4.1 Section 10(a)(2) Comprehensive Plans 

Section 10(a)(2) of the FPA requires the Commission to consider the extent to which a project is 

consistent with federal or state comprehensive plans for improving, developing, or conserving waterways 

affected by the project. Under section 10(a)(2), federal, state and local agencies filed comprehensive 

plans that address various resources in Oregon and Idaho. The 47 plans listed below address resources 

applicable to the project. Based on our review and analysis, we conclude that the project as proposed by 

Idaho Power and as described in the Staff Alternative would be consistent with the plans. 

5.4.1.1 Plans Applicable to Both Idaho and Oregon 

Forest Service. 2003. Hells Canyon National Recreation Area comprehensive management plan. 

Department of Agriculture, Baker City, Oregon. June 2003. 

Northwest Power and Conservation Council. 2000. Columbia River basin fish and wildlife 

program. Portland, Oregon. Council Document 2000-19. (1984, 1987, 1994, 2000, 

amended 2003 as Council Document 2003-4). 

Northwest Power and Conservation Council. 2005. The Fifth Northwest electric power and 

conservation plan. Portland, Oregon. Council Document 2005-07. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
743 

Northwest Power and Conservation Council. 1988. Protected areas amendments and response to 

comments. Document 88-22 (September 14, 1988). 

Northwest Power and Conservation Council. 2003. Mainstem amendments to the Columbia 

River basin fish and wildlife program. Portland, Oregon. Council Document 2003-11. 

5.4.1.2 Plans Applicable to Idaho 

Bureau of Land Management. Forest Service. 1991. Snake River final activity/operations plan. 

Department of the Interior, Idaho Falls, Idaho. Department of Agriculture, Idaho Falls, 

Idaho. February 1991. 101 pp. and appendices. 

Bureau of Land Management. 1988. Cascade Resource Management Plan. Department of 

Interior. Boise, Idaho. July 1, 1988. 

Bureau of Land Management. 1983. Lower Salmon River Recreation Area Management Plan. 

Department of the Interior. Boise, Idaho. May 1983. 

Forest Service. 2003. Payette National Forest land and resource management plan. Department 

of Agriculture, McCall, Idaho. July 2003. 

Forest Service. 1987. Nez Perce National Forest plan. Department of Agriculture, Grangeville, 

Idaho. October 1987. 171 pp. and appendices. 

Idaho Department of Fish and Game. 2001. Idaho fisheries management plan, 2001-2006. 

Boise, Idaho. 

Idaho Department of Fish and Game. 2003. Draft white sturgeon management plan: Status and 

objectives of Idaho's white sturgeon resources in the Snake River. Boise, Idaho. August 

2003. 

Idaho Department of Fish and Game. Bonneville Power Administration. 1986. Pacific 

Northwest rivers study. Final report: Idaho. Boise, Idaho. 12 pp. and appendices. 

Idaho Department of Health and Welfare. Division of Environment. 1985. Idaho water quality 

standards and wastewater treatment requirements. Boise, Idaho. January 1985. 72 pp. 

and appendices. 

Idaho Department of Parks and Recreation. Idaho Statewide Comprehensive Outdoor Recreation 

and Tourism Plan (SCORTP) 2003-2007. Boise, Idaho. 

Idaho Water Resource Board. 1986. State water plan. Boise, Idaho. December 1986. 

5.4.1.3 Plans Applicable to Oregon 

Bureau of Land Management. U.S. Forest Service. 1996. Status of the Interior Columbia Basin: 

Summary of scientific findings. Portland, Oregon. November 1996. 

Bureau of Land Management. 1993. Wallowa and Grande Ronde Rivers Final Management 

Plan. Department of the Interior, Baker, Oregon. December 1993. Chapters 1 – 3. 

Bureau of Land Management. 1990. Resource assessment of the Powder River. Department of 

the Interior, Baker, Oregon. August 1990. 

Bureau of Land Management. 1990. Resource assessment of the Grand Ronde River. 

Department of the Interior. Baker, Oregon. August 1990. 

Bureau of Land Management. 1989. Baker resource management plan. Department of the 

Interior, Baker, Oregon. July 1989. 151 pp. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
744 

Forest Service. 1990. Wallowa-Whitman National Forest land and resource management plan. 

Department of Agriculture, Baker City, Oregon. April 1990. 

Hydro Task Force and Strategic Water Management Group. 1988. Oregon comprehensive 

waterway management plan. Salem, Oregon. 

Oregon Department of Environmental Quality. 1978. Statewide water quality management plan. 

Salem, Oregon. November 1978. Seven volumes. 

Oregon Department of Fish and Wildlife. 1982. Comprehensive plan for production and 

management of Oregon's anadromous salmon and trout: Part I. General considerations. 

Portland, Oregon. June 1, 1982. 33 pp. 

Oregon Department of Fish and Wildlife. 1986. Oregon Bighorn sheep management plan. 

Portland, Oregon. November 1986. 17 pp. 

Oregon Department of Fish and Wildlife. 1987. The statewide trout management plan. Portland, 

Oregon. November 1987. 77 pp. 

Oregon Department of Fish and Wildlife. 1987. Warm water game fish management plan. 

Portland, Oregon. August 1987. 60 pp. 

Oregon Department of Fish and Wildlife. 2003. Oregon’s elk management plan. Portland, 

Oregon. February 2003. 

Oregon Department of Fish and Wildlife. 1993. Oregon black bear management plan, 1993-

1998. Portland, Oregon. 33 pp. and appendices. 

Oregon Department of Fish and Wildlife. 1993 (updated 1999). Oregon wildlife diversity plan. 

Portland, Oregon. November 1993 (updated January 1999). 

Oregon Department of Fish and Wildlife. 1993. Oregon cougar management plan, 1993-1998. 

Portland, Oregon. 31 pp. and appendices. 

Oregon Department of Fish and Wildlife. 2001. Oregon wildlife and commercial fishing codes: 

2001-2002. Portland, Oregon. 

Oregon Department of Fish and Wildlife. 1995. Biennial report on the status of wild fish in 

Oregon. Portland, Oregon. December 1995. 217 pp. and appendix. 

Oregon Department of Fish and Wildlife. 1995. Comprehensive plan for production and 

management of Oregon's anadromous salmon and trout: Part III. Steelhead plan. 

Portland, Oregon. April 26, 1995. 118 pp. and appendices. 

Oregon Department of Fish and Wildlife. 1996. Species at risk: Sensitive, threatened, and 

endangered vertebrates of Oregon. Portland, Oregon. June 1996. 

Oregon Department of Fish and Wildlife. 1997. Oregon plan for salmon and watersheds: 

Supplement 1 Steelhead. Salem, Oregon. December 1997. 

Oregon Department of Fish and Wildlife. 1987. Trout mini-management plans. Portland, 

Oregon. December 1987. 58 pp. 

Oregon Department of Transportation. State Parks and Recreation Division. 1987. Recreational 

values of Oregon rivers. Salem, Oregon. April 1987. 71 pp. 

Oregon State Game Commission. 1963-1975. Fish and wildlife resources - 18 basins. Portland, 

Oregon. 21 reports. 

Oregon State Parks and Recreation Department. 2003. Oregon Outdoor Recreation Plan 2003-

2007 (SCORP). Salem, Oregon. January 2003. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
745 

Oregon State Parks and Recreation Division. No date. The Oregon scenic waterways program. 

Salem, Oregon. 75 pp. 

Oregon State Water Resources Board. 1973. Surface area of lakes and reservoirs. Salem, 

Oregon. 43 pp. 

Oregon Water Resources Commission. 1987. State of Oregon water use programs. Salem, 

Oregon. 295 pp. 

Oregon Water Resources Department. 1985. Biennial Report, 1985–1987. 

Oregon Water Resources Department. 1988. Oregon water laws. Salem, Oregon. 240 pp. 

Department of the Army, Corps of Engineers. Portland District. 1993. Water resources 

development in Oregon. Portland, Oregon. 78 pp. 

5.4.2 Other Plans 

Certain other plans do not qualify as comprehensive plans under section 10(a)(2) of the FPA, but 

were the subject of comments made during scoping or in response to the Commission’s notice that the 

project was ready for environmental analysis. In the following sections, we discuss the consistency of 

Idaho Power’s Proposed Operations and the Staff Alternative with those plans. 

Umatilla, Warm Springs, and Yakama Tribes. 1995. Wy-Kan-Ush-Ma Wa-Kish-Wit: 

Spirit of the Salmon. The Columbia River Anadromous Fish Restoration Plan of the Nez 

Perce. 

We conclude that the measures proposed by Idaho Power and additional measures included in the 

Staff Alternative are consistent with Wy-Kan-Ush-Ma Wa-Kish-Wit: Spirit of the Salmon and would 

contribute to meeting the plan’s objectives to halt declining trends and increase populations of 

anadromous fish to levels that support tribal harvest opportunities. Measures proposed by Idaho Power 

that would contribute to meeting these objectives include: (1) continuation of reservoir operations in the 

fall, winter, and early spring for protection of fall Chinook spawning and salmon incubation; 

(2) continuation of fall Chinook redd and temperature monitoring to avoid the risk of dewatering 

developing salmon embryos; and (3) installation of spillway flow deflectors at Hells Canyon dam and 

continued preferential use of the upper spillgates at Brownlee dam during spill periods to reduce total 

dissolved gas concentrations in the Snake River downstream of Hells Canyon dam. Additional measures 

included in the Staff Alternative that would contribute to meeting plan objectives include: (1) periodic 

review of water quality monitoring data to determine when conditions in the mainstem Snake River 

upstream of Brownlee reservoir have improved sufficiently to warrant restoration of fall Chinook salmon; 

(2) flow augmentation and ramping rate restrictions that should improve in-river juvenile salmon survival; 

and (3) implementation of a white sturgeon conservation aquaculture plan that would restore white 

sturgeon populations to levels that support tribal harvest opportunities. 

Wallowa County Planning Department. Undated. Wallowa County Comprehensive Land 

Use Plan. 

We conclude that the measures proposed by Idaho Power and additional measures included in the 

Staff Alternative are consistent with Wallowa County Land Use Plan. The basic purposes of the Plan are 

to: (1) to protect the custom, culture, and community stability of the county; (2) maintain the agricultural 

and timber basis of the county; (3) accommodate anticipated development; and (4) make provisions for 

those uses that may be needed by the county, but that may have such undesirable characteristics as noise, 

smoke, and odor. The Staff Alternative includes measures that would improve protection of cultural 

resources, expand recreational opportunities in designated areas, and improve land use management on 

project lands. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
746 

5.5 RELATIONSHIP OF LICENSE PROCESS TO LAWS AND POLICIES 

5.5.1 Section 401 of the Clean Water Act—Water Quality Certification 

The status of the water quality certifications for the project is discussed in section 2.3.1.1. 

5.5.2 Coastal Zone Management Act—Consistency Certification 

Section 307(c) of the Coastal Zone Management Act requires that all federally licensed and 

permitted activities be consistent with approved state Coastal Zone Management Programs. If the project 

is located within a coastal zone boundary or if a project could affect resources located in the boundaries of 

the designated coastal zone, the applicant must certify that the project is consistent with the state Coastal 

Zone Management Program. The Hells Canyon Project is not located within the coastal zone boundary 

and would not affect resources located within the coastal zone boundary. 

5.5.3 Section 18 of the Federal Power Act—Authority to Prescribe Fishways 

Fishway prescriptions and recommendations for reservation of authority to prescribe fishways are 

discussed in section 2.3.1.2. 

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 and threatened species or cause the destruction or 

adverse modification of critical habitats of such species. Fourteen federally listed fish species (Snake 

River fall Chinook salmon, Snake River spring/summer Chinook salmon, Snake River sockeye salmon, 

Snake River steelhead, Upper Columbia River spring Chinook salmon, Columbia River steelhead, Lower 

Columbia River Chinook salmon, Upper Columbia River steelhead, Columbia River chum salmon, Lower 

Columbia River coho salmon, Lower Columbia River steelhead Upper Willamette River Chinook salmon, 

Upper Willamette River steelhead, and bull trout), one invertebrate (Idaho springsnail), three federally 

listed plant species (Howell’s spectacular thelypody, MacFarlane’s four-o’clock, and Spalding’s 

catchfly), and four federally listed wildlife species (gray wolf, Canada lynx, northern Idaho ground 

squirrel, and bald eagle) could occur in the project area or in downstream areas potentially affected by 

project operations. These species were identified as being likely to occur in the project area by FWS in a 

letter dated November 28, 2005 and by NMFS in a letter dated February 9, 2006. In its letter, NMFS 

identified the four Snake River ESUs (fall Chinook salmon, spring/summer Chinook salmon, sockeye 

salmon, and steelhead) and portions of their designated critical habitat as being the most likely to be 

affected by the project. 

By letter dated August 1, 2006, we requested formal consultation with NMFS on the four Snake 

River ESUs and their critical habitat (letter from T. Welch, Chief, Hydro West Branch 2, Commission, 

Washington, DC, to K. Kirkendall, FERC Coordinator, NMFS, Portland, OR). We also requested 

concurrence with our “not likely to adversely affect” determinations on the nine other Columbia River 

salmon and steelhead ESUs. In its comments on the draft EIS, NMFS did not concur with our 

determinations for the Columbia River ESUs and indicated that formal consultation would not be initiated 

because of insufficient information, incorrect baseline, and lack of a defined proposed action. On August 

1, 2006, we requested formal consultation with FWS on the bull trout and its critical habitat, as well as 

the bald eagle. We also requested concurrence with our “not likely to adversely affect” determinations on 

the MacFarlane’s four-o’clock, Spalding’s catchfly, gray wolf, and northern Idaho ground squirrel. By 

letter dated August 31, 2006, FWS indicated that the draft EIS did not meet the information requirements 

for initiation of formal consultation and that the action alternative was not adequately described (letter 

from J.L. Foss, Field Supervisor, Snake River Fish and Wildlife Office, FWS, Boise, ID, to M.R. Salas, 

Secretary, Commission, Washington, DC). 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
747 

Table 110 shows our determinations regarding the effect of relicensing the Hells Canyon Project 

on federally listed species. Table 110 also summarizes the basis for our effect determinations. We will 

request formal consultation with NMFS on all 13 listed ESUs of Snake and Columbia River salmon, and 

their critical habitat, and with FWS on MacFarlane’s four-o’clock and Spalding’s catchfly,135 as well as 

bull trout.136 We will also request concurrence from FWS with our findings for the gray wolf and 

northern Idaho ground squirrel. This final EIS will serve as our biological assessment. 

Table 110. Summary of effect determinations for fish, plants, and wildlife. 

Species Species Status Species Finding 

Critical Habitat 

Finding Basis for Determination 

Snake River fall 

Chinook salmon 

(Oncorhynchus 

tshawytscha) 

Threatened Likely to 

adversely affect 

Likely to adversely 

affect 

Continued potential for 

stranding mortality, effects of 

gas supersaturation on fry and 

juveniles, reduced recruitment 

of spawning gravel 

Snake River 

spring/summer 

Chinook salmon 

(O. tshawytscha) 

Threatened Likely to 

adversely affect 

Likely to adversely 

affect 

Continued potential for 

adverse effects of gas 

supersaturation on juvenile 

and adult fish 

Snake River 

sockeye salmon (O. 

nerka) 

Endangered Likely to 

adversely affect 

Likely to adversely 

affect 

Continued potential for 

adverse effects of gas 

supersaturation on juvenile 

fish 

Snake River 

steelhead (O. 

mykiss) 

Threatened Likely to 

adversely affect 

Likely to adversely 

affect 

Continued potential for 

adverse effects of gas 

supersaturation on juvenile 

and adult fish 

Upper Columbia 

River spring 

Chinook salmon 

(O. tshawytscha) 

Endangered Likely to 

adversely affect 

Likely to adversely 

affect 

Continued potential for 

beneficial and adverse effects 

of flood control operations on 

water quality and quantity 

during juvenile migration. 

Middle Columbia 

River steelhead (O. 

mykiss) 

Threatened Likely to 

adversely affect 

Likely to adversely 

affect 

Continued potential for 

beneficial and adverse effects 

of flood control operations on 

water quality and quantity 

during juvenile migration. 

 

135 In the draft EIS, we concluded that relicensing the project with our recommended measures was “not 

likely to adversely affect” MacFarlane’s four-o’clock or Spalding’s catchfly. We have modified our 

findings for these species to “likely to adversely affect” in light of the need for further surveys prior 

to conducting any ground-disturbing activities. 

136 As discussed in section 3.8.1.14, FWS announced a decision to remove the bald eagle from the list of 

threatened and endangered species, effective 30 days following publication in the Federal Register 

(FWS, 2007a). Consequently, there is no longer a need to complete formal consultation for this 

species. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
748 

Species Species Status Species Finding 

Critical Habitat 

Finding Basis for Determination 

Upper Columbia 

River steelhead (O. 

mykiss) 

Threatened Likely to 

adversely affect 

Likely to adversely 

affect 

Continued potential for 

beneficial and adverse effects 

of flood control operations on 

water quality and quantity 

during juvenile migration. 

Lower Columbia 

River Chinook 

salmon (O. 

tshawytscha) 

Threatened Likely to 

adversely affect 

Likely to adversely 

affect 

Continued potential for 

beneficial and adverse effects 

of flood control operations on 

water quality and quantity 

during juvenile migration. 

Columbia River 

chum salmon (O. 

keta) 

Threatened Likely to 

adversely affect 

Likely to adversely 

affect 

Continued potential for 

beneficial and adverse effects 

of flood control operations on 

water quality and quantity 

during juvenile migration. 

Lower Columbia 

River coho salmon 

(O. kisutch) 

Threatened Likely to 

adversely affect 

None designated Continued potential for 

beneficial and adverse effects 

of flood control operations on 

water quality and quantity 

during juvenile migration. 

Lower Columbia 

River steelhead 

(O. mykiss) 

Threatened Likely to 

adversely affect 

Likely to adversely 

affect 

Continued potential for 

beneficial and adverse effects 

of flood control operations on 

water quality and quantity 

during juvenile migration. 

Upper Willamette 

River Chinook 

salmon 

(O. tshawytscha) 

Threatened Likely to 

adversely affect 

Likely to adversely 

affect 

Continued potential for 

beneficial and adverse effects 

of flood control operations on 

water quality and quantity 

during juvenile migration. 

Upper Willamette 

River steelhead 

(O. mykiss) 

Threatened Likely to 

adversely affect 

Likely to adversely 

affect 

Continued potential for 

beneficial and adverse effects 

of flood control operations on 

water quality and quantity 

during juvenile migration. 

Bull trout 

(Salvelinus 

confluentus) 

Threatened Likely to 

adversely affect 

Likely to adversely 

affect 

Potential for stranding and 

turbine mortality, potential 

effects of gas supersaturation 

on juvenile and adult fish, 

impediments to migration, 

reduction in anadromous food 

base 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
749 

Species Species Status Species Finding 

Critical Habitat 

Finding Basis for Determination 

Idaho springsnail 

(Pyruglopsis 

idahoensis) 

Endangered No effect No effect Does not occur within or 

downstream of the project 

Howell’s 

spectacular 

thelypody 

(Thelypodium 

howellii ssp. 

spectabilis) 

Threatened No effect None designated No suitable habitat in the 

project area; no documented 

occurrences. 

MacFarlane’s fouro’clock (Mirabilis 

macfarlanei) 

Threatened Likely to 

adversely affect 

None designated Suitable habitat in the project 

vicinity, but no known 

occurrences on project lands. 

Project operations unlikely to 

affect, but surveys needed 

prior to ground-disturbance at 

high-probability sites because 

not all lands surveyed. 

Spalding’s catchfly 

(Silene spaldingii) 

Threatened Likely to 

adversely affect 

None designated Suitable habitat in the project 

vicinity, but no known 

occurrences on project lands. 

Project operations unlikely to 

affect, but surveys needed 

prior to ground-disturbance at 

high-probability sites because 

not all lands surveyed. 

Gray wolf (Canis 

lupus) 

Endangered/No

n-essential 

Experimental 

Population 

Not likely to 

adversely affect 

None designated Suitable habitat occurs in the 

project area; confirmed 

sightings nearby, and 

populations anticipated to 

increase. May be observed 

more frequently in the future, 

but species generally avoids 

concentrated activity. 

Canada lynx (Lynx 

canadensis) 

Threatened No effect No effect No suitable habitat in the 

project area; one unconfirmed 

sighting 70 miles downstream 

of Hells Canyon dam. May 

occur as transient. 

Northern Idaho 

ground squirrel 

(Spermophilus 

brunneus 

brunneus) 

Threatened Not likely to 

adversely affect 

None designated No suitable habitat occurs on 

project lands, but may be 

present on newly acquired 

lands, with potential for 

habitat enhancement. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
750 

Species Species Status Species Finding 

Critical Habitat 

Finding Basis for Determination 

Bald eagle 

(Haliaeetus 

leucocephalus) 

Delisted, 

monitor species 

Likely to 

adversely affect 

None designated Present in the project area, 

with increasing populations. 

Proposed and recommended 

measures including 

implementation of a 

management and monitoring 

plan, timing restrictions to 

minimize disturbance and 

review of measures to reduce 

risk of power line collision. 

5.5.5 Essential Fish Habitat 

Section 305(b)(2) of the Magnuson-Stevens Fishery Conservation and Management Act requires 

federal agencies to consult with the Secretary of Commerce regarding all actions or proposed actions that 

are authorized, funded, or undertaken by the agency that may adversely affect EFH. The Snake River 

downstream of the project comprises EFH for Chinook and coho salmon. 

Idaho Power proposes the following measures that should benefit Chinook EFH in the Snake 

River: (1) continue reservoir operations in the fall, winter, and early spring for protection of fall Chinook 

spawning and salmon incubation; (2) continue fall Chinook redd and temperature monitoring to avoid the 

risk of dewatering developing salmon embryos, but discontinue deep-water redd monitoring until fall 

Chinook escapement increases significantly; and (3) install spillway flow deflectors at Hells Canyon dam 

and continue preferential use of the upper spillgates at Brownlee dam during spill periods to reduce total 

dissolved gas concentrations in the Snake River downstream of Hells Canyon dam. 

In section 5.2, Discussion of Key Issues, we discuss two additional measures that we include in 

the Staff Alternative that would benefit EFH: (1) a pilot gravel augmentation program; and (2) measures 

to increase dissolved oxygen levels downstream of Hells Canyon dam. We conclude that Idaho Power’s 

proposal and the measures that we include in the Staff Alternative would not adversely affect EFH. 

5.5.6 National Historic Preservation Act 

Relicensing is considered an undertaking within section 106 of the NHPA, 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, traditional cultural properties, 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 that may have cultural affiliations with affected 

properties involving the undertaking. The overall review process involving section 106 is administered 

by the Advisory Council, an independent federal agency. 

To meet the requirements of section 106, the Commission would execute a Programmatic 

Agreement to take into account the effects on historic properties from the operation of the Hells Canyon 

Project (see section 5.2.6.1, Finalization of the HPMP). The terms of the Programmatic Agreement 

would ensure that Idaho Power would address and treat all historic properties identified within the areas 

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of potential effect through the HPMP. The HPMP entails ongoing consultation involving historic 

properties for the entire term of any new license. 

5.5.7 Pacific Northwest Electric Power Planning and Conservation Act, Columbia River 

Basin Fish and Wildlife Program, and Mainstem and Subbasin Plan Amendments 

to the Columbia River Basin Fish and Wildlife Program 

Under section 4(h) of the Pacific Northwest Power Planning and Conservation Act, the Northwest 

Power Planning Council (now known as the Northwest Power and Conservation Council) developed the 

Columbia River Basin Fish and Wildlife Program (Program) to protect, mitigate, and enhance the fish and 

wildlife resources associated with development and operation of hydroelectric projects in the Columbia 

River basin. Section 4(h) states that responsible federal and state agencies should provide equitable 

treatment for fish and wildlife resources, in addition to other purposes for which hydropower is 

developed, and that these agencies should take the Program into account to the fullest practical extent. To 

mitigate harm to fish and wildlife resources, the Council has adopted specific provisions to be considered 

in the licensing or relicensing of non-federal hydropower projects (appendix B of the Program). 

We conclude that the measures described in the Staff Alternative are consistent with most of the 

objectives of the Columbia River Basin Fish and Wildlife Program and would contribute toward 

achieving the program’s objectives. Measures to reduce total dissolved gas, enhance dissolved oxygen, 

maintain stable flows during fall Chinook salmon spawning, and minimize the risk of stranding, as well 

as the provision for flow augmentation water during the fall Chinook salmon outmigration, would assist 

with meeting the Program objectives of halting declining trends in salmon and steelhead populations 

above Bonneville dam and allowing for the recovery of fish and wildlife affected by the hydrosystem that 

are listed under the Endangered Species Act. The tributary enhancement program and planting surplus 

spring Chinook salmon and steelhead to provide forage for bull trout would contribute to the Program 

objective of restoring healthy ecosystems and watersheds. In addition to the measures listed above, which 

would contribute to halting declining trends in salmon and steelhead, development of a new facility on the 

Yankee Fork to collect, spawn, and incubate steelhead or Chinook salmon eggs and developing a plan to 

use surplus hatchery salmon and steelhead to provide ceremonial and subsistence fisheries for the 

Shoshone-Paiute and Burns Paiute tribes would assist with meeting the Program objective of providing 

abundant opportunities for tribal trust and treaty right harvest and for non-tribal harvest. The Staff 

Alternative does not include measures that would directly address the Program objective of restoring the 

widest possible set of healthy, naturally reproducing populations of salmon and steelhead; to reintroduce 

anadromous fish into blocked areas. However, we include several measures that would help to restore 

and monitor the condition of upstream habitat. In addition, construction of passage facilities on one or 

more tributaries should assist with the restoration of anadromous fish to areas upstream of and within the 

project area in the future when habitat is suitable and the concerns of other stakeholders have been 

addressed through the development of a comprehensive reintroduction plan. 

We conclude that the measures included in the Staff Alternative are also consistent with the 

mainstem amendments of the Columbia River Basin Fish and Wildlife Program and would contribute 

toward achieving the amendments’ objective of assisting the recovery of federally listed species. The 

Staff Alternative also includes a provision to evaluate the benefits of providing flow augmentation from 

Brownlee reservoir 6 years after license issuance, which is consistent with provisions in the mainstem 

amendments that call for federal agencies to report annually on the benefits of flow augmentation; to 

evaluate the validity of flow targets and flow augmentation actions in the 2000 Biological Opinion on 

operation of the Federal Columbia River Power System; and to ascertain the nature, extent of, and reasons 

for a flow-survival relationship through the lower Columbia River System. 

We reviewed each of the subbasin plans that have been prepared for subbasins within the Snake 

River basin. The subbasin plans provide a framework within which fish and wildlife projects to be 

funded by the Bonneville Power Administration are selected, based on objectives and strategies 

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developed for each subbasin. In table 111, we list measures included in the Staff Alternative that would 

contribute to meeting specific objectives identified within these subbasin plans. We did not identify any 

measures included in the Staff Alternative that would impede the attainment of any objectives listed in 

these subbasin plans. 

5.5.8 Wild and Scenic Rivers Act 

The Wild and Scenic River Act (P.L. 90-542) and its amendments protect, in their free-flowing 

conditions, designated rivers and their immediate environments that possess outstanding remarkable 

values (ORVs). ORVs may include scenic, recreational, geologic, fish and wildlife, historic, cultural, or 

other similar values. Section 7(a) of the act states that FERC shall not license the construction of any 

dam, water conduit, reservoir, powerhouse, transmission line, or other project works under the FPA on or 

directly affecting any river designated as a Wild and Scenic River. The Wild and Scenic Rivers Act 

specifically does not preclude licensing of developments upstream or downstream of designated wild, 

scenic, or recreational rivers if the development does not invade the area or unreasonably diminish the 

scenic, recreational, and fish and wildlife values present in the area on the date of designation of a river as 

a component of the national wild and scenic rivers system. 

Congress added 67.5 miles of the Snake River to the wild and scenic rivers system in 1975. The 

river is designated in two segments: the wild segment from Hells Canyon dam north to Upper Pittsburg 

Landing (about 31.5 miles) and the scenic segment from Upper Pittsburg Landing to a point about 36 

miles down river. Congress found that the wild portion of the river is free of impoundments and 

generally inaccessible except by trail, with watersheds or shorelines essentially primitive and waters 

unpolluted. Congress also found that the scenic portion of the river is free of impoundments, with 

shorelines or watersheds still largely primitive and shorelines largely undeveloped, but accessible in 

places by roads. The ORVs for the Snake Wild and Scenic River are broad reaching and include scenery, 

recreation, geology, wildlife, fisheries, cultural resources, vegetation/botany, and ecology. 

Current operations stop most sediment from moving through the project. This, in combination 

with powerboat wakes and variable releases from the Hells Canyon dam, appears to contribute to sandbar 

and shoreline erosion downstream of the project. The Forest Service, in its preliminary section 7(a) 

determination and report filed on January 26, 2006, determined that the continued degradation of sandbars 

under Idaho Power’s proposed operations would adversely affect the scenic, recreational, fish, and 

wildlife values of the river. The Forest Service also made a preliminary determination that the continued 

depletion of sand beaches and bars would result in the complete elimination of that resource by the end of 

a new license period, which would rise to the level of “unreasonable diminution” of scenic and 

recreational values. The Forest Service specified development of a sandbar maintenance and restoration 

plan (FS-4) to avoid unreasonably diminishing these values. In the draft EIS, we did not include FS-4 in 

the Staff Alternative because we considered the small additional sand restoration program to not be worth 

the potential adverse effects of sand-delivery barges on recreational boating and wildlife. Based on 

comments on the draft EIS, however, we reevaluated our recommendation and now include FS-4 in the 

Staff Alternative. Implementation of FS-4 would help restore some of the sand currently trapped by the 

dams and would assist in replenishing the sandbars that are an important component of the river’s scenic 

and recreational attributes. 

Overall, the environmental measures included in the Staff Alternative would help improve water 

quality passing through the project by increasing dissolved oxygen levels, allowing pesticides and other 

pollutants to break down in the upper reaches of Brownlee reservoir, and reducing elevated total dissolved 

gas levels. These measures would help improve water quality in the Wild and Scenic reaches. 

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Table 111. Measures included in the Staff Alternative relevant to objectives of Columbia River Fish and Wildlife 

plans. (Source: Staff) 

Number Measure Name 

RelAlt

Middle Snake (Shoshone Falls to Hells Canyon Dam) 

1a Restore aquatic ecosystems and user opportunities impacted by the loss of anadromous fish components. 8P, 2a Achieve white sturgeon population recovery to levels identified in table 5 in the subbasin plan. 11P3a Ensure continued existence of high density (core) redband trout populations. 8P 3b Ensure continued existence of moderate or low density redband trout (satellite) populations. 8P 4a Maintain and increase bull trout distribution and abundance (greater than or equal to 500 adults) within 

Indian and Wildhorse creeks. 

8P 

4b Reduce and prevent impacts of brook trout on bull trout where they exist, especially within the Indian Creek 

drainage 

8P 

5a Increase mountain whitefish productivity and production to desirable levels within 15 years through habitat 

improvements 

8P 

9a Support freshwater mollusk conservation and recovery through habitat restoration, ground and surface water 

conservation, and continued research of environmental factors limiting mollusk growth, survival, and reproduction. 

8P 

10a Increase understanding of the composition, population trends, and habitat requirements of the terrestrial 

communities of the middle Snake subbasins. 

12P

11a Restore flows in limited reaches 8P 11b Reduce water temperature to meet needs of aquatic focal species 8P, 

11c Reduce instream sedimentation to meet water quality standards 8P 11d Coordinate with TMDL process to support nutrient reduction efforts in 303 (d) listed stream segments 

affecting ESA listed or focal species. 

4P 

11e Reduce number of artificially blocked stream miles by 2019 to increase fish access to habitat, while 

screening diversions that negatively affect listed or focal species 

8P 

11f Improve aquatic habitat diversity and complexity in tributary systems where focal species populations are 

limited 

8P 

12a Protect existing quality, quantity, and diversity of native habitats. 12P

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Number Measure Name 

RelAlt

17P

12b Reduce extent and density of established noxious weeds and invasive exotics. 12P

20P 

14a Manage grazing to reduce impacts on the aquatic and terrestrial communities in the subbasin. Protect and 

restore riparian, wet meadow, and native upland habitats. 

12,15S 

14b Reduce conflicts between livestock and native wildlife, fish, and plant populations. 72P 16a Protect mature pine/fir forest habitats. 12P17a Protect existing shrub-steppe habitats from additional fragmentation and degradation. Prevent the additional 

loss of shrub-steppe habitats. Restore areas important for focal species 

12P

18a Protect remaining native grassland remnants. 12P18b Restore historic native grassland habitat to natural conditions. 12P19b Protect, enhance or restore riparian habitats. 12P

17P

22a Protect and foster cultural uses of natural resources in the Middle Snake subbasins. 103

Bruneau 

7a Within the next 10 years, increase riparian cover and stream shading in high-priority restoration hydrologic 

unit codes to levels consistent with the proper functioning condition and site capability. These levels vary, but in small to medium-sized streams (i.e., those measuring less than 5 meters in width), shading should equal between 60 and 80% (Zoellick, 2004). 

109

Owyhee There are no adopted measures or project effects applicable to objectives stated in this subbasin plan. Malheur 

5 Mitigate for the loss of anadromous fish species in the Malheur Subbasin through substitution programs that 

emphasize the long-term sustainability of native resident fish in native habitats wherever possible. 

103

Boise, Payette 

and Weiser 

There are no adopted measures or project effects applicable to objectives stated in this subbasin plan. 

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Number Measure Name 

RelAlt

Burnt/Powder 

1 Improve riparian, floodplain and wetland habitats 8P, 

14S

2 Improve stream channel processes. 8P 

3 Improve Water Quality (temperature, dissolved oxygen, chemical pollutants, biological pollutants, pH, 

turbidity). 

4p, 

4 Improve habitat connectivity and fish passage. 8P 

Snake River Hells Canyon (Hells Canyon dam to the Clearwater River) 

1a Ameliorate negative impacts from operations of the Hells Canyon Project 3P, 

1031079S, Op2, 3 

2a Increase smolt-to-adult return rates of naturally produced spawning adults to at least 4 to 6% for spring 

Chinook salmon, 3% for fall Chinook salmon, and 4% for steelhead, as measured at Lower Granite dam, to increase natural production and harvest of fish populations. 

4P, 106109101Op2, a

4a Increase understanding of the composition, population trends, interspecies interactions, habitat requirements, 

ecosystem processes, and impacts of management activities on terrestrial communities of the Snake Hells Canyon subbasin. 

18P

5a Maintain and enhance populations of focal, sensitive, and threatened and endangered species in the subbasin. 15P

15S 

6a Mitigate the negative impacts of Hells Canyon Dam on terrestrial species and habitats. 12P

21P15S 

8a Restore natural flow regime that supports and meets the life history needs of aquatic species in the subbasin. Ope

2 an

8b Provide temperature regimes that meet the life stage specific needs of aquatic focal species. 109

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Number Measure Name 

RelAlt

9a Protect the existing quality, quantity and diversity of native plant communities providing habitat to native 

wildlife species by preventing the introduction of noxious weeds and invasive exotic plants into native habitats. 

18P

9b Reduce the extent and density of established noxious weeds and invasive exotics. 18P11a Protect and restore riparian habitats. 11S 

Clearwater 

A Increase the number of naturally spawning adults to achieve goals in table 3 in the subbasin plan within 24 

years (timeline is consistent with the Council’s Fish and Wildlife Program). This should amount to 4–6% smolt-to-adult return rate for spring-summer Chinook salmon, 3% for fall Chinook salmon, and 4% for steelhead as measured at Lower Granite dam, within next 24 years. 

Opand 

R Develop an increased understanding of the thermal impacts of Dworshak dam operations on life history 

characteristics of fall Chinook salmon, other fishes, and associated wildlife species in downstream reaches, 

and reduce negative impacts by 2010. 

Op

Imnaha There are no adopted measures or project effects applicable to objectives stated in this subbasin plan. Salmon 

1a 1A: Increase the number of naturally spawning adults to achieve recovery goals in table 6 in the subbasin 

plan within 24 years (timeline is consistent with the Northwest Power and Conservation Council’s Fish and Wildlife Program). This should amount to 4–6% smolt-to-adult return rate for spring-summer Chinook salmon, 3% for fall Chinook salmon (minimum), 4% for sockeye salmon (minimum), and 4% for steelhead (minimum) as measured at Lower Granite dam and in the tributaries. 

5P, 108Opand 

1b 1B: Achieve goals defined in table 6 in the subbasin plan for the Salmon subbasin through the application of 

artificial propagation programs. Minimize short- and long-term genetic, ecological, and life history effects on wild populations. 

104

65a 65A: Protect and foster both Indian and non-Indian cultural uses of natural resources in the Salmon subbasin. 104

Grande Ronde 

There are no adopted measures or project effects applicable to objectives stated in this subbasin plan. 

Lower Snake There are no adopted measures or project effects applicable to objectives stated in this subbasin plan. 

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Several measures included in the Staff Alternative would benefit fisheries in the Snake River 

downstream of the project. The restrictive ramping rates and augmentation of summer migration flows 

would help improve anadromous fish returns, particularly for fall Chinook salmon. The improved water 

quality would also improve habitat conditions for native resident fish in the Snake River. Over time, 

improvements to the fishery could attract additional recreational users to the reach. However, we 

conclude that any increased recreational use associated with the improved fishery would be marginal and 

could not be distinguished from general increases in demand for boating and fishing in this section of the 

Snake River. 

Implementing the Staff Alternative recreational measures within the project boundary would have 

negligible effects on recreational resources in the designated Wild and Scenic reaches. The recreational 

measures primarily address recreational needs within the project boundary and would neither attract 

additional visitors to the designated reaches nor affect scenic values or wildlife values of these reaches. 

We conclude that implementation of the Staff Alternative would not invade or unreasonably 

diminish the scenic, recreational, and fish and wildlife values present in the area on the date of 

designation of the Snake River downstream of Hells Canyon dam as a component of the National Wild 

and Scenic Rivers System. 

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758 

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Turley, N.J.S. and A.M.A. Holthuijzen. 2003b. An investigation of avian communities and avian-habitat 

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2003. 

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7.0 LIST OF PREPARERS 

Federal Energy Regulatory Commission 

Alan Mitchnick—Project Coordinator/Terrestrial Resources, Threatened and Endangered Species 

(Environmental Biologist; M.S., Wildlife and Fisheries Sciences 

Emily Carter—Aesthetics, Land Use, Recreation (Environmental Biologist; B.A., Environmental 

Studies) 

Allan Creamer—Water Quality, Aquatic Resources, Threatened and Endangered Species (Fisheries 

Biologist; B.S. and M.S., Fisheries Science) 

James Fargo—Engineering (Civil Engineer; M.S., Civil Engineering) 

Frank Winchell—Cultural Resources (Archeologist; B.A., M.A., Ph.D., Anthropology) 

Louis Berger Group 

Ellen Hall—Task Manager (Senior Project Manager; Ph.D., Resource Economics; M.Ag., Agricultural 

Economics; B.A., History/Economics) 

Tim Abbe—Sediment Supply and Transport (Geomorphologist; Ph.D., Geomorphology/Geology, 

M.S., Geology, B.S., Geology) 

Martha Bowers—Cultural Resources (Cultural Resource Specialist; M.A., American History) 

Chris Brummer—Sediment Supply and Transport (Geomorphologist; Ph.D., Fluvial Geomorphology; 

B.A., Geology) 

Benjamin Ellis—Aesthetics, Land Use, Recreation (Environmental Planner; M.B.A., Ph.D., Natural 

Resources; B.S., Biology and Sociology,) 

Coreen Johnson—Editorial Review (Technical Editor; B.A., English Education) 

Mark Killgore—Developmental Analysis (Water Resource Engineer; M.S.C.E., Water Resources 

Engineering; B.C.E., Civil Engineering; B.A., Liberal Arts) 

Brian Mattax—Water Quality (Aquatic Scientist; B.S., Biology) 

Eileen McLanahan—Terrestrial Resources, Threatened and Endangered Species (Terrestrial Biologist; 

M.S., Biology) 

Robert Mohn—Water Quantity, Senior Technical Review (Deputy Project Manager; B.S., 

Engineering; M.P.A., Public Affairs; Regional Planning Certification) 

Fred Winchell—Aquatic Resources, Threatened and Endangered Species (Fishery Biologist; M.S., 

Fisheries Biology) 

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8.0 LIST OF RECIPIENTS 

Adams County Commissioners, Judith T. Ellis, Council, ID 

American Rivers, Inc., Brett Swift, Portland, OR 

American Whitewater, Thomas O’Keefe, PNW Stewardship Director, Seattle, WA 

American Whitewater, Kevin Colburn, National Stewardship Director, Missoula, MT 

Baker County Board of Commissioners, Legal Department, Baker City, OR 

Baker County, County Court, Baker City, OR 

Bureau of Land Management, Idaho State Office, John Martin, Boise, ID 

Bureau of Land Management, Baker Field Office, Dorothy Mason, Relicensing Team Lead, Baker City, 

OR 

Bureau of Land Management, Four Rivers Field Office, Rosemary Thomas, Boise, ID 

Bureau of Land Management, State Director, Boise, ID 

Bureau of Land Management, State Director, Portland, OR 

Boise, City of, Mayor, Boise, ID 

Bonneville Power Administration, Director, Portland, OR 

Burns Paiute Tribe, Denise Turner Walsh, Burns, OR 

Columbia River Inter-Tribal Fish Comm., Confederated Tribes of the Umatilla, Robert Heinith, 

Coordinator, Portland, OR 

Columbia River Inter-Tribal Fish Comm., Confederated Tribes of the Umatilla, Carl Merkle, Pendleton, OR 

Columbia River Inter-Tribal Fish Comm., Policy Dev. & Litigation Support, Portland OR 

Committee of Nine, John Simpson, Boise, ID 

Committee of Nine, Shelley Davis, Attorney, Boise, ID 

Committee of Nine, John Simpson, Barker Rosholt & Simpson, LLP, Boise, ID 

Committee of Nine, Shelley M Davis, Barker Rosholt & Simpson, LLP, Boise, ID 

Earthjustice Legal Defense Fund, Todd D. True, Seattle, WA 

Fort Hall Business Council, Lionel Boyer, Chairman, Fort Hall, ID 

Foundation for N. American Wild Sheep, Raymond Lee, Cody, WY 

Friends of Brownlee, Mike Nelson, President, Baker City, OR 

Hells Canyon Preservation Council Inc., Daniel Ousley, Attorney, Lewiston, ID 

Hydro Site Database, Steve Bellcoff, Portland, OR 

Idaho Department of Environmental Quality, Director, Boise, ID 

Idaho Department of Environmental Quality, Douglas Conde, Deputy Attorney General, Boise, ID 

Idaho Department of Fish and Game, Cynthia Robertson, Fishery Program Coordinator, Boise, ID 

Idaho Department of Water Resources, Phillip J. Rassier, Deputy Attorney General, Boise, ID 

Idaho Department of Lands, Boise, ID 

Idaho Department of Lands, C. Nicolas Krema, Deputy Atty. General, Boise, ID 

Idaho Department of Parks and Recreation, Mary Lucachick, Boise, ID 

Idaho Department of Water Resources, Phillip Rassier, Deputy Atty. General, Boise, ID 

Idaho Division of Environmental Quality, Dr. Balthasar B. Buhidar, Ph.D., Regional Manager, Twin Falls 

Regional Office, Twin Falls, ID 

Idaho Attorney General’s Office, Harriet A. Hensley, Deputy Attorney General, Boise, ID 

Idaho Soil Conservation Commission, Boise, ID 

Idaho Office of the Attorney General, Boise, ID 

Idaho Power Company, Craig Jones, Relicensing Project Manager, Boise, ID 

Idaho Power Company, James C. Tucker, Boise, ID 

Idaho Power Company, Nathan F. Gardiner, Attorney, Boise, ID 

Idaho Power Company, Robert W. Stahman, Vice President, Boise, ID 

Idaho Power Company, Vern Porter, General Manager, Boise, ID 

Idaho Public Utilities Commission, Chairman, Boise, ID 

Idaho Public Utilities Commission, Donald L. Howell, II, Deputy Attorney General, Boise, ID 

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Idaho Rivers United, Inc., Sara D. Eddie, Advocates for the West, Boise, ID 

Idaho Rivers United, Kevin L. Lewis, Conservation Director Boise, ID 

Idaho State Preservation Office, Director, Boise, ID 

Idaho Water Users Association, Inc. Robert D Ling, Ling, Nielsen & Robinson, Rupert, ID 

Idaho Water Users Association, Inc,. Norman Semanko, Executive Director, Boise, ID 

Industrial Customers of Idaho Power, Peter Richardson, Richardson & O’Leary, Boise, ID 

Industrial Customers of Idaho Power, Mark Ryan Thompson, Attorney, Boise, ID 

Jerome County, Chairman, Jerome, ID 

Lincoln County, Chairman, Shoshone, ID 

Lower Valley Energy Inc, Todd Gordon Glass, Heller Ehrman, Seattle, WA 

Malheur County, County Judge, Vale, OR 

Minidoka County Board of Commissioners, Chairman, Rupert, ID 

National Marine Fisheries Service, Ritchie Graves, Portland, OR 

National Marine Fisheries Service, Keith Kirkendall, Hydro Division, Portland, OR 

National Oceanic & Atmospheric Admin., Jane S. Hannuksela, Esq., Seattle, WA 

National Marine Fisheries Service, Regional Director, Long Beach, CA 

Nez Perce Tribal Executive Comm. Chairman, Lapwai, ID 

Nez Perce Tribe, Office of Legal Services, Ryan Sudbury, Lapwai, ID 

Nez Perce Tribe, Greg Haller, Lapwai, ID 

Nez Perce Water Resource Development, Director, Lapwai, ID 

Northwest Resource Information Center, Ed Chaney, Director, Eagle, ID 

NW Professional Power Vessel Association, Arthur Leslie Seamans, Executive Director, Lewiston, ID 

Northwest Power Planning Council, Peter Paquet, Portland, OR 

Oregon Department of Agriculture, Natural Resources Division, Jim Johnson, Salem, OR 

Oregon Department of Fish & Wildlife, Colleen E. Fagan, NE Region Hydro Coordinator, La Grande, 

OR 

Oregon Department of Fish & Wildlife, Ken Homolka, Hydropower Program Leader, Salem, OR 

Oregon Department of Forestry, Director, Salem, OR 

Oregon Department of Justice, Kurt Burkholder, Assistant Attorney General, Portland, OR 

Oregon Dept of Land Conservation & Development, Paul Curcio, Director, Salem, OR 

Oregon Dept. of Environmental Quality, Marilyn Fonseca, Portland, OR 

Oregon State Extension Services, Oregon State University, Director, Corvallis, OR 

Oregon Parks & Recreation Department, Jan E. Houck, Program Coordinator, Salem, OR 

Oregon Public Utility Commission, Bill McNamee, Salem, OR 

Oregon State Marine Board, Randy H. Henry, Policy Planning Analyst, Salem, OR 

Oregon Water Resources Department, Ronald Craig Kohanek, Salem, OR 

Oregon Water Resources Department, Phil Ward, Director, Salem, OR 

Oregon Department of Environmental Quality, Paul A. DeVito, Bend, OR 

Pacific Environmental Advocacy Center, Daniel J. Rohlf, Portland, OR 

Payette River Water Users Association, Pioneer Irrigation District, Scott L. Campbell, Moffatt, Thomas, 

Barrett, Rock & Fields, Boise, ID 

Power County Board of County Commissioners, Chairman, American Falls, ID 

Richardson, Mark, Clarkston, WA 

Shoshone-Bannock Tribes, Shaun Robertson, Fort Hall, ID 

Shoshone-Bannock Tribes, Keith Kutchins, Fort Hall, ID 

Shoshone-Paiute Tribe, Donald M. Clary, Holland & Knight LLP, Los Angeles, CA 

Shoshone-Paiute Tribe, Tim Dykstra, Owyhee, NV 

Shoshone-Paiute Tribe, Kyle Prior, Owyhee, NV 

U.S. Army Corps of Engineers, Portland, OR 

U.S. Army Corps of Engineers, Chief, Walla Walla District, Walla Walla, WA 

U.S. Bureau of Indian Affairs, Portland Area Office, Regional Hydro Policy Specialist, Portland, OR 

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U.S. Bureau of Indian Affairs, FERC Coordinator, Portland, OR 

 U.S. Bureau of Indian Affairs, Fred Allgaier, Lakewood, CO 

U.S. Bureau of Indian Affairs, Stanley Speaks, Regional Director, Portland, OR 

U.S. Bureau of Indian Affairs, Superintendent, Elko, NV 

U.S. Bureau of Reclamation, Boise, ID 

U.S. Bureau of Reclamation, Klamath Basin Area Office, Area Manager, Klamath Falls, OR 

U.S. Bureau of Reclamation, Regional Director, Boulder City, NV 

U.S. Coast Guard, MSO Portland, Portland, OR 

U.S. Department of Agriculture, Jocelyn B. Somers, Portland, OR 

U.S. Department of Agriculture, Kenneth D. Paur, Ogden, UT 

U.S. Department of the Interior, Office of Environmental Policy & Compl. Regional Environmental 

Officer, Portland, OR 

U.S. Department of the Interior, Office of the Solicitor, Frank S. Wilson, Portland, OR 

U.S. Forest Service, Darrington Ranger District, Walt Dortch, Hydropower Coordinator, Darrington, WA 

U.S. Forest Service, Hydropower Coordinator, Baker City, OR 

U.S. Forest Service, Payette National Forest, Forest Supervisor, McCall ID 

U.S. Forest Service, Intermountain Region, Director of Lands, Ogden, UT 

U.S. Forest Service, Kristen Bonanno, Negotiation Specialist, Portland, OR 

U.S. Forest Service, RHAT-Heritage, Steve Kramer, Colville, WA 

U.S. Forest Service, Regional Hydropower Coordinator, Salt Lake City, UT 

U.S. Forest Service, Wallowa-Whitman National Forest, Forest Supervisor, Baker City, OR 

U.S. Environmental Protection Agency, Director, Boise, ID 

U.S. Environmental Protection Agency, John E. Bregar, Coordinator, Seattle, WA 

U.S. Environmental Protection Agency, Region 9 - Federal Activities Office, David P. Schmidt, San 

Francisco, CA 

U.S. Fish & Wildlife Service, Boise Field Office, Boise, ID 

U.S. Fish and Wildlife Service, Field Supervisor, Boise, ID 

U.S. Fish & Wildlife Service, Director, Portland, OR 

U.S. Fish & Wildlife Service, FERC Coordinator, Portland, OR 

U.S. Fish & Wildlife Service, Upper Columbia River Basin Field Office, Regional Director, Spokane, WA 

U.S. Senate, Honorable Mike Crapo, Washington, DC 

U.S. Senate, Honorable Larry Craig, Washington, DC 

U.S. Senate, Honorable Ron Wyden, Washington, DC 

Umatilla Agency, Superintendent, Pendleton, OR 

Wallowa County, County Court, Enterprise, OR 

Warm Springs Tribe, Elton Greeley, Warm Springs, OR 

Washington County Commissioners, Diana Lee Thomas, Commissioner, Weiser, ID 

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APPENDIX A 

AGENCY IDENTIFIERS FOR MEASURES 

ADDRESSED IN THE EIS 

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A-1 

Appendix A. Agency Identifiers for Measures Addressed in the EIS 

Identifier Used 

in the EIS 

Recommending 

Entity ID 

Recommendation Type Description of Measure 

AR/IRU-1 I comment Reopen Idaho Power's Mid-Snake Projects and C.J. Strike project licenses. AR/IRU-2 II.1 comment Issue the license for a term of 30 years. AR/IRU-3 II.2 comment Convene a technical advisory committee to oversee adaptive management in the 

AR/IRU-4 II.3 comment Allow for a license reopener in the event that additional measures/modifications a

AR/IRU-5 III.1 10a Work with a subgroup of a Technical Advisory Committee on a fish passage and AR/IRU-6 III.2 10a Design, fund and implement a Fish Passage and Reintroduction Plan. 

AR/IRU-7a III.3.1 10a Provide passage of spring Chinook and steelhead into Pine and Indian Creeks. 

AR/IRU-7b III.3.1(sic) 10a Provide passage of spring Chinook and steelhead into Eagle, Daly and Goose Cre

AR/IRU-7c III.3.3 10a Consider and implement passage and reintroduction efforts in the Weiser and Pay

AR/IRU-7d III.3.4 10a Implement a pathogen risk assessment to understand the pathogen risks from a re

AR/IRU-8a III.4.1 10a Conduct water quality studies under a drawdown and full reservoir scenario. 

AR/IRU-8b III.4.2 10a Evaluate egg to fry survival of fall Chinook using egg boxes. 

AR/IRU-8c III.4.3 10a Study juvenile and adult fall Chinook migration through project reservoirs and to 

AR/IRU-8d III.4.4 10a Initiate fall Chinook reintroduction after sufficient egg survival rates have been d

AR/IRU-8e III.4.5 10a Design, construct, and test upstream and downstream fish passage facilities. 

AR/IRU-8f III.4.6 10a Evaluate passage needs at Swan Falls dam and C.J. Strike dam. 

AR/IRU-9a III.5.1, 5.2, 5.3 10a Construct fish passage facilities at Pine Creek, upgrade the Hells Canyon trap, etc

AR/IRU-9b III.5.4 10a Implement a brook trout eradication program for tributaries into which bull trout 

AR/IRU-9c III.5.5 10a Conduct a fish pathogen risk assessment. 

AR/IRU-9d III.5.6 10a Conduct long-term monitoring and evaluation of the resident fish passage programAR/IRU-10 IV 10a Undertake a hatchery program consistent with the priority objective of recovery o

AR/IRU-11a V.1.1 10a Fund and implement a tributary enhancement program; emphasis on Pine and Ind

AR/IRU-11b V.1.2 10a Reintroduce anadromous salmon and steelhead to restore marine-derived nutrient

AR/IRU-11c V.1.3 10a Ensure sufficient flows in the Oxbow bypassed reach to allow fish passage for bu

AR/IRU-11d V.1.4 10a Study project effects on bull trout prey base, foraging capability, growth, fecundi

AR/IRU-12a V.2.1.A 10a Implement ROR operations at Lower Salmon Falls, Bliss, C.J. Strike projects sea

AR/IRU-12b V.2.1.C 10a Monitor success of sturgeon spawning and early life history stages. 

AR/IRU-12c V.2.2 10a Develop conservation aquaculture program. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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Identifier Used 

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Recommending 

Entity ID 

Recommendation Type Description of Measure 

AR/IRU-12d V.2.3, V.2.6 10a Study limiting factors in each reach; determine whether passage is necessary to e

AR/IRU-12e V.2.4, V.2.7 10a Conduct a white sturgeon passage/connectivity study; implement anti-entrainmen

AR/IRU-12f V.2.8 10a Do not undertake sturgeon translocation until limiting factors have been determin

AR/IRU-12g V.2.10 10a Implement water quality improvement measures elsewhere in the basin to aid in s

AR/IRU-13 VI 10a Implement a Pacific lamprey restoration plan using adaptive management AR/IRU-14 VII 10a Require an adaptive management approach to the mitigation of project effects to AR/IRU-15 VIII.1 10a Provide a level of suspended fine sediment that mimics naturally occurring levels AR/IRU-16 VIII.2 10a Reduce nutrient and suspended particle delivery from on-land sources instead of 

AR/IRU-17a VIII.3.A 10a Conduct real time DO monitoring of Brownlee and implement similar systems at 

AR/IRU-17b VIII.3.B 10a Increase dissolved oxygen levels by aerating or oxygenating forebay waters and o

AR/IRU-17c VIII.3.B 10a Use adaptive-management approach in applying this measure. AR/IRU-18a VIII.4.1 10a Monitor TDG in real time during periods of spill or consistent with WQCs to det

AR/IRU-18b VIII.4.2 10a Use an adaptive-management approach using measurements of TDG as an indica

AR/IRU-18c VIII.4.3 10a Install deflectors to minimize the deep plunge of water immediately downstream 

AR/IRU-18d VIII.4.4 10a Evaluate if non-plunging discharge should be horizontally separated from plungin

AR/IRU-18e VIII.4.6 10a Develop a compensation program to address losses of aquatic biota when TDG at

AR/IRU-19 VIII.5 10a Continue to investigate installation of a temperature control structure to meet Cle

AR/IRU-20 VIII.6 10a Obtain a section 402 CWA permit for any discharges related to turbine operation AR/IRU-21 IX 10a Replenish an appropriate portion of the sediments to the Snake River below Hells AR/IRU-22 X.1. 10a Cooperate with BOR to provide flow augmentation. 

AR/IRU-23a X.2.1, 2.2 10a Implement a ramping rate of 2 inches per hour from Dec. 8 through Oct. 19, and 

AR/IRU-23b X.2.3 10a Monitor and identify potential stranding sites and minimize the potential for stran

AR/IRU-23c X.2.4 10a Measure flows and ramping rates at Hells Canyon dam. 

AR/IRU-23d X.2.5 10a Study and implement operations with respect to ramping rates to provide an optim

AR/IRU-24 X.3 10a Implement a minimum flow that would reduce entrapment during the spring fall AR/IRU-25 X.4 10a Identify and implement restrictions on a range of changes in daily maximum discAR/IRU-26 XI.1 10a Install and operate water quality monitoring stations. AR/IRU-27 XII 10a Establish mitigation funds for habitat enhancement and restoration for on and off

AR/IRU-28 XIII.1 10a Establish a Project Decommissioning Fund. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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Entity ID 

Recommendation Type Description of Measure 

AR/IRU-29 XIII.2 10a Implement conservation programs; non-hydropower renewable energy; demand s

BPT-1 G-1 10a Consult with BPT in a government-to-government relationship regarding activitie

BPT-2 G-2 10a Ensure compliance with all applicable laws, rules and regulations. 

BPT-3 G-3 10a Establish and fund a Resource Coordinating Committee. 

BPT-4 .G-4 10a Escalate costs and payment amounts according to the specified formula. 

BPT-5 A-1 10a Fund the acquisition of upland and riparian habitat in the Malheur River Sub-bas

BPT-6 A-2 10a Implement a Habitat and Water Quality Restoration Fund in areas where salmon BPT-7 A-3 10a Consider the feasibility and practicality of passage and partial restoration of anad

BPT-8 A-4 10a Establish and fund an Aquatic Resources Task Force and implement an Integrate

BPT-9 T-1 10a Establish and fund a Terrestrial Resources Task Force. 

BPT-10 C-1 10a Comply with all applicable cultural protection laws. 

BPT-11 C-2 10a Create a Burns Paiute Tribal Education Scholarship. BPT-12 C-3 10a Establish a Cultural Education Center. 

BPT-13 C-4 10a Complete studies regarding traditional cultural properties and file a Historic PropBPT-14 C-5 10a Provide law enforcement to protect cultural resources (develop monitoring plan). 

BPT-15 C-6 10a Establish a Cultural Resources Task Force. 

BPT-16 C-7 10a Consult and work with BPT on gathering information about cultural sites (fund). 

BPT-17 C-8 10a Establish a cooperative management area in the Snake River and its tributaries. 

BPT-18 R-1 10a Manage reservoir levels and recreation to preserve and protect cultural and natura

BPT-19 R-2 10a Prepare an Integrated Comprehensive Recreational Plan, a Visual Resource Mgm

Corps-1 2 10a Determine the flood control draft for Brownlee consistent with the November 199

Corps-2 3 10a Handle future winter flood control operations for Brownlee reservoir in conjunctiCorps-3 5.2.1.a 10a Operate the project in the interest of navigation to maintain flow targets continuoCorps-4 5.2.1.b 10a Set the minimum release from Hells Canyon dam when Brownlee Reservoir infloCorps-5 5.2.1c 10a Seek a temporary variance from the Corps for flow requirements under certain ciCorps-6 5.2.1d 10a Prevent the maximum variation in river stage from exceeding one foot per hour a

CTUIR-1 II.A 10a Provide a mitigation and compensation fund for artificial production of fisheries 

CTUIR-2 II.B 10a Manage emergency situations that may cause mortality or other harm to fish and 

CTUIR-3 II.C 10a Include FERC's standard reopener to reopen the license proceeding if needed. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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CTUIR-4 II.D 10a Remove or modify Project facilities and restore pre-Project conditions upon projeCTUIR-5 II.E 10a Issue the license for a term of no longer than 20 years. CTUIR-6 III.1 10a Timely pass all Upper Snake River water through the project. 

CTUIR-7 III.2 10a Maintain Brownlee reservoir at its upper flood control rule curve from February 2

CTUIR-8 III.3 10a Shift flood control space from Brownlee reservoir to Lake Roosevelt seasonally iCTUIR-9 III.4 10a Implement actions to make the most efficient use of Brownlee reservoir storage t

CTUIR-10 III.5 10a Restrict ramping rates to 2 inches per hour during fall chinook spawning and cert

CTUIR-11a III.6 10a Evaluate the feasibility of fish passage technologies for upstream and downstream 

CTUIR-11b III.6 10a Conduct field tagging studies to determine juvenile and adult lamprey migration 

CTUIR-11c III.6 10a Evaluate effects of reservoir drawdowns on fish passage, water quality, and wateCTUIR-12a III.7 10a Develop and implement a salmon and steelhead reintroduction plan. 

CTUIR-12b III.7.A 10a Design, construct and operate a juvenile spring Chinook collection facility on Ea

CTUIR-12c III.7.B 10a Provide a juvenile summer steelhead collection facility on Pine Creek or in the H

CTUIR-12d III.7.C 10a Re-introduce spring Chinook in Eagle Creek and summer steelhead in Pine Creek

CTUIR-12e III.7.D 10a Design, construct and operate improved adult collection facilities at Hells Canyon 

CTUIR-12f III.7.F 10a Design, construct and operate juvenile salmon and steelhead collection facilities i

CTUIR-12g III.7.G 10a Establish an escrow account into which the annualized cost of PME measures is d

CTUIR-13 III.8 10a Develop a plan that promotes rebuilding of white sturgeon populations within the 

CTUIR-14 III.9 10a Maintain a minimum flow of 6,500 cfs immediately below Hells Canyon dam anCTUIR-15 III.10 10a Establish and support a single, comprehensive fisheries and aquatic resources maCTUIR-16 III.11 10a Contribute to the funding of regional evaluations of salmon stocks that are affecteCTUIR-17 III.12 10a Investigate the status of the Pacific lamprey population in the project area and co

CTUIR-18 III.13 10a Ensure passage of juvenile Pacific lamprey through the project and meet downstrCTUIR-19 III.14 10a Develop a Lamprey Passage Plan CTUIR-20 III.15 10a Construct structures on Hells Canyon dam to abate total dissolved gas. CTUIR-21 III.16 10a Construct structures on Hells Canyon dam to add dissolved oxygen to the Snake CTUIR-22 III.17 10a Investigate installation of a temperature control structure at Brownlee reservoir. CTUIR-23 III.18 10a Prevent the discharge of point-source pollutants into the Snake River from the proCTUIR-24 III.18.C.1 10a Expand the APE to the confluence of the Snake and Clearwater Rivers and surve

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Entity ID 

Recommendation Type Description of Measure 

CTUIR-25 III.18.C.2 10a Finalize the HPMP. CTUIR-26 III.18.C.3 10a Remove all time frames for agencies to consult with tribes regarding undertakingCTUIR-27 III.18.C.4 10a Create a cultural resource work group. CTUIR-28 III.18.C.5 10a Clarify that all PMEs in all categories are undertakings for the purposes of the NaCTUIR-29 III.18.C.6 10a Specify what is meant by monitoring. CTUIR-30 III.18.C.7 10a Stabilize and protect affected historic properties and maintain any stabilization m

CTUIR-31 III.18.C.8 10a Mitigate sites and clarify that the significance of a given site may be tied to more 

CTUIR-32 III.18.C.9 10a Clarify that boat wakes on the reservoirs are project-related impacts. CTUIR-33 III.18.C.10 10a Ensure that artifacts removed from the APE are reburied on site or curated at a fe

CTUIR-34 III.18.C.11 10a Clearly delineate roles of other federal agencies that may play a role implementin

CTUIR-35a III.19 10a Identify, monitor and mitigate effects to historic properties, and ultimately to bett

CTUIR-35b III.19.A 10a Develop long-term monitoring framework and plan for archaeological sites. 

CTUIR-35c III.19.B 10a Develop monitoring plan for rock image sites. 

CTUIR-35d III.19.C 10a Develop monitoring framework and plan for TCPs. 

CTUIR-35e III.19.D 10a Enact measures for law enforcement. 

CTUIR-35f III.19.E 10a Involve public, other agencies, law enforcement in protection efforts. 

CTUIR-35g III.19.F 10a Discourage use of dispersed recreation sites in the APE. CTUIR-35h III.19.G 10a Conduct sensitivity training for staff. 

CTUIR-35i III.19.H 10a Resurvey APE every 10 years. CTUIR-35j III.19.H 10a Provide $1 million to tribes to assist their participation in consultation and coordi

CTUIR-35k III.19.H 10a Develop plan for increasing tribal access to tribal fishing sites in APE. 

FS-1 1 4e Obtain FS approval prior to habitat or ground-disturbing activities on Forest Serv

FS-2 2 4e Prepare a Resource Coordination Plan. 

FS-3 3 4e Prepare a Fire Prevention Plan. 

FS-4 4 4e Establish a mitigation fund for use by the Forest Service for the purpose of restor

sandbars. 

FS-5 5 4e Prepare an Integrated Wildlife Habitat Program (IWHP) and Wildlife Mitigation 

(WMMP). 

FS-6 6 4e Prepare a Land Acquisition and Management Plan to be incorporated into the IW

FS-7 7 4e Prepare and implement a cooperative Integrated Weed Management Plan. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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Entity ID 

Recommendation Type Description of Measure 

FS-8 8 4e Prepare a Threatened and Endangered Species Management and Monitoring StraFS-9 9 4e Prepare a Sensitive Species Management Plan to be incorporated into the WMMP

FS-10 10 4e Implement the Mountain Quail Habitat Enhancement program. 

FS-11 11 4e Develop a transmission line operation and maintenance plan. 

FS-12 12 4e Finalize the Hells Canyon Complex Comprehensive Recreation Management Pla

FS-13 13 4e Develop a site development plan for the Big Bar Recreation Area. 

FS-14 14 4e Implement the Eagle Bar site plan proposed in the draft Recreation Plan. 

FS-15 15 4e Implement the Eckels Creek Dispersed Site plan proposed in the draft Recreation 

FS-16 16 4e Complete a condition and safety inspection of Deep Creek Stairway/Trail #218 an

FS-17 17 4e Improve and maintain parking/signing at Allison, Kinney, Eckels, and Deep CreeFS-18 18 4e Perform O&M necessary to meet Forest Service standards for Eagle Bar, Eckels 

FS-19 19 4e Manage Hells Canyon reservoir levels to minimize impacts on recreation resourc

FS-20 20 4e Perform trail maintenance for trails designated by the Forest Service. 

FS-21 21 4e Prepare a plan for improvements of the Hells Canyon Creek Launch Site. 

FS-22 22 4e Develop an aesthetic improvement plan for enhancement of Hells Canyon dam. 

FS-23 23 4e There is no FS-23. 

FS-24 24 4e Prepare a Scenery Management Plan for FS lands within the project boundary an

boundary if they are affected. 

FS-25 25 4e Finalize a Historic Properties Management Plan for cultural resources within the 

FS-26 26 4e Provide a project map and aerial photographs depicting the approximate location FS-27 27 4e Implement additional measures as necessary. FS-28 There is no FS-28 

FS-29 1 10a Maintain a minimum flow of 8,500 cfs downstream of Hells Canyon dam to prov

FS-30 2 10a Assess the effects of load following downstream of Hells Canyon dam using the A

FS-31 3 10a Prepare a Gravel Monitoring Plan. FS-32 4 10a Develop, fund and implement a fish passage plan for bull trout. 

FS-33 5 10a Establish, fund and implement a Tributary Habitat Mitigation Fund for spring ChFS-34 6 10a Finalize and implement the Hells Canyon Resource Management Plan, IWHP, an

IDFG-1a III.C.1 10j Continue Idaho Power's fall Chinook spawning program, which includes providin

IDFG-1b III.C.1 10j Develop measures to reduce effects of entrapment on juvenile Chinook during th

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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Entity ID 

Recommendation Type Description of Measure 

IDFG-2 III.C.2 10j Continue to conduct shallow redd surveys and monitor temperature. IDFG-3 III.C.3 10j Continue and improve the anadromous fish hatchery facilities and program IDFG-4 III.C.4 10j Develop anadromous fish hatchery goals, especially those related to adult return aIDFG-5 III.C.5 10j Monitor and evaluate fish hatchery performance and employ an IDFG hatchery eIDFG-6 III.C.6 10j Purchase a new fish marking unit and implement measures to ameliorate whirling IDFG-7 III.C.7 10j Purchase and operate an additional transport vehicle for relocating surplus adult fIDFG-8 III.C.8 10j Improve public angler access to several fisheries. IDFG-9 III.C.9 10j Continue monitoring incubation conditions in the historic fall Chinook spawning 

IDFG-10 III.C.10 10j Monitor Pacific lamprey downstream and participate in the Columbia River Basin IDFG-11 III.E.1 10j Develop and implement a native salmonid plan IDFG-12 III.E.2 10j Implement a pathogen risk assessment plan for the Pine Creek, Indian Creek, and IDFG-13 III.E.3 10j Initiate a fish passage program; do not relocate bull trout until adverse effects fro

IDFG-14 III.E.4 10j Improve facilities at the existing Hells Canyon dam fish trap by implementing a sIDFG-15 III.E.5 10j Delay construction of a fish trap at Oxbow dam until the Hells Canyon fish trap cIDFG-16 III.E.6 10j Implement a tributary habitat enhancement program. IDFG-17 III.E.7 10j Supplement nutrients for resident salmonids using only spawned carcasses or car

IDFG-18 III.E.8 10j Conduct surveys for bull trout in the Hells Canyon Complex IDFG-19 III.E.9 10j Design, construct, and monitor a weir facility at Pine Creek IDFG-20 III.E.10 10j Explore feasibility of methods to control brook trout in Indian Creek IDFG-21 III.E.11 10j Use the white sturgeon conservation plan to contribute to the goal of restoring heIDFG-22 III.E.12 10j Conduct an assessment of degraded water quality impacts on early life stages of wIDFG-23 III.E.13 10j Conduct feasibility studies prior to the translocation of reproductive-sized white sIDFG-24 III.E.14 10j Focus initial conservation efforts to benefit white sturgeon on habitat restoration. IDFG-25 III.E.15 10j Conduct long-term population assessments of white sturgeon as proposed by IdahIDFG-26 III.E.16 10j Implement a genetic monitoring program of white sturgeon as proposed by Idaho IDFG-27 III.G.1 10j Implement measures to protect warmwater fish. IDFG-28 III.I.1 10j Acquire, protect, and enhance lands to mitigate project impacts. IDFG-29 III.I.2 10j Acquire and enhance low elevation upland and riparian habitat to replace habitats IDFG-30 III.I.3 10j Develop and fund a mountain quail restoration project adjacent to the project rese

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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Entity ID 

Recommendation Type Description of Measure 

IDFG-31 III.I.4 10j Enhance habitat on Gold, Huffman, Patch, and Porter Islands with increased fundIDFG-32 III.I.6 10j Control the establishment and spread of noxious weeds in the project area. IDFG-33 III.I.7 10j Protect rare plant sites affected by disturbance activities in Hells Canyon. IDFG-34 III.I.8 10a Manage the Big Bar recreation site for wildlife not intensive recreation. 

IDPR-1 IV.C.2 10a Implement Idaho Power’s proposed recreation and aesthetic measures. 

Interior-1 1 4e Consult and cooperate with the BLM prior to initiating activities on BLM-admini

Interior-2 2 4e Consult with BLM and prepare an annual report summarizing progress on implem

license that would affect recreation, cultural, aquatic, and terrestrial resources on adjacent to the project boundary. 

Interior-3 3 4e Develop a Travel and Access Management Plan for project and BLM-administereInterior-4 4 4e Develop and implement a Law Enforcement and Emergency Services Plan. Interior-5 5 4e Revise, finalize, and implement the final Historic Properties Management Plan fo

administered lands. 

Interior-6 6 4e Prepare a Comprehensive Recreation Management Plan. 

Interior-7 7 4e Develop and implement a litter and sanitation plan for the project. 

Interior-8 8 4e Develop a Project Boat Moorage Plan. 

Interior-9 9 4e Develop an enhancement plan for the BLM sites referred to as Airstrip, Bob Cree

Interior-10 10 4e Develop an enhancement plan for the BLM Swedes Landing Site (Swedes Plan). 

Interior-11 11 4e Develop an enhancement plan for the BLM Spring Recreation Site. Interior-12 12 4e Develop an enhancement plan for the BLM site referred to as Steck Recreation SInterior-13 13 4e Develop an enhancement plan for the BLM site referred to as Jennifer’s Alluvial 

Interior-14 14 4e Develop an improvement plan for site no. 2 below Hells Canyon Dam Bridge (BC

sanitation plan for BCHB(2) and other dispersed sites. 

Interior-15 15 4e Develop an enhancement plan for the BLM site referred to as Carter’s Landing an

Interior-16 16 4e Develop an enhancement plan for the BLM site referred to as Oasis. Interior-17 17 4e Develop an enhancement plan for the BLM site referred to as Copper Creek. 

Interior-18 18 4e Develop a Low-Water Boat Launch Plan. 

Interior-19 19 4e Withdrawn Interior-20 10(a)-1 10a Coordinate with FWS regarding measures to protect, mitigate damages, and enha

Interior-21 10(a)-2 10a Take appropriate actions to protect fish and wildlife in emergencies or under spec

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Entity ID 

Recommendation Type Description of Measure 

Interior-22 10(a)-3 10a Pass BOR flow augmentation water releases that reach Brownlee reservoir prior tInterior-23 10(a)-4 10a Submit a plan for application of pesticides on project or adjacent non-Project land

Interior-24 10(a)-5 10a Develop an Interpretation and Education plan. Interior-25 10(a)-6 10a Develop a Visual Resource Management Plan for project facilities. Interior-26 10(a)-7 10a Manage reservoir levels to minimize impacts on recreation resources during MayInterior-27 10(a)-8 10a Conduct a recreation user study at Weiser Sand Dunes and implement and partial

Interior-28 10(a)-9 10a Plan and implement an upgrade of facilities at Heller Bar and develop the Heller Interior-29 10(a)-10 10a Develop and implement a Recreation Land Acquisition and Management ProgramInterior-30 10(a)-11 10a Modify the Project boundary to include the Airstrip, Steck Park, Swedes LandingInterior-31 10(a)-12 10a Establish and convene a Recreation/Aesthetics Resource Work Group. 

Interior-32a 10(a)-13 10a Develop a revised warmwater recreational fisheries plan. 

Interior-32b 10(a)-13 10a Assess access to launch boats; satisfy reservoir-level requirements of Baker Coun

Interior-33 10(a)-14 10a Develop a process and schedule for acquiring 14.6 miles of tributary habitat. Interior-34 10(a)-15 10a Develop and implement a TES Species Management Plan for BLM-administered Interior-35 10(a)-16 10a Fund development and implementation of a Habitat Mitigation and Management Interior-36 10(a)-17 10a Evaluate, protect or mitigate any scientifically important paleontological discove

Interior-37a 10(j)-1.1 10j Develop and implement a plan to improve bull trout habitat conditions in Pine Cr

Interior-37b 10(j)-1.2 10j Operate and maintain a permanent weir structure at the mouth of Pine Creek 

Interior-37c 10(j)-1.3 10j Conduct population monitoring activities, including life history monitoring of bu

Interior-37d 10(j)-1.4 10j Determine whether brook trout limit the distribution, numbers, or reproduction of 

Interior-38a 10(j)-2.1 10j Develop and implement a plan to improve bull trout habitat conditions in Indian C

Interior-38b 10(j)-2.2 10j Operate and maintain a permanent weir structure at the mouth of Indian Creek 

Interior-38c 10(j)-2.3 10j Conduct population monitoring activities, including life history monitoring of bu

Interior-38d 10(j)-2.4 10j Determine whether brook trout limit the distribution, numbers, or reproduction of 

Interior-39a 10(j)-3.1 10j Develop and implement a plan to improve bull trout habitat in the Wildhorse Riv

Interior-39b 10(j)-3.2 10j Operate and maintain a permanent weir structure at the mouth of the Wildhorse R

Interior-39c 10(j)-3.4 10j Conduct population monitoring activities, including life history monitoring of bu

Interior-39d 10(j)-3.3 10j Determine whether brook trout limit bull trout in the Wildhorse River. 

Interior-40 10(j)-4.1 10j Conduct presence absence surveys for bull trout and evaluate habitat conditions w

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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Identifier Used 

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Recommending 

Entity ID 

Recommendation Type Description of Measure 

Interior-41 10(j)-5 10j Implement a program to provide bull trout access to anadromous fish as prey in PInterior-42 10(j)-6 10j Improve water quality in Oxbow and Hells Canyon reservoirs to meet water qualInterior-43 10(j)-7 10j Establish a conservation flow in the Oxbow bypass reach sufficient to meet requi

Interior-44 10(j)-8 10j Evaluate project effects on bull trout downstream of Hells Canyon dam. Interior-45 10(j)-9 10j Conduct activities to provide for the safe and effective passage of bull trout past H

Interior-46a 10(j)-10 10j Develop and implement a Fish Passage Plan related to the Hells Canyon fish trap 

Interior-46b 10(j)-10 10j Design, construct and operate improved adult collection facilities at Hells Canyon 

Interior-46c 10(j)-10 10j Design, construct, and monitor a weir facility at Eagle Creek. Interior-47a 10(j)-11.a 10j Evaluate habitat upstream of the project for the reintroduction of naturally spawn

Interior-47b 10(j)-11.b 10j Develop and refine plans to provide downstream passage of fall Chinook salmon 

Interior-48 10(j)-12 10j Develop a final set of hatchery production goals. Interior-49 10(j)-13 10j Provide put-and-take fisheries in selected rivers. 

Interior-50a 10(j)-15.1 10j Implement water quality improvement measures elsewhere in the basin to aid in s

Interior-50b 10(j)-14.4 10j Determine which Idaho Power facilities need to have their trashracks replaced to 

Interior-50c 10(j)-14.5 10j Study the conservation benefits of a seasonal ROR operation at various projects t

Interior-51 10(j)-15 10j Implement the white sturgeon conservation measures proposed in the Final LicenInterior-52 10(j)-16 10j Complete and implement a Final White Sturgeon Conservation and Action Plan. Interior-53 10(j)-17 10j Develop and implement a White Sturgeon Conservation Aquaculture Plan. Interior-54 10(j)-18 10j Implement seasonal run-of-river operations downstream of Hells Canyon dam for Interior-55 10(j)-19 10j Install protective trash racks at CJ Strike and Bliss dams for the conservation and Interior-56 10(j)-20 10j Complete and implement a Pacific Lamprey Management Plan. Interior-57 10(j)-21 10j Determine structural measures needed to mitigate for project effects to Pacific lamInterior-58 10(j)-22 10j Develop and implement a Native Fish Management Plan for native resident and aInterior-59 10(j)-23 10j Implement a schedule to correct fish passage barriers at road crossings and culverInterior-60 10(j)-24 10j Complete a stock assessment of anadromous and resident fish populations. Interior-61 10(j)-25 10j Install a turbine-venting system at the Brownlee development and the units at He

Interior-62a 10(j)-26 10j Install flow deflectors on Hells Canyon and Brownlee dam spillways. 

Interior-62b 10(j)-26 10j Work with IDEQ and ODEQ to design an effectiveness monitoring plan for the f

Interior-63 10(j)-27 10j Provide flows and oxygen supplementation to maintain water quality parameters 

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Identifier Used 

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Recommending 

Entity ID 

Recommendation Type Description of Measure 

Interior-64 10(j)-28 10j Comply with the terms set forth by IDEQ and ODEQ for water quality certificatiInterior-65 10(j)-29 10j Take river flow and stage measurements within one mile below Hells Canyon dam Interior-66 10(j)-30 10j Monitor modified operations to determine effects on aquatic species downstream 

Interior-67 10(j)-31 10j Monitor water quality below Hells Canyon dam at numerous locations at a minimInterior-68 10(j)-32 10j Monitor selected beaches, cobble bars, gravel bars, and sand bars to determine raInterior-69 10(j).33 10j Monitor quantity and quality of gravel material in the Snake River below Hells CInterior-70 10(j)-34 10j Monitor benthic macroinvertebrates to assess changes in the composition of benth

Interior-71 10(j)-35 10j Conduct biannual monitoring of benthic macrophytes and algae, emphasizing perInterior-72 10(j)-36 10j Conduct zonal distribution surveys and monitoring of keystone and sensitive benInterior-73 10(j)-37 10j Monitor known colonies of the Hells Canyon rapids snail and the short-faced lim

Interior-74 10(j)-38 10j Establish several experimental populations of Hells Canyon rapids snail and/or thInterior-75 10(j)-39 10j Establish several experimental populations of the western ridged mussel below HInterior-76 10(j)-40 10j Develop a strategy for terrestrial habitat mitigation to mitigate for loss and degradInterior-77 10(j)-41 10j Develop and implement an Integrated Weed Management Plan incorporated into Interior-78 10(j)-42 10j Develop and implement a Sensitive Plant Species Management Plan. Interior-79 10(j)-43 10j Develop and implement the Hells Canyon Resource Management Plan, IWHP, anInterior-80 10(j)-44 10j Develop and implement a mountain quail management plan. Interior-81 10(j)-45 10j Develop and implement a Bald Eagle Management Plan Interior-82 10(j)-46 10j Implement measures to protect Townsend’s big-eared bats Interior-83 10(j)-47 10j Develop and implement a Southern Idaho Ground Squirrel Management Plan. Interior-84 10(j)-48 10j Implement a Northern Idaho Ground Squirrel Management Plan. Interior-85 10(j)-49 10j Implement measures to protect amphibians and reptiles Interior-86 none Sec18 Reserve authority for Interior to prescribe the construction, operation, and mainteInterior-87 1.1 Sec18 Continue the trap and haul fishways and monitor permanent weirs and trap and hInterior-87 1.2 Sec 18 Develop and implement a Bull Trout Passage Plan. 

ISHS-1 None 10a Revise the historic properties management plan. 

ISHS-2 None 10a Ensure cost estimated for monitoring cultural sites below Hells Canyon dam is suISHS-3 None 10a Finalize list of sites to be stabilized below Hells Canyon dam. 

ISHS-4 None 10a Establish a fund to support archaeological testing to determine most effective me

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
A-12 

Identifier Used 

in the EIS 

Recommending 

Entity ID 

Recommendation Type Description of Measure 

ISHS-5 None 10a Establish a program to survey the reach of the Snake River between the Salmon aISHS-6 None 10a Update and revise the NRHP nomination for the Hells Canyon Archaeological D

ISHS-7 None 10a Establish an on-going Cultural Resource Work Group. 

ISHS-8 None 10a Provide funding for analyses of existing but unreported archaeological collection

LVE-1 A comment Compensate Wyoming and the Wyoming residents for the use of Wyoming's unuLVE-2 B comment Apportion some of the benefits of project power production to others in the regio

NMFS-1 XII.1 10j Provide stable flows between 8,500 and 13,500 cfs throughout fall Chinook spaw

NMFS-2 XII.2 10j Provide stable flows throughout the fall Chinook incubation period. NMFS-3 XII.3 10j Monitor the construction of fall Chinook salmon redds between Lower Granite reNMFS-4 XII.4 10j Release flows sufficient to reduce the incidence of juvenile entrapment. NMFS-5 XII.5 10j Conduct a juvenile entrapment and stranding study. NMFS-6 XII.6 10j Study fall Chinook salmon spawning gravel between Hells Canyon dam and the SNMFS-7 XII.7 10j Evaluate fall Chinook salmon egg-to-fry survival downstream of Hells Canyon dNMFS-8 XII.8 10j Refill Brownlee reservoir necessary to meet Corps flood control requirements an

NMFS-9 XII.9 10j Release 237 kaf of stored water from Brownlee reservoir between June 21 and Ju

NMFS-10 XII.10 10j Design and construct a gas abatement structure at the Hells Canyon dam spillway NMFS-11 XII.11 10j Design and construct a gas abatement structure at the Brownlee dam spillway NMFS-12 XII.12 10j Increase dissolved oxygen levels in outflows of the Hells Canyon developments d

NMFS-13 XII.13 10j Continue funding operation of its Rapid River, Pahsimeroi, Niagara Springs, and 

NMFS-14a XII.14 10j Fund water quality improvement projects in the Snake River Basin upstream of H

NMFS-14b XII.14.d 10j Monitor water quality upstream of the project and below Brownlee and Hells Can

NMFS-14c XII.14.e 10j Evaluate fall Chinook salmon egg-to-fry survival downstream of Bliss, C.J. Strik

NMFS-15 XII.15 10j Measure flows and ramping rates within 1 mile downstream of Hells Canyon damNMFS-16 XII.16 10j Conduct passage and reintroduction studies of fall Chinook salmon upstream of tNMFS-17 XII.17 10j Conduct passage and reintroduction studies of spring/summer Chinook salmon an

NMFS-18 XIII.1 10a Provide shifts in flood control from Brownlee reservoir to Grand Coulee reservoiNMFS-19 XIII.2 10a Share excess adult spring Chinook salmon or steelhead hatchery returns with the NMFS-20 XIII.3 10a Design and construct an anadromous fish interpretive display near Brownlee damNMFS-21 X 10a Include a general reservation of authority for NMFS to prescribe fishways. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
A-13 

Identifier Used 

in the EIS 

Recommending 

Entity ID 

Recommendation Type Description of Measure 

NMFS-22 XI 10a Include a specific ESA reopener provision. 

NPPVA-1 none comment Continue flows of 8,500 cfs above the Salmon River-Snake River confluence and 

NPT-1 II.1 10a Continue Idaho Power's fall Chinook spawning program which includes providinNPT-2 II.2 10a Provide passage of water released from USBR reservoirs and natural flow rights 

NPT-3 II.3 10a Limit ramping rate to 2 inches per hour from April through May to protect rearinNPT-4 II.4 10a Limit ramp rates to 2 in/hour if Lower Granite flows fall below 30,000 cfs during 

NPT-5 II.5 10a Maintain Brownlee reservoir at its upper flood control rule elevation from Feb 28 NPT-6 II.6 10a Consider shifting flood control requirements from Brownlee reservoir to Lake Ro

NPT-7 II.7 10a Draft and refill Brownlee reservoir by a timetable for summer flow augmentation 

NPT-8a II.8 10a Fund implementation of the Snake River-Hells Canyon TMDL in lieu of providin

NPT-8b II.8 10a Evaluate egg to fry survival of fall Chinook. 

NPT-8c II.8 10a Fund studies for salmon and steelhead collection in the Payette and Weiser rivers 

NPT-9 II.9 10a Coordinate Snake River fall Chinook artificial production through U.S vs. Orego

NPT-10 II.10 10a Develop a management agreement for Rapid River spring Chinook production. NPT-11 II.11 10a Develop a management agreement for Pahsimeroi summer Chinook production. 

NPT-12 II.12 10a Develop a management agreement for steelhead production from Niagara SpringNPT-13 II.13 10a Investigate installation of a temperature control structure at Brownlee reservoir 

NPT-14 II.14 10a Maintain a minimum flow no higher than 6,500 cfs below Hells Canyon dam and NPT-15 II.15 10a Construct structures on Hells Canyon and Brownlee dams and develop a plan to aNPT-16 II.16 10a Construct structures on Hells Canyon dam to add DO along with injecting oxygen NPT-17 II.17 10a Develop and implement a plan to prevent the discharge of point source pollutants NPT-18 II.18 10a Implement White Sturgeon conservation Plan. NPT-19 II.19 10a Investigate the status of and project effects on the Pacific lamprey population in tNPT-20 II.20 10a Monitor the movement of sand, silt and gravel from above, through and below thNPT-21 II.21 10a Restore sandbars to their pre-project number and size. 

NPT-22 II.22 10a Acquire lands to mitigate for impacts on wildlife habitat caused by the filling of tNPT-23 II.23 10a Hold lands purchased as open and unclaimed lands that will be open to the Tribe'

NPT-24 II.24 10a Provide a fund to purchase replacement fishing grounds for the Nez Perce Tribe i

NPT-25 II.25 10a Conduct and fund additional oral history studies of Nez Perce sites. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
A-14 

Identifier Used 

in the EIS 

Recommending 

Entity ID 

Recommendation Type Description of Measure 

NPT-26 II.26 10a Finalize the Historic Properties Management Plan. NPT-27 II.27 10a Update the Hells Canyon National Register District Nomination. 

NPT-28 II.28 10a Monitor all historic properties that may be affected by the project with increased 

NPT-29 II.29 10a Increase the number of sites and funding of site treatment/mitigation/stabilizationNPT-30 II.30 10a Extend the Area of Potential Effects downstream from Salmon River confluence 

NPT-31 II.31 10a Provide the $1,000,000 FLA funds in a lump sum at the beginning of the license. 

NPT-32 II.32 10a Establish a cultural resources advisory committee. 

NPT-33 II.33 10a Seek to employ qualified Nez Perce Tribal members in all contracts and work per

NPT-34 II.A 10a Manage emergency situations that may cause harm or mortality to fish and wildli

NPT-35 II.B 10a Include FERC's standard reopener to reopen the license to protect and enhance fi

NPT-36 II.C 10a Remove or modify Project facilities and restore pre-Project conditions upon proje

NPT-37 II.D 10a Issue the license for a term of no longer than 30 years. 

ODFW-1 10(j)-1 10j Establish and convene a Hells Canyon Project Coordinating Committee upon liceODFW-2 10(j)-2 10j Implement a long-term program to establish sustainable anadromous fish runs abODFW-3 10(j)-3 10j Develop and implement a Fish Passage Plan for native migratory resident and anODFW-4 10(j)-4 10j Establish a Fish Passage and Reintroduction Committee. ODFW-5 10(j)-5 10j Consult with ODFW in development of fishway and trap designs. ODFW-6 10(j)-6 10j Implement an evaluation plan for the construction and modification of the Hells CODFW-7 10(j)-7 10j Maintain all fishways and traps in proper order. ODFW-8 10(j)-8 10j Develop a fishway and trap operation and maintenance plan. ODFW-9 10(j)-9 10j Provide ODFW access to the Hells Canyon Project site and project records to ins

ODFW-10 10(j)-10 10j Modify and improve the existing Hells Canyon dam fish trap within 2 years. ODFW-11 10(j)-11 10j Design and construct a fish ladder and trap at Oxbow dam within 10 years. ODFW-12 10(j)-12 10j Develop, install and maintain a downstream fish passage and collection facility aODFW-13 10(j)-13 10j Design and implement a study of fish predators in Hells Canyon reservoir ODFW-14 10(j)-14 10j Provide for passage of spring Chinook salmon and summer steelhead into Pine CODFW-15 10(j)-15 10j Study production potential, migration behavior, and survival of steelhead and sprODFW-16 10(j)-16 10j Study production potential, etc. for fall Chinook salmon in the Swan Falls to Bro

ODFW-17 10(j)-17 10j Develop a detailed upstream and downstream Passage Plan for Pacific Lamprey. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
A-15 

Identifier Used 

in the EIS 

Recommending 

Entity ID 

Recommendation Type Description of Measure 

ODFW-18 10(j)-18 10j Develop and implement a fish passage plan for bull trout and/or redband trout. ODFW-19 10(j)-19 10j Develop and implement a fish passage plan for white sturgeon if this is determineODFW-20 10(j)-20 10j Implement measures to address limiting factors if passage and reintroduction effoODFW-21 10(j)-21 10j Monitor health of upstream and downstream Snake River fish populations. ODFW-22 10(j)-22 10j Evaluate anadromous and resident fish populations to pass for reintroduction. ODFW-23 10(j)-23 10j Develop and implement a Fish Habitat Protection, Mitigation and Enhancement PODFW-24 10(j)-24 10j Evaluate the effects of reintroducing anadromous fish on resident fish populationODFW-25 10(j)-25 10j Implement a monitoring and evaluation program for all four of Idaho Power's mitODFW-26 10(j)-26 10j Develop a Hatchery Production Plan ODFW-27 10(j)-27 10j Investigate and supply alternative fisheries in Oregon ODFW-28 10(j)-28 10j Expand Oxbow Hatchery for fall Chinook salmon broodstock collection, spawninODFW-29 10(j)-29 10j Upgrade Oxbow Hatchery facilities ODFW-30 10(j)-30 10j Continue hatchery operations at Oxbow, Rapid River, Pahsimeroi, and Niagara SODFW-31 10(j)-31 10j Implement project operations to meet specified objectives 

ODFW-32 10(j)-32 10j Cooperate with BOR in providing flow augmentation. ODFW-33 10(j)-33 10j Implement ramping rates and minimum flows as described. ODFW-34 10(j)-34 10j Implement a Fall Chinook Salmon Spawning and Incubation Protection ProgramODFW-35 10(j)-35 10j Fund and participate in annual spawning surveys for fall Chinook salmon downst

ODFW-36a 10(j)-36 10j Develop, fund and implement a Native Salmonid Plan. 

ODFW-36b 10(j)-36-i 10j Investigate turbine and spill related mortality. 

ODFW-37 10(j)-37 10j Evaluate turbine- and spill-related mortality of native salmonids (entrainment stuODFW-38 10(j)-38 10j Fund habitat measures in tributaries containing redband trout and bull trout within 

ODFW-39 10(j)-39 10j Investigate, fund and implement nutrient supplementation in all tributaries to the ODFW-40 10(j)-40 10j Install and operate a permanent monitoring and collection weir at the mouth of PiODFW-41 10(j)-41 10j Conduct presence/absence surveys for bull trout in major tributaries associated wODFW-42 10(j)-42 10j Update and implement measures identified in the White Sturgeon Conservation PODFW-43 10(j)-43 10j Evaluate potential impacts to white sturgeon from the bioaccumulation of contamODFW-44 10(j)-44 10j Fund measures to improve water quality and sturgeon habitat within and upstream ODFW-45 10(j)-45 10j Conduct white sturgeon stock assessments. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
A-16 

Identifier Used 

in the EIS 

Recommending 

Entity ID 

Recommendation Type Description of Measure 

ODFW-46 10(j)-46 10j Assess factors limiting sturgeon survival through their incubation and larval life sODFW-47 10(j)-47 10j Investigate opportunities for sturgeon translocation to increase production in the ODFW-48 10(j)-48 10j Monitor the genotypic frequencies of Snake River white sturgeon between Swan ODFW-49 10(j)-49 10j Develop, fund and implement Pacific lamprey habitat enhancement measures. ODFW-50 10(j)-50 10j Monitor warmwater fish populations and conduct annual creel surveys in all three ODFW-51 10(j)-51 10j Maintain Brownlee reservoir at specified levels with a target refill date of June 30ODFW-52 10(j)-52 10j Conduct studies of food habits of Brownlee reservoir warmwater fish species. ODFW-53 10(j)-53 10j Implement a Gravel Monitoring Program to assess spawning gravel for fall ChinoODFW-54 10(j)-54 10j Develop and implement a plan to meet the TDG allocation for the project. ODFW-55 10(j)-55 10j Ensure that the project does not contribute to violation of Oregon’s DO standard ODFW-56 10(j)-56 10j Develop and implement a temperature management plan. ODFW-57 10(j)-57 10j Conduct a study to determine mercury, Dieldrin, and DDT/DDE levels in BrownODFW-58 10(j)-58 10j Implement water quality monitoring measures. ODFW-59 10(j)-59 10j Develop and implement a Terrestrial Resources Management and Mitigation PlanODFW-60 10(j)-60 10j Establish a Terrestrial Resource Work Group. ODFW-61 10(j)-61 10j Fund development and implementation of a Land Acquisition and Management PODFW-62 10(j)-62 10j Establish a fund to maintain habitat values on Patch, Porter, Huffman and Gold isODFW-63 10(j)-63 10j Fund and participate in cooperative mountain quail reintroduction program. ODFW-64 10(j)-64 10j Develop a Bald Eagle Management Strategy (monitor, fund, complete surveys). ODFW-65 10(j)-65 10j Develop a Sensitive Species Management Plan. ODFW-66 10(j)-66 10j Develop an Integrated Weed Management Plan and establish a Noxious Weed AdODFW-67 10(j)-67 10j Develop and implement an integrated Transmission Line Operation and MaintenaODFW-68 10(j)-68 10j Prepare and implement a riparian and riverine vegetation management plan along ODFW-69 10(j)-69 10j Monitor for bird electrocution mortalities along transmission lines. ODFW-70 10(j)-70 10j Minimize risks of bird collisions with transmission lines. ODFW-71 10(j)-71 10j Study the effects of harsh winters on mule deer. ODFW-72 10(j)-72 10j Avoid road O&M activities on crucial winter range during winter months (road cODFW-73 10(j)-73 10j Develop and implement a public Information and Education program regarding hODFW-74 10(j)-74 10j Prevent further loss of fish and wildlife if project operations suddenly cause detri

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
A-17 

Identifier Used 

in the EIS 

Recommending 

Entity ID 

Recommendation Type Description of Measure 

ODFW-75 1 10a Implement a Recreation Adaptive Management Plan and form a Recreation StakeODFW-76 2 10a Develop a road management plan. 

ODFW-77 3 10a Continue, fund and enhance the Litter and Sanitation Plan. 

ODFW-78 4 10a Develop and implement an Information and Education Plan. 

ODFW-79 5 10a Consult with state and federal agencies regarding proposed changes to Hells CanyODFW-80 6 10a Develop site plans for Westfall; Bob Creek Section A, B and C; and Airstrip A&ODFW-81 7 10a Develop site plans for Copperfield, Oxbow Launch, Carters/Old Carters Landing

ODFW-82 8 10a Develop and implement a site plan for enhancement of Hewitt and Holcomb Park

ODFW-83 9 10a Develop a low-water boat launch on the Oregon side of Brownlee reservoir at or 

ODFW-84 10 10a Improve access to the Stud Creek Trail. ODFW-85 11 10a Fund law enforcement officers for project lands and waterways and form a Safety ODFW-86 12 10a Remove or modify Project facilities and restore pre-Project conditions upon proje

ODSL-1 none comment Obtain a lease from ODSL to occupy the state-owned submerged and submersiblODSL-2 none comment Obtain authorization from ODSL for project facilities or structures located on sta

OPRD-1 1 10a Apply a bank stabilization treatment to Farewell Bend State Park. OPRD-2 2 10a Develop and fund a maintenance plan to address sediment buildup at Farewell Be

OPRD-3 3 10a Implement a maintenance operation to remove sediment build-up at Farewell BenOPRD-4 1 10a Form a Recreation Stakeholder Group. OPRD-5 2 10a Fund, develop and implement a Recreation Adaptive Management Plan. OPRD-6 3 10a Develop and implement a Comprehensive Recreation Plan with the Recreation StOPRD-7 4 10a Implement the Comprehensive Recreation Plan. OPRD-8 5 10a Fund construction, O&M and monitoring efforts found within the Comprehensive OPRD-9 1 10a Increase and improve low water access to project reservoirs. 

OPRD-10 2 10a Install moorages for recreational watercraft. 

OPRD-11 3 10a Include moorages for shore access and composting toilets in site development. 

OSHPO No measures in this letter. 

OSMB-1 1 10a Provide salaries and expenses for two full-time seasonal Baker County marine deOSMB-2 2 10a Provide an effective marine enforcement and safety presence on the Snake River 

OSMB-3 3 10a Facilitate biannual law enforcement proceedings. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
A-18 

Identifier Used 

in the EIS 

Recommending 

Entity ID 

Recommendation Type Description of Measure 

OSMB-4 4 10a Implement a Recreation Adaptive Management Plan in consultation with a RecreOSMB-5 5 10a Include human waste disposal in litter and sanitation planning. OSMB-6 6 10a Incorporate education and outreach materials to prevent the introduction or sprea

OWRD No measures in this letter. 

SBT-1a 1 10a Develop and implement a water quality improvement program to improve habitat 

SBT-1b 1 10a Implement anadromous fish passage; but not until protection from the ESA is sec

SBT-2 2 10a Arrange for the construction maintenance and operation of two hatcheries in the YSBT-3 3A, 3B 10a Develop a cultural resources center and a HPMP for all cultural sites on lands nea

SBT-4 4 10a Consult on a government-to-government basis on all issues that may affect Triba

SPT-1 A.1 10a Conduct studies to examine project effects on the diet and health of tribal membeSPT-2 A.2 10a Place adult Chinook and steelhead in the Owyhee River where it flows through th

SPT-3 A.3 10a Reintroduce Chinook and steelhead into the Owyhee, Bruneau, and Snake rivers 

SPT-4 A.4 10a Convene an Aquatic Resource Task Force 

SPT-5 TR.1 10a Acquire lands to benefit the Tribes and their fish, wildlife and botanical resources

SPT-6 TR.2 10a Convene a Terrestrial Resource Task Force. SPT-7 TR.3 10a Utilize standardized Habitat Evaluation Procedures to determine suitable habitat u

SPT-8 TR.4 10a Fund the development and implementation of Wildlife Management Strategies. SPT-9 C.1 10a Undertake a multi-year ethnographic research project with specified objectives. 

SPT-10 C.2 10a Establish and fund a Cultural Center upstream of the Hells Canyon Complex. 

SPT-11 C.3 10a Include in the APE all lands to the confluence of the Snake and Salmon Rivers upSPT-12 C.4 10a Fund the Tribes' participation in and establish a Cultural Resources Task Force. 

SPT-13 C.5 10a Develop procedures for draw downs and other maintenance requirements to prote

SPT-14 C.6 10a Provide law enforcement to protect cultural resources. 

SPT-15 D 10a Allocate $10,000,000 to the Tribes for Native American Programs. 

SPT-16 E 10a Complete studies to examine environmental and human health risks from the proj

SPT-17 F 10a Comply with federal laws dealing with tribal sovereignty, religious freedom, and 

Note: AR/IRU – American Rivers-Idaho Rivers United 

 BPT – Burns Paiute Tribe  Corps – U.S. Army Corps of Engineers  CTUIR – Confederated Tribes of the Umatilla Indian Reservation 

 FS – Forest Service 

 IDPR – Idaho Department of Parks and R Interior – Department of the Interior  ISHS – Idaho State Historical Society  LVE – Lower Valley Energy  NMFS – National Marine Fisheries Serv

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
A-19 

 NPPVA – Northwest Professional Passenger Vessel Association  NPT – Nez Perce Tribe  ODFW – Oregon Department of Fish and Wildlife  ODSL – Oregon Department of State Lands  OPRD – Oregon Parks and Recreation Department  OSHPO – Oregon State Historic Preservation Office  OSMB – Oregon State Marine Board  OWRD – Oregon Water Resources Department  SBT – Shoshone-Bannock Tribes  SPT – Shoshone-Paiute Tribes 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
A-20 

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Document Accession #: 20070831-4002 Filed Date: 08/31/2007
APPENDIX B 

COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT 

FOR THE 

HELLS CANYON PROJECT 

PROJECT NO. 1171-079 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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Document Accession #: 20070831-4002 Filed Date: 08/31/2007
B-iii 

TABLE OF CONTENTS 

B1. PROCEDURAL AND GENERAL.................................................................................................. 5 

B2. EXECUTIVE SUMMARY ........................................................................................................... 10 

B3. PURPOSE OF ACTION AND NEED FOR POWER................................................................... 11 

B4. PROPOSED ACTION AND ALTERNATIVES .......................................................................... 11 

B5. CUMULATIVE EFFECTS ........................................................................................................... 18 

B6. WATER QUANTITY.................................................................................................................... 24 

B7. SEDIMENT SUPPLY AND TRANSPORT.................................................................................. 37 

B8. WATER QUALITY....................................................................................................................... 46 

B9. AQUATIC RESOURCES ............................................................................................................. 72 

B10. TERRESTRIAL RESOURCES................................................................................................... 121 

B11. THREATENED AND ENDANGERED SPECIES..................................................................... 136 

B12. CULTURAL RESOURCES ........................................................................................................ 142 

B13. RECREATION RESOURCES .................................................................................................... 157 

B14. AESTHETICS ............................................................................................................................. 167 

B15. LAND MANAGEMENT AND USE .......................................................................................... 169 

B16. SOCIOECONOMICS.................................................................................................................. 173 

B17. OVERSIGHT AND ADAPTIVE MANAGEMENT .................................................................. 178 

B18. DEVELOPMENTAL ANALYSIS.............................................................................................. 178 

B19. CONSISTENCY WITH COMPREHENSIVE PLANS .............................................................. 183 

B20. RELATIONSHIP OF LICENSE PROCESS TO LAWS AND POLICIES ................................ 183 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
B-1 

COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT 

FOR THE 

HELLS CANYON PROJECT 

PROJECT NO. 1171-079 

The U.S. Environmental Protection Agency’s (EPA) notice of availability of the draft 

environmental impact statement (EIS) was issued on August 7, 2006. Comments on the draft EIS were 

initially due on October 3, 2006, but the Commission later amended the due date to November 3, 2006. 

In addition, the Commission staff conducted five public meetings in Boise, Idaho (September 7 and 8, 

2006); Halfway, Oregon (September 11, 2006); Weiser, Idaho (September 12, 2006); and Lewiston, Idaho 

(September 13, 2006). Commission staff also held tribal consultation meetings with the Nez Perce Tribal 

Council and Nez Perce Tribe (Lapwai, Idaho; March 6, 2007), the Umatilla Tribes and CRITFC 

(Pendleton, Oregon; March 7, 2007), the Shoshone-Bannock Tribes (Fort Hall, Idaho; March 5, 2007), 

the Burns Paiute Tribe (Boise, Idaho; March 29, 2007), and the Shoshone-Paiute Tribes (Owyhee, 

Nevada; March 30, 2007). In this appendix, we summarize the written and oral comments received; 

provide responses to those comments; and indicate, where appropriate, how we 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 Entitya

 Filing Date 

Oregon Parks and Recreation Department September 7, 2006 

Brett Crow September 8, 2006 

Jason Jedry September 13, 2006 

Bill and Patty Davis September 13, 2006 

Michael Gerhard September 13, 2006 

Fred Larson September 13, 2006 

Lloyd Herbst September 13, 2006 

Bert and Janine Wollerman September 14, 2006 

John and Kerry Giardinelli, and Brian and Angie Thomas September 19, 2006 

Dale Litzenberger September 19, 2006 

Barry Dow September 19, 2006 

Paul Poorman September 19, 2006 

Nick Bradshaw September 19, 2006 

Paul Petersen September 19, 2006 

Northwest Watershed Institute September 19, 2006 

Michael Hryebewicz September 20, 2006 

State of Oregon September 21, 2006 

North Central Idaho Travel Association September 21, 2006 

Lewiston and Clarkston Chambers of Commerce September 21, 2006 

Jason Wallace September 21, 2006 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
B-2 

Commenting Entitya

 Filing Date 

White Bird and Riggins Chambers of Commerce September 21, 2006 

Alonzo Coby, for Shoshone-Bannock Tribes September 21, 2006 

Charles McKetta September 21, 2006 

Nancy Gover September 21, 2006 

Grangeville Chamber of Commerce September 21, 2006 

P.B. Rogers September 26, 2006 

Beverly Ferrell September 27, 2006 

Fred Mensik September 27, 2006 

Joshua Hough September 29, 2006 

Blaine R. Case September 29, 2006 

Justin Walsh September 29, 2006 

Tamra Dickinson October 3, 2006 

Western Whitewater Association October 3, 2006 

October 23, 2006 

Robin Stedfeld (representing 25 others) October 5, 2006 

Richard C. Wilson October 5, 2006 

Toddy Perryman October 5, 2006 

Laura Todd October 6, 2006 

Susan K. Chaloupka October 6, 2006 

H.L. Fitchett October 7, 2006 

U.S. Department of Agriculture, Forest Service October 10, 2006 

November 2, 2006 

Pioneer Irrigation District, Settlers Irrigation District, Payette River Water 

Users Association October 11, 2006 

Reed Burkholder October 12, 2006 

Peter Dietrich October 13,2006 

Matt Leidelker October 13, 2006 

Alan Kofoed October 13, 2006 

Sara Lee October 13, 2006 

Glen H. Petry October 13, 2006 

Rick Eichstardt October 13, 2006 

Idaho Power Company November 3, 2006 

Conservation Northwest October 18, 2006 

Karri Harpole October 23, 2006 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
B-3 

Commenting Entitya

 Filing Date 

David V. Vaneck October 23, 2006 

James M. Tamarelli October 26, 2006 

Ronald J. Krishnel October 27, 2006 

Jeffrey Wilhelm October 30, 2006 

Holiday Expeditions October 31, 2006 

Northwest Professional Power Vessel Association October 31, 2006 

Yvonne Prinslow October 31, 2006 

Hydropower Reform Coalition (245 comments attached from individuals) November 1, 2006 

Idaho Historical Society November 1, 2006 

W.B. Childress November 1, 2006 

Idaho Department of Fish and Game November 2, 2006 

U.S. Department of Agriculture, Forest Service, Pacific Northwest Region 

(Region 6) November 2, 2006 

William S. Parsons November 2, 2006 

U.S. Forest Service November 2, 2006 

Burns Paiute Tribe November 3, 2006 

ROW Inc. November 3, 2006 

Shoshone-Paiute Tribes November 3, 2006 

Idaho Rivers United and America Rivers November 3, 2006 

National Oceanic and Atmospheric Administration, National Marine Fisheries 

Service November 3, 2006 

U.S. Department of the Interior November 3, 2006 

American Whitewater November 3, 2006 

Idaho Water Users Association and Committee of Nine November 3, 2006 

Idaho Farm Bureau Federation November 3, 2006 

State of Idaho November 3, 2006 

Confederated Tribes of the Umatilla November 3, 2006 

Nampa and Meridian Irrigation District November 3, 2006 

State of Oregon, Water Resources Department, Hydroelectric Application 

Review Team November 3, 2006 

U.S. Army Corps of Engineers November 6, 2006 

Nez Perce Tribe November 6, 2006 

Shoshone-Bannock Tribes November 6, 2006 

November 24, 2006 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
B-4 

Commenting Entitya

 Filing Date 

Northwest River Runners November 6, 2006 

U.S. Environmental Protection Agency, Region 10 November 6, 2006 

J.R. Simplot Company November 6, 2006 

Bear Paw Expeditions November 6, 2006 

Citizens’ Utility Board of Oregon November 6, 2006 

Sego Jackson November 7, 2006 

Patricia A. Barclay, Idaho Council on Industry and Environment November 9, 2006 

Robert Stanuers November 9, 2006 

Margaret Wright November 13, 2006 

C. Wright November 13, 2006 

Francine Redding November 13, 2006 

Daniel Cretser November 13, 2006 

Lisa and William Colsen November 13, 2006 

Carmen Dorsch November 13, 2006 

Robert Stanuers November 13, 2006 

Cynthia Graham November 13, 2006 

Jacob Judd November 13, 2006 

Juel Ruble November 13, 2006 

Mat Huray November 13, 2006 

Tanya Kutterer November 13, 2006 

J. Kirkendall November 13, 2006 

Mkan Deffries November 13, 2006 

Lisa Armstrong and Tom Boatner November 21, 2006 

Frank Jones November 24, 2006 

Harold C. Poxleitmer November 27, 2006 

John Marks January 10, 2007 

Marshallee Walters January 18, 2007 

a Comments without legible signatures are not listed. 

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B1. PROCEDURAL AND GENERAL 

Comment PG-1: About 300 individuals137 state that FERC should restore some balance to the Snake 

River by requiring Idaho Power to do the following under the new license: 

1. Immediately provide fish passage for spring Chinook and steelhead past all dams and into 

previously accessible tributaries, and provide fall Chinook passage once water quality is 

sufficiently restored. 

2. Meet all federal and state water quality standards for temperature, heavy metals, and other 

current or potential water quality impacts that are a result of the dams. 

3. Implement tighter ramping rate restrictions to prevent drastic changes in flow, and release 

water to provide maximum benefit for salmon and steelhead. 

4. Replenish sands and gravels to restore beaches for habitat and recreation. 

Additionally, the commenters indicate that FERC should assess the economic benefits of restoring natural 

salmon runs, beaches, and water quality to the region, including the effect of sport and commercial 

fishing on communities in Idaho, Oregon, and Washington. 

Response: The role of the Commission in a licensing proceeding is to decide whether to grant a license 

to an applicant and what conditions to impose on any license that would, in its view, “be best adapted to a 

comprehensive plan for improving or developing a waterway or waterways” as provided for by section 

10(a)(1) of the FPA. To inform the Commission’s decision, the staff evaluates all recommended 

measures and makes a recommendation to the Commission as to which measures should be included in 

any new license. The measures recommended by the commenters were all considered in the draft EIS, 

and the staff’s rationale for its recommendations is explained in the following sections: (1) section 5.2 

4.3 addresses anadromous fish restoration; (2) section 5.2 addresses water quality measures; (3) sections 

5.2.4.1 and 5.2.4.2 discuss ramping rates during fall Chinook salmon spawning and incubation periods 

and outside those periods, respectively; and (4) section 5.2.1 addresses sand and gravel replenishment. In 

the final EIS, we evaluated these same concepts again, considering new information submitted since the 

draft EIS. In some cases, we revised our recommendation, as described in the same sections of the final 

EIS. With respect to doing a full economic analysis of the economic benefits of restoring natural salmon 

runs, this is a task beyond the scope of the Hells Canyon Project EIS. 

Comment PG-2: The Umatilla Tribes state that in terms of previously identified issues, the draft EIS did 

not adequately address: (1) upper Snake River water pass-through; (2) drawdown; (3) socioeconomic and 

environmental analyses; (4) appropriate geographic scope; (5) cumulative effects analysis; and (6) 

cultural resources protection and mitigation. The Umatilla Tribes recommend preparation of a 

supplemental draft EIS to address and rectify these deficiencies. 

The Shoshone-Bannock Tribes state that FERC should prepare a supplemental draft EIS to address gaps 

in information essential for the public and decision makers to fully understand the relative effects of 

alternative proposals, and to address new information developed just prior to, and following, release of 

the draft EIS, including the Tribe’s submittal of the Keller-Beisner study, results of the EPAct process, 

results of the section 401 water quality certification process, and decisions with respect to alternative 

fishway prescriptions submitted by the tribes and other stakeholders. 

 

137 Some of the comments are verbatim copies, while others are restated by the commenters. All address 

the same points, as summarized here.

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Interior states that the draft EIS is inadequate and that a supplemental draft EIS must be prepared to 

rectify the lack of the following elements in the draft EIS: (1) an alternative that would result in the least 

biological, physical, cultural, and historical resource damage; (2) inclusion of outcomes from the EPAct 

process, including the revised terms and conditions resulting from the negotiated agreements between 

Idaho Power and Interior; (3) inclusion of a broader range of alternative operating scenarios, relying on 

the information provided by Idaho Power, Interior, and other agencies; (4) a description of methods and 

criteria used in analysis of financial feasibility of individual measures; (5) a description of how costs and 

benefits were assessed against overall economics of the project; (6) a detailed analysis of effects on 

additional native aquatic species, including redband trout, bull trout, white sturgeon, and mountain 

whitefish; and (7) inclusion and use of existing information and scientific work on operational impacts. 

Interior notes that if the Commission elects not to prepare a supplemental draft EIS, then the comments 

contained in Interior’s letter of November 3, 2006, should be addressed in the final EIS. 

Response: The draft EIS addresses the issues raised by the Umatilla Tribes in the following locations: 

(1) upper Snake River water pass-through and drawdown are addressed in section 3.6.2.1, Effects of 

Project Operations on Aquatic Resources; (2) socioeconomic and environmental analyses are addressed 

throughout section 3, Environmental Analysis; (3) the appropriate geographic scope of the project-specific 

analysis is defined in the relevant resource sections of section 3.0 and the geographic scope of the 

cumulative effects analysis is defined in section 3.2.1, Geographic Scope; (4) cumulative effects analysis 

is introduced in section 3.2, Cumulatively Affected Resources, and resource-specific cumulative effects 

are presented at the end of the appropriate resource sections in section 3.0; and (5) cultural resources 

protection and mitigation are discussed in section 3.9, Cultural Resources. 

The other two topics raised by the Umatilla Tribes, upper Snake water pass through and drawdown, were 

addressed in the course of our evaluation of operational alternatives. As we describe in section 3.3.2.2 of 

the draft EIS, the Umatilla Tribes’ operational recommendations were among about 40 such 

recommendations we received from resource agencies, tribes, and other interested parties in response to 

the Commission staff’s Ready for Environmental Analysis notice. To deal effectively with these 

numerous recommendations, we combined various recommendations into a set of nine operational 

scenarios and sub-scenarios upon which we relied in assessing effects of the various operational 

recommendations. Our Scenario 2, Flow Augmentation, is representative of the recommendations calling 

for the pass-through of upper Snake releases and for drawdown. We describe the effects of this scenario 

in the various resource sections of EIS section 3.0, Environmental Analysis. 

With respect to the topics raised by the Shoshone-Bannock Tribe, the final EIS includes analyses of the 

revised terms and conditions resulting from conclusion of the EPAct process and elements of Idaho 

Power’s proposal that have been revised to be consistent with its January 31, 2007, application for section 

401 water quality certification. We do not view any of this new information as rising to the level of 

requiring a supplemental draft EIS. Following its usual practice, the Commission will not issue a license 

order until the 401 water quality certification process is completed and after final fishway prescriptions 

have been issued, thus ensuring that the license will be consistent with all mandatory conditions. 

With respect to the topics raised by Interior, most of these points are addressed in later sections of this 

appendix. For example, specific comments about the range of alternatives are addressed in section B4, 

Proposed Action and Alternatives, and specific comments about the methods and criteria used in the 

financial analysis are addressed in section B18, Developmental Analysis. We do not include in the final 

EIS an alternative that would “result in the least biological, physical, cultural, and historical resource 

damage”, because such an alternative would be impossible to define. Any action with regard to 

relicensing the Hells Canyon Project would entail trade-offs among resources. Thus, we continue to 

evaluate the operational scenarios and environmental measures proposed or recommended by all parties, 

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and craft a Staff Alternative that in our view strikes an appropriate balance among developmental 

objectives and environmental protections. As described throughout this appendix, we considered the 

comments submitted by all parties concerning the draft EIS, and we revised the text of the EIS, our 

analysis, and our conclusions as appropriate. 

Comment PG-3: The Umatilla Tribes comment that the draft EIS does not address the impacts of 

observed climate change on weather or hydrologic patterns. They state that the draft EIS fails to consider 

the negative impacts (e.g., warming winter temperatures, less snow accumulation, and increased 

variability of the snowmelt patterns) from future climate change, which is expected to accelerate during 

the term of the new license. They also note that the University of Washington’s Climate Impacts Group 

has documented climate change impacts. The Umatilla Tribes state that new forecast tools, which Idaho 

Power may not be using, are now available to improve water management, and that even changes to flood 

control must be considered to mitigate the regional impacts of global warming. The tribes recommend 

preparation of a supplemental draft EIS to address and rectify this and other deficiencies. 

Response: Future climate change impacts on water resources are unknown, although some models may 

attempt to predict change in certain river basins. The Commission’s standard re-opener article would be 

included in any license as the vehicle for making changes to the license should a material change in 

conditions occur that results in unanticipated environmental impacts. 

With respect to flood control, the Corps has primary responsibility for flood control. We note that the 

Corps provides language in its January 26, 2006, comment letter that offers some flexibility to respond to 

changing conditions. Flood control at Brownlee is also tied to managing floods at locations much farther 

downstream on the Columbia River. Changes in Columbia River flood control management practices can 

be undertaken only on a regional scale and the Corps is best suited for taking the lead on such studies. 

Comment PG-4: The Nez Perce Tribe notes that the draft EIS attempts to do too many things, and is 

poorly organized. The Tribe also states that the effects of the Staff Alternative are not analyzed as a 

whole, and are confusing. AR/IRU note that the draft EIS does not provide clear, easy-to-read 

information; is repetitive; and scatters different aspects of a single issue throughout the document. 

AR/IRU state that FERC should reexamine its approach, and note further that the organization by 

category of resource issues results in partial or incomplete discussion. AR/IRU note that a better 

approach would be having an initial chapter organized by action alternative, which would provide a 

comprehensive narrative description of how each alternative would affect resources. AR/IRU provide an 

example of a recommended outline. 

Response: We understand that some parties do not care for the organization adopted by the Commission 

for its environmental documents. Nonetheless, we find this to be the best organization for presenting the 

staff’s analysis of the myriad, and sometimes conflicting, environmental measures submitted by the many 

parties in a relicensing proceeding, and we find that overall, the organization is workable for all parties. 

Comment PG-5: Interior states that comments received during the two NEPA scoping comment periods 

for the project should be incorporated into a summary table. 

Response: Summarizing all of the scoping comments is not necessary for compiling the EIS or ensuring 

that all comments have been addressed. We refer Interior to the two documents already on the record that 

address scoping comments: Scoping Document 1 issued October 20, 2003 (FERC, 2003), and Scoping 

Document 2 issued November 24, 2004 (FERC, 2004). 

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Comment PG-6: Interior states that the Commission does not have the authority to alter its mandatory 

conditions, and that the EIS and supporting analysis should contain Interior’s mandatory terms and 

conditions exactly as filed, without Commission revision. Interior states that including the agencies’ 

unaltered mandatory conditions would constitute a significant new circumstance that warrants the 

Commission preparing a Supplemental draft EIS. The Forest Service states that the Commission staff 

inappropriately modified or completely omitted several Forest Service 4(e) Terms and Conditions 

(Conditions) from its Preferred Alternative, including Conditions 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 12, 13, 16, 

18, 19, 20, 21, 22, 24, 25, and 26. The Forest Service comments that the Commission has no authority to 

modify or omit Forest Service Conditions, as recently affirmed by the United States Court of Appeals for 

the District of Columbia Circuit in City of Tacoma v FERC, No. 05-1054 (D.C. Cir. August 22, 2006). 

Similarly, NMFS questions the Commission’s authority to alter FWS’s mandatory section 18 fish passage 

prescriptions. The Forest Service states that the staff’s modification or omission provides a reduced level 

of resource protection that is not adequately justified, and that is inconsistent with the Commission’s 

broad resource protection obligations under the FPA. 

Response: Although a Commission license must include valid terms and conditions submitted pursuant 

to sections 4(e) and 18 of the FPA, Commission staff still has the responsibility in its environmental 

documents to make recommendations to the Commission that in its view would “be best adapted to a 

comprehensive plan for improving or developing a waterway or waterways” as provided for by section 

10(a)(1) of the FPA. Our recommendations reflect this consideration. All of the Interior and Forest 

Service preliminary terms and conditions were referenced in section 2.3.1.2, Section 4(e) Federal Land 

Management Conditions, and were fully described and analyzed in section 3 of the draft EIS. The final 

EIS includes an analysis of the modified terms and conditions submitted by the Forest Service and 

Interior in their comments on the draft EIS. As noted below in our responses to comments on specific 

conditions, we reconsidered our recommendations with respect to some Forest Service and Interior 

conditions. However, neither the modified conditions nor our revised recommendations rise to the level 

of new circumstances that would warrant preparation of a supplemental draft EIS. In the final EIS, we 

include in section 4.0, Developmental Analysis, the cost and net power benefits associated with an 

alternative that includes all of the agencies’ mandatory conditions and fishway prescriptions. 

Comment PG-7: The Forest Service recommends that Commission staff give deference to the mitigation 

measures agreed to in a settlement between Idaho Power and the Forest Service as a result of the hearing 

process conducted in accordance with section 241 of the Energy Policy Act of 2005 (EPAct) because the 

Commission has a long-standing policy to encourage settlements of licensing issues. The Forest Service 

notes that the Commission confirmed its support of settlement agreements in both a statement issued by 

the Commission’s Chairman as well as in a formal settlement policy. The Forest Service further notes 

that, in this case, the settlement results from a procedure Congress established to resolves these types of 

issues. The Forest Service states that accordingly, the Commission staff should afford at least as much, if 

not more, deference to settlements reached in the section 241 hearing process as it does for settlements in 

general. Idaho Power also comments that the Forest Service-modified 4(e) conditions should be included 

in the Staff Alternative because they represent agreements reached between the two parties. 

Response: The Commission has a policy to encourage settlements of licensing issues. However, 

Commission staff still has the responsibility in its environmental documents to evaluate each measure and 

make recommendations to the Commission concerning the environmental merits of the measure. 

Additionally, the staff considers the appropriateness of the measures for inclusion in a Commission 

license; settlement parties may reach agreements that are outside the Commission’s jurisdiction or 

contrary to Commission policy. Our recommendations reflect these considerations. In any event, these 

modified conditions will be included in any license issued.

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Comment PG-8: Interior states that the draft EIS lacks inclusion of outcomes of proceedings that have 

transpired over the past 6 months under the EPAct proceedings, including the revised terms and 

conditions that resulted from negotiated agreements between the applicant and Interior. Interior states 

that these should be incorporated into an action alternative, their effects should be analyzed, and an 

opportunity for public review and comment should be provided. 

Response: The draft EIS reflected all of the EPAct proceeding results that were filed with the 

Commission through June 2006, prior to release of the draft EIS in July 2006. We revised the final EIS to 

incorporate subsequent filings related to the EPAct process. These are listed in EIS section 2.3.1.3, 

Section 4(e) Federal Land Management Conditions, and discussed in the appropriate resource sections of 

section 3, Environmental Analysis. However, these measures alone do not constitute a complete 

operational alternative for the project, and we continue to evaluate the measures individually. 

Comment PG-9: Interior states that in section 5, Staff Alternative, the EIS should identify and explain all 

the similarities and overlaps between measures contained in the list. For example, Interior indicates that 

no. 12, concerning the acquisition of mitigation lands for wildlife habitat losses, may be redundant with 

no. 17, which discusses lands purchased for conservation of botanical resources. 

Response: The Staff Alternative, described in section 5, Staff Alternative, is based on Idaho Power’s 

license application and as such follows the numbering convention used by Idaho Power. We continue to 

find that this is the clearest way for parties to track Idaho Power’s proposal through staff’s analysis of the 

proposal and other recommendations to the Staff Alternative. It would defeat the purpose of this 

summary section to include all the details of the various measures, which are discussed in detail in the 

resource sections of section 3.0, Environmental Analysis. 

Comment PG-10: The Nez Perce Tribe states that FERC should consider impacts related to the project 

and coordination for potential mitigation measures for the Columbia River system as a whole. 

Response: Coordinating potential mitigation measures for the Columbia River basin as a whole is 

beyond the Commission’s scope in making a licensing decision for the Hells Canyon Project. However, 

in section 3.2, Cumulatively Affected Resources, we address project effects on some resources as they 

relate to basin-wide concerns.

Comment PG-11: The Forest Service states that the draft EIS ignores the preliminary Wild and Scenic 

Rivers Act section 7(a) determination filed with the Commission on January 26, 2006. The Forest 

Service also states that the draft EIS provides no evidence to warrant a change in the Regional Forester’s 

finding that relicensing the project as proposed in the Staff Alternative would result in an unreasonable 

diminishment of the scenic and recreational values of the Snake Wild and Scenic River from the 

continued loss of sandbars downstream of Hells Canyon dam. The Forest Service indicates that 

information from the Forest Service’s section 7(a) determination should be included in the final EIS, and 

that unreasonable diminishment could be avoided if the staff adopted Forest Service condition no. 4 

without modification or limitation in the proposed action. 

Response: We revised the text in section 5.5.8, Wild and Scenic Rivers Act, to include some of the 

information provided by the Forest Service in its January 26, 2006, and November 2, 2006, filings. We 

also note that the final EIS reflects staff adoption of Forest Service condition no. 4 as part of the Staff 

Alternative. 

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Comment PG-12: Reed Burkholder suggests the license period for the Hells Canyon project be less than 

30 years in order to allow other power generation technologies to mature and come on line. 

Response: The license period will be determined by the Commission in the license order. The FPA 

requires that a license be issued for between 30 and 50 years.

B2. EXECUTIVE SUMMARY 

Comment ES-1: With respect to table ES-1, NMFS comments that FERC’s analysis in the draft EIS 

seems to indicate that the Staff Alternative would provide more benefit in terms of increased DO levels 

over a wider range of flow conditions than is indicated in the summary statement. NMFS also comments 

that with respect to Idaho Power’s proposal, the summary does not appear to recognize that, compared to 

the No-action Alternative, TDG levels downstream of Hells Canyon dam should be reduced as a result of 

Idaho Power’s proposed measures (spilling from the top gates of Brownlee spillway and constructing gas 

abatement structures at Hells Canyon dam). 

Response: In the draft EIS, we described the effects of project operations and environmental measures 

separately in table ES-1. It appears that NMFS misinterpreted the table by assuming that the Effects of 

Operations included both effects of operations and environmental measures. Because Idaho Power 

currently implements preferential use of crest (upper spillway) gates for passing spills at Brownlee dam, 

its proposal to continue this action would not improve TDG levels. In bullet 2 of Idaho Power’s Proposal 

under Effects of Environmental Measures, we state that the “Flow deflectors at Hells Canyon dam would 

reduce the frequency of TDG levels exceeding the 110 percent of saturation criterion.” In bullet 1 of the 

Staff Alternative, we state that “Revision of the dissolved oxygen supplementation plan to address 

downstream effects should lead to improved dissolved oxygen levels downstream of Hells Canyon dam 

during the Chinook salmon spawning period.” 

Comment ES-2: NMFS provides the following comments on the aquatic resources section of table ES-1: 

(1) NMFS does not believe that the ramping rate restriction would necessarily reduce mortalities due to 

stranding and entrapment in entrapment pools; and (2) based on the scientific information available and 

NMFS’s understanding of FERC’s proposed flow augmentation and evaluation report, it does not believe 

that this report will provide any scientifically credible information regarding the efficacy of flow 

augmentation. 

Response: We modified table ES-1 to indicate that the ramping rate would be implemented in 

conjunction with a stranding and entrapment management plan, which would include adaptive 

management provisions that would provide a higher level of assurance that mortality levels would be 

reduced. We also deferred the flow augmentation evaluation report from 2009 to 6 years after license 

issuance. We consider it likely that sufficient new information on the efficacy of flow augmentation will 

be developed by that time to warrant evaluation. Conducting the review would help ensure that 

augmentation water is released in a manner that maximizes benefits to outmigrating salmon while 

minimizing adverse effects on power generation and other resources, including warmwater recreational 

fisheries, that are affected by reservoir drawdowns. 

Comment ES-3: NMFS comments that the Executive Summary should mention that the State of Oregon 

and environmental groups each submitted to NMFS alternatives to its reservation of fish passage 

authority. It notes that the summary fails to include the effects of the project on all listed anadromous fish 

in the Columbia and Snake River basins. It also comments that the summary table would be greatly 

improved by adding a very brief description of the magnitude of effect (i.e., tons of sediment, mg/L of 

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DO, etc.), where such metrics are important for assessing the import of effects. 

Response: We evaluated the potential effects of the project on all listed ESUs of anadromous fish in 

draft EIS section 3.8.2, Environmental Effects on Threatened and Endangered Species. In that section, 

we conclude that the effects of the project on salmon and steelhead in the lower Columbia River are 

limited by the substantial distance from the project and by the relatively small proportion of total flows 

that are contributed by flows passing the project. We also note that the primary effect of the project on 

flows is attributable to flood control operations, which are under Corps jurisdiction. Because all of the 

most substantive project effects occur in the Snake River, we focused on these effects in the Executive 

Summary. However, we modified table ES-1 to note that the flow augmentation measure included in the 

Staff Alternative would likely benefit the migration of juvenile fall Chinook salmon in both the Snake and 

lower Columbia rivers. In regard to the recommendation to describe the magnitude of effect in the 

summary table, effects on tons of sediment, mg/L of DO, and so on are highly dependent on exactly how 

the project is operated and how recommended measures are implemented, so it is impractical to try to 

quantify effects in a way that would be meaningful in a summary table. Providing metrics to describe the 

magnitude of effects on aquatic resources is generally not feasible due to the many factors and 

interactions that affect biological or population responses. 

B3. PURPOSE OF ACTION AND NEED FOR POWER 

Comment NP-1: Interior states that the EIS should include an estimate of where new power generation 

will be needed, as well as a discussion of how Idaho Power plans to meet this increased load demand. 

Response: We modified EIS section 1.2, Need for Power, to more clearly identify where new power and 

transmission facilities would be located. We also updated the Need for Power section to reflect Idaho 

Power’s 2006 Integrated Resource Plan. New generation is estimated for the Idaho Power service area 

and does not include other utilities. 

B4. PROPOSED ACTION AND ALTERNATIVES 

Comment PA-1: The Forest Service comments that the draft EIS incorrectly presumes that a water 

quality certification will be completed in time for the final EIS filing, and notes that at the draft EIS 

public meeting both Oregon and Idaho commented that the 401 certification would not be issued in 

December due to a lack of information on some important water quality issues. 

Response: We revised the text of final EIS section 2.3.1.1, Water Quality Certification, to outline the 

current status of the section 401 certification process. We also revised the description of Idaho Power’s 

proposal to reflect measures included in Idaho Power’s January 30, 2007, application for section 401 

water quality certification. 

Comment PA-2: Brett Crow comments that section 2.4.3 of the draft EIS informs readers of the 

beneficial effects that would be lost if the project were retired, but fails to similarly inform readers of 

harmful effects that would end upon project retirement. 

Response: We modified the text in section 2.4.3, Project Retirement, to include information on the 

potential benefits that would accrue if the project were retired. 

Comment PA-3: Brett Crow comments that the project’s effect cannot be consistently measured without 

stating a project’s intended disposition upon retirement. He goes on to suggest four potential future 

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conditions that he feels could be used as baselines, each of which would cease power generation but 

would maintain reservoirs at current levels, full, partially full, or empty. He also comments that different 

sections of the draft EIS appear to use different baselines relative to reservoir levels in their assessment of 

project effects.

Response: As we indicated in section of 3.3 of Scoping Document 2 (SD2) and in section 2.1 of the draft 

EIS, we consider the No-action Alternative to represent a continuation of operations under the terms and 

conditions of the existing license, and this represents our baseline for environmental comparison. This 

ensures that the effects of alternative operations and environmental measures are evaluated against a 

relevant and clearly defined reference point, and not to a presumed future condition. We use this baseline 

consistently in our analysis of proposed measures, and could not locate any places in the draft EIS where 

a different baseline was used. For cumulatively affected resources, such as anadromous fish, we discuss 

available information on past impacts and the potential effects of reasonably foreseeable future actions in 

order to inform our analysis of cumulative effects, but that discussion is not meant to suggest a different 

baseline. The four alternatives that Mr. Crow describes would eliminate the power benefit of the project 

but would provide only limited environmental benefits. Because these conditions would provide little 

benefit at great cost, and because no party has recommended that the project be retired with the dams in 

place, there is no need for us to evaluate the retirement alternatives that Mr. Crow describes in his 

comment. 

Comment PA-4: Interior states that proposed operations for Brownlee dam should be described in a way 

that accurately reflects expected future operations, and that the estimated costs of flow augmentation may 

be overstated. 

Response: The description in draft EIS section 2.2.2, Proposed Project Operations, including the 

description of proposed operations for Brownlee dam, is based on Idaho Power’s proposal filed with its 

application. For the final EIS, we reviewed the cost estimates for all operational scenarios and revised 

section 4.2.2, Cost of Environmental Measures under the Applicant’s Proposal and Staff Alternative, 

where necessary. Idaho Power updated the costs of flow augmentation in its response to our Additional 

Information Request filed on March 30, 2007. We included the updated information in section 4.0, 

Developmental Analysis. 

Comment PA-5: The Forest Service, Interior, AR/IRU, the Nez Perce Tribe, NMFS, and others state that 

Commission staff has not adequately presented the potential range of alternative options available or 

adequately analyzed alternatives considered, especially given the wide array of conditions, 

recommendations, and alternative conditions provided by the parties to this proceeding. The Forest 

Service requests that Commission staff develop a more representative range of project operating 

alternatives and use the full extent of the information provided in the record to support a Proposed Action 

protective of the resources. 

NMFS comments that the alternatives analyzed in the draft EIS are insufficient in scope to provide 

meaningful analysis of how the project could be operated, or what additional actions might be 

contemplated, to mitigate for the project’s effects on aquatic resources. NMFS states that, for example, 

FERC did not fully analyze the reintroduction of fall Chinook salmon, including the effect of speeding up 

the water quality clean up so that habitat would be suitable for anadromous fish above the project in 30 

years, or the introduction of anadromous fish into Pine Creek and three tributaries of the Powder River as 

proposed by ODFW. 

NMFS comments that in the ITF report on NEPA procedures, FERC agreed to include resource agency 

recommended measures in one alternative, and if not, to ensure that all effects of the measures were 

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disclosed. NMFS comments, however, that FERC staff did not include NMFS’s recommended measures 

in one alternative, and did not fully disclose all of their effects. ODFW similarly objects to the lack of an 

agency alternative, stating that FERC staff has arbitrarily and capriciously removed ODFW 

recommendations from detailed consideration in the draft EIS. 

Interior comments that there appear to be only two alternatives that are being analyzed in the draft EIS: 

Idaho Power’s proposal and the Staff Alternative. It states that this narrow range of alternatives is 

inadequate in terms of the magnitude and duration of the effects of the project on the human environment 

and the long term commitments being made for another 30 to 50 years. It states that the project has had 

adverse effects on terrestrial and aquatic resources of the Snake River, several of which have not been 

addressed for the last 50 years, and that these impacts need to be fully analyzed in a NEPA document to 

fully understand these long-term effects and assist the Commission in the development of a full range of 

alternatives. 

Interior comments that the Commission should demonstrate that it has analyzed and considered a 

licensing alternative that addresses sediment movement caused by flow alterations at the project and its 

effect on downstream aquatic habitat for all native fish and invertebrates. 

The Umatilla Tribes state that the draft EIS should have considered several alternatives, including (1) a 

rigorous analysis of energy conservation and other power sources to supplement or replace project power; 

(2) a decommissioning alternative; and (3) an alternative that fully adopts the terms, conditions, and 

recommendations submitted by the tribes and state and federal fish and wildlife agencies. The Umatilla 

Tribes also state that an alternative with greater focus on energy conservation would allow increased fish, 

wildlife, and other resource benefits and make little difference in power generation and revenues. The 

Nez Perce Tribe states that the draft EIS provides no consideration for energy conservation and its role in 

any alternative, and notes that the draft EIS did not provide any specific evaluation of alternative energy 

sources and/or practices that could supplant some of existing power generation in the project. The Nez 

Perce Tribe notes several alternatives that could be analyzed and compared in additional studies, 

including gas-fired generation, wind generators, distributed generation, load management, efficiency 

improvements, strategic pricing of retail power, and truer cost pricing. 

Reed Burkholder comments that the EIS should include a two-scenario analysis: (1) retention of the four 

federal dams (Lower Granite, Little Goose, Lower Monumental, and Ice Harbor); and (2) without the four 

lower Snake River dams. Mr. Burkholder states that successful anadromous fish reintroduction would 

then be limited only by the Hells Canyon complex. 

The Shoshone-Bannock Tribes state that FERC staff should have considered three alternatives in the draft 

EIS: (1) an alternative that includes phased restoration of anadromous fish; (2) an alternative that 

includes all of the feasible environmental protection, mitigation, and enhancement conditions submitted 

by state, federal, and tribal entities; and (3) a decommissioning alternative. 

AR/IRU state that the final EIS should include additional alternatives, including: (1) immediate 

implementation of fish passage for spring and summer Chinook and steelhead; (2) implementation, once 

upstream water quality is sufficient, of mainstem fish passage above the project for fall Chinook, 

including immediate studies of how to implement passage; (3) sand augmentation necessary to fully 

support recreational activities and fall Chinook rearing habitat; (4) gravel augmentation necessary to 

mitigate for lost spawning habitat; (5) an upstream nutrient removal program to restore water quality 

within and downstream of the project; and (6) all section 18 and section 4(e) conditions and 10(j) 

recommendations. 

Response: In Scoping Document 2 (FERC, 2004), we described the alternatives that would be 

considered in the EIS, including no action, the applicant’s proposal, and a range of operational and 

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environmental measures. In licensing proceedings, the terms, conditions, and recommendations filed by 

agencies and other entities do not generally suggest clear alternatives to the applicant’s proposal. Instead, 

they include a variety of environmental enhancement and protection measures that reflect the individual 

concerns and interests of the parties. We note that in the ITF report on NEPA procedures cited by NMFS, 

FERC committed to analyzing an agency alternative in cases where agencies file a consistent set of 

recommendations or when only one agency files recommendations and FERC determines that the 

recommendations form a reasonable alternative. In the absence of a consistent set of agency 

recommendations or another clear alternative, we compare and analyze the relative merits of all of the 

terms, conditions, and recommendations in section 3 of the draft EIS, and then craft the Staff Alternative 

based on that analysis. In effect, our recommended alternative is directly derived from Idaho Power’s 

proposal, other parties’ recommendations, and measures we may independently identify. We therefore 

conclude that we achieve the goal of evaluating a reasonable range of alternatives. 

In the final EIS, we expanded section 1.2, Need for Power, to include alternative energy sources as 

identified in Idaho Power’s 2006 Integrated Resource Plan. Alternative energy and demand management 

would not replace the need for power from Hells Canyon, but would address projected energy and load 

growth in the Idaho Power service area. In final EIS section 2.4.3, Project Retirement, we also expanded 

our discussion of the factors that we considered in determining that project decommissioning is not a 

reasonable alternative. 

Comment PA-6: The Nez Perce Tribe states that the EIS should address the possibility of federal 

takeover, which would allow for better coordination with other federal Columbia River system projects, 

and could provide other benefits such as coordinated flow augmentation and shaping, load following 

operations, and fish passage 

Response: As noted in Scoping Document 2 (FERC, 2004), federal takeover of the project would require 

Congressional approval, and no federal agency has expressed an interest in operating the Hells Canyon 

Project. Thus, we do not consider this a reasonable alternative for inclusion in the EIS. 

Comment PA-7: The Forest Service indicates that it does not understand how the Commission Staff 

chose the individual Staff Alternative measures because little or no justification is provided. The 

Umatilla Tribes state that FERC should clarify the reasoning underlying which section 10(a) and section 

4(e) recommendations were included or rejected. 

Response: The information in the EIS about the environmental effects of the proposed action and action 

alternatives is sufficient. We recognize that the analysis of various alternative operating regimes and 

environmental measures (EIS section 3, Environmental Analysis) is separate from our conclusions 

concerning what we are recommending as part of the Staff Alternative (EIS section 5, Staff’s 

Conclusions). This is the result of our need to provide a document that can be used by other agencies, as 

well as FERC, to clearly present the analysis apart from the decision. In section 5.2, Discussion of Key 

Issues, we do not repeat all elements of the analysis that led us to our conclusions, but generally refer the 

reader back to section 3 for the analytical details that provide justification for the measures we include in 

the Staff Alternative. 

Comment PA-8: NPPVA states that the description of Idaho Power’s Proposed Operations, draft EIS 

table 1, skips from the period ending 9/30 to the period beginning 10/21, providing no daily limit between 

minimum and maximum releases for the period 10/1 to 10/20. NPPVA notes that this should be 

corrected. 

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Response: The table is correct as it appears in the draft EIS. The spring/summer constant applies only 

through the end of September. The fall Chinook salmon plan load following limits starts on or before 

October 21, depending on observed conditions. 

Comment PA-9: NPPVA states that for most of the Primary Recreation Season, 6/1 to 10/20, draft EIS 

table 1 shows minimum flows of 6,500 cfs, with 5,000 cfs under atypical conditions. NPPVA states that 

Idaho Power should not be allowed to determine atypical conditions without a regulatory definition of 

what constitutes “atypical.” 

Response: Atypical conditions (that is, conditions under which Idaho Power would be allowed to 

temporarily modify its operations to depart from license requirements) will be defined in the 

Commission’s license order for the Hells Canyon Project. 

Comment PA-10: NPPVA states that in the detailed list of condition changes listed on page 31 of the 

draft EIS, the four, not five, items listed do not include safe navigation flows. NPPVA requests 

clarification as to whether this omission was intended. 

Response: The reference to five items in the draft EIS, including a navigation flow, was a typographical 

error. We intended to list only four condition changes in the draft EIS and made a correction in the final 

EIS. We reviewed the issue of navigation flows again for the final EIS; our conclusions, which include a 

seasonal 8,500-cfs minimum flow in medium-high and extremely high water years, are summarized in 

section 5.2.2.2, Navigation Target Flow Levels.

Comment PA-11: NPPVA states that draft EIS table 1 does not mention the current minimum flow limit 

of 13,000 cfs below the confluence of the Snake River with the Salmon River. NPPVA notes that flow 

can be accurately measured at the McDuff/China Garden gage. 

Response: In section 3.3.2.7, Downstream Flows Important to Navigation, we point out that Idaho 

Power modeled the 13,000-cfs Lime Point flow by assuming the 6,500-cfs release from Hells Canyon 

dam that appears on draft EIS table 1 (FEIS table 2). 

Comment PA-12: The Shoshone-Bannock Tribes note that the draft EIS uses existing conditions as the 

No-action Alternative, and that the EIS should use pre-project conditions as the baseline. The Nez Perce 

Tribe states that the No-action Alternative does not allow the establishment of an appropriate baseline for 

comparison of benefits and costs of other alternatives, and also states that the No-action Alternative does 

not balance power and non-power values or give equal consideration to environmental factors. 

Response: It is Commission policy that when considering whether to grant a new license for an existing 

project, project operations under the existing license serve as the baseline, or No-action Alternative. As 

such, it simply represents the current situation as it is, regardless of whether there is a balance of power 

and non-power values. As appropriate, the staff addresses pre-project conditions in the context of 

cumulative impacts. 

Comment PA-13: The Shoshone-Bannock Tribes state that FERC should consider all of the comments 

provided in the Tribe’s letter, and revise the environmental analysis and preferred alternative accordingly. 

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The Nez Perce Tribe states that the draft EIS fails to adequately consider the Nez Perce recommendations, 

and states that the Staff Alternative does not represent an appropriate balance of environmental 

protection, mitigation, and enhancement measures with the production of power. The Tribe states that 

operational modifications included in the Staff Alternative do not incorporate the Tribe’s 

recommendations. The Umatilla Tribes state that the EIS should provide a thorough analysis of 

alternatives that balance the need for power with environmental impacts of the project, particularly on 

tribal treaty and trust resources. 

Interior states that many of its recommendations are not discussed and evaluated in the draft EIS as part of 

a robust alternative analysis for the project, leaving only one alternative in the draft EIS to analyze. 

Interior states that comments received from all parties should be reanalyzed and the EIS should display 

clear and distinct alternatives that give full consideration to Interior’s FPA section 4(e) conditions and 

Section 10(a) and 10(j) recommendations 

Response: As noted in a previous response, we compare and analyze the relative merits of all the terms, 

conditions, and recommendations in section 3 of the EIS, then craft a Staff Alternative based on that 

analysis. We consider all comments by all parties, although we sometimes combine our analysis of 

measures that are similar in intent but differ by degree. 

Comment PA-14: Interior states that the list of environmental measures in the draft EIS should be 

amended to reflect that efforts such as litter control, staffing for law enforcement, and visitor centers are 

not mitigation for project effects on fish and wildlife and their habitats. 

Response: The list of measures provided in draft EIS section 2.1.3, Current Environmental Measures, 

does not suggest that all the measures are mitigation for project effects on fish and wildlife and their 

habitats. 

Comment PA-15: AR/IRU state that each alternative should be independently described, rather than 

providing lists of proposed edits to Idaho Power’s proposal. 

Response: Our approach to describing the Staff Alternative in section 2.3.3 is meant to make it easier for 

the reader to understand the differences and similarities between the Applicant’s Proposal and the Staff 

Alternative; hence our approach, which we maintained in the final EIS. The presentation of the Staff 

Alternative in section 5.1.1.2, Staff Alternative, may be clearer for some readers.

Comment PA-16: AR/IRU comment that while the draft EIS discusses mitigation measures, it does not 

provide a comprehensive analysis of Idaho Power’s mitigation obligations. AR/IRU state that FERC 

should clearly state goals and objectives, and where monitoring, study, and planning are appropriate, 

triggers and specific goals for mitigation should also be included. 

Response: Our EIS discusses mitigation obligations in the context of our effects analysis, indicating first 

what the project effects are, and then evaluating the efficacy of Idaho Power’s proposed measures and the 

measures recommended by others in mitigating those effects. With respect to monitoring programs and 

studies, we do describe the goals of these programs and define the triggers that would determine when 

new action is required. These requirements involve coordination with interested agencies and other 

parties. Where the specific goals result from the consultations, goals and triggers cannot be defined at 

this time, but can be defined only following the consultation.

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Comment PA-17: Interior states that the draft EIS lacks inclusion and use of existing information and 

scientific work on operational impacts. AR/IRU state that the final EIS should include all significant 

“direct” or “indirect” impacts supported by credible scientific evidence. AR/IRU note that where 

information is inadequate, FERC should include: (1) a statement that information is incomplete or 

unavailable; (2) a statement of relevance to evaluation of reasonably foreseeable impacts of the missing 

information; (3) a summary of relevant, existing credible scientific information; and (4) FERC’s 

evaluation of all reasonably foreseeable impacts based upon generally accepted scientific research. 

Response: An EIS includes the information that staff finds most relevant to assessing project effects and 

evaluating measures that could be applied to mitigate those effects. We note where information is 

incomplete or unavailable, and clearly indicate the information on which our evaluation is based. We 

conclude that the draft EIS, augmented by new information provided in comments on the draft and 

included in the final EIS, includes the most relevant information on which the staff must base its 

recommendations, and this is sufficient information for the Commission to make a reasoned decision with 

respect to the terms of any new license issued for the project.

Comment PA-18: AR/IRU state that the draft EIS incorrectly states there would be no significant 

change from the current environmental setting under the No-action Alternative. AR/IRU note several 

examples, including continuing effects of the 12-inch-per-hour ramping rate, continuing loss of sand and 

gravel, blockage of fish passage, habitat loss for fish, and loss of macro-invertebrate production. AR/IRU 

note that FERC should further develop the effects analysis of the No-action Alternative to incorporate the 

continuing, cumulative, and compounding effects of the No-action Alternative. 

Response: We revised the text in section 3.14, Effects of No-action Alternative, to recognize certain 

ongoing effects of project operation. 

Comment PA-19: Interior comments that the draft EIS discounts both past riparian habitat values and 

present and future restoration potential. Interior suggests that the NEPA document analyze appropriate 

operational scenarios that restore and/or enhance riparian habitats, such as a “run of river” or “managed 

lakes” scenario. Interior suggests that the NEPA document acknowledge the lack of historical data on 

terrestrial habitat values and conditions and reconsider Interior, ODFW and IDFG 10(j) recommendations 

for terrestrial mitigation. 

Response: Idaho Power’s license application and technical reports (Blair et al., 2003a,b) compare a full 

pool run-of-river scenario with Idaho Power’s proposed operations. Staff did not request that Idaho 

Power model a Dam Removal Scenario, for reasons discussed in section 2.4.3, Project Retirement, but 

requested modeling of 11 other operating scenarios (AIR OP-1). Scenario 1a (where Hells Canyon would 

be used to re-regulate outflows) and Scenario 5 (Brownlee held at minimum pool, with Oxbow and Hells 

Canyon held at full pool) would correspond to Interior’s “run-of-river” and “managed lakes” scenarios. 

As discussed in section 3.3.2.2, Operational Recommendations and Alternative Evaluation Scenarios, we 

did not carry all the modeled scenarios forward for detailed analysis in the EIS; we narrowed the range of 

alternatives to reflect the range of operational recommendations that were received in response to the 

REA notice. We found that none of the three scenarios that we carried forward for detailed analysis 

offered a significant potential for restoring “normative” riverine and riparian conditions. For this reason, 

the Staff Alternative focuses on acquisition of riparian habitat, as described in section 5.2.5.4. The EIS 

recognizes the importance of riparian habitat throughout sections 3.7.2.1 and 5.2.5.4. 

We agree there is little detailed information about habitat conditions prior to project construction. 

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However, review of pre-project aerial and oblique photographs, General Land Office records, and 

interviews with agency biologists indicated that land uses (primarily unrestricted grazing since the turn of 

the last century) had severely reduced range conditions and virtually eliminated riparian vegetation by the 

time the Hells Canyon Project was built (Blair et al., 2003b). Since that time, conditions around most of 

Brownlee reservoir have not improved; riparian habitat continues to be limited by reservoir fluctuations, 

and invasive non-native weeds are widespread. However, the extent and quality of riparian habitat 

around Oxbow and Hells Canyon reservoirs and along the Snake River downstream of Hells Canyon dam 

has improved dramatically in response to changes in land use. The Staff Alternative would provide for 

further improvements by emphasizing protection, management, and enhancement of lands already in 

Idaho Power’s ownership around the project reservoirs and on adjacent lands acquired for mitigation. 

Comment PA-20: ODFW states that the river fluctuation zone or the shore and bottomland wetland 

cover type downstream of Hells Canyon dam is significantly affected by project ramping rates and mostly 

void of any annual or perennial vegetation. ODFW recommends that the final EIS include an alternative 

directing Idaho Power to increase riparian habitat below Hells Canyon dam, through changes to project 

operation or through land acquisition and enhancement. 

Response: Based on our review of Idaho Power’s technical studies, we concluded that project operations 

do not significantly affect the shore and bottomland wetland cover type because stage fluctuations occur 

within the scour zone, where rocky substrate and annual peak flows prevent the establishment of a 

perennial plant community that would provide significant habitat for wildlife. Information provided by 

the Forest Service in its comments on the draft EIS indicates that although project effects (interrupted 

sediment supply and load following) do not adversely affect the establishment of netleaf hackberry within 

the scour zone, they may prevent the establishment of sandbar willow on about 49 acres. To address this 

concern, we revised the Staff Alternative in section 2.3.3 to include acquisition of an additional 49 acres 

of riparian habitat, as part of the larger acquisition package. 

B5. CUMULATIVE EFFECTS 

Comment CE-1: The Shoshone-Paiute Tribes note the loss of riverine, wetland, and riparian habitat 

associated with Hells Canyon and other Idaho Power projects. The Shoshone-Paiute Tribes state that the 

final EIS should clearly describe this loss. 

The Nez Perce Tribe states that the draft EIS does not adequately analyze cumulative impacts to natural 

resources and anadromous fish from project operations. The Nez Perce Tribe notes that their fall Chinook 

supplementation program is not mentioned in the analysis. 

Response: The draft EIS addresses the loss of riverine habitat in Cumulative Impact sections 3.6.3 

(pacific lamprey, redband trout, and white sturgeon) and 3.8.3 (Snake River fall Chinook salmon, Snake 

River steelhead and spring/summer Chinook salmon, Snake River sockeye salmon, other Columbia River 

basin salmon and steelhead ESUs, and bull trout), and the loss of wetland and riparian habitats in section 

3.7.3.1, Riparian and Wetland Habitats. We revised these sections in the final EIS to include additional 

information with respect to cumulative effects and to acknowledge the benefits of the Nez Perce 

supplementation program and other tribal fisheries and habitat restoration efforts.

Comment CE-2: The Nez Perce Tribe notes that the benefits of the project (cheap electricity) are 

realized largely up river, and the impacts are felt down river, outside of the four-county area analyzed. 

The Nez Perce Tribe notes that project-related impacts on the reservation manifest as: (1) curtailed 

ceremonial and subsistence fisheries, affecting tribal health, welfare and culture; (2) curtailed commercial 

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fisheries, affecting tribal health, welfare and culture; and (3) elimination of usual and accustomed fishing 

areas in Treaty areas. The Nez Perce Tribe recommends the EIS discuss the cumulative effects on the 

Tribe of the reduced fishery. 

Response: The final EIS includes two new sections, 3.13.1.5, Native American Tribes, and 3.13.2.4, 

Effects on Native Americans, to address the points made by the Nez Perce Tribe. Nonetheless, we 

continue to conclude that Idaho Power’s proposed aquatic measures and the staff’s recommended aquatic 

resource measures, taken together, would represent an improvement in aquatic resources compared to 

existing conditions. These measures would help restore and maintain long-term ecosystem health, and 

would help support the economic and social needs of Native Americans in the project region, including 

those related to fisheries. In the Staff Alternative (see section 3.12.2.1, Land Use Management), we also 

recommend a measure that would establish a Technical Advisory Committee (plus resource-specific 

subcommittees) in which the tribes and other participants would have ongoing opportunities for 

consultation and contribution to design and implementation of aquatic, recreational, cultural resource, 

and other measures over the license term.

Comment CE-3: AR/IRU state that FERC should extend the temporal scope of the analysis back as far 

as possible before Snake River development, as well as into the future. 

Response: The temporal analysis includes sufficient pre-development information to characterize the 

changes that have been wrought on the Snake River basin environment. For example, section 3.8.3.1, 

Snake River Fall Chinook Salmon, notes the adverse effects of placer mining, agricultural production, 

timber harvest, and livestock production on habitat; the blockage of upstream passage by Swan Falls dam 

and Hells Canyon dam; the loss of spawning gravel recruitment, altered river flows, and adversely 

affected water quality caused by additional tributary dams and agricultural development; and the adverse 

effects of additional mainstem dams on the survival of migrating salmon. We do not see that any more 

detail concerning the past would provide information that would be useful to the staff in making its 

recommendations or to the Commission in making its decision with respect to a license order.

Comment CE-4: AR/IRU note that effects on the recreation, tourism and commercial industries were not 

included. AR/IRU note that FERC should consider aesthetic, historic, cultural, economic and social 

impacts in cumulative effects. 

Response: The resources to be addressed in the cumulative effects analysis were set in Scoping 

Document 2 (FERC, 2004) based on input during the scoping process, and we did not change that 

determination in the final EIS. We note that cumulative effects on recreation are discussed in draft EIS 

section 3.10.3, Cumulative Effects.

Comment CE-5: AR/IRU state that FERC’s discussion of cumulative impacts on sport-fishing and 

whitewater boating falls short, and that the elimination of miles of free-flowing river and suppression of 

the salmon, steelhead, and bull trout population are treated cursorily. 

Response: We continue to find that the acknowledgement of these cumulative effects provides an 

adequate foundation for our analysis of project effects and evaluation of alternative mitigation measures.

Comment CE-6: NMFS comments that FERC should expand the geographic scope for anadromous fish 

to include the entire historically accessible Snake River basin and the Columbia River from the Snake 

River mouth downstream to the Columbia River plume and nearshore ocean environment. The Nez Perce 

Tribe recommends that the geographic scope for anadromous fish should span the North Pacific to 

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southeast Alaska. 

Response: We expanded the geographic scope of our cumulative effects analysis for anadromous fish to 

include the entire Snake River basin upstream from its confluence with the Columbia River, and the 

mainstem lower Columbia River extending from its confluence with the Snake River to downstream of 

Bonneville dam. We include the entire Snake River basin in order to encompass the effects of dams and 

water storage upstream of historical barriers to anadromous fish, and the lower Columbia River due to its 

importance as a migratory corridor and the effects of mainstem dams on migration survival. 

Given the relatively small changes in seasonal flow caused by the project, and the fact that most of the 

change in seasonal flow is due to flood storage requirements imposed by the Corps, we do not agree that 

the relicensing action has substantive effects that extend to areas downstream of Bonneville dam, 

including the Columbia River plume and the nearshore ocean environment of the North Pacific and 

southeast Alaska. Therefore, we conclude that it is appropriate to focus our cumulative effects analysis 

on the riverine environment, where cumulative effects on anadromous habitat have the greatest potential 

to overlap. We address effects on anadromous fish production, which we acknowledge can affect the 

number of fish that are available for harvest in the ocean environment, as a project-specific effect. 

Comment CE-7: Interior comments that flow releases from Dworshak reservoir serve different purposes 

than those from the project, including water temperature regulation, which project releases probably 

cannot provide. Interior recommends that FERC eliminate this reference to tradeoffs with Dworshak 

reservoir releases unless there is a specific agreement between Idaho Power and the Corps to consider in a 

NEPA alternative. 

The Nez Perce Tribe comments that the EIS should clarify that operation of Dworshak dam is for flow 

augmentation and temperature control for impacts caused by the Hells Canyon Project and the lower 

Snake River dams. The Tribe states that the EIS should also clarify that Dworshak operations will 

continue regardless of the outcome of the relicensing and as such, the analysis should not look at the 

tradeoffs between Brownlee and Dworshak but rather how the Hells Canyon Project with and without a 

temperature control structure and flow augmentation operations interact and compliment or impact 

mitigation provided by Dworshak operations. 

Response: In the final EIS, we expanded our discussion of the role that coolwater releases from 

Dworshak reservoir play in the current flow augmentation program. The water that is released from 

Dworshak dam to benefit the migration of juvenile anadromous fish is guided by biological opinions on 

operation of the Federal Columbia River Power System, and does not serve as mitigation for impacts 

caused by the Hells Canyon Project. We conclude in final EIS section 5.2.3.2, Water Temperature 

Measures, that the operation of a temperature control structure at Brownlee dam could adversely affect 

water temperatures during the summer and could result in reduced dissolved oxygen levels and increased 

concentrations of ammonia, mercury and organochlorine compounds downstream of the project, 

regardless of the releases from Dworshak reservoir. On the other hand, our analysis shows that 

implementing watershed measures (e.g., temperature trading) could meet the project’s temperature 

responsibility in a manner that would provide a broader array of benefits without the risks identified 

above. 

Comment CE-8: The Nez Perce Tribe comments that the draft EIS fails to analyze the cumulative 

effects to natural resources from project operations and blocked passage to historic spawning grounds for 

fall Chinook salmon. The Nez Perce Tribe also notes that the draft EIS does not mention that the 

numbers of returning adult fall Chinook would be substantially lower if it were not for the Nez Perce 

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Tribe’s fall Chinook salmon supplementation program. 

Response: We modified the text in sections 3.8.1.1, Fall Chinook Salmon, and 3.8.3.1, Snake River Fall 

Chinook Salmon, to more fully explain the project’s contribution to cumulative effects on fall Chinook 

salmon, and the beneficial effect of the fall Chinook supplementation program undertaken by the Nez 

Perce Tribe. 

Comment CE-9: The Nez Perce Tribe comments that the draft EIS fails to include Pacific lamprey as a 

resource that is affected by the Hells Canyon Project and other dams in the Snake River basin. It states 

that Pacific lamprey are highly important to the Nez Perce Tribe’s culture and are used for subsistence 

and ceremonial purposes. It notes that the abundance and distribution of Pacific lamprey has been 

significantly reduced due to mainstem hydroelectric development in the Columbia River basin and 

therefore, the geographic scope for analysis should include the Columbia and Snake River including the 

former habitat above the Hells Canyon Project and mid-Snake dams. The Nez Perce Tribe states that this 

species must be analyzed in the EIS and that appropriate mitigation measures must be developed. The 

Umatilla Tribes and the Nez Perce Tribe recommend that Idaho Power contribute to the funding of 

regional evaluations of salmon and Pacific lamprey stocks. 

Response: We recognize the contribution of blocked passage caused by Idaho Power’s mainstem 

developments in our cumulative effects analysis for Pacific lamprey in section 3.6.3.1, Pacific Lamprey. 

In the final EIS, we recommend a measure that would require Idaho Power to participate in regional 

forums on Pacific lamprey restoration, and to file a report with the Commission every 3 years 

summarizing the results of research activities that may affect the potential for implementing measures at 

Hells Canyon to benefit Pacific lamprey. 

Comment CE-10: AR/IRU question why the geographic extent of the cumulative effects analysis for 

anadromous fish excludes the North Fork of the Clearwater River above Dworshak dam and the mainstem 

Clearwater above its confluence with the North Fork, while the entire Clearwater River basin is included 

for resident fish. 

Response: We modified the geographic scope of our cumulative effects analysis for anadromous fish to 

include the entire Snake River basin upstream of its confluence with the Columbia River (including 

tributaries), and the mainstem Columbia River extending from its confluence with the Snake River to 

downstream of Bonneville dam. 

Comment CE-11: AR/IRU comment that the draft EIS did not address cumulative effects on several 

critical resources including mountain whitefish and invertebrates other than federally listed mollusks. 

Response: Based on our assessment of information provided during scoping, we defined the resources to 

be included in our cumulative effects analysis in Scoping Document 2. For resident fish, we determined 

in Scoping Document 2 that our cumulative effects analysis would include bull trout, redband trout, and 

white sturgeon. We did not identify aquatic invertebrates (other than federally listed mollusks) as a 

resource that we would include in our cumulative effects analysis. Because the primary pathway for 

potential cumulative effects on aquatic invertebrates is through changes in water quality, we conclude that 

our analysis of cumulative effects on water quality is sufficient to encompass effects on aquatic 

invertebrates. 

Comment CE-12: AR/IRU comment that the discussion of cumulative impacts on resident fish did not 

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acknowledge the impact of blocked passage for resident fish species other than white sturgeon. 

Response: We modified the text of section 3.6.3.2, Redband Trout and White Sturgeon, to include this 

point. 

Comment CE-13: AR/IRU comment that the cumulative impact analysis does not provide sufficient 

detail, and restate their position that the cumulative effects analysis in the EIS for Idaho Power’s midSnake projects, which the Hells Canyon EIS tiers from, was itself inadequate. AR/IRU conclude that the 

cumulative impacts analysis in the draft EIS falls short of meeting NEPA requirements. 

Response: We consider our cumulative effects analysis for both the mid-Snake and Hells Canyon 

projects to be adequate to support a reasoned decision by the Commission in this relicensing. However, 

we expanded the analysis in several areas to address specific comments that we received on the draft EIS. 

Comment CE-14: AR/IRU comment that the cumulative impacts discussion for anadromous fish does 

not mention the impact of the loss of upstream habitat from the lack of passage at the Hells Canyon 

Project and Idaho Power’s other Snake River dams, sediment blockage by the project, how ramping may 

affect anadromous fish, and effects of projects on anadromous fish spawning. 

Response: We modified the text in section 3.8.3.1, Snake River Fall Chinook Salmon, to include 

discussion of these effects. 

Comment CE-15: Interior comments that the draft EIS states that the cumulative effects of watershed 

development on resident fish will include all tributaries of the Snake River between Hells Canyon dam 

and Lower Granite reservoir. It recommends that to the extent that fish stocks or populations from 

tributaries are known to coexist in the mainstem of the Snake River, FERC should analyze the effects of 

the project on these fish resources. 

Response: We expanded the text in sections 3.6.3.2, Redband Trout and White Sturgeon, and 3.8.3.5, 

Bull Trout, to include discussion of cumulative effects on redband and bull trout that migrate from 

tributaries into the main stem of the Snake River. 

Comment CE-16: NMFS recommends that the draft EIS briefly describe the cumulative effects on 

anadromous fish species of: (1) water storage projects throughout the Snake and Columbia River basin; 

(2) basin-wide requirements to limit flood-control to upper rule curves (as recommended by NMFS at this 

project) in the Columbia River basin; and (3) basin-wide flow-augmentation and temperature control 

efforts on flows and temperatures at key locations in the Columbia River. 

Response: We expanded the text in section 3.8.3, Cumulative Effects, Threatened and Endangered 

Species, to include a description of these effects. 

Comment CE-17: NMFS comments that the Marsing Reach was blocked by the construction of 

Brownlee in 1958, not by the construction of Hells Canyon dam in 1966 (which was actually completed 

in 1967). 

Response: We modified the text in section 3.8.3.1, Snake River Fall Chinook Salmon, to make this 

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correction. 

Comment CE-18: AR/IRU comment that the cumulative impacts discussion of water quality does not 

discuss the synergistic effect of upstream pollutants entering the Hells Canyon Project or how the 

complex alters pollutant processing in the river. 

Response: Although the synergistic effects are not specifically described, they are included in our 

evaluation of cumulative effects. 

Comment CE-19: NMFS states that FERC needs to consider the cumulative effects of flood control and 

irrigation on spring flows, and the cumulative effects of all these parameters on temperature, and that this 

analysis should be provided in as much detail as the draft EIS currently provides for sediment entrapment. 

Response: We revised draft EIS sections 3.5.3, and 3.8.3, Cumulative Effects (on Water Quality and on

Threatened and Endangered Species, respectively) to incorporate a discussion of estimated effects of flow 

regulation upstream of Brownlee reservoir on water temperature and on high spring (freshet) flows. 

Comment CE-20: Interior comments that because of daily and seasonal reservoir fluctuations and load 

following operations, the reservoir shorelines and much of the Snake River downstream of the projects is 

no longer capable of supporting native riparian habitats. Interior recommends that the NEPA document 

display a table or chart showing stream mileage and area of loss in acres, to illustrate the magnitude of 

this loss within the geographic scope of the cumulative effects analysis. The Shoshone-Paiute Tribes 

comment that the final EIS should clearly describe the loss of free-flowing riverine habitat, along with 

associated wetland and riparian habitats, caused by the project and cumulative effects of Idaho Power’s 

other projects. 

Response: We added text in section 3.7.3.1, Riparian and Wetland Habitats, to indicate that construction 

of the Hells Canyon Project converted almost 90 miles of free-flowing riverine habitat to reservoir, 

accounting for almost half of the reservoir length that now exists between the Shoshone Falls and Ice 

Harbor dams. Draft EIS table 2 (final EIS table 3) shows the length of each reservoir between Shoshone 

Falls and Bonneville dam. 

Comment CE-21: ODFW comments that staff does not address the effects and ongoing impacts on 

terrestrial species from loss of low elevation habitat due to reservoir inundation in its cumulative effects 

analysis. Because no mitigation was provided for inundation and loss of crucial low elevation winter 

range following construction and operation of the project, ODFW considers loss of this 10,220 acres 

(4,071 acres permanently) to be an ongoing impact and cumulative effect of project operation. Oregon’s 

mitigation policy states that mitigation shall be provided for continued impacts that have not been 

mitigated consistent with current standards. ODFW recommends that FERC include an analysis of the 

effects of annually inundated habitat and land acquisition and enhancement to mitigate for these effects in 

the reasonable alternatives of the final EIS. 

Response: Although we consider existing conditions to be the environmental baseline for evaluating the 

effects of relicensing the project, we agree that loss of habitat resulting from original construction is an 

important element of cumulative effects. We added text to section 3.7.3.2, Native Grasslands and 

Shrublands, to describe the loss of low elevation habitat due to inundation. 

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B6. WATER QUANTITY 

Comment WQN-1: The Nez Perce Tribe and the Umatilla Tribes state that key CHEOPS model 

assumptions are not described in the draft EIS and a standardized hydro-regulation model is not used to 

examine flow alternatives, operational changes, and cumulative impacts. The Nez Perce Tribe and the 

Umatilla Tribes state that Idaho Power should use the most updated Bonneville Power modified/adjusted 

streamflow record, so that the cumulative effects of upriver storage regulation changes, irrigation 

withdrawals, and evapotranspiration can be properly assessed. 

Response: The assumptions used in the CHEOPS model to simulate flows and power benefits for the 

evaluation scenarios were presented in appendix C of the draft EIS (appendix D of the final EIS). The 

simulations were run using the actual measured inflows that occurred in 5 years representing different 

water year types. These water years were selected because they occurred relatively recently (during the 

1990s and 2000s) and capture the effects of the recent levels of upriver storage regulation and irrigation 

withdrawals. We also note that BPA uses monthly flow data, whereas Idaho Power has used daily flow 

data that are more appropriate to the scale of the Hells Canyon Project. We did not change the text of the 

final EIS in response to this comment. 

Comment WQN-2: The Nez Perce Tribe notes that the three scenarios developed by FERC for analysis 

of project impacts do not adequately capture the recommendations by the tribe and agencies and do not 

provide reasonable comparison of environmental effects on tribal resources. 

Response: The scenarios adequately reflect the range of operational recommendations that were filed, 

and provide a sufficient basis to support our analysis and any Commission decision on the license 

application. The Nez Perce Tribe’s operation-related recommendations were among 40 such 

recommendations we reviewed in response to the Commission staff’s Ready for Environmental Analysis 

notice. To deal effectively with these numerous recommendations, we combined various 

recommendations into a set of nine operational scenarios and sub-scenarios. As explained in EIS section 

3.3.2.2, Operational Recommendations and Alternative Evaluation Scenarios, we then relied on these 

nine scenarios and sub-scenarios in our assessment of environmental effects. We believe these nine 

scenarios and sub-scenarios represent a sufficient range of operational alternatives to provide a sound 

basis upon which to conduct our environmental analysis. 

Comment WQN-3: Dale M. Litzenberger states that Idaho Power’s management of river flows has 

resulted in eroded river banks, loss of sandbars, chemical and thermal pollution, and lost salmon and 

steelhead runs. He urged FERC to correct these problems. 

Response: In the draft EIS, we evaluated a wide range of measures that were recommended by the 

agencies, tribes, and NGOs to address the effects of the project. We adopted many of these 

recommendations in the Staff Alternative. Many of these measures provide benefits to salmon and 

steelhead runs downstream of the project, and others may contribute to the eventual restoration of salmon 

and steelhead runs to areas upstream of the project. However, some project effects are unavoidable, and 

the costs of mitigating some types of project effects clearly outweigh their benefits. 

Comment WQN-4: The Shoshone-Bannock Tribes state that ramping rates should be limited to two 

inches per hour in order to protect fish and aquatic resources. Paul Poorman states that FERC should 

establish limits for flow fluctuations so that downstream water levels do not fluctuate on a daily basis by 

more than a few inches. The Nez Perce Tribe recommends ramping rate restrictions designed to protect 

juvenile salmon from stranding, as well as for protection and restoration of existing beaches and riparian 

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areas. 

Response: The Hells Canyon Project currently serves an important role in meeting electrical generation 

needs during periods of peak demand, and any severe restrictions on flow fluctuations would have a 

substantial effect on this important project benefit. We evaluated the costs and benefits of a range of 

limitations on flow fluctuations in the draft EIS, and we concluded that benefits to rearing fall Chinook 

salmon warranted the cost of a stricter 4-inch-per-hour ramping rate from March 15 to June 15. We also 

note that the available information on the effects of ramping on invertebrate production and on the 

potential for stranding rearing fall Chinook salmon was limited, and that there was no information on the 

effects of ramping on bull trout. As a result, we include monitoring of fish stranding and effects on 

invertebrate production in the Staff Alternative, with provisions for implementing additional measures 

based on monitoring results if warranted. During the 10(j) meeting, Idaho Power indicated that it had 

prepared a draft fish stranding management plan, and intended to work with NMFS and Interior to 

develop a plan that would be sufficient to protect federally listed fall Chinook salmon and bull trout 

downstream of Hells Canyon dam. 

Comment WQN-5: P. Brian Rogers states that he wishes to see Idaho Power regulate water release 

levels to benefit and not damage salmon and steelhead fisheries in the Snake River. 

Response: Regulating water release levels is not the sole means of benefiting fish downstream of the 

project. We include in the Staff Alternative several operational and environmental measures that would 

benefit anadromous fisheries downstream of the project, including flow management to benefit fall 

Chinook salmon spawning and incubation, restrictive ramping rates during the fall Chinook salmon 

rearing period, measures to improve water quality conditions by increasing DO levels and reducing gas 

supersaturation downstream from Hells Canyon dam, and augmentation of river flows during the juvenile 

outmigration period. 

Comment WQN-6: The Pioneer and Settlers Irrigation Districts and the Payette River Water Users 

Association state that the benefits of flow augmentation above the Hells Canyon dam complex to 

anadromous fish are ambiguous, and have not been firmly established. They also suggest that increased 

spill costs millions of dollars in lost low-cost electricity generation. 

Response: We recognize that there is disagreement on the benefits of flow augmentation, and that new 

information relevant to this issue will likely continue to be developed. As a result, we include in the Staff 

Alternative a provision that would require Idaho Power to develop a report 6 years after license issuance 

summarizing available information on the effects of providing flow augmentation water from Brownlee 

reservoir and to evaluate whether any changes in the volume or timing of release of flow augmentation 

water from Brownlee reservoir are warranted. 

Comment WQN-7: The Umatilla Tribes note that a decrease in water budget is expected to accelerate as 

a result of global climate change, and Idaho Power should use the best tools available for water 

management. 

Response: We recommend that Idaho Power consult with the agencies and tribes to develop a fall 

Chinook spawning and incubation flow management plan, which could include periodic review of new 

methods for forecasting seasonal flows to improve water management.

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Comment WQN-8: The Umatilla Tribes and the Nez Perce Tribe note that additional flow augmentation 

at Lower Granite dam is necessary to achieve target flows of 50 to 55 kcfs. The Nez Perce Tribe 

recommends a sliding scale flow augmentation program designed to provide appropriate flows for low, 

medium, and high water years. 

Response: We expanded our analysis of flow augmentation measures, including the sliding scale flow 

augmentation program proposed by the Nez Perce Tribe, in final EIS section 3.6.2.1, Effects of Project 

Operations on Aquatic Resources. We include the flow augmentation measure recommended by NMFS 

in the Staff Alternative. 

Comment WQN-9: The Umatilla Tribes note that maintaining a balance between maximum storage and 

power drawdown of Brownlee reservoir during medium and low flow years is particularly important. The 

Umatilla Tribes also note the tribes’ concurrence with the FERC Staff Alternative that retains the current 

minimum flows of 6,500 cfs at Hells Canyon dam and 13,000 cfs at Lime Point. 

Response: In the Staff Alternative, we address the concern that Brownlee reservoir elevations should be 

maintained at or near the upper range of the flood control rule curve. We adopt a measure that would 

require Idaho Power to fill Brownlee reservoir to a level between: (1) 1 foot of the April 15 and April 30 

required flood control draft, and (2) the required flood control draft on those dates. To comply with this 

requirement, Idaho Power would need to restrict drawdowns for power production that would interfere 

with refilling to meet these target levels. This measure applies to all hydrologic conditions, including 

medium- and low-flow years. We note the Umatilla Tribes’ concurrence with retention of the current 

minimum flows. 

Comment WQN-10: The Nez Perce Tribe recommends spring flood control shifts between Brownlee 

reservoir and Grand Coulee to maximize pass through of spring flows. 

Response: We discussed this issue in section 5.2.2.1 of the draft EIS, and conclude that any long-term 

modification of the project’s flood control operation involving transfer of storage capacity from Brownlee 

reservoir to other storage reservoirs in the Columbia River basin would be under the purview of the 

Corps, and any shift would require a separate environmental evaluation conducted by the Corps. 

Comment WQN-11: Interior states that the EIS should include a line on each of draft EIS figures 16 

through 20 showing simulated outflows under five water year types that would show the unaltered 

hydrograph as measured at the Weiser gage. Interior states that inflows from the Wildhorse River and 

Pine Creek should be included in the hydrograph. 

Response: The environmental baseline for flow conditions is current conditions and not unregulated 

flows at the Weiser gage. Furthermore, the Weiser gage is upstream of the project and not regulated by 

the Hells Canyon Project. Hydrographs for the Wildhorse River and Pine Creek for each of the five water 

year types can be found in the Final License Application. Please refer to Technical Report Appendix 

E.1.4, Project Hydrology and Hydraulics Models Applied to the Hells Canyon Reach of the Snake River, 

Chapter 2, Development of Inflow Hydrology for Hells Canyon Complex Studies. We did not change the 

figures (final EIS figures 17 through 21) in response to this comment. 

Comment WQN-12: Interior states that the EIS should include a map that shows the location of Hells 

Canyon dam, the Hells Canyon gage, Johnson Bar, Lime Point, the confluence of the Salmon River, and 

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the China Gardens gage to further explain the measurement of flows for navigation. 

Response: We added the suggested figure to final EIS section 3.3.1.1, Surface Water (see figure 8).

Comment WQN-13: The Corps notes that FERC should include the language recommended in the 

Corps’ January 26, 2006, letter regarding the spring runoff flood control draft and winter flood control 

operations for Brownlee reservoir. 

Response: The subject language is included on final EIS table 9, Operational Recommendations. 

Comment WQN-14: The Corps notes that any discussion in the final EIS that refers to releasing flow 

augmentation water between June 20 and July 1 should also note that Brownlee releases between June 20 

and July 1 may be restricted as needed for total system flood control and downstream levee protection. 

Response: We modified the Staff Alternative in sections 2.3.3 and 5.1.1.2 to specify that flow 

augmentation between June 20 and July 1may be restricted by the Corps if needed for system flood 

control purposes. 

Comment WQN-15: The Corps states that the final EIS should note that the June 7 target elevation of 

2,069 feet is subject to flood control requirements. 

Response: We modified the text in section 2.1.2.1, Brownlee Development, to reflect this fact. 

Comment WQN-16: The Corps recommends a wording change wherever the phrase “April 15 and April 

30 minimum elevations necessary” occurs in the draft EIS. The Corps recommends the following 

language be used instead “Idaho Power would refill Brownlee reservoir between 1 foot below the April 

15 and April 30 required flood control draft, up to the required flood control draft.” 

Response: We revised the text in sections 2.3.3, Staff Alternative, and 5.1.1.2, Staff Alternative, to reflect 

the Corps’ recommended change.

Comment WQN-17: The Corps notes that the information for Lime Point should be included in draft 

EIS table 3. 

Response: We added Lime Point to final EIS table 4. 

Comment WQN-18: The Corps notes that the header information for “The Dalles <= 75 MAF” should 

be deleted from the top of table 5 of the draft EIS, since this header information and corresponding 

information are shown on the previous page. 

Response: We deleted the header information from the table (FEIS table 6). 

Comment WQN-19: The Corps recommends clarifying in “footnote a” on table 5 of the draft EIS that 

the April to July volume inflow forecast applies to Brownlee and that the Dalles volume inflow forecast is 

for the April to August period. 

Response: We revised the footnote in final EIS table 6 to include this clarification. 

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Comment WQN-20: The Corps recommends that the first paragraph on page 69 of the draft EIS should 

note that the Corps will provide flood control guidance during the refill of Brownlee reservoir after April 

30. 

Response: We understand the Corps’ clarification. However, this paragraph simply summarizes the 

NMFS recommendation, so no change is called for. 

Comment WQN-21: Regarding the second and third sentences on page 533 of the draft EIS, the Corps 

notes that, during flood control refill operations that typically extend from May 1 to June 30, the Corps 

will specify Brownlee project releases for the purpose of system flood control as measured at the 

downstream flood control center at Portland-Vancouver. The Corps notes that Brownlee project releases 

are not specified by either Idaho Power or NMFS to control downstream flooding. 

Response: The third sentence of the first bullet makes clear that the coordination with NMFS “would not 

in any way diminish the Corps’ discretion over the project’s flood control operation,” so we do not 

believe any change is necessary. 

Comment WQN-22: The Corps states that Brownlee reservoir cannot be filled to full pool (elevation 

2,077 feet msl) by June 20 of each year, but may be held below elevation 2,077 for flood control. The 

Corp notes that any recommendations that the project be full by June 20 should include the words 

“subject to flood control requirements.” 

Response: We modified sections 2.3.3, Staff Alternative, and 5.1.1.2, Staff Alternative, to address this 

concern. 

Comment WQN-23: The Corps recommends revising the second bullet description on page 533 of the 

draft EIS to include what the operation would be if the reservoir is not full June 20, and make the revision 

to any other statement in the final EIS similar in wording to the last sentence in bullet 2. 

Response: To avoid any conflict with flood control operations directed by the Corps, we revised the 

description concerning the refill of Brownlee reservoir to indicate that operations could be restricted by 

the Corps for system flood control between June 20 and July 1. 

Comment WQN-24: The Corps recommends changing wording on page 533 of the draft EIS to “From 

December 1 to June 30, the Corps directs flood control operations of Brownlee reservoir as part of system 

flood control operations of the Columbia River projects to contain winter, spring and early summer flood 

waters from inundating the main downstream flood damage center located in the Portland-Vancouver 

metropolitan area.” 

Response: We included the suggested language in section 5.2.2.1, Flood Storage. 

Comment WQN-25: The Corps recommends replacing the second and third sentences on page 556 of 

the draft EIS with “Under the current license, Brownlee reservoir may be drawn down to elevation 2,034 

feet msl by February 28 to provide a maximum storage space of 500,000 acre-feet for system flood 

control. By April 30, Brownlee reservoir may be drawn down further to elevation 1,976 feet msl to 

provide an additional storage space of 480,000 acre-feet to contain floodwaters. This maximum draft of 

980,000 acre-feet of storage space pertains to the most severe combination of forecasted hydrologic 

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conditions for the Columbia River at The Dalles and Snake River above Brownlee reservoir.” 

Response: We included the suggested language in section 5.2.2.1, Flood Storage. 

Comment WQN-26: The Corps states that Idaho Power’s proposed operation does not provide flows 

required for safe navigation from June 1 through October 20. The Corps states it has determined that a 

minimum flow of 8,500 cfs is required for safe navigation conditions on the Snake River above the mouth 

of the Salmon. 

Response: We understand the Corps’ position on flows required for safe navigation, but navigation must 

be balanced with other resource benefits and costs. Refer to final EIS section 5.2.2.2, Navigation Target 

Flow Levels, for our conclusions on this subject, which now include a seasonal 8,500-cfs minimum flow 

in medium-high and extremely high water years. 

Comment WQN-27: The Corps states that it is unclear how much of the Idaho Power’s proposal is 

adopted in the draft EIS Staff Alternative because the language in sections 2.2.3 and 2.3.3 is unclear. 

Response: We corrected the conflicting language in sections 2.2.3, Proposed Environmental Measures, 

and 2.3.3, Staff Alternative. 

Comment WQN-28: The Corps comments that the current license limits the maximum variation in river 

stage at Johnson Bar to 1 foot per hour. The Corp strongly recommends that the new license contain this 

important safety provision as it currently exists or at some lesser rate of variation. 

Response: The 1-foot-per-hour maximum variation in river stage at Johnson Bar has been retained in the 

Staff Alternative. The ramping rate is further restricted to 4 inches per hour at Johnson Bar from March 

15 to June 15 to protect rearing fall Chinook salmon, and may be further restricted if needed based on the 

results of monitoring fish entrapment and stranding. 

Comment WQN-29: The Corps states that in the interest of providing flows to ensure safe navigation, it 

has determined the following safe navigation provisions: (1) for the reach of the Snake River above the 

mouth of the Salmon, minimum discharge should be 8,500 cfs; (2) for the reach of the Snake River 

downstream of the mouth of the Salmon River, minimum discharge should be 11,500 cfs; and (3) when 

the previous 3-day moving average for Brownlee reservoir inflow is less than 8,500 cfs, minimum 

discharge should not be below the 3-day moving average for Brownlee reservoir. 

Response: We present the Corps recommendation in draft EIS table 7 (final EIS table 9) and discuss it in 

sections 3.3.2.7, Downstream Flows Important to Navigation, and 5.2.2.2, Navigation Target Flow 

Levels. However, we reach the same conclusion in the final EIS that we reached in the draft EIS; that is, 

maintaining the Corps-recommended minimum flows would cause excessive dependable capacity losses. 

Comment WQN-30: The Corps states that the Corps minimum flow recommendations for safe 

navigation balances the operation of Hells Canyon dam in the interests of power and navigation because 

the Corps minimum flow recommendations do not require that flows from Hells Canyon dam be greater 

than flows that would occur without the existence of the dams, that power generation is not lost because 

the Corps does not require that water be taken out of storage to meet the recommended minimum flow, 

and that new license requirements for the next 30 to 50 years should be based on the reality of the current 

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navigation industry, not the industry that was envisioned when the original license was given to Idaho 

Power. 

Response: Although we understand that the Corps’ recommendation does not call for use of storage 

water to meet the minimum navigation flow, our economic analysis of the release of the minimum flow 

was based on the restriction of Hells Canyon dam peaking operations and the project’s dependable 

capacity. Our staff’s analysis is also based on the realities of the current navigation industry practices on 

the river, which became established during a period when the predominant de facto minimum flow was 

6,500 cfs. 

Comment WQN-31: NPPVA makes a number of comments with respect to draft EIS section 2.2.2, 

Proposed Project Operations, and section 2.3.3, Staff Alternative, and recommends that the analysis 

consider the following points: (1) draft EIS table 1 does not provide minimum and maximum flows for 

the period from 10/1 to 10/20, and this should be corrected. (2) For most of the primary recreation season 

defined by the Forest Service for its Wild and Scenic Snake River Recreation Management Plan, Idaho 

Power would be allowed to maintain a minimum flow of just 5,000 cfs under atypical conditions, 

allowing Idaho Power to operate just as it has for the last 50 years. (3) Section 2.3.3, Staff Alternative, 

indicates that the Staff Alternative includes “navigation target flows to promote safe recreational and 

commercial boating conditions downstream of Hells Canyon dam” among the list of five operational 

changes to Idaho Power’s proposal, but the detailed list of conditions lists only four of the five changes, 

dropping the reference to the navigation target flows. (4) The Staff Alternative gives Idaho Power 

authority to decide for itself when atypical conditions allow it to exceed the 10,000-cfs flow change limit 

or drop below the 6,500-cfs minimum flow, making the real flow variation limit 16,000 cfs and the real 

minimum flow 5,000 cfs. NPPVA states that this is unacceptable, and that Idaho Power’s responses to 

atypical situations must have third-party oversight. (5) Oversight should be provided by the Corps, 

similar to Article 43 of the current license, and recreationists and land owners should be given as much 

advance notice as possible when sudden changes in flow patterns could affect their safety and property. 

(6) draft EIS table 1 does not mention the minimum flow needed to navigate the river below the Snake 

River’s confluence with the Salmon River, and that minimum flow should not fall below 11,500 as 

measured at the McDuff/China Garden Creek gage except in emergency situations. 

Response: As noted in draft EIS table 1 (final EIS table 2) footnote c, the initial date of the fall Chinook 

plan load following restriction varies based on circumstances. After October 1, steady flows for salmon 

spawning are generally above 8,500 cfs. We find the table to be clear without adding an additional line 

for the 10/1 to 10/20 period. Regarding the comment on Idaho Power’s proposed “atypical conditions,” 

we note that the Commission’s license order for the Hells Canyon Project will define the circumstances 

under which Idaho Power may temporarily deviate from operational requirements of the license. We 

modified the text to eliminate the inconsistency between the listing in section 2.3.3 and the bullets that 

follow. We recognize NPPVA’s strong preference for adoption of the Corps’ recommended navigation 

flows; the basis for our decision is presented in section 5.2.2.2, Navigation Target Flow Levels. In the 

Staff Alternative, the13,000-cfs Lime Point minimum flow would be replaced by the Corps’ 

recommended 11,500-cfs minimum flow downstream of the mouth of the Salmon River as measured at 

the Snake River below McDuff Rapids gaging station. 

Comment WQN-32: NPPVA makes a number of comments with respect to draft EIS section 3.3.1.3, 

Navigation, and recommends that the analysis consider the following points: (1) The lower river 

minimum flow of 13,000 cfs at Lime Point should be retained, but the “95 percent of the time” qualifier 

should be dropped because the time frame for compliance is not clear. (2) The 6,500-cfs minimum flow 

below Hells Canyon dam was arrived at without representational input or analysis of boat sizes or loads 

or review of accidents. NPPVA notes that the Corps staff took a short trip with a single jet boat outfitter 

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who did not run trips into the upper river from Rush Creek to Hells Canyon dam, and did not request 

input from other outfitters. (3) NPPVA notes that they became aware of the existence of Article 43 

(provision addressing navigation in the Idaho Power license) during the organization of NPVVA. 

(4) Timed releases of 8,500 cfs were negotiated among Idaho Power, the Corps, and NPPVA, but the 

pulses are difficult to time and do not support flexible schedules for boaters and customers. NPPVA 

notes that between 2001 and 2004, timed releases were intended to support morning travel downstream 

from Hells Canyon and afternoon return. NPPVA states that grounding incidents, differential response 

times, and requirements of individual trips rendered pulses unworkable. (5) The draft EIS text fails to 

mention that during 2005, at the request of the Corps, minimum flows of 8,500 cfs above the Salmon 

River and at least 11,500 cfs at McDuff Rapids were maintained, while power needs were apparently met 

and Idaho Power was profitable. (6) The 8,500-cfs minimum flow was maintained until July 2006 when 

flows varied significantly from flows announced in the Lewiston Idaho Tribune and announcements on 

Idaho Power’s web site, and these inaccurate forecasts and unpredictable flows caused commercial boats, 

passengers, and private boaters to cancel trips. NPPVA states that these inaccurate, unreliable flow 

predictions are unsafe and inexcusable on a navigable waterway in a natural attraction and unacceptable 

at any cost. 

Response: The background information concerning various flow arrangements is noted, but we did not 

modify the text to include those details. This comment is helpful in emphasizing the need for 

predictability and for timely and accurate communication of flow conditions. In final EIS section 5.2.2.2, 

Navigation Target Flow Levels, we describe our recommended navigation plan, which Idaho Power 

would prepare in consultation with the Corps, NPPVA, and other interested parties. Our recommended 

plan includes a number of measures to improve the timeliness and accuracy of flow information to be 

provided by Idaho Power. 

Comment WQN-33: NPPVA makes a number of comments with respect to draft EIS section 3.3.2.6, 

Project Outflows, indicating that : (1) in draft EIS figures 16 to 20, it is unclear why project outflows 

would go above 8,500 cfs in the extremely low and medium-low situation; (2) the extreme low water 

conditions outlined in draft EIS figure 16 should be considered an emergency and provisions should be 

made to address an emergency variance and negotiation of a best flow scenario for all users; (3) in 

medium low conditions shown in draft EIS figure 17, navigation requirements should not be greater than 

8,500 cfs unless flows measured at McDuff/China Garden gage were to fall below 11,500 cfs; (4) 

provision of navigation flows poses no problem at the medium to high water conditions shown in draft 

EIS figures 18-20; and (5) reservoir capacity is not expected to be used for navigation, and flow 

augmentation should not be affected by navigation flow requirements. 

Response: The CHEOPS Model simulations seek to maximize the value of power production, subject to 

the operational constraints that are enumerated in draft EIS appendix C (final EIS appendix D). To the 

extent that outflows exceed 8,500 cfs, it is a result of the combined constraints imposed on the project 

operation. Under the extremely low flow situation, outflows do not exceed 8,500 cfs during the 

navigation season. We note NPPVA’s view that navigation flows should be waived under extremely low 

flow conditions; this would be an appropriate aspect of any 8,500-cfs navigation flow requirement. We 

sought and received clarification from Idaho Power that the provision of navigation flows of 8,500 cfs 

poses no problem related to power generation or dependable capacity impacts under medium-high and 

extremely high water conditions (refer to Idaho Power’s letter to Kimberly D. Bose, Secretary, 

Commission, dated April 25, 2007). We concur with NPPVA’s statement that storage water should not 

have to be used to meet navigation flow targets and that flow augmentation would not be affected by 

navigation flows. 

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Comment WQN-34: NPPVA states that the description of the Corps’ navigation proposal omits that 

when inflow to Brownlee reservoir drops below 8,500 cfs, the average 3-day inflow would be passed at 

Hells Canyon dam. 

Response: The first paragraph of the referenced section 3.3.2.7, Downstream Flows Important to 

Navigation, simply deals with the Corps’ stated flow preferences. The fourth paragraph fully explains the 

Corps’ navigation flow recommendation. 

Comment WQN-35: NPPVA states that draft EIS table 1 should, but does not, show the 13,000 cfs 

minimum at McDuff/China Garden Rapids. NPPVA states that large boats are not a recent practice, as 

asserted by Idaho Power, but have been used since 1910. NPPVA states that reduction of boat size is not 

a workable solution for overall navigation needs. NPPVA notes that the USGS maintained, calibrated, 

and recorded flows at the McDuff and Johnson Bar locations more accurately than Idaho Power does, and 

recommends that the USGS should again resume that responsibility. 

Response: In section 3.3.2.7, Downstream Flows Important to Navigation, we point out that Idaho 

Power modeled the 13,000-cfs minimum flow at Lime Point by specifying a 6,500-cfs release from Hells 

Canyon dam. Draft EIS table 1 (final EIS table 2) summarizes this operating constraint. We acknowledge 

NPPVA’s preference for USGS gage maintenance. Any license issued would require Idaho Power’s 

documented compliance with any flow requirements. We revised section 5.2.2.2, Navigation Target 

Flow Levels, to reflect new information provided by NPPVA and others in its draft EIS comments. 

Comment WQN-36: Idaho Water Users (IWU) (draft EIS, section 3.6.2.5, p 5) notes that any minimum 

streamflows, or bypass flows, called for in the draft EIS (e.g., the continued 100 cfs minimum flow at 

Oxbow) are subordinate to upstream water rights. 

Response: As we state in section 3.3.2.10, Water Users and Water Rights, we have no information to 

suggest that any operational requirements in the Staff Alternative would be inconsistent with existing 

water rights. 

Comment WQN-37: Idaho Power notes that it could not obtain a temporary variance from the Corps if 

the 3-day average Brownlee inflow drops below the required minimum Hells Canyon outflow. Idaho 

Power states that the Corps’ recommendation would require that Idaho Power automatically pass the 3-

day average inflow as the minimum as part of the standard procedure. 

Response: We concur that under the Corps’ recommendation, the release of a flow equal to the previous 

3-day moving average Brownlee reservoir inflow would be automatic when inflow drops below 8,500 cfs. 

To eliminate the potential for confusion, we removed the temporary variance wording in the Staff 

Alternative. 

Comment WQN-38: Idaho Power states that annual flood control operations should be based on a 

mutually agreed to local or regional flow forecast trigger that indicates an imminent risk of flooding. 

Idaho Power notes instances during the spring flood-control operation when Brownlee storage is used for 

energy demand, and because flood-control draft is controlled by the Corps, Idaho Power would have no 

ability to use Brownlee for energy demand during the April 15-April 30 period if the reservoir elevation 

were to remain within one foot of the Corps’ target. Idaho Power notes that occasionally additional 

storage space in Brownlee is needed to protect Idaho Power facilities and areas upstream and downstream 

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during uncontrollable local spikes in flow. 

Idaho Power states that flow augmentation efforts to meet federal flow targets or to aid the migration of 

fish through downstream federal projects are federal responsibilities, not those of Idaho Power customers. 

Idaho Power notes a 2006 example during which property damage and loss of power generation would 

have occurred if the flood control measure described in the Staff Alternative had been in place at that 

time. 

Response: We modified the description of the staff’s flood control measure (section 5.2.2.1, Flood 

Control Storage) to clarify that it would be subject to both local and regional flood control requirements. 

Comment WQN-39: Idaho Power states that although higher minimum flows below Hells Canyon dam 

may improve boatability, this complex issue involves other factors and public interest considerations. 

Idaho Power states that: 

• For the Snake River from Hells Canyon dam to the confluence with the Salmon River, Idaho 

Power proposes measuring minimum boating flows at Johnson Bar (RM 230). This is the 

current point, and the same point adopted in the draft EIS for ramping rates. 

• The 13,000-cfs minimum flow at Lime Point was established for now discontinued barge traffic, 

and no real-time gage exists at Lime Point. Idaho Power notes the real-time gage at McDuff 

Rapids would provide more accurate data for compliance. 

• Distinction should be made between setting minimum boating flows and mitigating recreation 

impacts from ramping rates or the amount of daily fluctuation. Idaho Power notes that higher 

minimum boating flow restrictions are an inappropriate tool to address potential recreation 

impacts from daily fluctuations. Idaho Power notes daily flow fluctuations have been voluntarily 

restricted from 16,000 cfs to 10,000 cfs between June 1 and September 30. Idaho Power has 

proposed to continue this operation, except during emergency conditions that could require up to 

16,000 cfs. 

• The terms, “boatability” and “minimum boating flows” are more specific and should be used 

instead of “navigability” and “minimum navigation flows.” 

Response: Compliance monitoring for the reach above the Salmon River should occur at the Johnson 

Bar gage. We modified the text of the Staff Alternative to indicate that the 8,500-cfs navigation flow 

target recommended by the Corps would be converted to the equivalent flow at Johnson Bar and 

measured there. In the Staff Alternative, we eliminated the 13,000-cfs Lime Point minimum flow in favor 

of the Corps’ recommended 11,500-cfs minimum flow measured at McDuff Rapids. We acknowledge 

the distinction between minimum flows, ramping rate restrictions, and daily stage fluctuation restrictions. 

Both minimum flows and daily stage fluctuation limitations have the potential to influence the 

recreational boating experience. Finally, we understand Idaho Power’s preference for the term “boating,” 

but have elected to continue with our use of the word “navigation.” Our use of the term “navigation” 

does not affect our analysis or conclusions. 

Comment WQN-40: Idaho Power comments that different choices of minimum boating flows affect 

how often low flows occur, which affect costs and benefits. Idaho Power provides additional information 

concerning flow amount, type of year (water availability), models, and flow frequency. 

Response: In section 5.2.2.2, Navigation Target Flow Levels, we included mention of Idaho Power’s 

additional modeling data regarding the effects of the Corps’ recommended navigation flows in 

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conjunction with 237 kaf flow augmentation scenario, and we considered the data in our analysis. 

Comment WQN-41: Idaho Power notes that the loss of generating capacity at the project if Idaho Power 

were required to provide 237 kaf for Flow Augmentation would be a considerable cost. Idaho Power 

notes that a significant loss of peaking capacity at Hells Canyon dam would be associated with an 8,500-

cfs minimum flow, in addition to loss of capacity at Brownlee dam due to the Staff Alternative’s Flow 

Augmentation. Idaho Power includes greater detail of analysis and modeling to address this issue. 

Response: We revised the text of section 5.2.2.2, Navigation Target Flow Levels, to reflect updated 

information on the economic impact of navigation flows as well as the 237-kaf Flow Augmentation. 

Comment WQN-42: Idaho Power states that the section 4(e) authority of the Corps to approve dams and 

structures applies only to structures not yet constructed, not to existing structures, such as Hells Canyon 

dam. 

Response: We revised the text of section 3.10.2.1, Effects of Project Operations on Recreation 

Resources, Navigation Downstream of Hells Canyon Dam, to clarify Corps and Commission 

responsibilities.

Comment WQN-43: The Nez Perce Tribe comments that the 1-foot-per-hour change in river stage 

measured 13 miles downstream of Hells Canyon dam is not protective of tribal cultural sites and 

resources in Hells Canyon, including sand beaches and terraces. The Nez Perce Tribe states additionally 

that this change in river stage during the growing season will not allow riparian vegetation or aquatic 

invertebrates to establish themselves along the riparian corridor. 

Response: In final EIS section 5.2.1, Sediment Augmentation and Monitoring, we revised our draft EIS 

conclusion and added to the Staff Alternative Forest Service condition FS-4, which specifies that Idaho 

Power fund a sandbar maintenance and restoration program consisting of sand augmentation and 

monitoring. We conclude in the final EIS that sand augmentation to restore sandbars could slightly 

increase rearing habitat for juvenile fall Chinook salmon, and potentially reduce losses to archaeological 

resources from beach erosion. Wave action from barges that would be used to deliver sand to the target 

beaches could slightly reduce the net benefit of the sand augmentation program. The Staff Alternative 

also includes acquisition of 49 acres of riparian habitat to mitigate for ongoing project effects (interrupted 

sediment supply, flow fluctuations) on the establishment of sandbar willow within the scour zone, and 

13.2 acres to mitigate for predicted effects (reduced hydrologic support as ramping rates are reduced) on 

riparian vegetation along the shoreline above the scour zone. Regarding effects on invertebrates, we 

adopt a restricted ramping rate that would reduce adverse effects during the fall Chinook salmon rearing 

period, as well as a monitoring plan to evaluate the extent of project effects and implementation of 

additional restrictions, if warranted. Regarding tribal cultural sites, the cultural resources monitoring 

program (in the HPMP) that Idaho Power would develop and implement in consultation with the tribes, 

agencies, and SHPOs would also contribute toward evaluation of project effects in Hells Canyon. The 

HPMP would contain procedures for determining appropriate treatments to resolve adverse effects that 

take the nature of a site's significance into account.

Comment WQN-44: Interior comments that the draft EIS incorrectly states that Granite Creek enters the 

Snake River immediately downstream of Hells Canyon dam. Interior states that Deep Creek is the first 

perennial tributary downstream of the dam, entering from the east (Idaho) side of the Snake River. 

Response: We modified the text in section 3.3.1.1, Surface Water, accordingly. 

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Comment WQN-45: Interior expresses concern that aquatic resources, including invertebrates and fish, 

are not discussed in regard to water quantity issues. 

Response: We evaluated the effects of project operations and measures recommended by stakeholders, 

including effects of the project on the flow regime downstream of Hells Canyon dam, in section 3.6.2.1, 

Effects of Project Operations on Aquatic Resources. We evaluated operational effects on aquatic 

resources in the Oxbow bypassed reach in section 3.6.2.5, Oxbow Bypassed Reach Flows. 

Comment WQN-46: Interior comments that the Commission required Idaho Power to evaluate a broad 

range of operating alternatives for the project in its additional information request (AIR OP-1) that 

included 11 individual and combined operational studies. Interior recommends that FERC provide a 

detailed discussion of what evaluation criteria were used by the Commission to retain or reject any of 

these eleven operating alternatives as licensing alternatives. It recommends that the NEPA document 

reflect a minimum of 6 clear alternatives, each delineated by a distinct operating regime. Interior 

comments that the range of alternatives should include an alternative in which the instantaneous outflow 

from Hells Canyon dam would equal the average daily project inflow from the previous 24-hour period. 

Response: As we describe in section 3.3.2.2, Operational Recommendations and Alternative Evaluation 

Scenarios, the operating scenarios that we requested Idaho Power to evaluate in our additional 

information request were designed to cover the range of operations that we anticipated might be 

recommended based on our review of scoping comments and additional study requests. In order to focus 

our analysis in the draft EIS, we selected a subset of six scenarios, which represent the range of 

recommendations that were filed in response to the REA notice. In our analysis of effects of alternative 

operations on fish habitat, we included figures of wetted area and WUA time series for a smaller subset of 

scenarios, but we included tabular data summaries for all six scenarios for each lifestage and species that 

was evaluated. The scenarios evaluated in the draft EIS included Scenario 1a, in which the instantaneous 

outflow from Hells Canyon dam equaled the average daily project inflow from the previous 24-hour 

period. We did not include each of these operating scenarios as a complete NEPA alternative, since 

matching each operating scenario with different combinations of non-operational measures would result 

in a very large number of alternatives, and a less focused analysis. 

Comment WQN-47: Interior comments that the operating alternatives requested by the Commission in 

the additional information request and analyzed by Idaho Power in their response (AIR OP-1 a through f 

and 2) call for measurement of ramping rates to be within one mile of Hells Canyon dam. Interior states 

that the NEPA document should clearly discuss why this operational requirement was rejected. Interior 

recommends that the NEPA document include at least one alternative where compliance is measured at 

this location. 

Response: In the draft EIS, we evaluated the effects of two alternative ramping rates (2 inches per hour 

and 6 inches per hour) on flow-dependant resources. These evaluations were based on hydraulic and 

habitat simulations performed by Idaho Power in response to AIR OP-1. The 2-inch and 6-inch ramping 

rates included in these scenarios were simulated assuming that compliance would be measured within 1 

mile downstream from Hells Canyon dam. Our analysis compared the effects of these alternative 

ramping rates to Idaho Power’s proposed operations, which were simulated using its proposed 12-inchesper-hour ramping rate as measured at Johnson Bar. Other information that we considered in our analysis 

included an evaluation of ramping rate effects on fish stranding and entrapment that occurred during the 

spring of 2005 (Brink and Chandler, 2006). This report included an evaluation of potential stranding rates 

of juvenile fall Chinook salmon that would occur at alternative ramping rates of 2, 4, 6 and 12 inches per 

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hour as measures at Johnson Bar. Based on the results of Brink and Chandler (2006), we adopted in the 

Staff Alternative a seasonal ramping rate restriction of 6 inches per hour as measured at Johnson Bar, and 

included additional monitoring to evaluate stranding and entrapment that occurs under different 

hydrologic conditions and for stranding and entrapment of bull trout, which was not evaluated in Brink 

and Chandler (2006). 

The ramp rate restriction that we included in the Staff Alternative was based on the analysis of stranding 

rates presented in Brink and Chandler (2006), which was based on rates measured at Johnson Bar. 

However, in the final EIS, we include a recommendation that Idaho Power develop a new combined flow 

and water quality monitoring site within 5 miles of Hells Canyon dam. We adopt this measure because it 

would provide better data about relationships between flow releases and water quality effects, especially 

for effects that do not extend as far downstream as Johnson Bar, such as the DO deficit that currently 

occurs in the late summer and fall months. As part of the plan, we recommend that Idaho Power 

determine the relationship between ramping rates observed at the new site with those that occur at 

Johnson Bar, and determine a new compliance ramping rate that is comparable to the ramping rate 

included in the new license, which may be based on rates observed at Johnson Bar. 

As we discuss in section 5.2.4.2, Flow Fluctuations Outside of the Fall Chinook Spawning and 

Incubation Period, Idaho Power stated during the 10j meeting that accurately measuring flow and 

ramping rate compliance within 1 mile downstream of Hells Canyon dam would not be feasible because 

spillway flow deflectors that would be installed at Hells Canyon dam would direct more energy 

downstream and cause substantial variations in water level that would extend at least 1 mile downstream 

from the dam. Because accurate measurement of river stage is essential for monitoring compliance with 

ramping rates, we conclude that measurement of ramping rate compliance within 1 mile downstream from 

Hells Canyon dam would not be a reasonable option. 

Comment WQN-48: The Umatilla Tribes and the Nez Perce Tribe comment that key CHEOPS model 

assumptions are not described in the draft EIS. They state that it is unclear what the period of record used 

is, or whether observed or modified/adjusted inflows are used. They state that the draft EIS fails to 

consider use of a standardized regional hydro-regulation model, such as GENESYS (NWPCC, 2006) or 

BPA’s HYDSIM, to examine draft EIS flow alternatives, operational changes and cumulative impacts. 

Response: A detailed description of the operations model may be found in the project record. Please 

refer to Technical Report Appendix E.1-4, Project Hydrology and Hydraulics Models Applied to the Hells 

Canyon Reach of the Snake River, Chapter 3, Hells Canyon Complex Operations Modeling in the Final 

License Application. Please note that in appendix C of the draft EIS (appendix D of the final EIS), we 

include Modeled Constraints for Idaho Power Company’s Proposed Operation and Operational 

Alternatives. We also provided an overview of the CHEOPS model on page 58 and 59 of the draft EIS. 

On page 59 of the draft EIS, we noted the period of record used for operations modeling. Please refer to 

Technical Report Appendix E.1.4, Project Hydrology and Hydraulics Models Applied to the Hells 

Canyon Reach of the Snake River, Chapter 2, Development of Inflow Hydrology for Hells Canyon 

Complex Studies, for a detailed description of the inflow hydrology development. We note that historical 

data (i.e., USGS data) were used in developing the inflow hydrology. 

We did not apply a regional hydro-regulation model, because the CHEOPS model is adequate to examine 

the flow alternatives, operational changes, and cumulative impacts addressed in the EIS. We did not 

change the text of the final EIS in response to this comment. 

Comment WQN-49: The Nez Perce Tribe states that the draft EIS inaccurately describes the Nez Perce 

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component of the SRBA settlement. 

Response: We incorporated the Nez Perce Tribe’s suggested changes to final EIS section 3.3.1.4, Water 

Rights. 

Comment WQN-50: NMFS comments that the concept of average daily inflows to Brownlee reservoir 

during the five representative years is a meaningless statistic without describing the frequency of expected 

occurrences. Similarly, NMFS comments that any subsequent discussion regarding the effect of 

operations in each of these “representative years” is meaningless without the context of how often each of 

these cases is likely to occur in the next 30 to 50 years (the duration of the action considered in the draft 

EIS). NMFS states that FERC should modify its analysis to identify the relative frequency of each of the 

representative years. 

Response: The information NMFS requests is not displayed in the draft or final EIS, but does appear in 

the record. We reviewed the record to respond to NMFS comment and developed an estimate of the 

frequency of expected occurrence for each of the five representative years. We added this information to 

final EIS section 3.3.1.1, Surface Water, Brownlee Inflows, table 5. 

Comment WQN-51: Interior comments that the descriptions and simulations in the draft EIS address 

reservoir drawdown only for flood control and flow augmentation for fisheries. Interior states that it is 

also important to display anticipated reservoir drawdowns for power production. Assuming these needs 

are additive, Interior concludes that the negative effect on recreation resources is probably much greater 

than displayed in draft EIS figures 11 through 15. 

Interior also notes that the Brownlee reservoir drawdown is the one significant operational outcome that 

affects recreation resources on BLM lands, and states that the EIS should clearly display how the FERC 

Staff Alternative would affect Brownlee reservoir drawdown during various water years. 

Response: Power production is implicitly included in each scenario, and hence draft EIS figures 11 

through 15 (final EIS figures 12 through 16) already include the effects of power production and there is 

no need to make further adjustments. We did request additional model runs from Idaho Power in a 

conference call on February 8, 2007. These new runs provide an estimate of the combined economic 

effects of flood control, power generation, and flow augmentation on reservoir levels, and this new 

information is reflected in the text of final EIS section 4.2.1, Reduced Benefits Associated with 

Operational Changes. However, we did not request additional information concerning associated effects 

on reservoir drawdown because earlier AIR responses adequately bracketed the range of alternatives, 

including the staff recommendations. 

With respect to the effect on recreation, Brownlee reservoir levels are affected primarily by flow 

augmentation. Draft EIS section 3.3.2.5 and draft EIS figures 11 through 15 (final EIS figures 12 through 

16) present simulated Brownlee reservoir levels under the 350-kaf flow augmentation scenario. These 

simulations provide an approximation of the effects of the 237-kaf flow augmentation scenario included 

in the Staff Alternative, and we did not revise this information in the final EIS. 

B7. SEDIMENT SUPPLY AND TRANSPORT 

Comment ST-1: Idaho Power comments that, in addition to the Swan Falls dam, tributary dams between 

Brownlee and Swan Falls dams also trap sediment, and that sediment transport between Brownlee and 

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Swan Falls dams is limited due to truncation of discharge peaks and reduction of flow volume. Idaho 

Power recommends that staff acknowledge sediment trapping by other tributary dams between Swan Falls 

and Hells Canyon dams. 

Response: We revised the text of section 3.2.1.1, Sediment Transport, to acknowledge the many small 

tributary dams between Brownlee and Swan Falls dams and their contributions to sediment supply and 

transport in the Snake River. 

Comment ST-2: Idaho Power comments that it disagrees with the characterization of downstream water 

and sediment inputs and that there are substantial sediment inputs between Hells Canyon dam and the 

Salmon River. Idaho Power further comments that sediment-size classes vary with different input areas 

and recommends that staff revise the text to reflect differences in loads associated with different sediment 

size classes and the portion cut off by the Hells Canyon Project and to avoid using total loads biased with 

silts and clays to represent sand and larger materials. 

Response: Although there are numerous (but small) water and sediment inputs between the Hells 

Canyon dam and the Salmon River (total contributing area of 75 square miles), the Salmon River is 

clearly the largest at 13,900 square miles. We revised the text on page 81, paragraph 2, in section 3.4.1, 

Affected Environment, to cite the document in which the project study reach downstream of the Hells 

Canyon dam is defined. 

Because the size fractions of gravel, sand, and finer sediment (silt and clay) delivered by tributaries have 

not been measured and therefore are unknown, we did not revise the text of section 3.4.1.1, Sediment 

Budget (Sediment Leaving the Reach, So), regarding different sediment size classes delivered by the 

mainstem Snake River and by the tributaries. 

Comment ST-3: Idaho Power comments that the effect of tributary dams on sediment movement is not 

mentioned and recommends that staff acknowledge other dams on the tributaries between Brownlee and 

Swan Falls dams because these tributary dams trap sediment from the Idaho Batholith that provided a 

large portion of the beach-building sediments to Hells Canyon. 

Response: We revised the text of section 3.4.1, Affected Environment, to acknowledge the many small 

tributary dams between Brownlee and Swan Falls dams that trapped sediment generated by twentiethcentury land disturbance, and that continue to trap sediment. Possible sources of beach-building sediment 

are addressed elsewhere in this document. 

Comment ST-4: Idaho Power comments that the existing language does not adequately characterize 

relative sizes of sediment storage facilities, and recommends revisions to the text that correctly reflect the 

size and significance of the tributary projects upstream of the Hells Canyon Project. 

Response: We revised the text of section 3.4.1.1, Sediment Budget (Sediment Supply at 

Weiser, Si), to emphasize that the tributary basin size (not the tributary reservoir volume) 

determines the relative significance of sediment trapping by tributary dams with respect to 

sediment trapping by mainstem dams. 

Comment ST-5: Idaho Power comments that the 220,000 tons per year of unmeasured sand and gravel 

should be 220,000 tons per year of unmeasured total sediment bedload. Idaho Power recommends 

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revisions to the text to accurately reflect that the 220,000 tons per year represents unmeasured total 

sediment bedload. 

Response: We revised the text of section 3.4.1.1, Sediment Budget (Sediment Supply at 

Weiser, Si), to emphasize that the unmeasured bedload comprises sand and gravel. 

Comment ST-6: Idaho Power recommends clarification of assumptions used to calculate the total 

sediment load, and revisions as necessary based on staff’s assumptions drawn from Mussetter (2006). 

Response: We revised the text of final EIS section 3.4.1.1, Sediment Budget (Sediment Supply 

at Weiser, Si); table 10; and figure 22 to reflect new information provided by Idaho Power (2006: 

Comments on draft EIS, November 2006), which allows us to calculate total suspended load 

using the assumptions reported by Mussetter (2006). 

Comment ST-7: Idaho Power recommends corrections to clarify the sediment sampling methods and the 

sampling results used to evaluate sediment composition in the three reservoirs. Idaho Power also 

comments that concerns in the Wilcock (2002) reference have already been addressed, and that their 

comments are no longer appropriate. Idaho Power recommends staff review information to determine if 

the reference to Wilcock et al. (2002) is appropriate in the context of sediment sampling in Brownlee 

Reservoir. 

Response: We revised the text of section 3.4.1.1, Sediment Budget (Sediment Leaving the 

Reach, So), to provide additional detail regarding sediment sampling techniques and the 

complex depositional environment described by Wilcock et al. (2002) from which these samples 

were obtained. The characterization of the depositional environment at the inlet to Brownlee 

reservoir is still valid. 

Comment ST-8: Idaho Power recommends that staff review values used to calculate area-normalized 

sediment yield calculated from measurements at Weiser. 

Response: We revised the text of section 3.4.1.1, Sediment Budget (Sediment Leaving the 

Reach, So), to reflect revisions to the range in area-normalized sediment yield as a result of new 

information. 

Comment ST-9: Idaho Power comments that estimates of total sediment and sand loads should not be 

used to estimate spawning gravel-sized material loads. Idaho Power recommends that the estimates of 

sand yields at Weiser not be used in the final EIS to estimate gravel loads. 

Response: We did not revise the text of section 3.4.1.1, Sediment Budget (Sediment Supplied 

to Tributaries, St), because sand loads were not used to estimate gravel loads. All 

measurements of sediment loads entering Brownlee reservoir are based on suspended-load 

measurements at Weiser, and Idaho Power’s assumption that bedload (sand and gravel) is 15 

percent of the measured suspended load. The gravel and sand portions were not differentiated 

based on the available information. 

Comment ST-10: Idaho Power asserts that the mineralogical signature of fine sediment collected 

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upstream of the Hells Canyon Project is distinct from the signature of fine sediment collected within the 

reservoirs and from the mainstem downstream of Hells Canyon dam. Idaho Power recommends that staff 

reexamine the mineral provenance data and discussion to evaluate the validity of the provenance 

evidence, paying particular attention to the component of K-spar. 

Response: We revised the text of section 3.4.1.2, Beaches and Terraces (Beaches), to clarify staff’s 

interpretation of data presented in the most recent provenance study (CH2M HILL, 2006). 

Comment ST-11: Idaho Power requests that staff confirm the decrease in number and area of sandbars 

reported by previous studies because these data conflict with results reported by Grams and Schmidt 

(1991, 1999a,b). In addition, Idaho Power comments that the terms “fluctuate,” “increase,” and 

“decrease” are used imprecisely, and misrepresent measured sandbar conditions. Idaho Power requests 

that staff confirm the use of the terms “fluctuate,” “increase,” and “decrease” in the final EIS. 

Response: We revised the text of section 3.4.1.2, Beaches and Terraces (Beaches), to properly reflect 

the reduction in the number and area of sandbars reported by Grams (1991), Grams and Schmidt (1999b), 

and Miller et al. (2003a). 

Comment ST-12: Idaho Power comments that it is unable to verify a reference to percent decrease in 

total sandbar area in Grams and Schmidt (1999a,b). Idaho Power recommends that the reference be 

verified and include any caveats that modify the quote. 

Response: We revised the text of section 3.4.1.2, Beaches and Terraces (Beaches), to cite Grams (1991) 

and include discussions that relate sand loss to measurement precision used by the author.

Comment ST-13: Idaho Power comments that it disagrees with the bar thickness used by Wilcock et al. 

(2002). It also disagrees with the use of historic sandbar loss rates, concluding that current loss rates are 

much less. Idaho Power recommends that the most recent data be used to estimate the rate of sand loss 

from sandbars in the Hells Canyon reach and that the most recent data be used to predict future sandbar 

areas. 

Response: The range in average sandbar thickness of 1 to 3 meters used by Wilcock et al. (2002) and 

adopted by staff is less than the maximum thickness of 2 to 4 meters measured by Idaho Power at four 

sandbars. Staff considers the range of 1 to 3 meters assumed by Wilcock et al. (2002) to be reasonable, 

given that: (1) sandbar depths have been measured at only four beaches, (2) a correlation between 

sandbar size and thickness has not been established, and (3) the thickness of pre-project sandbars is 

unknown. In addition, the range in the rate of sand loss estimated by Wilcock et al. (2002) represents 

historical losses of sand volume (or mass) and was not used to predict future losses of sandbar areas. 

Therefore, we did not revise the text of section 3.4.1.2, Beaches and Terraces (Beaches), in response to 

this comment. 

Comment ST-14: Idaho Power comments that it is Salt Creek Bar, rather than Pine Bar, that experienced 

only erosion. Idaho Power requests that “Pine Bar” be replaced with “Salt Creek Bar.” 

Response: We revised the text of section 3.4.1.2, Beaches and Terraces (Beaches), to replace “Pine Bar” 

with “Salt Creek Bar.” 

Comment ST-15: Idaho Power comments that the language in the draft EIS should be put in context 

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using the assumptions made in the stability analysis and field observations. It also disagrees with the 

statement that instability at Fish Trap Bar is expected. Idaho Power recommends that staff review the 

basis for statements regarding sandbar instability in light of analytical assumptions and field observations. 

Response: We revised the text of section 3.4.1.2, Beaches and Terraces (Beaches), to clarify results of 

the sandbar stability analysis and to indicate where model assumptions are conservative. Although 

Parkinson et al. (2003b, 2005b) conclude that slope failure is not expected, results of the stability analyses 

(which incorporated several conservative assumptions) show the contrary, as reiterated by Idaho Power in 

these comments. Staff defer to common engineering practice, which assumes that slopes are unstable 

until a more-representative (i.e., less conservative) model shows otherwise. 

Comment ST-16: Idaho Power comments that both overpredicted and underpredicted sand mobility 

should be discussed, not just underpredictions of mobility. To counterbalance this discussion, Idaho 

Power recommends that staff acknowledge cases where sand mobilization did not occur, as predicted by 

modeling. 

Response: We revised the text of section 3.4.1.2, Beaches and Terraces (Beaches), to indicate that 

modeling underpredicted and overpredicted sand mobilization measured in the field. 

Comment ST-17: Idaho Power comments that instability may be due to either flood flows or Idaho 

Power’s load following operations, and that additional assumptions used in the analysis are not clarified. 

Idaho Power states that this language does not distinguish between instability caused by Idaho Power 

operations and that caused by flood conditions. Idaho Power recommends that the final EIS clarify when 

instability is produced under operational flows controlled by Idaho Power or under flood flows where 

Idaho Power has less control due to hydrologic and regulatory constraints. 

Response: We revised the text of section 3.4.1.2, Beaches and Terraces (Terraces), to distinguish 

between project-related effects and non-operational effects on terraces. 

Comment ST-18: Idaho Power comments that it did not directly determine bed mobility from MIKE11 

results. Idaho Power recommends that the final EIS explain the combination of analyses used to evaluate 

incipient motion. In addition, Idaho Power comments that processes other than river flows may 

contribute to gravel movement. Idaho Power recommends that the final EIS acknowledge that spawningsize gravels can be mobilized by processes other than flows, such as spawning activity and boat wakes. 

Finally, Idaho Power comments that it has not explicitly stated a threshold discharge for gravel mobility. 

It states that its threshold of motion analysis uses a range of critical dimensionless shear stress values. 

Idaho Power recommends deletion of references to threshold discharge based upon Idaho Power’s model. 

Response: We revised the text of section 3.4.1.3, Spawning Gravel, to explain additional methods used 

to estimate gravel mobility and to report the range of bed area estimated to be mobile over the assumed 

range of critical dimensionless shear stress. Gravel mobilization during flows at or less than 30,000 cfs, 

as indicated by the scour chains, supports the model results, but could also be partly due to spawning 

activity (as implied by the location of scour chains in spawning beds). Boat wakes are not considered a 

likely mechanism for bedload transport because their influence is limited to disturbance of the armor layer 

in the near-shore environment. 

Comment ST-19: Idaho Power comments that no citations are provided to substantiate the statement that 

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beach erosion adversely affects aquatic resources. Idaho Power recommends either removal of the 

statement or citation of literature. 

Response: We revised the text of section 3.4.2.1, Effects of Project Operations on Sediment Transport 

(Beach and Terrace Erosion), to emphasize that it is the loss of beaches and sandbars (not necessarily the 

type of erosion causing this loss) that results in a reduction in the quantity of gently sloping shoreline 

habitat. 

Comment ST-20: Idaho Power comments that sand mobility was over- and under-predicted, and that 

both conditions should be presented, not just one. 

Response: We revised the text of section 3.4.2.1, Effects of Project Operations on Sediment Transport 

(Beach and Terrace Erosion), to reflect the conservative assumptions used in the sandbar stability 

analysis and to indicate that areas of sand mobility measured in the field were over- and under-predicted 

by the model.

Comment ST-21: Idaho Power comments that its stability analyses are being taken out of context 

because it did not analyze ramping rates, but assumed instantaneous drawdown. It also comments that the 

other assumptions of its analyses are not fully clarified. Idaho Power recommends that the final EIS 

explicitly state the analyzed failure mechanisms and assumptions, and that instantaneous drawdown is not 

extrapolated to ramping rates. 

Response: We revised the text of section 3.4.2.1, Effects of Project Operations on Sediment Transport 

(Beach and Terrace Erosion), to indicate that effects of ramping rates were not evaluated by Idaho Power.

Comment ST-22: Idaho Power comments that fine sediment is known to have adverse effects on 

spawning gravel, contradictory to language in the draft EIS. It also states that gains in spawning gravel 

mobility, created by increased fine sediment content of the bed, are offset by the effects of fine sediments 

on spawning gravels. Idaho Power recommends that staff revisit Wilcock and Kenworthy (2002) and reinterpret their results with respect to positive and negative effects on spawning gravel movement and 

quality. 

Response: We revised the text of section 3.4.2.1, Effects of Project Operations on Sediment Transport 

(Spawning Gravel), to distinguish between the detrimental effects to salmon redds caused by excessive 

sand content and insufficient sand content. 

Comment ST-23: Idaho Power comments that it has not established 30,000 cfs as a threshold for 

sediment mobility. It states that mobility is a function of the selected critical dimensionless shear stress 

value. Idaho Power recommends that either the value of 30,000 cfs not be discussed in the context of a 

mobility threshold, or that specific locations be cited where this threshold applies. Idaho Power further 

comments that no basis has been provided to select 22,200 cfs as the threshold for gravel mobilization, 

and that mobilization has not been well-defined. Idaho Power recommends that a basis of selection be 

provided, and that the support of the cited references (O’Connor [2002] and Wilcock et al. [2002]) be 

explained as it pertains to the final license application. 

Response: The threshold flow for sediment mobility was addressed in a previous response. The 

references to O’Connor (2002) and Wilcock et al. (2002) are no longer relevant, and they have been 

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deleted. We revised the text of section 3.4.2.1, Effects of Project Operations on Sediment Transport 

(Spawning Gravel), to clarify the basis for selecting 22,200 cfs for comparison of bed mobilization under 

the various operational scenarios. 

Comment ST-24: Idaho Power comments that the draft EIS does not specify either the areas of gravel 

mobilized at 22,200 cfs, or their significance. Idaho Power recommends that the final EIS supply an 

analysis showing that a significant area of spawning-sized gravel is mobilized at 22,200 cfs. Idaho Power 

further comments that the occurrence of gravel mobilizing flows (22,200 cfs) would not be reduced by as 

much as 10 percent for extreme high water years. It also comments that boat wakes significantly 

contribute to sand and gravel mobilization. Idaho Power recommends that the language be modified to 

reflect 3 percent rather than 10 percent reduction in flow recurrence, and that the impact of boat wakes be 

considered. 

Response: The draft EIS cites Parkinson et al. (2003a), which provides details of the gravel mobility 

study. We revised the text of section 3.4.2.1, Effects of Project Operations on Sediment Transport 

(Spawning Gravel), to correctly indicate that the occurrence of 22,200-cfs flows would be reduced 4 

percent rather than 10 percent for the indicated operational scenarios. The impact of boat wakes on gravel 

mobilization was addressed in the response to the comment on page 88, paragraph 5. 

Comment ST-25: Idaho Power has proposed a gravel monitoring plan and recommends that FERC 

review and adopt the plan. 

Response: We revised the text of section 3.4.2.2, Sediment Augmentation and Monitoring, to include a 

discussion of the proposed gravel monitoring plan. 

Comment ST-26: Idaho Power comments that Swan Falls dam is not immediately upstream of Brownlee 

reservoir, and that multiple other tributary dams trap sediments. Idaho Power recommends that this 

language be rewritten to explicitly state distances and dams referred to as “these dams.” 

Response: Swan Falls dam is the nearest mainstem dam upstream of Brownlee reservoir. We revised the 

text of section 3.4.3, Cumulative Effects, to clarify the areas from which Swan Falls dam and other 

tributary dams have historically trapped sediment. 

Comment ST-27: Idaho Power comments that the values stated in section 3.4.4, Unavoidable Adverse 

Effects, are over 50 years, rather than per year. Idaho Power recommends modifying the sentence to 

reflect a duration of 50 years. 

Response: We revised the text of section 3.4.4, Unavoidable Adverse Effects, to reflect a duration of 50 

years, rather than annually.

Comment ST-28: Idaho Power comments that the statement that spawning-sized gravel comprises 10 

percent of the sediment trapped in project reservoirs each year is unsupported. It also comments that 

current hydrology is unable to mobilize gravel-size particles between Swan Falls dam and the Hells 

Canyon Project. Idaho Power recommends that the final EIS present supporting data for this 10 percent 

value. 

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Response: We revised the text of section 3.6.2.14, Sediment Augmentation, to clarify that 10 percent of 

the combined coarse sand and gravel component (not 10 percent of the total sediment load) is likely 

spawning-size gravel. Assuming the coarse fraction is 15 to 25 percent of the total sediment load, 

spawning-size gravel would amount to 1 or 2 percent of the total load, which we consider reasonable. As 

noted above, we dropped the staff-proposed pilot gravel augmentation study in favor of Idaho Power’s 

proposed fall Chinook spawning and gravel monitoring plan. If the fall Chinook spawning and gravel 

monitoring study indicates that the quantity or quality of spawning habitat may be limiting the production 

of fall Chinook at some point in the future, appropriate measures to address this impact would be 

developed and implemented at that time. 

Comment ST-29: Idaho Power disagrees with the range of values given in draft EIS table 8 for tons of 

sand and gravel trapped in project reservoirs annually. 

Response: We revised the text of section 3.6.2.14, Sediment Augmentation, to reflect the values of total 

sand and gravel trapped in the three project reservoirs, as shown in final EIS table 10. The estimated 

value of 10 percent for spawning-size gravel was addressed in a previous response. 

Comment ST-30: Interior comments that the draft EIS fails to analyze the effects of the lack of gravel 

transport on species other than fall Chinook, or where gravels migrate to when they are mobilized 

downstream of Hells Canyon dam. In order to evaluate the potential changes in aquatic habitat that might 

occur through time, Interior states that it is important to know whether gravels and other coarse sediments 

move out of the project area or are merely moving to the thalweg of the Snake River channel. Interior 

comments that the draft EIS also fails to consider how extreme high flows (between 50,000 and 90,000 

cubic feet per second) alter habitat for sturgeon, bull trout, redband trout, and other resident fishes, or the 

role of stochastic flow events in tributaries on the bed material in the main stem of the Snake River. 

Response: Substrate monitoring included in the proposed gravel monitoring plan addresses the 

movement of spawning gravel from tributary sources to the thalweg. The influence of stochastic 

sediment inputs from tributaries on the channel morphology is addressed throughout section 3.4.1, 

Affected Environment. Since the project does not alter extreme high flow events, their effects on aquatic 

species has not been evaluated. Species other than fall Chinook salmon spawn primarily in tributaries to 

the Snake River, and are likely little affected by the reduced supply of sediments from upstream of Hells 

Canyon dam. Although Pacific lamprey also spawn and rear primarily in tributaries, we modified the text 

in section 3.6.3.1, Pacific Lamprey, to note that the reduced supply of fine sediments likely reduces the 

quantity and quality of potential habitat for Pacific lamprey in the mainstem Snake River downstream of 

Hells Canyon dam. 

Comment ST-31: Idaho Power states that there is no evidence that spawning gravel below Hells Canyon 

dam is deficient or in need of augmentation, and recommends that FERC withdraw the staff-proposed 

pilot gravel augmentation program. Idaho Power notes that during each year of spawning surveys, new 

spawning areas are being used and some areas that were heavily used in past years see little or no use. In 

addition, Idaho Power reports that neither Idaho Power nor the FWS have noted significant 

superimposition of redds during their weekly aerial and ground surveys of spawning sites. As an 

alternative, Idaho Power filed a fall Chinook spawning and gravel monitoring plan with its draft EIS 

comments, which it asks FERC staff to consider as part of its license application. 

The Forest Service comments that the volume of gravel that staff recommends be deposited during the 

pilot gravel study is not likely to be sufficient to cause an increase in the amount of spawning habitat, and 

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the amount of increase of turbidity would be imperceptible. ODFW comments that the total flux of 

coarse sediment within the Snake River at its confluence with the Salmon River is currently between 3 

and 7 percent of what it would be without the three dams of the Hells Canyon Project. Without 

augmentation of coarse-grained sediment downstream of Hells Canyon dam, ODFW states that the loss of 

sand and gravel bars would continue to adversely affect aquatic and riparian habitat. However, ODFW 

questions the probability of augmented sediment reaching targeted spawning sites due to the size of the 

river, the magnitude of the high flows, the distance of the augmentation site from spawning sites, and the 

relatively small amount of gravel proposed to be augmented in the pilot project. ODFW supports the 

general requirement to monitor erosion, substrate, and gravel, but states that much more detail is needed, 

including the actions that would be implemented should monitoring show an adverse effect or trend. 

Response: We revised the text of section 3.4.2.2, Sediment Augmentation and Monitoring, to reflect 

Idaho Power’s proposed fall Chinook salmon spawning and gravel monitoring plan. We adopt Idaho 

Power’s plan as part of the Staff Alternative instead of the pilot gravel augmentation study that we had 

recommended in the draft EIS. 

Comment ST-32: NMFS states that the annual loss of 22,700 to 90,800 tons of spawning-sized gravels 

to the Snake River is a serious threat to mainstem spawning areas, especially those nearest to Hells 

Canyon dam. NMFS comments that the threat to spawning habitat in these areas is sufficient to warrant 

physical and biological monitoring of the habitat to ensure that the quality and quantity of this habitat 

persists over time. NMFS comments that FERC should consider their recommendation to monitor 

spawning areas downstream of the project to be within the scope of section 10(j), since the monitoring is 

integral to ensuring that the conservation value of downstream spawning habitat remains adequate during 

the term of the license. It states that evaluating spawning habitat every 5 years is needed to determine the 

cause of any decline that is observed so that suitable steps can be taken. 

Response: We reconsidered our position on this measure, and we concur that measure NMFS-7 is a valid 

10(j) recommendation. We also adopted the fall Chinook salmon spawning and gravel monitoring plan 

proposed by Idaho Power, which includes incubation monitoring at 5-year intervals, consistent with the 

NMFS recommendation. 

Comment ST-33: The Forest Service comments that the draft EIS inaccurately characterizes spawning 

habitat conditions downstream of Hells Canyon dam as being “of very high quality.” The Forest Service 

notes that this statement conflicts with the statement that DO concentrations never meet spawning criteria 

in the fall (draft EIS pg 266). 

Response: Our statement on page 208 of the draft EIS referred to metrics of spawning gravel quality 

reported by Groves and Chandler (2003). Their evaluation of four commonly used metrics of spawning 

gravel quality (percent fines, geometric mean diameter, Fredle Index, and apparent velocity) indicated 

that survival to emergence in the upper Hells Canyon reach (upstream of the Salmon River) likely 

exceeds the survival to emergence downstream of the Salmon River, and that survival to emergence at 

both locations likely exceeds that in the Hanford Reach in the Columbia River. More recent redd 

monitoring conducted by Groves et al. (2006) in the Hells Canyon reach indicated that intragravel DO 

exceeded 8 ppm throughout the incubation period, and the mean survival rate of eyed eggs planted in 

artificial redds in the Hells Canyon reach averaged 89 percent in 2003–2004 and 84 percent in 2004–

2005. Regardless of these findings on the current quality of spawning and incubation habitat in the Hells 

Canyon reach, we adopted Idaho Power’s proposed fall Chinook spawning and gravel monitoring plan. 

This measure would help assess whether any adverse effects that occur in the future warrant 

implementing measures to protect or improve the quantity or quality of spawning habitat. 

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Comment ST-34: The Umatilla Tribes support the pilot gravel augmentation and monitoring program 

adopted by FERC staff in the draft EIS, and concur with the FERC staff that unwashed gravel, as long as 

it is free of hydrocarbons and other contaminants, would be appropriate for supplementing gravel areas 

and to raise turbidity levels to increase juvenile fall Chinook survival. However, the Umatilla Tribes note 

that FERC staff rejected the proposal for sand augmentation for fall Chinook spawning and rearing areas 

and to protect tribal cultural resource sites below the project that are now affected by the project. Other 

than costs to Idaho Power, they state that the draft EIS does not provide justification for why sand 

replenishment should not be undertaken as well as gravel replenishment, stating that both are necessary to 

increase fall Chinook habitat quantity and quality. The Nez Perce Tribe provides cautious support for the 

pilot gravel augmentation and monitoring program, but states that it is imperative that this proposal be 

further fleshed out in consultation with the Nez Perce Tribe and state and federal resource agencies. The 

Nez Perce Tribe states that it conducts a fall Chinook supplementation program in the Snake River below 

the Hells Canyon Project, and gravel augmentation needs to be coordinated with this program. AR/IRU 

comment that they are pleased that FERC is proposing to require Idaho Power to undertake a gravel 

augmentation pilot study, but they believe that the proposed program is too limited to show any 

meaningful results. AR/IRU also state their position that project effects on spawning gravel must be fully 

mitigated. 

Response: As noted previously, we abandoned the pilot gravel augmentation study that we 

recommended in the draft EIS and replaced it with Idaho Power’s proposed fall Chinook spawning and 

gravel monitoring study. This program should provide sufficient information to determine whether the 

quantity or quality of spawning habitat is decreasing and may be limiting the productivity of the fall 

Chinook salmon population. If this monitoring program indicates that the quantity or quality of available 

spawning habitat limits spawning and incubation success of fall Chinook salmon, then appropriate 

measures to address that effect can be developed. As we discussed in the draft EIS, because of the 

relatively high gradient and confined stream channel in the upper Hells Canyon reach, we conclude that 

the potential for increasing rearing habitat through fine sediment augmentation in this reach is very 

limited. 

B8. WATER QUALITY 

General 

Comment WQL-1: Idaho Power comments that the draft EIS does not reflect current water quality 

standards, and it specifically refers to changes that were approved by Oregon and Idaho since the TMDL 

was written but are not presented in the draft EIS. Idaho Power recommends that the final EIS describe 

current state water quality standards. 

Response: We revised the referenced table and text of section 3.5, Water Quality, to incorporate Idaho 

and Oregon water quality criteria that were approved by EPA after the TMDL was written. 

Comment WQL-2: Idaho Power agrees that water quality conditions in the Snake River basin are 

influenced by a wide range of natural and anthropogenic sources, but states that it is incorrect to assume 

that project impacts may be understood only by evaluating the entire Snake River basin. Idaho Power 

comments that it is possible to examine actual, discrete project impacts and tailor appropriate mitigation 

to address those impacts while acknowledging the effects of other water developments. Idaho Power 

notes that it is confident that a common understanding of project impacts on water quality and appropriate 

mitigation measures will result from its ongoing discussions with IDEQ and ODEQ in the water quality 

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certification process and recommends that FERC coordinate its review with the two states to ensure 

consistency. 

Response: We recognize that it is possible to examine discrete project impacts and tailor appropriate 

mitigation of those impacts. However, to properly assess benefits of the measures that have been 

proposed to address project impacts, they must be considered in the context of other past, present, and 

future actions that affect water quality and water quality-dependant resources. 

Comment WQL-3: Interior comments that the draft EIS stated that ODEQ (2005) reports coliform 

bacteria within the range of existing criteria, and it references a report that states that coliform bacteria 

have been detected in very high concentrations in the Boise River near its confluence with the Snake 

River. Interior recommends that the EIS include Idaho’s assessment of coliform bacteria in the Snake 

River and consider using Escherichia coli (E. coli) criteria alone since it is more strongly correlated with 

swimmer’s gastrointestinal illnesses than is coliform bacteria. 

Response: We revised the text in section 3.5.1.7, Coliform Bacteria, to reflect this new information for 

the Snake River. 

Comment WQL-4: The State of Idaho comments that the draft EIS includes an analysis of water quality 

issues and staff’s recommendations that address the impacts of the project on water quality within and 

downstream of the project. The State of Idaho and ODEQ comment that water quality certification will 

be required by both the state of Oregon and the state of Idaho prior to issuance of a new FERC license, 

and that any license issued for the project must incorporate any conditions accompanying these water 

quality certifications. 

Response: We acknowledge that the Idaho and Oregon water quality certifications will include 

conditions that they deem necessary to address violations of water quality standards. The final EIS 

evaluates Idaho Power’s revised proposal with respect to water quality measures, as described in its 

January 31, 2007, application for water quality certification. 

Comment WQL-5: The Shoshone-Bannock Tribes comment that it appears doubtful that Idaho Power’s 

proposal or the Staff Alternative would satisfy applicable water quality standards, based on the evidence 

discussed in the draft EIS. The Shoshone-Bannock Tribes recommend that FERC reconsider its analysis 

of water quality impacts and require additional mitigation that would result in compliance with state water 

quality standards downstream of the project and within project reservoirs. 

Response: Many factors contribute to the water quality in the project area and the Snake River 

downstream of Hells Canyon dam, and we note that Idaho Power should not be held responsible for water 

quality degradation caused by other parties. Therefore, even if Idaho Power implements measures that 

fully compensate for the project’s adverse water quality effects, some applicable water quality criteria 

may not be satisfied. Since the draft EIS was issued, new information has become available regarding 

both adverse effects caused by the project and the efficacy of potential water quality measures. We 

revised the draft EIS to discuss this new information and have revised our recommendation. In the final 

EIS, the Staff Alternative includes the following recommendations: 

• Develop a DO enhancement plan designed to determine the project’s DO load allocation, 

evaluate the effectiveness and feasibility of potential measures, and implement Commissionapproved measures (see section 5.2.3.1, Dissolved Oxygen Measures). 

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• Implement Idaho Power’s Temperature Adaptive Management Plan that would (1) identify 

the project’s responsibility for elevated temperatures downstream of Hells Canyon dam, (2) 

include an evaluation of potential measures to satisfy this responsibility, and (3) identify any 

appropriate measure(s) for implementation (see section 5.2.3.2, Water Temperature 

Measures). 

• Continue preferential use of the upper spillway gates at Brownlee dam; install spillway 

deflectors at Hells Canyon and Brownlee dams; and evaluate, select, and implement TDGabatement measures for Oxbow dam (see section 5.2.3.3, Total Dissolved Gas Abatement). 

• Develop and implement an operational compliance and water quality monitoring plan to 

document the compliance with the TMDL load allocations, appropriate pollution-trading 

requirements, and water quality standards (see section 5.2.3.4, Water Quality Monitoring). 

Comment WQL-6: Interior comments that pages 144 and 147 of the draft EIS refer to measures that 

Idaho Power proposed in its final license application and in subsequent discussions with the respective 

state water quality agencies. The measures discussed with the states of Idaho and Oregon, such as adding 

a TDG abatement structure at Brownlee dam, are not consistently acknowledged or discussed in the draft 

EIS. Interior recommends that the EIS include a clear discussion of the water quality measures that were 

included in the preferred alternative for the project. 

Response: We revised the text of the final EIS to clarify Idaho Power’s proposal to FERC, which 

includes the measures specified in its January 31, 2007, revised application for water quality certification. 

Temperature 

Comment WQL-7: Interior comments that the EIS should provide all available information about 

naturally occurring stream temperatures in our analysis of the proposed action on water temperatures. 

Response: We provided monthly average water temperatures for inflows to Brownlee reservoir, outflows 

from Hells Canyon dam, and pre-project temperatures measured at the site of Brownlee dam in draft EIS 

figure 25 (final EIS figure 26). This is sufficient data on which to base the staff’s analysis. Comparing 

outflow to inflow temperatures provides an understanding of the change in water temperature as flow 

passes through the project, and of how current outflow temperatures compare to those that would exist 

without the project in place. 

Comment WQL-8: Idaho Power comments that the statement “...although some tributaries with dams a 

short distance upstream of the confluence with the Snake River (e.g., the Owyhee River) are relatively 

cool (table 16)” on draft EIS page 105 is misleading. Idaho Power also comments that incomplete or 

incomparable data sets in table 16 could lead readers to erroneously conclude that the Anatone location is 

cooler than upstream locations. Idaho Power recommends revising table 16 and the accompanying 

narrative by incorporating the additional temperature data that it provides for the Owyhee and Malheur 

rivers and including the number of individual values and period(s) of record that were used to calculate 

the summary information contained in the table. 

Response: Our primary objective for including table 16 in the draft EIS (table 18 in the final EIS) was to 

use as much of the available data as practical to provide an overview of the conditions for flow, water 

temperatures, and phosphorus loading for sites throughout much of the basin. We revised the footnotes to 

the referenced table and associated text to incorporate the maximum temperature data provided by Idaho 

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Power for the mouths of the Owyhee and Malheur rivers and indicate that the temperature data are not 

directly comparable because the data were not collected over the same period for all sites. We did not 

incorporate the periods of record in the table because many of the sites have different periods of record 

and data gaps. As a result, adding this information would be of little value for readers. 

Comment WQL-9: Idaho Power comments that the statement “... in early spring of the wet year of 

1997, Brownlee reservoir was drawn down to an elevation of approximately 600 feet for flood-control 

purposes” on page 113 of the draft EIS is incorrect. Idaho Power states that the reservoir was drawn 

down approximately 100 feet to elevation 1,976 feet mean sea level (msl). 

Response: We revised the text of section 3.5.1.2, Temperature, as recommended. 

Comment WQL-10: Idaho Power states there is no scientific basis for concluding that springtime 

temperatures are cooler than natural conditions because of project operations. Idaho Power acknowledges 

that springtime temperatures of water released from Brownlee reservoir are cooler than contemporary 

inflowing water temperatures, but comments that contemporary inflowing temperatures do not represent 

“natural” conditions because the natural thermal regime was significantly altered due to major upstream 

storage and diversion projects developed during several decades prior to construction of the project. 

Idaho Power recommends that FERC delete speculative statements about springtime temperature effects 

of the project. 

Response: As noted in this comment, comparing the temperature of flows into Brownlee reservoir with 

concurrent downstream temperatures does not represent the change in temperature from natural 

conditions. However, this approach does provide a reasonable estimate of the effect of the project on 

downstream water temperatures given current, present day conditions. We revised the text of section 

3.5.2.4, Water Temperature, to clarify this point, and we discuss Idaho Power’s estimate of the historic 

temperature regime. 

Comment WQL-11: Interior comments that section 3.5.2.1, Effects of Project Operations on Water 

Quality, discusses water temperature in Brownlee reservoir and outflows from Hells Canyon dam, but 

does not analyze their importance from a biological perspective. It further notes that restoring the river’s 

thermal regime as close as possible to pre-impoundment conditions is important to the biota living in the 

Snake River downstream from the project. Interior credits the draft EIS with discussing how proposed 

operations would result in higher than normal winter temperatures and lower than normal summer 

temperatures, along with discussing the estimated amount of time that the TMDL temperature target 

would be exceeded. Interior comments that the draft EIS does not, however, discuss how altered 

temperatures would affect beneficial uses such as coldwater biota or provide a scenario for achieving 

temperatures that more closely mimic natural cycles. Interior requests that the EIS be revised to more 

completely address the impact of altered temperatures on invertebrates and fish, and provide an 

operational alternative that attempts to more closely mimic the natural temperature cycles. 

Response: The primary focus of our discussion of water temperatures in section 3.5.2.1 of the draft EIS, 

Effects of Project Operations on Water Quality, pertains to water quality, not effects on beneficial uses. 

In the draft EIS, we discussed the effects of water temperatures on fish and invertebrates in section 

3.6.2.1, Effects of Project Operations on Aquatic Resources and section 3.6.2.4, Temperature Control. 

Our analysis indicated that delayed warming caused by the project likely reduces the growth rate of fall 

Chinook salmon fry during the spring months, and delayed cooling may delay fall Chinook salmon 

spawning and reduce gamete viability. We amended the EIS to expand on this discussion, which now 

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includes a discussion of the potential effects of altered water temperatures on white sturgeon and bull 

trout. We also added a discussion of Idaho Power’s proposal, filed with the Commission on April 26, 

2007, to implement a Temperature Adaptive Management Plan that addresses the project’s thermal load 

allocation. As described in section 5.2.3.2, Water Temperature Measures, implementing this plan could 

provide substantial benefits to fall Chinook salmon and other aquatic resources. We therefore conclude 

that Idaho Power’s adaptive management program for temperature is warranted and would be worth the 

cost. We estimate the cost at $452,000 annually. 

Regarding a temperature control structure, we conclude that installing such a structure is not warranted. It 

carries a substantial cost, yet could have potential adverse effects on fall Chinook salmon from: (1) 

increased water temperatures downstream of the project during the summer outmigration season, and (2) 

reduced dissolved oxygen levels and increased releases of ammonia, mercury, and organochlorine 

compounds from Brownlee reservoir. We revised final EIS section 5.2.3.2, Water Temperature 

Measures, to incorporate these changes. 

Comment WQL-12: Interior comments that section 3.5.2.4 of the draft EIS, Temperature Control, 

provides an extensive description of the temperature of water entering, traveling through, and leaving the 

project, but that it does not discuss the importance of attempting to match water temperatures leaving the 

project with ambient temperatures in the Snake River upstream of Brownlee reservoir. Interior also states 

that the staff relies on analyses by Idaho Power to determine effects on species, primarily fall Chinook 

salmon. Interior recommends that the EIS display and analyze the effects that the altered temperature 

regime of the Snake River within and downstream of the project has on native aquatic fauna (bull trout, 

white sturgeon and other native fishes, and invertebrates) and explore potential measures to mitigate these 

effects in one of the alternatives chosen for detailed analysis. 

Response: We conclude that it is beneficial to attempt to match water temperatures leaving the project 

with the water temperatures upstream of Brownlee reservoir. In section 3.6.2.4, Water Temperature, we 

discuss ways that the project alters water temperatures in some seasons that adversely affect fall Chinook 

salmon, including slower growth in the spring due to delayed warming and adverse effects on spawning 

associated with delayed cooling. However, some project effects on water temperature likely provide 

benefits to fall Chinook salmon and other native species, including cooler water temperatures during the 

smolt migration season and warmer temperatures during the incubation period. In the final EIS, we 

expanded our analysis to better describe effects on other aquatic species, including white sturgeon and 

bull trout. 

Comment WQL-13: The Umatilla Tribes and the Nez Perce Tribe comment that the draft EIS failed to 

evaluate the benefits to adult fall Chinook migration, pre-spawning activities, gamete viability, and 

spawner success potential from a temperature control structure. They comment that even if there would 

not be sufficient cool water to provide both summer and fall “optimal” thermal conditions, as stated on 

pages 565-66 of the draft EIS, there would still be a benefit to either summer or fall temperatures from 

providing cool water, and selecting warm water in the spring would increase emergence timing and 

growth rates of fall Chinook, leading to earlier seaward migrations that would increase survival and lead 

to increased smolt-to-adult returns. The Umatilla Tribes and the Nez Perce Tribe comment that the draft 

EIS discounted the CRITFC analysis of the benefits of a temperature control structure, and have included 

a detailed response to the Idaho Power critique of CRITFC’s analysis. The Umatilla Tribes and the Nez 

Perce Tribe recommend that the EIS be revised to address these issues. 

Response: In draft EIS section 3.6.2.4, Temperature Control, we discussed and evaluated the potential 

benefits of using a temperature control structure to reduce water temperatures in the fall. Such a structure 

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could reduce stress caused by high water temperatures and low DO levels, as well as potentially reduce 

pre-spawning mortality and improve gamete viability. We also discussed the potential for increasing 

water temperatures in the spring to enhance growing conditions for juvenile fall Chinook salmon, which 

could promote earlier outmigration and attainment of a larger size prior to outmigration, both of which are 

likely to improve outmigration survival. After reviewing the information provided by the Umatilla 

Tribes, the Nez Perce Tribe, and Idaho Power, we reanalyzed potential benefits of temperature control 

structures, and we revised section 3.6.2.4, Water Temperature, accordingly. 

After the draft EIS was issued, Idaho Power filed a proposal to implement a Temperature Adaptive 

Management Plan to address the project’s thermal load allocation. Based on our analysis in section 

5.2.3.2, Water Temperature Measures, we conclude that implementing this plan could provide substantial 

benefits to fall Chinook salmon and other aquatic resources, and that it would be worth the estimated 

annualized cost of $452,000. We also conclude that installation of a temperature control structure is not 

warranted. Such a structure would be costly, yet potentially have adverse effects on fall Chinook salmon 

from: (1) increased water temperatures downstream of the project during the summer outmigration 

season, and (2) reduced dissolved oxygen levels and increased releases of ammonia, mercury, and 

organochlorine compounds from Brownlee reservoir. We revised final EIS section 5.2.3.2, Water 

Temperature Measures, to reflect this change. 

Comment WQL-14: EPA comments that it is encouraged that modeling by Idaho Power indicates that 

temperature control structures can achieve significant improvements in the reach between Hells Canyon 

dam and Lower Granite dam, potentially benefiting water quality for more than 100 river miles. In 

particular, the modeling indicates that a temperature control structure can achieve the 13°C TMDL target 

for salmon spawning. EPA also notes that these results indicate that a temperature control structure could 

substantially improve temperature conditions for rearing and migration, consistent with Oregon’s 20°C 

summer temperature criterion and the natural thermal regime standard. 

Response: We concur that Idaho Power’s modeling results indicate that a temperature control structure 

could satisfy the 13°C fall spawning target TMDL for Hells Canyon dam outflows and improve thermal 

conditions for rearing and migrating fall Chinook salmon. However, we conclude that the benefits of a 

temperature control structure do not warrant its substantial cost, given the associated potential to further 

degrade other water quality parameters (e.g., DO, ammonia, mercury, and organochlorine compounds). 

Instead, we include in the Staff Alternative Idaho Power’s proposal to implement a Temperature Adaptive 

Management Plan to address the project’s thermal load allocation. Measures implemented as part of this 

plan have the potential to enhance spawning and incubation conditions for fall Chinook salmon, and, in 

the case of watershed measures, could provide a broader array of environmental benefits. We revised 

final EIS section 5.2.3.2, Water Temperature Measures, to incorporate these changes.

Comment WQL-15: EPA recognizes that the Staff Alternative requires Idaho Power to develop and 

implement a temperature management plan in consultation with IDEQ and ODEQ. However, EPA 

comments that the draft EIS provides little information about how this plan would be developed and what 

types of measures would be evaluated and implemented. Accordingly, EPA recommends that the final 

EIS present more information about the basic timeline, milestones, and strategy for achieving water 

quality standards consistent with the existing TMDL. 

AR/IRU comment that although FERC proposes to require a plan regarding temperature, it provides no 

specifics as to what such a plan should include and makes no statement that Idaho Power must actually do 

something to address temperature impacts. They also comment that FERC provides no explanation or 

support for its assertion that its proposed alternative would result in changes to the temperature regime in 

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Hells Canyon. AR/IRU further comment that FERC is employing a double standard by claiming it cannot 

analyze and adopt recommendations of agencies and NGOs unless such recommendations are extremely 

specific, but then proposes vague, open-ended measures for plans, studies and assessment, without any 

requirement that Idaho Power actually undertake mitigation. 

Response: Idaho Power provided additional detail on its proposed temperature management plan in its 

January 31, 2007, application for water quality certification, and we revised section 3.5.2.4, Water 

Temperature, to include this information. In the final EIS, we adopt Idaho Power’s proposed approach, 

which includes three steps: (1) defining the extent and nature of the project’s temperature responsibility; 

(2) evaluating potential measures; and (3) identifying any appropriate measure(s) for implementation. 

In its application for water quality certification, Idaho Power states that certain measures designed to 

address the project’s temperature responsibility could also have adverse effects on aquatic resources. As 

such, Idaho Power notes that the effects on all aquatic resources should be considered before selecting 

measures for implementation. In the draft EIS, we concluded that the seasonal shift in water temperatures 

caused by the project adversely affected fall Chinook salmon by contributing to high water temperature 

during the spawning season and below optimal temperatures during emergence and early rearing periods. 

The approach proposed by Idaho Power, which we adopt as part of the Staff Alternative, would allow the 

comparison of benefits associated with alternative measures to address the project’s temperature 

responsibility under the TMDL. With respect to the AR/ARU statement that this approach represents a 

double standard, we note that the water quality certificates issued for this project will likely require Idaho 

Power to meet its temperature obligation under the TMDL. The Temperature Adaptive Management Plan 

proposed by Idaho Power would provide a process for ensuring that the selected measures provide the 

greatest overall benefit to aquatic resources. 

Comment WQL-16: EPA recommends that the final EIS provide additional information about the 

economic feasibility of temperature control structures. 

Response: We added the range of annualized costs ($3.7 to $40.6 million) for the five alternatives that 

were evaluated to section 5.2.3.2, Water Temperature Measures, in the final EIS. Detailed information 

on cost assumptions for each of the alternative temperature control structures were provided in Idaho 

Power’s responses to AIR WQ-2. These include: (1) detailed costs for each of the five alternative 

temperature control structures, as filed on February 4, 2005; (2) revised costs for the three alternatives 

evaluated in detail, filed on September 1, 2005; and (3) costs of DO augmentation associated with 

temperature control structures, filed on October 21, 2005. These filings may be obtained through FERC’s 

eLibrary system web page (http://www.ferc.gov/docs-filing/elibrary.asp). 

Comment WQL-17: EPA recommends that the final EIS provide further documentation of the 

temperature control structure modeling performed by Idaho Power, including detailed information about 

the seasonal withdrawal strategies that were evaluated. 

Response: We discuss the methods and results of modeling performed by Idaho Power to assess the 

effects of alternative temperature control structures in section 3.5.2.4 of the final EIS. Additional details 

about specific simulations that were run for each of the alternative structures are provided in reports filed 

by Idaho Power on December 13, 2004, and May 9, September 1, September 30, and October 21, 2005, in 

response to AIR WQ-2. These reports can be accessed through FERC’s eLibrary system web page 

(http://www.ferc.gov/docs-filing/elibrary.asp). As previously noted, in the final EIS we adopt Idaho 

Power’s proposed Temperature Adaptive Management Plan. 

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Comment WQL-18: EPA recommends that the final EIS provide additional temperature control model 

runs described in enclosure 4 and analysis of potential benefits described in enclosure 1 of its letter. 

Response: We revised section 3.5.2.4, Water Temperature, and 3.6.2.4, Water Temperature, in the 

Water Quality and Aquatic Resources sections, respectively, to include further modeling and analysis of 

the potential benefits that a temperature control structure could provide to spawning and rearing fall 

Chinook salmon. 

Comment WQL-19: EPA recommends that the final EIS provide available information from the states 

of Idaho and Oregon regarding the status of outstanding temperature issues in the CWA Section 401 

certification process. ODEQ comments that Idaho Power has been working closely with IDEQ and 

ODEQ to better define the project’s effect on water temperatures downstream of Hells Canyon dam 

during the fall Chinook salmon spawning period. ODEQ also comments that the ongoing evaluation 

indicates that the project’s warming effect downstream of the Hells Canyon dam may be less than 

previously estimated. ODEQ also notes that something less extensive than the earlier-evaluated 

temperature control structure alternative may be feasible to address the project-induced temperature 

effects of the fall. ODEQ further notes that upon resolution of this effort, Idaho Power would be better 

positioned to identify measures that are best suited to address the project’s impacts on lower river 

temperatures. 

Response: In its January 31, 2007, application for water quality certification, Idaho Power indicated that 

it intends to implement a Temperature Adaptive Management Plan. We discuss this plan in our analysis 

of water temperature effects in the final EIS, and incorporate it in the Staff Alternative. 

Comment WQL-20: EPA recommends that the final EIS provide analysis of estimated project effects on 

Snake River temperatures at the Washington border and compare it to applicable Washington water 

quality standards. 

Response: We revised the text of section 3.5.2.4, Water Temperature, to include a comparison of 

simulated temperatures for the Anatone gage, which is less than 10 miles downstream of the 

Oregon/Washington border, and Lower Granite reservoir tailwater to Washington’s year-round 

temperature criterion of 20°C. 

Comment WQL-21: Idaho Power comments that the draft EIS implies that warming springtime 

temperatures downstream of the project would benefit anadromous fish, but that this conclusion appears 

to conflict with the NMFS 2005 biological opinion for ESA Section 7 consultation for the operation and 

maintenance of BOR’s upper Snake River projects upstream of Brownlee reservoir. Idaho Power states 

that NMFS’s 2005 biological opinion suggests cooler springtime temperatures in the Snake River 

improve spring migrant conditions. Idaho Power recommends that FERC revise the EIS by incorporating 

NMFS’s analysis that cooler springtime temperatures benefit anadromous fish. 

Response: NMFS’s analysis to which Idaho Power refers states that BOR’s proposed operations would 

benefit spring-migrating yearling smolts by reducing the frequency of water temperatures exceeding 13°C 

downstream of Lower Granite dam between April 3 and June 20. Our evaluation indicates that water 

temperatures downstream of Hells Canyon dam rarely exceed 13°C before mid-May, indicating that there 

is considerable potential to increase water temperatures to improve the growth of rearing fall Chinook 

salmon from mid-March through mid-May without adversely affecting the temperature regime for 

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yearling migrants. 

Comment WQL-22: Idaho Power comments that the statement “[r]educing water temperatures in the 

fall also could increase the current low DO levels” on page 151 of the draft EIS is misleading. Idaho 

Power references modeling that it conducted for AIR WQ-2(b), which shows the potential for DO 

increases occurred only with a weir-type structure operated during low flow years, and that all other 

structures and flow years predicted lower DO conditions. Idaho Power recommends that the reference to 

reducing fall temperatures could increase DO levels be deleted. 

Response: The intent of the statement that Idaho Power refers to is simply to describe the physical 

relationship between water temperature and the solubility of oxygen. Thus, we revised the text of section 

3.5.2.4, Water Temperature, to clarify that changes in temperature have the potential to increase DO 

levels downstream of the project by increasing the solubility of DO. In the final EIS, we described the 

specific effects of alternative Brownlee temperature control structures on DO. 

Comment WQL-23: AR/IRU comment that FERC fails to adequately analyze temperature problems 

downstream of the project and does not include sufficient measures to address these problems. They also 

comment that FERC does not consider whether the lack of spawning during the fall temperature shift is 

due to adverse water temperatures caused by the project. AR/IRU further comment that FERC’s 

discussion of pH and ammonia does not comport with its discussion of DO, given various temperature 

control structure options, and that FERC does not adequately support its assertion that all options could 

result in greater amounts of ammonia and lower pH (on pages 154-155 of the draft EIS). AR/IRU 

recommend that if FERC ultimately decides to require Idaho Power to implement a temperature control 

structure, it should require that Idaho Power fully mitigate for any additional DO issues that may be 

caused by a temperature control structure. 

Response: We revised the text of section 3.5.2.4, Water Temperature, to better support our conclusions 

about the effects of temperature control structures on pH and production of ammonia. We continue to 

conclude that installation of a temperature control structure is not warranted, given its (1) high cost, (2) 

potential to increase summer temperatures, which could adversely affect out-migrating fall Chinook 

salmon, and (3) potential to reduce dissolved oxygen levels and increased releases of ammonia, mercury, 

and organochlorine compounds from Brownlee reservoir. Therefore, we do not include the temperature 

control structure in the Staff Alternative. However, as discussed in final EIS section 5.2.3.2, Water 

Temperature Measures, of the final EIS, we revised our recommendations to include Idaho Power’s 

proposal for implementing a Temperature Adaptive Management Plan to address the project’s 

temperature responsibility and enhance fall Chinook salmon habitat.

Comment WQL-24: AR/IRU comment that the draft EIS mentions Idaho Power’s efforts to obtain sitespecific criteria for water quality, but fails to discuss how it could affect the licensing and project impacts. 

They recommend that the final EIS provide more discussion of Idaho Power’s efforts. The Umatilla 

Tribes and the Nez Perce Tribe comment that adopting Idaho Power’s proposal for a site-specific change 

of the fall Chinook salmon spawning temperature criterion would essentially mean that Idaho Power 

could operate the project under status quo conditions, and avoid addressing the chronic temperature 

problems experienced by fall Chinook salmon in the upper Hells Canyon reach. The Tribes state that it is 

incumbent on Idaho Power to implement measures to address the thermal problems, as well as to abide by 

appropriate temperature criteria. 

Response: We revised our recommendations in the final EIS (see section 5.2.3.2, Water Temperature 

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Measures) to include Idaho Power’s proposal for implementing a Temperature Adaptive Management 

Plan to address the project’s temperature responsibility and benefit fall Chinook salmon. We also added a 

footnote to the table that summarizes water quality criteria and targets (final EIS, table 17) to indicate that 

EPA is concerned that Idaho Power’s proposed site-specific temperature criteria would likely not protect 

salmon spawning and egg incubation. 

Comment WQL-25: NMFS comments that it worked extensively with Idaho Power to investigate 

several temperature control measures at the project and various strategies for using these structures during 

the relicensing study period. Based on this information, NMFS concludes that these structures would not 

provide the substantial benefits to incubating, rearing, migrating, or spawning fall Chinook salmon that 

the agency had hoped would be attained with these structures. 

Response: We revised the text in section 3.5.2.4, Water Temperature Measures, to recognize NMFS’s 

position on the benefits of a temperature control structure.

Comment WQL-26: Interior states that there are several other fish species, including white sturgeon, 

bull trout and other native resident fish, that should be included in the analysis of the potential benefits of 

a temperature control plan at the project. Interior recommends that the EIS include a discussion of the 

relationship between DO and temperature and the acute and chronic effects of the diminished water 

quality conditions within and downstream of the project created by the combination of altered thermal 

regime and low DO. 

Response: We focus our analysis of a temperature control structure on fall Chinook salmon because 

potential benefits to this species are considerably greater than for other species. In addition, most parties 

that recommended the evaluation of a temperature control structure indicate that the measure would be 

intended to primarily benefit fall Chinook salmon. Nonetheless, we added text to section 3.6.2.4, Water 

Temperature, to describe the effects of temperature alterations on white sturgeon and bull trout. 

Regarding DO, we recommend that Idaho Power evaluate methods to augment DO downstream of the 

project. 

Comment WQL-27: Interior comments that the description of water quality measures, as specified in 

the Staff Alternative on page 534 of the draft EIS, is incomplete and should include the recommended 

measures that are contained in draft EIS table 96. 

Response: The list of staff-recommended water use and quality measures on page 534 of the draft EIS 

includes only those measures also proposed by Idaho Power; staff-recommended water use and quality 

measures that are not proposed by Idaho Power are listed on page 542 of the draft EIS. These lists 

correspond to measures in draft EIS table 96 (final EIS table 105). 

Comment WQL-28: The Umatilla Tribes and the Nez Perce Tribe state that it is not clear why 

temperature allocations for the project have not already been calculated, since a temperature TMDL has 

been completed, and they question why it is the purview of Idaho Power to determine its own 

responsibility for TMDL compliance. They note that temperature data upstream, within, and downstream 

of the project is spotty, making the ability to use this data for management very difficult. They state that 

collecting comprehensive water quality data in the Snake River encompassing the project, as 

recommended by CRITFC, should have been a precursor to preparing the TMDL and the draft EIS, and 

that it should be a significant part of future operations. The tribes also identify the need for access to data 

to corroborate or validate the positions taken by Idaho Power. 

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Response: Although Idaho Power could evaluate the project’s contribution to downstream water 

temperatures, IDEQ and ODEQ have responsibility for setting TMDL allocations associated with the 

project. We revised the Staff Alternative to include an operational compliance and water quality 

monitoring plan, which would include provisions for Idaho Power to post water quality, flow, and 

reservoir level data on the Internet. We discuss this monitoring plan in section, 5.2.3.4, Water Quality 

Monitoring. 

Comment WQL-29: The Umatilla Tribes and the Nez Perce Tribe comment that FERC staff appear to 

be content with not addressing the current thermal regime in the Hells Canyon reach, and state that the 

current regime does not provide suitable conditions for fall Chinook salmon. They comment that reliance 

on continued supplementation is not sufficient to bring about a self-sustaining population. The tribes also 

state that improving conditions in the reservoirs is dependent on funding upriver restoration efforts, and 

that reliance on production of fall Chinook salmon in the Clearwater and Salmon rivers is not a valid 

substitute for production in the mainstem Snake River. 

Response: We revised the Staff Alternative, as discussed in section 5.2.3.2, Water Temperature, to 

include Idaho Power’s proposal for implementing a Temperature Adaptive Management Plan to address 

the project’s temperature responsibility. This measure is expected to benefit fall Chinook salmon 

production in the mainstem of the Snake River downstream of the project. We also adopt a number of 

measures that would benefit fall Chinook salmon, including continued management of flows to benefit 

spawning and incubation, flow augmentation to improve the survival of outmigrating smolts, and 

measures to address adverse effects on DO and high TDG levels. We also expanded our discussion of the 

potential benefits of funding TMDL implementation, in section 3.6.2.6, Anadromous Fish Restoration, of 

the final EIS. However, we conclude that adverse effects on the quality of inflows to the project are the 

result of other activities in the basin, and that these have little nexus with the project and project effects 

(primarily via increased development associated with low power costs). Therefore, we do not include 

TMDL funding in the Staff Alternative. Nonetheless, we do adopt measures that Idaho Power proposes 

in its application for water quality certification to evaluate alternative approaches before selecting and 

implementing measures to meet the project’s temperature and nutrient responsibility under the TMDL. 

These alternative approaches include phosphorus trading and watershed measures, which have the 

potential to provide water quality benefits upstream of, within, and downstream of the project. 

Comment WQL-30: The Umatilla Tribes and the Nez Perce Tribe comment that the draft EIS 

recommends continuation of temperature monitoring, but that it is unclear what kind of temperature 

monitoring is required. They state that such data are very important for evaluating the effect of the 

project on downriver salmon habitat, and should be readily available to the public. 

Regarding staff measures 2, 3, and 4, NMFS suggests that to carry out its management plans, the water 

quality parameters would need to be measured within 1 mile downstream of the specified dams. NMFS 

encourages FERC to reconsider its decision to allow flow compliance to be measured at a separate 

location 16 additional miles downstream of this point so that a unified base of information will be created 

for future management decisions. 

Response: We modified the Staff Alternative to include a measure that would require Idaho Power to 

develop and implement an operational compliance and water quality monitoring plan, which would 

include continuous temperature monitoring at one site located less than 5 miles downstream of Hells 

Canyon dam. Additional spot measurements of water quality would be collected at downstream locations 

and at frequencies to be determined during consultation on staff’s recommended DO enhancement plan. 

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We note that during the 10j meeting held in December 2006, Idaho Power indicated that installing a 

combined water quality and flow measurement gage within 1 mile of Hells Canyon dam was not feasible 

because the proposed spillway TDG abatement structures would direct more energy downstream, 

resulting in turbulent conditions that are not conducive to representative measurement of water level 

variations. 

Comment WQL-31: Interior states that the draft EIS assessed biological productivity primarily by 

addressing phytoplankton community composition at different times of the year, and that the draft EIS did 

not discuss production of invertebrates or fish, both of which can be dramatically affected by alterations 

to natural temperature regimes. Interior comments that altered temperatures reduce species richness 

downstream of the dams because warmer than average winter temperatures can reduce or remove the 

thermal cues needed by eggs of many species to break diapause. Interior also comments that cooler 

summer temperatures may preclude the completion of development in some species; change the pattern of 

growth and development, or cause life cycles to lose synchrony, which may affect insect emergence. 

Interior recommends that the EIS address the combined effect of temperature and biological productivity 

on invertebrate and fish communities in and below the project. 

Response: The seasonal shift in the temperature regime caused by thermal inertia of the large volume of 

water in Brownlee reservoir is likely to cause some change in the aquatic species assemblage that occurs 

downstream of the project. However, we conclude that not all effects of the altered temperature regime 

are adverse, as implied by Interior. Many aquatic species benefit from a more stable temperature regime, 

which incorporates thermal characteristics more similar to the Thousand Springs section of the Snake 

River, which historically provided a highly productive habitat for fall Chinook salmon. However, we 

revised the Staff Alternative in the final EIS to include two additional measures that would help to 

determine, and address, project effects on aquatic invertebrates. As we describe in section 5.2.4.11, 

Invertebrate Monitoring, we recommend that Idaho Power develop and implement a plan to evaluate the 

effects of project operations and water quality measures on invertebrate production, and on sensitive 

mollusks. The plan would include provisions for annual monitoring reports, updating the monitoring plan 

at 5-year intervals, and evaluation of whether additional measures are warranted to address project effects, 

based on monitoring results. We also recommend that Idaho Power develop a plan to install continuous 

water quality monitoring equipment within 5 miles downstream from Hells Canyon dam and collect spot 

measurements of water quality at additional locations to monitor the extent of downstream effects. 

Comment WQL-32: AR/IRU state that staff’s implication that high phosphorous levels may derive from 

natural processes because of naturally high phosphorus in south-eastern Idaho is misleading, and notes 

that most of the phosphorus present in the Snake River derives from anthropogenic sources. They 

comment that the assessment of primary productivity lacks an evaluation of community 

production/respiration ratios. They indicate that measurements taken on a 24-hour basis would likely 

show more non-compliance with DO water quality standards, and that figure 28 of the draft EIS would 

likely look quite different had the samples been acquired at around 4 a.m. 

Response: We revised the text of section 3.5.1.3, Biological Productivity, to emphasize the 

anthropogenic sources of most nutrients. We concur that diurnal measurements provide a better 

representation of actual conditions than mean values. However, plots of DO in outflows from Hells 

Canyon reservoir measured at 10-minute intervals (Myers et al., 2003c) show DO concentrations similar 

to those in draft EIS figure 28 (final EIS figure 31) , indicating that DO concentrations of water drafted 

from deep in Hells Canyon reservoir remain similar throughout the day. 

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Total Maximum Daily Load 

Comment WQL-33: AR/IRU comment that FERC’s assumption that water quality standards will be 

fully met within a few years of license issuance is flawed. They state that this assumption ignores the fact 

that TMDLs are voluntary for non-point source polluters, and that the TMDL notes some pollutants will 

not be fully implemented for decades. AR/IRU indicate that it is unlikely that there will be significant 

movement toward TMDL implementation for at least another 20 years, and it is unlikely that the TMDL 

will be even close to fully implemented by the time a new license for the project expires. As a result, 

AR/IRU state that DO is likely to be a problem for decades to come. AR/IRU also comment that the 

proposed structures will not prevent TDG levels from exceeding 110 percent at high flows, and that TDG 

problems will be exacerbated if Idaho Power undertakes the proposed air injection at Hells Canyon dam. 

Response: We did not suggest in the draft EIS that water quality standards would be fully met within a 

few years. In the discussion of cumulative effects on water quality (section 3.5.3), we stated that 

implementation of TMDLs for the Snake River and its tributaries and any tributary restoration efforts 

conducted by Idaho Power would result in a slow, long-term decline in loadings of sediments, and that 

gradual improvements would be expected to continue through the license term. We revised the text of the 

final EIS to note that IDEQ and ODEQ anticipate that it would take up to 70 years to reduce nutrient 

levels to the target levels set in the TMDL. 

Comment WQL-34: The Umatilla Tribes and Nez Perce Tribe comment that the actions that will be 

taken to correct the DO problem become very difficult to follow in the draft EIS. They also comment that 

the draft EIS is deficient in specifying any timetable for completing, planning, and actually doing any 

implementation. The Umatilla Tribes and Nez Perce Tribe recommend that the EIS’s preferred 

alternative be revised to require the expedited implementation of plan measures to increase DO within 

and downstream from the project. The plan would outline a specific scope and schedule and would be 

developed in consultation with and approved by tribes and the state and federal resource agencies. 

AR/IRU comment that FERC’s proposed DO plan is much too vague and gives Idaho Power too much 

discretion. Specifically, AR/IRU state that FERC should specifically require Idaho Power to meet its 

water quality obligations upstream, downstream, and within the project. 

Response: Prior to issuance of the draft EIS, Idaho Power proposed to improve DO conditions within the 

Hells Canyon Project by injecting an average of 1,125 tons of oxygen during the summer into the 

transition zone of Brownlee reservoir. Idaho Power also proposed to install and operate turbine-venting 

systems in Brownlee units 1 through 4 and to evaluate the feasibility of implementing turbine-venting 

technology at Brownlee unit 5, but subsequently withdrew this proposal. In its January 31, 2007, 

application for water quality certification, Idaho Power proposes to meet its TMDL DO load allocation in 

Brownlee reservoir either by installing an oxygen diffuser system in Brownlee reservoir or through 

upstream phosphorus trading. Idaho Power also proposes to aerate Hells Canyon outflows using a forced 

air (blower) system at the Hells Canyon powerhouse to add 1,500 tons per year of DO downstream during 

summer and fall, or to install a similar system or aerating runners at Brownlee dam if it can provide 

reasonable assurance that the DO targets below Hells Canyon dam would be met. Based on our 

assessment, we modified the Staff Alternative to include the evaluation of phosphorus trading or other 

nutrient reduction measures as a potential approach for Idaho Power to meet its DO allocation under the 

Snake River-Hells Canyon TMDL. We discuss our rationale for this measure in final EIS section 5.2.3.1, 

Dissolved Oxygen Measures. The plan would be developed in consultation with IDEQ, ODEQ, NMFS, 

Interior, IDFG, ODFW, and interested tribes; would be filed with the Commission within one year of 

license issuance; and measures approved by the Commission would be implemented as soon as practical. 

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Comment WQL-35: Interior agrees that there are many parties responsible for degraded water quality in 

the Snake River, but states that water flowing into Brownlee reservoir generally meets ODEQ and IDEQ 

standards for DO. Interior states that DO concentrations at mile 247 downstream of Hells Canyon dam 

would be the same or higher than those levels at mile 340 to mile 343 if not for presence of the project. 

With this as a basis, Interior recommends that the EIS be revised to discuss the opportunities for matching 

DO levels of Hells Canyon outflows with Brownlee reservoir inflows. Interior states that this would 

require more than one DO monitoring site, especially in the first 10 miles downstream from Hells Canyon 

dam. 

The Umatilla Tribes and the Nez Perce Tribe disagree with FERC’s claim that Idaho Power should be 

responsible only for the project’s incremental changes to nutrients, temperature, and DO. To support this, 

the tribes state that slow flows and long water retention times in the reservoirs create conditions whereby 

nutrient and sediment loads produce poor habitat conditions in the reservoirs and reaches downstream 

from the project. The Nez Perce Tribe comments that the draft EIS fails to discuss mitigation for specific 

impacts associated with the afore-mentioned reservoir effects on water quality and the project’s 

elimination of the anadromous fish runs. 

Response: We recognize that the combination of high nutrient loads from upstream sources along with 

the reduction in assimilative capacity caused by converting the riverine environment into a reservoir 

system degrade water quality within and downstream from the project. The project also continues to 

block anadromous fish from historic habitat upstream of Hells Canyon dam. However, we note that 

without the project the high nutrient load would pass downstream and lead to greater water quality 

problems within and downstream of the lower Snake River impoundments. 

IDEQ and ODEQ addressed the effect of the project’s reservoirs on low dissolved oxygen in the Snake 

River-Hells Canyon TMDL, which specified a load allocation of 1,125 tons of DO per season, or the 

equivalent in pollutant trading, to Idaho Power for the project impoundments. As discussed above, we 

modified the Staff Alternative to include Idaho Power’s proposal to evaluate nutrient reduction in 

upstream tributaries as a method for meeting the project’s TMDL load allocations and other measures to 

enhance DO in the Oxbow bypassed reach and downstream from Hells Canyon dam. We also include in 

the Staff Alternative many measures that would benefit anadromous fisheries, including: (1) continuation 

and improvement of Idaho Power’s hatchery system; (2) Idaho Power’s continued participation in the 

existing flow augmentation program for the Snake River to improve conditions for outmigrating smolts; 

(3) continued management of flows to benefit spawning and incubation of fall Chinook salmon; (4) 

various measures to improve water quality downstream from the project; (5) a program to enhance habitat 

conditions in key tributaries to the project; (6) monitoring the spawning success of surplus hatchery 

steelhead and spring Chinook that enter Pine Creek; and (7) monitoring to determine when water quality 

conditions upstream of the project have improved to a point where reintroduction of anadromous fish is 

warranted. 

Comment WQL-36: ODEQ states that implementation of upstream measures may potentially provide 

more extensive (spatial and temporal) water quality and natural resource benefits than Idaho Power’s 

proposal of aerating Brownlee reservoir to address its TMDL requirement. For this reason, ODEQ 

recommends that any upper basin measures that could be implemented by or through Idaho Power to 

address the project’s DO TMDL requirement be explored. 

The Umatilla Tribes and Nez Perce Tribe comment that on page 653 of the draft EIS the benefits from the 

Staff Alternative appear distorted. The Umatilla Tribes and Nez Perce Tribe indicate that the effect of the 

reservoirs is to significantly alter the seasonal thermal regime, trap sediments and pesticides, and 

exacerbate the DO problems by acting as a collection point for nutrients that stimulate algal growth. The 

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Tribes comment that the measures adopted by FERC may improve DO somewhat, but more needs to be 

done. They indicate that greater improvement could be achieved by combining aeration with nutrient 

reduction. 

AR/IRU comment that the general tone of the draft EIS is dismissive of the importance of water quality 

concerns on the assumption that the new license and the TMDL will solve all water quality problems 

downstream of the dam. AR/IRU comment that FERC staff’s analysis and recommendations related to 

funding TMDL implementation ignores the synergistic impact on water quality of upstream nutrients and 

the operation of the project. They also comment that FERC further compounds the problem by refusing 

to seriously consider comprehensive, basin-wide approaches (e.g., nutrient removal) to resolving water 

quality concerns in the Snake River. AR/IRU comment that the proposals to inject air or oxygen into 

Brownlee reservoir or at Hells Canyon dam are simply a band-aid, and that a much more cohesive 

approach to the problem would be to order Idaho Power to work cooperatively with upstream pollutant 

sources on nutrient removal efforts. AR/IRU state that reducing upstream pollutants would have a lasting 

effect throughout the system, as opposed to reservoir supplementation, which is temporary and limited in 

geographic scope. Thus, AR/IRU recommend that FERC should require Idaho Power to develop a 

nutrient removal program, or at a minimum, include this measure in one of the action alternatives in the 

next version of the EIS. 

Response: We recognize there could be benefits associated with funding water quality improvements 

upstream of the project. However, because the project has no direct nexus with upstream water quality 

conditions, we did not include measures to improve water quality in upstream reaches in the draft EIS. 

However, in the draft EIS we also concluded that the reservoir aeration system proposed by Idaho Power 

for Brownlee reservoir would provide a very limited, localized benefit. In its January 31, 2007, 

application for water quality certification, Idaho Power proposes to investigate phosphorus trading as an 

alternative method for meeting its load allocation under the nutrient TMDL. In the final EIS, we adopt 

this proposal as part of the Staff Alternative because we conclude that phosphorus trading represents an 

alternative approach to meeting Idaho Power’s TMDL responsibility that could provide a broader array of 

environmental benefits. In the application for water quality certification, Idaho Power also proposed 

using a forced air (blower) system at Hells Canyon powerhouse to aerate Hells Canyon outflows, and 

installation and operation of a destratification system in the Oxbow bypassed reach. We also adopt these 

proposals as part of the Staff Alternative, in the final EIS, since we conclude that they would adequately 

compensate for adverse effects of the project in the Oxbow bypassed reach and the reach downstream of 

Hells Canyon dam. In addition, we revised the Staff Alternative to include the development of a DO 

enhancement plan, in consultation with stakeholders, that would identify and evaluate alternative 

approaches for meeting Idaho Power’s DO TMDL allocation. This evaluation would include measures 

that could benefit water quality upstream of as well as within and downstream of the project. We specify 

that the plan should include an evaluation of the benefits of reducing nutrient and organic matter loadings 

from upstream tributaries. We evaluate these benefits in sections 3.5.2.2, 3.5.2.5, 3.6.2.2, 3.6.2.5, and 

5.2.3.1 of the final EIS. 

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Comment WQL-37: Idaho Power states that it supports the staff recommendation that Idaho Power 

develop a DO enhancement plan that would determine whether reservoir DO supplementation is the most 

beneficial method to improve DO levels within and downstream of the project, and notes that the plan 

would need to be consistent with the water quality certification. NMFS indicates that it does not oppose 

the concept of an overarching DO plan, unless it would needlessly delay mitigation for this impact 

beyond the period that NMFS recommended. 

Interior comments that the Staff Alternative in the draft EIS includes a recommendation that Idaho Power 

develop a plan to determine whether reservoir DO supplementation is the preferred method for meeting 

Idaho Power’s TMDL DO allocation while also including Idaho Power’s proposal to supplement DO in 

the transition zone of Brownlee reservoir. Based on the results of Idaho Power’s simulation models 

showing that oxygen injection will have no effect on DO outside of Brownlee reservoir, Interior sees no 

need to develop a plan, as outlined in the Staff Alternative. 

The Umatilla Tribes and the Nez Perce Tribe state that FERC’s recommendation for a DO plan is 

needlessly delaying implementation of DO remedies based on uncertainties in cost effectiveness and the 

need for confirming DO load allocations, even though the costs and TMDL load allocations have already 

been calculated. 

Response: Because the water quality certification conditions would need to be incorporated into any new 

license for the project, Commission staff will review its recommendation for a DO enhancement plan to 

ensure that it is consistent with the water quality certificate. Interior may have misunderstood our 

recommendation. Idaho Power would be required to first develop a DO enhancement plan to address the 

project’s adverse effects on DO levels, then to implement measures required by the Commission, and then 

monitor the effectiveness of the measures implemented. We revised section 5.2.3.1, Dissolved Oxygen 

Measures, to indicate that our recommended DO enhancement plan should be developed and filed with 

the Commission within 1 year of license issuance, and that measures approved by the Commission should 

be implemented within the periods specified by the Commission. 

Comment WQL-38: Interior states that Idaho Power and the resource agencies recognize the seasonal 

DO deficit within the project as a critical problem for aquatic resources that must be addressed. Interior 

states that the Staff Alternative does not provide adequate measures and assurances that will increase DO 

downstream of Hells Canyon dam. Interior states that the following measures would help ensure DO 

levels are adequate to protect aquatic life: 

1. Analyzing the more protective DO standard (Oregon’s instead of Idaho’s) of an instantaneous 

minimum of 6 mg/L DO as the appropriate criteria for conservation of resident and 

anadromous salmonids; 

2. Providing a greater degree of assurance that DO supplementation will occur so as to protect 

listed and sensitive aquatic species downstream of Hells Canyon dam; 

3. Including and more thoroughly analyzing the information provided in addenda documents 

addressing DO, temperature, and TDG, along with analyzing their costs and effectiveness; 

and 

4. Including monitoring to evaluate the effectiveness of the DO measures implemented and 

requiring Idaho Power to take additional measures to ensure that DO is increased to reaches 

downstream of Brownlee dam, if needed to correct the dissolved oxygen deficit created by 

the project. 

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Response: We do not recommend that the new license require Idaho Power to achieve DO targets or 

criteria downstream of Hells Canyon dam, because factors not under the control of Idaho Power also 

contribute substantially to low DO levels both within and downstream of the project. Instead, we focus 

our evaluation on comparing the costs and benefits of alternative approaches for addressing project effects 

on water quality, and for enhancing aquatic resources within and downstream of the project. We revised 

the text of section 5.2.3.1, Dissolved Oxygen Measures, to clarify that we recommend developing and 

implementing a DO enhancement plan in consultation with interested stakeholders and filing the plan 

with the Commission for approval. The plan would include appropriate monitoring provisions to identify 

the need for new or modified measures, if warranted based on monitoring results. 

In draft EIS section 3.5.2.2, Dissolved Oxygen, we discussed potential measures to address low DO 

levels. These included using a reservoir diffuser system and oxygen supply facility to supplement DO in 

the transition zone of Brownlee reservoir, reduction of nutrient and organic matter loadings from 

tributaries, Brownlee and Hells Canyon turbine venting systems, and forced air blowers at Brownlee. We 

modified this discussion in the final EIS to include additional measures discussed by Idaho Power in its 

January 31, 2007, application for water quality certification. Idaho Power’s water quality certification 

application addenda documents, dated March 2006, present information on a number of potential 

measures to address DO and TDG. Most of this information was previously provided by Idaho Power in 

its responses to the Commission’s AIRs, which we included in the draft EIS. Parties desiring a more 

detailed description of potential alternatives or their cost can refer to: (1) Idaho Power’s responses to AIR 

WQ-1, Dissolved Oxygen Augmentation and AIR WQ-2, Temperature Control, which can be obtained 

from FERC’s eLibrary system web page (http://www.ferc.gov/docs-filing/elibrary.asp); and/or (2) the 

addenda documents that were filed with the Commission on April 12, 2006, which can also be obtained 

from the Commission’s eLibrary system. 

Comment WQL-39: AR/IRU state that Idaho Power’s proposed Brownlee reservoir oxygen 

supplementation will raise DO in only a very small geographic area, hence it will benefit only a very 

small number of aquatic species that enter that area. They also state that the draft EIS does not address 

whether the bubbler would increase the risk of mobilizing toxins, such as methylmercury, other trace 

metals, and ammonia. AR/IRU recommend that FERC address these issues in the final EIS. 

Response: In draft EIS section 3.5.2.2, Dissolved Oxygen, Reservoir Supplementation, we discussed 

potential changes in ammonia, mercury, and organochlorine compounds that are expected to occur from 

the proposed reservoir aeration system. We revised this section of the final EIS to better describe the 

potential for the proposed reservoir aeration system to mobilize toxins associated with sediments 

deposited on the reservoir’s bottom. In the same section, we also concluded that the proposed reservoir 

oxygen supplementation system would increase DO levels in a very limited portion of Brownlee 

reservoir, and this limited benefit was the primary reason that we recommend adopting Idaho Power’s 

proposal to evaluate phosphorus trading as an alternative approach for meeting its obligation under the 

Snake River-Hells Canyon TMDL. 

Comment WQL-40: Interior comments that the draft EIS states that Idaho Power’s modeling indicates 

that injecting air into the Brownlee dam generating units would elevate TDG levels. Interior recommends 

that the EIS analyze and discuss the benefits and cost effectiveness of this and other options to improve 

DO conditions in the context of an adaptive management approach. Interior also recommends that Idaho 

Power and other agencies and tribes work together to implement an action to address DO issues in a way 

that benefits aquatic habitats affected by the project, without adversely affecting aquatic life by elevating 

TDG to harmful levels. 

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Response: In the Staff Alternative, we recommend that Idaho Power work with agencies and tribes to 

implement appropriate actions to address DO issues in a way that benefits aquatic habitat, but does not 

adversely affect aquatic life by elevating TDG to harmful levels. This would be accomplished through 

the development and implementation of our recommended DO enhancement plan. 

Comment WQL-41: ODEQ comments that injection of 125 tons of oxygen per year into the turbine 

discharge of Hells Canyon dam to address project effects on DO levels in the lower river during the late 

summer and fall may be deemed insufficient for water quality certification. ODEQ comments that there 

should be additional evaluation of this proposal. AR/IRU comment that FERC accepted Idaho Power’s 

own assessment of its mitigation obligations for air injection at Hells Canyon dam, without any 

corroborating information. It states that the amount of oxygen injected should be determined by the 

Technical Advisory Committee based on water temperature and how much DO depletion has occurred. 

To facilitate this, AR/IRU recommend that Idaho Power conduct real-time monitoring and use the 

monitoring results to determine the appropriate timing for Idaho Power to inject oxygen at Hells Canyon 

dam. In addition, AR/IRU state a concern about the potential for the Hells Canyon dam air blower to 

increase TDG problems downstream from the dam, and emphasize their preference for injecting oxygen 

over atmospheric air. 

Response: In the draft EIS, we did not simply accept Idaho Power’s own assessment of its mitigation 

obligation for air injection at Hells Canyon dam, but instead recommended that Idaho Power consult with 

IDEQ and ODEQ on the amount of oxygen that would need to be injected to meet its TMDL allocation, 

as discussed in draft EIS section 5.2.3.1, Dissolved Oxygen Measures. In its January 31, 2007, 

application for water quality certification, Idaho Power estimated that the project’s maximum 

responsibility for low DO downstream of Hells Canyon dam is 637 tons of oxygen per year, and proposed 

to add 1,500 tons of oxygen per year downstream from Hells Canyon dam by aerating the Hells Canyon 

turbines or alternatively aerating the Brownlee turbines. We continue to recommend that Idaho Power 

consult with IDEQ and ODEQ on the amount of oxygen that would need to be injected to meet its TMDL 

allocation. We also recommend a monitoring plan that could be used to determine the appropriate timing 

for oxygen supplementation efforts. We discuss the potential for injection of atmospheric air at Hells 

Canyon dam to increase TDG to levels above the 110-percent TDG criterion in final EIS section 3.5.2.2, 

Dissolved Oxygen. 

Comment WQL-42: Interior states that all of the project dams have bottom-releases, which result in 

discharges of DO levels well below standards set by IDEQ and ODEQ. The draft EIS states that “Idaho 

Power’s evaluation of increases in DO show that baffles cannot induce additional airflow and thus would 

be ineffective at increasing DO levels,” but it does not cite such studies. 

Response: As described in the draft EIS, Idaho Power’s evaluation of the potential for using baffles at 

Brownlee shows that the units cannot induce additional airflow and thus would be ineffective at 

increasing DO levels. We amended the text in section 5.2.3.1, Dissolved Oxygen Measures, to include the 

citation for Idaho Power’s study. 

Comment WQL-43: The Umatilla Tribes and the Nez Perce Tribe indicate that it is important that water 

quality monitoring stations for TDG, temperature, DO, nitrogen, ammonia, organic pollutants and metals 

be established above the project, as well as within and downstream from it. Interior states a concern 

about a time lag between issuing the license and implementing monitoring that would be agreed to 

through the consultation process called for in ODFW-58. Interior states that if no monitoring occurs until 

the consultation process is complete, as recommended by the Staff Alternative, valuable data that would 

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aid in understanding the effectiveness of water quality improvement measures required by the license 

would be forgone. Interior recommends that the EIS be revised to include an alternative that incorporates 

provisions of its recommendation no. 41 (Interior-67 in the draft EIS) prior to beginning the monitoring 

called for in Oregon’s recommendations (ODFW-58 in the draft EIS). 

Response: We revised the Staff Alternative to include provisions for establishing a station for 

continuously monitoring water quality parameters within 5 miles downstream from Hells Canyon dam, as 

well as obtaining spot measurements of water quality upstream of Brownlee reservoir and at multiple 

locations downstream from Hells Canyon dam. Although additional water quality data could be collected 

during the development of our recommended DO enhancement plan, many years of data already exist to 

describe DO conditions under existing operations. Therefore, we conclude that water quality monitoring 

is not critical during this period. However, we encourage Idaho Power to continue consultation with 

stakeholders to determine appropriate monitoring measures and to initiate monitoring measures as soon as 

practical. If IDEQ or ODEQ require immediate monitoring of water quality as a condition of their water 

quality certification, the Commission would be required to include this condition in any license issued for 

the project. 

Comment WQL-44: Interior clarifies that its recommendation, measure Interior-66, does not address the 

scope of measures that are needed to increase DO downstream from the project. Rather it is specific to 

monitoring the response of the aquatic community before, during, and after supplementation to provide 

useful information for adaptive management purposes. Interior recommends that the EIS be revised to 

reconsider adopting Interior-66 as part of the Staff Alternative. 

Response: We concur with the need to monitor the effectiveness of measures to facilitate adaptive 

management. In the final EIS, we recommend that Idaho Power develop plans to monitor (1) water 

quality within and downstream of the project, (2) the effects of project operations and environmental 

measures on invertebrate production and populations of rare and sensitive mollusks, and (3) the effects of 

flow fluctuations on stranding and entrapment of fall Chinook salmon and bull trout. All of these plans 

include provisions for adaptive management based on monitoring results. There are two aspects of 

Interior-66 that we do not adopt. First, we do not adopt the establishment of specific study durations for 

sampling in each study phase, because we conclude that a well designed study program, with a year or 

more of baseline data, should be sufficient to document changes in the invertebrate community prior to 

DO implementation, and we expect that the schedule for implementing DO enhancement measures will 

be established in the section 401 certificate. Second, we do not adopt monitoring ramping rates within 

1 mile of Hells Canyon dam because the installation of spillway deflectors will divert energy downstream 

and make this location unsuitable for compliance measurement, and because doing so without adjusting 

ramping rates to account for the change in measurement location would cause a substantial reduction in 

the ability of the project to meet changes in energy demand. 

Comment WQL-45: Interior comments that the draft EIS does not acknowledge that low DO levels 

caused by continued operation of the project downstream from Oxbow and Hells Canyon dams cause 

habitat loss for aquatic species other than fall Chinook salmon. It states that all native aquatic species 

including bull trout, redband trout, and white sturgeon, in addition to the invertebrate fauna present in 

riverine sections of the Snake River, need improved DO conditions Interior recommends that the DO 

analysis of the EIS include other native species, and that it consider additional environmental measures to 

improve conditions for rare, sensitive, or declining species in the Oxbow bypassed reach, Hells Canyon 

reservoir, and in the Snake River downstream from the Hells Canyon dam. It states that such measures 

could include injecting liquid oxygen at Hells Canyon dam to improve DO immediately downstream of 

the dam and the use of hydraulic spillway deflectors to reduce TDG in a wider range of flow conditions. 

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Response: We discuss the potential effects of low DO on white sturgeon downstream from Hells Canyon 

dam in draft EIS section 3.6.2.2, Dissolved Oxygen, and we expanded this section in the final EIS to 

include a discussion of potential effects of low DO on bull and redband trout. In the final EIS, we include 

in the Staff Alternative the development of a DO enhancement plan that would evaluate alternative 

approaches to meeting Idaho Power’s DO TMDL allocation, including measures that would benefit water 

quality and improve habitat conditions upstream of, within and downstream from the project. The 

efficacy and cost-effectiveness of hydraulic spillway deflectors could be evaluated as part of our 

recommended TDG abatement plan. 

Comment WQL-46: Interior comments that the draft EIS does not include any discussion of the 

environmental effects of low DO in the project reservoirs or in the Snake River downstream of Hells 

Canyon dam on bull trout. It states that bull trout have been documented in Hells Canyon and Oxbow 

reservoirs, as well as downstream from Hells Canyon dam during periods when low DO levels associated 

with project operations may occur. It also states that analysis of the potential effects on this federally 

listed species is essential to a complete consideration of environmental effects of the project. 

Response: We expanded section 3.6.2.2, Dissolved Oxygen, to include a discussion of the potential 

effects of low DO on bull trout in the Oxbow bypassed reach, in project reservoirs, and downstream from 

Hells Canyon dam. 

Comment WQL-47: Interior expresses concern about the potential adverse effects of low DO on 

sturgeon, including potential effects on fecundity and exposure of juvenile sturgeon to predators or 

pathogens. AR/IRU state that staff’s sturgeon recovery requirements should not be tied to the assumption 

that there would be no water quality problems for sturgeon by the time hatchery sturgeon bound for the 

Swan Falls reach are of reproductive age. AR/IRU state that uses staff’s faulty logic for dismissing any 

concerns about water quality effects on hatchery sturgeon, and that the faulty logic contradicts staff’s 

logic for rejecting passage of fall Chinook salmon. 

Response: We revised section 3.6.2.2, Dissolved Oxygen, to include a discussion of adverse effects of 

low DO on white sturgeon within and downstream of the project. Our recommendation in the draft EIS to 

supplement the sturgeon population in the Swan Falls to Brownlee reach is based on sound logic, and it 

does not conflict with our conclusion that water quality conditions are not likely to support fall Chinook 

salmon in this reach in the near future. Even if nutrient targets in the TMDL take many decades to attain, 

implementing a stocking program to build sturgeon stocks in the reach could provide a substantial benefit 

to tribal subsistence and ceremonial fisheries and to recreational fisheries more rapidly than through the 

alternate path proposed by Idaho Power, which involves conducting water quality studies to be followed 

by the translocation of small numbers of adult sturgeon from other reaches. Because only a small 

proportion of sturgeon spawn in any given year, the small number of adults that would be available in 

early years of a translocation program would not allow for successful reproduction and recruitment to 

occur in all years. A supplementation program could easily seed the habitat to its capacity within a much 

shorter period of time and at relatively little cost, and with less adverse effect on the donor population 

Comment WQL-48: Interior states that improving water quality and/or habitat conditions immediately 

downstream of Hells Canyon dam is a critical step in contributing to the survival and recovery of 

salmonids, including fall Chinook salmon and bull trout. Interior recommends that the EIS be revised to 

address the fact that the biotic community downstream from Hells Canyon dam lacks the vigor and 

diversity expected in such a stream system, and examine causative factors, in addition to water quality, 

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such as flow and stage fluctuations from operations. Interior also recommends that if there is sufficient 

information to conclude that downstream impacts are due strictly to hypoxic conditions, the EIS should 

contain one or more alternatives that describe and analyze DO supplementation measures for the Hells 

Canyon reach. 

Response: We modified section 5.2.3.1, Dissolved Oxygen Measures, by recommending that Idaho 

Power develop a DO enhancement plan in consultation with stakeholders that would evaluate alternative 

measures to meet Idaho Power’s DO load allocation within and downstream of the project, and identify a 

preferred approach for implementation. In addition, we modified section 5.2.4.11, Invertebrate 

Monitoring, to require Idaho Power to develop and implement an invertebrate monitoring plan, in 

consultation with the state and federal fisheries agencies that would assess the ecological effects of water 

quality conditions and project operations on invertebrate production and on rare and sensitive species of 

mollusks. The plan would require annual reporting of the results of monitoring efforts, a description of 

any recommended adjustments to the monitoring effort, and a description of any measures that are 

proposed by Idaho Power or recommended by the resource agencies or tribes to address the effects of the 

project. 

Comment WQL-49: The Forest Service comments that the DO aeration system proposed for Brownlee 

reservoir, if it is effective at all, would likely provide only limited refugia for fish to reduce the intensity 

of fish kills in Brownlee and would not serve to address larger, basin-wide, pollution problems or increase 

DO concentrations downstream of the project within the Wild and Scenic Snake River. The Forest 

Service recommends that the EIS either include in the Staff Alternative the upstream water quality fund 

recommended by NMFS or delete references to TMDL attainment within the new license term. Interior 

comments that supplementation of DO in Brownlee reservoir may have limited success in correcting or 

significantly improving periodic conditions of hypoxia both within the reservoir and downstream. 

Interior comments that turbine venting or forced-air injection into turbines, as proposed for Hells Canyon 

dam, is far more likely to provide measurable improvement in water quality to the reach downstream of 

Hells Canyon dam. Interior states that the Commission needs to undertake a more active effort to plan for 

and implement such water quality measures at Hells Canyon dam, and recommends that this be included 

in the EIS. Interior also recommends that the EIS include a “road map” for implementing this measure as 

part of one or more alternatives. 

Response: We recognize that the Brownlee reservoir aeration system would provide a very limited 

benefit, and in the final EIS, we adopt a DO enhancement plan that would evaluate alternative measures 

to meet Idaho Power’s load allocation under the TMDL, which would include consideration of upstream 

nutrient reduction measures. The plan would be filed with the Commission within 1 year of license 

issuance, and any measure required by the Commission would be implemented as soon as practical. We 

revised section 5.2.4.3, Anadromous Fish Restoration, to clarify that upstream water quality would 

improve slowly as the TMDL is implemented. 

Comment WQL-50: AR/IRU comment that FERC fails to consider continuing and/or cumulative 

impacts of project operations over time, and that continuing effects can cause further degradation of the 

resource. They state that having Idaho Power restore conditions in tributaries as a pollution-trading 

measure could improve the quality of source water to the Oxbow bypassed reach, but that FERC does not 

include such a pollution-trading scheme in any of its action alternatives. 

Response: Our analysis is based on a No-action Alternative baseline, which includes continuation of 

numerous environmental effects. Although not necessary for our comparison to the No-action 

Alternative, we describe cumulative effects on water quality in section 3.5.3, Cumulative Effects. As we 

discuss in our response to comment WQL-36, we modified the Staff Alternative in the final EIS to adopt 

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Idaho Power’s proposal to evaluate the potential to pursue phosphorus trading as an alternative approach 

for meeting its TMDL allocation 

Hazardous Materials 

Comment WQL-51: AR/IRU comment that the draft EIS wrongly asserts that Idaho Power holds 

NPDES permits because it does not have an NPDES permit for its Brownlee powerhouse discharges. 

They state that Idaho Power previously held an NPDES permit for sewage discharges at Brownlee, but 

that permit has long since expired and it specifically prohibited any discharge of oil or grease. They hold 

that Idaho Power’s admitted oil discharges from Brownlee, however small, are in direct violation of Idaho 

Power’s previously held NPDES permit. AR/IRU comment that before FERC can issue a new license to 

the project, it must ensure that Idaho Power has complied with all applicable regulatory requirements, 

including the requirement that any and all pollutant discharges are covered by an NPDES permit, 

including oil discharges from Brownlee. 

Response: In table 6.1-13 of its January 31, 2007, application for water quality certification, Idaho 

Power shows that it has NPDES permits for cooling water and sump water at all three project 

developments. NPDES permits are not required prior to issuance of any license. 

Comment WQL-52: AR/IRU comment that DO, temperature, ammonia, and trace metal levels are all 

closely tied and changes in one parameter will cause changes in the others. They comment that the draft 

EIS states that in some years the augmentation flow will have some benefit for DO, but will never benefit 

ammonia or trace metals. AR/IRU state that there is an inverse relationship between oxygen tension and 

the presence of ammonia and soluble trace metals, and thus there will always be a decrease in ammonia 

and trace metals if there is an increase in DO. 

Response: Idaho Power’s modeling indicates that flow augmentation would result in the anoxic layer 

being at a slightly lower elevation than under the Proposed Operations. However, it would have little 

effect on the amount of near-bottom water that would be anoxic. Because production of ammonia and 

soluble metals from deposits on the reservoir’s bottom is controlled by the extent of anoxic conditions at 

the water/substrate interface, we conclude that flow augmentation would not result in substantially 

different production of ammonia or soluble metals, compared to Idaho Power’s proposed operations. 

Comment WQL-53: ODFW states that sturgeon are particularly susceptible to exposure and 

bioaccumulation of contaminants due to a number of factors, including poor water quality conditions 

between Swan Falls and Hells Canyon dams, long-life span, late age at maturation, their use of benthic 

habitats, and position at the top of the food chain. ODFW states that without financial assistance, 

significant water quality improvements that would substantially reduce the level of legacy contaminants 

over the term of the new license will not occur. ODFW also recommends site-specific analysis of white 

sturgeon to determine potential effects of contaminant bioaccumulation on reproductive success and 

recruitment. Interior recommends that the EIS clarify that supplementation with hatchery sturgeon does 

not resolve or eliminate risks associated with degraded water quality downstream from Hells Canyon 

dam. Interior recommends that the issue of contaminant monitoring be reconsidered, in terms of both 

monitoring the overall health and threats to the sturgeon population and evaluating the likelihood of 

success of the hatchery program in supplementing wild populations. 

Response: We re-evaluated this issue in the final EIS and conclude that implementing the TMDL would 

result in negligible reduction in bioaccumulation of toxic contaminants for at least 20 years. We also 

conclude that monitoring bioaccumulation in white sturgeon in a non-lethal manner would aid in 

determining the effects of contaminant bioaccumulation on reproductive success and recruitment, while 

minimizing adverse effects to the population. Although Idaho Power does not bear responsibility for the 

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introduction of these contaminants into the environment, slow water in the project reservoirs causes the 

deposition and retention of contaminated sediments, increasing the exposure of sturgeon to contaminants. 

Monitoring contaminant bioaccumulation in sturgeon could aid in managing sturgeon by providing a 

better understanding of the effect of contaminants on the sturgeon population, including potential effects 

on reproductive success. Therefore, we recommend that Idaho Power, if requested by IDEQ or ODEQ, 

collect sturgeon tissue samples during its proposed population assessments, and provide them to the state 

agencies for their use in analyzing bioaccumulation of contaminants. We amended section 5.2.4.10, 

Sturgeon Conservation Measures, accordingly. 

Comment WQL-54: ODFW states that even though the Staff Alternative in the draft EIS does not 

include habitat enhancements or support a water quality fund, Commission staff makes no 

recommendation for a contingency plan if water quality improvements are slow to occur or do not occur. 

Response: As noted above, we revised the Staff Alternative to include development of a DO 

enhancement plan, in consultation with stakeholders, that would evaluate alternative approaches for 

meeting Idaho Power’s TMDL DO allocation. The evaluation would include measures that could benefit 

water quality upstream of as well as within and downstream of the project. We expect that the water 

quality certificates to be issued by Oregon and Idaho will include appropriate provisions for monitoring 

and adaptive management to provide reasonable assurance that DO allocations will be fulfilled and that 

water quality criteria will be met within and downstream of the project in a timely fashion. 

Total Dissolved Gas 

Comment WQL-55: Idaho Power provides an update on it estimated 10-year, 7-day average flood flows 

(7Q10) for both Hells Canyon and Brownlee dams and recommends that the final EIS present the more 

recent estimates. 

Response: We revised the text of section 3.5.2.3, Total Dissolved Gas, to reflect this new information. 

Comment WQL-56: NMFS states that draft EIS tables 23 and 24 suggest that under Scenario 2 (flow 

augmentation), there would be a slight increase in the frequency of discharges at Brownlee and Hells 

Canyon dams in excess of powerhouse capacity, thereby increasing the risk of exceeding the TDG limit. 

NMFS comments that this is a modeling artifact. NMFS comments that during high flow years, when 

aiming for a June 20 refill, Idaho Power, NMFS, and FERC would confer and likely delay refill as 

appropriate to avoid unacceptable risks from involuntary spill. NMFS states that while there is the 

potential for runoff prediction errors to result in “fill and spill” operations, it believes that this possibility 

would be virtually equal in all alternatives considered. NMFS recommends that FERC staff carefully 

review the model results to determine if careful in-season management would avoid this adverse effect. 

Response: After reconsideration, we conclude that modeled flows likely over-predict the frequency of 

spill events, since predicted flows would be used to guide refill operations. We augmented the text of 

section 3.5.2.1, Effects of Project Operations on Water Quality, Total Dissolved Gas, to incorporate 

NMFS discussion of modeled flows and the procedure that would take place under Scenario 2 in high 

flow years, and also added this caveat to the table footnotes (FEIS tables 26 and 27). Under the Staff 

Alternative, Idaho Power would monitor TDG to determine whether it exceeds the 110-percent criterion, 

and implement appropriate measures to meet the water quality standard. 

Comment WQL-57: ODEQ comments that additional details still need to be resolved pertaining to 

project-related impacts on TDG concentrations. These details include: (1) taking a closer look at 

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potential excessive TDG concentrations caused by spill at Oxbow dam and measures that may be 

implemented to address them; (2) developing a monitoring plan; and (3) refining a TDG adaptive 

management plan and implementation schedule. 

Response: The issues raised by ODEQ would be addressed during development of our recommended 

TDG abatement plan described in section 5.2.3.3, Total Dissolved Gas Abatement. 

Comment WQL-58: AR/IRU comment that FERC staff’s TDG alternative is too vague, in that it only 

requires that Idaho Power develop a plan to address TDG. They state that the analysis section of the draft 

EIS staff discusses the installation of flow deflectors at both Hells Canyon and Brownlee dams to reduce 

TDG, but makes no mention of flow deflectors in the Staff Alternative. They recommend that FERC be 

more specific in the final EIS about what measures are being considered in the Staff Alternative, and urge 

FERC to specifically require Idaho Power to install flow deflectors at Hells Canyon and Brownlee dams. 

Interior states that the levels of TDG observed within and downstream from the project are detrimental to 

aquatic resources, and necessitate more stringent and enforceable environmental measures. Also, Interior 

comments that the draft EIS does not clearly identify the staff’s recommendations 

Response: In section 5.1.1.2, Staff Alternative, there are two lists of staff-recommended environmental 

measures. The first list includes measures that are proposed by Idaho Power, some of which have been 

modified by FERC staff, and the second list includes measures that are based on agency, tribal, and NGO 

recommendations and our analysis. In the draft EIS, we recommended that Idaho Power install spillway 

flow deflectors at both Hells Canyon and Brownlee dams and that it develop and implement a TDG 

Abatement Plan. In the final EIS, we revised the text in section 5.2.3.3, Total Dissolved Gas Abatement, 

to include evaluation and selection of a TDG abatement structure for Oxbow dam. 

Comment WQL-59: AR/IRU emphasize the adverse effects that project-caused elevated TDG have on 

out-migrating smolts and resident fish in the river, such as white sturgeon and bull trout. AR/IRU 

comment that it is likely that the technology does not exist to completely mitigate for the TDG impacts of 

the project as long as the project is in place. AR/IRU comment that FERC’s reasoning behind its refusal 

to consider their recommendation to require Idaho Power to compensate for TDG impacts that cannot be 

mitigated directly conflicts with many of FERC’s extremely open-ended and vague mitigation plans or 

requirements in the draft EIS. AR/IRU comment that it is imperative that Idaho Power provide some sort 

of compensation for this impact, in the form of other mitigation to protect the species that are harmed by 

TDG impacts (e.g., off-site habitat restoration and water quality measures). They recommend that the 

specifics of how the compensation program would look should be overseen by a Technical Advisory 

Committee. 

Response: We emphasized the need for satisfying the TDG standards in a timely manner by 

recommending TDG abatement measures for all three project dams along with a TDG abatement plan to 

adaptively manage total dissolved gas. Specific measures recommended include Idaho Power’s proposals 

to continue preferential use of the upper spillgates at Brownlee dam and install spillway deflectors at 

Hells Canyon dam, along with its intended spillway deflectors at Brownlee dam, 

evaluation/implementation of an appropriate TDG abatement measure for Oxbow dam, and an evaluation 

of the need for additional TDG abatement measures if warranted based on monitoring results. We 

conclude that the staff-recommended measures would satisfy the TDG standards, and therefore we do not 

include AR/IRU’s recommended compensation program in the Staff Alternative. 

Comment WQL-60: Interior observes that the draft EIS, on page 269, states that Idaho Power has 

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observed few effects of TDG on fish. Interior comments that this statement minimizes the scientific and 

historic information on the acute and chronic adverse effects of elevated TDG levels on aquatic life. 

Interior recommends that the EIS provide information from the record that documents the potential for 

major problems for fish life, including fish kills and gas bubble trauma, in the Snake River caused by spill 

at the project, both as part of the Affected Environment, and as a basis for evaluating the effects of 

imposing or not imposing license conditions that mitigate the effects on fish from elevated dissolved gas 

levels resulting from the project. 

Response: Idaho Power filed a study reporting the results of fish sampling conducted below Brownlee 

and Oxbow dams during spills, which found that a wide range of fish species showed evidence of GBT, 

especially when TDG levels exceeded 125 percent. We revised the text of section 3.6.2.3, Total 

Dissolved Gas, to reflect this information. In the final EIS, we also adopted additional measures to 

address gas supersaturation. 

Comment WQL-61: The Forest Service agrees that spillway deflectors are necessary at Brownlee dam, 

but states that other modifications downstream of Brownlee dam, such as a flow separator wall, may also 

be necessary if the new flow deflectors do not achieve the desired results. The Forest Service 

recommends that FERC require Idaho Power to work with ODEQ and IDEQ to identify an adaptive 

management process for TDG attainment whereby monitoring data would be used to determine the need 

for additional measures should those in the Staff Alternative prove inadequate. 

Response: We clarified our recommendation for adaptively managing TDG abatement in section 5.2.3.3, 

Total Dissolved Gas Abatement. This adaptive management process could result in Idaho Power 

constructing a flow separator wall downstream of Brownlee dam, if monitoring results document that the 

TDG standard is not satisfied. 

Comment WQL-62: The Umatilla Tribes and Nez Perce Tribe indicate that they recommended that 

Idaho Power install gas abatement structures at both Hells Canyon and Brownlee dams in order to meet 

water quality standards within 5 years. The Umatilla Tribes and Nez Perce Tribe also recommended a 

TDG monitoring program. Although the Staff Alternative in the draft EIS supports these measures, the 

Umatilla Tribes and the Nez Perce Tribe state that additional measures will need to be implemented 

during the term of the new license if monitoring indicates that the measures are not adequate to meet the 

standards. 

Response: As discussed in section 5.2.3.3, Total Dissolved Gas Abatement, we continue to recommend a 

TDG monitoring program. This program would document the need for any additional TDG abatement 

measures that are needed to address adverse effects. 

Oxbow Bypassed Reach Flows 

Comment WQL-63: Interior states that FERC staff’s conclusion that water quality improvements cannot 

be realized with more water flowing through the Oxbow bypassed reach is not consistent with Idaho 

Power’s analysis that determined that flows of 1,350 cfs completely mixed the stratified water that 

accumulated at mile 271.3. In addition, a 1960 order from the Federal Power Commission required a 

continuous flow of 1,000 cfs around the Oxbow Bypass to the fish trap facility at Oxbow dam. Upon 

evaluation of the 1,000-cfs flow, it was later determined that the minimum flow to be released through the 

Oxbow spillway and the spillway fish trap was to range between 250 and 750 cfs. Interior recommends 

that the EIS be revised to include the above minimum flows in an alternative that provides a greater level 

of protection of the ecological integrity of the Oxbow bypassed reach than Idaho Power’s current 100-cfs 

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proposal. Interior states that these flows should be the starting point in evaluating attraction flow needs 

for the Oxbow dam fish trap when it is built. Interior also notes that increases in DO would benefit listed 

species. 

Response: We amended section 3.5.2.5, Oxbow Bypassed Reach Flows, and section 3.6.2.5, Oxbow 

Bypassed Reach Flows, to clarify that increasing spill flows at Oxbow dam may provide some increase in 

DO levels within the bypassed reach during the summer months. However, we note that water 

temperatures would continue to be very high regardless of the flow volume that is released into the 

bypassed reach. In addition, Idaho Power’s radio telemetry studies indicate that bull trout move out of the 

bypassed reach into tributaries by mid-May, and would not benefit from increased DO levels during the 

summer months. 

Cumulative Effects 

Comment WQL-64: Interior observes that the draft EIS does not discuss the influence of wastewater 

discharges from industries and municipalities on the overall water quality in the project area. Interior 

recommends that source pollutants from recreational activities be mentioned in the general description of 

water quality, and that the EIS discuss the potential effect of recreation on beneficial uses of the project 

area. 

Response: We revised the text in section 3.5.3, Cumulative Effects, to address these points. However, 

this did not alter our analysis or conclusions. 

Comment WQL-65: Interior comments that the geographic scope described in section 3.2.1.2 of the 

draft EIS was to include the entire Snake River basin for water temperature and water quality. Interior 

recommends that the EIS be revised to include a more thorough discussion of the need to mitigate Hells 

Canyon TMDL loads, and include strategies to address these concerns as part of one of the alternatives 

for this project. 

Response: In section 5.2.3.1, Dissolved Oxygen Measures, and section 5.2.3.2, Water Temperature 

Measures, we discuss the need for Idaho Power to consult with IDEQ and ODEQ on the estimate of 

project effects and the TMDL load allocation for DO and temperature. As part of the Staff Alternative, 

we include individualized plans to address project effects on DO, TDG, and water temperature. We 

amended section 5.2.3.1, Dissolved Oxygen Measures, to make it clear that we recommend that Idaho 

Power identify appropriate upstream phosphorus trading partner(s) and evaluate the benefits of reducing 

nutrient and organic matter loadings from upstream tributaries, as well as other approaches for meeting 

TMDL load allocations and water quality standards. 

Comment WQL-66: Interior comments that the draft EIS discusses the cumulative effects of the 

project’s operation, but does not stress the importance of cumulatively affected resources downstream of 

the project. Interior states that the injection of oxygen in Brownlee reservoir does little for listed fish in 

either Oxbow or Hells Canyon reservoirs or downstream from the project dams. Interior recommends 

that the EIS provide more complete information regarding the cumulative effects to listed fish species and 

invertebrates immediately below the project dams, particularly within the first 10 to 15 miles downstream 

of Hells Canyon dam. 

Response: We discuss the potential effects of low DO on aquatic resources in the project reservoirs and 

downstream from Hells Canyon dam in section 3.6.2.2, Dissolved Oxygen. We expanded this section, 

however, to include a discussion of the potential effects of low DO on sturgeon, bull trout, and redband 

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trout. We address the potential effects of low DO in the Oxbow bypassed reach on aquatic species in 

section 3.6.2.5, Oxbow Bypassed Reach Flows. In section 5 of the final EIS, we recommend that Idaho 

Power evaluate alternative approaches to meeting TMDL loads and water quality standards within and 

downstream of the project, including measures such as nutrient reduction that would provide water 

quality benefits upstream of the project. We also recommend a plan to monitor the response of aquatic 

invertebrate production and rare and sensitive mollusks to changes in project operations and to water 

quality measures included in the new license. 

Comment WQL-67: Idaho Power comments that it disagrees with the draft EIS assertion that springtime 

temperatures need to be warmed to mimic natural conditions. Idaho Power recommends that the final EIS 

recognize that the cooler water being released from Brownlee dam under current operations is improving 

water conditions for spring migrants. 

Response: We revised sections 3.5.2.4, and 3.6.2.4, Temperature Control, to clarify that the project acts 

to delay seasonal warming and cooling compared to those that would occur if the project had not been 

constructed, which may differ from pre-project conditions. However, this did not change our analysis or 

conclusions. 

Comment WQL-68: AR/IRU comment that the draft EIS (page 160) does not address the full scope of 

unavoidable adverse consequences to water quality that cannot be mitigated. They state that these effects 

include creation and contamination of reservoir sediments, lost riverine function, and trace metals 

including methylmercury and ammonia. 

Response: We modified section 3.5.4, Unavoidable Adverse Effects, to include these effects. 

B9. AQUATIC RESOURCES 

Comment AR-1: Idaho Power provides clarification of Idaho Power’s participation to date in the 

regional effort to augment river flows during the juvenile migration season. 

Response: We modified section 5.2.2.3 to reflect Idaho Power’s clarifications. 

Comment AR-2: ODFW and AR/IRU comment that Idaho Power has indicated that with a cost cap of 

$2 million, 237 kaf could be provided in a majority of water years, while in the draft EIS, staff states that 

providing a flow release of 237 kaf would cost an estimated $6.6 million. ODFW requests that FERC 

staff include a detailed analysis and discussion of its cost estimates for flow releases of 237 to 350 kaf, 

and why its estimate is considerably greater than Idaho Power’s. AR/IRU comment that NEPA, the FPA, 

and the Northwest Power Act all mandate that FERC fully explain and support any cost estimates in an 

EIS. 

Response: We requested additional model runs from Idaho Power in a conference call on February 8, 

2007. These new runs provide an estimate of the combined effects of flood control, power generation, 

and flow augmentation on project economics. We use Idaho Power’s revised estimate for the 237-kaf 

augmentation scenario in final EIS table 102. Idaho Power’s latest estimate shows over $2.4 million in 

lost energy benefits alone. Total benefit losses including dependable capacity and ancillary benefits 

would potentially exceed $9.03 million. Under the 350 kaf augmentation scenario, additional lost energy 

benefits of $1.34 million would result; however, these benefits would be partially offset by lower 

dependable capacity losses due to higher summer flows such that the overall benefits loss would be about 

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$0.62 million higher or $9.65 million. 

Comment AR-3: The Umatilla Tribes and the Nez Perce Tribe comment that it is important for the new 

license to contain provisions that allow flood control operations to be modified based on improved 

forecasting tools and new Corps flood control assessments. 

Response: We anticipate that any new license would include provisions for adjusting flood control 

operations based on changed circumstances or new information. 

Comment AR-4: The Umatilla Tribes and the Nez Perce Tribe comment that their recommendation to 

shift a minimum of 110,000 acre-feet in flood control space from Brownlee reservoir to Lake Roosevelt 

in the March-through-May period during low to average flow years was not adopted as part of the Staff 

Alternative. They state that this shift is required by the 2000 and 2004 Federal Columbia River Power 

System biological opinions, and is included in the state and tribal fishery agencies’ comprehensive plan, 

Detailed Fishery Operating Plan with 1994 Operating Criteria. However, they note that to meet Lower 

Snake River target flows in past years, the Corps has approached Idaho Power to engage in the flood 

control shift, but Idaho Power declined. The Umatilla Tribes recommend that the preferred alternative 

contain a recommendation that requires Idaho Power to engage in the spring flood control shift, 

particularly in a low runoff year, if the Corps and the fishery agencies and tribes determine it is 

appropriate to assist in meeting the lower Snake River spring flow targets. 

The State of Idaho comments that it would be most efficient and constructive to use a cooperative 

approach for determining necessary flood control elevations in Brownlee reservoir on an annual basis. 

The State of Idaho, Idaho Power, and other regional interests should work collaboratively each year to 

review the Corps proposed flood control elevations and recommend operations that take into account the 

annual variation in water availability and migration timing of Chinook salmon and steelhead. 

Response: Any major changes in flood control on a system-wide basis would require a NEPA analysis of 

both the Snake River and Columbia River facilities. Because flood control is a congressionally 

authorized purpose that falls under the purview of the Corps, the Corps would be the responsible federal 

agency to lead any NEPA process related to flood control shifts. The Corps would also lead any efforts to 

modify the approach to inter-agency collaboration. We did not change the text of the final EIS in 

response to this comment. 

Comment AR-5: The Umatilla Tribes concur with retaining the current minimum flows of 6,500 cfs at 

Hells Canyon dam and 13,000 cfs at Lime Point. Based on their hydrological analysis, higher minimum 

flows during the summer for commercial and recreation would jeopardize storage necessary for fall 

Chinook spawning requirements in October in low flow years. 

Response: We note the Umatilla Tribe’s concurrence with the Staff Alternative that retains current 

minimum releases. We also note that preservation of storage water for fall Chinook salmon spawning 

requirements is a reason (among others) to retain current minimum Hells Canyon release levels.

Primary Production and Aquatic Macroinvertebrates 

Comment AR-6: Interior comments that the draft EIS’s extrapolation of area dewatered to assess 

impacts to the benthos and aquatic community is overly simplistic and does not take into account habitat 

type and quality, which it considers to be critical factors in assessing operational impacts to the 

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ecosystem. It states that both Bailey (1974) and Brusven et al. (1974) document the benthic habitat in the 

Snake River as primarily comprising two major zones: the Ash Grey Zone (approximately 3.15 to 26.8 

inches in depth) and the Cladophora Zone (greater than 26.8 inches). It reports that the Ash Grey Zone 

mostly comprises periphyton and is the most relied on by benthic grazers, while the deeper, Cladophora

Zone, which comprises the filamentous green alga Cladophora sp., is of relatively low nutritional value to 

most aquatic herbivores. 

Response: We revised the subsection on Primary Production and Aquatic Macroinvertebrates in section 

3.6.2.1 accordingly. However, our review of the references cited by Interior indicate that the deeper 

Cladophora Zone, which is less affected by daily dewatering, also supports a substantial amount of 

invertebrate production. 

Comment AR-7: Interior and AR/IRU reiterate their recommendation, and ODFW is supportive of, 

long-term monitoring of the benthic community to track ecological responses to changes in basin 

conditions, project operations, and implementation of aquatic resource enhancement measures, as well as 

to document mitigation or compensation needs. 

Response: We revised the Staff Alternative to include a measure that would require Idaho Power to 

develop and implement an invertebrate monitoring plan to evaluate trends in the abundance and 

distribution of rare and sensitive species of mollusks, to evaluate the effects of load following operations 

on the food supply available to fall Chinook salmon and bull trout, and to determine whether additional 

operating constraints are warranted. 

Comment AR-8: Interior comments that the new species of mollusk (Taylorconcha insperata) that was 

identified in the Hells Canyon reach should be regarded as sensitive and warrants greater consideration by 

the Commission and more consideration for future management. It states that Taylorconcha insperata 

and all but one other native mollusk are absent from the 12-mile reach immediately downstream from 

Hells Canyon dam. Interior considers the species’ presence in the Snake River significant to the 

continuing survival of the species, and it does not regard these data to show the species to be “abundant.” 

Interior states that use of the term “abundant” in the draft EIS misrepresents the status of this species 

within the project area. Interior also comments that the draft EIS does not present any data on potential 

project-related impacts to T. insperata and does not discuss measures to reduce or eliminate such impacts. 

It notes that Richards et al. (2005) provides data indicating that T. insperata becomes less abundant with 

increasing depth, placing this species at greater threat to load following operations. 

Interior states that it is inconsistent for the Commission to recognize that “project operations have the 

potential to disturb rare plant populations or ... the habitat that supports them” (draft EIS section 5.2.5.1, 

page 588), and for the Staff Alternative to include the proposed preparation of a “project-wide threatened, 

endangered, and sensitive species management plan,” but to exclude such a discussion or plan for 

sensitive and/or rare aquatic mollusks that will be directly affected and whose habitat will be disturbed 

from project operations. 

Response: We revised section 3.8.1.6, Bliss Rapids Snail, to include more information on the abundance 

and distribution of this species downstream from Hells Canyon dam. We revised the Staff Alternative to 

include the development and implementation of an invertebrate monitoring plan, which would include the 

assessment of effects on rare and sensitive species of mollusks. 

Comment AR-9: Interior states that the draft EIS should address the effects of the project on the 

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narrowly ranging Taylorconcha insperata and the declining Margaritifera falcata. 

Response: Richards et al. (2005) reported that no Margaritifera species were found in their survey effort, 

which was focused on the detection of rare and sensitive mollusk species in both reservoir and riverine 

habitats. As noted previously, we revised the Staff Alternative to include the development and 

implementation of an invertebrate monitoring plan, which includes continued monitoring and assessment 

of project effects on rare and sensitive species of mollusks. 

Comment AR-10: Interior comments that the construction, operation, and maintenance of the project has 

completely closed historic corridors of migration from 93 miles of the Snake River for freshwater mollusk 

species, precluding natural immigration and emigration to and from mollusk populations in the numerous 

tributaries to the Snake River between miles 340 and 247. It recommends that the Staff Alternative 

include measures for the conservation and enhancement of sensitive, rare, and/or declining species of 

freshwater mollusks in the project area. 

Response: We anticipate that measures to increase DO downstream of Hells Canyon dam will benefit 

rare and sensitive mollusks, and may over time improve the suitability of habitat for these species in the 

first 12 miles downstream of the dam, where they do not currently occur. The invertebrate monitoring 

plan that we include in the Staff Alternative, which would be developed in consultation with Interior, 

could include provisions for the reintroduction of rare and sensitive mollusks if the results of water 

quality monitoring indicate that habitat would support their reintroduction. 

Comment AR-11: AR/IRU comment that given uncertainty about the distribution of Snake River snails, 

FERC should not assume the absence of Idaho springsnails from the Hells Canyon reach, and Bliss 

Rapids snails should be discussed in the final EIS. 

Response: As reported in the draft EIS, neither of these species were found downstream of Hells Canyon 

dam during Idaho Power’s surveys, although several individual snails were misidentified as Bliss Rapids 

snails during Idaho Power’s initial survey efforts. Both of these species were found to be relatively 

abundant in reaches associated with Idaho Power’s upstream mid-Snake and C.J. Strike projects. Given 

the relative abundance of these species in upstream locations, we consider it likely that these species 

would have been detected during Idaho Power’s survey efforts if they occurred downstream of Hells 

Canyon dam. Nonetheless, the DO augmentation measures that we include in the Staff Alternative would 

benefit these species, if present, and our recommendation to continue invertebrate monitoring should 

assist with verifying the presence or absence of these species downstream of Hells Canyon dam. 

Anadromous Fish Species 

Comment AR-12: Interior recommends that FERC include and analyze the information, conclusions, 

and recommendations contained in the following Northwest Power Planning Council Subbasin Plans and 

use them to formulate additional licensing alternatives for the project: (1) Boise, Payette, and Weiser; (2) 

Burnt; (3) Grande Ronde; (4) Imnaha; (5) Lower Snake; and (6) Malheur. 

Response: We expanded section 5.5.7, Pacific Northwest Electric Power Planning and Conservation 

Act, to include evaluation of the consistency with the Hells Canyon, Powder River, Burnt River, Middle 

Snake River, Bruneau, Owyhee, Malheur, Clearwater, Imnaha, Grande Ronde, Salmon, Lower Snake, and 

Boise, Payette and Weiser River subbasin plans. Nearly all of the fish and wildlife measures included in 

the Staff Alternative would assist with meeting biological objectives identified in the Middle Snake River, 

Hells Canyon, Powder River, and Burnt River subbasin plans. Monitoring water quality conditions 

upstream of the project and efforts to evaluate hatchery steelhead and spring Chinook salmon production 

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in Pine Creek would contribute to the biological objective identified in the Boise, Payette, and Weiser 

Subbasin Plan to continue investigating the feasibility of restoring anadromous fish runs above Hells 

Canyon dam. Consulting with the agencies and tribes to determine the best use of surplus hatchery fish 

may result in development of recreational and tribal harvest fisheries upstream of the project, which 

would be consistent with the objective of the Malheur and the Boise, Payette and Weiser Subbasin Plans 

to compensate for lost opportunities to user groups related to diminished fish runs and ecological 

function. There is considerably less connection of proposed measures with biological objectives in the 

Imnaha, Grande Ronde, and Lower Snake River Subbasin Plans, although some measures, such as flow 

augmentation and TDG abatement, may improve conditions in the downstream migratory corridor for 

anadromous fish species. 

Regarding Interior’s recommendation that the subbasin plan recommendations be used to formulate 

additional licensing alternatives, we did not identify in the subbasin plans a separate agency alternative 

that would encompass the full scope of measures recommended by the different stakeholders. We 

therefore adopted our standard approach of evaluating the full range of recommended measures and 

combining the measures that stood on their merits into a comprehensive Staff Alternative to contrast with 

Idaho Power’s licensing proposal. 

Comment AR-13: NMFS comments that in its January 24, 2006, filing, it provided an analysis 

indicating that the Snake River upstream of Brownlee reservoir likely produced far more than the 214,000 

fall Chinook salmon estimated by Idaho Power and reported in the draft EIS. 

Response: We reviewed the assessment provided by NMFS, and compared it with Idaho Power’s 

estimate. We agree that NMFS’ estimate, which takes into account the account differences in habitat 

suitability upstream and downstream of the project, is likely more accurate than Idaho Power’s estimate, 

which assumed that the number of fall Chinook salmon produced in each reach was proportional to the 

linear miles of river contained in each reach. We revised the text in section 3.6.1.3, Anadromous Fish 

Species, to reflect this information. 

Comment AR-14: NMFS comments that in its January 24, 2006, filing, it provided its best assessment 

of the likely number of major population groups of fall Chinook salmon, spring/summer Chinook salmon, 

and steelhead that were extirpated with construction of the Swan Falls and Hells Canyon projects, both of 

which are owned by Idaho Power. 

Response: We recognize NMFS expertise in this area and appreciate being notified that we had not 

included this information in the draft EIS. We revised the text in sections 3.8.1.3, Sockeye Salmon; 

3.8.2.1, Snake River Fall Chinook Salmon; 3.8.2.2, Snake River Spring/Summer Chinook Salmon; and 

3.8.2.4, Snake River Steelhead; to include this information. 

Comment AR-15: NMFS comments that while it is true that salmon and steelhead must now migrate 

past eight mainstem dams located along the lower Snake and Columbia rivers to reach the ocean, NMFS’s 

Northwest Region Science Center estimates that juvenile survival is, at present, equivalent to that 

observed in the 1960s when only four dams were present. 

Response: We incorporated this information into final EIS section 3.6.1.3, Anadromous Fish Species.

Comment AR-16: NMFS comments that the description of juvenile fall Chinook salmon migration 

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timing in the draft EIS is outdated and did not include the detailed information provided by NMFS in its 

January 24, 2006, filing. This information indicates that the median date of juvenile migration at Lower 

Granite dam has shifter earlier into the summer over the past 10 to 15 years. 

Response: We incorporated this information into final EIS section 3.6.1.3, Anadromous Fish Species.

Comment AR-17: Interior and the Shoshone-Paiute Tribes provide additional information documenting 

that the historic distribution of Pacific lamprey in the Snake River extended upstream to Shoshone Falls, 

and included many of the Snake River’s tributaries. 

Response: We expanded our description of the historical range of Pacific lamprey in final EIS section 

3.6.1.3, Anadromous Fish Species.

Comment AR-18: Interior recommends that FERC revise the draft EIS to include information on water 

quality, flow and operational issues that were discussed in the 1965 report entitled, “Fishery Problems 

Associated with Brownlee, Oxbow, and Hells Canyon dams on the Middle Snake River.” 

Response: The cited report by Haas (1965) focuses on the construction history of the Hells Canyon 

Project, and of the attempts that were made to maintain anadromous fish runs to areas upstream of the 

project. We summarized this history in section 3.6.1.3, Anadromous Fish Species, of the draft EIS. We 

found no other information in the report to be relevant to our analysis of water quality, flow, and 

operational issues, and therefore did not make any changes in the final EIS. 

Passage and Restoration 

Comment AR-19: NMFS comments that mitigation for impacts of Idaho Power’s mid-Snake projects on 

anadromous fish should be added to the list of 11 principal issues that the draft EIS addresses. NMFS 

states that the draft EIS should be revised to elaborate on the effects of these projects on anadromous fish 

and to identify measures to mitigate for those effects that FERC would then incorporate into the project 

licenses. 

Response: The Commission deferred the analysis of cumulative effects on anadromous fish until the 

Hells Canyon proceeding because the types of measures that could be warranted to benefit anadromous 

fish at the mid-Snake projects depends to a large extent on what measures are implemented at the Hells 

Canyon Project. If and when a new license is issued for the Hells Canyon Project or subsequent actions 

are taken to restore anadromous fish populations upstream of Hells Canyon dam, the license amendment 

process would be needed to consider whether additional measures are warranted at the mid-Snake 

projects. 

Comment AR-20: NMFS and ODFW comment that there is no requirement in the FPA for anadromous 

fish reintroduction to occur only if there is a comprehensive plan. NMFS states that rather than 

developing a comprehensive reintroduction plan, NMFS has done what it typically does in FERC 

relicensing proceedings, and has provided its resource management goals and objectives for this 

relicensing. NMFS’s goals for salmon and steelhead recovery in the Columbia River basin include: (1) 

avoid extinction and foster long-term survival and recovery of Columbia River basin salmon and 

steelhead and other species; and (2) conserve the ecosystems upon which salmon and steelhead depend, 

including watershed health. The Forest Service questions the position of Commission staff that 

continuation of hatchery operations by itself is adequate mitigation for the continued loss of natural 

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production of anadromous fish from within and upstream of the project. The Forest Service states that 

staff, by relying on continued hatchery production as the sole mitigation for lack of passage at the project, 

has missed an opportunity to address habitat and natural production issues at one of the most significant 

human-made blockages for migratory fish remaining in the Columbia River System. AR/IRU 

recommend that the Commission require Idaho Power to immediately begin implementation of a 

spring/summer Chinook salmon and steelhead passage program and that the Commission require a 

detailed adaptive management process for studying and implementing passage of fall Chinook salmon. 

Response: In our view, a decision to proceed with restoring salmon and steelhead to areas upstream of 

Hells Canyon dam could provide large-scale benefits, but may also have a wide array of societal 

consequences. A comprehensive planning effort is needed to bring these wide ranging concerns and 

interests together. This planning effort does not need to be linked to any specific licensing proceeding, 

because appropriate environmental measures can be implemented through the license amendment process 

at any time. Many of the measures that we include as part of the Staff Alternative could help lay the 

groundwork for this type of planning effort by: (1) providing relevant information; (2) improving habitat 

conditions in potential restoration areas; (3) constructing facilities that could be used to pass anadromous 

fish; and (4) increasing the number of fish available for restoration efforts. Measures in the first category 

include establishing a water quality monitoring station at the head of Brownlee reservoir; compiling water 

quality data from upstream parts of the basin; monitoring tributary habitat enhancements in the Burnt, 

Powder, Wildhorse, Indian, and Pine basins; monitoring habitat use by surplus hatchery steelhead and 

spring Chinook salmon in Pine and Indian creeks; and observing behavior and habitat use, as well as 

reproductive success, of surplus adult salmon and steelhead released in tributaries to support tribal and 

recreational harvest fisheries. Measures in the second category include tributary enhancements in the five 

basins listed above and DO enhancement measures that are implemented upstream of Hells Canyon dam. 

Measures in the third category include improvement of the adult trapping facility at Hells Canyon dam; 

installation of a trap and weir (operable year-round) in Pine Creek; and eventual installation of additional 

passage facilities at Oxbow dam, Indian Creek, and Wildhorse River. Measures in the fourth category 

include flow augmentation, continuation of the fall Chinook spawning and incubation flow program, 

measures to improve DO and TDG levels, implementation of seasonal ramp rate restrictions, and 

construction of a new hatchery on Yankee Fork in the Salmon River basin. 

Comment AR-21: The Umatilla Tribes and the Nez Perce Tribe comment that FERC should require 

Idaho Power to conduct specific passage studies and stock evaluations to assess the feasibility of 

anadromous fish restoration. Both tribes note that they, as well as other stakeholders, recommended that 

Idaho Power fund, develop, and implement a salmon and steelhead reintroduction plan, in consultation 

with interested tribes and state and federal fishery agencies. Interior and the Shoshone-Paiute Tribe 

recommend that the final EIS evaluate and recommend studies using radio-tagged adult fall Chinook 

salmon to monitor the migration, spawning, and egg-to-fry survival upstream of Brownlee reservoir. 

NMFS comments that waiting to conduct biological studies until water quality is sufficient to support 

reintroduction would unnecessarily delay fish reintroduction by many years or decades. NMFS states that 

fish passage investigations at other major hydroelectric projects in the Pacific Northwest have proven to 

take considerable time and effort. ODFW recommends initiating studies of fall Chinook passage in the 

near term so that passage could occur as soon as the habitat is capable of supporting fish. 

Response: Our analysis in the EIS leads us to conclude that it may be several decades before much of the 

habitat upstream of and within the project area will be restored to a condition that is suitable for the 

reintroduction of anadromous fish. Our view is that it would be more appropriate to initiate passage 

studies and stock evaluations closer to the time when habitat and water quality conditions would support 

both rearing and passage. We note that fish tracking technologies will likely continue to improve in the 

future, and that it is uncertain which of the upstream reaches and tributaries will be the first to have 

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habitat that is suitable for restoration. Deferring studies until water quality conditions have improved will 

allow studies to be directed at resolving passage issues at the appropriate reaches and to take advantage of 

advancements in fish tracking techniques. 

Comment AR-22: The Shoshone-Bannock Tribes comment that they provided, as part of their draft EIS 

comments, a draft reintroduction plan that they recommend serve as the basis for a phased reintroduction 

plan. Also, the Shoshone-Bannock Tribes state that all parties advocating for reintroduction in this 

proceeding agree that planning is a logical first step in the process. The Forest Service comments that 

many recent FERC licenses for barrier dams in the Pacific Northwest have included requirements to 

develop anadromous fish reintroduction plans, including the Cowlitz, Lewis, Pelton/Round Butte, and 

North Umpqua projects. They state that in these other cases, the utility involved recognized the lack of 

passage as being a major project effect and worked with the other parties to develop a fish passage plan 

acceptable to all involved. The Forest Service comments that from the outset of the Hells Canyon Project 

relicensing, Idaho Power has resisted providing fish passage at the project and has been unwilling to 

participate in the development of such a cooperative plan. 

Response: The draft reintroduction plan filed by the Shoshone-Bannock Tribes represents a listing of 

many of the recommended terms and conditions that we evaluated in the draft EIS. Because the draft 

plan does not provide any substantive new measures, we do not evaluate it further in this final EIS. 

Nonetheless, we note that compared to the comprehensive planning effort that we describe above, the 

Shoshone Bannock’s plan is not based on a process that brings the full range of stakeholders together to 

balance the interests of all parties that would be affected by anadromous fish restoration. With respect to 

the Forest Service’s reference to other projects in the Pacific Northwest, the notable difference between 

the Hells Canyon Project and these other proceedings is that the other proceedings all included 

settlements, which provide the Commission with a much higher level of assurance that the benefits and 

consequences of restoration have been considered and resolved in a manner that is much more likely to 

serve the public interest. 

Comment AR-23: AR/IRU comments that it is unreasonable to require the agencies to develop a 

comprehensive plan for anadromous fish restoration, since the elimination of passage was caused by the 

Commission’s decision to license construction of the project and to allow its continued operation without 

fish passage. They state that if the Commission finds that passage is warranted and a comprehensive plan 

is needed, then the Commission should take the initiative to see that such a plan is created. AR/IRU 

recommends that the Commission clearly identify what would trigger a fish passage decision, as well as 

who would have authority to trigger such a decision. 

Response: We are not requiring anyone to develop a comprehensive plan. We maintain, however, that 

prior to restoring anadromous fish passage to areas upstream of the project, we believe that a cooperative 

process is needed to address the full range of concerns of the parties that would be affected by 

reintroduction. If such a process were to occur and the outcome supports the initiation of reintroduction 

and passage measures at the Hells Canyon Project are needed, the development of necessary fish passage 

studies and measures could be triggered by: (1) NMFS or FWS exercising their Section 18 authority to 

prescribe fishways; (2) re-opening the license at the request of a fish and wildlife agency; or (3) action of 

the Commission after opportunity for public hearing. Any of these actions could be triggered by a 

demonstration of substantial improvements in water quality in the Snake River upstream of the project or 

the filing of a comprehensive plan demonstrating that the initiation of a program to restore anadromous 

fish to areas upstream of the project is in the public interest. 

Comment AR-24: The Shoshone-Bannock Tribes comment that the Pacific Northwest Electric Power 

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Planning and Conservation Act of 1980 (Northwest Power Act) constrains the use of cost-effectiveness to 

judge measures required to restore salmon and steelhead populations adversely affected by hydroelectric 

development in the Columbia River basin. The act bars “...power losses and economic costs...from 

precluding biologically sound restoration of anadromous fish in the Columbia River basin...so long as an 

adequate, efficient, economical and reliable power supply is assured.” The Shoshone-Bannock Tribes 

also note that the cost of adding salmon and steelhead reintroduction to Idaho Power Company’s 

proposed measures would be modest, and would constitute a small fraction of the economic benefits 

received by the company, its shareholders, and ratepayers. ODFW comments that the lack of safe, timely, 

and effective passage for anadromous and resident native fish species is a continuing impact of the 

project, and that Oregon law requires mitigation of all ongoing adverse impacts. AR/IRU states that if 

passage of anadromous fish is not implemented, Idaho Power should be required to implement in-lieu 

mitigation that would benefit anadromous fish species affected by the project. 

Response: The FPA requires that the Commission ensure that the project to be licensed is best adapted to 

a comprehensive plan for developing the waterway for beneficial public purposes, and must give equal 

consideration to developmental and environmental values. As discussed in previous responses, the Staff 

Alternative includes measures that would benefit anadromous fish downstream of the project in the near 

term and other measures that would contribute toward the future restoration of anadromous fish to areas 

upstream from the project. We do not agree with the Shoshone-Bannock Tribes’ comment that the cost of 

adding salmon and steelhead reintroduction would be modest. Restoring fall Chinook salmon would be 

likely to require at least one very large screening facility on the mainstem Snake River, and collecting 

spring Chinook salmon and steelhead produced in tributaries would require smolt traps capable of 

screening high flows that occur during the spring outmigration. For example, we estimate that our 

recommendation to expand the size of the Pine Creek facility to operate year-round would increase the 

capital cost of the facility from $2.5 million to $7.5 million. Regarding ODFW’s comment, we 

acknowledge that the Staff Alternative may be inconsistent with state law. Finally, the Commission 

typically supports measures that address direct project impacts, when they are determined to be in the 

public interest, and generally does not require in-lieu mitigation. However, recognizing the substantial 

cumulative impact that Idaho Power’s projects have had on anadromous fish in the basin, a wide range of 

measures have been adopted in the Staff Alternative that would benefit anadromous fish downstream of 

the project, improve habitat conditions within and upstream of the project, and to support tribal 

ceremonial and subsistence fisheries. 

Comment AR-25: The Umatilla Tribes and the Nez Perce Tribe state that the draft EIS failed to evaluate 

how the measures in the FERC Staff Alternative would qualitatively or quantitatively assist in halting the 

decline of salmon and sturgeon stocks, which is the objective of the CRITFC tribes’ anadromous fish 

restoration plan. 

Response: We listed the measures that would contribute to attaining this objective in section 5.4.2 of the 

draft EIS, and we evaluated the effects of these measures in sections 3.5, Water Quality; 3.6, Aquatic 

Resources; and 5.2, Discussion of Key Issues. 

Comment AR-26: The Shoshone-Bannock Tribes comment that meeting the goal of natural selfsustaining populations may not be possible immediately, and note that this goal is not currently being met 

anywhere in the Snake River basin. The Shoshone-Bannock Tribes and ODFW indicate that 

reintroduction efforts will likely require a long-term infusion of hatchery produced fish, but reliance on 

hatchery supplementation would decrease over time. 

Response: These are factors that it should be considered when a comprehensive plan is developed to 

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restore anadromous fish to areas upstream of the project. 

Comment AR-27: The Shoshone-Bannock Tribes state that restoration of anadromous fish to 

habitat within and above the project is crucial to fulfillment of the tribes’ treaty rights, and that 

the economic, societal, and cultural benefits associated with restoration and recovery of 

anadromous fish runs would outweigh the costs. They further state that while the long-term 

goal of reintroduction is to reestablish self-sustaining populations, there are short and near-term 

reintroduction objectives and opportunities that FERC ignores. These include immediately 

reestablishing the presence of the native assemblage of species above Hells Canyon dam, and 

the related objective of immediately providing opportunity to harvest adult fish of hatchery origin. 

The Shoshone-Bannock Tribes state that these objectives can be quickly achieved and 

sustained under existing conditions. 

The Shoshone-Bannock Tribes discuss several considerations supporting their recommendation 

that Idaho Power construct additional hatcheries at Yankee Fork and Panther Creek. These 

considerations include: (1) Idaho Power has never achieved the spring or fall Chinook 

production goals that it agreed to in the 1980 Settlement Agreement; (2) the Hells Canyon 

Project and the smaller Idaho Power dams on the mid-Snake blocked passage to the most 

productive fall Chinook salmon habitat in the Snake River basin, as well as hundreds of miles of 

tributary habitat formerly occupied by spring/summer Chinook salmon and steelhead; (3) NMFS 

estimates that the blocked habitat historically produced at least 241,280 to 377,000 adult fall 

Chinook salmon; and (4) while the tribes strongly assert that the first priority for anadromous fish 

mitigation must be in-kind and in-place, the enormity of the loss warrants off-site and/or in-lieu 

mitigation, in addition to the in-kind and in-place measures. During tribal consultation meetings 

held in March 2007, the Shoshone-Bannock Tribes indicated that because of the effort they 

have put into habitat restoration in the Yankee Fork, the stream is ready to support fish now and 

implementation of a hatchery on the Yankee Fork would be of great value to them. 

The Shoshone-Paiute Tribes state that Idaho Power’s hatchery program does not serve to restore salmon 

and steelhead runs to the 50-mile-long Marsing reach, where members of the Shoshone-Paiute Tribes and 

other tribes once fished for salmon and steelhead. They also comment that Idaho Power’s fish restoration 

efforts have benefited primarily downriver interests and ignored the losses of the tribes that fished the 

upper Snake River above the project. The Shoshone-Paiute Tribes recommend that, in the short term, 

adult Chinook salmon and steelhead from Idaho Power hatchery facilities should be placed throughout the 

portion of the Owyhee River that flows through the Duck Valley Reservation to create put and take 

fishing opportunities for tribal and non-tribal members. 

Interior comments that unlisted adult steelhead and/or spring Chinook salmon captured at the Hells 

Canyon trap, which are in excess of current management needs, can and should be transported to 

available habitats in both Oregon and Idaho. Interior states that the EIS should discuss the benefits of this 

type of program, including moving anadromous fish into the Weiser, Payette, Powder, Malheur, and 

Owyhee rivers, as well as continuing to release fish into the Boise River. 

Response: We recognize that measures directed at improving fisheries downstream of Hells Canyon dam 

provide no immediate benefit to tribes that historically fished in areas within and upstream of the project. 

Discussion of near-term measures that would be of value to these tribes occurred during the March 2007 

tribal consultation meetings.138 As a result of these meetings, we modified the Staff Alternative to 

 

138 The tribal consultation meetings were publicly noticed, and transcripts of the meetings are part of the 

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include funding for a hatchery on the Yankee Fork as requested by the Shoshone-Bannock Tribes, and to 

require that Idaho Power develop a plan for using surplus unlisted hatchery salmon and steelhead to create 

and support harvest fisheries for the Shoshone-Paiute and Burns Paiute Tribes at locations to be 

determined in consultation with these tribes. A secondary objective of the plan would be to allocate 

surplus fish for stocking in project reservoirs and tributaries within the project area as a means to restore 

marine derived nutrients and provide forage for bull trout in tributaries within the project area. State and 

federal fisheries management agencies would also be consulted during plan development to ensure that 

actions implemented through the plan are consistent with fisheries management objectives, bull trout 

recovery, and other ongoing restoration efforts. 

Comment AR-28: NMFS comments that the reintroduction of fall Chinook salmon into areas upstream 

from Brownlee reservoir, and of spring Chinook salmon and steelhead into project reservoir tributaries, 

are quite different in scale and scope, and should be treated separately. 

Response: We expanded the analysis and discussion in the final EIS to address issues specific to the 

restoration of mainstem-spawning fall Chinook salmon versus those issues specific to the restoration of 

tributary-spawning steelhead and spring Chinook salmon. 

Comment AR-29: NMFS comments that Snake River fall Chinook salmon historically had three viable 

populations, but that two of the three populations were extirpated by Idaho Power’s Swan Falls and Hells 

Canyon projects. NMFS states that the Columbia River Recovery Team has advised it that the long-term 

risk of extinction of a species with only one viable population is substantially higher than if there were 

two viable populations. 

Response: We added this information to final EIS section 3.8.1.1, Fall Chinook Salmon.

Comment AR-30: NMFS comments that it views funding TMDL improvements as a vital step toward 

successfully restoring salmon and steelhead to historically important spawning and rearing habitat 

upstream of the project. NMFS comments that FERC staff’s analysis identifies, but fails to analyze, its 

proposed water quality enhancement fund as part of its reintroduction strategy. NMFS states that the 

measure is conceptually no different than the upstream habitat work that staff adopted for bull trout. 

NMFS also states that funding water quality improvements would comply with the comprehensive 

development standard because such improvements fit within state TMDL programs, the major federal and 

state effort to recover salmon and steelhead in the Columbia River basin, and NMFS’s goals for this 

project. Finally, NMFS comments that FERC should consider the effects of Idaho Power’s mid-Snake 

projects in considering its funding recommendation since the Scoping Document 2 for those projects 

deferred the consideration of cumulative effects on anadromous fish to the Hells Canyon EIS. 

The Forest Service comments that staff’s recommendation to track and report on changes in upstream 

water quality is relatively meaningless. The Forest Service states that, without some seed money or other 

monetary incentive such as that proposed by the agencies in the upstream fund concept, there is no 

incentive to make substantial water quality improvements within the timeframe encompassed by the new 

license, and that little improvement in water quality is likely to occur. The Shoshone-Bannock Tribes 

comment that FERC must require Idaho Power to contribute to the restoration of Upper Basin water 

quality, because such restoration is a necessary prerequisite to reintroduction of fish stocks to much of 

 

public record for the project. The transcripts may be obtained through eLibrary at www.ferc.gov. 

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their historic habitat. 

Response: We expanded the text in section 3.6.2.6, Anadromous Fish Restoration, to include evaluation 

of the potential benefits of providing TMDL funding as recommended by NMFS. However, we conclude 

that it would not be appropriate to require Idaho Power to implement measures to reduce nutrient loads 

attributable to upstream sources, given that Idaho Power’s projects on the Snake River, taken as a whole, 

serve to reduce the nutrient loads that are delivered to areas downstream of the project. Although we 

recognize that TMDL funding is conceptually similar to the tributary habitat enhancement program that 

we adopt in the Staff Alternative, there are several key differences, including: (1) greater geographic 

proximity of tributary measures to the project; (2) direct effects of the project on habitat connectivity 

between tributaries and inundation of the lower portion of each tributary by project reservoirs; and (3) 

greater certainty that the measures would provide substantive and documentable benefits to aquatic 

resources in the project area within the near future. 

We also adopted measures proposed by Idaho Power in its application for water quality certification to 

meet its responsibility under the nutrient and temperature TMDLs. These include an evaluation of 

alternative measures such as phosphorus trading and watershed measures that would provide broader 

ecological benefits than the measures that Idaho Power proposed in its license application. 

As discussed in previous responses, we also include numerous measures in the Staff Alternative that 

would benefit anadromous fish downstream of the project in the near term, other measures that would 

contribute to the future restoration of anadromous fish to areas upstream from the project, and other 

measures that would create tribal ceremonial and subsistence fisheries. The scope of the aquatic measures 

that we recommend in the final EIS reflect the substantial cumulative effects that Idaho Power’s midSnake and Hells Canyon projects have had on fisheries for resident and anadromous fish, including the 

blockage of anadromous fish from habitat upstream of Hells Canyon dam. 

Comment AR-31: NMFS states that FERC may have mislabeled some of the components of 

recommendation 14, since parts 14b, 14c, and 14f are not addressed in the EIS. These parts 

recommended the formation of a committee to oversee and evaluate which projects would receive funds, 

to evaluate the effectiveness of projects funded by the water quality improvement account, and determine 

whether monies should be shifted to different projects. 

Response: Because of the large number of individual recommendations that we evaluated in the draft 

EIS, we consolidated some recommendations to facilitate our analysis. We considered parts a, b, c and e 

of your recommendation 14 to be components of your recommendation to provide funding for TMDL 

implementation, and we addressed them as a single measure that we referred to as measure NMFS-14a in 

the draft EIS. To improve the clarity of our analysis in the final EIS, we expanded our description and 

discussion of measure NMFS-14, and we discuss all components of this recommendation together as a 

single measure to avoid any confusion that was introduced by the numbering system that we used in the 

draft EIS. We also revised the 10(j) table to follow the sub-element designations used in NMFS’s letter. 

Comment AR-32: NMFS comments that its recommendation to monitor water quality downstream of 

the Bliss, C.J. Strike, and Swan Falls dams is a vital part of its proposed program to restore fall Chinook 

salmon to habitat upstream of the project, and is necessary to determine when passage will be appropriate. 

NMFS states that there is a nexus with these upstream projects because FERC decided to defer addressing 

anadromous fish issues for these projects and consider them, instead, during the Hells Canyon relicensing. 

Response: The restoration of fall Chinook salmon to areas upstream of Swan Falls or C.J. Strike dams 

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would require that downstream passage be implemented at those dams. Accordingly, the potential for 

restoration of fall Chinook salmon to areas upstream of either dam would need to be addressed through 

the upcoming Swan Falls relicensing proceeding for the C.J. Strike reach or through re-opening the C.J. 

Strike license for the Bliss reach. We include monitoring of water quality conditions in the Snake River 

just upstream of Brownlee reservoir in the Staff Alternative, which would be useful for monitoring trends 

to determine when it would be appropriate to initiate fall Chinook salmon restoration studies in the Swan 

Falls reach. We note that provisions for monitoring water temperature and DO downstream of Idaho 

Power’s Upper and Lower Salmon Falls, Bliss and C.J. Strike were included in the licenses, and we 

recognize that water quality monitoring will be an issue in the Swan Falls licensing proceeding. We 

conclude that the monitoring provisions included in each license are appropriate and should be sufficient 

for tracking water quality improvements. 

Comment AR-33: NMFS, IDFG, and ODFW comment that water quality monitoring alone would not 

be sufficient to determine the condition of incubation habitat upstream of the project. They state that DO 

can vary, particulates can be different, and algae mats do not show up as water quality parameters but are 

important for gravel suitability. They note that monitoring egg-to-fry survival is a relatively low cost 

measure that provides important information for reintroduction. 

Response: We expanded our discussion of this issue in the final EIS. We recognize that the amount of 

sediment in the substrate affects DO levels within the gravel by affecting the flow of water through the 

substrate and biological oxygen demand from decomposing organic material. We conclude in the final 

EIS that a reduction in seasonal peak flows caused by water storage at upstream reservoirs operated by 

BOR has likely contributed to the build-up of fine sediment in the intragravel environment and the 

establishment of rooted aquatic vegetation. We maintain that substantial improvements in the condition 

of the intragravel incubation environment will require a sustained improvement in overall water quality 

(i.e., reduced nutrient loading), followed by one or more substantial high flow events to dislodge rooted 

aquatic vegetation and to cleanse fine sediments from potential spawning areas. Accordingly, we 

conclude that at this time, it would be premature to require Idaho Power to initiate restoration studies, 

including additional monitoring of incubation survival. 

Comment AR-34: The Shoshone-Bannock Tribes comment that FERC failed to consider evidence 

provided by the tribes, which suggests that water quality above Brownlee reservoir has not changed 

substantially since the 1960s (Keller Bliesner & Associates report, filed with the Shoshone-Bannock 

Tribes response to REA notice). The Shoshone-Bannock Tribes state that the report concludes that only 

slight improvements in water quality in the Upper Snake River will establish habitat necessary for 

successful anadromous fish passage and reintroduction. 

The Shoshone-Paiute Tribes comment that, due to high quality spring discharges and flows over 5,000 

cfs, both the Bliss and C.J. Strike reaches of the Snake River are suitable to justify live adult fall Chinook 

and egg incubation studies. They state that both reaches were primary anadromous fishing grounds for 

the tribes. Interior comments that it believes that water quality conditions in the Bliss and C.J. Strike 

reaches are sufficient to warrant egg incubation studies, and recommends that FERC staff reassess the 

proposed fall Chinook restoration studies and include them for early implementation in the anadromous 

fish passage plan. 

Response: We modified sections 3.0, Environmental Analysis, and 5.0, Staff’s Conclusions, in the final 

EIS to include information from the cited report. We recognize that the report indicates water quality 

conditions in the Swan Falls reach have changed little since the project was constructed. However, the 

intragravel monitoring studies conducted by Idaho Power demonstrate that the current condition of 

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spawning habitat in the Swan Falls reach is not adequate to provide for successful incubation to survival. 

The report also indicates that conditions in the C.J. Strike reach are beginning to improve. 

Comment AR-35: Interior states that the weir to be constructed on Pine Creek could serve as an 

evaluation tool for anadromous fish in addition to serving a key role in bull trout restoration. It also states 

that steelhead passed upstream of Hells Canyon dam are now successfully spawning in Pine and Indian 

Creeks, according to data from IDFG, ODFW, and Idaho Power, and that there is a put and take steelhead 

fishery in the Boise River. Thus, Interior recommends that FERC reanalyze the feasibility of 

reintroducing both steelhead and spring/summer Chinook salmon to tributary habitats. ODFW 

recommends that the monitoring weir should be designed for year round operation and for collection and 

handling of resident and anadromous species, and that the weir be designed to function at high spring 

flows when smolt migration occurs. 

Response: The reported observation of steelhead spawning in Pine and Indian creeks does not alter our 

conclusion that it would be premature to undertake restoration of passage to habitat within or upstream of 

the project in the absence of a comprehensive plan. However, we modified the text in sections 3.0, 

Environmental Analysis, and 5.0, Staff’s Conclusions, to include a discussion of the potential for the Pine 

Creek weir to be used to monitor the reproductive success of any surplus hatchery steelhead and spring 

Chinook salmon that enter Pine Creek after they have been released into Hells Canyon reservoir. To meet 

this objective, and to provide better information on the timing of bull trout migration, we recommend that 

Idaho Power design the Pine Creek weir to function year-round, encompassing at least 90 percent of the 

flows that occur in the stream during an average water year. 

Comment AR-36: ODFW recommends immediate initiation of studies in Oregon tributaries to 

support spring Chinook salmon and summer steelhead reintroduction. According to ODFW 

fishery biologists and available water quality information, habitat is sufficient in Pine, Eagle, 

Goose, and Daly creeks to warrant reintroduction in the near term and certainly within this 

license term. 

The Shoshone-Bannock Tribes comment that the resource agencies and tribes identified many 

tributaries as viable candidates for immediate reintroduction of spring Chinook and steelhead. 

They state that the Lower Middle Snake River Subbasin Plan found that existing habitat in Pine, 

Eagle, Goose, Daly, and Big creeks would sustain summer steelhead and spring Chinook 

salmon. They also comment that providing fish passage to Pine Creek, Indian Creek, the 

Wildhorse River and Eagle Creek would reopen 200 linear miles of suitable habitat with the 

potential to produce 500 adult spring Chinook salmon and 5,000 adult steelhead. The Tribes 

also state that production potential would increase considerably with implementation of the 

tributary habitat restoration efforts proposed by Idaho Power. They state that there is a vast 

area of existing, high-quality habitat for salmon and steelhead in the upper reaches of the 

Payette River basin, which IDFG estimated contains 43 percent of the spring Chinook habitat 

and 39 percent of the summer steelhead habitat remaining in the Snake River basin above Hells 

Canyon dam. 

The Shoshone-Paiute Tribes comment that suitable habitat exists upstream of Hells Canyon 

dam, where water quality and habitat conditions are not the primary limiting factors. They state 

that the final EIS should analyze the benefits of, and include in the Staff Alternative, a program 

for transporting adult steelhead and Chinook trapped at Hells Canyon dam into a number of 

tributaries including, but not limited to, the Owyhee and Bruneau Rivers. They recommend that: 

(1) adult Chinook and steelhead from the hatchery facilities be placed throughout the portion of 

the Owyhee River that flows through the Duck Valley Reservation; (2) Chinook salmon and 

steelhead be reintroduced in the Owyhee River; (3) full-scale reintroduction be implemented in 

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the Bruneau River, including Marty’s Creek; and (4) reintroduce fall Chinook salmon to the 

mainstem Snake River from Brownlee reservoir to the base of Upper Salmon Falls. 

Response: As stated previously, a decision to proceed with restoring anadromous fish to areas upstream 

of Hells Canyon dam could provide a wide range of benefits but would also have a variety of societal 

consequences. We conclude that development of a comprehensive plan outside of the licensing process 

would provide an opportunity for the concerns and interests of different users to be aired and considered. 

Moreover, such a comprehensive plan would allow for greater collaboration in the development of 

restoration approaches than is possible during a contested relicensing proceeding. When such a planning 

effort determines that proceeding with studies or the installation of passage facilities is warranted, 

measures could be implemented at the Hells Canyon Project through a variety of methods, including: 

(1) NMFS or FWS exercising section 18 authority to prescribe fishways; (2) amending the license at the 

request of a fish and wildlife agency; or (3) action of the Commission after opportunity for public hearing. 

Regarding the Shoshone-Paiute’s recommendation that adult hatchery Chinook salmon and steelhead be 

placed in the Owyhee River, we modified the Staff Alternative to require Idaho Power to develop a plan 

for using surplus hatchery salmon and steelhead to create and support harvest fisheries for the ShoshonePaiute and Burns Paiute tribes at locations to be determined in consultation with these tribes. 

Comment AR-37: ODFW recommends that reintroduction studies in Powder River tributaries be started 

immediately following completion of studies in Pine Creek and the installation and testing of the Pine 

Creek weir. ODFW fully expects to rely on hatchery supplementation at least initially to improve the 

likely success of reintroduction. ODFW recommends that reintroduction proceed into additional 

tributaries and habitats once smolt and adult migration, survival, and trapping studies are completed, 

assuming sufficient hatchery adults are available, and it is determined that that reintroduction should 

proceed. 

Response: We recognize ODFW’s desire to move forward with restoration of anadromous fish to 

tributaries in the Powder River basin. In the final EIS we expanded the tributary enhancement program to 

include the Powder and Burnt River basins. However, for the reasons stated in our response to the 

previous comment, we believe that the costs and benefits of restoring anadromous fish to the Powder 

River basin can best be evaluated in a comprehensive plan developed outside of this contested licensing 

proceeding. Again, year-round operation of the Pine Creek weir would provide useful information on the 

reproductive success of surplus hatchery steelhead and spring Chinook salmon, and assist with future 

decisions regarding the restoration of these species to tributary habitat upstream of Hells Canyon dam. 

Comment AR-38: ODFW comments that within draft EIS table 51, FERC staff indicates that ODFW 

recommends installation of an adult trap at Brownlee dam, a Brownlee smolt trap, and a fish screen at 

Hells Canyon dam. ODFW states that it has not recommended adult or smolt traps at Brownlee dam. 

Response: We modified draft EIS table 51 (final EIS table 56) accordingly. 

Comment AR-39: ODFW states that tributary trapping is not recommended for all tributaries with 

native fish nor is it expected to occur year round. ODFW also states that tributary weirs proposed by 

Idaho Power are not designed to be operational under all conditions or across all flows. For these reasons 

and because migratory species display a diversity of life-history characteristics, ODFW continues to 

recommend investigating the installation and operation of a downstream passage facility at Hells Canyon 

dam during the term of this license. 

Response: We recommend that Idaho Power design the Pine Creek weir and trap to operate year-round 

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to encompass typical high flow conditions. If the results of monitoring reproductive success of surplus 

hatchery steelhead and spring Chinook salmon in Pine Creek are favorable, we anticipate that the Indian 

Creek weir and trap would also be designed to operate year-round when it is constructed. Construction of 

these weirs to operate year round would allow the majority of migratory fish to be collected and 

transported downstream of Hells Canyon dam without risk of mortality from entrainment through the 

project’s turbines or from passing over the project’s spillway. While we acknowledge that installing a 

downstream passage facility at Hells Canyon dam would allow outmigrants from these creeks to rear in 

Hells Canyon reservoir with a reduced risk of turbine entrainment, this benefit would come at a 

disproportionately high cost for the construction and operation of a substantial downstream passage 

facility at the dam. 

Comment AR-40: Based on historical estimates of fish abundance, ODFW states that it does not agree 

with FERC staff’s estimates of the number of adult steelhead that could be produced from tributaries 

within the project area. ODFW also states that it expects production to increase with implementation of 

TMDLs and tributary enhancement measures, and through the implementation of additional measures to 

improve juvenile salmon survival through the Federal Columbia River Power System migratory corridor. 

Response: We revised the final EIS to note that the adult return estimates in draft EIS table 55 (final EIS 

table 60) appear to be conservative, and we now include an alternative estimate of 2,700 adult steelhead 

for Pine and Indian Creeks based on returns to the Hells Canyon dam trap in its first three years of 

operation. We also revised our estimates using species-specific survival rates taken from table 3 of 

Chapman and Chandler (2003). We note that there is potential for increased returns as tributary 

enhancements and TMDLs are implemented, and as additional measures are implemented to increase 

survival rates in the lower Snake and Columbia River migration corridors. 

Comment AR-41: The Umatilla Tribes and the Nez Perce Tribe recommend that Idaho Power contribute 

to the funding of regional evaluations of Pacific lamprey stocks. 

Response: As an outcome of the 10j process, we revised the Staff Alternative to include a measure that 

would require Idaho Power to participate in regional forums on Pacific lamprey restoration. Also, Idaho 

Power would be required to file a report with the Commission every 3 years summarizing the results of 

research activities that may affect the potential for implementing measures at Hells Canyon to benefit 

Pacific lamprey. 

Comment AR-42: Interior comments that Pacific lamprey are present in the Salmon and Clearwater 

basins, and states that the number of lamprey passing fish counting windows is often not accurately 

enumerated. Interior supports efforts to restore lamprey to their former abundance throughout the 

lamprey’s accessible range in the Snake and Columbia rivers. Interior recommends that monitoring and 

reporting protocols be developed for this species. Interior also recommends that the Columbia River 

lamprey workgroup should be tasked to develop a meaningful lamprey enumeration protocol and then to 

explore solutions to pass lamprey around the project dams. 

Response: We consider the effects of the Hells Canyon Project on the population size of Pacific lamprey 

to be limited, given the substantial migration challenges that are posed by downstream projects as 

reflected by the small number of lamprey that are counted passing Lower Granite dam. However, it is 

clear that the project blocks access to a substantial amount of habitat that was historically used by this 

species, and affects downstream habitat by interrupting sediment recruitment. Additionally, flow ramping 

may affect migratory movement of the lamprey in the river downstream from the project. Accordingly, 

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we revised the Staff Alternative to require Idaho Power to participate in regional forums on Pacific 

lamprey restoration, and to file a report with the Commission every 3 years summarizing the results of 

research activities, identifying any new information that is applicable to addressing project impacts, and 

any new measures that are proposed to address effects on this species. 

Comment AR-43: The Umatilla Tribes and the Nez Perce Tribe state that Idaho Power should be 

required to develop a lamprey passage plan with a goal of no net effect of the project on Pacific lamprey. 

They state that the presence and operation of the project, without any mitigation for the loss and 

cumulative and synergistic impacts to lamprey, directly contribute to the seriously depressed lamprey 

numbers found today in the lower Snake River and elsewhere. They state that FERC staff apparently do 

not adequately understand or appreciate the cultural and spiritual importance of lamprey to tribal people 

in the Columbia Basin. The Shoshone-Paiute Tribes comment that because lamprey occur in the Salmon 

and Clearwater basins, it is clear that the Hells Canyon project is blocking lamprey from using habitat 

upstream of Hells Canyon dam. The Shoshone-Paiute Tribes state that there is a significant benefit to 

considering lamprey passage at the project, and this issue needs to be analyzed in the final EIS. 

Response: See our response to the previous comment. Also, we understand that efforts to improve 

upstream passage at downstream dams are underway. However, given the small numbers of adult 

lamprey that pass Lower Granite dam and the large amount of underseeded lamprey habitat that is 

available in tributaries to the Hells Canyon reach, we consider it premature to initiate passage studies at 

the Hells Canyon Project. 

Comment AR-44: The Umatilla Tribes and the Nez Perce Tribe comment that the draft EIS recommends 

no lamprey measures for the project. Thus, the Umatilla Tribes and the Nez Perce Tribe state that the 

draft EIS fails to address the objective of halting the decline of Pacific lamprey stocks impacted by the 

project. 

Response: We recognize that no measures are proposed for immediate implementation. However, as 

described in the preceding response, we recommend a measure that would require Idaho Power to 

participate in regional forums to evaluate and, if warranted, implement measures to enhance lamprey 

restoration efforts. 

Comment AR-45: ODFW states that Idaho Power should: (1) develop, fund and implement habitat 

enhancement measures designed to improve mainstem and tributary habitat conditions for Pacific 

lamprey; (2) monitor Pacific lamprey using tributaries and the mainstem Snake River downstream of 

Hells Canyon dam; and (3) prepare a report on adult and juvenile counts at mainstem dams and juvenile 

trapping in tributaries to the Snake River. ODFW states that, in lieu of operational changes at the project 

(e.g., increased spring flows and reduced ramping) and absent a gravel and sand augmentation program 

below Hells Canyon dam to improve margin and juvenile lamprey rearing habitat, Idaho Power should 

contribute annually towards improvement of tributary habitat above, within, and below the project. 

Similarly, AR/IRU comments that an overt program to restore lamprey is likely the only solution to the 

problem of lamprey survival. ODFW also recommends that Idaho Power develop a detailed upstream and 

downstream passage plan for Pacific lamprey. Such a plan would have an extended timeframe of 10 to 20 

years to allow for advances in tagging technologies, passage technologies, and increased escapement to 

the Snake River, as well as allow for completion of upstream and downstream passage facilities for 

salmonids. 

Response: We recognize that the Hells Canyon Project blocks Pacific lamprey from a large area of 

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formerly occupied habitat. However, we maintain that conditions in the downstream migratory corridor 

are the primary factor limiting the abundance of this species in the Snake River basin upstream of Lower 

Granite reservoir, and that predation may limit the potential for providing downstream passage of juvenile 

lamprey through the project reservoirs. However, the installation of tributary traps, as detailed in 

Interior’s modified fishway prescription, would allow passage to and from the Pine, Indian and Wildhorse 

drainages to be implemented if the number of Pacific lamprey returning to the Snake River increase to 

levels that suggest that the species may benefit from access to additional habitat. As noted above, we 

revised the Staff Alternative to require Idaho Power to participate in regional forums on Pacific lamprey 

restoration, to report the number of Pacific lampreys that have been collected in the Hells Canyon fish 

trap, and to identify and implement reasonable studies and/or measures to enhance Pacific lamprey 

restoration efforts in the Snake River. 

Spawning Habitat 

Comment AR-46: NMFS expresses concern that the maintenance of steady flows between 8,000 and 

13,000 cfs during the fall Chinook salmon spawning season is characterized as a voluntary operation. 

NMFS considers this operational measure to be necessary to prevent harm to fall Chinook salmon redds, 

and urges FERC to make this a mandatory license requirement. 

Response: We modified the wording of the Staff Alternative to specify that flows are to be maintained 

between 8,500 and 13,500 cfs during the fall Chinook salmon spawning period, consistent with NMFS’s 

10(j) recommendation. 

Comment AR-47: IDFG comments that, in addition to Idaho Power’s proposed fall Chinook spawning 

flow program, a flow management plan should be developed, in consultation with IDFG and others, to 

determine appropriate monitoring methods for use in determining flow levels to be maintained 

downstream from the Hells Canyon dam during the fall Chinook spawning and incubation season. The 

Umatilla Tribes and the Nez Perce Tribe state that it is not clear how the October-December fall Chinook 

spawning flow is determined in real time, and whether the process takes advantage of new advances in 

water supply forecasts to ensure better management of Brownlee reservoir elevations. 

Response: As part of the Staff Alternative, we recommend that Idaho Power develop and implement a 

fall Chinook spawning and incubation flow management plan. Within this plan, Idaho Power would 

determine appropriate monitoring methods to assist with deriving flow levels to be maintained 

downstream from Hells Canyon dam during the fall Chinook spawning and incubation season. We added 

a requirement that the plan be developed in consultation with NMFS, FWS, IDFG, ODFW, and interested 

tribes139. 

 

139 We use the term “interested tribes” to be inclusive of all tribes that have been active participants in 

the relicensing proceeding, including the Nez Perce, Umatilla, Shoshone-Bannock, Shoshone-Paiute, 

and Burns Paiute tribes. Several of these tribes do not have federally recognized treaty fishing rights 

pertaining to existing anadromous fisheries downstream of the project. However, all of these tribes 

historically hunted and fished in areas that have been affected by the existence and operation of the 

project. It is our view that all of these tribes, including those that historically used areas upstream of 

the project, should be offered the opportunity to participate in consultation regarding measures that 

could affect anadromous and resident fish (to include measures affecting habitat and water quality), as 

well as plants and wildlife species of value to the tribes. This view is based on the premise that even 

measures that would affect only downstream habitat could help increase the abundance of fish that 

could be used in upstream restoration efforts, and that both fish and wildlife may move among the 

lands that are or were used by multiple tribes. 

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Comment AR-48: The Umatilla Tribes and the Nez Perce Tribe comment that continued monitoring of 

both shallow and deepwater fall Chinook redds is the best means of tracking the effective number of 

spawners, as well as the success of efforts to restore the population. Based on a number of factors, the 

tribes indicate that continuation of complete (shallow and deepwater) redd counts would be important as 

confirmation of population recovery and evidence of sufficient spawning gravels 

Response: As part of its proposed gravel monitoring plan filed with its comments on the draft EIS, Idaho 

Power committed to continuing both shallow and deepwater redd counts on an annual basis for the term 

of the license. Aerial helicopter surveys would be conducted from Asotin, Washington (RM145), 

upstream to the Hells Canyon dam (RM247.5). Video searches for deep-water spawning locations would 

continue to be conducted on an annual basis. In the final EIS, we adopted Idaho Power’s proposed gravel 

monitoring plan, including shallow and deepwater surveys, in the Staff Alternative. 

Rearing Habitat 

Comment AR-49: AR/IRU comments that in describing current operations, FERC includes a figure 

showing monthly reservoir fluctuations, but does not provide a similar depiction of shorter term changes 

in river elevation due to ramping. AR/IRU states that ramping and ramping rates are discussed 

throughout the document, but that FERC staff omitted a depiction of what the extent of ramping means in 

terms of actual changes in discharge and effects on river stage. AR/IRU also states that, in describing 

how Oxbow reservoir is currently used to re-regulate discharges from Brownlee, staff failed to discuss the 

extent to which there is additional capacity to limit flow fluctuations downstream from Hells Canyon 

dam. AR/IRU also comments that there is no indication that any of the ramping rates analyzed in the 

draft EIS would be measured below the dam. 

Response: Plots of hourly simulated flow rates at Hells Canyon dam and at Anatone (near the head of 

Lower Granite reservoir) are shown for three water years representing extreme low, medium, and extreme 

high water years for proposed operations and five evaluation scenarios in appendix D of the draft EIS 

(appendix E of the final EIS). Hourly changes in wetted area for the same years and scenarios are shown 

in draft EIS figures 37 through 46 (final EIS figures 56 through 65). While we did not include plots of 

reservoir elevations under scenario 1a (outflows from Hells Canyon dam equal to average preceding 24 

hours of inflows) in the draft EIS, plots filed by Idaho Power with their February 3, 2005 response to AIR 

OP-1(f) indicate that outflows could be fully re-regulated by Hells Canyon reservoir, with a typical 

fluctuation of less than 5 feet in the reservoir. We outlined the operational constraints that were used in 

Idaho Power’s modeling of the operational scenarios in appendix C of the draft EIS (appendix D of the 

final EIS). As specified in appendix table 7, Scenario 3 (navigation) was the only evaluation scenario 

where compliance was based on ramp rates measured at Johnson Bar; compliance for all other scenarios 

was based on measurement within 1.0 mile of Hells Canyon dam, as we specified in the additional 

information request. 

Comment AR-50: NMFS recommends that FERC analyze the likely amount of streambed that would be 

dewatered by the Staff Alternative’s 4-inches-per-hour ramping limit. 

Response: As previously explained, we designed our requested model runs to bracket the anticipated 

range of recommendations that would be received after the REA notice was issued. We believe that the 

model runs that used 2 and 6 inches per hour provide a sufficient understanding of the effects on wetted 

area and fish habitat associated with the 4-inch-per-hour ramp rate that we include in the Staff 

Alternative. In addition, we recommend that Idaho Power develop a stranding and entrapment 

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management plan, as well as an invertebrate monitoring plan, to assess the effects of load following on 

invertebrate production and on rare and sensitive mollusks. Both of these plans would be developed in 

consultation with NMFS, FWS, IDFG, ODFW, and interested tribes, and would include provisions for 

developing and implementing modified operational constraints, if warranted, based on monitoring results. 

Comment AR-51: NMFS states that it updated information on growth rates of juvenile fall Chinook 

salmon in its January 24, 2006, filing. It states that this recent information indicates that growth rates of 

fish captured and tagged in the Hells Canyon Reach of the Snake River and recaptured at Lower Granite 

dam have decreased slightly as the number of redds and rearing juveniles has increased. NMFS believes 

that this is an initial indication of density-dependent effects stemming from the relatively large number of 

juveniles rearing in the remaining habitat between Hells Canyon and Lower Granite dams. IDFG, 

however, states that there is no evidence to support the conclusion that increased competition for food and 

space has resulted in smaller outmigrating fish. IDFG agrees that competition could lead to reduced 

growth, but so could temperature. IDFG also states that earlier outmigration could be a function of more 

naturally spawning hatchery fish, which in many instances tend to have an earlier spawn timing. 

Response: We updated the information in section 3.6.1.3, Anadromous Fish Species, to incorporate the 

information on recent trends in growth and migration timing of fall Chinook provided by NMFS. We 

conclude that other factors that could affect fall Chinook salmon growth (e.g., water temperatures, 

nutrient levels, or project operations) have not changed substantially during this time period. We also 

conclude that it is likely that reduced growth rates are due to competition, and indicate that the number of 

juvenile fall Chinook salmon rearing in the Hells Canyon reach may be nearing the carrying capacity of 

the habitat. 

Comment AR-52: The Forest Service comments that ramping on the scale present below Hells Canyon 

dam can negatively affect fisheries communities present in affected reaches. It states that impacts can 

include: (1) increasing fry mortality and reducing overall recruitment to the population; (2) dislodging 

and transporting eggs and fry resulting in egg desiccation, physical injury and mortality; (3) stranding and 

trapping fish in the varial zone; (4) relegating fish spawning areas to permanently wetted channels; (5) 

possible food chain effects due to chronic disturbance regime; and (6) fish expending additional energy 

moving laterally to the new locations that may include the varial zone where food supply is reduced by 

dewatering caused by peaking operations. 

Response: We recognize that flow fluctuations have the potential to cause mortality by stranding fry and 

juvenile fish and may adversely affect fish growth by reducing the abundance of food and increasing 

energy expenditures. As noted above, we recommend (1) a seasonal 4-inch-per-hour ramp rate restriction 

to protect rearing fall Chinook salmon fry and juveniles, and (2) Idaho Power develop a stranding and 

entrapment management plan and an invertebrate monitoring plan to assess the effects of load following 

on fish and invertebrate production and on rare and sensitive mollusks. Ramping during the fall Chinook 

spawning and incubation seasons likely has no substantial adverse effects because flows are held at a 

steady rate during the spawning season, and fluctuations are curtailed during the incubation season to 

avoid dewatering the shallowest redd observed. 

Comment AR-53: Interior is concerned that aquatic resources, including invertebrates and fish, are not 

discussed in regard to water quantity issues. Interior states that the timing and magnitude of flows in river 

systems is of extreme importance to fish and wildlife resources, and that many species depend, in part or 

entirely, on environmental cues (e.g., the timing or magnitude of flows) to induce migration or 

reproduction. Interior further states that the frequency of large pulses of flow (like those from peak 

loading) represents an important impact to aquatic invertebrates, and that research has demonstrated that 

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the number of insects is positively correlated with the time since the last large rainfall event. Interior 

comments that frequent flushing events with little time between them may prevent the establishment of 

abundant insect populations, which is a detriment of other aquatic resources in the river system. Interior 

concludes that the timing and magnitude of flows below the project is dramatically altered from that in 

the river before construction of dams or other anthropogenic changes. Interior recommends that the 

NEPA document assess the effects of reduced or altered timing and magnitude of flows. 

The Forest Service comments that the draft EIS provides no evidence that the ramping rates included in 

the Staff Alternative would adequately protect anadromous fish, resident fish, macroinvertebrates, 

mollusks, or any other aquatic or riparian-dependent resource of concern downstream of Hells Canyon 

dam. ODFW states that FERC’s conclusion that only fall Chinook salmon are affected by project 

operations ignores the substantial information submitted by ODFW and other agencies, tribes, and nongovernmental organizations documenting project impacts on aquatic and terrestrial habitat and species. 

Response: The discussion of effects for water quantity issues (i.e., project operations) downstream of 

Hells Canyon dam and in the Oxbow bypassed reach is located in pages 191 to 265 and 270 to 272, 

respectively, of the draft EIS. We recognize that the fluctuating flow regime caused by load following 

operations likely causes some degree of alteration in the composition of the invertebrate community and 

likely has some adverse effects on invertebrate production and fish growth rates. However, the 

magnitude of these effects appears to be limited based on the favorable growth rates of fall Chinook 

salmon juveniles and the size of bull trout compared to bull trout sampled from the Salmon River, a river 

not exposed to load following operations. As noted above, we recommend that Idaho Power develop a 

stranding and entrapment management plan and an invertebrate monitoring plan, and both of these plans 

would include provisions for modifying operation, if warranted, based on monitoring results. 

Comment AR-54: The Forest Service comments that the peer-reviewed literature indicates that a 

ramping rate of between 0 and 2 inches per hour or less is necessary to protect anadromous fish, that the 

current 1-foot-per-hour ramping rate exceeds the ramping requirements included in other licenses recently 

issued in the region, and it far exceeds the natural rate of stage change on a river similar to the Snake 

River in the project area. 

Response: We recognize that a 2-inch per hour ramp rate is commonly applied at hydroelectric projects, 

but we also note that stranding potential is highly site-specific. There is considerably less risk of 

stranding in a river that flows in a confined channel with few gently-sloping shorelines such as the Hells 

Canyon reach, especially upstream of its confluence with the Salmon River, where stage fluctuations are 

the most pronounced. We do not dispute, however, that load following causes some adverse effects on 

aquatic resources. We recognize that reducing ramping rates during the fall Chinook salmon rearing 

season could improve growth rates, and we recommend that ramping rates be reduced from 12 inches to 4 

inches per hour during the rearing season for fall Chinook salmon. As noted previously, we also 

recommend that Idaho Power develop and implement a stranding management plan to collect additional 

information on fish mortality caused by stranding and entrapment, including a provision to further modify 

operations to reduce stranding, if warranted. 

Entrapment and Stranding 

Comment AR-55: Idaho Power indicates that it is working with NMFS to develop operational 

guidelines to minimize entrapment at high-priority entrapment sites in the upper Hells Canyon 

reach. The approach under development would include: (1) identification of significant 

entrapment pool areas and their connection flows in the upper Hells Canyon reach; (2) a use 

assessment (including any mortalities) of entrapment areas by juvenile Chinook salmon and 

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steelhead that would include expanded estimates for the entire rearing period; (3) 

documentation of thermal characteristics of pools during the rearing period; and (4) 

establishment of adaptive in-season operational protocols developed to protect and minimize (to 

the extent practical) negative effects to juvenile Chinook rearing in entrapment pools. Idaho 

Power urges FERC to adopt the adaptive approach described above. 

Response: We recognize the benefits of this adaptive approach, and include the development 

of a stranding and entrapment management plan in the Staff Alternative. However, we 

conclude that implementing a 4-inch-per-hour ramp rate as measured at Johnson Bar140 from 

March 15 to June 15 would benefit fall Chinook salmon by increasing food production in 

shallow-water habitats favored by fall Chinook salmon juveniles and by reducing energetic 

losses and the risk of predation or stranding associated with daily changes in habitat conditions 

associated with load following operations. 

Comment AR-56: NMFS comments that Idaho Power’s assessment of entrapment and stranding sites 

was able to assess entrapment effects only through mid-May when temperatures are relatively cool. It 

was unable to assess these effects later in the year because flows increased to beyond the generation 

capacity of the project. Thus, NMFS concludes that Idaho Power’s surveys greatly underestimate 

mortality in the entrapment areas between mid-May and the end of juvenile fall Chinook salmon rearing. 

NMFS states that FERC should not base decisions on this information alone. 

Response: As noted above, we recognize that additional information on stranding and entrapment is 

needed. We recommend that a stranding and adaptive management plan be developed to better define 

ongoing project effects and to develop methods to reduce impacts on rearing juvenile fall Chinook salmon 

and bull trout. 

Comment AR-57: NMFS comments that the 4-inch-per-hour ramping rate recommended by staff would 

not prevent the injury or death of juvenile salmon caught within several large, high-use entrapment areas 

that become disconnected from the river at flows below about 11,200 cfs (Durham Bar pools) and 9,900 

cfs (Little Bar). NMFS indicates that it continues to discuss this issue with Idaho Power and plan to 

provide FERC with a jointly-supported recommendation in the coming months. ODFW concurs with the 

staff-recommended 4-inch-per-hour ramp rate and comments that FERC should analyze the amount of 

streambed that would be dewatered under this ramping rate restriction. ODFW recommends a minimum 

flow of 11,500 cfs during the fall Chinook rearing season, which it states would reduce entrapment by 72 

percent. The Shoshone-Bannock Tribes comment that FERC cannot reject the more protective 2-inchper-hour ramping rate on grounds of cost, and that past court decisions have determined that the plain 

intent of Congress in enacting the ESA was to halt and reverse the trend towards species extinction, 

whatever the cost. 

The Umatilla Tribes and the Nez Perce Tribe recommend that ramping rates be limited to 2 inches per 

hour during the fall Chinook spawning, emergence and early rearing periods, as well as when flows reach 

30 kcfs below Lower Granite dam. The Tribes also recommend that critical flow levels be established to 

protect juvenile fall Chinook from stranding and entrapment. They report that the daily flow fluctuations 

that occur between June 15 and October 15 could cause substantial juvenile fall Chinook losses, citing 

 

140 We recommend that Idaho Power develop a new combined flow gage and water quality monitoring 

site within 5 miles of Hells Canyon dam. We also recommend that the ramp rate requirement at the 

new gage site be adjusted to account for any difference in the stage/discharge relationship at the new 

gage site compared to the Johnson Bar gage. 

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information from the Hanford Reach where 3.4 percent of fall Chinook are lost due to flow fluctuations 

from June 8 to 21. They state that juvenile size in the Hells Canyon reach is limited by cold water in the 

spring so that juveniles are not as large as those in the Hanford Reach by June 15. Consequently, they 

state that the incidence of stranding in the Hells Canyon Reach is apt to be much more severe on June 15 

than it is in the Hanford Reach, and that flow fluctuation restrictions should be extended for a 

considerably longer period than proposed, possibly until July 15. 

Response: In addition to the seasonal 4-inch-per-hour ramping rate and the stranding and entrapment 

management plan discussed in the previous response, we also recommend that Idaho Power develop an 

invertebrate monitoring plan to assess the effects of load following on invertebrate production and on rare 

and sensitive mollusks. Both plans would be developed in consultation with NMFS, FWS, IDFG, 

ODFW, and interested tribes, and would include provisions for developing and implementing additional 

operational restrictions, if warranted based on monitoring results. The seasonal 4-inch-per-hour ramping 

rate included in the Staff Alternative represents a substantial reduction from the current 12-inch-per-hour 

ramping rate. We conclude that it represents a reasonable and substantial first step toward minimizing 

impacts during the fall Chinook rearing period. 

Comment AR-58: IDFG comments that because the timing of migration changes between years, 

operations to protect fall Chinook salmon during the rearing period should be developed on a real time 

basis in consultation with appropriate state and federal agencies and treaty tribes. IDFG states that Idaho 

Power should continue to monitor key pools, reconnect pools on a daily basis, conduct a mark/recapture 

study to monitor distribution, conduct survival assessments, and conduct salvage operations as necessary. 

Response: In the final EIS, we assessed these recommendations and identified them as potential 

components of the stranding and entrapment management plan that is included in the Staff Alternative. 

Comment AR-59: The Umatilla Tribes and the Nez Perce Tribe state that, while they support the 

implementation of a stranding and entrapment monitoring plan a more precautionary approach to protect 

an ESA-listed species and tribal treaty resource is to implement the 2-inch-per-hour restriction. If, 

through monitoring and consensus agreement of an aquatic resource committee (of tribes and resource 

agencies), a 4-inch-per-hour ramping rate is found to provide as much protection as the 2-inch-per-hour 

rate, they state that it could be implemented. Interior comments that with resumption of the proposed 12-

inch-per-hour ramping rate after June 15, juvenile Chinook are more likely to be stranded or entrapped, 

and the macroinvertebrate food base will undergo reductions due to stranding-related mortality, increased 

rates and frequency of drift, and reduced food production. Interior also comments that the increased ramp 

rate would be implemented before outmigration has peaked, subjecting juvenile salmon to stranding, 

entrapment, other related disturbance, and reduced food abundance. Interior recommends that protective 

ramping rates be implemented throughout the period of outmigration or at least throughout the period of 

highest outmigration. 

Response: Recent data indicate that migration of juvenile fall Chinook salmon past Lower Granite dam 

currently peaks in mid to late June, indicating that most juveniles would have emigrated from the Hells 

Canyon reach before the ramping rate restriction is relaxed on June 15. Connor et al. (1991) reported that 

the shoreline rearing by fall Chinook parr in the upper Hells Canyon reach (upstream of the Salmon 

River) was complete by June 21 in four out of 6 years studied, with end dates ranging from June 15 in 

1997 to July 5 in 1998. The monitoring and adaptive management approach would allow the timing and 

magnitude of ramping rate restrictions to be adjusted if it is warranted based on monitoring results. 

Comment AR-60: The Forest Service comments that Idaho Power’s studies did not evaluate stranding 

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on cobble bars, entrapment in seasons other than the spring, or the cumulative effect of fish being 

entrapped multiple times during their downstream migration. ODFW recommends that monitoring of 

entrapment and stranding should include evaluation of stranding on cobble bars and be expanded beyond 

March-June to assess stranding of other species. 

Response: We include, as part of the Staff Alternative, a stranding and entrapment management plan that 

would be developed in consultation with the management agencies and interested tribes. The plan would 

include monitoring of stranding on cobble bars and of entrapment of fall Chinook salmon juveniles and 

bull trout, and would establish a mechanism for modifying project operations through adaptive 

management to address unidentified or unanticipated adverse effects. 

Comment AR-61: The Forest Service states that a review of Idaho Power’s instream flow study, 

prepared under contract to the Forest Service (Hardy, 2006), indicates that Idaho Power’s analysis 

underestimated the potential impact of daily ramping cycles. 

Response: We revised section 3.6.2.1, Effects of Project Operations on Aquatic Resources, to include a 

discussion of the review prepared by Hardy (2006). 

Comment AR-62: Interior expresses concern that the draft EIS considers the potential impacts of project 

operations only on fall Chinook salmon. It recommends that the benefits of an adaptive approach to 

studying the effects of ramping rates on native aquatic species be considered. 

Response: We expanded the stranding and entrapment management plan to include monitoring effects 

on bull trout, and we added an invertebrate monitoring plan to determine effects on invertebrate 

production and on rare and sensitive mollusks. Both of these plans include adaptive management 

provisions that would offer a means of modifying project operations to address project effects. 

Comment AR-63: NMFS, Interior, and ODFW recommend that FERC require that outflows from Hells 

Canyon dam be measured within one mile downstream from the dam at USGS station number 1320450. 

NMFS states that measuring compliance 17 miles downstream at Johnson Bar masks project effects, 

thereby reducing the usefulness of the measurements in ensuring compliance. NMFS also recommends 

that the station be used to monitor DO and TDG to ensure compliance with other license conditions. The 

Forest Service comments that the draft EIS fails to identify specific data to support the proposal to 

monitor compliance at Johnson Bar. Interior states that the NEPA document should include a table that 

shows current ramping rates at other licensed projects, and that ramping rates at the Hells Canyon Project 

should conform to current standards at projects that affect important anadromous and resident fisheries. 

Response: As an outcome of discussions that occurred at the 10j meeting held in December 2006, we 

added a requirement to the Staff Alternative that would require Idaho Power to develop and implement an 

operational compliance and water quality monitoring plan. The purpose of this plan is to monitor 

compliance with minimum flows, reservoir levels, and ramping rates specified in the license, and to 

monitor water quality upstream of Brownlee reservoir, within Brownlee reservoir, and downstream of 

Brownlee and Hells Canyon dams. The plan would include continuous monitoring of river flows and 

water quality at one site located within 5 miles downstream of Hells Canyon dam, as well as periodic spot 

measurements of water quality above, within, and downstream of Brownlee reservoir and at multiple 

points downstream of Hells Canyon dam. The results of the monitoring would be made available to the 

public on the Internet and summarized in annual reports. We recommend that the plan require a new 

ramping rate be developed to account for the change in location. We also recommend that adaptive 

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management provisions be incorporated in the monitoring plans to assess fish stranding and entrapment 

and invertebrate production. These provisions would allow ramp rates to be adjusted in the future to 

address adverse effects that are identified by the results of monitoring. We see little value in preparing a 

table showing current ramping rates at other licensed projects, since the effects of ramping are highly 

dependent on site-specific factors including the species and lifestages that are present and the occurrence 

of gently sloping shorelines or pools and side channels that can become disconnected from the river 

channel. 

Comment AR-64: Interior comments that the draft EIS includes the annual cost of changing Idaho 

Power’s flow compliance point to within one mile of Hells Canyon dam, which would be between $4 and 

$7.5 million due to reduced ramping rates. At the same time, the draft EIS states that the potential cost of 

run-of-river operations for 6 years would be $5 million annually, and the cost of the Staff Alternative to 

reduce ramp rates to 4 inches per hour from March 15 to June 15 would be $6.8 million annually. Interior 

states that it is unclear how these costs were estimated, and there does not appear to be consistency among 

the various operational changes and associated costs. 

Response: During the section 10(j) meeting, Idaho Power clarified that the annual cost of 6 years of runof-river operation was less than changing the compliance point because the 6-year test period was 

considered to be a temporary measure, which would not have a permanent effect on the project’s 

dependable capacity. Idaho Power noted that these costs were calculated in a manner determined by the 

Public Utilities Commission. However, we over-estimated the cost for the staff-recommended seasonal 

4-inch-per-hour ramping rate in the draft EIS. The original cost estimate was based on costs estimated by 

Idaho Power for Scenarios 1(d) and 1(e), which was based on compliance measurement within 1 mile of 

Hells Canyon dam. The 4-inch-per-hour seasonal ramping rate included in the Staff Alternative would be 

measured at Johnson Bar, and would not affect ramping rates or dependable capacity compared to current 

conditions, other than in the March 15 to June 15 period when the more restrictive ramping rate would be 

imposed. Because this is not a high-demand period, there would be no effect on dependable capacity. As 

a result, our estimated annual cost for the seasonal 4-inch-per-hour ramping rate included in the Staff 

Alternative is reduced substantially in the final EIS, from $6.8 million to $988,000. 

Comment AR-65: The Forest Service comments that the draft EIS, on page 209, inaccurately describes 

the maximum daily flow change (10,000 cfs) under typical operating conditions. The Forest Service 

states that Idaho Power proposes this limitation only for the summer recreation season (Memorial Day to 

Labor Day). 

Response: We modified the text in final EIS section 3.6.2.1 to include this correction. 

Juvenile Migration 

Comment AR-66: Interior comments that the document should discuss the regional and local 

environmental effects of delivering flow augmentation water from upstream BOR storage facilities to 

Brownlee reservoir, including alternative methods that provide for the maximum benefit to aquatic 

resources. It states that these methods should track and account for this water and ensure its delivery in a 

measured and timely fashion downstream from the project. 

Response: We expanded our analysis of the effects of measures recommended by stakeholders regarding 

Idaho Power’s participation in the regional flow augmentation program in section 3.6.2.1, Effects of 

Project Operations on Aquatic Resources, in the subsection on Anadromous Fish Juvenile Migration. In 

that section, we conclude that adopting the target Brownlee elevations identified by NMFS in measures 

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NMFS-8 and NMFS-9 would ensure that flow augmentation water is passed through the project in a 

timely fashion. Furthermore, we added to the Staff Alternative a measure that would require Idaho Power 

to develop an operational compliance and water quality monitoring plan to monitor compliance with 

minimum flows, reservoir levels, and ramping rates specified in the license, which would include the 

posting of reservoir levels and flow rates on the Internet. 

Comment AR-67: NMFS comments that none of the graphics depicting the effects of flow augmentation 

releases at Brownlee reservoir (reservoir elevation as vertical axis) throughout the juvenile migration 

section of the document reflect what was recommended by NMFS or adopted by FERC staff. 

Response: The figures that we used in the draft and final EISs to portray the effects of operational 

recommendations are from Idaho Power’s response to our AIR, which was based on additional study 

requests submitted by the agencies, tribes and NGOs. The flow augmentation scenario was developed 

using the reservoir elevations and timing that was specified in the additional study request filed by 

NMFS. Although we understand that the 10(j) recommendation that was ultimately filed by NMFS 

differs from the modeled scenario in some respects (e.g., the maximum drawdown would be to elevation 

2,059 feet msl instead of to 2,049 feet msl), we considered the model results to be sufficient to provide a 

conservative representation of the effects of flow augmentation on other resources. 

Comment AR-68: NMFS states that it provided clarifications in its January 24, 2006, filing with respect 

to the “reservoir“ or “estuary“ type Chinook salmon life-history strategy that has been expressed only 

since the flow augmentation releases (including cool water releases from Dworshak dam) have been 

instituted. NMFS recognizes that these life-history strategies are providing substantial numbers of 

returning adults, but takes issue with Idaho Power’s characterization of these fish being a small proportion 

of all juveniles migrating past Lower Granite dam. NMFS states that the proportion of juveniles 

produced in the various spawning areas that adopts each of these life history strategies is unknown, but it 

appears that yearling fish are predominantly from the cooler water spawning and rearing areas, not from 

the mainstem Snake River that is most directly affected by the Hells Canyon Project. 

NMFS comments that the key to sustaining the yearling life-history strategy is to provide suitable water 

temperatures for rearing (less than 68° F) in the Snake River through August, and good passage 

conditions during the following spring, when many of these fish are actively migrating. Thus, NMFS 

states that measure NMFS-8, which would minimize reductions in streamflow associated with spring 

flood operations, should benefit fall Chinook salmon that outmigrate as yearlings. 

Response: We incorporated this information into the text in section 3.6.2.1, Effects of Project Operations 

on Aquatic Resources, in the subsection on Anadromous Fish Juvenile Migration. 

Comment AR-69: IDFG comments that the statement “[y]earling fish typically migrate before flow 

augmentation water is released from Brownlee reservoir in late June through July” is not entirely 

accurate. IDFG notes that Connor et al. (2005) showed that some fall Chinook salmon juveniles in the 

Snake River basin spend their first winter in a reservoir and resume seaward movement the following 

spring at age one. 

Response: We clarified the text in section 3.6.2.1, Effects of Project Operations on Aquatic Resources, in 

the subsection on Anadromous Fish Juvenile Migration, to say that yearling fish typically outmigrate in 

the following spring. 

Comment AR-70: NMFS comments that figure 56 in the draft EIS (figure 76 in the final EIS) indicates 

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that flow augmentation causes an increase in water temperatures downstream of Hells Canyon dam in 

July and August. It comments that because the majority of fall Chinook reared in the Hells Canyon 

Reach begins their seaward migration by early July and are predominantly located in and below Lower 

Granite reservoir, this graphic is largely immaterial to the question of how 237 kaf of flow augmentation 

affects juveniles migrating through Lower Granite reservoir. NMFS states that Idaho Power’s modeling 

indicates that project operations only slightly affect temperatures in Lower Granite reservoir. NMFS 

states that the draft EIS would be improved by including information on how flow augmentation affects 

conditions in Lower Granite reservoir and discussing how Dworshak dam releases are managed to 

optimize both flow and temperatures for actively migrating juveniles. 

Response: We incorporated this information into the text in section 3.6.2.1, Effects of Project Operations 

on Aquatic Resources, in the subsection on Anadromous Fish Juvenile Migration. 

Comment AR-71: Interior comments that draft EIS figures 57 and 58 (final EIS figures 77 and 78), 

which depict adult escapement at Lower Granite dam and flow augmentation releases, should also show 

the number of hatchery fall Chinook released by year into the Snake River. NMFS states that although 

these figures suggest support for the hypothesis that flow augmentation increases adult returns, it notes 

that adult returns are driven in large part by ocean and estuarine conditions, by the number of smolts 

produced by both natural and artificial means, and by the rate at which they survive through the mainstem 

Snake and Columbia River dams. 

Response: We added a new table in the final EIS (table 51) that provides annual totals of yearling and 

subyearling fall Chinook salmon released from acclimation sites upstream of Lower Granite dam. We 

also revised the text to describe other factors that have likely contributed to the recent increase in the 

number of adult fall Chinook passing lower Granite dam. 

Comment AR-72: NMFS and ODFW recommend that FERC remove the post-licensing 

reevaluation of flow augmentation from the Staff Alternative. The Nez Perce Tribe expresses 

concern that the flow augmentation report would be used to discontinue flow releases from 

Brownlee reservoir. NMFS states that the mainstem Snake River produces only a few 

“reservoir type” juveniles in most years, and that the majority outmigrate in June and July when 

they would benefit from flow augmentation. NMFS and ODFW state that there are many 

environmental factors affecting the adult return rate of fall Chinook, and that it would be risky to 

ascribe variations in adult returns to flow conditions alone, particularly over such short time 

periods. Interior comments that uncertainties introduced by this requirement would make it 

impossible to address how project operations would affect listed species after 2009. ODFW 

recommends that a comprehensive monitoring program be conducted over the term of the new 

license to provide information necessary to determine the efficacy of flow augmentation. This 

monitoring program would include parameters identified by the Independent Scientific Advisory 

Board (ISAB, 2003). Idaho Power comments that development of an experimental design to 

assess the efficacy of flow augmentation is complex, and requires significantly more thought 

and analysis than the approach recommended by FERC staff. 

Response: In the final EIS, we eliminated from the Staff Alternative the 2009 post-licensing 

reevaluation of flow augmentation that we recommended in the draft EIS. However, it is likely 

that additional information on the effects of flow augmentation will continue to be developed, 

and that this information could improve our understanding of how flow augmentation water can 

be managed to maximize benefits to outmigrating salmon and steelhead. Accordingly, we 

recommend that the manner in which Brownlee storage is used to provide flow augmentation 

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water be reviewed in 2015 or sooner if petitioned by Idaho Power, IDFG, ODFW, NMFS, FWS, 

or interested tribes. 

Comment AR-73: NMFS states that juvenile migration survival rates are the most appropriate 

evaluation tool, not adult returns. The Umatilla Tribes and the Nez Perce Tribe recommend that the 

metrics for evaluating the benefits of flow augmentation should be measurement of juvenile migration 

timing and reach survival to Lower Granite dam. 

Response: We recognize that adult returns are influenced by a large number of variables, and 

that evaluating the survival rates of juvenile salmon passing at downstream dams is a better 

method to evaluate survival benefits associated with flow augmentation. Accordingly, we 

eliminated the recommendation that we made in the draft EIS that the effectiveness of flow 

augmentation be evaluated based on adult returns, and instead recommend evaluation based 

on juvenile salmon. 

Comment AR-74: IDFG comments that flow augmentation from the upper Snake River may provide 

marginal travel time benefits and harm downstream migrants through increased summer water 

temperature. IDFG cites a number of limitations of studies conducted to date, and recommend that 

inferences regarding the efficacy of flow augmentation from the upper Snake River should either be 

qualified or eliminated from the draft EIS. IDFG states that little, if any, research has focused specifically 

on the efficacy of flow augmentation from the upper Snake River (which has different flow and 

temperature characteristics than flow augmentation from Dworshak reservoir) on fall Chinook salmon 

migration and survival in the lower Snake River. IDFG also states that draft EIS figures 57 and 58 (final 

EIS figures 77 and 78), which show fall Chinook salmon adult returns and flow augmentation volumes, 

are misleading because they do not take into account other factors that influence adult returns, and 

recommend that the figures and associated text be removed from the draft EIS. 

Response: In the final EIS, we qualified our conclusions regarding the relationship between flow 

augmentation and adult returns. Also, we added final EIS table 51 showing the number of hatchery fall 

Chinook salmon that have been introduced to the reach to better portray the likely influence of 

supplementation on adult returns. As noted above, we recommend that the manner in which Brownlee 

storage is used to provide flow augmentation water be reviewed in 2015, or sooner if petitioned by Idaho 

Power, IDFG, ODFW, NMFS, FWS, or interested tribes. 

Comment AR-75: IDFG cites a recent study showing that lower flows from Hells Canyon result in less 

water mixing below the confluence of the Snake and Clearwater rivers. Decreased mixing resulted in a 

slightly warmer epilimnion (upper stratified zone) in Lower Granite reservoir and cooler hypolimnion 

(lower stratified zone) temperatures (lower by more than 1°C). By inference, greater flow augmentation 

from the upper Snake River may increase mixing and therefore increase summer temperatures in an 

otherwise cooler hypolimnion, which may negate possible travel time benefits from upper Snake River 

flow augmentation. 

Response: We incorporated this information into the text in section 3.6.2.1, Effects of Project Operations 

on Aquatic Resources, in the subsection on Anadromous Fish Juvenile Migration. 

Comment AR-76: IDFG recommends that any re-evaluation of flow augmentation be conducted in 

cooperation with other state and federal agencies and regional interests. IDFG comments that the 

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evaluation should, at minimum, quantify the physical impacts of flow augmentation from Brownlee 

reservoir (e.g., water velocity, turbidity, temperature) and the biological impacts (e.g., migration and 

survival impacts). 

Response: We concur that any re-evaluation of flow augmentation should be conducted in cooperation 

with other state and federal agencies and regional interests. We also conclude that the flow augmentation 

evaluation include consideration of the factors identified by IDFG. 

Comment AR-77: ODFW requests that it be included in the consultation on refill rates after Brownlee 

reservoir has been drawn down for flood control purposes. 

Response: We modified the Staff Alternative to include coordination of Brownlee refill after April 30 

with the Corps, NMFS, ODFW, IDFG and interested tribes. 

Comment AR-78: The Umatilla Tribes and the Nez Perce Tribe comment that the draft EIS does not 

examine specific flow augmentation benefits to Snake River fall Chinook salmon associated with a range 

of augmentation flows. They state that CRITFC and EPA collaborated on an analysis of flow 

augmentation volumes from 237 to 927 kaf on water temperatures at Lower Granite dam and particle 

travel time as a result of Hells Canyon Project outflows. Based on reduced water particle travel time, 

their analysis indicates that most of the fall Chinook migration would experience increases in survival 

with flow augmentation greater than 237 kaf in all years modeled, even without temperature control from 

the project. In addition to the work of Connor et al. (2003) cited in the draft EIS, the Umatilla Tribes state 

that some of the best available scientific information regarding the strong correlation between increased 

fall Chinook survival and reduced water particle travel time is offered by Williams et al. (2005). 

Response: We incorporated the pertinent information from Williams et al. (2005) into our analysis in 

section 3.6.2.1, Effects of Project Operations on Aquatic Resources, in the subsection on Anadromous 

Fish Juvenile Migration. As previously stated, we recommend that the manner in which Brownlee 

storage is used to provide flow augmentation water be reviewed in 2015, or sooner if petitioned by Idaho 

Power, IDFG, ODFW, NMFS, FWS, or the interested tribes. 

Comment AR-79: ODFW recommends that Idaho Power pass all BOR flow augmentation water 

through the project, and assist with flow augmentation by shaping up to 100 kaf of BOR water releases as 

necessary. ODFW states that typically, Idaho Power has only needed to shape 30 to 35 kaf. AR/IRU 

comment that the draft EIS failed to analyze the benefits of flow shaping and providing timely passthrough of flow augmentation water provided from the upper Snake River basin. The Umatilla Tribes and 

the Nez Perce Tribe comment that the draft EIS does not address their recommendation to provide timely 

pass through of all BOR Upper Snake water through the project, in consultation with, and subject to 

approval of, the Umatilla Tribes and other appropriate tribes, as well as state and federal agencies. The 

Umatilla Tribes state that in the past, Idaho Power has held this water within the project boundaries for its 

own economic gain when it was needed to aid anadromous fish migration in the Lower Snake River. 

Interior comments that the NEPA document should discuss methods to account for, and to ensure the 

timely delivery of, augmentation water from BOR’s storage reservoirs to the Snake River downstream of 

the project. IDFG comments that because system-wide coordination is essential to any flow 

augmentation study or program, it recommends that a more accessible water accounting system be 

developed collaboratively by BOR, IDWR, and Idaho Power. 

Response: As previously stated, we expanded our analysis of the effects of measures recommended by 

stakeholders regarding Idaho Power’s participation in the regional flow augmentation program in section 

3.6.2.1, Effects of Project Operations on Aquatic Resources, in the subsection on Anadromous Fish 

Juvenile Migration. We conclude that adopting the target Brownlee elevations identified by NMFS 

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(NMFS-8 and NMFS-9) would ensure that flow augmentation water is passed through the project in a 

timely fashion. During the December 2006 section 10(j) meeting, Idaho Power reported that BOR has 

developed approaches for managing its storage facilities that have allowed its augmentation water to be 

delivered to the lower Snake River in a timely fashion. We also recommend, as part of the Staff 

Alternative, that Idaho Power develop an operational compliance and water quality monitoring plan, 

which would include posting hourly water surface elevations and estimated storage volumes in each of 

the project reservoirs on an Internet site. This plan would provide the framework for documenting 

compliance with any reservoir elevations required in a new license. 

Comment AR-80: The Umatilla Tribes and the Nez Perce Tribe comment that the draft EIS says 

“[m]odeling conducted by Idaho Power shows that 350 kaf of storage from Brownlee reservoir would 

increase water temperatures.” However, they state there is no citation or report given to support this 

statement. The Umatilla Tribes go on to state that they provide a quantitative temperature modeling 

analysis in their comments that clearly indicates there would be a benefit to juvenile anadromous fish 

from flow augmentation. 

Response: Our analysis of Idaho Power’s temperature modeling results is in section 3.6 of the draft EIS. 

Also, plots of simulated water temperatures downstream of Hells Canyon dam under proposed operations 

and with 350 kaf of flow augmentation were shown in draft EIS figure 56 (final EIS figure 76). While 

there are studies to the contrary, we conclude that the preponderance of evidence indicates that flow 

augmentation provides a benefit to migrating juvenile anadromous fish. 

Comment AR-81: The Umatilla and Nez Perce tribes comment that maintaining Brownlee reservoir at 

its upper curve for flood control during the late winter and early spring would assist with meeting target 

flows specified in the 2004 biological opinion (85 to 100 kcfs between April 10 and June 20 and between 

50 to 55 kcfs between June 20 and August 31). They recommend that the preferred alternative include a 

provision that would require Idaho Power to maintain Brownlee reservoir at its upper flood control rule 

curve, and that Brownlee reservoir not be refilled during the spring target flow period (April 10 to June 

20) unless target flows are being met at Lower Granite dam. 

Response: We revised the text in section 3.6.2.1, Effects of Project Operations on Aquatic Resources, in 

the subsection on Anadromous Fish Juvenile Migration, to address these recommendations. We conclude 

that filling Brownlee reservoir by April 15 would minimize the potential for adverse flow effects during 

the majority of the spring outmigration season. We note, however, that deferring refill until after June 20 

would conflict with NMFS’s recommendation to fill the reservoir in preparation for summer flow 

augmentation to benefit subyearling fall Chinook salmon. 

Comment AR-82: The Umatilla and Nez Perce tribes comment that operation of Brownlee reservoir to 

one set of fixed elevations for anadromous fish flows, is inflexible and fails to take advantage of runoff 

and flow conditions that can vary significantly between years. The Umatilla Tribes recommend that 

Idaho Power, subject to annual tribal and fishery agency consultation and approval, should investigate and 

make the most efficient use of Brownlee storage to meet anadromous fish needs on an annual basis. They 

recommend that Brownlee operations be managed to: (1) draft Brownlee reservoir by May 15 for spring 

flows; (2) refill Brownlee reservoir by June 15 for summer flow storage for fish flows and pass some 

portion of inflows during this period; and (3) draft Brownlee for summer flow augmentation by August 1 

and then refill to a level necessary to provide minimum flow of 9,000 cfs for fall Chinook spawning and 

incubation below the project. The Umatilla Tribes support their recommendation with an analysis of 50 

years of historical flows, which indicates that all three fish flow objectives could be met and balanced by 

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judicious use of annual flow forecasts and real-time management. 

Response: We modified final EIS sections 3.6.2.1 and 5.2.2.3 to include an evaluation of these 

recommendations. We recognize that there may be opportunities to increase flow augmentation levels in 

years with high runoff forecasts that would still allow Brownlee reservoir to be refilled to meet refill 

requirements for summer augmentation and recreation. However, we conclude that the biological benefit 

of implementing flow augmentation is the greatest during low flow years, and that increasing the amount 

of flow augmentation water provided from Brownlee reservoir in medium and high flow years would 

provide little biological benefit. Nonetheless, we include in the Staff Alternative a provision that Idaho 

Power’s participation in the flow augmentation program may be revisited via petition if substantial 

evidence indicates that such a review is warranted. 

Comment AR-83: The Umatilla and Nez Perce tribes cite recent literature that supports the importance 

of flow augmentation to reduce water particle time and increase survival rates of outmigrating 

anadromous fish. They also comment that Federal Columbia River Power System operations have 

significantly changed with the advent of 24-hour spill at lower Snake dams and at McNary dam. They 

indicate that implementation of this spill in 2005 and 2006 has significantly reduced water particle and 

fish travel time and increased reach survival for Snake River fall Chinook. They note that increasing the 

amount of flow augmentation provided from Brownlee reservoir would increase the volume of water that 

can be spilled at downstream projects, and would increase the survival of juvenile fall Chinook salmon 

migrating past downstream dams. 

Response: Our understanding is that summer spills to improve survival at downstream projects are 

typically limited by TDG levels during medium and high water years. Consequently, increasing flow 

augmentation water provided from Brownlee reservoir in high runoff years would not necessarily increase 

the amount of water that could be spilled at downstream projects. However, in the event that information 

becomes available that would support modifying the flow augmentation, as previously noted, we include 

a provision in the Staff Alternative that Idaho Power’s participation in the flow augmentation program 

can be revisited via petition if substantial evidence indicates that such a review is warranted. 

Comment AR-84: Idaho Power discusses four arguments that supports its position that the provision of 

flow augmentation water from Brownlee reservoir is not justified: (1) the 1980 Hells Canyon settlement 

agreement was designed to provide full and complete mitigation for all numerical losses of salmon and 

steelhead caused by construction and operation of the project under the original license; (2) adoption of 

flow augmentation in the Staff Alternative is based on a false premise that the project is having adverse 

effects on fall Chinook spawning and rearing downstream from Hells Canyon dam that have not been 

addressed; (3) impacts to migrating salmon due to delayed passage through downstream federal projects 

are not related to the operations or existence of the project; and (4) the efficacy of the flow augmentation 

program remains in considerable doubt. 

Response: With regard to Idaho Power’s first three arguments, we do not concur that Idaho Power’s 

hatchery program has effectively mitigated all impacts associated with the cumulative effects of Idaho 

Power’s hydroelectric projects on the Snake River. Idaho Power has not met its fall Chinook salmon 

production target in most years and, other than the release of limited numbers of surplus steelhead and 

spring Chinook salmon, the hatchery program does very little to mitigate for lost fisheries in the basin 

upstream of Hells Canyon dam. As to the fourth argument, we conclude, based on our independent 

review and analysis that the preponderance of evidence indicates that flow augmentation provides a 

substantial benefit to outmigrating anadromous fish. 

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Native Resident Salmonids 

Comment AR-85: Interior comments that the draft EIS does not say that there is limited information 

currently available on bull trout movement and migration downstream of Hells Canyon dam, and that 

population trends and status for the species over time are not available. Interior recommends that FERC 

include a more thorough description of the information available for bull trout downstream of Hells 

Canyon dam, and of any assumptions made in the environmental analysis based on that information. 

Interior states that this analysis should include a description of the scope of existing studies and any 

potential data limitations. Interior also comments that the draft EIS does not provide information 

regarding what life stages of bull trout are present throughout the project and how those life stages are 

expected to use different habitats within the project. 

Response: We summarized available information on the distribution, status and life history of bull trout 

within and downstream of the project area in section 3.6.1.4 of the draft EIS. We recognize that the 

information available on bull trout trends, status, and migration downstream of Hells Canyon dam is 

limited. This is part of the reason that we recommend additional monitoring to evaluate bull trout 

stranding and project effects on invertebrate production to assess effects on the food resources available 

to bull trout and other fish species. For more detailed information on the status and life history of the bull 

trout population within and downstream of the project, we refer Interior to sections 4.2, 4.3, 5.1 and 5.2 of 

technical appendix E.3.1-7 of Idaho Power’s license application. Available information on population 

trends in the project area is limited, and this limitation forms the basis for Idaho Power’s proposal to 

construct a monitoring weir on Pine Creek. 

Comment AR-86: Interior recommends that FERC staff consider information about mortality factors 

from radio telemetry studies and observations of radio tagged bull trout in the main stem of the Snake 

River. 

Response: We modified the text in section 3.6.1.4, Native Resident Salmonids, to include a discussion of 

the movements of radio tagged bull and redband trout. 

Comment AR-87: Interior recommends that Commission staff review and include information contained 

in FWS’s September 2005 paper Hydroelectric Operations: A Summary of Studies of Effects on Aquatic 

Resources, which was submitted with Interior’s preliminary terms and conditions. 

Response: We incorporated information into the final EIS from several of the studies that were cited in 

FWS’s review paper. It is not our practice, however, to include an exhaustive literature review on each 

issue that is addressed. We include only enough information to adequately support and inform our 

analysis. 

Comment AR-88: Interior comments that the modeling results for bull trout and redband trout in the 

Snake River was conducted using habitat use criteria collected in a highly altered Snake River 

environment, which may not be reflective of preferred habitat in an improved aquatic environment. 

Interior states that conclusions made based on the WUA analysis should be reconsidered in the EIS using 

a cooperative approach, as is intended with any instream flow habitat assessment. 

Response: In our view, the suitability criteria developed by Idaho Power are sufficient for the purposes 

of assessing project effects and for evaluating the potential effects associated with modifying project 

operations. The habitat suitability criteria were developed based on telemetry data from 23 bull trout 

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monitored over the winter and early spring months, when water quality conditions are generally good and 

would not be expected to alter habitat use substantially. Although information on habitat use at night was 

not determined, this is an understandable limitation given the safety considerations related to night 

operation of boats on a whitewater river. Habitat use may have also been affected to some degree by load 

following operations, but the extent of load following varied considerably over the monitoring period, so 

the data collected is representative of a wide range of operations. We recognize that the study would have 

benefited from a higher level of coordination with the resource agencies and tribes. However, the study 

approach used by Idaho Power was technically sound and yielded results that are sufficient to support our 

analysis of the effects of project operation on aquatic resources. 

Comment AR-89: Interior comments that the draft EIS is correct in that some resident salmonids move 

out of the main Snake River into tributaries. However, Interior states that resident salmonids may be 

present in the Snake River at any time and are therefore vulnerable to effects from project operations. For 

example, Interior states that Idaho Power’s limited data indicates that at least 2 of 7 bull trout monitored 

with radio telemetry were located in the mainstem Snake River in August of 2000. ODFW states that 

Idaho Power’s studies documented usage of the mainstem Snake River by bull trout, including nearshore 

habitats affected by load following operations, in all seasons, and that anglers have reported catching 

rainbow trout in the mainstem Snake River in nearly every month of the year. The Forest Service and 

ODFW state that the draft EIS did not consider: (1) Muhlfeld et al. (2003) that indicates that bull trout 

sub-adults use margin-related foraging sites during the winter, or (2) Chandler (2006) that identifies bull 

trout adults using the “plumes” at coldwater tributary junctions of several streams. 

Response: We modified the text in section 3.6.2.1, Effects of Project Operations on Aquatic Resources, 

and 5.2.4.2, Flow Fluctuations Outside of the Fall Chinook Spawning and Incubation Period, to reflect 

this information. 

Comment AR-90: The Forest Service comments that there is insufficient information to determine the 

effects of project operations on species other than fall Chinook salmon. The Forest Service notes that 

collection of 1,070 redband trout, with a catch per unit effort of 0.5 to 2.0 fish per hour, during sampling 

conducted by Idaho Power indicates the presence of a substantial population of redband trout in this 

reach. 

Response: Based on new information filed with comments on the draft EIS, we modified the Staff 

Alternative to include additional monitoring of fish stranding and entrapment of native resident 

salmonids, as well as invertebrate monitoring, to determine project effects. Both monitoring efforts 

would include adaptive management components to refine project operations if warranted to enhance 

habitat conditions for aquatic species. 

Comment AR-91: AR/IRU comment that the draft EIS provides little information on mountain 

whitefish, and recommend that the EIS include an analysis of project impacts and mitigation needs for 

this species. 

Response: Effects on mountain whitefish were not identified as a major issue during NEPA scoping. In 

addition, no measures specifically designed to benefit this species were recommended by any party to the 

proceeding. Nonetheless, most of the measures that would benefit redband and bull trout would also 

provide benefits to mountain whitefish. 

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Comment AR-92: Interior states that the NEPA document should provide a complete analysis of the 

effects of project operations on bull trout prey availability. 

Response: We expanded our discussion of the effects of load following on invertebrates in section 

3.6.2.1, Effects of Project Operations on Aquatic Resources, including information from several relevant 

studies cited by Interior. We also expanded the discussion of effects on bull trout in section 3.8.2.6, Bull 

Trout. 

Comment AR-93: Interior comments that Idaho Power recently collected 1 year of data on the 

entrapment of juvenile salmon during the spring. Interior states that this effort did not address other 

Snake River native fishes of interest, including (1) younger age classes of redband and bull trout, which 

may be present in any month of the year, and (2) white sturgeon, which never migrate out of the 

mainstem of the Snake River to complete their life history. Interior recommends that the NEPA 

document include a complete analysis of the potential and expected effects of stranding and entrapment to 

bull trout and redband trout, and specify whether and under what conditions Idaho Power will continue 

monitoring these effects. 

Response: We include, as part of the Staff Alternative, a measure that would require Idaho Power to 

develop a Stranding and Entrapment Management Plan, which would require expanded monitoring to 

assess effects on fall Chinook salmon, bull trout, and redband trout, and to determine whether additional 

measures are warranted to benefit these species. The expanded monitoring effort would also provide 

information on any other species or lifestages that are susceptible to stranding and entrapment. 

Comment AR-94: Interior states that the draft EIS cites Chandler et al. (2006 that documents that bull 

trout found in the Snake River were similar in size and condition as those from the Salmon River. 

However, the draft EIS does not identify the significance or potential implications of this statement. 

Interior recommends that the NEPA document expand on the Chandler et al. (2006) findings and 

explicitly interpret those findings in the context of effects of the project on bull trout. Interior also 

recommends that the NEPA document include an analysis of other related information, such as the 

relationship between size and density in fish communities. 

Response: We expanded our discussion of bull trout in section 3.6.2.1, Effects of Project Operations on 

Aquatic Resources, of the final EIS to include more information and analysis of weights and condition 

factors. 

Comment AR-95: The Forest Service does not agree with FERC staff’s modification of the Bull Trout 

Passage Plan included in its 10(a) recommendation and FWS’s fishway prescription. Interior states that 

the NEPA document should include a recommendation that Idaho Power actively participate in the 

management and life history restoration for resident fish species over the term of the license. It also 

recommends that the Staff Alternative include and clearly describes the measures needed to lead to the 

restoration of resident fish passage at the project. The Shoshone-Paiute Tribes comment that passage of 

resident fish has been largely ignored and needs to be included. 

Response: In the final EIS, we adopt Interior’s modified fishway prescription in the Staff Alternative, 

which involves the phased restoration of connectivity among native resident salmonids in several key 

tributaries in the project area. This measure should help to restore the fluvial life form of bull trout, 

which has likely been greatly reduced as a result of poor passage conditions at the project. 

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Comment AR-96: Idaho Power, Interior, and ODFW recommend that the Pine Creek weir not be 

delayed pending brook trout removal efforts, as recommended by staff. All three agree that the weir is 

needed to establish a long-term trend and monitoring program of fluvial bull trout. 

Response: In the final EIS, we adopt Interior’s modified fishway prescription in the Staff Alternative, 

which specifies that the Pine Creek weir and trap fishway be constructed within 2 years of license 

issuance. 

Comment AR-97: ODFW recommends that Idaho Power conduct a population viability risk analysis of 

genetic and demographic costs incurred by donor and recipient bull trout populations. ODFW comments 

that very little is known about the fluvial component of bull trout currently within the Pine Creek basin or 

any Snake River basin, and there is currently no means of establishing long-term trends of fluvial fish 

deemed to be critical to recovery of the core area. ODFW states that trend information for fluvial bull 

trout using the mainstem Snake River is limited and difficult to obtain, especially given the low numbers 

of bull trout in the system. 

Response: We modified our recommendation so that the need for a population viability analysis would 

be determined through development of the Bull Trout Passage Plan implemented as part of Interior’s 

modified fishway prescription. 

Comment AR-98: ODFW questions the statement in the draft EIS that the results of radio telemetry 

studies might lead to a decision to transfer outmigrating bull trout from Pine Creek to habitat downstream 

of Hells Canyon dam. ODFW is concerned that transferring bull trout could mine fish from upstream 

populations and increase their risk of extinction. Furthermore, ODFW states that it does not want to 

preclude use of Hells Canyon reservoir as a rearing area for native migratory fish species. ODFW 

recommends that Idaho Power evaluate turbine- and spill-related mortality of native salmonids once 

ODFW and Idaho Power determine that sufficient numbers of fluvial fish exist to conduct an entrainment 

study. ODFW recognizes that given the low number of fluvial bull trout currently in the system, it is 

likely impossible to evaluate turbine-and spill-related mortality. However, ODFW states that this should 

be done in the future after passage systems and weirs are installed and fluvial fish numbers increase. 

Response: We modified the text in sections 3.6.2.8, Resident Salmonid Passage, and 5.2.4.4, Resident 

Salmonid Passage, to reflect the fact that Idaho Power’s telemetry studies conducted to date do not 

suggest that there is a high entrainment potential for bull trout. However, we recognize that additional 

telemetry studies may be conducted in the future as part of the monitoring efforts associated with 

Interior’s modified fishway prescription. 

Comment AR-99: IDFG states that if the development and implementation of a Fish Pathogen 

Plan requires additional agency resources and personnel, the license should allow for additional 

funding to support any additional state agency expenses. ODFW states that it has health 

expertise and efficient fish health laboratories, and that Idaho Power should consider funding a 

full or part-time pathologist position with ODFW for any fish health monitoring and authorization 

associated with the project and mitigation measures. Idaho Power states that it intends to fund 

the necessary pathology work associated with the proposed fish pathogen assessment. 

However, Idaho Power comments that it should have the option, but not be required, to fund a 

pathologist as part of its staff or through the fish management agencies. Idaho Power states 

that the primary consideration should be that the work be conducted by personnel qualified to 

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conduct such assessments, and recommends that the final EIS provide for the option to fund a 

pathologist but should not require such funding. 

Response: We modified the text in sections 3.6.2.9 and 5.2.4.6 of the final EIS to reflect that 

Idaho Power may hire or fund a full-time fish pathologist only if one is needed to perform the 

pathology work associated with the proposed fish pathogen assessment. 

Comment AR-100: ODFW recommends expansion of pathogen surveying and monitoring to both native 

resident and anadromous populations upstream of, within, and downstream from the project. ODFW 

states that the survey area in Oregon should include the Snake River upstream of and downstream from 

the project, Pine Creek, Powder River (including Eagle, Daly and Goose Creeks), Burnt River, Owyhee 

and the Malheur River basins, and the Imnaha and Grande Ronde rivers downstream from Hells Canyon 

dam. If carcass outplants are to occur, ODFW indicates that there will likely be the need for annual fish 

health inspections to meet ODFW outplant guidelines for the use of adult salmon and steelhead carcasses. 

It states that the appropriate scope of the pathogen assessment should be determined in consultation with, 

and agreement of, ODFW and IDFG fish pathologists. 

Response: We conclude that it is reasonable and appropriate to limit the scope of the pathogen survey to 

the range proposed by Idaho Power, which encompasses the tributaries and adjacent reservoirs where 

passage would be provided under Interior’s modified fishway prescription. We note that Idaho Power’s 

telemetry studies did not document any movement of bull trout to areas downstream from the Imnaha 

River. As a result, we do not include the Grande Ronde River. 

Tributary Habitat Enhancements 

Comment AR-101: Interior comments that BLM should be included in the parties invited to participate 

in the advisory committee that would oversee tributary habitat invited to participate in the advisory 

committee that would oversee tributary habitat improvements. The Shoshone-Paiute Tribes comment that 

the project area and the upstream habitat represent important aboriginal lands of the tribes, so the tribes 

should be included in the Technical Advisory Committee that oversees tributary habitat enhancements. 

Response: We identify the parties that are expected to participate in the technical committee in section 

5.2.4.5, Tributary Habitat Improvements. This would include landowners and representatives from state 

and federal agencies that manage lands where enhancements would be implemented, including BLM. 

Comment AR-102: The Forest Service states that Idaho Power’s tributary habitat mitigation fund should 

be expanded to include other tributaries including Eagle Creek. ODFW recommends that habitat 

enhancements to benefit redband trout and bull trout be expanded to include the Powder and Burnt River. 

ODFW comments that the Staff Alternative makes no provision for habitat enhancement if bull trout are 

present in Eagle Creek, or provisions to enhance redband trout within the Powder or Burnt River basins, 

or other tributaries that are also affected by project operations. 

Response: We modified the Staff Alternative to include tributary habitat enhancements in portions of the 

Powder and Burnt River basins, where there is potential for rebuilding populations of redband or bull 

trout. 

Comment AR-103: AR/IRU comment that they view Idaho Power’s proposed $8.5 million funding level 

for tributary enhancements to be inadequate and that the draft EIS did not address the extent of Idaho 

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Power’s financial contribution to the tributary habitat enhancement effort. They also state that the draft 

EIS does not address their recommendation that there be an adaptive management approach that leaves 

open the possibility of geographically expanding the tributary habitat improvement program. 

Response: As previously stated, we modified the Staff Alternative to include tributary habitat 

enhancements in portions of the Powder and Burnt River basins where there is potential for rebuilding 

populations of redband or bull trout. To estimate the funding that would be needed to restore suitable 

habitat in the Powder River basin, we used the cost per square mile of drainage area in the Pine, Indian 

and Wildhorse basins from Idaho Power’s proposal and applied it to the drainage of key tributaries in the 

Powder River basin (Eagle, Goose and Daly Creeks). We assumed that a comparable amount of funding 

would be required to improve suitable habitat in the Burnt River basin. The total funds that we 

recommend Idaho Power allocate to tributary enhancement measures is $18.0 million, which compares to 

$8.5 million proposed by Idaho Power and $22.5 million proposed by ODFW. ODFW recommended that 

the funding be provided in $750,000 increments in each year of the license. In order to expedite 

restoration efforts, we assumed that all funds would be allocated in the first ten years of the new license, 

which resulted in an annualized cost nearly twice that of ODFW’s proposed measure. ODFW’s staff has 

considerable knowledge of habitat conditions and enhancement opportunities in the project area. Based 

on the similarity of our proposed funding level, we conclude that our proposed level of funding is 

appropriate. 

Comment AR-104: ODFW recommends that Idaho Power conduct presence/absence surveys for bull 

trout in all of the major tributaries associated with the Eagle Creek basin, including Eagle Creek, West 

Eagle Creek, and East Fork Eagle Creek. As part of these investigations, ODFW states that Idaho Power 

should operate a temporary picket-style weir near the mouth of Eagle Creek during the fall months to 

capture any fluvial fish exiting the Eagle Creek basin. If bull trout are captured, ODFW states that 

genetic sampling should occur to examine the extent of hybridization with brook trout. 

Response: We modified the text in section 3.6.2.10 of the final EIS to clarify that all the components 

outlined by ODFW are included in Idaho Power’s proposal, which we adopt in the Staff Alternative. 

Comment AR-105: Interior recommends that the Staff Alternative include an adaptive management 

component as part of the tributary enhancement program to allow evaluation of the tributary habitat 

enhancements and associated effects on the native salmonids and their habitats. Interior also recommends 

that the NEPA document describe the magnitude and severity of the effect of water quality conditions in 

project reservoirs on connectivity among bull trout populations. 

Response: We modified the text in section 5.2.4.5 to clarify that part of the funding would be used to 

conduct an appropriate level of monitoring to guiding future enhancement efforts. We also expanded 

section 3.6.1.4 to include analysis of effects of water quality conditions in project reservoirs on the 

seasonal habitat suitability for bull trout. 

Marine-Derived Nutrients 

Comment AR-106: ODFW recommends that nutrient supplementation be implemented in all tributaries 

to the project in coordination with ODFW and ODFW fish pathologists to improve forage opportunities 

for bull trout. ODFW states that if the proposed presence/absence survey documents the existence of bull 

trout in Eagle Creek, this tributary should be a priority area for nutrient supplementation. In addition, 

ODFW recommends that placement of salmon carcasses be designed to minimize benefits to brook trout 

and maximize benefits to bull trout and other native resident species, as opposed to making nutrient 

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supplementation contingent upon the success of brook trout eradication efforts. ODFW concurs with staff 

that the transport and release of live surplus adult fish into Hells Canyon reservoir would benefit bull trout 

by increasing forage opportunities for bull trout from the eggs, fry, and carcasses of any fish that spawn in 

Pine and Indian creeks. 

Response: We modified section 5.2.4.5, Tributary Habitat Improvements, to indicate that nutrient 

supplementation in Eagle Creek could be added to the tributary enhancement program if bull trout are 

found to occur in that stream during the proposed presence/absence survey. We also modified section 

3.6.2.1, Marine Derived Nutrients, to reflect the suggestion that nutrient supplementation be targeted for 

habitat that would maximize benefits to bull trout and minimize benefits to brook trout. 

Comment AR-107: Interior comments that the NEPA document should include a specific 

recommendation that Idaho Power develop a program to provide hatchery salmon and steelhead access to 

tributaries within the project area, as a means to restore marine-derived nutrients and improve forage for 

bull trout. 

Response: In section 3.6.2.11, Marine-Derived Nutrients, of the final EIS we discuss the potential 

benefits of stocking surplus adult hatchery steelhead and spring Chinook into project reservoirs or directly 

into tributaries to restore marine derived nutrients and increase forage opportunities for bull trout. In final 

EIS section 5.2.4.8, Hatchery Production, of the final EIS we recommend that this use of surplus fish be 

considered in the development of a Surplus Hatchery Fish Plan to be developed in consultation with the 

Shoshone-Paiute and Burns Paiute tribes and fisheries management agencies (IDFG, ODFW, Interior, and 

NMFS). 

Comment AR-108: The Umatilla Tribes and the Nez Perce Tribe comment that restriction of the 

Nutrient Supplementation Plan to Pine Creek, Indian Creek, and the Wildhorse River is inappropriate, 

because Idaho Power’s projects have eliminated anadromous fish access to upstream tributaries as well. 

Response: While we recognize that Idaho Power’s Snake River projects have blocked anadromous fish 

access to many upstream tributaries, it is appropriate to focus fisheries restoration efforts associated with 

this relicensing proceeding on tributaries within the reach that is directly affected by the Brownlee, 

Oxbow and Hells Canyon impoundments. Focusing efforts in this manner is appropriate, because the 

nexus to a range of project effects is limited. Such effects include inundation of portions of the tributaries 

and adverse effects on connectivity from inhospitable water quality conditions during the summer and 

early fall. In addition, portions of these tributaries have been identified by stakeholders as areas with 

substantial potential for restoration and enhancement of habitat for native salmonid fisheries. 

White Sturgeon 

Comment AR-109: Interior recommends that the NEPA document describe precisely how the average 

WUA values for sturgeon were determined and expand the analysis of effects of different operating 

alternatives on different lifestages and sturgeon production, including comparisons to production that 

would occur under run-of-river conditions. 

Response: As described on page 242 of the draft EIS, we used the plots of WUA to estimate the 

minimum, maximum and normal maximum daily percent fluctuation. All three of these statistics were 

estimated by visual interpretation of the plots shown in the draft EIS. As noted in footnote 48, the normal 

fluctuation was defined as the largest percentage change that occurred in at least 3 consecutive days. We 

compiled these statistics for each lifestage of sturgeon under each evaluation scenario and water year type 

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in draft EIS table 49 (final EIS table 53). Interpretation of the biological significance of the observed 

level of variation in WUA relies on the analyst or the reader’s scientific expertise, as there currently are 

no widely accepted tools or models for translating fluctuations in WUA into changes in fishery 

production. However, as stated in the draft EIS, we conclude that the size distribution of sturgeon (shown 

in draft EIS figure 76 and final EIS figure 96) indicates that the effects of current operations on the 

spawning success and recruitment are minimal. This finding is supported by the uniform distribution of 

larger size classes, which indicates that successful reproduction and recruitment occurs in most, if not all, 

years. 

Comment AR-110: AR/IRU comments that the draft EIS analysis on effects of ramping impacts to 

sturgeon did not take into account effects on spawning or on the food supply available to white sturgeon. 

AR/IRU recommends that FERC refer to the FWS biological opinion on relicensing of the C.J. Strike and 

mid-Snake projects, which found that flow fluctuation can shrink the amount of deep-water habitat, 

degrade water quality and reduce food availability, even when such habitat is not dewatered. 

Response: Habitat conditions in the Hells Canyon reach are substantially different from those that occur 

in the C.J. Strike reach. Habitat in the C.J. Strike reach is much shallower than the Hells Canyon reach, 

and contains few deep, turbulent areas that are favored by spawning sturgeon and that are abundant in the 

Hells Canyon reach. Further, habitat use information provided in Lepla and Chandler (2003) indicate that 

all lifestages of sturgeon from larvae to adult rarely use habitat that is less than 4 meters deep. We 

maintain that the level of food production in water this deep is unlikely to be affected by the range of flow 

fluctuations that are caused by project operations. As we noted on page 257 of the draft EIS, there is no 

indication that growth rates have declined because the sturgeon population rebounded after catch-andrelease regulations were implemented, and the growth rates of sturgeon in the Hells Canyon reach 

compare favorably to other reaches of the Snake and Columbia rivers. 

Comment AR-111: The Forest Service comments that FERC staff should adopt the adaptive 

management program proffered by the Forest Service and FWS as a means to identify the need for more 

restrictive ramping during sturgeon spawning, as well as other recommendations submitted by resource 

agencies designed to protect and enhance sturgeon populations in the Snake River. AR/IRU comments 

that the fact that there is some sturgeon recruitment does not show that project operations are not reducing 

the recruitment of sturgeon. AR/IRU state that FERC has dismissed Interior’s expert analysis without 

any real justification. 

Response: Given the considerable variation in load following operations between low and high flow 

years, we would expect to see evidence of impaired recruitment, if it were to occur, during low-flow years 

when load following operations are prevalent during the sturgeon spawning and incubation season. 

However, the size distribution of sturgeon both upstream of and downstream from the Salmon River is 

uniform for all size classes between 100 and 230 cm in length (shown in draft EIS figure 76 and final EIS 

figure 96). We find no indication of impaired recruitment. In addition, we consider it highly unlikely that 

the load following study proposed by the Forest Service and Interior would yield any useful insights 

regarding the effects of load following on sturgeon recruitment, considering the lack of effective methods 

for assessing the abundance of young lifestages of sturgeon before they attain a size that is susceptible to 

setline sampling (approximately 70 cm). 

Comment AR-112: Interior states that in average flow years, the refilling process at Brownlee reservoir 

likely has a negative effect on white sturgeon progeny that have just hatched and are foraging in the main 

stem of the Snake River downstream from Hells Canyon dam. Interior states that this appears to be an 

unmitigated effect that occurs every year and should be analyzed more fully in the EIS. 

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Response: If reduced flows during the refilling process at Brownlee reservoir were adversely affecting 

recruitment, we would expect to see reduced recruitment during high flow years when flood control drafts 

are more substantial. Based on the information in draft EIS figure 76 (final EIS figure 96), we see no 

indication that substantial variation in recruitment occurs between years. 

Comment AR-113: Interior states that the NEPA document should fully analyze the potential permanent 

loss of sturgeon production in the Brownlee reservoir reach as a result of project caused temperature and 

water quality problems. 

Response: Based on the evidence in the record, there appears to have been no permanent loss of sturgeon 

production in Brownlee reservoir. There has not been a kill of adult sturgeon observed in Brownlee 

reservoir since 1990, and water quality conditions in the Swan Falls reach and in Brownlee reservoir are 

expected to gradually improve with implementation of the phosphorus TMDL. Idaho Power proposes 

measures, which we adopt in the Staff Alternative, to assess whether recruitment in this reach is limited 

by water quality conditions, followed by translocation or stocking efforts to rebuild the sturgeon 

population in the Swan Falls to Brownlee reach. 

Comment AR-114: Interior comments that because setlines are not efficient at collecting smaller 

sturgeon, there is a lack of information on survival and recruitment of younger age classes of white 

sturgeon. Interior states that the NEPA document should include an analysis of other measures that could 

be implemented at the project to boost sturgeon survival from vitellogenesis and spawning through 

incubation, early rearing, juvenile, and adult life stages. 

Response: We maintain that the uniform size distribution of sturgeon between 100 and 230 cm observed 

both upstream of and downstream from the Salmon River, despite substantial differences in flow levels 

and load following operations between years, provides substantial evidence that recruitment is occurring 

consistently and is not being substantially affected by project operations. 

Comment AR-115: The Shoshone-Paiute Tribes recommend that conservation and restoration of white 

sturgeon be made a high priority issue for the project, and that effects on sturgeon be included in the list 

of principal issues in section 1.1, Purpose of Action. 

Response: We modified final EIS section 1.1, Purpose of Action, of the final EIS, accordingly. 

Comment AR-116: Interior and the Shoshone-Paiute Tribes state that the goal of the hatchery sturgeon 

program should be amended to reflect the goal of Idaho Power’s White Sturgeon Conservation Plan, 

which is to have harvestable (catch and keep) fisheries for sturgeon in the Snake River. 

Response: We modified the text in section 3.6.2.13, Sturgeon Conservation Measures, accordingly. 

Comment AR-117: The Umatilla Tribes and the Nez Perce Tribe express support for the development of 

a Sturgeon Aquaculture Plan, but indicate that the plan needs more details regarding: (1) a plan for siting 

and operation a conservation hatchery; (2) broodstock collection, holding, and catalogue procedures; (3) 

collection and monitoring schedule for regular (1–3 year intervals) stock assessment/broodstock 

collection surveys; (4) genetic catalogue of adult spawners and released family groups; (5) breeding plan; 

and (6) research and development using radio/sonic tags to evaluate movement of hatchery sturgeon prior 

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to implementation of management-level stocking. 

Response: We include, in the Staff Alternative, a measure that would require Idaho Power to conduct a 

feasibility assessment that would assess the risks and benefits of the translocation and conservation 

aquaculture approaches for restoring white sturgeon populations in the reaches between Swan Falls and 

Hells Canyon dams. We note, however, that implementing a conservation aquaculture program would 

require approval from IDFG and ODFW, and approval by these agencies is uncertain. If approval to 

proceed with a conservation aquaculture program is obtained, the development of a detailed Aquaculture 

Plan, in consultation with the agencies and tribes, would be appropriate. We discuss our recommendation 

in section 5.2.4.10, Sturgeon Conservation Measures. 

Comment AR-118: AR/IRU comment that the draft EIS does not address the Conservation Groups 

recommendation that a Technical Advisory Committee have authority to determine whether the 

conservation aquaculture program should be expanded beyond the Swan Falls reach. 

Response: Expansion of a sturgeon aquaculture program to include stocking of additional reaches could 

be accommodated at minimal additional cost. However, any decision to stock sturgeon in reaches 

upstream of Swan Falls dam would need to be implemented through the licenses of those projects 

associated with the reach under consideration. In the case of the Mid-Snake and C.J. Strike projects, this 

would be accomplished through the license re-opener process. For the Swan Falls Project, this could be 

addressed in the upcoming licensing proceeding. 

Comment AR-119: The Umatilla Tribes and the Nez Perce Tribe concur that attempts to implement 

upstream passage for sturgeon or replacing trashracks would likely involve a substantial expenditure of 

resources while providing little benefit. They note that downstream movement of white sturgeon will 

provide continued genetic variability, provided that the Conservation Plan includes a breeding program 

that maximizes genetic diversity in the affected section of the Snake River. Similarly, they agree that 

reducing trash rack spacing and entrainment concerns might create more mortality than turbine passage, 

particularly for young fish, and note that this issue has not been a significant concern on the lower Snake 

and the Columbia rivers. 

Response: We note the Umatilla and Nez Perce’s concurrence with our analysis on this matter. We did 

not modify our recommendations pertaining to sturgeon passage. 

Comment AR-120: Interior recommends that the NEPA document include cost estimates for providing 

effective trash rack upgrades to prevent juvenile sturgeon entrainment. ODFW supports ongoing 

consultation to determine whether providing upstream and downstream passage is feasible and desirable. 

AR/IRU comment that the draft EIS does not address whether, in the absence of entrainment, the sturgeon 

populations would be in better shape. 

Response: We expand our analysis in final EIS section 3.6.2.13, Sturgeon Conservation Measures, to 

evaluate whether reducing the trash rack spacing is a viable option to minimize the risk of entrainment. 

Based on our analysis, we conclude that the potential for sturgeon impingement on the racks would 

increase. Expanding the size of the intake and trash rack structure could reduce approach velocities and 

the potential for impingement, but would involve substantial capital costs given the engineering 

challenges of constructing a large structure in a deepwater forebay environment. We modified our 

recommended White Sturgeon Plan to include annual meetings with agencies and tribes to discuss 

monitoring and study results, and to consider whether additional measures or refinement of existing 

measures may be warranted to further enhance populations of white sturgeon. 

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Comment AR-121: The Forest Service comments that FERC staff appears to be relying on outdated 

paradigms by asserting that aquaculture and hatcheries can resolve problems related to white sturgeon 

habitat and population recovery in the Snake River. ODFW comments that sturgeon populations cannot 

be rebuilt relying on hatchery production alone. ODFW states that, as seen throughout the Columbia 

River basin with salmon and steelhead, suitable habitat conditions, including water quality and quantity, 

throughout the sturgeon’s life history are necessary to support natural reproduction. 

IDFG expresses concern regarding adoption of a conservation aquaculture approach to rebuilding 

sturgeon populations in the project area. The primary concerns that IDFG identifies are the risk of genetic 

swamping of wild populations with offspring from a small number of parent fish and artificial selectivity 

associated with aquaculture practices and the hatchery environment. In addition, IDFG notes that in 

Idaho, only the director of IDFG is authorized to establish and maintain fish hatcheries, and has 

supervision over all matters pertaining to the inspection, cultivation, propagation and distribution of 

wildlife. IDFG states that implementation of a hatchery conservation program, as the primary mitigation 

measure for white sturgeon protection and enhancement, is inconsistent with IDFG’s Fisheries 

Management Plan and Draft White Sturgeon Management Plan. 

ODFW (73-81) expresses many of the same genetic concerns as IDFG. ODFW states that it does not 

currently support a conservation aquaculture program due to the inherent risks and uncertainties 

associated with such a program. ODFW comments that the genetic implications of hatchery 

supplementation on wild stocks of white sturgeon, especially those downstream from Hells Canyon dam, 

must be thoroughly investigated first. ODFW continues to support genetic monitoring to detect the 

potential loss of genetic variation by inbreeding and genetic drift. 

Idaho Power opposes stocking of sturgeon in the project reservoirs because: (1) stocking is not supported 

by the state resource management agencies, and (2) such programs are experimental and have not 

demonstrated long-term effectiveness in preserving sturgeon populations. Idaho Power also notes that 

some degree of continued supplementation would probably be required to maintain some desired level of 

population abundance, making the long-term benefit of this action questionable. 

Response: We maintain that implementing a conservation aquaculture program is the only feasible 

means, other than a large-scale translocation program, to rebuild sturgeon populations in many of the 

interdam segments that do not include appropriate habitat to support the spawning, incubation, and larval 

lifestages of white sturgeon. Due to low population sizes and the fact that only about 10 percent of adult 

female sturgeon spawn in each year, only a small number of reproductive broodstock would need to be 

collected in any given year to match or exceed the level of genetic diversity that would result from natural 

reproduction in these reaches, especially if the broodstock were collected from a large, genetically diverse 

population such as in the lower Columbia River. In addition, because few adult fish would be needed in 

any year, new broodstock could be collected from the wild each year. This would help avoid the selective 

pressures that can occur when multiple generations of fish are spawned and reared in the hatchery 

environment. 

We recognize that white sturgeon could not be stocked without approval from the state management 

agencies. Thus, we modified the Staff Alternative to include a feasibility assessment that is intended to 

assist IDFG and ODFW with weighing the risks and benefits of implementing a conservation aquaculture 

program. 

We maintain that genetic risks can be reduced to negligible levels through appropriate selection of 

broodstock, and that regular stocking could succeed in developing harvestable populations of sturgeon in 

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river segments that do not provide suitable habitat for spawning, incubation and larval lifestages of 

sturgeon. Also, marking of hatchery sturgeon via fin clips would allow selective harvest of any hatcheryorigin sturgeon that move downstream into the Hells Canyon reach, further reducing the level of genetic 

risk to that population of sturgeon. Nonetheless, we modified the Staff Alternative to include monitoring 

of genetic variation, recognizing that this would provide useful information for guiding a conservation 

aquaculture or translocation program for rebuilding sturgeon populations. 

Comment AR-122: Idaho Power maintains that the measures and strategies proposed for white sturgeon, 

as outlined in the final license application, provide a reasonable and logical progression for adaptive 

implementation of actions as the White Sturgeon Conservation Plan unfolds. Idaho Power, therefore, 

urges that the proposed alternative in the final EIS include each of the aspects of the proposed White 

Sturgeon Conservation Plan. 

Response: We modified the Staff Alternative to include each of the measures recommended by Idaho 

Power in the White Sturgeon Conservation Plan. However, we added a feasibility assessment for 

implementing a conservation aquaculture approach to rebuilding white sturgeon populations in each interdam segment between Swan Falls and Hells Canyon dams. 

Comment AR-123: ODFW (78-79) states that FERC staff should place increased emphasis on habitat 

improvement, and that sturgeon mitigation efforts should be focused on improving degraded water quality 

via a concerted and cooperative effort led by the Idaho and Oregon Departments of Environmental 

Quality. ODFW notes that white sturgeon collected from Brownlee reservoir had significantly lower 

condition factors than white sturgeon captured in Bliss, Oxbow, and Lower Granite reservoirs, and that 

Idaho Power attributes these lower condition factors to poor water quality in the reach of the Snake River 

below Walters Ferry to Brownlee reservoir. Interior and AR/IRU recommend that the discussion of 

future water quality improvements be revised to reflect the fact that changes may be quite slow since the 

nutrient portion of the TMDL has a 70- to 75-year compliance time frame, and is voluntary with respect 

to nonpoint source polluters. 

Response: Efforts to improve water quality conditions in the project reservoirs (such as funding efforts 

to reduce phosphorus inputs) would benefit white sturgeon, as would water quality improvements in the 

Swan Falls reach. However, this type of measure lacks sufficient nexus to the effects of Idaho Power’s 

Snake River projects for the Commission to require that the measures be funded by Idaho Power. To 

address the temporal issues, we qualified our references to water quality improvements to indicate that 

they would be gradual in nature and would extend beyond the term of the next license. 

Comment AR-124: The Umatilla Tribes and the Nez Perce Tribe comment that it is inappropriate for 

FERC staff to reject measures to improve water quality for sturgeon in upstream areas since reservoirs act 

to exacerbate nutrient problems, resulting in large DO-related fish kills. They note that anoxic conditions 

near the reservoir bottoms tend to increase the concentration of methylmercury, the most toxic and 

bioaccumulative form of mercury. They also comment that increasing the concentration of DO in the 

reservoir beyond what is simply required in TMDL calculations is important in the interest of reducing 

the exposure to mercury. 

Response: See previous response. Our understanding of the conditions that led to the major fish kill in 

1990 included anoxic conditions within the riverine reach upstream of, as well as within, the reservoir. 

This indicates that the fish kill may have extended upstream into the free-flowing river, and was not 

necessarily exacerbated by reservoir processes. In addition, we note that no major fish kills have been 

reported in project reservoirs since 1990. 

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Comment AR-125: The Umatilla Tribes and the Nez Perce Tribe comment that it will be necessary for 

Idaho Power to maintain close involvement with other resource managers dealing with white sturgeon for 

guidance and assistance as they begin the task of restoring the species to the capacity of the habitat. They 

recommend that the NEPA document contain a recommendation for this issue to be addressed by the 

aquatic resource committee. 

Response: Idaho Power continues to convene the interagency white sturgeon Technical Advisory 

Committee on an annual basis to review the results of the past year’s efforts and to guide ongoing study 

efforts. We modified the Staff Alternative to include annual meetings of the white sturgeon Technical 

Advisory Committee for the purpose of reviewing the results of monitoring efforts and managing ongoing 

monitoring programs, as well as managing the implementation of enhancement measures. 

Comment AR-126: The Umatilla Tribes and the Nez Perce Tribe comment that monitoring the 

bioaccumulation of toxic materials in sturgeon may provide useful information. They note that sturgeon 

have been a key fish species in environmental monitoring below Hanford for years because of their mode 

of feeding on bottom sediments and also their ability to ingest organisms from higher trophic levels. 

Because contaminated sediments can be scoured and exposed to the surface intermittently, the tribes state 

that a long-lived species such as sturgeon can be said to better integrate conditions over a greater time 

period. ODFW recommends site-specific analysis of the potential effects of bioaccumulation of 

contaminants on reproductive success and recruitment of white sturgeon. 

Response: Although Idaho Power is not responsible for introducing these legacy contaminants into the 

environment, the accumulation of contaminant-laden sediments in the project reservoirs does increase the 

exposure of sturgeon and other fish species to these contaminants. As discussed in final EIS section 

5.2.4.10, Sturgeon Conservation Measures, we modified the Staff Alternative to require that Idaho Power 

collect tissue samples during their proposed population monitoring efforts, and provide the samples to 

IDEQ or ODEQ for analysis, if it is requested to do so by either of these agencies. 

Reservoir Fisheries 

Comment AR-127: Interior comments that in draft EIS table 29, tadpole madtom (Noturus gyrinus) is 

not native to the Snake River and should be listed as an exotic species. 

Response: We modified final EIS table 32 accordingly. 

Comment AR-128: AR/ARU questions why the draft EIS discusses the risk of dewatering bass nests in 

Brownlee reservoir, when water levels typically rise during the bass spawning season. AR/IRU also 

claims that the draft EIS says that reduced ramping during the fall Chinook rearing will “significantly” 

reduce erosion downstream from the project. 

Response: Water levels typically rise during the smallmouth bass spawning season. However, figure 23 

in Richter and Chandler (2001) indicates that some smallmouth bass nests were exposed to receding water 

levels during the 1991 to 1998 study period. As for the effects of ramping, we were not able to locate any 

statements in the draft EIS where we indicated that the seasonal ramp rate would significantly reduce 

erosion. However, we revised the final EIS text to clearly indicated that the reduction in erosion 

associated with the seasonal ramp rate would be minor. 

Comment AR-129: Interior recommends that the Commission include implementation of an adaptive 

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management program for warmwater fisheries, as well as a mitigation plan for any impacts to warmwater 

fisheries that are caused by project operations. Interior also recommends that BLM be consulted 

regarding the Warmwater Fisheries Plan. 

Response: We modified the Staff Alternative to include annual consultation with ODFW, IDFG and 

BLM on the results of warmwater fisheries monitoring and assessing effects of project operations on the 

fishery, as well as to identify any feasible measures to minimize adverse effects. 

Comment AR-130: The Umatilla and Nez Perce tribes comment that FERC staff recommends measures 

such as spawning protection to promote warmwater fish population productivity within the project. The 

tribes state that they do not support these measures because exotic warmwater fish prey on, and cause 

ecological problems for, native resident fish, anadromous salmonids, and other native species. They state 

that the draft EIS does not examine active measures to control and reduce inappropriate warmwater fish 

populations and the implications of these measures on restoration of native fish. The tribes recommend 

that these measures be addressed in the NEPA document. 

Response: We recognize the cultural importance of native fish species to the tribes. Many of the 

measures that we adopt in the Staff Alternative are intended to benefit these species. However, the 

warmwater fishery in Brownlee reservoir is a popular recreational resource and provides substantial 

economic benefits to local communities. Although the presence of warmwater fish species could result in 

predation on salmon and steelhead smolts if anadromous fish species are reintroduced upstream of the 

project, this potential adverse effect would be limited if downstream migrating smolts were collected 

upstream of and transported around the project reservoirs. Also, the potential benefits of controlling 

warmwater fish populations to reduce predation on anadromous fish can be addressed as part of any 

future anadromous fish restoration planning efforts. 

Comment AR-131: ODFW states that it supports the operating constraints recommended by FERC staff 

to protect warmwater fish spawning, including the provision that warmwater fish spawning protection 

would be secondary to any conflicting operational requirements. ODFW also supports staff’s proposal to 

conduct annual warmwater fish population monitoring at established electrofishing sites in each reservoir, 

and every fifth year between Swan Falls dam and Brownlee reservoir. ODFW comments that sampling 

should be coordinated annually with ODFW and expanded to assess the status of catfish, which was 

identified as the primary target species in angler surveys conducted by Idaho Power. 

Response: We modified Idaho Power’s proposed Warmwater Fish Monitoring Plan to include methods 

suitable for monitoring channel catfish; to file annual reports of monitoring results; and to consult with 

ODFW, IDFG, and BLM to identify feasible measures to reduce adverse effects on warmwater fisheries. 

Hatchery Production 

Comment AR-132: Interior comments that draft EIS table 36 should be moved to section 3.6.1.8 

Response: The referenced table (final EIS table 39), which is cited in the first paragraph on page 191 of 

the draft EIS, is already part of section 3.6.1.8. It remains in the same section in the final EIS 

Comment AR-133: NMFS comments that it views HGMPs as a necessary component of the 

management of any hatchery, and that it is unclear from the language on page 303 whether 

FERC agrees that the HGMPs are essential. NMFS notes that FERC staff appears to 

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misconstrue its intent for monitoring various aspects of hatchery fish performance, including 

smolt-to-adult return rates and straying rates. Such monitoring is not intended by NMFS to 

supplant specified hatchery production levels. Rather, monitoring is designed to identify the 

likelihood of return and straying rates to identify any problems with fish qualities in keeping with 

the HGMP. 

Response: We understand that the development of and implementation of HGMPs are essential to 

ensuring that hatchery operations are in compliance with NMFS’s 4(d) rules for take of listed species. 

Furthermore, we recognize that HGMPs may contain elements to evaluate, minimize, and account for the 

propagation program’s genetic and ecological effects on natural populations, including disease transfer, 

competition, predation, and genetic introgression caused by straying of hatchery fish. In the Staff 

Alternative, we recommend that Idaho Power fund IDFG, as the operator of Idaho Power’s hatchery 

system, to work with NMFS to develop HGMPs for each of the project’s hatcheries. 

Comment AR-134: Interior states that it agrees that the current level of hatchery production as 

proposed in the final license application is appropriate, at least in the interim. Interior’s 

recommendation for a new license is for the Commission to include a plan to reduce 

dependence on artificial fish production by restoring natural fishery production for fall Chinook 

salmon, spring Chinook salmon, and summer steelhead. Interior states that the Staff Alternative 

should require a Habitat Improvement Plan that facilitates increased fishery production by 

addressing present and ongoing project effects caused by degraded water quality and 

operations of the project. Interior recommends that the NEPA document assess the long-term 

role of hatchery production for the project, and evaluate whether it is possible to fully mitigate 

anadromous and resident fish losses by improving habitat, access, and connectivity 

downstream, within, and upstream of the project. 

Response: We evaluate a wide range of environmental measures in the draft EIS that are 

directed toward improving habitat conditions, addressing fish passage and habitat connectivity. 

We adopt many measures in the Staff Alternative that would benefit the natural production of 

resident and anadromous fish. Such measures include: (1) enhancing DO and reducing TDG 

levels within and downstream from the project; (2) implementing tributary habitat enhancements 

in the Burnt, Powder, Wildhorse, Indian, and Pine basins; (3) improving the fish trap at Hells 

Canyon dam and installing tributary traps at Pine Creek, Indian Creek, and the Wildhorse River 

and a second adult trap at Oxbow dam; (4) continuing the flow augmentation and fall Chinook 

salmon spawning and incubation flow programs; (5) implementing seasonal ramp rate 

restrictions; and (6) constructing a new hatchery on Yankee Fork in the Salmon River basin 

Comment AR-135: The Nez Perce Tribe comments that all hatchery management plans 

regarding the production of Chinook salmon and release locations are developed through the 

United States v Oregon process, which the Nez Perce Tribe is an active participant in. The tribe 

comments that FERC has no say in this process and cannot approve or disapprove of 

measures developed in this ongoing court-overseen process. The Nez Perce Tribe rejects 

staff’s conclusion that hatchery management plans be developed with “tribes,” because this 

assumes that all tribes in this proceeding have an equal say in hatchery production by Idaho 

Power. The Nez Perce Tribe benefits from Idaho Power hatcheries in its treaty area, including 

the Rapid River and Oxbow facilities, through harvest in the Rapid River and with spring 

Chinook salmon restoration efforts in the Clearwater River basin. By lumping all tribes together, 

including those without treaty fishing rights in this recommendation, the Nez Perce Tribe states 

that FERC unwittingly has created a situation for serious fisheries management conflicts 

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between the Nez Perce and other tribes in this proceeding. The tribe states that Nez Perce 

treaty rights and fisheries must not be negatively affected by this measure. 

Response: During the section 10j meetings, NMFS clarified that it works with the operators of each 

hatchery to develop HGMPs, and that its recommendation was directed at ensuring that Idaho Power fund 

measures that are required under the HGMP. As a result, we modified the final EIS to clarify that our 

Staff Alternative includes funding of hatchery measures required for the hatcheries to be operated in 

compliance with their HGMPs. We no longer recommend that Idaho Power develop the plan or identify 

who would be consulted in its development. 

Comment AR-136: ODFW comments that hatchery management plans should comply with 

revised United States v Oregon production plans and balance available fish needed for fish 

passage and reintroduction with production needed for fisheries. ODFW states that the 

management plans should include provisions to identify and develop suitable spring Chinook 

and fall Chinook broodstock for reintroduction, as well as ensure that suitable numbers of spring 

Chinook, summer steelhead, and fall Chinook are available to conduct passage studies and 

implement reintroduction. ODFW requests that within the final EIS, FERC staff provide specific 

information on what is included in the hatchery management plans, and provide assurances that 

10(j) recommendations such as alternative fisheries in Oregon and development of a fall 

Chinook salmon broodstock at Oxbow Hatchery are included. ODFW recommends that a 

component of the monitoring and evaluation program should be to monitor hatchery fish straying 

to natural spawning grounds. 

Response: See our response to the previous comment. As we discuss in final EIS section 5.2.4.3, 

Anadromous Fish Restoration, we conclude that it is premature for the Commission to require Idaho 

Power to proceed with a program to reintroduce anadromous fish upstream of the project, so we do not 

include a requirement that Idaho Power develop broodstock for reintroduction at this time. However, we 

do include in the Staff Alternative a provision that would require Idaho Power to consult with the Burns 

Paiute Tribe, the Shoshone-Paiute Tribe, potentially the Shoshone-Bannock Tribes, the Nez Perce Tribe, 

ODFW, IDFG, Interior and NMFS to develop a surplus hatchery fish distribution plan. The goals of the 

plan would be to (1) stock surplus hatchery fish in the project reservoirs and/or select tributaries within 

the project area to restore marine derived nutrients to these streams and provide forage for bull trout; (2) 

provide an opportunity to evaluate spawning success, egg viability and survival, as well as smolt outmigration and survival in Pine Creek; and (3) identify and support ceremonial, subsistence, and 

recreational fisheries in the project area and Snake River basin. We expect that this plan would outline 

the specific priorities for how the surplus hatchery fish are to be used. 

Comment AR-137: AR/IRU comment that the quality of Idaho Power’s hatchery stock is not 

comparable to those of state and federal hatcheries. AR/IRU state that FERC should mandate 

that Idaho Power hatcheries operate according to best management practices, and, at a 

minimum, under the same standards as federal and state hatcheries and in compliance with the 

Lower Snake Compensation Plan. 

Response: The Staff Alternative recommends that Idaho Power implement HGMPs that are 

under development for its hatcheries. This requirement would likely result in identification of 

best management practices and policies necessary to meet its obligation for hatchery 

production. 

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Comment AR-138: Idaho Power comments that the current hatchery program targets 1 million 

fall Chinook salmon, 3 million spring Chinook salmon, 1 million summer Chinook salmon, and 

400,000 pounds of steelhead smolts. Idaho Power states that the switch from 4 million spring 

Chinook salmon to 3 million spring Chinook and 1 million summer Chinook was made by IDFG 

in 1985 to focus Idaho Power’s hatchery program on propagation of indigenous Pahsimeroi 

River summer Chinook salmon, rather than the Rapid River spring Chinook stock, which was 

not native to this drainage. The 1980 Settlement Agreement allows for this type of deviation 

from the defined production goals, as long as the total production remains within the prescribed 

4 million Chinook smolts annually. 

Response: We modified the text of final EIS section 3.6, Aquatic Resources, to show the 

current hatchery program targets, as modified in 1985 by IDFG. 

Comment AR-139: Idaho Power comments that the locations of the Upper Pahsimeroi Fish 

Hatchery and Lower Pahsimeroi Fish Hatchery shown in draft EIS figure 36 are reversed, and 

that the word “Niagara” is misspelled in figure 36. 

Response: We corrected draft EIS figure 36 (final EIS figure 55) accordingly. 

Comment AR-140: Idaho Power states that it is proposing to acquire a fish-marking unit, as 

part of the new operating license, to make the current marking programs more efficient, not to 

increase current marking capacity. Idaho Power also states that the final EIS should clarify that 

all smolts currently produced and released as part of the Idaho Power’s mitigation program are 

marked with an adipose fin clip. Also, some smolts are marked with coded wire tags and/or 

passive integrated transponders for evaluation purposes. 

Response: We revised the text in the final EIS accordingly. 

Comment AR-141: Idaho Power states that it does not believe that its involvement in a hatchery 

technical oversight committee would resolve conflicts among state and federal resource agencies, Native 

American tribes, and conservation groups, as stated in the draft EIS. Idaho Power notes that conflicts 

generally involve broader fish management issues such as use of hatchery-bred fish in listed species 

recovery planning, sport and tribal harvest management, and equitable distribution of surplus hatcherybred fish, and other issues that Idaho Power has no authority to resolve. 

Response: We revised the final EIS to eliminate reference to formation of a Hatchery Oversight 

Committee. However, we recommend that Idaho Power consult with the state and federal fisheries 

management agencies and interested tribes to outline the goals and objectives for each hatchery. Such 

consultation would help ensure that: (1) goals and objectives are accurately reflected in the HGMPs that 

will govern future hatchery operations, and (2) the HGMPs are consistent with United States v Oregon

production plans and Idaho Power’s responsibilities under a new license. We also recommend that Idaho 

Power consult with these same parties to develop a plan for the use of surplus hatchery fish. Although we 

recognize that Idaho Power does not have authority over agency and tribal resource management 

decisions, it would be beneficial for Idaho Power to participate in the development of these plans to 

ensure that they are consistent with any requirements that are included in a new license. 

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Comment AR-142: Idaho Power states that the NOAA Fisheries-sponsored HGMP is the 

appropriate mechanism to achieve the goals expressed by AR/IRU, ODFW, and IDFG of 

adaptively managing the Idaho Power hatchery program and measuring its long-term 

performance. Idaho Power does not agree that ongoing review should allow for increases in 

hatchery smolt production beyond that established in the 1980 Settlement Agreement. Nor 

does Idaho Power support a forum to discuss increases in current smolt production to satisfy a 

continually increasing competition for fish between resource agencies, Native American tribes, 

and conservation groups to fulfill their individual fisheries objectives (i.e., adult escapement 

goals). Further, Idaho Power states that, since it has no authority to determine the appropriate 

distribution of surplus adult fish from its hatchery program, its involvement in drafting a hatchery 

management plan will not resolve ongoing conflicts among state agencies and Native American 

tribes for equitable distribution of surplus adult hatchery fish. Assuming that agencies and tribes 

can reach consensus on the appropriate use of hatchery-origin fish, Idaho Power states that it 

remains prepared to make such fish available to them without delay. 

Response: Our Staff Alternative recommends that the smolt production targets, as specified in 

the current license, should continue under any new license issued for the project. Developing 

HGMPs for Idaho Power mitigation hatcheries and a distribution plan for surplus hatchery fish 

collected at the hatcheries and the Hells Canyon trap, in consultation with fisheries 

management agencies and the tribes would create a process for determining how surplus 

hatchery fish would be used and an evaluation of the impacts of hatchery production on listed 

stocks. 

Comment AR-143: Idaho Power states that in 1984 it entered into an agreement with the 

Corps that guaranteed it sufficient eggs from the Lyons Ferry Hatchery to support the entire fall 

Chinook salmon program at Oxbow Hatchery. While development of a fall Chinook broodstock 

at Oxbow Hatchery remains an option, Idaho Power states it should not be considered 

mandatory, because the existing agreement fully meets Idaho Power’s obligation regarding fall 

Chinook hatchery production. 

Response: In the draft and final EIS, we recommend maintenance of current hatchery 

production as appropriate for the new license. Steps that are needed to operate Idaho Power’s 

hatchery system in compliance with the ESA 4(d) rules, which may require development of a fall 

Chinook salmon broodstock at Oxbow Hatchery, will be identified in the HGMP for Oxbow 

Hatchery. 

Comment AR-144: Idaho Power comments that available production space in their hatchery 

system should not be used to assist with restoration of fisheries such as those in Panther Creek 

and the Yankee Fork, as recommended by the Shoshone-Bannock Tribes. Idaho Power states 

that there has been no showing of Shoshone-Bannock tribal entitlement to the restoration of 

such fisheries, and if such a showing could be made, the duty to restore the fisheries would be 

with the United States, the trustee of the tribes, not with Idaho Power. Idaho Power states that 

passing on the cost of a hatchery program not related to operation of the project would be unfair 

to Idaho Power ratepayers. Also, Idaho Power states that no evidence exists to suggest that 

Idaho Power’s hatchery stocks are appropriate for fisheries restoration in the Yankee Fork or 

Panther Creek. Given that ESA-listed Chinook salmon and steelhead may be present in these 

Salmon River tributaries, Idaho Power states that decisions on the appropriate use of hatcheryorigin fish in species recovery lies solely with NOAA Fisheries. Idaho Power comments that it is 

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prepared to make all surplus adult fish from its hatchery program available to state and federal 

resource agencies and Native American tribes for their use, as they deem most appropriate. 

Idaho Power states that upgrades to its anadromous fish hatchery facilities should focus on: 

(1) operational efficiencies (e.g., improved waste management, employee safety, etc.); 

(2) technological advances to improve the quality of smolts produced (e.g., increased survival, 

reduced pathogens, reduced handling stress, increased egg quality, etc.); and (3) monitoring 

and evaluation requirements (e.g., improved fish marking). Idaho Power states that modification 

of hatchery production goals and distribution of surplus fish should not drive the need for facility 

improvements. 

Response: As noted in our response to previous comments, we include in the Staff Alternative 

a recommendation that Idaho Power provide funding to the Shoshone-Bannock Tribes to 

develop a program to spawn and incubate salmon and steelhead eggs on the Yankee Fork of 

the Salmon River. Also, the project dams continue to block fish passage, which, in turn, 

continues to affect the opportunity for the Shoshone-Bannock Tribes, Shoshone-Paiute Tribes, 

and Burns Paiute Tribe to catch fish for ceremonial and other purposes. These upstream tribes 

do not receive any benefit from Idaho Power’s hatchery system. To provide these tribes with 

fisheries benefits in the near term, we include in the Staff Alternative a measure that would 

require Idaho Power to consult with these tribes, the Nez Perce Tribe, and state and federal 

fisheries management agencies to develop a plan to use surplus hatchery salmon and 

steelhead. Among the plan’s goals would be using surplus fish to create and support harvest 

fisheries at locations that would provide the maximum benefit to the tribes. The plan would also 

provide for releasing surplus fish into the project reservoirs and tributaries within the project 

reach to add marine-derived nutrients to the system, increase forage opportunities for bull trout, 

and support recreational fisheries, as well as facilitate establishing a program to evaluate 

production of spring Chinook salmon and steelhead in Pine Creek. 

Comment AR-145: Idaho Power comments that FERC statements in the draft EIS regarding 

the appropriate level of hatchery production are contradictory. 

Response: We modified section 5.2.4.8, Hatchery Production, to clarify that we recommend 

the current smolt production targets be retained, but that Idaho Power would be required to fund 

operations that comply with HGMP to be developed by IDFG and NMFS for each hatchery. We 

understand, based on discussions at the section 10(j) meeting, that the HGMPs could include 

goals for societal use that would be used to assess whether changes in production strategy are 

warranted. These goals would not be used to leverage increases in levels of smolt production, 

which will be specified in an appropriate license article. 

B10. TERRESTRIAL RESOURCES 

Terrestrial Habitat Conditions 

Comment TR-1: Brett Crow suggests some reorganization of the NEPA document so that the Affected 

Environment section for terrestrial resources more directly informs the Commission and the public about 

the dry land acreage given up to current power generation practices. 

Response: The acreage of land inundated by project construction has been added to the discussion of 

cumulative effects in section 3.7.3, Cumulative Effects. Draft EIS table 65 (final EIS table 70) shows the 

acreage of land currently affected by the project.

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Comment TR-2: ODFW comments that draft EIS table 65 fails to include the ongoing and unmitigated 

impacts of reservoir and river inundation and does not include estimates of wetland habitat affected or 

acreage of impacts by habitat or cover type. 

Response: Draft EIS table 65 (final EIS table 70) is intended to summarize the acreage of riparian 

(including wetland) and upland habitat types affected by ongoing project operation. We did not revise the 

table in the final EIS.

Key Wildlife Species 

Comment TR-3: Interior requests that the NEPA document include a discussion of the Deer Flat 

National Wildlife Refuge and Fort Boise WMA, which are regionally important nesting and resting areas 

for migratory birds in western Idaho. 

Response: We added text to section 3.7.1.4, Key Wildlife Species, to describe these two areas.

Comment TR-4: Idaho Power comments that the mew gull does not nest in Hells Canyon. 

Response: The text that identifies the mew gull as one of several colonially nesting species that may be 

present in the project area in spring or summer is based on appendix 3 of Turley and Holthuijzen (2003c). 

The EIS does not identify this species as nesting in Hells Canyon. 

Special Status Plants and Wildlife 

Comment TR-5: IDFG agrees that a project-wide Threatened, Endangered, and Sensitive Species 

Management Plan (TESSMP) should be developed in consultation with IDFG and other agencies and 

interests. ODFW also supports development of a TESSMP, recommending that Idaho Power provide a 

forum for cooperative strategy updates once every 5 years with participation by interested stakeholders. 

Response: We added a recommendation that the TESSMP include a mechanism for coordination and 

cooperation with adjacent landowners and land managers, as well as regular consultation with agencies, 

tribes, and other stakeholders. 

Comment TR-6: Interior comments that the Staff Alternative is unclear regarding the specifics of the 

TESSMP (including monitoring and adaptive management) and how it would accomplish the needed 

mitigation for the list of species identified in Interior, ODFW, and IDFG 10(j) and 10(a) 

recommendations. 

Response: We added an outline of the staff-recommended TESSMP to section 5.2.5.1, Special Status 

Plant and Wildlife Protection. The plan would include monitoring, with changes in management based 

on the results of monitoring, as needed. We also added text to explain how we address the species lists 

provided by Interior and ODFW. 

Comment TR-7: Interior recommends the NEPA document include a list of agency-recommended 

threatened, endangered, and sensitive species that would be included in the TESSMP, and a better 

analysis of species (e.g., peregrine falcon) that would be excluded. 

Response: We added text to section 5.2.5.1 explaining which agency or tribe-recommended species we 

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include in the Staff Alternative’s TESSMP, and why we excluded some species. 

Comment TR-8: Interior notes that the TESSMP described in the draft EIS does not appear to provide 

for trend monitoring. Interior indicates that trend monitoring is important to demonstrate compliance 

with achieving recovery goals and reintroduction goals and to demonstrate non disturbance compliance as 

well. 

Response: The staff-recommended TESSMP would not provide for trend monitoring, except in the case 

of the bald eagle, because the intent is to focus on the implementation and effectiveness of specific 

environmental measures. However, the results of Idaho Power’s monitoring program should be useful to 

the resource management agencies in evaluating progress toward species recovery and/or reintroduction 

goals. 

Comment TR-9: The Shoshone-Paiute Tribes comment that the scope of staff’s recommended projectwide TESSMP is unclear and that the tribes should be included as parties that will be consulted in 

development and implementation of the plan. 

Response: As described above, we added text to section 5.2.5.1, Special Status Plant and Wildlife 

Protection, to clarify the scope of the TESSMP and identify parties that should be consulted.

Comment TR-10: The Shoshone-Paiute Tribes reiterate terrestrial conditions submitted by the tribes in 

response to the REA Notice, including measures for funding and development of wildlife management 

strategies for appropriate species (e.g., bald eagle and mountain quail) on acquired lands. 

Response: As discussed in sections 5.2.5.1, Special Status Plant and Wildlife Protection, and 5.2.5.5, 

Cooperative Wildlife Management Projects, the Staff Alternative calls for Idaho Power to develop and 

implement measures to protect bald eagles and to participate in projects designed to benefit mountain 

quail habitat and species recovery. 

Comment TR-11: The Forest Service recommends that staff include condition no. 8 (Terrestrial 

Threatened and Endangered Species Management) and condition no. 9 (Sensitive Species Management) 

without modification or limitation in the Proposed Action in the final EIS. The Forest Service provides 

additional detail about the purpose and content of the conditions, and comments that the Staff Alternative, 

which combines these plans, is not clear and does not adequately define requirements for species to be 

included, updating species lists, conducting surveys, monitoring, and protecting or restoring sites to 

address project impacts. 

Response: We added text to section 5.2.5.1, Special Status Plant and Wildlife Protection, to clarify our 

recommendations regarding the TESSMP. We note that the Forest Service modified conditions will be 

included in any new license that is issued for the project.

Comment TR-12: Interior suggests that the NEPA document discuss and analyze the fact that very little 

trend information about special status wildlife species exists as a result of relicensing studies, making it 

difficult to determine project effects. Interior comments that the NEPA document should discuss longterm effects on native wildlife species and the loss of riverine and associated habitats that occurred when 

the project was constructed. 

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Response: Trend information would provide an overview of increases or decreases in wildlife 

populations in the vicinity of the Hells Canyon Project, but would be difficult to use to identify project 

operation as a cause of population change. In our view, surveys of particular species and/or groups of 

species, considered in relationship to project reservoirs, project facilities, and project-related activities, 

provides a more accurate basis for assessing project effects. We added text to the discussion of 

cumulative effects (section 3.7.3.2) to describe the loss of riverine and associated habitats as a result of 

project construction.

Comment TR-13: Interior recommends that the TESSMP include a multi-party advisory board, similar 

to the rare plant advisory board. 

Response: We agree an advisory board would be helpful in providing a mechanism for coordination and 

implementation of cooperative measures. We revised section 5.2.5.1, Special Status Plant and Wildlife 

Protection, to incorporate this conclusion.

Comment TR-14: Interior recommends the NEPA document give additional emphasis to endemic plants 

to determine a range of potential measures that could be implemented during the term of a new license to 

preserve them and prevent them from becoming listed as threatened or endangered. 

Response: The TESSMP would provide a means of protecting and managing endemic species that 

agencies recommended for inclusion in the plan or that Idaho Power’s studies identified as being affected 

by project operations or project-related activities. 

Comment TR-15: Interior comments that the NEPA document should include Interior’s 

recommendations regarding the southern Idaho ground squirrel, amphibians, and reptiles, as well as 

appropriate analysis of project impacts. 

Response: Section 3.7.2.8, Special Status Wildlife, discusses project effects on these species and the 

benefits of recommended measures. We added text to the TESSMP discussion in section 5.2.5.1, Special 

Status Plant and Wildlife Protection, to clarify Interior’s recommendations and how the Staff Alternative 

addresses them. Draft EIS table 97 (final EIS table 108) shows which measures were adopted or adopted 

with exceptions. 

Noxious Weeds and Invasive Exotic Plants 

Comment TR-16: The Forest Service recommends that staff include condition no. 7 (Exotic and 

Invasive Vegetation Management) without modification or limitation in the Proposed Action in the final 

EIS. The Forest Service explains that a Cooperative Weed Management Area (CWMA) would serve as a 

mechanism for building cooperative relationships among agencies, landowners, land managers and other 

individuals and organizations involved in managing weeds, while a Noxious Weed Advisory Board 

(which could include members who are also involved in the CWMA) would develop and implement the 

Integrated Weed Management Plan specified in condition no. 7. The Forest Service also comments that a 

60-day review and comment period prior to Idaho Power’s filing of an Integrated Weed Management 

Plan with the Commission for approval is needed to ensure adequate time for Forest Service review of 

activities that would occur on National Forest System lands. 

Response: We modified the text of section 5.2.5.2, Noxious Weed and Exotic Invasive Plant 

Management, to show that the Staff Alternative includes establishment of a CWMA, as well as a 60-day 

review and comment period prior to filing. 

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Comment TR-17: IDPR states that it concurs with the staff recommendation that the Integrated Weed 

Management Plan should include an agency consultation requirement, and recommends that IDPR be 

included because noxious and invasive weeds have adverse effects on aesthetics and recreation sites. 

IDPR recommends that the plan address the potential spread of noxious weeds by recreational users. 

Response: We modified section 5.2.5.2, Noxious Weed and Exotic Invasive Plant Management, to 

specify that IDPR should be one of the consulting agencies. Section 3.7.2.3 recognizes the potential for 

human activity, including recreation, to serve as a vector for weed spread.

Comment TR-18: ODFW supports the development of an Integrated Weed Management Plan and a 

Noxious Weed Advisory Board, and recommends it be updated every 5 years. ODFW recommends that 

the plan include inventory, prevention and early detection, treatment and restoration, and monitoring and 

evaluation, and that the plan be coordinated with surrounding counties and their weed programs. 

Response: We added text to section 5.2.5.2 to clarify the staff’s recommendations regarding the 

Integrated Weed Management Plan and Noxious Weed Advisory Board. We agree the plan should be 

formally updated at 5-year intervals, but recognize that more frequent adjustments may be needed based 

on the results of monitoring.

Comment TR-19: Interior recommends the NEPA document discuss a specific role for Idaho Power to 

play in the management of project lands to promote long-term control and elimination of invasive and 

noxious plant species, and address the potential future need to expand the list of weedy plant species as 

new invasives populate the area around and within the project boundary. 

Response: We added text to section 5.2.5.2, Noxious Weed and Exotic Invasive Plant Management, to 

clarify the Staff Alternative regarding weed management, including Idaho Power’s role and the need to 

update the list as conditions change. 

Comment TR-20: Interior recommends that the NEPA document include a plan to monitor and manage 

weeds as specified in Interior’s 10(a) and 10(j) recommendations and describe the membership to be 

included on the [noxious weed] advisory board. Interior recommends that the plan include an agency 

review of all pesticide application procedures. 

Response: The Staff Alternative incorporates Interior’s recommendations, with the exception of a 

project-wide inventory within 3 years after issuance of any new project license. The Staff Alternative 

supports the weed board membership as proposed by Idaho Power, i.e., including agencies, landowners, 

land managers, and other interested individuals and organizations, as well as Idaho Power representatives. 

Idaho Power’s HCRMP (Johnson, 2003) specifies pesticide application procedures consistent with federal 

and state law.

Roads, Transmission Lines, and ROWs 

Comment TR-21: IDFG comments that an O&M plan for transmission line 945 should include 

monitoring of electrocution and collision mortality and that O&M activities should be scheduled to 

minimize disturbance to wintering mule deer. 

Response: As discussed in section 5.2.3.3, the Staff Alternative includes monitoring of electrocution and 

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collision mortality and recommends scheduling O&M to minimize disturbance to wintering mule deer, as 

proposed by Idaho Power.

Comment TR-22: ODFW supports development and implementation of a Transmission Line Operation 

and Maintenance Plan, and recommends that it be incorporated into the IWHP and WMMP. 

Response: Staff has elected to leave the transmission line operation and maintenance plan as a standalone plan, because management would focus on a specific set of concerns, within a specific area, within 

a specific ownership. 

Mule Deer 

Comment TR-23: In discussing mule deer winter range, ODFW comments that Brownlee reservoir does 

not increase mortality on 86,408 acres of crucial winter range; rather it is responsible for 10 to 30 percent 

of mule deer mortality. 

Response: Idaho Power’s studies indicate that Brownlee reservoir reduces habitat capability on crucial 

winter range and that it contributes directly and indirectly to winter mortality (Edelmann, 2003; Edelmann 

et al., 2003b). Idaho Power estimated that direct and indirect effects comprised 10 percent of annual 

winter mortality, and an additional 9 percent during harsh winters, based on historic data provided by 

ODFW.

Comment TR-24: Idaho Power notes agreement with the conclusion that the risk of mule deer mortality 

due to reservoir icing is small, but comments that the discussion of mule deer migration and reservoir 

icing is out of context with study results. Idaho Power clarifies that Ryel et al. (2003) found that ice is 

most likely to form in the pool associated with the Powder River arm, not in the arm itself, where mule 

deer cross, and that the timing of migrations only marginally overlaps with the period when ice most 

likely occurs. 

Response: We continue to conclude that the risk of mule deer mortality due to icing is small, and have 

revised text that indicated otherwise. However, we note that Ryel et al.’s analysis (which does not 

distinguish between the Powder River arm and the Powder River pool) predicted that ice formation is 

most likely to occur in late December, with break-up and thawing from late February through early April. 

Edelmann et al.’s study of mule deer movements (2003a) found that 25 percent of the crossings occurred 

during the winter (January and February) and 25 percent occurred during green-up (late March–April). 

For this reason, many deer could encounter ice while attempting to cross the Powder River arm.

Comment TR-25: In discussing mule deer mortalities related to wintertime reservoir crossings, ODFW 

comments that annual mortality attributable to project reservoirs in harsh winters has not been quantified. 

However, ODFW biologists estimate that 30 percent mortality could occur in the severest winters. 

ODFW requests clarification on the specific reason for not including a study of the effects of a harsh 

winter on mule deer in the Staff Alternative. ODFW reiterates that FERC staff needs to evaluate the 

effect of two or more hard winters in a row on the ability of deer populations to recover. 

Response: Edelmann et al. (2003a) used survey data provided by ODFW to evaluate the likely effects of 

harsh winters on mule deer populations in the project vicinity. We did not include an empirical study in 

the Staff Alternative because we concluded that modeling provided an adequate estimate of harsh-winter 

mortality. 

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Comment TR-26: ODFW states that it strongly disagrees with staff’s assumption that ODFW identified 

an area of project effects on mule deer that conflicts with the results of mule deer studies, and with staff’s 

conclusion that the studies showed that habitat capability is reduced only within a very narrow band 

above full pool at Brownlee reservoir. ODFW comments that staff erroneously assumed that mule deer 

studies were designed to identify a zone of effect; the studies were conducted to describe components of 

the winter ecology of mule deer and how various factors, including project reservoirs, might influence 

these components. The studies identified direct and indirect mortality caused by the project. The studies 

did not identify a zone of effect or acreage necessary to mitigate for reduced habitat capability. 

Response: We understand the objectives of the mule deer winter ecology study, and agree the purpose 

was not to identify a zone of effect or the acreage needed for mitigation. We maintain, however, that the 

results of the study are important in showing how and where deer interact with the project during the 

winter. The winter ecology study, together with other technical reports (Edelmann et al., 2003a; 

Christensen, 2003; Dumas et al., 2003; Edelmann et al., 2003), provided the basis for staff’s conclusions 

regarding project effects on mule deer, mule deer winter range, and an appropriate acreage of mitigation.

Comment TR-27: ODFW states that it does not identify elevation 3,200 feet as the zone of effect, rather 

as the upper extent of crucial mule deer winter range in the project area, based on concentration and 

distribution of deer, similar to Idaho Power. 

Response: We revised the text of section 5.2.5.4, Upland and Riparian Habitat Acquisition, to reflect 

that ODFW considers elevation 3,200 feet as the upper extent of crucial mule deer winter range. 

Comment TR-28: ODFW comments that FERC staff ignored crucial winter range delineated by wildlife 

experts (334,665 acres) and ODFW biologists (121,337 acres). ODFW estimates that 23,054 acres (0.19 

x 121,337 acres of crucial winter range) is necessary to mitigate for direct and indirect mortality caused 

by project operations and reservoirs. ODFW recommends the Staff Alternative include acquisition and 

enhancement of 1,452 acres of riparian habitat and 21,602 acres of uplands to mitigate for mule deer 

mortality associated with project operations. 

Response: Staff did not ignore crucial winter range delineations, but as described above, relied on the 

results of the surveys that evaluated how deer used winter range, and where they concentrated. We note 

that Idaho Power’s proposed land acquisitions are all located within or adjacent to areas mapped as 

crucial deer winter range (Christenson, 2003) or a major migration route, and that the total acreage is 

about the same as ODFW recommends. Although it contains less riparian habitat, Edelmann (2003) 

found that wintering mule deer numbers were concentrated in areas with high-quality forbs, low grasses, 

bitterbrush, and sagebrush on south and southwest-facing slopes. This finding suggests that grasslands 

and shrublands serve as important habitat during the winter.

Game Species and Plants of Cultural Importance 

Comment TR-29: Interior recommends that the discussion of plants of importance to Native Americans 

be moved to a more appropriate or separate section of the NEPA document (rather than appearing in 

section 3.7.1.1, Transmission Line Right-of-Way). 

Response: We added a heading (3.7.1.3, Plants of Cultural Importance) to separate the discussion of 

ethnobotanical resources from the transmission line right-of-way discussion. 

Comment TR-30: The Shoshone-Bannock Tribes comment that the description of the transmission 

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right-of-way section briefly describes native plant use by tribes, but provides no additional analysis. The 

Shoshone-Bannock Tribes comment that adding more specific Tribal ethnographic information would be 

useful in determining what management practices should occur. The Shoshone-Bannock Tribes 

recommend that staff describe wildlife species and plants of cultural importance in more detail in the 

affected environment section, and continue with the discussion in the environmental effects section. The 

Shoshone-Bannock Tribes note that the discussion of wildlife species of cultural importance refers to the 

“Big Game Winter Range and Migration Routes” discussion, but the referenced section includes no 

discussion of cultural importance. 

Response: We added a heading (3.7.1.3, Plants of Cultural Importance) to separate the description of 

plants of cultural importance from the transmission line right-of-way discussion, and added a section 

(3.7.1.6, Special Status Wildlife Species) describing game species of cultural importance. We also revised 

the headings in section 3.7.2.1, Effects of Project Operations on Terrestrial Resources, to discuss project 

effects on plants and game animals of cultural importance. We agree that adding more specific 

ethnographic information could improve the analysis, but the record contains very limited information. 

Comment TR-31: The Shoshone-Bannock Tribes comment that the draft EIS provides no rationale or 

justification to explain why some plants and animals were identified as having cultural importance, or if 

these species adequately represent resources of importance to the Shoshone-Bannock Tribes. The 

Shoshone-Bannock Tribes disagree with analyses provided by Reed-Jerofke (1999) and Whipple (2001), 

which reflect oral history studies conducted with the Warm Springs, Burns Paiute, and Umatilla tribes, 

not the Shoshone-Bannock Tribes. 

Response: As mentioned above, there is little information in the record regarding important cultural 

plant and animal species. We used the available information. 

Land Acquisition 

Comment TR-32: Idaho Power clarifies that it purchased 10,212 acres associated with the Daly Creek 

Ranch, not 10,695 acres. Idaho Power notes that since release of the draft EIS, it has reached an 

agreement to purchase 6,115 acres associated with the Sturgill Creek property. 

Response: We revised the text of sections 3.7.2.5, Upland and Riparian Habitat Acquisition, and 5.2.5.4, 

Upland and Riparian Habitat Acquisition, to show this information. 

Comment TR-33: ODFW comments that staff should clarify how the purchase of Daly Creek Ranch 

(10,695 acres) and the Cottonwood Creek property (1,971 acres) total 24,884 acres (1,004 acres riparian 

and 23,564 acres upland). Interior comments that acreages of upland and riparian habitat acquisition 

discussed in the draft EIS may be in error. Interior states that Interior and the states agreed to the general 

amount of mitigation land potentially available in four ranch properties, totaling a minimum of 23,500 

acres. 

Response: The total acreage refers to all the parcels described in the paragraph, including those targeted 

for purchase and those already purchased. The acreage of each parcel, and the total, has been updated in 

the final EIS to reflect information provided by Idaho Power in its comments on the draft EIS. 

Comment TR-34: Idaho Power comments that enhancement of 13 acres of riparian habitat downstream 

of Hells Canyon dam would have marginal benefits, because habitat in this reach is at or near its full 

potential. Idaho Power states that incorporating the 13 acres into the larger habitat acquisition plan would 

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match priorities to purchase and manage large habitat blocks associated with key wildlife species and 

habitats, including mountain quail. 

Response: We modified the Staff Alternative to include acquisition of this acreage as part of the broader 

acquisition “package.” 

Comment TR-35: Idaho Power comments that FERC contemplates the use of grazing allotments as 

mitigation, but provides no details on how this might be done. If grazing allotments are to be used as 

mitigation, Idaho Power recommends that appropriate credit for management and improvement be 

granted through a reduction in the amount of acquisition acres required, and that such allotments not be 

included within the project boundary. 

Response: We added text to section 3.7.2.7, Wildlife Management on Idaho Power Lands, to clarify our 

conclusions regarding cooperative management of grazing allotments. 

Comment TR-36: IDFG comments that 1:1 habitat replacement is sufficient if on-site, in-kind 

mitigation parcels (i.e., those with habitat values similar to uplands and riparian areas affected by project 

operation) can be purchased and managed, but a 2:1 ratio should be applied if such lands are not 

available. At a minimum, IDFG recommends that the license allow for development of alternative 

replacement ratios. 

Response: We added text to section 5.2.5.4, Upland and Riparian Habitat Acquisition, discussing a 

contingency for additional acquisitions that may be needed to meet the acreage target if the “first tier” 

parcels cannot be acquired within 5 years of license issuance. 

Comment TR-37: ODFW comments that the Staff Alternative for land acquisition is not acceptable 

because it assumes sufficient habitat value is provided because parcels targeted for acquisition are near 

project reservoirs, and that a 1:1 ratio is sufficient mitigation for riparian and wetland habitat. ODFW 

reiterates that the Staff Alternative is not in compliance with ODFW’s Fish and Wildlife Habitat 

Mitigation Policy or ODSL rules for wetland mitigation. ODFW states that it would consider other 

measures such as operational changes to decrease mule deer mortality, but no other measures have been 

proposed by FERC or Idaho Power. 

Response: The Staff Alternative includes Idaho Power’s proposed land acquisitions not only because the 

parcels are located near project reservoirs, but also because they meet each of the other criteria identified 

by the TRWG. The Staff Alternative calls not only for land acquisition, but also for implementation of 

measures to improve habitat values. To further address concerns about adequate mitigation, we added a 

contingency plan to the Staff Alternative, recommending mitigation ratios higher than 1:1 if targeted 

parcels cannot be acquired within a reasonable amount of time following issuance of any new license. 

In preparing the draft EIS, we considered one operational scenario (Brownlee reservoir held at minimum 

pool, Oxbow and Hells Canyon reservoirs held at full pool) that could benefit mule deer by allowing 

establishment, over time, of about 5,000 acres of low-elevation winter range around Brownlee reservoir. 

It could provide some benefits to fish, as well, by allowing more rapid cooling in the fall for adult fall 

Chinook salmon, reducing stress and leading to earlier spawning, emergence and outmigration, and more 

rapid warming in the spring that could enhance growth of juvenile fall Chinook salmon. However, this 

scenario would prevent Idaho Power from controlling flows during fall Chinook salmon spawning and 

incubation and providing flow augmentation to improve survival of out-migrating juveniles, and would 

result in warmer water temperatures during the summer, with adverse effects on rearing juvenile fall 

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Chinook salmon. Implementation of this scenario also would have substantial adverse effects on the 

warmwater fishery and recreational access to Brownlee reservoir, eliminate flood control capability, and 

increase the risk of downstream transport of noxious weeds. Overall, staff concluded that the potential 

negative effects would outweigh the benefits. No agencies recommended implementation of such a flow 

scenario, and for this reason, we did not carry it forward for analysis in the draft or final EIS. 

We recognize that the Staff Alternative may not be consistent with state policies regarding the acreage of 

mitigation lands. However, the FPA does not require mitigation for all project effects. We conclude that 

the combination of measures included in the Staff Alternative will provide an appropriate level of 

mitigation for mule deer and other terrestrial resources.

Comment TR-38: ODFW comments that draft EIS table 64 mischaracterizes the minimum acreage 

proposed or recommended by ODFW for acquisition. ODFW proposes acquisition and enhancement of 

1,110 acres (275 acres riparian and 835 acres upland) to mitigate for decreased habitat capability in the 

fluctuation zone of all three reservoirs. ODFW proposes acquisition and enhancement of 23,054 acres to 

mitigate for mule deer mortality caused by presence and operation of the project. Minimum acreage 

assumes that acquisition and enhancement will occur in-kind and in-proximity, or within the 2,100-foot 

elevation contour. 

Response: We revised draft EIS table 64 (final EIS table 69) to reflect our understanding of the basis for 

ODFW’s recommendations. 

Comment TR-39: ODFW comments that it disagrees with staff’s recommended land acquisition 

proposal. ODFW recommends acquisition and enhancement of 35,739 acres (30,784 acres upland and 

4,955 acres riparian), and comments that additional mitigation will be needed to provide for impacts to 

wetland habitat once these are identified by Idaho Power and FERC. If enhancement occurs outside the 

2,100-foot elevation contour, ODFW recommends mitigation at a minimum ratio of 1:1 for upland and 

3:1 for riparian habitat. If enhancement or creation of habitat occurs out-of-kind and off-proximity, 

ODFW recommends that upland and riparian habitat be mitigated at a 3:1 and 5:1 ratio, respectively. To 

mitigate for impacts to wetland habitat, once quantified, ODFW recommends a 3:1 ratio for enhancement. 

Response: ODFW’s recommended acquisition of 35,739 acres includes 11,157 acres to mitigate for 

inundation, an effect of original project construction, while 24,582 acres would address current project 

effects. The Staff Alternative recommends acquisition and management of 23,582 acres to mitigate for 

current project effects. In section 5.2.5.4, Upland and Riparian Habitat Acquisition, we discuss the need 

for acquisition of additional (i.e., beyond the acreage included in Idaho Power’s proposal in response to 

AIR TR-1) riparian habitat to mitigate for ongoing project effects on shore and bottomland wetland, 

predicted effects on scrub-shrub wetland as a result of a new flow regime, and erosion likely to occur 

during any new license period. In this section, we added text describing the staff’s recommendation for 

including a contingency plan in the Staff Alternative. The contingency plan would call for mitigation 

ratios higher than 1:1, if there should be a delay of more than 5 years in acquiring the remaining target 

parcels, or if “first tier” parcels cannot be acquired. 

As discussed in sections 3.7.2.5, Upland and Riparian Habitat Acquisition, and 5.2.5.4, Upland and 

Riparian Habitat Acquisition, we are not otherwise recommending higher mitigation ratios, because 

parcels to be acquired are located as close as possible to the project; adjoin Idaho Power’s existing 

ownership and/or large blocks of wildlife habitat on public lands; provide substantial acreage, rather than 

small fragments; and support existing and potential high-priority habitats and species. All four parcels 

provide mule deer winter range, with most of the acreage located within crucial winter range. 

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Comment TR-40: ODFW estimates that 615 acres (58 acres of riparian habitat and 576 acres of upland) 

would be required to mitigate for impacts to low-elevation winter range that is unavailable in the reservoir 

fluctuation zone of all three reservoirs. ODFW estimates that an additional 217 acres of riparian habitat 

and 259 acres of upland habitat is necessary to mitigate for decreased habitat capability in the annually 

inundated reservoir zones. 

Response: The Staff Alternative includes mitigation for low-elevation habitat that is precluded from 

establishing in all three reservoirs. This acreage includes 388 acres of riparian habitat and 5,761 acres of 

upland habitat. The Staff Alternative does not apply a habitat coefficient reflecting reduced habitat 

capability to Oxbow or Hells Canyon reservoirs, because most mule deer interactions with the project 

occur at Brownlee reservoir. In keeping with the Commission’s policy that sets continuing operations 

under the current license as the baseline, the Staff Alternative does not address the effects of original 

project construction.

Comment TR-41: ODFW states that it disagrees with staff’s conclusions that expected improvements in 

habitat quality over time, together with the physical location of the parcels and the fact that they are 

contiguous to other lands that are being or will be managed for wildlife, should result in net benefits, 

because there are no guarantees that improvements will occur to completely mitigate for lost habitat 

values. 

Response: Staff recommends that Idaho Power implement the IWHP and WMMP, as described in Idaho 

Power’s response to AIR TR-1. The WMMP would identify overall goals and objectives, best 

management practices, protection and enhancement priorities, and mechanisms for adaptive management, 

reporting, consultation, and program review and updating. For each WMA and SMA, Idaho Power would 

evaluate baseline conditions, identify desired future conditions, implement habitat treatments and monitor 

their effectiveness, and report progress to an interdisciplinary group (similar to the TRWG) and to FERC. 

We do not know of any way to guarantee that improvements would completely mitigate for lost habitat 

values, but conclude that Idaho Power’s approach provides a reasonable assurance of success. If 

monitoring shows that goals are not being met, additional measures or lands may be required. We 

presume ODFW would participate in development of the site-specific plans, and would have 

opportunities for input throughout any new license period. 

Comment TR-42: ODFW describes the key components of the TRWG discussions that occurred in 2001 

as placing a priority on in-kind replacement to recreate similar structure and function. ODFW states that 

replacement of habitat values should be strictly tied to losses and impacts to habitat types, versus a simple 

acre for acre approach as recommended by FERC staff. ODFW states that the mitigation site should 

replace or create the same habitat type as the one affected by the project or activity. 

Response: Staff does not recommend a simple acre-for-acre approach to mitigation, without regard for 

habitat types or values. The Staff Alternative is based on our understanding of the ranking process that 

Idaho Power and the TRWG used to identify suitable target parcels for acquisition. Idaho Power and the 

TRWG assigned the highest priorities for acquisition to large, contiguous blocks of land near the project 

that would provide habitat for high-value species, including threatened, endangered, and sensitive species; 

waterfowl; big game; upland game birds; aquatic furbearers,; amphibians; and neotropical migrants. The 

target parcels ranked highest, and staff concludes that their acquisition and management would maximize 

the potential for mitigation lands to meet the resource needs identified by the TRWG.

Comment TR-43: ODFW recommends that the final EIS should address alternatives that the Licensee 

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will need to implement if identified parcels are not available, parcels providing out-of-kind or out-ofproximity mitigation are acquired, or mitigation measures are not successful at recreating lost habitat 

types. Interior also recommends that the NEPA document include a relicensing alternative that describes 

how this terrestrial habitat mitigation will be achieved, what the funding needs will be, and what the 

course of action will be in meeting agency resource goals if all of the land acquisition parcels identified 

by the TRWG cannot be purchased within 10 years (at the most) from license issuance. 

Response: We revised text in section 5.2.5.4, Upland and Riparian Habitat Acquisition, to clarify the 

Staff Alternative with respect to these issues. 

Comment TR-44: ODFW recommends the use of HEP to establish baseline conditions prior to initiation 

of habitat enhancement projects, and in long-term monitoring. The Shoshone-Bannock Tribes comment 

that FERC failed to use proper procedures and methods for determining suitable habitat for mitigation, 

and also recommends that FERC use HEP to determine suitable habitat. The Shoshone-Paiute Tribes 

reiterate their earlier recommendation (TR-3) for use of HEP to determine suitable habitat units for 

mitigation. 

Response: We acknowledge that a systematic monitoring program will be needed, both to establish 

baseline conditions and evaluate progress toward desired future conditions that will be identified for each 

parcel. The Staff Alternative includes Idaho Power’s proposal, as described in its response to AIR TR-1, 

which outlines such a monitoring plan and identifies specific elements that would be included. Idaho 

Power would develop the monitoring plan in consultation with a TRWG. The group could elect to use 

HEP, but we do not recommend this approach because focused monitoring techniques would be needed to 

measure the effects of various habitat treatments. HEP is often valuable in describing large-scale changes 

in habitat quantity and quality, but is less useful in providing site-specific information for on-the-ground 

adaptive management.

Comment TR-45: Interior states that the draft EIS does not adequately describe project effects on 

terrestrial resources, due to the lack of a quantifiable habitat evaluation. Interior had earlier suggested 

that HEP be used to develop a terrestrial mitigation plan and establish the environmental baseline for 

Idaho Power lands and could be used to monitor progress in restoring these lands to their full potential. 

Interior states that if Idaho Power has collected data on present habitat status for lands it has or is 

intending to acquire, the data should be displayed in the NEPA document. 

Response: We concluded that a HEP was not necessary to describe project effects on terrestrial resources 

because the information contained in the technical study reports was adequate to both quantify project 

effects on upland and riparian habitat and identify the species most affected by project operation. We also 

concluded that the study reports, together with the parcel ranking and selection process described in Idaho 

Power’s response to AIR TR-1, provide a strong foundation for focusing mitigation efforts on acquiring 

and managing land that would help to offset project effects. Data regarding habitat conditions, wildlife 

use, and special status species occurrences is provided in the license application, technical study reports, 

and response to AIR TR-1 for all of the land in Idaho Power’s ownership and three of the four parcels 

proposed for acquisition, although part of the fourth parcel (Daly Creek) is outside the rim-to-rim study 

area. 

Comment TR-46: ODFW comments that it will consider lands currently owned by Idaho Power as 

mitigation properties based on the demonstrated benefits of these properties to mitigate for terrestrial 

resources affected by the project. This includes projected increases in habitat units and function expected 

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with active management. 

Response: The value of these parcels as mitigation properties is described in Idaho Power’s response to 

AIR TR-1. 

Comment TR-47: ODFW states that management planning should establish desired future conditions 

and include protocols, performance expectations, methods, and a reporting schedule for monitoring 

effectiveness through the new license period. ODFW recommends that Idaho Power evaluate 

effectiveness of habitat acquisition and management by funding assessments of habitat quantity and 

quality using HEP or another appropriate methodology. 

Response: We included in the Staff Alternative the approach Idaho Power outlined in its response to 

AIR TR-1 regarding development and implementation of the IWHP, WMMP, site-specific management 

plans for WMAs and SMAs, and a long-term monitoring plan.

Comment TR-48: The Shoshone-Bannock Tribes state it is unacceptable that any lands set aside for 

wildlife be held in fee title by Idaho Power. They also state that the draft EIS should have considered 

alternative methods of land ownership to properly protect the tribes’ treaty rights and traditional use 

rights, including transferring title of lands acquired for mitigation to the United States to hold in trust on 

behalf of the tribes, or transferring title of the acquired lands to the tribes. 

Response: If the Commission determines that the parcels proposed for acquisition are necessary to the 

operation of the project (i.e., necessary to mitigate for project effects), the Commission would likely 

require that the lands remain under Idaho Power’s control so that the Commission retains authority over 

Idaho Power’s management to achieve expected benefits. 

Comment TR-49: The Shoshone-Paiute Tribes reiterate terrestrial conditions submitted in response to 

the REA Notice, including measures for acquisition of 10,000 acres adjacent to or near the Duck Valley 

Indian Reservation to be held in fee title by the Shoshone-Paiute Tribes (TR-1). 

Response: Project operations do not affect terrestrial resources in the vicinity of the Duck Valley Indian 

Reservation. For this reason, acquisition and management of lands near the reservation would not 

mitigate project effects on wildlife or wildlife habitat.

Comment TR-50: Interior comments that the parcels targeted for acquisition are not directly adjacent to 

the project, lie at higher elevations, and have lower habitat values than lands inundated by the project. 

Interior states that the NEPA document should address this issue by recognizing replacement ratios 

appropriate to habitat type and condition to provide reasonable mitigation acreages. Interior reiterates the 

recommendation that Idaho Power acquire a total of 41,747 acres. 

Response: The proposed parcels are not intended to mitigate for the habitat inundated by the project; 

they are intended to mitigate for ongoing effects. 

Comment TR-51: The Forest Service recommends that staff include condition no. 6 (Land Acquisition 

and Management Plan), without modification or limitation, in the Proposed Action in the final EIS. The 

Forest Service comments that the Staff Alternative excludes several elements of condition no. 6 (e.g., 

mitigation for the loss of 56.3 acres of riparian habitat in the scour zone along the Snake River 

downstream of Hells Canyon dam; a range of alternatives to assessing and controlling shoreline erosion) 

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that are needed to provide mitigation for project effects. The Forest Service comments further that a 60-

day review and comment period prior to Idaho Power’s filing of a Land Acquisition and Management 

Plan with the Commission for approval is needed to ensure adequate time for Forest Service review of 

activities that would occur on National Forest System lands. 

Response: We revised the text in section 5.2.5.4, Upland and Riparian Habitat Acquisition, to explain 

that the Staff Alternative now includes a recommendation for Idaho Power to add 49 acres of riparian 

habitat to its mitigation package to address project effects on sandbar willow in shore and bottomland 

wetland along the Snake River downstream of Hells Canyon dam. It is our understanding that the Forest 

Service recommendation for mitigation of 7.3 acres of riparian habitat is based on the assumption that 

Idaho Power’s proposed flow regime would be implemented. The Staff Alternative assumes the staffrecommended flow regime would be implemented, which would reduce riparian habitat by about 13.2 

acres. For this reason, the Staff Alternative recommends Idaho Power acquire, protect, and enhance a 

total of 62.2 acres, rather than 56.3 acres, to address project effects along the Snake River downstream of 

Hells Canyon dam. The Staff Alternative expands on FS-6 in terms of recommendations for assessing 

and controlling shoreline erosion through any new license period.

Cooperative Wildlife Projects 

Comment TR-52: IDFG comments that with adequate funding, Gold Island can provide an opportunity 

to mitigate for waterfowl habitat lost through project construction and operation. IDFG further comments 

that funding would be consistent with FERC’s policy on off-site mitigation. 

ODFW comments that inclusion of Patch and Gold islands within the Staff Alternative would provide 

suitable in-kind, off-site mitigation for impacts to an estimated 275 acres (based on a recent GIS analysis 

by BLM) of island habitat that is affected by reservoir fluctuations and inundation. ODFW concurs with 

staff’s recommended level of annual funding, but also recommends purchase of equipment and machinery 

at an estimated cost of $298,800. ODFW comments further that the islands should be included within the 

project boundary, because they were purchased as mitigation for original project impacts. ODFW 

suggests that an alternative would be to hold Brownlee reservoir at a lower elevation and enhance island 

habitat that would be exposed within the reservoir fluctuation zone. 

Response: We revised the Staff Alternative to include Patch and Gold islands as two of the four islands 

where Idaho Power would implement cooperative management measures.

Comment TR-53: Idaho Power comments that its participation in habitat enhancement on Porter and 

Hoffman islands should be limited to provision of funding. Idaho Power notes that part of the annual 

funding it is proposing could be provided as a lump-sum payment early in the license term for the 

purchase of equipment, with a corresponding reduction in the annual contribution for the balance of the 

license term. 

Response: We revised the Staff Alternative to include Patch and Gold islands, as well as Porter and 

Hoffman islands, as sites where Idaho Power would implement cooperative management measures. We 

also revised the Staff Alternative to recommend that Idaho Power provide the initial funding for 

equipment that will be needed to initiate and maintain enhancement projects, as well as $26,000 annually 

for implementation. 

Comment TR-54: IDFG agrees that a consultation requirement should be included in the measure 

regarding enhancement of habitat and reintroduction of mountain quail. 

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Response: We note IDFG’s support for this aspect of the Staff Alternative. 

Comment TR-55: ODFW states that it supports Idaho Power’s contribution of $100,000 for the 

cooperative reintroduction of mountain quail and enhancement of low elevation riparian habitat, but 

believes funding should primarily be used for capture and translocation efforts. ODFW recommends 

acquiring birds from Douglas County, Oregon and putting them in Hells Canyon in the best habitat 

available, and monitoring movements, habitat use, and incidence and factors of mortality. Furthermore, 

ODFW recommends that identification of suitable parcels for enhancement and reintroduction should be 

tied to the Land Acquisition and Management Program. 

Response: We revised the Staff Alternative to recommend that Idaho Power cooperate with the resource 

management agencies to implement specific projects or specific elements of projects, rather than 

contributing funding to state programs. We agree it would be reasonable to link enhancement and/or 

reintroduction projects to lands Idaho Power owns or would acquire for wildlife mitigation, or to other 

resource enhancement measures (e.g., tributary enhancement for resident salmonids). 

Comment TR-56: Idaho Power comments that mountain quail reintroduction objectives are the 

responsibility of the states, and that Idaho Power’s participation in any reintroduction efforts should be 

limited to provision of funding. 

Response: As mentioned above, we revised the Staff Alternative to recommend that Idaho Power 

cooperate with the resource management agencies to implement specific projects or specific elements of 

projects. This approach is consistent with Idaho Power’s initial proposal to provide funding, equipment, 

personnel, logistical support, and expertise to projects that are initiated by the resource management 

agencies. 

Comment TR-57: The Forest Service recommends that staff include condition no. 10 (Mountain Quail 

Habitat Enhancement) without modification or limitation in the Proposed Action in the final EIS. The 

condition specifies that Idaho Power should implement the enhancement program as proposed. 

Response: As described above, we revised our recommendations concerning mountain quail to more 

clearly define how Idaho Power should participate. We anticipate that this approach would meet the 

intent of the Forest Service modified 4(e) condition. We also revised the Staff Alternative to recommend 

that Idaho Power acquire 13.2 acres of riparian habitat as part of its larger wildlife mitigation package, 

rather than enhancing habitat along the Snake River downstream of Hells Canyon dam.

Wildlife Management on Idaho Power Lands 

Comment TR-58: The Forest Service recommends that staff include condition no. 5 (Wildlife Mitigation 

and Management Plan) without modification or limitation in the Proposed Action in the final EIS. The 

Forest Service comments that project impacts extend beyond the project boundary, and that restricting the 

condition to apply only to project lands is inconsistent with other staff recommendations. The Forest 

Service comments further that a 60-day review and comment period prior to Idaho Power’s filing of the 

IWMP and WMMP with the Commission for approval is needed to ensure adequate time for Forest 

Service review of actions that would be implemented on National Forest System lands. 

Response: We revised section 5.2.5.4, Upland and Riparian Habitat Acquisition, to reflect that the Staff 

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Alternative accepts FS-5.

Comment TR-59: IDFG agrees that the WMMP should include an Information and Education Program 

to minimize the risk of wildlife disturbance and O&M should be scheduled to minimize disturbance on 

deer winter range. IDFG comments that Idaho Power should consult with IDFG in development of the 

plans. 

Response: We note ODFW’s support for this aspect of the Staff Alternative. 

Comment TR-60: ODFW supports establishment of a terrestrial resource work group to assist in 

developing, finalizing, and implementing the IWHP, WMMP, and management plans. 

Response: In the Staff Alternative, we recommend establishment of an IWHP group similar to the 

TRWG.

Comment TR-61: The Shoshone-Paiute Tribes reiterate terrestrial conditions submitted in response to 

the REA Notice, including establishment of a Terrestrial Resource Task Force, with Idaho Power to fund 

participation of the Shoshone-Paiute Tribes (TR-2) 

Response: The Staff Alternative includes establishment of an IWHP Work Group, with roles and 

responsibilities similar to the TRWG. As described in section 5.2.6.5, Tribal Participation, Education, 

and Training, the Staff Alternative also includes funding for tribal participation in the IWHP Work 

Group.

Comment TR-62: ODFW notes that management plans would need to be consistent with agency 

policies, rules, regulations, goals and objectives, and must identify habitat enhancement and public access 

for fishing and hunting as important objectives. 

Response: Idaho Power would be subject to the same federal, state, and county laws and regulations 

under which it currently operates. Habitat protection and enhancement are the primary purpose of the 

Wildlife Mitigation Plan, and we anticipate that ODFW would participate with the TRWG to evaluate 

fishing and hunting access on a site-by-site basis. 

Comment TR-63: The Shoshone-Bannock Tribes recommend that all interested tribes be appointed to 

serve on the terrestrial work group to ensure protective management for native plant resources. 

Response: The Staff Alternative includes establishment of an IWHP Work Group, with roles and 

responsibilities similar to the TRWG. As described in section 5.2.6.5, the Staff Alternative also includes 

funding for tribal participation in the IWHP Work Group.

B11. THREATENED AND ENDANGERED SPECIES 

Comment TES-1: NMFS agrees that the magnitude of flow and water quality changes resulting from 

operation of the project and other Idaho Power Snake River basin projects is small. However, NMFS 

states that the information provided in this section is not adequate to initiate consultation on the Columbia 

River basin species. NMFS notes that increased flows of a few thousand cfs may be characterized as a 

“relatively small proportion” of overall flows at a specific location. However, NMFS states that FERC 

must consider in its analysis of cumulative effects that similar measures to those being recommended at 

Brownlee reservoir have been implemented at federal hydroelectric and water storage projects for many 

years. Together, these measures have had substantial effects on flows and temperatures in the Snake and 

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Columbia rivers. 

Response: To illustrate the effects of proposed operations on flows downstream from the project, we 

added three figures (112, 113, and 114) in final EIS section 3.8.2.5, Other Columbia River Basin Salmon 

and Steelhead ESUs. The figures show, for 3 years that represent a range of hydrologic conditions, 

outflows from the project under Idaho Power’s proposed operations and flows that would occur under 

run-of-river operations with Brownlee reservoir held at minimum operating pool. We also describe the 

additional effect that providing 237 kaf of flow augmentation water, which is part of the Staff Alternative, 

would have on outflows from Hells Canyon dam. Our understanding is that the most accurate method for 

determining the effects of these changes in outflows and water temperatures on migration survival 

through the lower Snake and Columbia rivers would be for NMFS to use the SIMPAS model that they 

used in preparing the upper Snake Biological Opinion. We expect that NMFS would conduct this 

analysis to assess the effects of flow changes caused by the project on the survival rates of listed ESUs 

during their migration through the Lower Columbia River. 

Comment TES-2: NMFS states that it disagrees with FERC’s determination that the project is unlikely 

to adversely affect nine species of salmon and steelhead migrating in the lower Columbia River, estuary, 

and nearshore ocean environment. NMFS states that the biological opinion on BOR’s Snake River basin 

projects is a good source of information for staff’s analysis. NMFS notes that in its September 7, 2006, 

letter responding to FERC’s request for formal ESA consultation, it indicated that because the project has 

a substantial effect on streamflows in the Snake and Columbia rivers that the species list for consultation 

would include all listed species that use the Snake and Columbia River migratory corridors. NMFS 

comments that the draft EIS should discuss the effects of project operations on every ESA-listed 

anadromous fish species in the Columbia and Snake River basins. NMFS states that this information will 

be necessary for ESA consultation. 

Response: As noted above, we added figures 112, 113, and 114 in final EIS section 3.8.2.5, Other 

Columbia River Basin Salmon and Steelhead ESUs, to illustrate the effects of Idaho Power’s proposed 

operations on flows downstream of the project and in the lower Columbia River. These data indicate that 

flood control operations at Brownlee dam may reduce stream flows by about 10,000 to 15,000 cfs during 

the spring freshet in May and June when flows at McNary dam average between 250,000 and 300,000 cfs. 

When outflows from Brownlee are managed to hold flows steady during the fall Chinook spawning 

season (generally in November and December), outflows may be reduced by about 7,000 to 8,000 cfs 

when flows at McNary dam average between 120,000 and 150,000 cfs. While we maintain that these 

changes in flow are minor, flood control operations at Brownlee act in concert with flood control 

operations at other reservoirs in the basin that contribute to a substantive cumulative reduction in the 

spring flow freshet. As a result, we revised our determination for the nine Columbia River and 

Willamette River ESUs from not likely to adversely affect to likely to adversely affect. We also added 

text discussing how these changes in flow may affect the nine Columbia and Willamette River ESUs. 

Comment TES-3: NMFS states that in its scoping comments, it recommended that FERC model inflow 

= outflow at minimum pool (Brownlee reservoir) to better assess the continuing effects of the project on 

important water quality parameters and flows. NMFS states that this analysis would facilitate identifying 

the proposed project’s effects on the critical habitat of ESA-listed salmon and steelhead. NMFS further 

states that the draft EIS does not adequately portray the environmental baseline (nor, by extension, the 

continuing effects of the project) for the purpose of ESA consultation. NMFS recommends that FERC 

reevaluate the environmental baseline as requested by NMFS to comply with ESA. 

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Response: Scenario 5, which we required Idaho Power to model in AIR OP-1, matches the scenario that 

NMFS describes. We did not specifically evaluate NMFS’s recommended alternative in the draft EIS 

because we concluded that other scenarios presented the most meaningful range of alternatives. We note 

that the full modeling results for Scenario 5 are available in Idaho Power’s February 3, 2005, filing, which 

is available through the Commission’s website. The three figures (112, 113, and 114) we added to final 

EIS section 3.8.2.5, Other Columbia River Basin Salmon and Steelhead ESUs, illustrate the effects of 

Idaho Power’s proposed operations on flows downstream of the project and in the lower Columbia River. 

We evaluate the effects of the project on water quality parameters in sections 3.5, Water Quality, and 3.6, 

Aquatic Resources, and we maintain that any direct effects of the project on TDG, temperature, or DO 

likely equilibrate over the 247.6 river miles between Hells Canyon dam and the Snake River’s confluence 

with the Columbia River. 

Comment TES-4: AR/IRU comment that many of the more significant project effects on fall Chinook 

salmon are omitted from the threatened and endangered species section summary of effects on fall 

Chinook, including: (1) low DO impacts on rearing fish; (2) ramping; (3) loss of spawning gravels and 

rearing beaches; (4) altered temperature regime; (5) TDG and ammonia exceedances; and (6) trace metals 

on spawning, incubation, emerging and rearing fall Chinook. AR/IRU state that this discussion also 

omits the adverse effect of using air blowers on TDG. 

Response: We modified the text of final EIS section 3.8.2, Environmental Effects, Threatened and 

Endangered Species, to address the effects identified by AR/IRU. 

Comment TES-5: NMFS states that the title of subsections of section 3.8.1 that pertain to salmon and 

steelhead, should start with the words “Current Status and Critical Habitat of.” NMFS recommends that 

the EIS clearly identify which hatchery programs are included as part of the listed species ESU or DPS. 

NMFS also states that it will update much of the status information in the draft recovery plan, which is 

expected to be released early in 2007 and will be filed with FERC so that it can be incorporated into the 

NEPA process. 

Response: We modified the introductory paragraph of final EIS section 3.8.1, Affected Environment

under Threatened and Endangered Species, to clarify that this section of the EIS describes the current 

status and critical habitat for salmon and steelhead species. We also modified the text to specify which 

hatchery programs are included as part of each listed ESU or DPS. 

Comment TES-6: The Umatilla Tribes and the Nez Perce Tribe state that heavy supplementation of 

Snake River fall Chinook from the Lyon's Ferry hatchery, as well as the release of large numbers of 

unmarked fall Chinook at acclimation sites upstream of Lower Granite dam, contributes to the increasing 

trend in total returns and in the number of unmarked spawners passing Lower Granite dam. 

Response: We modified the text of final EIS section 3.8.1.1, Fall Chinook Salmon, to clarify the likely 

influence of releases of unmarked fall Chinook salmon from acclimation sites on the returns of unmarked 

adult fall Chinook salmon. 

Comment TES-7: The Umatilla Tribes and the Nez Perce Tribe state that the draft EIS failed to offer a 

comprehensive and updated status of fall Chinook salmon or other anadromous fish stocks affected by the 

project, which is critical to the consideration of anadromous fish restoration. 

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Response: In the draft EIS, we summarized available information on population trends of wild and 

hatchery fish, as well as on stocking levels by species, in section 3.8.1, Affected Environment. We 

describe the factors that have contributed to the current status of the species in section 3.8.3, Cumulative 

Effects. 

Comment TES-8: IDFG comments that the number of spring/summer Chinook migrating past Lower 

Granite dam has fluctuated wildly over the last several years, and that the draft EIS incorrectly states that 

returns have been increasing since 2001. IDFG clarifies that returns have been decreasing since 2001 and 

naturally produced steelhead numbers also show a similar trend. 

Response: We modified the text of final EIS section 3.8.1, Affected Environment, Threatened and 

Endangered Species, accordingly. 

Comment TES-9: NMFS states that sockeye salmon occurred in the Payette River system. However, 

NMFS indicates that there is no information that documents whether these fish were part of the Snake 

River sockeye salmon ESU or whether they were a separate, now extinct, ESU. 

Response: We modified the text of final EIS section 3.8.1, Affected Environment, Threatened and 

Endangered Species, accordingly. 

Comment TES-10: Interior comments that the NEPA document should reflect the current run size of 

steelhead; according to Fish Passage Center data it is not quite two times as large as the average adult 

count at Lower Granite dam during the 1990s. Interior suggests that the NEPA document also display 

hatchery releases for summer steelhead over the last 20 years in the Snake River basin due to the full 

implementation of the Corps’ Lower Snake River Compensation Plan. Interior states that the Lower 

Snake River Compensation Plan hatcheries produce and release salmon, steelhead, and resident rainbow 

trout as part of the program's mitigation responsibility. The mitigation goals for the program include 

adult returns of 55,100 steelhead, 58,700 spring/summer Chinook salmon, and 18,300 fall Chinook 

salmon to the Snake River. Interior also states that to mitigate lost angler days for resident species, the 

Lower Snake River Compensation Plan program stocks about 86,000 pounds of rainbow trout into inland 

lakes and ponds close to the project area. 

Response: We revised the text of final EIS section 3.8.1, Affected Environment, Threatened and 

Endangered Species, to describe the potential effects of increased hatchery production on run sizes of 

steelhead, spring/Chinook salmon and fall Chinook salmon. 

Comment TES-11: Interior recommends that the NEPA document should include a complete discussion 

of the effects of turbine mortality on bull trout, as well as an assessment of likely population impacts. 

Interior also recommends that the NEPA document specifically evaluate the potential effects of flow 

fluctuations downstream of Hells Canyon dam, and of low DO and elevated water temperatures on bull 

trout habitat in the project area. 

Response: We added an assessment of the effects of low DO and elevated water temperatures on bull 

trout, and of the potential effects of entrainment mortality on bull trout, in final EIS section 3.6.1.4, 

Native Resident Salmonids. We evaluate the effects of flow fluctuations on bull trout in final EIS section 

3.6.2.1, Effects of Project Operations on Aquatic Resources.

Comment TES-12: NMFS observes that the draft EIS recognizes that the project alters the Snake 

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River’s thermal regime, interacts with nutrient rich inflows, reduces DO in project outflows, and blocks 

upstream and downstream passage of salmon and steelhead. NMFS states that all these effects will 

continue to some degree and should be identified as unavoidable adverse effects. 

Response: We modified the text of final EIS section 3.8.4, Unavoidable Adverse Effects, accordingly. 

Comment TES-13: Interior recommends that the Commission provide more information about bald 

eagles, including information about nesting, winter feeding and roosting areas, potential adverse and 

beneficial project effects, and conservation and impact minimization measures. Interior also recommends 

that the NEPA document contain specific requirements regarding recreation management to minimize 

disturbance and protection of mature trees that could be used for nesting, roosting or perching. 

Response: We added more information to final EIS section 3.8.2.12, Bald Eagle, to describe bald eagle 

nesting and potential adverse and beneficial project effects. Idaho Power indicates that no additional 

information about winter feeding or roosting areas is available (Idaho Power, 2007). In the Staff 

Alternative, we recommend that Idaho Power consult with Interior and other stakeholders to identify and 

implement measures to prevent or minimize the risk of disturbance to nesting birds that could result from 

recreation. We note that Idaho Power’s HCRMP does identify a number of specific measures that are 

intended to protect bald eagles and other sensitive species and habitats within Special Management Areas, 

Resource Protection Areas, and Resource Conservation areas, as well as common policies that protect 

important natural resources wherever they occur on Idaho Power lands. 

Comment TES-14: As part of the TESSMP, ODFW recommends Idaho Power fund habitat 

enhancements for bald eagles, because ODFW biologists believe that perching, nesting, and roosting 

habitat is probably limiting to bald eagles in Hells Canyon. 

Response: We have seen no evidence in the record to indicate that perching, nesting or roosting habitat 

is limiting to bald eagles in Hells Canyon. The HCRMP contains BMPs and land use designations that 

would protect riparian habitat. The record indicates that bald eagle use of the project area is increasing, 

consistent with population trends in the region and throughout the country. 

Comment TES-15: Idaho Power comments that the final EIS should discuss the entire period of record 

for which bald eagle productivity information was collected. 

Response: We added this information to section 3.8.1.14, Bald Eagle. 

Comment TES-16: Interior comments that there are discrepancies in survey methods between Idaho 

Power’s vegetation mapping and rare plant surveys and recommendations in the Silene Conservation 

Strategy. For this reason, Interior recommends the Commission assess potential project impacts on Silene 

spaldingii with the assumption that habitat exists in the project area, until adequate and timely surveys 

have been conducted. 

Response: We assume that Spalding’s catchfly could occur in the project area, as noted in the draft EIS. 

We do not know of any discrepancies between Idaho Power’s survey methodology and recommendations 

in the conservation strategy, although there may be some trade-offs in sightability of this species if 

surveys are conducted in September rather than in July or August. As noted in the Conservation Strategy, 

Spalding’s catchfly remains green late into the season (which makes it easier to see in surrounding strawDocument Accession #: 20070831-4002 Filed Date: 08/31/2007
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colored vegetation), while its stickiness allows wind-blown dust, plant fragments, and spider webs to 

adhere to it (which makes it harder to see). In any case, staff assumes this species could be present in 

project-area grasslands, and recommends surveys at sites where project-related construction or 

disturbance could cause adverse effects. If surveys confirm the species is present, the Staff Alternative 

recommends that Idaho Power consult with FWS and the other stakeholders to identify and implement 

any protective measures that may be needed. 

Comment TES-17: Interior comments that the Commission should assess the potential presence of 

Mirabilis macfarlanei and potential impacts to the species with the acknowledgement that the timing of 

the surveys conducted to date and the sufficiency of 7-year-old data are questionable. 

Response: The timing of surveys between April and June 1999 should have been appropriate to identify 

MacFarlane’s four-o’clock, if present in surveyed areas, and we consider 7-year-old data to be reliable in 

providing an indication of the prevalence of this and other plant species in the project area. However, to 

ensure that the most relevant data are available, the Staff Alternative recommends surveys at sites where 

project-related construction or disturbance could cause adverse effects. If surveys confirm the species is 

present, the Staff Alternative recommends that Idaho Power consult with FWS and the other stakeholders 

to identify and implement any protective measures that may be needed.

Comment TES-18: Interior comments that the NEPA document should discuss which aspects 

(e.g., geographic scope) of Interior’s 10(j) recommendation regarding MacFarlane’s four-o’clock and 

Spalding’s catchfly would be incorporated into the staff’s recommended TESSMP. 

Response: The Staff Alternative would be consistent with items 1, 2, 4, 6, 7, and 8 of Interior’s 10(j) 

recommendation. Item 3 calls for additional surveys when evidence indicates that potential habitat exists 

and original surveys did not include these sites/habitats. Rather than recommending that Idaho Power 

conduct inventory-level surveys of all potential habitat, the Staff Alternative would focus surveys at sites 

where project-related construction or other activities could adversely affect sensitive plant species; i.e., 

surveys would be conducted in potential habitat if project-related effects could occur. 

Item 5 calls for an annual monitoring and evaluation plan for selected sites for the first 5 years, then once 

every 2 years for the terms of the license. We are recommending that the monitoring frequency should be 

based on site-specific conditions; i.e., more frequent monitoring at sites with a high risk of disturbance, 

and less frequent monitoring at remote sites. 

Comment TES-19: Interior comments that the draft EIS does not adequately describe baseline 

conditions or potential project effects on northern Idaho ground squirrel habitat. Specifically, Interior 

comments that Idaho Power’s management of Barber Flats has the potential to affect this species through 

habitat alteration, and suggests that the NEPA document call for Idaho Power to retain ownership and 

manage Barber Flats as a conservation reserve. 

Response: As described in draft EIS section 3.8.2.11, Northern Idaho Ground Squirrel, we concluded 

that the project does not affect the northern Idaho ground squirrel, because this subspecies occurs at 

higher elevations than those occupied by project features or affected by project operations. We updated 

the text of the final EIS to clarify that Idaho Power no longer owns the Barber Flats parcel, but we 

continue to recommend that Idaho Power consult with the agencies, tribes and other stakeholders to 

address management of this subspecies if Idaho Power acquires lands that provide potential or occupied 

habitat, and we include this species in the TESSMP. 

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Comment TES-20: Interior comments that additional cumulative effects analysis is needed if the EIS is 

to serve as a biological assessment under section 7 of the ESA. 

Response: We added text to final EIS section 3.8.3.7, Bald Eagle, to address cumulative effects on bald 

eagles.

Comment TES-21: Interior comments that the NEPA document should specify the geographic scope of 

the project-wide threatened and endangered species management plan, and the parties that will be 

involved with its development. 

Response: We added text to section 5.2.5.1, Special Status Plant and Wildlife Protection, to define the 

geographic scope and the parties to be involved.

Comment TES-22: Interior comments that text regarding unavoidable adverse effects on threatened and 

endangered plants and wildlife species is confusing and should be clarified. 

Response: We clarified the text in section 3.8.4, Unavoidable Adverse Effects, to show that we identified 

unavoidable adverse effects on listed fish species. 

B12. CULTURAL RESOURCES 

Comment CR-1: The Nez Perce Tribe states that the draft EIS fails to recognize the Nez Perce Tribe’s 

unique cultural and treaty-based relationship to Hells Canyon and the project area. 

Response: We revised the text in section 3.9.1.2, Cultural History Overview, to acknowledge the Nez 

Perce Tribe’s relationship to Hells Canyon and the project area.

Comment CR-2: Idaho Power comments that it anticipates a rotating monitoring schedule ensuring that 

all sites are monitored during the first 3-year monitoring cycle, consistent with Forest Service revised 

preliminary condition no. 25; it has not proposed annual monitoring of all historic properties. 

Response: We revised the text in section 3.9.2.2, under Monitoring, and in section 5.2.6.2, Cultural 

Resources Monitoring, to indicate that Idaho Power has proposed a rotating monitoring schedule ensuring 

that all sites are monitored over the course of the first 3-year monitoring cycle. 

Comment CR-3: Idaho Power comments that the $7,600 annualized cost estimate for development of 

oral histories for the Shoshone-Bannock and Shoshone-Paiute tribes would be in excess of the efforts put 

into the other oral histories that were submitted as part of the final license application and that the 

estimate should be revised to be comparable to the support Idaho Power offered the other tribes. 

The Shoshone-Bannock Tribes comment that the funding for ethnographic studies should be increased to 

$150,000 per year through the term of the license to secure a contractor to produce the tribal cultural 

geography for the Hells Canyon area. 

Response: We revised the text in section 5.2.6.4, Ethnographic and Oral History Studies, to indicate that 

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the funding for oral histories for the Shoshone-Bannock and Shoshone-Paiute tribes should be consistent 

with that allocated by Idaho Power for the oral histories of the other tribes. 

Comment CR-4: Oregon SHPO reiterates its recommendation that Idaho Power update the National 

Register nomination for the Hells Canyon Historic District to permit new analysis of contributing sites 

and to assist in prioritizing the protection/stabilization of such sites. The Shoshone-Bannock Tribes 

comment that revising the Hells Canyon Archaeological District nomination may afford greater protection 

and offer the tribes recourse if sites in the district are affected. It may also provide an opportunity for 

public education about the importance and use of the area prior to European contact. Idaho Power 

comments that section 106 does not require Idaho Power to update of the National Register nomination 

for the Hells Canyon Archaeological District and that the cost of doing so using only existing data would 

range from $50,000 to $60,000. 

Response: We reconsidered our position on this measure and acknowledge that the Advisory Council’s 

regulations implementing section 106 of NHPA do not require federal agencies to nominate properties to 

the National Register. Section 106 only requires federal agencies to determine whether properties are 

eligible for inclusion in the National Register, and to assess a proposed project’s potential effects on the 

properties. Thus, in the Staff Alternative in the final EIS, we do not require Idaho Power to update the 

National Register nomination for the Hells Canyon Archaeological District. However, we do find that 

Idaho Power would need to resolve any project-related adverse effect to any National Register-eligible 

property that exists within that portion of the Hells Canyon Archaeological District that lies within the 

project’s APE, as well as any National Register-eligible property within any other part of the project’s 

APE. As stated in draft HPMP section 3.1.1.4.2, Idaho Power acknowledges that all but a handful of the 

more than 800 archeological sites recorded between Hells Canyon dam and the confluence of the Snake 

and Salmon rivers—the majority of which fall within the Hells Canyon Archaeological District—are 

considered eligible for the National Register. Regardless of whether contributing elements to the Hells 

Canyon Archaeological District are nominated to the National Register, Idaho Power must still manage 

these elements as historic properties. Thus, revising the Hells Canyon Archaeological District nomination 

would not afford sites within the district any greater protection. 

Comment CR-5: The Forest Service comments that staff should clarify whether it recommends adoption 

of all of the components of FS-25, and recommends that the final EIS should include the following items 

as requirements of the HPMP: 

1. Review process and time frame for preparing HPMP in coordination with the Forest Service 

2. Adaptive management strategy to accommodate unforeseen challenges and changes to 

conditions affecting historic properties: 

3. How consultation requirements of 36 CFR 800 will be satisfied. 

4. Discussion of how future project-related developments will be evaluated and potential 

revisions to the APE undertaken. 

5. Identification of conditions under which new surveys may be required. 

6. Identification of when additional surveys resulting from increased shoreline erosion or 

reservoir drawdown on Forest Service lands will be completed. 

7. Development of a detailed monitoring plan. 

8. Development of site specific treatment plans and implementation schedule for any sites 

requiring mitigation or treatment as a result of adverse effects of the project. 

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9. A provision for sharing all cultural resources data collected by Idaho Power with the Payette 

and Wallowa-Whitman National Forests. 

10. Development of a Cultural Resources Advisory Group. 

11. Provision that all artifacts recovered as a result of Idaho Power-sponsored cultural resource 

investigations be curated in accordance with 36 CFR 79. 

12. Inclusion of all provisions of the draft HPMP submitted with the final license application 

unless replaced or modified by provisions of Forest Service condition no. 25. 

Response: Staff does recommend adoption of FS-25 in its entirety; we revised the text in section 5.2.6.1, 

Finalization of HPMP, to clarify this issue. 

Comment CR-6: The Forest Service requests clarification regarding how the Commission has decided to 

move forward with a Programmatic Agreement to prepare and implement the HPMP. 

Response: The Commission drafted and circulated to agencies, SHPOs, and tribes for comment a 

Programmatic Agreement stipulating the finalizing and implementation of the HPMP. Prior to any 

license issuance, the Commission would execute the final Programmatic Agreement with the SHPOs and 

Advisory Council, if the latter decides to participate. The Forest Service, BLM, Idaho Power, and the 

tribes would be concurring parties. 

Comment CR-7: The Forest Service comments that the final EIS should discuss factors, such as erosion, 

resulting from reservoir impoundment of sediment and subsequent lack of sediment in flows downstream 

of Hells Canyon dam, in addition to the effects of water fluctuation. 

Response: Section 3.4, Sediment Supply and Transport, discusses these factors. 

Comment CR-8: The Forest Service comments that prior to finalizing the HPMP, Idaho Power should 

develop criteria to measure project-related impacts that the Commission, SHPOs, concerned tribes, and 

agencies can all agree on. The Forest Service comments that this is necessary to develop a successful 

monitoring program. 

Response: We revised the text in section 3.9.2.2, Site Treatment, Stabilization to clarify the need for 

development of criteria to measure project-related impacts as an integral element of the monitoring plan. 

Comment CR-9: The Forest Service comments that the Commission should clarify whether it is 

following the subpart B section 106 process or the subpart C program alternative process, and if the latter, 

provide Federal Register volume, number and date of the Commission’s notice. 

Response: The Commission follows the subpart B section 106 process in relicensing. 

Comment CR-10: Interior comments that archaeologists reported three sites on Oxbow reservoir and 

two sites on Hells Canyon reservoir as being affected by pool fluctuations and/or cutbank erosion. 

Response: We revised the text in section 3.9.2.1, Effects of Project Operations on Cultural Resources, 

Prehistoric and Historic Archaeological Resources, to state the correct numbers of sites affected by 

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fluctuations and/or cutbank erosion at Oxbow and Hells Canyon reservoirs. 

Comment CR-11: Interior comments that a sentence on page 416 of the draft EIS should be corrected to 

read “The tribes and Idaho State Historical Society recommend, and the BLM (Interior-5) and Forest 

Service specify, that Idaho Power revise, finalize and implement the HPMP.” 

Response: We revised the text in section 3.9.2.5, Management of Cultural Resources, Revise and 

Finalize the HPMP, accordingly. 

Comment CR-12: Interior comments that BLM should be a principal signatory to the Programmatic 

Agreement. 

Response: It has been the Commission’s practice to use the traditional 2-party Programmatic Agreement 

format (when the Advisory Council chooses not to participate), allowing the SHPO (in this instance, 

SHPOs) to be the only other signatory beside ourselves in executing a PA for a new hydroelectric 

license. All other parties to the Programmatic Agreement are designated as concurring parties, including 

the licensee, who also has major responsibilities in managing lands under its new license. Being a 

concurring party does not diminish the responsibilities of BLM as a land manager. Irrespective of being a 

signatory or concurring party, all parties to the Programmatic Agreement have equal status in consultation 

and have the ability to recommend the Programmatic Agreement be amended at any time during the term 

of the new license. As a result, BLM remains as a concurring party to the Programmatic Agreement. 

Comment CR-13: Interior comments that the NEPA document should describe the potential effects of 

flow augmentation or flood control measures on cultural resources and that the Staff Alternative should 

specify that the deferred cultural resource monitoring study on effects of reservoir water level fluctuations 

should include effects of flow augmentation or flood control measures. 

Response: Idaho Power’s plan for studying effects of reservoir water level fluctuations on cultural 

resources calls for characterizing daily, monthly and annual fluctuations and identifying those fluctuations 

attributable to project operations and those attributable to other purposes or requirements, such as flood 

control. 

Comment CR-14: Interior comments that the NEPA document should clearly state that evaluation and 

protection of important inadvertent paleontological discoveries would be retained in the final HPMP. 

Response: We clarified the text in section 5.2.6.7, Other Cultural Resource Management Measures, 

regarding treatment of paleontological resources in the HPMP. 

Comment CR-15: The Oregon SHPO comments that it needs a complete list of all sites and Idaho 

Power’s determinations for each section of the study area to determine which sites have not been 

adequately addressed. The Oregon SHPO also comments that a monitoring program cannot be developed 

until all eligibility determinations have been made. The Nez Perce Tribe comments that the tribe 

considers many of the archaeological sites in Hells Canyon to be eligible for the National Register under 

criteria other than D, and that all the National Register criteria should be applied to archaeological sites to 

properly assess site significance and adverse effects. 

The Umatilla Tribes comment that staff should clarify that the Commission will require all unevaluated 

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cultural resource sites to be treated as eligible for inclusion in the National Register. 

Response: Lists of sites in the APE are contained in the final license application and supporting technical 

reports. On June 26, 2003, Idaho Power filed its National Register eligibility determinations with the 

Commission. In section 3.1.1 of its draft HPMP, Idaho Power summarizes information about listed and 

eligible resources, including those identified below Hells Canyon dam. The resources and their 

evaluations are itemized in appendix 3.1-a of that document. In the final EIS, we clarified the text in 

section 3.9.2.2, Site Treatment, Monitoring, to specify that the reasons a site is considered significant 

should be taken into account in assessing effects of project operation on the site and that the possibility 

that a site is considered significant under criteria other than D should also be taken into account. 

Additionally, in section 4.2.4 of its draft HPMP, Idaho Power specifies that Idaho Power would record 

and evaluate the National Register eligibility of any previously-identified resources prior to any actions 

that could affect such resources. 

Comment CR-16: The Oregon SHPO comments that the EIS needs to recognize that the Oregon SHPO 

disagrees with Idaho Power regarding effects on cultural resources downstream of the Salmon River 

confluence. 

Response: We revised the text in section 3.9.2.1, Effects of Project Operations on Cultural Resources, 

Prehistoric and Historic Archaeological Resources, and in section 3.9.2.5, Management of Cultural 

Resources, Expansion of Area of Potential Effect, to indicate that the Oregon SHPO disagrees with Idaho 

Power regarding effects on cultural resources downstream of the Salmon River confluence. 

Comment CR-17: Oregon SHPO comments that site treatment and monitoring cannot be discussed 

without first having completed adequate documentation of current site status. 

Response: We clarified the text in section 3.9.2.2, Site Treatment, Monitoring, regarding the updating of 

site condition information as an integral element in the initial 3-year phase of the monitoring program. 

Comment CR-18: The Oregon SHPO reiterates its recommendation that Idaho Power provide future 

funding to support analysis of previously recorded archaeological materials. The Oregon SHPO states 

that knowledge gained from such studies would help in future site evaluations and interpretations and 

could assist in making proper management recommendations. 

Response: In section 3.9.2.3, Cultural Resources Interpretation, we acknowledge that analysis of 

previously recovered archaeological materials could potentially contribute to the state of knowledge 

concerning the cultural history of the Hells Canyon area. However, we conclude that its potential 

contribution toward management and protection of resources extant in the project would not be sufficient 

to support a recommendation that Idaho Power fund such analysis. Nevertheless, this conclusion does not 

preclude Idaho Power from acting on its own to collaborate with local educational institutions and 

interested tribes to provide access to, and the opportunity to conduct research on, those archeological 

collections in Idaho Power’s possession. 

Comment CR-19: The Oregon SHPO comments that general recreational enhancements do not always 

adequately address tribal concerns regarding access to tribal fishing sites in the APE. 

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Response: In section 4.3.4.2 of its draft HPMP, Idaho Power states that it will endeavor to provide 

access to TCPs identified within the APE where it is practical and safe to do so. Providing tribes with 

access to sacred sites and TCPs (which may include tribal fishing sites and locations of culturally 

significant plants, as well as other locations), is also specified as an action to be undertaken under 

Standard Procedure 1 of the draft HPMP. The SHPOs are among the consulting parties listed under SP 1. 

We revised final EIS section 3.9.2.4, Support for Native American Programs, to include this information. 

Comment CR-20: The Oregon SHPO and the Nez Perce Tribe comment that at least a portion of the 

area downstream of the confluence of the Snake and Salmon rivers should be part of the APE. 

Response: As stated in section 5.2.6.7, Other Cultural Resource Management Issues, we conclude that 

neither information filed with the Commission nor the recommendations to expand the APE downstream 

of the confluence of the Snake and Salmon rivers provide an empirical basis for attributing erosional 

impacts on cultural resources downstream of the Salmon River to operation of the Hells Canyon Project. 

Comment CR-21: The Oregon SHPO and the Shoshone-Bannock Tribes comment that discrepancies 

among Idaho Power’s archaeological consultants’ investigations should be addressed and that areas 

within the APE for which site information is inaccurate or inconsistent should be resurveyed to address 

these shortcomings. 

Response: The technical archaeological report that Idaho Power submitted with its license application 

about surveys downstream of Hells Canyon dam acknowledges discrepancies in the ways the 

archaeological consultants interpreted effects. These discrepancies would be rectified (and information 

on effects updated) through the monitoring program undertaken under the HPMP. 

Comment CR-22: The Oregon SHPO comments that sites cannot be selected for stabilization until all 

sites have been fully documented and evaluated and that discussions regarding stabilization should take 

place among Idaho Power, the federal land managing agencies, and the SHPOs. The Umatilla Tribes 

comment that staff should clarify: (1) how the numbers of sites identified for stabilization were arrived 

at; (2) that effects on all affected sites, regardless of the number of sites, should be resolved; and (3) the 

threshold for implementing treatment on sites identified during monitoring as being adversely affected by 

the project and also whether the Commission or Idaho Power is responsible for making sure site treatment 

is appropriately implemented. The Nez Perce Tribe also requests clarification about how the sites were 

selected for stabilization and states that there is no consensus among the consulting parties as to which 

sites are being adversely affected by project operations. 

Response In section 3.9.2.2, Site Treatment, Stabilization, we note that neither Idaho Power’s application 

nor its draft HPMP describes the criteria it used to select sites for stabilization. We then state that 

“[d]ecisions regarding stabilization need to be based on clearly articulated, measurable criteria” set forth 

in the final HPMP. Section 3.9.2.2 also notes that Idaho Power proposes to coordinate with the 

appropriate SHPO, land-managing agency, and tribes to develop stabilization or other measures 

appropriate to historic properties (site, rock image, or other such property) affected by the project. 

Additionally, the Commission would require implementation of the HPMP (including approaches and 

measures for site treatment) as a condition of any new license. 

Comment CR-23: The Oregon SHPO reiterates its recommendation that there be an Advisory 

Committee or working group specifically concerned with implementation of the HPMP. 

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Response: The Staff Alternative includes this measure; see section 5.2.8.1, Land Use Management. 

Comment CR-24: The Umatilla Tribes comment that consultation with Native American tribes can 

contribute to identification of historic properties, and that historic properties can be of any ethnic origin. 

Response: In its draft HPMP, Idaho Power proposes to identify and evaluate historic properties in 

consultation with the SHPOs, tribes, and, as appropriate, land-managing agencies. As noted in section 

3.9.1.4 of the EIS, studies have identified a variety of historic properties in the Hells Canyon area 

associated with Euro-American and Euro-Asian presence in the region, as well as the numerous properties 

of Native American origin. 

Comment CR-25: The Umatilla Tribes comment that changes to the Pine Creek-Hells Canyon 69-kV 

line could visually affect historic properties outside the 50-foot APE. 

Response: Idaho Power proposes no changes to the Pine Creek-Hells Canyon 69-kV line. However, in 

the event that Idaho Power planned to make any changes to the 69-kV line in the future, the draft HPMP 

outlines the process (figure 4.3-c) by which work would be reviewed to determine its potential to affect 

historic properties and the steps necessary to ensure that any adverse effects are properly resolved. This 

process would be finalized in the final HPMP. 

Comment CR-26: The Umatilla Tribes comment that while 0.1-mile upslope from high-pool level is an 

appropriate APE in some areas, it is inappropriate for places where recreation sites provided by Idaho 

Power are affecting an area more than 0.1 mile from the reservoir. 

Response: Over the term of a license, it is possible that the APE, as well as other elements of the HPMP, 

may require adjustment in response to changing circumstances or new information regarding historic 

properties and project effects. We included in the Staff Alternative a recommendation for periodic review 

and, as necessary revision, of the HPMP. 

Comment CR-27: The Umatilla Tribes comment that the APE should be extended to Anatone because 

the Commission has determined that the project has measurable impacts at that location. 

Response: As indicated in section 5.2.6.7, Other Cultural Resource Management Issues, we conclude 

that neither information filed with the Commission nor the recommendations to expand the APE 

downstream of the confluence of the Snake and Salmon rivers provide an empirical basis for attributing 

erosional impacts on cultural resources downstream of the Salmon River to operation of the Hells Canyon 

Project. 

Comment CR-28: The Umatilla Tribes comment that the APE should be extended upstream because the 

project blocks salmon from traditional fishing areas along the Snake River. The inability of salmon to 

reach traditional fishing areas compromises the integrity of the TCPs. 

Response: In final EIS section 3.8.3, we note that settlement and development of the Snake and 

Columbia River basins have had substantial cumulative adverse effects on the habitat and population size 

of Snake River fall Chinook salmon. We also note that Snake River steelhead and spring/summer 

Chinook salmon have been subject to these same cumulative effects, although those species have been 

more directly affected by tributary development, particularly development associated with irrigation 

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diversions. We acknowledge that blockage of salmon from TCPs that are the locations of traditional 

fishing areas constitutes an adverse effect on such TCPs. However, given the very large number and 

variety of factors other than the presence and operation of the Hells Canyon Project that contribute to the 

loss and degradation of salmon and steelhead habitat and to reduction in population sizes, we conclude 

that expansion of the project’s APE as recommended by the Umatilla Tribes is not warranted. We do 

note, however, that measures proposed by Idaho Power and also those recommended in the Staff 

Alternative regarding protection and enhancement of aquatic resources would contribute to enhanced 

integrity of traditionally used tribal fishing sites both within and outside the project’s APE. 

Comment CR-29: The Umatilla Tribes comment that the EIS should include a statement about the 

Burns Paiute, Warm Springs, and Umatilla reservations similar to the statement about the reservations of 

other tribes. 

Response: We revised the text in section 3.9.1.2, Cultural History Overview, to include discussion of the 

Burns Paiute, Warm Springs, and Umatilla reservations. 

Comment CR-30: The Umatilla Tribes comment that the continued existence of the dams means the 

continued existence of the reservoirs and continued damage to shoreline sites from boat wakes. 

The Nez Perce Tribe comments that while state and federal land-managing agencies built boat ramps on 

the reservoirs, Idaho Power has some responsibility for boat wakes damaging sites. 

Response: In section 3.9.2.1, under Prehistoric Archaeological Resources, we acknowledge that 

requiring Idaho Power to provide boat access to the reservoirs creates a nexus between the project and 

erosion resulting from boat wakes. 

Comment CR-31: The Umatilla Tribes comment that if a site has been determined to be adversely 

affected and in need of treatment, monitoring is unnecessary, and that what is necessary is to resolve the 

adverse effects immediately. They state that monitoring may be necessary after treatment. 

Response: As discussed in section 3.9.2.2, Site Treatment, Idaho Power has proposed measures for 

stabilization and mitigation based on information from the cultural resources surveys conducted for Idaho 

Power’s application. The monitoring program implemented as part of the HPMP would determine if 

other sites are being affected by project operations. 

Comment CR-32: The Umatilla Tribes comment that staff should clarify how one monitoring program 

ensures consistency of approach and analysis. They also comment that the approach to monitoring an 

archaeological site is different from the approach to monitoring a rock image site. 

Response: In section 3.9.2.2, Site Treatment, Monitoring, we state that employing monitoring methods 

that take key characteristics of a resource type and its significance into account would enhance 

assessment of the resource’s condition. Because rock images frequently occur in association with Native 

American archaeological sites, we conclude that a single monitoring program, designed to address a range 

of feature characteristics, would ensure consistency of approach and analysis. 

Comment CR-33: The Umatilla Tribes comment that analysis of archaeological materials removed from 

the project during previous investigations would provide a better context for sites and thus assist in 

evaluation of unevaluated sites in the APE. 

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Response: In section 3.9.2.3, Cultural Resources Interpretation, we acknowledge that analysis of 

previously recovered archaeological materials could potentially contribute to the state of knowledge 

concerning the cultural history of the Hells Canyon area. However, we conclude that its potential 

contribution toward management and protection of resources extant in the project would not be sufficient 

to support a recommendation that Idaho Power fund such analysis. Nevertheless, as we stated above, this 

would not preclude Idaho Power from collaborating with local educational institutions and interested 

tribes to provide access to and opportunity to conduct research on archeological collections in Idaho 

Power’s possession. 

Comment CR-34: The Umatilla Tribes comment that access to traditionally used tribal fishing sites, 

many of which are TCPs, involves the presence of traditionally harvested fish. They state that the lack of 

traditionally harvested fish compromises the integrity of these TCPs. 

Response: Measures proposed by Idaho Power and also those recommended in the Staff Alternative 

regarding protection and enhancement of aquatic resources would potentially contribute to enhanced 

integrity of traditionally used tribal fishing sites. We did not revise our conclusion in that regard. 

Comment CR-35: The Umatilla Tribes comment that Idaho Power should assist county, state, and 

federal law enforcement organizations by providing funding for individuals to focus law enforcement 

energy (to protect cultural resources) within the Hells Canyon Complex, as Idaho Power has been doing 

with Adams County, Idaho. 

Response: In draft EIS section 5.2.8.2, Law Enforcement and Fire Protection, we note that the 

responsibility of funding law enforcement activities on private, state, and federal lands lies with the 

county, state, and federal agencies having jurisdiction over those areas. We did not revise our conclusion 

in the final EIS. 

Comment CR-36: The Umatilla Tribes reiterate their recommendation that the APE be resurveyed every 

10 years, noting that field conditions, methodologies, technology, and interpretations change over time, 

and that many sites will become historic over the next 30 years. 

Response: We acknowledge that field conditions, methodologies, technologies, and interpretations 

change over time, and may change over the term of a license. We include FS-25 in the Staff Alternative. 

FS-25 specifies, among other measures, that Idaho Power’s final HPMP include provisions for an 

adaptive management strategy to accommodate unforeseen challenges and conditions and also provisions 

for determining when and under what circumstances new survey, or resurvey of previously examined 

areas, may be required. 

Comment CR-37: The Umatilla Tribes comment that a TCP assessment would need to be conducted 

prior to the proposed hatchery improvements because only an archaeological assessment has been done to 

date. The tribes also comment that staff should clarify that lands acquired for terrestrial resource 

mitigation would need to be surveyed for all types of historic properties prior to beginning any work that 

could affect historic properties on those lands. 

Response: Section 4.2.4 of Idaho Power’s draft HPMP specifies that it will evaluate all new construction 

projects for the presence of significant cultural resources in accordance with the Secretary of the Interior’s 

Standards and Guidelines for Identification. This provision in a finalized HPMP would extend to the 

proposed hatchery improvements and any lands acquired under the terms of the license for terrestrial 

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resource mitigation. 

Comment CR-38: The Umatilla Tribes comment that staff should clarify what the Commission is 

requiring in terms of minimizing and avoiding effects on historic properties from recreational use in the 

Hells Canyon Complex. 

Response: In section 5.5 of its draft HPMP, Idaho Power specifies actions it will take to resolve any 

adverse effects on historic properties resulting from implementation of specific recreational 

environmental measures. Resolution of other recreational effects on historic properties would be carried 

out under monitoring and treatment provisions of the final HPMP. 

Comment CR-39: The Umatilla Tribes comment that staff should clarify that continued project 

operation would have adverse effects, how the Commission plans to have Idaho Power mitigate the 

effects, and that Idaho Power is responsible for carrying out all cultural resource activities in the HPMP 

regardless of cost. 

Response: Draft EIS section 3.9.2, Environmental Effects, describes known and potential adverse effects 

on cultural resources from continued project operation. To ensure that adverse effects are appropriately 

resolved over the license term, the Commission has drafted and circulated a Programmatic Agreement 

that it proposes to execute with the SHPOs, tribes, agencies, and Advisory Council. In the Programmatic 

Agreement, the Commission agrees to ensure that, upon license issuance for the Hells Canyon Project, 

Idaho Power would finalize and implement its HPMP. The requirement to finalize and implement its 

HPMP would also be a condition of any new license issued by the Commission. 

Comment CR-40: The Umatilla Tribes comment that staff should clarify how an annualized reduction 

of $70,200 per year for scholarships was determined. 

Response: Because neither Idaho Power nor the tribes provided a breakdown of each of the three 

elements of Idaho Power’s proposal with respect to tribal funding, staff estimated that 30 percent of the 

funds would support Native American Programs to obtain funding for participating in and/or 

administering cultural resources environmental measures; 35 percent would support scholarship/training 

funds; and 35 percent would be devoted to facilitating several cultural enhancement programs. This 

would amount to about $11,700 per tribe for scholarship/training funds, which would equal an annual 

reduction of $70,200 for all six tribes. We corrected the incorrectly labeled support measures in appendix 

I of the final EIS. 

Comment CR-41: The Nez Perce Tribe comments that as camping locations are lost due to erosion, 

campers move farther inland, and begin to use cultural features such as housepits for camping. The Nez 

Perce Tribe also comments that this recreational effect on cultural resources is a direct result of projectrelated sediment trapping. 

Response: Section 3.4, Sediment Supply and Transport, discusses the influence of beach loss on 

recreationists’ choices for camping locations. Section 3.9.2.6, under Recreational Measures, also 

acknowledges that recreational activities are perhaps the greatest threat to cultural resources. In the final 

EIS, the Staff Alternative includes FS-4, Sandbar Restoration, which would help restore some shoreline 

areas used by campers. 

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Comment CR-42: The Nez Perce Tribe comments that the Modoc and Klamath are part of the Klamath 

Language Isolate, not part of the Sahaptian language family. 

Response: We corrected the text of section 3.9.1.2, Cultural History Overview, regarding the association 

of specific Native American communities with particular language groups. 

Comment CR-43: The Nez Perce Tribe comments that the EIS should include the information that much 

of Hells Canyon was originally located within the Nez Perce Indian Reservation and that the Nez Perceceded territory includes all of Hells Canyon and the project north of the confluence of the Powder and 

Snake rivers. 

Response: We revised the text of section 3.9.1.2, Cultural History Overview, to indicate that much of the 

area of the Hells Canyon Project was contained within the boundaries of the Nez Perce Tribe reservation 

established under the 1855 treaty. 

Comment CR-44: The Nez Perce Tribe comments that section 3.9.1.5, Traditional Cultural Properties, 

Sacred Sites and Rock Art, should be renumbered as 3.9.1.6. 

Response: We revised the final EIS section number accordingly. 

Comment CR-45: The Nez Perce Tribe comments that its oral history study was submitted to Idaho 

Power approximately 2 years ago. 

Response: The Commission thanks the Nez Perce Tribe for this information. We revised section 3.9.2.4, 

under Participation, Education, and Training, to indicate that the Nez Perce Tribe’s oral history study 

was filed with the Commission in February 2007. 

Comment CR-46: The Nez Perce Tribe comments that to properly determine the best course of site 

treatment, the criteria under which the site is eligible must be determined. 

Response: We clarified the text in section 3.9.2.2, Site Treatment, Stabilization, to specify that the 

reasons a site is considered significant should be taken into account in determining appropriate site 

treatment. 

Comment CR-47: The Nez Perce Tribe comments that its $10 million estimate for monitoring was 

based on a field crew operating nearly year-round at $333,000 for 30 years. It also comments that Idaho 

Power did not indicate how its initial estimate of monitoring costs was determined. 

Response: We revised the text in section 3.9.2.2, Site Treatment, Monitoring, to include the Nez Perce 

Tribe’s basis for its $10 million estimate for monitoring. 

Comment CR-48: The Nez Perce Tribe comments that if the oral histories completed for the project so 

far did not discuss TCPs in terms of National Register criteria, and are therefore insufficient to determine 

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Paiute Tribes comment that existing ethnographic studies of the Hells Canyon area are inadequate and 

have not properly identified or described the cultural and natural resources or their tribal meaning and 

uses. The Shoshone-Paiute Tribes comment that the staff recommendation regarding an oral history for 

the Shoshone-Paiute Tribes should be expanded to include ethnographic studies conducted by a qualified 

ethnographer approved by the tribes and involving tribal elders and religious leaders. 

Response: Each of the four oral history studies filed in association with Idaho Power’s application for 

new license was conducted by a qualified tribal member or qualified individual associated with the 

respective tribe. Although all are titled “Oral History Study,” each study reflects the particular interests 

and concerns of the tribe and tribal members with whom it was developed and conducted. The Staff 

Alternative includes a measure for funding an oral history for the Shoshone-Paiute Tribes and ShoshoneBannock Tribes to afford these tribes another opportunity to contribute information and insight into the 

ethnography of the Hells Canyon area. The licensing process offered all the tribes the opportunity to 

contribute such information as they chose toward identification of cultural resources important to them. 

Information necessary for determining National Register eligibility in a public forum may be considered 

confidential by tribes. Tribal participation in consultations with Idaho Power during implementation of 

the final HPMP, and in the cultural resources technical subcommittee, will provide further opportunities 

for the tribes to indicate concerns regarding project operations that could affect specific resources of 

interest to the tribes. We also note that under NEPA, the “cultural environment” may include not only 

National Register-eligible resources but also other culturally valued property and cultural use of the 

biophysical environment. 

Comment CR-49: The Nez Perce Tribe comments that the draft EIS recommendation against sand 

augmentation (because it could interfere with recreational boating and disturb wildlife) conflicts with one 

of the main purposes of the act creating NHNRA, which was to preserve historical and archaeological 

values of the Hells Canyon Area. 

Response: In the final EIS, the Staff Alternative includes FS-4, Sandbar Maintenance and Restoration. 

Comment CR-50: The Nez Perce Tribe comments that there are discrepancies and lack of information in 

the HPMP and that requiring Idaho Power to complete the HPMP within 1 year of license issuance is out 

of compliance with section 106. 

Response: As indicated in section 5.2.6.1, Finalization of the HPMP, we included in the Staff 

Alternative a measure explicitly requiring Idaho Power to finalize the HPMP in consultation with the 

SHPOs, tribes, agencies, and Commission. Such consultation would afford all concerned parties the 

opportunity to identify discrepancies and make recommendations regarding information in the HPMP. 

Through execution of a Programmatic Agreement, the section 106 process would be completed for this 

particular relicensing. The Programmatic Agreement would be made part of any new license issued for 

this project. Prior to Commission approval of the HPMP, the licensee will be required to follow the 

interim process, as stipulated in the Programmatic Agreement, which essentially follows the section 106 

process. 

Comment CR-51: The Nez Perce Tribe comments that the annualized cost of monitoring all historic 

properties, as provided in the draft EIS, is extremely low. 

Response: Monitoring costs provided in the NEPA document are estimates. As the monitoring program 

is implemented over time, these estimates may be refined based on actual expenditures and monitoring 

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results. 

Comment CR-52: The Nez Perce Tribe comments that Idaho Power and the Commission should consult 

with each tribe regarding how the funding proposed by Idaho Power should be prioritized and used, and 

that the Nez Perce Tribe should be able to use its share of the funding for its own priorities. 

Response: In its license application and in its draft HPMP, Idaho Power states that it proposes to consult 

with each tribe in developing the funding program for that tribe; this proposal would be carried into the 

final HPMP. 

Comment CR-53: The Nez Perce Tribe comments that the discussion on Native American interpretive 

sites does not differentiate among the tribes and that the Nez Perce Tribe is the tribe that should be 

consulted regarding development of such interpretive displays. The Nez Perce Tribe indicates that the 

project area should be acknowledged as being within the Nez Perce Tribe’s former 1855 reservation and 

Indian Claims Commission-defined boundaries of the tribe’s aboriginal territory. 

Response: In its license application, Idaho Power stated that its proposals for Native American 

interpretive sites arose from consultation with Native Americans who expressed strong interest in 

educating the public about Native American presence and land use in the project area. Any future 

planned development involving Native American interpretive sites can be further elaborated upon in the 

final HPMP. We do not recommend that such consultation be limited to only one tribe. Information to be 

included at interpretive sites could appropriately include discussion of the conflicts between Native 

peoples and Euro-Americans in the nineteenth century, including forced relocations, establishment of 

reservations (including the reservation established for the Nez Perce in 1855), and other pertinent events. 

Comment CR-54: The Nez Perce Tribe comments that scholarships provide the means by which 

members of Native American tribes can obtain the education and training necessary to perform work in 

natural and cultural resource management. The Shoshone-Bannock Tribes make a similar comment. 

Response: We acknowledge the importance of education in the cultural well-being of the tribes. 

However, as indicated in draft EIS section 5.2.6.5, Tribal Participation, Education, and Training, there 

does not appear to be a nexus between the funding of scholarships and the Hells Canyon Project and 

effects. This does not preclude Idaho Power from promoting such scholarships; however, this kind of 

initiative would have to take place outside any new license for the project. 

Comment CR-55: The Shoshone-Paiute Tribes reiterate their Cultural Resource conditions 1 through 6. 

Response: We analyze the Shoshone-Paiute Tribes’ Cultural Resource Conditions in the appropriate 

topical subsections of draft EIS section 3.9.2, Environmental Effects. We did not revise that analysis in 

the final EIS. 

Comment CR-56: The Shoshone-Paiute Tribes comment that Idaho Power’s offer of $1 million to each 

tribe to support tribal programs is not adequate to enable the programs to be successful and comment that 

the amount should be increased to $10 million. 

Response: As indicated in draft EIS section 5.2.6.5, Tribal Participation, Education, and Training, we 

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do not include in the Staff Alternative recommendations to increase the funding to $10 million per tribe 

because the record provides no information to tie such an increase to project effects, and therefore the 

measure lacks nexus to the project. 

Comment CR-57: The Shoshone-Bannock Tribes comment that the draft EIS did not address Tribal 

Treaty or cultural resources in the affected environment, discuss cumulative effects on Treaty or cultural 

resources, or develop mitigation for Treaty and cultural resources. 

Response: Implementation of the HPMP and measures and plans for aquatic and terrestrial resources 

would ensure that treaty and trust rights of the tribes for the protection of valued cultural resources are 

respected through the term of the new license. Implementation of the HPMP would include continued 

consultation among the tribes, Idaho Power, the Forest Service, BLM, and the SHPOs, as well as 

oversight from Commission staff. 

Comment CR-58: The Shoshone-Bannock Tribes comment that staff should include discussion of site 

impacts resulting from the Brownlee service road. They also comment that this service road runs directly 

through sites 10-WN-157 and 10-WN-158, and sites 10-WN 159 and 10-WN-160 are adjacent to the 

service road and therefore affected by the project. 

Response: None of these sites is listed in the final license application or any of the technical reports 

regarding archaeological resources in the project. However, if the Shoshone-Bannock Tribes provided 

information about these sites, this information could be incorporated into Idaho Power’s final HPMP, and 

the sites could be managed in accordance with the processes and procedures contained in the final HPMP. 

Comment CR-59: The Shoshone-Bannock Tribes comment that 10-WN-61 is a burial site located near 

the Brownlee dam road from which human remains were removed and reposited at the Idaho State 

University Museum of Natural History, and that the Shoshone-Bannock Tribes are investigating the status 

of these human remains and compliance with NAGPRA. 

Response: We note this new information. 

Comment CR-60: The Shoshone-Bannock Tribes comment that the EIS should contain a comprehensive 

regional summary of the culture history of the area and describe which tribes have been identified as an 

interested or affected tribe. 

Response: The technical reports submitted as part of Idaho Power’s license application provide detailed 

information regarding the culture history of the area; it is not necessary to repeat this information in the 

EIS. We note that section 3.9.1.5, Traditional Cultural Properties, Sacred Sties, and Rock Art, identifies 

by name the tribes that have an interest in the area. 

Comment CR-61: The Shoshone-Bannock Tribes comment that they disagree with use of the 

chronology of the Columbia River when the project lies between the Northwest Plateau and the Great 

Basin, and that staff should include the Great Basin culture chronology to ensure that all interested tribes 

are represented. 

Response: We revised the text in section 3.9.1.2, Cultural History Overview, to include discussion of the 

Great Basin culture chronology. 

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Comment CR-62: The Shoshone-Bannock Tribes comment that the draft EIS failed to adequately 

address protection of petroglyphs and pictographs due to lack of ethnographic information from 

Shoshone-Bannock Tribes about rock writing. The Shoshone-Bannock Tribes comment that additional 

funding needs to be provided to the tribes to gather information to develop appropriate mitigation. The 

Shoshone-Bannock Tribes also comment that Idaho Power is not providing effective preservation 

measures for sites located on reservoir shorelines. 

Response: As indicated in section 3.9.2.2, Site Treatment, Stabilization, Idaho Power’s draft HPMP 

provides for the design of plans for stabilization or other measures for each historic property (site, rock art 

image, or other such property) adversely affected by the project. Such plans would be designed in 

consultation with the appropriate SHPO, land-managing agency, and tribes. 

Comment CR-63: The Shoshone-Bannock Tribes comment that there should be adequate mitigation to 

the Shoshone-Bannock Tribes for loss of sites inundated by the project and continuing effects of project 

operations. 

Response: As stated in section 2.1, No-action Alternative, our baseline for analysis of Idaho Power’s 

proposals and other alternatives is existing conditions, not pre-project conditions. Finalization and 

implementation of the HPMP would ensure that effects from continued project operation would be 

appropriately addressed. 

Comment CR-64: The Shoshone-Bannock Tribes reiterate their recommendation that Idaho Power build 

and operate a Cultural Center within an Idaho Power project area, and a satellite office for Upper Snake 

River tribes, to assist in natural and cultural resource management in the region. 

Response: In draft EIS section 3.9.2.3, Cultural Resources Interpretation, we conclude that other 

measures proposed by Idaho Power or included in the Staff Alternative would have a closer nexus to the 

project and project resources than would a cultural center. We did not revise this conclusion in the final 

EIS. Our decision to not include this measure in the Staff Alternative would not preclude Idaho Power 

from establishing or assisting with a cultural center outside the framework of a new license. 

Comment CR-65: The Shoshone-Bannock Tribes comment that artifacts recovered from county, state, 

and federal lands should preferably be reburied as close to the original site as possible, or curated at one 

federally recognized facility. 

Response: In section 3.9.2.5, Management of Cultural Resources, Curation of Archaeological Materials, 

we note that disposition of archaeological materials recovered on federal land is the responsibility of the 

land-managing agency. However, we revised our recommendation in the Staff Alternative regarding 

disposition of archaeological materials recovered on non-federal land has been modified to indicate that 

this policy should include consultation with the tribes and appropriate SHPO. 

Comment CR-66: The Shoshone-Bannock Tribes comment that the tribes should be consulted in the 

selection of natural resource mitigation sites, in order to minimize or avoid damage to archaeological 

sites. 

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Response: In section 3.9.2.6, under Terrestrial Resource Measures, we note that any lands acquired by 

Idaho Power under a new license would automatically come under the provisions of the final HPMP 

regarding treatment of any historic properties that may exist on those lands. 

Comment CR-67: The Shoshone-Bannock Tribes comment that they should be included in the Task 

Force/Advisory Committee/Cultural Resources Work Group. 

Response: We revised the text in section 3.9.2.5, Management of Cultural Resources, to make clear that 

representatives from all the tribes would be members of this working group or technical subcommittee. 

Comment CR-68: The Shoshone-Bannock Tribes comment that the tribes were not provided with site 

forms or other sensitive archaeological information necessary for the tribes to provide meaningful 

comments in the consultation process. 

Response: In section 5.2.6.7, Other Cultural Resources Management Issues, we include in the Staff 

Alternative a measure for establishment of Technical Advisory Committees (including a cultural 

resources subcommittee whose membership would include representatives from all the tribes) to 

participate in implementation of the HPMP. Participation on this technical subcommittee would afford 

the tribes access to the information necessary for them to provide meaningful contributions to the 

management of cultural resources in the project. 

B13. RECREATION RESOURCES 

Comment RR-1: NPPVA states that the navigation history described in section 3.10.1.1, Regional 

Recreation Setting, does not agree with historic facts and should be rewritten with reference to Enclosure 

I of NPPVA’s comment letter. 

Response: Section 3.10.1.1 of the draft EIS describes the regional recreational resources in the area at a 

high level of generalization to establish a baseline from which to consider project-specific recreational 

resources. The EIS does not need to include detailed descriptions the history of boating in the Hells 

Canyon area or of other recreational resources in the region. Although short, the description is consistent 

with NPPVA’s description of boating use along the entire Hells Canyon reach. Therefore, we did not 

change the text in the final EIS. 

Comment RR-2: NPPVA states that use estimates described in section 3.10.1.1, Regional Recreation 

Setting, are different than those reported by the Forest Service permit system. It also states that use 

estimates north of the HCNRA were not approximated; and during steelhead fishing season, 15 to 25 

commercial craft use the lower river each day. 

Response: The differences between the numbers cited in the draft EIS (Brown 2003c) and Forest Service 

numbers provided by NPPVA are small. The recreational-use data provides sufficient detail to 

understand the general boating trends in Hells Canyon. Therefore, we did not change the text in the final 

EIS. 

Comment RR-3: NPPVA notes that use figures for private and commercial use in table 68 of the draft 

EIS are reversed and that more recent data than 1992 to 1999 should have been used. 

Response: We chose to show recreational-use data from common years across all recreational activities. 

The most thorough and accurate recreational use study of the project was conducted by Idaho Power and 

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reported for these years in its license application. We corrected the private and commercial headings in 

draft EIS table 68 (final EIS table 76) and modified the text of final EIS section 3.10.1.1, Regional 

Recreational Setting, accordingly. 

Comment RR-4: NPPVA states that the bar chart in figure 91 of the draft EIS appears to show no 

powerboat use for 1996 to 1999. NPPVA states that the larger commercial power vessels are certified to 

carry 50 to 60 passengers, not 40. NPPVA also notes that private power boaters do not concentrate at the 

portals. 

Response: Draft EIS figure 91 (final EIS figure 118) shows commercial and private power boating in all 

years. In the final EIS, we clarified section 3.10.1.6, Boating Use Downstream of the Project, concerning 

the number of passengers on the larger vessels and deleted the reference to boater concentrations at 

portals. 

Comment RR-5: Idaho Power comments that the study by Shelby, Whittaker & Brown, 2003, Technical 

Report appendix E.57, provided substantial information about the effect of flows on floating and power 

boating use on the Snake River below the project. Idaho Power notes that study methods, relevant study 

issues, and findings are summarized on pages 10–12 of the study’s appendix. Based on the study, Idaho 

Power makes the following points: 

• Different flows are needed for different users varying from inexperienced floaters to 

experienced powerboats, and overall, minimum boating flows established for powerboats are 

likely to meet minimum boating needs for floaters. Idaho Power states that power boats can 

travel upstream of the Salmon River at flows of about 6,000 to 7,000 cfs, but the “margin for 

error” improves up to about 9,000 to 10,000 cfs, and that this “margin for error” is probably 

more important for larger boats, less skilled drivers, and more challenging rapids. Idaho 

Power notes that given the effects of these variables, a “criterion” craft, skill level, and type 

of power boating opportunity must be specified before a “minimum boating flow” can be 

established. 

• The Corps analysis on powerboat boatability should be combined with information from 

other sources to understand how flows affect boatability and safety, or what criteria should 

be considered to establish minimum boating flows. Idaho Power notes that all studies agree 

that preventing powerboat collision with rocks depends on three main variables: (1) boat 

characteristics; (2) operator skill and experience in Hells Canyon; and (3) flow. Idaho Power 

notes that additional variables include: (4) channel marking, and (5) channel modifications, 

both of which have been used to improve boatability in Hells Canyon. Idaho Power briefly 

summarizes the history of channel modifications and marking. 

• Comments by the Corps on accidents at minimum boating flows provide an incomplete 

assessment of accident rates. Idaho Power notes additional information and data which it 

believes would be more useful for comparison. 

• Shelby et al. (2003, pages 23–25) found the effects of low flows on number of boaters to be 

small. 

• Based on results from Shelby et al. (2003), the Corps-recommended 8,500-cfs minimum is 

more accurately characterized as a flow in the middle of the “technical boating opportunity,” 

well above a “minimum safe flow.” Idaho Power notes that a 1974 PNRBC study concluded 

“a minimum flow conducive to relatively non-hazardous powerboat navigation between the 

mouth of the Salmon and Granite Creek Rapids is between 7,700 cfs and 5,000 cfs.” Idaho 

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Power notes that this study also concluded, “from the standpoint of riding comfort, speed of 

travel, and relative safety from hazards, the optimum flow appears to be in the range of 8,000 

to 9,000 cfs.” Idaho Power provides charts, tables, and discussion to support their comments 

on Navigation Target Flow Levels. 

NPPVA states that the discussion on flows in draft EIS section 3.10.1.6, Boating Use Downstream of the 

Project, could use input from professional boaters who are on the river daily. NPPVA notes that the 

margin of safety is low at flows lower than 6,500 cfs, and is adequate for all craft only at 8,500 cfs. 

The Chambers of Commerce from Clarkston, Washington, and Lewiston, Riggins, White Bird, and 

Grangeville, Idaho, as well as the North Central Idaho Travel Association, cite data from the Forest 

Service indicating more than 250,000 people took a variety of boats into the HCNRA during the period 

2001 to 2006. That total includes 33,137 power-boat passengers and 12,207 in privately owned powercraft per year. These entities also note that thousands more boat on the river between Asotin, 

Washington, to the HCNRA boundary. 

The Corps notes that the draft EIS did not take into account comments from the Corps and proposes flow 

conditions that are potentially hazardous to those navigating the river. The Corps states that the FERC 

staff recommendation needs to be revised to incorporate minimum flows that assure safe navigation. The 

Corps also states that Idaho Power substantially followed the Corps’ recommended 8,500-cfs minimum 

flow from August 2004 until July 2006, and that there was a boating mishap when a boat ran aground 

after Idaho Power returned to flows below 8,500 cfs. 

The Clarkston, Washington, and Lewiston, Riggins, White Bird, and Grangeville, Idaho Chambers of 

Commerce; the North Central Idaho Travel Association; John and Kerry Giardinelli; Brian and Angie 

Thomas, Michael Bell, and more than 12 individual members of the Western Whitewater Association 

(WWA) wrote to support the Corps’ minimum flow recommendation of 8,500 cfs for the Snake River, as 

stated in the Corps’ letter to the Commission filed January 26, 2006, to FERC. The same commenters 

express concern about public safety related to both commercial and private navigation on the Snake and 

Salmon rivers, while WWA states that the Corps’ recommended flow rates are necessary to support 

public safety for private boaters. John and Kerry Giardinelli and Brian and Angie Thomas also note that 

some private landowners can access their property only by boat and access during normal low flows or 

under special conditions (e.g., fires) could be limited. 

Response: In the final EIS, we include in the Staff Alternative a recommendation that the minimum flow 

be set at 8,500 cfs from the start of Memorial Day weekend to September 30 in medium-high and 

extremely high water years. We also recommend that, if the 3-day moving average inflow to Brownlee 

reservoir is less than 8,500 cfs during that period, the instantaneous minimum release required from Hells 

Canyon dam for the current day would be equal to the previous 3-day moving average. In other years, we 

continue to recommend Idaho Power’s proposed instantaneous minimum flow of 6,500 cfs at the Hells 

Canyon dam. The current license requires Idaho Power to meet 5,000 cfs, but, since 1980, Idaho Power 

has generally operated the project to meet a 6,500-cfs instantaneous minimum flow at Hells Canyon dam. 

Our analysis shows that flows were below 6,500 cfs only about 1 percent of the time between 1980 and 

2006. 

Recreational and commercial boating downstream of the project has evolved over many years under 

existing project operations, when minimum flows of 6,500 cfs prevailed. As described in section 

3.10.1.6, Boating Use Downstream of the Project, commercial power boaters are by far the largest 

recreational use group in Hells Canyon. Under existing conditions, annual recreational use does not 

appear to be significantly affected by low flows. For example, between 1992 and 1999, the years with the 

least use are associated with the highest flows, not the lowest flows. The current state of commercial 

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boating reflects that the industry is strong and that Idaho Power’s proposal would continue to support 

levels of use similar to those seen since 1980. 

In section 3.10.2.1, Effects of Project Operations on Recreation Resources, we recognize that during low 

and extremely low water years at flows below 8,500 cfs, boating becomes more difficult and safety 

concerns increase for some boats, including the larger commercial boats. However, this is not the case for 

all recreational visitors to the HCNRA. There is ample information on the record that indicates flows of 

6,500 cfs are sufficient for smaller powerboats and float boats (Shelby et al., 2002). In fact, more skilled 

and experienced power boaters are also known to navigate large boats through the entire Snake River, 

from Hells Canyon dam to Lewiston, when Hells Canyon dam is releasing 6,500 cfs. 

As recommended in the Staff Alternative, including 237 kaf flow augmentation, there would be 40 days 

with flows below 8,500 cfs in medium water years, 120 days in medium-low water years, and 116 days in 

extremely low water years. At those times, it is incumbent on recreational boaters to take on a certain 

level of responsibility to evaluate their skill set, equipment, and accident potential as they decide where 

and how to use the recreational resource. It is not clear to us from any comment on the record why 

ensuring access to all types of boats at all times is a project responsibility, especially when the benefits 

accrue to a small number of boaters and the incremental cost of such an assurance is high (see section 

5.2.2.2, Navigation Target Flow Levels). 

Comment RR-6: NPPVA states that a significant need exists for accurate, reliable, and timely flow 

information as well as adequate minimum flow. NPPVA agrees with statements by the Corps concerning 

the Navigation Scenario and predictability of flows. 

Response: In section 3.10.2.8, Flow Information Downstream of Hells Canyon Dam, we discuss Idaho 

Power’s proposal for an Internet site and flow phone that would provide flow information sufficient to 

plan a trip in the canyon up to 4 days in advance of launching. We note, however, the discrepancies 

between the actual flows and the flows posted on Idaho Power’s Internet site. Idaho Power is not 

currently under any license obligation to maintain accuracy on the Internet site, as illustrated in NPPVA’s 

letter. If the Commission adopts this recommendation, Idaho Power would be required to maintain the site 

in a timely and accurate manner. We revised the text of the final EIS to make this point. 

Comment RR-7: Paul Poorman states that the 250,000 current visitors to the project pale in comparison 

to the number that would come if a viable salmon and steelhead fishery was restored. He states that the 

money spent on recreation facilities at the reservoirs benefits only power boaters and that the money 

would be better spent on restoring a natural river that could be enjoyed by float boaters and fishermen. 

Response: Given the important role that the project currently serves in meeting regional peak load 

demand, we determined during scoping that dam removal in order to restore the natural river was not a 

reasonable alternative. Our analysis of anadromous fish restoration measures led us to conclude that 

proceeding directly to anadromous fish upstream of the project is not viable at this time regardless of how 

many people might benefit. We note, however, that the Staff Alternative includes several measures that 

would benefit anadromous fish (and hence, fishermen) downstream of the project, including continued 

management of flows during the fall Chinook spawning and incubation season, restricting flow 

fluctuations during the fall Chinook rearing season, participation in the flow augmentation program to 

improve conditions for outmigrating smolts, and measures to improve water quality downstream of the 

project. Other measures that would improve the condition of fisheries for resident fish species and may 

foster a future decision to proceed with anadromous fish restoration include a program to enhance habitat 

conditions in key tributaries to the project, monitoring the spawning success of any surplus hatchery 

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steelhead and spring Chinook that enter Pine Creek, and monitoring to determine when water quality 

conditions upstream of the project have improved to a point that may warrant reintroduction of 

anadromous fish. 

Comment RR-8: Idaho Power states that the only portion of Idaho Power ownership at Hibbards 

Landing is up to elevation 2,085 feet msl. Idaho Power states that the Airstrip A site belongs to the 

federal government, managed by BLM. 

Response: Some of the facilities that make up Hibbards Landing are within the project boundary, thus 

we did not change the reference to Hibbard’s Landing in the final EIS. We deleted the reference to 

Airstrip A from the Executive Summary and revised draft EIS table 69 (final EIS table 77) to reflect that 

BLM owns and manages Airstrip A. 

Comment RR-9: Idaho Power states that FERC identifies boater numbers from Brown (2003) as 

estimates. Idaho Power notes that neither the Forest Service nor Idaho Power found reason to believe that 

boaters use the HCNRA without registering, and that this is a census of boaters rather than an estimate. 

Response: Based on the letters on the record, including the NPPVA’s comments on the draft EIS, 

recreational use numbers for the HCNRA vary. As such, we continue to refer to the boater numbers as an 

estimate rather than a census. We made no changes to the text of the final EIS.

Comment RR-10: Idaho Power notes that the existing project boundary (as shown in exhibit G of the 

final license application) does not include all portions of recreation areas described in table 78 of the draft 

EIS. Idaho Power states that the final EIS should reflect actual locations in relation to the project 

boundary. 

Response: Draft EIS table 78 (final EIS table 86) summarizes proposed and recommended measures 

regardless of whether they are within or outside of the current project boundary. In section 5.2.8.3, 

Boundary Modification, we conclude that any enhancement to a site that is currently outside of the project 

boundary should be included in a new boundary for the project. We did not change the in the final EIS. 

Comment RR-11: Idaho Power notes that in table 78 of the draft EIS, it appears that agency conditions 

and recommendations for Copper Creek were mistakenly placed beside the Copperfield boat launch label. 

Response: In the final EIS, we revised draft EIS table 78 (final EIS table 86) to correct this error. 

Comment RR-12: Idaho Power notes that the Forest Service has recently revised preliminary conditions 

regarding a Settlement Agreement that addresses the Deep Creek Stairway measure listed in table 78 of 

the draft EIS. Idaho Power states the final EIS should reflect the measure as written in the Forest Service 

revised preliminary conditions. 

Response: In the final EIS, we recommend that the Commission include Idaho Power’s new proposal 

and the Forest Service’s revised preliminary 4(e) condition with respect to the Deep Creek Stairway as 

part of any license issued for the project. Draft EIS table 78 (final EIS table 86) now includes the revised 

condition recommended by the Forest Service and supported by Idaho Power. . 

Comment RR-13: Idaho Power notes that Farewell Bend State Park is on the same side of the reservoir 

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as the Oasis site (Oregon), not on the opposite side as stated in the draft EIS. 

Response: We revised the description in final EIS section 3.10.2.3, Recreation Site Improvements, in the 

final EIS to clarify that Farewell Bend State Park is on the same side of Brownlee reservoir as Oasis. 

Comment RR-14: Idaho Power comments that Steck Park is located on the Idaho side of Brownlee 

reservoir. 

Response: We revised the text in section 3.10.2.3, Recreation Site Improvements, Steck Recreation Site, 

to clarify that Steck Park is not located on the Oregon side of Brownlee reservoir. 

Comment RR-15: Idaho Power comments that it is unaware of any dispersed site designated by any 

entity as “INFISH.” Idaho Power requests that FERC clarify the location of the site “INFISH.” 

Response: We removed the reference to INFISH from the text in section 3.10.2.3, Recreation Site 

Improvements, Dispersed Site Plan. 

Comment RR-16: Idaho Power comments that on page 471 of the draft EIS, paragraph 2, the section 

reference should be to 3.10.2.4 instead of 3.10.2.6. 

Response: We corrected the reference in the final EIS. 

Comment RR-17: Idaho Power comments that the trail registration card information referenced on page 

471 of the draft EIS was collected from 1998 to 2002. 

Response: We corrected the referenced collection period in section 3.10.2.6, Trails. 

Comment RR-18: Idaho Power comments that in reference to Idaho Power’s proposal related to the 

Carters Landing and Old Carters Landing sites, no modification is necessary in the Staff Alternative 

because site operation and maintenance was specified in the relevant portion of the final license 

application. 

Response: We corrected the text of section 5.1.1.2, Staff Alternative to eliminate the duplication. 

Comment RR-19: Idaho Power notes that in the adaptive management proposal in the final license 

application, the wording “recreation sites” was intended to include all recreation sites (developed or 

otherwise) and that no wording in the proposal eliminates the consideration of dispersed sites from the 

plan. 

Response: In the final license application, Idaho Power distinguished between the types of recreational 

sites, and it typically made specific reference to dispersed sites when they were discussed. The staff 

recommendation to include dispersed sites is consistent with Idaho Power’s comments and clarifies the 

scope and intent of Idaho Power’s proposal. We did not change the text of the final EIS. 

Comment RR-20: The Forest Service recommends that staff include condition no. 18, Operations and 

Maintenance, without modification or limitation in the Proposed Action in the final EIS, and that the staff 

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include additional information provided by the Forest Service in its comments. The condition would 

require Idaho Power to perform necessary operations and maintenance as described in the condition for 

Eagle Bar, Eckels, Big Bar, and Black Point Viewpoint parking areas, as well as dispersed areas on 

National Forest System lands within the project boundary. The Forest Service also notes that FERC staff 

indicates that O&M standards and Meaningful Measures are not defined by the Forest Service. The 

Forest Service states that the Meaningful Measures Guide has been filed, as described in the condition 

and recommends that information provided in Enclosure V and condition no. 18 be included without 

modification or limitation in the final EIS. 

Response: Based on new information filed by the Forest Service, and Idaho Power’s withdrawal of its 

alternative 4(e) condition, we now recommend adopting FS-18 in its entirety. In final EIS section 

3.10.2.7, Operation and Maintenance at Forest Service and BLM sites, we deleted reference to the 

alternative 4(e) condition. We deleted the exception noted in draft EIS table 98 (final EIS table 109), 

item no. 36.

Comment RR-21: The Forest Service recommends that staff include condition no. 19, Hells Canyon 

Reservoir Drawdown, without modification or limitation in the Proposed Action in the final EIS, and that 

the staff include additional information provided by the Forest Service in its comments. The condition 

would require Idaho Power to manage reservoir levels to minimize effects on recreation resources during 

the summer. The Forest Service notes that maximum drawdown during the recreation season is currently 

limited to 5 feet from full pool elevation. The Forest Service recommends that, if, for protracted periods, 

the reservoir is drawn down below 5 feet from full pool elevation, Idaho Power reconstruct or modify 

boat launching facilities to provide access to the reservoir. 

Response: With this filing, the Forest Service clarifies that the purpose of the condition is not to manage 

Hells Canyon reservoir levels, which depend on lake levels in Brownlee reservoir, but to extend boat 

ramps. Therefore, we changed our recommendation in draft EIS table 98 (final EIS table 109), item 37 

and added Boat Ramps on Hells Canyon Reservoir to final EIS section 3.10.2.3, Recreation Site 

Improvements. We find that the condition, as clarified by the Forest Service, is appropriate for developed 

recreational sites on Forest Service lands with existing or proposed boat ramps included in the Staff 

Alternative. We also recommend that Idaho Power extend boat ramps at its developed recreation site, if 

warranted and feasible. 

Comment RR-22: In reference to Forest Service condition no. 12, Recreation Management, the Forest 

Service notes that specific condition no. 12 requirements are not discussed in the draft EIS, and the Forest 

Service is unclear as to which are included in the FERC Staff Alternative measures. The Forest Service 

states that FERC staff should include each requirement and, in the final EIS, identify it as such, including 

items recommended in the condition. The Forest Service recommends that information provided in 

Enclosure V and condition no. 12 be included without modification or limitation in the final EIS. 

Response: Forest Service 4(e) condition no. 12 is very broad, concerning the planning and 

implementation of recreation, aesthetic, transportation, land use, and vegetation plans. Consequently, 

these components are handled in different sections of the EIS: section 3.10.2.2, Recreation Plan; section 

3.10.2.9, Adaptive Management; section 3.12.2.6, Road Management Plan; and section 5.3.2, Interior and 

Forest Service 4(e) Conditions. In these sections, and as summarized in section 5.0, Staff Conclusions, 

we do recommend inclusion of condition no. 12 in its entirety. We did not change the text of the final 

EIS. 

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Comment RR-23: In reference to Forest Service condition no. 13, Big Bar Development, the Forest 

Service comments that specific condition no. 13 requirements are not discussed in the draft EIS, and the 

Forest Service is unclear as to which are included in the FERC Staff Alternative measures. The Forest 

Service states that the major difference is that Forest Service approval of the site development plan is not 

required. The Forest Service recommends that the final EIS provide additional details about the review 

and comment process, including a Big Bar Development as described in condition no. 13. The Forest 

Service recommends that information provided in Enclosure V and condition no. 13 be included without 

modification or limitation in the final EIS. 

Response: We revised draft EIS table 78 (final EIS table 86) to reflect the new agreement between Idaho 

Power and the Forest Service. In the final EIS, we continue to recommend adopting FS-13 as part of any 

license issued. However, we note that the purpose of the EIS is to consider the environmental effects of a 

proposal. The consultation requirements of any license article would be developed as part of a license 

order for the project. 

Comment RR-24: In reference to Forest Service condition no. 16, Deep Creek Stairway, the Forest 

Service comments that recreation use at Deep Creek is a direct result of the project and that it is in the 

public interest to maintain a cooperative effort among Idaho Power, IDFG, and the Forest Service. The 

Forest Service states that it supports the inclusion of the Deep Creek stairway and trail in the project 

boundary. The Forest Service recommends that information provided in Enclosure V and condition no. 

16 be included without modification or limitation in the final EIS. 

Response: We concur and have revised draft EIS table 78 (final EIS table 86) to reflect the new 

agreement between Idaho Power and the Forest Service. In the final EIS, we continue to recommend 

adopting FS-16 as part of any license issued. 

Comment RR-25: In reference to Forest Service condition no. 20, Reservoir Trail Maintenance, the 

Forest Service comments that FERC staff did not include condition no. 20 in the Staff Alternative because 

staff could not find a clear nexus between the project and recreational use of Forest Service trails outside 

of the project boundary. The Forest Service states that Idaho Power, in a February 27, 2006, filing, 

provides its new analysis of trailhead surveys collected in 2006 and offers additional information about 

the portion of trails that are categorized as primarily upland hiking trails available with or without the 

project. The Forest Service notes that the agency requested a copy of the new analysis from Idaho Power, 

but that Idaho Power responded that a new analysis had not been conducted. The Forest Service notes 

that this information is not in the record. The Forest Service recommends that FERC staff analyze Forest 

Service comments indicated in condition no. 20 and that the information and condition no. 20 be included 

without modification or limitation in the final EIS. 

Response: In section 3.10.2.6, Trails, page 470 of the draft EIS, we simply repeat Idaho Power’s 

statement regarding new analysis of trailhead surveys. This sentence, which reports statements on the 

record, is not used exclusively in our analysis, which continues in the remainder of the section. On page 

472 of the draft EIS, we analyze the Forest Service’s statement that 22 percent of visitors use Forest 

Service-managed trails. This information suggests to us that a much smaller percentage of visitors to the 

project hikes along trails, while a larger percentage may walk along the reservoir or on lands within or 

immediately adjacent to the project. 

As discussed in draft EIS section 3.10.2.6, Trails, the Forest Service relies on the data from the mail 

survey that shows 28 percent of visitors to the project engage in walking. In fundamental contrast to the 

Forest Service’s conclusions from this data, Whitaker and Shelby (2003) find that“[o]ver one-quarter of 

all visitors reported walking, while 7 percent reported hiking. This suggests that most reservoir users do 

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not travel along the reservoirs by foot, but if they do so, it is to explore the immediate vicinity rather than 

travel long distances.” We continue to recommend excluding Forest Service condition no. 20 from any 

new license issued. However, we note that any license issued for the project will include all 4(e) 

conditions specified by the Forest Service. 

Comment RR-26: In reference to Forest Service condition no. 21, Hells Canyon Creek Launch Site and 

Visitor Center Facilities, the Forest Service notes a general inconsistency between FERC staff 

recommendations and items provided in condition no. 21. However, the Forest Service comments that 

the FERC staff recommendation requires potable water and a portable waste disposal system to be 

developed at the Hells Canyon Creek launch site. In contrast, condition no. 21 requires that a potable 

water/gray water disposal system be developed at Hells Canyon Creek launch site if these facilities were 

not developed at Eagle Bar, but that development of such a system at both sites is not necessary at this 

time. 

Response: It was not our intent to require potable water or a gray water disposal system at Hells Canyon 

Creek Launch site. We do not indicate in draft EIS section 3.10, Recreational Resources, that these 

facilities should be located specifically at the launch, although we recommend that Idaho Power install 

these facilities primarily because of the unique type of recreational use that occurs at the launch. We 

agree that potable water and gray water facilities are not needed at both Eagle Bar and Hells Canyon 

Creek launch site. In the draft EIS, we refer to these measures as being implemented in the Hells Canyon 

Creek area, which includes Eagle Bar, because the recreation sites are close together and a visitor must 

pass Eagle Bar to launch or take out at Hells Canyon Creek launch site. On page 640 of the draft EIS, we 

note that staff recommends adopting FS-21 as written. In the final EIS, we deleted the discussion about 

Idaho Power’s alternative 4(e) condition from section 3.10.2.3, but made no other change in this regard. 

Comment RR-27: Interior (p 53) states that the draft EIS does not illustrate the effects of the Staff 

Alternative on reservoir levels and that this information is needed to assess the effects of the Staff 

Alternative on recreation and aesthetics. 

Response: As described in section 2.1.2, Current Project Operations, section 3.3.2.2 Operational 

Recommendations and Alternative Evaluation Scenarios, and elsewhere in the draft EIS, Idaho Power 

proposes no changes to project operations that would affect lake levels in the project. The Staff 

Alternative includes flow augmentation, the release of 237 kaf of water that would result in an earlier and 

more rapid drafting of Brownlee reservoir. In draft EIS section 3.10.2.1, Effects of Project Operations on 

Recreation Resources, we discuss the effects of this measure on recreational resources. We find that flow 

augmentation would have substantial benefits to boating downstream of the project, but that it would 

adversely affect flat water boating and crappie fishing on Brownlee reservoir compared to existing 

conditions. We also disclose this adverse effect in draft EIS table 96 (final EIS table 105). In the final 

EIS, we revised section 5.2.2.3, Flow Augmentation for Anadromous Fish Juvenile Migration, to 

acknowledge this effect. 

Comment RR-28: Interior states that it supports the development and implementation of a recreation 

work group because it would be important in implementing recreation mitigation measures. Interior 

indicates that the recreation work group should be addressed in the EIS. 

Response: In the final EIS, consistent with our discussion on page 451 of the draft EIS, we continue to 

recommend including the work group as part of any license issued for the project. 

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Comment RR-29: Interior states that the draft EIS does not include a discussion of Interior’s 10(a) 

recommendation no. 8, Weiser Dunes. Interior states that Weiser Dunes provides the only access road to 

Brownlee reservoir on the Idaho side and that it experiences a high level of project-related use. Interior 

states that this recommendation should be addressed in the final EIS. 

Response: We added a section titled Weiser Dunes to 3.10.2.3, Recreation Site Improvements. Based on 

the record, including recreational use information in Brown (2002d), we do not find a nexus to the 

project. In the final EIS, we do not recommend including development and implementation of a 

recreation plan for the site as part of any license issued for the project. 

Comment RR-30: Interior states that the draft EIS does not include a discussion of Interior’s 10(a) 

recommendation no. 9, Heller Bar, noting that Heller Bar receives 15,000 to 20,000 visits annually and 

serves as a center for commercial enterprises offering jet boat trips up the Snake River to the Hells 

Canyon dam. Interior indicates that this recommendation should be addressed in the final EIS. 

Response: We discuss Interior’s recommended measures at Heller Bar in draft EIS section 3.10.2.3, 

Recreation Site Improvements, and section 5.2.7.2, Recreation Site Improvements. We do not find a 

nexus between the project and Heller Bar, pointing out that the site is more than 100 miles downstream of 

the project and that there is nothing substantiated on the record that indicates recreational use of Heller 

Bar is project related or that project operations adversely affect the site. We did not change the text in the 

final EIS. 

Comment RR-31: Interior states that the agency disagrees with the draft EIS conclusion that the 

acquisition of additional recreation lands is not justified and notes that privately owned lands currently 

being used for public recreation may become unavailable over the term of a new license. Interior states 

that it is reasonable to request that Idaho Power seek to acquire these recreation use sites from private 

land owners as they become available. Interior indicates that this recommendation (Interior 10(a) 

recommendation no. 10) should be addressed in the final EIS. 

Response: As stated in the draft EIS, Idaho Power owns important recreational and project-related lands 

within the project boundary that provide reasonable public access to project waters and have substantial 

opportunities for expansion. We expect that anticipated future recreational use of the project would be 

easily absorbed by existing facilities on project lands and point out that there are many opportunities 

through the proposed Recreation Adaptive Management Plan to formalize dispersed sites or expand 

existing sites. These facilities appear to be sufficient to provide reasonable public access to the project for 

the term of any new license. We did not change the text in the final EIS. 

Comment RR-32: Interior states that the EIS should address the potential conflict between recreation 

use, land acquisition, and special management of lands within the project boundary to benefit wildlife 

habitat and other special natural resources such as special status plants. Interior states that the EIS should 

include an analysis of the potential conflict and should include specific measures to be implemented to 

manage recreation use on special status wildlife habitat areas within the project boundary. 

Response: The Staff Alternative includes recommendations for Idaho Power to develop and implement 

plans to prevent or minimize adverse effects of project-related activities on sensitive species and habitats. 

These include the Threatened and Endangered Species Management Plan and cooperative bald eagle nest 

and roost site management plans. Protective measures would also be incorporated into the 

IWHP/WMMP, as new lands are acquired for wildlife mitigation. Idaho Power has already mapped the 

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locations of many sensitive species occurrences and habitats, transferred the data into a project GIS, used 

the information to identify sites where project facilities or activities could cause disturbance, and 

developed preliminary recommendations for managing the sites. The HCRMP incorporates this 

information as the basis for several land use designations and BMPs regarding recreation. Plans 

developed under any new license that may be issued would also build upon this existing information, and 

upon consultation with the resource management agencies and tribes. 

B14. AESTHETICS 

Comment AS-1: Idaho Power states that while no study has been done on the white band along the river 

banks, it does not appear to result from project operations and is visible in 1940s photos prior to project 

construction. Idaho Power states that FERC staff should either delete the statement or clarify that 

changes in river stages that cause the white line are not necessarily due to project operations. 

Response: In the final EIS, section 3.11.2.1, Effects of Project Operations on Aesthetics, Riverbanks 

Downstream of Hells Canyon Dam, we expanded the discussion of the white band along the river banks 

downstream of Hells Canyon dam to clarify that the degree to which the project contributes to its 

formation is unknown. 

Comment AS-2: Idaho Power states that the draft EIS presents no valid information to support the 

statement that “.. stage changes in the river as a result of project operations can affect the establishment of 

sandy beaches and alter their composition....” Analyses contained in the final license application 

(Parkinson et al., 2003) and responses to AIRs (Parkinson et al., 2005) show that sandbar slopes are not 

likely to fail under load-following operations. Idaho Power also states that it is unclear what the draft EIS 

means by “...their composition....” 

Response: The reference to the effects of stage change on sandy beaches was generalized and used to 

frame aesthetic issues downstream of hydroelectric projects. Analysis of whether stage change has 

effects on aesthetic resources of the Snake River downstream of the project is considered in subsequent 

pages of draft EIS section 3.11.2.1, Effects of Project Operations on Aesthetics, Riverbanks Downstream 

of Hells Canyon Dam, under Our Analysis. We made no changes to the final EIS text. 

Comment AS-3: Idaho Power notes that appendix H of Technical Report E. 1-1 (Parkinson et al., 2003) 

concludes that slope failure at Fish Trap Bar due to load-following operations is not expected. Two 

transects do show instability, but the report notes that the substrate along these transects is not sand and 

would thus have a higher strength (due to interlocking) than the rest of the transects. The analysis shows 

instability under flood recession; however, the discussion notes that the analysis involves very 

conservative drainage assumptions (instantaneous drawdown), and it is likely that the slopes would be 

more stable than the analysis shows if information was available to more accurately characterize drainage 

of the sandbar. 

Response: In section 3.11.2.1, Effects of Project Operations on Aesthetics, Riverbanks Downstream of 

Hells Canyon Dam, we are not primarily concerned with slope failure at Fish Trap Bar. Rather, we are 

more concerned with the ongoing aesthetic effects of project operations on beaches and riverbanks 

downstream of the project. In the final EIS, we modified the language to make this clear. 

Comment AS-4: In reference to Forest Service condition no. 22, Aesthetic Improvements to Hells 

Canyon Dam Site and Recreation Portal, the Forest Service comments that FERC staff recognizes that 

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visual enhancements must be consistent with the approved security plan. The Forest Service states that an 

implementation schedule is necessary as described in the condition no. 22. The Forest Service 

recommends that information provided in Enclosure V and condition no. 22 be included without 

modification or limitation in the final EIS. 

Response: The revised FS-22 was filed in October 2006, based on a Settlement Agreement with Idaho 

Power. The final EIS includes an analysis of the updated version of FS-22. In section 5, Staff 

Conclusions, we recommend including the proposed measure as part of any license issued for the project. 

Comment AS-5: In reference to Forest Service condition no. 24, Aesthetics Resource Management, the 

Forest Service states that on October 10, 2006, it filed condition no. 24 with the Commission and 

recommends that staff include condition no. 24 in the Proposed 

Response: Revised FS-24, which included deletion of FS-23, was filed in October 2006, based on a 

Settlement Agreement with Idaho Power. The final EIS includes analysis of the updated version of FS24. In section 5, Staff Conclusions, we recommend including the proposed measure as part of any license 

issued for the project. 

Comment AS-6: In reference to Forest Service condition no. 24, Aesthetics Resource Management, the 

Forest Service states that it disagrees with FERC staff’s conclusion in regard to E.6.4.3.1 and 2 (Design 

Standards and Guidelines for Physical Structures and Landscaping). The Forest Service states that the 

adopted measures were only broad general objectives that the Design Standards and Guidelines would be 

developed to meet. The Forest Service also states that the scope of the FERC staff recommendation is 

unclear as “certain project facilities” does not specify what facilities are to be addressed. Condition no. 

24 requires that all facilities viewed from key observation points be improved to meet a high scenic 

integrity objective to enhance the recreational experience. Further, Forest Service states that the Scenery 

Management Plan should include the seven measures found in condition no. 24 as well as the Aesthetic 

Improvement Plan, and an implementation schedule for any and all improvements as required by 

condition no. 22. The Forest Service states that this is necessary to meet the high scenic integrity 

objective in the area that is required by the Hells Canyon Comprehensive Management Plan. 

Response: The referenced discussion in draft EIS section 3.11.2.2, Aesthetic Improvements and Resource 

Management, was based on Idaho Power’s original proposal and the Forest Service’s original 4(e) 

conditions. Based on the settlement between Idaho Power and the Forest Service, we updated section 

3.11.2.2 and now recommend including FS-24 and FS-22 as part of any license issued for the project. We 

continue to recommend that a scenery management plan be prepared for the entire project. 

Comment AS-7: Interior states that the negative effect of reservoir drawdown for flood control and flow 

augmentation on recreation users is probably much greater than described in the draft EIS, and that the 

analysis should include the effects of all the operational drawdowns and their impacts on Brownlee 

reservoir during various water years. 

Response: Idaho Power conducted a comprehensive recreation study for the project that considered 

effects of project operations on recreational use. Idaho Power assessed how Brownlee reservoir levels 

affect the amount, type, and location of recreation and compared the recreational use at Brownlee 

reservoir with other reservoirs that have less daily or seasonal level changes. The results show that under 

existing conditions 2/3 to 3⁄4 of visitors to Brownlee reservoir find levels to be acceptable and the concerns 

of the remaining group are closely linked to the larger drawdowns. 

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In the draft EIS, we recommended Proposed Operations as part of the Staff Alternative. Based on new 

information, we now recommend the Flow Augmentation scenario. In draft EIS section 3.10.2.1, Effects 

of Project Operations on Recreation Resources, we state that Flow Augmentation would have the most 

substantial adverse effects on flat-water boating opportunities. In all hydrologic year types, the Flow 

Augmentation Scenario would result in an earlier and more rapid drafting of Brownlee reservoir and in 

some water years, full pool would not be reached at all during summer months. 

Under the Flow Augmentation scenario, Brownlee reservoir would be drawn down about 25 feet during 

low and medium water years. These drawdowns would typically occur in August and September. 

Although 25 feet represents a substantial drawdown, access does not appear to be substantially limited, as 

shown on draft EIS table 77 (final EIS table 85). Flow augmentation would have less of an effect 

(approximately 10 feet) during above-average water years. 

Based on the information and discussion in the draft EIS, we did not revise our analysis in the final EIS.

Comment AS-8: Interior states that the draft EIS fully recognizes the negative visual effects of reservoir 

drawdown, but that it only marginally recognizes the negative effects to all the other aspects of recreation 

experiences. Interior comments that the draft EIS does state that implementation of aesthetic 

improvements should not be left open ended but does little to set a limit on time frames for 

implementation. Interior states that aesthetic improvements should be implemented as soon as possible to 

improve the visual experience of the project area and that Interior’s 10(a) Recommendation 6, Visual 

Resource Management, should be included in the EIS and analyzed. 

Response: In draft EIS section 5.2.8.5, Aesthetic Resource Management, we conclude that a detailed 

aesthetic improvement schedule tied to Idaho Power’s scheduled maintenance program would improve 

aesthetic resources and recommend including the measure in any license issued for the project. Our 

recommendation remains the same in the final EIS.

B15. LAND MANAGEMENT AND USE 

Comment LU-1: The Forest Service recommends that staff include condition no. 26, Project Boundary 

Modification, without modification or limitation in the Proposed Action in the final EIS, and that the staff 

include additional information provided by the Forest Service in its comments. The condition would 

require Idaho Power to provide the Forest Service with a map and aerial photos depicting the approximate 

location of the project boundary and Geographic Information System (GIS) information as described in 

the condition. The Forest Service states that including the Forest Service terms and conditions without 

limitation would eliminate the need for expensive surveying and monumenting of the project boundary. 

Response: In the final EIS, the Staff Alternative and section 5.2.8.3, Boundary Modifications, 

recommend adopting the revised FS-26 as proposed by Idaho Power and specified by the Forest Service. 

In section 3.12.2, Boundary Modifications, we deleted reference to Idaho Power’s Alternative condition 

FS-26. 

Comment LU-2: Idaho Power states that the Baker County Settlement Agreement (2003) modified 

Idaho Power’s responsibilities for Homestead Road to include the entire road. 

Response: We revised the paragraph in section 5.2.8.4, Road Management Plan, to be consistent with 

the Baker County Settlement Agreement. 

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Comment LU-3: Idaho Power comments that the draft EIS reviewed preliminary and certain revised 

preliminary section 4(e) conditions filed by Interior and the Forest Service, as well as proposed alternative 

conditions filed by Idaho Power. Idaho Power states that subsequent to issuance of the draft EIS, Idaho 

Power entered into settlement agreement with the Forest Service that resulted in the filing of additional 

revised preliminary conditions and resolution of all remaining 4(e) issues with the Forest Service. Idaho 

Power states that it expects to accomplish the same objective with Interior. In view of the mandatory 

nature of such conditions and the fact that the Forest Service and Interior consider such revised conditions 

adequate for the protection and utilization of reservations that are under their respective supervision, 

Idaho Power recommends that FERC adopt the revised preliminary conditions as filed by Interior and the 

Forest Service in the final EIS. 

Response: We recommend adopting all of the Recreation, Land Use and Aesthetic measures on which 

Idaho Power and the Forest Service reached settlement following the filing of the draft EIS. These 

changes are made throughout the final EIS. We also recommend adopting most of Interior’s revised 

conditions with the exception of conditions 3 and 4. We did not recommend including these measures in 

any license issued in the draft EIS or final EIS. Interior did not file additional information that would 

justify inclusion of these measures within any license issued for the project. Therefore, we did not revise 

the text except to include the new modified language for each condition and to delete Idaho Power’s 

alternative 4(e) conditions. 

Comment LU-4: Idaho Power comments that the road running the length of Oxbow reservoir on the 

Oregon side is the Brownlee-Oxbow Road, owned and maintained by Idaho Power, not Idaho State 

Highway 71. 

Response: We made this change in the final EIS. 

Comment LU-5: Idaho Power comments that Kirkwood Ranch is not a project facility, but is owned and 

maintained by the Forest Service. 

Response: The sentence considers project-related facilities, not just facilities owned by the licensee. We 

made no change to the text of the final EIS. 

Comment LU-6: Idaho Power notes that the Hells Canyon Visitor Information Center is not a project 

facility. It is owned and managed by the Forest Service. 

Response: The sentence considers project-related facilities, including facilities owned by the licensee and 

the Forest Service. However, to clarify that the site is currently not part of the project, we changed the 

sentence in the final EIS to make this clear: 

Comment LU-7: Idaho Power comments that the implementation section on page 503 of the draft EIS 

regarding specific management plans should be modified, and offers alternative wording. 

Response: Based on the new information in the comment, we changed the subject paragraph in final EIS 

section, 3.12.2.1, Land Management, as suggested. 

Comment LU-8: Idaho Power notes that what FERC describes as a proposal for fire suppression and 

cooperation on page 507 of the draft EIS is what Idaho Power already practices. Idaho Power 

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recommends that the statement be modified, and offers alternative wording. 

Response: We adopted the alternative wording in final EIS section 3.12.2.4, Fire Protection. 

Comment LU-9: With respect to a sentence on page 511 of the draft EIS, Idaho Power states that it does 

not intend to provide information about the location of cultural resources to the public, only about 

presence and value to make people aware their actions could cause damage. Idaho Power recommends 

alternative wording to this effect. 

Response: We adopted the alternative wording in final EIS section, 3.12.2.6, Road Management Plan. 

Comment LU-10: With respect to a statement on page 511 of the draft EIS, Idaho Power notes that the 

HCRMP applies only to Idaho Power-owned lands within and adjacent to the project, and that most of the 

company’s hatcheries are located outside the project area and would not be affected by the plan. Idaho 

Power recommends alternative wording to clarify this point. 

Response: We adopted Idaho Power’s language in final EIS section 3.12.2.7, Effects of Other Measures 

on Land Management, Aquatic Resource Measures. 

Comment LU-11: Idaho Power notes that the resource management plans to be developed under Idaho 

Power’s proposal are those specifically proposed in exhibit E of the final license application and in the 

HCRMP. Idaho Power states that supplementation of the Staff Alternative should be modified to delete 

item (2), which is already defined in the HCRMP, and item (3), which is already included in the HCRMP. 

Response: This filing by Idaho Power clarifies the specific resource plans that would be developed as 

part of the HCRMP. In the final EIS, section 5.1.1.2, Staff Alternative, Land Management and Aesthetics,

we deleted item 2 from the Staff Alternative based on Idaho Power’s November 3, 2006, filing that 

clarifies which plans would be covered by the HCRMP. However, the GIS proposal is not specific 

enough to include roads, as discussed in the final EIS. Therefore, we include item 3 for the purposes of 

clarifying the condition and helping to ensure that the proposed GIS system includes a layer on road 

maintenance. We changed recommendation #72 in the final EIS accordingly. 

Comment LU-12: Idaho Power states that the meaning of supplemented measure #73 in the Staff 

Alternative (draft EIS page 541) is vague and unclear. Idaho Power states that this measure should be 

modified, and offers alternative wording to this effect. 

Response: We changed recommendation #73 in the final EIS to reflect Idaho Power’s suggested wording. 

Comment LU-13: Idaho Power comments that parts of Staff Alternative measure #22 (draft EIS page 

544) are unclear and likely to cause difficulty in interpretation and implementation. Idaho Power states 

that the measure should be modified as noted in its comment. 

Response: We adopted Idaho Power’s language and changed the recommendation in the final EIS. 

Comment LU-14: Idaho Power states that Staff Alternative measure #26 (draft EIS page 544) is already 

included in activities covered by Idaho Power measure #78 (draft EIS page 542). Idaho Power states that 

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this measure should be deleted since it may cause confusion implementing a license article. 

Response: We deleted the recommendation from the final EIS. 

Comment LU-15: Idaho Power states that while Idaho Power did not propose the measures described in 

paragraph 2, page 611 of the draft EIS, they are generally compatible with implementation commitments 

of the HCRMP. Idaho Power states that the description should be modified as noted in its 

recommendation. 

Response: We adopted Idaho Power’s language and changed the subject sentence in final EIS section 

5.2.8.1, Land Use Management. 

Comment LU-16: Idaho Power refers to policy 6.3.8.4 of the HCRMP and notes that the addition of the 

biannual timeframe with respect to law enforcement and fire protection, as recommended by FERC Staff 

on page 611 of the draft EIS, is reasonable. Idaho Power states that the final sentence should be modified 

as noted in its comments. 

Response: We adopted Idaho Power’s language and changed the last sentence in the subject paragraph in 

section 5.2.8.2, Law Enforcement and Fire Protection. 

Comment LU-17: Idaho Power comments that the Forest Service and Idaho Power have reached 

agreement on Forest Service condition no. 3 regarding fire prevention. Idaho Power states that FERC 

should adopt the language agreed upon by Idaho Power and the Forest Service, as noted in its comment. 

Response: We revised section 3.12.2.4, Fire Protection, to reflect Idaho Power’s proposed and the 

Forest Service specified fire protection measures. 

Comment LU-18: Idaho Power states that Idaho Power does not own Homestead Road, but maintains 

the referenced section. Idaho Power states that the statements should be modified to correct errors and 

incorporate the language of the Idaho Power/BLM agreement as noted in the comment. 

Response: Based on the recent settlement between Idaho Power and Interior, as well as Idaho Power’s 

recommended language, we changed the subject paragraph in final EIS section 5.2.8.4, Road 

Management Plan, as suggested. 

Comment LU-19: Idaho Power notes that in the implementation section of the HCRMP, Idaho Power 

proposes to develop a GIS atlas of critical and sensitive resources intended for the same purposes as the 

FERC Staff Alternative. Idaho Power states that the discussion should be modified as noted in its 

comment. 

Response: Idaho Power’s comments clarify the original intent of the road management measures and 

how these measures fit with the proposed GIS system to protect natural resources. To improve clarity of 

the staff recommendation and to provide continuity between Idaho Power’s comments and any new 

license, we changed the subject paragraph in final EIS section 5.2.8.4, Road Management Plan, to reflect 

Idaho Power’s suggested wording. 

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Comment LU-20: With reference to Forest Service condition no. 1, Implementation of Activities on 

National Forest System lands, and condition no. 2, Resource Coordination, the Forest Service states that 

FERC staff appear to concur with these measures; however, FERC staff limit the scope of activities to 

National Forest System lands within the project boundary. The Forest Service states that the limitation of 

the scope of these conditions is inappropriate, and recommends that the final EIS incorporate this 

information and condition no. 1 without modification or limitation in the Proposed Action in the final 

EIS. 

Response: We consider our recommended limitation of Forest Service condition nos. 1 and 2 to lands 

within the project boundary to be appropriate because Idaho Power activities covered by a new license 

would take place within the project boundary, as defined by the new license. Although we did not change 

our recommendation in the final EIS, we note that any license issued by the Commission must include the 

mandatory conditions as submitted pursuant to FPA section 4(e). 

Comment LU-21: With reference to Forest Service condition no. 3, Fire Prevention Plan, the Forest 

Service states that FERC staff direct Idaho Power to develop a Fire Prevention Plan for all lands within 

the project boundary, not just National Forest System lands, and that FERC staff exclude National Forest 

System lands adjacent to the boundary for inclusion within the Fire Prevention Plan. The Forest Service 

recommends that the final EIS incorporate condition no. 3 without modification or limitation. 

Response: In the final EIS, we continue to recommend including FS-3 as part of any license issued for 

the project. We also continue to recommend developing a Fire Prevention Plan for all lands within the 

project boundary. The plan would include measures for coordinating with other management agencies in 

the project area. However, there are many thousands of acres adjacent to the project, managed by private 

residents as well as local state and federal agencies. These lands are managed by others for purposes that 

are not project related. Therefore, we do not recommend including oversight of adjacent lands within any 

project-related fire management plan. 

B16. SOCIOECONOMICS 

Comment SO-1: NPPVA states that Enclosure II of its comment letter, the report by Forest Economics, 

has a detailed discussion of the socioeconomic effects of the project, and notes that the report highlights a 

number of problems with the analysis included in the draft EIS, including: (1) the number and size of 

boats used by each outfitter is inaccurate; (2) boats are gasoline powered as well as diesel; (3) boat trips 

and fishing outfitter business outside of the HCNRA are not included; (4) a number of contract and 

charter trips, including trips for cruise ships coming to the Port of Clarkston, were not included; (5) 

employee wages are different than indicated; (6) local boat manufacturing should be noted; (7) values 

accrued to businesses in communities north of the project are inaccurate; (8) the private boating sector is 

not included; and 9) public safety and the public interest is not given a value. NPPVA notes that the final 

EIS should contain other data sources besides Idaho Power about these subjects. 

The Chambers of Commerce from Clarkston, Washington; Lewiston, Riggins, White Bird, and 

Grangeville, Idaho; and the North Central Idaho Travel Association all note the economic dependence of 

the local area upon business and industry related to boating, especially manufacturing and tourism. They 

state that boating and related industries, as well as tourism, rely on navigable access to the Snake and 

Columbia Rivers and the Hells Canyon National Recreation Area. They also note that Lewiston and 

Clarkston are accessible as ports to sea-going craft. Each of the letters recommends that any alternative 

addressed in the final EIS include an economic impact analysis assessing project effects on boating and 

tourism for this region. All of the organizations state their support for the 8,500-cfs minimum flow 

recommendation outlined in the Corps’ January 26, 2006, letter to FERC. 

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Response: As defined in Scoping Documents 1 and 2, the focus of the socioeconomic assessment was 

narrowly defined. Specifically, we agreed to focus the socioeconomic section on the effects of changes in 

current project operations on local governments, power users, and commercial enterprises. We note that 

Idaho Power’s proposed 6,500-cfs minimum flow is the same minimum flow that Idaho Power adhered to 

in practice since 1980, with the exception of following the Corps’ recommended 8,500-cfs minimum flow 

from August 2004 through July 2006. Thus, the proposed 6,500-cfs minimum flow is the same as the 

flow that prevailed since 1980 and would not be expected to have a major effect on commercial boating. 

We also note that many of the commenter’s statements are actually related to Idaho Power’s response to 

the Corps-recommended minimum flow, where Idaho Power relies on economic analysis from CRA 

International. The comments are not related to the EIS, which does not use the CRA International study. 

Comment SO-2: Charles McKetta and Dan Green of Forest Economics, Inc, under contract to NPPVA, 

evaluated economic analyses and reasoning by Idaho Power for reduction of minimum summer flow rates 

below the 8,000 to 9,000 cfs minimum recommended by the Corp of Engineers. As part of their broader 

critique of Idaho Power’s comments, they cite two broad areas of critique for the analysis included in the 

draft EIS: 

1. Environmental and Recreation Values—McKetta and Green state that lower summer flows 

coupled with increased ramping rate fluctuation produces several negative downstream 

effects, including higher water temperatures, beach erosion, concentration of pollutants, 

variable DO concentration, shifts of aquatic habitat, unpalatable smells, reduced aesthetics, 

poor fishing, dangerous conditions for swimming, reduced access to upstream terrestrial 

recreation, and hazards or difficulties for boat and raft navigation. They state that some of 

these were discussed in terms of the technical issues, but they were not translated into 

economic values associated with changes in wilderness, environmental, or recreation 

quality. 

2. Economic Effects of Navigation Safety—McKetta and Green state that public safety is a 

prime consideration and that the economic effects on navigation caused by flow rate 

reduction are inadequately treated in the draft EIS. They also note that accident data in the 

draft EIS are focused on commercial vessels, which they state may be less than 5 percent of 

total incidents. They state that the economic cost of reduced safety should include higher 

insurance fees, higher maintenance and repair costs, reduced recreation opportunity, lower 

quality of experience, the value of loss of human life and time, and the increased liability 

litigation costs to both users and flow regulators associated with low flows. 

Response: McKetta and Green make a number of arguments against our approach to the developmental 

analysis and the socioeconomic analysis in the draft EIS. As noted in their comments, the EIS considers 

and describes numerous environmental effects associated with licensing the project. These environmental 

effects are discussed throughout the document and provide a basis for balancing competing environmental 

resource needs in the context of the need for reliable and safe electricity generation. However, we do not 

conduct comprehensive cost-benefit analysis using contingent valuation or other means to assign dollar 

values to all of the direct and indirect environmental measures. Such an analysis tends to create 

controversy and muddy the environmental review rather than improve the basis of the staff 

recommendation to the Commission. 

We also note that all of McKetta and Green’s arguments are based on a faulty assumption about the 

environmental and economic baseline for our environmental review; their report assumes that the 

proposed minimum flow differs dramatically from existing conditions and would, therefore, lead to a 

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marginal and measurable change in recreational use of the Snake River downstream of the project. As 

stated on page 19 and elsewhere in their analysis: “The limited relicensing issue that we address is 

focused only on the economics of allowing lower summer minimum flows” (page 19). However, with the 

specific exceptions noted below, Idaho Power has essentially operated the project to meet a minimum 

flow of 6,500 cfs since 1980. Thus, current navigational use of the river developed largely during a 

period when the de facto minimum flow was 6,500 cfs. 

As described in draft EIS section 3.3.1.3 Navigation, in September 1988, the Corps and Idaho Power 

agreed to maintain a minimum flow of 6,500 cfs downstream of Hells Canyon dam (compared to the 

5,000 cfs in the current license). Inflow is passed when flows are below 6,500 cfs. In 2001 and 2002, 

Idaho Power, in conjunction with the Corps and the Northwest Professional Power Vessel Association 

(NPPVA), began providing timed releases of 8,500 cfs below Hells Canyon dam, while still maintaining a 

floor of 6,500 cfs. Because of flow attenuation and lag times between locations below Hells Canyon dam, 

these timed release flows had limited utility and were discontinued. Later from August 2004 through July 

2006, Idaho Power provided a minimum flow of 8,500 cfs. Currently, Idaho Power continues to use the 

6,500 cfs minimum flow as it has in most past years, and its proposal does not differ from conditions that 

prevailed in most years since 1980. NPPVA’s comment letter on the draft EIS includes flow data from 

Hells Canyon dam that demonstrates this point. 

As noted above, the commercial power boating industry on the Snake River has developed, in part, as a 

result of prevailing project operations. To the degree that prevailing conditions would continue in the 

future, there is no reason to assume that Idaho Power’s minimum flow recommendation would adversely 

affect the existing commercial industry. 

With regard to McKetta and Green’s discussion on navigational safety, we agree that a higher minimum 

flow would improve boating safety. In final EIS section 3.3.2.7, Downstream Flows Important to 

Navigation, as well as section 5.2.2.2, Navigation Target Flow Levels, we find that the Corpsrecommended navigation flow scenario would decrease the number of days when flows drop below 6,500 

cfs. However, as discussed further in our response to NPPVA, the commercial boating industry has 

developed around existing conditions and it is not the responsibility of the licensee to eliminate this risk 

for all types of boats at all times of the year. 

Comment SO-3: The Nez Perce Tribe states that the socioeconomic analysis is critically flawed 

because: (1) it does not consider how project-created impacts to treaty-reserved resources affect the 

social, cultural, and economic welfare of the Nez Perce Tribe; and (2) it is limited to the four counties of 

the project area, although the impacts extend both farther downstream and upstream. The Nez Perce 

Tribe states that the final EIS should expand the socioeconomic analysis to include the Zone 6 fishery in 

the Columbia River. 

The Shoshone-Paiute Tribes state that only reservoir-based recreation was addressed in the draft EIS, and 

that the economic impact of restored subsistence, commercial and recreational fishing was not. 

Interior states that the significance of the reservoir fishery is demonstrated through the data provided 

regarding angler hours. The draft EIS on page 177 shows the combined angler hours for the reservoir use 

at 610,000 above the Hells Canyon dam (459,654 at Brownlee, 71,145 at Oxbow, 85,907 at Hells 

Canyon) and 183,000 below the Hells Canyon dam. Interior states that the EIS should include an analysis 

of the social and economic impacts related to recreational fishing and that information presented by 

Interior should be used to estimate the local and regional values for recreation fishing directed at the Hells 

Canyon reservoirs in the EIS. Interior recommends that estimates for the net benefit of improved or 

maintained fisheries to the local economy be developed and included in the EIS for all of the alternatives 

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and displayed for comparison of their relative contribution to the overall benefits of the Project. Interior 

comments that the contributions and economic value of recreational fishing produced in the Hells Canyon 

reservoirs under present and future conditions should be included as part of the comparison of alternatives 

in the EIS. 

Interior recommends that estimates of the net benefit of improved or restored fisheries to the local 

economy be developed and included in the EIS for all of the alternatives and displayed for comparison of 

their relative contribution to the overall benefits of the project. Interior recommends that the commercial, 

tribal, and sport fisheries including salmon, steelhead and lamprey be included, extending to the lower 

Columbia River and Pacific Ocean fisheries from Oregon northward to Washington, British Columbia 

and Alaska. Interior comments that the contributions and economic value of anadromous fish produced in 

the Snake River basin under present and restored conditions should be included as part of the comparison 

of alternatives in the EIS. 

Similarly, the Shoshone-Paiute Tribes state that the economic value and other values of anadromous 

fishes produced in the Snake River basin and its tributaries under present and restored conditions needs to 

be analyzed and included as part of the comparison of alternatives in the final EIS. Further, the tribes 

state that the benefits of restored anadromous fish runs to the tribes must be included in this analysis. 

The Nez Perce Tribe comments that the geographic scope should include the Lower Columbia River 

where the Nez Perce and other CRITFC tribes harvest fall Chinook salmon affected by the Hells Canyon 

Project and steelhead and should span the North Pacific coast to southeast Alaska. The Nez Perce 

comment that the socioeconomic impacts on harvest should be analyzed for each of the draft EIS 

alternatives. 

Interior states that the EIS should discuss and display a reasonable economic analysis of the value of 

restored anadromous fisheries to commercial fishing interests in the Columbia River and Pacific Ocean. 

These include both Indian and non-Indian commercial fisheries for white sturgeon as well. Interior also 

states that the EIS should include an analysis for the net local and regional economic value of restored 

fish and wildlife resources in comparison to the net local and regional economic value of the power 

produced by the project. 

Response: As defined in Scoping Documents 1 and 2, the focus of the socioeconomic assessment was 

narrowly defined. Specifically, we agreed to focus the socioeconomic section on the effects of changes in 

current project operations on local governments, power users, and commercial enterprises. The 

restoration of subsistence, commercial, and recreational fishing was not part of any of the alternatives 

considered and is not recommended by staff. Therefore, we did not include an assessment of this issue in 

the socioeconomic analysis. Because effects on commercial fishing interests and fall Chinook salmon 

and steelhead in the lower Columbia River and as far away as southeast Alaska are influenced by many 

factors unrelated to the Hells Canyon Project, an economic analysis of those factors would be far beyond 

the scope of this relicensing process. 

Comment SO-4: P. Brian Rogers states that the Idaho Power dams on the Snake River have destroyed 

anadromous fish runs, and requests that FERC generate a formal assessment of the economic benefits of 

restoring sport fishing in the Hells Canyon area and the effects of the relative timing of water flow rates 

and water quality on fisheries. 

Beverly Ferrell states that there has been a diminution of local revenue caused by decreased salmon 

fisheries in Washington and Adams counties, Idaho, and requests that Idaho Power counterbalance this 

related loss of local economic base. She states that Washington and Adams counties are paying a hidden 

cost for supporting production of cheap electricity for other areas. 

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The Shoshone-Paiute Tribes note that the economic and social needs of tribes are adversely affected by 

the Hells Canyon project, and that fish passage has to be provided for the tribes to access anadromous 

fishing resources. 

Response: We use existing conditions as our baseline for comparison with Idaho Power’s Proposal and 

the Staff Alternative, and to judge the benefits and costs of any measures that might be required under a 

new license. The removal of anadromous fish upstream of the Hells Canyon dam represents pre-project 

conditions and, therefore, we did not include it as part of our environmental review. 

Comment SO-5: The Pioneer and Settlers Irrigation Districts and the Payette River Water Users 

Association, Inc., comment that existing water rights for flow and storage related to irrigation could be 

affected by mitigation required of Idaho Power. They state that irrigators and ratepayers have already 

paid for hatcheries built and operated by Idaho Power and consider further payment for reintroduction of 

anadromous fish species above Brownlee dam to be redundant. 

Response: As discussed in draft EIS section 3.13, Socioeconomic Resources, we recognize that the cost 

of the staff-recommended measures is large, although the impact on rates appears to be very small. In 

final EIS section 5.0, Staff’s Conclusion, we continue to find that the Staff Alternative appropriately 

balances power production with environmental resource protection and enhancement. 

Comment SO-6: The Shoshone-Paiute Tribes state that FERC analyzed socioeconomic impacts of the 

project on Adams, Washington, Baker, and Wallowa counties and did not address economic impacts 

outside of those four counties, thereby excluding the tribes from the economic analysis. 

Response: In draft EIS section 3.13.2.5, Effects on Minority and Low-income Communities and Indian 

Tribes, we discuss the effects of the Staff Alternative on Native American communities, consistent with 

the scope outlined in the Scoping Document. In the final EIS, we include two new sections specifically 

addressing project effects on the tribes: 3.13.1.5, Native American Tribes, and 3.13.2.4, Effects on Native 

Americans. Nonetheless, in the final EIS, we continue to find that, given existing conditions, licensing 

the project with the staff-recommended measures would represent an improvement in aquatic resources, 

with the goal of improving returns of salmonids to and above the Hells Canyon project. 

Comment SO-7: The Shoshone-Bannock Tribes state that by examining only the cost to Idaho Power 

associated with environmental restoration measures, FERC staff does not quantify or take into account 

economic benefits to others. 

Response: The purpose of section 3.13, Socioeconomic Resources, is primarily to qualitatively describe 

the effects of licensing the project. In that section we discuss some of the positive and negative effects of 

the proposed and recommended measures on socioeconomic resources in the region. 

Comment SO-8: Interior points out that the draft EIS states that certain market and non-market values 

would accrue to the project from completion of aquatic mitigation measures. Interior states that terrestrial 

mitigation measures would have similar positive and measurable effects on regional and local economies. 

Interior recommends that the EIS contain a full economic analysis that includes completion of Interior’s 

10(j) and section 18 recommendations, including non-power costs and benefits for the term of the new 

license issued for the project. 

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Response: The information on the record is not detailed enough to conduct a full economic analysis of all 

proposed and recommended measures. As such, any quantitative economic analysis, as Interior 

recommends, would be speculative at best. Nonetheless, we acknowledge that some environmental 

measures would contribute positively to socioeconomic resources in the region even while reducing the 

project’s net power benefits. As it relates to the Staff Alternative’s benefits to wildlife and the 

socioeconomic values that would accrue from improved wildlife, we recognize and discuss those benefits 

in draft EIS section 3.13.2.3, Effects on Commercial Enterprises. We note that draft EIS table 90 (final 

EIS table 99) shows that the socioeconomic benefits of hunting and wildlife viewing are very small 

compared to other recreational uses. We made no changes to the final EIS in this regard. 

B17. OVERSIGHT AND ADAPTIVE MANAGEMENT 

Comment AM-1: The Umatilla Tribes comment that the NEPA document should examine the benefits 

of establishing an aquatic resources committee, comprised of interested tribes, resource agencies, and 

Idaho Power, to undertake adaptive management studies and actions during the full term of the new 

license. 

Interior recommends that the Staff Alternative include the establishment of a Technical Advisory 

Committee to oversee implementation activities for mitigation measures. Interior also recommends that 

the NEPA document include a more detailed description of the adaptive management program, including: 

(1) objectives; (2) coordination; (3) process; (4) dispute resolution; (5) organization and responsibility; (6) 

timeline for actions; (7) triggers for alternative action if results are not met (i.e., ESA, CWA, new listings, 

etc.); (8) funding and budget. 

Response: The Staff Alternative includes establishment of a technical advisory committee and various 

resource-specific subcommittees. Our analysis of this concept appears in draft EIS section 3.12.2.1, Land 

Use Management, and our recommendation for the Staff Alternative appears in section 5.2.8.1, Land Use 

Management. Our recommendation has not changed in the final EIS. 

B18. DEVELOPMENTAL ANALYSIS 

Comment DA-1: AR/IRU state that FERC does not explain how cost estimates were arrived at for 

implementing recommended measures or provide documentation to support estimates and that FERC’s 

cost estimate is greater than that of Idaho Power. AR/IRU recommend that FERC provide justification 

for how costs and benefits of mitigation were determined. 

Response: Staff developed cost estimates based on the applicant’s cost estimates, similar mitigation 

measures at other Commission licensed projects, and our professional experience. Based on our 

independent review and on comments by other parties, we sometimes recommend additional mitigation 

beyond that proposed by the applicant. In that case, staff cost estimates are generally higher than costs 

estimated by Idaho Power. We note that extensive appendices were provided for the draft EIS to 

document our estimated costs, and they also appear in the final EIS as well. Information about capital 

costs and annual operations and maintenance costs were provided in appendices E and F of the draft EIS. 

Because the level of detail we provided in the draft EIS is appropriate for its intended use, we did not 

change our basic approach in the Developmental Analysis section of the final EIS.

Comment DA-2: Idaho Power comments that the value for dependable capacity of $114 (sic) per MW 

per year is a FERC staff number provided in the mid-Snake River project final EIS and used by Idaho 

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Power in its analysis. The Corps states that the dollar value of dependable capacity used in the draft EIS 

appears to be high, resulting in overstated power impacts for the navigation measure. 

The Corps comments that the draft EIS provides no explanation of why the power impacts analysis was 

based on a capacity replacement cost of $114,000/MW per year rather than on the simple-cycle 

combustion turbine (CT) value of $73,700/MW per year provided by Idaho Power. The Corps 

recommends that the power impacts analysis for all proposed future operating scenarios be recalculated 

based on the $73,700/MW per year cost. 

Response: Our use of the $114,000 per MW value of dependable capacity is based on both capital and 

fixed and operations and maintenance costs associated with a combined cycle combustion turbine. We 

note that Idaho Power did use this figure in its additional information response, and did not propose any 

different estimate at that time. Our reason for using this value is that the plant factors for the Brownlee, 

Oxbow, and Hells Canyon developments are 53.3 percent, 66.7 percent, and 67.6 percent, respectively, 

which are more consistent with combined cycle combustion turbines than with simple cycle combustion 

turbines that operate at much lower plant factors. For comparison purposes, we include in the final EIS a 

sensitivity analysis of the potentially lower effects on benefits associated with simple cycle combustion 

turbines ($73,700/MW) for staff-recommended measures. 

Comment DA-3: Idaho Power states that AIR DR-4 is incorrectly referenced as Bowling and Whittaker 

(2005) and, instead, should be referenced as Idaho Power (2005). 

Response: We corrected the reference as suggested by Idaho Power and added the complete citation to 

the Literature Cited section of the final EIS. 

Comment DA-4: NPPVA states that for replacement of load following capacity lost to navigation, there 

are less costly alternatives to a 100-MW gas-fired plant. NPPVA also states that the costs shown in table 

93 of the draft EIS are apparently based on modeling for July 1994 and that instead should be based on 

real world operations that would indicate a much lower cost of navigation flows. 

Response: We do not recommend a 100 MW replacement plant, but rather the percentage of such a plant 

corresponding to the lost dependable capacity. NPPVA does not suggest what other alternatives might be 

cheaper yet equivalent to combined cycle combustion turbines. Gas-fired generation is generally the most 

economical replacement power available under current economic conditions. Combined cycle 

combustion turbines are consistent with load factors cited by Idaho Power for the project. Our values are 

based on Commission data derived from actual capital and fixed operations and maintenance costs 

associated with combustion turbines. 

In its November 2006 comments on the draft EIS, Idaho Power reiterates that 1994 dry year conditions 

correspond to the criteria used in its least-cost planning efforts and that hydro capacity lost under that 

approach must be replaced by other sources to meet capacity and reliability objectives. It is appropriate to 

base dependable capacity on below-normal hydrologic conditions and to do so in a manner consistent 

with the utility’s least cost plan. With respect to using July 1994 modeled conditions rather than actual 

operations data in draft EIS table 93 (final EIS table 102), we note that actual historical releases during 

1994 do not necessarily correspond to present day or future effects on dependable capacity under similar 

conditions. Because Idaho Power loads have increased over time, it is likely that the project would be 

operated more aggressively to maximize on-peak generation during the most critical hour of the day. 

Thus, we conclude that modeled conditions provide an acceptable basis for our evaluation of capacity 

impacts. 

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Comment DA-5: The Corps comments that conclusions in the draft EIS concerning impacts on power 

generation are not supported by the data presented for the navigation scenario. The Corps notes that no 

specific data or methods are provided to show how the MW reduction in dependable capacity is 

calculated for each alternative, if the overall impact is reasonable, or if it is calculated consistently among 

alternatives. The Corps states that it is unclear how FERC estimated the values stated in scenario 2, or if 

it is appropriate to use a simple scaling approach. The Corps states that it is also unclear how FERC 

determined impacts for the flow augmentation measure in table 93 of the draft EIS. The Corps notes that 

costs of the combined ramping rate flow augmentation measures indicated in the Staff Alternative may be 

inconsistent and result in an underestimation of cost and an overstatement of the impact on navigation. 

The Corps recommends FERC explain in more detail how the dependable capacity estimates and 

corresponding power costs were developed. 

Response: In the Developmental Analysis section of the draft EIS, we used the modeling and economic 

evaluation results for each power generation scenario that were provided by Idaho Power in various 

filings with the Commission. For a complete description of Idaho Power’s methods, we refer the Corps to 

several specific filings, including Idaho Power’s February 2005 response to the Commission’s AIR DR-3, 

Parts (a) and (b) (Power Economics) and AIR OP-1 (Operational Scenarios), as well as a correction filed 

on June 22, 2005. A description of the dependable capacity methodology is provided on pages 3 and 4 of 

the DR-3 response. On pages 12-16 of the DR-3 response, Idaho Power provided a series of answers to 

staff questions about the economic analysis; this additional information may further clarify the 

methodology for the Corps. 

The dependable capacity estimates presented in the draft EIS are based on the fixed replacement costs 

using combustion turbines. The higher figure of $114,000 is based on combined cycle combustion 

turbines, while the lower figure of $73,700 is based on simple cycle combustion turbines. Fixed costs 

include both the fixed operations and maintenance costs as well as amortized capital costs. We continue 

to conclude that the cost associated with combined cycle combustion turbines is the appropriate cost to 

use in our analysis and allows us to assess economic impacts in a consistent manner. For informational 

purposes, we added an estimate of impacts based on the lower-cost single cycle combustion turbines in 

footnotes to draft EIS tables 93 and 94 (final EIS tables 102 and 103). 

Based on information related to additional scenarios provided by Idaho Power in its comments on the 

draft EIS and in response to our Additional Information Request, our computations of economic impacts 

associated with operational measures are more consistent in the final EIS than the analysis we presented 

in the draft EIS. Given the results of additional model runs by Idaho Power, we were able to drop the 

scaling approach and use actual modeled results to assess the effects of ramping rate changes, flow 

augmentation, and both in combination. That information is reflected in final EIS section 4.0, 

Developmental Analysis. As shown in final EIS table 102, we continue to conclude that providing a 

minimum flow of 8,500 cfs for navigation is a very expensive measure, and we do not include the 

navigation flow in the Staff Alternative except in medium-high and extremely high water years, which 

would not negatively affect dependable capacity. 

Comment DA-6: Interior states that the draft EIS lacks a description of methods and criteria used to 

analyze the financial feasibility of individual measures and of how costs and benefits were assessed 

against overall economics of the project. 

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benefit basis. Instead, we estimate costs for each measure based on estimates from Idaho Power, other 

parties, and our own experience. Additionally, if a measure affects operations, we assess the effect on 

project power benefits based on alternative power costs. As shown in draft EIS table 95 (final EIS table 

104), the overall economics of the project alternatives are summarized in terms of annual costs, power 

benefits, and net benefits. We explain our procedures in section 4.3, Comparison of Alternatives. We did 

not change our methods or description in the final EIS. 

Comment DA-7: Paul Poorman states that the EIS provides no balance between low cost energy and 

environmental protection. He comments that Idaho Power rates are among the lowest in the country, and 

that higher power rates would encourage conservation, justify the use of more renewable energy resources 

such as solar and wind, and lead to more widespread use of energy efficient bulbs and appliances. He 

further states that increased electricity costs would not devastate the economy, but that much economic 

activity would result from efforts to reduce consumption. 

Response: We acknowledge that Idaho Power’s rates are low compared to other regions of the country. 

Nonetheless, this does not mean that the Commission should alter its approach to balancing the need for 

power and environmental protection. For the final EIS, we revised some of our conclusions based on new 

information provided by commenters on the draft EIS. The Staff Alternative presented in the final EIS 

includes several environmental measures in addition to those included in the draft EIS, and we conclude 

that it provides an appropriate balance between low cost power and environmental protection. 

Comment DA-8: Idaho Power notes that comments were provided with respect to the tables in section 4, 

Developmental Analysis, to FERC staff via conference call on September 25, 2006, and that this 

communication is included on the FERC record. 

Response: We incorporated Idaho Power’s comments and made appropriate changes in our final EIS. 

Comment DA-9: Interior states that the cost of the terrestrial mitigation package does not appear to 

include land acquisition costs that were previously estimated by Idaho Power, and that those costs should 

be included in the EIS. 

Response: Idaho Power updated its terrestrial costs in its March 13, 2007, submittal to FERC in response 

to our additional information request. Further clarification was provided in its March 20, 2007, filing. 

These updated costs are included in final EIS appendix H. 

Comment DA-10: Interior states that the EIS needs to clarify whether new CHEOPS runs were done by 

the Commission and Idaho Power to show new results for AIR OP-1 alternatives with the flow 

compliance point downstream at Johnson Bar rather than 1 mile downstream of Hells Canyon dam, as 

specified in AIR OP-1. Interior also states that the EIS should contain an analysis of all the AIR OP-1 

alternatives receiving equal consideration using consistent evaluation criteria so that comparisons are not 

skewed by flow and economic data that use variable or poorly described constraints. 

Response: The CHEOPS Model is a proprietary model, as described on page 527 of the draft EIS, so 

only Idaho Power can make new runs. Idaho Power conducted new runs combining flow augmentation 

and navigation for normal, dry, and very dry years and summarized the results on page 22 of its 

November 2006 comments on the draft EIS. 

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We conclude that project operating constraints are adequately addressed in appendix C of the draft EIS. 

Tables 6 and 7 of appendix C of the draft EIS show that compliance for the runs of concern was measured 

at Hells Canyon rather than at Johnson Bar. We did not modify the format of our tables in the final EIS. 

We do note, however, that we made a typographic error in draft EIS table 93 (final EIS table 102). The 

estimated decrease in benefits for the 4-inch-per-hour ramping rate is based on compliance downstream of 

Hells Canyon dam rather than at Johnson Bar. We corrected this in the final EIS and modified the costs 

in accordance with Idaho Power’s March 30, 2007, response to our additional information request.

Comment DA-11: EPA notes that the draft EIS concludes that “the potential benefits of installing a 

temperature control structure at Brownlee dam would not be worth the cost” (page 566). EPA is 

concerned that, other than a footnote that presents a wide range of potential costs ($3.9 million to $28 

million annually) for construction and operation of a temperature control structure, there is no further 

analysis in the draft EIS to support the conclusion that a temperature control structure is not economically 

feasible. Given the potential benefits of a temperature control structure, EPA recommends that this issue 

be examined more fully in the final EIS. 

Response: As indicated in the referenced footnote, which provides the cost for each of the three 

alternative temperature control structures evaluated in detail, the estimated costs of the temperature 

control structures evaluated vary widely. 

In comments on the draft EIS, EPA, the Umatilla Tribes, and Nez Perce Tribe indicated that there may be 

benefits to foregoing releases of cool water in the summer to reserve cool water for release in the fall. 

Idaho Power conducted studies to evaluate potential summer/fall cooling and spring warming from a 

temperature control structure. The extent of cooling in the fall depends on the amount of coolwater 

reserves used in the summer. To better understand potential benefits from a temperature control structure, 

we amended our recommendation for a Temperature Management Plan to include additional evaluation of 

the potential benefits to fall Chinook salmon that could result from a temperature control structure 

operated to cool Hells Canyon dam releases during the first month of spawning and warm releases in 

early to mid-spring. We revised final EIS section 5.2.3.2, Water Temperature Measures, to incorporate 

this change. 

Comment DA-12: Interior recommends that the Commission assess the economics of an alternative that 

includes installing a small generator at Oxbow dam to provide sufficient flows for bull trout habitat. 

Response: In the final EIS, we include in the Staff Alternative a recommendation that Idaho Power 

investigate energy recovery associated with providing instream flows in the Oxbow bypass reach. 

Because instream flows are yet to be finalized, it is premature to conduct such an analysis at this time. 

Comment DA-13: Idaho Power comments that although FERC’s annualized cost estimate for various 

PM&E measures exceeds preliminary numbers provided in the final license application, Idaho Power 

believes they are too low. Idaho Power provides a table showing re-calculated costs and explains the 

basis for these changes. 

Response: We revised the cost estimate in section 4.0, Developmental Analysis, based on information 

provided by Idaho Power in its comments on the draft EIS, as well as information provided in its April 

19, 2007, and April 30, 2007, filings with the Commission. 

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B19. CONSISTENCY WITH COMPREHENSIVE PLANS 

Comment CP-1: Interior lists four comprehensive plans accepted by the Commission that were omitted 

from the list of comprehensive plans applicable to the project, and states that the EIS should include those 

four plans. 

Response: We revised the text in section 5.4.1, Section 10(a)(2) Comprehensive Plans, to include the 

four plans mentioned by Interior. 

B20. RELATIONSHIP OF LICENSE PROCESS TO LAWS AND POLICIES 

Comment LP-1: NMFS states that it remains committed to working with FERC or its designated nonfederal representative to develop a proposed action that would avoid jeopardy and adverse modification of 

critical habitat. NMFS also states that if FERC chooses to rely on the draft EIS as its biological 

assessment, then a supplemental draft EIS is appropriate because there would be substantive changes to 

the proposed action and analysis of effects. 

Response: We revised our analysis and incorporated a number of changes in the Staff Alternative that 

will further contribute to the protection of listed species, as well as the protection and restoration of 

habitat for the listed species. 

Comment LP-2: NMFS comments that the Staff Alternative is indefinite because there are a number of 

possible significant changes to the proposed action. These include changes in the state 401 water quality 

certification, changes due to the outcome of the 10(j) meeting, and changes due to the inclusion of 

modified mandatory conditions. NMFS states that each of these has the potential to change the proposed 

action significantly relative to NMFS’s analysis of jeopardy and adverse modification of critical habitat. 

Furthermore, NMFS expresses concern that the provision to re-evaluate the benefits of flow augmentation 

in 2009 introduces uncertainty about whether this measure would be continued after 2009. In summary, 

NMFS states that it does not consider the draft EIS to be adequate for use as a biological assessment 

because it does not provide: (1) a sufficiently defined proposed action; (2) an adequate analysis of the 

effects of the action on listed species, including cumulative effects; or (3) an adequate analysis of 

alternative actions considered by the action agency. 

Response: Several events have helped us to clarify and define the proposed action in the final EIS. First, 

we deferred the re-evaluation of flow augmentation from 2009 to 2015 and specified that we would 

consult with NMFS and Interior on the need to reinitiate consultation if a change to the flow 

augmentation program is proposed. Second, we completed the process of considering information that 

was exchanged during the 10(j) process, and as a result of that process have revised some elements of the 

Staff Alternative to be more consistent with the agency 10(j) recommendations. Finally, we reviewed the 

measures that Idaho Power included in its revised application for Section 401 water quality certification, 

and incorporated these measures in the Staff Alternative. Together, these changes substantially reduce the 

uncertainties about which NMFS expresses concern. 

We find our analysis to be adequate with respect to effects on listed species. We evaluated the full scope 

of the recommended terms and conditions that were received and provided a sufficient description of past, 

present and future cumulative effects. In cases where draft EIS comments identified information or 

analysis that would improve the document, we incorporated this information or analysis into the final EIS. 

We were not able to identify a separate agency alternative that would encompass the full scope of 

measures recommended by the different stakeholders, so we adopted our standard approach of evaluating 

the full range of recommended measures and combining the measures that stood on their merits into a 

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comprehensive Staff Alternative to contrast with Idaho Power’s licensing proposal. 

Comment LP-3: The Shoshone-Bannock Tribes comment that the draft EIS analysis of effects 

pertaining to blocked access for fall Chinook and steelhead are identical, and should provide more detail. 

Response: We expanded the text in final EIS section 3.8.2, Environmental Effects on Threatened and 

Endangered Species, to provide greater detail on the effects of blocked access to habitat on anadromous 

fish species. 

Comment LP-4: The Shoshone-Bannock Tribes comment that: (1) the Staff Alternative would continue 

to adversely modify critical habitat for fall Chinook, due to its adoption of unreasonably high ramping 

rates; and (2) FERC’s reliance on cost-benefit analyses to reject measures designed to benefit ESA-listed 

species does not comply with its obligation to take necessary measures to protect ESA-listed fish stocks. 

The tribes also state that the draft EIS contains inadequate analysis of the cumulative effects associated 

with other Columbia River basin hydropower projects, the cumulative impacts that will result from 

relicensing the Hells Canyon Project, and of ways to mitigate for cumulative impacts. 

Response: The Staff Alternative includes sufficient measures to prevent the adverse modification of fall 

Chinook critical habitat downstream from Hells Canyon dam. These measures include: (1) 

implementation of a 4-inch ramping rate during the fall Chinook rearing period; (2) development and 

implementation of adaptive management plans to monitor and address any adverse effects from stranding 

and entrapment or on invertebrate production; (3) continued management of flows to benefit spawning 

and incubation of fall Chinook salmon; (4) continued monitoring of the quantity and condition of 

spawning habitat and the implementation of gravel augmentation if warranted; (5) measures to augment 

DO and reduce gas supersaturation; and (6) water releases from Brownlee reservoir to benefit the 

migration of juvenile fall Chinook salmon. In addition, measures directed toward providing immediate 

benefits to bull trout would contribute to the long-term goal of restoring steelhead and spring Chinook 

salmon to areas upstream of the project. These include tributary habitat improvements in five tributary 

basins and the implementation of fish passage measures, starting in Pine Creek. Many of these measures 

would not be supported by a strict cost-benefit analysis, but were adopted as part of the Staff Alternative 

based on their benefits to ESA-listed species or to address the cumulative effects of Idaho Power’s Snake 

River projects on anadromous fish species and on other aquatic species that are of cultural importance to 

the tribes. 

Comment LP-5: NMFS states that FERC staff relied on Idaho Power’s model results to assess the 

effects of different project operations on water quality, flow, and the aquatic resources downstream of 

Hells Canyon Project. However, NMFS states that the draft EIS does not include an analysis of the 

effects of the Staff Alternative on downstream aquatic resources. 

Response: At the time that we developed additional information requests for the project, we were in the 

position of having to forecast what operational alternatives would eventually emerge from the relicensing. 

We used our best judgment and requested modeling runs for 6 scenarios and 6 sub-scenarios in AIR OP1. After recommended terms and conditions were filed, we found that the scenarios that we requested, 

while they did not precisely match all of the terms and conditions that were recommended by the 

stakeholders, effectively bracketed these terms and conditions. This allowed us to assess the relative 

benefits and costs of the individual operational recommendations, which we then combined into a Staff 

Alternative. In our view, the modeling results that we provide in the final EIS are sufficient to support the 

development of appropriate license conditions, particularly given that the Staff Alternative provides for 

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adaptive management based on monitoring results. 

Comment LP-6: NMFS comments that the draft EIS failed to provide any assessment of the impacts of 

habitat loss for the remaining portions of the ESUs. NMFS comments that it provided summaries of key 

Technical Recovery Team products in its January 24, 2006, filing, yet FERC ignored this information. 

NMFS states that these summaries are especially pertinent for Snake River fall Chinook salmon, which 

now comprise a single remaining population (the other two populations were extirpated by the project and 

Idaho Power’s Swan Falls dam). NMFS notes that this information, along with a detailed list of citations, 

should assist FERC in its assessment of any impact of habitat loss. 

Response: We expanded the text in final EIS section 3.8.2, Environmental Effects on Threatened and 

Endangered Species, to include this information.

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Document Accession #: 20070831-4002 Filed Date: 08/31/2007
APPENDIX C

MANDATORY CONDITIONS 

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FOREST SERVICE SECTION 4(E) CONDITIONS 

TERMS AND CONDITIONS 

License articles contained in the Federal Energy Regulatory Commission’s (Commission) 

Standard Form L-1 issued by Order No. 540, dated October 31, 1975, cover those general requirements 

that the Secretary of Agriculture, acting by and through the USDA Forest Service, considers necessary for 

adequate protection and utilization of the land and related resources of the Payette and Wallowa-Whitman 

National Forests. Under authority of section 4(e) of the Federal Power Act (16 U.S.C. 797(e)), the 

following terms and conditions are deemed necessary for adequate protection and utilization of National 

Forest System (NFS) lands and resources. These terms and conditions are based on those resources 

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, 

including the Hells Canyon National Recreation Area Act and 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 

Resources Management Plans prepared in accordance with the National Forest Management Act. 

Therefore, pursuant to section 4(e) of the Federal Power Act, the following conditions covering specific 

requirements for protection and utilization of the NFS lands shall also be included in any license issued 

for the Hells Canyon Complex Hydroelectric Project (Project). 

Condition No. 1—Implementation of Activities on National Forest System Lands 

The Licensee shall not commence implementation of habitat or ground-disturbing activities on 

National Forest System (NFS) lands until the USDA Forest Service has approved site-specific project 

designs and issued a notice to proceed. 

Additional NFS Lands 

If additional NFS lands are included within the Project boundary, the Licensee shall obtain a 

special-use authorization for occupancy and use of NFS lands added to the Project area boundary from the 

USDA Forest Service. Within six months of License issuance and before any habitat or grounddisturbing activities, the Licensee shall obtain from the USDA Forest Service and file with the 

Commission a special-use authorization for occupancy and use of NFS lands added to the Project area 

boundary in the License. 

Additional lands authorized for use by the Licensee in a new special-use authorization shall be 

subject to laws, rules, and regulations applicable to the NFS. The terms and conditions of the USDA 

Forest Service special-use authorization are enforceable by the USDA Forest Service under the laws, 

rules, and regulations applicable to the NFS. The special-use authorization shall also be subject to 

applicable sanctions and enforcement procedures of the Commission at the request of the USDA Forest 

Service. Should additional NFS lands be needed for this Project over the License term, the special-use 

authorization shall be amended to include any additional NFS lands. 

Approval of Changes on NFS Lands after License Issuance 

Notwithstanding any License authorization to make changes to the Project, the Licensee shall 

receive written approval from the USDA Forest Service prior to making changes in the location of any 

constructed Project features or facilities on NFS lands, or in the uses of Project land and waters on NFS 

lands, or any departure from the requirements of any approved exhibits for Project facilities located on 

NFS lands filed by the Licensee with the Commission. Following receipt of such approval from the 

USDA Forest Service, and at least 60 days prior to initiating any such changes or departure, the Licensee 

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shall file a report with the Commission describing the changes, the reasons for the changes, and showing 

the approval of the USDA Forest Service for such changes. The Licensee shall file an exact copy of the 

report with the USDA Forest Service at the time it is filed with the Commission. 

Coordination with Other Authorized Uses on NFS Lands 

In the event that portions of the Project area are under federal authorization for other activities 

and permitted uses, the Licensee shall consult with the USDA Forest Service to coordinate such activity 

with authorized uses before starting any activity on NFS land that the USDA Forest Service determines 

may affect another authorized activity. 

Site-Specific Plans 

The Licensee shall prepare site-specific plans subject to review and approval by the USDA Forest 

Service for habitat and ground-disturbing activities on NFS lands required by the License, including 

activities contained within resource management plans required by the License prepared subsequent to 

License issuance. The Licensee shall prepare site-specific plans for activities one year in advance of 

implementation dates required by the License. 

Site-specific plans shall include: 

1. A map depicting the location of the proposed activity and GPS coordinates. 

2. A description of the USDA Forest Service land management area designation for the location 

of the proposed activity and applicable standards and guidelines. 

3. A description of alternative locations, designs and mitigation measures considered including 

erosion control and implementation and effectiveness monitoring designed to meet applicable 

standards and guidelines. 

4. Draft biological evaluations or assessments including survey data as required by regulations 

applicable to habitat or ground-disturbing activities on NFS lands in existence at the time the 

plan is prepared. 

5. An environmental analysis of the proposed action consistent with USDA Forest Service 

National Environmental Policy Act (NEPA) policy in existence at the time the plan is 

prepared for FERC licensed projects on NFS lands. 

Cost Reimbursement 

The Licensee shall provide funding to the USDA Forest Service for all costs associated with the 

analysis, review, inspection, and monitoring required for implementing habitat and ground-disturbing 

activities on NFS lands required by the License, including activities contained within resource 

management plans required by the License prepared subsequent to License issuance. Funding for the 

analysis, review, inspection, and monitoring of site-specific projects on NFS lands required by the 

License shall be through the use of a Collection Agreement or other instrument consistent with USDA 

Forest Service regulations in effect at the time the project is proposed and shall be executed by the 

Licensee and the Payette National Forest and/or the Wallowa-Whitman National Forest, as appropriate. 

Condition No. 2—Resource Coordination 

Within one year of License issuance, the Licensee shall, in consultation with and approval by the 

USDA Forest Service, prepare a Resource Coordination Plan (RCP) and file the plan with the 

Commission for approval. The RCP shall establish a process for information exchange and coordinate 

efforts for implementation of License conditions and ongoing Project operations and maintenance (O&M) 

activities impacting NFS lands. The RCP shall provide for coordination of the implementation of the 

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various management plans required under the License to the extent they impact NFS lands, such as but 

not limited to: visual resource management, cultural resource management, integrated weed management, 

aquatic plant management, fish and wildlife management, sensitive species management, recreation 

resource management, monitoring, erosion control and other resource protection plans. The RCP plan 

shall require the Licensee to: 

1. Consult with the USDA Forest Service each year during the 60 days preceding the 

anniversary of the License, or as agreed to by USDA Forest Service, to evaluate the past 

year’s activities and develop a proposed implementation schedule for the upcoming year’s 

activities and measures required by the License for NFS lands. Within 60 days following 

such consultation, the Licensee shall file with the Commission evidence of the consultation 

with any recommendations made by the USDA Forest Service. 

2. Document the requirements, tasks and methods and reports related to monitoring the effects 

of Project operations and facilities on natural and/or social resources and effectiveness of 

protection, mitigation, and enhancement measures where the monitoring is required by 

USDA Forest Service terms and conditions. 

3. Provide a mechanism for revising implementation strategies and methods to reflect 

improvement in sampling procedures and/or changes in regulations or environmental 

conditions. 

4. Identify practices for record keeping and annual reporting. 

5. Include provisions for the routine updating of the RCP, including incorporation of monitoring 

measures identified in site-specific plans prepared under the requirements of USDA Forest 

Service Condition No. 1 (Implementation of Activities on NFS lands). 

6. Develop a field manual identifying standard operating procedures, including cultural resource 

identification and reporting procedures that the Licensee and its contractors shall follow 

while conducting activities on NFS lands. 

7. Develop a process to resolve disagreements regarding the implementation of the RCP. 

8. Designate an Environmental Coordinator to coordinate the implementation of the RCP and 

Licensee activities with the USDA Forest Service. 

Condition No. 3 – Fire Prevention Plan 

Within one year of License issuance, the Licensee shall, in consultation with and approval by the 

USDA Forest Service and in consultation with appropriate State and local fire agencies, prepare a Fire 

Prevention Plan for NFS lands within the Project boundary and NFS lands adjacent to the Project 

boundary that are impacted by the Project and file the plan with the Commission for approval. The Fire 

Prevention Plan shall require the Licensee to: 

1. Analyze fire prevention needs to ensure that prevention equipment and personnel are 

available. 

2. Identify fire hazard reduction measures (e.g., eliminating ladder fuels, reducing fuel loading). 

3. Provide the USDA Forest Service a list of the location of available fire prevention equipment 

and the location and availability of fire prevention personnel. 

Condition No. 4—Sandbar Maintenance and Restoration 

For the purposes of restoring and maintaining 14 acres of sandbars on or adjacent to NFS lands 

between Hells Canyon Dam and the confluence of the Snake and Salmon Rivers that may be affected by 

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the existence and/or operation of the HCC over the term of the new license (including any annual licenses 

issued thereafter), the Licensee shall establish a Mitigation Fund for use by USDA Forest Service to fund 

restoration and maintenance activities, which may include: 

1. Development of a list of sites to be maintained, and a list of sites to be restored through 

managed sand supply based on the inventory of existing sandbars and potential restoration 

sites (Term and Condition Exhibit 1 attached hereto). 

2. Restoration efforts by supplying sand to establish sufficient depth over designated areas 

between appropriate flow elevations. Maintenance will be implemented when average sand 

depths on treated sandbars fall below established criteria. 

3. Distribution of sand on National Forest System lands above appropriate flow elevation 

contours to minimize annual sand loss attributable to ordinary high water. 

4. Monitoring of existing sandbars and restoration areas on a five-year interval to evaluate 

whether maintenance and restoration objectives are being met. 

Fund Administration 

The Licensee shall, in a fiduciary capacity with the USDA Forest Service as the beneficiary, 

establish and maintain an independent interest-bearing account for the purpose of funding mitigation and 

enhancement projects undertaken pursuant to this Condition. The financial institution where the interestbearing account shall be established must be insured by the Federal Deposit Insurance Corporation 

(FDIC) and the terms of the escrow agreement shall be approved in advance by the USDA Forest Service, 

Chief Financial Officer. The Fund’s principal shall be invested in interest-bearing securities of the U.S. 

Treasury. The Licensee shall bear the cost of all reasonable administrative, legal, and overhead costs 

associated with the management of the account and shall not assess any such costs against the account or 

against the USDA Forest Service. The USDA Forest Service will designate an official with the authority 

to direct payment to the USDA Forest Service for specific project work in furtherance of the purposes of 

the Fund. The account shall be administered at the sole discretion of the USDA Forest Service. The 

Licensee and the USDA Forest Service will collaborate on development of public information to 

communicate the benefits of the projects being completed under this Fund. 

Quarterly Reports 

The financial institution shall provide quarterly reports, at a minimum, to the USDA Forest 

Service Chief Financial Officer, showing account activity during the period, the amounts of principal and 

interest income. 

Annual Reports 

The Licensee shall submit to FERC and the USDA Forest Service, Chief Financial Officer 

written annual reports that reflect the amounts of payments deposited into and disbursed from the Fund. 

On each anniversary of the Mitigation Fund’s establishment, and every year thereafter, the Licensee shall 

provide an annual independent audit of the Fund and submit the results of the audit to the USDA Forest 

Service, Chief Financial Officer. The USDA Forest Service will provide information to the Licensee 

annually concerning how funds have been expended in furtherance of the purposes of the Fund. 

Timing and Schedule of the Licensee’s Contributions to the Fund 

Within one year of the order issuing the new license, the Licensee shall establish the Mitigation 

Fund and shall contribute $937,000.00 annually (in 2006 dollars adjusted for inflation in accordance with 

Exhibit 2 attached hereto) to the Fund for the first 10 years of the license. The USDA Forest Service may 

begin to draw from the Fund on the date of the first anniversary of the new license. The Licensee shall be 

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responsible for no further contributions to the Fund. The contributions shall be nonrefundable, except 

that any balance resulting from the Licensee’s contributions, including any accrued interest, remaining in 

the Fund on the date that the next license order for the Project is issued shall be returned to the Licensee. 

A final independent audit of the Fund shall be made by the Licensee to determine the final principal and 

interest remaining in the Fund to be returned to the Licensee. Based on the results of the audit, USDA 

Forest Service shall make the final disbursement to the Licensee. 

Condition No. 5—Integrated Wildlife Habitat Program and Wildlife Mitigation and 

Management Plan 

Within one year of License issuance, the Licensee shall, in coordination with the USDA Forest 

Service, prepare an Integrated Wildlife Habitat Program (IWHP) and Wildlife Mitigation and 

Management Plan (WMMP) as defined in FERC AIR TR-1, for lands within the Project boundary and 

NFS lands adjacent to the Project boundary that are impacted by the Project, and file the plan with the 

Commission for approval. The goal of the IWHP and WMMP is to specify programmatic and 

stewardship goals and measurable objectives, policies, guidelines and administrative procedures, 

including monitoring and adaptive management that provide terrestrial and botanical resource protection, 

mitigation and enhancement measures to lands as described above. The Licensee shall be responsible to 

implement the IWMP and WMMP. In addition to incorporating all USDA Forest Service terrestrial and 

botanical conditions approved by FERC, the IWMP and WMMP shall require the Licensee to: 

1. Develop and implement a monitoring program to estimate the status and trends of the 

terrestrial habitats being managed and determine whether management practices support 

those resources goals or should be changed. The monitoring program shall include a process 

to establish baseline biological conditions for the resources that will be managed and 

monitored. 

2. Develop and implement an adaptive management process, including protocols and schedules 

to monitor implementation and effectiveness of the terrestrial and botanical resource 

protection, mitigation and enhancement measures, and adapt implementation measures as 

needed to meet resource-specific goals and objectives. Adaptive management shall be based 

on periodic monitoring cycles tailored to each resource objective related to a specific 

mitigation or management action. 

3. The IWHP and WMMP shall be prepared in coordination with the USDA Forest Service. 

The Licensee shall include with the plans documentation of coordination, copies of comments 

and recommendations on the completed plans after it has been prepared and provided to the 

USDA Forest Service, and specific descriptions of how the USDA Forest Service comments 

are addressed by the plans. The Licensee shall allow a minimum of 60 days for the USDA 

Forest Service to comment and to make recommendations prior to filing the plans with the 

Commission for approval. If the Licensee does not adopt a recommendation, the filing shall 

include the Licensee's reasons, based on Project-specific information. 

Condition No. 6—Land Acquisition and Management Plan 

Within one year of License issuance, the Licensee shall in coordination with the USDA Forest 

Service prepare a Land Acquisition and Management Plan (LAMP) that shall be incorporated into the 

Licensee’s Integrated Wildlife Habitat Program (IWMP) and Wildlife Mitigation and Management Plan 

(WMMP) and file the LAMP with the Commission for approval. 

1. The purpose of the LAMP is to describe the Licensee’s land acquisition and management 

of habitat mitigation parcels as described in the FLA, FERC’s AIR TR-1 and other License 

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conditions. The LAMP shall include but not be limited to the following elements: Program 

goals and objectives (TR-1 Sections 1.2: #1) 

a. Parcel and conservation easement acquisition criteria (TR-1 Appendix 1) and/or new 

criteria developed by the IWMP Work Group (TR-1) 

b. Implementation schedule for land (habitat) acquisition and improvement (TR-1 Sections 

1.2: #4) 

c. Desired habitat conditions (TR-1 Sections 1.2: #2) 

d. Comprehensive best management practices and programs (TR-1 Sections 1.2: #6) 

e. Priorities and procedures for habitat restoration of parcels in degraded condition (TR-1 

Sections 1.2: #4) 

f. Priorities and procedures for maintaining functioning habitat on the acquired parcels (TR-1 

Sections 1.2: #4) 

g. Procedures for effectiveness monitoring in determining whether the desired habitat 

conditions and trends are being achieved (TR-1 Sections 1.2: #7) 

h. Apply adaptive management practices when objectives and trends are not achieved (TR-1 

Sections 1.2: #9) 

i. Provision for the program’s periodic review and revision, as necessary (TR-1 Sections 1.2: 

#11) 

2. The LAMP shall be prepared in coordination with the USDA Forest Service. The Licensee 

shall include with the LAMP documentation of coordination, copies of comments and 

recommendations on the completed LAMP after it has been prepared and provided to the 

USDA Forest Service, and specific descriptions of how the USDA Forest Service 

comments are addressed by the plan. The Licensee shall allow a minimum of 60 days for 

the USDA Forest Service to comment and to make recommendations prior to filing the 

LAMP with the Commission for approval. If the Licensee does not adopt a 

recommendation, the filing shall include the Licensee's reasons, based on Project-specific 

information. 

3. The Licensee shall acquire 56.3 acres of riparian habitat to mitigate continuing Project 

impacts to riparian vegetation on the Snake River below Hells Canyon dam. The Licensee 

shall include the above riparian habitat mitigation into its land acquisition program. 

4. Within two years of License issuance, the Licensee shall, in coordination with the USDA 

Forest Service, assess the shoreline erosion sites identified in the FLA, Technical Report 

E.3.2-42 and, where warranted and feasible, design and install control measures to correct 

active shoreline erosion problems at its source, including planting the sites with native 

riparian vegetation, maintaining the control measures in a functioning condition and 

monitor control measure effectiveness. For those sites were control measures are deemed 

infeasible, the acreage of these sites shall be added to the Licensee’s riparian acquisition 

program. In addition, the Licensee shall survey for new shoreline erosion sites every 5 

years, and implement control measures when deemed warranted and feasible. 

Condition No. 7—Exotic and Invasive Vegetative Management 

Within one year of License issuance, the Licensee shall prepare and implement a cooperative 

Integrated Weed Management Plan (IWMP) for the prevention, suppression, containment, endeavor to 

eradication and control of invasive non-native plant species, including noxious weeds in and adjacent to 

the Project area. The intent of this plan is to enhance and promote the coordinated management of 

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noxious weeds with entities responsible for weed management in Hells Canyon. The plan includes the 

following: 

1. The IWMP shall be developed cooperatively with a Licensee established Noxious Weed 

Advisory Board. The Board shall be comprised of entities responsible for weed 

management, including the USDA Forest Service. The Licensee shall include provisions to 

update the plan in 5 year intervals to keep the plan contemporary with new weed 

management science and practices. 

2. The IWMP shall require the Licensee to (FLA E.3.3.3.2.1.2 pages E.3-690 & E.3-691): 

a. Develop communication and coordination protocols for the Licensee and the Noxious 

Weed Advisory Board members, including: 

1) Defining participants roles and responsibilities 

2) Schedules for annual reports and work plan, meeting, review and updates 

b. Define the geographic scope of the plan’s implementation efforts 

c. Identify noxious weed management goals and objectives 

d. Develop weed species and habitat overview/descriptions 

1) Location description/mapping of populations using Geographic Information Systems 

2) Current site (habitat) condition 

3) Data gap; identify and implement needed site-specific surveys and methodology, as 

appropriate 

e. Create the Hells Canyon Cooperative Weed Management Area (CWMA) 

f. Describe the desired conditions 

g. Make recommendations for site-specific management consistent with federal state and 

county laws and regulations 

h. Schedule for periodic inventory using common inventory and mapping protocols 

i. Develop Best Management Practices (BMP) that pertain to all ground disturbing projects 

and proactive prevention measures to stop new infestations, consistent with Federal and 

State initiatives 

j. Develop and implement an effectiveness monitoring program 

k. Modify practices when objectives and trends are not achieved 

3. The IWMP shall be prepared in coordination with the USDA Forest Service. The Licensee 

shall include with the plan documentation of coordination, copies of comments and 

recommendations on the completed IWMP after it has been prepared and provided to the 

USDA Forest Service, and specific descriptions of how the USDA Forest Service 

comments are addressed by the IWMP. The Licensee shall allow a minimum of 60 days 

for the USDA Forest Service to comment and to make recommendations prior to filing the 

IWMP with the Commission for approval. If the Licensee does not adopt a 

recommendation, the filing shall include the Licensee's reasons, based on Project-specific 

information. 

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Condition No. 8—Terrestrial Threatened and Endangered Species 

Within one year of License issuance, the Licensee shall, in coordination with the USDA Forest 

Service, and USFWS, if appropriate, prepare a Threatened and Endangered Species Management and 

Monitoring Strategy for the long-term protection, management and enhancement of Threatened and 

Endangered species and their habitats on NFS lands affected by the Project. The strategy shall be 

incorporated into the WMMP and filed with Commission for approval. The strategy shall address those 

measures required by the USFWS as a result of consultation under the Endangered Species Act (ESA) for 

the protection, management, enhancement, and monitoring of Threatened and Endangered species and 

their habitats. 

The USDA Forest Service shall be provided the opportunity to participate in the ESA 

consultation process. To the extent that any such measures shall be implemented on NFS lands, the 

Licensee shall coordinate with the USDA Forest Service on such implementation. 

Condition No. 9—Sensitive Species Management 

Within one year of License issuance, the Licensee shall, in coordination with the USDA Forest 

Service prepare a Sensitive Species Management Plan (SSMP) that shall be incorporated into the WMMP 

and filed with the Commission for approval. The goal of the WMMP is to provide for the protection, 

management, enhancement and monitoring of currently identified and any new (per paragraph 1 below) 

Sensitive species and their habitat on NFS lands affected by the Project. The SSMP shall require the 

Licensee to: 

1. In consultation with USDA Forest Service, conduct additional Sensitive species surveys 

when new species are listed on the Regional Forester Sensitive Species list that are known 

to exist in the Hells Canyon Project area. When there are Project-related activities that may 

have an impact on the newly listed species or their habitat, surveys will be conducted. The 

Licensee shall prepare a draft biological evaluation for Regional Forester Sensitive Species 

as per USDA Forest Service Condition No. 1 Implementation of Activities on National 

Forest System lands. 

2. Conduct monitoring every two years for all Sensitive confirmed sites for the first six years 

of the License term and at three-year intervals thereafter to determine habitat condition and 

trend. The need for continued monitoring will be evaluated after year six of the new 

License term. 

3. Protect and/or restore Sensitive sites/habitats that are declining in condition, as a result of 

Project-related impacts, as determined through monitoring as set out in paragraph 2 above. 

4. Update the Sensitive Species Management Plan to address revisions to the Regional 

Forester sensitive species list over the License term. 

Condition No.10—Mountain Quail Habitat Enhancement 

The Licensee shall implement the Mountain Quail Habitat Enhancement program proposed in the 

Final License Application (FLA, 2003). Measures proposed for NFS lands shall be subject to Condition 

No. 1 Implementation of Activities on National Forest System lands. 

Condition No. 11—Transmission Line Management 

Within one year of License issuance, the Licensee shall, in consultation with and approval by the 

USDA Forest Service, develop a transmission line operation and maintenance plan which shall be 

incorporated into the WHMMP and filed with the Commission for approval. The goal of the plan is to 

provide communication and coordination between the Licensee and the USDA Forest Service in 

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implementing, monitoring, and adapting all resource specific restoration, protection, and management 

actions associated with the transmission line occupying NFS lands. 

Condition No. 12—Recreation Management 

Within one year of License issuance, the Licensee shall finalize the Hells Canyon Complex 

Comprehensive Recreation Management Plan (Recreation Plan) and file the Recreation Plan with the 

Commission for approval. The Recreation Plan shall be inclusive of appropriate License requirements 

and also address Project-related recreation resources located on NFS lands within the existing Project 

boundary or as otherwise ordered by the Commission. The Recreation Plan shall include provisions for 

adaptive management to address changing recreation needs and preferences and shall be updated as 

appropriate every six years in conjunction with filing the Commission Form 80. The Licensee shall 

implement the Recreation Plan. 

The Recreation Plan shall be prepared in coordination with the USDA Forest Service and other 

appropriate entities. The Licensee shall include with the Recreation Plan documentation of coordination, 

copies of comments and recommendations on the completed Recreation Plan after it has been prepared 

and provided to the USDA Forest Service, and specific descriptions of how the USDA Forest Service 

comments are addressed by the Recreation Plan. The Licensee shall allow a minimum of 60 days for the 

USDA Forest Service to comment and to make recommendations prior to filing the Recreation Plan with 

the Commission for approval. If the Licensee does not adopt a recommendation, the filing shall include 

the Licensee's reasons, based on Project-specific information. 

The Recreation Plan shall include an annual implementation schedule, consultation, and approval 

procedures and include: 

1. Measures to adequately address USDA Forest Service resource concerns and standards of 

quality (e.g. Meaningful Measures) throughout the License term. 

2. The following measures proposed by the Licensee in the Draft Recreation Plan (FLA, 

2003): 

a. Litter and Sanitation Plan (E.5.4.3.1, E.5.4.4.1.2) 

b. Public Safety Program (E.5.4.3.1.2) 

c. Local Law Enforcement (E.5.4.3.1.3, E.5.4.4.1.4) 

d. Road Maintenance (E.5.4.3.1.4, E.5.4.4.1.6) 

e. Boat Moorage on HCC Reservoirs (E.5.4.4.1.1) 

f. Information and Education (I&E) Plan (E.5.4.4.1.3) 

g. Recreation Adaptive Management Plan (E.5.4.4.1.5) 

h. Performance of Operation and Maintenance at Applicant-Enhanced BLM and USFS 

Reservoir-Related Recreation Sites (E.5.4.4.1.7) 

i. Enhancement of Eagle Bar Dispersed Recreation Site (E.5.4.4.2.1) 

j. Development of Site Plan for Big Bar Recreation Site (E.5.4.4.2.1) 

k Enhancement of Boat Ramp and Associated Facilities at Big Bar Recreation Site 

(E.5.4.4.2.2) 

l. Development of Site Plan and Enhancement of Eckels Creek Dispersed Recreation 

Site (E.5.4.4.2.4) 

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3 The Licensee shall implement the Comprehensive Road Management Plan proposed in the 

FLA as it pertains to NFS lands to meet the existing standards, designs and operations and 

maintenance plan guidelines established in the Hells Canyon Scenic Byway Management 

Plan (USFS, 1993). The Licensee shall maintain Hells Canyon Dam (HCD) Road for safe 

and reasonable use by the public including access to Hells Canyon Creek Visitor Center, 

parking lot, and boat launch and also including dispersed parking between the HCD and the 

visitor center. 

4 To address adaptive management the Licensee shall: 

a. Develop a comprehensive recreation monitoring plan that includes evaluation of 

recreation use, preferences and trends 

b. Report recreation use information to the USDA Forest Service and other interested 

entities as it becomes available, including annual reporting of use occurring at 

Licensee fee parks 

c. Coordinate with the USDA Forest Service to establish trigger points that indicate a 

need for additional development or improvements at USDA FS sites identified in the 

Recreation Plan 

d. Provide for appropriate expansion of existing recreation facilities or development of 

new Project related recreation facilities and for other recreational opportunities on 

NFS lands commensurately with Project-related use pursuant to the Recreation Plan 

5. The Licensee shall develop and implement a Vegetation Management Plan for all 

developed sites on NFS lands identified in the Recreation Plan. The Vegetation 

Management Plan shall include a schedule and procedures for maintenance, including 

planting, fertilizing, mulching, watering, thinning, staking, mowing, trimming, spraying 

and/or weeding, etc., for each developed site. 

6. The Licensee shall every six years in conjunction with FERC Form 80 requirements 

conduct visitor satisfaction surveys in the HCC. Details of the survey content and 

implementation will be coordinated with the USDA Forest Service and other applicable 

entities to ensure that the level of detail and applicability of information is consistent with 

previous surveys and analysis. When practicable these surveys should endeavor to 

duplicate the survey protocols developed by Whittaker and Shelby, 2002, and presented in 

the Licensee’s Technical Report E.5-4, FLA 2003) during the first survey periods. 

Condition No. 13—Big Bar 

Within three years of License issuance the Licensee shall, in coordination with the USDA Forest 

Service, develop a site development plan for the Big Bar Recreation Area (Big Bar Development Plan, 

BBDP) and file the plan with the Commission for approval. The BBDP shall address specific facility 

elements needed at Big Bar Section C as well as possible future expansion opportunities on other sections 

of Big Bar that shall be addressed as part of the adaptive management component of the Comprehensive 

Recreation Management Plan. The BBDP shall include a site plan, design drawings; detailed erosion and 

sediment control measures, and a schedule for implementation and maintenance. 

The Licensee shall include with the BBDP documentation of coordination, copies of comments 

and recommendations on the completed site plan after it has been prepared and provided to the USDA 

Forest Service, and specific descriptions of how the USDA Forest Service comments are addressed by the 

site plan. The Licensee shall allow a minimum of 60 days for the USDA Forest Service to comment and 

to make recommendations prior to filing the BBDP with the Commission for approval. If the Licensee 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
C-11 

does not adopt a recommendation, the filing shall include the Licensee's reasons, based on Projectspecific information. 

The BBDP shall require the Licensee to develop a campground facility on the southern portion of 

Big Bar Section C within five years of License issuance. The campground shall be development level “3” 

which is characterized by moderate site modification with design of improvements generally based on use 

of native materials. (FSM 2300, 2330) Primary development at Big Bar shall include, but not be limited 

to, approximately 15 to 20 universal campsites with parking spurs, picnic tables and fire rings, centrally 

located vault toilets, potable water, hardened access roads, xeric landscaping and meeting accessibility 

(ADA) requirements. The Licensee shall be responsible for all costs associated with the campground 

development. 

The Licensee shall perform O&M at this facility as described in Condition No. 18 (See O&M 

Condition.) 

Condition No. 14—Eagle Bar 

Within three years of License issuance, the Licensee shall implement the site plan proposed in the 

draft Recreation Plan (FLA 2003), for Eagle Bar. Elements of the site plan include reconstructing the 

boat ramp, designating parking for boat ramp use and trailhead access, designating campsites with picnic 

shelters and fire rings, constructing a vault toilet, constructing a fishing pier using ADA guidelines and 

standards, and providing potable water. 

The Licensee shall perform O&M at this facility as described in Condition No. 18 (See O&M 

Condition.) 

Condition No. 15—Eckels Creek 

Within three years of License issuance the Licensee shall implement the site plan proposed in the 

draft Recreation Plan (FLA 2003), for the Eckels Creek Dispersed Site. Designated sites shall be 

established to limit resource damage to the site, and shall be delineated using boulders and other natural 

features. The site shall be graveled and contain two to three single unit picnic/camp sites. Sites shall 

include one fire ring each (ADA) and one table each (ADA). A single-vault toilet shall be installed near 

the roadside that can be used by both overnight campers and by trail users parking to access Eckels Creek 

trail across the road. 

The Licensee shall perform O&M at this facility as described in Condition No. 18 (See O&M 

Condition.) 

Condition No. 16—Deep Creek Stairway 

Within one year of License issuance, the USDA Forest Service shall complete a condition and 

safety inspection of Deep Creek Stairway/Trail #218. Upon completion of the safety inspection, the 

Licensee, USDA Forest Service and Idaho Department of Fish and Game shall coordinate and mutually 

agree upon measures to correct any deficiencies noted in the inspection. The Licensee shall implement 

the measures identified within two years of License issuance. 

The Licensee, in coordination with the USDA Forest Service shall develop an O&M Plan and 

implementation schedule which provides for O&M and replacement as necessary at this facility. The 

Licensee shall not be required to assume the ownership of the Stairway/Trail Structure. 

If repairing the Stairway/Trail appears to be economically unfeasible, other alternatives for access 

to Deep Creek will be explored with the Licensee, USDA Forest Service and Idaho Department of Fish 

and Game. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
C-12 

Condition No. 17—Parking Areas 

Within two years of License issuance, the Licensee shall develop or improve and maintain 

parking and signing at four USDA Forest Service roadside parking areas along the Hells Canyon 

Reservoir. The parking areas are located adjacent to the paved Hells Canyon Road that connects Oxbow 

and Hells Canyon Dam. The four locations are Allison Creek, Kinney Creek, Eckels Creek, and Deep 

Creek. The improvement work includes developing surfaced parking lots large enough for two to four 

vehicles and providing information/interpretive signing. 

The Licensee shall perform O&M at this facility as described in Condition No. 18 (See O&M 

Condition.) 

Within five years of License issuance, the Licensee shall replace the toilet at Deep Creek. 

Condition No. 18—Operations and Maintenance 

For the term of the License, the Licensee shall perform the Operations and Maintenance 

necessary to meet USDA Forest Service Standards, Meaningful Measures as amended over the License 

term for Eagle Bar, Eckels, Big Bar, parking areas along Hells Canyon Reservoir, Black Point Viewpoint, 

and dispersed areas on NFS lands within the project boundary pursuant to the Recreation Plan. 

Condition No. 19—Hells Canyon Reservoir Drawdown 

For the term of the License, the Licensee shall manage reservoir levels to minimize impacts on 

recreation resources during the summer. Maximum draw down during the recreation season is presently 

limited to five feet from full pool elevation. If, based on operational modifications ordered by the 

Commission or system emergencies, the reservoir is drawn down for protracted periods below five feet 

from full pool elevation, the Licensee shall reconstruct or modify boat launching facilities to provide 

access to the reservoir. 

Condition No. 20—Reservoir Trail Maintenance 

Within one year of License issuance and over the remaining term of the License, the Licensee 

shall perform trail maintenance for the USDA Forest Service trails as shown in the table below. 

USDA Forest Service Trails to be Maintained by Idaho Power 

Trail Name Beginning at Ending at 

Deep Creek Trail to Oxbow Creek (Trail # 219) Eagle Bar Deep Creek 

Kinney Creek Trail (Trail # 221) Road 545 Junction of Trail 222 

Mid-Slope Trail (Trail # 222) Junction of Trail 221 Eckels Creek 

Eckels Creek Trail (Trail # 223) Road 545 Junction of Trail 222 

Allison Creek Trail (Trail # 514) Road 545 Junction of Trail 222 

Stud Creek Trail (Trail # 1781) Hells Canyon Creek Stud Creek 

McGraw Creek Trail Loop (Trail #1879) Junction of Trail #1890 Junction of Trails #1884 

Bench Trail to McGraw Creek Trail Junction 

(Trail #1884) 

Junction of Trail #1879 Milepost 2 

HC Reservoir Trail to Leep Creek (Trail # 1890) Copper Creek TH Leep Creek 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
C-13 

The Licensee shall maintain the trails according to Forest Service standards (Trail and 

Specification Handbook EM7720.103 specifications for trails) or as otherwise mutually agreed upon. 

Within one year of License issuance, the License in coordination with the USDA Forest Service 

shall develop a plan that addresses the future management of the HC Reservoir Trail (Trail #1890) from 

Leep Creek mile 4.3 to its terminus mile 8.1. 

Within five years of License issuance, the Licensee in coordination with the USDA Forest 

Service and the DOI Bureau of Land Management shall develop a plan that addresses the future 

management of the McGraw Creek trail (#1879A, 3.9 miles). 

The HC Reservoir Trail and McGraw Creek plans shall be prepared in coordination with the 

USDA Forest Service and other appropriate entities. The Licensee shall include with the plans 

documentation of coordination, copies of comments and recommendations on the completed plans after 

they have been prepared and provided to the USDA Forest Service, and specific descriptions of how the 

USDA Forest Service comments are addressed by the plans. The Licensee shall allow a minimum of 60 

days for the USDA Forest Service to comment and to make recommendations prior to filing the plans 

with the Commission for approval. If the Licensee does not adopt a recommendation, the filing shall 

include the Licensee's reasons, based on Project-specific information. 

Condition No. 21—Hells Canyon Creek Launch Site and Reservoir Facilities 

Within one year of License issuance, the Licensee shall prepare a plan for the USDA Forest 

Service site referred to as HC Creek Launch Site (HCCLS) and file the HCCLS Plan to the Commission 

for approval. 

The HCCLS Plan shall be prepared in coordination with the USDA Forest Service. The Licensee 

shall include with the HCCLS Plan documentation of coordination, copies of comments and 

recommendations on the completed HCCLS Plan after it has been prepared and provided to the USDA 

Forest Service, and specific descriptions of how the USDA Forest Service comments are addressed by the 

HCCLS Plan. The Licensee shall allow a minimum of 60 days for the USDA Forest Service to comment 

and to make recommendations prior to filing the HCCLS Plan with the Commission for approval. If the 

Licensee does not adopt a recommendation, the filing shall include the Licensee's reasons, based on 

Project-specific information. 

The HCCLS Plan will address the items listed below: 

1. Develop potable water and associated grey water disposal system at the Hells Canyon 

Creek Visitor Center if the proposed potable water/grey water disposal system is not 

developed at the Eagle Bar Site. The Licensee shall perform 100% of the O&M of these 

items as described in Condition No. 18 Operations and Maintenance. 

2. The Licensee shall lead a cooperative effort with the USDA Forest Service and other 

partners to provide a sanitary cleaning system (SCAT) capable of cleaning portable human 

waste carry out systems within the Hells Canyon Reservoir area. The Licensee’s 

responsibility will consist of providing a location on or within their lands/parks for the 

device and annual O&M for these items for the term of the License. 

3. Elements of the HCCLS Plan will address safety issues at the boat launch and may include 

modifying the existing ramp and/or evaluating the possibility of relocating it. The Licensee 

shall be responsible for costs associated with the boat launch enhancement and a schedule 

for implementation and maintenance. 

4. The Licensee shall within one year of License issuance repair the footing on the ramp at the 

launch site. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
C-14 

5. Upon License issuance and for the remaining term of the License, the License shall 

maintain the existing level of Licensee staffing (as referenced in MOU No. 99-Mu11061600-556 with Modification No. 001) at the Hells Canyon Creek Launch site and 

Visitor Center. 

6. The Licensee shall be 100% responsible for the maintenance of the following items upon 

License issuance: the road to, parking areas, vault toilets, and ramps associated with the 

area know as the Hells Canyon Creek Launch for the life of the License. 

Condition No. 22—Aesthetic Improvements to the Hells Canyon Dam Site and Recreation 

Portal 

Within one year of License issuance, the Licensee shall, in coordination with the USDA Forest 

Service, develop an Aesthetic Improvement Plan (AIP) for enhancing the upper deck, and entrance and 

egress areas of Hells Canyon Dam that will be incorporated into the Scenery Management Plan and file 

the AIP with the Commission for approval. Alterations may include changes in fencing material, color of 

materials, screening of stop blocks, parking, signage, pedestrian walkways, interpretation, viewing areas 

and landscaping provided that such alterations are consistent with the FERC approved security plan for 

the Dam. A schedule for implementation, to be conducted by the Licensee, shall be included in the AIP. 

Condition No. 23—There is no Condition No. 23 

Condition No. 24—Aesthetics Resource Management 

Within one year of License issuance, the Licensee shall, in coordination with the USDA Forest 

Service, prepare a Scenery Management Plan (SMP) for NFS lands within the Project boundary and 

adjacent to the Project boundary that are affected by the Project and file the SMP with the Commission 

for approval. The Licensee shall implement the SMP. 

The Licensee shall include with the SMP documentation of coordination, copies of comments and 

recommendations on the completed plan after it has been prepared and provided to the USDA Forest 

Service, and specific descriptions of how the USDA Forest Service comments are addressed by the SMP. 

The Licensee shall allow a minimum of 60 days for the USDA Forest Service to comment and to make 

recommendations prior to filing the SMP with the Commission for approval. If the Licensee does not 

adopt a recommendation, the filing shall include the Licensee's reasons, based on Project-specific 

information. 

The SMP shall include the following measures proposed by the Licensee in the FLA: 

1. E.6.1.6 Existing Transmission Lines and Associated Service Roads. 

2. E.6.4.3.1 Design Standards and Guidelines for Physical Structures. 

3. E.6.4.3.2 Design Standards and Guidelines for Landscaping. 

4. E.6.4.3.3 General Aesthetic Clean-Up and Implementation. 

5. E.6.4.3.4 Replacement of Guardrails and Jersey Barriers. 

6. E.6.4.3.5 Mitigation of Contrast from Project Facilities. 

7. E.6.4.3.6 Enhancement of Others Facilities 

Process for Modification of Visual Resources 

A process for evaluating the licensee’s proposed modification to Project facilities and 

landscaping, in terms of their effect on visual resources, including consulting with agencies, will be 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
C-15 

developed through consultation with the USDA Forest Service. This SMP will consider compliance with 

the desired landscape character and scenic integrity level standards from all identified special places or 

key observation points from which the modifications can be seen as identified in Technical Report E.6.3. 

included in the FLA. 

Condition No. 25—Cultural Resource Management 

Within one year of License issuance, the Licensee shall, in coordination with the USDA Forest 

Service, Idaho SHPO, Oregon SHPO, Bureau of Land Management, and appropriate Native American 

Tribes, will finalize a Historic Properties Management Plan (HPMP) for cultural resources within the area 

of potential effect (APE) for the Project, which is defined as extending from the high water-mark line to 

0.1 mile inland on the reservoirs within the Project boundaries and from the river shoreline to 100 meters 

inland on the free flowing section of the Snake River below Hells Canyon Dam to the confluence of the 

Salmon River, and file the HPMP with the Commission for approval. 

The HPMP shall be prepared in coordination with the USDA Forest Service. The Licensee shall 

include with the HPMP documentation of coordination, copies of comments and recommendations on the 

completed HPMP after it has been prepared and provided to the USDA Forest Service, and specific 

descriptions of how the USDA Forest Service comments are accommodated by the HPMP. The Licensee 

shall allow a minimum of 60 days for the USDA Forest Service to comment and to make 

recommendations prior to filing the HPMP with the Commission for approval. If the Licensee does not 

adopt a recommendation, the filing shall include the Licensee’s reasons, based on Project-specific 

information. 

The HPMP will provide for the protection, management, and interpretation of historic properties 

within the HCC Project area and for the mitigation of Project-related impacts to historic properties. 

The HPMP will include the following: 

1. Provisions for an adaptive management strategy that will allow the HPMP to accommodate 

unforeseen challenges and changes in conditions that may affect historic properties. The 

HPMP will also include an evaluation and amendment process to insure that the document 

can be updated and revised as necessary to respond to changing technology and conditions, 

including changes in site eligibility as defined by regulation 36 C.F.R. 800 as amended. 

2. Explanation of how consultation and the other requirements of 36 C.F.R. 800 as amended 

will be met. 

3. Provisions for the evaluation of all future Project-related developments, including PM&E 

measures, for the compliance with the requirements of Section 106 of the National Historic 

Preservation Act (NHPA). The HPMP will provide a process to allow for revisions to the 

Project APE for future undertakings. 

4. Provisions for a process for determining when and under what circumstances new survey, 

or resurvey of previously examined areas may be required. Recognizing the longevity of 

the license, the HPMP will provide for opportunities to conduct additional survey, if 

necessary, over the course of the license. Following the requirements of Section 106, the 

document will also provide guidelines for determining when archaeological inventories 

may be necessary on new Project lands added to the Project boundary. 

5. Conduct additional inventories on newly exposed lands from shoreline erosion or increased 

reservoir draw down on NFS lands as circumstances allow or in cases where planned draw 

downs will occur over an extended period of time. 

6. Provisions for the development of a detailed monitoring plan that will implement regular 

monitoring and assessment of all historic properties (cultural resources determined eligible 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
C-16 

or potentially eligible for the NRHP) within the APE to monitor site condition and assess 

the possible need for the implementation of mitigation or protection measures on historic 

properties being adversely affected by Project operations. The monitoring program will 

commence within 1 year of approval of the HPMP, and will be the primary vehicle to 

collecting the additional data necessary to identify sites that may be adversely affected by 

Project operations, so that appropriate mitigation measures can be initiated. 

7. Documentation shall, at a minimum, consist of a detailed description of the current site 

condition with accompanying photos and specific attention to determining adverse effects 

and possible needs for immediate protection or mitigation. If it is determined that the 

original site recordation is deficient, then the following elements will be added to the site 

monitoring protocol, as appropriate: mapping (GPS, hand drawn site map, clearly defined 

site boundaries), updating or completion of the appropriate SHPO form(s) and a detailed 

narrative describing the site, its contents and archaeological context. 

8. The monitoring plan shall include a provision to use an established and recognized 

photographic protocol on some select rock art sites to be determined through coordination 

with the USDA Forest Service. 

9. Provisions for the development of site specific treatment plans (treatment plans) and an 

implementation schedule for any sites that may need mitigation or treatment as a result of 

adverse effects from Project-related operations to sites on NFS lands within the APE. 

Treatment plans will be completed in consultation with the USDA Forest Service, 

appropriate agencies, Tribes and SHPOs for sites located on NFS lands within a mutually 

agreed upon timeframe. The treatment plans will employ archaeologically/scientifically 

sound methods of testing, oral histories, remote sensing, excavation, preservation, and 

stabilization. The treatment plans will emphasize site conservation and preservation 

oriented ethic that stress in-place protection and preservation over data recovery. 

Treatment plans will also provide for flexible mitigation alternatives that are responsive to 

the specific qualities for which a site is eligible, and which recognize the traditional 

archaeological data recovery may not always be the only or best mitigation alternative. 

10. Make all collected data related to cultural resources on NFS lands available to the Payette 

and Wallowa-Whitman National Forests consistent with 36 C.F.R. 800 as amended, subject 

to provisions of any ARPA permit issued for study or inventory purposes. 

11. Provisions for the establishment of a Cultural Resources Advisory Group (CRAG) that will 

provide an organized forum for continued consultation and coordination between the 

Licensee and agencies, Tribes and the SHPOs, in the implementation of the HPMP. 

12. Provisions for the curation of any artifacts recovered during IPC-sponsored research 

conducted in conjunction with testing, mitigation, or treatment, in a facility that meets the 

requirements of 36 C.F.R. 79. 

13. The revised HPMP will include all the provisions previously specified within the draft 

HPMP submitted as part of the Final License Application (Hells Canyon FLA Technical 

Report Appendix E.14-15), unless otherwise replaced or modified by the provisions listed 

above. 

Condition No. 26—Project Boundary Modification 

Within one year of License issuance, the Licensee shall provide the USDA Forest Service with a 

map and aerial photos depicting the approximate location of the project boundary together 

with Geographic Information System (GIS), compatible with USDA Forest Service GIS, 

shapefiles with Metadata for the project boundary on National Forest System lands. The 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
C-17 

project boundary GIS data will be positionally accurate to ±40 feet, in order to comply with 

National Map Accuracy Standards for maps at a 1:24,000 scale. At locations on National 

Forest System lands where the project boundary has been surveyed and monuments placed 

on the ground, monuments shall be logged using a Global Positioning System (GPS) with 

accuracies meeting National Standard for Spatial Data Accuracy (NSSDA) standards. This 

data shall be used to geo-reference the project boundary within the GIS 

Condition No. 27—Reservation of Authority 

The Licensee shall implement, upon order of the Commission, such additional measures as may 

be identified by the Secretary of Agriculture, pursuant to the authority provided in Section 4(e) of the 

Federal Power Act, as necessary to ensure the adequate protection and utilization of the public land 

reservations under the authority of the USDA Forest Service. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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Document Accession #: 20070831-4002 Filed Date: 08/31/2007
C-19 

Exhibit 1—Sandbar Inventory 

River Mile Bar Type 

1964 

(1000s ft2) 

1973 

(1000s ft2) 

1982 

(1000s ft2) 

246.91 CM HCD-Launch 5 

246.9 CM HCD-Launch 5 

246.9 CM HCD-Launch 5 

245.8 CM (Stud Ck) 15 5 

245.7 CM Lamont Spr. 15 

245.3 CM Square Beach 15 5 5 

244.7 S Brush Creek 25 15 15 

244.6 CM 5 5 

244.2 CM Fawn Bar 5 

244 CM 5 5 5 

243.4 CM Chimney Bar (Moose) 5 

243.3 R Cactus Camp 15 

243.1 CM Warm Springs 15 

242.91 CM 5 

242.9 R 5 

242.5(.6) CM (Daily Bar) 5 5 5 

242.2 (1) R Battle Creek 15 

241.9 (.8) CM Sand Dunes 5 

241.6 CM Birch Springs 0 5 

241.3 R Wild Sheep 5 

241 CM 5 

240.7 CM 5 5 

240 S 5 

238.7 CM 5 

238.5 CM 5 

238.3 CM 5 

237 CM Dry Gulch 5 

236.6 R Hastings 5 

236.4 CM 5 

236.3 CF 5 5 

236(.2) CM Saddle Creek 5 

235.8 R 5 

235.5 CM 5 

235.1 CM Bernard Creek 5 5 

234.02 CM 5 

234.01 CM 5 

234 CM 5 

231.3(.4) CM Rush Creek 5 

230.9 CM 5 

230.5 CM 5 

 

229.8 R Johnson Bar Landing 35 25 15 

229.7 CM 5 

229.3 CF 5 

229.2(.3) S Sheep Creek Cabin 5 

229.1 R 5 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
C-20 

River Mile Bar Type 

1964 

(1000s ft2

) 

1973 

(1000s ft2) 

1982 

(1000s ft2) 

229 S Steep Creek 5 5 

228.8 R 15 

228.7 CF 15 5 5 

228.6 CM Yreka Bar 5 

228.5 CM Upper Yreka Bar 5 

228.4 CM 5 

228.1 R (Upper Sand Ck) 15 

228.01 CM 5 

228 CM 10 

227.9 CF Sand Creek 5 

227.8 R 5 

227.6 CM 5 5 

227.5 R Pine Bar 35 35 25 

227.4 CF 5 

227.3 CF 5 

226.8 R 5 

226(.2) R (Lower Quartz Ck) 15 5 5 

225.9 CM 5 

224.6 R No Name 5 

224.4 R 15 5 

224.3 CM Dry Gulch 5 5 

223.6(.8) CM Temperance 5 

223.1 CM 5 

223 CF 5 

222.9 CM Hominy Bar 1 25 

222.8 CF Hominy Bar 2 15 

222.4 (.6) R Salt Creek 35 35 35 

222.2 CM Two Corral 25 

222.1 R (toad Bar) 15 5 

222 CM Gracie Bar 5 5 

221.7 CM 5 5 5 

221.6 S 5 

221.5(.4) R Half Moon Bar 25 5 

220.8 R Kirkwood Ranch 35 25 25 

220.6 CM 5 

220 CM Yankee Bar 5 5 5 

219.9(.6) R (Russell Bar) 25 

218.6 CM 15 

218.5 CM 5 

218.3 CM Cat Gulch 5 

218.2 CM 5 5 

218.1 CM 5 

217.9 CM 5 5 

217.4 (.2) CM (Corral Ck) 15 

216.9(.7) R (Trail Ck) 25 

216.4 R Fish Trap Bar 35 35 35 

216.2 R Upper Pittsburg 15 

215.7 R Klopton Ck 5 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
C-21 

River Mile Bar Type 

1964 

(1000s ft2

) 

1973 

(1000s ft2) 

1982 

(1000s ft2) 

215.6 CM Wilson Eddy/Tin Shed 15 

215.3 CM 15 

214.71(.8) S Pittsburg Admin 25 35 25 

214.7 R Pittsburg Admin 35 15 25 

213.91 MC 5 

213.9 CM 15 15 5 

213.2 CM 5 

213.11 CM 5 

213.1 CM 5 

212.6 CM 5 5 5 

212.5 S 5 

212.4 R 15 5 

212.3 CM 5 

211.91 CM 5 5 5 

211.9 CM McCarty Creek 25 15 5 

211.8 CF 5 

211.7 CM 5 

211.6 CM 5 

211.4 CF 5 5 5 

211.2 CM 5 5 

210.7(.8) CM (Big Canyon) 5 

210.6(.4) CM (Lower Big Canyon) 5 

210.21 CF 5 5 

210.5 CM (Elk Calf Camp) 5 5 

210.4(.0) CM Somers Range 5 5 5 

210.3 CM 15 5 5 

209.9 CM Camp Creek 15 5 5 

209.7 CM 5 

209.2 CF 5 5 5 

208.3 R Jones Creek 15 5 5 

208.2 R Lookout Creek 25 

206.9 CM 5 5 

206.8 CM 5 5 

205.9 CM 5 5 

205.51 CF 5 5 

205.5 CM 5 5 

205.3 R 15 

204.8 CF 5 5 

204.6 CM 5 

204.5 CM Bob Creek 5 5 5 

203.4 CF 15 

203.1 CM 5 

202.81 R 5 

202.41 CM 5 5 

201.9 S Bar Creek 15 5 5 

200.7 CM 5 

200.1 CM 5 5 5 

199.5 CF 5 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
C-22 

River Mile Bar Type 

1964 

(1000s ft2

) 

1973 

(1000s ft2) 

1982 

(1000s ft2) 

199.2 CM 5 

199.1 CF 5 

199 S Deep Creek Camp 5 5 5 

198.5(.4) CM Robinson Gulch 5 5 5 

198.3(.1) CF Dug Creek 15 5 

197.7 CF 5 

197.4 R 15 5 

194.9 CM 5 

194.1 CM 5 

194 CM 5 5 5 

193.8(.6) R (Mary Camp) 25 15 5 

192.7 CM 5 

192.4 CF China Bar 15 15 15 

192.2 CM 5 5 5 

192.1 CM 5 5 5 

190.9 CM 35 25 15 

190.3 CM 5 

190.2 CM 5 

189.6 CM 5 5 5 

189.2 CF 5 

188.7 CM 5 

188.5 CF 5 5 5 

188.4 CF 5 

 

Private Land on Idaho Side of River 

River Mile Bar Type 

1964 

(1000s ft2

) 

1973 

(1000s ft2) 

1982 

(1000s ft2) 

218.8 CM Kirby Creek Lodge 35 35 35 

207.8 CM 5 5 

207.5 S Marlboro B 5 5 5 

207.4 CF 5 

207.3 S 5 5 5 

206.7 S 5 5 5 

206.3(.1) R High Range 25 

206 R 5 5 

205.8 CF Getta Creek 5 5 5 

205.7 R 5 5 

205.1(.0) CF (Ragtown Bar) 25 15 15 

204.81 CM 35 35 

204.4 CF 5 

204.2(.0) S Cat Ck 15 15 

203.9 S 15 5 5 

203.5 CM 5 5 5 

202.9 CM Wolf Creek Camp 5 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
C-23 

River Mile Bar Type 

1964 

(1000s ft2

) 

1973 

(1000s ft2) 

1982 

(1000s ft2) 

202.8 S 5 5 5 

202.5 CM 5 5 5 

202.4 CM 5 5 

201.61 CM 5 

201.6 CM 5 

201.5 R 15 5 5 

201.2 CM (Hitchcock Ranch) 35 25 25 

201.1 CM 15 15 5 

201 R (Hitchcock Ranch) 15 5 5 

200.9 R Dry Cr Camp 15 

200.3 CM 5 5 5 

199.4 CF 5 

199.3 CF 5 

199.21 CM Deep Creek 5 5 

199.13 CF 5 

199.12 CF 5 

198.7 CM 15 5 

197.3 CM 5 

195.3 CM Warm Springs Rapids 15 15 15 

195 CM 5 5 5 

194.7 CM 5 

194.31 CM 5 

194.3 CM 5 

194.2 CM 5 

194.11 CM 5 5 5 

194.01 CM 5 5 5 

193.5 CM 5 5 

193.3 CM 5 5 

192.21 CM 5 5 

190.8 CF 5 5 

190 CM 5 5 5 

189.8 CM 5 

189.7 CM 5 

189.3 CM 5 5 5 

188.6 CM 5 

188.4 CF 

188.3 CM Salmon Mouth 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
C-24 

Exhibit 2—Escalation of Costs 

Unless otherwise indicated, all costs or payment amounts specified in dollars shall be deemed to be stated 

as of the year 2006, and IPC shall escalate such sums as of January 1 of each following year (starting in 

January 2007) according to the following formula: 

AD = D x (NGDP) 

 IGDP 

WHERE: 

 AD = Adjusted dollar amount as of January 1 of the year in which the adjustment is 

made. 

 D = Dollar amount prior to adjustment. 

 IGDP = GDP-IPD for the third quarter of the year before the previous adjustment date 

(or, in the case of the first adjustment, the third quarter of the year before the 

Effective Date). 

 NGDP = GDP-IPD for the third quarter of the year before the adjustment date. 

 “GDP-IPD” = the value published for the Gross Domestic Product Implicit Price Deflator by the 

U.S. Department of Commerce, Bureau of Economic Analysis in the publication 

Survey of Current Business, Table 7.1 (being on the basis of 1987 = 100), in the 

third month following the end of the applicable quarter. If that index ceases to be 

published, any reasonably equivalent index published by the Bureau of Economic 

Analysis may be substituted by the Parties. If the base year for GDP-IPD is 

changed or if publication of the index is discontinued, the Parties shall promptly 

make adjustments or, if necessary, select an appropriate alternative index to 

achieve the same economic effect.

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
C-25 

INTERIOR SECTION 4(E) CONDITIONS 

The Department of the Interior (Department) has reviewed the notice of application Ready for 

Environmental Analysis and Soliciting Comments, Recommendations, Terms and Conditions, and 

Prescriptions for the Hells Canyon Hydroelectric Project, FERC Project No. 1971-079, located on the 

Snake River in Wallowa and Baker Counties, Oregon, and Adams and Washington Counties, Idaho. 

Because a Draft Environmental Impact Statement (DEIS) or Draft Environmental Assessment (DEA) has 

not yet been issued by the Federal Energy Regulatory Commission (Commission), this response contains 

preliminary comments, recommendations, terms and conditions, and prescriptions only. The Department 

reserves the right to amend these preliminary comments, recommendations, terms and conditions, and 

prescriptions, if warranted, based on the results of new information and conclusions developed during the 

Commission’s environmental analysis. 

The preliminary comments, recommendations, terms and conditions, and prescriptions herein are 

provided in accordance with the provisions of the Fish and Wildlife Coordination Act (16 U.S.C. §661 et 

seq.), the Federal Power Act (FPA), (16 U.S.C. § 791 et seq.), the Endangered Species Act (ESA), (16 

U.S.C. §1531 et seq.), the Federal Land Management and Policy Act (FLPMA), (43 U.S.C. § 1701 et 

seq.), and the National Environmental Policy Act (NEPA) (42 U.S.C. § 4321 et seq.). The Department 

does not intend to object to the issuance of a new license for the Hells Canyon Hydroelectric Project 

(Project), provided our comments, recommendations, terms and conditions, and prescriptions are 

incorporated into the new license. 

Modified Condition No. 1—Activities on or Affecting Bureau of Land Management 

Administered Lands 

(A) The Licensee shall consult with the Bureau of Land Management (BLM) to identify and 

resolve any potential conflicts with BLM policy and direction prior to initiating activities 

on BLM-administered lands that is beyond the scope of the Project license or for which the 

Licensee has not otherwise obtained BLM approval. 

(B) The Licensee shall cooperate with the BLM to obtain the appropriate rights-of- way or 

permits for use or access to BLM-administered lands prior to engaging in any activity that 

has the potential to affect other federally authorized activities on those lands. 

(C) The Licensee shall receive written approval from BLM prior to changing the location of 

any Project feature or facility located on BLM-administered lands. The Licensee shall also 

receive written approval for any actions which are inconsistent with activities authorizing 

use or occupancy of BLM-administered lands according the new license. Following BLM 

approval and at least 90 days prior to any change or departure, the Licensee shall file a 

report with the Federal Energy Regulatory Commission (Commission) and with the BLM, 

describing the change, reasons for the change, and demonstrating BLM approval of the 

change. 

(D) The Licensee shall prepare site-specific plans for approval by the BLM for any ground 

disturbing activities on BLM-administered lands required by the license, including 

activities outlined in BLM resource management plans (RMP). RMPs prepared subsequent 

to issuance of the license shall be developed in reference to license articles that may be 

affected as a consequence of RMP implementation. The Licensee’s site-specific plans shall 

include: 

i. a map depicting the location of the proposed activity; 

ii. a description of the land classification, designation, current management, applicable 

standards and guidelines, and current monitoring for the area of proposed activity; 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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iii. a description of alternative locations, designs, and mitigations for the proposed 

activity; and 

iv. data from surveys, biological evaluations, or consultation required by regulation for 

ground- or habitat-disturbing activity on BLM-administered lands available at the 

time the plan is prepared; 

(1) When surveys indicate that activities may affect an Endangered Species Act 

(ESA) listed or proposed listed species or their habitat, the Licensee shall 

evaluate the impacts of the action on the species or habitat and submit this 

evaluation to the BLM. 

(2) When surveys indicate an activity may affect a BLM sensitive species or their 

habitat, the Licensee shall evaluate the impact of the action and submit 

conclusions to the BLM for review and approval. BLM reserves the authority 

to require mitigation for impacts to BLM sensitive species or their habitat. 

(E) The Licensee shall file a Safety During Construction Plan with the Commission 60 days 

prior to initiating any ground-disturbing activity on BLM-administered lands. This plan 

will identify potential hazard areas s and measures to protect public safety, particularly for 

construction activities near public roads, trails, recreation sites, and BLM-administered 

facilities. 

 The Licensee shall perform daily (or according to a schedule otherwise agreed by the 

BLM) inspections of Licensee's construction operations on BLM-administered lands while 

construction is in progress. The Licensee shall document these inspections and provide 

documentation to the BLM on a schedule agreed by the Licensee and BLM. Inspections 

must evaluate fire plan compliance, public safety, and environmental protection. The 

Licensee shall act immediately to address any necessary corrections identified by BLM. 

(F) The Licensee shall consult with BLM to prepare a Spoils Disposal Plan prior to initiating 

any ground disturbing activity on BLM-administered lands. Upon BLM approval, the plan 

shall be filed with the Commission. The plan shall address disposal and/or storage of waste 

soil and/or rock materials (spoils) generated by road maintenance, slope failures, and 

construction projects. The plan shall include provisions for: 

i. identifying and characterizing the nature of the spoils in accordance with applicable 

BLM regulations; 

ii. identifying sites for the disposal and/or storage of spoils to prevent surface or 

groundwater contamination; and 

iii. developing and implementing stabilization, slope reconfiguration, erosion control, 

reclamation, and rehabilitation measures. 

(G) The Licensee shall file a Hazardous Substances Plan for oil and hazardous substance 

storage, spill prevention, and clean up with the Commission prior to initiating activities on 

or that may affect BLM-administered lands adjacent to the Project. At least 90 days prior 

to submission to the Commission, the Licensee shall provide a copy of the plan to the BLM 

for its review and approval. At a minimum, the plan shall: 

i. outline procedures for reporting and responding to releases of hazardous substances, 

including names and phone numbers of all emergency response personnel and their 

assigned responsibilities; and 

ii. identify and locate a cache of hazardous spill cleanup equipment sufficient to contain 

any spill from the Project. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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iii. include procedures for notifying the BLM as to the nature, time, date, location, and 

action taken for any spill affecting BLM administered lands. On a semi-annual basis, 

the Licensee shall provide the BLM information on the location of spill cleanup 

equipment on BLM-administered lands and the location, type, and quantity of oil and 

hazardous substances stored in the Project area on BLM-administered lands. The 

Licensee shall inform BLM immediately as to the nature, time, date, location and 

action taken for any spill affecting BLM administered lands. 

(H) The Licensee shall avoid disturbing all public land survey monuments and BLM boundary 

markers. In the event a marker or monument is destroyed by action or omission oversight 

of the Licensee, depending on the type of monument destroyed, the Licensee shall 

reestablish the monument according to (1) procedures outlined in the "Manual of 

Instructions for the Survey of the Public Land of the United States," (2) specifications of 

the County Surveyor, and/or (3) BLM specifications.. The Licensee shall ensure that 

official survey records affected are amended as required by law. 

(I) The Licensee shall maintain Project-related improvements and facilities on BLMadministered lands to BLM standards of repair, orderliness, neatness, sanitation, and safety. 

The Licensee shall comply with all applicable Federal, State, and local laws, regulations, 

including but not limited to, the Federal Water Pollution Control Act, 33 U.S.C. § 1251 et 

seq., the Resources Conservation and Recovery Act, 42 U.S.C. § 6901 et seq., the 

Comprehensive Environmental Response, Control, and Liability Act, 42 U.S.C. § 9601 et 

seq., and other relevant environmental laws, public health and safety laws, and other laws 

relating to the sighting, construction, operation, maintenance of any facility, improvement, 

or equipment. 

(J) The Licensee shall restore BLM-administered lands to a condition satisfactory to the BLM 

prior to surrender of the Project license or abandonment of Project facilities, consistent with 

the Federal Power Act and Commission regulations. At least one year prior to filing an 

application for license surrender, the Licensee shall file a restoration plan approved by the 

BLM with the Commission. The restoration plan shall identify any capital improvements 

that will be removed, restoration measures, time frames, and costs. In addition, the 

Licensee shall commission an audit to assist the BLM in determining whether the Licensee 

has the financial ability to fund the decommissioning and restoration work specified in the 

plan. 

 As a condition of any transfer or surrender of the license or sale of the Project, the Licensee 

shall ensure that the cost of surrender and restoration will be borne by the Licensee or 

transferee. Any license amendment that authorizes use of BLM-administered lands shall be 

subject to such conditions the BLM deems necessary to protect and utilize affected BLM 

reservations. 

(K) The Licensee shall indemnify, defend, and hold the United States harmless for any costs, 

damages, claims, liabilities, and judgments arising from past, present, and future action or 

oversight of the Licensee relating to use and/or occupancy of BLM-administered lands 

necessary for Project maintenance and operation and so authorized by the license. The 

indemnification and hold harmless provision applies to any action or oversight of the 

Licensee, heirs, assigns, agents, employees, affiliates, subsidiaries, fiduciaries, contractors, 

or lessees authorized to use or occupy Project lands and/or facilities that result in: (1) 

violation of law and regulation, including but not limited to the Comprehensive 

Environmental Response Compensation and Liability Act, Resource Conservation and 

Recover Act, Oil Pollution Act, Clean Water Act, and the Clean Air Act; (2) judgments, 

claims, demands, penalties, or fees assessed against the United States; (3) costs, expenses, 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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and damages incurred by the United States; or (4) the release or potential release of any 

solid waste, hazardous substances, pollutants, or contaminants in any form in the 

environment. 

Modified Condition No. 2—Consultation with the Bureau of Land Management 

Commencing five years after a new license is issued and unless otherwise provided, the Licensee 

shall prepare and submit an annual, written report summarizing progress on implementing articles of the 

license that affect recreation, cultural, aquatic, and terrestrial resources administered by BLM on BLM 

lands within and adjacent to the Project boundary. The Licensee shall provide the report to BLM allowing 

a minimum of 60 days for review and to make recommendations prior to filing the report with the 

Commission. If the Licensee does not agree with or adopt a recommendation and does not negotiate a 

mutually agreeable alternative, the filing shall document the Licensee’s rationale. The BLM reserves the 

right, after notice, comment and administrative review, to require changes to Project operation through 

revision of Mandatory Conditions. 

Modified Condition No. 3—Travel and Access Management 

Within three years of the issuance of the new license or on an alternate schedule agreed to by 

BLM and the Licensee, the Licensee in consultation with the BLM shall develop and file with the Federal 

Energy Regulatory Commission (Commission) an integrated Travel and Access Management Plan for 

Project lands and for lands administered by the Bureau of Land Management (BLM) affected by the 

Project. The Travel and Access Management Plan (TAMP) shall be incorporated into the Comprehensive 

Recreation Management Plan (CRMP) and coordinated with the Integrated Wildlife Habitat Program 

(IWHP) and Wildlife Mitigation and Management Plan (WMMP). The TAMP is intended to be a 

planning document to increase the effectiveness and efficiency of efforts to manage, maintain, and 

enhance travel and access to not only Project lands but also lands within the vicinity of the Project and 

assist in the assessment of the Licensee’s role and responsibilities with regard to travel and access to the 

Project. The TAMP is also intended to foster coordination, cooperation and integration of efforts between 

the Licensee and the various federal, state, and local authorities with jurisdiction or authority over roads, 

trails or lands within the Hells Canyon area. 

The TAMP shall be developed collaboratively in consultation with the BLM and other relevant 

state and federal agencies, including the U.S. Forest Service, Idaho Department of Parks and Recreation, 

the Oregon Department of Parks and Recreation, and members of the Recreation Resource Work Group 

(RRWG). 

Documentation and a description of the consultation process including responses to any written 

comments received during the consultation process will be included as an appendix to the TAMP. The 

TAMP shall be based on the best data and information available and is intended to be an adaptive plan 

subject to amendment and revision during the term of the new license. 

The purpose of the Travel and Access Management Plan is to provide transportation maintenance 

and management, provide for public safety, improve habitat effectiveness on the winter range, protect 

sensitive wildlife and plant populations from human interference during critical periods of the year, 

manage vehicle access and numbers consistent with resource goals, coordinate off-highway vehicle 

(OHV) management between Federal land use agencies and IPC, manage noxious weeds, improve aquatic 

connectivity, and protect cultural resources. The TAMP, at a minimum, shall include provisions to: 

(i) Identify management goals and objectives consistent with BLM resource protection for 

BLM-administered lands affected by the Project; 

(ii) Identify Licensee responsibilities for road management and maintenance for roads which it 

has assumed responsibility, and for roads on BLM-administered lands affected by the 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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Project as determined by the data and factual information developed during the consultation 

and planning process. At a minimum, the following roads will be addressed in the TAMP: 

Road Name State Holder Location 

Est. Road 

Miles 

Snake River Road OR Baker County Huntington (RM 328*) 

to Swedes (RM 304) 

then inland to Richland 

41 

Homestead Road OR Baker County and 

Wallow County 

Oxbow (RM 271) to 

Copper Creek (RM 261) 

10 

Oxbow Road OR Idaho Power 

Company 

Oxbow (RM 271) to 

Oxbow bridge (RM 284) 

13 

Hells Canyon road ID Idaho Power 

Company 

Oxbow (RM 271) to 

TNTY** (RM 267) 

4 

Brownlee Road ID Idaho State Oxbow bridge (RM 284) 

to NETA** (RM 286) 

2 

Olds Ferry Road 

and beyond 

ID Weiser Road 

District 

Weiser (RM 351) to 

ROCK** (RM 320) 

31 

Total 

* River Mile 

** 4-digit code of most distant BLM dispersed site 

With regard to the Olds Ferry Road, for the 11-mile section of the road between the end of the 

existing pavement and Steck Recreation Site, the TAMP shall consider the need for an upgrade of that 

road to AASHTO (American Association of State Highway and Transportation Officials) standard M147-

65, along with appropriate maintenance to preserve the improved road surface. This evaluation shall 

include a consideration of the appropriateness of Licensee cooperation among others, in any funding for a 

road upgrade and maintenance for the license term. The evaluation shall also include the identification 

and potential acquisition of any grants available for a road upgrade and maintenance for the license term. 

(iii) Within five years of the Commission’s approval of the TAMP or on an alternate schedule 

agreed to by the BLM , the Licensee shall replace culverts to provide aquatic connectivity 

and re-connect riparian function and structure on all class 1 and 2 streams where shotgun 

culverts are located along: a) Hells Canyon Road: 14 culverts (13 full barriers and 1 partial) 

b) Brownlee Road: 4 culverts (4 full barriers). 

(iv) Following the Commission’s approval of the TAMP, the Licensee shall begin 

implementation of the provisions of the TAMP relating to the non-motorized use of trails 

connecting recreation sites along the Oregon side of Hells Canyon Reservoir. 

Implementation shall follow a schedule identified in the TAMP. As part of the TAMP, the 

Licensee shall also conduct a feasibility study relative to the development of a trail system 

along the Oregon side of the Hells Canyon, Brownlee, and Oxbow reservoirs connecting 

Farewell Bend State Park to Hells Canyon National Recreation Area, 

(v) Within five years of the Commission’s approval of the TAMP, the Licensee shall have 

evaluated Best Management Practices (BMP) and implemented measures, on those roads 

for which the licensee is responsible under the TAMP, to: 

a) Maintain and improve roads to reduce potential for road failure as a consequence of 

reservoir fluctuation and/or weather; 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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b) Mitigate for soil erosion; 

c Monitor road use and increased/decreased use of roads for recreation access; 

d) Manage OHV use on and off roads within the Project and adjacent BLMadministered lands affected by the project. The Licensee shall assume responsibility 

for a proportion of the costs, as provided for in the TAMP, to implement and 

administer mitigation measures for impacts from OHV users on adjacent BLMadministered lands affected by OHV use as a result of the Project. Costs associated 

with these measures may include interpretive, directional and regulatory signs, road 

and trail closures (including fencing, berms, and rehabilitation of unauthorized 

routes), trail maintenance, use supervision and enforcement; 

e) Construct barriers, guardrails and other safety measures that are aesthetically 

pleasing; 

f) Identify and implement seasonal road closures as necessary to protect wildlife and 

decrease big game/vehicle interactions; 

g) Identify and implement road closures as needed; 

h) Prevent sidecasting; and 

i) Identify and implement BMPs for maintenance necessary to protect cultural 

resources, control the spread of noxious weeds, protect sensitive plants and 

threatened and endangered species, minimize soil erosion, and protect aquatic 

resources; 

(vi) Within five years of the Commission’s approval of the TAMP, the Licensee shall develop a 

road atlas for all access and service roads in the rim-to-rim study area using a geographic 

information system. The intent is to provide spatially based information regarding roads 

and sensitive resources. The atlas should provide spatial and temporal information 

regarding existing and proposed road maintenance activities and the potential to impact atrisk resources and further reduce conflicts between road-related activities and sensitive 

resources. The GIS database should be accessible to all parties who administer resources 

affected by the action. The plan shall accommodate unrestricted access by the BLM for 

purposes necessary to manage and administer BLM lands and resources that are impacted 

by Project operations. The plan shall include provisions as necessary to restrict vehicular 

access to Project roads in locations and at times when access could cause damage to BLMadministered lands and resources. For example, access restrictions may be necessary 

during times of the year in order to protect nesting habitat for listed or sensitive wildlife 

species. 

 The Licensee shall consult the BLM for a list of times and locations when road access 

restrictions should be in effect. The plan shall include provisions for the maintenance of 

crossings and rights-of-way (ROW) required by and consistent with permit requirements 

for power lines, penstocks, ditches, and pipelines. The Licensee shall consult with the 

BLM prior to erecting any signs on BLM-administered lands that are necessary for 

operation or maintenance of the Project or related Licensee facilities. The Licensee must 

obtain approval from the BLM specific to the location, design, size, color, and content of 

signs. The Licensee shall be responsible for maintaining all Licensee erected signs to neat 

and presentable standards. 

 The TAMP shall be prepared in coordination with the BLM and the other parties described 

above. The Licensee shall include with the Plan submitted to the Commission 

documentation of coordination and copies of comments and recommendations on the Plan. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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The Licensee shall allow a minimum of 60 days for the BLM to comment and to make 

recommendations prior to filing the Plan with the Commission for approval. The Plan 

submitted to the Commission shall include all recommendations submitted by the BLM. If 

the Licensee does not agree with a recommendation made by BLM, the filing will include 

the Licensee's reasons for disagreeing with the BLM recommendation, based on Projectspecific information. The Commission may consider the Licensee’s comments on the 

BLM recommendations in its decision adopting or modifying the final Plan. The Licensee 

shall implement the Plan as approved by the Commission. 

Modified Condition No. 4—Law Enforcement and Emergency Services 

Within five years of license issuance or on an alternate schedule agreed to by BLM and the 

Licensee, the Licensee shall develop, and thereafter will begin implementation of, a Law Enforcement 

and Emergency Services Plan (LEESP) that includes provision for coordination and cooperative funding 

of law enforcement and emergency services personnel with jurisdiction within the Hells Canyon 

Hydroelectric Project (Project). The LEESP is intended to be a planning document to increase the 

effectiveness and efficiency of law enforcement and response for medical and other emergencies and 

foster coordination and cooperation between the Licensee and the various federal, state and local 

authorities with jurisdiction over law enforcement and emergency services in the Hells Canyon area. 

The LEESP shall be developed collaboratively in consultation with the BLM and other relevant 

state, federal and local authorities, including the U.S. Forest Service, relevant Idaho and Oregon 

departments of law enforcement and emergency services, relevant local and county governments, and 

members of the Recreation Resource Work Group (RRWG). Documentation and a description of the 

consultation process including responses to any written comments received during the consultation 

process will be included as an appendix to the LEESP. The LEESP shall be based on the best data and 

information available and is intended to be an adaptive plan subject to amendment and revision during the 

term of the new license. 

The LEESP may include provisions for law enforcement presence, other types of public contact 

personnel presence, enhanced emergency communication and response procedures, public safety and 

security, protection measures for natural resources, recreation resources, and heritage resources within the 

Project generally. The LEESP shall also address medical response measures, including the need for, 

number, placement, and time availability of quick response units and certified “first responders.” At a 

minimum, the LEESP shall provide for three strategically placed certified “first responders” and 

associated quick response units during all high use periods. For the purposes of the LEESP, “first 

responders” shall mean persons who have completed sufficient emergency training (approximately 40 

hours of certified instruction under applicable Oregon and Idaho standards) to provide stabilization and 

evaluation in an emergency situation; and “quick response units” shall mean a first responder along with 

some basic emergency equipment. 

Licensee shall develop and implement the original LEESP and subsequent revisions as provided 

for in the LEESP. 

The LEESP should include provisions to coordinate with the local counties and the Bureau of 

Land Management (BLM) to assess law enforcement needs and establish triggers to determine when 

and/or if additional law enforcement personnel are necessary to patrol BLM-administered lands that are 

impacted by the Project. This evaluation should include an assessment of the need for additional federal 

law enforcement. If additional law enforcement on BLM-administered lands is necessary over the period 

of the new license as a result of the operation, maintenance or use of the project, the LEESP shall contain 

provisions to assure adequate law enforcement, including funding for additional personnel (county, state, 

or federal) to the BLM and other law enforcement jurisdictions. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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The LEESP shall include provisions for coordination with the BLM to evaluate the need for 

enhanced fire protection on IPC lands and BLM-administered lands affected by the project, including 

monitoring, evaluation, and appropriate management changes necessary to prevent recurring humancaused fires that affect BLM-administered lands. If monitoring demonstrates an increased need for fire 

prevention, detection, and suppression as a result of licensee activities in connection with the operation 

and maintenance of the Project, the LEESP shall contain provisions for 100% of the costs of these 

activities to be funded by the Licensee. Licensee shall not be responsible for fires caused by third parties 

regardless of whether such fires originate on or within the project. 

The Licensee shall continue to implement actions necessary for the safe and legal use and access 

of Project reservoirs and facilities according Protection, Mitigation, and Enhancement Measure (PM&E) 

5.4.3.1.3 on p. 283 and PM&E 5.4.4.1.4 on p. 290 in the Technical Report, Appendix E, of the Final 

License Application dated July 2003 (FLA). 

The Licensee shall implement law enforcement provisions of the Baker County Settlement 

Agreement dated October 3, 2003. 

The LEESP shall be prepared in coordination with the BLM and the other parties described 

above. The Licensee shall include with the Plan submitted to the Commission documentation of 

coordination and copies of comments and recommendations on the Plan. The Licensee shall allow a 

minimum of 60 days for the BLM to comment and to make recommendations prior to filing the Plan with 

the Commission for approval. The Plan submitted to the Commission shall include all recommendations 

submitted by the BLM. If the Licensee does not agree with a recommendation made by BLM, the filing 

will include the Licensee’s reasons for disagreeing with the BLM recommendation, based on Projectspecific information. The Commission may consider the Licensee’s comments on the BLM 

recommendations in its decision adopting or modifying the final Plan. The Licensee shall implement the 

Plan as approved by the Commission. 

Modified Condition No. 5—Historic Properties Management Plan 

(A) Within one year of license issuance, the Licensee shall file a revised final Historic 

Properties Management Plan (HPMP) with the Federal Energy Regulatory Commission 

(Commission). The plan shall be revised in consultation with the Bureau of Land 

Management (BLM), U.S. Forest Service, Oregon and Idaho State Historic Preservation 

Offices (SHPO) and Tribal governments. A draft of the revised plan shall be submitted to 

the BLM, providing for review and comment before completion of the final plan for 

submission to the Commission. As new historic properties are identified or additional 

Project effects are documented, site-specific monitoring, protection or mitigation measures 

shall be incorporated into HPMP updates, and subject to BLM review and comment. 

 The Licensee shall include with the HPMP submitted to the Commission documentation of 

consultation and copies of comments and recommendations on the HPMP. The Licensee 

shall allow a minimum of 60 days for the BLM to comment and to make recommendations 

prior to filing the HPMP with the Commission for approval. The HPMP submitted to the 

Commission shall include all recommendations submitted by the BLM. If the Licensee 

does not agree with a recommendation made by the BLM, the filing will include the 

Licensee’s reasons for disagreeing with the BLM recommendation, based on projectspecific information. The Commission may consider the Licensee’s comments on the 

BLM recommendations in its decision adopting or modifying the final HPMP. The 

Licensee shall implement the HPMP as approved by the Commission. 

(B) The Licensee shall prepare and submit annual reports to BLM describing its activities 

involving BLM-administered cultural resources. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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(C) The Licensee shall conduct periodic reviews of the HPMP focusing on the degree to which 

protection and mitigation measures are contributing to cultural resource maintenance and 

protection on BLM administered lands. The review shall include consultation with and 

comments from signatories to the Programmatic Agreement. A formal report of the review 

shall be prepared by Licensee and submitted to the BLM and Commission. 

(D) In addition to following the Guidelines for an HPMP as described by the Commission and 

Advisory Council on Historic Preservation (ACHP), the revised HPMP will provide for the 

following: 

i. Development of site-specific plans for evaluating eligibility, monitoring, protection 

and mitigation of historic properties on BLM land in consultation with and subject to 

review and approval of the BLM. Plans shall be submitted to the Commission before 

implementation. The following plans and actions shall be included: 

1. Determinations of National Register Eligibility 

 During the license term, Licensee shall complete investigations necessary to 

determine eligibility for cultural resource properties on BLM-administered 

lands. Evaluations shall be completed within three years of discovery of any 

newly identified properties. Evaluation work plans shall be developed in 

consultation with BLM, SHPOs and Tribes, allowing at least 60 days for 

review and comment on proposed work plans. Final evaluation work plans 

shall be subject to prior BLM and SHPO approval. 

 Within five years of license issuance, Licensee shall complete evaluations of 

the National Register eligibility for Section 106 purposes for specific BLM 

heritage properties documented at the time of License issuance. These include 

the following sites: 35 BA 894, BK 489 (HC-6). An eligibility evaluation 

report for each site shall be submitted to BLM, Tribes and SHPO, allowing at 

least 60 days for review and comment before completion of the final report. 

Eligibility determinations shall be subject to the approval of BLM and the 

SHPO, prior to submission to the Commission. In addition, the Licensee shall 

endeavor to relocate, evaluate for significance and record the following sites in 

Idaho: 19N4W17/01; and 10WN557. 

2. Site Monitoring 

 Within two years of issuance of a new project license, Licensee shall develop 

and submit a site monitoring program with data collection methods, timing, 

priorities and schedules for eligible and potentially eligible sites affected by the 

Project on BLM administered lands. The program will be developed in 

consultation with BLM and SHPOs, and subject to a minimum of 60 day 

review and comment, before submission of the final for approval by the BLM 

and SHPO. Methods and data collected for the initial monitoring program 

shall be standardized and quantifiable so as to provide adequate data for 

comparison of changes to site content, condition and impacts. At a minimum, 

documentation shall map site boundaries; update site records; provide a 

detailed description of the site, describe observed impacts; and provide 

recommendations for site protection or mitigation of any adverse effects. The 

monitoring protocol should describe how effects discovered during monitoring 

will be mitigated. Schedules, priorities and the list of sites identified for 

subsequent monitoring cycles will be adjusted based on initial results, and shall 

be prepared by Licensee in consultation with and subject to the approval of 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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BLM. Licensee shall update the monitoring program to incorporate new 

historic properties on BLM administered lands as they are identified. 

Monitoring reports and updated site records shall be provided to BLM at the 

end of each calendar year. The Licensee shall include the following known 

sites in the initial monitoring cycle: 35 BA 893; IPCBD 97-02; IPCBD 97-03; 

IPCBD 00-70; IPCBD 00-74; IPCBD 00-75; 10 WN 451, 10 AM 516, IPCBD 

97-15, IPCBD 00-52, IPCBD 00-53, IPCBD 00-54, and IPCBD 00-61. 

3. Site Protection and Stabilization 

 The Licensee shall prepare and implement site-specific plans for protection or 

stabilization of known or newly identified historic properties (including 

traditional cultural properties) on BLM land that are affected by Project 

operations. The Licensee shall develop the treatment plans in consultation with 

BLM, SHPOs, and Tribes, allowing a minimum of 60 days for review and 

comment on a draft prior to development of final plans. Plans shall be subject 

to BLM and SHPO approval. 

 Plans shall a) assess need for, feasibility of, and alternative methods for 

protection, stabilization or restoration of affected, eligible properties, b) 

identify treatment objectives, priorities, and implementation schedule and c) be 

responsive to the criteria under which a site is considered eligible for the 

National Register. The Licensee shall maintain the site protection measures 

until the treatment has achieved objectives and has been assessed as no longer 

needed in consultation with BLM and SHPO. 

 If monitoring results or condition assessments indicate that protection measures 

are needed, the Licensee shall prepare site-specific feasibility plans for 

protection or stabilization for six sites on BLM administered lands. Licensee 

shall complete the protection or stabilization measures, if feasible, for the 

following sites: 10WN 451, IPCBD 97-15, IPCBD 00-52; IPCBD 00-53, 

IPCBD 00-54, and IPCBD 00-61. Licensee shall conduct post treatment 

efficacy monitoring and provide a report of results to the BLM. 

4. Data Recovery 

 When in-place protection is not technically feasible, the Licensee shall develop 

and implement plans to recover data from affected eligible historic properties 

on BLM administered lands impacted by the Project. Plans shall be developed 

and implemented in consultation with the Advisory Council on Historic 

Preservation (ACHP) as necessary, BLM, SHPOs, and Tribes, allowing a 

minimum of 60 days for review and comment on proposed plans. 

 Within five years following issuance of a new project License, the Licensee 

shall prepare plans to stabilize or recover data from IPCBD 97-03, and to 

recover data from IPCBD 00-75. Data recovery plans shall be responsive to 

the criteria under which the site is considered eligible to the National Register. 

Licensee shall assess protection alternatives and feasibility for stabilization 

prior to implementing data recovery at IPCBD 97-03. The Licensee shall 

implement the stabilization, if feasible, and/or data recovery plans for IPCBD 

97-03 within ten years of issuance of the project license. 

ii. Curation: 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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 The Licensee shall arrange and fund long term curation, at a repository meeting 

federal curation standards, for collections and documentation resulting from 

Licensee’s studies of BLM administered resources in the APE. The Licensee shall 

comply with the curation standards and requirements established by 36 C.F.R. 79, the 

curation repository and the Oregon and Idaho SHPOs. 

iii. Plan for updated inventories within the APE; including: 

 If, over the period of the License, flow management or Project operations result in 

newly exposed, previously unsurveyed lands with potential for discoverable sites in 

the project APE, the Licensee shall inventory BLM administered lands and provide a 

report to BLM on known and newly identified sites. 

 The Licensee shall ensure that all surveys and documentation meet federal and state 

agency requirements, and shall consult with the BLM on the design of any new field 

inventories on BLM administered lands. The Licensee shall provide a minimum of 

60 days for BLM review and comment on draft survey reports and site forms for 

BLM administered land. Final reports shall be subject to BLM approval. 

iv. Interpretation and Education Plan 

 Licensee shall consult with BLM, SHPO and Tribes on the development and 

implementation of any cultural Interpretive and Educational plan(s) proposed by 

Licensee on BLM administered lands’ in the APE. Interpretative facilities or 

protection signage proposed on BLM lands shall be subject to prior BLM approval. 

v. Prior to requesting BLM approval on any plan or project which would potentially 

affect Native American historic or prehistoric properties, sacred sites, or properties of 

traditional cultural and religious importance on BLM administered land, the Licensee 

shall provide a minimum of 60 days for BLM to consult with affected Tribes. 

vi. The Licensee shall make records available to BLM of cultural resource data gathered 

by Licensee for inventory, evaluation, monitoring, or site mitigation on BLM 

administered land. 

vii. The Licensee should document procedures for maintaining confidentiality and 

security of sensitive site data and records protected under the ARPA and NHPA; 

viii. The Licensee should outline procedures for protecting historic properties during 

emergency undertakings; including how emergency undertakings will be defined, and 

how the BLM will be notified and consulted when BLM lands are involved. 

ix. The Licensee shall immediately notify BLM if any human remains, funerary items, 

sacred objects or objects of cultural patrimony, as defined in the Native American 

Graves Protection and Repatriation Act (NAGPRA) are discovered on BLM 

administered land within the APE and Project. Discovery and stop work 

requirements shall be described, in accordance with 43 C.F.R.10, for inadvertent 

discoveries of Native American human remains and other items subject to NAGPRA 

on federal lands. 

x. The Licensee shall immediately notify BLM of any discovery of previously 

unidentified cultural resources encountered during Licensee Project work on BLM 

lands. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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Modified Condition No. 6—Comprehensive Recreation Management Plan (CRMP) 

Within one year of license issuance, the Licensee shall prepare a Comprehensive Recreation 

Management Plan (CRMP) for the Project. The CRMP shall include but not be limited to provisions for: 

1. Developing and implementing the recreation conditions; 

2. Consultation with the Recreation Resource Work Group (RRWG), which may include but 

will not be limited to: U.S. Forest Service (USFS), BLM, Idaho Department of Parks and 

Recreation, Idaho Department of Fish and Game, Oregon Department of Fish and Wildlife, 

Oregon Parks and Recreation Department, and the Oregon and Idaho counties around the 

Hells Canyon Complex. 

3. A decision making structure that involves all RRWG participants; 

4. Implementing provisions of the Project CRMP according to the Americans with Disabilities 

Act; 

5. Developing a framework for monitoring that incorporates a feedback loop and trigger 

points for adaptive management; 

6. Monitoring recreation use and preferences. Monitoring methodology will be coordinated 

with the BLM to ensure that the level of detail and applicability of information is consistent 

with methodology identified in item 8 below. 

7. Protocols for consultation with agencies; 

8. Changes in recreation impacts at dispersed recreation sites will be monitored by periodic 

aerial photography. This effort will be supplemented by annual on-site examinations of the 

sites by litter and sanitation crews who will record any obvious newly-created impacts. 

9. Law enforcement; and 

10. A process to reassess need for capital and operations and maintenance (O&M) every 6th 

year. The CRMP would establish a “base” condition against which changes resultant of 

mitigations or adaptive management provisions could be compared. The CRMP shall 

include provisions for a range of recreation experiences in a variety of settings over the 

entire Hells Canyon Complex; will identify recreation facility needs; identify and correct 

public health and safety issues as they arise. The CRMP will identify the relevance of 

visitor contact, resource patrols, public outreach, interpretation, and information to best 

improve compliance with management goals. 

The CRMP will assess use and resource conflicts at dispersed recreation sites and provide 

mitigation for impacts to the BLM reservation. The CRMP will identify and implement actions to 

mitigate impacts, including measures to limit or prohibit recreation use when necessary. 

The CRMP will also define acceptable operational and maintenance standards for recreation 

facilities and enhancements, and will define monitoring and data collection standards used to evaluate 

facility condition, resource conflicts, public safety, levels of use, need for new or expanded facilities, and 

public satisfaction with recreation their recreation experience on Project and BLM-administered lands.. 

The CRMP shall be prepared in coordination with the BLM and other appropriate parties. The 

Licensee shall include with the Plan submitted to the Commission documentation of coordination and 

copies of comments and recommendations on the Plan. The Licensee shall allow a minimum of 60 days 

for the BLM to comment and to make recommendations prior to filing the Plan with the Commission for 

approval. The CRMP submitted to the Commission shall include all recommendations submitted by the 

BLM. If the Licensee does not agree with a recommendation made by BLM, the filing will include the 

Licensee’s reasons for disagreeing with the BLM recommendation, based on project-specific information. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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The Commission may consider the Licensee’s comments on the BLM recommendations in its decision 

adopting or modifying the final CRMP. The Licensee shall implement the Plan as approved by the 

Commission. 

Modified Condition No. 7—Litter and Sanitation Plan 

Within one year of license issuance, the Licensee shall develop and implement a litter and 

sanitation plan for the Project, including but not limited to: supplying dumpsters with appropriate 

frequency of service in appropriate locations near lands administered by the Bureau of Land Management 

(BLM) along the Homestead, Oxbow, and Snake River Roads, installation of permanent vault toilets at 

appropriate dispersed recreation sites, insuring the provision of at least one floating restroom on each 

reservoir, subject to capital and O&M funding provided by the Oregon State Marine Board, and by 

implementing a routine litter pickup program that is adequate to mitigate the litter problem. If monitoring 

indicates that a floating restroom is not feasible in the future at any of the Project’s reservoirs, then the 

Licensee, with the concurrence of the BLM and the Commission, shall no longer be required to maintain 

a floating restroom on such reservoir(s). Parameters to determine appropriate locations for dumpsters, 

floating restrooms and vault toilets, and adequacy of litter program will be identified within the Litter and 

Sanitation Plan. Operation and maintenance (O&M) for this plan will be the responsibility of the 

Licensee. This plan will be incorporated into the Comprehensive Recreation Management Plan (CRMP). 

The Licensee shall continue existing actions regarding litter and sanitation measures as described 

in Final License Application dated July 2003 (FLA). 

The Licensee shall implement the litter and sanitation provisions of the Baker County Settlement 

Agreement dated October 3, 2003. 

The Plan shall be prepared in coordination with the BLM and other appropriate parties. The 

Licensee shall include with the Plan submitted to the Commission documentation of coordination and 

copies of comments and recommendations on the Plan. The Licensee shall allow a minimum of 60 days 

for the BLM to comment and to make recommendations prior to filing the Plan with the Commission for 

approval. The Plan submitted to the Commission shall include all recommendations submitted by the 

BLM. If the Licensee does not agree with a recommendation made by BLM, the filing will include the 

Licensee’s reasons for disagreeing with the BLM recommendation, based on project-specific information. 

The Commission may consider the Licensee’s comments on the BLM recommendations in its decision 

adopting or modifying the final Plan. The Licensee shall implement the Plan as approved by the 

Commission. 

Modified Condition No. 8—Boat Moorage on Project Reservoirs 

Within one year of license issuance, the Licensee shall develop a Project Boat Moorage Plan and 

submit this plan to the Commission for approval. The Plan shall be implemented within three years of 

Commission approval. The Plan shall provide a minimum of one moorage facility at Westfall, Bob Creek 

section C, Airstrip, and Copper Creek on Hells Canyon Reservoir; and Oxbow Boat Launch and Carter’s 

Landing on Oxbow Reservoir. If monitoring indicates a need for additional moorage at these sites, they 

should be provided in accordance with the Plan. 

The purpose of the BLM condition for boat moorage is to mitigate impacts to terrestrial and 

aquatic resources from trampling and removal of vegetation, shoreline erosion, and soil compaction. 

Moorage facilities shall be developed to meet standards of the Oregon State Marine Board (OSMB) or 

States Organization for Boating Access (SOBA) and shall incorporate the Americans with Disabilities 

Act (ADA) Access guidelines from the Unites States Access Board. Operation and maintenance (O&M) 

of the moorage facilities shall become the responsibility of the Licensee. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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The Plan shall be prepared in coordination with the BLM and other appropriate parties. The 

Licensee shall include with the Plan submitted to the Commission documentation of coordination and 

copies of comments and recommendations on the Plan. The Licensee shall allow a minimum of 60 days 

for the BLM to comment and to make recommendations prior to filing the Plan with the Commission for 

approval. The Plan submitted to the Commission shall include all recommendations submitted by the 

BLM. If the Licensee does not agree with a recommendation made by BLM, the filing will include the 

Licensee’s reasons for disagreeing with the BLM recommendation, based on project-specific information. 

The Commission may consider the Licensee’s comments on the BLM recommendations in its decision 

adopting or modifying the final Plan. The Licensee shall implement the Plan as approved by the 

Commission. 

Modified Condition No. 9—Airstrip, Bob Creek section C, and Westfall 

Within ten years of license issuance, the Licensee shall file for Commission approval an 

Enhancement Plan for the BLM sites Airstrip, Bob Creek section C, and Westfall and submit this plan to 

the Commission for approval. The Plan shall include three site plans and design drawings; a discussion 

of how the needs of the disabled were considered in the planning and design of each facility; detailed 

erosion and sediment control measures; and a schedule for implementation and maintenance. Elements of 

the site plans would include provisions for Americans with Disabilities Act (ADA) accessibility, boat 

moorage, and one camp host site for all three sites. The provision of a public potable water source in the 

vicinity of these BLM camp sites shall be evaluated in the Plan and implemented if feasible. 

Operations and maintenance (O&M) for facilities included in this Plan shall be the responsibility 

of the Licensee. 

The Plan shall be prepared in coordination with the BLM and other appropriate parties. The 

Licensee shall include with the Plan submitted to the Commission documentation of coordination and 

copies of comments and recommendations on the Plan. The Licensee shall allow a minimum of 60 days 

for the BLM to comment and to make recommendations prior to filing the Plan with the Commission for 

approval. The Plan submitted to the Commission shall include all recommendations submitted by the 

BLM. If the Licensee does not agree with a recommendation made by BLM, the filing will include the 

Licensee’s reasons for disagreeing with the BLM recommendation, based on project-specific information. 

The Commission may consider the Licensee’s comments on the BLM recommendations in its decision 

adopting or modifying the final Plan. The Licensee shall implement the Plan as approved by the 

Commission. 

Modified Condition No. 10—Swede’s Landing 

Within four years of completing the low water boat ramp and associated campground facilities at 

Private Dude’s Cove, the Licensee shall prepare, fund and implement a plan, in coordination with BLM, 

to rehabilitate the BLM lands currently known as Swede’s Landing. The plan shall address riparian 

habitat restoration, public safety and control, and revegetation of the site, along with assessing current and 

future uses of the site. 

If the low water boat ramp and associated campground facilities at Private Dude’s Cove are not 

developed within two years of license issuance, an enhancement plan for the BLM Swede’s Landing Site 

will be developed within three years of license issuance. The Plan shall include provisions for enhanced 

campsites with kitchen areas, improved Americans with Disabilities Act (ADA) accessibility, 

enhancement of Quicksand Creek riparian area and rehabilitation, replacement of existing toilets, 

replacement of jersey barriers with a more aesthetic barrier, and shade shelters. The Plan shall include an 

implementation schedule. Operation and maintenance of the campsite facilities shall become the 

responsibility of the Licensee. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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The Licensee shall implement the road maintenance provisions of the Baker County Settlement 

Agreement dated October 3, 2003. 

The Plan shall be prepared in coordination with the BLM and other appropriate parties. The 

Licensee shall include with the Plan submitted to the Commission documentation of coordination and 

copies of comments and recommendations on the Plan. The Licensee shall allow a minimum of 60 days 

for the BLM to comment and to make recommendations prior to filing the Plan with the Commission for 

approval. The Plan submitted to the Commission shall include all recommendations submitted by the 

BLM. If the Licensee does not agree with a recommendation made by BLM, the filing will include the 

Licensee’s reasons for disagreeing with the BLM recommendation, based on project-specific information. 

The Commission may consider the Licensee’s comments on the BLM recommendations in its decision 

adopting or modifying the final Plan. The Licensee shall implement the Plan as approved by the 

Commission. 

Modified Condition No. 11—Spring Recreation Site Enhancement 

Within three years of license issuance, or on an alternative schedule to be agreed to by the Bureau 

of Land Management (BLM), the licensee shall develop an enhancement plan for the BLM site referred to 

as Spring Recreation Site and submit this plan to the Commission for approval. The Plan shall be based 

on the best data and information available and is to be an adaptive plan, subject to amendment and 

revision during the term of the new license. The Plan is intended to a be a planning document which will 

assess the current condition of the site, the nature and extent of its current, and anticipated future, use and 

contain provisions to address any current deficiencies and prepare for any increases in use that may occur 

in the future. The Plan shall include an implementation and maintenance schedule for any measures 

proposed by the Plan. The Plan may explore options for funding that may be available through a 

cooperative venture between the licensee and third-party sources through recreational or similar grants. 

The licensee shall develop the Spring Recreation Plan in consultation with the Recreation 

Resource Work Group (RRWG) and the BLM. The licensee shall submit a draft of the Spring Recreation 

Plan to members of the RRWG for review and comment. Documentation and a description of the 

consultation process including responses to any written comments received during the consultation 

process will be included as an appendix to the Plan. 

The Plan shall include provisions, among others, addressing the need for, and feasibility of, the 

following measures: 

• • Redesign vehicle circulation and relocate portions of the interior road; 

• • Increase parking capacity for day use boat trailer parking; 

• • Define camping sites, add electric and water hookups where appropriate; 

• • Improve tent camping areas including parking and ADA toilets; 

• • Surface new and existing roads and parking areas with asphalt; 

• • Develop overflow parking; 

• • Retrofit the existing boat launch and boat ramp to be ADA accessible; 

• • Design access from boat ramps to boarding docks with accessible grade according to 

Oregon State Marine Board ADA design; 

• • Replace boat dock system to minimize ongoing maintenance and to better accommodate 

reservoir drawdowns and refill; 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
C-40 

• • Improve fish cleaning station to minimize ongoing maintenance, reduce offensive odors, 

and to meet DEQ septic requirements; 

• • Retrofit water system throughout site. Develop an irrigation system for vegetation; 

• • Upgrade one RV space for a campground host including shade and septic system; and 

• • Landscape site to maximize shade and reduce dust. Install shade structures where 

appropriate. 

The Plan shall provide for the Licensee’s assumption of the responsibility associated with the 

operation and maintenance of existing and new facilities at this site, and, to the extent allowed by 

applicable law, the transfer and assignment to the Licensee of any use fees associated with this site for the 

life of the new license. 

The Spring Recreation Plan shall be prepared in coordination with the BLM and the other parties 

described above. The Licensee shall include with the Plan submitted to the Commission documentation 

of coordination and copies of comments and recommendations on the Plan. The Licensee shall allow a 

minimum of 60 days for the BLM to comment and to make recommendations prior to filing the Plan with 

the Commission for approval. The Plan submitted to the Commission shall include all recommendations 

submitted by the BLM. If the Licensee does not agree with a recommendation made by BLM, the filing 

will include the Licensee's reasons for disagreeing with the BLM recommendation, based on Projectspecific information. The Commission may consider the Licensee’s comments on the BLM 

recommendations in its decision adopting or modifying the final Plan. The Licensee shall implement the 

Plan as approved by the Commission. 

Modified Condition No. 12—Steck Recreation Site 

Within one year of license issuance, or on an alternative schedule agreed to by the Bureau of 

Land Management (BLM), the Licensee shall develop an Enhancement Plan for the BLM site referred to 

as Steck Recreation Site and submit this plan to the Commission for approval. The Plan shall be based on 

the best data and information available and is to be an adaptive plan, subject to amendment and revision 

during the term of the new license. The Plan is intended to be a planning document which will assess the 

current condition of the site, the nature and extent of its current use and anticipated future use, and contain 

provisions to address any current deficiencies and prepare for any increases in use that may occur in the 

future. The Plan shall include an implementation and maintenance schedule for any measures proposed 

by the Plan. The Plan may explore options for funding that may be available through a cooperative 

venture between the Licensee and third-party sources through recreational or similar grants. 

The Licensee shall develop the Plan in consultation with members of the Recreation Resource 

Work Group (RRWG) and the BLM. The Licensee shall submit a draft of the Enhancement Plan to the 

RRWG for review and comment. Documentation and a description of the consultation process including 

responses to any written comments received during the consultation process will be included an appendix 

to the Plan. 

The Plan shall include provisions, among others, addressing the need for, and feasibility of, 

communication capabilities for emergency and other necessary purposes to meet such needs based on site 

requirements; separate day-use facilities with shade structures, tables, cement pads, and grills, and an 

additional public information kiosk. 

The Plan shall provide for the Licensee’s assumption of the responsibility associated with the 

operation and maintenance of existing and new facilities at the site, and, to the extent allowed by 

applicable law, the transfer and assignment to the Licensee of any use fees associated with this site for the 

life of the new license. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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The Steck Enhancement Plan shall be prepared in coordination with the BLM and the other 

parties described above. The Licensee shall include with the Plan submitted to the Commission 

documentation of coordination and copies of comments and recommendations on the Plan. The Licensee 

shall allow a minimum of 60 days for the BLM to comment and to make recommendations prior to filing 

the Plan with the Commission for approval. The Plan submitted to the Commission shall include all 

recommendations submitted by the BLM. If the Licensee does not agree with a recommendation made by 

the BLM, the filing will include the Licensee’s reasons for disagreeing with the BLM recommendation, 

based on Project-specific information. The Commission may consider the Licensee’s comments on the 

BLM recommendations in its decision adopting or modifying the final Plan. The Licensee shall 

implement the Plan as approved by the Commission. 

Modified Condition No. 13—Jennifer’s Alluvial Fan 

Within two years of license issuance, the Licensee shall file for Commission approval an 

Enhancement Plan for the BLM site referred to as Jennifer’s Alluvial Fan Site for the project. The plan 

shall include a site plan, design drawings; a discussion of how the needs of the disabled were considered 

in the planning and design; detailed erosion and sediment control measures; and a schedule for 

implementation and maintenance. The plan shall include, but not be limited to provisions for a toilet, 

information kiosk with map, and barriers to delineate the site and prevent expansion of vehicle impacts, 

and improvement of access from Olds Ferry Road. The Plan shall be prepared in coordination with BLM 

and members of the Recreation Resource Working Group. The Licensee shall include with the Plan 

submitted to the Commission documentation of coordination and copies of comments and 

recommendations on the Plan. The Licensee shall allow a minimum of 60 days for the BLM to comment 

and to make recommendations prior to filing the Plan with the Commission for approval. The Plan 

submitted to the Commission shall include all recommendations submitted by the BLM. If the Licensee 

does not agree with a recommendation made by BLM, the filing will include the Licensee’s reasons for 

disagreeing with the BLM recommendation, based on Project-specific information. The Commission 

may consider the Licensee’s comments on the BLM recommendations in its decision adopting or 

modifying the final Plan. The Licensee shall implement the Plan as approved by the Commission. The 

Licensee shall assume the responsibility associated with operation and maintenance of new facilities at 

this site for the life of the new license. 

Modified Condition No. 14—Idaho Dispersed Sites 

Within five years of license issuance, the Licensee shall develop and implement a Plan for the 

BCHB(2).141 The Plan shall include a provision for a five vehicle gravel parking lot to be constructed 

adjacent to the primary paved Hells Canyon Road. The parking lot shall incorporate a barrier (such as 

natural boulders) to prevent motorized vehicle use from causing further damage to adjacent uplands. The 

Plan shall also include provisions for a portable toilet that will be available on a seasonal basis and the 

improvement of an existing trail leading from the parking area to nearby rock bluffs, if necessary. The 

BCHB(2) site will be designated as a day-use only facility. 

Within one year of the completion of this project, the Licensee shall develop and implement a 

litter and sanitation plan for BCHB(2) and for other Idaho Dispersed Sites, including, but not limited to, 

WILS142, and BICB143, consistent with Condition No. 7 (Litter and Sanitation Plan). 

 

141 BCHB is the acronym used by IPC to refer to Site No. 2 Below Hells Canyon Bridge. The site is 

located .01 miles below the Bridge across Hells Canyon Reservoir, on the Idaho side of the Snake 

River. 

142 WILS is the acronym used by IPC to refer to Williamson Creek. The site is primarily a boat-in camp 

located on the Idaho side of Oxbow Reservoir approximately 5.9 miles upstream of Oxbow Dam. 

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The Plan shall be prepared in coordination with BLM and members of the Recreation Resource 

Working Group. The Licensee shall include with the Plan submitted to the Commission documentation 

of coordination and copies of comments and recommendations on the Plan. The Licensee shall allow a 

minimum of 60 days for the BLM to comment and to make recommendations prior to filing the Plan with 

the Commission for approval. The Plan submitted to the Commission shall include all recommendations 

submitted by the BLM. If the Licensee does not agree with a recommendation made by BLM, the filing 

will include the Licensee’s reasons for disagreeing with the BLM recommendation, based on Projectspecific information. The Commission may consider the Licensee’s comments on the BLM 

recommendations in its decision adopting or modifying the final Plan. The Licensee shall implement the 

Plan as approved by the Commission. The Licensee shall assume the responsibility associated with 

operation and maintenance of new facilities at these sites for the life of the new license. 

Modified Condition No. 15—Oxbow Boat Launch and Carter’s Landing 

Within one year of license issuance, the Licensee shall, in consultation with the BLM, prepare an 

Enhancement Plan for each of the BLM sites referred to as Carter’s Landing and Oxbow Boat Launch and 

file the Plans with the Commission for approval. Each Plan shall include a site plan, design drawings; a 

discussion of how the needs of the disabled were considered in the planning and design of each facility; 

detailed erosion and sediment control measures; and a schedule for implementation and maintenance. 

The Carter’s Landing plan will include, but not be limited to, provisions for enhanced campsites with 

kitchen areas, improved Americans with Disabilities Act (ADA) accessibility, boat moorage, and shade 

shelters. Oxbow Boat Launch plan will include improved boat ramp, boarding floats, improved 

Americans with Disabilities Act (ADA) accessibility, and enhanced parking. The Licensee shall assume 

the responsibility associated with operation and maintenance of new facilities at these sites for the life of 

the new license. 

The Plan shall be prepared in coordination with the BLM and other appropriate parties. The 

Licensee shall include with the Plan submitted to the Commission documentation of coordination and 

copies of comments and recommendations on the Plan. The Licensee shall allow a minimum of 60 days 

for the BLM to comment and to make recommendations prior to filing the Plan with the Commission for 

approval. The Plan submitted to the Commission shall include all recommendations submitted by the 

BLM. If the Licensee does not agree with a recommendation made by BLM, the filing will include the 

Licensee’s reasons for disagreeing with the BLM recommendation, based on project-specific information. 

The Commission may consider the Licensee’s comments on the BLM recommendations in its decision 

adopting or modifying the final Plan. The Licensee shall implement the Plan as approved by the 

Commission. 

Modified Condition No. 16—Oasis 

Within two years of license issuance, or on an alternative schedule to be agreed to by the Bureau 

of Land Management (BLM), the Licensee shall develop an Enhancement Plan for the BLM site referred 

to as Oasis and submit this plan to the Commission for approval. The Plan shall be based on the best data 

and information available and is to be an adaptive plan, subject to amendment and revision during the 

term of the new license. The Plan is intended to a be a planning document which will assess the current 

condition of the site, the nature and extent of its current, and anticipated future, use and contain provisions 

to address any current deficiencies and prepare for any increases in use that may occur in the future. The 

 

WILS is located on IPC and private land. 

143 BICB is the acronym used by IPC to refer to Boat-in Camping Area #2. The site is primarily a boat-in 

camp located on the Idaho side of Oxbow Reservoir approximately 8.5 miles upstream of Oxbow 

Dam. BICB is located on BLM-managed land. 

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Plan shall include an implementation and maintenance schedule for any measures proposed by the Plan. 

The Plan may explore options for funding that may be available through a cooperative venture between 

the licensee and third-party sources through recreational or similar grants. 

The Licensee shall develop the Enhancement Plan in consultation with members of the 

Recreation Resource Work Group (RRWG) and the BLM. Within eighteen months of license issuance, 

the licensee shall submit a draft of the Enhancement Plan to the RRWG for review and comment. 

Documentation and a description of the consultation process including responses to any written comments 

received during the consultation process will be included as an appendix to the Plan. 

The plan shall include provisions, among others, addressing the need for, and feasibility of, 

enhanced restrooms, parking, vehicle control, day use activities, foot trail, and signing. 

The Plan shall provide for the Licensee’s assumption of the responsibility associated with the 

operation and maintenance of existing and new facilities and, to the extent allowed by applicable law, the 

transfer and assignment to the Licensee of any use fees associated with this site for the life of the new 

license. 

The Oasis Enhancement Plan shall be prepared in coordination with the BLM and the other 

parties described above. The Licensee shall include with the Plan submitted to the Commission 

documentation of coordination and copies of comments and recommendations on the Plan. The Licensee 

shall allow a minimum of 60 days for the BLM to comment and to make recommendations prior to filing 

the Plan with the Commission for approval. The Plan submitted to the Commission shall include all 

recommendations submitted by the BLM. If the Licensee does not agree [sic] 

Modified Condition No. 17—Copper Creek 

Within two years of license issuance, the Licensee shall file for Commission approval an 

Enhancement Plan, including an evaluation of potential effects to cultural resources, for the BLM site 

referred to as Copper Creek. Development and implementation shall be consistent with Section 106 of 

the National Historic Preservation Act (NHPA) and the requirements for the National Environmental 

Policy Act (NEPA). Depending on findings of these evaluations, the plan may include provisions for a 

road system serving designated campsites with picnic shelters and fire rings, trailhead parking, equestrian 

staging area, boat moorage and mitigations for soil erosion around point near mouth of Copper Creek. 

Enhancement design shall mitigate impacts to terrestrial and aquatic resources, i.e. trampling and removal 

of vegetation, shoreline erosion and soil compaction. If it is determined that enhancing the site would 

require substantial cultural site mitigation, the Licensee would consult with BLM to determine alternative 

actions that would preserve the integrity of cultural sites. 

The Licensee shall assume the responsibility associated with the operation and maintenance of 

this site for the life of the new licensee. 

The Plan shall be prepared in coordination with the BLM and other appropriate parties. The 

Licensee shall include with the Plan submitted to the Commission documentation of coordination and 

copies of comments and recommendations on the Plan. The Licensee shall allow a minimum of 60 days 

for the BLM to comment and to make recommendations prior to filing the Plan with the Commission for 

approval. The Plan submitted to the Commission shall include all recommendations submitted by the 

BLM. If the Licensee does not agree with a recommendation made by BLM, the filing will include the 

Licensee’s reasons for disagreeing with the BLM recommendation, based on project-specific information. 

The Commission may consider the Licensee’s comments on the BLM recommendations in its decision 

adopting or modifying the final Plan. The Licensee shall implement the Plan as approved by the 

Commission. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
C-44 

Modified Condition No. 18—Low Water Boat Launch 

If, within one year of license issuance, the Licensee has not constructed a Low Water Boat 

Launch at Private Dude’s Cove and if BLM Condition No. 10 for Swedes Landing has not been is 

implemented, then the following shall be implemented: 

Within the second year after license issuance, the Licensee shall file for Commission approval a 

Low-Water Boat Launch Plan. The plan shall include provisions to find a suitable location at or near 

Swedes Landing, develop a site plan and implement the site plan for a low water boat launch. The Plan 

shall include site plan design drawings; a discussion of how the needs of the disabled were considered in 

the planning and design; detailed erosion and sediment control measures; and a schedule for 

implementation and maintenance. The Licensee shall assume the responsibility associated with operation 

and maintenance of this site for the life of the new license. 

The Plan shall be prepared in coordination with the BLM and other appropriate parties. The 

Licensee shall include with the Plan submitted to the Commission documentation of coordination and 

copies of comments and recommendations on the Plan. The Licensee shall allow a minimum of 60 days 

for the BLM to comment and to make recommendations prior to filing the Plan with the Commission for 

approval. The Plan submitted to the Commission shall include all recommendations submitted by the 

BLM. If the Licensee does not agree with a recommendation made by BLM, the filing will include the 

Licensee’s reasons for disagreeing with the BLM recommendation, based on project-specific information. 

The Commission may consider the Licensee’s comments on the BLM recommendations in its decision 

adopting or modifying the final Plan. The Licensee shall implement the Plan as approved by the 

Commission. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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INTERIOR—SECTION 18 PRESCRIPTIONS 

Guidance for the Prescription of Fishways Pursuant to Section 18 of the FPA (USFWS 

2002c). 

Reservation of Authority to Prescribe Fishways 

The Service has prepared its prescriptions for fishways in response to the proposals being 

considered by the Commission in this proceeding involving the proposed relicensing of the Hells Canyon 

Hydroelectric Project, FERC No. 1971. If any proposal is modified as a result of licensing or after 

licensing, then the Department, through the Service, will require adequate opportunity to reconsider each 

prescription and make modifications it deems appropriate and necessary for submittal to the Commission. 

Therefore, the Service requests that the Commission include the following condition in any license it may 

issue for the Project, Commission No. 1971: 

Authority is reserved for the Department of the Interior, as delegated to the U.S. Fish and 

Wildlife Service, to prescribe the construction, operation, and maintenance of fishways at 

the Hells Canyon Hydroelectric Project, Project No. 1971, as appropriate, including 

measures to determine, ensure, or improve the effectiveness of such fishways, pursuant to 

Section 18 of the Federal Power Act, as amended. This reservation includes, but is not 

limited to, authority to prescribe fishways for spring/summer Chinook salmon, summer 

steelhead trout, Pacific lamprey, bull trout, redband trout, fall Chinook salmon, white 

sturgeon, and any other fish to be managed, enhanced, protected, or restored to the Snake 

River Basin during the term of the license. 

Modified Section 18 Fishway Prescription 

1.0. Upstream and Downstream Fishways for Bull Trout 

To provide for the safe, timely and effective upstream passage of adult and subadult bull trout at 

the Hells Canyon Project, the Licensee shall continue to rehabilitate, operate, and monitor the Hells 

Canyon Dam trap and haul fishway and modify the existing structure as described in the Preferred 

Alternative to the Additional Information Request—Aquatic Resources Number 1 (AIR AR-1) to the 

Hells Canyon Complex Final License Application. A second phase of the passage prescription is to 

construct a trap similar in operation and design to the Hells Canyon trap to provide for the safe, timely 

and effective upstream passage of adult and sub-adult bull trout at the base of Oxbow Dam. The future 

fishway/trap at the base of Oxbow Dam shall include measures and operations necessary to provide 

adequate attraction flow to safely and rapidly attract bull trout into the Oxbow trap for collection and 

transport upstream. Final documentation of what flows and/or mechanisms are necessary for effective 

fish collection at Oxbow Dam will occur in the amendment to the Bull Trout Passage Plan when the 

trigger criteria to pass bull trout upstream of Oxbow Dam has been met. All upstream facilities 

prescribed herein shall be designed and operated to meet the anadromous passage facility guideline and 

criteria established by NOAA Fisheries (NOAA Fisheries 2004).144

To provide for safe, timely and effective downstream passage of migrating adult and sub-adult 

bull trout from bull trout bearing (a tributary that supports all life stages of bull trout) tributaries into the 

reservoirs of the Hells Canyon Complex (Pine Creek, Indian Creek, and the Wildhorse River), the 

Licensee shall construct operate, maintain and monitor permanent weirs and trap and haul fishways near 

the mouths of these tributaries for the downstream passage and transport of adult and subadult bull trout 

 

144 Ibid 

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to a suitable release point downstream of Hells Canyon Dam. The period of facility operation will be 

determined through the bull trout passage planning process and may be adapted based on information 

gathered through future monitoring efforts to meet the biological needs of bull trout in each identified 

tributary system. All downstream facilities prescribed herein shall be designed and operated to meet the 

anadromous passage facility guideline and criteria established by NOAA Fisheries (NOAA Fisheries 

2004).145

Implementation of Fishway Prescription 

To implement the above prescription, the Licensee shall, within 1 year of license issuance, in 

consultation with the Service, the Oregon Department of Fish and Wildlife, the Idaho Department of Fish 

and Game, and the affected consulting parties develop and file with Federal Energy Regulatory 

Commission (Commission), a Bull Trout Passage Plan. The Bull Trout Passage Plan shall be submitted 

to the consulting agencies for a 60-day period for review and comment period for approval prior to 

submittal to the Commission for approval and implementation. The Bull Trout Passage Plan shall 

include: 1) final engineering design plans of the Hells Canyon upstream trap fishway modification, 2) 

final engineering design plans of the Pine Creek monitoring weir and trap fishway including a schedule 

to construct the fishway within two years of license issuance; 3) specific protocols for the period of 

operation, location of release point and handling of all lifestages of bull trout and other fish captured for 

these two facilities; 4) provisions for transport of bull trout between Pine Creek and Hells Canyon Dam, 

5) an assessment of monitoring necessary to evaluate the potential and risk of introductions of deleterious 

pathogens, and 6) a Post-construction monitoring plan. The Bull Trout Passage plan shall also include 

description of specific triggers related to the timeline of construction and implementation of the Oxbow 

upstream trap fishway, the Indian Creek permanent weir and trap fishway, and the Wildhorse River weir 

and trap fishway. The Plan will include specific monitoring necessary to determine when established 

triggers have been satisfied. Triggers that establish the timeline of construction and implementation of 

these facilities shall be based on the status of bull trout within these tributaries in terms of their 

abundance, the potential for hybridization with non-native brook trout, the potential of the fishways to 

contribute towards recovery, and habitat conditions necessary to support bull trout. The Bull Trout 

Passage Plan shall contain a provision that within 1 year of meeting the trigger criteria for one of these 

facilities, as determined by the consulting agencies, an Amendment to the Bull Trout Plan shall be filed 

that contains specifications for the period of operation, location, design, construction and operation of the 

facility, a provision for transport of captured fish to their designated release points, and establish suitable 

protocol and release point for handling all life-stages of bull trout and other fish captured in the facilities. 

The Amendment for each facility shall be submitted to the consulting agencies for a 60-day review and 

comment period for approval prior to submittal to the Commission for approval and implementation. 

Construction of passage facilities shall begin within 2 years of meeting trigger criteria, unless another 

timeframe is mutually agreed upon by the consulting agencies. 

A Post-construction Monitoring Plan shall be developed for the Hells Canyon upstream fishway 

and Pine Creek weir and trap and shall be included with the Bull Trout Passage Plan. The Postconstruction Monitoring Plan shall be to describe the evaluation and monitoring necessary to determine 

the effectiveness of each facility. Such a plan will be part of each Amendment to the Bull Trout Passage 

Plan that initiates Commission approval of each fishway as trigger criteria are met. The Post-construction 

monitoring plan shall include operation and maintenance (O&M) procedures (including operator training 

and supervision) of each facility as they are constructed to insure effective operation. The O&M 

procedures shall include provisions for prior notification and coordination with the consulting agencies 

regarding maintenance scheduling or emergency operations that affect the functioning of each fishway. 

 

145 Ibid 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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Document Accession #: 20070831-4002 Filed Date: 08/31/2007
APPENDIX D 

MODELED CONSTRAINTS FOR IDAHO POWER COMPANY’S 

PROPOSED OPERATION AND OPERATIONAL ALTERNATIVES 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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To support the evaluation of resource effects of alternative operating regimes, Idaho Power used a 

simulation computer model for hydropower systems, called CHEOPS.146 CHEOPS evaluates physical 

and operational changes at multiple-development hydroelectric projects. It is designed to emphasize 

long-term simulations of project operations, and it emphasizes maintaining correct mass balances in 

reported flows and meeting all project-related operating constraints. This appendix presents the 

constraints used in the CHEOPS modeling of project operations for the Applicant’s Proposed Operation 

(Section 2.2.2) and for the several alternative operating scenarios described in DEIS Section 2.3.2. 

Following are the operating scenarios evaluated: 

• Applicant’s Proposed Operation 

• Alternative Operating Scenarios 

 Scenario 1(a). Stabilized Hells Canyon Release, with instantaneous outflow from Hells 

Canyon dam equaling the average inflow to the Hells Canyon reservoir during the 

previous 24 hours. 

 Scenario 1(b). Stabilized Hells Canyon Release, with maximum ramping rate of 

2 inches per hour (year-round). 

 Scenario 1(c). Stabilized Hells Canyon Release, with maximum ramping rate of 

6 inches per hour (year-round). 

 Scenario 1(d). Stabilized Hells Canyon Release, with maximum ramping rate of 

2 inches per hour (March 1 through May 31). 

 Scenario 1(e). Stabilized Hells Canyon Release, with maximum ramping rate of 

6 inches per hour (March 1 through May 31). 

 Scenario 1(f). Stabilized Hells Canyon Release, with maximum ramping rate of 

2 inches per hour March 1 through May 31 and 6 inches per hour for the rest of the year, 

plus a maximum total daily fluctuation of 2.0 feet year-round. 

 Scenario 2. Flow Augmentation with Stabilized Release. 

 Scenario 3. Navigation Target Flow. 

 Scenario 7. Stabilized Hells Canyon Release, with a seasonal maximum ramping rate of 

4 inches per hour March 15 through June 15 and 1 foot per hour the remainder of the 

year. Ramp rate compliance was modeled at Johnson Bar. 

 Scenario 8. A 237-kaf release of flow augmentation water from Brownlee reservoir by 

refilling to elevation 2,077 feet msl by June 20, beginning augmentation on June 21, 

with target reservoir elevations set to 2,066 feet msl on July 15 and 2,059 feet msl on 

July 31, with no refill to occur before August 31. 

 Scenario 9. A combination of Scenarios 7 and 8. 

 

146 The content of the appendix is based on Idaho Power’s Responses to FERC Additional Information 

Request OP-1(a) Operational Scenarios, Power Economics, February 2005 (scenarios 1, 2 and 3) and 

Idaho Power’s March 30, 2007 response to FERC’s February 23, 2007, Additional Information 

Request (scenarios 7, 8, and 9). 

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Table 1. Constraints for modeled proposed operations and Scenarios 1a and 1b for the 

Brownlee development. 

Constraints 

Brownlee Development 

Modeled Proposed 

Operations Scenario 1a Scenario 1b 

Maximum reservoir elevation 2,077 feet msl 2,077 feet msl 2,077 feet msl 

Minimum reservoir elevation 1,976 feet msl 1,976 feet msl 1,976 feet msl 

Flood-control Requirements 

Brownlee reservoir official 

target elevations specified for 

February 28, March 31, April 

15, and April 30 

Corps flood-control rule 

curve requirementsa

Corps flood-control 

rule curve 

requirementsa

Corps flood-control 

rule curve 

requirementsa

Daily Reservoir-level Fluctuationb 

January 1 through May 20 3 feet 3 feet 3 feet 

May 21 through June 21 for 

resident fish spawning 

1 foot 1 foot 1 foot 

June 22 through December 31 3 feet 3 feet 3 feet 

Reservoir Target Elevation 

June 7 2,069 feet msl or higherc

 2,069 feet msl or 

higherc

2,069 feet msl or 

higherc

June 8 through July 5 2,075 feet msld

 2,075 feet msld 2,075 feet msld

August 31e

 

High water year 2,059 feet msl 2,059 feet msl 2,059 feet msl 

Medium water year 2,069 feet msl 2,069 feet msl 2,069 feet msl 

Low water year 2,072 feet msl 2,072 feet msl 2,072 feet msl 

October 21f 2,040 feet msl or higher 2,040 feet msl or higher 2,040 feet msl or higher 

December 11 through 31g 2,075 feet msl 2,075 feet msl 2,075 feet msl 

a

 For modeling purposes, reservoir target elevations are calculated in the model using the Corps’ 1998 modified 

rule curve procedure and are based on observed inflows (not monthly forecasts). Flood-control requirements 

are not modeled past the last April 30 target date. 

b

 Dates specified are for modeling purposes only and may vary under actual operations. 

c

 The elevation of 2,069 feet msl or higher was set as a target in the model for June 7 for resident fish spawning 

requirements. 

d

 A full reservoir during this period helps Idaho Power meet peak summer load demands. The dates specified are 

for modeling purposes only and would vary as a function of Idaho Power’s system needs and water conditions. 

e

 This target was only specified in the model for this date as a means of modeling power needs of the system by 

drafting Brownlee reservoir. The specified target was also a function of water year type. 

f

 Reservoir elevation for modeling purposes was calculated as a function of the specified fall Chinook flow for 

water year type for Hells Canyon Development discharge (see table 6). This calculation resulted in reservoir 

elevations typically 2,040 feet msl or higher, except under extreme high-water conditions for the model runs. 

g

 In the late fall, the reservoir is operated to accommodate the fall Chinook program, and in early December, 

Idaho Power attempts to have a full reservoir, typically around 2,075 feet msl, to help meet peak winter load 

conditions. December 11 was specified for modeling purposes only and is a function of inflow and system or 

load needs during this period. 

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Table 2. Constraints for Scenarios 1c, 1d, and 1e for the Brownlee development. 

Constraints 

Brownlee Development Scenario 1c Scenario 1d Scenario 1e 

Maximum reservoir elevation 2,077 feet msl 2,077 feet msl 2,077 feet msl 

Minimum reservoir elevation 1,976 feet msl 1,976 feet msl 1,976 feet msl 

Flood-control Requirements 

Brownlee reservoir official 

target elevations specified for 

February 28, March 31, April 

15, and April 30 

Corps flood-control rule 

curve requirementsa

Corps flood-control 

rule curve 

requirementsa

Corps flood-control 

rule curve 

requirementsa

Daily Reservoir-level Fluctuationb 

January 1 through May 20 3 feet 3 feet 3 feet 

May 21 through June 21 for 

resident fish spawning 

1 foot 1 foot 1 foot 

June 22 through December 31 3 feet 3 feet 3 feet 

Reservoir Target Elevation 

June 7 2,069 feet msl or higherc

 2,069 feet msl or 

higherc

2,069 feet msl or 

higherc

June 8 through July 5 2,075 feet msld

 2,075 feet msld 2,075 feet msld

August 31e

 

High water year 2,059 feet msl 2,059 feet msl 2,059 feet msl 

Medium water year 2,069 feet msl 2,069 feet msl 2,069 feet msl 

Low water year 2,072 feet msl 2,072 feet msl 2,072 feet msl 

October 21f 2,040 feet msl or higher 2,040 feet msl or higher 2,040 feet msl or higher 

December 11 through 31g 2,075 feet msl 2,075 feet msl 2,075 feet msl 

a

 For modeling purposes, reservoir target elevations are calculated in the model using the Corps’ 1998 modified 

rule curve procedure and are based on observed inflows (not monthly forecasts). Flood-control requirements 

are not modeled past the last April 30 target date. 

b

 Dates specified are for modeling purposes only and may vary under actual operations. 

c

 The elevation of 2,069 feet msl or higher was set as a target in the model for June 7 for resident fish spawning 

requirements. 

d

 A full reservoir during this period helps Idaho Power meet peak summer load demands. The dates specified are 

for modeling purposes only and would vary as a function of Idaho Power’s system needs and water conditions. 

e

 This target was only specified in the model for this date as a means of modeling power needs of the system by 

drafting Brownlee reservoir. The specified target was also a function of water year type. 

f

 Reservoir elevation for modeling purposes was calculated as a function of the specified fall Chinook flow for 

water year type for Hells Canyon Development discharge (see table 6). This calculation resulted in reservoir 

elevations typically 2,040 feet msl or higher, except under extreme high-water conditions for the model runs. 

g

 In the late fall, the reservoir is operated to accommodate the fall Chinook program, and in early December, 

Idaho Power attempts to have a full reservoir, typically around 2,075 feet msl, to help meet peak winter load 

conditions. December 11 was specified for modeling purposes only and is a function of inflow and system or 

load needs during this period. 

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Table 3. Constraints for Scenarios 1f, 2, and 3 for the Brownlee development. 

Constraints 

Brownlee Development Scenario 1f Scenario 2 Scenario 3 

Maximum reservoir elevation 2,077 feet msl 2,077 feet msl 2,077 feet msl 

Minimum reservoir elevation 1,976 feet msl 1,976 feet msl 1,976 feet msl 

Flood-control Requirements 

Brownlee reservoir official 

target elevations specified for 

February 28, March 31, April 

15, and April 30 

Corps flood-control rule 

curve requirementsa

Corps flood-control 

rule curve 

requirementsa

Corps flood-control 

rule curve 

requirementsa

Daily Reservoir-level Fluctuationb 

January 1 through May 20 3 feet 3 feet 3 feet 

May 21 through June 21 for 

resident fish spawning 

1 foot 1 foot 1 foot 

June 22 through December 31 3 feet 3 feet 3 feet 

Reservoir Target Elevation 

June 7 2,069 feet msl or higherc

 2,069 feet msl or 

higherc

2,069 feet msl or 

higherc

June 8 through July 5 2,075 feet msld

 NA 2,075 feet msld

June 8 through June 20 NA 2,075 feet msl NA

July 5 NA 2,069 feet msl NA

July 31 through August 31 NA 2,049 feet msl NA

August 31e 

High water year 2,059 feet msl 2,049 feet msl 2,059 feet msl 

Medium water year 2,069 feet msl 2,049 feet msl 2,069 feet msl 

Low water year 2,072 feet msl 2,049 feet msl 2,072 feet msl 

October 21f 2,040 feet msl or higher 2,040 feet msl or higher 2,040 feet msl or higher 

December 11 through 31g 2,075 feet msl 2,075 feet msl 2,075 feet msl 

Note: NA – Not applicable 

a

 For modeling purposes, reservoir target elevations are calculated in the model using the Corps’ 1998 modified 

rule curve procedure and are based on observed inflows (not monthly forecasts). Flood-control requirements 

are not modeled past the last April 30 target date. 

b

 Dates specified are for modeling purposes only and may vary under actual operations. 

c

 The elevation of 2,069 feet msl or higher was set as a target in the model for June 7 for resident fish spawning 

requirements. 

d

 A full reservoir during this period helps Idaho Power meet peak summer load demands. The dates specified are 

for modeling purposes only and would vary as a function of Idaho Power’s system needs and water conditions. 

e

 This target was only specified in the model for this date as a means of modeling power needs of the system by 

drafting Brownlee reservoir. The specified target was also a function of water year type. 

f

 Reservoir elevation for modeling purposes was calculated as a function of the specified fall Chinook flow for 

water year type for Hells Canyon Development discharge (see table 6). This calculation resulted in reservoir 

elevations typically 2,040 feet msl or higher, except under extreme high-water conditions for the model runs. 

g

 In the late fall, the reservoir is operated to accommodate the fall Chinook program, and in early December, 

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D-8 

Idaho Power attempts to have a full reservoir, typically around 2,075 feet msl, to help meet peak winter load 

conditions. December 11 was specified for modeling purposes only and is a function of inflow and system or 

load needs during this period. 

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D-9 

Table 4. Constraints for Scenarios 7, 8, and 9 for the Brownlee development. 

Constraints 

Brownlee Development Scenario 7 Scenario 8 Scenario 9 

Maximum reservoir elevation 2,077 feet msl 2,077 feet msl 2,077 feet msl 

Minimum reservoir elevation 1,976 feet msl 1,976 feet msl 1,976 feet msl 

Flood-control Requirements 

Brownlee reservoir official 

target elevations specified for 

February 28, March 31, April 

15, and April 30 

Corps flood-control rule 

curve requirementsa

Corps flood-control 

rule curve 

requirementsa

Corps flood-control 

rule curve 

requirementsa

Daily Reservoir-level Fluctuationb 

January 1 through May 20 3 feet 3 feet 3 feet 

May 21 through June 21 for 

resident fish spawning 

1 foot 1 foot 1 foot 

June 22 through December 31 3 feet 3 feet 3 feet 

Reservoir Target Elevation 

June 7 2,069 feet msl or higherc

 2,069 feet msl or 

higherc

2,069 feet msl or 

higherc

June 21 2,075 feet msld

 2,077 feet msld 2,077 feet msld

July 15 2,075 feet msld

 2,066 feet msle 2,066 feet msle 

July 31 2,075 feet msld 2,059 feet msle 2,059 feet msle

August 31f

 

High water year 2,059 feet msl 2,059 feet msl 2,059 feet msl 

Medium water year 2,069 feet msl 2,059 feet msl 2,059 feet msl 

Low water year 2,072 feet msl 2,059 feet msl 2,059 feet msl 

October 21g 2,040 feet msl or higher 2,040 feet msl or higher 2,040 feet msl or higher 

December 11 through 31h 2,075 feet msl 2,075 feet msl 2,075 feet msl 

a

 For modeling purposes, reservoir target elevations are calculated in the model using the Corps’ 1998 modified 

rule curve procedure and are based on observed inflows (not monthly forecasts). Flood-control requirements 

are not modeled past the last April 30 target date. 

b

 Dates specified are for modeling purposes only and may vary under actual operations. 

c

 The elevation of 2,069 feet msl or higher was set as a target in the model for June 7 for resident fish spawning 

requirements. 

d

 A full reservoir during this period helps Idaho Power meet peak summer load demands. The dates specified are 

for modeling purposes only and would vary as a function of Idaho Power’s system needs and water conditions. 

e Brownlee flow augmentation contribution of 237,000 acre-feet. f

 This target was only specified in the model for this date as a means of modeling power needs of the system by 

drafting Brownlee reservoir. The specified target was also a function of water year type except for Scenarios 8 

and 9. 

g

 Reservoir elevation for modeling purposes was calculated as a function of the specified fall Chinook flow for 

water year type for Hells Canyon Development discharge. This calculation resulted in reservoir elevations 

typically 2,040 feet msl or higher, except under extreme high-water conditions for the model runs. 

h

 In the late fall, the reservoir is operated to accommodate the fall Chinook program, and in early December, 

Idaho Power attempts to have a full reservoir, typically around 2,075 feet msl, to help meet peak winter load 

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conditions. December 11 was specified for modeling purposes only and is a function of inflow and system or 

load needs during this period. 

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D-11 

Table 5. Constraints for modeled proposed operations and alternative scenarios for the Oxbow 

development. 

Constraints 

Oxbow Development Modeled Proposed Operations 

Scenarios 1a, 1b, 1c, 1d, 1e, 

1f, 2, 3, 7, 8, and 9 

Maximum reservoir elevation 1,805 feet msl 1,805 feet msl 

Minimum reservoir elevation 1,800 feet msl 1,800 feet msl 

Daily reservoir-level fluctuation 

(January 1 through December 31)a

5 feet 5 feet 

Bypass flow (January 1 through 

December 31) 

100 cfs 100 cfs 

a

 The typical operating limit for modeling purposes was 5 feet. 

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Table 6. Constraints for modeled proposed operations and Scenarios 1a and 1b for the Hells 

Canyon development. 

Constraints 

Hells Canyon Development 

Modeled Proposed 

Operations Scenario 1aa

 Scenario 1b 

Maximum reservoir elevation 1,688 feet msl 1,688 feet msl 1,688 feet msl 

Minimum reservoir elevation 1,683 feet mslb 1,668 feet mslc 1,668 feet mslc

Daily reservoir-level fluctuation 

limit (January 1 through 

December 31) 

5 feet None None 

Ramp-rate Restrictionb 

Ramp rate 1 foot per hour None 2 inches per hour 

Compliance ramp-rate curved Johnson Bar Hells Canyon Hells Canyon 

Daily Limit Between Minimum and Maximum Flows 

December 12 through May 31 None No load following None 

June 1 through September 30 10,000 cfse No load following 10,000 cfse

October 1 through October 20 None No load following None 

October 21 through December 11f

 No load following No load following No load following 

Minimum Instantaneous Flows 

December 12 through May 31g

 

Low 8,500 cfs 8,500 cfs 8,500 cfs 

Medium 10,500 cfs 10,500 cfs 10,500 cfs

High 12,000 cfs 12,000 cfs 12,000 cfs

June 1 through October 20

Low 6,500 cfsh 6,500 cfsh 6,500 cfsh

Medium 6,500 cfsh

 6,500 cfsh 6,500 cfsh

High 6,500 cfsh

 6,500 cfsh 6,500 cfsh

October 21 through December 11f

 

Low 9,000 cfs 9,000 cfs 9,000 cfs 

Medium 11,500 cfs 11,500 cfs 11,500 cfs 

High 13,000 cfs 13,000 cfs 13,000 cfs 

a

 The model passed daily average flow below Hells Canyon dam in this scenario with no load following. Flood 

control and the fall Chinook program are also modeled in this scenario. 

b

 The typical operating limit for modeling purposes was 5 feet. 

c

 An extreme minimum was defined for modeling purposes such that the model was not constrained under these 

scenario constraints. 

d

 Compliance was modeled at either the Johnson Bar gage, located approximately 17.6 miles downstream of 

Hells Canyon dam or at the Hells Canyon gage, located 0.6 mile downstream of Hells Canyon Dam. 

e

 A limit of 10,000 cfs was modeled during this time frame to represent typical operations. 

f

 For modeling purposes only, flows under the fall Chinook program began October 21 and ended December 11. 

g

 Releases under the fall Chinook program are reduced in the model and assume that the most critical shallow 

redd is still protected under load-following conditions downstream of the Hells Canyon Complex. The 

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D-14 

December 12 date was specified for modeling purposes only, since the actual date that fall Chinook spawning is 

completed can vary. h Minimum flow modeled was 6,500 cfs or project inflow during this period to avoid drafting Brownlee reservoir. 

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Table 7. Constraints for Scenarios 1c, 1d, and 1e for the Hells Canyon development. 

Constraints 

Hells Canyon Development Scenario 1c Scenario 1d Scenario 1e 

Maximum reservoir elevation 1,688 feet msl 1,688 feet msl 1,688 feet msl 

Minimum reservoir elevation 1,668 feet msla 1,668 feet msla 1,668 feet msla

Daily reservoir-level fluctuation 

limit (January 1 through 

December 31) 

None None None 

Ramp-rate Restrictionb 

Ramp rate 6 inches per hour 1 foot per hour (except 

2 inches per hour from 

March 1–May 31) 

1 foot per hour 

(except 6 inches per 

hour from March 1–

May 31) 

Compliance ramp-rate curvec Hells Canyon Hells Canyon Hells Canyon 

Daily Limit Between Minimum and Maximum Flows 

December 12 through May 31 None None None 

June 1 through September 30 10,000 cfsd

 10,000 cfsd 10,000 cfsd

October 1 through October 20 None None None 

October 21 through December 11e

 No load following No load following No load following 

Minimum Instantaneous Flows 

December 12 through May 31f

 

Low 8,500 cfs 8,500 cfs 8,500 cfs 

Medium 10,500 cfs 10,500 cfs 10,500 cfs

High 12,000 cfs 12,000 cfs 12,000 cfs

June 1 through October 20

Low 6,500 cfsg 6,500 cfsg 6,500 cfsg

Medium 6,500 cfsg

 6,500 cfsg 6,500 cfsg

High 6,500 cfsg

 6,500 cfsg 6,500 cfsg

October 21 through December 11e

 

Low 9,000 cfs 9,000 cfs 9,000 cfs 

Medium 11,500 cfs 11,500 cfs 11,500 cfs 

High 13,000 cfs 13,000 cfs 13,000 cfs 

a

 An extreme minimum was defined for modeling purposes such that the model was not constrained under these 

scenario constraints. 

b

 The typical operating limit for modeling purposes was 5 feet. 

c

 Compliance was modeled at either the Johnson Bar gage, located approximately 17.6 miles downstream of 

Hells Canyon dam or at the Hells Canyon gage, located 0.6 mile downstream of Hells Canyon Dam. 

d

 A limit of 10,000 cfs was modeled during this time frame to represent typical operations. 

e

 For modeling purposes only, flows under the fall Chinook program began October 21 and ended December 11. 

f

 Releases under the fall Chinook program are reduced in the model and assume that the most critical shallow 

redd is still protected under load-following conditions downstream of the Hells Canyon Complex. The 

December 12 date was specified for modeling purposes only, since the actual date that fall Chinook spawning is 

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D-16 

completed can vary. g Minimum flow modeled was 6,500 cfs or project inflow during this period to avoid drafting Brownlee reservoir. 

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Table 8. Constraints for Scenarios 1f, 2, and 3 for the Hells Canyon development. 

Constraints 

Hells Canyon Development Scenario 1f Scenario 2 Scenario 3 

Maximum reservoir elevation 1,688 feet msl 1,688 feet msl 1,688 feet msl 

Minimum reservoir elevation 1,668 feet msla 1,683 feet mslb (except 1,668 

feet msl from March 1–May 31)a

1,683 feet mslb

Daily reservoir-level fluctuation 

limit (January 1 through 

December 31) 

None 5 feet (except none from 

March 1–May 31) 

5 feet 

Ramp-rate Restrictionb 

Ramp rate 6 inches per hour 1 foot per hour 1 foot per hour 

2 inches per hour 

(March 1–May 31) 

2 inches per hour 

(March 1–May 31) 

Compliance ramp-rate curvec Hells Canyon Hells Canyon Johnson Bar 

Daily Limit Between Minimum and Maximum Flows 

December 12 through May 31 2 feet on gage None None 

June 1 through September 30 2 feet on gage 10,000 cfsd 10,000 cfsd

October 1 through October 20 2 feet on gage None None 

October 21 through December 11e

 No load following No load following No load following 

Minimum Instantaneous Flows 

December 12 through May 31f

 

Low 8,500 cfs 8,500 cfs 8,500 cfs 

Medium 10,500 cfs 10,500 cfs 10,500 cfs

High 12,000 cfs 12,000 cfs 12,000 cfs

June 1 through October 20

Low 6,500 cfsg 6,500 cfsg 8,500 cfsh

Medium 6,500 cfsg

 6,500 cfsg 8,500 cfsh

High 6,500 cfsg

 6,500 cfsg 8,500 cfsh

October 21 through December 11e

 

Low 9,000 cfs 9,000 cfs 9,000 cfsi

Medium 11,500 cfs 11,500 cfs 11,500 cfs 

High 13,000 cfs 13,000 cfs 13,000 cfs 

a

 An extreme minimum was defined for modeling purposes such that the model was not constrained under these 

scenario constraints. 

b

 The typical operating limit for modeling purposes was 5 feet. 

c

 Compliance was modeled at either the Johnson Bar gage, located approximately 17.6 miles downstream of 

Hells Canyon dam or at the Hells Canyon gage, located 0.6 mile downstream of Hells Canyon dam. 

d

 A limit of 10,000 cfs was modeled during this time frame to represent typical operations. 

e

 For modeling purposes only, flows under the fall Chinook program began October 21 and ended December 11. 

f

 Releases under the fall Chinook program are reduced in the model and assume that the most critical shallow 

redd is still protected under load-following conditions downstream of the Hells Canyon Complex. The 

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December 12 date was specified for modeling purposes only, since the actual date that fall Chinook spawning is 

completed can vary. 

g Minimum flow modeled was 6,500 cfs or project inflow during this period to avoid drafting Brownlee reservoir. 

h

 The minimum instantaneous flow modeled was 8,500 cfs unless inflows to Brownlee reservoir dropped below 

8,500 cfs. When this occurred, the modeled minimum instantaneous flow below the Hells Canyon development 

was calculated as the 3-day moving average of Brownlee reservoir inflow. 

i

 The constant flows below the Hells Canyon development were not modified during the fall Chinook program to 

achieve 11,500 cfs downstream of the mouth of the Salmon River. 

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Table 9. Constraints for Scenarios 7, 8, and 9 for the Hells Canyon development. 

Constraints 

Hells Canyon Development Scenario 7 Scenario 8 Scenario 9 

Maximum reservoir elevation 1,688 feet msl 1,688 feet msl 1,688 feet msl 

Minimum reservoir elevation 1,683 feet msla 1,683 feet msla 1,683 feet msla

Daily reservoir-level fluctuation 

limit (January 1 through 

December 31) 

5 feet 5 feet 5 feet 

Ramp-rate Restrictiona 

Ramp rate 4 inches per hour 

(March 15–June 15) 

1 foot per hour 4 inches per year 

(March 15–June 15) 

Compliance ramp-rate curveb Johnson Bar Johnson Bar Johnson Bar 

Daily Limit Between Minimum and Maximum Flows 

December 12 through May 31 None None None 

June 1 through September 30 10,000 cfsc

 10,000 cfsc 10,000 cfsc

October 1 through October 20 None None None 

October 21 through December 11d

 No load following No load following No load following 

Minimum Instantaneous Flows 

December 12 through May 31e

 

Low 8,500 cfs 8,500 cfs 8,500 cfs 

Medium 10,500 cfs 10,500 cfs 10,500 cfs

High 12,000 cfs 12,000 cfs 12,000 cfs

June 1 through October 20

Low 6,500 cfsf 6,500 cfsf 6,500 cfsf

Medium 6,500 cfsf

 6,500 cfsf 6,500 cfsf

High 6,500 cfsf

 6,500 cfsf 6,500 cfsf

October 21 through December 11d

 

Low 9,000 cfs 9,000 cfs 9,000 cfsi

Medium 11,500 cfs 11,500 cfs 11,500 cfs 

High 13,000 cfs 13,000 cfs 13,000 cfs 

a

 The typical operating limit for modeling purposes was 5 feet. 

b

 Compliance was modeled at either the Johnson Bar gage, located approximately 17.6 miles downstream of 

Hells Canyon dam. 

c

 A limit of 10,000 cfs was modeled during this time frame to represent typical operations. 

d

 For modeling purposes only, flows under the fall Chinook program began October 21 and ended December 11. 

e

 Releases under the fall Chinook program are reduced in the model and assume that the most critical shallow 

redd is still protected under load-following conditions downstream of the Hells Canyon Complex. The 

December 12 date was specified for modeling purposes only, since the actual date that fall Chinook spawning is 

completed can vary. 

f Minimum flow modeled was 6,500 cfs or project inflow during this period to avoid drafting Brownlee reservoir. 

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APPENDIX E 

FLOW FLUCTUATIONS DOWNSTREAM OF HELLS CANYON DAM—FIGURES

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Figure E-1 Simulated river flows for the Snake River near Hells Canyon dam (top) 

and near Anatone (bottom) modeled under Proposed Operations for 

extremely low water conditions. (Source: Brink and Chandler, 2005-

OP-1f) 

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Figure E-2 Simulated river flows for the Snake River near Hells Canyon dam (top) 

and near Anatone (bottom) modeled under Proposed Operations for 

medium water condition. (Source: Brink and Chandler, 2005-OP-1f) 

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Figure E-3 Simulated river flows for the Snake River near Hells Canyon dam (top) 

and near Anatone (bottom) modeled under Proposed Operations for 

extremely high water conditions. (Source: Brink and Chandler, 2005-

OP-1f) 

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Figure E-4 Simulated river flows for the Snake River near Hells Canyon dam (top) 

and near Anatone (bottom) modeled under Scenario 1b (Year-round 2-

Inches-Per-Hour Ramping Rate) for extremely low water conditions. 

(Source: Brink and Chandler, 2005-OP-1f) 

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Figure E-5 Simulated river flows for the Snake River near Hells Canyon dam (top) 

and near Anatone (bottom) modeled under Scenario 1b (Year-round 2-

Inches-Per-Hour Ramping Rate) for medium water conditions. (Source: 

Brink and Chandler, 2005-OP-1f) 

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Figure E-6 Simulated river flows for the Snake River near Hells Canyon dam (top) 

and near Anatone (bottom) modeled under Scenario 1b (Year-round 2-

Inches-Per-Hour Ramping Rate) for extremely high water conditions. 

(Source: Brink and Chandler, 2005-OP-1f) 

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Figure E-7 Simulated river flows for the Snake River near Hells Canyon dam (top) 

and near Anatone (bottom) modeled under Scenario 1c (Year-round 6-

Inches-Per-Hour Ramping Rate) for extremely low water conditions. 

(Source: Brink and Chandler, 2005-OP-1f) 

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Figure E-8 Simulated river flows for the Snake River near Hells Canyon dam (top) 

and near Anatone (bottom) modeled under Scenario 1c (Year-round 6-

Inches-Per-Hour Ramping Rate) for medium water conditions. (Source: 

Brink and Chandler, 2005-OP-1f) 

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Figure E-9 Simulated river flows for the Snake River near Hells Canyon dam (top) 

and near Anatone (bottom) modeled under Scenario 1c (Year-round 6-

Inches-Per-Hour Ramping Rate) for extremely high water conditions. 

(Source: Brink and Chandler, 2005-OP-1f) 

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Figure E-10 Simulated river flows for the Snake River near Hells Canyon dam (top) 

and near Anatone (bottom) modeled under Scenario 2 (Flow 

Augmentation) for extremely low water conditions. (Source: Brink and 

Chandler, 2005-OP-1f) 

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Figure E-11 Simulated river flows for the Snake River near Hells Canyon dam (top) 

and near Anatone (bottom) modeled under Scenario 2 (Flow 

Augmentation) for medium water conditions. (Source: Brink and 

Chandler, 2005-OP-1f) 

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Figure E-12 Simulated river flows for the Snake River near Hells Canyon dam (top) 

and near Anatone (bottom) modeled under Scenario 2 (Flow 

Augmentation) for extremely high water conditions. (Source: Brink and 

Chandler, 2005-OP-1f) 

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Figure E-13 Simulated river flows for the Snake River near Hells Canyon dam (top) 

and near Anatone (bottom) modeled under Scenario 3 (Navigation) for 

extremely low water conditions. (Source: Brink and Chandler, 2005-

OP-1f) 

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Figure E-14 Simulated river flows for the Snake River near Hells Canyon dam (top) 

and near Anatone (bottom) modeled under Scenario 3 (Navigation) for 

medium water conditions. (Source: Brink and Chandler, 2005-OP-1f) 

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Figure E-15 Simulated river flows for the Snake River near Hells Canyon dam (top) and 

near Anatone (bottom) modeled under Scenario 3 (Navigation) for 

extremely high water conditions. (Source: Brink and Chandler, 2005-OP1f) 

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APPENDIX F 

INFORMATION ABOUT THE STATUS OF BULL TROUT FROM FWS 2005 UPPER 

SNAKE RIVER BIOLOGICAL OPINION 

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BULL TROUT STATUS AND ENVIRONMENTAL 

BASELINE

(excerpt from March 2005 U.S. Fish and Wildlife Service’s Biological Opinion on the U.S. Bureau of 

Reclamation’s Upper Snake River Basin Projects) 

Chapter 9 

BULL TROUT 

I. Status of the Species 

A. Regulatory Status 

The Service (1998) issued a final rule listing the Columbia River and Klamath River populations of bull 

trout as threatened. With the listing of the Jarbidge River population (Service 1999c) and the CoastalPuget Sound and St. Mary-Belly River populations (Service 1999b) as threatened, all bull trout in the 

coterminous United States were considered threatened. The Service designated critical habitat for bull 

trout, but there is none designated within the action area. The Service (2002) published a draft recovery 

plan for bull trout, but the final recovery plan will not be released until the Service completes a 5-year 

status review (scheduled for completion in spring 2005). The purpose of the review is to determine if the 

bull trout should be removed from the threatened species list, if its status should be changed to 

endangered, or if its status should remain the same. 

B. Description of the Species 

Bull trout (Salvelinus confluentus), member of the family Salmonidae, is a char native to the Pacific 

Northwest and western Canada. Bull trout historically occurred in major river drainages in the Pacific 

Northwest from the southern limits in the McCloud River in northern California and the Jarbidge River in 

Nevada to their northern boundary in the headwaters of the Yukon River in the Northwest Territories, 

Canada (Cavender 1978; Bond 1992). To the west, the bull trout range includes Puget Sound, coastal 

rivers of British Columbia, Canada, and southeast Alaska (Bond 1992). Bull trout are widespread 

throughout the Columbia River basin, including its headwaters in Montana and Canada, and also occur in 

the Klamath River basin of south central Oregon. East of the Continental Divide, bull trout are found in 

the headwaters of the Saskatchewan River in Alberta and the MacKenzie River system in Alberta and 

British Columbia (Cavender 1978; Brewin and Brewin 1997). Girard first described bull trout as Salmo 

spectabilis in 1856 from a specimen collected on the lower Columbia River, and it was subsequently 

described under a number of names such as Salmo confluentus and Salvelinus malma (Cavender 1978). 

Bull trout and Dolly Varden (Salvelinus malma) were previously considered a single species (Cavender 

1978; Bond 1992). Cavender (1978) presented morphometric (measurement), meristic (geometrical 

relation), osteological (bone structure), and distributional evidence to document specific distinctions 

between bull trout and Dolly Varden. The American Fisheries Society formally recognized bull trout and 

Dolly Varden as separate species in 1980 (Robins et al. 1980). 

C. Status and Distribution 

Though widely distributed in parts of Oregon, Washington, Idaho, and Montana, bull trout in the interior 

Columbia River basin presently occur in only about 44 to 45 percent of their potential historical range 

(Quigley and Arbelbide 1997; Rieman et al. 1997). Habitat loss, fragmentation, and associated declining 

populations have been documented rangewide (Bond 1992; Schill 1992; Thomas 1992; Ziller 1992; 

Rieman and McIntyre 1993; Newton and Pribyl 1994; Idaho Department of Fish and Game, in litt., 1995). 

Several local extinctions have been reported, beginning in the 1950s (Rode 1990; Ratliff and Howell 

1992; Donald and Alger 1993; Goetz 1994; Newton and Pribyl 1994; Berg and Priest 1995; Light et al. 

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1996; Buchanan and Gregory 1997; Washington Department of Fish and Wildlife 2004). The combined 

effects of habitat degradation and fragmentation, blockage of migratory corridors, degraded water quality, 

angler harvest and poaching, entrainment into diversion channels and dams, introduced non-native species 

(e.g., brook trout (Salvelinus fontinalis)), and climate change (Reiman et al. 1997) have resulted in 

declines in bull trout distribution and abundance. Land and water management activities such as dams and 

other diversion structures, forest management practices, livestock grazing, agriculture, road construction 

and maintenance, mining, and urban and rural development continue to degrade bull trout habitat and 

depress bull trout populations (Service 2002). 

The Columbia River distinct population segment includes bull trout residing in portions of Oregon, 

Washington, Idaho, and Montana. The Columbia River distinct population segment has declined in 

overall range and numbers of fish. In some areas within the distinct population segment, robust 

populations of bull trout still exist. However, many occur as isolated local populations in headwater lakes 

or tributaries where migratory fish have been lost, potentially as a result of habitat fragmentation, 

isolation, and barriers that limit bull trout distribution and migration within the basin. 

In its draft recovery plan for bull trout, the Service (2002) divides the Columbia River distinct population 

segment into 22 recovery units, each of which is comprised of one or more core areas and further divided 

into local populations. These divisions were intended to provide a structure that considers both the genetic 

relationship of local population and management options (recovery units), to reflect metapopulation 

structure (core areas), and to approximate a panmictic (completely random breeding) group of individuals 

(Service 2002; Whitesel et al. 2004). Whitesel et al. (2004) evaluated the appropriateness of these 

divisions. They found that the definitions and delineations of local populations and core areas hold true to 

theory in some cases but not all. In general, they indicated that this scale of delineation is appropriate. 

However, they found that recovery units, as defined, did not adequately represent biological groupings of 

bull trout, and they recommended the use of Conservation Units instead, as described below. 

Recent literature (Spruell et al. 2003) provides updated information on the genetic population structure of 

bull trout across the northwestern United States. Based on analysis of four microsatellite loci, Spruell et 

al. (2003) suggested that there are three major genetically differentiated groups (lineages) of bull trout 

represented within the Columbia River distinct population segment. They described these as “Coastal” 

populations, “Snake River” populations, and “Upper Columbia” populations (including primarily the 

Lake Pend Oreille and Clark Fork basin populations), with populations further subdivided, primarily at 

the level of major river basins. Whitesel et al. (2004) used this and other information to describe four 

“Conservation Units” (upper Columbia River, Snake River, Klamath River, and Coastal- Puget Sound) 

that are thought to represent the best estimate for delineation of areas that are necessary to ensure 

evolutionary persistence of bull trout. 

The action area for this consultation falls within the Snake River Conservation Unit, which includes the 

Clearwater, Salmon, Grande Ronde, Umatilla/Walla Walla, John Day, Malheur, Boise, Payette, Weiser, 

Imnaha/Snake, Jarbidge, and Powder River basins, and Pine and Indian Creeks. The status of populations 

within these basins varies widely, and overall abundance of bull trout in some populations is largely 

unknown (e.g., in the Salmon River basin). We do not have reliable abundance information for all of 

these basins, but we can characterize them in a qualitative way based on number of local populations and 

some incomplete abundance information. For the purposes of this document, strong populations are those 

that are considered well distributed and relatively abundant within the capability of the watersheds in 

which they exist. The Clearwater, Salmon, Umatilla/Walla Walla, and Imnaha/Snake River basins have 

bull trout populations in a variety of conditions, including some that are relatively strong (areas with 

2,500 to 5,000 adults or more). The Grande Ronde, John Day, Boise, and Payette River basins also have 

bull trout populations in a variety of conditions, with the whole basin abundance best characterized as 

moderate (e.g., approximately 500 adults). Populations in the Weiser, Jarbidge, Malheur, and Powder 

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River basins, and Pine and Indian Creeks are weak, with less than 500 adults in the total basin. 

1. Historical Distribution 

The historical range of bull trout includes major river basins in the Pacific Northwest at about 41 and 60 

degrees North latitude, from the southern limits in the McCloud River in northern California and the 

Jarbidge River in Nevada to the headwaters of the Yukon River in the Northwest Territories, Canada 

(Cavender 1978; Bond 1992). The range extended east of the continental divide in the headwaters of the 

Saskatchwan River in Alberta and Montana and in the Mackenzie River system in Alberta and British 

Columbia, Canada (Cavender 1978; Brewin and Brewin 1997). 

Bull trout were present throughout the Snake River basin and in the western section of Idaho downstream 

from Shoshone Falls, including the Clearwater, Salmon, Boise, and Payette River systems. The species is 

reported to have been widely dispersed throughout the basin, limited only by natural passage and thermal 

barriers. In this drainage, their historical range approximates that of spring, summer, and fall Chinook 

salmon (Thurow 1987; Rieman and McIntyre 1993) and possibly included the Owyhee and Bruneau 

River basins and other tributaries upstream as far as Salmon Falls Creek. They are not known to have 

occurred in the Snake River upstream from Shoshone Falls, the Wood River system, Birch Creek, or any 

stream in Idaho that drains the Centennial Mountains between Henrys Lake and the Bitterroot Range. An 

isolated population exists in the Little Lost River near Howe, Idaho, between the Lost River and Lemhi 

mountain ranges (Batt 1996). 

In eastern Oregon, bull trout are present in the Grand Ronde, Malheur, and Powder River systems, but 

they are not known to occur in the Burnt River system. Data on its historical distribution in the Malheur 

River drainage is limited and dates from Oregon Department of Fish and Wildlife observations beginning 

in 1955 (Buchanan et al. 1997). Before the construction of dams, bull trout could access the Snake River 

from the Malheur and North Fork Malheur Rivers. Anadromous salmon and steelhead historically 

spawned in the upper Malheur River basin (Northwest Power and Conservation Council 2002). The lower 

Malheur River was most likely too warm for bull trout spawning or juvenile rearing but would have 

provided migratory habitat to and from the Snake River and overwintering habitat (Hanson et al. 1990 in 

Buchanan et al. 1997). 

The Snake River Hells Canyon subbasin lies within the historical native range of bull trout, although no 

clear documentation of the historical distribution of bull trout within the subbasin exists (Nez Perce Tribe 

2004). According to Buchanan et al. (1997), there is no documentation of bull trout in the Powder River 

basin prior to the 1960s. It is suspected that they were widespread in the upper Powder River drainage and 

seasonally connected to the Snake River. Historical information about the distribution of bull trout below 

Hells Canyon Dam in the mainstem Snake River is very limited (Chandler 2003). Buchanan et al. (1997) 

reported that the Idaho Department of Fish and Game observed bull trout at the mouth of Sheep, Granite, 

Deep, and Wolf Creeks between Hells Canyon Dam and the Imnaha River. The distribution of bull trout 

may have paralleled the distribution of potential prey such as whitefish and sculpins. In several river 

basins where bull trout evolved with populations of juvenile salmon, bull trout abundance declined when 

juvenile salmon prey declined or were eliminated (Ratliff 1992). 

2. Current Distribution 

The Service (2002) has identified 22 management units for bull trout in the Columbia River basin. Draft 

recovery plans for each of these units contain information relating to the current distribution of bull trout. 

The “Environmental Baseline” discussion in Section II of this chapter describes the current distribution of 

bull trout within the action area.

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D. Life History 

Bull trout exhibit resident and migratory life history strategies throughout much of the current range 

(Rieman and McIntyre 1993). Resident bull trout complete their entire life cycle in or near the streams 

where they spawn and rear. Migratory bull trout spawn and rear in streams for 1 to 4 years before 

migrating downstream to either a lake/reservoir (adfluvial), river (fluvial), or in certain coastal areas, to 

salt water (anadromous), where they reach maturity (Fraley and Shepard 1989; Goetz 1989). Resident and 

migratory forms often occur together, and it is suspected that individual bull trout may give rise to 

offspring exhibiting both resident and migratory behavior (Rieman and McIntyre 1993). 

Bull trout have specific habitat requirements that distinguish them from other salmonids (Rieman and 

McIntyre 1993). Watson and Hillman (1997) concluded that watersheds must have specific physical 

characteristics to provide habitat requirements for bull trout to successfully spawn and rear, and that the 

characteristics are not necessarily ubiquitous throughout these watersheds. Because bull trout exhibit a 

patchy distribution, even in pristine habitats (Rieman and McIntyre 1993), the fish should not be expected 

to simultaneously occupy all available habitats (Rieman et al. 1997). 

Bull trout are found primarily in colder streams, although individual fish are migratory in larger, warmer 

river systems throughout the Columbia River basin (Fraley and Shepard 1989; Rieman and McIntyre 

1993, 1995; Buchanan and Gregory 1997; Rieman et al. 1997). Dunham et al. (2003) found that the 

probability of bull trout occurrences is low when mean daily temperatures exceed 14 to 16 °C; Selong et 

al. (2001) reported that maximum growth of bull trout occurred at 13.2 °C. These temperature 

requirements may partially explain the patchy distribution within a watershed (Fraley and Shepard 1989; 

Rieman and McIntyre 1995). Spawning areas are often associated with high elevation, colE-water springs, 

groundwater infiltration, and the coldest streams in a given watershed (Pratt 1992; Rieman and McIntyre 

1993; Rieman et al. 1997). Goetz (1989) suggested optimum water temperatures for rearing of about 7 to 

8 °C and optimum water temperatures for egg incubation of 2 to 4 °C. In Granite Creek, Idaho, Bonneau 

and Scarnecchia (1996) observed that juvenile bull trout selected the coldest water available in a plunge 

pool, 8 to 9 °C within a temperature gradient of 8 to 15 °C. Dunham et al. (2003) found that maximum 

bull trout use during the summer (July 15 to September 30) occurred between 7 and 12 °C. All bull trout 

life history stages are associated with complex forms of cover, including large woody debris, undercut 

banks, boulders, and pools (Oliver 1979; Fraley and Shepard 1989; Goetz 1989; Hoelscher and Bjornn 

1989; Sedell and Everest 1991; Pratt 1992; Thomas 1992; Rich 1996; Sexauer and James 1997; Watson 

and Hillman 1997). In general, bull trout prefer relatively stable channel and water flow conditions 

(Rieman and McIntyre 1993). Jakober (1995) observed bull trout overwintering in deep beaver ponds or 

pools containing large woody debris in the Bitterroot River drainage, Montana, and suggested that 

suitable winter habitat may be more restrictive than summer habitat. Juvenile and adult bull trout 

frequently inhabit side channels, stream margins, and pools with suitable cover (Sexauer and James 

1997). 

Fraley and Shepard (1989) found that bull trout select spawning habitat in low gradient stream sections 

with gravel substrates; Goetz (1989) found preferred spawning water temperatures of 5 to 9 °C. They 

typically spawn from August to mid-October during periods of decreasing water temperatures. High 

juvenile densities were observed in Swan River, Montana, and tributaries with diverse cobble substrate 

and low percentage of fine sediments (Shepard et al. 1984). Pratt (1992) indicated that increases in fine 

sediments reduce egg survival and emergence. 

Life history strategy influences bull trout size. Growth of resident fish is generally slower than growth of 

migratory fish; resident fish tend to be smaller at maturity and less fecund (Fraley and Shepard 1989; 

Goetz 1989). Bull trout normally reach sexual maturity in 4 to 7 years and live as long as 12 years. Repeat 

and alternate-year spawning has been reported, although repeat spawning frequency and post-spawning 

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mortality are not well understood (Leathe and Graham 1982; Fraley and Shepard 1989; Pratt 1992; 

Rieman and McIntyre 1996). 

Migratory bull trout frequently begin migrations as early as April and have been known to move upstream 

as far as 250 kilometers (155 miles) to spawning grounds (Fraley and Shepard 1989). Depending on water 

temperature, incubation is normally 100 to 145 days (Pratt 1992), and after hatching, juveniles remain in 

the substrate. Time from egg deposition to fry emergence may exceed 200 days. Fry normally emerge 

from early April through May, depending upon water temperatures and increasing stream flows (Pratt 

1992; Ratliff and Howell 1992). 

Bull trout are opportunistic feeders with food habits primarily a function of size and life history strategy. 

Resident and juvenile migratory bull trout prey on terrestrial and aquatic insects, macrozooplankton, and 

small fish (Boag 1987; Goetz 1989; Donald and Alger 1993). Adult migratory bull trout are primarily 

piscivores (Fraley and Shepard 1989; Donald and Alger 1993). Rieman and McIntyre (1993) indicated 

that diverse life history strategies are important to the stability and persistence of populations of any 

species. Such diversity is thought to stabilize populations in highly variable environments or to reestablish 

segments of populations that have disappeared due to anthropogenic or natural events. 

Variation in the timing of migration and in the timing and frequency of spawning within a metapopulation 

also represents diversity in life history. A metapopulation is an interacting network of local populations 

with varying frequencies of migration and gene flow among them (Meffe and Carroll 1994). Bull trout 

may spawn each year or in alternate years (Block et al. in Batt 1996). It is possible that four or more ageclasses could comprise any spawning population, with each age-class including up to three migration 

strategies (Rieman and McIntyre 1993). This theory supports the idea that the multiple life history 

strategies found in bull trout populations represent important diversity within populations.

E. Population Dynamics 

Migratory corridors link seasonal habitats for all bull trout life history forms, and the ability to migrate is 

important to the persistence of local bull trout populations (Rieman and McIntyre 1993; Rieman et al. 

1997). Pre- and post-spawning migrations facilitate gene flow among local populations because 

individuals from different local populations interbreed when some stray and return to non-natal streams. 

Local populations extirpated by catastrophic events may also become reestablished in this manner. 

Metapopulation concepts of conservation biology theory are applicable to the distribution and 

characteristics of bull trout (Rieman and McIntyre 1993). Local populations may become extinct, but they 

may be reestablished by individuals from other nearby local populations. Metapopulations provide a 

mechanism for reducing the risk of local extinction because the simultaneous loss of all local populations 

is unlikely, and multiple local populations distributed and interconnected throughout a watershed provide 

a mechanism for spreading risk from stochastic events (Rieman and McIntyre 1993). 

F. Conservation Needs 

Bull trout conservation requires the long-term persistence of self-sustaining, complex, interacting groups 

of fish distributed throughout the species’ native range. Two of the factors identified as necessary for 

recovery also translate into general factors that address the conservation needs of the species. These two 

factors include restoring and maintaining suitable habitat conditions for all bull trout life stages and life 

history strategies, and conserving genetic diversity and providing opportunity for genetic exchange. To 

achieve these general needs, several specific conservation measures should be addressed. The first 

involves metapopulation theory. As described above, a functioning metapopulation is comprised of 

multiple local populations distributed and interconnected throughout a watershed, which provides a 

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mechanism for reducing the risk of extirpation associated with stochastic events. 

The second measure involves connectivity between populations. A migratory component in bull trout 

populations is recognized as important to overall health, long-term persistence, and recovery because it 

allows for reestablishment of populations in reaches where bull trout have been extirpated (Rieman and 

McIntyre 1993; Whiteley et al. 2003). In addition, migratory bull trout are larger and more fecund than 

their resident counterparts. The greater reproductive capacity of migratory bull trout is also thought to 

provide an important contribution to the abundance and long-term persistence of local populations 

(Rieman and McIntyre 1993). In addition, migrations facilitate gene flow among local populations when 

individuals from different local populations interbreed or stray to non-natal streams. Dams, irrigation 

diversions, and other waterway alterations have interrupted bull trout migration. Dams need adequate fish 

passage to maintain populations with migratory life histories that habitat conditions are not available. 

Without fish passage, dams may isolate upstream and downstream bull trout populations or limit them 

exclusively to one or the other. 

An adequate prey base is another essential component for bull trout conservation. Bull trout are described 

as having voracious appetites, which makes them vulnerable to angling injury or mortality (Post et al. 

2003). Fish are considered to be the major item in the diet of large bull trout. They feed primarily along 

the bottom and mid-water levels, consuming insects and other fish species such as suckers, sculpins, 

minnows, and trout (Pratt 1992). Mountain whitefish and kokanee salmon are two of the bull trout’s 

preferred prey (Fraley and Shepard 1989; Vidergar 2000). 

Appropriate habitat conditions are also essential for bull trout survival. Bull trout have more specific 

habitat requirements than other native trout species, mainly because they require water that is especially 

cold with clean cobble or gravel size substrate for spawning and development of embryos and alevins. 

Available overwintering habitat, bank stability, winter precipitation, drought, substrate type, available 

cover, cold water temperature, and the presence of migration corridors consistently appear to influence 

bull trout distribution and abundance (see Allan et al. in Batt 1996; Dunham and Rieman 1999; Salow 

2001; Salow and Cross 2003). Reductions in road construction for timber harvest and fire control 

measures are needed since they lead to increased siltation, channelization, and loss of habitat complexity 

and may have lead to historical declines in bull trout. 

Conservation of bull trout is also dependent on protecting bull trout genetic diversity and phenotypic 

adaptation within each distinct population segment and spreading or reducing the risk of extinction 

through the maintenance of multiple populations across the range. Retaining a species’ genetic variation 

is important because this variation allows populations to adapt to changing environmental conditions over 

short (inter-generational) and long (evolutionary) time frames (Allendorf and Leary 1986) and is the basis 

for maintaining a species’ evolutionary legacy, including its geographical distribution, and morphological, 

physiological, and life-history variation (Allendorf et al. 1997). 

Loss of genetic variation negatively affects the development, growth, fertility, and disease resistance of 

fishes. This loss of variation may also reduce fitness and preclude adaptive change in populations 

(Frankham 1995) or affect the species’ ability to recover from disturbance events (Rieman et al. 1997). 

Genetic variation needs to be preserved in order to increase the likelihood of a species survival (Allendorf 

and Leary 1986), and maintaining genetic variation within populations should be a primary goal of 

conservation and management of species (Wang et al. 2002), bull trout included. In general, an effective 

population size (Ne) of 50 is necessary to avoid inbreeding depression, and a Ne of 500 is necessary to 

avoid the loss of genetic and phenotypic variation through genetic drift over the long term. However, 

Rieman and Allendorf (2001) found that populations with a Ne of 500 may still lose genetic variation 

over the long term (200 years) and recommended that long-term management goals, where appropriate, 

include populations with at least 1,000 spawning adults each year. Bull trout populations on the margin of 

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the species’ range may be adapted to unique environments and may represent a disproportionate part of 

the total diversity within the species, although the importance of this in a given population is affected by 

gene flow, generational time, life history, and ecological conditions (Rieman et al. 1997; Lesica and 

Allendorf 1995). The preceding section, “Status and Distribution,” describes new scientific information 

indicating that Conservation Units (as described in Whitesel et al. 2004) may be the most accurate 

representation of the evolutionary lineage and genetic structure of populations of bull trout (see Spruell et 

al. 2003; Whitesel et al. 2004). Each Conservation Unit across the range of bull trout contains an 

environmental template that allows the full expression of genotypic, phenotypic, and spatial diversity 

among bull trout populations. The conservation of this template will help ensure resilience and 

persistence of the species when environmental changes occur. To ensure the evolutionary persistence of 

bull trout within a Conservation Unit, Whitesel et al. (2004) suggested that an effective population size of 

at least 5,000 is necessary. They also suggested that conservation of the species within a Conservation 

Unit is necessary to ensure the evolutionary persistence of the species as a whole. This represents the 

most recent scientific information available regarding appropriate conservation units for bull trout. In this 

Opinion, the Service will consider effects to bull trout within the Snake River Conservation Unit and the 

subsequent relationship to the larger Columbia River distinct population segment. 

A related conservation need of the species involves the development of conservation assessments and 

prioritization of populations for management and conservation actions across the range (see Epifanio et 

al. 2003; Allendorf et al. 1997). Currently, work has not been completed range-wide to describe the 

conditions affecting individual populations or metapopulations, the risk of local extinction, or the 

ecological and evolutionary importance of metapopulations or river basins to the larger Conservation 

Units or to the Columbia River distinct population segment. Because bull trout are a wide-ranging 

species, and scientific, financial, and human resources are limited, it is likely an unrealistic goal to treat 

and conserve all populations equally (Epifanio et al. 2003). Prioritizing areas or populations for protection 

should consider the risk of extinction, any potentially unique genetic or phenotypic expressions, including 

habitat usage and life history, and evolutionary and ecological legacy (Allendorf et al. 1997). Epifanio et 

al. (2003) described six strategies that could be used to prioritize bull trout populations based on the 

factors described above. The prioritization of bull trout populations would help ensure that those 

populations with disproportionately high conservation value are more strictly managed to ensure their 

persistence, and that over the long term, the fullest range of ecological and evolutionary characteristics is 

conserved. These activities would provide a better mechanism for protecting the long-term viability of 

bull trout populations. Prevention of human-caused mortality is another conservation need for bull trout. 

Adequate angler education and enforcement of existing fishing regulations are necessary to reduce both 

unintentional angler mortality and poaching. 

II. Environmental Baseline 

Regulations implementing the Act (50 CFR §402.02) define the environmental baseline as the past and 

present impacts of all Federal, State, or private actions and other human activities in the action area. The 

environmental baseline also includes the anticipated impacts of all proposed Federal projects in the action 

area that have already undergone section 7 consultations, and the impacts of state and private actions that 

are contemporaneous with the consultations in progress. 

A. Status of the Species in the Action Area 

Bull trout within the action area are located in the Boise, Payette, Malheur, and Powder River basins, and 

in the mainstem Snake River downstream from Brownlee Dam. Many bull trout populations in the Boise, 

Payette, and Malheur River basins have developed life history strategies associated with Reclamation 

facilities (adfluvial form), although it is not known to what degree this has altered the productivity and 

diversity of existing populations. Resident populations of bull trout also occur in tributaries to the 

mainstem rivers affected by the action (e.g., Deadwood River). In the Boise River basin, Reclamation and 

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Corps dams have constrained bull trout movement patterns within the larger stream network, and this has 

resulted in discontinuities in genetic factors related to dispersal and gene flow (Whiteley et al. 2003). 

Populations in the Powder River basin, and some populations in the other basins, consist primarily or 

exclusively of resident bull trout, which use headwater streams and tributaries year-round and do not 

migrate seasonally. 

The action area lies entirely within the Snake River Conservation Unit (Spruell et al. 2003; Whitesel et al. 

2004). The proposed action will affect bull trout in 3 of 15 watersheds: the Boise, Payette, and Malheur 

River basins. The Boise and Malheur River basins are on the extreme southern edge of the Snake River 

Conservation Unit (excepting the Jarbidge River basin). Bull trout populations on the margin of the 

species’ range may be adapted to unique environments and may represent a disproportionate part of the 

total diversity within the species (Rieman et al. 1997; Lesica and Allendorf 1995), although we do not 

have information regarding the specific role of these populations in conserving the Snake River 

Conservation Unit. Spruell et al. (2003) found that the Boise, Malheur, and Jarbidge River basins formed 

a discrete genetic cluster compared to other river basins within the Conservation Unit, indicating a similar 

evolutionary lineage. 

Figure 18 shows the known bull trout distributions and upstream migratory, spawning, and rearing 

habitats in the middle Snake River basin. The following sections describe the current known distribution 

of bull trout in the action area by river basin. 

Figure 18. Bull trout distribution within the action area at the watershed scale.

1. Boise River Basin [omitted] 

2. Payette River Basin [omitted] 

3. Weiser River Basin [omitted] 

4. Malheur River Basin [omitted] 

5. Powder River Basin 

Current distribution of bull trout in the Powder River basin is in two headwater tributaries of the Powder 

River in the Elkhorn Mountain range; one local population is located 8 to 17 miles upstream from Phillips 

Lake, and the other 20 to 25 miles upstream from Thief Valley Reservoir. All bull trout inhabiting the 

Powder River basin are thought to be resident fish (Service 2002). To date, no bull trout have been 

documented in either Phillips Lake or Thief Valley Reservoir (Buchanan et al. 1997; Schwabe et al. 

2003). Historical dredge mining along most of the Powder River upstream from Phillips Lake severely 

degraded habitats in those reaches; this likely limits the current bull trout distribution to the headwater 

tributaries (Service 2002). 

6. Snake River from Brownlee Reservoir to the Columbia River and the Columbia River below the 

Snake River Confluence 

Historically, the mainstem Snake River served as a migratory corridor for anadromous salmonids, 

including steelhead and Chinook, that were documented throughout the Owyhee, Malheur, Weiser, 

Payette and Boise River drainages in the 1800s and 1900s (Pratt et al. 2001; Welsh et al. 1965). Bull trout 

also used the area Brownlee Reservoir currently inundates. Bull trout were reported in creel records from 

Brownlee Reservoir before and after the dam’s completion in 1959. Although bull trout are not currently 

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known to occur in or use Brownlee Reservoir, it is likely that bull trout would use the reservoir as 

overwintering habitat if migratory individuals become reestablished in the Weiser River drainage. 

Currently, the mainstem Snake River, specifically downstream from the Weiser River within the 

Southwest Idaho Recovery Unit, may have the potential to function as both migratory and overwintering 

habitat for bull trout. However, the extent and nature of bull trout use, as well as the quality of habitat 

provided by the reservoirs on the mainstem Snake River, are not well understood. To function as 

migratory habitat, the mainstem Snake River and reservoirs must provide holding water with adequate 

temperature, depth, and cover to ensure successful bull trout movement. To function as overwintering 

habitat, the mainstem Snake River and reservoirs must also provide sufficient forage for bull trout to 

either maintain or gain mass. 

Information about the use of the mainstem Snake River by bull trout from the Weiser River drainage (the 

only major river that lacks large dams) has been identified as a research need in the Southwest Idaho 

Recovery Unit. Habitat conditions in lakes and reservoirs can determine the relative availability of bull 

trout forage and may mediate interactions of bull trout with potential competitors, predators, or prey in 

complex and lake/reservoir-specific ways (Montana Bull Trout Scientific Group 1998). Relationships 

between depth distributions of potential forage and bull trout habitat use have not been thoroughly 

investigated in Brownlee Reservoir and the mainstem Snake River upstream. These interactions are likely 

important in determining whether Brownlee Reservoir and the mainstem Snake River could provide 

suitable bull trout foraging and overwintering habitat in the future. Further investigation is needed to 

determine if bull trout from the Weiser River could use Brownlee Reservoir as foraging, migrating and 

overwintering habitat in a recovered condition. 

Bull trout currently occur in Oxbow Reservoir, the Oxbow Bypass Reach, and Hells Canyon Reservoir 

(Chandler 2003). No bull trout have been documented above Brownlee Dam (Chandler 2003). Bull trout 

occur in several tributaries to the Hells Canyon Projects, including the Wildhorse River, Indian Creek, 

and Pine Creek; they also occur in the mainstem Snake River below Hells Canyon Dam. 

B. Factors Affecting Species Environment within the Action Area 

There are numerous natural and anthropogenic influences on bull trout in the action area. Although some 

restoration actions and ongoing research efforts have positively affected bull trout, the majority of 

anthropogenic influences have contributed to the species decline by reducing bull trout numbers, 

reproduction, and distribution. Factors affecting the species within the action area include migration 

barriers; diversions; water, forestry, and past sport fisheries management practices; habitat fragmentation 

and degradation through grazing and road construction; reduced water quality from development, road 

construction, and mining; and introduction of non-native competitive species (Service 2002). 

The Service (1999a, 2002) determined that the Reclamation facilities that affect bull trout within the 

action area include Arrowrock, Anderson Ranch, Deadwood, and Agency Valley Dams. Winter pool 

content is an important habitat factor for bull trout at Arrowrock, Anderson Ranch, Deadwood, and 

Beulah Reservoirs. This consultation also considers Reclamation operations that control the conveyance 

and storage of irrigation water at Lucky Peak Dam and Reservoir. Construction and operation of these 

facilities have modified streamflows, changed stream temperature regimes, blocked migration routes, 

entrained bull trout, and changed bull trout forage bases. None of these facilities has fish passage, and 

they function as barriers to upstream and downstream fish migration. Though little information is known 

about the extent of the impacts to historical migration of bull trout from these facilities, populations of 

bull trout have been found upstream, downstream, or adjacent to these facilities. 

1. Boise River Basin [omitted] 

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2. Payette River Basin [omitted] 

3. Malheur River Basin [omitted] 

4. Snake River from Brownlee Reservoir to the Columbia River and the Columbia 

River below the Snake River Confluence 

Chandler (2003) reported that bull trout found in the Oxbow Bypass Reach and Hells Canyon Reservoir 

appeared to be extremely low in abundance. Chandler (2003) also reported that bull trout populations 

found in the tributaries to the Complex upstream from Hells Canyon Dam had extremely low numbers 

and that they were absent from lower reaches in the drainage. A significant number of bull trout captured 

in Oxbow and Hells Canyon Reservoirs showed signs of hybridization with brook trout, a result of bull 

trout and brook trout being present in the tributaries (Chandler 2003); this is a major concern for bull trout 

populations in this area. Below the Hells Canyon Complex, bull trout do not show any signs of 

hybridization with brook trout, an exotic species that has been widely introduced in Snake River 

tributaries (Chandler 2003). 

Chandler (2003) found that bull trout use the Oxbow Bypass Reach and Hells Canyon Reservoir primarily 

during late fall and winter. Telemetry studies showed fluvial bull trout within the Complex migrating to 

tributaries between April and early June where they likely oversummer and then spawn in the fall 

(Chandler 2003). 

Chandler (2003) documented bull trout below Hells Canyon Dam that exhibited “classic fluvial 

migrations” during the years that they monitored movement. Over half of the bull trout monitored made 

spring migratory movements downstream to the Imnaha River after wintering in the mainstem Snake 

River (Chandler 2003). Other bull trout that spawned the previous year but did not exhibit fluvial 

behavior may have remained in the Snake River throughout the summer. Fluvial bull trout were then 

documented to return to the Snake River following spawning in the tributaries, sometime in November 

and December, and to remain in the Snake River from January to April (Chandler 2003). Chapter 9 – Bull 

Trout Effects of the Proposed Action 234 U.S. Fish and Wildlife Service March 2005 

C. Recent Section 7 Consultations 

Effects from activities or projects that have already undergone section 7 consultation, as reported in a 

biological opinion, are an important component of objectively characterizing the current condition of the 

species. The Snake River Fish and Wildlife Office (for the Deadwood/South Fork Payette River and 

Boise River basins) and La Grande Field Office (for the Malheur River basin) have completed 20 

biological opinions for bull trout in the action area since the year 2000. Eight of these biological opinions 

applied to activities affecting bull trout in the Boise River basin (including Anderson Ranch, Arrowrock, 

and Lucky Peak Reservoirs). Activities or projects included a hydroelectric plant, Arrowrock Dam valve 

replacement, a forest plan revision, water quality standards criteria, and emergency wildfire and road 

repairs. Three biological opinions applied to activities affecting bull trout in the Deadwood River 

drainage (South Fork Payette basin) and addressed flow augmentation, a forest plan revision, and water 

quality standards (the forest plan revision and water quality standards criteria consultations are common 

to both the Deadwood and Boise River watersheds). Eleven biological opinions applied to activities 

affecting bull trout in the Malheur River basin and addressed grazing programs, emergency fire 

consultation, road reconstruction, and bridge removal. 

Our analysis showed that we consulted on a wide array of actions, which had varying levels of effects. 

Many of the actions consisted of only short-term adverse effects, but some had long-term beneficial 

effects. Some of the actions resulted in long-term adverse effects. No actions that have undergone 

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consultation were found to appreciably reduce the likelihood of survival and recovery of the bull trout. 

Furthermore, no actions that have undergone consultation were anticipated to result in the loss of any 

subpopulations or local populations of bull trout. A more detailed analysis of consulted-on effects to bull 

trout is available in our files and is hereby incorporated by reference. 

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APPENDIX G 

INFORMATION ABOUT THE STATUS OF COLUMBIA RIVER SALMON AND 

STEELHEAD ESUs FROM THE NMFS 2005 UPPER SNAKE RIVER BIOLOGICAL 

OPINION 

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STATUS OF COLUMBIA RIVER SALON AND STEELHEAD ESUS AND FACTORS 

AFFECTING SALMON AND STEELHEAD IN THE ACTION AREA 

(excerpt from March 31, 2005, NMFS Biological Opinion on the U.S. Bureau of Reclmation’s Upper 

Snake River Basin Projects) 

4.3.1 SR Spring/Summer Chinook Salmon 

4.3.1.1 ESU Structure 

Based on genetic and geographic considerations, the Interior TRT (2003) established five major 

population groups in this ESU: the Lower Snake River Tributaries, the Grande Ronde and Imnaha Rivers, 

the South Fork Salmon River, the Middle Fork Salmon River, and the Upper Salmon River. The Interior 

TRT further subdivided these groupings into a total of 31 extant, demographically independent 

populations (Appendix B, Figure B-1). However, Chinook salmon have been extirpated from the Snake 

River and its tributaries above Hells Canyon Dam, an area that encompassed about 50% of the preEuropean spawning areas in the Snake River Basin (NRC 1996). Major subbasins in the Clearwater were 

blocked to Chinook salmon in 1927 by the Lewiston Dam. Although the number of spring-run spawning 

aggregations that were lost due to construction of the Snake River mainstem dams is unknown, the ESU 

still has a wide spatial distribution in a variety of locations and habitat types. 

4.3.1.2 The BRT Findings 

NMFS recently conducted a status review of the SR spring/summer Chinook salmon and other ESUs. As 

part of that status review, NMFS convened a BRT to evaluate the available scientific data. The BRT 

analysis included dam counts and spawner returns for natural-origin fish through 2001. As indicated in 

Section 1, NMFS must examine the criteria for a sufficient number and distribution of VSPs in order to 

assess the range-wide biological requirements of the ESU. The BRT did the same thing in assessing 

whether or not the ESU should be listed as an endangered or threatened species. In this case, the BRT 

found that, compared to the levels needed for a healthy species, there was a moderately high risk that the 

abundance and productivity criteria were not currently being met and a low risk that the spatial structure 

and diversity criteria were not currently being met. Concerns regarding diversity were somewhat 

alleviated, because out-of- ESU Rapid River broodstock had been phased out of the Grande Ronde. 

Despite the recent positive signs, the BRT still felt that the ESU was at some level of risk. 

4.3.1.3 2004 Status Review 

An indicator of the current range-wide status of this ESU is the number of spawners returning to natural 

production areas. In 1995, NMFS established abundance levels for natural production areas that would be 

indicative of a recovered population (NMFS 1995b), and these levels were updated as “interim abundance 

and productivity targets” in 2002 (NMFS 2002). Many, but not all of the 29 extant natural production 

areas within this ESU have experienced large increases in the number of returning spawners in the last 2 

to 3 years, with two populations (Grande Ronde and Imnaha) nearing the previously specified recovery 

abundance levels. Due to the severe declines in the populations since the 1960s and the short-term nature 

of the recent high returns, long-term productivity trends remain below replacement for all natural 

production areas, despite the recent increases. However, the short-term productivity trends for the 

majority of the natural production areas in the ESU are at or above replacement, which is a positive sign. 

During the Status Review, NMFS evaluated whether conservation efforts, such as the extensive artificial 

propagation program, within this ESU reduced or eliminated the risk to SR spring/summer Chinook 

salmon. In performing this analysis, NMFS was guided by the NMFS/USFWS “Policy for Evaluation of 

Conservation Efforts When Making Listing Decisions” (“PECE,” 68 FR 15100; March 28, 2003). NMFS 

concluded that the artificial propagation programs did provide benefits to the ESU in terms of abundance, 

spatial structure, and diversity, but that the programs had neutral or uncertain effects in terms of overall 

ESU productivity. As a result, NMFS did not believe that the artificial propagation programs were 

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sufficient to substantially reduce the long-term extinction risk of the ESU. Thus, even though the ESU is 

likely to benefit from strong upcoming brood years,147 NMFS proposed to retain the current listing of this 

species as threatened (i.e., likely to become an endangered species within the foreseeable future). Actions 

under the 2000 FCRPS Biological Opinion and improvements in hatchery practices are addressing some 

of the ESU’s factors for decline. 

4.3.1.4 Recent Dam Counts and Returns to the Spawning Grounds 

Cooney (2004) updated the spawner count data used by the BRT (2003) for use by the Interior Columbia 

Basin TRT, adding data for 2002 and 2003, which he requested from the co-managers. In general, for 

most of the 24 populations where recent data were available, indices of abundance (i.e., redd counts) for 

natural-origin SR spring/summer Chinook salmon were high in 2002 and 2003 compared to the 1990s. 

Fisher and Hinrichsen (2004) provided a preliminary evaluation of the effects of recent natural-origin 

spring Chinook salmon returns on past geometric mean abundance levels and population trends. The latter 

were calculated as the slope of the regression line for the (log transformed) index of abundance over time. 

They assessed whether the geomean was greater when calculated from the most recent data (beginning in 

2001) compared to a base period (1996-2000) and whether the trend was greater when counts for 2001-

2003 were added to the 1990-2000 data series. Their methods were taken from those used by NMFS’ 

BRT (2003). The geomean for 2001-2003 (33,581) exhibited a 548% increase over the 1996-2000 base 

period (5,186 fish). The slope of the trend for the natural-origin population increased 17% (from 0.97 to 

1.14) when the data for 2001-2003 were added to the 1990-2000 series, reversing the decline and 

indicating that, at least for the short-term, the natural-origin population has been increasing. Hatchery fish 

constituted 69% of the return during the recent period compared to an average of 60% during 1990-2000 

(Fisher 2004). Even so, natural-origin fish exhibited the substantial increase in numbers described above. 

Neither the BRT nor the Interior TRT has reviewed Fisher and Hinrichsen (2004) or Fisher (2004). 

4.3.2 SR Fall Chinook Salmon 

4.3.2.1 ESU Structure 

A majority of the fish in this ESU spawn in the mainstem Snake River between the head of Lower Granite 

Reservoir and Hells Canyon Dam, with the remaining fish distributed among lower sections of the major 

tributaries (Connor et al. 2002). Fish in the mainstem Snake appear to be distributed in a series of 

aggregates from the mouth of Asotin Creek to River Mile (RM) 219, although smaller numbers have been 

reported spawning in the tailraces of the Lower Snake dams (Connor et al. 1993; Dauble et al. 1995). Due 

to their proximity and the likelihood that individual tributaries could not support a sufficiently large 

population, the Interior TRT (2003) considered these aggregates and the associated reaches in the lower 

major tributaries to the Snake to be a single population (Appendix B, Figure B-2). This is consistent with 

past practice in prior biological opinions. 

Before European impact, Snake River fall Chinook salmon are believed to have once occupied and 

spawned in the mainstem Snake River from its confluence with the Columbia River upstream to 

Shoshone Falls (RM 615). The spawning grounds between Huntington, Oregon (RM 328) and Auger 

Falls in Idaho (RM 607) were historically the most important for this species. Historically, only limited 

spawning activity occurred downstream of RM 273 (Waples et al. 1991), which is about one mile below 

Oxbow Dam. However, the development of irrigation and hydropower projects on the mainstem Snake 

River has inundated or blocked access to most of this area in the past century. Construction of Swan Falls 

Dam (RM 458) in 1901 eliminated access to 157 miles (about 25%) of total potential habitat, leaving 458 

miles of habitat. Construction of the Hells Canyon Dam complex (1958-1967) cut off anadromous fish 

access to 211 miles (or 46%) of the remaining historical fall Chinook salmon habitat upstream of RM 

 

147 That is, the upcoming brood years were derived from strong spawning escapements and improved 

conditions during the ocean phase of the life cycle. 

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247. Additional fall Chinook salmon habitat was lost through inundation as a result of the construction of 

the four lower mainstem Snake River dams. Currently, SR fall Chinook salmon have access to 

approximately 100 miles of mainstem Snake River habitat, which is roughly 22% of the 458 miles of 

historical habitat available prior to completion of the Hells Canyon Complex and the four lower Snake 

River dams. Historical use of habitat in the Clearwater River is uncertain. Tiffan et al. (2001) concluded 

that there was “no conclusive evidence” whether the lower Clearwater River supported the basin 

subyearling migrant life-history pattern associated with Snake River fall Chinook salmon. 

4.3.2.2 The BRT Findings 

Approximately 80% of historical spawning habitat was lost with the construction of a series of dams on 

the mainstem Snake River. The loss of spawning habitat, restricting the extant ESU to a single naturally 

spawning population, increased the ESU’s vulnerability to environmental variability and catastrophic 

events. The diversity associated with populations that once resided above the Snake River dams has been 

lost, and the impact of out-of-ESU fish straying to the spawning grounds has the potential to further 

compromise the genetic diversity of the ESU. Although recent improvements in the marking of out-ofESU hatchery fish and their removal at Lower Granite Dam have reduced the impact of these strays, 

introgression below Lower Granite Dam remains a concern. The BRT found moderately high risk for all 

VSP categories and therefore felt that, despite the recent positive signs, the ESU was at some level of risk. 

4.3.2.3 2004 Status Review 

During the Status Review, NMFS evaluated whether artificial propagation programs within this ESU 

reduce or eliminate risks to its viability, guided by the PECE policy (Section 4.3.1). NMFS concluded 

that the artificial propagation programs have provided benefits to the ESU in terms of abundance, spatial 

distribution, and diversity in recent years, although the contribution of these programs to overall ESU 

productivity is uncertain and the artificial propagation programs are not sufficient to substantially reduce 

the long-term risk of extinction. Depending upon the assumption made about the likelihood of the 

progeny of hatchery fish returning as productive adults, long- and short-term trends in productivity are at 

or above replacement. Thus, NMFS proposed to retain the current listing of this species as threatened 

(i.e., likely to become an endangered species within the foreseeable future) even though it is not likely to 

go extinct in the near future. Actions under the 2000 FCRPS Biological Opinion and improvements in 

hatchery practices have provided some encouraging signs in addressing the ESU’s factors for decline. 

4.3.2.4 Recent Dam Counts and Returns to the Spawning Grounds 

Cooney (2004) reported that the high counts of natural-origin SR fall Chinook salmon continued in 2002 

and 2003 (2,114 and 3,896 adults at Lower Granite Dam, respectively). In their preliminary analysis of 

recent returns, Fisher and Hinrichsen (2004) reported that the geometric mean abundance of naturallyproduced fall Chinook salmon was 3,462 during 2001-2003, compared to 694 in 1996-2000 (a 398% 

increase). The slope of the population trend increased 8.0% (from 1.16 to 1.24) when the data for 2001-

2003 were added to the 1990-2000 series. These results indicate that, at least for the short-term, the 

population has been increasing. Approximately 64% of the aggregate run at Lower Granite Dam was 

hatchery fish in 2001-2003, compared to 67% during 1990-2000 (Fisher 2004). 

4.3.3 UCR Spring Chinook Salmon 

4.3.3.1 ESU Structure 

The Interior TRT (2003) identified one major population group consisting of three demographically 

independent populations in the UCR spring Chinook salmon ESU (Appendix B, Figure B-3). Due to the 

relatively small size of the area, they did not identify any major groupings. Within the current boundary 

of the ESU, spring Chinook salmon are considered extirpated from the Okanogan drainage. The historical 

status of spring-run, stream-type fish belonging to this ESU in the Okanogan is uncertain. The Interior 

TRT could not determine definitively whether an independent population of UCR spring Chinook salmon 

existed there in the past but recognized the possibility that the area may have supported one. The 

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construction of Grand Coulee Dam in 1939 blocked access to over 50% of the river miles formerly 

available to UCR spring Chinook salmon (NRC 1996). Tributaries in this blocked area may have 

supported one or more populations, but the lack of data on distribution and genetic makeup made it 

impossible for the Interior TRT to make any definitive determination. 

4.3.3.2 The BRT Findings 

The five hatchery spring-run Chinook salmon populations considered to be part of this ESU are programs 

aimed at supplementing natural production areas. These programs have contributed substantially to the 

abundance of natural spawners in recent years. However, little information is available to assess the 

impact of these high levels of supplementation on the long-term productivity of natural populations. The 

BRT (2003) concluded that spatial structure in this ESU was of little concern, because there is passage 

and connectivity among almost all populations. During years of critically low escapement (1996 and 

1998), extreme management measures were taken in one of the three major spring Chinook salmon 

producing basins where all returning adults were collected and taken into the hatchery supplementation 

programs, reflecting the ongoing vulnerability of certain segments of this ESU. The BRT expressed 

concern that these actions, while appropriately guarding against the catastrophic loss of populations, may 

have compromised ESU population structure and diversity. The BRT’s assessment of risk for the four 

VSP categories reflects strong concerns regarding abundance and productivity and comparatively less 

concern for ESU spatial structure and diversity (BRT 2003). 

4.3.3.3 2004 Status Review 

In its Status Review, NMFS’ assessment of the effects of artificial propagation concluded that the withinESU hatchery programs do not substantially reduce the extinction risk of the ESU in total (NMFS 2004c). 

Protective efforts, as evaluated pursuant to the PECE, did not alter NMFS’ assessment that the ESU is in 

danger of extinction or likely to become so in the foreseeable future. Actions under the 2000 FCRPS 

Biological Opinion, Federally funded habitat restoration efforts, and other protective efforts are 

encouraging signs in addressing the ESU’s factors for decline, but they do not as yet substantially reduce 

the ESU’s extinction risk. Artificial propagation practices within the geographic range of the ESU do not 

fully support the conservation and recovery of UCR spring-run Chinook salmon. In particular, NMFS is 

concerned that the non-ESU Entiat National Fish Hatchery has compromised the genetic integrity of the 

native natural population of spring-run Chinook salmon in the Entiat Basin. 

4.3.3.4 Recent Dam Counts and Returns to the Spawning Grounds 

Cooney (2004) reported that natural-origin returns to the Methow subbasin in 2002 and to the Entiat and 

Wenatchee during 2002 and 2003 continued to exceed those observed during much of the 1990s. 

However, returns to the Methow declined during 2003. In their preliminary analysis, Fisher and 

Hinrichsen (2004) reported that the geometric mean of aggregate numbers of UCR spring Chinook 

salmon increased 1,038% from 1996-2000 (4,959) to 2001-2003 (436 fish). The slope of the aggregate 

population trend increased 9.3% (from 1.00 to 1.10) when the data for 2001-2003 were added to the 1990-

2000 series. These results indicate that, at least in the short term, the aggregate population and the naturalorigin populations in the Entiat and Wenatchee subbasins have been increasing. 

4.3.4 UWR Chinook Salmon 

4.3.4.1 ESU Structure 

The Willamette/Lower Columbia River (W/LC) TRT (McElhany et al. 2004) identified seven 

demographically independent populations of UWR Chinook salmon in a single major group (Appendix B, 

Figure B.4). All of these populations are extant, although they vary in degree of viability. 

4.3.4.2 The BRT Findings 

Numbers passing Willamette Falls have remained relatively steady over the past 50 years (ranging from 

approximately 20,000 to 75,000), but are an order of magnitude below the peak abundance levels 

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observed in the 1920s (approximately 300,000 adults). The Clackamas and McKenzie River populations 

have shown substantial increases in total abundance since 2000. Trends in the other populations are 

difficult to determine. However, interpretation of the difference in abundance levels for the other 

populations remains confounded by a high but uncertain fraction of hatchery-origin fish. 

The BRT estimated that, despite improving trends in total productivity since 1995, productivity would be 

below replacement in the absence of artificial propagation. The BRT was particularly concerned that a 

majority of the historical spawning habitat and approximately 30% to 40% of total historical habitat are 

now inaccessible behind dams. The restriction of natural production to just a few areas increases the 

ESU’s vulnerability to environmental variability and catastrophic events. Losses of local adaptation and 

genetic diversity through the mixing of hatchery stocks within the ESU and the introgression of out-ofESU hatchery fall-run Chinook salmon represent threats to ESU diversity. However, the BRT was 

encouraged by the recent closure of the fall-run hatchery and by improved marking rates of hatchery fish 

to assist in monitoring and in the management of a marked-fish selective fishery. The BRT found 

moderately high risks for all VSP categories. 

4.3.4.3 2004 Status Review 

There are no direct estimates of total natural-origin spawner abundance for the UWR Chinook salmon 

ESU. The abundance of the aggregate run passing Willamette Falls has remained relatively steady over 

the past 50 years (ranging from approximately 20,000 to 70,000 fish), but is only a fraction of peak 

abundance levels observed in the 1920s (approximately 300,000 adults). Interpretation of abundance 

levels is confounded by a high but uncertain fraction of hatchery-produced fish. The McKenzie River 

population has shown substantial increases in total abundance (hatchery origin and natural origin fish) in 

the last 2 years, while trends in other natural populations in the ESU are generally mixed. With the 

relatively large incidence of hatchery fish spawning in the wild, it is difficult to determine trends in 

productivity for natural origin fish. 

Seven artificial propagation programs in the Willamette River produce fish that are considered to be part 

of the UWR Chinook salmon ESU. All of these programs are funded to mitigate for lost or degraded 

habitat and produce fish for harvest purposes. During the Status Review, NMFS’ assessment of the effects 

of artificial propagation concluded that these hatchery programs collectively do not substantially reduce 

the extinction risk of the ESU (NMFS 2004c). An increasing proportion of hatchery-origin returns has 

contributed to increases in total ESU abundance. However, it is unclear whether these returning hatchery 

and natural fish actually survive over winter to spawn. Estimates of pre-spawning mortality indicate that a 

high proportion (more than 70%) of spring Chinook salmon in most ESU populations die before 

spawning. In recent years, hatchery fish have been used to reintroduce spring Chinook salmon back into 

historical habitats above impassible dams (e.g., in the North Santiam, McKenzie, and Middle Fork 

Willamette Rivers), slightly decreasing risks to ESU spatial structure. Within-ESU hatchery fish exhibit 

different life-history characteristics from natural ESU fish. High proportions of hatchery-origin natural 

spawners in remaining natural production areas (i.e., in the Clackamas and McKenzie Rivers) may 

thereby have negative impacts on within- and among population genetic and life-history diversity. 

Collectively, artificial propagation programs in the ESU have a slight beneficial effect on ESU abundance 

and spatial structure but neutral or uncertain effects on ESU productivity and diversity. Protective efforts, 

as evaluated pursuant to the PECE, did not alter the assessments of the BRT and the Artificial 

Propagation Evaluation Workshop participants that the ESU is “likely to become endangered within the 

foreseeable future.” The USFWS Greenspaces Program, the Oregon Plan, hatchery reform efforts, and 

other protective initiatives are encouraging signs. However, restoration efforts in the ESU are very local 

in scale and have yet to provide benefits at the scale of watersheds or at the larger spatial scale of the 

ESU. The blockage of historical spawning habitat and the restriction of natural production areas remain to 

be addressed. 

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4.3.4.4 Recent Dam Counts and Returns to the Spawning Grounds 

Fisher and Hinrichsen (2004) report that the preliminary geometric mean aggregate abundance of UWR 

Chinook salmon in the Clackamas and McKenzie Rivers is equal to 12,530 for 2001-2003, compared to 

3,041 in 1996-2000, a 312% increase. The slope of the aggregate population trend increased 15.2% (from 

0.89 to 1.02) when the data for 2001-2003 were added to the 1990-2000 series, reversing the decline and 

indicating that, at least in the short-term, the aggregate population has been increasing. 

4.3.5 LCR Chinook Salmon 

4.3.5.1 ESU Structure 

The W/LC TRT (McElhany et al. 2004) identified a total of 23 extant, demographically independent 

populations in six major population groups: the Coastal fall-run, Cascade fall-run, Cascade late fall-run, 

Cascade spring-run, Gorge fall-run, and Gorge spring-run (Appendix B, Figures B.5a and B.5b). 

4.3.5.2 The BRT Findings 

Abundance estimates of naturally produced spring Chinook salmon have improved since 2001 due to the 

marking of all hatchery spring Chinook salmon releases (compared to a previous marking rate of only 1% 

to 2%), which allows for the separation in counts at weirs and traps and on spawning grounds. Despite 

recent improvements, long-term trends in productivity are below replacement for the majority of 

populations. Of the historical populations, 8 to 10 have been extirpated or nearly extirpated. Although 

approximately 35% of historical habitat has been lost behind impassable barriers, the ESU exhibits a 

broad spatial distribution in a variety of watersheds and habitat types. Natural production currently occurs 

in approximately 20 populations, although only one population has a mean spawner abundance exceeding 

1,000 fish. The BRT expressed concern that most of the extirpated populations are spring-run, and the 

disproportionate loss of this life history type represents a risk to ESU diversity. Additionally, of the 4 

hatchery spring-run Chinook salmon populations considered to be part of the ESU, 2 are propagated in 

rivers that, although they are within the historical geographic range of the ESU, probably did not support 

spring-run populations. High hatchery production poses genetic and ecological risks to the natural 

populations and complicates assessments of their performance. The BRT also expressed concern over the 

introgression of out-of-ESU hatchery stocks. The BRT found moderately high risk for all VSP categories. 

4.3.5.3 2004 Status Review 

In its Status Review, NMFS notes that many populations within the LCR Chinook salmon ESU have 

exhibited pronounced increases in abundance and productivity in recent years, possibly due to improved 

ocean conditions. Abundance estimates of naturally spawned populations have been uncertain until 

recently due to a high (approximately 70%) fraction of naturally spawning hatchery fish. Abundance 

estimates of naturally-produced spring Chinook salmon have improved since 2001 due to the marking of 

all hatchery spring Chinook salmon releases (compared to a previous marking rate of only 1% to 2%), 

which allows for the separation in counts at weirs and traps and on spawning grounds. Despite recent 

improvements, long-term trends in productivity through 2001 were below replacement for the majority of 

populations in the ESU. Of the historical populations, 8 to 10 were extirpated or nearly extirpated. 

Although approximately 35% of historical habitat is behind impassable barriers, the ESU exhibits a broad 

spatial distribution in a variety of watersheds and habitat types. Natural production occurs in 

approximately 20 populations, although as of 2001, only one population had a mean spawner abundance 

exceeding 1,000 fish. 

Seventeen artificial propagation programs releasing hatchery Chinook salmon are considered part of the 

LCR Chinook salmon ESU. All of these programs are designed to produce fish for harvest, and three of 

these programs are also intended to augment naturally spawning populations in the basins where the fish 

are released. These three programs integrate naturally produced spring Chinook salmon into the 

broodstock in an attempt to minimize the genetic effects of returning hatchery adults that spawn in the 

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wild. 

During the 2004 Status Review, NMFS’ assessment of the effects of artificial propagation concluded that 

these hatchery programs do not substantially reduce the extinction risk of the ESU in total (NMFS 

2004c). Although the hatchery programs have been successful at producing substantial numbers of fish, 

thereby reducing risks to ESU abundance, their effect on the productivity of the ESU in total is uncertain. 

Additionally, the high level of hatchery production in this ESU poses potential genetic and ecological 

risks to the ESU and confounds the monitoring and evaluation of abundance trends and productivity. The 

Cowlitz River spring Chinook salmon program releases parr into the Upper Cowlitz River Basin in an 

attempt to reestablish a naturally spawning population above Cowlitz Falls Dam. Such reintroduction 

efforts increase the ESU’s spatial distribution into historical habitats and slightly reduce risks to ESU 

spatial structure. The few programs that regularly integrate natural fish into the broodstock may help 

preserve genetic diversity within the ESU. However, the majority of hatchery programs in the ESU have 

not converted to the practice of regularly incorporating natural broodstock, thus limiting this risk-reducing 

feature at the ESU scale. Past and ongoing transfers of broodstock among hatchery programs in different 

basins represent risks to within- and among-population diversity. Collectively, artificial propagation 

programs in the ESU provide slight benefits to ESU abundance, spatial structure, and diversity but have 

neutral or uncertain effects on productivity. 

NMFS’ assessment of the effects of artificial propagation concluded that the within-ESU hatchery 

programs do not substantially reduce the risk of the ESU in total (NMFS 2004c). Protective efforts, as 

evaluated pursuant to the PECE, did not alter NMFS’ assessment that the ESU is “likely to become 

endangered within the foreseeable future.” Planned dam removals on the Sandy River, Federally funded 

habitat restoration efforts, the Washington Department of Natural Resources HCP, and other protective 

efforts are encouraging signs that the ESU’s factors for decline are being addressed, but they do not as yet 

substantially reduce threats to the ESU. 

4.3.5.4 Recent Dam Counts and Returns to the Spawning Grounds 

Fisher and Hinrichsen (2004) compared the aggregate abundance of 41,450 during 2001 to a geomean of 

11,135 for the years 1996-2000, a 272% increase. The slope of the aggregate population trend increased 

6.6% (from 0.76 to 1.03) when the count for 2001 was added to the 1990-2000 data series, reversing the 

decline and indicating that, at least in the short-term, the aggregate population is increasing. 

4.3.6 SR Steelhead 

4.3.6.1 ESU Structure 

The Interior TRT (2003) identified 23 populations148 in 6 major population groups in this ESU: the 

Clearwater River, the Grande Ronde River, Hells Canyon, the Imnaha River, the Lower Snake River, and 

the Salmon River (Appendix B, Figure B.6). Like SR spring/summer Chinook salmon, SR steelhead were 

blocked from portions of the Upper Snake River beginning in the late 1800s and culminating with the 

construction of Hells Canyon Dam in the 1960s. The SR steelhead ESU includes all naturally spawned 

populations of steelhead (and their progeny) in streams in the Snake River Basin of southeast 

Washington, northeast Oregon, and Idaho (62 FR 43937; August 18, 1997). 

NMFS’ June 14, 2004, listing proposal did not resolve the ESU membership of native resident 

populations that are above recent (usually manmade) impassable barriers but below natural barriers. It 

was provisionally proposed that these resident populations not be considered part of the revised SR 

steelhead ESU until such time as significant scientific information becomes available to afford a case-by-

 

148 The Interior TRT (2003) identified one additional group of tributaries, Hells Canyon, which members 

thought was not large enough to support a demographically independent population. 

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case evaluation of their ESU relationships. There was one exception in the listing proposal: recent genetic 

data suggest that native resident steelhead above Dworshak Dam on the North Fork Clearwater River are 

part of the ESU. However, NMFS did not propose that hatchery rainbow trout introduced to the 

Clearwater River (and other areas within the ESU) be included in the ESU. The presence of 6 major 

population groups in this ESU means that it is less likely that any single group is significant for this 

ESU’s survival and recovery, compared to ESUs with fewer major population groups. 

4.3.6.2 The BRT Findings 

The BRT (2003) noted that the ESU remains spatially well distributed in each of the six major geographic 

areas in the Snake River Basin. However, the Snake River Basin steelhead “B run”149 was particularly 

depressed. The BRT was also concerned about the predominance of hatchery origin fish in this ESU, the 

inferred displacement of naturally produced fish by hatchery-origin fish, and potential impacts on ESU 

diversity. High straying rates exhibited by some hatchery programs generated concern about the possible 

homogenization of population structure and diversity. However, recent efforts to improve the use of local 

broodstock and release hatchery fish away from natural production areas are encouraging. For many BRT 

members, the presence of relatively numerous resident fish reduces risks to ESU abundance but provides 

an uncertain contribution to ESU productivity, spatial structure, and diversity (NMFS 2003, 2004b). The 

BRT found moderate risk for the abundance, productivity, and diversity VSP categories and 

comparatively lower risk in the spatial structure category. 

4.3.6.3 2004 Status Review 

The paucity of information on adult spawning escapement for specific tributary production areas in the 

SR steelhead ESU made a quantitative assessment of viability difficult. Annual return estimates are 

limited to counts of the aggregate return over Lower Granite Dam, and spawner estimates for the 

Tucannon, Grande Ronde, and Imnaha Rivers. The 2001 return over Lower Granite Dam was 

substantially higher relative to the low levels seen in the 1990s; the recent 5- year mean abundance 

(14,768 natural returns) approximately 28% of the interim recovery target level. The abundance surveyed 

in sections of the Grande Ronde, Imnaha, and Tucannon Rivers was generally improved in 2001. 

However, recent 5-year abundance and productivity trends (through 2001) were mixed. Five of the nine 

available data series exhibit positive long- and short-term trends in abundance. The majority of long-term 

population growth rate estimates for the nine available series were below replacement. The majority of 

short-term population growth rates (through 2001) were marginally above replacement or well below 

replacement, depending upon the assumption made regarding the effectiveness of hatchery fish in 

contributing to natural production. 

There are six artificial propagation programs producing steelhead in the Snake River Basin that are 

considered to be part of the ESU. Artificial propagation enhancement efforts occur in the Imnaha River 

(Oregon), Tucannon River (Washington), East Fork Salmon River (Idaho, in the initial stages of 

broodstock development), and South Fork Clearwater River (Idaho). In addition, Dworshak Hatchery acts 

as a gene bank to preserve the North Fork Clearwater River “B-run” steelhead population, which no 

longer has access to historical habitat due to construction of Dworshak Dam. During the Status Review, 

NMFS’ assessment of the effects of artificial propagation concluded that these hatchery programs 

collectively do not substantially reduce the extinction risk of the ESU in total (NMFS 2004c). Snake 

River Basin hatchery programs may be providing some benefit to the local target, but only the Dworshakbased programs have appreciably benefited the total number of adult spawners. The Little Sheep Hatchery 

program is contributing to total abundance in the Imnaha River but has not contributed to increased 

natural productivity. The Tucannon and East Fork Salmon River programs were only recently initiated 

 

149 B-run steelhead have a 2-year ocean residence and larger body size and are believed to be produced 

only in the Clearwater, Middle Fork Salmon, and South Fork Salmon Rivers. 

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and have yet to produce appreciable adult returns. Thus, the overall contribution of the hatchery programs 

in reducing risks to ESU abundance is small, and the contribution of ESU hatchery programs to the 

productivity of the ESU in total is uncertain. Most returning Snake River Basin hatchery steelhead are 

collected at hatchery weirs or have access to unproductive mainstem habitats, limiting potential 

contributions to the productivity of the entire ESU. The artificial propagation programs affect only a small 

portion of the ESU’s spatial distribution and confer only slight benefits to ESU spatial structure. Large 

steelhead programs not considered to be part of the ESU occur in the mainstem Snake, Grande Ronde, 

and Salmon Rivers and may adversely affect ESU diversity. These out-of-ESU programs are currently 

undergoing review to determine the level of isolation between the natural and hatchery stocks and to 

define what reforms may be needed. Collectively, artificial propagation programs in the ESU provide a 

slight beneficial effect to ESU abundance and spatial structure but have neutral or uncertain effects on 

ESU productivity and diversity. 

4.3.6.4 Recent Dam Counts and Returns to the Spawning Grounds 

The lack of information on adult spawning escapement to many tributary production areas makes it 

difficult to assess quantitatively the viability of the SR steelhead ESU. Estimates of annual returns are 

limited to estimates of aggregate numbers over Lower Granite Dam and spawner estimates for the 

Tucannon, Grande Ronde, and Imnaha Rivers. Cooney (2004) reported continuing high returns of naturalorigin SR steelhead (both A- and B-run fish) during 2002 and 2003 compared to those observed during 

much of the 1990s. In their preliminary report, Fisher and Hinrichsen (2004) estimated that the geometric 

mean of the natural-origin run was 37,784 during 2001-2003, a 253% increase over the 1996-2000 period 

(10,694 steelhead). The slope of the population trend increased 9.3% (from 1.00 to 1.10) when the counts 

for 2001-2003 were added to the 1990-2000 data series. These data indicate that, at least in the short-term, 

the natural-origin run has been increasing. 

4.3.7 UCR Steelhead 

4.3.7.1 ESU Structure 

The Interior TRT (2003) identified four historical, demographically independent populations in a single 

major population group in this ESU (Appendix B, Figure B.7). As described above for UCR spring 

Chinook salmon, the construction of Grand Coulee Dam in 1939 blocked access to over 50% of the river 

miles formerly available to UCR steelhead (NRC 1996). Tributaries in this blocked area may have 

supported one or more populations, but the lack of data on distribution and genetic makeup made it 

impossible for the Interior TRT to make a definitive determination. The UCR steelhead ESU includes all 

naturally spawned populations of steelhead in streams in the Columbia River Basin upstream from the 

Yakima River in Washington to the United States- Canada border (62 FR 43937; August 18, 1997). 

NMFS’ June 14, 2004, listing proposal did not resolve the ESU membership of native resident 

populations that are above recent (usually man-made) impassable barriers but below natural barriers. It 

was provisionally proposed that these resident populations not be considered part of the revised UCR 

steelhead ESU, until such time as significant scientific information becomes available, thereby affording a 

case-by-case evaluation of their ESU relationships. 

4.3.7.2 The BRT Findings 

The BRT (2003) was concerned about the general lack of detailed information regarding the productivity 

of natural populations. The extremely low replacement rate of naturally spawning fish (0.25-0.30 at the 

time of the last status review in 1998) does not appear to have improved appreciably. The predominance 

of hatchery-origin natural spawners (approximately 70% to 90% of adult returns) is a significant source of 

concern for the diversity of the ESU and generates uncertainty about long-term trends in natural 

abundance and productivity. The natural component of the anadromous run over Priest Rapids Dam has 

increased from an average of 1,040 (1992-1996) to 2,200 (1997-2001). This pattern, however, is not 

consistent for other production areas within the ESU. The mean proportion of natural-origin spawners 

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declined by 10% from 1992-1996 to 1997-2001. For many BRT members, the presence of relatively 

numerous resident fish reduced risks to ESU abundance but provided an uncertain contribution to ESU 

productivity, spatial structure, and diversity (NMFS 2003, 2004b). The BRT found high risk for 

productivity and comparatively lower risk for abundance, diversity, and spatial structure. 

4.3.7.3 2004 Status Review 

In its Status Review, NMFS reported that the last 2-3 years (through 2001) had seen an encouraging 

increase in the number of naturally produced fish in the UCR steelhead ESU. The 1996-2001 average 

aggregate return through the Priest Rapids Dam fish ladder (just below the upper Columbia steelhead 

production areas) was approximately 12,900 total adults, compared to 7,800 adults for 1992–1996. 

However, the recent 5-year mean abundances (through 2001) for naturally spawned populations in this 

ESU were 14% to 30% of their interim recovery target abundance levels. 

Six artificial propagation programs that produce hatchery steelhead are considered to be part of the UCR 

steelhead ESU. These programs are intended to contribute to the recovery of the ESU by increasing the 

abundance of natural spawners, increasing spatial distribution, and improving local adaptation and 

diversity (particularly with respect to the Wenatchee River steelhead). Research projects to investigate the 

spawner productivity of hatchery-reared fish are being developed. Some of the hatchery-reared steelhead 

adults that return to the basin may be in excess of needs of the naturally spawning population in years 

when survival is high, potentially posing a risk to the natural-origin component of the ESU. The artificial 

propagation programs included in this ESU adhere to strict protocols for the collection, rearing, 

maintenance, and mating of the captive brood populations. Genetic evidence suggests that these programs 

remain closely related to the naturally spawned populations and maintain local genetic distinctiveness of 

populations within the ESU. HCPs with the Chelan and Douglas Public Utility Districts and binding 

mitigation agreements ensure that these programs will have secure funding and will therefore continue 

into the future. These hatchery programs have undergone ESA Section 7 consultation to ensure that they 

do not jeopardize the recovery of the ESU and have received ESA Section 10 permits for production 

though 2007. Annual reports and other specific information reporting requirements are used to ensure that 

the terms and conditions specified by NMFS are followed. These programs, through adherence to best 

professional practices, have not experienced disease outbreaks or other catastrophic losses. 

During the Status Review, NMFS’ assessment of the effects of artificial propagation concluded that 

hatchery programs collectively mitigate the immediacy of extinction risk for the UCR steelhead ESU in 

total in the short-term, but the contributions of these programs to the long-term survival and recovery of 

the species is uncertain (NMFS 2004c). The ESU hatchery programs substantially increase total ESU 

returns, particularly in the Methow Basin, where hatchery-origin fish make up an average of 92% of all 

returns. The contribution of hatchery programs to the abundance of naturally spawning fish is uncertain, 

as is their contribution to the productivity of the ESU in total. However, the presence of large numbers of 

hatchery-origin steelhead in excess of both broodstock needs and available spawning habitat capacity may 

decrease the productivity of the ESU. With increasing ESU abundance in recent years, naturally 

spawning, hatchery-origin fish have expanded into unoccupied spawning areas. Collectively, artificial 

propagation programs benefit ESU abundance and spatial structure but have neutral or uncertain effects 

on ESU productivity and diversity. 

4.3.7.4 Recent Dam Counts and Returns to the Spawning Grounds 

Fisher and Hinrichsen’s (2004) preliminary estimate of the geometric mean of natural-origin UCR 

steelhead was 3,643 during 2001-2003, compared to 1,146 in 1996-2000, a 218% increase. The slope of 

the natural-origin population trend increased 9.2% (from 0.97 to 1.06,) when the data for 2001-2003 were 

added to the 1990-2000 series, reversing the decline and indicating, at least in the short-term, that the run 

size has been increasing. 

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4.3.8 MCR Steelhead 

4.3.8.1 ESU Structure 

The Interior TRT (2003) identified 15 populations in 4 major population groups (Cascades Eastern Slopes 

Tributaries, John Day River, the Walla Walla and Umatilla Rivers, and the Yakima River) and 1 

unaffiliated independent population (Rock Creek) in this ESU (Appendix B, Figure B.8). There are 2 

extinct populations in the Cascades Eastern Slope major population group (MPG), the White Salmon and 

Deschutes Rivers above Pelton Dam. 

The MCR steelhead ESU includes all naturally spawned populations of steelhead in streams from above 

the Wind River in Washington and the Hood River in Oregon (exclusive), upstream to and including the 

Yakima River in Washington, excluding steelhead from the Snake River Basin (64 FR 14517; March 25, 

1999). 

NMFS’ June 14, 2004, listing proposal did not resolve the ESU membership of native resident 

populations that are above recent (usually manmade) impassable barriers but below natural barriers. It 

was provisionally proposed that these resident populations not be considered part of the revised MCR 

steelhead ESU until such time as significant scientific information becomes available, thereby affording a 

case-by-case evaluation of their ESU relationships. 

4.3.8.2 The BRT Findings 

The continued low number of natural returns to the Yakima River (10% of the interim recovery target 

abundance level, for a subbasin that was a major historical production center for the ESU) generated 

concern in the BRT. However, steelhead remain well distributed in the majority of subbasins in the ESU. 

The presence of substantial numbers of out-of-basin (and largely out-of- ESU) natural spawners in the 

Deschutes River raised substantial concern regarding the genetic integrity and productivity of the native 

Deschutes population. The extent to which this straying is a historical natural phenomenon is unknown. 

The cool Deschutes River temperatures may attract fish migrating in the comparatively warm Columbia 

River, inducing high stray rates. The BRT noted a particular difficulty in evaluating the contribution of 

resident fish to ESU-level extinction risk. Several sources indicate that resident fish are very common in 

the ESU and may greatly outnumber anadromous fish. The BRT concluded that the relatively abundant 

and widely distributed resident fish in the ESU reduce risks to overall ESU abundance but provide an 

uncertain contribution to ESU productivity, spatial structure, and diversity (NMFS 2003, 2004b). 

4.3.8.3 2004 Status Review 

In its Status Review, NMFS noted that the abundance of natural populations in the MCR steelhead ESU 

increased substantially in 2001 over the previous 5 years. The Deschutes and Upper John Day Rivers had 

recent 5-year mean abundance levels in excess of their respective interim recovery target abundance 

levels (NMFS 2002). Due to an uncertain proportion of out-of-ESU strays in the Deschutes River, the 

recent increases in this population were difficult to interpret. 

There are seven hatchery steelhead programs considered to be part of the MCR steelhead ESU. These 

programs propagate steelhead in 3 of 16 ESU populations and improve kelt (post-spawned steelhead) 

survival in 1 population. There are no artificial programs producing the winter-run life history in the 

Klickitat River and Fifteenmile Creek populations. All of the ESU hatchery programs are designed to 

produce fish for harvest, although two are also implemented to augment the naturally spawning 

populations in the basins where the fish are released. During the Status Review, NMFS’ assessment of the 

effects of artificial propagation on ESU extinction risk concluded that these hatchery programs 

collectively do not substantially reduce the extinction risk of the ESU in total (NMFS 2004c). ESU 

hatchery programs may provide a slight benefit to ESU abundance. Artificial propagation increases total 

ESU abundance, principally in the Umatilla and Deschutes Rivers. The kelt reconditioning efforts in the 

Yakima River do not augment natural abundance but do benefit the survival of the natural populations. 

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The Touchet River Hatchery program has only recently been established, and its contribution to ESU 

viability is uncertain. The contribution of ESU hatchery programs to the productivity of the three target 

populations and the ESU in total is uncertain. The hatchery programs affect a small proportion of the 

ESU, providing a negligible contribution to ESU spatial structure. Overall, the impacts to ESU diversity 

are neutral. Collectively, artificial propagation programs in the ESU provide a slight beneficial effect to 

ESU abundance but have neutral or uncertain effects on ESU productivity, spatial structure, and diversity. 

4.3.8.4 Recent Dam Counts and Returns to the Spawning Grounds 

In their preliminary report, Fisher and Hinrichsen (2004) estimated a geometric mean of natural-origin 

MCR steelhead equal to 17,553 during 2001-2002, compared to 7,228 in 1996-2000, a 143% increase. 

The slope of the population trend for natural-origin fish increased 6.2% (from 0.99 to 1.05) when the data 

for 2001-2002 were added to the 1990-2000 series, reversing the decline and indicating that, at least in the 

short run, the natural-origin population has been increasing. 

4.3.9 UWR Steelhead 

4.3.9.1 ESU Structure 

The UWR steelhead ESU includes all naturally spawned populations of winter-run steelhead in the 

Willamette River in Oregon and its tributaries upstream from Willamette Falls to the Calapooia River 

(inclusive) (64 FR 14517; March 25, 1999). The W/LC TRT (McElhany et al. 2004) identified four 

extant, demographically independent populations in one major population group (Appendix B, Figure 

B.9). NMFS’ June 14, 2004, listing proposal did not resolve the ESU membership of native resident 

populations that are above recent (usually manmade) impassable barriers but below natural barriers. It 

was provisionally proposed that these resident populations not be considered part of the revised UWR 

steelhead ESU, until such time as significant scientific information becomes available to afford a case-bycase evaluation of their ESU relationships. 

This ESU does not include any artificially propagated steelhead stocks that reside within the historical 

geographic range of the ESU. Hatchery summer steelhead occur in the Willamette Basin but are an outof-basin stock that is not included in the ESU. 

4.3.9.2 The BRT Findings 

The BRT considered the cessation of the “early” winter-run hatchery program a positive sign for ESU 

diversity risk but remained concerned that releases of non-native summer steelhead continue. Because 

coastal cutthroat trout are dominant in the basin, resident steelhead are not as abundant or widespread 

here as in the inland proposed steelhead ESUs. The BRT did not consider resident fish to reduce risks to 

ESU abundance, and their contribution to ESU productivity, spatial structure, and diversity is uncertain 

(NMFS 2003, 2004b). The BRT found moderate risks for each of the VSP categories. 

4.3.9.3 2004 Status Review 

In its Status Review, NMFS noted that approximately one-third of the LCR steelhead ESU’s historically 

accessible spawning habitat is now blocked. Notwithstanding the lost spawning habitat, the ESU 

continues to be spatially well distributed, occupying each of the four major subbasins (the Molalla, North 

Santiam, South Santiam, and Calapooia Rivers). There was some uncertainty about the historical 

occurrence of steelhead in drainages of the Oregon Coastal Range. Coastal cutthroat trout is a dominant 

species in the Willamette Basin, and thus steelhead are not expected to have been as widespread in this 

ESU as they are east of the Cascade Mountains. 

4.3.9.4 Recent Dam Counts and Returns to the Spawning Grounds 

In their preliminary report, Fisher and Hinrichsen (2004) estimated a geometric mean of natural origin 

UWR steelhead at Willamette Falls equal to 9,541 during 2001-2004, compared to 3,961 in 1996-2000, a 

141% increase. The slope of the population trend increased 10.4% (from 0.93 to 1.02) when the data for 

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2001-2004 were added to the 1990-2000 series, reversing the decline and indicating that, at least in the 

short run, the natural-origin population has been increasing. 

4.3.10 LCR Steelhead 

4.3.10.1 ESU Structure 

The LCR steelhead ESU includes all naturally spawned populations of steelhead in streams and tributaries 

to the Columbia River between the Cowlitz and Wind Rivers in Washington (inclusive) and the 

Willamette and Hood Rivers in Oregon (inclusive). Excluded are steelhead in the Upper Willamette River 

Basin above Willamette Falls and steelhead from the Little and Big White Salmon Rivers in Washington 

(62 FR 43937; August 18, 1997). The W/LC TRT (McElhany et al. 2004) identified a total of 20 extant, 

demographically independent populations in four major populations groups: Cascade winter-run, Cascade 

summer-run, Gorge winter-run, and Gorge summer-run in this ESU (Appendix B, Figure B.10). 

NMFS’ June 14, 2004, listing proposal did not resolve the ESU membership of native resident 

populations that are above recent (usually manmade) impassable barriers but below natural barriers. It 

was provisionally proposed that these resident populations not be considered part of the revised LCR 

steelhead ESU until such time as significant scientific information becomes available to afford a case-bycase evaluation of their ESU relationships. The presence of four major population groups in this ESU 

makes it is less likely that any single group is significant for this ESU’s survival and recovery, compared 

to ESUs with fewer major population groups. 

4.3.10.2 The BRT Findings 

Approximately 35% of historical habitat has been lost in this ESU due to the construction of dams or 

other impassible barriers, but the ESU exhibits a broad spatial distribution in a variety of watersheds and 

habitat types. The BRT was particularly concerned about the impact on ESU diversity of the high 

proportion of hatchery-origin spawners in the ESU, the disproportionate declines in the summer steelhead 

life history, and the release of nonnative hatchery summer steelhead in the Cowlitz, Toutle, Sandy, Lewis, 

Elochoman, Kalama, Wind, and Clackamas Rivers. Resident fish are not as abundant in this ESU as they 

are in the proposed steelhead ESUs. The BRT did not consider resident fish to reduce risks to ESU 

abundance, and their contribution to ESU productivity, spatial structure, and diversity is uncertain (NMFS 

2003, 2004b). 

The BRT found moderate risks in each of the VSP categories. 

4.3.10.3 2004 Status Review 

In its Status Review, NMFS noted that some anadromous populations in the LCR steelhead ESU, 

particularly summer-run steelhead populations, had shown encouraging increases in abundance in the 2 to 

3 years ending 2001. However, population abundance levels remained small (no population had a recent 

5-year mean abundance greater than 750 spawners). 

There are 10 artificial propagation programs releasing hatchery steelhead that are considered to be part of 

the LCR steelhead ESU. All of these programs are designed to produce fish for harvest, but several are 

also implemented to augment the natural spawning populations in the basins where the fish are released. 

Four of these programs are part of research activities to determine the effects of artificial propagation 

programs that use naturally produced steelhead for broodstock in an attempt to minimize the genetic 

effects of returning hatchery adults that spawn naturally. One of these programs, the Cowlitz River laterun winter steelhead program, is also producing fish for release into the Upper Cowlitz River Basin in an 

attempt to reestablish a natural spawning population above Cowlitz Falls Dam. 

NMFS concluded that these hatchery programs collectively do not substantially reduce the extinction risk 

of the ESU in total (NMFS 2004c). The hatchery programs have reduced risks to ESU abundance by 

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increasing total ESU abundance and the abundance of fish spawning naturally in the ESU. The 

contribution of ESU hatchery programs to the productivity of the ESU in total is uncertain. It is also 

uncertain if steelhead reintroduced into the Upper Cowlitz River will be viable in the foreseeable future, 

because outmigrant survival appears to be quite low. As noted by the BRT, out-of-ESU hatchery 

programs have negatively impacted ESU productivity. The within-ESU hatchery programs provide a 

slight decrease in risks to ESU spatial structure, principally through the re-introduction of steelhead into 

the Upper Cowlitz River Basin. The eventual success of these reintroduction efforts, however, is 

uncertain. Collectively, artificial propagation programs in the ESU provide a slight beneficial effect on 

ESU abundance, spatial structure, and diversity but uncertain effects on ESU productivity. 

4.3.10.4 Recent Dam Counts and Returns to the Spawning Grounds 

In their preliminary report, Fisher and Hinrichsen (2004) estimated that the aggregate abundance of LCR 

steelhead was equal to 4,429 during 2001, compared to 6,333 during the period 1996- 2000, a 30% 

decrease in abundance. The slope of the aggregate population trend declined by 0.8% (from 0.93 to 0.92) 

when the 2001 count was added to the 1990-2000 data series. 

4.3.11 CR Chum Salmon 

4.3.11.1 ESU Structure 

The W/LC TRT (McElhany et al. 2004) identified a total of 8 extant, demographically independent 

populations in three major population groups in this ESU: Coastal, Cascade, and Gorge (Appendix B, 

Figure B.11). Approximately 90% of the historical populations in the Columbia River chum ESU are 

extirpated or nearly so, and the Gorge population group was established by inferring that the 

approximately 100 adult chum salmon that ascend the Bonneville Dam fish ladders each year are 

spawning upstream. However, the Washington Department of Fish and Wildlife (WDFW) found only one 

and two carcasses in its 2002 and 2003 spawning ground surveys in the Gorge area, respectively, and its 

radio-tag data indicate that at least some fish fall back downstream (Ehlke and Keller 2003). The Smolt 

Monitoring Program has no record of juvenile chum salmon at Bonneville Dam. 

4.3.11.2 The BRT Findings 

The loss of off-channel habitats and the extirpation of approximately 17 historical populations increase 

the ESU’s vulnerability to environmental variability and catastrophic events. The populations that remain 

are low in abundance and have limited distribution and poor connectivity. The BRT found high risks for 

each of the VSP categories, particularly for the ESU’s spatial structure and diversity. 

4.3.11.3 2004 Status Review 

In its Status Review, NMFS noted that approximately 90% of the historical populations in the CR chum 

salmon ESU are extirpated or nearly so. During the 1980s and 1990s, the combined abundance of natural 

spawners for the Lower and Upper Columbia River Gorge, Washougal, and Grays River populations was 

below 4,000 adults. In 2002, however, the abundance of natural spawners exhibited a substantial increase 

at several locations. The preliminary estimate of natural spawners in 2002 was approximately 20,000 

adults. The cause of this dramatic increase in abundance is unknown. Improved ocean conditions, the 

initiation of a supplementation program the Grays River, improved flow management at Bonneville Dam, 

favorable freshwater conditions, and increased survey sampling effort may have contributed to the 

elevated 2002 abundance. However, long- and short-term productivity trends for ESU populations were at 

or below replacement. The loss of off-channel habitats and the extirpation of approximately 17 historical 

populations increase the ESU’s vulnerability to environmental variability and catastrophic events. The 

populations that remain are low in abundance, have limited distribution and poor connectivity. 

There are three artificial propagation programs producing chum salmon considered to be part of the 

Columbia River chum salmon ESU. These are conservation programs designed to support natural 

productivity. The Washougal Hatchery artificial propagation program provides artificially propagated 

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chum salmon for reintroduction into recently restored habitat in Duncan Creek, Washington. This 

program also provides a safety net for the naturally spawning population in the mainstem Columbia River 

below Bonneville Dam. That population can access only a portion of spawning habitat during low-flow 

conditions. The other two programs are designed to augment natural production in the Grays River and 

the Chinook River in Washington. All these programs use naturally produced adults for broodstock. 

These programs were only recently established (1998-2002), with the first hatchery chum salmon 

returning in 2002. 

NMFS’ assessment of the effects of artificial propagation on ESU extinction risk concluded that these 

hatchery programs collectively do not substantially reduce the extinction risk of the ESU in total (NMFS 

2004c). They have only recently been initiated and are just beginning to provide benefits to ESU 

abundance. The contribution of ESU hatchery programs to the productivity of the ESU in total is 

uncertain. The Sea Resources and Washougal Hatchery programs have begun to provide benefits to ESU 

spatial structure through reintroductions of chum salmon into restored habitats in the Chinook River and 

Duncan Creek, respectively. These three programs have a neutral effect on ESU diversity. Collectively, 

artificial propagation programs in the ESU provide a slight beneficial effect to ESU abundance and spatial 

structure but have neutral or uncertain effects on ESU productivity and diversity. 

4.3.11.4 Recent Returns to the Spawning Grounds 

In their preliminary report, Fisher and Hinrichsen (2004) estimated a geometric mean of the aggregate 

number of CR chum salmon in two index areas (Grays River and Hamilton and Hardy Creeks) equal to 

1,776 during 2001-2003, compared to 2,114 in 1996-2000, a 16% decrease. The slope of the aggregate 

population trend decreased 1.5% (from 1.02 to 1.00) when the data for 2001-2003 were added to the 

1990-2000 series. 

4.3.12 SR Sockeye Salmon 

4.3.12.1 ESU Structure 

Anadromous sockeye salmon were once abundant in a variety of lakes throughout the Snake River Basin, 

including the Alturas, Pettit, Redfish, Stanley, and Yellowbelly Lakes in the Sawtooth Valley and in 

Wallowa, Payette, and Warm Lakes (Appendix B, Figure B.12), but the only remaining population 

resides in Redfish Lake. Beginning in the late nineteenth century, anadromous sockeye salmon were 

affected by heavy harvest pressures, unscreened irrigation diversions, and dam construction (TRT 2003). 

In addition, in the 1950s and 1960s, the Idaho Department of Fish and Game (IDFG) actively eradicated 

sockeye salmon from some locations. The SR sockeye salmon ESU includes populations of anadromous 

sockeye salmon from the Snake River Basin in Idaho, though extant populations occur only in the Stanley 

Basin (56 FR 58619; November 20, 1991). The ESU also includes residual sockeye salmon in Idaho’s 

Redfish Lake, as well as one captive propagation hatchery program. Artificially propagated sockeye 

salmon from the Redfish Lake Captive Broodstock Program are considered part of this ESU. NMFS has 

determined that this artificially propagated stock is genetically no more than moderately divergent from 

the natural population (NMFS 2004c). Subsequent to the 1991 listing determination for SR sockeye 

salmon, a “residual” form of Snake River sockeye salmon (hereinafter residuals) was identified. The 

residuals often occur together with anadromous sockeye salmon and exhibit similar behavior in the timing 

and location of spawning. Residuals are thought to be the progeny of anadromous sockeye salmon but are 

generally non-anadromous. In 1993, NMFS determined that the residual population of Snake River 

sockeye salmon that exists in Redfish Lake is substantially reproductively isolated from kokanee (i.e., 

non-anadromous populations of O. nerka that become resident in lake environments over long periods of 

time), represents an important component in the evolutionary legacy of the biological species, and thus 

merits inclusion in the SR sockeye salmon ESU. 

Only 16 naturally produced adults have returned to Redfish Lake since the Snake River sockeye salmon 

ESU was listed as an endangered species in 1991. All 16 fish were taken into the Redfish Lake Captive 

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Broodstock Program, which was initiated as an emergency measure in 1991. The return of over 250 adults 

in 2000 was encouraging; however, subsequent returns from the captive program in 2001 and 2002 have 

been fewer than 30 fish. The BRT found extremely high risks for all four VSP categories. 

4.3.12.2 The BRT Findings and the 2004 Status Review 

There is a single artificial propagation program producing SR sockeye salmon in the Snake River Basin. 

The Redfish Lake sockeye salmon stock was originally founded by collecting the entire anadromous adult 

return of 16 fish between 1990 and 1997, the collection of a small number of residual sockeye salmon, 

and the collection of a few hundred smolts migrating from Redfish Lake. These fish were put into a 

Captive Broodstock program as an emergency measure to prevent extinction of this ESU. Since 1997, 

nearly 400 hatchery-origin anadromous sockeye salmon adults have returned to the Stanley Basin from 

juveniles released by the program. Redfish Lake sockeye salmon have also been reintroduced into Alturas 

and Pettit Lakes using progeny from the captive broodstock program. The captive broodstock program 

presently consists of several hundred fish of different year classes maintained at facilities in Eagle, Idaho, 

and Manchester, Washington. 

NMFS’ assessment of the effects of artificial propagation on ESU extinction risk concluded that the 

Redfish Lake Captive Broodstock Program does not substantially reduce the extinction risk of the ESU in 

total (NMFS 2004c). The Artificial Propagation Evaluation Workshop noted that the Redfish Lake 

Captive Broodstock Program has likely prevented extinction of the ESU. This program has increased the 

total number of anadromous adults, attempted to increase the number of lakes in which sockeye salmon 

are present in the Upper Salmon River (Stanley Basin), and preserved what genetic diversity remains in 

the ESU. Although the program has increased the number of anadromous adults in some years, it has yet 

to produce consistent returns, and the long-term effects of captive rearing are unknown. The consideration 

of artificial propagation does not substantially mitigate the BRT’s assessment of extreme risks to ESU 

abundance, productivity, spatial structure, and diversity. 

4.3.12.3 Recent Dam Counts and Returns to the Spawning Grounds 

In their preliminary report, Fisher and Hinrichsen (2004) estimated a geometric mean of aggregate 

numbers of SR sockeye salmon equal to 14 during 2001-2004 compared to 4 in 1996- 2000, a 211% 

increase. However, because returns were higher in 2001 and 2002 than in 2003, the slope of the aggregate 

population trend decreased 3.7% (from 1.26 to 1.22) when the data for 2001-2004 were added to the 

1990-2000 series. 

4.3.13 LCR Coho Salmon 

4.3.13.1 ESU Structure 

The W/LC TRT (McElhany et al. 2004) identified a total of 21 extant, demographically independent 

populations in three major population groups in this ESU: Coastal, Cascade, and Gorge (Appendix B, 

Figure B-13). There are only 2 extant populations in the LCR coho salmon ESU with appreciable natural 

productivity, the Clackamas and Sandy River populations, down from an estimated 23 historical 

populations in the ESU. 

4.3.13.2 The BRT Findings 

Short- and long-term trends in productivity are below replacement. Approximately 40% of historical 

habitat is currently inaccessible, which restricts the number of areas that might support natural 

productivity and further increases the ESU’s vulnerability to environmental variability and catastrophic 

events. The extreme loss of naturally spawning populations, the low abundance of extant populations, 

diminished diversity, and fragmentation and isolation of the remaining naturally produced fish confer 

considerable risks on the ESU. The lack of naturally produced spawners in this ESU is contrasted by the 

very large number of hatchery-produced adults. The abundance of hatchery coho salmon returning to the 

Lower Columbia River in 2001 and 2002 exceeded 1 million and 600,000 fish, respectively. The BRT 

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expressed concern that the magnitude of hatchery production continues to pose significant genetic and 

ecological threats to the extant natural populations in the ESU. However, these hatchery stocks 

collectively represent a significant portion of the ESU’s remaining genetic resources. The 21 hatchery 

stocks considered to be part of the ESU, if appropriately managed, may prove essential to the restoration 

of more widespread naturally spawning populations. The BRT found extremely high risks for all VSP 

categories. 

4.3.13.3 2004 Status Review 

There are only 2 extant populations in the LCR coho salmon ESU with appreciable natural production 

(the Clackamas and Sandy River populations), from an estimated 23 historical populations in the ESU. 

Although adult returns in 2000 and 2001 for the Clackamas and Sandy River populations exhibited 

moderate increases, the recent 5-year mean of natural-origin spawners for both populations represented 

less than 1,500 adults. The Sandy River population had exhibited recruitment failure in 5 of 10 years (i.e., 

1992-2001), and had exhibited a poor response to reductions in harvest. During the 1980s and 1990s, 

natural spawners were not observed in lower basin tributaries. Coincident with the 2000–2001 abundance 

increases in the Sandy and Clackamas populations, a small number of coho salmon spawners of unknown 

origin have been surveyed in some of these areas. Short- and long-term trends in productivity are below 

replacement. 

Approximately 40% of historical habitat is currently inaccessible, which restricts the number of areas that 

might support natural production, and further increases the ESU’s vulnerability to environmental 

variability and catastrophic events. The extreme loss of naturally spawning populations, the low 

abundance of extant populations, diminished diversity, fragmentation, and isolation of the remaining 

naturally produced fish confer considerable risks. The paucity of natural-origin spawners is contrasted by 

the very large number of hatchery-produced adults. The numbers of hatchery coho salmon returning to the 

lower Columbia River in 2001 and 2002 exceeded 1 million and 600,000 fish, respectively. 

All of the 21 hatchery programs included in the LCR coho salmon ESU are designed to produce fish for 

harvest, and 2 of the smaller programs are also designed to augment the natural spawning populations in 

the Lewis River Basin. Artificial propagation in this ESU continues to represent a threat to the genetic, 

ecological, and behavioral diversity of the ESU. Past artificial propagation efforts imported out-of-ESU 

fish for broodstock, generally did not mark hatchery fish, mixed broodstocks derived from different local 

populations, and transplanted stocks among basins throughout the ESU. The result is that the hatchery 

stocks considered to be part of the ESU represent a homogenization of populations. Several of these risks 

have recently begun to be addressed by improvements in hatchery practices. Out-of-ESU broodstock is no 

longer used, and near 100% marking of hatchery fish is employed to improve monitoring and evaluation 

of broodstock and (hatchery- and natural-origin) returns. However, many of the within-ESU hatchery 

programs do not adhere to best hatchery practices. Eggs are often transferred among basins in an effort to 

meet individual program goals, further compromising ESU spatial structure and diversity. Programs may 

use broodstock that does not reflect what was historically present in a given basin, limiting the potential 

for artificial propagation to establish locally adapted naturally spawning populations. Many programs lack 

Hatchery and Genetic Management Plans (HGMPs) that establish escapement goals appropriate for the 

natural capacity of each basin and that identify goals for the incorporation of natural-origin fish into the 

broodstock. 

During the Status Review, NMFS’ assessment of the effects of artificial propagation on ESU extinction 

risk concluded that hatchery programs collectively mitigate the immediacy of extinction risk for the LCR 

coho salmon ESU in total in the short-term, but these programs do not substantially reduce the extinction 

risk of the ESU in the foreseeable future (NMFS 2004c). At present, within-ESU hatchery programs 

significantly increase the abundance of the ESU in total. Without adequate long-term monitoring, the 

contribution of ESU hatchery programs to the productivity of the ESU in total is uncertain. The hatchery 

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programs are widely distributed throughout the Lower Columbia River, reducing the spatial distribution 

of risk from catastrophic events. 

Additionally, reintroduction programs in the Upper Cowlitz River may provide additional reduction of 

ESU spatial structure risks. As mentioned above, the majority of the ESU’s genetic diversity exists in the 

hatchery programs. Although these programs have the potential of preserving historical local adaptation 

and behavioral and ecological diversity, the manner in which these potential genetic resources are 

presently being managed poses significant risks to the diversity of the ESU in total. At present, the LCR 

coho salmon hatchery programs reduce risks to ESU abundance and spatial structure, provide uncertain 

benefits to ESU productivity, and pose risks to ESU diversity. Overall, artificial propagation mitigates the 

immediacy of ESU extinction risk in the short-term but is of uncertain contribution in the long-term. 

Over the long-term, reliance on the continued operation of these hatchery programs is risky (NMFS 

2004c). Several LCR coho salmon hatchery programs have been terminated, and there is the prospect of 

additional closures in the future. With each hatchery closure, any potential benefits to ESU abundance 

and spatial structure are reduced. Risks of operational failure, disease, and environmental catastrophes 

further complicate assessments of hatchery contributions over the long-term. Additionally, the two extant 

naturally spawning populations in the ESU were described by the BRT as being “in danger of extinction.” 

Accordingly, it is likely that the LCR coho salmon ESU may exist in hatcheries only within the 

foreseeable future. It is uncertain whether these isolated hatchery programs can persist without the 

incorporation of natural-origin fish into the broodstock. Although there are examples of salmonid 

hatchery programs having been in operation for relatively long periods of time, these programs have not 

existed in complete isolation. Long-lived hatchery programs historically required infusions of wild fish in 

order to meet broodstock goals. The long-term sustainability of such isolated hatchery programs is 

unknown. It is uncertain whether the LCR coho salmon isolated hatchery programs are capable of 

mitigating risks to ESU abundance and productivity into the foreseeable future. In isolation, these 

programs may also become more than moderately diverged from the evolutionary legacy of the ESU and 

hence no longer merit inclusion in the ESU. Under either circumstance, the ability of artificial 

propagation to buffer the immediacy of extinction risk over the long-term is uncertain. 

4.3.13.4 Recent Dam Counts and Returns to the Spawning Grounds 

In their preliminary report, Fisher and Hinrichsen (2004) estimated a geometric mean of aggregate 

numbers of LCR coho salmon equal to 3,027 during 2001-2003, compared to 822 in 1996-2000, a 268% 

increase. The slope of the aggregate population trend increased 10.4% (from 0.92 to 1.02) when the data 

for 2001-2003 were added to the 1990-2000 series, reversing the decline and indicating that, at least in the 

short run, the aggregate run is increasing. 

5.3 Factors Affecting Salmon and Steelhead Survival in the Action Area 

An array of factors influences salmon and steelhead survival in the action area. These factors include dam 

and reservoir passage conditions at the eight FCRPS mainstem dams, hydrologic conditions, water quality 

conditions, predation, disease, artificial propagation programs, and harvest. The PA under consideration 

in this Opinion directly and indirectly affects hydrologic conditions in the action area. Changes in 

hydrologic conditions can affect dam and reservoir passage survival, water quality conditions (primarily 

water temperature), and disease and predation rates (by its influence on water temperature). 

5.3.1 Baseline Physical Habitat Conditions in the Action Area 

The Columbia River is a dynamic system. It has been affected and shaped over eons by a variety of 

natural forces, including volcanic activity, storms, floods, natural events, and climate changes. These 

forces had, and continue to have, a significant influence on biological factors, habitat, inhabitants, and the 

whole riverine and estuarine environment of the Columbia River. The Snake River and lower Columbia 

River and estuary habitats have been affected over the past 60 years by the existence and operation of the 

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series of mainstem hydropower dams and reservoirs (Section 5.2.1), as well as by the operation of both 

Federal and non-Federal upstream multipurpose storage projects. The impoundments have also inundated 

extensive salmon spawning and rearing habitat. Historically, fall chinook salmon spawned in mainstem 

reaches from near The Dalles, Oregon, upstream to the Pend Oreille and Kootenai Rivers in Idaho, and to 

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Table 5-1 Federal storage and diversion facilities and associated actions to develop a “Without 

Projects Operations” scenario.1 Source: USBR 2004. 

the Snake River downstream of Shoshone Falls. Presently, mainstem production areas for fall chinook 

salmon are confined to the Hanford Reach of the Columbia River, the Hells Canyon Reach of the Snake 

River, the mid-Columbia River, and in the tailrace areas downstream from the lower Snake River projects 

and Bonneville Dam. The Hanford Reach is the only known mainstem spawning area for steelhead. 

Spawning habitat used historically by LCR Chinook salmon, CR chum salmon, and LCR steelhead was 

probably inundated by the Bonneville pool. Mainstem habitats in the lower Columbia and Willamette 

Rivers have been greatly reduced. What once were complex channels with bars, islands, and intricate flow 

patterns have often been reduced to a single thread. Floodplains have been reduced, off-channel habitat 

features have been eliminated or disconnected from the main channel, and the amounts of large woody 

debris in the channels have been greatly reduced. Finally, most of the remaining habitats are affected by 

flow fluctuations associated with reservoir water management for power peaking, flood control, 

irrigation, and other operations. 

Estuarine habitat has been lost or altered directly through diking, filling, and dredging. Estuarine habitat 

has also been removed indirectly through changes to flow regulation that affect sediment transport and 

salinity within specific habitats in the estuary. Not only have rearing habitats been removed, but the 

habitats needed to support tidal and seasonal movements of juvenile salmon are no longer accessible 

because connections have been lost. 

Major changes in the estuary resulting from anthropogenic alterations include a loss of vegetated, 

shallow-water habitat and changes in the size, seasonality, and behavior of the plume. These changes have 

significant consequences for salmonid diversity and population productivity. ESUs with fry and fingerling 

life-history strategies that use and depend upon these shallow-water habitat areas are most significantly 

affected by these changes (Fresh et al. 2004). 

The lower Columbia River estuary lost about 43% of its historical tidal marsh (from 16,180 to 9,200 

acres) and 77% of historical tidal swamp habitats (from 32,020 to 6,950 acres) between 1870 and 1970 

(Thomas 1983). One example is the diking and filling of floodplains formerly connected to the tidal river 

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that have resulted in the loss of large expanses of low-energy, offchannel habitat for salmon rearing and 

migrating during high flows. Similarly, diking of estuarine marshes and forested wetlands within the 

estuary have removed most of these important off-channel habitats. Sherwood et al. (1990) estimated that 

the Columbia River estuary lost 20,000 acres of tidal swamps; 10,000 acres of tidal marshes; and 3,000 

acres of tidal flats between 1870 and 1970. 

The total volume of the estuary inside the entrance has declined by about 12% since 1868 (Sherwood et 

al. 1990). This study further estimated an 80% reduction in emergent vegetation production and a 15% 

decline in benthic algal production. The authors analyzed early navigational charts and noted profound 

bedform changes in the river entrance from year to year. The pre-development river mouth was 

characterized by shifting shoals, sandbars, and channels forming ebb and flood tide deltas. Prior to jetty 

construction, the navigable channel over the tidal delta varied from a single, relatively deep channel in 

some years to two or more shallow channels in other years. 

Within the lower Columbia River, diking, river training devices (pile dikes and riprap), railroads, and 

highways have narrowed and confined the river to its present location. Between the Willamette River and 

the mouth of the Columbia River, diking, flow regulation, and other human activities have resulted in the 

confinement of 84,000 acres of floodplain that likely contained large amounts of aquatic habitat (i.e. tidal 

marsh, and swamp). The lower Columbia River’s remaining tidal marsh and swamp habitats are located 

in a narrow band along the banks of the Columbia River and its tributaries and around undeveloped 

islands. 

Since the late 1800s, the Corps has been responsible for maintaining navigation safety on the Columbia 

River. During that time, the Corps has taken many actions to improve and maintain the navigation 

channel. The channel has been dredged periodically to make it deeper and wider and annually for 

maintenance. To improve navigation and reduce the frequency of maintenance dredging, the navigation 

channel has also been realigned and hydraulic control structures, such as in-water fills, channel 

constrictions, and pile dikes, which act as break-waters, have been built. Most of the present day pile dike 

system was built in the periods 1917-1923 and 1933-1939, with an additional 35 pile dikes constructed 

between 1957 and 1967. 

The existing navigation channel pile dike system consists of 256 pile dikes, totaling 240,000 linear feet. 

Ogden Beeman and Associates (1997) noted that navigation channel maintenance activities from 1885 to 

1985 required closing of river side channels, realigning river banks, removing rock sills, stabilizing river 

banks, and placement of river “training” features. Most of these habitat alterations were constructed or 

occurred before the listings of any Pacific salmonids as endangered and threatened species. 

These aforementioned physical changes also affect other factors in the riverine and estuarine 

environment. Tides raise and lower river levels at least 4 feet and up to 12 feet twice every day. The 

historical range for tides was probably similar, but seasonal ranges and extremes in water surface 

elevations have certainly changed because of river flow regulation and stream bank development. The 

salinity level in areas of the estuary can vary from zero to 34 parts per thousand (ppt), depending on tidal 

intrusion, river flows, and storms. The salinity wedge is believed to have ranged from the river mouth to 

as far upstream as RM 37.5 in the past. It is now generally believed that the upper edge of the wedge 

ranges between the mouth and RM 30. The river bed within the navigation channel is composed of a 

continuously moving series of sand waves that can migrate downstream up to 20 feet per day at flows of 

400,000 cfs or greater and the lesser rates at lower flows. 

As development has changed the circulation pattern in the estuary, it has increased shoaling rates such 

that the estuary is now a more effective sediment trap (Independent Science Group 1996). Although the 

Columbia River is characterized as a highly energetic system, it has been changing as a result of 

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development and is now similar to more developed and less energetic estuaries throughout the world 

(Sherwood et al. 1990). 

In addition, model studies indicate that the hydrosystem and climate change together have decreased 

suspended particulate matter to the lower river and estuary by about 40% (as measured at Vancouver, 

Washington) and have reduced fine sediment transport by 50% or more (Bottom et al. 2001). Overbank 

flow events, important to habitat diversity, have become rare, in part because water storage and irrigation 

withdrawals prevent high flows, and in part because diking and revetments have increased the “bank full” 

flow level (from about 18,000 to 24,000 m3/s). The dynamics of estuarine habitat have changed in other 

ways relative to flow and stream bank development. The availability of shallow (between 10 cm and 2 m 

depth), low-velocity (less than 30 cm/s) habitat now appears to decrease at a steeper rate with increasing 

flow than during the 1880s, and the absorption capacity of the estuary appears to have declined. 

The significance of these changes for salmonids is unclear. Estuarine habitat is likely to have provided 

services (food and refuge from predators) to subyearling migrants that resided in estuaries for up to two 

months or more (Casillas 1999). Historical data from Rich (1920) indicate that small juvenile salmon (< 

50 mm), which entered the Columbia River estuary during May, grew 50 mm to 100 mm during June, 

July, and August. Data from a more contemporary period (Dawley et al. 1986; CREDDP 1980) show 

neither small juveniles entering the estuary in May nor growth over the summer season. 

The Columbia River plume also appears to be an important habitat for juvenile salmonids, particularly 

during the first month or two of ocean residence. The plume may simply represent an extension of the 

estuarine habitat. More likely, it represents a unique habitat created by interaction of the Columbia River 

freshwater flow with the California current and local oceanographic conditions. Ongoing studies show 

that nutrient concentrations in the plume are similar to nutrient concentrations associated with upwelled 

waters. Upwelling is a well recognized oceanographic process that produces highly productive areas for 

fish. Primary productivity, and more important, the abundance of zooplankton prey, is higher in the plume 

compared with adjacent non-plume waters. Further, salmon appear to prefer low surface salinity, as the 

abundance and distribution of juvenile salmon are higher and more concentrated in the Columbia River 

plume than in adjacent, more saline waters. These findings support the notion that the plume is an 

important habitat for juvenile salmonids. What is not known precisely is how Columbia River flows 

affect the structure of the plume relative to salmonid biological requirements during outmigration periods, 

and whether critical threshold flows are needed. 

5.3.2 Hydrologic Conditions 

Hydrologic conditions influence salmonid survival through the migratory corridor by changing the rate of 

migration; affecting water quality, particularly water temperature, turbidity, and TDG concentrations; and 

by influencing FCRPS project operations. 

Flow regulation, water withdrawal, and climate change have reduced the Columbia River’s average flow 

and altered its seasonality, sediment discharge and turbidity, thereby changing the estuarine ecosystem 

(National Research Council 1996; Sherwood et al. 1990; Simenstad et al. 1982, 1990; Weitkamp 1994). 

Annual spring freshet flows through the Columbia River estuary are about one-half of the traditional 

levels that flushed the estuary and carried smolts to sea, and total sediment discharge is about one-third of 

nineteenth-century levels. For instance, reservoir storage and flow regulation that began in the 1970s has 

reduced the 2-year flood peak discharge, as measured at The Dalles, Oregon, from 580,000 cfs to 360,000 

cfs (Corps 1999). 

Decreased spring flows and sediment discharges have also reduced the extent, speed of movement, 

thickness, and turbidity of the plume that extended far out and south into the Pacific Ocean during the 

spring and summer (Cudaback and Jay 1996; Hickey et al. 1997). Changes in estuarine bathymetry and 

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flow have altered the extent and pattern of salinity intrusion up the Columbia River and have increased 

stratification and reduced mixing (Sherwood et al. 1990). The direct effects of flow on juvenile survival 

are the relationships between flow and travel time and flow and the distribution of fish among the various 

dam passage routes. In general, the lower the flow through the series of FCRPS reservoirs, the longer the 

travel time of outmigrating juveniles. The longer juveniles remain in project reservoirs, the greater their 

exposure to predation, disease, and other mortality factors. Also, the longer juveniles remain in the project 

reservoirs, the greater the potential that they will residualize (remain in fresh water for months to another 

year). Changing flows can also affect dam operations as operating protocols are often defined in terms of 

streamflow criteria. For example, at spring flows of less than 85,000 cfs at Lower Granite Dam, the spill 

rate and duration are reduced. Spillways are widely considered the safest route of juvenile dam passage 

(Ferguson et al. 2004). Changing flows indirectly affect juvenile survival by changing water temperatures. 

Lower flows result in higher summer water temperatures (all other conditions being equal). High summer 

water temperatures increase disease, predation rates, and thermal stress on juvenile salmonids. 

Very high flow conditions can cause high rates of involuntary spill at FCRPS projects in the migratory 

corridor. High spill rates can generate supersaturated TDG concentrations in downstream waters. This 

effect is discussed in Section 5.3.3, Water Quality Conditions. Streamflows are directly affected by the 

PA and these effects and their associated effects on salmon survival are the focus of the analysis of effects 

generated in developing this Opinion (Section 6). 

Agricultural water use in the Snake and Columbia Basins began around 1850 and accelerated rapidly in 

the early twentieth century (Volkman 1997). Today, about 85% of water consumption in the basins is 

associated with irrigated agriculture. For example, at Brownlee Reservoir, all upstream water use reduces 

flows by about 6 million acre-feet (Maf) annually, about one-third of native flows (USBR 1999). At 

Lower Granite Dam, upstream water developments consume about 6.4 Maf, about 7% of native flows. At 

McNary Dam, upstream water uses consume about 12 Maf annually, about 12% of native flows. At 

Bonneville Dam, about 13.3 Maf is consumed at upstream water developments. This water consumption 

reduces streamflows primarily during the growing season (April through October), has affected the status 

of the species in the action area, and is included in the environmental baseline (reference operation). 

Future water consumption is discussed in Section 7.2, Cumulative Effects. 

The principal change in environmental conditions between those currently existing and those under the 

reference operation (current conditions absent the effects of the USBR’s upper Snake project operations) 

is the change in Snake and Columbia River flows. Because all project facilities are located upstream from 

Brownlee Reservoir, Idaho, this change is best illustrated by estimated inflows to Brownlee Reservoir 

(Figure 5-2). This depiction of Snake River flow conditions is intended to illustrate how the baseline 

hydrology used in this Opinion differs from the existing conditions. 

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Figure 5-2. Mean monthly Snake River inflow (cfs) at Brownlee Dam under current conditions and under 

the reference operation. Sources: current conditions, BPA HYDSIM model run 

5.3.3 Water Quality Conditions 

Water and sediment quality is another important aspect of the environmental condition of the lower 

Columbia River ecosystem with the potential to affect salmonids’ growth and survival. Water quality in 

streams throughout the Columbia River Basin has been degraded by human activities such as dams and 

diversion structures, water withdrawals, farming and grazing, road construction, timber harvest activities, 

mining activities, and urbanization. Over 2,500 streams and river segments and lakes do not meet 

Federally approved, State, and tribal water quality standards and are now listed as water quality-limited 

under Section 303(d) of the Clean Water Act (CWA). Tributary water quality problems contribute to poor 

water quality where sediment and contaminants from the tributaries settle in mainstem reaches and the 

estuary. 

The importance of three water quality characteristics—water temperature, TDG concentrations, and water 

and sediment pollutants—are discussed below. 

5.3.3.1 Water Temperature 

Salmonids evolved to take advantage of the natural cold, freshwater environments of the Pacific 

Northwest. Temperature directly governs their metabolic rate and directly influences their life history. 

Natural or anthropogenic fluctuations in water temperature can induce a wide array of behavioral and 

physiological responses in these fish. Feeding, growth, resistance to disease, successful reproduction, 

sufficient activity for competition and predator avoidance, and successful migrations are all affected by 

water temperatures (Yearsley 1999). These behavioral and physiological effects may lead to impaired 

functioning of the individual and decreases viability at the organism, population, and species level. 

Williams (2004) noted that multivariate models indicated that the condition that had the strongest effect 

on survival of yearling chinook salmon through the Snake River was water temperature. For yearling 

chinook salmon, temperatures above 13°C appeared detrimental to survival. The date on which 

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temperatures at Lower Monumental Dam reached 13°C varied from year to year, ranging from May 7 in 

1998 to June 11 in 1997. The average date on which this apparent threshold temperature was reached was 

May 25 (Williams et al 2004). Zaugg and Wagner (1973) found that gill Na + -K + ATPase (an indicator 

of migratory readiness) and migratory urge declined at water temperatures of 13°C and higher. Steelhead 

that migrate too late in the season, when water temperatures are above this threshold, may have a 

tendency to residualize. For subyearling chinook salmon, Williams et al (2004) noted that average 

survival was nearly constant for water temperature below 19.3°C, and nearly constant, but considerably 

lower for water temperature above 20.6°C. 

For Snake River fall chinook salmon juveniles, Connor et al (2003) determined that flow and temperature 

explained 92% of the observed variability in cohort survival from points of release in Hells Canyon to the 

tailrace of Lower Granite Dam and built a multiple regression model of cohort survival based on these 

parameters. Cohort survival generally increased as flow increased, and decreased as temperature 

increased (Connor 2003). Based on the regression model developed, survival is predicted to change by 

approximately 3% with each change of 100 m3/s in flow when temperature is held constant. The change 

in survival is approximately 7% for each 1°C change in temperature when flow is held constant (Connor 

2003). 

The Snake River from its confluence with the Salmon River at RM 188 to its confluence with the 

Columbia River has been included on the 303(d) list (a list of impaired waters compiled under Section 

303(d) of the CWA) for water temperature by Idaho, Oregon, and Washington. Additionally, Oregon and 

Washington include most of the mainstem Columbia River on their lists as impaired for temperature. 

Most of the water bodies in Oregon, Washington, and Idaho that are on the 303(d) list are included 

because they do not meet water quality standards for temperature. Water temperature alterations affect 

salmonid metabolism, growth rate, and disease resistance, as well as the timing of adult migrations, fry 

emergence, and smoltification (EPA 2002). Many factors can cause high stream temperatures, but they 

are primarily related to land- and water-use practices rather than point-source discharges (Coutant 1999). 

Water temperatures in excess of the States of Washington and Oregon’s 20°C (68°F) water quality 

standards (e.g., OAR, Ch. 30, Division 041) stress anadromous salmonids and can directly or indirectly 

cause mortality (e.g., increase fish susceptibility to disease, increase predation rates of piscivorous fish). 

Some common actions that have resulted in high stream temperatures are the removal of trees or shrubs 

that directly shade streams, excessive water withdrawals for irrigation or other purposes, and warm 

irrigation return flows. Loss of wetlands and increases in groundwater withdrawals have contributed to 

lower base-stream flows, which in turn contribute to temperature increases. Water temperature is also 

directly affected by streamflow conditions through the effects of changes in the mass affected by heat 

flux. For this Opinion, NMFS has employed both Environmental Protection Agency (EPA) and Corps 

water temperature modeling. Under the reference operation, EPA (2005) estimated water temperature 

conditions in the Snake and Columbia Rivers throughout the peak juvenile migration season (April 

through September) for low, average, and high water years (Table 5-2). 

Table 5-2. Estimated water temperatures (in °C) at selected FCRPS dams for low, average, and high flow 

years under the reference operation. Source: EPA 2005. 

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In some instances, these modeling results appear to be counterintuitive. For example, at Lower Granite 

Dam under the high water conditions of 1997, a lower July water temperature than the average or dry 

years would be expected, all other conditions being equal. However, the Snake River upstream from 

Lower Granite Dam is a warmer river than the Clearwater River, the other major Snake River tributary 

entering Lower Granite Reservoir. Therefore, higher flows in the Snake River can result in warmer water 

temperatures at Lower Granite Dam. The Corps attempts to control water temperatures at Lower Granite 

Dam by releasing cold water (7°C) from Dworshak Dam on the Clearwater River at rates up to 14 kcfs. 

When flows are warm and high coming out of the Snake River Basin, this measure would have a lesser 

effect on water temperatures at Lower Granite Dam. 

5.3.3.2. Total Dissolved Gas 

High rates of spill at mainstem FCRPS dams can cause high TDG concentrations. High TDG 

concentrations can cause gas bubble trauma (GBT) in adult and juvenile salmonids resulting in injury or 

death. Biological monitoring shows that the incidence of GBT in both migrating smolts and adults 

remains below 1% when TDG concentrations in the upper water column do not exceed the Oregon and 

Washington water quality standard (110%) and gas waiver levels of 120% in FCRPS project tailraces and 

115% in forebays. When those levels are exceeded, there is a corresponding increase in the incidence of 

signs of GBT. Exceedence of this standard is generally associated with high rates of involuntary spill 

associated with the peak of the annual runoff hydrograph. Current reservoir operations typically limit gasgenerating, high-spill events to a few days or weeks during high-flow years. Historically, TDG 

supersaturation was considered a major contributor to juvenile salmon mortality, and TDG control has 

been a focus of efforts to improve salmon survival. The Corps has invested heavily in controlling TDG at 

its projects in the migratory corridor through the installation of spillway improvements and by managing 

spill operations to reduce gas entrainment, and thorough TDG monitoring and abatement evaluation. 

As part of the TDG abatement program, the Corps has developed spill limits at its projects designed to 

prevent the creation of adverse TDG conditions downstream. For example, the spill cap at Lower Granite 

Dam in the 2004 Water Management Plan (Corps 2004) is 43,000 cfs. Using the 50-year simulated 

hydrology for the environmental baseline (reference operation), the spill cap at Lower Granite Dam 

would be exceeded on a monthly average basis as follows: March, 1 out of 50; April, 2 out of 50; May, 12 

out of 50; and June, 14 out of 50. 

5.3.3.3 Pollutants 

Background or ambient levels of pollutants in inflows carry cumulative loads from upstream areas in 

variable and generally unknown amounts. Municipal and industrial waste discharges have occurred in the 

greater Lewiston, Idaho-Clarkston, Washington area and have been received from larger population 

centers in the Upper Snake River Basin. Major tributaries and drainages have delivered higher 

background concentrations of metals, which are generally associated with mining areas that are common 

in portions of the Clearwater and Salmon Rivers and in tributaries throughout the Upper Snake River. 

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Current environmental conditions in the Columbia River estuary indicate the presence of contaminants in 

the food chain of juvenile salmonids including DDT, PCBs, and polyaromatic hydrocarbons (PAH) 

(NWFSC Environmental Conservation Division 2001). These data indicate that juvenile salmonids within 

the Columbia River estuary have contaminant body burdens that may already be within the range where 

sublethal effects may occur, although the sources of exposure could be widespread and are not clear. In 

field studies, juvenile salmon from sites in the Pacific Northwest have demonstrated immunosuppression, 

reduced disease resistance, and reduced growth rates due to contaminant exposure during their period of 

estuarine residence (Arkoosh et al. 1991, 1994, 1998; Varanasi et al. 1993; Casillas et al. 1995a, 1995b, 

1998a). 

5.3.4 Predation 

Salmon and steelhead are exposed to high rates of natural predation, particularly during freshwater 

rearing and migration stages. Ocean predation may also contribute to significant natural mortality, 

although the levels of predation are largely unknown. In general, salmonids are prey for pelagic fishes, 

birds, and marine mammals, including harbor seals, sea lions, and killer whales. There have been recent 

concerns that the rebound of seal and sea lion populations, following their protection under the Marine 

Mammal Protection Act of 1972, has resulted in substantial mortality for salmonids. In recent years, for 

example, sea lions have learned to target UWR spring chinook salmon in the fish ladder at Willamette 

Falls and other spring Chinook salmon ESUs in the tailrace area downstream from Bonneville Dam. 

Dams and reservoirs are generally believed to have increased the incidence of predation over historical 

levels (Poe et al. 1994). Effects such as the increase in habitat suitable for predatory fish, warmer nearsurface water temperatures that increase their foraging rates, and the delay and aggregation of migrating 

salmonids in project forebays and tailraces all increase the susceptibility of anadromous fish to predation 

(NMFS 2004a, Section 5.3.1). 

5.3.5 Disease 

Columbia Basin salmonids co-exist with a range of viruses, bacteria, fungi, and parasites. Some of these 

organisms have significant effects on salmon populations through mortality or reduced fitness 

(morbidity). These organisms are collectively known as pathogens. For salmonid and pathogen 

populations to persist, interactions between host and pathogen, like interactions between predator and 

prey, must maintain a dynamic balance where neither party is wholly eliminated. Three major factors in 

this balance have been identified as host, environment, and pathogen. A change in one or more of these 

three factors will result in a change in the equilibrium, often resulting in large outbreaks of disease 

(epizootics) which may decimate salmonid populations (Hedrick 1998; Gerstman 2003; Arkoosh et al. 

2004). 

With the development of the Columbia Basin, a number of factors emerged which have the potential to 

cause shifts in the host-pathogen equilibria, increasing risks of epizootics. Dams and other impoundments 

increased summer water temperatures, creating conditions where some pathogens increased their 

infectivity (rate of spread) and virulence (severity of effects on the host organism), while at the same time 

stressing salmonids and reducing their resistance to disease (Becker and Fujihara 1978; WDOE 2002; 

Mesa et al. 2000). The introduction of exotic species and the between-basin transfer of native fishes 

creates opportunities for the introduction of new pathogens, or for endemic pathogens to increase their 

range. Large-scale intensive hatchery culture provides conditions where pathogens could spread rapidly 

within the hatchery, and increases the risk of transfer of disease out of the hatchery through hatchery 

effluents and the release of infected fish. Changing environmental conditions altered relationships 

between parasites and their hosts, potentially increasing the severity of parasitic infection. Handling and 

transport of fish at dams has led to fish being held at much higher densities than observed in the wild, 

increasing chances of disease transmission. Thus, with changes in host, pathogen, and environment, a 

shift in host-pathogen relationships from pre-development conditions has occurred. 

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The effects of disease on wild salmonid populations are notoriously hard to enumerate, and the 

significance of a particular pathogen may also widely vary among different salmonid populations 

(Hedrick 1998). Diseases which have been observed to cause significant losses to migrating fish (both 

hatchery and wild) in the Columbia River system are Columnaris (Flexibacter columnaris) (Becker and 

Fujihara 1978), bacterial kidney disease (Renibacterium salmoninarum) (Arkoosh et al. 2004; Elliot et al. 

1997), and ceratomyxosis (Ceratomyxa shasta) (Ratliff 1981; Bartholomew 1998). With the interruptions 

of natural disease control mechanisms through shifts in environmental conditions, introductions of new 

pathogens (or changes in distribution of endemic ones), or introduction of new potential sources of 

pathogens, such as hatcheries, this equilibrium has been substantially altered and the potential for large 

epizootics and high losses to salmonid populations has increased. 

Effects of Temperature on Disease. In addition to the stress and direct physiological damage suffered by 

salmonids when exposed to elevated water temperatures, risks of mortality due to disease also increase. 

There appear to be two primary reasons for this increase. Temperature related stress reduces the capacity 

of the fish to resist infection and eliminate pathogens. 

Pathogens also respond to changes in temperature. There is a particular range of optimum temperatures 

for each pathogen and in this range the reproduction, infectivity, and virulence of a pathogen are 

maximized. The combination of reduced resistance of fish and increased virulence and infectivity of a 

particular pathogen can result in epizootics and high rates of mortality due to disease. In a summary of 

issues related to temperature criteria for salmon, the EPA (2001) summarized the effects of water 

temperature on disease risk as follows: 

Risk Temperature range (°C) 

Minimized <12-13°

Elevated 14-17° 

Severe 18-20°

There are a number of pathogens known in the Columbia Basin which show a direct increase in 

infectivity and virulence with increased water temperature. Some diseases, such as Columnaris 

(Flexibacter columnaris), are rare within the natural range of water temperatures in the Columbia Basin 

(i.e., temperatures that would be observed absent man-caused effects) (Becker and Fujihara 1978). A brief 

summary of Columbia Basin pathogens with the potential for causing increased mortality among 

salmonids under elevated water temperature conditions is described in Table 5-3. 

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Table 5-3. Fish diseases known from the Columbia Basin showing increases in infectivity and virulence 

with increasing water temperature (WDOE 2002; EPA 1999; EPA 2001) 

Organism Disease Temperature effects Susceptible species 

Severity of effects Bacteria 

Juvenile salmon and steelhead mortalities from an array of disease have been observed at many fish 

collection and handling systems in the migratory corridor. Columnaris and BKD are two common 

diseases observed at mainstem FCRPS juvenile fish collection facilities. In many cases, the proximate 

causes of fish mortality in the action area are largely unknown. While it is known that juvenile passage 

survival is lower under low-flow, high-temperature conditions, it is seldom known whether the direct 

cause of death is thermal stress, increased predation, or increased susceptibility to disease, or a 

combination of these factors. 

5.3.6 Artificial Propagation 

Artificial propagation programs mandated by Congress under the Lower Snake River Compensation 

Program are included in the environmental baseline for this consultation. Many artificial propagation 

facilities under this program were originally authorized to help mitigate for the construction of the four 

Federal lower Snake River hydroelectric dams. Other Federally funded artificial propagation programs in 

the Snake Basin are not included in the environmental baseline for this consultation, as they are currently 

undergoing consultation. 

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Although located outside of the action area, all Federal and non-Federal artificial propagation programs in 

the Columbia Basin above Priest Rapids Dam are also part of the environmental baseline for this 

consultation. They are included because hatchery progeny pass through the lower Columbia River 

migration corridor and interact with ESA-listed fish that are the focus of this consultation. The current 

Section 7 biological opinion for hatchery operations associated with unlisted salmon species (for 

Federally funded programs) and Permit 1347 (for Stateoperated programs) both expire October 22, 2013. 

ESA permits (1396, USFWS and 1412, Confederated Tribes of the Colville Reservation) associated with 

listed steelhead are in place through October 2, 2008, and permit 1395 (issued to WDFW) is in place 

through October 2, 2013. ESA permit 1300 issued to the USFWS to propagate listed spring chinook 

salmon is in place through December 31, 2007, and permit 1196 issued to WDFW expires January 20, 

2014. Artificial propagation programs in the Columbia Basin below the confluence with the Snake River 

are not included in the environmental baseline for this consultation. New ESA authorization is in process 

for these programs. 

Because hatcheries have traditionally focused on providing fish for harvest, it is only recently that the 

substantial adverse effects of hatcheries on natural populations have been demonstrated. For example, 

hatchery practices, among other factors, have contributed to the 90% reduction in natural coho salmon 

runs in the lower Columbia River over the past 30 years (Flagg et al. 1995). NMFS has identified four 

primary ways hatcheries harm natural-origin salmon and steelhead: 1) ecological effects, 2) genetic 

effects, 3) overharvest effects, and 4) masking effects. 

Ecologically, hatchery-origin fish can prey on, displace, and compete with natural fish. These effects are 

most likely to occur when hatchery-reared juveniles are released in poor condition and remain in the fresh 

water for extended rearing periods rather than migrating to marine waters. Hatchery-origin fish also can 

transmit hatchery-borne diseases, and hatcheries themselves can release disease-carrying effluent into 

streams. Hatchery-origin fish can affect the genetic variability of native fish by interbreeding with them. 

Outbreeding depression can result from the introduction of stocks from other areas. Genetic interactions 

like these can result in fish being less adapted to the local habitats where the original native stock 

evolved, and may therefore be less productive there. 

In many areas, hatchery-origin fish provide increased fishing opportunities. However, when natural fish 

mix with hatchery-origin fish in these areas, naturally produced fish can be overharvested. Moreover, 

when migrating adult hatchery and natural fish mix on the spawning grounds, the health of the natural 

runs and the habitat’s ability to support them can be overestimated because hatchery fish can mask the 

actual natural run status from surveyors’ observations. 

The role hatcheries play in the Columbia Basin is being redefined by NMFS’ proposed hatcherylisting 

policy, developing environmental impact statements, and recovery planning efforts. These efforts will 

focus on maintaining and improving ESU viability. Research designed to clarify interactions between 

natural and hatchery fish and quantify the effects of artificial propagation on natural fish will play a 

pivotal role in informing these efforts. The final facet of these initiatives is to use hatcheries to create 

fishing opportunities that are benign to listed populations (e.g., terminal area fisheries). 

5.3.7 Harvest 

Treaty Indian Harvest. Treaty Indian fishing rights are included in the environmental baseline for this 

consultation. The four Columbia River “Stevens” Treaty Tribes (the Nez Perce, Umatilla, and Warm 

Springs Tribes, and the Yakama Indian Nation) entered into treaties with the United States in 1855. In 

exchange for the Indians relinquishing their interest in certain lands, the treaties reserved to the Tribes 

"exclusive" on-reservation rights and the right to take "fish at all usual and accustomed places in common 

with citizens of the United States" outside the reservations on the Columbia River and major tributaries. 

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Indian treaty rights, such as hunting and fishing rights, are reserved rights that generally date from time 

immemorial. See Felix S. Cohen, Handbook of Federal Indian Law, 441-448 (1982); United States v. 

Winans, 198 U.S. 371, 381 (1905), 25 S.Ct. 662, 49 L.Ed. 1089 (“In other words, the treaty was not a 

grant of rights to the Indians, but a grant of right from them -- a reservation of those not granted. There 

was an exclusive right of fishing reserved within certain boundaries. There was a right outside of those 

boundaries reserved ‘in common with the citizens of the territories”). Starting in 1977, Tribal and State 

fisheries subject to U.S. v. Oregon have been regulated pursuant to a series of Court orders reflecting 

Court-approved settlement agreements among the parties. The last long-term agreement, known as the 

Columbia River Fishery Management Plan (CRFMP), was adopted and approved by the Court in 1988 

and expired in 1999. At the Court’s direction and under its supervision, the parties are currently in the 

process of negotiating a new long-term agreement. 

During the past 10 years, harvest has been managed pursuant to the CRFMP and successor agreements 

that contain restraints on the fisheries necessitated by the ESA listings of some of the ESUs. As a result, 

NMFS has conducted ESA Section 7 consultations and issued no-jeopardy opinions covering these 

agreements and their impact on ESA-listed species. 

Agreed-to and estimated harvest rates for various stocks under the current U.S. v. Oregon agreements are 

set forth in Tables 5-4 and 5-5. For the purpose of projecting the environmental baseline into the future, 

these current harvest rates are assumed to continue through the term of this Opinion. In terms of the 

analysis in the Opinion, it does not matter whether the Tribes harvest all of the harvest available to them 

or, as has been the practice, allocate a portion of that harvest to the States. Accordingly, to estimate the 

extent of this baseline harvest, NMFS will presume that treaty and non-treaty harvest rates comparable to 

the current harvest rates will continue into the future pursuant to Court-approved settlement agreements. 

In addition, the Colville Confederated Tribal fisheries have been consulted on and remain in effect 

through October 2012. 

Non-Indian Harvest. Non-Indian fisheries include both commercial and sport fishing harvest and 

mortality. Commercial harvest of listed ESUs occurs as an unintentional bycatch during fisheries aimed at 

hatchery fish. Intentional sport fishing harvest of listed fish is limited to populations considered healthy. 

Most hatchery progeny in the basin are marked by the removal of their adipose fins and anglers are 

required to release unmarked fish in most fisheries to protect listed stocks. However, a small fraction of 

the unmarked fish caught and released by sport fishermen suffer injury or stress and subsequently die. 

Estimates of total non-Indian harvests are shown in Tables 5-4 and 5-4 and are considered part of the 

environmental baseline for this consultation. 

Table 5-4. Expected harvest rates for listed salmonids in winter, spring, and summer season fisheries in 

the mainstem Columbia River and in tributary recreational fisheries under the 2001 - 2005 Spring 

Agreement in U.S. v. Oregon NA—similar estimates not available for other areas. (Table modified from 

NMFS 2004b) 

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5.3.8 Population Response to Environmental Variation 

The abundance of salmonid populations is substantially affected by changes in the freshwater and marine 

environments that are in turn the result of large-scale environmental variations. For example, large-scale 

climatic regimes, such as El Niño, affect changes in ocean productivity. Much of the Pacific Coast was 

subject to a series of very dry years during the first part of the 1990s and since 2000. In the latter 1990s, 

severe flooding adversely affected some stocks. For example, the low return of Lewis River bright fall 

chinook salmon in 1999 is attributed to flood events during 1995 and 1996. 

Among the known variations in ocean conditions are the phenomena termed El Niño and the Pacific 

Decadal Oscillation (PDO). 

Table 5-5. Expected harvest rates for listed salmonids in fall season fisheries in the mainstem Columbia 

River under the 2004 Fall Agreement in U.S. v. Oregon. (Table modified from NMFS 2004b). 

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El Niño is a disruption of the ocean-atmosphere system in the tropical Pacific having important 

consequences for global weather patterns and near-shore Pacific Ocean productivity 

(http://www.pmel.noaa.gov/tao/elnino/gif/summer_winter1-nns.gif). Among these consequences are 

warmer near-surface ocean water temperatures along the U.S. west coast, and generally warmer, drier 

weather in the Pacific Northwest. This warmer surface layer reduces thermodynamic upwelling off the 

U.S. coast, reducing nutrient inputs to the euphotic zone, which reduces near-shore ocean productivity. 

This reduction in productivity has been shown to reduce juvenile salmon growth and survival (Mantua 

and Francis in press). Warmer surface waters can also change the spatial distribution of marine fishes 

with potential predator-prey effects on salmon. The warmer, drier weather in the Pacific Northwest often 

associated with El Niño can also cause or increase the severity of regional droughts. Droughts reduce 

streamflows through the Columbia and Snake River migratory corridor, increase water temperatures, and 

reduce the extent of suitable habitat in some drainages. Each of these physical effects has been shown to 

adversely affect salmon survival. Thus, El Niño events can present a substantial drag on anadromous fish 

populations. 

The PDO is a long-lived El Niño-like pattern of Pacific climate variability. While the two climate 

oscillations have similar spatial climate fingerprints, they have very different behavior in time. Fisheries 

scientist Steven Hare coined the term "Pacific Decadal Oscillation" (PDO) in 1996 while researching 

connections between Alaska salmon production cycles and Pacific climate. Two main characteristics 

distinguish the PDO from El Niño. First, 20th century PDO "events" persisted for 20 to 30 years, while 

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typical El Niño events persisted for 6 to 18 months. Second, the climatic fingerprints of the PDO are most 

visible in the North Pacific/North American sector, while secondary signatures exist in the tropics. The 

opposite is true for El Niño. Several independent studies find evidence for just two full PDO cycles in the 

past century. "Cool" PDO regimes prevailed from 1890-1924 and again from 1947-1976, while "warm" 

PDO regimes dominated from 1925-1946 and from 1977 through (at least) the mid- 1990s. Shoshiro 

Minobe has shown that twentieth century PDO fluctuations were most energetic in two general 

periodicities, one from 15 to 25 years, and the other from 50 to 70 years. (Quoted from: 

http://tao.atmos.washington.edu/pdo/.) Major changes in northeast Pacific marine ecosystems have been 

correlated with phase changes in the PDO. Warm eras have seen enhanced coastal ocean biological 

productivity in Alaska and inhibited productivity off the west coast of the contiguous United States, while 

cold PDO eras have seen the opposite north-south pattern of marine ecosystem productivity. Causes for 

the PDO are not currently known. Likewise, the potential predictability for this climate oscillation is not 

known. Some climate simulation models produce PDO-like oscillations, although often for different 

reasons. Discovery of the mechanisms giving rise to PDO will determine whether skillful, decades-long 

PDO climate predictions are possible. For example, if PDO arises from air-sea interactions that require 

10-year ocean adjustment times, then aspects of the phenomenon will (in theory) be predictable at lead 

times of up to 10 years. Even in the absence of a long-term predictive understanding, PDO climate 

information improves season-to-season and year-to-year climate forecasts for North America because of 

its strong tendency for multi-season and multi-year persistence. From a societal impacts perspective, 

recognition of PDO is important, because it shows that "normal" climate conditions can vary over time 

periods comparable to the length of a human's lifetime. 

Recent evidence suggests that marine survival of salmonids fluctuates in response to the PDO’s 20- to 30-

year cycles of climatic conditions and ocean productivity (Cramer et al. 1999). Ocean conditions that 

affect the productivity of Northwest salmonid populations appear to have been in a low phase of the cycle 

for some time and an important contributor to the decline of many stocks. The survival and recovery of 

these species will depend on their ability to persist through periods of low natural ocean survival, but the 

mechanism whereby stocks are affected is not well understood. The pattern of response to these changing 

ocean conditions has differed among stocks, presumably due to differences in their ocean timing and 

distribution. NMFS presumes that juvenile fish survival is driven largely by events occurring between 

ocean entry and recruitment to a subadult life stage. One indicator of early ocean survival can be 

computed as a ratio of coded-wire-tag (CWT) recoveries of subadults relative to the number of CWTs 

released from that brood year. Time series of survival rate information for UWR spring chinook salmon, 

Lewis River fall chinook salmon, and Skagit fall chinook salmon show highly variable or declining trends 

in early ocean survival, with very low survival rates in recent years (NMFS 1999b). 

5.3.9 Dam and Reservoir Passage 

As stated above, the eight Federal dams on the mainstem Columbia and lower Snake Rivers that dominate 

the characteristics of fish habitat in the migratory corridor in the action area from the upstream limit of 

Lower Granite Reservoir on the Snake River to Bonneville Dam on the Columbia River, are part of the 

environmental baseline. A substantial amount of juvenile mortality occurs in this reach and delay in 

passing the dams can affect adult survival and may affect fecundity. 

The effects of changes in flow due to the operation and maintenance of the USBR’s Upper Snake Basin 

projects on dam and reservoir passage survival through the mainstem Columbia and lower Snake River 

FCRPS projects are a focus of the analysis conducted for this Opinion. The 2004 FCRPS UPA included 

an array of measures to improve dam passage survival. Those improvements that have already occurred or 

are expected to occur within the next year (by spring 2006) are included in the near-term environmental 

baseline analysis. The effects of those system configuration improvements are expected to continue until 

the long-term FCRPS configuration improvements are implemented fully by 2014. FCRPS fish passage 

facility improvements and operations beyond 2014 are undefined but, for the purposes of this 

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consultation, are assumed to result in survival rates that are the same or higher than those estimated in the 

long-term (2014) analysis in the 2004 FCRPS Biological Opinion (NMFS 2004a). Thus, for the purposes 

of this consultation, the long-term effects of all of those FCRPS configuration improvements are assumed 

to remain about the same as those estimated in the long-term (2014) analysis and are expected to continue 

throughout the term of this biological opinion as part of the long-term environmental baseline. 

5.3.9.1 Passage Effects on Juvenile Salmon and Steelhead Survival 

Juvenile salmon dam and reservoir passage survival has been the subject of extensive research and 

evaluation and has dominated efforts taken to improve survival of the species through numerous ESA 

Section 7 consultations. 

NMFS placed the first Pacific Northwest salmon ESU on the Endangered Species list in 1991. Since then, 

NMFS and the FCRPS Action Agencies have engaged in numerous consultations. The focus of those 

consultations has been on the survival of listed juvenile salmon and steelhead as they migrate through the 

FCRPS and measures to improve it. Biological opinions outlining a number of proposed operations and 

structural configuration changes to FCRPS dams designed to improve juvenile survival were issued in 

1993, 1994, 1995, 1998, 2000, and 2004. Measures taken to improve juvenile salmon survival through the 

FCRPS migratory corridor include: water management to increase spring and summer migration season 

flows, juvenile collection systems and transportation programs, voluntary spills at FCRPS dams, 

improved spillway juvenile passage efficiency (e.g., removable spillway weirs [RSW]), predatory fish 

control, and other measures. As a result of these operations and configuration improvements, juvenile 

survival through the FCRPS migration corridor has improved significantly since the early 1990s. For 

Snake River spring/summer chinook salmon juveniles migrating in-river, Williams et al. (2004) estimated 

survival through the eight mainstem Federal dams is now between 28% and 58%, compared with an 

estimated survival rate during the 1970s of 3% to 30% (Williams et al. 2001). For Snake River steelhead 

juveniles migrating in-river, Williams et al. (2004) estimated survival through the eight mainstem Federal 

dams to currently range between 4% and 50%, compared with an estimated survival rate during the 1970s 

of 1% to 27% (Williams et al. 2001). The transportation of smolts from the Snake River and McNary 

Dam on the Columbia River has also improved FCRPS system passage survival rates. 

Although changes in FCRPS operations and configuration, including juvenile transportation around 

portions of the Federal hydrosystem, have improved juvenile passage survival, periods of warm weather 

and low runoff continue to cause high rates of mortality among out-migrants in Lower Granite Reservoir. 

Lower Granite is the uppermost FCRPS reservoir in the migratory corridor and juvenile fish must pass 

through this reach without the aid of transportation (i.e., the juvenile collection facilities are located 

downstream at Lower Granite Dam). 

5.3.9.1.1 Methods Used to Estimate Juvenile Passage Survival Rates. [omitted] 

5.3.9.2 Passage Effects on Adult Salmon and Steelhead 

Adult salmon and steelhead must pass up to eight FCRPS dams and reservoirs in the action area to reach 

their natal spawning streams and river reaches. Each FCRPS project within the action area imposes 

stresses on migrating adults. Those project-induced effects most likely to adversely affect adult survival 

are delay and delay-induced predation, water quality changes (e.g., TDG concentrations and water 

temperatures), and fallback and volitional downstream passage (e.g., steelhead kelts). 

Delay. To pass each mainstem FCRPS dam, adult fish must successfully locate and ascend the project 

fish ladder(s). The ability to successfully pass each dam has been found to be affected by project 

configuration and various operating characteristics, principally attraction flow rates, project spill patterns, 

and powerhouse discharge patterns. However, Bjornn et al. (2000) estimated that the median time to 

transit the lower Snake River in 1993 was the same or less with dams than it would be without dams, 

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suggesting that adult passage timing through the FCRPS dams and reservoirs is relatively unaffected by 

the FCRPS. This is due to the faster transit times through project reservoirs than would occur in a 

naturally flowing river combined with any dam passage delays. 

Available data suggest that mainstem FCRPS projects with well designed and carefully operatedfishways 

result in very low mortality rates for migrating adults. High per-project and system survivals indicate 

adult salmonid biological requirements are generally being met during passage through the FCRPS under 

the environmental baseline. 

Increasing pinniped predation of adult salmon and steelhead near the fishway entrances at Bonneville 

Dam is a concern for all ESUs that have populations upstream of Bonneville Dam. Efforts to evaluate and 

minimize this problem are part of the 2004 FCRPS UPA (Corps et al. 2004). As solution of this problem 

is uncertain, pinniped predation at Bonneville Dam’s fishway entrances is part of the environmental 

baseline for this consultation. 

Fallback and Volitional Downstream Passage. Fallback refers to adult fish that pass a dam and then are 

entrained in the spillway, navigation lock, or powerhouse intakes, and pass back through the dam. 

Fallback of adult spring/summer chinook salmon passing mainstem dams during spill has been found to 

reduce the number of fish that passed between tops of ladders at Bonneville Dam and Lower Granite or 

Priest Rapids Dams (after adjustments for harvest). Fallback of steelhead at Bonneville and Ice Harbor 

Dams similarly has been found to reduce escapement (Keefer and Peery 2004). During 1996-2002, 

escapement, on average, was lower for fallback fish by 6.5% for spring/summer chinook salmon 

(P<0.05), 19.5% for fall chinook salmon (P<0.005), and 13.2% for steelhead (P<0.005) (Keefer et al. 

2004). Multiplying the percentage reduction in escapement for fish that fall-back by the percentage of fish 

that actually fallback provides an estimate of the reduction in overall system escapement (e.g., steelhead: 

13.2% lower escapement for fallback fish * 21.4% fish that fell back = 2.82% reduction in escapement). 

Accordingly, average reductions in overall run escapements were estimated at 1.30% (range=0.46-

2.27%), 2.26% (range=1.32-2.91%) and 2.82% (range = 1.34-4.02%) for spring/summer chinook salmon, 

fall chinook salmon, and steelhead, respectively as a result of dam passage. 

However, system-wide adult passage information showed no significant difference in spring/summer 

chinook salmon and steelhead escapement due to fallback during spill (about 30- 50 kcfs) and no spill 

periods in 2001 (Keefer and Peery 2004). Escapements of adult steelhead from Bonneville to Lower 

Granite Dam adjusted for harvest in 2000, 2001, and 2002, were very similar (87.6, 85.2, and 85.6%, 

respectively), even though 2001 had very little spill at dams compared with 2000 and 2002. No 

differences (P<0.05) in escapement were found for fallback of spring/summer and fall chinook salmon 

with and without spill for all years (1996-2002) pooled (Keefer et al. 2004). These similar escapements 

with and without spill may be due to so few fish falling back during non-spill periods. Further, with all 

years combined, steelhead escapement was significantly higher (P=0.002) during no spill at John Day 

Dam, and marginally higher (P=0.056) during no spill at Bonneville Dam. 

Steelhead Kelts. Only recently have studies been conducted to identify kelt (post-spawning, downstreammigrating adult steelhead) numbers and to investigate downstream passage success and route-specific 

passage at dams. Studies conducted since 2000 have shown that over 13,000 kelts passed John Day Dam, 

and 83% of the kelts observed at Lower Granite Dam were females. For fish tagged and released at Lower 

Granite Dam, 3.8%, 13.3%, and 34.4% were detected below Bonneville Dam in 2001, 2002, and 2003, 

respectively (Boggs and Peery 2004). Migration rates in 2003 were positively correlated with river flow 

(P<0.0001, R2 = 0.63). Conditions that provided the 34% survival to below Bonneville Dam in 2003 

include spill at dams and a very large freshet in late May/early June when kelts were migrating. 

Repeat spawning rates for Snake River steelhead currently average less than 2% (Ferguson et al. 2004). 

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This is about the same repeat spawning rate observed by Whitt (1954) when returning fish only had to 

negotiate two dams compared to the current eight, suggesting that factors other than dam passage may 

have a more significant effect on kelt survival. 

Sublethal Effects. Adult salmon exposed to suboptimal water quality conditions in the migratory corridor 

and/or delayed by FCRPS dams may succeed in reaching their spawning grounds yet exhibit poor 

spawning success due to sublethal dam passage experience. For example, stressed fish are known to 

produce smaller and fewer eggs than fish in excellent condition. Information is not currently available to 

determine whether such sublethal effects occur as a result of FCRPS dam passage or whether such effects 

are biologically significant. 

5.3.10 Anticipated Changes in Environmental Baseline Conditions in the Action Area 

Over the 30-year life of this Opinion, numerous changes in the action area environment are likely. For 

those anticipated future actions for which ESA Section 7 consultations have been completed, the nature 

and characteristics of anticipated changes in the action area environment are evaluated as part of the 

environmental baseline for this Opinion. Those actions anticipated to be completed or to show marked 

effects on the environmental baseline only after March 2006 are part of the long-term environmental 

baseline for this consultation and are described below. The Corps constructed riprap levees along the 

lower Snake and Clearwater Rivers and continues to regularly dredge sediment from channels in the 

upper part of Lower Granite Reservoir in order to maintain flood conveyance and navigation channels to 

ports in the Lewiston and Clarkston area. These actions were analyzed in NMFS’ March 15, 2004, 

Biological Opinion, “Lower Snake and Clearwater Rivers 2004-2005 Dredging Snake River fall chinook 

salmon, Snake River spring/summer chinook salmon, and Snake River steelhead” (NMFS 2004d), and are 

part of the environmental baseline for this Opinion. Discharge from Potlatch Pulp and Paper Mill in 

Lewiston, Idaho, into the surface waters and sediments in the lower Clearwater and Snake Rivers is 

expected to increase levels of total suspended solids and elevate concentrations of some organic 

constituents. This action was analyzed in NMFS’ April 2, 2004, Biological Opinion, “Potlatch Pulp and 

Paper Mill, Lewiston, Idaho, National Pollution Discharge Elimination System (NPDES) Permit No.: ID000116-3 for the discharge of effluents into the Snake River, Nez Perce County, Idaho and Asotin 

County, WA (1 Project)” (NMFS 2004e). 

The 2004 FCRPS UPA includes an array of actions that will be completed or show marked effect on the 

environment after March 2005 (Corps et al. 2004). As the various measures in the UPA are implemented; 

NMFS anticipates dam passage survival, particularly for juvenile fish, will continue to improve. The 

long-term environmental baseline analyzed for this Opinion includes all the configuration and operational 

changes and the increased predator control proposed in the 2004 FCRPS UPA (Corps et al. 2004). 

Several actions in the 2004 FCRPS UPA are designed to improve the performance of fish protection 

systems (e.g. improved inspections, maintenance, and spare part inventories). Although these actions are 

expected to improve fish survival within the action area for this Opinion, their effects are implicitly 

included in our analysis in that our approach assumes that all fish protection systems are constantly 

functioning at their normal performance levels. Other 2004 FCRPS UPA actions that will provide greater 

system flexibility (e.g., reducing electrical transmission system constraints) are important to facilitating 

an adaptive management approach to fish protection, but the fish survival benefits are impossible to 

quantify at this time. Others are likely to improve fish survival outside the action area for this Opinion 

(e.g., tributary habitat enhancements). 

5.3.10.1 Anticipated Operations and Configurations Improvements at FCRPS Dams That 

Will Improve Long-term Fish Survival in the Action Area 

In their 2004 FCRPS UPA and subsequent Records of Decision, the Action Agencies committed to 

numerous fish passage facility improvements. In addition, individual dams will be operated as further 

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detailed in the water management plans, the implementation plans, the processes afforded through the 

Regional Forum, and the project decision documents. These measures include a number of actions that 

would measurably improve juvenile passage survival. NMFS modified SIMPAS parameters to simulate 

these long-term FCRPS operations and configuration improvements and estimated juvenile passage 

survival in the long-term environmental baseline (Table 5-7). Appendix A describes the anticipated 

system configuration and operation changes included in the long-term environmental baseline. 

5.3.10.2 Expanded Predator Control 

The FCRPS Action Agencies will expand efforts to reduce predation of juvenile salmon by birds and 

other fish. Caspian tern management actions are expected to be implemented as early as 2005 (pending 

completion of environmental review and approval), with resulting juvenile survival improvements as 

early as 2006. Increased incentives under the NPMP will also improve the survival of juveniles from all 

ESUs in the Columbia Basin. It is not currently possible to quantitatively estimate the long-term juvenile 

survival improvements for listed ESUs from these expanded predator control efforts. 

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Table 5-7. Estimated average juvenile survival rates through the FCRPS under the long-term reference 

operation. Estimated survivals in the free-flowing river (survival in the absence of the FCRPS dams) are 

presented for comparison. These estimates do not include possible post- Bonneville latent mortality of inriver migrants. Source: NMFS staff (Appendix A) 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
APPENDIX H 

DEVELOPMENTAL ANALYSIS OF NEW ENVIRONMENTAL 

MEASURES PROPOSED BY IDAHO POWER 

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H-1 

Table H-1. Developmental analysis of new sediment transport measures proposed by Idaho Power. 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comm

IPC-101 Develop and implement a 

program to monitor beach and terrace erosion, substrate, and gravel (101P). 

Idaho 

Power 

$0 $280,000 $280,000 Estimate base

IPC 11-3-06 cresponse—ApB. 

IPC-102 Create a mitigation fund to be 

used by the Forest Service to restore and maintain 14 acres of sandbars on or adjacent to National Forest System lands between Hells Canyon dam and the confluence of the Snake and Salmon rivers (102P) 

Idaho 

Power, 

Forest 

Service 

$0 $534,100 $534,100 Staff estimate 

on $937,000 pfor first 10 ye

Total Idaho Power Proposal $0 $814,100 $814,100 Subtotal Staff Alternative $0 $814,100 $814,100 

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Table H-2. Developmental analysis of new water quality measures proposed by Idaho Power. 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

IPC-84 Implement one of two measures 

to fully meet the SR-HC TMDL Brownlee reservoir DO allocation (an average of 1,125 tons of oxygen during the summer into the transition zone of Brownlee reservoir): inreservoir aeration or upstream phosphorus trading (4P). 

Idaho 

Power 

$1,817,400 $291,500 $447,800 Staff estimate 

on Idaho PowFeb-05 AIR Wresponse. 

IPC-103 Aerate Hells Canyon outflows 

using a forced air (blower) system at Hells Canyon powerhouse that would add 1,500 tons of oxygen per year (103P). 

Idaho 

Power 

$635,000 $120,000 $184,700 Staff estimate 

on IPC estimaprovided on A2007. 

IPC-104 Install and operate a 

destratification system in the Oxbow bypassed reach at the deep pool just upstream of the Indian Creek confluence to prevent anoxic conditions at this location (104P). 

Idaho 

Power 

$52,000 $11,100 $16,000 Staff estimate 

on IPC estimaprovided on A2007. 

IPC-85 Install Hells Canyon dam 

spillway flow deflectors to reduce TDG levels in the tailrace of Hells Canyon dam and the Snake River downstream of the dam (5P). 

Idaho 

Power 

$2,060,000 $0 $182,700 Staff estimate 

on IPC estimaprovided on A2007. 

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H-4 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

IPC-105 Install Brownlee dam spillway 

flow deflectors to reduce TDG levels in Oxbow and Hells Canyon reservoirs and the Snake River downstream of Hells Canyon dam (105P). 

Idaho 

Power 

$2,560,000 $0 $197,500 Staff estimate 

on IPC estimaprovided on A2007. 

IPC-106 Evaluate and implement 

measures on the Oxbow dam spillway or bypassed reach to reduce TDG levels as necessary to meet the SR-HC TMDL load allocation (106P). 

Idaho 

Power 

$4,400,000 $2,700 $278,200 Staff estimate 

on IPC estimaprovided on A2007. 

IPC-107 Adaptively manage TDGabatement measures to ensure 

that Idaho Power meets its TDG load allocation below each of the project’s dams (107P) 

Idaho 

Power 

$0 $2,000 $2,000 Staff estimate

IPC-108 Work with ODEQ and IDEQ to 

develop a TDG monitoring plan that would include monitoring during spill to determine compliance with the TMDL load allocation assigned to Idaho Power (108P). 

Idaho 

Power 

$0 $37,200 $37,200 Staff estimate

IPC-109 Implement Idaho Power’s 

Temperature Adaptive Management Plan, which would (1) define the extent of the project’s temperature responsibility, (2) evaluate potential measures and select the appropriate measure, and (3) implement the appropriate measure (109P). 

Idaho 

Power 

Idaho 

Power 

$4,210,000 $158,600 $452,000 Staff estimate 

on IPC estimaprovided on A2007. 

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H-5 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

Total Idaho Power Proposal $15,734,400 $623,100 $1,798,100 Subtotal Staff Alternative $15,734,400 $623,100 $1,798,100 

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Table H-3. Developmental analysis of new operational measures proposed by Idaho Power. 

Identifier Measure Entity 

Capital 

Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost 

Annualized 

Reduction in 

Energy Benefit Comm

IP-OPs Protect peak spawning 

periods for smallmouth bass and crappie by limiting Brownlee reservoir drafts to no more than 1 foot from the highest elevation reached during a 30-day period starting on May 21, and by maintaining an elevation of at least 2,069 feet msl from the end of the 30-day period through July 4 (7Pa). 

Idaho 

Power 

 $0 No increm

power benestimated Idaho Powrelative to current conditions 

 Subtotal Staff 

Alternative (this table) 

 $0 $0 $0 $0 

 Subtotal Staff 

Alternative (IPC table) 

 $0 $0 $0 $0 

 Total Staff Alternative $0 $0 $0 $0 

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Table H-4. Developmental analysis of new aquatic resources measures proposed by Idaho Power. 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

IPC-110 Implement the fall Chinook 

salmon spawning and gravel monitoring plan described in appendix B of Idaho Power’s comments on the draft EIS (110P). 

Idaho 

Power, 

Forest 

Service 

 Costs associa

this measure aincluded in IPin table H-1. 

IPC-15 Conduct pathogen survey in the 

Pine-Indian-Wildhorse core area to support development of a pathogen risk assessment plan (8Pa) 

Idaho 

Power 

$0 $34,700 $34,700 Idaho Power 

with staff par

IPC-7 Prepare and implement a plan 

to allow for the capture of resident salmonids and other species migrating upstream and for their transfer to areas above Hells Canyon and Oxbow dams. The plan includes modification of the Hells Canyon fish trap to capture juvenile salmonids, construction of facilities for sorting and holding fish and for scanning PIT-tag returns, and potentially expansion of yearround operations. The plan also includes a provision to construct a fish trap at Oxbow dam a minimum of 5 years after the Hells Canyon trap has been modified (8Pb.i). 

Idaho 

Power 

$2,800,000 $369,500 $675,300 Idaho Power 

with staff par

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H-10 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

IPC-20 Purchase two new tanker trucks 

to support fish passage plan (8Pb.ii). 

Idaho 

Power 

$400,000 $0 $43,700 Idaho Power 

with staff par

IPC-14 The plan also includes a 

provision to construct a fish trap at Oxbow dam a minimum of 5 years after the Hells Canyon trap has been modified (8Pb.iii.). 

Idaho 

Power 

$2,800,000 $153,100 $458,900 Idaho Power 

with staff par

IPC-16 Design, construct, and monitor 

a permanent monitoring weir at Pine Creek to establish a longterm monitoring program of fluvial fish migrating upstream and downstream in the Pine Creek system (8Pf). 

Idaho 

Power 

$2,500,000 $92,400 $365,500 Idaho Power 

with staff par

IPC-18 Prepare and implement a 

tributary habitat enhancement plan within the Pine Creek, Indian Creek, and Wildhorse River basins and smaller tributaries to the Hells Canyon Complex reservoirs (8Pc). 

Idaho 

Power 

$8,500,000 $0 $928,400 Idaho Power 

with staff par

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H-11 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

IPC-6 Supplement marine-derived 

nutrients to enhance the forage base within bull trout rearing areas (Pine, Indian, and Wildhorse core area) (8Pd). 

Idaho 

Power 

$0 $40,000 $40,000 Idaho Power 

with staff parIdaho Power these costs wiOxbow hatchRapid River hupgrades. 

IPC-21 Conduct Eagle Creek 

presence/absence survey to determine, with statistical probability, the presence or absence of bull trout within the Eagle Creek basin (8Pe). 

Idaho 

Power 

$0 $42,700 $42,700 Idaho Power 

with staff par

IPC-13 Evaluate the feasibility of, and 

possibly implement, an experimental brook trout suppression program in Indian Creek (8Pg). 

Idaho 

Power 

$0 $51,700 $51,700 Idaho Power 

with staff par

IPC-19 Assess water quality-related 

effects on early life stages of white sturgeon in the Swan Falls-Brownlee reach (11Pa). 

Idaho 

Power 

$0 $24,000 $24,000 Idaho Power 

with staff par

IPC-17 Translocate reproductive-sized 

white sturgeon into the Swan Falls-Brownlee reach to increase spawner abundance and population productivity, if water quality is found to be adequate and if genetic and demographic risks to the donor population are found to be acceptable (11Pb). 

Idaho 

Power 

$0 $20,600 $20,600 Idaho Power 

with staff par

IPC-22 Develop an experimental 

conservation aquaculture plan to maintain adequate population 

Idaho 

Power 

$0 $28,000 $28,000 Idaho Power 

with staff par

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-12 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

size and genetic variability of white sturgeon in the Swan Falls-Brownlee reach, if approved IDFG and ODFW (11Pc). 

IPC-12 Make periodic population 

assessments to monitor white sturgeon populations in the Swan Falls-Brownlee, Brownlee-Hells Canyon, and Hells Canyon-Lower Granite reaches of the Snake River (11Pd). 

Idaho 

Power 

$0 $95,900 $95,900 Idaho Power 

with staff par

IPC-23 Monitor genotypic frequencies 

of white sturgeon between Shoshone Falls and Lower Granite dams (11Pe). 

Idaho 

Power 

$0 $2,300 $2,300 Idaho Power 

with staff parScope restrictSwan Falls to Granite damsupstream areacovered undemid-Snake lic

Total Idaho Power Proposal $17,000,000 $954,900 $2,811,700 

Subtotal Staff Alternative $0 $305,200 $305,200 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-13 

Table H-5. Developmental analysis of new hatchery measures included in the Idaho Power Proposal. 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comm

IPC-10a Make improvements to the 

Pahsimeroi fish hatchery to control pathogens (IPC 10Pa). 

Idaho 

Power 

$6,320,000 $187,500 $877,800 Idaho Power 

estimate witparameters. 

IPC-10b Develop a locally adapted 

steelhead broodstock at Pahsimeroi hatchery (IPC 10Pa). 

Idaho 

Power 

$20,000 $8,500 $10,700 Idaho Power 

estimate witparameters. 

IPC-10c Monitor and evaluate 

hatchery performance at Pahsimeroi fish hatchery through one FTE fish biologist (IPC 10Pa). 

Idaho 

Power 

$0 $46,200 $46,200 Idaho Power 

estimate witparameters. 

IPC-9a Make improvements to the 

Oxbow fish hatchery by constructing adult holding pond and spawning facilities, distributing carcasses, and generally upgrading the hatchery facilities (IPC 10Pb). 

Idaho 

Power 

$2,783,000 $24,900 $328,900 Idaho Power 

estimate witparameters. 

IPC-9b Make improvements to the 

Oxbow fish hatchery by expanding the fall Chinook rearing program (IPC 10Pb). 

Idaho 

Power 

$2,500,000 $10,000 $283,100 Idaho Power 

estimate witparameters. 

IPC-9c Monitor and evaluate 

hatchery performance at Oxbow hatchery through one FTE fish biologist (IPC 10Pb). 

Idaho 

Power 

$0 $46,200 $46,200 Idaho Power 

estimate witparameters. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-14 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comm

IPC-8a Make improvements to the 

Niagara Springs fish hatchery by expanding the hatchery building, acquiring an additional smolt tanker, acquiring a fish marking unit, upgrading employee housing, and monitoring and evaluating hatchery performance (IPC 10Pc). 

Idaho 

Power 

$1,550,000 $9,200 $178,500 Idaho Power 

estimate witparameters. 

IPC-8b Acquire a fish marking unit 

(IPC 10Pc). 

Idaho 

Power 

$750,000 $4,600 $86,500 Idaho Power 

estimate witparameters. 

IPC-8c Monitor and evaluate 

hatchery performance at Niagara Springs through one FTE fish biologist (IPC 10Pc). 

Idaho 

Power 

$0 $46,200 $46,200 Idaho Power 

estimate witparameters. 

IPC-11a Make improvements to the 

Rapid River fish hatchery by constructing an adult holding pond and spawning facilities, distributing carcasses, upgrading employee housing, generally upgrading the hatchery facilities, constructing an offsite smolt acclimation/ adult collection facility, and monitoring and evaluating hatchery performance (IPC 10Pd). 

Idaho 

Power 

$3,083,000 $39,700 $376,400 Idaho Power 

estimate witparameters. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-15 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comm

IPC-11b Monitor and evaluate 

hatchery performance at Rapid River hatchery through one FTE fish biologist (IPC 10Pd). 

Idaho 

Power 

$0 $46,200 $46,200 Idaho Power 

estimate witparameters. 

Total Idaho Power Proposal $17,006,000 $469,200 $2,326,700 Subtotal Staff Alternative $17,006,000 $469,200 $2,326,700 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-16 

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Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-17 

Table H-6. Developmental analysis of new terrestrial resources measures proposed by Idaho Power. 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

IPC-86 Acquire, enhance, and manage 

approximately 22,761 acres of upland and 821 acres of riparian habitat near the Hells Canyon Project reservoirs and downstream of Hells Canyon dam to mitigate for the estimated effects of project operations on wildlife (12P). 

Idaho 

Power 

$16,190,700 $0 $1,768,400 Idaho Power 

IPC-88a In cooperation with ODFW, 

enhance habitat on two Snake River islands (Hoffman and Porter) for waterfowl and for threatened, endangered, candidate, and special status species (13P). 

Idaho 

Power 

$0 $6,000 $6,000 Idaho Power 

with staff par

IPC-88b In cooperation with ODFW and 

IDFG, enhance habitat on two Snake River islands (Gold and Patch) for waterfowl and for threatened, endangered, candidate, and special status species (13P). 

Idaho 

Power 

$0 $20,000 $20,000 Idaho Power 

with staff par

IPC-87 Cooperate with state and 

federal wildlife management agencies to enhance lowelevation riparian habitat and reintroduce mountain quail in areas adjacent to the Hells Canyon Project reservoirs, providing $20,000/yr for 5 yrs (14P). 

Idaho 

Power 

$100,000 $0 $9,600 Idaho Power 

with staff par

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-18 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

IPC-90 Through an interdisciplinary 

team, develop and implement an integrated wildlife habitat program to manage wildlife resources (15P). 

Idaho 

Power 

$663,200 $954,300 $1,026,700 Extrapolated 

Idaho Power 

IPC-89 Develop and implement an 

operation and maintenance plan for the Pine Creek-Hells Canyon transmission line to minimize effects on wildlife, protect wildlife resources, and enhance habitat conditions (16P). 

Idaho 

Power 

$0 $5,500 $5,500 Idaho Power 

IPC-1 Formalize cooperative 

relationships to accomplish noxious weed control and nonnative invasive weed management, site monitoring, and re-seeding along the Snake River corridor from Weiser downstream to the confluence of the Salmon River (18P). 

Idaho 

Power 

$0 $50,000 $50,000 Idaho Power 

IPC-2 Formalize cooperative 

relationships, including establishment of a rare plant advisory board, to protect and monitor sensitive plant sites along the Snake River corridor from the headwaters of Brownlee reservoir downstream to the confluence of the Salmon River (19P). 

Idaho 

Power 

$0 $6,000 $6,000 Idaho Power 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-19 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

IPC-3 Develop and implement an 

operation and maintenance plan for the Pine Creek-Hells Canyon transmission line to minimize effects on rare plants, protect botanical resources, and enhance habitat conditions. (20P and 21P). 

Idaho 

Power 

$0 $4,200 $4,200 Idaho Power 

Total Idaho Power Proposal $16,953,900 $1,046,000 $2,896,400 Subtotal Staff Alternative $16,953,900 $1,046,000 $2,896,400 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-20 

Table H-7. Developmental analysis of new cultural resources measures proposed by Idaho Power. 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

IPC-30 Monitor sites along 

transmission line 945 that are eligible for inclusion on the National Register (22P) 

Idaho 

Power 

$0 $2,400 $2,400 Idaho Power 

with staff par

IPC-31 Monitor the known burial site 

on Oxbow reservoir (23P). 

Idaho 

Power 

$0 $800 $800 Idaho Power 

with staff par

IPC-34 Monitor selected known 

eligible sites on Oxbow and Hells Canyon reservoirs (24P). 

Idaho 

Power 

$0 $20,800 $20,800 Idaho Power 

with staff par

IPC-33 Monitor selected known 

eligible sites on Brownlee reservoir (25P). 

Idaho 

Power 

$0 $20,100 $20,100 Idaho Power 

with staff par

IPC-32 Monitor selected known 

eligible sites downstream of Hells Canyon dam (26P). 

Idaho 

Power 

$0 $65,000 $65,000 Idaho Power 

with staff par

IPC-43 Stabilize approximately 

20 archaeological sites downstream of Hells Canyon dam after identifying sites requiring stabilization (27P). 

Idaho 

Power 

$0 $106,700 $106,700 Idaho Power 

with staff par

IPC-44 Stabilize seven archaeological 

sites on Brownlee reservoir (28P). 

Idaho 

Power 

$0 $34,700 $34,700 Idaho Power 

with staff par

IPC-26 Recover archaeological data at 

four archaeological sites on Brownlee reservoir to prevent possible damage by reservoir operations (29P). 

Idaho 

Power 

$0 $35,400 $35,400 Idaho Power 

with staff par

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-21 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

IPC-35 Establish Native American 

interpretive sites on Brownlee reservoir to enhance visitors’ awareness of Native American presence and land use in the project area (30P). 

Idaho 

Power 

$22,000 $2,200 $4,600 Idaho Power 

with staff par

IPC-36 Establish Native American 

interpretive sites on Oxbow and Hells Canyon reservoirs to enhance visitors’ awareness of Native American presence and land use in the project area (31P). 

Idaho 

Power 

$11,000 $1,100 $2,300 Idaho Power 

with staff par

IPC-28 Establish European-American 

interpretive sites on Brownlee, Oxbow, and Hells Canyon reservoirs to enhance visitors’ awareness of EuropeanAmerican presence and land use in the project area (32P). 

Idaho 

Power 

$22,000 $2,200 $4,600 Idaho Power 

with staff par

IPC-25 Establish Asian-American 

interpretive sites on Brownlee, Oxbow, and/or Hells Canyon reservoirs to enhance visitors’ awareness of Asian-American presence and land use in the project area (33P) 

Idaho 

Power 

$22,000 $2,200 $4,600 Idaho Power 

with staff par

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-22 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

IPC-27 Support European-American 

and Asian-American interpretive projects by assisting local community museums with collections acquisition, display, and curation related to Hells Canyon area trappers, miners, homesteaders, ranchers, and river runners of European and Asian descent (34P). 

Idaho 

Power 

$0 $5,800 $5,800 Idaho Power 

with staff par

IPC-37a Provide support for Native 

American programs of the Burns Paiute Tribe in its efforts to obtain funding for participating in and/or administering cultural resources PME measures (35Pa). 

Idaho 

Power 

$0 $10,000 $10,000 Staff estimate

IPC-37b Provide support for Native 

American programs of the Burns Paiute Tribe in its efforts to educate its youth by providing scholarship/ training funds (35Pb). 

Idaho 

Power 

$0 $11,700 $11,700 Staff estimate

commitment ofunding is not included in a license, it wouway preclude Power from futhis commitmoutside the lic

IPC-37c Provide support for Native 

American programs of the Burns Paiute Tribe in its efforts to obtain funding to facilitate several cultural enhancement programs (35Pc). 

Idaho 

Power 

$0 $11,700 $11,700 Staff estimate

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-23 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

IPC-39a Provide support for Native 

American programs of the Confederated Tribes of the Warm Springs Indian Reservation in its efforts to obtain funding for participating in and/or administering cultural resources PME measures (36Pa). 

Idaho 

Power 

$0 $10,000 $10,000 Staff estimate

IPC-39b Provide support for Native 

American programs of the Confederated Tribes of the Warm Springs Indian Reservation in its efforts educate its youth by providing scholarship/ training funds (36Pb). 

Idaho 

Power 

$0 $11,700 $11,700 Staff estimate

commitment ofunding is not included in a license, it wouway preclude Power from futhis commitmoutside the lic

IPC-39c Provide support for Native 

American programs of the Confederated Tribes of the 

Warm Springs Indian Reservation in its efforts to obtain funding to facilitate several cultural enhancement programs (36Pc). 

Idaho 

Power 

$0 $11,700 $11,700 Staff estimate

IPC-40a Provide support for Native 

American Programs of the Nez Perce Tribe in its efforts to obtain funding for participating in and/or administering cultural resources PME measures (37Pa). 

Idaho 

Power 

$0 $10,000 $10,000 Staff estimate

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-24 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

IPC-40b Provide support for Native 

American programs of the Nez Perce Tribe in its efforts to educate its youth by providing scholarship/ training funds (37Pb). 

Idaho 

Power 

$0 $11,700 $11,700 Staff estimate

commitment ofunding is not included in a license, it wouway preclude Power from futhis commitmoutside the lic

IPC-40c Provide support for Native 

American programs of the Nez Perce Tribe in its efforts to obtain funding to facilitate several cultural enhancement programs (37Pc) 

Idaho 

Power 

$0 $11,700 $11,700 Staff estimate

IPC-41a Provide support for Native 

American Programs of the Confederated Tribes of the Umatilla Indian Reservation in its efforts to obtain funding for participating in and/or administering cultural resources PME measures (38Pa). 

Idaho 

Power 

$0 $10,000 $10,000 Staff estimate

IPC-41b Provide support for Native 

American Programs of the Confederated Tribes of the Umatilla Indian Reservation in its efforts to educate its youth by providing scholarship/ training funds (38Pb). 

Idaho 

Power 

$0 $11,700 $11,700 Staff estimate

commitment ofunding is not included in a license, it wouway preclude Power from futhis commitmoutside the lic

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-25 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

IPC-41c Provide support for Native 

American programs of the Confederated Tribes of the Umatilla Indian Reservation in its efforts to obtain funding to facilitate several cultural enhancement programs (38Pc). 

Idaho 

Power 

$0 $11,700 $11,700 Staff estimate

IPC-38a Provide support for Native 

American programs of the Confederated Tribes of the Shoshone Paiute Indian Reservation in its efforts to obtain funding for participating in and/or administering cultural resources PME measures (39Pa). 

Idaho 

Power 

$0 $10,000 $10,000 Staff estimate

IPC-38b Provide support for Native 

American programs of the Shoshone Paiute Tribe in its efforts to educate its youth by providing scholarship/ training funds (39Pb). 

Idaho 

Power 

$0 $11,700 $11,700 Staff estimate

commitment ofunding is not included in a license, it wouway preclude Power from futhis commitmoutside the lic

IPC-38c Provide support for Native 

American programs of the Shoshone Paiute Tribe in its efforts to obtain funding to facilitate several cultural enhancement programs (39Pc). 

Idaho 

Power 

$0 $11,700 $11,700 Staff estimate

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-26 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

IPC-42a Provide support for Native 

American Programs of the Shoshone-Bannock Tribes in its efforts to obtain funding for participating in and/or administering cultural resources PME measures (40Pa). 

Idaho 

Power 

$0 $10,000 $10,000 Staff estimate

IPC-42b Provide support for Native 

American Programs of the Shoshone-Bannock Tribes in its efforts to educate its youth by providing scholarship/ training funds (40Pb). 

Idaho 

Power 

$0 $11,700 $11,700 Staff estimate

commitment ofunding is not included in a license, it wouway preclude Power from futhis commitmoutside the lic

IPC-42c Provide support for Native 

American Programs of the Shoshone-Bannock Tribes in its efforts to obtain funding to facilitate several cultural enhancement programs (40Pc). 

Idaho 

Power 

$0 $11,700 $11,700 Staff estimate

IPC-24 Fund additional Section 106 

projects to protect sites and mitigate for any unforeseen adverse effects attributed to Hells Canyon Project operations (41P). 

Idaho 

Power 

$0 $0 $0 Cannot estima

projects ident

Total Idaho Power Proposal $77,000 $499,800 $508,200 Subtotal Staff Alternative $77,000 $323,700 $332,100 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-27 

Table H-8. Developmental analysis of new recreation measures proposed by Idaho Power. 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

IPC-76 Provide additional boat 

moorage on Hells Canyon Project reservoirs to improve angling access (45P). 

Idaho 

Power 

$180,000 $3,300 $19,300 Idaho Power 

with staff par

IPC-67 Enhance litter and sanitation 

plan to improve litter cleanup and access to portable and vault toilets at dispersed recreational sites (46P). 

Idaho 

Power 

$60,000 $55,000 $61,600 Idaho Power 

with staff par

IPC-74 Develop and implement an 

integrated Information and Education (I&E) Plan to promote protection and preservation of cultural, natural, and historical resources through education (47P). 

Idaho 

Power 

$1,380,000 $18,400 $149,800 Idaho Power 

with staff par

IPC-75 Coordinate the prioritization of 

law enforcement resource use among appropriate law enforcement agencies to address public safety issues (48P). 

Idaho 

Power 

$0 $15,000 $15,000 Idaho Power 

with staff par

IPC-79 Develop and implement a 

Recreation Adaptive Management Plan to identify and address the adequacy of Idaho Power’s Recreation Plan over the life of the new license (49P). 

Idaho 

Power 

$1,270,000 $58,000 $108,100 Idaho Power 

with staff parMeasure inclu4e condition 1

IPC-70 Enhance road maintenance to 

improve public safety and further protect at-risk cultural and natural resources (50P). 

Idaho 

Power 

$20,000 $25,600 $27,800 Idaho Power 

with staff par

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-28 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

IPC-81 Perform operation and 

maintenance at Idaho Powerenhanced BLM and Forest Service reservoir-related recreational sites to benefit recreation, provide public access, enhance visitor services and user satisfaction, and reduce the responsibilities of federal agencies to provide operations and maintenance (O&M) services (51P). 

Idaho 

Power 

$0 $85,300 $85,300 Idaho Power 

with staff par

IPC-65 Enhance Eagle Bar dispersed 

recreational site and improve boat ramp access to Hells Canyon reservoir (52P). 

Idaho 

Power 

$150,000 $0 $15,300 Idaho Power 

with staff par

IPC-57 Develop site plan for Big Bar 

recreational site to accommodate recreational use and provide cultural and natural resource protection (53P). 

Idaho 

Power 

$50,000 $10,000 $15,500 Idaho Power 

with staff parO&M cost estby staff. 

IPC-58 Enhance boat ramp and 

associated facilities at Big Bar Section D recreational site to improve access to lower Hells Canyon reservoir and provide cultural and natural resource protection (54P). 

Idaho 

Power 

$249,900 $0 $25,500 Idaho Power 

with staff par

IPC-56 Develop site plan and enhance 

Eckels Creek dispersed recreational site to benefit recreation and provide cultural and natural resource protection (55P) 

Idaho 

Power 

$30,000 $0 $3,100 Idaho Power 

with staff par

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-29 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

IPC-68 Supplement the existing O&M 

budget to accommodate enhancements at Idaho Powermanaged parks and recreational facilities (56P). 

Idaho 

Power 

$0 $85,300 $85,300 Idaho Power 

with staff par

IPC-63 Develop and implement a site 

plan for the Copper Creek dispersed recreational site to benefit recreation and provide cultural and natural resource protection (57P). 

Idaho 

Power 

$50,000 $0 $5,100 Idaho Power 

with staff par

IPC-77 Reconstruct Hells Canyon Park 

to benefit recreation, improve public access, and protect cultural and natural resources (58P). 

Idaho 

Power 

$2,000,000 $0 $176,100 Idaho Power 

with staff par

IPC-54 Develop Airstrip A&B 

dispersed recreational site to benefit recreation, improve public access, and protect cultural and natural resources (59P). 

Idaho 

Power 

$40,000 $0 $4,100 Idaho Power 

with staff par

IPC-59 Develop and implement a site 

plan for Bob Creek Section A dispersed recreational site to benefit recreation, improve public access, and protect cultural and natural resources (60P). 

Idaho 

Power 

$50,000 $0 $5,100 Idaho Power 

with staff par

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-30 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

IPC-60 Develop and implement a site 

plan for Bob Creek Section B dispersed recreational site to benefit recreation, improve public access, and protect cultural and natural resources (61P). 

Idaho 

Power 

$25,000 $0 $2,500 Idaho Power 

with staff par

IPC-61 Develop and implement a site 

plan for Bob Creek Section C dispersed recreational site to benefit recreation, improve public access, and protect cultural and natural resources (62P). 

Idaho 

Power 

$50,000 $0 $5,100 Idaho Power 

with staff par

IPC-73 Develop and implement a site 

plan for Westfall dispersed recreational site to benefit recreation, improve public access, and protect cultural and natural resources (63P). 

Idaho 

Power 

$60,000 $0 $6,100 Idaho Power 

with staff par

IPC-64 Enhance Copperfield boat 

launch area to benefit day-use activities (64P). 

Idaho 

Power 

$100,000 $0 $9,500 Idaho Power 

with staff par

IPC-69 Implement a site plan for 

Oxbow boat launch to benefit recreation, improve public access, and protect cultural and natural resources (65P). 

Idaho 

Power 

$80,000 $0 $7,600 Idaho Power 

with staff par

IPC-62 Implement a site plan for 

Carters Landing and Old Carters Landing recreational sites to benefit recreation, improve public access, and protect cultural and natural resources (66P). 

Idaho 

Power 

$80,000 $0 $8,200 Idaho Power 

with staff par

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-31 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

IPC-78 Reconstruct McCormick Park 

to meet current standards of services, benefit recreation, improve public access, and protect cultural and natural resources (67P). 

Idaho 

Power 

$3,000,000 $0 $266,500 Idaho Power 

with staff par

IPC-66 Develop and implement a site 

plan for Hewitt and Holcomb Parks to accommodate recreational use and provide cultural and natural resource protection (68P). 

Idaho 

Power 

$99,900 $0 $10,200 Idaho Power 

with staff par

IPC-55 Develop and implement a site 

plan for a low-water boat launch at or near Swedes Landing to improve boat access to Brownlee reservoir during seasonal reservoir drawdowns and periods of low reservoir levels (69P). 

Idaho 

Power 

$250,000 $0 $25,200 Idaho Power 

with staff par

IPC-72 Develop and implement a site 

plan for Swedes Landing to benefit recreation, improve public access, and protect cultural and natural resources (70P). 

Idaho 

Power 

$75,000 $0 $7,300 Idaho Power 

with staff par

IPC-71 Develop and implement a site 

plan for Spring recreational site to enhance recreational facilities and improve boat ramp access to Brownlee reservoir (71P). 

Idaho 

Power 

$500,000 $0 $46,000 Idaho Power 

with staff par

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-32 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comme

IPC-101 Complete a condition and 

safety inspection of Deep Creek Stairway/Trail #218 and correct any deficiencies found during inspection (21Se). 

 $80,000 $3,000 $11,700 Staff estimate

Measure was subsequently by Idaho Powthe FEIS. 

Total Idaho Power Proposal $9,929,800 $358,900 $1,207,900 

Subtotal Staff Alternative $9,929,800 $358,900 $1,207,900 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-33 

Table H-9. Developmental analysis of new land use and aesthetic resources measures proposed by Idaho Powe

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Com

IPC-53 Incorporate aesthetic concerns 

when upgrading or repairing the existing transmission line 945 (73P). 

Idaho 

Power 

$20,000 $3,300 $5,500 Idaho Powe

with staff p

IPC-46 74. Develop standards and 

guidelines for designing new physical structures and modifying existing structures to achieve aesthetic and other goals (74P, 112P). 

Idaho 

Power 

$35,000 $0 $3,800 Idaho Powe

with staff p

IPC-45 75. Establish standards and 

guidelines for the design of vegetation and hardscape elements and structures in developed areas to control noxious weeds and to achieve aesthetic and other goals (75P, 112P). 

Idaho 

Power 

$55,000 $0 $6,000 Idaho Powe

with staff pIncludes FS

IPC-48 76. Implement a general aesthetic 

clean-up plan to enhance the quality of the recreational experience in specific areas (76P, 112P). 

Idaho 

Power 

$215,000 $4,600 $28,100 Idaho Powe

with staff pIncludes FS

IPC-52 77. Replace guardrails and Jersey 

barriers with barriers of corten steel or other visually acceptable material, except where Jersey barriers function as barriers to slides and falling rocks along roads and developed areas (77P, 112P). 

Idaho 

Power 

$160,000 $0 $13,900 Idaho Powe

with staff p

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-34 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Com

IPC-50 78. Reduce the visual contrast of 

certain project facilities with their environment to improve aesthetics and enhance the recreational experience near those facilities (78P, 112P). 

Idaho 

Power 

$304,000 $4,100 $32,900 Idaho Powe

with staff p

IPC-47 Cooperate with BLM and the 

Forest Service to develop and assist them with implementing proposed design standards and guidelines at specific BLM and Forest Service facilities, including the Spring recreational site on Brownlee reservoir (BLM), Copper Creek trailhead on Hells Canyon reservoir (BLM), and Big Bar and Eagle Bar on Hells Canyon reservoir (Forest Service) (79P). 

Idaho 

Power 

$10,000 $0 $1,100 Idaho Powe

with staff p

IPC-49 Provide signs and/or facilities that 

interpret some elements of the Hells Canyon Project that cannot be effectively modified to reduce their visual contrast (80P). 

Idaho 

Power 

$11,000 $0 $1,200 Idaho Powe

with staff p

IPC-51 Implement the common policies 

of the Hells Canyon Resource Management Plan to provide for the management, protection, and/or conservation of natural and cultural resources (81P). 

Idaho 

Power 

$10,000 $71,000 $72,100 Idaho Powe

with staff p

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
H-35 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Com

IPC-113 Provide the Forest Service with a 

map and aerial photos depicting the approximate location of the project boundary, together with GIS shape files of the project boundary on National Forest System lands (113P). 

Idaho 

Power 

$20,000 $0 $2,200 Staff estima

Total Idaho Power Proposal $840,000 $83,000 $166,800 

Subtotal Staff Alternative $840,000 $83,000 $166,800 

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Document Accession #: 20070831-4002 Filed Date: 08/31/2007
APPENDIX I 

DEVELOPMENTAL ANALYSIS OF OTHER MEASURES INCLUDED 

IN THE STAFF ALTERNATIVE

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
Document Accession #: 20070831-4002 Filed Date: 08/31/2007
I-1 

Table I-1. Developmental analysis of new sediment transport measures included in the Staff Alternative. 

Identifier Measure Entity Capital Cost 

Annualized O&M 

Cost 

Total 

Annualiz

Cost 

Interior-68 5-year volumetric monitoring of sand 

and gravel bars (1S, 101P). 

Interior $0 $28,800 $28,800 

OPRD-1 Apply a bank stabilization treatment 

to Farewell Bend State Park (Staff 

21Sc). 

OPRD $720,400 $0 $78,700 

 Subtotal Staff Alternative 

(this table) 

$720,400 $28,800 $107,50

Subtotal Staff Alternative (IPC table) 

 $0 $814,100 $814,10

 Total Staff Alternative $720,400 $842,900 $921,60

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Table I-2. Developmental analysis of new water quality measures included in the Staff Alternative. 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost 

ST-WQ-1 Develop and implement 

operational compliance and water quality monitoring plan (4S and 6S). 

Staff $50,000 $25,000 $30,500 Staff estim

Interior-64 Comply with IDEQ and ODEQ 

water quality certifications (WQC). 

Interior $0 $0 $0 WQCs hav

these costs is likely thmeasure. 

ODFW-54a Develop TDG-abatement plan 

(107S). 

ODFW $20,000 $0 $2,200 Staff estim

ODFW-55 Develop and implement a 

dissolved oxygen enhancement plan to ensure that the project does not contribute to violation of dissolved oxygen standards within or below the project (4P). 

ODFW $20,000 $0 $2,200 Staff estim

control me

ODFW-43&57 (partial) 

If requested by IDEQ or ODEQ, collect tissue samples from white sturgeon within and downstream of the project area and from Brownlee reservoir fish for the purpose of monitoring toxic bioaccumulants (5S). 

ODFW $0 $2,000 $2,000 Staff estim

collected dmonitoring Power (Id11d) and oeffort. 

 Subtotal Staff Alternative 

(this table) 

 $90,000 $27,000 $36,900 

Subtotal Staff Alternative (IPC table) 

 $15,734,400 $623,100 $1,798,100 

 Total Staff Alternative $15,824,400 $650,100 $1,835,000 

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Table I-3. Developmental analysis of new operational measures included in the Staff Alternative. 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost 

Annualized 

Reduction in 

Energy 

Benefit 

ST-1 Implement a 4-inch-per-hour 

ramp rate measured at Johnson Bar from March 15 through June 15, to be adjusted if warranted based on monitoring studies (Staff Op-3). 

Staff $1,600,000 $68,000 $242,800 $1,831,000 

Corps-1 The flood control draft for 

Brownlee in preparation of the spring runoff should be determined consistent with the November 1998 Procedure for Determining Flood Control Draft at Brownlee reservoir (IPC). 

Corps $0 $0 $0 $0 

Corps-2 Handle future winter flood 

control operations for Brownlee reservoir in conjunction with the Corps on a case-by case basis (IPC). 

Corps $0 $0 $0 $0 

Corps-6 Prevent the maximum 

variation in river stage from exceeding 1 foot per hour as measured at the Snake River at Johnson Bar gaging station (Staff Op-3). 

Corps $0 $0 $0 $0 

IDFG-1a Continue Idaho Power’s fall 

Chinook spawning program which includes providing stable flows (IPC). 

IDFG $0 $0 $0 $0 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
I-6 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost 

Annualized 

Reduction in 

Energy 

Benefit 

NMFS-1 Provide stable flows between 

8,500 and 13,500 cfs below Hells Canyon dam throughout fall Chinook salmon spawning season (IPC). 

NMFS $0 $0 $0 $0 

NMFS-2 Provide instantaneous 

minimum flows below Hells Canyon dam throughout the fall Chinook salmon incubation period that are equal to, or greater than, the stable flows provided during the spawning period unless surveys indicate that shallow water redds can be fully protected at a lower flow (IPC). 

NMFS $0 $0 $0 $0 

NMFS-8 Refill Brownlee reservoir to 

within 1 foot of the April 15 and April 30 minimum elevations necessary to meet the Corps flood control requirements and coordinate refill with NMFS (Staff Op-1) 

NMFS $0 $0 $0 $0 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
I-7 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost 

Annualized 

Reduction in 

Energy 

Benefit 

NMFS-9 Refill Brownlee reservoir to 

full pool by June 20, release 237 kaf of stored water from Brownlee reservoir between June 21 and July 31 (release at least 150 kaf of this water by July 15) and not refill until after August 31 (Staff Op-2). 

NMFS $0 $0 $0 $9,033,000 

 Subtotal Staff Alternative 

(this table) 

 $1,600,000 $68,000 $242,800 $10,478,000 

 Subtotal Staff Alternative 

(IPC table) 

 $0 $0 $0 $0 

 Total Staff Alternative $1,600,000 $68,000 $242,800 $10,478,000 

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Table I-4. Developmental analysis of new aquatic resources measures included in the Staff Alternative. 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized Cost 

Interior-87 Develop and implement a bull 

trout passage plan, modify the Hells Canyon fish trap and construct a permanent monitoring weir at Pine Creek, conduct pathogen surveys, conduct monitoring studies needed to determine when trigger criteria have been met to construct an adult trap at Oxbow dam and permanent monitoring weirs on Indian Creek and the Wildhorse River, evaluate and monitor fishway effectiveness (8Pb). 

Idaho 

Power 

$16,258,000 $667,200 $1,974,300 Idaho 

for Hemodifweir acompoAssumCanyoconstrin yeaCreek trap an20. 

ST-AQ-Strand Develop and implement a 

stranding and entrapment monitoring plan (9S). 

Staff $0 $107,000 $107,000 Staff e

ST-AQ-6 Develop and implement a fall 

Chinook spawning and incubation flow management plan (10S). 

Staff $25,000 $0 $2,700 Staff e

ST-AQ-7 Prepare a flow augmentation 

evaluation report (105S). 

Staff $25,000 $0 $1,800 Staff e

ST-AQ-Lamp Participate in regional lamprey 

forums, report findings relevant to restoration opportunities every 5 years (8S). 

Staff $0 $5,000 $5,000 Staff e

ST-AQ-Sturg Conduct a feasibility assessment of 

translocation and aquaculture approaches for restoring sturgeon in reaches between Swan Falls and Lower Granite dams (11Pc). 

Staff $20,000 $0 $2,200 Staff e

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
I-10 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized Cost 

ST-AQ-Inv Develop and implement an 

invertebrate monitoring plan (101S). 

Staff $57,000 $57,000 Staff e

monito$100,0

ST-AQ-Trib Develop and implement an 

expanded tributary enhancement plan (Pine, Indian, Wildhorse, Powder and Burnt basins) (8Pc). 

Staff $18,000,000 $0 $1,466,700 Staff e

Subtotal Staff Alternative (this table) 

 $34,328,000 $836,200 $3,616,700 

Subtotal Staff Alternative (IPC table) 

 $0 $305,200 $305,200 

 Total Staff Alternative $34,328,000 $1,141,400 $3,921,900 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
I-11 

Table I-5. Developmental analysis of new hatchery measures included in the Staff Alternative. 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost 

ST-HT-1 Fund the development and 

implementation of HGMPs for each hatchery (9P). 

Staff $0 $66,700 $66,700 S

IDFG-7 Purchase new adult fish transport 

vehicle (10Pc). 

IDFG $160,000 $2,000 $18,300 S

NMFS-13l Screen hatchery water intakes to meet 

NMFS juvenile fish screen criteria (9P). 

NMFS $10,000 $0 $1,100 S

NMFS-13m Assess and minimize impacts of 

hatchery steelhead to listed ESUs (9P). 

NMFS $0 $8,300 $8,300 S

ST-HT-2 Develop and implement, in 

consultation with the Burns-Paiute Tribe, the Shoshone-Paiute tribes, ODFW, IDFG, FWS and NMFS, a plan to use surplus adult hatchery spring Chinook and steelhead to support ceremonial and subsistence fisheries for the Burns-Paiute and Shoshone-Paiute tribes and to improve forage for bull trout in tributaries within the project area (103S) 

Staff, 

NMFS, 

BurnsPaiute 

Tribe,a

ShoshonePaiute 

Tribe 

$0 $80,900 $80,900 S

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
I-12 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost 

ST-HT-3 Develop a plan, in consultation with 

the Shoshone-Bannock tribes, IDFG, NMFS, and FWS, to fund the design, construction and operation of facilities on the Yankee Fork of the Salmon River to spawn and incubate 1,000,000 salmon or steelhead eggs to support the Shoshone-Bannock Tribe’s streamside incubator program (104S) 

Staff and 

the 

ShoshoneBannock 

Tribes 

$205,000 $69,900 $89,600 S

Subtotal Staff Alternative (this table) 

 $375,000 $227,800 $264,900 

Subtotal Staff Alternative (IPC table) 

$17,006,000 $469,200 $2,326,700 

 Total Staff Alternative $17,381,000 $697,000 $2,591,600 

a This specific measure was not described by the Burns Paiute Tribe, but the tribe identified fisheries restoration in the M

especially important to the tribe during tribal consultation meeting held on March 29, 2007 in Boise, Idaho. 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
I-13 

Table I-6. Developmental analysis of new terrestrial resources measures included in the Staff Alternative. 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualiz

Cost 

FS-5 Finalize and implement the Hells Canyon Resource 

Management Plan, Integrated Wildlife Habitat Program and Wildlife Mitigation and Management Plan (15S). 

FS $50,000 $20,000 $25,500 

FS-6a Acquire 56.3 acres of riparian habitat to mitigate for 

project effects downstream of Hells Canyon dam (14S). 

FS $954,300 $56,300 $160,500 

FS-7 Prepare an Integrated Weed Management Plan (18P). FS $5,000 $30,000 $30,500 FS-8 Prepare and implement a Threatened and Endangered 

Species Management and Monitoring Strategy (12S). 

FS $1,000 $0 $100 

FS-9 Develop and implement a Sensitive Species 

Management Plan (12S). 

FS $5,000 $62,000 $62,500 

FS-11 Develop and implement a Transmission Line 

Operation and Maintenance Plan (13S, 16P, 20P). 

FS $2,000 $1,000 $1,200 

IDFG-31 Fund habitat management on 4 state-owned islands 

(13P). 

IDFG $100,000 $0 $10,900 

Interior-23 Submit pesticide plans and reports to BLM (18P). Interior $1,000 $500 $600 Interior-77 Develop and implement Integrated Weed 

Management Plan for project lands, including cooperative projects on adjacent lands (18P). 

Interior $10,000 $85,000 $86,100 

Interior-82 As part of Threatened, Endangered, and Sensitive 

Species Management Plan, implement measures to protect Townsend’s big-eared bat maternity sites and hibernacula (12S). 

Interior $0 $1,500 $1,500 

Interior-83 As part of Threatened, Endangered, and Sensitive 

Species Management Plan, implement measures to protect southern Idaho ground squirrel (12S). 

Interior $2,000 $1,000 $1,200 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
I-14 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualiz

Cost 

Interior-85 As part of Threatened, Endangered, and Sensitive 

Species Management Plan, implement measures to protect special status amphibians and reptiles (12S). 

Interior $0 $1,000 $1,000 

Interior-34b As part of project-wide plan, develop and implement 

Threatened, Endangered, and Sensitive Species Management Plan for BLM-administered lands inside project boundary (12S). 

Interior $1,000 $1,000 $1,100 

 ODFW-62 Additional funding of habitat management on 4 stateowned islands (13P) ODFW $198,800 $0 $21,700 

ODFW-72 As part of WMMP, schedule O&M to minimize 

disturbance on deer winter range (15S). 

ODFW $0 $1,000 $1,000 

ODFW-73 As part of WMMP, develop and implement I&E 

program to minimize risk of wildlife disturbance (15S). 

ODFW $5,000 $1,000 $1,500 

ODFW-60b Establish a Terrestrial Resources Work Group (15P). ODFW $5,000 $12,000 $12,500 Staff-TR-1 Develop and implement project-wide Threatened, 

Endangered, and Sensitive Species Management Plan (12S). 

Staff $10,000 $47,500 $48,600 

Staff-TR-2 Monitor bald eagles and manage nest and roost sites 

as part of project-wide Threatened, Endangered, and Sensitive Species Management Plan (12S). 

Staff $5,000 $10,000 $10,500 

Staff-TR-3 – now FS-6b 

Conduct riparian planting feasibility assessment and implement stabilization/revegetation program if possible; if not, acquire 70 acres of riparian habitat off-site (11S). 

FS $300,000 $20,000 $52,800 

Staff-TR-4 As part of Transmission Line O&M Plan for 

transmission line 945, monitor electrocution and collision and implement measures to reduce risks (13S). 

Staff $0 $1,000 $1,000 

Staff-TR-5 Acquire 5.9 acres of riparian habitat to mitigate for 

anticipated effects of preferred flow alternative (14S). 

Staff $100,000 $5,900 $16,800 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
I-15 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualiz

Cost 

Subtotal Staff Alternative (this table) 

 $1,755,100 $357,700 $549,100 

Subtotal Staff Alternative (IPC table) 

$16,953,900 $1,046,000 $2,896,40

 Total Staff Alternative $18,709,000 $1,403,700 $3,445,50

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Table I-7. Developmental analysis of new cultural resources measures included in the Staff Alternative. 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualiz

Cost 

AMC-FS-25 Revised Preliminary FS Condition 25—in 

consultation with the FS, BLM, SHPOs and tribes, finalize a Historic Properties Management Plan (HPMP) for cultural resources within the area of potential effect (APE) for the project (19S). 

Idaho Power $0 $800 $800 

BPT-15 Establish a Cultural Resources Task Force that 

adds an oversight committee (27S). 

BPT $0 $1,000 $1,000 

Staff-CR-1 Renew, within a specified time frame, the offer to 

fund oral histories for the Shoshone-Bannock and Shoshone-Paiute Tribes (16S). 

Staff $0 $7,600 $7,600 

Staff-CR-2 Within 1 year of license issue, develop monitoring 

plan for archaeological sites, rock art and TCPs in consultation with the tribes, SHPOs, Forest Service and BLM and file with the Commission (17S). 

Staff $0 $2,300 $2,300 

Staff-CR-3 Within 1 year of license issue, in consultation with 

the tribes, SHPOs, Forest Service, and BLM, develop an implementation plan for Study 8.4.7, Effects of Reservoir Water Level Fluctuations on Cultural Resources, which Idaho Power deferred, in consultation with the CRWG, until the monitoring plan was implemented. File with the Commission (18S). 

Staff $0 $1,900 $1,900 

Staff-CR-5 Expand monitoring program to cover all known 

historic properties in the project APE (20S). 

Staff $0 $185,500 $185,50

Staff-CR-6 Develop and implement a program to re-evaluate 

buildings and structures within the project boundary as they reach 50 years old (20S). 

Staff $0 $3,000 $3,000 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
I-18 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualiz

Cost 

Staff-CR-7 Provision for review, and as necessary revision, of 

the HPMP, in consultation with the SHPOs, tribes, Forest Service and BLM every 6 years over the license term (19S). 

Staff $0 $1,700 $1,700 

Subtotal Staff Alternative (this table) 

 $0 $203,800 $203,800 

Subtotal Staff Alternative (IPC table) 

$77,000 $323,700 $332,100 

 Total Staff Alternative $77,000 $527,500 $535,900 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
I-19 

Table I-8. Developmental analysis of new recreation measures included in the Staff Alternative. 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized Cos

Interior-6 Prepare a Comprehensive Recreational 

Plan (21S). 

Interior $70,000 $0 $7,600 

FS-21 Design, construct, and maintain facility 

enhancements at the Hells Canyon Creek Launch Site and Visitor Center (21Sf). 

FS $275,000 $10,000 $36,100 

Interior-8 Develop a Project Boat Moorage Plan 

(45P). 

Interior $0 $5,000 $5,000 

Interior-9 Develop an enhancement plan for the 

BLM sites referred to as Airstrip A&B, Bob Creek section C, and Westfall (59P, 62P, and 63P) 

Interior $0 $4,600 $4,600 

Interior-10 Develop an enhancement plan for the 

BLM Swedes Landing site (70P) 

Interior $0 $5,000 $5,000 

Interior-11 Develop an enhancement plan for the 

BLM Spring recreation site (71P). 

Interior $0 $5,000 $5,000 

Interior-12 Portion of revised Interior condition 12–

Steck recreation site improved communication system (21Sb). 

Interior, 

staff 

$35,000 $0 $3,800 

Interior-13 Develop an enhancement plan for the 

BLM site referred to as Jennifer’s Alluvial Fan Site (21Sd). 

Interior $50,000 $5,000 $9,800 

Interior-14 Develop an Idaho Dispersed Sites Plan 

(49P). 

Interior $200,000 $50,000 $69,000 

Interior-15 Develop an enhancement plan for the 

BLM site referred to as Carter’s Landing and Oxbow Boat Launch (65P and 66P). 

Interior $10,000 10,000 

Interior-16 Revised Interior Condition 16—develop 

site plan for minor improvements and monitor the need for a higher level of development at the BLM site referred to as 

Interior $50,000 $0 $4,400 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
I-20 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized Cos

Oasis through the Recreation Adaptive Management Plan during the license term (21Sa). 

Interior-17 Develop an enhancement plan for the 

BLM site referred to as Copper Creek (57P). 

Interior $0 $5,000 $5,000 

Interior-18 Develop a Low-Water Boat Launch Plan 

As modified by staff to lessen layers of decision-making authorities reduces the number of steps in consultation processes (70P). 

Interior $0 $5,000 $5,000 

Interior-32b As part of the warmwater fisheries plan 

(Interior-32a), describe relationship between the timing of reservoir level fluctuations and the ability to access and launch boats at existing Idaho Power boat ramps, and satisfy reservoir-level requirements of Baker County Settlement Agreement (7Pb) 

Interior $0 $0 $0 

NMFS-20 Design and construct an anadromous fish 

interpretive display located at a mutually agreeable location near Brownlee dam (47P). 

NMFS $8,000 $500 $1,400 

ODFW-79 Hells Canyon Park Consultation—ODFW 

(58P) 

ODFW $0 $0 $0 

OPRD-2 Sediment Maintenance Plan for Farewell 

Bend State Park–OPRD (21Sc). 

OPRD $2,000 $4,000 $4,200 

OSMB-6 I&E Plan (47P) OSMB $0 $0 $0 

Interior-7 Implement Litter and Sanitation Plan as 

modified by staff to include the service schedule and include floating restrooms only where the need is confirmed through consultation (46P). 

Interior $120,000 $55,000 $66,800 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
I-21 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized Cos

As part of the Recreation Plan, consult with the Corps, NPPVA, the Forest Service, and other interested parties to prepare and implement a Navigation Plan that addresses non-flow measures, including installation of additional stream gages, downstream of Hells Canyon dam (108S) 

Staff 160,000 20,000 36,300 

Subtotal Staff Alternative (this table) 

 $970,000 $184,100 $279,000 

Subtotal Staff Alternative (IPC table) 

$9,929,800 $358,900 $1,207,900 

 Total Staff Alternative $10,899,800 $543,000 $1,486,900 

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Table I-9. Developmental analysis of new land use and aesthetic resources measures included in the Staff Alte

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

To

Annua

Co

ST-LM-1 Expand the HCRMP by creating the following maps: 

map of roads for which Idaho Power should be responsible for within the HCRMP. Maps will be made available to the public as part of the I&E program that include 1) roads and important resource areas and areas of high wildlife collisions, and 2) land and water use (72P). 

Staff $15,000 $0 $1,5

ST-LM-2 Create oversight and Resource Technical Advisory 

Committees (27S). 

Staff $0 $50,000 $50,

FS-1 Coordinate with BLM and FS concerning activities on 

their lands (25S). 

FS $0 $1,000 $1,0

FS-2 Prepare and implement a Resource Coordination Plan 

as modified by staff to limit scope to Forest Service lands in the project boundary (24S). 

FS $10,000 $5,000 $6,

Interior-1 Follow BLM requirements for Idaho Power activities 

on or affecting BLM-administered lands as modified by staff to limit the scope to activities on BLM land and permit more flexibility in timing (25S). 

Interior $40,000 $0 $4,4

Interior-2 Commencing five years after a new license is issued 

and unless otherwise provided, the Licensee shall prepare and submit an annual, written report summarizing progress on implementing articles of the license that affect recreation, cultural, aquatic, and terrestrial resources administered by BLM on BLM lands within and adjacent to the Project boundary. 

Interior $5,000 $5,0

Interior-25 Develop a Visual Resource Management Plan for 

project facilities to address the design, maintenance, and construction of project facilities (both existing and future facilities) in order to preserve or enhance visual resource values in the project area (22S). 

Interior $25,000 $0 $2,5

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
I-24 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

To

Annua

Co

Interior-30 Modify the Project boundary to include all of the land 

within the Airstrip, Steck Park, Swedes Landing, and Westfall recreation sites (23S). 

Interior $10,000 $0 $1,0

ODFW-76 Develop a road management plan (81P). ODFW $10,000 $0 $1,OSMB-3 Facilitate biannual law enforcement proceedings (81P). OSMB $0 $5,000 $5,0

Subtotal Staff Alternative (this table) 

 $110,000 $66,000 $77,

Subtotal Staff Alternative (IPC table) 

$840,000 $83,000 $166

 Total Staff Alternative $950,000 $149,000 $244

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
APPENDIX J 

DEVELOPMENTAL ANALYSIS OF MANDATORY MEASURES THAT ARE NOT 

INCLUDED IN THE STAFF ALTERNATIVE 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
Document Accession #: 20070831-4002 Filed Date: 08/31/2007
J-1 

Table J-1. Developmental analysis of new sediment transport measures specified by agencies, but not included 

[Agencies did not specify any mandatory sediment transport measures that were not included by sta

Table J-2. Developmental analysis of new water quality measures specified by agencies, but not included by s

[Agencies did not specify any new water quality measures that were not included by staff] 

Table J-3. Developmental analysis of new operational measures specified by agencies, but not included by sta

[Agencies did not specify any new operational measures that were not included by staff] 

Table J-4. Developmental analysis of new aquatic resources measures specified by agencies, but not included 

[Agencies did not specify any new aquatic resources measures that were not included by staff] 

Table J-5. Developmental analysis of new hatchery measures specified by agencies, but not included by staff. 

[Agencies did not specify any new hatchery measures that were not included by staff] 

Table J-6. Developmental analysis of new terrestrial resources measures specified by agencies, but not include

[Agencies did not specify any new terrestrial resources measures that were not included by staff] 

Table J-7. Developmental analysis of new cultural resources measures specified by agencies, but not included 

[Agencies did not specify any new cultural resources measures that were not included by staff] 

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J-3 

Table J-8. Developmental analysis of new recreation measures specified by agencies, but not included by staff

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comm

FS-20 Within one year of License 

issuance and over the remaining term of the License, the Licensee shall perform trail maintenance for several USDA Forest Service trails. 

FS $10,000 $10,000 

Total recreation measures not included by staff $0 $10,000 $10,000 

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Table J-9. Developmental analysis of new land use and aesthetic resources measures specified by agencies, bu

staff. 

Identifier Measure Entity Capital Cost 

Annualized 

O&M Cost 

Total 

Annualized 

Cost Comm

Interior-3 Develop an integrated Travel 

and Access Management Plan for BLM-administered lands affected by the project, which will be incorporated into the Comprehensive Recreation Management Plan and coordinated with the Integrated Wildlife Habitat Program and Wildlife Mitigation and Management Plan. 

Interior $50,000 $10,000 $15,100 Staff Estimate 

for the plan an$10,000 per yroad maintenaaddition to IPproposed $30year 

Interior-4 Within 5 years of license 

issuance or on an alternate 

schedule agreed to by BLM and the Licensee, the Licensee shall develop, and thereafter will begin implementation of, a Law Enforcement and Emergency Services Plan (LEESP) that includes provision for coordination and cooperative funding of law enforcement and emergency services personnel. 

Interior $50,000 $0 $5,100 Staff estimate

Total land use measures not included by staff $100,000 $10,000 $20,200 Total mandatory agency measures not included by staff (all categories) 

 $100,000 $20,000 $30,200 

Document Accession #: 20070831-4002 Filed Date: 08/31/2007
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Document Accession #: 20070831-4002 Filed Date: 08/31/2007
Document Content(s)

Report_Cover.PDF ...............................................1

Cover_Letter.PDF ...............................................3

Cover_Sheet.PDF ................................................5

Table_of_Contents.PDF ..........................................9

Executive_Summary.PDF .........................................35

Section_1_Purpose_of_Action_and_Need_for_Power.PDF ............53

Section_2_Proposed_Action_and_Alternatives.PDF ................54

Section_3_Environmental_Analysis.PDF ..........................55

Section_4_Developmental_Analysis.PDF ..........................56

Section_5_Staff's_Conclusions.PDF .............................67

Section_6_Literature_Cited.PDF ...............................219

Section_7_List_of_Preparers.PDF ..............................251

Section_8_List_of_Recipients.PDF .............................253

Appendix_A.PDF ...............................................257

Appendix_B.PDF ...............................................279

Appendix_C.PDF ...............................................468

Appendix_D.PDF ...............................................517

Appendix_E.PDF ...............................................539

Appendix_F.PDF ...............................................557

Appendix_G.PDF ...............................................570

Appendix_H.PDF ...............................................611

Appendix_I.PDF ...............................................649

Appendix_J.PDF ...............................................675

Document Accession #: 20070831-4002 Filed Date: 08/31/2007