Final Environmental Impact Statement

For Hydropower License

Office of

Energy

Projects

February 2011

FERC/F-0237

Federal Energy

Regulatory

Commission

McCloud-Pit Hydroelectric Project

FERC Project No. 2106, California

Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426

FERC/F-0237

FINAL ENVIRONMENTAL IMPACT STATEMENT

FOR HYDROPOWER LICENSE

McCloud-Pit Hydroelectric Project—FERC Project No. 2106

Federal Energy Regulatory Commission

Office of Energy Projects

Division of Hydropower Licensing

888 First Street, NE

Washington, DC 20426

February 2011

FEDERAL ENERGY REGULATORY COMMISSION

WASHINGTON, DC 20426

OFFICE OF ENERGY PROJECTS

To the Agency or Individual Addressed:

Reference: Final Environmental Impact Statement

Attached is the final environmental impact statement (final EIS) for the

McCloud-Pit Project (Project No. 2106), located on the McCloud and Pit Rivers in Shasta

County, California.

This final EIS documents the view of governmental agencies, nongovernmental

organizations, affected Indian tribes, the public, the license applicant, and Federal Energy

Regulatory Commission (Commission) staff. It contains staff evaluations on the

applicant’s proposal and alternatives for relicensing the McCloud-Pit Project.

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

concerns relevant to the public interest. The final EIS will be part of the record from

which the Commission will make its decision. The final EIS was sent to the U.S.

Environmental Protection Agency and made available to the public on or about

February 25, 2011.

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

Branch, Room 2A, located at 888 First Street, N.E., Washington DC 20426. The EIS also

may be viewed on the internet at http://elibrary.ferc.gov. 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

COVER SHEET

a. Title: Relicensing the McCloud-Pit Hydroelectric Project, FERC Project

No. P-2106

b. Subject: Final Environmental Impact Statement

c. Lead Agency: Federal Energy Regulatory Commission

d. Abstract: On July 16, 2009, Pacific Gas and Electric (PG&E) filed an application

to relicense its 368-megawatt (MW) McCloud-Pit Hydroelectric

Project (P-2106). The McCloud-Pit Project is located on the McCloud

and Pit Rivers in Shasta County, California. The project consists of

three power developments (James B. Black, Pit 6, and Pit 7) and

generates an average of about 1,542.2 gigawatt-hours (GWh) annually.

The project occupies 1,651.4 acres of federal lands managed by the

U.S. Department of Agriculture.

The staff’s recommendation is to relicense the project as proposed,

with certain modifications and additional measures recommended by

the agencies.

e. Contact: Emily Carter

Federal Energy Regulatory Commission

Office of Energy Projects

888 First Street, NE

Washington, DC 20426

(202) 502-6512

f. Transmittal: This Environmental Impact Statement (EIS) prepared by the

Commission’s staff on the hydroelectric license application filed by

PG&E for the existing McCloud-Pit Hydroelectric Project

(FERC No. P-2106) is being made available to the public on or about

February 25, 2011, as required by the National Environmental Policy

Act of 1969.1

1 National Environmental Policy Act of 1969, amended (Public Law [Pub. L.]

91-190, 42 United States Code [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).
FOREWORD

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

Federal Power Act (FPA)2and the U.S. Department of Energy Organization Act,3is

authorized to issue licenses for up to 50 years for the construction and operation of nonfederal hydroelectric developments subject to its jurisdiction, on the necessary

conditions:

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

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

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

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

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

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

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

to in section 4(e)...4

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

as may be found necessary to provide for the various public interests to be served by the

project.5 Compliance with such conditions during the licensing period is required. The

Commission’s Rules of Practice and Procedure allow any person objecting to a licensee’s

compliance or noncompliance with such conditions to file a complaint noting the basis

for such objection for the Commission’s consideration.6

2

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

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

and the Energy Policy Act of 2005, Pub. L. 109-58 (2005).

3

Pub. L. 95-91, 91 Stat. 556 (1977).

4

16 U.S.C. §803(a) (2006).

5

16 U.S.C. §803(g) (2006).

6

18 Code of Federal Regulations (CFR) §385.206 (2010).
iii

TABLE OF CONTENTS

COVER SHEET ...................................................................................................................i

FOREWORD.......................................................................................................................ii

TABLE OF CONTENTS ...................................................................................................iii

LIST OF FIGURES...........................................................................................................vii

LIST OF TABLES............................................................................................................viii

ACRONYMS AND ABBREVIATIONS..........................................................................xii

EXECUTIVE SUMMARY................................................................................................. 1

1.0 INTRODUCTION ............................................................................................... 15

1.1 APPLICATION ................................................................................................... 15

1.2 PURPOSE OF ACTION AND NEED FOR POWER ........................................ 15

1.2.1 Purpose of Action.......................................................................................... 15

1.2.2 Need for Power.............................................................................................. 18

1.3 STATUTORY AND REGULATORY REQUIREMENTS................................ 18

1.3.1 Federal Power Act......................................................................................... 20

1.3.1.1 Section 18 Fishway Prescriptions........................................................... 20

1.3.1.2 Section 4(e) Conditions.......................................................................... 20

1.3.1.3 Alternative Conditions under the Energy Policy Act of 2005 ............... 20

1.3.1.4 Section 10(j) Recommendations ............................................................ 21

1.3.2 Clean Water Act............................................................................................ 22

1.3.3 Endangered Species Act................................................................................ 22

1.3.4 Coastal Zone Management Act..................................................................... 22

1.3.5 National Historic Preservation Act ............................................................... 23

1.3.6 California Environmental Quality Act.......................................................... 23

1.4 PUBLIC REVIEW AND COMMENT ............................................................... 25

1.4.1 Scoping.......................................................................................................... 25

1.4.2 Interventions.................................................................................................. 26

1.4.3 Comments on the Application....................................................................... 27

2.0 PROPOSED ACTION AND ALTERNATIVES................................................ 29

2.1 NO-ACTION ALTERNATIVE .......................................................................... 29

2.1.1 Existing Project Facilities ............................................................................. 29

2.1.1.1 James B. Black Development................................................................. 29

2.1.1.2 Pit 6 Development .................................................................................. 34

2.1.1.3 Pit 7 Development .................................................................................. 35

2.1.1.4 Existing Project Boundary...................................................................... 36

2.1.2 Project Safety ................................................................................................ 37

2.1.3 Existing Project Operation ............................................................................ 37

2.1.4 Existing Environmental Measures ................................................................ 38

2.2 APPLICANT’S PROPOSAL .............................................................................. 38

2.2.1 Proposed Project Facilities............................................................................ 38

2.2.1.1 McCloud Development .......................................................................... 38
iv

2.2.1.2 Pit 7 Afterbay Development................................................................... 39

2.2.2 Proposed Project Operation........................................................................... 40

2.2.3 Proposed Environmental Measures............................................................... 40

2.2.4 Modifications to the Applicant’s Proposal—Mandatory Conditions ........... 45

2.2.4.1 Section 4(e) Federal Land Management Conditions.............................. 45

2.2.4.2 Alternative 4(e) Conditions Pursuant to the Energy Policy Act of 200548

2.3 STAFF ALTERNATIVE..................................................................................... 51

2.4 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED

ANALYSIS.......................................................................................................... 59

2.4.1 Issuing a Non-Power License........................................................................ 59

2.4.2 Federal Government Takeover of the Project ............................................... 59

2.4.3 Project Retirement......................................................................................... 59

3.0 ENVIRONMENTAL ANALYSIS...................................................................... 61

3.1 GENERAL DESCRIPTION OF THE RIVER BASIN....................................... 61

3.2 SCOPE OF CUMULATIVE EFFECTS ANALYSIS......................................... 62

3.2.1 Geographic Scope ......................................................................................... 63

3.2.2 Temporal Scope............................................................................................. 63

3.3 PROPOSED ACTION AND ACTION ALTERNATIVES................................ 63

3.3.1 Geology and Soils ......................................................................................... 64

3.3.1.1 Affected Environment ............................................................................ 64

3.3.1.1.1 Geologic Setting ................................................................................. 64

3.3.1.1.2 Reservoir Shorelines........................................................................... 65

3.3.1.1.3 Project Reaches................................................................................... 71

3.3.1.2 Environmental Effects............................................................................ 76

3.3.2 Aquatic Resources......................................................................................... 89

3.3.2.1 Affected Environment ............................................................................ 89

3.3.2.1.1 Water Quantity ................................................................................... 89

3.3.2.1.2 Water Quality ...................................................................................107

3.3.2.1.3 Aquatic Biota....................................................................................117

3.3.2.2 Environmental Effects..........................................................................127

3.3.2.3 Cumulative Effects...............................................................................164

3.3.3 Terrestrial Resources...................................................................................167

3.3.3.1 Affected Environment ..........................................................................167

3.3.3.1.1 Vegetation ...........................................................................................167

3.3.3.1.2 Wildlife.............................................................................................172

3.3.3.2 Environmental Effects..........................................................................182

3.3.3.2.1 Vegetation ...........................................................................................182

3.3.3.2.2 Wildlife.............................................................................................197

3.3.4 Threatened and Endangered Species...........................................................218

3.3.4.1 Affected Environment ..........................................................................218

3.3.4.2 Environmental Effects..........................................................................221

3.3.5 Recreation Resources..................................................................................228

3.3.5.1 Affected Environment ..........................................................................228
v

3.3.5.2 Environmental Effects..........................................................................246

3.3.6 Cultural Resources ......................................................................................290

3.3.6.1 Affected Environment ..........................................................................290

3.3.6.2 Environmental Effects..........................................................................308

3.3.7 Land Use and Aesthetic Resources.............................................................320

3.3.7.1 Affected Environment ..........................................................................320

3.3.7.2 Environmental Effects..........................................................................330

3.4 NO-ACTION ALTERNATIVE ........................................................................340

4.0 DEVELOPMENTAL ANALYSIS....................................................................341

4.1 POWER AND ECONOMIC BENEFITS OF THE PROJECTS ......................341

4.1.1 Economic Assumptions...............................................................................341

4.1.2 Current Annual Costs and Future Capital Costs under the No-Action

Alternative ..................................................................................................342

4.2 COMPARISON OF ALTERNATIVES............................................................343

4.2.1 No-Action Alternative.................................................................................345

4.2.2 PG&E’s Proposed Action ...........................................................................345

4.2.3 Staff Alternative ..........................................................................................345

4.2.4 Staff Alternative with Mandatory Conditions.............................................345

4.3 COST OF ENVIRONMENTAL MEASURES.................................................346

4.3.1 Cost of Environmental Measures for the McCloud-Pit Project ..................346

4.3.2 Effect of Environmental Measures on Energy Generation .........................349

4.4 Comparison of Alternatives for PG&E’s Proposed Powerhouses ....................349

5.0 STAFF’S CONCLUSIONS...............................................................................351

5.1 COMPARISON OF EFFECTS OF PROPOSED ACTION AND

ALTERNATIVES .............................................................................................351

5.2 COMPREHENSIVE DEVELOPMENT AND RECOMMENDED

ALTERNATIVE................................................................................................360

5.2.1 Discussion of Key Issues ............................................................................369

5.3 UNAVOIDABLE ADVERSE EFFECTS.........................................................417

5.4 SUMMARY OF SECTION 10(j) RECOMMENDATIONS AND 4(e)

CONDITIONS...................................................................................................419

5.4.1 Fish and Wildlife Agency Recommendations ............................................419

5.4.2 Forest Service 4(e) Conditions....................................................................424

5.5 CONSISTENCY WITH COMPREHENSIVE PLANS....................................434

6.0 LITERATURE CITED......................................................................................437

7.0 LIST OF PREPARERS .....................................................................................443

8.0 LIST OF RECIPIENTS .....................................................................................445

APPENDIX A—STAFF RESPONSES TO COMMENTS ON THE DRAFT

ENVIRONMENTAL IMPACT STATEMENT..............................................................A-1

APPENDIX B—MCCLOUD-PIT PROJECT MITIGATION AND MONITORING

SUMMARY.................................................................................................................... .B-1
vi

APPENDIX C—CAPITAL AND ANNUAL COSTS OF MEASURES FOR THE

MCCLOUD-PIT PROJECT............................................................................................C-1

APPENDIX D—COMMISSION STAFF RECOMMENDED LICENSE

CONDITIONS.................................................................................................................D-1

APPENDIX EFOREST SERVICE 4(E) CONDITIONS............................................ E-1
vii

LIST OF FIGURES

Figure 1-1. McCloud-Pit Project, location map. (Source: PG&E, 2009a).................... 17

Figure 2-1. McCloud-Pit Project, system map. (Source: PG&E, 2009a)...................... 31

Figure 2-2. Schematic of the McCloud-Pit Project. ........................................................ 33

Figure 3-1. Historic median and mean daily reservoir storage for McCloud-Pit

Hydroelectric Project reservoirs, water years 1974athrough 2006. (Source:

PG&E 2009a)................................................................................................ 93

Figure 3-2. Existing and proposed recreation facilities at McCloud reservoir. (Source:

PG&E, 2009a).............................................................................................233

Figure 3-3. Existing and proposed recreation facilities at Iron Canyon reservoir.

(Source: PG&E, 2009a)..............................................................................236

Figure 3-4. Existing and proposed recreation facilities at Pit 7 reservoir and Pit 7

afterbay dam. (Source: PG&E, 2009a)......................................................238
viii

LIST OF TABLES

Table 1-1. Major statutory and regulatory requirements for the McCloud-Pit

Hydroelectric Project. ................................................................................... 19

Table 3-1. Distribution of erosion inventory sites for the McCloud reservoir and Lower

McCloud River study region. (Source: PG&E, 2009a).............................. 67

Table 3-2. Distribution of erosion inventory sites for the Iron Canyon reservoir and

dam study region. (Source: PG&E, 2009a)................................................ 70

Table 3-3. Distribution of erosion inventory sites for the Oak Mountain Road Study

Region. (Source: PG&E, 2009a) ................................................................ 75

Table 3-4. Distribution of erosion sites in the Lower Pit River Study Region. (Source:

PG&E, 2009a)............................................................................................... 75

Table 3-5. Reservoir and afterbay characteristics. (Source: Staff, based on

specifications provided in PG&E, 2009a) .................................................... 91

Table 3-6. Current required releases to Lower McCloud River and Iron Canyon Creek.

(Source: Adapted by staff, from PG&E, 2009a) ......................................... 94

Table 3-7. Mean, minimum, and maximum unimpaired flows in the McCloud River

above McCloud reservoir for water years 1974–2006 (USGS gage

11367500/MC-3); all flows are unimpaired at this location. (Source: PG&E

2009)............................................................................................................. 95

Table 3-8. Mean, minimum, and maximum regulated flows in the McCloud tunnel for

water years 1974–2006 (USGS gage 11367720/MC-8); all flows are

regulated at this location. (Source: PG&E 2009a) ..................................... 96

Table 3-9. Mean, minimum, and maximum regulated and unimpaired flows in the

McCloud River at the McCloud dam for water years 1974–2006 (USGS

gage 11367760/MC-7, synthesized unimpaired hydrology data). (Source:

PG&E 2009a)................................................................................................ 97

Table 3-10. Mean, minimum, and maximum regulated and unimpaired flows in the

McCloud River at Ah-Di-Na for water years 1974–2006 (USGS gage

11367800/MC-1, synthesized unimpaired hydrology data). (Source: PG&E

2009a) ........................................................................................................... 98

Table 3-11. Mean, minimum, and maximum regulated and unimpaired flows in the

McCloud River above Shasta Lake for water years 1974–2006 (USGS gage

11368000/MC-5, synthesized unimpaired hydrology data). (Source: PG&E

2009a) ........................................................................................................... 99

Table 3-12. Mean, minimum, and maximum regulated and unimpaired flows in Iron

Canyon Creek at Iron Canyon dam for water years 1974–2006 (USGS gage

11363930/MC-10, synthesized unimpaired hydrology data). (Source:

PG&E 2009a)..............................................................................................100

Table 3-13. Mean, minimum, and maximum regulated and unimpaired flows in the

Pit River below the Pit 5 dam for water years 1974–2006 (USGS gage
ix

11363000/PH-27, synthesized unimpaired hydrology data). (Source: PG&E

2009a) .........................................................................................................101

Table 3-14. Mean, minimum, and maximum regulated and unimpaired flows at the Pit 5

powerhouse for water years 1974–2006 (USGS gage 11362700/PH-69); all

flows are regulated at this location. (Source: PG&E 2009a)....................102

Table 3-15. Mean, minimum, and maximum regulated and unimpaired flows in the

Pit River at the Pit 7 dam for water years 1974–2006 (USGS gage

11365000/PH-47, synthesized unimpaired hydrology data). (Source: PG&E

2009a) .........................................................................................................103

Table 3-16. Mean, minimum, and maximum regulated and unimpaired at the James B.

Black powerhouse for water years 1974–2006 (USGS gage

11363910/MC-11); all flows are regulated at this location. (Source: PG&E

2009a) .........................................................................................................104

Table 3-17. Mean, minimum, and maximum regulated and unimpaired at the Pit 6

powerhouse for water years 1974–2006 (USGS gage 11364150/PH-63); all

flows are regulated at this location. (Source: PG&E 2009a)....................105

Table 3-18. Mean, minimum, and maximum regulated and unimpaired at the Pit 7

powerhouse for water years 1974–2006 (USGS gage 11364480/PH-64); all

flows are regulated at this location. (Source: PG&E 2009a)....................106

Table 3-19. Water quality objectives to support designated beneficial uses in the project

area. (Source: PG&E, 2009a) ....................................................................108

Table 3-20. Fish species documented in the McCloud-Pit Project reservoirs. ..............122

Table 3-21. Average monthly flow (cfs) by water year type for 1994-2006 at Ah-Di-Na

(MC-1). .......................................................................................................125

Table 3-22. Minimum flows proposed, specified, or recommended for gage MC-7 below

McCloud dam (USGS gage 11367760) by PG&E, the Forest Service,

California Fish and Game, and NMFS. (Source: Staff) ...........................130

Table 3-23. Minimum flows proposed, specified, or recommended for gage MC-10

below Iron Canyon dam (USGS gage 11363930). (Source: Staff) ..........135

Table 3-24. Minimum flows proposed, specified, or recommended for gage PH-47

below Pit 7 dam (USGS gage 11365000). (Source: Staff).......................136

Table 3-25. Minimum flows proposed by the Forest Service, California Trout, Trout

Unlimited, and McCloud River Club for gage MC-7 below McCloud dam

(USGS gage 11367760). Specified flow increases are relative to flows

specified in table 3-22 for the same date interval. Variations from Forest

Service condition 19 are indicated in bold. (Source: Staff)......................137

Table 3-26. Minimum flows (cfs) proposed by the McCloud RiverKeepers for gage MC7 below McCloud dam (USGS gage 11367760) and for gage MC-1 at AhDi-Na (USGS gage 11367800) compared to revised Forest Service condition

19 and PG&E alternative condition 19. (Source: Staff)............................138

Table 3-27. Flows proposed, specified, or recommended at McCloud dam by American

Whitewater. (Source: Staff)......................................................................139
x

Table 3-28. Winnemem Wintu Tribe summer flow proposal to be achieved by 2015;

flows consistent with upper range of NMFS recommendations (table 3-22).

(Source: Staff)............................................................................................139

Table 3-29. Stage (feet) to discharge (cfs) conversion for Ah-Di-Na gage. (Source:

Staff) ...........................................................................................................149

Table 3-30. Recreation Facilities at McCloud Reservoir. (Source: PG&E, 2009a and

2008b, and staff).........................................................................................232

Table 3-31. Recreation facilities at Iron Canyon reservoir. (Source: PG&E, 2009a and

2008b, and staff).........................................................................................235

Table 3-32. Primary activity by general area within the project. (Source: PG&E, 2008d,

as modified by staff)...................................................................................240

Table 3-33. Project study area current use estimates by month using observation method.

(Source PG&E, 2008d, as modified by staff).............................................241

Table 3-34. Change in Number of Whitewater Boating Days (500-1,500 cfs) for

Alternative Flow Recommendations Compared to No-action Alternative.

(Source: Staff)............................................................................................252

Table 3-35. Change in Number of Optimal Fishing Days (210-375 cfs) for Alternative

Flow Recommendations Compared to No-action Alternative. (Source:

Staff) ...........................................................................................................253

Table 3-36. Change in Number of Acceptable Fishing Days (200-475 cfs) for Flow

Alternative Recommendations Compared to No-action Alternative. (Source:

Staff) ...........................................................................................................254

Table 3-37. Archaeological and historic-era resources located on McCloud River Club

lands within the McCloud River Expanded APE. (Source: PG&E, 2009d;

Berryman, 1999).........................................................................................299

Table 3-38. Previously recorded archaeological and historic-era resources that were not

relocated during Archaeological field survey. (Source: PG&E, 2009d)..300

Table 3-39. Documented archaeological and historic-era resources located within the

APE. (Source: PG&E, 2009d) ...................................................................302

Table 3-40. Site-specific potential effects for archaeological and historic-era resources.

(Source: PG&E, 2010b).............................................................................313

Table 3-41. Project roads. ..............................................................................................325

Table 3-42. Summary of Shasta-Trinity National Forest VQO classifications and

guidelines for NFS lands within the project area or influenced by project

operations. (Source: PG&E, 2009a) ..........................................................330

Table 4-1. Staff assumptions for economic analysis of the McCloud-Pit Project.

(Source: Staff)............................................................................................342

Table 4-2. Summary of current annual costs and future costs under the no-action

alternative for the McCloud-Pit Project. (Source: PG&E, 2009a, staff)..343

Table 4-3. Summary of annual net benefits for the no-action alternative, proposed

action, staff alternative, and staff alternative with mandatory conditions for

the McCloud-Pit Project. (Source: Staff) .................................................344
xi

Table 4-4. Summary of annualized costs by resource area for measures included in the

proposed action, staff alternative, and staff alternative with mandatory

conditions for the McCloud-Pit Project.a(Source: Staff).........................347

Table 4-5. Summary of annualized costs by resource area for measures directly

associated with construction of proposed powerhouses under the proposed

action, staff alternative, and staff alternative with mandatory conditions for

the McCloud-Pit Project. (Source: Staff) .................................................348

Table 4-6. Summary of the effect of environmental measures on energy for the noaction alternative, proposed action, staff alternative, and staff alternative

with mandatory conditions for the McCloud-Pit Project. (Source: Staff) 349

Table 4-7. Summary of annual net benefits for the proposed powerhouses of the

McCloud-Pit Project. (Source: Staff) .......................................................350

Table 5-1. Comparison of alternatives for the McCloud-Pit Hydroelectric Project.

(Source: Staff)............................................................................................351

Table 5-2. Analysis of fish and wildlife agency section 10(j) recommendations for the

McCloud-Pit Hydroelectric Project. (Source: Staff) ................................421

Table 5-3. Forest Service 4(e) conditions for the McCloud-Pit Hydroelectric Project.

(Source: Forest Service, 2010a).................................................................425
xii

ACRONYMS AND ABBREVIATIONS

ABA Architectural Barriers Act

ADA Americans with Disabilities Act

Advisory Council Advisory Council on Historic Preservation

APE area of potential effects

APLIC Avian Power Line Interaction Committee

basin plan Water Quality Control Plan for the Sacramento

and San Joaquin River Basins

BLM Bureau of Land Management

BMP best management practice

°C degrees Celsius

California Boating California Department of Boating and

Waterways

California Fish and Game California Department of Fish and Game

California Water Board California State Water Resources Control Board

CDEC California Data Exchange Center

Central Valley Regional Water Board Central Valley Regional Water Quality Control

Board

CEQA California Environmental Quality Act

CFR Code of Federal Regulations

cfs cubic feet per second

Commission Federal Energy Regulatory Commission

CSU California State University

CWHR California Wildlife-Habitat Relationships

CZMA Coastal Zone Management Act

DO dissolved oxygen

draft EIS draft environmental impact statement

DWR California Department of Water Resources

EIR environmental impact report

EIS environmental impact statement

EPA U.S. Environmental Protection Agency

ESA Endangered Species Act

°F degrees Fahrenheit

FERC Federal Energy Regulatory Commission

final EIS final environmental impact statement

Forest Service U.S. Department of Agriculture − Forest

Service

FLA Final License Application

FPA Federal Power Act

FR Forest Road

FSORAG Forest Service Outdoor Recreation Accessibility

Guidelines
xiii

FSTAG Forest Service Trail Accessibility Guidelines

FWS U.S. Department of the Interior − Fish and

Wildlife Service

GIS geographic information system

GWh gigawatt-hour(s) (equals one million kilowatthours)

HCM Habitat Criteria Mapping

hp horsepower

IBM Individual Base Modeling

IFIM instream flow incremental methodology

ILP Integrated Licensing Process

Interior U.S. Department of the Interior

KOP key observation point

kV kilovolt(s)

kW kilowatt(s)

kWh kilowatt hour(s)

licensee Pacific Gas and Electric

LSR Late Successional Reserve

LWD large woody debris

msl mean sea level

MMI multimetric index

MOU memorandum of understanding

MVA megavolt-ampere

MW megawatt

MWh megawatt-hours

NA not applicable

National Register National Register of Historic Places

NEPA National Environmental Policy Act

NERC North American Electric Reliability Council

NFS National Forest System

NHPA National Historic Preservation Act

NMFS U.S. Department of Commerce, National

Oceanic and Atmospheric Administration,

National Marine Fisheries Service

NTU nephelometric turbidity unit(s)

OCAP BiOp NMFS Operations Criteria and Plan Biological

Opinion

O&M operation and maintenance

OHV off-highway vehicle

PA Programmatic Agreement

PAOT people-at-one-time

Park Service National Park Service

PG&E Pacific Gas and Electric
xiv

PHABSIM Physical Habitat Simulation Modeling

project McCloud-Pit Hydroelectric Project

Public Draft Recovery Plan Public Draft Recovery Plan for the

Evolutionarily Significant Units of Sacramento

River Winter-run Chinook Salmon and the

Distinct Population Segment of Central Valley

Steelhead

QA/QC quality assurance / quality control

RMO road management objective

RO runoff

ROD Record of Decision on Management of Habitat

for Late-Successional and Old-Growth Forest

Related Species within the Range of the

Northern Spotted Owl

ROS recreation opportunity spectrum

RPA Reasonable and Prudent Alternative

RV recreational vehicle

SHPO State Historic Preservation Officer

SMS Scenery Management System

TCP Traditional Cultural Property

TMDL total maximum daily load

Tribes Winnemem Wintu Tribe, Pit River Tribe, and

Redding Rancheria

TSS total suspended solids

U.S.C. United States Code

USGS U.S. Geological Survey

VAOT vehicles-at-one-time

VELB valley elderberry longhorn beetle

VQO visual quality objective

WECC Western Electricity Coordinating Council

WROS Water Recreation Opportunity Spectrum

WUA weighted usable area
1

EXECUTIVE SUMMARY

On July 16, 2009, Pacific Gas and Electric (PG&E) filed an application for a new

major license for its McCloud-Pit Hydroelectric Project, Project No. 2106 (project). The

368-megawatt (MW) project is located on the McCloud and Pit Rivers in Shasta County,

California, and consists of three power generating developments (James B. Black, Pit 6,

and Pit 7). These developments collectively include four reservoirs, three powerhouses,

five dams, two tunnels, an afterbay, and associated equipment and transmission facilities.

The project is described in more detail in section 2.1.1, Existing Project Facilities. The

project occupies 1,651.4 acres of federal lands managed by the U.S. Department of

Agriculture − Forest Service (Forest Service).

Proposed Action

To improve aquatic resources, PG&E proposes changes to existing operations,

including higher minimum instream flow releases in two project reaches: Lower

McCloud River and Iron Canyon Creek. In addition, PG&E proposes measures to protect

sensitive species and measures to maintain and enhance existing recreation opportunities

as well as to provide additional recreational facilities. Furthermore, PG&E proposes to

develop and/or implement the following plans: a Large Woody Debris (LWD)

Management Plan; an Erosion and Sediment Monitoring and Control Plan; a Gravel and

Coarse Sediment Monitoring Plan; a water quality and temperature monitoring plan; an

Aquatic Biological Monitoring and Management Plan; a Vegetation Management Plan; a

Terrestrial Management Plan; a Recreation Management Plan; a Project Sign and

Education Plan; a Historic Properties Management Plan (HPMP); a Road and

Transportation Facilities Management Plan; a Hazardous Substance Management Plan;

and a Visual Quality Management Plan. PG&E’s measures are described in more detail

in section 2.2, Applicant’s Proposal. Finally, PG&E proposes to construct a new

powerhouse at the base of McCloud dam and a powerhouse at Pit 7 afterbay dam, along

with associated transmission facilities.

Public Involvement and Areas of Concern

PG&E utilized the Federal Energy Regulatory Commission’s (FERC or the

Commission) Integrated Licensing Process (ILP) to prepare its license application. The

intent of the Commission’s pre-filing process under the ILP is to initiate public

involvement early in the project planning process and to encourage citizens,

governmental entities, Tribes, and other interested parties to identify issues and

information needs prior to an application being formally filed with the Commission.

As part of the pre-filing process, we distributed Scoping Document 1 to interested parties

on September 25, 2006, and issued a letter responding to comments made on Scoping

Document 1 on October 8, 2007. Scoping meetings were held in Redding, California, on

October 23 and 24, 2006. On December 1, 2009, after the final license application filing,

we requested comments, conditions, and recommendations in response to our notice of

application ready for environmental analysis.
2

The primary issues associated with relicensing the project are appropriate

minimum flows in project-affected reaches; assessment of project effects on special

status species; effects of any new minimum flow regime on angling, whitewater boating,

and reservoir-based recreation; assessment of project effects on recreation facilities; and

potential effects of project operation on water quality, aquatic habitat, and fish.

Draft Environmental Impact Statement

On July 31, 2010, we issued a draft Environmental Impact Statement (EIS) for the

McCloud-Pit Project that analyzed environmental impacts of PG&E’s proposal, as well

as the comments, conditions, and recommendations we received. We requested that

comments on the draft EIS be filed by September 28, 2010. In addition, we hosted two

public comment meetings September 9, 2010 in order to receive oral testimony on the

draft EIS recommendations. In appendix A of this final EIS, we summarize the written

and oral comments received; provide responses to those comments; and indicate, where

appropriate, how we have modified the text for the final EIS.

In its November 29, 2010, filing of modified section 4(e) conditions, the Forest

Service agrees in many cases with our recommendations in the draft EIS. Additionally,

in its November 24, 2010, filing, PG&E supports the modified Forest Service conditions,

except those pertaining to instream flows at McCloud dam (condition 19), road and

transportation facility management (condition 29), and recreation development

management (condition 30). In its filing, PG&E withdraws its alternative 4(e) conditions

except for conditions 19, 29, and 30.

After reviewing the comments on the draft EIS and the filings related to the

4(e) conditions, we have revised some of our recommendations for the final EIS. The

following recommendations differ from those in the draft EIS:

(1) PG&E should implement the Forest Service’s specified instream flows below

McCloud dam rather than those originally proposed by California Trout,

Trout Unlimited, and McCloud River Club;

(2) PG&E should file an annual report with the Commission on the activities of

the Interagency Fish Passage Steering Committee;

(3) PG&E should include modifications to some of the species-specific

monitoring schedules included in the draft Aquatic Biological Monitoring

Plan and draft Terrestrial Biological Management Plan that the Forest

Service submitted with its modified 4(e) conditions (Forest Service, 2010d,

Enclosure 3);

(4) PG&E should include additional parameters regarding the use of pesticides

and herbicides associated with future project operation and maintenance

(O&M) in the Vegetation and Invasive Weed Management Plan;
3

(5) If PG&E is unable to secure the use of the land at the Star City site for a

campground, PG&E should file a plan with the Commission for approval for

a different campground location at McCloud reservoir;

(6) PG&E should construct a new campground at the Gap Creek site for single

unit campsites; and

(7) PG&E should provide streamflow data from gage MC-7 in addition to gage

MC-1 and reservoir drawdown information to the public via its website on

the internet.

Finally, we no longer recommend that PG&E develop a plan to enhance angling

access to Iron Canyon Creek.

Alternatives Considered

This final EIS analyzes the effects of continued project operation and recommends

conditions for a new license for the project. In addition to PG&E’s proposal, we consider

two alternatives: (1) staff alternative, and (2) no action—continued operation with no

changes.

Staff Alternative

Under the staff alternative, the project would include most of PG&E’s proposed

measures and would be operated to maintain existing flows in the Pit 7 reach of the Pit

River, but would include higher instream flows than proposed by PG&E in the Lower

McCloud River bypassed reach and in the Iron Canyon Creek bypassed reach. The staff

alternative also includes the following measures:

 development and/or implementation of plans for gravel and coarse sediment

management, water quality and temperature monitoring, aquatic biological

monitoring, vegetation and invasive species management, terrestrial biological

management, recreation development and management, fish stocking, historic

properties management, and visual resources, with staff modifications;

 ramping rates to protect fish, macroinvertebrates, and foothill yellow-legged

frogs;

 O&M of gages to measure streamflows;

 foothill yellow-legged frog surveys; and

 real-time monitoring of water temperatures to assist in determining effects of

mudflows from Mud Creek on project waters in the Lower McCloud River.

The staff alternative is based in part on recommendations made by the Forest

Service, United States Department of Interior – Fish and Wildlife Service (FWS);

California Department of Fish and Game (California Fish and Game), California Trout,

Trout Unlimited, McCloud River Club, and American Whitewater. We include most, but

not all, of the section 4(e) conditions filed by the Forest Service in the staff alternative.
4

Project Effects

The project alters flows in the McCloud and Pit Rivers and Iron Canyon Creek via

water storage in four reservoirs and one afterbay, and diversion of flows to generate

power at three powerhouses. Existing and potential project effects resulting from the

current O&M of the McCloud-Pit Project include: the lack of LWD below McCloud

dam; trapped sediments behind McCloud dam resulting in a degraded aquatic habitat

below the dam; erosion and fine sediment delivery to stream channels; lower instream

flows due to water diversions; a lack of flow ramping during spill events; increased water

temperature, turbidity, and contaminants in project-stream reaches; introduction and

spread of invasive weed species; avian collision and electrocution at project transmission

lines; accessibility of project waters for recreational access (boating and angling);

potential adverse effects to historic properties; and decreased aesthetic values throughout

the project area.

In recognition of these existing and potential project effects, the table below

summarizes the measures proposed to mitigate these effects associated with the three

alternatives considered in this final EIS.

Resource No-Action

Alternative Proposed Action Staff Alternative

Generation 1,542.2 gigawatt-hours

(GWh)

1,524.3 GWh 1,502.2 GWh

Geology and

Soils

Continued removal of

LWD behind McCloud

dam

Prepare an LWD

Management Plan to

facilitate the placing of

LWD downstream of

McCloud dam

Same as proposed

action

Continue to maintain

roadways and

implement best

management practices

(BMPs) to reduce

sediment input to

project waters

Implement Erosion

and Sediment

Monitoring and

Control Plan to

minimize erosion

Same as proposed

action
5

Resource No-Action

Alternative Proposed Action Staff Alternative

Monitor gravel and

coarse sediment that

could benefit

downstream aquatic

habitat

The proposed action

plus implement a

Gravel and Coarse

Sediment Management

Plan to add 150 to

600 tonnes of gravel

and coarse sediment,

from Star City Creek

or other potential sites,

to the Lower McCloud

River periodically for

protection of geology

and soil resources

Aquatic

Resources

Provide existing

minimum flows in all

stream reaches

Higher minimum

instream flows below

McCloud and Iron

Canyon dams

Higher minimum

instream flows below

McCloud and Iron

Canyon dams

consistent with a more

natural spring

hydrograph
6

Resource No-Action

Alternative Proposed Action Staff Alternative

No ramping rates for

seasonal minimum

flow changes, but

upramping at

100 cubic feet per

second (cfs) per hour

prior to uncontrollable

spills at McCloud dam

Upramping at 100 cfs

per hour prior to

uncontrollable spills at

McCloud dam

Downramping at

150 cfs each 48 hours

at McCloud dam

during spills

controllable by valve

Maximum upramping

during controllable

spills at 200 cfs each

24 hours at McCloud

dam

Upramping and

downramping related

to testing of the flow

valve at Iron Canyon

dam in 20-cfs

increments

Move streamflow

measurements for

McCloud dam from

gage MC-1 to MC-7

Measure streamflow

compliance at two

compliance points

(MC-7 and MC-1)

No Aquatic Biological

Monitoring Plan

Implement an Aquatic

Biological Monitoring

Plan

Implement water

quality monitoring

plan

Same as proposed

action

File annual reports on

the reintroduction and

status of listed

salmonids in the

project area.
7

Resource No-Action

Alternative Proposed Action Staff Alternative

Terrestrial

Resources

Continue to implement

vegetation

management programs

around project

facilities

Implement Vegetation

Management Plan to

guide restoration using

native plants and

manage invasive plants

Implement BMPs to

protect wetlands

during construction of

McCloud transmission

line

Use native vegetation

during restoration of

areas disturbed by

project-related

activities

Implement a

Vegetation

Management Plan as

proposed under Forest

Service condition 25

with modifications to

include provision of

information to

managers regarding

sensitive species,

protection of culturally

significant plant

populations,

provisions for the use

of herbicides and

pesticides, and

implementation of

BMPs to protect

wetlands

Monitor bald eagle

territories

Implement Wildlife

Management Plan

Implement a

Terrestrial Biological

Management Plan as

proposed under Forest

Service condition 26

with modifications to

include monitoring

schedules and limited

operating periods

Prepare biological

evaluations for special

status species and

biological assessments

for threatened and

endangered species

prior to new

construction within the

project boundary
8

Resource No-Action

Alternative Proposed Action Staff Alternative

Implement Avian

Power Line Interaction

Committee (APLIC)

standards for

transmission lines to

minimize avian

collision and

electrocution hazards

Same as proposed

action

Threatened

and

Endangered

Species

Implement Valley

Elderberry Longhorn

Beetle (VELB)

Conservation Program

Same as no-action plus

conduct preconstruction surveys

for Pacific fisher and

to minimize effects on

northern spotted owl

Same as proposed

action

Recreation

Resources

Fund California Fish

and Game trout

stocking program

Continue funding to

California Fish and

Game for stocking

trout annually and to

evaluate fish stocking

program

Stock 60,000 pounds

of trout annually at the

project and develop

and implement a fish

stocking plan to

evaluate stocking

success at the project

Continue to operate

and maintain existing

recreational facilities

at the project

Develop and

implement Recreation

Development and

Management Plan to

include rehabilitation

and upgrades to

existing recreation

facilities, reservoir

water surface

management,

recreation monitoring,

and a Signage and

Education plan,

providing streamflow

information to the

public via the internet

Same as proposed

action but include

posting of streamflow

data at MC-7 on the

internet in addition to

MC-1, consultation

with American

Whitewater and

Friends of the River
9

Resource No-Action

Alternative Proposed Action Staff Alternative

Construct new day-use

area, reconstruct and

extend existing boat

ramp, and add parking

at Tarantula Gulch

Same as proposed

action but add lighting

at Tarantula Gulch

boat ramp

Provide a formal dayuse area and

campground at

McCloud reservoir at

Star City

Same as proposed

action

Conduct a feasibility

study to find a suitable

location for a floating

dock or pier and trail

at McCloud reservoir

and construct if

feasible

Same as proposed

action

Construct day-use

areas at McCloud

reservoir at Red Banks

and Tarantula Gulch

inlet

Same as proposed

action

Construct three access

points to McCloud

reservoir at Battle

Creek and on each side

of McCloud dam

Same as proposed

action

At McCloud and Iron

Canyon reservoirs,

assess and implement

closures of usercreated roads leading

to the shoreline of

McCloud and Iron

Canyon reservoirs, in

coordination with the

Forest Service

Same as proposed

action with inclusion

of trails and dispersed

use sites in the

assessment and

closures; expand to

include area inside

project boundary at

both McCloud and

Iron Canyon reservoirs
10

Resource No-Action

Alternative Proposed Action Staff Alternative

Construct a day-use

site and access trail

along the Lower

McCloud River, at the

base of McCloud dam

Same as proposed

action

Reconstruct Hawkins

Landing boat ramp and

campground and

provide additional

parking, restroom

facilities

Same as proposed

action

Conduct a site

evaluation and provide

three paved parking

areas along FR37N78

with shoreline access

points to Iron Canyon

reservoir

Same as proposed

action

Construct new boat

ramp and shoreline

access at Iron Canyon

reservoir

Same as proposed

action with the

inclusion of adding

lighting at the boat

ramp

Relocate (if feasible)

or reconstruct Deadlun

Campground if a

suitable location is

found

Reconstruct Deadlun

Campground to

provide double and

triple sites and

construct new

campground at Gap

Creek for single unit

campsites

Remove snow at Iron

Canyon dam boat

ramp and access road

when project

operations require

snow removal from

Oak Mountain Road

Same as proposed

action
11

Resource No-Action

Alternative Proposed Action Staff Alternative

Evaluate the feasibility

of constructing a

pedestrian shoreline

access trail at the

upper end of Pit 7

reservoir, downstream

of Pit 6 powerhouse

tailrace, and construct

if suitable location

found

Construct the

shoreline access trail

Conduct feasibility

assessment for

providing boat put-in

or boat hand- launch at

Montgomery Creek,

near the lower end of

Pit 7 reservoir, if not

feasible construct a

fishing access trail

with boat hand-launch

Conduct a site

evaluation to

determine the location

of a pedestrian

shoreline access trail

at the lower end of

Pit 7 reservoir with

paved parking and

construct this facility

Reconstruct Fenders

Flat day-use area

(above Pit 7 afterbay

dam) and boat ramp

Same as proposed

action

If the Pit 7 afterbay

powerhouse is

constructed, provide

access near the

proposed Pit 7 afterbay

powerhouse, and

provide parking at the

end of the powerhouse

access road or along

Fenders Ferry Road

Same as proposed

action
12

Resource No-Action

Alternative Proposed Action Staff Alternative

Develop and

implement Project

Patrol Plan to provide

project patrols

No requirement for

Project Patrol Plan,

patrols, or funding for

law enforcement

position

Cultural

Resources

Implement a final

HPMP

Implement the final

HPMP upon license

issuance

Continue employee

environmental training

and sensitivity

program

Continue employee

environmental training

and sensitivity

program as part of the

HPMP

Same as proposed

action

Provide program to

educate public about

cultural significance of

area (with assistance

from Pit River Tribe,

Winnemem Wintu

Tribe, and the Forest

Service)

Same as proposed

action

Land Use

and

Aesthetics

Continue to maintain

all project roads and

facilities

Develop and

implement a Road and

Transportation Facility

Management Plan for

project roads

Same as proposed

action plus revise

project boundary to

include all project

roads and existing

recreational facilities

Execute a separate

memorandum of

understanding (MOU)

with the Forest Service

for areas with shared

responsibility

Outside of licensing

proceeding
13

Resource No-Action

Alternative Proposed Action Staff Alternative

Continue to implement

the Spill Prevention,

Control, and

Countermeasures Plan

and the Hazardous

Materials Business

Plan

Same as no-action Same as no-action, but

file existing Spill

Prevention, Control,

and Countermeasures

Plan and Hazardous

Materials Business

Plan with the

Commission

Identify specific visual

quality mitigation

measures and develop

an implementation

schedule

Same as proposed

action

Develop and

implement a Fire

Response Plan

Same as proposed

action

Conclusions

Based on our analysis, we recommend licensing the project as proposed by PG&E,

with some staff modifications and additional measures (staff alternative), as described

previously under Alternatives Considered.

In section 4.2 of the EIS, Comparison of Alternatives, we compare the total project

cost of obtaining power from a likely alternative source of power in the region (annual

power value, table 4-3), for each of the alternatives identified above. Our analysis shows

that during the first year of operation under the no-action alternative the project produces

power at a cost of $23,102,000, or about $111,085,000 [$72.52/megawatt hours (MWh)]

less than the cost of alternative power. Under the applicant’s proposal, the project would

produce power at a cost of $33,291,000, or about $100,085,000 ($65.66/MWh) less than

the cost of alternative power. Under the staff-recommended alternative, the project

would produce power at a cost of $33,951,000, or about $97,492,000 ($64.90/MWh) less

than the cost of alternative power. With regards to PG&E’s proposed additional

generation units at McCloud dam and Pit 7 afterbay, we find that the cost of these new

units may exceed the potential power benefits; however, PG&E has not yet determined

the final size of the units and their hydraulic capacity. Until PG&E decides on the final

capacity of the units, we make no recommendation regarding the proposed additional

generation units.

We choose the staff alternative as the preferred alternative because:

(1) the project would provide a dependable source of electrical energy for the region
14

(1,502,200 megawatt-hours annually); (2) the project may save the equivalent amount of

fossil fueled generation and capacity, thereby continuing to help conserve non-renewable

energy resources and reduce atmospheric pollution; and (3) the recommended

environmental measures proposed by PG&E, as modified by staff, would adequately

protect and enhance environmental resources affected by the project. The overall

benefits of the staff alternative would be worth the cost of the proposed and

recommended environmental measures.
15

1.0 INTRODUCTION

1.1 APPLICATION

On July 16, 2009, Pacific Gas and Electric (PG&E) filed an application to

relicense its 368-megawatt (MW) McCloud-Pit Project (P-2106) with the Federal Energy

Regulatory Commission (FERC or Commission). The McCloud-Pit Project is located on

the McCloud and Pit Rivers in Shasta County, California, and consists of three existing

developments (James B. Black, Pit 6, and Pit 7; figure 1-1). Project features collectively

include two storage reservoirs (McCloud and Iron Canyon reservoirs), two regulating

reservoirs (Pit 6 and Pit 7 reservoirs), one afterbay (Pit 7 afterbay), two tunnels, three

powerhouses (James B. Black, Pit 6, and Pit 7 powerhouses), and associated equipment

and transmission facilities. PG&E proposes to construct two new generation facilities at

the base of McCloud dam (5 to 8 MW) and at the base of Pit 7 afterbay dam (10 MW),

including a transmission line. A portion of the route of the proposed McCloud

transmission line would cross about 5 miles of the southern portion of Siskiyou County.

The current license expires July 31, 2011. The average annual energy generation

(1979-2004) for James B. Black, Pit 6, and Pit 7 powerhouses is 656.3, 373.8, and

512.1 gigawatt-hours (GWh), respectively.

The project currently occupies 1,651.4 acres of federal lands, managed by the U.S.

Department of Agriculture − Forest Service (Forest Service). The proposed new

generation facilities would add about 45.4 additional acres within the project boundary,

of which about 4.6 acres would be federally-owned lands managed by the Forest Service.

1.2 PURPOSE OF ACTION AND NEED FOR POWER

1.2.1 Purpose of Action

The purpose of the McCloud-Pit Project is to continue to provide a source of

hydroelectric power. Therefore, under the provisions of the Federal Power Act (FPA),

the Commission must decide whether to issue a license to PG&E for the McCloud-Pit

Project and what conditions should be placed on any license issued. In deciding whether

to issue a license for a 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: (1) energy conservation; (2) the protection of,

mitigation of damage to, and enhancement of fish and wildlife (including related

spawning grounds and habitat); (3) the protection of recreational opportunities; and

(4) the preservation of other aspects of environmental quality.

Issuing a new license for the McCloud-Pit Project would allow PG&E to continue

to generate electricity at the project for the term of a new license, making electric power

from a renewable resource available to its customers.
16

This final environmental impact statement (EIS) assesses the effects associated

with operation of the proposed project, examines alternatives to the proposed project, and

makes recommendations to the Commission on whether to issue a new license, and if so,

recommends terms and conditions to become a part of any license issued.

In this EIS, we assess the environmental and economic effects of continuing to

operate the project: (1) as proposed by PG&E and (2) as proposed by PG&E with our

recommended measures (the staff alternative). We also consider the effects of the noaction alternative. Important issues that are addressed include appropriate minimum

flows in project-affected reaches, assessment of project effects on special status species,

effects of any new minimum flow regime on recreation, and potential effects of project

operation on water quality, aquatic habitat, fish, and recreational access.
17

Figure 1-1. McCloud-Pit Project, location map. (Source: PG&E, 2009a)
18

1.2.2 Need for Power

The project is located in the California-Mexico Power area of the Western

Electricity Coordinating Council (WECC). According to the North American Electricity

Reliability Corporation (NERC, 2009), which forecasts electrical supply and demand

nationally and regionally, summer total internal demands for the California-Mexico

Power area is projected to grow at an annual compound rate of 0.9 percent from 2009 to

2018. Annual energy use is projected to grow at an annual compound rate of 1.3 percent.

NERC forecasts that about 31,613 MW of capacity will be added to the CaliforniaMexico Power area of WECC over the project planning period (2009 – 2018). The

project could continue to meet part of the existing load requirements within a system in

need of resources. In addition, pursuant to California Senate Bill 1078 passed in

September 2002, the proposed new small hydro powerhouses may qualify as “eligible

renewable energy resources,” and could be used to help meet California’s Renewable

Portfolio Standard.

California’s principal energy agencies (the California Energy Commission,

California Public Utility Commission, and California Power Authority) developed a

common policy vision calling for: optimizing energy conservation and resource

efficiency; meeting new generation needs first with renewable energy resources and

distributed generation, then with clean fossil fuel generation; and improving the bulk

electricity transmission grid and distribution infrastructure. The California Energy

Commission projects that the statewide annual peak demand will grow an average of

1.35 percent between 2008 and 2018.

We conclude that power from the McCloud-Pit Project could continue to meet a

need for power in the WECC region in both the short- and long-term. The project

provides low-cost power that may displace non-renewable, fossil-fired generation and

contributes to a diversified generation mix. Displacing the operation of fossil-fueled

facilities may avoid some power plant emissions and creates an environmental benefit.

1.3 STATUTORY AND REGULATORY REQUIREMENTS

The license for the McCloud-Pit Project is subject to numerous requirements

under the FPA and other applicable statutes. Major regulatory and statutory requirements

are summarized in table 1-1 and described below.
19

Table 1-1. Major statutory and regulatory requirements for the McCloud-Pit

Hydroelectric Project.

Requirement Agency Status

Section 18 of the FPA

(fishway prescriptions)

U.S. Department of

Interior (Interior) – Fish

and Wildlife Service

(FWS); U.S. Department

of Commerce – National

Oceanic and Atmospheric

Administration, National

Marine Fisheries Service

(NMFS)

FWS reserved its authority to

prescribe fishways on

January 28, 2010. NMFS

reserved its authority on

January 29, 2010.

Section 4(e) of the FPA

(land management

conditions)

Forest Service

The Forest Service provided

conditions on January 29, 2010,

one revised condition on March

1, 2010, and modified

conditions on November 29,

2010.

Section 10(j) of the FPA

California Department of

Fish and Game

(California Fish and

Game); NMFS

On January 29, 2010, NMFS

provided section 10(j)

recommendations. California

Fish and Game provided

recommendations on

February 2, 2010.

Clean Water Act water

quality certification

California State Water

Resources Control Board

(California Water Board)

PG&E filed an application for

water quality certification with

the California Water Board on

January 27, 2010. PG&E

withdrew that application and

simultaneously re-filed its

application by letter dated

January 5, 2011. Certification

due by January 5, 2012.
20

Requirement Agency Status

Endangered Species Act

(ESA) consultation FWS

We requested concurrence from

FWS on our “not likely to

adversely affect” determination

on listed species under its

jurisdiction. On

December 21, 2010, FWS filed

a letter concurring with our

conclusions presented in the

EIS.

Coastal Zone

Management Act

consistency

California Coastal

Commission

Relicensing the project would

not influence resources in the

designated coastal zone.

1.3.1 Federal Power Act

1.3.1.1 Section 18 Fishway Prescriptions

Section 18 of the FPA states that the Commission is to require construction,

operation, and maintenance by a licensee of such fishways as may be prescribed by

the secretaries of Commerce or Interior. By letter filed January 28, 2010, the U.S.

Department of the Interior (Interior) requested that a reservation of authority to prescribe

fishways be included in any project license for the McCloud-Pit Project. NMFS filed a

request for reservation of authority on January 29, 2010.

1.3.1.2 Section 4(e) Conditions

Section 4(e) of the FPA 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. The Forest Service filed 34

section 4(e) conditions for the McCloud-Pit Project on January 29, 2010, and one revised

condition on March 1, 2010. The Forest Service filed modified 4(e) conditions on

November 29, 2010. These conditions are described under section 2.2.4, Modifications

to the Applicant’s Proposal—Mandatory Conditions, summarized in table 5-3, analyzed

in the appropriate resource sections of section 3, Environmental Analysis, and discussed

in section 5, Staff’s Conclusions.

1.3.1.3 Alternative Conditions under the Energy Policy Act of 2005

The Energy Policy Act of 2005 provides parties to this licensing proceeding the

opportunity to propose alternatives to 4(e) conditions. No trial-type hearings were
21

requested, but PG&E provided 16 alternative 4(e) conditions and California Trout, Trout

Unlimited, and McCloud River Club provided one alternative condition.7 On

November 24, 2010, PG&E withdrew 13 of its alternative 4(e) conditions in full and one

alternative condition in part. We discuss these alternative conditions in the appropriate

resource analysis sections of this EIS and in section 2.2.4.2, Alternative 4(e) Conditions

Pursuant to the Energy Policy Act of 2005. We discuss our conclusions in section 5,

Staff’s Conclusions.

1.3.1.4 Section 10(j) Recommendations

Under section 10(j) of the FPA, each hydroelectric license issued by the

Commission must 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, unless it determines that they are inconsistent

with the purposes and requirements of the FPA or other applicable law. Before rejecting

or modifying an agency recommendation, the Commission is required to attempt to

resolve any such inconsistency with the agency, giving due weight to the

recommendations, expertise, and statutory responsibilities of such agency.

On January 29, 2010, NMFS filed 12 recommendations under section 10(j) for the

McCloud-Pit Project. California Fish and Game filed three recommendations on

February 2, 2010. In the draft EIS, we made a preliminary determination that 10 of the

recommendations made by NMFS and two of the recommendations made by California

Fish and Game were within the scope of section 10(j). Of those 12 recommendations, we

adopted three and partially adopted one. We did not adopt the remaining eight

recommendations made by NMFS because they may be inconsistent with the

comprehensive planning standard of section 10(a) and the equal consideration provision

of section 4(e) of the FPA.

Commission staff held a 10(j) meeting with NMFS in Sacramento, California, on

November 17, 2010, in an attempt to resolve these preliminary inconsistencies.

California Fish and Game did not request its own 10(j) meeting; however, the agency

attended the November 17, 2010, meeting.

We summarize these recommendations in table 5-1, analyze them in the

appropriate resource sections in section 3, Environmental Analysis, and present our

7 McCloud RiverKeepers, American Whitewater, and Friends of the River also

filed alternative conditions; however, in its September 27, 2010, letter, the Forest Service

stated that because these filings occurred after the March 18, 2010, deadline for filing

alternative conditions, these filings should not be classified as alternative condition

filings to the Forest Service’s preliminary section 4(e) conditions. As such, in this final

EIS, we discuss and analyze these recommendations in section 3.3.2, Aquatic Resources,

and present our conclusions in section 5, Staff’s Conclusions.
22

conclusions in section 5, Staff’s Conclusions. We also discuss and address the agency

recommendations in section 5.4.1, Fish and Wildlife Agency Recommendations.

1.3.2 Clean Water Act

Under section 401 of the Clean Water Act, a license applicant must obtain

certification from the appropriate state pollution control agency verifying compliance

with the Clean Water Act. By letter dated January 27, 2010, PG&E submitted its

application for water quality certification to the California Water Board. By letter dated

February 26, 2010, the California Water Board documented receipt of the application on

January 27, 2010.

By letter filed September 22, 2010, the California Water Board notes that while it

has 1 year to act on an application for water quality certification, all of the information

necessary for it to act on the application must be submitted, and environmental

documents necessary to comply with the California Environmental Quality Act (CEQA)

must be finalized. By letter dated October 27, 2010, PG&E filed a reply to the California

Water Board’s comments. Additionally, by letter dated January 5, 2011, PG&E

withdrew its original application for water quality certification and simultaneously refiled its application. Consequently, the water quality certification is due by

January 5, 2012.

1.3.3 Endangered Species Act

Section 7 of the ESA requires federal agencies to ensure that their actions are not

likely to jeopardize the continued existence of endangered or threatened species or result

in the destruction or adverse modification of the critical habitat of such species. Four

federally-listed species have the potential to occur in the project vicinity: northern

spotted owl, valley elderberry longhorn beetle (VELB), California red-legged frog, and

Pacific fisher. Our analyses of project effects on threatened and endangered species are

presented in section 3.3.4, Threatened and Endangered Species, and our

recommendations in section 5.2, Comprehensive Development and Recommended

Alternative.

In the draft EIS, we concluded that relicensing of the McCloud-Pit Project, as

described under the staff alternative, would have no effect on the California red-legged

frog and would not likely adversely affect the VELB, Pacific fisher, and northern spotted

owl. On August 6, 2010, we issued a letter seeking concurrence from FWS on this

determination, indicating that the draft EIS would serve as our biological assessment of

the proposed licensing on listed species. On December 23, 2010, FWS filed a letter

concurring with our determination.

1.3.4 Coastal Zone Management Act

Under section 307(c)(3)(A) of the Coastal Zone Management Act (CZMA),

16 United States Code (U.S.C.) § 1456(3)(A), the Commission cannot issue a license for
23

a project within or affecting a state’s coastal zone unless the state CZMA agency concurs

with the license applicant’s certification of consistency with the state’s CZMA program,

or the agency’s concurrence is conclusively presumed by its failure to act within 180 days

of its receipt of the applicant’s certification.

The project is located in the Sierra Nevada Mountains and is not located within the

boundary of a designated Coastal Zone Management Program, which extends from a few

blocks to 5 miles inland from the sea (www.coastal.ca.gov), and relicensing the project

would not affect resources within the boundary of a designated coastal zone. Therefore,

the project is not subject to California coastal zone program review and no consistency

certification is needed. We provided a copy of the draft EIS to the California Coastal

Commission for review and received no comment from that agency.

1.3.5 National Historic Preservation Act

Section 106 of the National Historic Preservation Act (NHPA) 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 (TCPs), and objects significant in American history, architecture, engineering,

and culture that are eligible for inclusion in the National Register of Historic Places

(National Register).

To meet the requirements of section 106, the Commission intends to execute a

Programmatic Agreement (PA) with the California State Historic Preservation Officer

(SHPO) for the protection of historic properties from the effects of the operation of the

McCloud-Pit Hydroelectric Project. The terms of the PA, a draft of which was issued

August 26, 2010, ensure that PG&E addresses and treats all historic properties identified

within the project’s area of potential effects through the implementation of PG&E’s

Historic Properties Management Plan (HPMP).

1.3.6 California Environmental Quality Act

CEQA is the California counterpart to the National Environmental Policy Act

(NEPA). CEQA went into effect in 1970 for the purpose of monitoring land

development in California through a permitting process. This statute, enacted to protect

the health of the environment from current and future development, requires state and

local agencies to identify the significant environmental impacts of their actions and to

avoid or mitigate those impacts, if feasible. CEQA applies to all discretionary activities

proposed to be undertaken or approved by California state and local government

agencies. The California Water Board, which must act on PG&E’s request for water

quality certification for the project (see section 1.3.2, Clean Water Act), is the lead

agency under CEQA.

Under CEQA, an environmental impact report (EIR) is prepared when the public

agency finds substantial evidence that the project may have a significant effect on the

environment. An EIR is the public document used to analyze the significant
24

environmental effects of a proposed project, to identify alternatives, and to disclose

possible ways to reduce or avoid the possible environmental damage. CEQA guidelines

state that when federal review of a project is also required, state agencies are encouraged

to integrate the two processes to the fullest extent possible, which may include a joint

EIS/EIR. While this document is not a joint EIS/EIR, the California Water Board has the

opportunity to use this document, as appropriate, to satisfy its responsibilities under

CEQA. As such, we invited the California Water Board’s comments on the draft EIS as

they may pertain to the agency’s use of the final EIS for CEQA purposes. By letter dated

September 22, 2010, the California Water Board commented that its staff may rely on

sections of the EIS and additional analysis to comply with CEQA. The California Water

Board also noted that, for projects with less than significant environmental effects, a

negative declaration or mitigated negative declaration can be issued.

One element needed in an EIR, but not required by NEPA, is a discussion of a

program for monitoring or reporting on mitigation measures that were adopted or made

conditions of project approval. The monitoring or reporting program must ensure

compliance with mitigation measures during project implementation. The program may

also provide information on the effectiveness of mitigation measures. Although

discussion of the mitigation reporting or monitoring program can be deferred until the

final EIR or, in some cases, after project approval, it is often included in the draft EIR to

obtain public review and comment.

In section 3 of this EIS, Environmental Analysis, we describe each potential

environmental resource impact, our analysis of each recommended mitigation measure,

and our conclusion with respect to the effectiveness of each measure in addressing the

impact. In section 5.2, Comprehensive Development and Recommended Alternative, we

list the mitigation measures, and monitoring and reporting requirements we recommend

for inclusion in any license issued for the McCloud-Pit Project. Additionally, any

conditions of the water quality certification that may be issued for this project will

become an enforceable part of any license issued for this project. To specifically address

CEQA requirements with respect to mitigation monitoring, appendix B, McCloud-Pit

Project Mitigation and Monitoring Summary, identifies each potentially significant

impact of relicensing the McCloud-Pit Project, lists the project changes or mitigation

measures that are recommended for inclusion in a new license to avoid or reduce the

impact, and describes the monitoring and reporting measures PG&E would undertake to

ensure the project changes and mitigation measures are implemented as intended.

Another analysis required under CEQA but not required in an EIS is a description

of any growth-inducing effects caused by the project. For this relicensing, higher

minimum instream flows would translate to less annual power generation of the project.

A net reduction in power generation would not facilitate population growth or remove an

obstacle to growth. PG&E, however, also is proposing to construct new powerhouses at

the McCloud and Pit 7 afterbay dams, and associated transmission lines. Increased

power generation would facilitate population growth and remove a potential obstacle to

growth.
25

1.4 PUBLIC REVIEW AND COMMENT

The Commission’s regulations (18 Code of Federal Regulations [CFR] §5.1-5.16)

require that applicants consult with appropriate resource agencies, tribes, and other

entities before filing an application for a license. This consultation is the first step in

complying with the Fish and Wildlife Coordination Act, the ESA, the NHPA, and other

federal statutes. Pre-filing consultation must be complete and documented according to

the Commission’s regulations.

1.4.1 Scoping

Under the Commission’s regulations, issuing a licensing decision for any project

first requires preparation of either an environmental assessment or an EIS, in accordance

with NEPA. The preparation of an environmental assessment or EIS is supported by a

scoping process to ensure the identification and analysis of all pertinent issues. We

issued a notice of intent to prepare an EIS on December 1, 2009.

On September 25, 2006, the Commission issued Scoping Document 1 to enable

resource agencies; the Winnemem Wintu Tribe, Pit River Tribe, and Redding Rancheria

(Tribes); and other interested parties to more effectively participate in and contribute to

the scoping process. In Scoping Document 1, we requested clarification of preliminary

issues concerning the McCloud-Pit Project and identification of any new issues that

needed to be addressed. On October 8, 2007, we issued a letter responding to comments

made on Scoping Document 1.

We held two public scoping meetings regarding the project, on

October 23 and 24, 2006, in Redding, California. We issued notices for the scoping

meetings in a local newspaper and the Federal Register. Based on completion of sign-in

sheets at the scoping meetings, 25 individuals attended the October 23 evening scoping

meeting, and 32 individuals attended the October 24 morning scoping meeting. In

addition, we conducted an environmental site review of the project area on

September 19 and 20, 2006, and several of the individuals who also attended one or both

of the scoping meetings attended the site review. We also issued notices for the

environmental site review in a local newspaper and the Federal Register.

We requested that written comments regarding the project be filed with the

Commission by November 23, 2006. In addition to the oral comments received during

the scoping meetings, we received written scoping comments from the following entities:

Commenting entity Date of filing

Redding Rancheria November 13, 2006

PG&E November 20, 2006

National Park Service (Park Service) November 21, 2006
26

Commenting entity Date of filing

Forest Service November 21, 2006

California Fish and Game November 21, 2006

California Trout, Friends of the River, and Trout Unlimited November 22, 2006

Pit River Tribe November 24, 2006

California Water Board November 22, 2006

The Hearst Corporation November 24, 2006

Sierra Pacific Industries November 28, 2006

1.4.2 Interventions

On December 1, 2009, the Commission issued a public notice accepting the

application and soliciting motions to intervene. This notice set a 60-day period during

which interventions could be filed, ending February 1, 2010. The Commission also

solicited interventions in its July 30, 2010, public notice of the availability of the draft

EIS. This notice set a 60-day period during which interventions could be filed, ending

September 28, 2010. In response to these notices, the following entities filed motions to

intervene in this proceeding:

Entity Date of filing

California Fisheries and Water Unlimited December 3, 2009;

amended

December 4, 2009

Forest Service December 10, 2009

Anglers Committee December 10, 2009

Friends of the River and American Whitewater December 18, 2009

Winnemem Wintu Tribe December 22, 2009

California Salmon and Steelhead Association December 30, 2009

Center for Water Advocacy January 8, 2010

California Sportfishing Protection Alliance January 13, 2010

California Trout, Trout Unlimited, and Northern California

Council, Federation of Flyfishers

January 26, 2010

California Water Board January 28, 2010
27

Entity Date of filing

McCloud River Club January 28, 2010

Interior February 1, 2010

NMFS January 29, 2010

The Fly Shop January 29, 2010

McCloud RiverKeepers February 1, 2010

California Fish and Game February 1, 2010

Pit River Tribe February 8, 2010a

The Hearst Corporation February 16, 2010 a

a

Late intervention granted by Commission notice issued February 25, 2010.

1.4.3 Comments on the Application

On December 1, 2009, the Commission issued a Ready for Environmental

Analysis Notice and requested comments, recommendations, and terms and conditions

(subject to sections 4(e), 10(a), 10(j) and 18 of the FPA) with a filing deadline of

February 1, 2010.8The following entities filed comments, terms, conditions,

prescriptions, or recommendations:

Commenting entity Date of filing

Forest Service December 21, 2009

January 29, 2010 – filed one 4(e) condition

revised in part

California Fisheries and Water Unlimited January 19, 2010

FWS January 28, 2010

NMFS January 29, 2010

American Whitewater February 2, 2010

Winnemem Wintu Tribe February 1, 2010

California Fish and Game February 2, 2010

Forest Service March 1, 2010

PG&E March 3, 2010

8

Several comments were received after the filing deadline, but are still considered

in this EIS.
28

Commenting entity Date of filing

California Trout, Trout Unlimited, and

McCloud River Club

March 4, 2010

California Water Board March 8, 2010

The Hearst Corporation March 16, 2010

PG&E March 16, 2010

PG&E March 22, 2010

The Hearst Corporation March 22, 2010

American Whitewater and Friends of the

River

March 30, 2010

American Whitewater and Friends of the

River

March 31, 2010

McCloud RiverKeepers April 14, 2010

McCloud RiverKeepers April 22, 2010

PG&E April 23, 2010

Winnemem Wintu Tribe May 26, 2010

1.4.4 Comments on Draft Environmental Impact Statement

The Commission sent the draft EIS to the U.S. Environmental Protection Agency

(EPA) and made the draft available to the public on July 30, 2010. The Commission

requested that any comments on the draft EIS be filed by September 28, 2010. In

addition, the Commission held two public meetings in Redding, California, on September

9, 2010, to receive oral testimony on the draft EIS, and the transcripts from these

meetings were filed in the administrative record for the project. In appendix A, we

summarize the written and oral comments received; provide responses to those

comments; and indicate, where appropriate, how we have modified the text of the final

EIS.
29

2.0 PROPOSED ACTION AND ALTERNATIVES

2.1 NO-ACTION ALTERNATIVE

Under the no-action alternative, the McCloud-Pit Project would continue to

operate under the terms and conditions of the existing license, and no new environmental

protection, mitigation, or enhancement measures would be implemented. We use this

alternative to establish baseline environmental conditions for comparison with other

alternatives.

2.1.1 Existing Project Facilities

Located in the McCloud and Pit River drainages of Northern California, the

McCloud-Pit Project involves the transfer of water from the McCloud River basin to the

Lower Pit River basin. McCloud reservoir is located on the McCloud River, which

originates at Moosehead Creek, southwest of Mt. Shasta, and flows in a southwesterly

direction before entering Shasta Lake, a reservoir formed by the U.S. Department of

Interior – Bureau of Reclamation’s Shasta dam at the confluence of the Pit, Sacramento,

and McCloud Rivers. From McCloud reservoir, water is transferred via a tunnel to Iron

Canyon reservoir, which is located on Iron Canyon Creek, a tributary of the Pit River.

Water from Iron Canyon reservoir flows, via a tunnel, to the James B. Black powerhouse,

located on the Pit River, just downstream of PG&E’s Hat Creek and Pit 3, 4, 5 projects.

The water from the McCloud River drainage then enters the Pit River and travels through

the Pit 6 and Pit 7 developments before entering Shasta Lake. Although the project

diverts water from the McCloud River basin to the Lower Pit River basin, both basins

drain to Shasta Lake. The project is located entirely within the Sacramento River

Hydrologic Region of California and both drainages are located along the western slope

of the Cascade Range.

The McCloud-Pit Hydroelectric Project commenced commercial operation in

1965-1966. The project is composed of three hydroelectric developments: James B.

Black, Pit 6, and Pit 7, each of which is described below. During the period from 1979 to

2004, the developments have annually generated an average of 1,542 GWh of power,

respectively. The locations of the various facilities and features are presented in

figure 2-1, and a schematic of project facilities is provided in figure 2-2.

2.1.1.1 James B. Black Development

McCloud Dam and McCloud Reservoir

McCloud dam is a 241-foot-high, 630-foot-long earth- and rock-filled dam located

on the McCloud River that impounds McCloud reservoir. The McCloud reservoir has a

surface area of 520 acres and a maximum storage capacity of about 35,197 acre-feet. The

spillway (elevation 2,696.0 feet above mean sea level [feet msl]) is on the south side of

the dam. The reservoir has a normal maximum water surface elevation of 2,680 feet msl.

The dam’s spillway is equipped with three radial gates measuring 27 feet by 24.5 feet that
30

return spillage flows to the McCloud River. The dam also has a 7-foot-diameter

diversion/outlet tunnel that runs under the dam to a 24-inch Howell-Bunger valve for

releasing instream flows to the McCloud River, as well as an 84-inch-diameter butterfly

valve for emergency use to control reservoir levels. Controls for the diversion/outlet

tunnel are located at the intake within McCloud reservoir.

McCloud Tunnel

McCloud dam diverts flows from the McCloud River via a 7.2-mile-long lined and

unlined tunnel and a 563-foot-long pipeline section at Hawkins Creek crossing that

hydraulically links McCloud reservoir and Iron Canyon reservoir. An intake tower

within McCloud reservoir collects water for the McCloud tunnel, which is about 17 feet

in diameter, and heads southeasterly to Iron Canyon reservoir. The differential in water

surface elevations between the two reservoirs controls the amount of water drafted

through the tunnel. The McCloud tunnel diversion results in an approximately 24-milelong bypassed reach of the McCloud River, between the project reservoir and Shasta

Lake.
31

Figure 2-1. McCloud-Pit Project, system map. (Source: PG&E, 2009a)
32

Figure 2-1 (continued). McCloud-Pit Project, system map. (Source: PG&E, 2009a)
33

Figure 2-2. Schematic of the McCloud-Pit Project.
34

Iron Canyon Dam and Reservoir

A 214-foot-high and 1,130-foot-long earth-filled dam impounds Iron Canyon

Creek water to create Iron Canyon reservoir. The reservoir has a maximum storage

capacity of 24,241 acre-feet with about a 500-acre surface area. The dam has a slide gate

leading to a 48-inch-diameter pipe for instream flow releases to Iron Canyon Creek.

Normal maximum water surface elevation within the reservoir is 2,664 feet msl.

Iron Canyon Tunnel and Penstock

The 2.9-mile-long, 18-foot-diameter Iron Canyon tunnel diverts water from Iron

Canyon reservoir. An associated 1,194-foot-long, 11.5-foot-diameter pipeline at the

Willow Spring Creek crossing, and a 5,467-foot-long, 11.5-foot-diameter steel penstock

provides water to James B. Black powerhouse. The penstock bifurcates before James B.

Black powerhouse to deliver water flow to the two turbine generator units. The tunnel

and penstock have a total flow capacity of 2,000 cubic feet per second (cfs). The Iron

Canyon tunnel diversion results in an approximately 4-mile-long Iron Canyon Creek

bypassed reach leading to the Pit 6 reservoir.

James B. Black Powerhouse

James B. Black powerhouse is located on the northwest bank of the Pit River,

about 0.5 mile upstream of the Pit 5 powerhouse (FERC project no. 233). The

powerhouse is a three-level, reinforced-concrete structure containing two vertical shaft

impulse turbines rated at 104,000 horsepower (hp) each. They operate at a normal

maximum gross head of 1,226 feet. Two vertical axis outdoor generators, Unit 1 rated at

94.8 megavolt-ampere (MVA) and Unit 2 rated at 92.6 MVA, are connected to a

three-phase, 86-MVA transformer bank. Their combined maximum capacity is 172 MW.

Average annual generation within the past 25 years at the station is 656.3 GWh. Flows

discharge from this powerhouse via a tailrace leading directly from the generation units

to the Pit River.

Transmission

The primary transmission lines (230 kilovolt [kV]) extend about 0.5 mile from the

transformer bank in the switchyard adjacent to James B. Black powerhouse to the

switchyard adjacent to the non-project Pit 5 powerhouse.

2.1.1.2 Pit 6 Development

Pit 6 Dam and Reservoir

Pit 6 dam and reservoir are located on the Pit River downstream of James B. Black

powerhouse. The 183-foot-high, 560-foot-long concrete gravity Pit 6 dam has a crest

elevation of 1,432 feet msl. The top of the dam contains a trash rake, motors for two

42-foot-high by 49-foot-long slide gates, and a control building. The control building

houses a hydraulic system for two low-level 8-foot-diameter outlets at the base of the

dam. The Pit 6 reservoir has a maximum storage capacity of about 15,619 acre-feet and a

maximum surface area of about 268 acres. The normal maximum water surface elevation
35

of the reservoir is 1,425 feet msl. The reservoir serves as the forebay for Pit 6

powerhouse. Two 18-foot-diameter steel penstocks with a total flow capacity of 6,470

cfs extend 602 feet from the dam to the Pit 6 powerhouse turbines located at the base of

the dam.

Pit 6 Powerhouse

Pit 6 powerhouse is located along the east bank of the Pit River at the base of Pit 6

dam. The powerhouse is a four-level, reinforced concrete structure, three levels of which

are below grade. The structure contains two vertical-shaft, Francis reaction turbines,

rated at 53,000 hp each and operating at a normal maximum gross head of 155 feet.

There are two outdoor vertical axis generators, rated at 44 MVA each, with each unit

connected to a three-phase, 44-MVA transformer bank that steps up plant output to 230

kV. The maximum generator capacity is 80 MW. Average annual generation over the

last 25 years is 373.8 GWh. Water is discharged from the Pit 6 powerhouse directly into

the Pit 7 reservoir.

Transmission

The primary transmission lines extend about 3.3 miles from the switchyard

adjacent to Pit 6 powerhouse to PG&E’s interconnected transmission system.

2.1.1.3 Pit 7 Development

Pit 7 Dam and Reservoir

Pit 7 dam and reservoir are located on the Pit River downstream of Pit 6

powerhouse. Pit 7 dam is a 228-foot-high and 770-foot-long concrete gravity dam. The

top of the dam contains a trash rake, motors for two 49-foot by 42-foot slide gates at the

crest of the dam, and a control building. The control building houses hydraulic controls

for two 8-foot-diameter low-level outlets at the base of the dam. Pit 7 reservoir has a

maximum storage capacity of 34,142 acre-feet and a surface area of about 468 acres at a

normal maximum water surface elevation of 1,270 feet msl. As with Pit 6 reservoir, Pit 7

reservoir serves as the forebay for Pit 7 powerhouse. Two penstocks, 15 feet in diameter,

extend 572 feet from the dam to the turbines in the powerhouse, located at the base of the

dam. Total flow capacity within the penstocks is 7,440 cfs.

Pit 7 Powerhouse

Pit 7 powerhouse is located along the east bank of the Pit River at the base of the

Pit 7 dam. The powerhouse consists of a four-level, reinforced concrete structure, three

levels of which are below grade. The powerhouse contains two vertical-shaft, reaction

turbines that are rated at 70,000 hp each and operate at a normal maximum gross head of

205 feet. Two vertical axis generators are rated at 52.2 (Unit 2) and 62.1 (Unit 1) MVA,

respectively. Their maximum combined capacity is 112 MW. Each unit is connected to

a three-phase, 58-MVA transformer bank that steps up plant output to 230 kV. The

average annual generation over the last 25 years is 512 GWh. Water is discharged from

Pit 7 powerhouse directly into Pit 7 afterbay.
36

Transmission

The primary transmission lines extend about 3.5 miles from the switchyard

adjacent to Pit 7 powerhouse to PG&E’s interconnected transmission system.

Pit 7 Dam and Afterbay

Pit 7 afterbay has a surface area of about 69 acres at a normal “maximum” water

surface elevation of 1,067 feet msl (maximum water surface of Shasta Lake). The

afterbay dam is a 30-foot-high, steel reinforced, rock-fill structure, including a variable

width concrete gravity regulations weir section. Pit 7 afterbay serves to attenuate

changes in the water flow from Pit 7 dam and powerhouse before entering Shasta Lake,

which abuts and sometimes inundates the afterbay.

2.1.1.4 Existing Project Boundary

The existing project boundary, consisting of lands necessary for the safe operation

and maintenance (O&M) of the project and other purposes, such as recreation, shoreline

control, and protection of environmental resources, includes about 3,707.6 acres of land

in Shasta County, California.

The project boundary generally only encompasses project facilities, including:

dams and diversions; impoundments; water conveyances and associated structures;

access roads and trails; transmission, communication, and control lines; powerhouses;

gaging stations; and helicopter landing sites used for access to project structures. The

project boundary also includes land adjacent to project features and the width of these

zones varies depending on the feature. The current project boundary encloses the project

facilities associated with the three developments (James B. Black, Pit 6, and Pit 7) along

the McCloud and Pit Rivers, and lands within Shasta-Trinity National Forest.

The project currently contains six existing recreation sites within the project

boundary. These sites include: (1) the Forest Service’s Star City dispersed recreation

site at McCloud reservoir; (2) the existing Tarantula Gulch boat launch at McCloud

reservoir; (3) PG&E’s Hawkins Landing campground at Iron Canyon reservoir;

(4) PG&E’s Hawkins Landing boat launch at Iron Canyon reservoir; (5) the Forest

Service’s Fenders Flat car-top boat launch at Pit 7 afterbay dam; and (6) the Forest

Service’s existing Deadlun Creek campground.

PG&E proposes to expand the project boundary to include: (1) all proposed

recreation development at McCloud, Iron Canyon, and Pit 7 reservoirs and Pit 7 afterbay

area and (2) the right-of-way for the proposed McCloud and Pit 7 afterbay transmission

lines.

About 45 percent of the land (1,651.4 acres) within the project boundary is owned

by the United States and is managed by the Forest Service as part of Shasta-Trinity

National Forest. PG&E owns 1,239.4 acres (33 percent) of the land within the project

boundary, and the remaining 816.8 acres are privately owned.
37

2.1.2 Project Safety

The McCloud-Pit Project has been operating under the existing license for more

than 48 years, during which time Commission staff have conducted operational

inspections focusing on the continued safety of the structures, identification of

unauthorized modifications, efficiency and safety of operation, compliance with the terms

of the license, and proper maintenance. In addition, the project has been inspected and

evaluated every 5 years by an independent consultant, and a consultant’s safety report has

been filed for Commission review. As part of the relicensing process, the Commission

staff would evaluate the continued adequacy of the proposed project facilities under a

new license. Special articles would be included in any license issued, as appropriate.

Commission staff would continue to inspect the project during the new license term to

assure continued adherence to the Commission-approved plans and specifications; special

license articles relating to construction, operation, and maintenance; and accepted

engineering practices and procedures.

2.1.3 Existing Project Operation

The project operates both as a peaking system and a load-following system

throughout the year, using the available water supply after satisfying minimum instream

flow requirements.

James B. Black, Pit 6, and Pit 7 powerhouses are typically operated on a peaking

basis. The powerhouses’ output varies on an hourly basis from minimum or no load

during the off-peak periods, up to the powerhouses’ maximum output during peak

demand periods. During the mid-peak demand periods, the powerhouses are operated

near their more efficient loads depending on the available flow. During periods of high

flow, the powerhouses are operated at their maximum capacities in order to minimize

spill.

Operations of McCloud and Iron Canyon reservoirs are coordinated to optimize

use of water. The movement of water through the tunnel from McCloud reservoir to Iron

Canyon reservoir and through a tunnel and penstock from Iron Canyon reservoir to James

B. Black powerhouse is carefully planned to prevent spills at Iron Canyon reservoir and

minimize spills at McCloud reservoir. The water surface elevation in Iron Canyon

reservoir is regulated through the operation of James B. Black powerhouse. The relative

level of McCloud reservoir and Iron Canyon reservoir determines the rate of flow

through the tunnel connecting the two reservoirs. When spill conditions are forecast

because of high inflows to the reservoirs, Iron Canyon reservoir is drawn down to avoid

use of its spillway while maximizing the tunnel flow and minimizing spill at McCloud

dam. Iron Canyon reservoir does not spill, while McCloud reservoir, on average, spills

about 4 out of every 10 years.
38

2.1.4 Existing Environmental Measures

The current license for the project includes minimum flow requirements for

McCloud and Iron Canyon dams (article 31). For McCloud dam, requirements include

a 50-cfs flow release from May through November and a 40-cfs flow release from

December through April, as measured at gage MC-7, with additional releases as

necessary to maintain minimum flows of 160 to 210 cfs at gage MC-1 near Ah-Di-Na.

Flows of at least 3 cfs are required to be released to Iron Canyon Creek downstream of

Iron Canyon dam at all times.

To facilitate use of the boat ramp during the recreation season from May 15 to

October 15, PG&E voluntarily keeps the water surface elevation of Iron Canyon reservoir

at or above elevation 2,615 feet msl, instead of the minimum elevation of 2,593 feet msl

allowed by the current license.

Land use is regulated under article 56 and is subject to the Shasta County general

plan, Shasta-Trinity National Forest Land and Resource Management Plan and the

McCloud River Coordinated Resource Management Plan. The current license articles

also include requirements for fire prevention and suppression.

PG&E is a participant in the McCloud River Coordinated Resource Management

Plan, which provides for coordinated management of the McCloud River by federal and

state resource agencies, adjacent landowners, and conservation organizations. Any

changes in the operation of the McCloud dam are expected to undergo review by the

Coordinated Resource Management Plan coordinating group (McCloud River

Coordinated Resource Management Plan, 1991). Also, the Shasta-Trinity National

Forest Land and Resource Management Plan guides protection of environmental

resources (Forest Service, 1995).

2.2 APPLICANT’S PROPOSAL

2.2.1 Proposed Project Facilities

PG&E proposes to construct a new powerhouse at the base of McCloud dam and

a new powerhouse at Pit 7 afterbay dam, along with associated transmission facilities.

PG&E also proposes to construct four new recreational facilities at McCloud reservoir,

two new recreation facilities at Iron Canyon reservoir, one new recreation facility at Pit 6

reservoir, and two new recreation facilities at Pit 7 afterbay dam.

2.2.1.1 McCloud Development

At McCloud Development, PG&E proposes to construct a powerhouse located at

the base of McCloud dam. Generation output from the proposed powerhouse would be

connected to a new transmission line that would be routed from the proposed powerhouse

to connect to an existing substation located about 14 miles to the north, in the town of

McCloud, California. The McCloud Development would use water stored in McCloud

reservoir and released into the Lower McCloud River to meet instream flow
39

requirements, and no new impoundments are proposed. With a flow range of 150 to

400 cfs, the turbine and generator set would have an installed capacity of about 5 to

8 MW. The proposed McCloud Development would have an average range of annual

energy production of 30 to 40 GWh, and average monthly generation would be about

2.5 to 3.3 GWh. PG&E proposes to base the final size of the unit, powerhouse hydraulic

capacity, and average annual energy production on instream flow requirements included

in the new project license.

The proposed powerhouse would be positioned to the south of the current outlet

works control building and would be a reinforced concrete-and-block masonry structure

designed to enclose and protect the electro-mechanical generation equipment, withstand

area snow loads, and prevent vandalism. It would be accessed via the existing project

road that connects to Forest Road (FR) 38N11.

The powerhouse would be equipped with a single vertical-axis Francis turbine.

The turbine, which would have a discharge diameter of about 54 inches, would operate at

about 450 revolutions per minute. The direct-coupled synchronous generator rating

would range from 5,600 to 7,500 kilowatts (kW).

The proposed transmission line route from the powerhouse would follow

FR 38N11 and then county roads to the existing substation about 14 miles north in the

town of McCloud.

2.2.1.2 Pit 7 Afterbay Development

PG&E also proposes to construct facilities at Pit 7 Afterbay Development,

including a powerhouse located on the west side of Pit 7 afterbay dam at the regulating

weir. Generation output from the proposed powerhouse would be connected to a new

transmission line that would be routed from the powerhouse to connect to the switchyard

located about 1.6 miles to the east at the existing Pit 7 powerhouse. The proposed

facilities would have no meaningful storage and would operate in a run-of-the-river

mode. The available flows for energy production would be dictated by the operation of

the upstream Pit 7 powerhouse.

The proposed Pit 7 afterbay powerhouse would use water released upstream from

Pit 7 powerhouse and dam and no new impoundments are proposed. The proposed

powerhouse would be configured for two horizontal-axis synchronous generating units,

each rated at 5,500 kW and housed in a 30-foot-wide by 110-foot-long intake approach

bay. Each of the generating bays would have a design flow of 2,500 cfs. The upstream

entrance to each intake bay would include a trash rack to stop large debris from entering

the unit. Two radial gates about 26 feet wide by 52 feet high would be constructed

upstream of the unit to regulate flow and for dewatering the turbine pit. A roller gate

would be constructed at the downstream end of each bay or the tailrace to prevent

backwatering during maintenance. A combination of ramps, walkways, and ladders

would be used in each bay to allow for maintenance access and to support the gate

operator mechanism. A 20-foot-wide bypass flow bay, which would house a radial gate
40

and operator, would be built in the first phase of construction. The bypass flow bay

would be used to pass river flows during the second phase of construction and during

times of non-generation. The bypass flow bay also would require a walkway to allow

maintenance and operation access and support the gate operator mechanism. A new

access road would be constructed to access the powerhouse for construction, operation,

and maintenance. The access road would extend between Fenders Ferry Road and the

afterbay, just west of Fenders Ferry Bridge. Based on a flow range of 2,500 to 5,000 cfs,

the two-unit powerhouse would accommodate turbine and generator sets capable of an

installed capacity of about 5 MW each for a total of 10 MW. The average monthly

generation from this proposed powerhouse would be about 4.2 GWh.

The proposed powerhouse substation would be fenced and located on the ground

near the control house, but above the maximum anticipated flood and tailwater levels.

Substation equipment would include a step-up substation to transform energy for the

transmission line. Powerhouse controls and switchgear would be installed in a separate

building located on the right bank of the river, positioned above the maximum anticipated

water level and inside the substation fence. The building would house the required

equipment for control and protection of the generation units and would be equipped with

electric heating and cooling. The transmission line would be a 1.6-mile-long, 34.5-kV,

wooden-pole line connecting the proposed powerhouse to a new 34.5- to 230-kV

transformer, positioned at or near the existing 230-kV Pit 7 switchyard. A new 230-kV

circuit breaker and disconnect switch would be connected by a short span to the main bus

of the existing Pit 7 switchyard.

2.2.2 Proposed Project Operation

Future operation of existing project structures would be generally consistent with

existing operation. One significant change in future operation, however, is related to

minimum flow releases, as described below (Measures 5, 7, and 8). PG&E also proposes

to release recreational flows below McCloud dam (Measure 6).

The proposed McCloud powerhouse would generate electricity with water stored

in McCloud reservoir and released into the Lower McCloud River to meet instream flow

requirements, and no new impoundments are proposed. The final size of the unit,

powerhouse hydraulic capacity, and average annual energy production would be

determined based on instream flow requirements included in the new project license.

The proposed Pit 7 afterbay powerhouse would operate in run-of-the-river mode.

2.2.3 Proposed Environmental Measures

In its new license application, PG&E proposed the following protection and

enhancement measures:

General

 Consult annually with the Forest Service (Measure 1).
41

 Conduct annual training in coordination with the Forest Service, to familiarize

project staff with local resource issues, special status species, noxious weeds,

procedures for reporting to the Forest Service, and applicable Forest Service

orders (Measure 2).

 Obtain Forest Service approval of designs and schedules for any changes to

project construction and activities (Measure 4).

Geology and Soils

 Implement a Large Woody Debris (LWD) Management Plan that calls for

transporting LWD from McCloud reservoir and depositing it in the Lower

McCloud River (Measure 11).

 Develop and implement an Erosion and Sediment Monitoring and Control Plan

that specifies treatment criteria; methods for inventorying, monitoring, and

reporting; and protocols for emergency erosion control. The plan would

include provisions for detecting and treating new erosion sites, as well as

treating and monitoring existing sites (Measure 12).

Aquatic Resources

 Increase minimum instream flow releases below McCloud dam to the

McCloud River, and move the point for measuring compliance about 4 miles

upstream to the base of McCloud dam. The proposed target minimum

instream flow below McCloud dam is 220 cfs from December through April

and 150 cfs from May through November (Measure 5).

 Increase minimum instream flows below Iron Canyon dam to Iron Canyon

Creek from 3 cfs, year-round, to a varied scenario of flows from 5 to 20 cfs,

depending on time of year and water year type (Measure 7).

 Implement an upramping rate measure for the Lower McCloud River, identical

to the existing voluntary operational practice, which would be implemented

during uncontrolled spill events (Measure 9).

 Continue providing a minimum flow release of 150 cfs to the Pit River below

Pit 7 dam when Shasta Lake is lower than 1,055 feet msl to maintain water

flow in the Pit 7 afterbay (Measure 8).

 Develop and implement a water quality monitoring plan, which would provide

for continued monitoring of water temperature and turbidity for selected sites

at which PG&E has been monitoring since about 1987, and add monitoring the

effects of changes to instream flow releases on water temperature and turbidity

and monitoring bacteria in McCloud and Iron Canyon reservoirs (Measure 10).

 Prepare, for Forest Service approval, a biological evaluation of the potential

effects of any proposed action to construct project features on Forest Service

lands on special status species. The evaluation would include procedures to
42

minimize any adverse effects, meet any management plan restrictions, and

monitor implementation and effectiveness of any measures taken as part the

construction (Measure 15).

 Develop a Wildlife Management Plan for aquatic and terrestrial species that

includes monitoring methodologies, pre-construction survey protocols, and

avoidance and protection measures for special status mollusks, Shasta

salamander, foothill yellow-legged frog, and northwestern pond turtle

(Measure 14).

Terrestrial Resources

 Develop a Vegetation Management Plan in consultation with resource agencies

to ensure that PG&E: (1) identifies, monitors, and protects individuals and

populations of special status species, and culturally significant plant species to

maintain well-distributed, viable populations; (2) specifies allowable treatment

methods for project O&M practices to minimize the introduction and spread of

invasive plant species; (3) protects wetland areas; and (4) restores native

vegetation in areas disturbed by project operation and activities (Measure 13).

 Develop a Wildlife Management Plan for aquatic and terrestrial species that

describes monitoring methodologies, pre-construction survey protocols, and

avoidance and protection measures for VELB, northern goshawk, bald eagle,

peregrine falcon, willow flycatcher, communities of breeding birds, special

status bats, and forest carnivores (Measure 14).

 Modify any existing power line that does not meet established Avian Power

Line Interaction Committee (APLIC) standards for preventing bird

electrocution; construct any new power lines to meet the established standards

(Measure 16).

 Prepare, for Forest Service approval, a biological evaluation of the potential

effects of any proposed action to construct project features on Forest Service

lands. The evaluation would include procedures to minimize any adverse

effects, meet any management plan restrictions, and monitor implementation

and effectiveness of any measures taken as part the construction. This measure

would apply to and protect terrestrial and aquatic Forest Service special status

species (Measure 15).

Threatened and Endangered Species

 Pacific fisher: Perform pre-construction surveys using passive detection

systems, such as baited camera stations. Survey methods from the scientific

literature, and any available standard species survey protocols, would be

considered in defining the survey approach. Avoidance, protection, and

mitigation measures would be used at construction sites (Measures 14 and 15).
43

 Northern spotted owl: Conduct protocol-level surveys prior to construction

and implement appropriate mitigation measures if required, or alternatively

assume the presence of spotted owls, and propose measures, as appropriate,

to address potential project-related effects. If spotted owls are detected,

implement restrictions on project activities near nest sites documented during

pre-construction surveys or other observations. Define the seasonal timing and

the buffer distance around occupied sites for each type of activity. Ensure that

these restrictions are generally consistent with those applied by the Forest

Service at other occupied sites in the vicinity (Measure 14).

Recreation Resources

 Obtain Forest Service approval of final design before construction of project

facilities occurs on National Forest System (NFS) lands to ensure that any

concerns about consistency with the Shasta-Trinity National Forest Land and

Resource Management Plan, including visual quality objectives, are addressed

when planning, designing, and constructing project facilities and implementing

project measures (Measures 3 and 19).

 Continue funding to California Fish and Game for stocking rainbow trout or

kokanee in the drainages of the Pit and McCloud Rivers below the uppermost

project development to Shasta Lake. This measure would continue to enhance

recreational fishing in project waters (Measure 17).

 Develop and implement a Recreation Development and Management Plan to

address recreation resource needs at the project. A number of sub-plans are

proposed in the project Recreation Plan: (1) a Signage Plan to provide

directions to project recreation opportunities and inform visitors about

applicable rules and regulations; (2) a surface water and shoreline management

plan to manage reservoir use at McCloud reservoir; (3) an Interpretive and

Education Plan to enhance visitor experience; and (4) a Recreation Monitoring

Plan to provide information that could be used to implement actions to address

the effects of recreation use throughout the license term (Measure 19).

 Include the following facilities at McCloud reservoir in the project Recreation

Plan: a walk-in campground at Star City, four day-use facilities, reservoir

shoreline access (i.e., parking areas with pedestrian shoreline access trails) at

three access points, and a whitewater put-in at the base of McCloud dam

(Measure 19).

 Include the following facilities at Iron Canyon reservoir in the project

Recreation Plan: a boat launch near the dam and reservoir shoreline access

after conducting a site evaluation (i.e., three parking areas with pedestrian

shoreline access trails) (Measure 19).

 Reconstruct Forest Service facilities (Tarantula Gulch boat launch, if feasible,

and Deadlun Campground) and PG&E-owned facilities at Hawkins Landing.
44

Reconstruction at Deadlun Campground would include redesigning the facility

to include additional overnight capacity. Upgrade Hawkins Landing to Forest

Service standards, resurface the access road, and replace or repair the surfacing

that connects to the concrete ramp. If feasible within site constraints, extend

the boat ramp at Tarantula Gulch. After construction or reconstruction, the

facilities would become project recreation facilities, and PG&E would be

responsible for O&M for the facilities, including fee collection (Measure 19).

 Provide hosts at project campgrounds (Measure 19).

 Develop in consultation with the Forest Service and implement a Project Patrol

Plan to include NFS lands within the project area or affected by project

facilities, access areas, and dispersed use sites to respond to concerns about

trash, vandalism, and improper or disruptive visitor behavior near project

reservoirs (Measure 20).

 Include the following proposed facilities at Pit 7 afterbay in the project

Recreation Plan: a day-use area at Fenders Flat and, if the Pit 7 afterbay

powerhouse is constructed, pedestrian access to the shoreline between the

powerhouse and the bridge. Grade and maintain the access road to the car-top

boat launch and continue to prohibit public access to the Pit 7 afterbay water

surface and shoreline (Measure 19).

 Assess and implement, in coordination with the Forest Service, closures of

existing and future user-created roads leading to the shoreline. This measure

would prohibit vehicle access between certain forest roads and the shoreline

except to developed facilities and prohibit dispersed camping and off-highway

vehicle (OHV) use between the roads and the shoreline (Measure 19).

 Provide a recreation flow event from McCloud dam when natural spill of at

least 300 cfs for seven consecutive days during the period of April 1 through

October 31 has not occurred at any time in the three previous calendar years

(Measure 6).

 Provide real-time flow information on the internet (gage MC-1) in the Lower

McCloud River. Inform the public via internet if the project reservoir levels

are sufficient for launching boats (i.e., end of the launch lanes are sufficiently

submerged). Provide flow and boat launch information so visitors will know

when conditions are suitable for their activities (Measure 19).

 Conduct feasibility studies to evaluate the potential for constructing a few

recreation facilities as suggested at meetings among relicensing participants

and construct if feasible. At McCloud reservoir, evaluate locations for a

floating dock or pier and trail for fishing and swimming. At Pit 7 reservoir,

evaluate the feasibility of providing shoreline access at the upper end of the

reservoir and a hand launch boat put-in where Montgomery Creek enters the

reservoir (Measure 19).
45

Cultural Resources

 Develop and implement the HPMP. The plan has been developed in

consultation with the Tribes and Forest Service; however, consultation will

continue until the Commission approves the HPMP. Specifications are

included in the plan to avoid or manage any potential project-related adverse

effects on properties that are unevaluated, eligible for, or listed on the National

Register (Measure 22).

Land Use and Aesthetic Resources

 Prepare a Road and Transportation Facilities Management Plan for NFS roads

or project roads affecting NFS resources (Measure 18).

 Plan and create, in coordination with the Forest Service, shaded fuel breaks

around all project recreation facilities that would be constructed and

maintained by PG&E (Measure 19).

 Develop a Fire Response Plan to address ongoing concerns about wildland fire

and potential damage to project infrastructure and forest resources. This

measure would provide pre-suppression coordination with fire management

agencies; describe hazard reduction treatments; and identify contacts,

equipment, personnel, and access routes that can be immediately referenced to

support suppression actions. It would also specify requirements for reporting

project-caused fires and supporting fire investigations (Measure 21).

2.2.4 Modifications to the Applicant’s Proposal—Mandatory Conditions

The following mandatory conditions have been provided and are evaluated in this

document.

2.2.4.1 Section 4(e) Federal Land Management Conditions

In a January 29, 2010, filing with the Commission, the Forest Service submitted

terms and conditions pursuant to section 4(e) of the FPA, including 18 standard Forest

Service conditions and 16 project-specific resource protection conditions. On

March 1, 2010, the Forest Service revised one condition in part, condition 19,

Streamflow. The Forest Service modified four standard conditions and 14 resourcespecific protection conditions with its filing of modified 4(e) conditions on

November 29, 2010.

On December 14, 2010, the Forest Service filed a settlement agreement between

PG&E and the Forest Service for non-project recreation facilities (specifically, Ash

Camp, Ah-Di-Na Campground, and the Lower McCloud River Trail) and roads in the

Shasta-Trinity National Forest, which are also detailed in the Forest Service’s

4(e) conditions.

Of the Forest Service’s 34 conditions, we consider the 18 standard conditions

(conditions 1 through 18) to be administrative or legal in nature and not specific
46

environmental measures. With the exception of Forest Service condition 1, Consultation,

condition 11, Protect Forest Service Special Status Species, and condition 15, Pesticide

Use Restrictions on NFS Lands, we do not analyze these conditions in this EIS. We

analyze conditions that we consider to be environmental measures in section 3,

Environmental Analysis, and we summarize our analysis of these measures in section

5.4.2, Forest Service 4(e) Conditions.

The initial and revised Forest Service conditions that we analyze in this document

specify that PG&E:

 Consult with the Forest Service annually on measures needed to ensure

protection and utilization of the National Forest resources affected by the

project. [Forest Service condition 1]

 Prepare and submit a biological evaluation to the Forest Service before taking

action to construct new project features that may affect Forest Service special

status species or their critical habitat. [Forest Service condition 11]

 Obtain prior written approval from the Forest Service for use of pesticides on

NFS lands or in areas affecting NFS lands. Pesticide use would be excluded

from NFS lands within 500 feet of known locations of Shasta salamanders,

northwestern pond turtles, foothill yellow-legged frogs, or known locations of

Forest Service special status or culturally significant plant populations. [Forest

Service condition 15]

 Maintain specified minimum streamflows in project reaches in accordance

with the provisions described in the Forest Service filing. The minimum

instantaneous 15-minute streamflow shall be at least 80 percent of the

prescribed mean daily flow for those minimum streamflows less than or equal

to 10 cfs, and at least 90 percent of the streamflows required to be greater than

10 cfs. Should the mean daily flow as measured be less than the required mean

daily flow but more than the instantaneous flow, PG&E shall begin releasing

the equivalent under-released volume of water within 7 days of discovery of

the under-release. [Forest Service condition 19]

 Determine the water type year for minimum flow compliance based on the

California Department of Water Resources (DWR) Bulletin 120 water year

forecast of unimpaired runoff for the McCloud River above Shasta Lake.

[Forest Service condition 19, part 2]

 Operate, maintain, and modify (if necessary) gages needed to determine river

stage and minimum streamflow, and measure and document all instream flow

releases in publicly available formats. [Forest Service condition 19, part 3]

 Prepare a water quality and temperature monitoring plan in consultation with

agencies and approved by the Forest Service. [Forest Service condition 20]
47

 Prepare an LWD Plan in consultation with agencies and approved by the Forest

Service. [Forest Service condition 21]

 Prepare an Erosion and Sediment Control Management and Monitoring Plan

developed in consultation with agencies and approved by the Forest Service.

[Forest Service condition 22]

 Develop a Gravel and Coarse Sediment Management Plan in consultation with

agencies and approved by the Forest Service. [Forest Service condition 23]

 Note: The Forest Service withdrew condition 24 on November 29, 2010.

 Develop a Vegetation and Invasive Weed Management Plan, in consultation

with agencies and approved the Forest Service, to address special status

species, aquatic and terrestrial invasive species, and revegetation source plant

populations, including culturally significant plants, within the project boundary

and adjacent to project features directly affecting NFS lands including roads

and distribution and transmission lines. [Forest Service condition 25]

 Develop a Terrestrial Biological Management Plan, including Forest Service

special status species potentially affected by the project on NFS lands. Ensure

that all power poles conform to APLIC guidelines. [Forest Service condition

26]

 Develop an Aquatic Biological Monitoring Plan, in consultation with agencies

and approved by the Forest Service. [Forest Service condition 27]

 Note: The Forest Service withdrew condition 28 on November 29, 2010.

 File a Road and Transportation Facility Management Plan, approved by the

Forest Service, for protection and maintenance of project and project-affected

roads on or affecting NFS lands. [Forest Service condition 29]

 Prepare a Recreation Development and Management Plan in consultation with

agencies and approved by the Forest Service to address recreation resource

needs associated with the project that includes the following components:

O&M, recreation survey and monitoring, project patrol, reservoir surface water

management, and construction and reconstruction of recreation facilities. All

new and reconstructed project recreation facilities would comply with federal

accessibility standards and include the following facilities:

o Reconstruct Tarantula Gulch boat launch;

o Develop campground and day-use area at Star City;

o Develop day-use areas at Tarantula Gulch inlet and Red Banks;

o Create reservoir access points at Battle Creek and on each side of McCloud

dam;

o Construct a day-use area at the base of McCloud dam;
48

o Provide three reservoir access sites at Iron Canyon reservoir;

o Construct Iron Canyon dam boat ramp;

o Reconstruct Hawkins Landing Campground and boat ramp;

o Reconstruct Deadlun campground;

o Construct new Gap Creek Campground;

o Develop two surfaced parking areas with reservoir access trails below Pit 6

dam to provide fishing access and boating put-in onto the upper Pit 7

reservoir;

o Develop road access to a surfaced parking area and short walkway to putin/take-out onto the lower Pit 7 reservoir, either at Montgomery Creek or

near the Pit 7 dam;

o Construct day-use area at Fenders Flat in vicinity of boat launch;

o Reconstruct car-top boat launch near Fenders Flat; and

o Investigate known safety and public access issues at Pit 7 afterbay dam.

[Forest Service condition 30]

 In collaboration with the Forest Service, develop and implement a project Sign

and Interpretive/Education Plan for all non-traffic signs within the project, and

an interpretive and educational component that includes a website for public

information and informational kiosks. [Forest Service condition 31]

 Develop procedures and a timeline for mitigation measures to provide for

visual quality of project and project-affected NFS lands. [Forest Service

condition 32]

 Develop a Fire and Fuels Management Plan, in consultation with agencies and

approved by the Forest Service, for prevention, reporting, and emergency

response to fires in the vicinity of the project resulting from project operations.

The plan shall address fuels treatment, prevention and response, and

investigation of project-related fires. [Forest Service condition 33]

 File an HPMP approved by the Forest Service with the Commission. [Forest

Service condition 34]

2.2.4.2 Alternative 4(e) Conditions Pursuant to the Energy Policy Act of

2005

The Energy Policy Act of 2005 provides parties to this licensing proceeding

the opportunity to propose alternatives to mandatory conditions. On March 4, 2010,

PG&E filed alternatives to 16 of the Forest Service’s 4(e) conditions. By letter dated

November 24, 2010, PG&E withdrew 13 of its alternative 4(e) conditions in full and part

of alternative condition 19. PG&E states that it has not reached agreement with the

Forest Service on parts of condition 19 and on conditions 29 and 30. While our list of
49

PG&E’s and others’ alternative 4(e) conditions reflects their current status, we continue

to analyze all alternative 4(e) conditions in this EIS, regardless of that status.

 PG&E alternative condition 12 − proposed that access to Forest Service lands

within the licensed area be permitted by the Forest Service specifically for the

protection, administration, management, and utilization of Forest Service

lands, in a manner that did not require PG&E to disproportionately bear costs;

 PG&E alternative condition 18 − proposed that this Forest Service condition

be limited to PG&E-proposed ground-disturbing activities on or directly

affecting Forest Service lands and eliminated requirements for PG&E to bear

Forest Service staff-related time and expenses;

 PG&E alternative condition 19, part 1, subpart b − proposes minimum

streamflow requirements and measurement for McCloud River below

McCloud dam.

 PG&E alternative condition 19, part 1, subpart c − proposed minimum

streamflow requirements and measurement for Iron Canyon Creek below Iron

Canyon dam and allowed for a longer scheduling timeframe for the adjustment

of flows and dam tests;

 PG&E alternative condition 19, part 2 − proposes that compliance with flow

changes be implemented within five business days for Iron Canyon dam

between February and May, to account for potential weather-related access

difficulties.

 PG&E alternative condition 20 − addressed the timeframe for the development

of the water quality and temperature monitoring plan as well as access issues,

such as those related to private property and inclement weather, associated

with the installation of water quality sensors and temperature monitoring;

 PG&E alternative condition 23 − addressed the conditions for implementation

of a Gravel and Coarse Sediment Management and Monitoring plan, and

defined the monitoring area and sediment augmentation metric and methods;

 PG&E alternative condition 24 − stated that PG&E does not anticipate a need

for development of a dredging plan;

 PG&E alternative condition 25 − proposed a new timeframe for development

of a Vegetation and Invasive Weed Management and Monitoring Plan, the

definition of culturally significant plants, invasive weed monitoring priorities

and intervals, and geographic monitoring boundaries;

 PG&E alternative condition 26 – proposed a new timeframe for development

of a Terrestrial Biological Management and Monitoring plan, identified

targeted populations and habitat for monitoring, monitoring intervals, and the

timeline and focus for APLIC recommended upgrades;
50

 PG&E alternative condition 27 − proposed a new timeframe for development

of an Aquatic Biological Management and Monitoring Plan, identified nonproject roads and eliminates associated fish passage responsibilities, and

addressed fish monitoring in project reservoirs;

 PG&E alternative condition 28 − proposed that PG&E would provide the

Forest Service copies of its existing Spill Prevention, Control, and

Countermeasures Plans and Hazardous Materials Business Plans for the

project in lieu of a plan approved by the Forest Service for oil and hazardous

substances storage and spill prevention and cleanup;

 PG&E alternative condition 29 − clarifies road segments that would be covered

by the Road and Transportation Facility Management Plan;

 PG&E alternative condition 30 − proposes to remove the requirement for

Forest Service approval of the Recreation Development and Management Plan;

modifies specific components of the Recreation Plan, including recreation

facility enhancements and recreation facility construction and site assessment

schedules; clarifies the applicability of recreation monitoring to project

facilities and project lands and waters; specifies that existing recreation

facilities would be included within the project boundary after reconstruction;

and modifies the schedule for surface sweeps of McCloud and Iron Canyon

reservoirs and boat ramps;

 PG&E alternative condition 31 − specified that for the Informational Sign Plan,

PG&E would provide project recreation information, except for confidential

business information, to the Forest Service for posting on the Forest Service’s

website;

 PG&E alternative condition 32 − proposed to define the applicability of

specific mitigation measures as existing and proposed project facilities,

clarifies terminology, and accounts for an apparent inconsistency between the

assigned visual quality objective (VQO) and the appearance of the project area;

 PG&E alternative condition 33 − proposed minor clarifications to the Fire and

Fuels Plan; and

 PG&E alternative condition 34 − proposed clarifications in terminology and

allowances for modifications to the HPMP upon completion of an ethnographic

study, clarifies conditions for National Register site evaluation, and ensured

collaborative HPMP development and appropriate consideration of new

cultural materials.

On March 4, 2010, California Trout, Trout Unlimited, and McCloud River Club

filed an alternative to Forest Service condition 19:

 Forest Service condition 19, part 1 − California Trout, Trout Unlimited, and

McCloud River Club recommend modifications to streamflow requirements for
51

McCloud River below McCloud dam, including a minimum baseflow of 200

cfs at MC-1 and summer base flows at MC-1 of 200 cfs or the historic average

summer base flows, whichever is higher.

The Forest Service filed its analysis of the alternative 4(e) conditions with its

modified 4(e) conditions on November 29, 2010. The Forest Service modified 18

conditions and withdrew two conditions as a result of its analysis and discussions with

PG&E and other interested parties. By letter dated November 29, 2010, California Trout,

Trout Unlimited, and McCloud River Club state their agreement with the Forest Service’s

modified condition 19.

2.3 STAFF ALTERNATIVE

After evaluating PG&E’s proposal and recommendations from resource agencies

and other interested parties, we compiled a set of environmental measures that we

consider appropriate for addressing the resource issues raised in this proceeding, calling

this the staff alternative. The staff alternative includes some measures included in

PG&E’s proposal and some of the Forest Service’s section 4(e) conditions and PG&E’s

alternative section 4(e) conditions, section 10(j) recommendations, section 10(a)

recommendations, and measures developed by Commission staff.

The staff alternative incorporates PG&E’s proposed environmental measures (see

section 2.2.3, Proposed Environmental Measures), as modified by staff (indicated by

italics):

Geology and Soils

 Prepare an LWD Management Plan.

 Prepare an Erosion and Sediment Monitoring and Control Plan.

Aquatic Resources

 Continue to implement the current minimum flow release schedule for the Pit 7

afterbay reach.

 Implement upramping rates of no more than 100 cfs per hour prior to the start

of an uncontrolled spill event at McCloud dam.

 Develop and implement a water quality monitoring plan.

Recreation Resources

 Develop and implement a Recreation Development and Management Plan that

would include: location, conceptual designs, and schedules for upgrading

existing recreation facilities and constructing new recreation facilities,

including the reevaluation of the facilities for degradation at mid-license term

or 25 years, whichever is greater; plans using the Forest Service design

standards (including applicable standards for providing access to users with

disabilities); and details regarding O&M activities at all recreation facilities
52

including existing and new project recreation facilities. The plan also should

incorporate the following components:

o A Project Sign Plan that includes an interpretive and education component;

o Monitoring, visitor surveys, and use estimation with report concurrent with

the recreation Form 80 reporting. This measure also should include details

addressing collection of annual use data at facilities where passes/fees are

collected; consultation with the Forest Service on the survey methods for

the Recreational Resource Survey; and consultation every 6 years

(concurrent with the recreation Form 80) with the Forest Service,

appropriate agencies, and interested parties to review and adjust projectwide recreation management objective, if needed; and

o A water surface management plan to manage reservoir use at McCloud

reservoir. This plan component would include installing speed limit signs

in the northern end of the reservoir, LWD removal from the reservoir,

points of public access to the shoreline, and boating speeds. This measure

would also include details addressing monitoring and management of

recreation user safety, including developing protocols for all project

reservoirs for preventing/removing unapproved buoy courses, approved use

of docks, and measures to prevent unauthorized access to project lands and

waters; annual surface sweeps of McCloud and Iron Canyon reservoirs and

boat ramps to remove logs and other debris; monitoring boat use on

McCloud and Iron Canyon reservoirs every 6 years coinciding with the

recreation Form 80 schedule; and reassessing water surface management

mitigations every 6 years.

 Provide real-time streamflow (gages MC-1 and MC-7) and drawdown

information to the public via PG&E’s website on the internet.

 At McCloud and Iron Canyon reservoirs, assess and implement closures of

user-created roads, trails, and dispersed use sites leading to the shoreline of

McCloud and Iron Canyon reservoirs, in coordination with the Forest Service.

McCloud Reservoir

 Within 5 years of Commission approval of the Recreation Plan, reconstruct the

Tarantula Gulch boat ramp to California Department of Boating and

Waterways (California Boating) standards with one lane ramp, provide a

boarding dock, and extend the launch ramp to 3 feet (vertical) below the

minimum operating pool elevation, including redesigning the parking lot to

maximize parking spaces and a day-use area.

 Within 5 years of Commission approval of the Recreation Plan, provide access

points (paved parking and shoreline access trail) at Battle Creek, West dam,

and East dam.
53

 Within 5 years of Commission approval of the Recreation Plan, provide dayuse areas at Red Banks and the intersection of Tarantula Gulch access road and

FR 11.

 Within 5 years of Commission approval of the Recreation Plan, develop a

formal campground and day-use area at Star City with walk-in sites (estimate

six sites), paved parking, vault restroom, potable water, tables, fire rings/grills,

trash receptacles/removal, and host site.

 Conduct a feasibility study to find a suitable location for a floating dock or pier

and trail at McCloud reservoir and construct the facilities if feasible.

Lower McCloud River

 Within 5 years of Commission approval of the Recreation Plan, provide a dayuse facility at the base of McCloud dam and provide parking, vault restroom,

trash receptacle/removal, and shoreline pedestrian access trail on river left to

the pool below the spillway. This measure is modified to recommend that the

trail accommodate fishing and boating access and to include an access road.

Iron Canyon Reservoir

 Within 5 years of Commission approval of the Recreation Plan, reconstruct

Hawkins Landing Campground to the Forest Service standards and provide

potable water and reconstruct or resurface the access road to allow all-season

use.

 Within 5 years of Commission approval of the Recreation Plan, retain concrete

ramp surface at Hawkins Landing Boat Launch and replace or repair the

surfacing that connects to the concrete ramp. This measure is modified to

include specifications for reconstruction of boat ramp surface (length and

width, but not grade) to meet California Boating standards for one lane, and

for construction of a parking area.

 Within 5 years of Commission approval of the Recreation Plan, reconstruct

Deadlun Campground to the Forest Service standards and increase capacity by

about 10 sites to provide about 37 sites and provide potable water a shoreline

access trail. This measure is modified to specify that the campground be

reconstructed to accommodate double and triple campsites.

 Within 5 years of Commission approval of the Recreation Plan, construct a

new boat launch at the east end of Iron Canyon dam that meets California

Boating standards and provide vault restroom, picnic tables, potable water, and

trash receptacles/removal. This measure is modified to recommend that the

boat ramp be operable at minimum operating pool, and that snow be removed

from the parking area and ramp when project operations require snow

removal from Oak Mountain Road.
54

 Conduct a site evaluation to determine the location of three paved parking

areas along FR 37N78, each with a capacity of up to three vehicle parking

spaces and a pedestrian shoreline access trail. This measure is modified to

specify that once three suitable locations are identified, design and construct

these project facilities.

 Allow public use of at least one campground year-round. This measure is

modified to specify that a schedule for implementation would be included in the

Recreation Plan.

Pit 7 Reservoir

 Conduct a site evaluation to determine the location of a pedestrian shoreline

access trail at the upper end of Pit 7 reservoir, downstream of Pit 6 powerhouse

tailrace. This measure is modified to include consultation with the Forest

Service, and once a suitable location is found, constructing this facility within

5 years of Commission approval of the Recreation Plan. The facility would

include a trailhead, parking for up to three vehicles, and hand-launch boating

access.

Pit 7 Afterbay

 Within 2 years of Commission approval of the Recreation Plan, grade and

maintain FR 35N66 from its intersection with FR 37N78 to the car-top boat

launch. Provide a vault restroom near the car-top boat launch.

 Continue to prohibit public access to Pit 7 afterbay water surface and shoreline

by maintaining fencing, signage, and patrols.

 If the Pit 7 afterbay powerhouse is constructed, provide a paved parking area

for two to three vehicles at the end of the powerhouse access road or along

Fenders Ferry Road and provide a vault restroom, trash receptacle/removal,

and pedestrian access to the shoreline between the powerhouse and Fenders

Ferry Bridge. This measure is modified to condition the day-use area on

public safety and homeland security needs.

 Within 5 years of Commission approval of the Recreation Plan, provide a dayuse site at Fenders Flat with a capacity of five sites, parking, vault restroom,

tables, fire grills, and trash receptacles/removal, and coordinate with the Forest

Service to develop and implement a plan to revegetate disturbed areas and

prevent vehicle access beyond the access road and parking area.

Land Use and Aesthetic Resources

 Develop, file, and implement, within 1 year of license issuance, a Road and

Transportation Facilities Management Plan for all project roads.

 Develop, file, and implement, within 1 year of license issuance, a Fire

Prevention and Response Plan.
55

 Include all existing project roads and recreation sites within the project

boundary and file a revised exhibit G with the Commission within 1 year of

license issuance.

 Develop, file, and implement, within 1 year of license issuance, visual quality

management tasks and a timeline.

Additional Measures Identified by Staff

In addition to PG&E’s proposed measures listed above (and modified as

indicated), the staff alternative also includes the following additional measures identified

by staff based on agency, tribal, and non-governmental organization specifications,

recommendations, and our analysis.

Geology and Soils

 Within 12 months of license issuance, develop and implement a Gravel and

Coarse Sediment Management Plan in consultation with agencies and

approved by the Forest Service. Employ an adaptive management approach to

monitoring with Bald Mountain Creek confluence serving as the downstream

terminus for the monitoring program, and augment gravel and coarse sediment

periodically. Evaluate Star City Creek as a primary source of gravel, and

evaluate other potential alternate local sites, such as Tarantula Gulch delta in

the development of the Coarse Sediment Management Plan.

Aquatic Resources

 Within 90 days of license issuance, release mean daily flows of at least 175 cfs

year round from the McCloud dam (as measured at MC-7) such that the mean

daily flow at Ah-Di-Na (MC-1) is at least 200 cfs. Augment flows during the

period February 15 through August 31 as follows:

Month Lower McCloud River Flows (cfs) by Water Yeara

February 15-29 0-75% ROb No flow change

76-89% ROb No flow change

90-99% RObIncrease flow by 75 cfs

100-119% RObIncrease flow by 125 cfs

≥120% RObIncrease flow by 175 cfs
56

Month Lower McCloud River Flows (cfs) by Water Yeara

March 1-15 0-75% ROb No flow change

76-89% RObIncrease flow by 50 cfs

90-99% RObIncrease flow by 50 cfs

100-119% RObIncrease flow by 100 cfs

≥120% RObIncrease flow by 150 cfs

March 16-31 0-75% ROc No flow change

76-89% ROc No flow change

90-99% ROcIncrease flow by 50 cfs

100-119% ROcIncrease flow by 50 cfs

≥120% ROcIncrease flow by 150 cfs

April 1-15 0-75% ROc No flow change

76-89% ROc No flow change

90-99% ROc No flow change

100-119% ROcIncrease flow by 50 cfs

≥120% ROcIncrease flow by 50 cfs

If the release from McCloud dam (MC-7) on April 15 is equal to or greater than 200

cfs:

On each Friday after April 15, decrease the flow by 50 cfs per week until the flow reaches

200 cfs, then maintain 200 cfs release at McCloud dam (MC-7) through June 30

July 1 through August 31: release 175 cfs at MC-7, but maintain at least 215 cfs at Ah-DiNa (MC-1)

Beginning September 1: Release 175 cfs at MC-7, but maintain at least 200 cfs at Ah-Di-Na

(MC-1)

If the release from McCloud dam (MC-7) on April 15 is less than 200 cfs:

Beginning April 16: Release 175 cfs at MC-7, but maintain at least 200 cfs at Ah-Di-Na

(MC-1).

a Using most recent California Department of Water Resources Sacramento Valley

Water Year Type Index forecast

b

February 1 runoff percentage from DWR Bulletin 120 for McCloud River above

Shasta Lake

c March 1 runoff percentage from DWR Bulletin 120 for McCloud River above

Shasta Lake.
57

 Implement a minimum flow release schedule for the Iron Canyon dam reach,

as follows:

Release from Iron Canyon Dam (cfs) by Water Year-type

Month Wet Above Normal

Below Normal, Dry,

Critically Dry

October 10 7 7

November 10 7 7

December 15 10 7

January 15 10 7

February 15 10 7

March >20a15 10

April >20a15 10

May 15 10 7

June 15 10 7

July 10 7 7

August 10 7 7

September 10 7 7

a

In March and April of wet water years, the flow control vale on Iron

Canyon dam shall be fully opened. Mean daily flow shall be at least 20 cfs

during this period.

 Downramp all spill events controllable at McCloud dam by valve operation at

a maximum rate of 150 cfs per 48 hour until the prescribed minimum instream

flow value is reached and upramp operational controllable spills at McCloud

dam at a maximum rate of 200 cfs per 24-hour period.

 Determine water year type based on the forecast of unimpaired runoff of the

McCloud River above Shasta Lake as provided by DWR Bulletin 120 or its

successor.

 Operate, maintain, and modify (if necessary) gages needed to determine river

stage and minimum streamflow; measure and document all instream flow

releases in publicly available formats.

 Develop and implement an Aquatic Biological Monitoring Plan, as specified

by Forest Service condition 27, for fish, benthic macroinvertebrates, special

status aquatic mollusks, other special status species, and invasive aquatic

species, with the inclusion of monitoring schedules specific to each component

of the plan. The special status species section of the Aquatic Biological
58

Monitoring Plan also should incorporate a monitoring plan for northwestern

pond turtles and foothill yellow-legged frogs. The number of sites, site

locations, sampling methods, and data protocols should be consistent with

relicensing studies.

 File an annual report on the reintroduction and status of listed anadromous

species in the project area. The report should detail the steps that have been

taken in the reintroduction, a status of the findings and actions of the

Interagency Fish Passage Steering Committee, and should include the

comments of NMFS.

Terrestrial Resources and Threatened and Endangered Species

 Implement a Vegetation and Invasive Weed Management Plan, as specified by

Forest Service condition 25, with modifications to include provision of

information to managers regarding sensitive species, protection of culturally

significant plant populations, provisions for the use of herbicides and

pesticides, and implementation of BMPs to minimize effects on wetlands.

 Implement a Terrestrial Biological Management Plan, as specified by Forest

Service condition 26, with the inclusion of species-specific monitoring

modifications and limited operating periods. Prepare biological evaluations for

special status species and biological assessments for threatened and

endangered species prior to construction.

Recreation Resources

 Stock 60,000 pounds of trout annually at the project, develop (for Commission

approval) and implement a fish stocking plan in consultation with California

Fish and Game within 1 year of license issuance, and evaluate and monitor the

amount of fish to be stocked every 6 years.

 Provide lighting at both the Tarantula Gulch and Iron Canyon boat launches.

 Conduct a site evaluation to determine the location of a pedestrian shoreline

access trail at the lower end of Pit 7 reservoir, with paved parking. Once a

suitable location is found, construct this facility within 5 years of Commission

approval of the Recreation Plan.

Cultural Resources

 Implement the final HPMP (PG&E, 2010b) upon license issuance.

Land Use and Aesthetic Resources

 File copies of the existing Spill Prevention, Control, and Countermeasures Plan

and Hazardous Materials Business Plan with the Commission and provide

copies to the Forest Service and the Central Valley Regional Water Quality

Control Board (Central Valley Regional Water Board) within 30 days of

license issuance and continue to implement these plans.
59

2.4 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED

ANALYSIS

2.4.1 Issuing a Non-Power License

A non-power license is a temporary license that the Commission terminates when

it determines that another governmental agency will assume regulatory authority and

supervision over the lands and facilities covered by the license. At this point, no agency

has suggested a willingness or ability to do so. No party has sought a non-power license,

and we have no basis for concluding that the project should no longer be used to produce

power. Thus, we do not consider a non-power license a realistic alternative to relicensing

in this circumstance.

2.4.2 Federal Government Takeover of the Project

We do not consider federal takeover to be a reasonable alternative. Federal

takeover and operation of the project would require Congressional approval. Although

that fact alone would not preclude further consideration of this alternative, there is no

evidence to indicate that federal takeover should be recommended to Congress. No party

has suggested federal takeover would be appropriate, and no federal agency has

expressed an interest in operating the project.

2.4.3 Project Retirement

Project retirement could be accomplished with or without removal of the dams.

Either alterative would involve denial of the relicense application and surrender or

termination of the existing license with appropriate conditions and cessation of power

generation at the project, resulting in the following effects:

 Energy currently generated at the project by a renewable resource would be

lost.

 There would be significant costs involved in retiring the powerhouse and

appurtenant facilities.

 The environmental enhancements currently proposed by PG&E would be

foregone.

 If the dam and control structures were removed, the original riverine habitat

could not be reestablished because of the presence of Shasta dam and Shasta

Lake, which inundates the Lower McCloud River and abuts the Pit 7 afterbay.

Also, the presence of Shasta dam prevents unobstructed fish passage into areas

upstream, including the McCloud-Pit Project.

 If the dam and control structures were removed, the existing recreational,

residential, and commercial interests around the project would be

compromised.
60

 The potential for environmental effects such as the release of sediments

accumulated behind the dam to the river downstream and loss of lacustrine

habitats and wetlands could occur.

The removal of the dam and control structures, however, would restore some

riverine habitat, eliminate any fish entrainment mortality that may be occurring, provide

recreational riverine boating, provide the potential for future unobstructed fish passage if

Shasta dam were removed, and allow the Tribes to potentially re-establish some of their

traditional uses of the river that occurred prior to impoundment.

Despite these potential benefits, we do not regard this alternative as reasonable in

view of the many more potential losses.

The second project retirement alternative would involve retaining the dam and

control structures and disabling or removing equipment used to generate power. Project

works would remain in place and could be used for historic or other purposes. This

alternative would require us to identify another government agency with authority to

assume regulatory control and supervision of the remaining facilities. No agency has

stepped forward to assume regulatory control and no participant has advocated this

alternative; therefore, we have no basis for recommending this action. Furthermore,

because the power supplied by the project is needed, a source of replacement power

would have to be identified. In these circumstances, we do not consider removal of the

electric generating equipment to be reasonable alternative.

For these reasons, we do not consider dam removal a reasonable alternative to

relicensing the project with appropriate protection, mitigation, and enhancement

measures.
61

3.0 ENVIRONMENTAL ANALYSIS

In this section, we present: (1) a general description of the project vicinity; (2) an

explanation of the scope of our cumulative effects analysis; and (3) our analysis of the

proposed action and other recommended environmental measures. Sections are

organized by resource area (aquatic, recreation, etc.) and we first describe each resource’s

affected environment, which includes historic and current conditions. The existing

condition is the baseline against which environmental effects of the proposed action and

alternatives are compared. Next, we describe the environmental effects of the proposed

project, including an assessment of the effects of proposed protection, mitigation, and

enhancement measures, and any potential cumulative effects of the proposed action and

alternatives. Unless otherwise identified, the source of our information is the license

application for the project (PG&E, 2009a). We provide citations for information

obtained from other sources, including subsequent filings related to the project.

3.1 GENERAL DESCRIPTION OF THE RIVER BASIN

The project is located along the western slope of the Cascade Range in the Central

Valley of northern California, within Shasta County and the Shasta-Trinity National

Forest.9The project area originates at McCloud reservoir and occupies the McCloud and

Lower Pit River Basins to Shasta Lake. The project area is entirely contained within the

Sacramento River Hydrologic Region of California and specifically includes the

following: McCloud reservoir; McCloud River from McCloud reservoir downstream to

the confluence with Squaw Valley Creek; Iron Canyon reservoir and Iron Canyon Creek

from Iron Canyon dam downstream to the Pit River; the Pit River downstream of the

James B. Black powerhouse to the Pit River arm of Shasta Lake immediately downstream

of Pit 7 afterbay; and tributaries that flow into the project reservoirs. The maximum

elevation of the project area is about 2,680 feet, the normal maximum water surface

elevation of McCloud reservoir.

The area surrounding the project is primarily federal forest land with rural

communities and one larger incorporated city (>80,000 residents) nearby. Land uses in

and around the project area include recreational and commercial activities such as

fishing, swimming, timber harvest, and wildlife management. Water uses such as

municipal and domestic supply, power production, recreation, warm- and cold-water

spawning, and wildlife habitat are also associated with the project area.

The Cascades are a chain of active and explosive volcanic cones that extend from

British Columbia in the north to Mount Lassen, California. Mount Shasta, the headwater

region of the McCloud River system associated with the project, is the second highest

volcano within the Cascade Range. To the east of the Cascades, the geologic setting

9 A portion of the route of the proposed McCloud transmission line crosses about

5 miles of the southern portion of Siskiyou County.
62

transitions into one dominated by formations associated with the Modoc Plateau; the

major drainage of the Modoc Plateau is the Pit River, which is meandering and lowgradient in its upper reaches until it enters the canyon topography upstream of Shasta

Lake, including the Pit 6 and Pit 7 Developments. Rivers and streams of the project area

are typically steep gradient and highly confined, resulting in minimal flood plain

development.

The project vicinity has a temperate climate with warm, dry summers and cool

winters. Moderate snowfall occurs above elevations of 5,000 feet, and precipitation falls

predominantly as rain at lower elevations. The National Weather Service maintains a

monitoring station (No. 045449) in the town of McCloud, which has documented July air

temperatures from an average maximum high of 87.8 degrees Fahrenheit (°F) to an

average minimum low of 47.6°F. Air temperatures in January range from an average

maximum high of 45.7°F to an average minimum low of 23.6°F. Annual mean

precipitation at McCloud is 50.57 inches, most (78 percent) of which falls between

November and March, and annual mean snowfall is 81.5 inches.

The project area is characterized by a variety of vegetation types typical of mixed

woodland and mid-elevation forest habitats found in the southeastern Klamath Mountains

and west-slope southern Cascade regions. More than three-quarters of the land is

occupied by Douglas-fir–Ponderosa pine, Douglas-fir, and mixed conifer forests. The

remaining land supports a wide array of vegetation types where plant species diversity is

high due to the complex topography of the project area. In general, the topographical

features of the project area preclude extensive wetland habitat, although wetlandassociated vegetation often exists adjacent to and within the active river channel, and

additional wetlands occur in small patches along the reservoirs.

In addition to the McCloud-Pit Hydroelectric Project, which is the only

hydroelectric project on the McCloud River, PG&E owns and operates other projects in

the Pit River watershed: Pit 1 Project (FERC No. 2687); Pit 3, 4, and 5 Project

(FERC No. 233); and Hat Creek Project (FERC No. 2661). Tributaries to the Pit River

also have several smaller-scale hydroelectric projects. These other hydroelectric systems

receive and regulate flows from most of the Pit River watershed upstream of the town of

Big Bend.

3.2 SCOPE OF CUMULATIVE EFFECTS ANALYSIS

According to the Council on Environmental Quality’s regulations for

implementing NEPA (50 CFR §1508.7), an action may cause cumulative effects if its

impacts overlap in space and time with the impacts of other past, present, and reasonably

foreseeable future actions, regardless of what agency or person undertakes such other

actions. Cumulative effects can result from individually minor but collectively

significant actions taking place over a period of time, including hydropower and other

land and water development activities.
63

Based on information in the license application, agency comments, public

comments, other filings related to the project, and staff analysis, we identified water

quality and fisheries as having the potential to be cumulatively affected by the continued

operation and expansion of the McCloud-Pit Project, in combination with other past,

present, and future activities that occur in the McCloud and Pit River watersheds. These

cumulative effects are discussed in more detail in section 3.3.2.3, Cumulative Effects

(Aquatic Resources).

3.2.1 Geographic Scope

The geographic scope of the cumulative effects analysis defines the physical limits

or boundaries of the proposed action’s effects on resources. Because the proposed action

would affect resources differently, the geographic scope for each resource may vary. For

most fisheries and water resources, the geographic scope would include all project

reservoirs (McCloud, Iron Canyon, Pit 6, and Pit 7), Pit 7 afterbay, tributaries that flow

into the reservoirs, and streams downstream of the project reservoirs, including the

McCloud River from McCloud reservoir downstream to the confluence with Squaw

Valley Creek, Iron Canyon Creek from Iron Canyon dam downstream to the Pit River,

and the Pit River downstream of the James B. Black powerhouse to the Pit River arm of

Shasta Lake, immediately downstream of the Pit 7 afterbay.

3.2.2 Temporal Scope

The temporal scope of our cumulative analysis in the EIS will include past,

present, and future actions and their possible cumulative effects on each resource. Based

on the license term, the temporal scope will look 30 to 50 years into the future,

concentrating on the effect of reasonably foreseeable future actions on the resources. The

historical discussion will be, by necessity, limited to the amount of available information

for each resource.

3.3 PROPOSED ACTION AND ACTION ALTERNATIVES

This section outlines environmental effects of the proposed action and action

alternatives with regard to: (1) geology and soils, (2) aquatic resources, (3) terrestrial

resources, (4) threatened and endangered species, (5) recreation resources, (6) cultural

resources, and (7) land use and aesthetic resources.

In discussing environmental effects, we review the proposals submitted by the

applicant, agencies, and the public in accordance with the ILP. As summarized in

section 2.2, Applicant’s Proposal, we specifically discuss in each section, where

applicable:

 The applicant’s proposed protection, mitigation, and enhance measures

included in its license application filed on July 16, 2009;

 The Forest Service’s 4(e) conditions filed on January 29, 2010;
64

 The Forest Service’s modified condition 19 filed on March 1, 2010;

 PG&E’s alternative 4(e) conditions filed on March 3, 2010;

 PG&E’s modified alternative 4(e) conditions filed on November 24, 2010; and

 The Forest Service’s modified 4(e) conditions filed on November 29, 2010.

In the draft EIS, we analyzed the Forest Service’s January and March conditions

and PG&E’s March alternative conditions. In this final EIS, we revise our analysis, as

necessary, to reflect the Forest Service’s and PG&E’s November filings, which

substantially revised their earlier proposals. We also address comments on the draft EIS

in this final EIS; in appendix A, we provide a summary of those comments and our

responses.

3.3.1 Geology and Soils

3.3.1.1 Affected Environment

3.3.1.1.1 Geologic Setting

The McCloud-Pit Hydroelectric Project covers three major geologic terranes

which affect surficial processes, erodibility, and drainage development: the Eastern

Klamath belt, the Western Cascades terrane, and the High Cascades terrane. The

majority of the upper basin of McCloud dam is located in the High Cascades and Western

Cascades terranes, and the lower basin occurs almost entirely in the Eastern Klamath belt.

The entire Lower McCloud River and portions of the Iron Canyon Creek watershed and

the Lower Pit River are located within the Eastern Klamath belt.

The landscape in the project vicinity reflects widespread regional uplift and fluvial

incision resulting in highlands and deep canyons. The upper portion of McCloud

reservoir is underlain by shale and greywacke sandstone. In the middle portion of

McCloud reservoir, metavolcanic rocks are juxtaposed against outcrops of limestone and

interbedded tuffaceous mudstone and sandstone. Erosion tendencies along riparian

slopes in the Lower McCloud River vary according to the adjacent rock type. Mafic

flows, tuffaceous mudstone, and minor amounts of limestone occur in the lower portion

of the reservoir and downstream of McCloud dam, and exposed rocks are strongly jointed

and moderately fractured, forming steep slopes that are generally erosion-resistant.

Fractured and weathered metasedimentary and metavolcanic rocks, however, are

relatively weak and prone to mass wasting in areas with steep slopes. Survey sites in and

around Hawkins Creek are underlain by shale, siltstone, and metavolcanic rocks, with

gentle to steep slopes covered with gravelly soils and typically supporting dense mixed

conifer and oak woodland vegetation.

In the Lower McCloud River watershed, soils mantling steep slopes overlaying

metasedimentary and metavolcanic rocks are typically thin and rocky, except in areas

with convergent topography, where a thicker mantle of soil and colluvium is more

susceptible to landslides and debris flow during intense storm events. Active and
65

dormant landslide scars are susceptible to secondary erosion by rock fall and shallow

debris slides. Intensely weathered, fine-grained, and highly erodible sedimentary rocks

surrounding Iron Canyon reservoir and the upper portions of Pit 6 Powerhouse Road are

particularly susceptible to erosion when disturbed, as are potentially unstable landforms

on fractured metamorphic rocks in the Oak Mountain Road corridor and inner gorge of

the Lower Pit River.

Soil conditions around the Lower Pit River include highly weathered upland

surfaces which are in some places composed of saprolite. These soils are susceptible to

erosion and have potential for high fine sediment yields if sparsely vegetated or denuded.

Soils mantling the generally steep sided canyon slopes are thin and rocky. Debris flows

commonly are triggered on steep canyon slopes with convergent topography and thick

soil mantle during and following major storm events. These conditions are commonly

found in the area of Iron Canyon reservoir and dam, as well as in the area of the James B.

Black Development.

Seismicity

Available seismic data for the project area are classed as Critical Energy

Infrastructure Information. The Commission’s Dam Safety Program regulations

(18 CFR part 12D) require PG&E to retain an independent consultant every 5 years to

inspect, review data, and prepare project safety reports to be submitted to the

Commission. The California Water Code requires seismic stability adequacy for all dams

under the jurisdiction of the California Department of Water Resources, Division of

Safety of Dams, which are in general satisfied by the same requirements of

18 CFR part 12D. The most recent part 12D safety reports for the McCloud, Iron

Canyon, Pit 6, and Pit 7 dams were prepared in October 2006.

3.3.1.1.2 Reservoir Shorelines

McCloud Reservoir

In general, shorelines around McCloud reservoir are underlain by resistant

bedrock that limits the degree to which the shoreline can be eroded as a result of

fluctuations in the reservoir water level. McCloud reservoir shorelines can be classified

into four types: (1) convex, bedrock controlled shorelines overlain by coarse rock debris

with moderate to steep slopes and shallow soils; (2) shorelines with convex to uniform

slope profiles in protected cove locations with low to moderate slopes and fine-grained

sandy loam soils; (3) steep to very steep shorelines with shallow erosional scarps and

loose underlying rocky colluviums and sandy loam soils that support stands of mixed

conifer and shrubs; and (4) shorelines with active shallow soil erosion or rock slide

activity with very steep slopes and little or no vegetative cover. Surveys of the McCloud

reservoir shoreline revealed few erosion sites, all of which had relatively low impact

potential (table 3-1). PG&E has mitigated moderate erosion due to drainage or surface

runoff that has occurred at a few recreation areas associated with McCloud reservoir
66

(Tarantula Gulch Recreation Area, Ash Camp and Ah-Di-Na Campgrounds, Star City

Creek).

Erosion Sites

Sites for erosion evaluation in the project area were selected based on their

potential to affect aquatic resources of concern (water quality and biota), project

infrastructure, public and private access, and public health and safety. Sediment delivery

to McCloud reservoir has occurred where shoreline slopes are characterized as type 4 and

where stream crossings along FR 38N11 have gullied, resulting in sediment delivery

below the high water shoreline. Multiple road-related erosion sites were identified along

FR 38N11, in the proposed areas for future powerhouse and transmission line

development. Additionally, the actively eroding slopes of the McCloud tunnel spoils,

where they are composed of finer-grained material and located directly adjacent to

Hawkins Creek, may increase delivery of fine sediment to Hawkins Creek. However,

most of the Hawkins Creek channel is buffered from the spoil slopes by floodplain

surfaces covered by dense riparian vegetation.

Sediment Delivery

Young volcanic rocks and unconsolidated surficial deposits in the Upper McCloud

River Basin form large areas with little runoff or sediment delivery to the Upper

McCloud River. However, natural debris flows originating from the unconsolidated

inner gorge slopes of Mud Creek Canyon high on the southeast flank of Mount Shasta

have historically delivered large quantities of fine sediment to the Upper McCloud River

during summer months (Osterkamp et al., 1986), and sediment delivery from debris flows

in Mud Creek constitutes a large fraction of the sediment currently stored in McCloud

reservoir. McCloud dam and McCloud reservoir trap all coarse sediment

(>2 millimeters) delivered from upstream source areas. Sediment delivery from

tributaries draining steep topography surrounding McCloud reservoir constitutes

the majority of the coarse sediment stored in the McCloud reservoir: about

937,400 tonnes representing an average annual coarse sediment yield of about 140±30

tonnes per square kilometer per year. Other direct sediment delivery to McCloud

reservoir is attributed primarily to road-related erosion. Gully erosion extending from

suspended culverts or shallow erosion associated with very steep, barren fill slopes are

the two most common modes of erosion along FR 38N11, between McCloud dam and

Tarantula Gulch. Although active erosion was identified at site-specific locations, the

potential risk to the road infrastructure remains negligible.
67

Table 3-1. Distribution of erosion inventory sites for the McCloud reservoir and Lower McCloud River study region.

(Source: PG&E, 2009a)

Number of Erosion Sites

Ranka Roads Proposed

Infrastructureb

Mass

Wasting Spoils Shoreline Tributary RecreationUse Total

High 5 6 -- -- -- -- 3 14

Medium 5 17 3 4 -- -- 10 39

Low 1 7 -- 3 4 2 10 27

Total 11 30 3 7 4 2 23 80

a Rank is based on the potential for the site to cause future effects to project infrastructure or water resources of

concern by direct sediment delivery, relative to all inventory sites. A percentile greater than 75 is considered High; a

percentile between 25 and 75 is considered Medium, and a percentile less than 25 is considered Low.

b

Proposed Infrastructure, defined in Study Region 1 by the proposed McCloud powerhouse and proposed McCloud

transmission line, includes road-related erosion sites surveyed along FR 38N11 between McCloud dam and the town of

McCloud, California.
68

Large Woody Debris

In the McCloud basin, LWD can play an important role in channel formation and

as aquatic and riparian habitat for aquatic and wildlife resources. LWD is delivered to

the system via areas of mass wasting and toppling of tree or large limbs as a result of

bank undercutting and during storm events. LWD in tributaries of the upper McCloud

basin is carried progressively downstream during periods of high water discharge. Prior

to construction of McCloud dam, LWD from the upper basin would continue to be

redistributed through the Lower McCloud River during storm events. Presently, LWD

from the upper basin is trapped and accumulates over time in McCloud reservoir. For the

safety of recreational boaters and protection of dam structures, PG&E is required under

the existing license to regularly capture and remove LWD accumulated behind McCloud

dam.

Iron Canyon Reservoir

Iron Canyon reservoir and dam are underlain by volcaniclastic and pyroclastic

rocks, and argillite and tuffaceous sandstone, as well as weathered, clay-rich, and friable

sedimentary rocks. Outcrops of weakly metamorphosed and moderately to strongly

weathered, interbedded sedimentary rocks in this region express a wide range of rock

resistance. Shoreline slopes are moderate (30 to 65 percent) to steep (>65 percent).

The highly weathered soils and saprolite in this area are easily eroded, particularly

where sparsely vegetated, and are potential sources of sediment. Slopes around the

northern and western portions of Iron Canyon reservoir range from gentle to moderate

but become steep along the southern margin in areas adjacent to the dam. Gentle to steep

slopes surrounding the reservoir and dam support mixed conifers, oak woodland, and

riparian vegetation.

The two predominant soil types in shoreline areas are loose, gravelly sandy loam

soils and cohesive, clay loam soils. Shoreline erosion of up to about 3 feet above the

water line occurs at locations where tree stumps and roots have been exposed and is

common around the reservoir perimeter, indicating shoreline lowering since completion

of Iron Canyon dam in 1965. There are deeply incised gullies where stream channels

enter the reservoir. Concentrated surface runoff from spur roads has caused lesser

amounts of gully erosion below the high water shoreline. Slumping and shallow scarps

were observed in relatively few shoreline areas, on moderately steep slopes and steep

hillslopes above the high water line.

Erosion Sites

Surveys of the Iron Canyon reservoir shoreline identified five erosion sites, all of

which have low to medium impact potential (table 3-2). The Iron Canyon reservoir

perimeter road has 22 erosion sites associated with road drainage diversions, plugged or

restricted ditch relief structures, and OHV use; 15 of these were classified as low to

medium impact. Concentrated surface runoff has resulted in rill erosion along steep,

unpaved road surfaces. During erosion inventories, PG&E observed delivery of fine
69

sediment to Iron Canyon reservoir and tributary stream channels at the majority of

erosion sites surveyed along the perimeter road.

Two former borrow pits located northeast of Iron Canyon dam were evaluated

during field surveys. The northernmost borrow pit showed extensive evidence of past

and active gully erosion at numerous locations across the disturbed hillslope. It appears

that significant headward erosion into brittle, clay-rich sediments has occurred since

excavation of the borrow pit. Two deep gully channels incise up to 2,500 feet of slope

extending to Iron Canyon reservoir. Thick accumulations of sediment were stored behind

grade control structures installed along these gully channels, and some of the grade

control structures near the gully headwalls have failed. The Forest Service has

implemented measures to control severe gully erosion at this site.

Large Woody Debris

In the Iron Canyon basin, LWD plays an important role in channel formation and

as habitat for fish and aquatic resources. LWD is delivered to the system via areas of

mass wasting and toppling of tree or large limbs as a result of bank undercutting and

during storm events. LWD in tributaries to Iron Canyon reservoir is carried progressively

downstream during periods of high water discharge. Prior to construction of Iron Canyon

dam, LWD would continue to be redistributed down Iron Canyon Creek to the Pit River

during storm events. Presently, LWD from tributaries to Iron Canyon reservoir is trapped

and accumulates over time in the reservoir. For the safety of recreational boaters and

protection of dam structures, PG&E has instituted a program to periodically capture and

remove LWD from Iron Canyon reservoir.
70

Table 3-2. Distribution of erosion inventory sites for the Iron Canyon reservoir and dam study region. (Source: PG&E,

2009a)

Number of Erosion Sites

Ranka Roads Proposed

Infrastructure

Mass

Wasting Spoils Shoreline Tributary RecreationUse Total

High 7 -- -- 1 -- -- -- 8

Medium 12 -- 2 7 3 6 4 34

Low 3 -- -- 3 2 11 2 21

Total 22 0 2 11 5 17 6 63

a Rank is based on the potential for the site to cause future effects to project infrastructure or water resources of

concern by direct sediment delivery, relative to all inventory sites. A percentile greater than 75 is considered High; a

percentile between 25 and 75 is considered Medium, and a percentile less than 25 is considered Low.
71

Sediment Delivery

Sources of fine sediment to Iron Canyon reservoir include road erosion into

tributaries to Iron Canyon reservoir, active erosion from the borrow pits northeast of Iron

Canyon dam, and concentrated road runoff along the Iron Canyon dam access road.

Additionally, the reservoir shoreline, with erosion ranging from localized to extensive, is

a major contributor of fine sand, silt, and clay to the reservoir. Channel banks along

tributaries above the high water shoreline are protected mostly by dense riparian

vegetation or bedrock outcrops, but actively eroding channel banks in reaches below the

high water shoreline with bedrock channel beds have a high potential to deliver sediment

to the reservoir. Finally, rill erosion and soil disturbance related to unrestricted OHV use

is a widespread source of direct fine sediment delivery to Iron Canyon reservoir.

3.3.1.1.3 Project Reaches

Lower McCloud River

Sediment Delivery

In contrast to the Upper McCloud River Basin, the Lower McCloud River Basin is

comprised almost entirely of steep slopes and a dense, deeply incised channel network

that promotes a more peaked response to storm events and higher rates of coarse

sediment delivery by mass wasting. Cumulative sediment supply to the Lower McCloud

River under regulated conditions ranges from 1,450 tonnes per year at the Hawkins Creek

confluence to 7,050 tonnes per year at the Squaw Valley Creek confluence. Under

unimpaired conditions, the Lower McCloud River was likely supply limited from

McCloud dam to at least Bald Mountain Creek. Large alluvial bedforms such as point

bars and island bars occur infrequently and are relatively immobile due to their coarsegrained composition. LWD does not influence channel morphology or sediment storage

in the Lower McCloud River. The number and distribution of erosion sites in this area is

provided in table 3-1.

At McCloud dam, a tight meander bend located directly across from the bottom of

the spillway lies within sheared metavolcanic and sedimentary bedrock and is subject to

erosion during large spillway releases. Future large spillway releases have the potential

to further erode rock in the meander bend and associated low saddle as well as in the

embankment supporting the road. Rock fall and shallow landslides have produced dry

ravel (loose rock particles) along steep cut slopes, and deposited rock and debris into the

inboard ditch associated with FR 38N11 as it traverses relatively steep terrain

immediately downstream of McCloud dam. Mass wasting associated with sites in this

area indicates a potential to affect road access and deliver sediment to the McCloud

River. Sediment produced by episodic erosion during large spillway releases and chronic

secondary erosion of the retreating cliff face across from McCloud dam is delivered

directly to the Lower McCloud River, indicating a high potential for future mass wasting

in the vicinity.
72

The Lower McCloud River is a mixed bedrock-alluvial channel with high

transport capacity relative to sediment supply and generally low volumes of active

sediment storage. Channel reach morphology in the Lower McCloud River broadly

transitions from predominantly step pool upstream of Ah-Di-Na to alternating plane bed

and pool riffle downstream of Ah-Di-Na, reflecting an overall decrease in slope and

confinement and an increase in mobile sediment supply. The resistant bedrock and

boulder channel boundaries in the Lower McCloud River render channel geometry less

sensitive to changes in hydrologic and sediment supply regimes. Large, immobile grains

within the Lower McCloud River reduce the sheer stress available for transporting finer

mobile sediment and create velocity shadows that induce deposition of finer material,

forming one of the primary storage elements of mobile coarse sediment within the active

channel. Similarity in the size of coarse sediment supplied by major tributaries and the

size of mobile deposits in the mainstem Lower McCloud River emphasizes the

importance of coarse sediment inputs from major tributaries (e.g., Hawkins Creek,

Ladybug Creek, Bald Mountain Creek, Claiborne Creek, Squaw Valley Creek) in

supplying the mobile sediment fraction, including spawning gravel size classes, to the

McCloud River downstream of McCloud dam.

Bed mobility and transport capacity in the Lower McCloud River are primarily

controlled by differences in channel slope which generally follow a downstream

decreasing continuum. Bed mobilization occurs at an estimated 1,030 cfs in the vicinity

of Ah-Di-Na and at 2,060 cfs between Claiborne Creek and Squaw Valley Creek. Initial

mobilization of more mobile sediment patches in most locations occurs at flows >620 cfs.

Annual average bedload transport capacity peaks in the vicinity of Ah-Di-Na and

declines downstream, reaching a minimum between Claiborne Creek and Squaw Valley

Creek. The presence of suspended sediment in the Lower McCloud River, including

sediment delivery from Mud Creek, is discussed in section 3.3.2.1.2, Water Quality.

Large Woody Debris

Because LWD from the upper McCloud basin is trapped and removed from behind

McCloud dam, the quantity of LWD is reduced in the Lower McCloud River. LWD

inventories show that there is very little LWD stored in the Lower McCloud River

channel between McCloud dam and Shasta Lake. Below Squaw Valley Creek, the Lower

McCloud River is subject to higher flow variation and debris inputs from multiple

tributaries, so the effect of McCloud dam on the quantity and distribution of LWD is

diminished.

Iron Canyon Creek

Sediment Delivery

Accelerated sediment delivery in Iron Canyon Creek is related to erosion of the

access road to the Iron Creek gage and related spur roads, rilling of the native hillslopes

adjacent to the east and west dam abutments, and entrainment of fine sediment stored in

Iron Canyon reservoir in the vicinity of the valve intake. The consequent accelerated
73

delivery of fine sediment to Iron Canyon Creek and the absence of flow releases that

frequently mobilize sediment have resulted in increased fine sediment storage in the bed

and banks of the relatively low-gradient channel reach immediately downstream of Iron

Canyon dam. Geomorphic monitoring demonstrates that annual valve releases would

effectively reduce fine sediment accumulation in the reach immediately downstream of

Iron Canyon dam.

Increases in suspended sediment concentrations in Iron Canyon Creek and the Pit

River due to interbasin transfer between the McCloud River Basin and the Iron Canyon

Creek and Pit River Basins during episodic mass-wasting events is minimal and

discussed in more detail in section 3.3.2.1.2, Water Quality.

Large Woody Debris

Based on field observations, the recruitment of LWD to Iron Canyon Creek is

comparable to regional creeks and environments. The quantity of LWD is consistently

distributed longitudinally along the stream channel between Iron Canyon dam and Pit

River. Experimental flow releases at Iron Canyon dam indicated that LWD was

mobilized when flows exceeded the bankfull discharge.

Lower Pit River

Project areas characterized in the Lower Pit River include those in the vicinity of

Oak Mountain Road, Pit 6 Powerhouse Road, Pit 7 Powerhouse Road, and the Proposed

Pit 7 afterbay powerhouse and transmission line. The topography in the Oak Mountain

Road (FR 37N34) corridor north of the Pit 6 reservoir is moderately steep to steep, with

dormant landslides and debris basins on very steep, southeast-facing slopes from the

ridgeline to the Pit River (Forest Service, 2005). In the Lower Pit River, gentle to

moderate slopes are underlain by resistant volcanic rocks which are relatively stable, with

localized debris basins on steeper slopes leading to the Pit River. Shallow debris slides

coalesce and areas of active rock-fall occur along the steep inner gorge slopes of Pit

River Canyon.

PG&E reported 54 observed erosion sites along the Oak Mountain Road corridor,

about 59 percent of which were identified as road-related (table 3-3). Sites along this

road and associated spur roads have a moderate to high potential to deliver sediment to

Iron Canyon reservoir, tributaries to Iron Canyon Creek, or the Pit River. Additionally,

concentrated surface runoff and road-related erosion along spur roads to the Willow

Creek siphon have potential to deliver sediment to Willow Springs Creek and interrupt

access to project facilities.

Erosion is also evident in a few locations along the edge of the Iron Canyon tunnel

spoils (table 3-3), which are near the ridgeline of a tributary to Iron Canyon Creek west

of the penstock pipe and downstream of the Iron Canyon tunnel portal. PG&E attributes

two existing shallow debris slides to the settling of the spoils. Downslope, two gully

channels are scoured to bedrock and have coalesced, delivering sediment directly into an

Iron Canyon Creek tributary.
74

PG&E mitigated the effects of a 1997 storm-related large debris flow that

destroyed stream crossing structures. The debris flow scar from this storm remains a

major potential sediment source. Other debris flow-related mitigation includes the repair

of the James B. Black penstock pipe that ruptured after a 1978 bedrock landslide, and

associated bedrock stabilization. PG&E’s subsequent creation of a Penstock Safety

Program ensures routine evaluation and review of penstock alignment and adjacent

slopes.

PG&E identified additional erosion sites further downstream in the Lower Pit

River (table 3-4). Along Pit 6 Powerhouse Road, there is evidence of past and active

erosion in several areas. Concentrated surface runoff from culvert outlets and diverted

road drainage has caused gully erosion and shallow slope failure of soils and engineered

road fill. Debris slide scars along steep inner gorge slopes exposed unconsolidated

fluvial gravels overlying metasedimentary bedrock.

The access road to the Pit 7 powerhouse traverses moderately steep, wellvegetated slopes. Aggraded ditch relief structures, suspended culvert outfalls, diverted

road runoff, and fluvial erosion along channel bank toe slopes has caused surface and

gully erosion at the outboard road edge at several sites. Thinly bedded metasedimentary

bedrock along the access road is relatively resistant to erosion and shows only a few

localized shallow slide scars at steep to near vertical road cut banks.
75

Table 3-3. Distribution of erosion inventory sites for the Oak Mountain Road Study Region. (Source: PG&E, 2009a)

Number of Erosion Sites

Ranka Roads Proposed

Infrastructure

Mass

Wasting Spoils Shoreline Tributary RecreationUse Total

High 17 -- 10 1 -- -- -- 28

Medium 14 -- 6 2 1 2 -- 25

Low 1 -- -- -- -- -- -- 1

Total 32 0 16 3 1 2 0 54

a Rank is based on the potential for the site to cause future effects to project infrastructure or water resources of

concern by direct sediment delivery, relative to all inventory sites. A percentile greater than 75 is considered High; a

percentile between 25 and 75 is considered Medium, and a percentile less than 25 is considered Low.

Table 3-4. Distribution of erosion sites in the Lower Pit River Study Region. (Source: PG&E, 2009a)

Number of Erosion Sites

Ranka Roads Proposed

Infrastructure

Mass

Wasting Spoils Shoreline Tributary RecreationUse Total

High 6 -- -- -- -- -- -- 6

Medium 17 1 -- 1 -- -- -- 19

Low 3 1 -- 2 -- -- 1 7

Total 26 2 0 3 0 0 1 32

a Rank is based on the potential for the site to cause future effects to project infrastructure or water resources of

concern by direct sediment delivery, relative to all inventory sites. A percentile greater than 75 is considered High; a

percentile between 25 and 75 is considered Medium, and a percentile less than 25 is considered Low.
76

Proposed Infrastructure

PG&E evaluated slope conditions in the vicinity of the proposed location for the

Pit 7 afterbay powerhouse and transmission line. This area is characterized by moderate

to steep (40–65 percent) slopes underlain by massive to fractured volcaniclastic bedrock

and overlain by shallow, rocky soils that support mature conifers and understory shrubs.

PG&E observed old shallow landslide scars in this area but no active erosion. A narrow

and benched ridgeline along the northern divide of this second drainage provides

potentially suitable sites for the new powerhouse. Bedrock outcrops at the terminus of

this ridge form a nearly vertical slope above the west abutment of the Pit 7 afterbay dam.

As planned, the proposed transmission line has an initial trajectory of south 10°

east leading from the proposed Pit 7 afterbay powerhouse to FR 35N23. The proposed

alignment traverses an active gully and steep, inner gorge slopes between the east

abutment of Pit 7 afterbay dam and FR 35N23. An alternative alignment for the

transmission line would traverse more gentle slopes (<50 percent) underlain at shallow

depths by bedrock.

Sediment Delivery

Active erosion along the steep inner gorge portion of Pit 6 Powerhouse Road has

caused delivery of unconsolidated sediment and spoils material to the Pit River. Active

gully incision from a non-project road, FR 34N17, has caused multiple gully channels to

form on lower gradient toe slopes located within the project area with a high potential for

direct delivery of eroded sediment to the Lower Pit River.

3.3.1.2 Environmental Effects

Continued operation of the McCloud-Pit Project could affect geology and soils in

the watershed by affecting streamflow, sediment trapping and transport, and geomorphic

characteristics of the stream channel. PG&E proposes infrastructure additions that may

affect geology and soils in the watershed, and PG&E’s proposed license measures focus

on minimizing issues that may result from the installation of the proposed infrastructure

as well as address operation and management issues that have been observed during

project operation in the current term of the license. Observed issues include trapping of

LWD; erosion from bare surfaces, rockfalls, road-related surfaces, tunnel spoils, and

borrow pits; reservoir sedimentation; and project effects on sediment supply and

transport.

Continued operation of the project may influence the rate of erosion in the

watershed and the trapping of sediment in project reservoirs. Project operations may also

limit LWD retention and sediment storage in the Lower McCloud River. Therefore,

PG&E proposes to develop an Erosion and Sediment Monitoring and Control Plan and an

LWD Management Plan. Additionally, the Forest Service, NMFS, and FWS have

recommended that PG&E develop a plan for gravel and coarse sediment management,

which was not included in the final license application.
77

Large Woody Debris

LWD can provide habitat structure in streams and affect sediment storage and

channel morphometry through its effect on the distribution of flows and water velocity

within the stream channel and sediment mobilization and transport. LWD can provide

cover and holding habitat for fish, serve as substrate for growth of epibenthic algae and

invertebrates, and affect sediment deposition and scouring. Loss of LWD could result in

reduced complexity of aquatic habitat and reduced carrying capacity for aquatic biota.

In Iron Canyon Creek, LWD is abundant and project operations appear to have

little or no effect on LWD supply, based on observations that LWD recruitment

downstream of Iron Canyon dam is comparable to regional creeks and environments.

The volume of LWD in Iron Canyon Creek is consistently distributed longitudinally in

the stream channel, which may indicate that LWD mobilization happens on a regular

basis despite flow regulation.

In the Lower McCloud River, the large channel width, high stream power, and

normally low LWD loads due to project operations result in limited opportunity for LWD

retention and associated long-term sediment storage within the bank full channel

perimeter. LWD from the upper watershed accumulates in McCloud reservoir during

high flow events, and under the current license, PG&E generally removes LWD to

protect the McCloud dam structure. These active safety measures, as well as the dam

itself, reduce the supply of LWD and impede the transport of LWD from the upper

reaches of the McCloud River to the lower reaches of the river below McCloud dam.

In its license application, PG&E proposes to prepare an LWD Management Plan,

in consultation with the Forest Service, within 1 year after license issuance. The plan

would provide an operating procedure to facilitate the placing of woody debris

downstream of McCloud dam to replace LWD removed from the system by O&M of the

McCloud dam. The plan would specify size criteria, placement and storage sites, volume

and frequency of placement, and monitoring procedures.

Forest Service condition 21 supports PG&E’s proposal to prepare an LWD

Management Plan approved by the Forest Service within 1 year of license approval.10

The condition specifies that monitoring procedures included in the plan should assess

mobilization of LWD from the augmentation site. In its November 29, 2010, filing the

Forest Service included a draft LWD Plan as an enclosure to the filing (Forest Service,

2010d, Enclosure 3). In the draft plan, the Forest Service recommends a framework and

guidelines for capture, removal, placement, storage, and monitoring of LWD from

McCloud reservoir.

10 In its modified condition 21, the Forest Service changed the starting point for

preparing project plans from license “issuance” to license “acceptance.” In discussing

Forest Service conditions throughout section 3.3, we have changed the term without

highlighting it as a change from the original conditions filed in January 2010.
78

In its original condition 30, the Forest Service specified that LWD removed from

reservoirs as part of recreation development, management, and monitoring may be reintroduced to the Lower McCloud River as directed in the LWD Management Plan. The

Forest Service dropped this specification from modified condition 30.

NMFS also submitted comments on the proposed action, specifically stating that

the LWD Management Plan should ensure that LWD inputs will not be prevented from

migrating downstream, in order to maintain habitat benefits to both resident biota and

anadromous listed salmonids.

Our Analysis

LWD contributes to productive aquatic ecosystems, and is an important

component in the formation of complex aquatic habitat units and channel maintenance.

LWD provides aquatic habitat along the margins and in the active portion of the river

channel, riparian habitat on surfaces above the low-flow channel, and organic matter

which supports the aquatic food web.

PG&E conducted inventories and aerial footage reviews of the Lower McCloud

River that indicated little LWD storage between McCloud dam and Shasta Lake and few,

if any, channel forming LWD elements. Although the frequency of smaller flood events

is diminished by project operations, larger floods capable of mobilizing and redistributing

LWD are uncontrolled and continue to occur on a regular basis. These floods,

supplemented by placement of accumulated LWD from McCloud reservoir in

downstream reaches, would increase the abundance of LWD in these reaches and provide

habitat benefiting aquatic and riparian organisms in areas where LWD is retained within

the active stream channel and adjacent riparian areas.

NMFS recommends that any LWD Management Plan should ensure that LWD

inputs would not be prevented from migrating downstream. Presumably, the rate of

LWD inputs from the upper watershed remains similar to that experienced during preproject hydrologic conditions; however, the current hydrograph below the dam is

significantly different from pre-project conditions. Therefore, the carrying capacity of

the lower watershed is not likely able to accommodate the volume of LWD generated

within the upper watershed.

The Forest Service specifies that monitoring procedures in the LWD Plan

specifically assess mobilization of LWD from the augmentation site. Existing survey

information documents the amount and distribution of LWD in the Lower McCloud

River; however, there is an absence of data that indicates how effective the proposed

minimum and periodic spill flows will be at mobilizing and distributing LWD. The

Forest Service’s recommended monitoring program would provide information necessary

to assess whether the locations and quantity of LWD placement are appropriate to

achieve the objectives.
79

Erosion and Sediment Control

Surface erosion, increased overland flow, and mass wasting associated with

project construction and maintenance could release fine sediment into project waterways;

fine sediment can adversely affect environmental resources increasing turbidity and

degrading coarse substrate used for spawning. PG&E proposes construction that could

lead to stream sedimentation, increased turbidity, and geomorphic effects if proper

erosion and sediment control measures are not implemented and maintained.

Reduction of seasonal high flow events as a result of project operations may

contribute to the accumulation of fine sediment in spawning gravels, which could

adversely affect trout spawning and incubation success and contribute to the

encroachment of riparian vegetation into the stream channel. Sediment that originates

from surface erosion, rockfalls, and mass wasting in the upstream watershed is generally

transported downstream in the channel reaches and retained in reservoirs behind

structures. An inventory by PG&E identified 56 erosion sites in the project vicinity that

were ranked in the 75th percentile or above, indicating high potential of these sites to

adversely affect project infrastructure or sediment delivery to streams.

In order to manage existing erosion and minimize future erosion and sediment

delivery to stream channels, PG&E proposes to prepare an Erosion and Sediment

Monitoring and Control Plan within 1 year after license issuance. PG&E would develop

the plan in consultation with the Forest Service and other appropriate agencies. The plan

would guide management of erosion and sediment control during the term of the new

license and would include the following elements:

 Methods for ongoing inventory of project-related erosion and sedimentation;

 A schedule for periodic monitoring;

 An inventory of erosion sites (e.g., map and database) identified by periodic

monitoring;

 Criteria for treating erosion sites;

 Protocols for emergency erosion and sediment control; and

 A process and schedule for reporting monitoring results, including periodic

plan review and revision.

Inventory of project-related erosion and sedimentation would include project

roads, facilities, infrastructure, reservoir shorelines, recreational use areas, and areas of

mass wasting that are project-related or affected by project roads and facilities. Initial

priority would be placed on the 56 sites ranked as having high erosion potential. Sites

would be monitored for 5 years to assess erosion activity and associated causes. Annual

monitoring reports would include a Forest Service-compatible database of erosion sites

and detailed site-specific erosion and sediment control measures where necessary and

appropriate. Botanical resources affected by project-related erosion would be revegetated
80

according to the Vegetation Management Plan, as discussed in section 3.3.3, Terrestrial

Resources.

User-created OHV roads between the maintained Forest Service roads and

reservoir shoreline are a source of erosion and direct input of fine sediment to Iron

Canyon reservoir and tributaries. As part of the Recreation Plan, PG&E proposes to

block access to and close these user-created roads and prevent the creation of new OHV

roads in the future (see section 3.3.5.2, Environmental Effects, Dispersed Use and OHV

Use). Erosion sites associated with OHV roads located within the project boundary

would be included in the inventory of locations for prioritization, monitoring, and

mitigation.

Forest Service condition 22 specifies that, within 1 year after license acceptance,

PG&E should file with the Commission its Erosion and Sediment Control Management

and Monitoring Plan developed in consultation with the conditioning agencies 11 and

other interested parties. The condition specifies that the plan should be approved by the

Forest Service and should provide direction for managing erosion and controlling

sediment during the term of the new license. Furthermore, the Forest Service states that

during planning, and before any new construction or non-routine maintenance projects

with the potential for causing erosion or stream sedimentation on or affecting Forest

Service lands, PG&E should develop site-specific erosion control plans that will be

approved by the Forest Service. The plans would include measures to control erosion,

stream sedimentation, dust, and soil mass movement.

In its November 29, 2010 filing, the Forest Service included a draft Erosion and

Sediment Control Management Monitoring Plan as an enclosure to the filing (Forest

Service, 2010d, Enclosure 3). In the draft plan, the Forest Service recommends the

minimum components necessary to treat erosion and control sedimentation within the

project and project-affected lands during the term of the new license.

Ground-disturbing activities have the potential to disturb soil integrity. Forest

Service condition 18 specifies that if PG&E proposes additional future ground-disturbing

activities, PG&E should consult with the Forest Service to determine the scope of work

and potential for project-related effects, and whether additional information would be

required to proceed with the planned activity. This condition and the PG&E alternative

are discussed further in section 3.3.7, Land Use and Aesthetic Resources.

NMFS filed a 10(j) recommendation, with concurrence from FWS, stating that as

soon as listed salmonids are documented in the McCloud River and affected by the

11 In its November 29, 2010, filing, the Forest Service replaced California Water

Board and California Fish and Game with “Conditioning Agencies,” a term which it did

not define. In discussing Forest Service conditions throughout section 3.3, we have

changed the term without highlighting it as a change from the original conditions filed in

January 2010.
81

project, PG&E should implement flow regimes and non-flow-related measures necessary

to mitigate impacts of the project’s facilities and operations on sediment movement and

deposition, river geometry, and channel characteristics. According to the 10(j)

recommendation, these actions would include mitigation of impacts on stream

competence, capacity, floodplain conductivity, bank stability, and extent, duration, and

repetition of high flow events. This recommendation is discussed further in section 3.3.2,

Aquatic Resources.

In addition to formal 10(j) recommendations, NMFS submitted comments on the

proposed action, specifically stating that the Erosion and Sediment Monitoring and

Control Plan should consider the habitat and biological criteria needs of listed salmonids,

particularly because sediment could have adverse effects on spawning substrate and

water quality that are important for listed salmonids. The extent to which the plan would

monitor or reduce sediment inputs from the project may be beneficial to most aquatic

biota, including listed salmonids. The plan should consider the seasonal timing of

construction and O&M activities which could affect listed salmonids as well as the

sediment/erosional inputs and resulting turbidity.

Although no measures are proposed to address reservoir sedimentation or the few

areas of surface erosion (including mass wasting and rockfalls), studies, environmental

site reviews, and agency and stakeholder discussions concluded that these issues do not

present significant risk during the term of the proposed license.

Our Analysis

PG&E’s proposal for management and control of erosion and sedimentation would

provide for periodic monitoring, inventory, and prioritization of potential erosion sites,

identification of criteria and procedures for controlling/mitigating erosion sites,

development of emergency response protocols to manage erosion and sedimentation, and

establish annual mechanisms for reporting and agency review of procedures and actions.

This proposal would provide mitigation for existing erosion sites and prevention of

erosion and sedimentation associated with project infrastructure and future project

actions. It also assures consultation with Forest Service and other appropriate agencies in

developing the plan and subsequent periodic annual review by these agencies of the plan

and actions taken. The annual review would include updates to the Forest Servicecompatible database of erosion sites and detailed site-specific control measures. The

proposal would provide controls necessary to protect water quality, aquatic and riparian

habitat from the effects of erosion and sedimentation. Periodic review by the Forest

Service would provide a mechanism to insure that the measures implemented are

appropriate and adequate to prevent water quality and aquatic habitat impacts.

As part of the Recreation Plan, PG&E proposes to block access to, and prohibit

use of, user-created OHV roads and prevent future creation of such roads. Project road

locations that are a direct source of erosion and fine sediment loading have been

identified in the erosion site inventory and would be remediated as prioritized under the
82

Erosion and Sediment Monitoring and Control Plan. Site prioritization and mitigation

methods would be subject to Forest Service review on at least an annual basis.

Monitoring implemented as part of routine safety inspections at penstocks and

project water conveyance structures would minimize the risk of erosion associate leakage

or potential failure of such structures as occurred at the Iron Canyon penstock.

Developing and implementing an appropriate Erosion and Sediment Monitoring

and Control Plan for active erosion sites and future construction activities, as specified by

Forest Service condition 22, would minimize the release of disturbed sediment into

waterways, and therefore would minimize effects on water quality, aquatic habitat, and

public health and safety. Use of a ranking system to prioritize the severity of erosion

sites would provide a system for immediate mitigation and minimize any potential

impacts to waterbodies or public safety. Proper revegetation and post-construction

monitoring would ensure that disturbed areas are restored with native species, and that

gullying or other forms of erosion do not occur as a result of construction disturbance.

Monitoring the effectiveness of erosion control treatment measures would aid in

determining if further control measures are necessary.

The NMFS 10(j) recommendation included general measures to affect sediment

movement and deposition, substrate quality, and channel characteristics to support listed

anadromous salmonids. No specific measures or procedures are recommended. The

Keswick and Shasta dams on the Sacramento River downstream of the McCloud dam are

existing barriers to upstream passage of anadromous salmonids including Chinook

salmon and steelhead. None of the listed anadromous salmonids would be expected to

have access to habitat in the Lower McCloud River until upstream migration of listed

species is implemented through Shasta Lake. Therefore, the general recommendations by

NMFS would provide no benefit for listed species at this time. The Central Valley

Project and State Water Project in the Central Valley, California—a document commonly

referred to as the Operations Criteria and Plan Biological Opinion (OCAP BiOp; NMFS,

2009a), issued on June 4, 2009, provides NMFS’s review of the proposed long-term

operations of the Central Valley Project and State Water Project in California, and its

effects on listed anadromous fishes and marine mammal species, and designated and

proposed critical habitat, in accordance with section 7 of the ESA. As part of the

reasonable and prudent alternative (RPA) of the OCAP BiOp, studies are to be

implemented to assess the feasibility to facilitate fish passage over the Keswick and

Shasta dams on the Sacramento River downstream of the McCloud dam. Feasibility

studies to assess the suitability and functionality of existing or potential habitat for

spawning and rearing of listed salmonids are expected to begin in January 2010 and

continue through January 2012. Based on the results of the feasibility studies, a pilot

program could be implemented to re-introduce listed anadromous species to habitat

above Shasta and Keswick dams beginning in March 2012. If this pilot-program proves

successful, a long-term anadromous fish passage program would be implemented by

January 31, 2010 which would include structural and operational modifications to dams

to provide both upstream and downstream fish passage. Implementation of the RPA of
83

the OCAP BiOp could result in the future presence of listed salmonids in the Lower

McCloud River and waters of the McCloud-Pit project below McCloud dam as early as

2012. Additionally, in October 2009, NMFS issued the Public Draft Recovery Plan for

the Evolutionarily Significant Units of Sacramento River Winter-run Chinook Salmon

and Central Valley Spring-run Chinook Salmon and the Distinct Population Segment of

Central Valley Steelhead (Public Draft Recovery Plan; NMFS, 2009b). This Public Draft

Recovery Plan identified the McCloud River as a “high” priority habitat for supporting

spawning populations of these listed salmonids and provided that, as part of the recovery

strategy, habitat evaluations and feasibility studies including fish passage logistics be

implemented to support re-introduction efforts in habitat above Shasta dam. The RPA for

the OCAP BiOp adopted this action.

Gravel and Coarse Sediment

McCloud dam and reservoir trap coarse sediment (>2 millimeters) delivered from

upstream sources, limiting available gravel and coarse sediment that in an unregulated

system would support and enhance aquatic habitat in the Lower McCloud River.

Reduction in sediment supply to the Lower McCloud River due to sediment trapping in

McCloud reservoir decreases with distance downstream of McCloud dam as a result of

sediment input from tributaries and riparian areas; the effect ranges from a 94 percent

reduction at the Hawkins Creek confluence to a 78 percent reduction at the Squaw Valley

Creek confluence. In response to project operations, the Lower McCloud River from

about 5 to 8 kilometers downstream of McCloud dam is the reach most likely to exhibit

degraded habitat characterized by coarsening of the bed surface and reduction in the

frequency and quantity of mobile sediment deposits.

Coarsening of the river bed surface may result in coarse sediment habitat that is

no longer considered optimal for salmonid spawning. Finer sediments are the first to

mobilize as flows begin to increase; the largest components of the substrate (e.g.,

boulders) may be mobilized only at the highest spill flows. As flows below the dam

continue to move coarse sediment downstream, no coarse sediment is supplied to the

reach from the upper watershed above the dam to replenish it. This eventually may leave

only the largest boulders which are only moved by infrequent floods. NMFS (2010) has

expressed concern that this process can trap fine particles and lock the bed in a pavementlike state called “armoring,” making it harder for salmonids to dig spawning redds, which

typically consist of loose gravel that can be easily excavated by the fish. Project

operations could result in long-term minor to moderate adverse impacts on aquatic

habitat.

The reach below McCloud dam is confined by relatively undeformable bedrock

and boulder and has a steeper slope than reaches below Hawkins Creek. Consequently,

this reach has relatively high capacity for sediment transport, but limited storage capacity

for coble, gravel, and finer sediment. The fine sediment fraction comprised only 10 to

11 percent of bulk sediment in the mainstem and major tributaries to the Lower McCloud

River. Some fining of the substrate in the Lower McCloud River was observed at the
84

confluence of major tributaries, but decreased quickly moving downstream. This would

indicate that while substrates below the dam may have coarsened, armoring is not a

widespread condition in the Lower McCloud River.

In its original condition 23, the Forest Service specified that PG&E should

develop and implement a Gravel and Coarse Sediment Management Plan within 1 year of

license issuance, in consultation with the Forest Service, California Fish and Game, the

California Water Board, and other interested parties, and with approval of the

Commission and the Forest Service. The plan would require the addition of 150 to

600 tonnes (depending on monitoring results) of gravel and coarse sediment

(8-128 millimeters) to the Lower McCloud River, with inputs specifically within the

reach between the McCloud dam spillway and the Hawkins Creek confluence. Although

the Forest Service did not specify a source for the material, it recommended that PG&E

consider using sorted gravel and coarse sediment from extensive deposits at the Star City

Creek inlet in McCloud reservoir. The Forest Service specified that the material would

be placed in the Lower McCloud River between the spillway and Hawkins Creek

confluence. The plan would also include monitoring of the Lower McCloud River

between the McCloud dam and Bald Mountain Creek confluence to evaluate the

biological population trends of trout and macroinvertebrates that are affected by gravel

and coarse sediment, long-term changes in channel morphology, and the fate of

introduced gravels and coarse sediment over the course of the license term. This

monitoring component would be integrated into the Biological Monitoring Plan,

PG&E alternative condition 23 proposed to revise the time to develop the Gravel

and Coarse Sediment Management Plan to 2 years, to allow for receipt of license articles

from the Commission and collaborative plan development. PG&E also proposed that

gravel and coarse sediment introductions occur periodically rather than annually and that

the source of the coarse sediment would be the delta deposit at the head of the Star City

Creek arm of McCloud reservoir, where the coarse sediment will be excavated “in the

dry” and not dredged. Coarse sediment augmentation would occur as far upstream in the

specified Lower McCloud River reach (between the spillway and the Hawkins Creek

confluence) as operationally feasible and cost effective. PG&E proposed that the

monitoring component of the plan cover the Lower McCloud River between McCloud

dam and Ladybug Creek rather than Bald Mountain Creek. PG&E also proposed that

implementation would be contingent on receipt of section 401 water quality

certifications, a streambed alteration agreement from California Fish and Game, and a

section 404 permit from the U.S. Army Corps of Engineers with terms and conditions

that do not substantively alter the cost or specifications of the action proposed. If this is

not the case, or if for any reason the sediment currently stored in the Star City Creek delta

is considered to be of insufficient quantity or quality, PG&E proposed that it then would

be exempt from the Forest Service’s original condition 23.

In its November 29, 2010 filing, the Forest Service modified condition 23 to

specify that the source of material would be “coarse sediment deposits within McCloud

reservoir,” and it specifies that the placement site would be the Lower McCloud River
85

directly below the spillway splash pool. The Forest Service included a draft Coarse

Sediment Management Plan in the filing (Forest Service, 2010d, Enclosure 3). In the

draft plan, the Forest Service recommends an adaptive management framework for

collection, storage, and placement of coarse sediment into the Lower McCloud River.

The plan would require the periodic, rather than annual, addition of gravel and coarse

sediment to the Lower McCloud River, with inputs specifically within the reach between

the McCloud dam spillway and the Hawkins Creek confluence. The coarse sediment

would be excavated during low water from Star City Delta (or Tarantula Gulch if

sediment at Star City Delta is unsuitable) in the first year following license acceptance

and continue until sufficient quantities are reached. In its November 24, 2010 filing,

PG&E accepts the Forest Service’s modified condition and withdraws its alternative

condition 23. California Fish and Game recommends that PG&E prepare a Gravel and

Sediment Management Plan requiring the annual addition of 150 tonnes of gravel and

sediment to the McCloud River, between the dam spillway and the confluence with

Hawkins Creek. California Fish and Game recommends that PG&E consider using the

Star City Creek inlet as a material source. As part of the long-term monitoring

component of this plan, California Fish and Game’s recommendation incorporates

amphibians as an indicator species for assessing ecosystem health.

Forest Service condition 24 specified that PG&E should prepare a reservoir

dredging plan in consultation with the Forest Service and approved by the Commission

and the Forest Service, if required for the purposes of increasing gravel and sediment

supply or for removing sediment from reservoirs to accomplish project management

objectives. The plan should be filed not less than 90 days prior to any proposed or

scheduled reservoir dredging operations and should include details regarding the

following: dredging location, amount, and timing; dredged material amount,

composition, and size; stockpile site identification; equipment, road access, and material

storage/staging needs; conditions to minimize related ecological impacts; and public

notification.

PG&E alternative condition 24 proposed that PG&E does not anticipate a need for

dredging during the license term, because PG&E alternative condition 23 proposed

excavation of material during periods when reservoir water surface elevations would be

below the Star City Creek delta. This plan for gravel and coarse sediment management

would eliminate the need for dredging within McCloud reservoir and the associated

requirement for a dredging plan and permit. In its November 29, 2010, filing, the Forest

Service drops condition 24 after analyzing PG&E’s alternative condition. In its

November 24, 2010, filing, PG&E withdraws its alternative condition 24.

NMFS, with concurrence from FWS, recommends that, as soon as listed

salmonids are documented in the McCloud River and affected by the project, PG&E

should design and implement a listed salmonid gravel substrate augmentation plan, in

consultation with the U.S. Bureau of Reclamation, NMFS, FWS, California Fish and

Game, and the Commission, and with the approval of the Commission and NMFS.
86

Our Analysis

The development and implementation of a Gravel and Coarse Sediment

Management Plan, and monitoring and adaptive management of gravel and coarse

sediment augmentation as specified by Forest Service condition 23 would help mitigate

project effects on aquatic habitat. Gravel and coarse sediment augmentation below

McCloud dam would likely mimic patterns of sediment deposition created below

downstream tributary confluences in the Lower McCloud River. Gravel introduction

below McCloud dam would have the effect of contributing the gravel and sediment

equivalent of an additional tributary to the most supply-limited reach of the Lower

McCloud River. Increasing the availability of gravel in the affected reach could benefit

aquatic resources by increasing the availability and quality of salmonid spawning habitat,

as well as aquatic habitat in general. Increasing the amount of gravel deposits could also

increase the amount of invertebrate habitat that is available within the stream substrate,

and enhancing invertebrate production could increase the biomass of fish species that can

be supported by the invertebrate forage base in the reach.

Recommendations regarding the amount and timing of gravel augmentation

covered a broad range from California Fish and Game’s recommendation to provide

150 tonnes of gravel and coarse sediment annually to the Forest Service’s specification to

provide 150 to 600 periodically. This range reflects the uncertainty as to how much and

how quickly sediment would be mobilized and distributed through the downstream reach

and the sediment storage capacity of the reach. Forest Service modified condition 23

specifies placement of material periodically based on an adaptive management approach

to be provided in the Gravel and Coarse Sediment Management Plan. This approach

recognizes that the rate of mobilization and downstream dispersion of gravel and coarse

sediment depends on river flow and that spill flows capable of mobilizing larger sediment

material occur at a frequency of about 4 out of 10 years at McCloud dam. As opposed to

a fixed annual augmentation schedule, the Forest Service’s specification to periodically

augment coarse sediment in the Lower McCloud River based on spring flows and spill

events would provide a more flexible mechanism for determining the volume and

frequency of sediment introduction necessary to enhance aquatic habitat below McCloud

dam.

PG&E proposed to use the Star City Creek delta as the source of gravel and

sediment, but did not propose to explore an alternate source of material if Star City Creek

proves to be inadequate for any reason. The Forest Service’s draft Coarse Sediment

Management Plan recommends that PG&E use delta deposits at Star City Creek as a

source of gravel and sediment, and if necessary, evaluate Tarantula Gulch delta deposit as

another potential local source. Identifying an alternative course sediment source would

provide the necessary volumetric, physical, and chemical characteristics, as well as the

logistics for transport, and would be prudent to ensure the suitability of alternative source

material for augmentation. The Forest Service withdrew condition 24, which specified

that PG&E should prepare a reservoir dredging plan, if required, for the purposes of

increasing gravel and sediment supply, because excavation of coarse sediment material
87

would only be required within the dry portion of the delta with ground-based equipment.

While dredging would allow for the collection of locally suitable source material, the

technique is often costly, and may pose additional environmental risks, including, but not

limited to, the release of mercury and increased turbidity. Use of sediment deposits at the

mouth of the Star City Creek tributary, located adjacent to the McCloud reservoir, would

provide material with a natural size range typical of the regional sources in the upper

McCloud watershed. The proposed monitoring component of the Gravel and Coarse

Sediment Management Plan would provide procedures to determine how the introduced

gravel and coarse sediment are distributed downstream and the potential benefit to

aquatic resources, while the adaptive management approach would provide a mechanism

for modifying the gravel and sediment augmentation program based on the observations

from the monitoring program.

In its alternative condition 23, PG&E proposed that monitoring for the gravel and

coarse sediment program focus on the measurement of changes to the physical

characteristics of the substrate through the reach targeted for augmentation. In its

original condition 23, the Forest Service specified that the monitoring plan be integrated

with the Biological Monitoring Plan. Although the Forest Service dropped that

specification from modified condition 23, habitat monitoring is still included as a

component of the Forest Service’s draft Aquatic Biological Monitoring Plan. The two

monitoring plans would allow for the evaluation of the gravel augmentation program on

the physical habitat as well as the associated changes to the biological resources and

provide an effective and efficient means for analyzing the success and potential benefits

of the program to aquatic resources.

In its modified condition 23, the Forest Service removed its original specification

that the geographic scope of monitoring encompass the reach from the McCloud dam to

Bald Mountain Creek. In the draft Coarse Sediment Management Plan, the Forest

Service recommends that monitoring occur in the reach of the Lower McCloud River

from the McCloud dam spillway to a suitable point near or downstream of Hawkins

Creek confluence to be determined in the final plan. PG&E originally proposed that

monitoring extend to Ladybug Creek, about a mile and a half upstream of Bald Mountain

Creek and 3.5 miles downstream of Hawkins Creek. PG&E suggested this as the

downstream limit to monitoring because pre-licensing studies indicated a suitable mix of

gravel substrate for spawning below Ladybug Creek. Three of the Habitat Criteria

Mapping (HCM) study sites (HCM-02, HCM-03, and HCM-04) are located between

Ladybug Creek and Bald Mountain Creek. The reach between Ladybug Creek and Bald

Mountain Creek could provide a good baseline for evaluating the success of the program

given the pre-licensing data for the three HCM study sites and the fact that good quality

spawning substrate currently exists in this reach.

California Fish and Game’s recommendation is generally consistent with the

Forest Service and PG&E’s alternative. Relative to the monitoring plan California Fish

and Game specifically recommended the use of amphibians as indicators of success of

the gravel and coarse sediment augmentation program. We note that while the foothill
88

yellow-legged frog is the only amphibian in the area likely to benefit from gravel

augmentation, it is not found in these upper reaches of the Lower McCloud River because

water temperatures are generally too cold to support the species. Within the proposed

coarse sediment and gravel augmentation reach, fish, particularly salmonids, and

invertebrates are more likely to benefit from augmentation than amphibians. Monitoring

focused on fish and invertebrates would provide data that is more indicative of a

biological response to gravel and coarse sediment augmentation. PG&E provides a

rationale for completion of the gravel and coarse sediment management and monitoring

plans 2 years following issuance of the new license rather than 1 year proposed by Forest

Service. However, because the Forest Service and PG&E have worked collaboratively

on the draft Coarse Sediment Management Plan and it is substantially complete, we

expect that 1 year would be adequate for consultation, completion of the plan, and

securing all approvals and permits.

The recommendations by NMFS and FWS are made relative to augmentation of

gravel substrate for listed salmonids when they are documented in the Lower McCloud

River and affected by the project. The Keswick and Shasta dams on the Sacramento

River downstream of the McCloud dam are existing barriers to upstream passage of

anadromous salmonids including Chinook salmon and steelhead. None of the listed

anadromous salmonids would be expected to have access to habitat in the Lower

McCloud River if and until upstream migration of listed species is implemented through

Shasta Lake. Therefore, management of gravel spawning substrate recommended by

NMFS and FWS would provide no benefit for listed species at this time. As part of the

RPA for the OCAP BiOp and consistent with the Public Draft Recovery Plan for listed

salmonids, feasibility studies are to be implemented to assess the suitability of habitat for

listed salmonids and to asses fish passage logistics over the Keswick and Shasta dams on

the Sacramento River downstream of the McCloud dam. Feasibility studies to assess

habitat for listed salmonids are expected to begin in January 2010 and continue through

January 2012 and, based on the results of these studies, a pilot program could be

implemented to re-introduce listed salmonids to habitat above Shasta and Keswick dams

beginning in March 2012. Based on the results of the pilot-program, a long-term

anadromous fish passage program to provide both upstream and downstream fish passage

could be implemented by January 31, 2020. Therefore, these actions could result in the

future presence of listed salmonids in the Lower McCloud River and waters of the

McCloud-Pit project below McCloud dam as early as 2012. Implementation of the

Gravel and Coarse Sediment Management Plan and monitoring of changes to the physical

habitat conditions would provide information to assess the potential benefits of the plan

to resident wild and reintroduced anadromous salmonids. The proposed monitoring

program would provide a mechanism for adapting the augmentation program to benefit

listed anadromous species, if necessary, if and when they are present and affected by the

project.
89

3.3.2 Aquatic Resources

3.3.2.1 Affected Environment

3.3.2.1.1 Water Quantity

Water Storage and Hydrology

The McCloud-Pit Hydroelectric Project includes two major storage reservoirs, two

regulating reservoirs, one afterbay, two tunnels, and three powerhouses and associated

transmission facilities. Key characteristics of the five project basins, including inflow,

surface area, length, storage capacity, releases, and drainage area are described below.

McCloud reservoir has a maximum surface area of 520 acres, is 5 miles long,

and has a maximum storage capacity of about 31,197 acre-feet. The reservoir shoreline is

14 miles long. The McCloud River watershed above McCloud reservoir includes the

highest altitude within the project vicinity and thus has the largest amount of snowmelt

influence of the four reservoirs. As a result, McCloud reservoir receives a large

component of base flow from springs (about 700 cfs) that discharge groundwater from

the aquifer to the east of Mount Shasta into the McCloud River and its tributaries.

Another noteworthy contribution comes from glacial melt from Konwakiton Glacier, one

of several glaciers located on Mount Shasta’s southeastern slopes just above Mud Creek.

A number of small tributaries flow directly into McCloud reservoir, including

Huckleberry Creek, which also carries most of the flow diverted from Mud Creek. Water

is normally released from McCloud reservoir to Iron Canyon reservoir via McCloud

tunnel and to the Lower McCloud River via the McCloud dam spillway and a low-level

outlet tunnel.

Iron Canyon reservoir has a surface area of 506 acres, is 1 mile long, and has a

maximum storage capacity of about 24,241 acre-feet. The reservoir shoreline is 11 miles

long. The majority of the water in Iron Canyon reservoir originates in the McCloud

River watershed and is diverted via McCloud tunnel. Iron Canyon reservoir is also the

confluence point of five small streams: Gap Creek, Little Gap Creek, Cedar Salt Log

Creek, Deadlun Creek, and McGill Creek. Water is normally released from Iron Canyon

reservoir to Pit 6 reservoir through the James B. Black powerhouse on the Pit River via

Iron Canyon tunnel, an associated pipeline, and a steel penstock. The minimum and

maximum recorded daily flows through James B. Black powerhouse are 0 and 2,280 cfs,

respectively, and the historical mean and median daily discharges are 900 and 863 cfs,

respectively (U.S. Geological Survey [USGS] gage 11363910/MC-11). Iron Canyon

reservoir also releases to Pit 6 reservoir via a low-level slide gate to Iron Canyon Creek.

Pit 6 reservoir has a surface area of 265 acres, is about 5 miles long, and has a

maximum storage capacity of about 15,619 acre-feet. The reservoir shoreline is 5 miles

long. The watershed contributing to Pit 6 reservoir begins on the Pit River at Pit 5 dam

and includes the mainstem Pit River and its tributaries, including Iron Canyon Creek

downstream of Iron Canyon dam. The watershed of one major tributary in this area,

Kosh Creek, constitutes almost half of the Pit 6 reservoir watershed. Water is normally
90

released from Pit 6 reservoir through the Pit 6 powerhouse to the Pit River and Pit 7

reservoir. The minimum and maximum recorded daily flows through Pit 6 powerhouse

are 0 and 8,650 cfs, respectively, and the historical mean and median daily discharges are

4,193 and 3,800 cfs, respectively (USGS gage 11364150/PH-63).

Pit 7 reservoir has a surface area of 468 acres, is 8 miles long, and has a maximum

storage capacity of about 34,142 acre-feet. The reservoir shoreline is 16 miles long. The

two primary tributaries to the Pit River in the watershed contributing inflow to Pit 7

reservoir are Roaring Creek and Hatchet Creek. Water is normally released from Pit 7

reservoir through the Pit 7 powerhouse to the Pit River and Pit 7 afterbay before

continuing to Shasta Lake. The minimum and maximum recorded daily flows through

Pit 7 powerhouse are 0 and 9,080 cfs, respectively, and the historical mean and median

daily discharges are 4,231 and 3,760 cfs, respectively (USGS gage 11364800/PH-64).

Pit 7 afterbay has a surface area of about 69 acres at normal “maximum” surface

elevation of 1,067 feet, which is the maximum water surface of Shasta Lake. The

afterbay is located immediately downstream from the Pit 7 powerhouse and has no

storage capacity. Flows from Pit 7 reservoir are regulated with the V-notch weir in the

Pit 7 afterbay dam. Changes in water flow from the Pit 7 dam and powerhouse are

attenuated by the afterbay.

Table 3-5 shows physical characteristics of each reservoir and the Pit 7 afterbay,

and figure 3-1 shows historic trends in storage for each reservoir. Table 3-6 provides

minimum required flow releases to Lower McCloud River and Iron Canyon Creek, and

tables 3-7 through 3-18 provide regulated flows compared to estimated unimpaired flows

for each of the main project reaches. We provide a discussion of instream flow

requirements for aquatic species in section 3.3.2.1.3, Aquatic Biota.
91

Table 3-5. Reservoir and afterbay characteristics. (Source: Staff, based on

specifications provided in PG&E, 2009a)

Elevation (feet) Storage capacity

(acre-feet)

Basin Normal

Maximum

Normal

Minimum Gross

McCloud reservoir 2,680 2,635 31,197

Iron Canyon reservoir 2,664 2,593a24,241

Pit 6 reservoir 1,425 1,385 15,619

Pit 7 reservoir 1,270 1,235 34,142

Pit 7 afterbay 1,067b1,036c0

a

2,615 feet during summer recreation season.

b

Shasta Lake at full pond.

c

Elevation of afterbay weir v-notch invert.
92

a) McCloud Reservoir

b) Iron Canyon Reservoir
93

c) Pit 6 Reservoir

d) Pit 7 Reservoir

Figure 3-1. Historic median and mean daily reservoir storage for McCloud-Pit

Hydroelectric Project reservoirs, water years 1974athrough 2006. (Source:

PG&E 2009a)

a

Pit 7 reservoir data represent water years 1975 through 2006.
94

Table 3-6. Current required releases to Lower McCloud River and Iron Canyon Creek.

(Source: Adapted by staff, from PG&E, 2009a)

Reservoir Gage Location

(USGS/PG&E No.) Date Required MinimumFlow (cfs)

McCloud McCloud Dam

(11367760/MC-7) All Years

May 1–Nov 30 50

Dec 1–Apr 30 40

Normal

Year

Dry

Year

Ah-Di-Na (11367800/MC-1) Jan 1–Feb 28 160 160

Mar 1–Apr 30 170 170

May 1–May 15 170 160

May 16–Aug 31 200 160

Sep 1–Dec 15 210 180

Dec 15–Dec 31 170 170

Iron

Canyon

Iron Canyon Dam

(11363930/MC-10) All Years

Year-round 3

Pit 6 N/A N/A N/A

Pit 7 Downstream of Pit 7 Dam

(11365000/PH-47)

When Shasta Lake

elevation <1,055 feet.

150

Pit 7

Afterbay

N/A N/A N/A
95

Table 3-7. Mean, minimum, and maximum unimpaired flows in the McCloud River

above McCloud reservoir for water years 1974–2006 (USGS gage

11367500/MC-3); all flows are unimpaired at this location. (Source:

PG&E 2009)

Regulated Flow (cfs) Unimpaired Flow (cfs)

Month Mean Minimum Maximum Mean Minimum Maximum

January NA NA NA 941 532 11,900

February NA NA NA 990 541 6,490

March NA NA NA 1,133 577 8,330

April NA NA NA 1,117 647 3,930

May NA NA NA 1,097 576 3,190

June NA NA NA 935 566 2,250

July NA NA NA 831 559 1,390

August NA NA NA 795 552 1,130

September NA NA NA 775 546 1,080

October NA NA NA 757 546 1,140

November NA NA NA 801 541 4,170

December NA NA NA 854 537 9,700
96

Table 3-8. Mean, minimum, and maximum regulated flows in the McCloud tunnel for

water years 1974–2006 (USGS gage 11367720/MC-8); all flows are

regulated at this location. (Source: PG&E 2009a)

Regulated Flow (cfs) Unimpaired Flow (cfs)

Month Mean Minimum Maximum Mean Minimum Maximum

January 879 271 1,620 NA NA NA

February 934 0 1,470 NA NA NA

March 1,051 0 1,580 NA NA NA

April 1,053 337 1,590 NA NA NA

May 957 266 1,460 NA NA NA

June 841 0 1,430 NA NA NA

July 769 321 1,420 NA NA NA

August 726 16 1,210 NA NA NA

September 689 296 1,320 NA NA NA

October 652 159 1,220 NA NA NA

November 668 180 1,420 NA NA NA

December 775 237 1,540 NA NA NA
97

Table 3-9. Mean, minimum, and maximum regulated and unimpaired flows in the

McCloud River at the McCloud dam for water years 1974–2006 (USGS

gage 11367760/MC-7, synthesized unimpaired hydrology data). (Source:

PG&E 2009a)

Regulated Flow (cfs) Unimpaired Flow (cfs)

Month Mean Minimum Maximum Mean Minimum Maximum

January 228 40 17,646 1,198 589 16,544

February 201 39 5,546 1,283 594 8,792

March 250 39 8,690 1,437 703 11,646

April 206 40 3,529 1,325 714 5,497

May 247 44 2,100 1,248 637 4,108

June 206 58 1,680 1,043 618 2,646

July 175 131 346 915 607 1,571

August 179 121 223 869 598 1,248

September 192 116 228 846 590 1186

October 193 45 251 829 592 1,557

November 200 47 4,630 917 585 6,546

December 163 39 3,025 1,035 585 13,096
98

Table 3-10. Mean, minimum, and maximum regulated and unimpaired flows in the

McCloud River at Ah-Di-Na for water years 1974–2006 (USGS gage

11367800/MC-1, synthesized unimpaired hydrology data). (Source:

PG&E 2009a)

Regulated Flow (cfs) Unimpaired Flow (cfs)

Month Mean Minimum Maximum Mean Minimum Maximum

January 384 153 25,200 1344 596 19,207

February 408 147 9,110 1452 604 10,081

March 484 143 11,800 1614 738 13,556

April 362 149 5,690 1,441 732 6,399

May 350 146 3,620 1,319 653 4,593

June 248 157 1,405 1,084 628 2,880

July 205 148 343 939 610 1,716

August 204 150 278 885 602 1,295

September 217 162 265 861 594 1,222

October 217 178 447 847 598 1,808

November 257 178 5,690 966 589 8,005

December 284 163 17,000 1,129 589 14,992
99

Table 3-11. Mean, minimum, and maximum regulated and unimpaired flows in the

McCloud River above Shasta Lake for water years 1974–2006 (USGS gage

11368000/MC-5, synthesized unimpaired hydrology data). (Source:

PG&E 2009a)

Regulated Flow (cfs) Unimpaired Flow (cfs)

Month Mean Minimum Maximum Mean Minimum Maximum

January 1,376 208 44,999 2,336 644 39,007

February 1,564 217 18,700 2,609 675 21,662

March 1,647 226 26,000 2,776 831 27,756

April 1,034 209 12,400 2,113 807 13,109

May 730 212 7,220 1,699 756 8,192

June 452 194 2,266 1,294 689 4,103

July 329 191 945 1,063 637 2,419

August 289 187 485 971 619 1,507

September 294 191 549 938 605 1,371

October 311 196 2,310 941 617 3,671

November 561 216 15,900 1,270 614 18,855

December 908 202 31,100 1,753 617 29,092
100

Table 3-12. Mean, minimum, and maximum regulated and unimpaired flows in Iron

Canyon Creek at Iron Canyon dam for water years 1974–2006 (USGS gage

11363930/MC-10, synthesized unimpaired hydrology data). (Source:

PG&E 2009a)

Regulated Flow (cfs) Unimpaired Flow (cfs)

Month Mean Minimum Maximum Mean Minimum Maximum

January 3.9a0.4a11.0a67 3 1,341

February 13.8a2.0a538.0a78 3 931

March 9.8a2.7a501.0a79 4 961

April 3.8a2.6a6.4a45 3 454

May 3.9a2.5a7.4a26 4 244

June 3.9 2.6 7 14 2 92

July 3.9 2.7 7 8.4 2 48

August 3.9 0.4 7.6 5.8 1.2 18

September 3.9 2.7 7.8 5.2 0.7 24

October 3.9a2.7a8.1a6 0.8 126

November 3.9a2.7a9.1a21 2 735

December 3.8a0.4a15.0a42 2 955

a Regulated data set is incomplete (0.25 percent missing data).
101

Table 3-13. Mean, minimum, and maximum regulated and unimpaired flows in the

Pit River below the Pit 5 dam for water years 1974–2006 (USGS gage

11363000/PH-27, synthesized unimpaired hydrology data). (Source:

PG&E 2009a)

Regulated Flow (cfs) Unimpaired Flow (cfs)

Month Mean Minimum Maximum Mean Minimum Maximum

January 1,014 46 30,200 4,255 2,076 32,529

February 1,252 47 36,500 4,812 1,884 36,882

March 1,586 50 15,700 5,347 2,220 20,517

April 1,004 45 12,000 4,440 2,037 17,020

May 805 67 17,500 3,930 1,812 20,328

June 274 107 5,460 2,946 1,724 9,533

July 145 78 322 2,411 1,620 4,220

August 155 72 1,940 2,305 1,618 3,438

September 143 89 3,160 2,358 1,627 3,783

October 149 88 2,770 2,525 1,655 3,745

November 240 48 7,450 2,941 1,865 12,110

December 459 39 15,200 3,409 2,035 19,721
102

Table 3-14. Mean, minimum, and maximum regulated and unimpaired flows at the Pit 5

powerhouse for water years 1974–2006 (USGS gage 11362700/PH-69); all

flows are regulated at this location. (Source: PG&E 2009a)

Regulated Flow (cfs) Unimpaired Flow (cfs)

Month Mean Minimum Maximum Mean Minimum Maximum

January 2,955 196 4,184 NA NA NA

February 3,179 0 4,330 NA NA NA

March 3,500 1,020 4,250 NA NA NA

April 3,233 114 4,330 NA NA NA

May 3,002 0 4,240 NA NA NA

June 2,517 0 4,140 NA NA NA

July 2,120 0 3,989 NA NA NA

August 2,032 0 4,000 NA NA NA

September 2,124 0 4,060 NA NA NA

October 2,286 0 4,058 NA NA NA

November 2,535 0 4,138 NA NA NA

December 2,699 0 4,520 NA NA NA
103

Table 3-15. Mean, minimum, and maximum regulated and unimpaired flows in the

Pit River at the Pit 7 dam for water years 1974–2006 (USGS gage

11365000/PH-47, synthesized unimpaired hydrology data). (Source:

PG&E 2009a)

Regulated Flow (cfs) Unimpaired Flow (cfs)

Month Mean Minimum Maximum Mean Minimum Maximum

January 6,216 466 43,500 5,533 2,144 52,183

February 7,017 376 49,000 6,302 1,985 42,933

March 7,765 740 32,800 6,844 2,702 33,957

April 6,428 291 32,400 5,305 2,254 25,088

May 5,419 533 22,200 4,419 2,005 22,173

June 3,876 145 10,800 3,217 1,825 10,219

July 3,216 30 8,240 2,571 1,677 4,679

August 3,024 62 6,940 2,415 1,667 3,569

September 3,080 71 7,980 2,458 1,669 3,968

October 3,325 140 14,500 2,647 1,727 5,798

November 4,046 356 20,000 3,333 1,932 22,384

December 4,752 257 32,600 4,212 2,115 37,874
104

Table 3-16. Mean, minimum, and maximum regulated and unimpaired at the James B.

Black powerhouse for water years 1974–2006 (USGS gage

11363910/MC-11); all flows are regulated at this location. (Source: PG&E

2009a)

Regulated Flow (cfs) Unimpaired Flow (cfs)

Month Mean Minimum Maximum Mean Minimum Maximum

January 973 0 1,950 NA NA NA

February 1,025 0 1,920 NA NA NA

March 1,142 0 2,020 NA NA NA

April 1,080 0 1,970 NA NA NA

May 972 0 2,060 NA NA NA

June 856 0 1,910 NA NA NA

July 835 0 1,970 NA NA NA

August 808 0 2,280 NA NA NA

September 779 0 1,970 NA NA NA

October 732 0 2,000 NA NA NA

November 744 0 2,010 NA NA NA

December 860 0 2,000 NA NA NA
105

Table 3-17. Mean, minimum, and maximum regulated and unimpaired at the Pit 6

powerhouse for water years 1974–2006 (USGS gage 11364150/PH-63); all

flows are regulated at this location. (Source: PG&E 2009a)

Regulated Flow (cfs) Unimpaired Flow (cfs)

Month Mean Minimum Maximum Mean Minimum Maximum

January 4,804 606 8,520 NA NA NA

February 5,236 48 8,090 NA NA NA

March 5,940 1,090 8,080 NA NA NA

April 5,477 279 8,200 NA NA NA

May 4,778 0 7,900 NA NA NA

June 3,755 56 7,680 NA NA NA

July 3,221 0 6,430 NA NA NA

August 3,061 0 6,680 NA NA NA

September 3,087 0 6,330 NA NA NA

October 3,194 0 6,380 NA NA NA

November 3,611 0 8,020 NA NA NA

December 4,207 0 8,650 NA NA NA
106

Table 3-18. Mean, minimum, and maximum regulated and unimpaired at the Pit 7

powerhouse for water years 1974–2006 (USGS gage 11364480/PH-64); all

flows are regulated at this location. (Source: PG&E 2009a)

Regulated Flow (cfs) Unimpaired Flow (cfs)

Month Mean Minimum Maximum Mean Minimum Maximum

January 5,068 136 9,240 NA NA NA

February 5,546 0 9,030 NA NA NA

March 6,228 772 9,080 NA NA NA

April 5,741 70 8,980 NA NA NA

May 4,999 330 8,990 NA NA NA

June 3,760 20 8,660 NA NA NA

July 3,155 0 8,240 NA NA NA

August 2,941 0 6,940 NA NA NA

September 3,022 0 6,620 NA NA NA

October 3,172 0 8,090 NA NA NA

November 3,605 0 9,050 NA NA NA

December 4,342 0 9,035 NA NA NA
107

Consumptive Use

Although designated beneficial uses include domestic and municipal water supply

in the Lower McCloud River and domestic and municipal water supply, stock watering,

and irrigation in the Pit River, consumptive uses of water within the project area are

minimal.

3.3.2.1.2 Water Quality

The Central Valley Regional Water Board defines water quality criteria for the

Sacramento River and its tributaries and formally designates existing and potential

beneficial uses and water quality objectives. The McCloud River is designated in the

Central Valley Regional Water Board Water Quality Control Plan for the Sacramento

and San Joaquin River Basins (basin plan; Central Valley Regional Water Board, 2007)

for municipal and domestic water supply, contact and non-contact recreation (including

fishing, canoeing, and kayaking), power production, cold freshwater habitat, coldwater

spawning, and wildlife habitat. The Pit River in the project area is designated for all of

the beneficial uses designated for the McCloud River, as well as for water supply for

irrigation and stock watering, warm freshwater habitat, and warmwater spawning. Basin

plan objectives that are applicable to project-affected waters are described in table 3-19.

The McCloud River is not listed under section 303d of the Clean Water Act as an

impaired water body. However, the Pit River is listed for nutrients, organic

enrichment/low dissolved oxygen (DO), and water temperature, with agriculture and

grazing cited as the probable sources of impairment; the river is targeted as low priority

for the development of total maximum daily load (TMDL) standards, with proposed

TMDL completion in 2013 (California Water Board, 2006).
108

Table 3-19. Water quality objectives to support designated beneficial uses in the project

area. (Source: PG&E, 2009a)

Water

Quality

Objective

Description

Bacteria Fecal coliform concentration: less than a geometric average of 200 per

100 milliliters water on five samples collected in any 30-day period and

less than 400 per 100 milliliters on 10 percent of all samples taken in a

30-day period.

Escherichia coli concentrations: less than a geometric average of

126 per 100 milliliters of water on five samples collected in any 30-day

period and less than 235 per 100 milliliters on 10 percent of all samples

taken in a 30-day period. Basin plan criteria for fecal coliform will be

replaced with criteria for E. coli following approval of the amendment

(Central Valley Regional Water Board, 2002) by the State Board,

Office of Administrative Law and EPA.

Biostimulatory

Substances

Water shall not contain biostimulatory substances that promote aquatic

growth in concentrations that cause nuisance or adversely affect

beneficial uses.

Chemical

Constituents

Waters shall not contain chemical constituents in concentrations that

adversely affect beneficial uses. Although certain trace element levels

have been applied to particular water bodies, no portion of the projectaffected area is cited within the basin plan. In addition, waters

designated for municipal or domestic use must comply with portions of

title 22 of the California Code of Regulation.

Color Water shall be free of discoloration that causes a nuisance or adversely

affects beneficial uses.

DO Monthly median of the average daily DO concentration shall not fall

below 85 percent of saturation in the main water mass, and the

95 percent concentration shall not fall below 75 percent of saturation.

Minimum level of 7 milligrams per liter. When natural conditions

lower DO below this level, the concentrations shall be maintained at or

above 95 percent of saturation.

Floating

Material

Water shall be free of floating material in amounts that cause nuisance

or adversely affect beneficial uses.

Oil and Grease Waters shall not contain oils, greases, waxes, or other materials in

concentrations that cause nuisance, result in a visible film or coating on

the surface of the water or on objects in the water, or otherwise

adversely affect beneficial uses.
109

Water

Quality

Objective

Description

Pesticides Waters shall not contain pesticides or a combination of pesticides in

concentrations that adversely affect beneficial uses.

pH The pH of surface waters will remain between 6.5 to 8.5, and cause

changes of less than 0.5 in receiving water bodies.

Radioactivity Radionuclides shall not be present in concentrations or accumulate in

the food web to an extent that is harmful to human, plant, animal or

aquatic life.

Sediment The suspended sediment load and suspended-sediment discharge rate of

surface waters shall not be altered in such a manner as to cause a

nuisance or adversely affect beneficial uses.

Settleable

Material

Waters shall not contain substances in concentrations that result in the

deposition of material that causes a nuisance or adversely affects

beneficial uses.

Suspended

Material

Waters shall not contain suspended material in concentrations that

cause a nuisance or adversely affect beneficial uses.

Tastes and

Odor

Water shall not contain taste- or odor-producing substances in

concentrations that impart undesirable tastes and odors to domestic or

municipal water supplies, fish flesh, or other edible products of aquatic

origin, or substances that cause nuisance or otherwise adversely affect

beneficial uses.

Toxicity All waters shall be maintained free of toxic substances in concentrations

that produce detrimental physiological responses in human, plant,

animal, or aquatic life. Compliance with this objective will be

determined by analysis indicator organisms, species diversity,

population density, growth anomalies, and biotoxicity tests as specified

by the Regional Water Quality Control Board.

Turbidity In terms of changes in turbidity (nephelometric turbidity units [NTU])

in the receiving water body: where natural turbidity is 0 to 5 NTU,

increases shall not exceed 1 NTU; where 5 to 50 NTU, increases shall

not exceed 20 percent; where 50 to 100 NTU, increases shall not exceed

10 NTU; and where natural turbidity is greater than 100 NTU, increase

shall not exceed 10 percent.
110

Water

Quality

Objective

Description

Water

Temperature

The natural receiving water temperature of interstate waters shall not be

altered unless it can be demonstrated to the satisfaction of the Regional

Water Quality Control Board that such alteration in water temperature

does not adversely affect beneficial uses. Increases in water

temperatures must be less than 2.8 degrees Celsius (oC) above natural

receiving-water temperature.

Water Quality Standards

Water quality in the project area was determined to be generally in accordance

with basin plan objectives, with only one potential exceedance of basin plan criteria for

pH, which PG&E considered to be insignificant, and no exceedances for other

parameters. Monitoring results and the observed exceedance are summarized below.

Chemical Constituents

Sampling has demonstrated low levels of chemical constituents regulated under

title 22 of the California Code of Regulations. Although limited data are available on

metals in the McCloud and Pit Rivers, samples collected in 1985-1986 indicated

generally low metals concentrations near or below laboratory reporting limits. Levels of

minerals in samples collected in the project area and surrounding watershed in 2007 did

not exceed the applicable maximum contaminant levels.

Although little data exist on anthropogenic pollutants such as oil and grease,

pesticides, and herbicides in project-affected waters, pesticide screening samples

collected upstream of Shasta Lake in the Pit and Lower McCloud Rivers in 1999 and

2000, respectively, contained low pesticide levels.

Dissolved Oxygen

Generally, measured DO levels in project-affected waters remained above the

7 milligrams per liter basin plan standard at all times. During one sampling event, DO

saturation near the bottom of McCloud reservoir dropped below 85 percent, and in one

case, it dropped below 75 percent. However, monthly median DO remained above

85 percent, as required by the basin plan criterion. During a short period in late June

2004, PG&E reported DO concentrations near 3 milligrams per liter in the McCloud

River, downstream of McCloud dam that quickly rose to 10 milligrams per liter. PG&E

attributed the anomalous DO measurements to an equipment malfunction.
111

Toxicity

Ammonia levels measured for this study were well below toxicity thresholds. A

limited amount of rainbow trout tissue sampling for mercury was conducted in the Pit and

McCloud Rivers, with mercury concentrations of about 0.05 milligram per kilogram.

Measurements were taken in summer, 2007, at the sediment-water interface of

McCloud and Iron Canyon reservoirs to assess oxidation-reduction potential (a measure

of anoxia sometimes used to indicate conditions suitable for mercury methylation); data

were above the range typically associated with methylation. No mining activities occur

within 1 mile from project boundaries, limiting potential sources and input of metals to

the project-affected portion of the system.

Water Temperature

McCloud Reservoir—The water temperatures and water quality conditions in

McCloud reservoir support a coldwater trout fishery. Although project operations

influence seasonal water quality conditions in McCloud reservoir and water temperatures

in the Lower McCloud River are affected by releases from McCloud reservoir,

measurements of water temperature in the reservoir (<20 degrees Celsius [°C]) were well

within the tolerance range of salmonids and generally met basin plan criteria.

Temperatures in McCloud reservoir reflect the large volume of cool water entering

the reservoir from the spring-fed Upper McCloud River and the relatively short residence

time of water in the reservoir. Daily average surface water temperatures at upstream

reservoir stations in McCloud reservoir ranged from 6.9oC in May to 16oC in August,

while downstream reservoir stations were somewhat warmer. For example, daily average

surface water temperatures at the most downstream reservoir station ranged from about

12.0oC in May to 20oC in August, cooling to less than 10oC in October. Overall, water

temperature changes from upstream of McCloud reservoir to downstream do not differ by

more than 1.6oC at any time and are comparable to the normal heating expected along the

pre-project river length. Despite surface water warming, hypolimnetic release

temperatures below McCloud dam are cold because of the steep thermocline and large

hypolimnion.

Reservoir temperature profiles in summer from 2006–2008 were characterized by

a relatively shallow (0–3 meters ) epilimnion, a 3-6 meter thermocline (metalimnion)

characterized by sharply reduced temperatures with depth, and a deep (40-52 meters)

thermally stable hypolimnion that extends beneath the thermocline to the reservoir

bottom. The stratification period typically extends from early June to late September in

the project area. A coldwater pool, operationally defined as all depths exhibiting water

temperatures less than 10.0oC, ranged in thickness from 137.8 feet (42 meters) in August

to 167.3 feet (51 meters) in June, 2008.

Minimum flow releases from McCloud dam to the Lower McCloud River are

withdrawn from a low-level gate near the bottom of the reservoir. During 2007-2008,

daily average temperatures from the bottom of the reservoir ranged from 7.0oC in May to
112

10.1oC in August. Water temperatures at the elevation of the intake for McCloud tunnel

(elevation 2,556 feet), which leads to Iron Canyon reservoir, never exceeded 10.3oC.

Lower McCloud River—River temperatures below McCloud dam as observed

during 2008 monitoring efforts increased during spring and summer spill events, due to

water releases from the warmer epilimnion of the reservoir. Although these temperature

increases were conferred downstream, the effects of the spills diminished with tributary

flow augmentation from upstream to downstream, and water temperatures near Shasta

Lake did not exceed 19oC.

Under current minimum flows, water temperatures in the Lower McCloud River

remain below 18.8°C for the entire 24-mile-long reach year-round. Temperatures vary

seasonally, increasing from June to mid-July, remaining warmest in mid-summer, and

declining from mid- to late August through September. Hourly temperature averages

never exceeded 20oC, except at the most downstream site above Shasta Lake. During the

2006-2008 monitoring period, daily average water temperatures recorded in tributaries to

the Lower McCloud River ranged from 6 to 19.7oC from May through October and were

both slightly warmer and more variable than daily average temperatures in the mainstem

McCloud River. As expected, tributary temperatures varied with ambient air temperature

and the coldest tributary measured, Ladybug Creek, was generally 3-4oC cooler than the

lower elevation Claiborne and Squaw Valley Creeks.

Iron Canyon Reservoir— Water temperatures in Iron Canyon reservoir are

influenced by water delivered from the McCloud reservoir hypolimnion, some surface

water warming and entrainment within Iron Canyon reservoir, and the relatively short

residence time. The water temperatures and water quality conditions in the reservoir

include a well-developed thermocline and a deep thermally stable hypolimnion, which

supports a coldwater trout fishery. The temperature of flows from the bottom of the dam

was similar to the temperature of the McCloud River upstream of McCloud reservoir

(which reflects cold groundwater input).

The summer (June to September) temperature differences between monitoring

stations above the reservoir and below the Iron Canyon dam are small: a 0.14oC decrease

per mile was observed under hot meteorological conditions (water temperatures exceeded

13.1oC above the reservoir and 12.7oC below the dam no more than 10 percent of the

time), whereas a 0.03oC increase was observed under normal temperature conditions

(water temperatures exceeded 12.0oC above the reservoir, 12.1oC below the dam, and

15.0oC above the Pit River confluence no more than 50 percent of the time).

The thermal structure of Iron Canyon reservoir was characterized by a warmer

epilimnion underlain by a thermocline extending to about 4 to 10 meters deep throughout

the spring to late summer. Surface water temperatures ranged from 12.3 to 22.5oC in July

2006–2008. In the hypolimnion strata, water temperatures near the bottom of the

reservoir ranged from 11.0 to 12.3oC in July 2006–2008. Although project operations

influence water quality conditions in Iron Canyon reservoir, water quality measurements

were well within the tolerance range of salmonids (<20°C) and met basin plan criteria.
113

Iron Canyon Creek—Water is discharged from the Iron Canyon reservoir

hypolimnion to Iron Canyon Creek at an elevation of 2,565 feet and the James B. Black

powerhouse intake at an elevation of 2,556 feet. Under current operating conditions, cold

hypolimnetic (deep) releases of water from Iron Canyon reservoir and low residence

times tend to reduce the temperature variability immediately below the dam, and result in

downstream Iron Canyon Creek temperatures that are virtually identical to temperatures

above the reservoir. Water temperatures in Iron Canyon Creek below the dam from June

through September of 2006-2008 exhibited daily average temperatures from 10 to 17oC.

Although the upstream site below the dam exhibited very small diel and seasonal

fluctuations due to reservoir releases of thermally isolated hypolimnetic water, water

temperatures downstream of Iron Canyon dam do not change significantly with change in

streamflow, largely due to the abundance of shade along the stream channel. Stations

located downstream exhibited patterns that more closely reflect ambient meteorological

conditions, increasing temperatures from May to July and declining from late August to

early October. Downstream from the monitoring station below the dam to the station

above the confluence with the Pit River, water temperature increased an average of about

0.64oC per mile under normal meteorological thermal conditions.

Pit 6 and Pit 7 Reservoirs—Water diverted from the McCloud River enters the Pit

River watershed at James B. Black powerhouse, having traversed through two tunnels

and Iron Canyon reservoir. Daily average temperatures at surface water monitoring sites

in the Pit River reservoirs were comparatively warmer than those observed in the

McCloud River Basin. The thermal structures of Pit 6 and Pit 7 reservoirs were similar

during the 2007-2008 monitoring period and reflected the large flow volume and short

residence time of water in the reservoirs. Water temperature and water quality conditions

in the Pit 6 and Pit 7 reservoirs support a transitional-zone fish assemblage including

native tule perch, hardhead, Sacramento pikeminnow, and Sacramento sucker, which is

similar to other Pit reservoirs upstream of the project area. Pit 7 reservoir also supports

small populations of largemouth and smallmouth bass, tui chub, and rainbow trout.

Unlike the Lower McCloud River and Iron Canyon Creek watersheds,

temperatures in the Pit River watershed did not exhibit increasing variability with

distance downstream. The differences on average (normal condition) between

monitoring stations above the reservoir and James B. Black powerhouse represented a

sharp decline in temperature: 5.6oC within less than 0.1 mile. After mixing with flow

from the upstream Pit 3, 4, and 5 Project, temperatures increase an average of about 0.1oC

per mile, which reflects the limited stratification and low residence time of water in Pit 6

and 7 reservoirs. Ambient daily average temperatures at stations above the project area

ranged from 12 to 22oC from June through September.

Pit River—Daily average temperatures below the interbasin transfer entering

through James B. Black powerhouse were cooler, with temperatures downstream of the

Pit 6 powerhouse less than 19°C. Below Pit 7 reservoir, the river water temperature

reaches a maximum of 18 to 20oC during the middle to late summer with a diel variation
114

of 2 to 7oC during the spring, summer, and early fall. There is a steady decline in water

temperatures in the fall and winter, with minimum water temperatures at all sites near

4oC. Samples collected in 2007 showed that the water temperature in the Pit River

watershed was well within the tolerance range of salmonids, native minnows, and suckers

and met basin plan criteria.

pH

Analysis of historical and recent data indicates that measured pH values

throughout the project area and surrounding watershed occasionally approach or exceed

the basin plan water quality objectives, which specify an acceptable pH range of 6.5-8.5.

Monitoring efforts in 2007 and 2008 revealed two potential exceedances: a pH of 8.9

was measured in the metalimnion of McCloud reservoir in June 2007, and a pH of 9.1

was measured in McCloud River downstream of Squaw Valley Creek in May 2008.

However, historical data show that comparable pH levels occur naturally in the system,

and lower pH measurements were typically recorded in the vicinity of these elevated

readings, which indicate that the exceedance was a natural episodic event and not likely

representative of conditions in the river as a whole.

Biostimulatory Substances

Although biostimulatory substances are of general concern in the Pit River

(California Water Board, 2006), levels of all nutrients measured throughout the project

area were low, and chlorophyll-a levels were below the method detection limit of

0.05 milligram per liter at every site sampled. Although in situ DO data suggested some

localized algal growth at intermediate depths in both McCloud and Iron Canyon

reservoirs in the summer, such growth is typical in lakes in the region.

Coliform Bacteria

The state water quality criteria for the protection of waters used for water contact

recreation are based on the collection of a minimum of five fecal coliform samples within

a 30-day period. Although there is no basin plan criterion for total coliform, the levels

found in project-affected waters in summer, 2007, were slightly in excess of the 230 most

probable number per 100 milliliters criterion in the EPA (2003) guidelines for water

contact recreation. Heavier recreational use associated with the 2008 Labor Day

weekend in Iron Canyon reservoir and its tributaries did not appear to significantly alter

fecal coliform concentrations. Overall, historical and recent sampling in project-affected

waters, including recreational areas in McCloud and Iron Canyon reservoirs, resulted in

generally low concentrations of total coliform, fecal coliform, and E. coli.

Sediment Transport and Supply

Mud Creek, a tributary upstream of McCloud dam, adversely affects water clarity

in the Lower McCloud River by periodically delivering large amounts of fine volcanic

sediment from the Konwakiton glacier on Mount Shasta directly into McCloud reservoir.

Project operations affect the volume, rate, and timing of sediment transport downstream.

The increased turbidity in McCloud reservoir and the Lower McCloud River associated
115

with these natural occurring events continues to be a fishery and aesthetic concern.

Increased turbidity is known to alter fish feeding behavior (Barrett et al., 1992; Tippets

and Moyle, 1978), as well as impair angling conditions (see section 3.3.5, Recreation

Resources). PG&E conducted an extensive suspended sediment monitoring program in

the project area during 2007 and 2008, and results of that monitoring are discussed

below.

Turbidity Upstream of McCloud Reservoir

Mud Creek streamflow is routed by an upstream landowner to Huckleberry Creek,

which flows into the head of McCloud reservoir. Suspended sediment levels entering

McCloud reservoir are largely a function of conditions in the Mud Creek drainage.

Under base-flow conditions, synoptic sampling of total suspended solids (TSS)

at the mouth of Mud Creek / Huckleberry Creek ranged from 13 to 141 milligrams per

liter (2 to 113 NTU). However, because sampling was not continuous and spring-fed

Huckleberry Creek mixes with Mud Creek before it reaches McCloud reservoir, these

data can under-represent suspended sediment and turbidity levels in Mud Creek.

Synoptic sampling of TSS in Mud Creek above the Highway 89 bridge during non-event

periods ranged from 54 to 1,260 milligrams per liter (15 to 840 NTU), whereas

continuous data from this site showed turbidity exceeding 1,600 NTU on a regular basis.

The maximum continuous turbidity monitoring in Mud Creek during high flow

events was beyond the instrument maximum range of 1,602 NTU, and PG&E assumed

actual levels to be significantly greater than this maximum value. TSS sampling in Mud

Creek that occurred during these events showed concentrations of up to 9,360 milligrams

per liter.

Turbidity in McCloud Reservoir

There is sustained transport of sand and coarser material from Mud Creek into

McCloud reservoir during all periods of active transport. Project operations influence the

capture and re-sorting of coarse sediments stored in a McCloud reservoir deltaic deposit

downstream of the mouth of Huckleberry Creek, the capture and settling of finer

sediments stored in the distal portions of the reservoir, and sediment transport through the

reservoir to downstream reaches.

Depending on the elevation of the reservoir, bed materials collected from the

active channel in Mud Creek are deposited either at the confluence of Mud Creek /

Huckleberry Creek with the McCloud River or moved rapidly downstream to areas

exhibiting reservoir-like properties and deposited in a submerged delta. The leading edge

of this deltaic deposit terminates about 2.5 miles downstream of the Mud Creek /

Huckleberry Creek confluence and 2.5 miles upstream of the dam. As reservoir levels

are drawn down, this deltaic material is re-suspended and transported by incoming flows

to the next depositional zone, forming a wedge-shaped deposit that gradually moves

downstream.
116

During a Mud Creek event, the highest density sediment plume enters McCloud

reservoir and travels rapidly along the reservoir bottom to the low level outlet located

near McCloud dam. As the event pulse moves through the reservoir, a process of

diffusion takes place where turbidity spreads and disperses into the greater reservoir

water column, reducing its density and spreading into the upper hypolimnion and

metalimnion in areas with neutral density that can suspend the plume at mid-depths.

Depending on the size of the event and associated turbulent mixing and upward current

induced by surface winds, the mid-depth, lower density plume can, at times, reach the

surface layer and become visible. The stratification of turbidity in McCloud reservoir

within the water column allows reservoir fish to use other portions of the water column as

refugia. Depending on the size of the event pulse, the plume arrives at the dam anywhere

from 1 to 3 days after entering the reservoir.

Turbidity Downstream of McCloud Reservoir

Project operations can also alter sediment transport characteristics from McCloud

reservoir and into the Lower McCloud River as well as the introduction of sediments into

the Iron Canyon and Pit River watersheds through interbasin transfer.

Under base-flow conditions, suspended sediment values ranged from <2.0 to

4 milligrams per liter TSS (0.5 to 3.6 NTU) in the Lower McCloud River. These baseflow conditions are generally significantly lower than reported above for Mud Creek /

Huckleberry Creek. Although the absolute concentration of the event pulse is diluted by

the reservoir receiving waters, wave action and scour during reservoir drawdown can remobilize sediments stored in the reservoir, and turbidity downstream of McCloud

reservoir during Mud Creek events is significantly higher than under base-flow

conditions. Continuous turbidity monitoring over five events in August-October 2007,

and August-September 2008, showed downstream turbidity levels in the Lower McCloud

River ranging from 65 to 300 NTU below McCloud reservoir, 12 to 155 NTU above

Claiborne Creek, and 5 to 72 NTU above Shasta Lake. TSS sampling that occurred

during these events showed TSS concentrations of up to 167 milligrams per liter below

McCloud reservoir (nearly two orders of magnitude less than the peak reported in Mud

Creek). Depending on the size of the Mud Creek wasting event, the post-event

“cleansing” period can last anywhere from a few days to more than a week. Turbidity

levels typically spike on the day the event pulse reaches the dam outlet and then decline

significantly over the next several days (typically 4-8 days).

In the Iron Canyon watershed, turbidity levels within the interbasin transfer from

the McCloud River watershed during Mud Creek events were slightly above those found

during base-flow conditions due to a number of factors: dilution, dispersion, and

diffusion due to the large volume of the two upstream reservoirs, as well as the elevation

of the discharge intake/outlet structures relative to the elevations of turbidity plumes

associated with a particular event. Continuous data at Iron Canyon dam measured

maximum daily average turbidity during two August-September, 2008, Mud Creek

events of 5.5 NTU, representing a change of 4.2 NTU above pre-event levels.
117

Under base-flow conditions in the Pit River watershed, turbidity ranges were

0.8 to 2.1 NTU (3 to 6 milligrams per liter TSS) upstream of James B. Black powerhouse,

1.5 to 4.1 NTU (2 to 3 milligrams per liter TSS) below Pit 6 powerhouse, and 1.1 to 6.8

NTU (2 to 5 milligrams per liter TSS) below Pit 7 powerhouse. These baseline turbidity

data indicate that conditions in the Pit River upstream of the James B. Black powerhouse

(above the interbasin transfer) were similar to those measured downstream of the Pit 5

powerhouse (downstream of all diversion inputs) during non-event periods.

During periods when mass wasting is occurring upstream on Mount Shasta, some

signal of Mud Creek turbidity reaching the Iron Canyon Creek sites was apparent, with

turbidity increases of up to 4 NTU above pre-event levels in August and September,

2008. However, the large volume of flow coming from the Pit 3, 4, and 5 project, as well

as settling that occurs in Pit 6 and Pit 7 reservoirs, attenuates any potential effects of

turbidity in the Pit River system. Only one of the two major turbidly events occurring in

2008 was measured by the continuous recording sensor in the Lower Pit River; the

maximum turbidity at this site during the August 2008 Mud Creek event was measured as

2.6 NTU, about 1 NTU above pre-event levels.

The increases in suspended sediment concentrations and turbidity in Iron Canyon

Creek and the Pit River, resulting from interbasin transfer between the McCloud River

basin and the Iron Canyon Creek and Pit River basins during episodic mass-wasting

events, caused temporary exceedances of basin plan criteria. However, as stated above,

the suspended sediment levels in the Pit River watershed resulting from water transfers

from McCloud reservoir during Mud Creek events were minimal (<4.5 NTU) and would

not deleteriously affect fish populations in Pit 6 reservoir or in downstream

impoundments.

3.3.2.1.3 Aquatic Biota

The project area supports both stream and reservoir fisheries. Project stream

reaches include a rainbow and brown trout fishery in the Lower McCloud River and Iron

Canyon Creek. The project reservoirs—Pit 6 and 7 reservoirs and Pit 7 afterbay—also

support native minnow, sucker, and tule perch populations. In this section we describe

the aquatic habitats and aquatic biota within project-area waters.

Important and Special Status Fish Species

Rainbow and brown trout support important recreational fisheries in the project

area. The McCloud River historically had the southernmost and only bull trout

(Salvelinus confluentus) population in the state of California until it was extirpated in

1975. The river also supported Chinook salmon (Oncorhynchus tshawytscha), steelhead

(Oncorhynchus mykiss), and occasional coho salmon (Oncorhynchus kisutch). The Pit 6

reservoir supports a population of hardhead, a California species of concern and a Forest

Service sensitive species.

Coastal rainbow trout are the trout species native to most west-side watersheds,

and were historically found below an elevation of 4,900 feet, but have been introduced
118

throughout the western Sierra Nevada including most of the project area. Rainbow trout

spawn in the spring, although the specific spawning time is influenced by factors such as

the genetic strain of the fish, water temperature, and period of daylight. Spawning

usually occurs in gravel riffles or gravel pockets of small streams. Females excavate a

nest, or “redd,” in the gravel and, after spawning, cover the eggs with gravel. After

hatching, the fry remain in the gravels until their yolk sacs are absorbed. The fry then

venture into open water, feeding on plankton and aquatic macroinvertebrates. As they

mature, they begin to feed on aquatic and terrestrial insects, and large trout also feed on

fish and crayfish.

Brown trout are an introduced species in California, and occur mainly in low- to

mid-elevation ranges. Brown trout spawn in the fall, although the specific spawning time

is influenced by factors such as the genetic strain of the fish, water temperature, and

period of daylight. Spawning usually occurs in gravel riffles or gravel pockets of small

streams. Despite differences in timing, the spawning and rearing characteristics of brown

trout are similar to rainbow trout. Brown trout can be found in tributaries, rivers, lakes,

and reservoirs. Adults generally remain near the bottom of pools, while juveniles can be

found in riffles as well as in pools. Brown trout prefer temperatures below 20°C, and

have high growth rates at water temperatures between 12 and 20°C (Moyle, 2002).

Brown trout compete with other trout species for resources.

Hardhead are a large, native minnow generally found in undisturbed areas of

larger low- to middle-elevation streams (elevation between 30 and 4,760 feet in the

Sacramento and San Joaquin watersheds). Its range extends from the Kern River in the

south to the Pit River in the north. Hardhead inhabit areas that have clear, deep pools

with sandy, gravel/boulder substrates and slow water velocities (less than 0.05 feet per

second). Hardhead co-occur with Sacramento pikeminnow and usually with Sacramento

suckers, and tend to be absent from streams where introduced species, especially

centrarchids, predominate. Hardhead have been identified in the Pit 6 and Pit 7 reservoirs

during fish population surveys conducted in October 2007.

Prior to the completion of Shasta dam in 1942, Chinook salmon and other

anadromous fishes were able to travel up the McCloud River as far as the 20-foot-high

Lower Falls. Chinook salmon have been extirpated from the McCloud and Pit Rivers. In

addition, the extirpation of Chinook populations had further impacts by affecting other

species in the system, notably bull trout (originally identified as Dolly Varden) that feed

on early life stages of Chinook (California Fish and Game, 1990). In 1950, Keswick dam

was completed downstream of Shasta dam, further blocking anadromous fish passage

9 miles downstream of Shasta dam (Yoshiyama et al., 2001).

After the completion of McCloud dam in 1965, bull trout were present and

spawning access remained available within the Upper McCloud River (above McCloud

dam) and its tributaries, where both fry and juvenile rearing habitat are present. The

construction of McCloud dam, which blocked access to downstream adult holding

habitat, also created new adult habitat within the reservoir where cold, deep water was
119

abundant. However, following the construction of McCloud dam, the McCloud reservoir

was extensively stocked with rainbow trout, brown trout, and brook trout, and was

heavily promoted as a fishing destination. The brook trout did not survive or grow well,

and California Fish and Game ceased stocking brook trout but continued stocking brown

and rainbow trout. Bull trout harvest increased after McCloud reservoir opened to fishing

in 1966, and fish were present above McCloud dam up until around 1971 (California Fish

and Game, 1990). Although issues with the population were identified, angling

restrictions for bull trout were not adopted until 1976 (California Fish and Game, 1990)

when they had already been extirpated from the system. Given the loss of Chinook

salmon as a food source, over-harvesting by anglers, and the introduction of non-native

salmonids that most likely led to competition and hybridization between the species

yielding sterile offspring, the extirpation of bull trout within the Upper McCloud River

appears to be the cumulative effect of an array of stressors on the population to which

construction of the McCloud dam may have been but one contributing factor. Attempts

to reintroduce the species by California Fish and Game in the early 1990s were

unsuccessful and the effort was subsequently abandoned.

Following construction of the McCloud dam and other management objectives,

the fish community residing in the Lower McCloud River currently includes Sacramento

pikeminnow, riffle sculpin, Sacramento sucker, rainbow trout, and brown trout, with

additional fishes (e.g., smallmouth and spotted bass) likely entering the lower-most

section of the river from Shasta Lake periodically or on a seasonal basis.

Currently, the upper portion of the Lower McCloud River is managed by

California Fish and Game as a wild trout stream, and is therefore no longer stocked;

however, California Fish and Game continues to stock sport fish in Shasta Lake. It is

expected that a portion of the trout that California Fish and Game releases in Shasta Lake

migrate upstream into portions of the Lower McCloud River. Monitoring conducted at a

fish counting weir near Ladybug Creek indicated that brown trout appear highly

migratory in comparison to rainbow trout within the Lower McCloud River (Moyle,

unpublished; California Fish and Game, 1994). In addition, California Fish and Game

released 127,252 Chinook salmon in Shasta Lake as part of an ongoing mark/recapture

study funded by PG&E in 2005-2006 (letter from Jason F.R. Vann, License Coordinator,

PG&E, October 31, 2008). However, no Chinook salmon were observed during the fall,

2007, McCloud River fish surveys.

As part of the RPA for the OCAP BiOp issued by NMFS on June 4, 2009 and

consistent with the October 2009 Public Draft Recovery Plan for listed salmonids, studies

are to be implemented to assess the feasibility to facilitate fish passage over the Keswick

and Shasta dams on the Sacramento River downstream of the McCloud dam. Feasibility

studies to assess the suitability and functionality of existing or potential habitat for

spawning and rearing of listed salmonids are expected to begin in January 2010 and

continue through January 2012. Based on the results of the feasibility studies, a pilot

program could be implemented to re-introduce listed anadromous species to habitat

above Shasta and Keswick dams. This pilot program would implement upstream fish
120

passage for listed salmonids through a “trap and transport” program beginning in March

2012. If this pilot-program proves successful, a long-term anadromous fish passage

program would be implemented by January 31, 2020 which would include structural and

operational modifications to dams to provide both upstream and downstream fish

passage. Implementation of the RPA for the OCAP BiOp could result in the future

presence of listed salmonids in the Lower McCloud River and waters of the McCloud-Pit

project below McCloud dam as early as 2012.

Benthic Macroinvertebrates

PG&E conducted benthic macroinvertebrate sampling in the project-affected

reaches of the Lower McCloud River and Iron Canyon Creek in August and September,

2007, and November, 2008. During the 2007 sampling, PG&E also collected reference

samples from Squaw Valley Creek, a tributary of the McCloud River and Clear Creek, a

tributary to Iron Canyon reservoir. In addition, PG&E acquired historical (1999–2008)

benthic macroinvertebrate data for The Nature Conservancy’s McCloud River Preserve

for comparison purposes. From the 14 benthic samples collected by PG&E in 2007 and

2008, a total of 6,970 organisms comprising 95 distinct taxa were collected. Insects

comprised a majority of the benthic community including 13 mayfly taxa, 19 stonefly

taxa, 18 caddisfly taxa, and 9 beetle taxa. Other invertebrates included oligochaetes,

clams, and gastropods.

A multimetric index (MMI) based on five metrics described by Rehn et al. (2007)

was formulated for each sample taken within the project area. MMI values of Iron

Canyon Creek were within or slightly below the range of MMI values of reference sites.

MMI values from the McCloud River sites were lower when compared to MMI values of

reference sites; however, MMI values generated from historical data collected over a 10-

year period (1999–2008) on the McCloud River Preserve were consistently closer to

those of the reference sites and notably higher than those collected from the other Lower

McCloud River sites. Overall, the physical habitat data and benthic macroinvertebrate

samples collected over 10 years within the project area generally indicated good aquatic

habitat conditions and water quality.

Aquatic Mollusks

An aquatic mollusk survey was conducted in the summer and fall, 2007, to

inventory all mollusk species in the project vicinity including Forest Service special

status aquatic mollusk species. In total, three species of freshwater mussels, four species

of Sphaeriacian clams, and nine species of aquatic snails were found during the 2007

survey. The Forest Service special status freshwater mussel species Anodonta

californiensis/nuttalliana was found in lentic habitat in the Pit 6 and Pit 7 reservoirs, and

the Forest Service special status aquatic snail species Fluminicola seminalis was found in

the Lower McCloud River at the confluence of Chatterdown Creek. No Forest Service

special status aquatic mollusks were found in the proposed McCloud or Pit 7 afterbay

construction area surveys.
121

Reservoir Fish

In total, 20 different species have been documented in project reservoirs

(table 3-20). During fish surveys conducted in the fall of 2007 and 2008, a total of

15 species were observed, including four species (bluegill, brook trout, channel catfish,

and spotted bass) that had not been previously documented. Five species (bigeye

marbled sculpin, common carp, green sunfish, pit roach, and speckled dace) that were

historically observed in project reservoirs were not observed in the 2007 and 2008

surveys.

McCloud Reservoir

Fish species that occur in McCloud reservoir include naturally spawned rainbow

and brown trout and annually stocked hatchery raised rainbow trout. Brown trout, brook

trout, and rainbow trout were captured in the reservoir during the 2007 surveys. Rainbow

trout and brown trout were the more abundant species, representing more than 99 percent

of the total catch during gill net surveys. Both species were distributed evenly around the

reservoir and were captured in both shallow and deeper waters. Only one brook trout was

collected in the reservoir. During electrofishing surveys, brown trout and rainbow trout

were the only species collected. With the exception of brook trout, both juveniles and

adults of trout species were captured. No records of historic fish sampling in McCloud

reservoir were found for comparison to this study.

Iron Canyon Reservoir

Rainbow trout and brown trout were captured in the reservoir during the 2007

surveys. Rainbow and brown trout comprised 76 and 24 percent of the total catch,

respectively, during gill net surveys. Twenty-three fish consisting of rainbow trout and

brown trout were captured by electrofishing in the reservoir. About 8 percent of the

rainbow trout captured during fish surveys in Iron Canyon reservoir were identified as

hatchery-origin fish. Both juveniles and adults of rainbow and brown trout were

captured. No records of historic fish sampling in Iron Canyon reservoir were found for

comparison to this study.
122

Table 3-20. Fish species documented in the McCloud-Pit Project reservoirs.

Species McCloud

Reservoira

Iron

Canyon

Reservoira

Pit 6

Reservoir

Pit 7

Reservoir

Pit 7

Afterbaya

bluegill ○

bigeye marbled

sculpin ●

brook trout ○

brown trout ○ ○ ●

channel catfish ○

common carp ●

green sunfish ●

hardhead ●○ ●○ ○

largemouth bass ● ●○

Pit roach ●

Pit sculpin ● ○

rainbow trout ○ ○ ● ●○ ○

riffle sculpin ●○

Sacramento

pikeminnow ●○ ○

Sacramento

sucker ●○ ●○ ○

smallmouth bass ● ●○ ○

speckled dace ●

spotted bass ○

tui chub ○

tule perch ●○ ●○

a No historical data available.

○ Species documented during 2007 and 2008 surveys.

● Species documented historically.
123

Pit 6 Reservoir

Water temperature and water quality conditions in the Pit 6 reservoir support a

transitional-zone fish assemblage including native tule perch, hardhead, Sacramento

pikeminnow, and Sacramento sucker. During gill net surveys in 2007, tule perch and

hardhead represented 54 and 36 percent, respectively, of the total catch. Other species

collected in gill net surveys included Sacramento pikeminnow, Sacramento sucker, and

channel catfish. A total of two fish (one hardhead and one riffle sculpin) were captured

during electrofishing surveys. Six age classes of hardhead were identified in the

reservoir. Small sample sizes for Sacramento pikeminnow and Sacramento sucker

precluded definitive identification of age groups. Other fish historically documented in

the reservoir, but not captured in 2007, include rainbow trout, largemouth bass,

smallmouth bass, common carp, Pit roach (Hesperoleucus mitriulus), speckled dace

(Rhinichtyhs osculus), Pit sculpin (Cottus pitensis), and bigeye marbled sculpin

(California Fish and Game, 2001; PG&E, 2001). Additionally, channel catfish were

captured in 2007, but not reported in previous years.

Pit 7 Reservoir

Fish species that occur in the Pit 7 reservoir include tule perch, hardhead,

Sacramento sucker, Sacramento pikeminnow, smallmouth bass, largemouth bass,

rainbow trout, tui chub, and bluegill. During gill net surveys in 2007, tule perch was the

most abundant species, representing 47 percent of the fish captured, followed by

hardhead. During electrofishing surveys, Sacramento sucker was the most abundant

species, representing 42 percent of the fish captured. Three fish species captured in 2007

(bluegill, Sacramento pikeminnow, and tui chub) were not reported in previous years.

Pit 7 Afterbay

The reservoir fish assemblage in Pit 7 afterbay includes hardhead, Sacramento

sucker, rainbow trout, spotted bass, smallmouth bass, and Pit sculpin. During gill net

surveys in 2007, hardhead was the most abundant species, representing 86 percent of the

fish captured, followed by Sacramento sucker. All other fish species represented less

than 1 percent of the total fish captured. During the 2007 electrofishing surveys,

hardhead was the dominant species captured followed by Sacramento sucker, rainbow

trout, spotted bass, smallmouth bass, and Pit sculpin. Hardhead were primarily in the

upstream portion of the impoundment (below Pit 7 dam), which has a more riverine

character, while warmwater species (smallmouth and spotted bass) were primarily in the

downstream, lacustrine portion of the impoundment near the Pit 7 afterbay dam.

Additionally, more than 1,000 juvenile hardhead were observed within the upstream

riverine portion of the impoundment during electrofishing in Pit 7 afterbay.

Stream Fish Populations

PG&E conducted fish surveys at eight sites on the mainstem Lower McCloud

River in fall, 2007, and three sites on Iron Canyon Creek in 2007 and 2008. A total of six

species of fish were observed in the Lower McCloud River and Iron Canyon Creek
124

during these surveys. PG&E also conducted sampling at nine sites on the mainstem of

the Lower McCloud River (including a new station between McCloud dam and Hawkins

Creek) in 2009. These data were presented in updated Technical Memorandum 18

(November 2009); results were similar to 2007.

Lower McCloud River

The Lower McCloud River travels about 24 miles over an elevation range of

1,425 feet (1.1 percent average gradient) from 2,500 feet at McCloud dam to 1,075 feet at

Shasta Lake (non-project). Groundwater springs provide a continuous source of cold

water to the upper McCloud River. Flow in the Lower McCloud River is regulated by

releases from McCloud dam, but receives significant groundwater discharge from springs

and tributaries; water temperatures supporting the coldwater fishery averaged 9.0°C

below McCloud dam and 14.6°C above Shasta Lake between May and October 2008.

This cold water supports a viable trout fishery throughout the entire 24-mile-long reach.

The Lower McCloud River also supports a Sacramento sucker / pikeminnow assemblage

just above Shasta Lake; these species are typically associated with foothill elevations and

transitional zone water temperatures and probably enter the lower river from Shasta Lake.

The current license establishes minimum instream flows below McCloud dam for

the protection of aquatic resources and the high quality coldwater fishery. Flow in the

Lower McCloud River ranges from a minimum monthly mean of 204 cfs in August to a

maximum monthly mean of 484 cfs in March (as measured at gage MC-1). The Lower

McCloud River hydrograph indicates a relatively stable base-flow regime with relatively

minimal annual variance outside of natural high flow events driven by snow melt or

prolonged moderately intense rainfall. The limited base-flow variability in the Lower

McCloud River at gage MC-1 under regulated conditions is affected by minimum flow

releases from McCloud dam for aquatic resources. Variability in the flow regime

increases with distance downstream, due to significant tributary inflow at various

locations. PG&E, as required by the current license (article 31), provides minimum

instream flow releases with compliance determined at two locations: McCloud dam and

the Lower McCloud River at Ah-Di-Na. At McCloud dam, required minimum flows are

50 cfs from May 1 through November 30, and 40 cfs from December 1 through April 30;

actual flow releases are usually much higher in order to meet downstream requirements at

the Ah-Di-Na gage. For the Lower McCloud River at Ah-Di-Na (gage MC-1), there are

dual minimum flow requirements for dry and normal years: dry year minimum instream

flow requirements range from 160 to 180 cfs, depending on the month. During normal

years, the minimum instream flow requirement at Ah-Di-Na ranges from 160 to 210 cfs,

depending on the month. Monthly average flows (April-October) at Ah-Di-Na (MC-1)

for the period 1994-2006 are analyzed by water year type (table 3-21). Except during dry

years, flows at this location were consistently greater than 215 cfs; during dry years

monthly flows averaged more than 175 cfs.
125

Table 3-21. Average monthly flow (cfs) by water year type for 1994-2006 at Ah-Di-Na

(MC-1).

Wet

Above

Normal

Below

Normal Dry

April 639 248 222 189

May 629 217 325 177

June 341 221 229 176

July 227 224 216 176

August 226 229 218 176

September 232 235 236 194

October 226 228 222 238

Mud Creek, a tributary upstream of McCloud dam, can adversely affect water

clarity in the reservoir and Lower McCloud River by periodically discharging large

amounts of sediment composed of fine volcanic material released naturally from the

Konwakiton glacier on Mount Shasta. Discharge of this suspended material from Mud

Creek continues to be a fisheries and aesthetic concern affecting turbidity in the Lower

McCloud River.

The dominant substrate in the Lower McCloud River is coarse-grained

boulder/cobble with many large boulders and bedrock outcrops. Total spawnable gravel

quantity increases gradually from McCloud dam downstream to near Ah-Di-Na

Campground. Below Ah-Di-Na, overall spawnable gravel quantity increases down to

Ladybug Creek. The quality of spawnable gravel improves from McCloud dam to

Ladybug Creek; gravel quality upstream of Hawkins Creek was “fair” to “poor,” whereas

gravel quality below Hawkins Creek was “good” on average. The number of brown trout

redds observed also increased downstream to just below Ah-Di-Na Campground. Below

Ah-Di-Na, the frequency of redds observed was low, although the abundance of

spawnable gravel continued to increase. Overall, the majority of gravel patches were less

than 100 square feet in size and ranged from “poor” to “excellent” in quality.

LWD in the river channel can provide a significant source of cover for juvenile

and adult fish. A review of existing LWD inventories shows that there is very little LWD

stored in the Lower McCloud River channel between McCloud dam and Shasta Lake.

LWD transported from the upper watershed is trapped at McCloud reservoir and not

distributed downstream to the Lower McCloud River.

Fishes observed in the Lower McCloud River in 2007 included rainbow trout,

brown trout, riffle sculpin, unidentified sculpin species, Sacramento sucker, Sacramento

pikeminnow, and unidentified minnow species. Rainbow trout and brown trout were

observed in similar relative abundance at all sites. Rainbow trout were numerically

dominant overall with the exception of the downstream-most site, which included a

higher percentage of sculpin. Trout and sculpin species were distributed throughout the
126

Lower McCloud River. Sacramento suckers were only observed at the sites immediately

upstream and downstream of Tuna Falls. Minnow species (including Sacramento

pikeminnow) were observed only at the downstream-most site. During 1984-1987,

surveys at a fish weir installed about 1 mile upstream of Shasta Lake on the Lower

McCloud River documented brown trout, rainbow trout, Sacramento sucker, Sacramento

pikeminnow, smallmouth bass, Chinook salmon, and kokanee. Observation from an

upstream fish weir installed on the Lower McCloud River near Ladybug Creek during the

same period documented brown trout and rainbow trout.

Iron Canyon Creek

Iron Canyon Creek travels 4.6 miles over an elevation range of 1,041 feet

(4.3 percent average gradient), from 2,470 feet at Iron Canyon dam to 1,430 feet at the

confluence with Pit 6 reservoir. Iron Canyon Creek receives water from Iron Canyon

reservoir, which receives water diverted from McCloud reservoir and from a few small

tributary streams. Minimum streamflow in Iron Canyon Creek is maintained by a yearround minimum release of 3 cfs from Iron Canyon reservoir. Accretion from small

tributary streams increases flow in Iron Canyon Creek by 2 to 3 cfs under low flow

conditions. During non-runoff periods in 2007, moderate accretion sources increased

flows at the mouth of Iron Canyon Creek by 2 to 4 cfs over the minimum release flow.

Once a year, typically in the late fall or early winter, high flows are released down Iron

Canyon Creek for a short period (usually under 30 minutes) during a valve exercise.

Flow releases during this exercise vary depending on reservoir water levels, but were

about 280 cfs in 2008, and are high enough to mobilize some LWD and transport fine

sediments downstream.

Mean daily water temperatures at the mouth of Iron Canyon Creek ranged between

8.4°C and 17.3°C from May through October 2007. Temperatures immediately

downstream of Iron Canyon dam exhibit minimal daily and monthly fluctuations,

reflecting reservoir releases of cold hypolimnetic water. Pools make up 25 percent of the

stream channel, with flatwater and riffle habitat accounting for the remaining 37 and

38 percent, respectively. The stream channel has an abundance of riparian shade and

ample vegetative, structural, and LWD cover for fish. Excluding the lower and upper

0.5 mile, spawning substrate is evenly distributed longitudinally along the stream

channel. Iron Canyon Creek supports a self-sustaining trout population.

During 2007 and 2008 surveys, three fish species were observed in Iron Canyon

Creek including rainbow trout, Pit sculpin, and brown trout. Rainbow trout were

observed at all sites and were numerically dominant overall, whereas brown trout were

observed at the lower and upper sites and Pit sculpin were observed at the two lower

sites.
127

3.3.2.2 Environmental Effects

Minimum Flows

Reduced flow and limited seasonal variation in flow associated with project

operations at McCloud and Iron Canyon reservoirs and diversion of water to the project

powerhouses affect habitat for aquatic biota and recreational opportunities in downstream

reaches. Therefore, minimum instream flow requirements for the reaches in Lower

McCloud River below McCloud dam, Iron Canyon Creek below Iron Canyon dam, and

the Pit River below Pit 7 dam are established to meet both aquatic biota and recreational

needs. Minimum flow levels may also substantially influence other resources including

foothill yellow-legged frog breeding (see section 3.3.3, Terrestrial Resources), wading

conditions for anglers and boating opportunities (see section 3.3.5, Recreation

Resources), and project generation (see section 4.2, Comparison of Alternatives). Flows

that support optimal conditions can differ significantly among these various resources

and users. Therefore, PG&E, the resource agencies, and several non-governmental

stakeholders provided alternative minimum flows to balance the requirements of these

various resources.

Flow Recommendation

In its final license application, PG&E proposes a minimum flow regime for each

of these reaches that varies by month and water year type to more closely reflect a natural

hydrograph for the system and support aquatic resources and other users. PG&E

alternative condition 19 proposes modifications to the instream flows specified by the

Forest Service in its original condition 19. On March 1, 2010, the Forest Service

modified its condition 19 to specify seasonal flow regimes for each of these reaches that

are the same as the PG&E alternative flows. In all three flow scenarios, seasonal flow

requirements for the Lower McCloud River and Iron Canyon Creek were tied to existing

conditions in the watershed (DWR Bulletin 120). The three flow scenarios are shown in

table 3-22 for the Lower McCloud River, table 3-23 for Iron Canyon Creek, and table 3-

24 for the Pit River below Pit 7 dam. In all cases, the proposed flows are equal to or

greater than the flows that are required in the current project license (table 3-6).

California Fish and Game and NMFS filed a 10(j) recommendation for the Lower

McCloud River below McCloud dam (table 3-22). California Fisheries and Water

Unlimited, and the California Salmon and Steelhead Association, support the existing

daily flow requirements for the Lower McCloud River below McCloud dam. The

McCloud River Club states that any significant increase in flows on the Lower McCloud

River during the early fishing season could harm trout populations and the ability of

anglers to safely fish during the spring season (see section 3.3.5, Recreation Resources)

and cite the state classification and reputation of this reach as a world class wild trout

fishery under existing conditions.

California Trout, Trout Unlimited, and McCloud River Club alternative

condition 19 proposed modifications to instream flows when flows are increasing
128

between mid-March and mid-April (table 3-25). By recommending the minimum flows

increase at a lower rate in relatively normal water years and decrease at a higher rate in

wetter years, the California Trout, Trout Unlimited, and McCloud River Club alternative

would increase the number of available angling days in late April and May. California

Trout, Trout Unlimited, and McCloud River Club support the Forest Service’s proposed

minimum baseflow of 200 cfs at Ah-Di-Na (MC-1) but suggest that summer base flows

at Ah-Di-Na should be the higher of (1) 200 cfs, or (2) the historic average summer base

flows during normal years under the existing license (about 210 to 220 cfs).

McCloud RiverKeepers filed flow recommendations that proposed minimum flow

releases at McCloud dam (MC-7) of 100 cfs year-round and a second compliance point at

Ah-Di-Na (MC-1) with minimum flows ranging from 160 to 210 cfs (table 3-26).

McCloud RiverKeepers’ basis for its proposed flows is that they allow the project to

produce more power than the Forest Service condition 19 flows and keep similar

minimum flows as those under the current license will support existing fish populations.

NMFS filed a 10(j) recommendation that, as soon as listed salmonids are

documented as within the McCloud River and affected by the project, PG&E should

implement NMFS’s instream flow release ranges from McCloud dam in July through

September to meet the summer spawning thermal requirements for winter-run Chinook

salmon. NMFS considers the presence of winter-run Chinook in the Lower McCloud

River to be imminent given the implementation schedule for a fish passage pilot study

listed as an RPA required by the OCAP BiOp and consistent with the Public Draft

Recovery Plan for listed salmonids. This pilot study would evaluate the release of

winter-run Chinook trapped below the Shasta dam in appropriate habitat upstream of

Shasta Lake, including the Lower McCloud River in 2012 to 2015. Additionally, in its

comments on the proposed action, NMFS recommends establishing a higher base flow

downstream of McCloud dam so that the difference between typical winter/spring spills

and base flow would not result in appreciable differences in habitat conditions.

In addition to formal 10(j) recommendations, NMFS also submitted comments on

the proposed action, specifically stating that release volumes (and instream flows)

downstream of McCloud dam should be within a range acceptable for meeting the

physical habitat and biological criteria requirements of listed salmonids. According to

the NMFS comment, in the event of a turbine shutdown, a continuous flow bypass would

be required to maintain suitable ranges of flow releases beneficial to listed salmonids.

American Whitewater recommends the following flows at McCloud dam

(table 3-27): peak flows of 600 cfs during April and ramping down through May in wet

and above normal years; at least 400 cfs during the month of April in below normal water

years; and flows of 300 cfs ramping down to 200 cfs base flows by the opening day of

trout season in dry and critically dry years.

To support restoration of anadromous salmonids and the fish passage pilot study

(RPA of the OCAP BiOp), the Winnemem Wintu Tribe recommends that the minimum

flow increase to 300 cfs by 2013; and increase further by 2015 to 600 cfs in July and
129

400 cfs in August (table 3-28). During critically dry years, the Tribe also recommends

that flows during September be increased to 400 cfs beginning in 2015. These flow

recommendations are consistent with the upper range of flows proposed by NMFS for

these months when listed anadromous species are present and affected by the project

(table 3-22).

In its November 29, 2010 filing, the Forest Service modified condition 19 to

specify that, during normal and above normal water years (flows at the McCloud dam

greater than or equal to 200 cfs on 15 April) flows at Ah-Di-Na (MC-1) should be at least

215 cfs in July and August and then drop to 200 cfs in September. In their November 29,

2010 filing, California Trout, Trout Unlimited, and McCloud River Club concurred with

the flows specified by Forest Service modified condition 19 filed on November 29.

Flow Compliance

PG&E and the resource agencies also propose ways to comply with the minimum

flows that differ. PG&E proposes that the minimum flow requirements be met on the

basis of the seven-day running average of mean daily flow. PG&E proposes the

following: (1) individual mean daily flows may be less than the required minimum

streamflow; (2) the instantaneous 15-minute streamflow should be at least 90 percent of

the required minimum streamflow; and (3) the seven-day running average of the daily

mean be equivalent to or greater than the required minimum flow. This method is

consistent with the compliance requirements in the license for the Pit 3, 4, and 5 project

(FERC No. 233) upstream of the McCloud-Pit Project developments on the Pit River.

California Fish and Game recommends and Forest Service condition 19 specifies that

compliance for the Lower McCloud River and Iron Canyon Creek be based on two

measurements of flow: instantaneous and 24-hour average. Instantaneous measurement

of instream flows should occur at time intervals not to exceed 15 minutes; mean daily

flow would be calculated from all instantaneous readings between midnight of one day

and midnight of the next. California Fish and Game and the Forest Service specify that

the instantaneous flow should be at least 80 percent of the specified mean daily flow for

minimum flows less than or equal to 10 cfs, and at least 90 percent of the specified mean

daily flow for minimum flows greater than 10 cfs. California Fish and Game and the

Forest Service specify that, should the mean daily flow be less than the required mean

daily flow, while the instantaneous flows are higher than the 80-90 percent required,

PG&E should begin releasing the equivalent under-released volume of water within

7 days of discovery of the under-release. Credit for such additional releases would not

exceed 20 percent of the instantaneous flow amount, when used to attain the equivalent

of the under-released volume.

California Fish and Game recommends and Forest Service specifies that

compliance with minimum instream flows at Pit 7 (table 3-23) should be based on

instantaneous flow measurements.
130

Table 3-22. Minimum flows proposed, specified, or recommended for gage MC-7 below McCloud dam (USGS gage

11367760) by PG&E, the Forest Service, California Fish and Game, and NMFS. (Source: Staff)

Release from McCloud Dam (cfs) by Water Yeara

All Water Years Normal Dry

Critically

Dry

Month

PG&E

Final

License

Application

(FLA) PG&E Alt 4(e)

Forest Service

DFG & FS (original

1/29/2010) NMFS Modified 3/1/2010 e

Modified

11/29/2010

October 150 175f175f175f200

November 150 175f175f175f200

December Min. 200,

Target 220 175f175f175f200

January Min. 200,

Target 220 175f175f175f200

February

1-14

Min. 200,

Target 220 175f175f175f200

February

15-29

Min. 200,

Target 220 0-75% ROb No flowchange

0-75% ROb No flow

change

No flow

change 0-75% RObNo flow change

76-89%

ROb

No flow

change 76-89% ROb No flowchange

No flow

change

76-89%

ROb No flow change

90-99%

ROb

Increase flow

by 75 cfs 90-99% ROb Increase flowby 75 cfs

Increase flow

by 75 cfs

90-99%

ROb

Increase flow by

50 cfs

100-119%

ROb

Increase flow

by 125 cfs

100-119%

ROb

Increase flow

by 125 cfs

Increase flow

by 125 cfs

100-119%

ROb

Increase flow by

100 cfs

≥120%

ROb

Increase flow

by 175 cfs ≥120% ROb Increase flowby 175 cfs

Increase flow

by 175 cfs

≥120%

ROb

Increase flow by

150 cfs
131

Release from McCloud Dam (cfs) by Water Yeara

All Water Years Normal Dry

Critically

Dry

Month

PG&E

Final

License

Application

(FLA) PG&E Alt 4(e)

Forest Service

DFG & FS (original

1/29/2010) NMFS Modified 3/1/2010 e

Modified

11/29/2010

March

1-15

Min. 200,

Target 220 0-75% ROb No flowchange 0-75% ROb No flowchange

No flow

change 0-75% RObNo flow change

76-89%

ROb

Increase flow

by 50 cfs 76-89% ROb Increase flowby 50 cfs

Increase flow

by 50 cfs

76-89%

ROb

Increase flow by

50 cfs

90-99%

ROb

Increase flow

by 50 cfs 90-99% ROb Increase flowby 50 cfs

Increase flow

by 50 cfs

90-99%

ROb

Increase flow by

50 cfs

100-119%

ROb

Increase flow

by 100 cfs

100-119%

ROb

Increase flow

by 100 cfs

Increase flow

by 100 cfs

100-119%

ROb

Increase flow by

100 cfs

≥120%

ROb

Increase flow

by 150 cfs ≥120% ROb Increase flowby 150 cfs

Increase flow

by 150 cfs

≥120%

ROb

Increase flow by

150 cfs

March

16-31

Min. 200,

Target 220 0-75% ROc No flowchange 0-75% ROc No flowchange

No flow

change 0-75% ROcNo flow change

76-89%

ROc

No flow

change 76-89% ROc No flowchange

No flow

change

76-89%

ROc No flow change

90-99%

ROc

Increase flow

by 50 cfs 90-99% ROc Increase flowby 50 cfs

Increase flow

by 50 cfs

90-99%

ROc

Increase flow by

50 cfs

100-119%

ROc

Increase flow

by 100 cfs

100-119%

ROc

Increase flow

by 100 cfs

Increase flow

by 50 cfs

100-119%

ROc

Increase flow by

100 cfs

≥120%

ROc

Increase flow

by 150 cfs ≥120% ROc Increase flowby 150 cfs

Increase flow

by 150 cfs

≥120%

ROc

Increase flow by

150 cfs
132

Release from McCloud Dam (cfs) by Water Yeara

All Water Years Normal Dry

Critically

Dry

Month

PG&E

Final

License

Application

(FLA) PG&E Alt 4(e)

Forest Service

DFG & FS (original

1/29/2010) NMFS Modified 3/1/2010 e

Modified

11/29/2010

April 1-15 Min. 200,

Target 220 0-75% ROc No flowchange 0-75% ROc No flowchange

No flow

change 0-75% ROcNo flow change

76-89%

ROc

No flow

change 76-89% ROc No flowchange

No flow

change

76-89%

ROc No flow change

90-99%

ROc

No flow

change 90-99% ROc No flowchange

No flow

change

90-99%

ROc No flow change

100-119%

ROc

Increase flow

by 50 cfs

100-119%

ROc

Increase flow

by 50 cfs

Increase flow

by 50 cfs

100-119%

ROc

Increase flow by

50 cfs

≥120%

ROc

Increase flow

by 50 cfs ≥120% ROc Increase flowby 50 cfs

Increase flow

by 50 cfs

≥120%

ROc

Increase flow by

50 cfs

April 16-

last Fri/Sat

Min. 200,

Target 220

April 15

MC-7

Release ≥

200 cfs

Decrease flow

by 50 cfs each

Friday after

April 15 until

flow is 200 cfs

& maintain 200

cfs release at

MC-7 through

June 30

April 15 MC7 Release ≥

200 cfs

Decrease flow

by 50 cfs each

Friday after

April 15 until

flow is 200 cfs

& maintain 200

cfs release at

MC-7 through

June 30

Decrease flow

by 50 cfs each

Friday after

April 15 until

flow is 200 cfs

& maintain 200

cfs release at

MC-7 through

June 30

0-89% ROd Decrease flow by

50 cfs (maintain

min. 200 cfs)

April 15

MC-7

Release

<200 cfs

175 cfs at MC7; maintain at

least 200 cfs at

Ah-Di-Na

(MC-1)

April 15 MC7 Release

<200 cfs

175 cfs at MC7; maintain at

least 200 cfs at

Ah-Di-Na

(MC-1)

175 cfs at MC7; maintain at

least 200 cfs at

Ah-Di-Na

(MC-1)

≥90% ROd

No flow change
133

Release from McCloud Dam (cfs) by Water Yeara

All Water Years Normal Dry

Critically

Dry

Month

PG&E

Final

License

Application

(FLA) PG&E Alt 4(e)

Forest Service

DFG & FS (original

1/29/2010) NMFS Modified 3/1/2010 e

Modified

11/29/2010

Last

Fri/Sat in

AprilApril 30

Min. 200,

Target 220 Decrease flow 50 cfs each

Friday to 200 cfs

May 150 April 15

MC-7

Release ≥

200 cfs 200f

April 15 MC7 Release ≥

200 cfs 200f200f200

April 15

MC-7

Release

<200 cfs 175f

April 15 MC7 Release

<200 cfs 175f175f

June 150 April 15

MC-7

Release ≥

200 cfs 200f

April 15 MC7 Release ≥

200 cfs 200f200f200

April 15

MC-7

Release

<200 cfs 175f

April 15 MC7 Release

<200 cfs 175f175f

July 150 175f175f175g200 400-600 400-600 ~600

August 150 175f175f175g200 300-400 300-400 ~400

September 150 175f175f175f200 150-300 150-300 ~400

Notes:

a Using most recent California Department of Water Resources Sacramento Valley Water Year Type Index forecast.
134

b

February 1 McCloud runoff (RO) percentage from DWR Bulletin 120 for McCloud River above Shasta Lake.

c March 1 McCloud runoff (RO) percentage from DWR Bulletin 120 for McCloud River above Shasta Lake.

d April 1 McCloud runoff (RO) percentage from DWR Bulletin 120 for McCloud River above Shasta Lake.

e

Flows recommended when listed salmonids are present in McCloud River.

f Mean daily flow at USGS gage 11367800 (MC-1) at Ah-Di-Na should be at least 200 cfs.

g

If the release on April 15 is greater than 200 cfs, mean daily flow at USGS gage 11367800 (MC-1) should be at least

215 cfs. If the release on April 15 is less than 200 cfs, mean daily flow at MC-1 should be at least 200 cfs.

Shaded values are consistent with flows specified in Forest Service modified condition 19 (November 29, 2010).

The release requirement for the current license is 50 cfs from May 1 to Nov 30 and 40 cfs from Dec 1 to Apr 30 in all years.
135

Table 3-23. Minimum flows proposed, specified, or recommended for gage MC-10 below Iron Canyon dam (USGS gage

11363930). (Source: Staff)

Release from Iron Canyon Dam (cfs) by Water Yeara

Wet Above Normal

Below Normal, Dry, Critically

Dry

Month

PG&E

FLA

PG&E

Alt

4(e)cFS DFG

PG&E

FLA

PG&E

Alt

4(e)dFS DFG

PG&E

FLA

PG&E

Alt

4(e)eFS DFG

October 10 10 10 7 7 7 5 7 7

November 10 10 10 7 7 7 5 7 7

December 15 15f15 same 10 10f10 same 7 7

f

7 same

January 15 15 15 10 10 10 7 7 7

February 15 15g15 as 10 10g10 as 7 7

g

7 as

March 20 >20b,g >20b15 15g15 10 10g10

April 20 >20b,g>20bFS 15 15g15 FS 10 10g10 FS

May 15 15g15 10 10g10 7 7

g

7

June 15 15 15 10 10 10 7 7 7

July 10 10 10 7 7 7 5 7 7

August 10 10 10 7 7 7 5 7 7

September 10 10 10 7 7 7 5 7 7

Notes:

a Using most recent California Department of Water Resources Sacramento Valley Water Year Type Index forecast.
136

b

In March and April of wet water years, the flow control valve on Iron Canyon dam should be fully opened. Mean

daily flow should be at least 20 cfs during this period.

c Defined as 120% or greater of average April-July forecasted runoff in DWR Bulletin 120 for McCloud River above

Shasta Lake.

d Defined as 100-119% of average April-July forecasted runoff in DWR Bulletin 120 for McCloud River above Shasta

Lake.

e Defined as less than 100% of average April-July forecasted runoff in DWR Bulletin 120 for McCloud River above

Shasta Lake.

f

Flow changes during December would be performed as soon as weather and site accessibility permit.

g

Flow changes during these months would be made once, within five business days of the actual publication date of

that month's DWR Bulletin 120, or as soon as permitted by weather and site accessibility.

Shaded values are consistent with flows specified in Forest Service modified condition 19 (November 29, 2010).

The release requirement for the current license is 3 cfs year-round. The previous month's flows would continue through the

first several days of the months where forecasts are used to determine flows, until the new flow has been determined and the

flow change made.

Table 3-24. Minimum flows proposed, specified, or recommended for gage PH-47 below Pit 7 dam (USGS gage

11365000). (Source: Staff)

Release from Pit 7 Dam (cfs)

PG&E FLA Alt 4(e) Forest Service

California Fish and

Game

150 (when Shasta

Lake elevation

<1,055 feet.)

NA 150 (year-round

instantaneous flow)

Same as Forest

Service

Notes: Shaded values are consistent with flows specified in Forest Service modified condition 19 (November 29, 2010).

The release requirement for the current license is 150 cfs whenever the elevation of Shasta Lake is below 1,055 feet.
137

Table 3-25. Minimum flows proposed by the Forest Service, California Trout, Trout Unlimited, and McCloud River Club

for gage MC-7 below McCloud dam (USGS gage 11367760). Specified flow increases are relative to flows

specified in table 3-22 for the same date interval. Variations from Forest Service condition 19 are indicated in

bold. (Source: Staff)

Release from McCloud Dam (cfs) by Water Yeara

Month FS (modified 11/29/2010)

California Trout, Trout Unlimited, and McCloud River

Club alt 4(e)

March 16-

31

100-119% RObIncrease flow by 50 cfs 100-119% RObIncrease flow by 50 cfs

≥120% RObIncrease flow by 150 cfs ≥120% RObIncrease flow by 150 cfs

April 1-15 100-119% RObIncrease flow by 50 cfs 100-119% ROb No flow change

≥120% RObIncrease flow by 50 cfs ≥120% RObIncrease flow by 50 cfs

April 16-

last Fri/Sat

April 15 MC-7

Release ≥ 200

cfs

Decrease flow by 50 cfs

each Friday after April

15 until flow is 200 cfs

& maintain 200 cfs

release at MC-7 through

June 30

April 15 MC-7

Release ≥ 200

cfs

Decrease flow by 50 cfs each Friday after

April 15 (if 0-99%ROd) and by 75 cfs per

week (if ≥100%ROc) until flow is 200 cfs.

Decrease flow by 50 cfs each Friday after

May 1 until flow is 200 cfsd. Maintain 200

cfs release at MC-7 through June 30

Last

Fri/Sat in

AprilApril 30

April 15 MC-7

Release <200

cfs

175 cfs at MC-7;

maintain at least 200 cfs

at Ah-Di-Na (MC-1)

April 15 MC-7

Release <200

cfs

175 cfs at MC-7; maintain at least 200 cfs at

Ah-Di-Na (MC-1)

a Using most recent California Department of Water Resources Sacramento Valley Water Year Type Index forecast.

b March 1 McCloud runoff (RO) percentage for Lower McCloud River above Shasta Lake from DWR Bulletin 120.

c April 1 McCloud runoff (RO) percentage for Lower McCloud River above Shasta Lake from DWR Bulletin 120.

d Matches Forest Service original condition 19.
138

Table 3-26. Minimum flows (cfs) proposed by the McCloud RiverKeepers for gage MC-7 below McCloud dam (USGS

gage 11367760) and for gage MC-1 at Ah-Di-Na (USGS gage 11367800) compared to revised Forest Service

condition 19 and PG&E alternative condition 19. (Source: Staff)

McCloud dam (MC-7) Ah-Di-Na (MC-1)

McCloud RiverKeepers

Month Forest

Service

McCloud

RiverKeepers

Forest

Service Normal Year Dry Year

January 175 100 200 160 160

February 175-350 100 200 160 160

March 175-650 100 200 170 170

April 175-700 100 200 170 170

May 1-15 175-550 100 200 170 160

May 16-31 175-400 100 200 200 160

June 175-200 100 200 200 160

July 175 100 200 200 160

August 175 100 200 200 160

September 175 100 200 210 180

October 175 100 200 210 180

November 175 100 200 210 180

December 1-15 175 100 200 210 180

December 16-31 175 100 200 170 170
139

Table 3-27. Flows proposed, specified, or recommended at McCloud dam by American Whitewater. (Source: Staff)

Month

Wet and AboveNormal Water

Years

Below-Normal

Water Years

Dry and Critically

Dry Water Years

April Peak flows of 600 cfs At least 400 cfs 300 cfs ramping

down to 200 cfs

baseflows by the

opening day of trout

season

May Ramping down to

200 cfs

Ramping down to

200 cfs

Table 3-28. Winnemem Wintu Tribe summer flow proposal to be achieved by 2015; flows consistent with upper range of

NMFS recommendations (table 3-22). (Source: Staff)

Month Wet Water Years

Normal Water

Years

Dry and Critically

Dry Water Years

July 600 600 600

August 400 400 400

September 300 300 400
140

Our Analysis

To develop the flows proposed in its license application, PG&E used three flow

studies (HCM, Individual Base Modeling [IBM], and Physical Habitat Simulation

Modeling [PHABSIM]) as well as macroinvertebrate, fisheries, and riparian vegetation

studies to determine appropriate flows for aquatic and terrestrial biota. The HCM method

was used to estimate total available habitat area in the Lower McCloud River for each

resident trout life stage in order to evaluate the effects of varying streamflow on rainbow

and brown trout habitat. Evaluation of both rainbow and brown trout was also included

in an IBM developed for two subreaches of the Lower McCloud River, which assessed

key population responses, such as persistence, abundance, biomass, and size distributions

under relevant hydrologic and thermal regimes. Instream flow incremental methodology

(IFIM) and PHABSIM modeling were used to evaluate flow conditions and habitat

criteria for each life stage of rainbow trout in Iron Canyon Creek downstream of Iron

Canyon dam. In response to comments from resource agencies on the final license

application, PG&E also performed PHABSIM model runs for resident rainbow and

brown trout in the Lower McCloud River for comparison with HCM and IBM results.

PG&E used the HCM to estimate suitable habitat for trout below McCloud dam

under flows of about 200, 300, 400, 600, 800, and 1000 cfs (as measured at the Ah-Di-Na

gage) at sites upstream of Squaw Valley Creek and at flows of about 300, 400, 600, 800,

and 1000 cfs at sites downstream of Squaw Valley Creek. PG&E, in cooperation with

interested relicensing participants, developed habitat suitability criteria for rainbow and

brown trout based on a review of existing literature; during the consultation process

PG&E also agreed to incorporate habitat suitability criteria developed for the Yuba-Bear

and Drum-Spaulding Projects. The habitat suitability criteria included water depth and

velocity criteria for fry, juvenile, adult, and spawning life stages. The results of PG&E’s

HCM study shows that the lowest study flows likely provide the most suitable habitat for

rainbow and brown trout in comparison to the other measured flows.

The Forest Service reviewed the results of the HCM to evaluate its value in

determining minimum flows for McCloud dam. The Forest Service determined that in

the upper reach of the study area, maximum trout habitat would occur at flows between

190 and 250 cfs. In the lower reach below Squaw Valley Creek, the Forest Service

suggested that maximum trout habitat would occur at flows between 250 and 450 cfs;

these flows would generally be achieved in this reach by the incremental accretion from

tributaries entering the Lower McCloud River below the Ah-Di-Na gage (MC-1).

However, the Forest Service and the California Water Board concluded that the HCM

analysis was not an accurate tool to determine flows that would provide maximum

habitat.

At the request of participants in the consultation process, PG&E also analyzed

instream flows in the Lower McCloud River using IBM to evaluate the responses of

rainbow trout and brown trout to various flow regimes and water quality conditions.

PG&E evaluated five flow regimes in the model: unimpaired, historic (1990-2006),
141

constant year round, constant summer varying only in winter, and constant winter flows

varying only in summer. Results of the unimpaired and historic flow evaluation

predicted that trout abundance was higher under project flows compared to pre-project

unimpaired flows. The results of the year-round flow evaluation predicted that increasing

flow above about 200 cfs at Ah-Di-Na (MC-1) would not increase trout abundance and

would decrease the relative abundance of rainbow versus brown trout. For varying

summer flows, the model predicted that increasing summer flow above about 200 cfs

would decrease relative abundance of rainbow trout. The varying winter flow evaluation

produced variable results between sample sites: at the upper site near MC-1, the model

predicted little change to trout abundance under simulated flows and at the lower site near

MC-5, increasing flows above 200 cfs produced a decline in trout abundance. An

increase in brown trout abundance was predicted as flows increased from 100 to 300 cfs.

The results of the study suggest that more controlled flows at the McCloud dam may

result in more stable habitat conditions for resident trout populations. PG&E noted that

higher pre-project unimpaired flow regime may have been more suitable for extirpated

species including listed salmonids and bull trout compared to resident trout; no model

runs were performed using habitat criteria appropriate for either of these species. After

reviewing the results, the Forest Service and the California Water Board concluded that

the IBM analysis was not an accurate tool to determine flows that would provide

maximum habitat.

PG&E used the PHABSIM model to compare spawning habitat in Iron Canyon

Creek under the existing minimum flows to that under unimpaired flows. Compared to

unimpaired conditions, the model results show the higher flows of the existing minimum

flow regime at the top of the reach provide lower spawning weighted usable area (WUA)

and the lower flows in the lower reach result in higher spawning WUA. The Forest

Service evaluated the PHABSIM model results and noted that flows need to exceed 8 cfs

before the entire channel and its margins are filled to some extent and flows in the range

of 16 to 20 cfs provide some depth of flow in side channel areas. Furthermore, the Forest

Service indicated base flow in the range of 7 to 10 cfs would be suitable for juveniles in

the summer/fall period (July through October), and a spawning period flow in the range

of 20 to 40 cfs is appropriate for March and April. Studies indicated that a self-sustaining

rainbow trout population currently inhabits the waters of Iron Canyon Creek. Increasing

the minimum instream flow from a year-round 3 cfs, to a seasonally variable flow, with a

minimum of 7cfs will provide more usable habitat for all life stages of rainbow trout,

while introducing a late winter-spring peak flow that mimics natural hydrologic

conditions will provide more suitable habitat for spawning trout. Additionally, providing

seasonally variable flow conditions will increase habitat heterogeneity, an important

factor in providing for overall aquatic species diversity, and therefore, ecosystem health.

The minimum mean daily flows specified by the Forest Service for Lower McCloud

River, Iron Canyon Creek, and Pit River, shown in tables 3-22 through 3-24, are the same

as PG&E alternative condition 19 flows during all months; however, PG&E

recommended that flow changes during February through May at Iron Canyon dam
142

should be made within five business days of the actual publication date of that month's

DWR Bulletin 120 because of potential seasonal access issues to the site. Similarly,

PG&E recommended that flow changes in December be conducted as soon as weather

and site accessibility permit. The Forest Service modified condition 19 concurs with

PG&E’s recommendation.

Flows recommended by California Fish and Game (see tables 3-22 through 3-24)

are the same as those specified by the Forest Service’s original condition 19, but are

generally higher than the modified Forest Service condition 19 flows for the reach below

McCloud dam. Following review of the modeling studies conducted by PG&E,

California Fish and Game determined that a base flow of 200 cfs below McCloud dam as

measured at USGS gage MC-7 should be implemented (compared to 175 cfs proposed by

PG&E and specified by the Forest Service), with flow augmentation from February 14 to

April 30. The flows recommended by California Fish and Game for Iron Canyon dam

and Pit 7 afterbay are the same as the Forest Service specified flows.

As previously stated, during pre-license application consultation the resource

agencies proposed several methods (HCM, IBM, PHABSIM) to analyze the relationship

between flow and quality and quantity of aquatic habitat available to target species and

life stages in the Lower McCloud River. Despite differences among methods, the

optimum range of flow predicted to provide peak available habitat was relatively

consistent among the models. PHABSIM modeling runs first using all study transects

(TM-74) and second using a subset of transects (TM-75) provided nearly identical

estimates of flows for peak habitat for each life stage evaluated, demonstrating the

robustness of the model. Similarly results of IBM and HCM generally indicated that

flows at the lower end of the range studied (175-200 cfs) provide greatest abundance or

highest habitat values, respectively. Models used for analysis of aquatic ecosystems

typically make various simplifying assumptions in order to simulate a very complex

system. Depending on the associated assumptions, any model will have certain strengths

and weakness that must be recognized. The PHABSIM model initially developed by

FWS has received fairly universal acceptance for evaluation of the effects of flow on

available habitat for a wide range of hydropower and water projects. Although it may not

accurately depict the actual utilization of aquatic habitat, it does provide a reliable tool

for comparative assessment of a wide range of flow conditions. Although HCM and IBM

have not been widely used to evaluate flow scenarios for relicensing, they are accepted

tools for scientific assessment of factors affecting aquatic populations. These three

models take significantly different approaches to evaluate the effects of flow, but provide

similar predictions of optimal conditions. We find that, taken in combination, the weight

of evidence from these multiple analyses supports the flows recommended for protections

and enhancement of the species evaluated, particularly resident trout.

The various flow recommendations from licensing participants are all designed to

create a seasonal hydrograph that is more typical of natural patterns for the Lower

McCloud River with increasing flows during late winter and early spring followed by

decreasing flows through late spring to base flow through the summer and fall. The
143

major differences among flow recommendations from the participants relate to seasonal

base flow, where base flow is measured, and the rate of increase and decrease around

seasonal and event flow peaks during late winter through late spring.

All recommendations concur that compliance should be measured at McCloud

dam (gage MC-7) to ensure that the desired minimum base flow and seasonal flow

variation is achieved in the upper reach between the dam and Ah-Di-Na. Under the

current license conditions, minimum flow compliance at gage MC-1 at Ah-Di-Na, and

flow augmentation from Hawkins Creek provides the seasonal flow structure downstream

of Ah-Di-Na. Forest Service modified condition 19 specifies and PG&E alternative

condition 19 proposes a second compliance location at MC-1 to assure that minimum

base flow downstream of this point is 200 cfs even during periods when flows from

Hawkins Creek are very low. The Forest Service/PG&E proposal for base flow would

provide minimum flow at McCloud dam (175 cfs) that is more than three times that

required under the current license (50 cfs). The difference in available habitat (HCM or

PHABSIM) or abundance of 1-year and older trout (IBM) between 175 and 200 cfs is

generally less than 10 percent; habitat area available at 175 cfs is generally within 10

percent of peak area for resident fry, juvenile, and adult trout. Peak area for trout

spawning was predicted by PHABSIM and HCM at between 300 cfs and 400 cfs;

spawning habitat area at 175-200 cfs was predicted at less than 50 percent of peak. It

should be noted that rainbow trout spawn during spring when most of the

recommendations augment minimum flow to reflect a more typical natural seasonal

hydrograph; thus, flows would typically be in the higher optimal range during rainbow

trout spawning except during the driest years.

For the Lower McCloud River below McCloud dam, the Forest Service, PG&E,

California Fish and Game recommend increasing flow twice a month beginning in midFebruary depending on the relative rate of runoff in a given year as documented in DWR

Bulletin 120. The flow increase recommended by Forest Service, PG&E, and California

Fish and Game (table 3-22) for a given runoff condition (0-75 percent, 76-89 percent, 90-

99 percent, 100-119 percent, and greater than120 percent) is the same between March 1

and April 15. The first increase implemented on February 15 is 25 cfs higher in the

Forest Service modified condition 19 and the PG&E alternative condition 19 than in the

California Fish and Game recommendation when the runoff factor is 90 percent or

higher. Beginning on April 16, PG&E agrees to decreasing flow at weekly intervals (as

long as the flow is equal to or greater than 200 cfs) until flows at MC-7 reach 200 cfs or

until May 1 when flows are set at 200 cfs at McCloud dam. On July 1, flow would be

decreased to base flow conditions, 175 cfs at McCloud dam and 200 cfs at MC-1. The

Forest Service specifies the same decrease in flows after April 15 as PG&E; however, the

Forest Service specifies 215 cfs at MC-1 beginning July 1 if flows on April 15 are greater

than or equal to 200cfs. On April 16, if the runoff factor is less than 90 percent,

California Fish and Game recommends the same flow decrease as Forest Service/PG&E;

however, if the runoff factor is greater than 90 percent, California Fish and Game

recommends maintaining the existing flow until the last Friday in April then decreasing
144

to 200 cfs at McCloud dam. California Fish and Game’s recommendation would increase

flows more slowly during the first two weeks at the beginning of the late winter-spring

flow augmentation, but maintain higher flows than Forest Service/PG&E during normal

to wet years for a 2-week period at the end of April. The Forest Service/PG&E

recommendation could benefit rainbow trout spawning for the two weeks early in the

season, while the California Fish and Game recommendation could benefit late spawning

rainbow trout during the last two weeks of the flow augmentation program. The

difference in the actual benefit from these two flow scenarios to the trout population

would probably vary from year to year depending on a range of additional factors that

can influence the onset, duration, and success of spawning.

Forest Service modified condition 19, filed on November 29, 2010, would provide

slightly higher flows during the summer during normal to wet years than its original

condition 19. If the flow at MC-7 is equal or greater than 200 cfs on 15 April, the

minimum flow at MC-1 in July and August would be 215 cfs instead of 200 cfs. Several

commenters indicated that under the existing license, flows at Ah-Di-Na (MC-1) were

commonly greater than the minimum 200 cfs proposed by the Forest Service’s original

condition 19. Using archived issues of DWR Bulletin 120, we classified each year

between 1994 and 2006 according to water year type and then calculated average flow for

each month based on water year type (table 3-21). During dry years, average flows were

slightly above 175 cfs at Ah-Di-Na during summer (June-August); during below normal

to wet years, average summer flows were generally between 215 cfs and 230 cfs. Forest

Service modified condition 19 would also reduce the flow increase on 16 March from the

100 cfs specified in the original condition to 50 cfs (table 3-22) when the runoff

percentage is between 100 and 119. These changes result in flows similar to those

proposed by California Trout, Trout Unlimited, and McCloud River Club. In their

November 29, 2010 filing, California Trout, Trout Unlimited, and McCloud River Club

concurred with the Forest Service’s November 29 modified condition.

Although California Fish and Game recommends minimum flows at 200 cfs

during May through February 14 measured at one compliance point near the McCloud

dam, the Forest Service specifies minimum flows of 175 cfs during the same period as

measured at McCloud dam and 200/215 cfs as measured downstream of McCloud dam at

USGS gage MC-1 (Ah-Di-Na). California Fish and Game did not provide quantitative

evidence that an increase of 25 cfs at McCloud dam would provide a substantial

improvement in fish habitat. Various modeling exercises performed by PG&E indicate

that this 25 cfs increase would have a negligible effect on available aquatic habitat. The

Forest Service indicated that the lower 175 cfs release from McCloud dam allows

discharge from Hawkins Creek near Ah-Di-Na to exercise greater natural control on

fluctuations in the seasonal hydrograph downstream of Ah-Di-Na. California Fish and

Game noted that higher base flows from McCloud dam may provide better conditions for

recreation and reduce the potential for excessive fish harvest during low flows; such

effects on recreational fishing are discussed in section 3.3.5, Recreation Resources.
145

The original recommendations submitted by California Trout, Trout Unlimited,

and McCloud River Club (table 3-25) for the late winter-spring flow augmentation on the

Lower McCloud River differed slightly from Forest Service’s March 1 modified

condition 19, PG&E’s alternative condition 19 and California Fish and Game’s

recommendation. During the second half of March, if the runoff factor is between 100

and 119 percent (above normal years), their flow recommendation would increase flows

50 cfs, half of that recommended originally by Forest Service/PG&E/California Fish and

Game; during the first half of April, if runoff is 100 to 119 percent, they recommend no

flow increase compared to 50 cfs increase originally recommended by Forest

Service/PG&E/California Fish and Game. When flows begin decreasing on 16 April, if

the runoff factor is greater than 100 percent, California Trout, Trout Unlimited, and

McCloud River Club recommend decreasing flow by 75 cfs per week, 25 cfs higher than

the Forest Service’s original condition 19. The overall effect of the California Trout,

Trout Unlimited, and McCloud River Club recommendation compared to the Forest

Service condition 19 is to increase flows at a slower rate at the beginning of the season

during normal to dry years and decrease flows at a faster rate at the end of the season

during normal to wet years. These slight changes in the rate of increase and decrease in

spring flows are not likely to have a significant effect on available habitat for various

trout life stages, but could result in lower instream flows and associated more wadeable

conditions, which we discuss in section 3.3.5, Recreation Resources, during the early

trout fishing season.

California Trout, Trout Unlimited, and McCloud River Club indicated that their

alternative flows would likely meet the needs of all life stages of rainbow and brown

trout and provide optimum fishing conditions in the Lower McCloud River. Under these

alternative flows, during the period March 16 to May 21 when the McCloud River runoff

factor is 100 to 119 percent, the number of days when flows greater than 300 cfs would

occur is about 60 days per year rather than about 95 days per year under the Forest

Service condition 19 flows. During periods when runoff is equal to or greater than

120 percent, the number of days that flows would be greater than 300 cfs would be about

94 and the number days flows would be greater than 600 cfs would be 37, compared to

116 and 45 days, respectively, under Forest Service revised condition 19. All other

seasonal flows for each runoff scenario would be the about same. The alternative flows

proposed by California Trout, Trout Unlimited, and McCloud River Club may provide

more days with optimum wading-condition flows (less than 300 cfs) for fishing (see

discussion in section 3.3.5, Recreation Resources); however, there is no substantial

evidence that these flows would provide additional benefit to resident fish populations.

The McCloud RiverKeepers recommends that minimum flows be established at

100 cfs year-round at McCloud dam and flows varying by month ranging from 160 to

210 cfs at MC-1 (table 3-26) with augmentation from Hawkins Creek. McCloud

RiverKeepers based this recommendation on the existing quality of trout populations and

the recreational fishery at lower flows under current license conditions and the significant

decrease in flow available for power generation under the other relicensing
146

recommendations for flows. While this recommendation would increase minimum flows

compared to the current license, it would not create a more natural seasonally varying

flow regime supported by the other recommendations. Seasonal variation in flow typical

of most streams in lower mountain and foothill landscapes can benefit aquatic habitat and

a balanced aquatic ecosystem supporting a diverse seasonal forage base and robust age

structure among species at the top of the food chain.

PG&E did not perform a flow-habitat study of the Pit 7 afterbay downstream of

Pit 7 dam. However, PG&E proposes, California Fish and Game recommends, and the

Forest Service specifies a minimum instream flow of 150 cfs in the Pit 7 afterbay,

downstream of Pit 7 dam. This minimum instream flow proposal reflects current

operating procedures. The Pit 7 afterbay is operated run-of-river; therefore, the

relationship between flow and habitat is largely influenced by natural seasonal variability.

The afterbay supports a diverse warmwater fish assemblage which exhibits a recurrent

exchange with populations in the Pit River arm of Shasta Lake. Maintaining the 150 cfs

minimum flow downstream of Pit 7 dam would ensure adequate flow to maintain habitat

for aquatic organisms even during critically dry periods. Furthermore, the 150 cfs

minimum flow would ensure continuity with the Pit River arm of Shasta Lake when

Shasta Lake’s water surface elevation is below 1,055 feet msl.

Ramping Rates

Rapid changes in streamflow have the potential to strand and kill young fish and

macroinvertebrates (Bradford et al., 1995; Hunter, 1992; Huntington, 2004), and may

also cause adverse effects on amphibians including the early life stages foothill yellowlegged frogs. Under the existing license, there are no ramping rate requirements

downstream of any project impoundments and no ramping is required when changing

between seasonal required minimum flow rates. However, occasional upramping is

conducted at the project prior to uncontrolled spill events in order to minimize effects to

downstream aquatic habitat and to ensure public safety.

PG&E does not propose to implement any ramping except prior to the start of an

uncontrolled spill event at McCloud dam, during which PG&E would make a good faith

effort to ramp up water flows at a target rate of no more than 100 cfs per hour. These

ramping rates are consistent with current practice, although the existing project license

does not require ramping requirements downstream of any project impoundment. No

ramping is proposed when making seasonally required changes to minimum flow rates.

California Fish and Game recommends and Forest Service condition 19 specifies

that PG&E ramp down all McCloud dam spill events once the spill reaches 1,000 cfs, at

which point the control valve could be used to control the discharge. Downramping

would proceed at a 150-cfs decrease every 48 hours until the prescribed minimum

instream flow value for that time period is reached. Additionally, operationally

controllable spills would be upramped in increments not to exceed 200 cfs in a 24-hour

period. Upramping and downramping related to testing of the flow valve at Iron Canyon

dam should occur in 20-cfs increments, assuming a 200-cfs maximum. Ramping
147

increments would be spaced at least 15 minutes apart for upramping and 30 minutes apart

for downramping. PG&E alternative condition 19 proposes the same ramping rates

specified by Forest Service condition 19 and recommended by California Fish and Game

for McCloud dam and Iron Canyon dam.

The Forest Service’s original condition 19 specified valve safety compliance

testing at Iron Canyon dam should only occur between March 5 and March 15. PG&E

alternative condition 19, however, proposes an extension of the window available to

perform valve safety testing for dam compliance at Iron Canyon dam to between March 1

and March 31, to allow for potential road access issues resulting from inclement late

winter weather conditions. In its November 29, 2010, filing, the Forest Service modified

condition 19 to specify that the valve safety testing for dam compliance at Iron Canyon

dam be performed between March 1 and March 31, which concurs with PG&E

alternative condition 19.

NMFS filed a 10(j) recommendation that PG&E should modify ramping to

minimize impacts on listed salmonids, as soon as listed salmonids are documented as

within the McCloud River and affected by the project.

American Whitewater and Friends of the River alternative condition 19 proposes

modified downramping and upramping rates. American Whitewater and Friends of the

River recommend downramping all spill events based on stage rather than flow at

McCloud dam; that is, at a rate of 0.2 feet every 48 hours, as measured at MC-7, until the

prescribed minimum flow is reached. Upramping during operationally controllable spills

would be conducted at a rate not to exceed 1.0 foot every 24 hours, as measured at MC-7.

Our Analysis

PG&E did not conduct any analyses of the potential for fish stranding to occur in

the project reaches. There is, however, some potential for fish to be stranded at times

when flows are reduced following spill events or valve test flow releases. In these cases,

implementing the ramping rates recommended by the Forest Service and California Fish

and Game would help to limit the potential for stranding of fish and macroinvertebrates.

Additionally, implementing ramping rates would decrease the potential to disrupt

salmonid fry and foothill yellow-legged frogs, inhabiting shallow edge water habitats,

which are particularly vulnerable to water velocity changes during up-ramping and

stranding during downramping.

Expansion of the valve testing window from March 1 to March 31, as proposed by

PG&E alternative condition 19 and specified by the Forest Service’s November 29

modified condition 19 would provide flexibility, given that late winter weather conditions

can make access to Iron Canyon dam difficult and road conditions unsafe during March.

The timing, frequency, and magnitude of natural peak spring runoff events can be highly

variable depending of storms and snowmelt; therefore shifting the valve test 1 to 2 weeks

earlier or later to accommodate safety and access is not likely to have adverse effects on

aquatic resources.
148

The potential for stranding of fish and other aquatic organisms during rapid

changes in flow is a function of changes in water depth particularly in backwater and side

channel areas rather than flow rate directly. However, the relationship between flow and

water depth (stage-discharge) varies along the stream channel depending on the

complexity and configuration of the channel cross-section and in particular the

dimensions of the floodplain and side channels. USGS gages measure water surface level

(feet), but flow (cfs) is calculated from stage-discharge relationships based on a series of

field calibrations where cross-sectional area (square feet) and velocity (feet per second)

are measured over a range of flows. USGS gage locations are typically selected

specifically for uniform cross-sections with minimal complexity to provide an accurate

and reliable stage discharge relationship to estimate flow. However, the location selected

to establish a gage may not be indicative of the stage discharge relationship throughout

the adjacent reach. The recommendation by American Whitewater to adjust the ramping

rate based on stage (water level) rather than flows was based on the shape of the stage

and discharge curves from the Ah-Di-Na gage. We provide an estimate of the stagedischarge relationship for Ah-Di-Na (table 3-29) for the range of operationally

controllable flows (i.e., less than1,000 cfs). At the downramping rate recommended by

PG&E and California Fish and Game and specified by Forest Service condition 19 (150

cfs per 48 hours), the typical change in stage would be about 0.18 feet per day (2.2 inches

per day) over a 10 day period to reduce flow from 1,000 cfs to 250 cfs. Numerous factors

can affect the potential for stranding in addition to the rate of stage change, including

beach and bar slope, species, and life stage, and attenuation of ramping downstream. In

2004, PacifiCorp reviewed factors affecting impacts of ramping for relicensing the

Klamath River Project. This study evaluated natural rates of ramping from high flow

events in unregulated stream reaches and looked at stranding rates below several dams at

different ramping rates. Ramping rates of 0.1-0.6 feet/hour resulted in minimal stranding

and were well within the natural range of rates to which resident and anadromous

salmonids are adapted in unregulated systems. The ramping rate recommended by

PG&E and California Fish and Game, and specified by Forest Service (150 cfs per 48

hours) would be about 0.01 feet/hour, at least an order of magnitude lower than the

ramping rates specified by the Klamath River study for minimizing stranding. Given that

the downramping rate of 150 cfs per 48 hours proposed at McCloud dam is relatively

gradual and the stage-discharge relationship is dependent on channel configuration at any

selected location, we find that flow (cfs) is an appropriate and generally accepted tool for

management of ramping rates.
149

Table 3-29. Stage (feet) to discharge (cfs) conversion for Ah-Di-Na gage. (Source:

Staff)

Gage

(feet) Flow (cfs)

1.0 128

1.1 152

1.2 176

1.3 202

1.4 229

1.5 257

1.6 286

1.7 317

1.8 349

1.9 382

2.0 417

2.1 453

2.2 490

2.3 529

2.4 569

2.5 611

2.6 655

2.7 700

2.8 747

2.9 795

3.0 845

3.1 898

3.2 951

3.3 1007

Flow Monitoring and Determination of Water Year Type

PG&E proposes to monitor compliance with minimum flows using existing USGS

flow gages in each reach. For McCloud dam, minimum flows would be measured at two

compliance points including USGS flow gage no. 11367760 (MC-7) or directly at

McCloud dam and USGS flow gage no. 11367800 (Ah-Di-Na or MC-1); for Iron Canyon

dam, minimum flows would be measured at USGS gage no. 11363930 (MC-10), and for

Pit 7 dam, minimum flows would be measured at USGS gage no. 11365000 (PH-47).

Forest Service specifies that PG&E operate and maintain existing gages, under

USGS supervision, that are needed to determine the river stage and minimum streamflow

on the Lower McCloud River below McCloud dam, Pit River below Pit 7 dam, and Iron

Canyon Creek below Iron Canyon dam. Forest Service also specifies the following: that
150

any modification of these gage facilities that may be necessary to measure the new

minimum streamflow releases be completed within 3 years of issuance of the new

license; that flows be documented in publicly available and readily accessible formats;

that flow data at gage MC-1 be real-time data and posted on the California Data

Exchange Center (CDEC) or its successor website; and that flow data be subject to

quality assurance/quality control (QA/QC) review by PG&E before it is made available

to USGS for review and publication on the internet. Forest Service further specifies that

flow values (generally 15-minute recordings) used to construct the 24-hour average flows

be made available to the resource agencies upon request.

In comments on the draft EIS, California Trout, Trout Unlimited, and Northern

California Council, Federation of Fly Fishers recommended that real-time flow data from

both MC-1 and MC-7 be made available on the internet; this would facilitate recreational

user ability to monitor flow conditions that affect their respective recreational interests.

California Fish and Game filed a 10(j) recommendation that PG&E have only one

McCloud dam compliance point at the upper gage nearest the dam (MC-7), instead of at

the Ah-Di-Na gage (MC-1) below the confluence with Hawkins Creek. NMFS filed a

concurring 10(j) recommendation, specifically stating that PG&E should move the

McCloud dam compliance point either to McCloud dam or gage MC-7. This would

allow accretion from Hawkins Creek 1 mile downstream to provide seasonal variability

to the Lower McCloud River flow regime. The California Sportfishing Protection

Alliance also supports moving the flow compliance point to just downstream of McCloud

dam. In its modified condition 19, the Forest Service specifies that flows would be

measured for compliance at both the Ah-Di-Na gage and either at gage MC-7 or directly

at McCloud dam real-time flow data would be posted from gage MC-1 only.

Forest Service specifies the methodology that would be followed to determine the

water year type that would guide the implementation of minimum flows. Forest Service

specifies that PG&E use the forecast of unimpaired runoff of the McCloud River above

Shasta Lake that is provided by the DWR Bulletin 120 report. Each month between

January and April, PG&E would determine the water year type based on the Bulletin 120

water year forecast and would manage release rates in the minimum flow table for the

month based on that forecast. The May forecast would be used to establish the final

water year type for the remaining months of the water year. PG&E would implement

minimum instream flows triggered by the water year within 2 business days of the actual

publication date of Bulletin 120. PG&E alternately proposed that for Iron Canyon dam

between February and May, given potential weather-related access difficulties,

compliance with flow changes be implemented within five business days.

The Forest Service’s original condition 19 specified that changes to minimum

instream flows for Iron Canyon Creek below Iron Canyon dam be implemented within

two business days of the actual publication date of DWR Bulletin 120. PG&E’s

alternative condition 19 proposes that flow changes in December and February through

May be made within five business days of the actual publication of that month’s DWR
151

Bulletin 120 or as soon as weather and site accessibility permit. Forest Service modified

condition 19, filed on November 29, 2010, concurs with PG&E’s alternative condition

that minimum instream flow changes below Iron Canyon dam be made when weather and

site accessibility permits but specifies that, if site access permits, flow changes be

implemented within three business days of the actual publication date of that month’s

DWR Bulletin 120.

In its final license application, PG&E proposed methods to measure compliance

with the proposed minimum flow releases at below McCloud dam and Iron Canyon dam.

Under PG&E’s proposal, flow would be measured instantaneously at 15-minute intervals,

and mean daily flow would be the average of all instantaneous measurements collected

over a 24-hour period. PG&E also proposes that all instantaneous measurements be

within 90 percent of the target minimum flow. The method proposed by PG&E is

consistent with the compliance protocol in the license for the Pit 3, 4, and 5 Project

upstream of the McCloud-Pit Project developments on the Pit River.

Forest Service specifies and California Fish and Game recommends the same

methods proposed by PG&E to measure compliance of flows below McCloud dam and

Iron Canyon dam; however, Forest Service specifies and California Fish and Game

recommends that the minimum instantaneous 15-minute streamflow shall be at least 80

percent of the prescribed mean daily flow for those minimum streamflows less than or

equal to 10 cfs, and at least 90 percent of the prescribed mean daily flow for those

minimum streamflows required to be greater than 10 cfs. In cases where the measured

mean daily flow is less than the required mean daily flow but more than the instantaneous

flow, PG&E would be required to release the equivalent under-released volume of water

within 7 days of discovery of the under-release.

Our Analysis

The continued use of two compliance points for minimum flows at McCloud dam

would ensure that adequate flows are provided in reaches directly below the dam and in

the lower reaches that receive flow input from other tributaries to the Lower McCloud

River.

Specifying the methodology for determining water year type would be an essential

requirement for determining compliance with minimum flows under the new license,

because it would aid PG&E in implementing the appropriate minimum flow release

schedule and other measures that are dependent on water year. Water year types listed

for Iron Canyon dam releases (wet, above normal, below normal, dry, and critically dry)

correspond to the five runoff percent ranges (> 120 percent, 100-119 percent, 90-99

percent, 76-89 percent, and 0-75 percent) listed for McCloud River dam releases. We

find that these ranges adequately capture the range of flow conditions and provide an

appropriate mechanism and protocol to mimic a more natural hydrograph, capturing the

late winter/spring snowmelt event(s). We also find that the most appropriate source of

information to determine the water year type at both dams is the Lower McCloud River

above Shasta Lake provided in Bulletin 120.
152

Funding the continued O&M of the USGS gages in each of the affected reaches,

including any modifications that may be required to accurately measure minimum flows

or ramping rates that are included in a new license, would help to ensure that these gages

remain functional and can be used to effectively monitor compliance with flow-related

measures included in the license.

Funding the operation of the gages also would help to ensure that flow data

continues to be available to other water users in the basin and to the general public.

Provision of flow data recorded at 15-minute intervals to the agencies upon request

would help to verify compliance with any instantaneous flows and ramping rates that are

included in the license. Flow data, following a QA/QC review, should be available to the

public and accessible, including postings on the internet. Public availability of flow data

recorded at both compliance locations (MC-1 and MC-7) on the Lower McCloud River

would provide recreational and other water users with useful information on the

conditions of project reaches and reservoirs as it pertains to their interests. The

availability of real-time flow data at MC-7 would be valuable to whitewater enthusiasts

given that the prime reach for whitewater boating considering accessibility (see

section 3.3.5, Recreation Resources) would be between McCloud dam and Ah-Di-Na.

The methods to measure compliance with the proposed minimum flow releases

proposed by PG&E are slightly different from the methods specified by Forest Service

condition 19 and recommend by California Fish and Game; however, the two approaches

appear to accomplish essentially the same goal. Both methods to measure flow

compliance below McCloud dam allow the individual mean daily flows to be less than

the required minimum streamflow but require the instantaneous, 15-minute streamflow to

be at least 90 percent of the required minimum streamflow. PG&E proposes this same

method to measure flow compliance below Iron Canyon dam, and it is consistent with the

compliance protocol in the license for the Pit 3, 4, and 5 Project upstream of the

McCloud-Pit Project developments on the Pit River. On the contrary, the Forest Service

specifies and California Fish and Game recommends that instantaneous minimum flows

below Iron Canyon dam be no less than 80 percent of the target when the target is less

than 10 cfs. This method would provide more flexibility at Iron Canyon dam where

target minimum flows for much of the year are less than 10 cfs. In addition, for

minimum instream flow measurement at both McCloud dam and Iron Canyon dam, the

Forest Service specifies and California Fish and Game recommends, that PG&E release

an equivalent volume of water following periods of under-released flows. This

requirement to compensate for under-released flows would assist PG&E in meeting

minimum flow compliance at project reaches.

Water Quality Monitoring

In its license application, PG&E proposed to prepare a water quality monitoring

plan within 1 year after license issuance. PG&E would prepare the plan in consultation

with the California Water Board, Forest Service, California Fish and Game, and other

interested parties. The plan would include monitoring methodologies, survey rationale,
153

and water quality standards, as appropriate, for temperature, turbidity, and bacteria (total

or fecal coliform), as well as a process and schedule for reporting survey and monitoring

results.

In its original condition 20, the Forest Service specified content for the water

quality and temperature monitoring plan for the project. Under the plan, the following

would occur: periodic monitoring of all project reservoirs once every 5 years for

contaminants; periodic monitoring of DO at McCloud, Pit 6, and Pit 7 reservoirs; annual

monitoring (May-September) for 10 years, of potential water temperature effects to

beneficial uses including recreation, aquatic habitats, and target species, as a result of

modified instream flows and reservoir operations, with potential additional monitoring if

temperatures above 20°C occur in reservoirs or downstream reaches; continuous turbidity

monitoring in the Lower McCloud River (at MC-7 or MC-1) during the fishing season, as

well as in Iron Canyon Creek (at MC-10) for at least 5 years after license issuance to

ensure PG&E’s repairs reduce sedimentation into the creek below the dam; and

implementation of BMPs to satisfy Aquatic Conservation Strategy objectives within the

Northwest Forest Planning Area.

PG&E alternative condition 20 proposed that the water quality and monitoring

plan be filed within 2 years following issuance of license and appropriate consultation,

and noted that routine maintenance and deployment of temperature and turbidity sensors

may be delayed as a result of high flows or late snows during spring months. In addition,

PG&E recommended that if turbidity and sedimentation in Iron Canyon Creek is reduced

as a result of the erosion and sediment control measures during the first 5 years of

monitoring and with the consent of the Forest Service, turbidity monitoring at this

location would be terminated. Further, PG&E indicated that maintenance and installation

of temperature sensors on private lands would be subject to landowner permission.

NMFS recommends that as soon as listed salmonids are documented as within the

McCloud River and are affected by the project, PG&E should modify the project’s

structures or operations necessary to mitigate direct, indirect, or cumulative water

temperature and quality impacts or enhance water temperature and quality conditions.

According to the NMFS recommendation, these actions would include water temperature

management to ensure the optimal survival and distribution of all life stages of

anadromous listed salmonids within and downstream of the Commission-delineated

physical project boundaries.

Forest Service condition 16 reserves the right for the Forest Service to modify its

conditions to respond to any water quality certification issued for this project by the

California Water Board.

In its November 29, 2010 filing, the Forest Service included modifications to

condition 20. The provisions specified in Forest Service modified condition 20 are

similar to those specified in the Forest Service’s original condition 20, except that the

Forest Service specifies that PG&E should produce the draft monitoring plan in

consultation with the California Water Board, which is responsible for issuing the §401
154

water quality certification and compliance with water quality standards and designated

uses. Under modified condition 20, the Forest Service would review and approve the

final plan, which would then be submitted to the Commission. Additionally, the Forest

Service specifies that temperature monitoring locations would be subject to permission to

enter private lands and that if, before 5 years, PG&E proposes, and the Forest Service

approves and other conditioning agencies agree, that erosion control repairs have

effectively reduced sedimentation and turbidity below Iron Canyon dam, turbidity

monitoring would no longer be necessary. In its November 24, 2010, filing, PG&E

accepts Forest Service modified condition 20 and withdraws its alternative condition 20.

Our Analysis

Development and implementation of the water quality and temperature monitoring

plan would provide guidance and consistency for monitoring potential effects of project

operations on water quality for the term of the license and ensure appropriate water

quality conditions for aquatic biota. Monitoring temperature annually for a 10-year

period would ensure that new project minimum flows and operations during all wateryear types are not adversely affecting habitat conditions for aquatic species. Continuous

monitoring of turbidity in the Lower McCloud River (at MC-7 or MC-1) during the

fishing season and providing real-time data monitoring on the internet would be useful

for determining the effects of mudflows from Mud Creek on the project waters and

inform the public of such occurrences. The implementation of BMPs under the plan

would also minimize potential effects to water quality from new construction or

maintenance activities at the project and satisfy Aquatic Conservation Strategy objectives

within the Northwest Forest Planning Area.

PG&E’s proposed construction of the Pit 7 afterbay transmission line may result in

soil erosion along inner gorge slopes, leading to increased sedimentation and turbidity in

the Pit River. If this transmission line is constructed, a site-specific sediment and erosion

control plan would be required to prevent increases in turbidity associated with

construction. PG&E’s plan to inventory erosion sites and implement erosion control

measures at Iron Canyon reservoir and to monitor turbidity as specified by the Forest

Service in Iron Canyon Creek for a minimum of 5 years would ensure that the erosion

control practices are effective in reducing sedimentation in the Pit River. Allowing

PG&E to cease turbidity monitoring below Iron Canyon dam following effective erosion

control repairs within the first 5 years, and following approval by the Forest Service and

other conditioning agencies, would allow monitoring to be adaptively managed.

Although measurements of fecal coliform or E. coli taken at McCloud or Iron

Canyon reservoirs or McCloud River have not exceeded basin plan criterion, the periodic

monitoring of all project reservoirs once every 5 years for E. coli and contaminants

would serve to ensure proper water quality conditions for recreational users at the project.

Periodic monitoring of DO at McCloud, Pit 6, and Pit 7 reservoirs for the term of the

license would provide data for ongoing evaluation of habitat conditions for aquatic biota.
155

The Commission cannot require PG&E to access private land that is outside of the

project boundary. PG&E would need to coordinate with private landowners to gain

access to any private land outside of the project boundary, as proposed in PG&E

alternative condition 20 and Forest Service modified condition 20. The number and

location of monitoring points could be limited by access issues; however, involvement of

the California Water Board in developing the monitoring plan and the Commission’s

authority to approve the final plan should provide adequate assurance that the monitoring

program satisfies the program objectives.

In its final license application, PG&E proposed to develop and implement a water

quality monitoring plan in consultation with agencies and stakeholders within 1 year of

license issuance. The proposed water quality monitoring plan did not provide specific

details associated with monitoring frequency, locations, or parameters. Development and

implementation of the water quality monitoring plan specified by Forest Service modified

condition 20 would ensure a consistent monitoring frequency and duration and provide

specific locations and water quality parameters to be monitored for the term of the

license.

The Lower McCloud River currently supports a thriving cold-water fishery.

While different species possess differing optimal water quality and temperature

conditions, current thermal conditions in the McCloud River are suitable to support

salmonids, including listed anadromous salmonids. The Keswick and Shasta dams on the

Sacramento River downstream of the McCloud dam are existing barriers to upstream

passage of anadromous salmonids including Chinook salmon and steelhead. As part of

the restoration plan for these listed species, studies are ongoing to assess the feasibility of

alternatives to facilitate fish passage at these two structures and quality of available

aquatic habitat in tributaries to Shasta Lake including the McCloud River. None of the

listed anadromous salmonids would be expected to have access to habitat in the Lower

McCloud River until upstream reintroduction of listed species is implemented through

Shasta Lake. Therefore, at this time, the modification of project structures or operations

to minimize or eliminate water temperature and quality conditions as recommended by

NMFS would provide no benefit for listed species.

At this time it is not certain what effect the flow regime that would be part of the

new license would have on water temperatures in this reach or on the cold water pool

available below the thermocline in McCloud reservoir. The results of the water quality

and temperature monitoring plan would provide data to evaluate water temperatures

under the new flow regime and assess their compatibility with requirements of

anadromous salmonid life stages. In addition, the habitat modeling performed by PG&E

for the license application focused on habitat suitability for resident salmonids; data from

this program and the Aquatic Biological Monitoring Plan (draft included in enclosure to

the Forest Service modified conditions) would provide a basis for re-evaluating the

models in terms of any potential reintroduction of listed anadromous salmonids.
156

Fish Entrainment at Project Tunnels and Intakes

Entrainment of fish into hydroelectric intakes typically causes injury or mortality

to a portion of the fish that are entrained, with mortality rates tending to be lower for

smaller fish and higher for turbines that operate under a higher head, with higher

rotational speeds, and with smaller passageways (Cook et al., 1997; Franke et al., 1997;

Winchell et al., 2000). PG&E evaluated the potential for fish entrainment in its license

application, and concluded that effects of the project on trout populations were likely to

be minor, and did not propose any measures to reduce or mitigate for fish entrainment.

NMFS submitted comments on the final license application proposed action and

action alternatives, stating that if listed salmonid species become established in the

McCloud River and fish passage is prescribed over McCloud dam, then the powerhouse

intakes would require appropriate screening.

Our Analysis

PG&E developed and implemented a study in consultation with the agencies to

assess the potential for entrainment losses to affect fish populations in the project area.

The study included a tracking study, mark-recapture study, literature review, review of

the likelihood of entrainment based on the physical characteristics of each intake, and

assessment of fish populations upstream and downstream of each intake.

The results of PG&E’s entrainment studies and literature review indicate that

entrainment potential at the existing and proposed McCloud-Pit reservoir intakes is

probably low because of generally slow maximum intake velocities compared to the

swim burst rates of resident fish species, absence of obligatory migratory fish species,

and low instances of interbasin fish movement. Although the fish stocking program

proposed by PG&E and California Fish and Game is related to meeting recreational

fishing demands, supplementation of wild fish would serve to augment fish populations

in project reaches and offset the negligible effects of entrainment. PG&E and California

Fish and Game could use population assessment data to guide the fish stocking program

and ensure that the stocking effort is directed to reaches where it would provide the most

benefit to trout populations.

The Keswick and Shasta dams on the Sacramento River downstream of the

McCloud dam are existing barriers to upstream passage of anadromous salmonids

including Chinook salmon and steelhead. As part of the restoration plan for these listed

species, studies are ongoing to assess the feasibility of alternatives to facilitate fish

passage at these two structures and the quality and availability of appropriate habitat in

tributaries to Shasta Lake including the Lower McCloud River. None of the listed

anadromous salmonids would be expected to have access to habitat in the Lower

McCloud River until reintroduction of listed species is implemented through Shasta Lake.

Therefore, the screening facilities recommended by NMFS would provide no benefit for

listed species. At this time, the pilot study to introduce Chinook salmon into tributaries

of Shasta Lake (RPA of the OCAP BiOp) in the timeframe of 2012 to 2015 could include
157

the Lower McCloud River. In its RPA for the OCAP BiOp, NMFS did not include reintroductions above McCloud dam, therefore the presence of listed-salmonids in the

upper McCloud River is not imminent. PG&E’s participation in the existing Interagency

Fish Passage Steering Committee formed as part of the RPA of the OCAP BiOp would

be beneficial in providing a mechanism for evaluating the need for the modification of

project structures to reduce potential entrainment.

Fish Population Monitoring

Monitoring of aquatic resources could provide a tool for assessing the success or

identify appropriate modifications to either the new prescribed flow regimes or the

Gravel and Sediment Management Plan. In its final license application, PG&E did not

propose developing and implementing a fish population monitoring plan. Forest Service

condition 27 specifies that, within 1 year after license acceptance, as a component of the

Aquatic Biological Management Plan, PG&E develop a plan to monitor fish populations

in project reaches, in consultation with the Forest Service, California Fish and Game,

potentially affected tribes, and other interested parties.

The plan specified by the Forest Service would involve:

 Collection of data on population trends, age-class structure, and condition

factors.

 A list of fish species to be monitored and use of same sampling methods

established during relicensing surveys.

 Fish surveys would be conducted once every 3 years, or at frequency jointly

agreed to by the agencies, potentially affected tribes, or other interested parties,

for the first 9 years and then once every 5 years for the term of the license.

 PG&E would provide the results of fish monitoring to the agencies as a

component of the aquatic biological monitoring technical report every 5 years.

In addition to describing the results, the report would include a map

(compatible with Forest Service geographic information system [GIS]) that

includes baseline data from the licensing study plan surveys and updated data

from periodic monitoring.

PG&E alternative condition 27 proposed the addition of a specific subsection

entitled “fish populations” to the Aquatic Biological Management Plan specified by the

Forest Service for clarity and specificity. In addition, PG&E indicated that fish

population monitoring of project reservoirs was unnecessary since McCloud and Iron

Canyon reservoirs are supported by trout stocking and there are no proposed changes to

project operations in Pit 6 and Pit 7 reservoirs; furthermore, the final license application

did not propose significant changes to reservoir operations and management that could

reasonably be expected to affect reservoir populations. PG&E supported fish population

monitoring in project streams as specified by Forest Service condition 27 with some

minor changes to the methodology.
158

PG&E alternative condition 27 proposed that 1 year to develop the Aquatic

Biological Management Plan following issuance of license, as specified by the Forest

Service, would not provide adequate time to complete the plan. PG&E suggested that 2

years would be necessary to complete the plan and provided rationale for this

determination based on the time required to receive license articles from the Commission;

review, accept, and implement the license articles; procure a contractor; develop the draft

plan; and schedule and complete relicensing participant meetings to review and finalize

the plan. PG&E alternative condition 27 proposed a timeline for plan development of up

to 16 months.

In its November 29, 2010 filing, the Forest Service included modifications to

condition 27. The provisions specified in Forest Service modified condition 27 are

similar to those specified in the Forest Service’s original condition 27, except that the

Forest Service has removed specific details of the plan components and monitoring

schedules from the 4(e) condition and placed them in the draft Aquatic Biological

Monitoring Plan included as an enclosure to the filing (Forest Service, 2010d,

Enclosure 3). Specifically, the Forest Service specifies that fish population monitoring

will be conducted only in the McCloud River, Iron Canyon Creek, and Pit 7 reservoir,

rather than all project-affected streams and reservoirs, as specified in its original

condition 27. Periodic fish monitoring would occur in Pit 7 reservoir once every 5 years.

In its November 24, 2010, filing, PG&E accepts Forest Service modified condition 27

and withdraws its alternative condition 27.

Our Analysis

Monitoring fish populations would assist with determining the effects of any

changes in operation or measures that are implemented in the new license to enhance

resident fish populations, and for assessing whether any modifications or additional

measures are needed. Potential changes to project operations under a new license could

alter the existing flows and water quality characteristics of project streams and affect

resident stream fish populations. Monitoring fish populations in project streams would

help determine if changes to project operations under the new license are affecting fish

populations. Because reservoir fish populations would likely be monitored as a

component of plans to stock fish in project reservoirs, and no substantial changes to

project reservoirs are expected as a result of the new license, additional monitoring of

reservoir fishes under the Aquatic Biological Monitoring Plan would be redundant.

PG&E withdrew its alternative condition 27 in which it proposed 16 months for

preparation of an approvable Aquatic Biological Management Plan. PG&E has worked

collaboratively with the Forest Service on the draft Aquatic Biological Monitoring Plan

included in Forest Service condition 27, and because it is substantially complete, we

expect that 1 year should be adequate to complete the plan.
159

Benthic Macroinvertebrates

The effects of project operations on sorting and distribution of stream substrate

affects benthic habitat and could affect the benthic invertebrate community, an important

source of forage for other aquatic biota including resident trout. Forest Service condition

27 specifies that, within 1 year after license acceptance, as a component of the Aquatic

Biological Management Plan, PG&E monitor benthic macroinvertebrates in the Lower

McCloud River and Iron Canyon Creek, in consultation with the Forest Service,

potentially affected tribes, and other interested parties.

The monitoring specified by the Forest Service would involve:

 Collection of data on population robustness and heterogeneity, composition of

functional feeding groups, and pollution tolerance and intolerance trends.

 Benthic macroinvertebrate sampling would be conducted once every 3 years

during the first 9 years and then once every 5 years for the term of the license.

 PG&E may modify the number of sampling sites, site locations, and the

frequency of monitoring, following consultation with the Forest Service,

potentially affected tribes, and other interested parties.

 Ten percent of the benthic macroinvertebrate monitoring sites would be located

within the first one and one-half miles of the Lower McCloud River below the

McCloud dam.

 PG&E would provide the results of benthic macroinvertebrate sampling to the

agencies as a component of the aquatic biological monitoring technical report

every 5 years. In addition to describing the results, the report would include a

map (compatible with Forest Service GIS) that includes base data from the

study plan surveys and updated data from periodic monitoring.

PG&E alternative condition 27 proposed that periodic benthic macroinvertebrate

sampling specified by Forest Service condition 27 should initiate following the

“Commission’s acceptance of the monitoring plan” rather than following license

issuance. PG&E also indicated that required consultation concerning modifications to

sampling protocols should include only the Forest Service and other interested parties and

that the number of sampling sites and site locations should be consistent with sites

sampled during the relicensing studies on Forest Service lands. In addition, PG&E noted

that sampling methods and data protocols used to monitor benthic macroinvertebrates

should be the same as those used during the relicensing studies.

In its November 29, 2010 filing, the Forest Service included modifications to

condition 27. The provisions specified in Forest Service modified condition 27 are

similar to those specified in the Forest Service’s original condition 27, except that the

Forest Service has removed specific details of the plan components and monitoring

schedules from the 4(e) condition and placed them in the draft Aquatic Biological

Monitoring Plan included as an enclosure to the filing (Forest Service, 2010d,
160

Enclosure 3). In the draft plan, the Forest Service recommends monitoring of benthic

macroinvertebrates in the Lower McCloud River and Iron Canyon Creek, calculating

benthic community metrics using protocols identified in the Surface Water Ambient

Monitoring Program, and comparing the results to baseline data collected in 2007 and

2008. In its November 24, 2010, filing, PG&E accepts Forest Service modified

condition 27 and withdraws its alternative condition 27.

Our Analysis

Benthic macroinvertebrate monitoring would assist with determining the

effectiveness of measures implemented in the new license for enhancing water quality,

substrate characteristics, and resident fish populations, and for assessing whether any

modifications or additional measures are needed.

Initiating the benthic macroinvertebrate monitoring component of the Aquatic

Biological Monitoring Plan following Commission approval would provide adequate

time to conduct sampling once every 3 years for the first 9 years (i.e., three annual

surveys), and then every 5 years thereafter, as specified by the Forest Service.

Sampling benthic macroinvertebrates using the sampling methods and data

protocols used during the relicensing studies would ensure the comparability of the

methods and the data from the two programs, and would minimize biases associated with

potential changes in sampling protocols. Sampling at site locations used during the

relicensing studies would help in identifying changes, if any, to the benthic

macroinvertebrate community following relicensing.

Fish Passage and Restoration

The design and condition of some culverts on reservoir tributaries at Forest

Service roads could act as impediments to fish passage. In its original condition 27, the

Forest Service specified that, within 1 year of license issuance, as a component of the

Aquatic Biological Management and Monitoring Plan, PG&E develop specific

management actions and schedule for providing fish passage and monitoring for affected

reservoir streams, in consultation with the Forest Service, California Fish and Game,

potentially affected tribes, and other interested parties.

These management actions specified by the Forest Service would include:

 Constructing or correcting fish passage structures on Deadlun, McGill, Cedar

Salt Log, Little Gap, and Gap Creek on Iron Canyon reservoir and Tarantula

Gulch and Battle Creek on McCloud reservoir.

 Maintaining the fish passage structures on an annual basis, if needed,

concurrent with road condition surveys.

 Monitoring each stream reach every 3 years to determine fish passage structure

effectiveness
161

 PG&E would provide the results of fish passage monitoring concurrently with

aquatic monitoring reports.

PG&E alternative condition 27 proposed that roads impeding fish passage on

tributaries to the project reservoirs are not project roads. However, PG&E did indicate

that it would provide compensation to the Forest Service for fish passage maintenance as

part of an off-license road agreement discussed in section 3.3.7, Land Use and Aesthetic

Resources.

NMFS recommends that, as soon as listed salmonids are documented within the

McCloud River and affected by the project, PG&E should, in consultation with the U.S.

Bureau of Reclamation, NMFS, FWS, California Fish and Game, and the Commission,

create and implement a Listed Salmonid Technical Integration Committee. According to

the recommendation, the Listed Salmonid Technical Integration Committee would assess

and mitigate the project’s effects on listed salmonids. This committee could be integrated

with the existing Interagency Fish Passage Steering Committee (or affiliated Technical

Advisory Committees) to begin discussions of passage logistics at Shasta dam and habitat

assessments that include studies of McCloud River historic anadromous salmonid

habitats.

In its November 29, 2010 filing, the Forest Service included modifications to

condition 27. The provisions specified in Forest Service modified condition 27 are

similar to those specified in the Forest Service’s original condition 27, except that the

Forest Service has removed specific details of the plan components and monitoring

schedules from the 4(e) condition and placed them in the draft Aquatic Biological

Monitoring Plan included as an enclosure to the filing (Forest Service, 2010d,

Enclosure 3). Specifically, Forest Service modified condition 27 specifies that fish

passage condition monitoring will be conducted only at Gap Creek, Deadlun Creek, and

Cedar Salt Log Creek road crossing around Iron Canyon reservoir, rather than

construction, repair, maintenance, and monitoring of fish passage structures as specified

in the Forest Service’s original condition 27. In its November 24, 2010, filing, PG&E

accepts Forest Service modified condition 27 and withdraws its alternative condition 27.

Our Analysis

PG&E conducted a survey of fish passage conditions within the inundation zone

of the project reservoirs in October 2007 and found no impediments to fish passage;

however, in the final license application, PG&E noted that upstream fish impediments

may exist at road crossings along FR 37N78 upstream of the influence of reservoir

fluctuations. The Forest Service owns and maintains the roads that may block fish

passage to project reaches. The Forest Service roads span the project reaches with the

use of culverts and bridges which may restrict flow and entrain large debris resulting in

project reaches becoming impassable to some fish. Monitoring fish passage at Gap

Creek, Deadlun Creek, and Cedar Salt Log Creek road crossing around Iron Canyon

reservoir, and reporting the results to the Forest Service, would help identify and reduce

impediments to fish passage during spawning migrations.
162

The Keswick and Shasta dams on the Sacramento River downstream of the

McCloud dam are existing barriers to upstream passage of anadromous salmonids

including Chinook salmon and steelhead. As part of the restoration plan (RPA of the

OCAP BiOp) for these listed species, studies are ongoing to assess the feasibility of

alternatives to facilitate fish passage at these two structures and the quality and

availability of appropriate habitat in tributaries to Shasta Lake including the Lower

McCloud River. None of the listed anadromous salmonids would be expected to have

access to habitat in the Lower McCloud River until reintroduction of listed species is

implemented through Shasta Lake. Currently, no anadromous salmonids have been

documented within project reaches because of the existing barriers to upstream passage;

therefore, at this time, NMFS’s recommendation for PG&E to create a Listed Salmonid

Technical Integration Committee to assess and mitigate the project’s effects on listed

salmonids would provide no direct benefit to listed salmonids. However, to avoid the

possibility of the take of any listed species, it would be beneficial for PG&E to maintain

awareness of the ongoing feasibility studies and the status of the potential re-introduction

of listed anadromous species in the vicinity of the project. Therefore, we recommend that

PG&E file an annual report with the Commission that details the status of listed

anadromous species in the project vicinity. When the presence of listed anadromous fish

in the project area is deemed imminent, this plan should provide an assessment of any

project O&M measures that would have the potential to contribute to the take of any

listed species. These annual reports, in combination with the implementation of various

proposed monitoring programs for aquatic habitat, biota, and water quality parameters

would provide a mechanism to allow for the various management programs to adapt to

changing conditions in the project area, including new the more natural hydrograph and

increased minimum flows and the introduction of new species of concern, such as listed

anadromous salmonids.

Special Status Aquatic Mollusks

During the relicensing studies, PG&E identified one special status aquatic mollusk

(California floater) in Pit 6 and Pit 7 reservoirs. In addition, PG&E identified nugget

pebblesnail inhabiting the Lower McCloud River, outside of the project boundary. In its

original condition 27, the Forest Service specified that, within 1 year of license issuance,

as a component of the Aquatic Biological Management Plan, PG&E monitor special

status aquatic mollusks.

The monitoring specified by the Forest Service would involve:

 Monitoring population trends and changes in distribution of the California

floater, nugget pebblesnail, scalloped juga, and montane peaclam.

 Special status aquatic mollusk monitoring would occur once every 3 years (or

for a period determined by the Forest Service that is consistent with other

monitoring requirements) during the first 9 years and once every 5 years for

the term of the license.
163

PG&E alternative condition 27 disagreed with the Forest Service language and

recommended that periodic monitoring may be conducted “for a period determined by the

Forest Service to be sufficient that is consistent with other monitoring requirements.” In

addition, PG&E recommended that periodic monitoring would begin in the third year

after plan approval by the Commission. PG&E also recommended that sampling sites,

locations, methods, and data protocols used to monitor special status aquatic mollusks

should be the same as those used during the relicensing studies.

In its November 29, 2010, filing, the Forest Service included modifications to

condition 27. The provisions specified in Forest Service modified condition 27 are

similar to those specified the Forest Service’s original condition 27, except that the Forest

Service has removed specific details of the plan components and monitoring schedules

from the 4(e) condition and placed them in the draft Aquatic Biological Monitoring Plan

included as an enclosure to the filing (Forest Service, 2010d, Enclosure 3). Forest

Service modified condition 27 specifies that monitoring of aquatic special status species

should also include northwestern pond turtles and foothill yellow-legged frog within

project waters. Although the northwestern pond turtle and foothill yellow-legged frog

have been moved from the Terrestrial Biological Management Plan to the Aquatic

Biological Management Plan, the monitoring component for these species is discussed in

section 3.3.3.2.2, Wildlife, Special Status Wildlife Species.

In the draft Aquatic Biological Monitoring Plan, the Forest Service recommends

monitoring of special status aquatic mollusks in areas of potentially suitable habitat and

known occupied sites within all project-affected waters. New surveys of potentially

suitable habitat for special status aquatic mollusks would be conducted within 1 year

following license acceptance, and then once every 10 years thereafter. Suitable habitat

where special status aquatic mollusks were identified in previous surveys would be

surveyed once every 10 years, beginning 5 years after the initial survey. Additionally,

surveys of special status aquatic mollusks would be conducted prior to any construction

within potentially suitable habitat areas. In its November 24, 2010, filing, PG&E accepts

Forest Service modified condition 27 and withdraws its alternative condition 27.

Our Analysis

PG&E alternative condition 27 did not provide rationale for PG&E’s disagreement

with the Forest Service’s specification to conduct monitoring for a period determined by

the Forest Service. Because all other components of the Aquatic Biological Management

Plan follow similar monitoring periods, it is assumed that the Forest Service may alter

monitoring periods based on the results and the potential for inclusion of new species that

might be found in the project area. The draft Aquatic Biological Monitoring Plan

provided as an enclosure to Forest Service modified condition 27 recommends a schedule

for monitoring surveys of aquatic mollusks that were previously identified, new surveys

of potentially suitable habitat areas, and surveys of suitable habitat areas prior to any

construction activities. The sampling frequency specified in Forest Service modified

condition 27 would ensure consistency with other monitoring requirements under the
164

plan and would be sufficient to determine population trends and changes in distribution

associated with conditions (e.g., water temperature, sedimentation rates) in project

reaches during the term of the new license.

Monitoring special status aquatic mollusks using the standardized methods and

data protocols used during the relicensing studies would ensure the comparability of the

data from the two periods and projects without potential biases associated with any

changes in sampling protocols. Surveying at site locations used during the relicensing

studies would help identify changes, if any, to special status aquatic mollusks following

relicensing. Additionally, new surveys of potentially suitable habitat areas within

project-affected waters or construction areas would help detect any unknown populations

of special status aquatic mollusks within project waters and help to minimize potential

impacts of the project that were not realized from previous surveys.

The monitoring of special status aquatic mussels and the results from the

monitoring program would provide periodic information to evaluate the condition of

populations and the benefits to aquatic mollusks from improvements to water quality and

quantity.

3.3.2.3 Cumulative Effects

The development of hydroelectric projects on the Pit River, including the

McCloud-Pit and Pit 3, 4, 5 Projects, has had cumulative effects on water resources and

fisheries resources. These projects resulted in the conversion of a historically freeflowing river into a water body consisting of alternating flowing stream reaches and

impoundments. This alteration to the Pit River has resulted in changes to aquatic habitat,

water quality characteristics including DO and temperature, erosion and distribution of

sediment including coarse gravel, distribution of LWD, depth regimes, and water

velocities.

The presence and operation of the McCloud-Pit Project contributes to cumulative

effects on water resources and fisheries resources within the McCloud and Pit River

basins. Project effects on water temperatures are the result of interbasin water transfer

from the McCloud reservoir to the Pit River watershed via the James B. Black

powerhouse. Although ambient water temperatures on the Pit River above the James B.

Black powerhouse ranged from 12 to 22°C from June through September, water entering

through James B. Black powerhouse was cooler, with temperatures below Pit 6

powerhouse less than 19°C. However, during periods when cooler water inputs occur,

there have been no observed effects to the native transition zone fish species in these

reaches. The lack of observable effects is likely the result of the tolerance of transition

zone fish to a wide range of temperatures. Therefore, the waters of the Pit River

combined with inputs from the McCloud River basin seem to be capable of supporting

both transition zone and coldwater fish species, and the cumulative effects of temperature

changes on fish populations are insubstantial.
165

PG&E impoundments and tunnels also modify the duration, distribution, and

dissipation of natural mudflows from Mud Creek through the Lower McCloud watershed

and support interbasin transfer of material from these events which contributes to

occasional cumulative increases of turbidity in the Pit River watershed. However, of two

significant turbidity events associated with Mud Creek in 2008, only one was detected in

the Pit River at about 1 NTU above ambient conditions, which did not exceed the basin

plan numerical criteria for turbidity. Continued monitoring of turbidity levels in Iron

Canyon Creek and the Pit River following future mud flow events would help to

determine cumulative effects, if any, on the Pit River watershed resulting from the

project.

The Lower McCloud River and Iron Canyon Creek support self-sustaining

populations of rainbow trout, with the McCloud River highly regarded as a productive

sport fishery. Operation of the project in accordance with the various proposed,

recommended, and specified flow regimes may improve the production, growth, and

condition of trout by providing more optimal flow-habitat during growth and spawning

seasons.

Bull trout, at the southern extent of its range, was historically an important part of

the aquatic community of the McCloud River. The extirpation of this species from the

watershed is postulated to have been the cumulative effect of a number of factors

including, but not limited to, loss of juvenile Chinook salmon, an important forage for

bull trout, excessive fishing pressure in McCloud reservoir, competition from other

managed game species (rainbow and brown trout), and reduction of habitat associated

with construction of McCloud dam. Efforts by California Fish and Game in the1970s to

restore the species through stocking were unsuccessful. Restoration is not currently a

primary management goal of the agency and no recommendations have been proposed

specifically to support restoration of this species.

The McCloud and Pit River watersheds historically provided habitat for several

listed species, including Chinook salmon and steelhead. Although the project dams act as

barriers to upstream migration, construction of the Bureau of Reclamation’s Shasta and

Keswick projects downstream on the Sacramento River prevent access for these species

to the upper Sacramento River and its tributaries, including the McCloud and Pit Rivers

and their tributaries. As part of restoration plans for these species, studies are ongoing to

evaluate options that would provide passage at the Keswick and Shasta projects.

Issued to the Bureau of Reclamation on June 4, 2009, the OCAP BiOp (NMFS,

2009a), provides NMFS’s review of the proposed long-term operations of the Central

Valley Project and State Water Project in California, and designated and proposed critical

habitats, in accordance with section 7 of the ESA. As part of the RPA for the OCAP

BiOp, studies are to be implemented to assess the feasibility to facilitate fish passage over

Keswick and Shasta dams on the Sacramento River downstream of McCloud dam. In

October 2009, NMFS issued the Public Draft Recovery Plan (NMFS, 2009b). This

Public Draft Recovery Plan identified the McCloud River as a “high” priority habitat for
166

supporting spawning populations of these listed salmonids and provided that, as part of

the recovery strategy, habitat evaluations and feasibility studies including fish passage

logistics be implemented to support re-introduction efforts in habitat above Shasta dam.

The RPA for the OCAP BiOp adopted this action.

An Interagency Fish Passage Steering Committee was created by the OCAP BiOp

to oversee planning and implementation of the salmon reintroduction program. As part

of the RPA for the OCAP BiOp, studies are to be implemented to assess the feasibility to

facilitate fish passage over Keswick and Shasta dams on the Sacramento River

downstream of McCloud dam. Feasibility studies to assess the suitability and

functionality of existing or potential habitat for spawning and rearing of listed salmonids

were expected to begin in January 2010 and continue through January 2012. Based on

the results of the feasibility studies, a pilot program could be implemented to re-introduce

listed anadromous species to habitat above Shasta and Keswick dams beginning in March

2012. Implementation of the pilot program could result in the future presence of listed

salmonids in the Lower McCloud River and waters of the McCloud-Pit Project below

McCloud dam as early as 2012. If this pilot-program proves successful, a long-term

anadromous fish passage program could be implemented by January 31, 2020. Such a

long-term program would include structural and operational modifications to dams to

provide both upstream and downstream fish passage.

We note that there are uncertainties regarding the viability and implementation of

reintroduction program set forth by the OCAP BiOp. In October 2010, the Interagency

Fish Passage Steering Committee’s Annual Report of Activities12 indicated that the

Bureau of Reclamation requested, but has not received funding for fiscal year 2012 and

does not have dedicated fiscal year 2011 funding for the Fish Passage Program. The

program is currently subsisting by requesting that partner agencies “...provide what

support they are able to provide within existing budgets and staffing.” In a letter filed

January 18, 2010, PG&E reiterated that the Public Draft Recovery Plan has yet to be

signed by the Secretary of Commerce, and therefore, has no legal effect. PG&E also

indicated that on March 5, 2010, a United States District Court judge ruled that Bureau of

Reclamation’s adoption of and NMFS and Bureau of Reclamation’s implementation of

the OCAP BiOp RPA violated NEPA, since the agencies failed to conduct the required

NEPA analysis before acting. PG&E suggests that any future implementation of the

OCAP BiOp will require NEPA analysis

While the ultimate reintroduction of listed anadromous salmonids to the project

area is uncertain, we discuss this issue further in section 5.2, Comprehensive

Development, and make a recommendation regarding PG&E’s role in future efforts

concerning the reintroduction of anadromous salmonids.

12 Filed in the public record on January 25, 2011.
167

3.3.3 Terrestrial Resources

3.3.3.1 Affected Environment

3.3.3.1.1 Vegetation

To provide baseline information on vegetation communities in the project area,

PG&E conducted vegetation mapping efforts to characterize and quantify all existing

vegetation types within 0.5 mile of the project boundary. Elevations in the study area

range between 1,100 and 3,500 feet msl, with moderate to very steep terrain.

The project area includes a variety of upland vegetation types typical of midelevation forests and valleys found in the southeastern Klamath Mountains and southern

Cascade regions, and is dominated by Douglas fir, Douglas fir-ponderosa pine, mixed

conifer and canyon live oak plant communities that together comprise about 84 percent of

the upland vegetation cover within the project area. Douglas fir-ponderosa pine is the

most common vegetation type within the project area and generally occurs throughout all

portions of the area. Associated understory species for the most common upland

vegetation communities include small specimens of canopy species as well as shrubs and

vine species. Groundcover varies from sparse to moderate for these communities and is

characterized by various species of grasses and forbs.

Vegetation mapping within the proposed new construction and transmission line

corridors identified a total of 17 vegetation series, three other vegetation types and three

non-vegetated features. The non-vegetated features included the McCloud Cemetery,

McCloud Golf Course, and paved roads. Together these three features encompassed

about 159 acres (2 percent). As identified within the existing project area, uplands were

primarily determined to be mixed conifer vegetation series (32 percent), ponderosa pine

(31 percent), Douglas fir (6 percent) and Douglas fir-ponderosa pine (5 percent). The

community of McCloud is represented by urban land (10 percent). Mixed willow

riparian vegetation community and California annual grasslands were also relatively

common (3 and 2 percent, respectively).

Other habitats encountered that are not defined by vegetation included littoral,

riverine, lacustrine, and barren areas. Littoral habitats within the study area consist of the

reservoir fluctuation zones surrounding lacustrine habitats. Most of these areas are

devoid of vegetation, particularly around the steep shoreline of the McCloud reservoir.

Portions of the littoral zone do support vegetation during draw-down periods, including

various woody and herbaceous riparian and upland species such as cheat grass,

intermediate wheatgrass, and prickly lettuce. Littoral habitats surrounding the more

gradual slopes adjacent to Iron Canyon reservoir are characterized by denser vegetation,

and in general, included a large number of weed species such as yellow star-thistle,

Himalayan blackberry, Kentucky bluegrass, and wooly mullein. Over the project area,

about 34 acres of littoral habitats were mapped.

Riverine habitat areas consisting of non-vegetated open water occur along the

free-flowing portions of the Pit and McCloud Rivers. These areas are highly variable and
168

range between moderate, low gradient, and steep, moderate gradient stream reaches in

moderate to well confined stream channels. About 240 riverine acres were mapped.

Lacustrine habitats within existing facilities are open water areas including areas

inundated by the two project reservoirs as well as the Pit 6 and Pit 7 reservoirs, and Pit 7

afterbay. A total of about 1,056 acres of lacustrine habitat were mapped within existing

facilities. A pond at the McCloud sewer treatment facility east of Squaw Creek Valley

Road is within the proposed transmission line corridor and is about 11 acres.

Barren areas consist mainly of non-vegetated, man-made features scattered

throughout the study area, such as fill slopes and old construction sites, non-vegetated

landings resulting from previous logging operations, and naturally occurring rock outcrop

and/or talus slope features. About 15 acres of barren areas were mapped in the project

area; 22 acres were mapped along the proposed McCloud transmission line route.

Riparian and Wetland Vegetation

Wetland and riparian habitats are dependent on particular hydrologic regimes and

are, therefore, considered particularly sensitive to potential project effects. Historical

photo analysis was conducted for the Lower McCloud River from McCloud dam

downstream to Shasta Lake to analyze longitudinal changes in riparian vegetation

distribution over time. Historical aerial photographs from the Forest Service were

compared with PG&E’s 2006 aerial photographs. Photographs of selected stream reaches

were available for the years 1944, 1952, and 1970 (the project was constructed in 1965).

Significant changes in the longitudinal and cross-sectional extent of riparian vegetation

due to project-related flow alterations were not detected during this analysis.

In addition to reviewing aerial photographs, vegetation mapping identified about

493 acres of riparian habitat and less than one acre of wetland habitat within the project

area; more than 631 acres of wetland habitat were identified along the proposed McCloud

transmission line corridor due to the relatively low gradient, broad meadow features

within the corridor. Spikerush vegetation series accounted for 85 percent (540 acres) of

wetland vegetation. Overall, 121 vascular plant species, 10 vegetation series, and 18

provisional plant associations were identified in the riparian zone of the Lower McCloud

River.

The riparian zone of the Lower McCloud River, as defined by the presence of

riparian vegetation, is generally less than 75 feet wide because of the steep nature of the

surrounding valley walls that form a confined channel. White alder vegetation type was

the most common riparian plant community (65 percent of riparian cover) and occurred

along most of the drainages within the project area as narrow to moderately wide bands

of vegetation within and along the margins of river, stream, and other drainages. Mixed

willow and big-leaf maple vegetation communities were also common and together

comprised an additional 30 percent of riparian vegetation. Riparian habitat ground layer

was characterized as open to dense in cover and dominated by rushes, sedges, forbs and
169

grasses. Spikerush, sedges, cattail, bulrush, were species indicative of wetlands within

the project area.

Riparian studies in 2007 identified a gap in the age class distribution of white alder

resulting from flooding in 1997, the largest annual peak flow in the 45-year record. The

1997 flood mobilized the channel bed and the resulting scouring action removed the

existing riparian vegetation. Since then, no other bed-mobilizing flood events have

occurred. Young white alder trees and other riparian vegetation have colonized the lower

bank elevations of the Lower McCloud River and expanded laterally into the Lower

McCloud River channel. Alterations in riparian vegetation structure were evident on

gravel bar and split channel features in river reaches through Nature Conservancy and

McCloud River Club owned lands upstream of the Squaw Valley confluence. Results of

the aerial photograph interpretation of riparian vegetation determined that no distinct

difference in vegetation character or longitudinal extent of riparian vegetation was

apparent along the Lower McCloud River. Some areas of localized changes in density,

height, and age of riparian vegetation have occurred within the active channel. Longterm shifts in species composition of riparian vegetation on mid-channel gravel and

cobble bars versus along the channel banks were not evident during the study.

Noxious Weeds

Botanical surveys for invasive plant species were conducted within the project

area and included land adjacent to project facilities, designated and dispersed recreation

sites, and proposed infrastructure construction areas and their associated buffers. In

addition, incidental information on targeted invasive plant species located along cross

sections of the Lower McCloud riparian corridor between McCloud dam and Squaw

Valley Creek is included; this information was collected as part of the riparian vegetation

study.

In order to differentiate the level of survey effort necessary for each species, this

combined target list of species was divided into high, medium, and low priority species

based on their abundance in mapped areas. As a result, 16 high-priority, 9 mediumpriority, and 40 low-priority targeted, terrestrial invasive plant species were observed, for

a total of 65 species. No invasive aquatic weed species were observed. Of all the

targeted, high-priority invasive plant species that were surveyed, four species were

particularly pervasive: yellow star-thistle, bull thistle, Himalayan blackberry, and

spreading hedge-parsley. The most ubiquitous low-priority species were hedgehog

dogtail and common St. Johnswort. Existing roads and transmission lines were heavily

infested with noxious weeds due to the disturbed soils and maintenance activities.

Reservoir shorelines also have high levels of infestation due to fluctuating water levels

that allow noxious weeds to invade. New plants can become established as a result of

water-borne seed transport, or seeds may be present within the soil bank of the shoreline

and new plants can colonize newly emerging shorelines as water levels recede.

Recreational activities such as boating can also break off portions of plants that can

propagate.
170

Black locust, an invasive tree, occurs in the upland and riparian areas along the

Lower McCloud River. The origination of black locust is in a former homestead in the

Ah-Di-Na area, and the species’ occurrence is concentrated at Ah-Di-Na though it is

dispersed throughout the Lower McCloud River. No black locust was found at the most

upstream or the most downstream study sites. The species prefers habitat of coarsegrained sediment in areas of infrequent inundation.

Special Status and Special Interest Plant, Lichen, and Fungi Species

Consultation with agencies and a literature review were used to develop a list of

special status plant, lichen, and fungi species with the potential to occur in the project

area. Field botanical surveys were conducted to determine if populations of the listed

species were present in the project area. A total of eight special status vascular plant

species were located during the surveys. No special status lichen or fungi species were

documented in the study area.

Shasta eupatorium is a perennial shrub in the sunflower family and endemic to

Shasta County. It occurs from 1,300 to 5,900 feet msl in chaparral and lower montane

coniferous forest with rocky carbonate soils or on limestone cliffs. One small patch of

about five plants was found growing on a bank of exposed bedrock at a dispersed

recreation site adjacent to the Lower McCloud River.

Butte County morning glory is a perennial, rhizomatous herb in the morning glory

family endemic to California and found in the High Cascade Range, Klamath Range, and

San Francisco Bay Area, as well as in Butte, Contra Costa, Del Norte, Mendocino,

Shasta, and Tehama Counties. The Butte County morning glory prefers dry rocky soils

and occurs from 1,900 to 5,000 feet msl in chaparral, open areas of lower montane

coniferous forests and occasionally along roadsides. It blooms from May to July. Five

populations of Butte County morning glory were found in the study area. One population

was located in a shady location along Pit 6 Road, in lower montane coniferous forest

flats; a second population was located along the Pit 6 transmission line, and the

remaining three populations were all observed along the existing Pit 7 transmission line.

Northern clarkia is an annual herb in the primrose family and is endemic to

California (Shasta and Trinity counties) growing from 1,300 to 4,400 feet msl in

chaparral, cismontane (west of the Sierra Nevada) and foothill woodlands, as well as

lower montane coniferous forest. The blooming period is June to September. A total of

20 northern clarkia populations were found throughout the study area: 16 populations

along Oak Mountain Road, two along Pit 6 Road, and two along the Pit 6 transmission

line.

Butte County fritillary is found only in Tehama, Butte, and Shasta Counties in the

Cascade Range from 160 to 4,900 feet msl. A perennial herb in the lily family, Butte

County fritillary and is conspicuous between March and June on dry benches and slopes,

generally in chaparral, cismontane woodland, and in openings in lower montane

coniferous forest. Six populations of Butte County fritillary were found within the
171

proposed Pit 7 afterbay powerhouse and proposed access road to Pit 7 afterbay

powerhouse areas.

Howell’s lewisia is a perennial herb in the purslane family distributed from Idaho

through Oregon to Northern California. Specifically in California it is found in Shasta,

Del Norte, Trinity, Humboldt, and Siskiyou Counties. It blooms from April to July on

rock outcrops and canyon walls in broadleaf upland forest, chaparral, cismontane

woodland, and lower montane coniferous forest at elevations ranging from 490 to

6,600 feet msl. One population of Howell’s lewisia was found at a Lower McCloud

River recreation site, and a second population was found at a recreation site between

McCloud dam and Hawkins tunnel.

English peak greenbriar is a perennial, herbaceous vine endemic to California and

is found in the Cascade and Klamath ranges, as well as Del Norte, Shasta, Siskiyou, and

Trinity Counties, typically at elevations of 1,900 to 8,000 feet msl. It occurs primarily in

association with alder thickets marshes and swamps, lake margins, stream banks

including lake margins and stream banks within, lower montane and montane coniferous

forest and deciduous forests. It blooms from May to July or August. Five populations of

English peak greenbriar were documented along the Iron Canyon reservoir road.

Long-fruit jewel flower is a short-lived perennial herb in the mustard family

endemic to California and more specifically to Butte, Shasta, and Tehama Counties.

Recently described by Clifton and Buck (2007), long fruit jewel flower is limited to the

eastern side of the Klamath Range at the southern edge of the Cascade Range and the

western side of the northernmost Sierra Nevada Mountains. It occurs at elevations from

2,350 to 5,000 feet msl and blooms from April to September throughout cismontane

woodlands and lower coniferous forest openings with a variety of soil types, often in

disturbed areas. Three populations of this newly described species were documented:

two populations along Oak Mountain Road and one population along the Pit 6 road.

Slender false lupine occurs in the Klamath and North Coast ranges in California

north through Oregon, specifically in Del Norte, Humboldt, Shasta, Siskiyou, and Trinity

Counties. It is found at elevations ranging from 300 to 4,500 feet msl in open, often dry

sites (sometimes roadsides), including chaparral, cismontane woodland, lower montane

coniferous forest, meadows and seeps, and north coast coniferous forest. An herb in the

pea family, it blooms from March to July. Six populations of slender false lupine were

located across the study area, one along Pit 7 afterbay road, two along Oak Mountain

Road, and three populations along the proposed route for the Pit 7 afterbay transmission

line.

Special interest plants include native plant populations suitable for revegetation

source material; culturally significant plant species, as defined by the Tribes; and

elderberry (Sambucus mexicana) plants suitable for supporting the federally threatened

VELB, section 3.3.4, Threatened and Endangered Species.
172

A confidential list of culturally significant plants, including a threshold abundance

criterion for each species, was developed in consultation with the Tribes during a series

of meetings in early 2007. The list and survey results related to culturally significant

plants was presented directly to the Tribes as a confidential report attachment and is also

confidential. A total of 95 populations, containing 32 species of culturally significant

species were located during the survey.

Elderberry is a large, deciduous, perennial shrub or small tree in the honeysuckle

family. It typically occurs along stream banks and forest openings below 9,840 feet msl

within a variety of habitats including chaparral, foothill woodland, red fir forest, riparian

forest and woodland, and yellow pine forest throughout California. Fifteen populations

of elderberry were documented in the McCloud reservoir, McCloud tunnel, Iron Canyon

reservoir, Iron Canyon tunnel, Oak Mountain Road, and Pit 7 afterbay areas. Most of the

populations were sparse, with between one and 10 individuals; however, two populations

contained between 11 and 50 individuals and one population had more than 100. Aside

from abundance, percent cover, and patch size, no additional VELB habitat-specific

information (i.e., number of stems greater than or equal to 1-inch diameter at ground

level and the presence or absence of VELB exit holes) was recorded for the elderberry

population.

3.3.3.1.2 Wildlife

General Wildlife

As a result of the diverse vegetation community structure within the project area,

wildlife resources are also diverse and include common, resident, and migratory species.

Invertebrates, amphibians, reptiles, birds, small and large mammals, game species, and

special status species are represented. Wildlife resources were assessed using

methodologies that included literature review, agency consultation, and field surveys.

Unless otherwise noted, information for this section was derived from the license

application and technical memos resulting from specific surveys and provided in the

license application (PG&E, 2009a).

Sierran mixed conifer forest is the most common forest type in the project area,

and provides habitat for small mammals such as chipmunks, western gray squirrel, deer

mouse, and bats. Larger mammals typically found in Sierran mixed conifer forest

include gray fox, black bear, and mule deer. Dead trees (snags) and large trees provide

nesting sites for predatory birds (raptors) such as red-tailed hawks. Other species of birds

typically found in this vegetation community include dark-eyed junco, mountain

chickadee, Steller’s jay, western wood-pewee, and northern flicker. Western fence lizard

may also occur on the forest floor.

Montane hardwood is the second most frequent wildlife habitat type in the project

vicinity. This woodland vegetation provides habitat for many species that are reliant on

acorns as food. Many bird species such as western scrub jay, evening grosbeak, acorn

woodpecker, white-breasted nuthatch, and Hutton’s vireo utilize this habitat type (Forest
173

Service, 1995). Western gray squirrel, California ground squirrel, and chipmunks also

rely on acorns. All of these species inadvertently distribute acorns and, as a result,

enhance the growth of oaks in the community. This vegetation community also provides

habitat for raptors including owls and hawks.

Similar to Sierran mixed conifer forest, ponderosa pine forest provides habitat for

raptors including red-tailed hawk and small mammals such as western gray squirrel.

Other species that may use this vegetation community include mountain quail, western

scrub jay, and deer.

Blue oak-foothill pine woodlands are found between lower elevation grasslands

and the lower montane mixed coniferous forest and, consequently, generally share

species with adjacent vegetation communities resulting in a high diversity of wildlife

species.

Mixed chaparral occurs adjacent to the previously described blue oak woodlands.

Wildlife using chaparral habitat is varied and may include deer, bushtit, green-tailed

towhee, wrentit, and mountain lion (Forest Service, 1995).

Many species depend upon riparian, wetland, or littoral habitat including beaver,

muskrat, long-tailed weasel, American mink, California red-legged frog, black

salamander, yellow warbler, willow flycatcher, and Pacific fisher. Freshwater emergent

wetlands are used by aquatic and semi-aquatic species of wildlife including tailed frogs,

northwestern pond turtle, bald eagle, river otter, water shrew, ducks, geese, and

shorebirds (Forest Service, 1995).

Generally terrestrial wildlife species within the project area use the open water

associated with the creeks and forebays of the project as foraging habitat and water

source. The open water also provides resting and foraging habitat for aquatic bird species

(grebes, waterfowl, wading birds, shorebirds, gulls, and terns) and aerial insect foragers

such as swifts, swallows, flycatchers, and bats. Fish-eating species such as osprey, bald

eagle, and belted kingfisher are also found. Many common mammals use open water as a

source of drinking water, and raccoons forage for prey along the shoreline.

The developed/disturbed urban habitat surrounding the development facilities

attracts species that are tolerant of human activity and have adapted to maintained

vegetation (lawns and landscaped areas). Typical species include rock pigeons, western

scrub jay, northern mockingbird, house finch, house sparrow, opossum, raccoon, and

striped skunk.

A wide variety of game species occur within a variety of wildlife habitats in the

project area including game birds such as band-tailed pigeons, blue grouse, mountain

quail, mourning dove, ruffed grouse, wild turkey, California quail, ducks, and geese.

Mammal species that are hunted include black bear, elk, mule deer, wild boar, gray

squirrel, Douglas squirrel, hares, rabbits, bobcat, beaver, coyote, and gray fox (Forest

Service, 1995). Amphibian and reptile surveys located ensatina, black salamander,
174

western fence lizard, western skink, ringneck snake, and western rattlesnake in the

project area.

Bat species detected by acoustic and capture surveys in the project area, including

existing and proposed infrastructure areas, include Mexican free-tailed bat, big brown

bat, silver-haired bat, hoary bat, California myotis, long-eared myotis, fringed myotis,

Yuma myotis, and western pipistrelle. Five other species were detected (pallid bat,

Townsend’s big-eared bat, spotted bat, western red bat, and western mastiff bat) and are

discussed in the special status wildlife section below. Yuma myotis was the most

abundant species captured during surveys, and was captured at the highest number of

sites; this species was also detected at every acoustic survey site.

Survey results identified roost sites in the project area and include powergeneration and dam structures, siphons, campground structures, overflow spillways, and a

natural limestone cave complex on the west shore of McCloud reservoir. Two structures

were confirmed to support day roosts for maternity colonies: James B. Black

powerhouse and McCloud intake. Willow Creek siphon is also likely a maternity colony.

These sites are critical to bats during the reproductive season, generally spring to fall.

Winter hibernacula surveys were conducted at McCloud reservoir intake, McCloud dam

diversion/outlet tunnel, Ah-Di-Na campground old cellar building, and Iron Canyon

reservoir overflow spillway, but no evidence of hibernacula was observed.

Special Status Wildlife Species

Special status wildlife species include species that may be protected by the state of

California as endangered or threatened, California species of concern, California fully

protected species, species identified as watchlist species by California Fish and Game,

and other species identified as special animals by California Fish and Game. Also

included are Forest Service Region 5 species of concern. Federally listed rare,

threatened, or endangered species; candidate species for listing; and any applicable

designated critical habitat for a listed species are discussed in section 3.3.4, Threatened

and Endangered Species.

Based on discussions with California Fish and Game and FWS, PG&E developed

a list of special status wildlife species that are known to occur or have the potential to

occur where suitable habitat exists in the project area: VELB; bald eagle; golden eagle;

northern goshawk; peregrine falcon; Northern spotted owl; willow flycatcher; bank

swallow; greater sandhill crane; American marten; Pacific fisher; Sierra Nevada red fox;

California wolverine; ringtail; pallid bat; spotted bat; Townsend’s big-eared bat; western

red bat; western mastiff bat; Shasta salamander; tailed frog; foothill yellow-legged frog;

northwestern pond turtle; and 10 species of terrestrial mollusks, six of which are

considered Forest Service special status species. As federal-listed species, VELB,

northern spotted owl, Pacific fisher, and California red-legged frog are addressed in

section 3.3.4, Threatened and Endangered Species.
175

Other species considered but eliminated from further discussion include: great

gray owl, California spotted owl, bank swallow, southern torrent salamander and

Cascades frog. Great gray owls are not discussed due to the distance of the project area

from the typical range of the species (more than 150 miles) (California Wildlife-Habitat

Relationships [CWHR], 2010). The Forest Service identifies the range of northern

spotted owls as north of the Pit River, and California spotted owls as south of the Pit

River, and commented that the project is not within the range of the California spotted

owl; therefore, it is not further addressed (PG&E, 2006). The project area does not

provide suitable habitat for southern torrent salamander or Cascades frog.

Terrestrial Mollusks

Three of the 10 terrestrial mollusk species were detected within the project area:

Shasta chaparral snail, Shasta hesperian, and the Oregon shoulderband snail.

Shasta Chaparral Snail—The Shasta chaparral snail is endemic to Shasta County

and is generally found within 100 meters of lightly to deeply shaded limestone areas. In

the project area it was detected at the Pit 6 and 7 reservoirs and facilities.

Shasta Hesperian Snail—The Shasta hesperian snail is found on damp ground near

springs, seeps, and at stream margins under or on loose rocks, woody debris, or decaying

leaves and is considered common along the middle reaches of the Pit River. It was the

most abundant and ubiquitous of the special status terrestrial mollusk species detected

within the project area. In the project area, it was found near year-round sources of water

under rocks, leaf litter, or woody debris. This species was found at McCloud reservoir,

Lower McCloud River; Iron Canyon reservoir, Iron Canyon Creek, Pit 6 reservoir and

project facilities, and Pit 7 reservoir and facilities. The Shasta hesperian snail was found

at the proposed Pit 7 powerhouse site and all of the sites along the proposed Pit 7

transmission line route. In the proposed McCloud construction site, the Shasta hesperian

snail was found in low abundance at Tarantula Gulch.

Oregon Shoulderband Snail—The Oregon shoulderband snail is associated with

talus and other rocky substrates wherever permanent ground cover such as rock fissures

or LWD, or moisture is available but is somewhat adapted to dry conditions during a

portion of the year. The Oregon shoulderband snail was found in the Lower McCloud

River, Iron Canyon reservoir, James B. Black facilities, Pit 6 reservoir and project

facilities, and the Pit 7 reservoir and project facilities. This species was also found in the

study area associated with the proposed Pit 7 afterbay construction area where it was

detected under boulders at the USGS gage building.

Amphibians and Reptiles

Shasta Salamander—The Shasta salamander is listed as threatened under the

California ESA. The Shasta salamander primarily inhabits limestone outcrops and caves

and adjacent slope habitats in mixed forests of Douglas-fir, foothill pine, and black and

canyon oak, at elevations from 1,000 to 3,000 feet msl, though it may also use a variety

of non-limestone habitats within its known range. The Shasta salamander lays and
176

broods its eggs in limestone caves in summer. Individuals were found at McCloud

reservoir and Fenders Flat / Pit 7 afterbay dam during surveys.

Tailed Frog—The tailed frog is a California species of special concern. This

species uses cold, rocky streams in humid forests of Douglas-fir, pine, spruce, hemlock,

redwood, maple, and alder, with interspersed grassland or chaparral (Stebbins, 2003).

Most breeding occurs in early fall; eggs are laid in June and July and attached to rocky

streambed. Hatching occurs in August and September. Adult and tadpole stages of tailed

frogs were found at Ladybug Creek, a tributary to the Lower McCloud River. The Forest

Service commented on November 18, 2006, that the tailed frog is known to be present in

the McCloud reservoir based on unpublished data from a Forest Service employee.

Foothill Yellow-Legged Frog—The foothill yellow-legged frog is a Forest Service

sensitive species and a California species of special concern. The foothill yellow-legged

frog inhabits small streams below 5,000 feet msl where breeding occurs in low to

moderate gradient streams in shallow edgewater areas, often close to confluences with

tributary streams. In the spring, the foothill yellow-legged frog deposits masses of eggs

on the downstream side of cobbles and boulders in gently flowing water once water

temperatures reach about 53 to 55°F. Tadpoles tend to remain near the hatching site;

these areas are typically associated with edgewater habitat and are adjacent to riffles,

cascades, main channel pools, and plunge-pools that provide escape cover and food.

Tadpoles metamorphose into juvenile frogs in 3 to 4 months. Juvenile and adult

individuals prefer perennial streams and ephemeral creeks with pools and areas that

provide exposed basking sites and cool shady areas adjacent to the edge of the water.

During amphibian surveys in the project area, foothill yellow-legged frog

individuals were observed at seven sites located between river mile 1.4 and 5.7 on the

Lower McCloud River and in associated tributaries. Evidence of breeding (egg masses or

tadpoles and post-metamorphic frogs (adults, juveniles, or young of the year) were

observed at four mainstem sites. Post-metamorphic frogs were also observed in three

tributaries. Twelve egg masses were observed in the Lower McCloud River between

May 8 and June 10; seven of these showed evidence of successful hatching (tadpoles

were found nearby), and the other five failed due to scouring, fungal infestation, or

predation.

Northwestern Pond Turtle—The northwestern pond turtle, also called the north

Pacific pond turtle or the western pond turtle, is a species of special concern in

California. It is distributed from western Washington to northwest Baja California,

mostly west of the Cascade-Sierra crest, and may be found at elevations up to 6,696 feet

but mostly below 4,980 feet msl (Stebbins, 2003). It inhabits ponds, lakes, rivers,

marshes, streams, and irrigation ditches with rocky or muddy bottoms and herbaceous

vegetation. Natural Heritage records exist for this species in Shasta and Siskiyou

Counties, and in the McCloud, Upper Pit and Lower Pit watersheds.

Surveys for northwestern pond turtle were conducted by boat in 2007 and 2008 in

the McCloud, Iron Canyon, Pit 6, and Pit 7 reservoirs; individuals were found in the Pit 6
177

and Pit 7 reservoirs. In addition to the reservoir surveys, individuals were observed

during surveys for foothill yellow-legged frog at four sites on the Lower McCloud River,

in Pit 6 reservoir, and in Pit 7 reservoir.

All northwestern pond turtle individuals found in the Pit 6 and Pit 7 reservoirs

were sighted in the lower reaches of the reservoirs. Areas of suitable habitat in Iron

Canyon and McCloud reservoirs were found to be well above the waterline in 2008;

refuge areas in shoreline brush and basking areas were greatly reduced by low water

levels. It was surmised that it is unlikely that either Iron Canyon reservoir or McCloud

reservoir supports a northwestern pond turtle population, although there is potential for

individual turtles to escape detection. The tributary streams upstream of Iron Canyon

reservoir are likely too small to support northwestern pond turtle populations. Those

tributaries upstream of McCloud reservoir may lack sufficient slow-water habitat and

may be too cold.

Birds

Bald Eagle—The bald eagle was removed from the federal endangered species list

in 2007; however, it continues to be protected by the federal Bald and Golden Eagle

Protection Act and Migratory Bird Treaty Act, as a California listed endangered species

and fully protected species and as a Forest Service sensitive species.

The bald eagle tends to nest in areas of mature / late successional or old-growth

forest where large trees are available for nest building in fairly close proximity to large

bodies of water used for hunting. Winter habitat requirements include adequate food

supplies and the presence of roosting sites generally located close to open water but

which can be over 20 miles from foraging areas. Important perch and roost sites include

snags and dead-topped, live trees in areas with minimal human disturbance. Fish are the

primary diet, although waterfowl, gulls, and other birds; mammals; and carrion may also

be taken.

PG&E has monitored all known bald eagle territories since the mid-1980s located

within the area defined in the Pit River Management Zone of the Pacific Bald Eagle

Recovery Plan, developed and implemented by FWS in 1986. Overall, the population of

eagles has increased in the project area; nest success and productivity is below average

for the state; and nests along reservoirs have had better productivity than those along

rivers, suggesting that as the population increases in the area some territories are

established in marginal habitat affecting nest success and productivity.

Prelicensing surveys located eight bald eagle nesting territories within the project

area including two previously unknown territories on Chatterdown Creek and McCloud

Bridge. Other territories in the project area located at McCloud reservoir, McCloud

River, Iron Canyon reservoir (two), Pit 6 reservoir, and Pit 7 afterbay near Pit 7 dam.

Winter sightings of adult bald eagle individuals near known territories indicate that pairs

are likely year-round residents. Bald eagle prey studies in the 1980s at McCloud and Iron

Canyon reservoirs revealed a diverse diet of salmonids; water and land birds; and
178

mammals including deer and squirrels; though it is suspected that salmonids make up a

large portion of the diet of these eagles (Nevares et al., 2008a).

Golden Eagle—The golden eagle is protected under the Bald and Golden Eagle

Protection Act and the Migratory Bird Treaty Act, and is a California fully protected

species. Golden eagles use a variety of habitats including conifer, hardwood or mixed

woodland, alpine, grassland, cliff, desert, savannah, and tundra. Golden eagles were

noted as occurring in the project area for the Pit 1 new license environmental assessment,

about 50 miles from the McCloud-Pit project (PG&E, 1999). No surveys were conducted

in the McCloud-Pit project area for golden eagles.

Northern Goshawk—The northern goshawk, a large forest-dwelling raptor that

uses a wide variety of habitat types, is a federal species of concern, California species of

concern, and Forest Service sensitive species. The northern goshawk prefers dense, late

successional stage forest for nesting that is interspersed with meadows and other

openings, and low-elevation riparian habitats for foraging. The goshawk nesting period

extends from mid-February through mid-September.

Surveys of potentially suitable habitat were conducted to determine if northern

goshawks were present and if active nesting was occurring. The broadcast acoustical

method was used for initial surveys, and the stand search method was used for follow up

surveys. Two surveys occurred during the breeding season (June 1 through August 15)

of 2007 and 2008. Although no active nests were identified, there were six northern

goshawk detections during the 2007 survey season; no detections were documented

during 2008 surveys. The majority (four) of the detections were associated with a

suspected northern goshawk activity center located on Forest Service land about 0.5 mile

south of Ah-Di-Na Campground. This area is considered a suspected northern goshawk

activity center due to detections occurring in each survey period and the observation of at

least two birds displaying aggressive/territorial behavior. The remaining detections

occurred at the southeast end of the Pit 6 transmission line about 1.5 miles northwest of

Wengler (Nevares and Lindstrand, 2008a).

Peregrine Falcon—The peregrine falcon was officially removed from the federal

list of endangered species in 1999 and from the California state list in 2009 (California

Fish and Game, 2010), but remains a California fully protected species, and is protected

under the Migratory Bird Treaty Act of 1918. Individuals feed primarily on birds from

warbler- to mallard-sized, taken in flight over various habitats including forest edges,

meadows, and water bodies (reservoirs, rivers, and streams). Steep-walled canyons and

limestone outcroppings provide potential nesting habitat for peregrine falcons. Eggs are

laid and young are reared on ledges or in small caves. The breeding season extends from

about March to mid-August, although timing can vary.

Several territories have been documented in the vicinity of the project area, and

surveys to assess habitat and presence of nesting individuals resulted in the

documentation of nesting pairs along almost all major project water bodies within the

project area. Peregrine falcon nesting pairs were documented in large rock outcroppings
179

along the McCloud River, Iron Canyon Creek, Pit 7 reservoir, and Pit 6 reservoir. The

2007-2008 surveys also documented breeding at four territories and each nesting pair

produced at least one young and, in most cases, two young were observed (Nevares et al.,

2008b).

Willow Flycatcher—Willow flycatcher is a California listed endangered species

and a Forest Service species of concern. Suitable habitats occurring in the project area

include “monotypic, willow, marsh-lake margin” and “mixed shrub riparian–varying

stream size” habitat types and meet willow flycatcher protocol criteria of having patchy

shrubby riparian vegetation, and at least some surface water or saturated soil during the

early portion of the breeding season. Surveys conducted in 2008 detected non-territorial

individuals in suitable habitat at the Cedar Salt Log, McGill Creek, and Fenders Flat /

Pit 7 afterbay dam survey areas. The individuals detected are considered migrants;

however, it is possible that some individuals may breed in the project area (Nevares and

Lindstrand, 2008b).

Bank Swallow—In California, the state-listed threatened bank swallow relies on

naturally eroding habitats of major lowland river systems (California Fish and Game,

2003). This species nests in colonies and creates nests by burrowing into vertical banks

of fine-textured soils. Currently, individuals are locally common only in portions of

California where sandy, vertical bluffs or riverbanks are available. The current range for

this species does not appear to overlap the project area.

Greater Sandhill Crane—The greater sandhill crane is a California fully protected

species, and is state-listed as a threatened species. This species feeds on a variety of prey

items (amphibians, snakes, invertebrates) as well as grasses and grains in wet meadows,

flooded grain fields, pastures, shallow water habitats, and wetlands. Pairs return to the

same territory and even the same approximate nest location every year (California Fish

and Game, 2003). Based on the survey data recorded since 1981, areas of suitable

wetland and meadow habitat in Shasta and Siskiyou Counties support breeding

individuals; however, individuals in the project area are on the edge of their range

(CWHR, 2010).

Mammals

American Marten—American marten is a Forest Service species of concern.

Natural heritage records exist for American marten in Shasta and Siskiyou Counties, and

the Lower Pit and McCloud watersheds (NatureServe, 2009). Martens are medium-sized

carnivores that inhabit dense, coniferous, mixed, or deciduous forests and occupy holes in

tree stumps. Loss or degradation of habitat due to timber harvesting is the primary threat

to this species. The project area is within the known range of American marten (CWHR,

2010); surveys were not conducted in the project area for this species.

Sierra Nevada Red Fox—The Sierra Nevada red fox is a state-listed threatened

species. The range of the Sierra Nevada red fox is described as the southern Cascade

Range in northern California, southeastward to the northern Sierra Nevada, and then
180

south along the Sierra Nevada crest to Tulare County. Preferred habitat for the Sierra

Nevada red fox appears to be red fir and lodgepole pine forests in the sub-alpine, and in

the alpine of the Sierra Nevada. The current status of the Sierra Nevada red fox is

unknown, and threats to the species have not been identified. This species is assumed to

be present in the project area though it was not detected during prelicensing surveys

(PG&E, 2006).

California Wolverine—The California wolverine is a California listed threatened

species and is also considered a California fully protected species. This species requires

dense cover for resting and reproduction, and open areas for hunting. The home range

size of the California wolverine is extremely variable (less than 39 square miles to over

347 square miles) and appears to depend on the abundance and distribution of food.

Dens are found in trees, dead standing trees (snags), downed logs, abandoned beaver

lodges, among boulders, rock ledges, in old bear dens, and in caves. Riparian areas are

used as travel corridors. The environmental assessment for the Pit 1 license lists

wolverines as present in the Pit 1 project area, which is located about 50 miles from the

McCloud-Pit project (table 11, PG&E, 1999). The project area is within the known range

of the California wolverine (CWHR, 2010), but no survey was conducted for this species.

Though it was undetected during prelicensing surveys, the California wolverine is

assumed to be present in the project area (PG&E, 2006).

Ringtail—The ringtail is an omnivorous, raccoon-like mammal and a California

fully protected species found in desert scrub, chaparral, pine-oak or conifer woodland

habitats with rocky areas and fallen log debris (NatureServe, 2009). It is known to occur

near the project area in the Central Valley. PG&E reported ringtail in the Pit 1

environmental assessment for a new license; the Pit 1 project is located about 50 miles

from the McCloud-Pit project (PG&E, 1999). No surveys were conducted in the project

area for this species.

Special Status Bats— Four special status bat species—pallid bat, Townsend’s bigeared bat, spotted bat, and western red bat—were detected during acoustic and capture

surveys in the study area which included existing project structures, reservoirs, and

project-affected stream reaches.

Pallid Bats. A California mammal species of special concern and Forest Service

sensitive species, the pallid bat roosts in structures, cavities, and live or dead trees

anywhere from the riparian zone to ridges above, or in rock features on slopes of river

drainages. A pallid bat colony can range from 35 to 300 individuals. The pallid bat has

one litter per year and often gives birth to twins. This species forages primarily on

ground-dwelling arthropods, most frequently in riparian zones, open oak savannah, and

open mixed deciduous forest habitats, and uses pools in rivers and streams as a source of

water.

Individuals were captured at the Pit 6 and 7 dams and along the existing Pit 7

transmission line corridor. The capture of a juvenile at Pit 7 dam confirmed the presence

of a reproductive population and acoustic records document the presence of this species
181

throughout the proposed McCloud and Pit 7 afterbay infrastructure sites during the

summer breeding season (July through September). This species is not known to be

migratory, and likely hibernates in the area, as suggested by one acoustic detection record

from February, 2009, at the McCloud dam spillway.

Townsend’s Big-Eared Bat. Townsend’s big-eared bat is also a California

mammal species of special concern and a Forest Service sensitive species and is widely

distributed in the lava bed and limestone areas of Shasta, Siskiyou, and Modoc Counties

where it roosts in tunnels, caves, mines, or rock shelters that are close to water.

Townsend’s big-eared bat forages in riparian zones as well as creek and river drainages

feeding primarily on moths, and, like the pallid bat, uses pools in rivers and streams to

drink. Colony size ranges from 35 to 500 individuals and adult females give birth to a

single young per year. Acoustic records document the presence of Townsend’s big-eared

bat only in association with the exposed limestone along the margin of McCloud

reservoir where one adult female (non-reproductive) was captured.

Spotted Bat. The spotted bat is a mammal species of special concern in California

and, although rare and patchily distributed, is known to occur in the project vicinity. The

spotted bat forages over open areas and along forest areas, particularly in association with

wet meadows, and uses creeks and rivers as a source of water. This species roosts in rock

features, often on steep slopes or rock outcrops associated with river drainages. The

spotted bat is thought to be non-colonial, and females give birth to a single young each

year.

Documented in the Pit 4 development area in 2000, individuals were detected

acoustically in spring and late summer in a clearing adjacent to an inactive sewage lagoon

near the town of McCloud, within the proposed construction footprint for the McCloud

transmission line.

Western Red Bat. The western red bat is a California mammal species of special

concern and a Forest Service sensitive species that is known to occur in the project

vicinity, and likely uses the Pit and McCloud Rivers as migration corridors. This species

roosts in riparian vegetation and uses riparian edge habitats as well as a variety of

terrestrial and aquatic habitats for foraging. The western red bat is non-colonial, and

females give birth to one litter of twins per year. Individuals were detected at proposed

McCloud infrastructure sites, Pit 7 afterbay sites including the afterbay powerhouse

construction site, and both proposed transmission corridors. During the survey effort,

most acoustic records were between late July and early October, at a time when this

species begins to move south in fall migration. Individuals were detected year-round at

the proposed Pit 7 afterbay and existing Pit 7 transmission line sampling sites indicating

that the Pit River may be a fall migration corridor for the western red bat, and that not all

individuals migrate. No western red bat activity was recorded during the winter at

proposed McCloud infrastructure sites.

Western Mastiff Bat—The western mastiff bat is found in rock features, often

steep slopes or rock outcrops associated with river drainages, under slabs of exfoliating
182

granite, or in basaltic columns. Colony size ranges from 35 to 200 individuals. Females

give birth to a single young each year. This species is an open-air forager, and has been

detected flying/foraging over reservoirs elsewhere in their range. Individuals were

detected acoustically at the Pit 6 dam in September, 2007, the first record of this species

for the Pit River.

3.3.3.2 Environmental Effects

3.3.3.2.1 Vegetation

Upland Vegetation

The vegetation community within the project area is relatively stable and is subject

to disturbances from non-project related influences (rock slides, fire, disease, insect

infestation). Periodic maintenance work along existing transmission lines, roads, tunnels,

gages, powerhouses, associated facilities and reservoirs would cause short-term, minor

localize disturbance or removal of vegetation. Mechanical activities such as

snowplowing, road grading, ditch cleaning, and slide removal could cause surface to

shallow depth disturbance of vegetation and top soil layers; however, no adverse effects

to the existing seed bank within the soil would be expected. Over time, vegetation would

be expected to reestablish as a result of pioneering of plant species in adjacent areas (with

measures to control invasive species, erosion, and sedimentation), growth of plants from

the existing seed bank, and restoration of native vegetation by PG&E. PG&E states in its

license application that herbicide use is a part of road and facility maintenance, but no

pesticides are used as a part of project O&M. However, the spraying of herbicides as part

of future O&M activities to control undesirable vegetation such as non-native invasive or

noxious weed species (section 3.3.3.1.1, Vegetation, Noxious Weeds) could cause

localized loss of upland vegetation susceptible to the herbicide(s) being used.

Proposed construction of the two new powerhouses and the Pit 7 afterbay

substation are associated with primarily developed areas surrounding the existing project

dam structures. There would be temporary minor disturbance to upland vegetation

during construction of the facilities and a permanent loss of vegetation within the

footprint of the construction area.

The proposed Pit 7 afterbay transmission line would potentially remove vegetation

along a corridor about 1.6 miles long and 150 feet wide. Disturbance or removal of

vegetation along the construction corridor would be short-term. Upon completion of the

transmission line, a 40-foot-wide corridor would undergo periodic maintenance to protect

the transmission line from vegetation encroachment and allow access for maintenance

and repairs. The McCloud transmission line is proposed as a corridor of about 14 miles

in length and during construction would be about 150 feet wide; the final width of the

transmission line is expected to be 25 feet. Construction of the proposed McCloud

transmission line would require significant tree and vegetation clearing to establish the

150 foot-wide construction corridor. Tree removal would result in a long-term alteration

of vegetation community structure. Post-construction, it is expected that the area would
183

gradually return to natural vegetation through pioneering from adjacent species (with

measures to control invasive species), revegetation from the existing seed bank, natural

succession, and restoration of native vegetation by PG&E.

PG&E proposed protection and enhancement measures designed to minimize the

environmental effects of project operations and proposed construction on vegetation

within the project area. In measure 13, PG&E proposed to develop a Vegetation

Management Plan in consultation with the Forest Service and other appropriate agencies.

The Vegetation Management Plan would guide the management of vegetation within the

project and project-affected area including transmission line and would address

vegetation-related issues at the project for the term of the new license. The Vegetation

Management Plan would contain specific elements including: (1) identification,

protection and monitoring of special status species potentially affected by project-related

activities to maintain well-distributed, viable populations within the project-affected area;

(2) protection of culturally significant plant populations potentially affected by projectrelated activities and to enhance populations when feasible opportunities exist;

(3) invasive plant species management and monitoring to minimize the introduction and

spread of noxious weeds and to assess the success of noxious weed management

activities associated with project O&M activities; (4) use of BMPs to avoid or minimize

effects on wetlands; and (5) restoration of native vegetation in relevant areas disturbed by

project-related O&M activities within the project-affected area. In addition, employees

would receive employee awareness training that would provide employees working

within the project area with the knowledge base to ensure effects from disturbance and

direct removal of vegetation are minimized and that revegetation activities are monitored.

Employee awareness training would ensure the coordination of the implementation of the

Vegetation Management Plan with other management plans. The Vegetation

Management Plan would include a process and schedule for reporting survey and

monitoring results and provide for periodic review and revision of the Vegetation

Management Plan.

In its original condition 25, the Forest Service specified that PG&E file a

Vegetation and Invasive Weed Management Plan developed in consultation with the

Forest Service, appropriate County Agricultural Commissioner, California Department of

Food and Agriculture, potentially affected tribes and other interest parties. The plan

would be approved by the Forest Service and would be developed within 1 year of

license issuance. Components of the plan included: treatment protocols and measures

for removing or trimming vegetation within the project and project-affected area;

protection of special status and culturally significant plants and populations; invasive

species management and monitoring; and pesticide or herbicide use restrictions and

prohibitions. Each component would provide specific guidance elements.

Treatment protocols and measures for removing or trimming vegetation included:

(1) hazard tree removal and trimming and power line / transmission line clearing that

would include slash disposal for both management protocols; (2) vegetation management

for habitat improvement; (3) revegetation of disturbed sites, including standards of
184

success, monitoring schedule, and remediation measures; (4) soil protection and erosion

control including use of certified weed-free straw and other methods that minimize the

risk of introducing non-native invasive plant species; (5) establishment of and / or

revegetation with culturally important plant species; and (6) use of clean, weed-free seed

with guidance on the use of locally collected native seed, and a plan to collect and

propagate or otherwise acquire an adequate supply of appropriate native plant material

for use in erosion control.

In its original condition 25, the Forest Service specified that the plan include the

development of a monitoring component for special status and culturally significant

plants approved by the Forest Service. Current locations (including boundaries) for

populations of special status and culturally significant plant species would be identified

and delineated by GPS. Periodic monitoring of the known locations would occur every 5

years and every 10 years for the project and project-affected area to determine if

additional special status or culturally significant species have become established in the

project or project-affected area to provide measures for addressing populations of newly

established species. Surveys would also be conducted for new, listed special status

species potentially occurring within the project or project-affected area; if identified

species would be monitored. Information on locations, protection, monitoring, and

survey measures for sensitive, culturally significant, invasive species and other rare plant

locations would be shared with managers of O&M activities of any power distribution

lines that cross portions of the project area.

In its original condition 25, the Forest Service specified that the special status

species survey element be initiated by consultation with the Forest Service, concurrent

with the annual consultation meeting as specified in Forest Service condition 1, to review

the most current list of special status plant species that might occur on Forest Service

lands in the project area or the project-affected area. When species are added to any of

the lists, consultation would determine if suitable habitat occurs on Forest Service lands

and, within 1 year, PG&E would develop and implement a study plan in consultation

with the Forest Service to reasonably assess the effects of the project on the species.

PG&E would prepare a draft report that provides the objectives, methods, results, and

recommended resource measures as appropriate, schedule for implementation, to the

Forest Service for review and approval; the final report would be filed with the

Commission and would include documentation of consultation.

PG&E alternative condition 25 proposed modifications to specific elements of the

Forest Service’s original condition 25, including an alternate schedule for preparation.

PG&E stated that adequate protection and utilization of Forest Service lands would be

contained within PG&E alternative condition 25 because PG&E would protect, mitigate

and/or enhance populations of sensitive plant species potentially affected by project

operations by conducting management and monitoring.

PG&E alternative condition 25 proposed that the preparation of the Vegetation

and Invasive Weed Management Plan be made consistent with the original measure 13
185

schedule of “2 years after license issuance” instead of the 1 year that was specified in the

Forest Service’s original condition 25. PG&E argued that providing 2 years instead of

1 year to prepare the plan would allow more careful planning and adequate schedule

coordination among the various agencies and other interested parties involved in drafting

a plan. During relicensing meetings, Forest Service staff stated that it desired consistency

between McCloud-Pit license conditions and those developed for a nearby PG&E-owned

project, Pit 3, 4, and 5. PG&E noted that 2 years would provide adequate time to achieve

consistency with license conditions for McCloud-Pit and Pit 3, 4, and 5. To support its

proposal of a 2-year time frame for preparing and implementing a Vegetation and

Invasive Weed Management Plan, PG&E presented a timeline of about 9-16 months

which would make the 1-year schedule proposed by Forest Service infeasible. PG&E

also pointed out that there was nothing to preclude completion prior to the 2-year

schedule proposed.

PG&E further proposed to limit the scope of the Forest Service’s original

condition 25 to only culturally significant plant species associated with TCPs. Areas

identified during relicensing surveys, that support populations of these plant species, are

not considered to be TCPs subject to the requirements of section 106 of the NHPA unless

they were also specifically identified by Tribal members. As a result, PG&E noted that

there is no regulatory requirement to include culturally significant plant species in any

long-term monitoring component for special status plant species as specified for inclusion

in a Vegetation and Invasive Weed Management Plan by the Forest Service’s original

condition 25.

The Hearst Corporation notes that Hearst lands surround the entire McCloud

reservoir and expresses concern that the Forest Service’s original condition 25 would

require PG&E to conduct surveys on private land. The Hearst Corporation suggests

monitoring and management plans and surveys be limited to project-affected PG&E and

national forest lands. In addition, The Hearst Corporation suggests that annual meetings

also be opened to “project-affected” private landowners.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 25. The provisions specified in Forest Service modified condition 25 are

similar to those specified in the Forest Service’s original condition 25, except that the

Forest Service has removed specific details of the plan components and monitoring

schedules from the 4(e) condition and placed them in the draft Vegetation and Invasive

Weed Management Plan, included as an enclosure to the filing (Forest Service, 2010d,

Enclosure 3). In the draft plan, the Forest Service recommends approaches for the

revegetation of disturbed sites, including detailed standards of success, a monitoring

schedule, and remediation measures. Additionally, in the draft plan, the Forest Service

recommends the implementation of botanical management actions to improve wildlife

habitat. In particular, the Forest Service recommends enhancement of special status

species wildlife habitat, including the protection of willow and alder habitat for the

willow flycatcher and riparian habitat for neotropical breeding birds (see the Riparian

and Wetland Vegetation section, below), as well as nesting habitat for bald eagles and
186

northern spotted owls, and maternity sites for special status bats (section 3.3.3.2.2,

Wildlife). In its November 24, 2010, filing, PG&E accepts Forest Service modified

condition 25 and withdraws its alternative condition 25.

Our Analysis

Normal O&M activities currently have negligible effects on established vegetation

within the project area. Proposed new construction within the project would have a longterm minor to moderate adverse effect on upland vegetation within the project area.

Clearing for the construction of the Pit 7 access road and construction staging area would

result in minor, long-term effects to vegetation. Clearing along transmission corridors

would result in the loss of linear portions of existing vegetation communities; however,

we expect that over the long-term the width of cleared area needed for construction

would be revegetated and most vegetation would re-establish. Development and

implementation of a Vegetation and Invasive Weed Management Plan would provide

guidance for the restoration of vegetation using native plant species as well as monitoring

to maximize the success of vegetation restoration efforts. Permanent loss of vegetation

communities along the proposed transmission line corridors would occur. Vegetation

within the permanent corridor would re-establish; however, the vegetation within the

corridor would be managed and maintained as necessary and would be permanently

altered from the original plant communities that existed prior to the construction of the

new transmission lines.

In measure 13, PG&E addressed vegetation-related issues at the project for the

term of the new license that contained generalized plan elements for management,

protection, restoration and control of vegetation within the project boundary, a timeframe

for development and implementation, and a proposed schedule for completion of specific

monitoring and control elements.

In its original condition 25, the Forest Service specified that PG&E file a

Vegetation and Invasive Weed Management Plan also developed in consultation with the

Forest Service and specifically added the County Agricultural Commissioner, California

Department of Food and Agriculture, potentially affected tribes and other interest parties.

The plan specified by the Forest Service’s original condition 25 would be developed

within 1 year of license issuance.

PG&E alternative condition 25 proposed a 2-year schedule for a Vegetation and

Invasive Weed Management Plan to allow consistency with Pit 3, 4, and 5 license

conditions. Regarding culturally significant plant species in particular, PG&E alternative

condition 25 proposed limitations to the scope of the Forest Service’s original

condition 25 so that it would apply to only culturally significant plant species associated

with TCPs.

Forest Service modified condition 25 specifies a 1-year schedule for completion of

this plan. Because a draft of the plan has been collaboratively developed by the Forest

Service and PG&E, a 1-year time frame would provide adequate time for the
187

development of the plan to address the treatment of vegetation communities of the

watershed in a consistent and comprehensive manner to ensure the maintenance of viable

plant communities. Implementation of standards of success, a monitoring schedule,

remediation measures for the revegetation of disturbed sites, and protection and

enhancement of special status species wildlife habitat, as recommended by the Forest

Service in the draft plan, would provide structure for the mitigation of effects to larger

disturbed areas, including prevention of soil erosion, control of invasive weed species,

support for the re-establishment of native vegetation, and protection of special status

wildlife species.

Regarding access to private lands, it is up to PG&E to obtain whatever rights are

necessary to carry out its license obligations. PG&E would need to coordinate with

landowners if access is needed to lands outside of project boundary, as proposed in the

PG&E alternative 4(e) conditions. However, if private land is located within project

boundary, PG&E would need to consult with the private landowner to gain access to that

land to carry out the purposes of its license. If PG&E is not able to obtain the property

rights necessary to operate or carry out the terms of the license by negotiation with the

private landowner, it may use the power of eminent domain to acquire those rights.

Riparian and Wetland Vegetation

Inundation frequency and annual peak flows influence the distribution of riparian

vegetation with inundation frequency having the greatest effect on lateral extent.

Relatively infrequent annual peak flows of high magnitude (once per 20 years) that can

mobilize cobble and gravel bars resulting in scouring riparian vegetation appear to occur

at a similar frequency as in pre-project conditions; the most recent occurring in 1997.

Annual peak flows of lesser magnitude that occur more frequently (< 10 years) have

decreased since project operations began. The decrease in magnitude of annual peak

flows and a decrease in duration of inundation from flooding during the growing season

as a result of project operations is increasing riparian vegetation along the lower reaches

of the river. The decreased magnitude of annual peak flows is also affecting the age

distribution of white alders at higher and lower elevations; mature specimens are not

being replaced by younger white alder as a result of decreased flooding flows at higher

and lower elevations that allow establishment of young trees.

Riparian vegetation encroaching on the channel could potentially affect the quality

and coverage of terrestrial riparian and aquatic habitat along the Lower McCloud River,

though the linear extent is not affected and appears to continue at the same level under

project operations as it existed under pre-project conditions.

PG&E proposed minimum instream flow regimes (section 3.3.2.1.1, Water

Quantity) that would provide additional flow volumes over an annual and seasonally

distributed schedule. In addition, upward ramping of flows prior to uncontrolled spill

events would return scouring flows to the stream channel, which would reduce the ability

of riparian vegetation to become established along the channel. California Fish and

Game recommends and the Forest Service’s original condition 19 specified a minimum
188

instream flow regime for the Lower McCloud River in order to provide benefits for

fisheries.

A total of 820.65 acres of wetland and riparian habitats were mapped within the

proposed McCloud transmission line corridor and could be affected by construction

activities. To protect wetland habitat, PG&E proposed to follow BMPs to avoid or

minimize effects on wetland areas, including pre-construction wetland mapping and

associated protection measures.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 25. The provisions specified in Forest Service modified condition 25 are

similar to those specified in the Forest Service’s original condition 25, except that the

Forest Service has removed specific details of the plan components and monitoring

schedules from the 4(e) condition and placed them in the draft Vegetation and Invasive

Weed Management Plan, included as an enclosure to the filing (Forest Service, 2010d,

Enclosure 3). Additionally, Forest Service modified condition 25 specifies that the plan

should include botanical enhancements for specific special status wildlife species.

In the draft plan, the Forest Service has changed its recommendation to agree with

the staff recommendation from the draft EIS regarding the implementation of applicable

BMPs if O&M is required around riparian areas. Additionally, in the draft plan, the

Forest Service recommends the implementation of botanical management actions to

enhance special status species wildlife habitat, including the protection of willow and

alder habitat for the willow flycatcher and riparian habitat for neotropical breeding birds

(section 3.3.3.2.2, Wildlife).

Our Analysis

Natural riparian systems are well-adapted to the periodic inundation and scouring

that flood events can produce. Under the proposed action, increased minimum flows

would increase inundation periods during the growing season, restricting growth and

encroachment of riparian vegetation and improving the channel width. The proposed

action would not alter low frequency, high magnitude scouring floods. As a result,

encroachment of riparian vegetation into the channel would be minimized and aquatic

and terrestrial riparian habitat would be improved. Flows would be sufficient to control

lateral expansion of riparian vegetation without necessitating manual removal that could

destabilize sediments and increase erosion.

Pre-construction wetland mapping prior to the initiation of any construction, and

avoidance of existing wetlands to the extent practicable, would minimize effects from

construction. Any required state and federal permits would be required prior to

construction and any regulatory restrictions, and required BMPs or other conditions

would be implemented. Regardless, some adverse effects to wetlands are likely during

the construction of the McCloud transmission line. We expect that employment of preconstruction mapping and avoidance in concert with BMPs and permit requirements

would minimize effects, and effects would be short-term since no permanent disturbance
189

to the hydrology of the wetland systems is expected to occur as a result of construction.

After completion of construction, wetland systems within the width of the construction

corridor would return to pre-construction conditions over time as vegetation becomes reestablished. Within the permanent corridor of the transmission line, wetland and riparian

vegetation could be permanently altered as a result of continued vegetation maintenance

and management. We expect that the development and implementation of the Vegetation

and Invasive Weed Management Plan would also minimize effects on wetlands; elements

of the plan would provide restoration guidance, pesticide and herbicide restrictions and

prohibitions, integrate employee training and awareness including use of BMPs, and

protect and enhance special status species wildlife habitat.

Noxious Weeds

Activities associated with project O&M, recreation, and construction can cause

disturbances to existing vegetation which could spread or facilitate introduction of

noxious weeds in the project area or beyond. Project O&M activities with the potential to

affect the distribution of noxious weeds include slide removal; road grading; vegetation

management activities along transmission lines, roads, tunnels, gages, project facilities,

and reservoirs; and ditch clearing. Reservoir fluctuations create disturbances in littoral

habitats that make them susceptible to colonization by noxious weeds. In addition,

recreation activities that move from outside of the project to recreation sites within the

project area can result in noxious weeds and invasive species being introduced into the

project area via recreational equipment and vehicles. Newly cleared soil from

construction areas can be colonized by seeds from surrounding vegetation or seeds

brought into the area by a variety of methods. In addition, seeds and portions of plants

that can facilitate propagation and establishment could be dispersed by earthmoving

equipment. Vehicles used to access construction sites have the potential to facilitate the

spread of noxious weed species into and out of the construction sites. Construction of

transmission corridors, especially the construction of the McCloud transmission line with

a linear distance of about 14 miles, have the potential to affect sensitive riparian and

wetland vegetation communities in the corridor with the spread of invasive noxious

weeds.

Black locust prefers shoreline areas where hydrologic conditions reduce the

frequency of inundation. No historical information exists to provide insight into the level

of abundance of black locust in the Lower McCloud River prior to project operations.

Because the decreased flows and less frequent inundation as a result of project operations

has likely allowed riparian vegetation to encroach into the Lower McCloud River

channel, it is possible that hydrological conditions resulting from project operations have

also resulted in conditions that provide opportunity for black locust to increase. A

literature review led to the conclusion that black locust seed dispersal is unlikely to be

affected by the project, but that germination of seeds could be more successful due to the

project-related decrease in inundation frequency. For example, there is a potential project

nexus between decreases in base flow and annual peak flow and increased black locust
190

habitat, particularly in areas with high percent cover of coarse material downstream of

Ah-Di-Na.

Specific to invasive plant species monitoring and control, the original PG&E

measure 13 proposed invasive plant species monitoring and management as part of the

Vegetation Management Plan development to minimize the introduction and spread of

noxious weeds and to assess the success of noxious weed management activities

associated with project O&M activities.

In its original condition 25, the Forest Service specified that the Vegetation and

Invasive Weed Management Plan would contain several components targeting invasive

species management and monitoring and would include elements to: (1) monitor area

with ground disturbing activities associated with the license annually for 3 years after the

completion of activities to assess the presence of any invasive weed populations that may

have been introduced as a result of activities; and (2) monitor known invasive plant

species populations annually for the first 3 years after license issuance to determine if

noxious weed populations are expanding into any locations of existing special status or

culturally significant plant populations; or if other adverse impacts are occurring to these

plant populations. After annual surveys for the first 3 years, monitoring would occur

once every 5 years for the term of the license. All monitoring would occur in the

appropriate season when plants are conspicuous but can be coordinated with other

concurrent surveys or tasks. In addition, inventory and mapping of new populations of

noxious weeds would be employed to update the GIS database maintained by the Forest

Service every 5 years and protocols and strategies to prevent and control the spread of

known populations or introductions of new populations would be developed. Spot

treatments would be allowed for detections of new, small infestations at the time of

detection. The protocols and strategies to prevent and control the spread of known

populations would address the following elements: (1) cleaning of construction

equipment prior to entering and exiting the project area (but would not apply to vehicles

used for PG&E’s regular O&M activities); and (2) the use of weed-free straw, sand and

gravel for restoration and construction and restoration activities, rice straw may be

substituted. The invasive species management and monitoring component would include

additional elements including: development of a schedule for control (containment or

eradication) of populations of prioritized invasive weed species designated by resource

agencies; annual monitoring of known populations for the term of the license in locations

tied to project actions or effects, such as road maintenance, facilities, project O&M

activity areas; construction sites to evaluate the effectiveness of revegetation and invasive

weed control measures; employee awareness training on the location and identification of

invasive weed species that may occur in the area and proper mechanisms for avoiding

transport of weed seeds while working and notification of the Forest Service when new

populations of invasive weed species are identified; and an adaptive management element

to implement methods for the prevention of aquatic invasive weeds; and reasonable

efforts to control the entire population unit for prioritized species that are contiguous and
191

extend beyond the project boundary. Consultation and coordination with the Forest

Service would determine control measures.

With respect to which invasive weed species would be monitored and controlled,

the Forest Service’s original condition 25 specified the development of a schedule for

control (containment or eradication) of all known populations of California Department

of Food and Agriculture rated A, B, and Q species; California Invasive Plant Council

“high” and “moderate” rated species; and selected other rated invasive species designated

by resource agencies.

PG&E alternative condition 25 proposed a change to focus control on agreedupon “high-priority” species that are deemed of significant concern to the project and

considered to be controllable by current management methods. PG&E also proposed a

change to the Forest Service’s original condition 25 language that stated that new

infestations of “A,” “B,” or “high” and “moderate” agency rated species should be

controlled within 1 year of detection, or as soon as practicable and feasible, to focus on

the agreed upon “high priority” species considered to be controllable by currently

available treatment methods. PG&E alternative condition 25 proposed a list of “high

priority” invasive plant species that was consistent with the Forest Service’s original

condition 25 list of “invasive species known to occur in the project and project-affected

area.” Additionally, PG&E alternative condition 25 proposed monitoring of known

populations of invasive weeds within the first year after approval of the Vegetation and

Invasive Weed Management Plan and every 5 years thereafter, as opposed to monitoring

annually for 3 years after license issuance and every 5 years thereafter, as specified in the

Forest Service’s original condition 25. PG&E alternative condition 25 also proposed

monitoring new populations of invasive weeds within the first year after plan approval

and every 5 years thereafter, as opposed to monitoring every 5 years as specified in the

Forest Service’s original condition 25.

Forest Service condition 15 specifies that PG&E exclude the use of pesticides and

herbicides on NFS lands unless prior written approval is received from the Forest

Service. Materials used would be limited to those registered by EPA and consistent with

those used by Shasta-Trinity National Forest.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 25. The provisions specified in Forest Service modified condition 25 are

similar to those specified in the Forest Service’s original condition 25, except that the

Forest Service has removed specific details of the plan components and monitoring

schedules from the 4(e) condition and placed them in the draft Vegetation and Invasive

Weed Management Plan, included as an enclosure to the filing (Forest Service, 2010d,

Enclosure 3). Additionally, Forest Service modified condition 25 specifies protection of

revegetation source populations rather than culturally significant plant populations.

In the draft plan, the Forest Service recommends that a comprehensive survey of

selected high priority and additional noxious weeds be conducted within the first year of

license acceptance and every 5 years thereafter. Additionally, the Forest Service
192

recommends that monitoring following ground-disturbing activities would be a focused

follow-up, and that invasive plant control sites would be monitored after revegetation and

disturbance for 3 years following the final revegetation or control work in order to

evaluate the effectiveness of revegetation and invasive weed control measures and

determine if revegetation meets objectives.

Regarding pesticide and herbicide use, the Forest Service notes in the draft plan

that pesticide applications are not considered a default treatment method and

recommends that other reasonable and practicable methods for vegetation treatment be

evaluated, based on analysis of potential environmental impacts and anticipated

effectiveness, along with site characteristics, security, safety and health, and economics.

The Forest Service further recommends that site-specific measures be identified and

implemented to protect non-target plants and animals. In its November 24, 2010, filing,

PG&E accepts Forest Service modified condition 25 and withdraws its alternative

condition 25.

Our Analysis

The components for invasive species management proposed in PG&E measure 13

and PG&E alternative condition 25, and specified in the Forest Service’s original

condition 25, all provided guidance, methods, and protocols for treatment and

management, monitoring, and other elements that are similar in structure and intent: the

avoidance and control of noxious weed species within the project and project-affected

area. In combination with employee awareness training and the use of BMPs prior to

routine project O&M or construction activities with the potential to increase the

introduction or dispersion of invasive noxious weeds, PG&E would monitor the

distribution and species composition of noxious weeds within the project and projectaffected area and prioritize populations for feasible management or control measures.

We expect annual monitoring for 3 years of areas that undergo ground or

vegetation disturbance including management treatments would be effective in discerning

the establishment of noxious weeds that are generally aggressive in pioneering new areas.

As proposed in PG&E alternative condition 25, monitoring, inventory, and mapping of

all areas of “high priority” noxious weed populations that remain undisturbed could be

conducted at 5-year increments consistent with monitoring special status and culturally

important plant populations and the 5-year interval inventory and mapping element.

Implementation of this monitoring schedule would provide coordination and efficiency of

monitoring schedules and multiple-element monitoring could be conducted concurrently.

In the draft Vegetation and Invasive Weed Management Plan, the Forest Service

recommends details of components and monitoring schedules for inclusion in and

protection of revegetation source populations, which include culturally significant plant

populations not associated with TCPs. Specifically, the Forest Service recommends

monitoring of selected known populations of invasive weeds annually rather than

monitoring of all known populations annually for 3 years after license issuance. This

recommendation in the draft plan would provide for more focused, long-term monitoring
193

effort on invasive weed populations of particular concern, and all populations of noxious

weeds would still be monitored on a 5-year cycle, which would be sufficient to identify

additional populations that may need focused monitoring and control

We expect that monitoring of known populations of noxious weeds associated

with project actions and effects in conjunction with a comprehensive survey of invasive

weeds within the first year of license issuance and every 5 years thereafter, as

recommended by the Forest Service in the draft plan, would provide for comprehensive

noxious weed management. The survey and monitoring schedule recommended by the

Forest Service in the draft plan is consistent with the timeframe specified in the Forest

Service’s original condition 25, except that a baseline survey within the first year of

license issuance would establish the status of current invasive weed populations and

would place all vegetation surveys on the same schedule. Annual monitoring of known

“high priority” noxious weed populations in areas tied to project actions or effects would

create situational awareness of weed encroachment into locations of existing special

status or culturally significant plant populations, determine if other adverse impacts are

occurring to these plant populations, and facilitate prompt scheduling of treatment as

necessary. The comprehensive survey of selected “high priority” and additional invasive

weeds would also facilitate updates to original survey work in the Commission-approved

project area of potential effects (APE) (see section 3.3.6, Cultural Resources, for a

description of the APE). Herbicides should not be the automatic first choice for weed

control, because of the potential health and environmental risks associated with their use,

especially near surface water. However, many herbicides have a lower risk of unintended

adverse effects than other kinds of controls, and the risks of any control method must be

weighed against the adverse effects of the weed in infestation itself (Tu et al., 2001).

Any integrated weed management plan should emphasize nonherbicide techniques, and

allow for herbicide use, if any, only at specific sites.

Special Status and Special Interest Plant, Fungi and Lichen Species

Project operations have the potential to affect documented special status plant

species that occur within the project area. Special status plant species were identified

along the proposed McCloud and Pit 7 afterbay transmission line corridors, along the

proposed access road to Pit 7 afterbay powerhouse, and at the proposed Pit 7 afterbay

powerhouse. Populations of English Peak greenbriar, northern clarkia, slender false

lupine, long-fruit jewel-flower, and Butte County morning glory could be susceptible to

project construction and maintenance activities along project roads. In addition, project

operations that alter flow in the Lower McCloud River could affect a population of

Shasta eupatorium that occurs within the high water mark of the Lower McCloud River if

flow regime alterations increase flows. Water level changes as a result of project

operations could affect the sole population of Shasta eupatorium within the project area.

Based on a list of culturally significant plant species developed in consultation

with the Tribes, a total of 32 species of culturally significant species were located during
194

surveys. Survey results for culturally significant plant species results were presented

directly to the Tribes as a confidential report.

The Tribes have stated that they are concerned about the effects of herbicide

applications to culturally significant plant species that grow near McCloud dam and

tunnels and are traditionally used by the Tribes. The Tribes are also concerned about the

effects of construction of the proposed McCloud transmission line on culturally important

plants and habitats; chokecherry, hazel, bear grass, and medicinal plants are gathered in

the area between McCloud reservoir and the town of McCloud.

In its original condition 25, the Forest Service specified the development and

implementation of a Vegetation and Invasive Weed Management Plan, which would

include provisions for identification, protection, and monitoring of populations of special

status plant species (including culturally significant plant species). Specifically, the

Forest Service would request that PG&E develop, in consultation with the Forest Service

and approved by the Forest Service, a special status plant species component that

includes elements to protect and maintain well-distributed, viable populations of special

status and culturally significant plant species within the project and project-affected area.

The Forest Service specified that the component for special status plant species

(including culturally significant plant species) of the Vegetation and Invasive Weed

Management Plan would require the delineation of current locations of special status and

culturally significant plants using a global positioning system. This would ensure that

information on locations of special status and culturally significant plant species is shared

with other managers of transmission lines that cross the project area. The component

would also provide for periodic monitoring once every 5 years to assess expansion or

contraction of existing special status species populations; final populations would be

selected from those located in Study CR-S2 for the Pit River Tribe but not identified in

association with TCPs, and a similar protocol would be suggested for the Winnemem

Wintu Tribe if it requests that culturally important plant species be included in

revegetation efforts. In addition, the component would include surveys once every

10 years to determine the presence of any new populations of special status species,

including culturally significant plant species or newly listed special status species.

Alternatively, sites requiring protection could be displayed on an operations map as areas

to avoid in order to prevent effects during management activities. Annual consultation

and review of the most current Forest Service list of special status species would

determine if any newly listed species or un-surveyed suitable habitat could potentially

occur within the project area; additional monitoring would be initiated to detect the

presence of the newly listed species within the project area. Should a species be located,

a monitoring plan for the species would be developed in consultation with the Forest

Service within 1 year to assess the potential for project-related effects to the species.

In its original condition 25, the Forest Service specified that, in addition to the

development of the Vegetation and Invasive Weed Management Plan, PG&E would

prepare, for Forest Service approval, a biological evaluation of the potential effects to

special status species of any proposed action to construct project features on Forest
195

Service lands. The evaluation would include procedures to minimize any adverse effects,

meet any management plan restrictions, and monitor implementation and effectiveness of

any measures taken as part the construction.

PG&E alternative condition 25 included a component for special status and

culturally significant plant species proposing that monitoring would begin the first year

after the Vegetation and Invasive Weed Management Plan is approved by the

Commission and every 5 years thereafter for periodic monitoring; and surveys for

periodic assessment and inventory as well as those implemented for newly added species

would occur the first year after the Vegetation and Invasive Weed Management Plan is

approved by the Commission and every 10 years thereafter. In addition, specific to

culturally significant plant species, PG&E proposed to limit the scope of the Forest

Service’s original condition 25 by removing specific measures for culturally significant

plant species from the Vegetation and Invasive Weed Management Plan and including

only culturally significant plant populations associated with TCPs. Instead, PG&E

alternative condition 25 proposed that PG&E would share with managers information on

the locations of culturally significant plant populations so that these populations could be

considered prior to and during O&M activities and would be undertaken in consultation

with the Forest Service. In addition, PG&E would comply with the requirements of the

HPMP and section 106 of the NHPA with regard to areas identified in the re-licensing

study for cultural resources that are currently utilized by Tribes to gather plants for

traditional purposes and that qualify for inclusion in the National Register as historic

properties. Finally, culturally significant plant species would be used during revegetation

activities where feasible.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 25. The provisions specified in Forest Service modified condition 25 are

similar to those specified in the Forest Service’s original condition 25, except that the

Forest Service has removed specific details of the plan components and monitoring

schedules from the 4(e) condition and placed them in the draft Vegetation and Invasive

Weed Management Plan, included as an enclosure to the filing (Forest Service, 2010d,

Enclosure 3).

In the draft plan, the Forest Service recommends that a baseline comprehensive

survey of special status, revegetation source, and essential habitat plant populations be

conducted within the first year of license acceptance and every 10 years thereafter. These

surveys would determine if special status plant species have moved into the project or

project-affected area, if there are any changes to revegetation source populations (which

include culturally significant plant populations not associated with TCPs), and the

location and size of specific habitat areas for potentially project-affected special status

wildlife species. Additionally, the Forest Service recommends that monitoring surveys of

known special status and essential habitat plant populations be conducted within 1 year of

plan approval and every 5 years thereafter. Regarding revegetation source populations,

the Forest Service recommends that an operations map accessible to field crews and
196

managers display these populations so they can be avoided during habitat-disturbing

work, rather than monitoring surveys in years between comprehensive surveys.

In the draft plan, the Forest Service also recommends that management actions

would be put into effect to protect special status and essential habitat species when

triggered by specific events, such as construction or project O&M. For planned

disturbance activities, pre-construction surveys for special status and essential habitat

plant species would be conducted within 30 days prior to ground disturbance.

Disturbances would be restricted within a 100-foot buffer of known populations and

fencing would be provided for populations if disturbance occurs within 100 feet;

construction would be conducted, if possible, after vegetation has gone to seed; and top

soil would be salvaged to maintain the seed source. While not explicitly stated in the

draft plan, the implication of instituting limits and controls on disturbances to special

status plant populations is that managers would be informed of sensitive or rare species

locations, as was specified in the Forest Service’s original condition 25. In its November

24, 2010, filing, PG&E accepts Forest Service modified condition 25 and withdraws its

alternative condition 25.

Our Analysis

Surveys for special status plant species resulted in the identification of eight

special status plant species. Coordination and consultation with the Forest Service during

the development of the Vegetation and Invasive Weed Management Plan would provide

ample protection of species and their habitats known to occur within the project area.

Elements of the Vegetation and Invasive Weed Management Plan should provide

potential enhancement of existing populations and habitat by managing and minimizing

encroachment of invasive noxious weeds; providing measures to ensure proper use of

herbicides; training and awareness for employees on special status species, including

informing managers of sensitive, culturally significant, or rare plant population locations;

adaptive management; and education of the public. PG&E alternative condition 25

proposed measures consistent with the Forest Service’s original condition 25, with

schedule modifications such that baseline population surveys and monitoring would be

conducted within 1 year of plan approval. There is no regulatory requirement to include

culturally significant plant species in any long-term monitoring component for special

status plant species. Pre-licensing surveys did not identify any locations of culturally

significant plant populations that had been specifically identified by Tribal members prior

to and during meetings, and populations of culturally significant plant species that were

identified are not considered to be TCPs subject to section 106 requirements of the

NHPA. PG&E alternative condition 25 proposed to limit the scope of this element to

only culturally significant plant populations associated with TCPs. Gathering areas that

qualify as TCPs would have management measures incorporated into a revised HPMP

prepared in consultation with the Tribes, Forest Service, SHPO, and the Commission.

We expect that implementation of the provisions recommended in the draft

Vegetation and Invasive Weed Management Plan would minimize and mitigate for any
197

project effects to special status and essential habitat plant species that may occur as a

result of new construction and project O&M for the term of the license. Regarding

culturally significant plant populations not associated with TCPs, a component of the

plan addressing the creation of an operations map identifying these species would provide

protection of these populations from ground-disturbing or vegetation management

activities related to project operations and/or construction activities. In addition, baseline

surveys of these populations within 1 year of plan approval and every 5 years thereafter,

conducted concurrently with other vegetation monitoring, would determine the range and

extent of existing culturally significant plant populations that are not associated with

TCPs. Additionally, reference to the measures for culturally significant plants associated

with TCPs, as identified in the HPMP, should be included in the Vegetation and Invasive

Weed Management Plan. Other, more general components in the Vegetation and

Invasive Weed Management Plan such as employee awareness training and specific

guidance on pesticide and herbicide treatments would also protect culturally significant

plant populations. Restoration plantings should consider the use of culturally significant

plant species where habitat is appropriate. When additional populations of culturally

significant plant species are identified during monitoring, those new populations should

be assessed for applicability with section 106 requirements and provided in a revised

HPMP in coordination and consultation with the Forest Service, tribal members, and

California SHPO.

3.3.3.2.2 Wildlife

General Wildlife

Project O&M activities at existing project facilities and proposed new construction

sites that may generate short-term disturbances to general wildlife species include noise;

road grading; slide removal; vegetation trimming or clearing and other ground-disturbing

activities that result in habitat modification or removal; reservoir fluctuations; removal of

logs and branches from reservoirs; and spraying of herbicides. Activities related to

construction of future project facilities such as the proposed McCloud and Pit 7 afterbay

powerhouses or recreation facilities that result in temporary disturbance to wildlife

species include noise, lighting, and human activity during all aspects of proposed

construction. Activity associated with construction may also result in the mortality of

non- or minimally mobile wildlife species. Any effects of project O&M or construction

activities on terrestrial wildlife species that occupy habitats within the project area as

resident, transient, or migratory species would be mitigated through the implementation

of limited operating periods and other monitoring and mitigation measures such as

relocation. Additionally, species intolerant of disturbance that are mobile enough to flee

or avoid the areas of activity would leave until activity subsides. In general, the effects

would be short-term and temporary and not severe enough to affect the survival of a

species or population.

In the license application, PG&E proposed measure 14 to develop a Wildlife

Management Plan with a primary goal to guide the management of wildlife populations
198

and habitat at the project for the term of the new license. PG&E measure 14 would, at a

minimum, contain monitoring methodologies, pre-construction survey protocols, and

avoidance and protection measures as appropriate for special status species. The Wildlife

Management Plan proposed by PG&E would also include a process and schedule for

reporting survey and monitoring results as well as a process for periodic plan review and

revision. In addition to measure 14, PG&E proposed measure 16 for avian hazard

reduction. As proposed in measure 16, PG&E would, within 3 years after license

issuance, upgrade segments of the existing distribution line that do not currently meet

avian transmission line standards recommended by the APLIC to prevent bird

electrocutions. In addition, measure 16 would require that all new construction of

transmission and distribution of powerlines meet APLIC-recommended avian

transmission line standards.

In its original condition 26, the Forest Service specified that, within 1 year of

license issuance, PG&E develop a Terrestrial Biological Management Plan, in

consultation with the Forest Service, California Fish and Game, potentially affected

tribes, and other interested parties, and approved by the Forest Service. The Terrestrial

Biological Management Plan would include Forest Service special status species (Forest

Service Sensitive, Survey and Manage, and Management Indicator Species) potentially

affected by the project on Forest Service lands. The plan would be implemented upon

approval by the Commission.

In its original condition 26, the Forest Service specified that, to the extent possible,

the development of the Terrestrial Biological Management Plan should be consistent with

completed biological implementation plans for the nearby Pit 3, 4, and 5 Project to

provide for similar data collection protocols for species that are found within both project

areas and adjacent Forest Service lands. The Terrestrial Biological Management Plan

would include but not be limited to: (1) monitoring of populations and locations

occupied for special status species; (2) periodic surveys throughout the term of the

license within the project and project-affected area to determine the location of any

additional populations; and (3) reporting every 5 years (or at species-specific frequencies

identified by the Forest Service) of terrestrial survey and monitoring results including

suitable habitat, populations, individuals, pairs and nest locations. Results would be

compatible with Forest Service GIS. In addition, and specific to disturbance or

construction activities, the Forest Service’s original condition 26 specified pre- and postconstruction surveys for Forest Service special status species. All surveys and

monitoring would be conducted under Forest Service approved standard protocols. Postdisturbance / construction monitoring would identify whether mitigation measures are

necessary. Lastly, the Forest Service’s original condition 26 specified that PG&E

observe limited operating periods where required, excluding emergency situations. In

order to protect special status avian species, the Forest Service specified that PG&E

conduct surveys for neotropical breeding birds within suitable habitat prior to disturbance

activities or observe annual limited operating periods from April 1 through August 30.
199

In its original condition 26, the Forest Service specified that within 1 year of

license issuance, PG&E file with the Commission, an avian collision and electrocution

hazards plan, approved by the Forest Service in consultation with appropriate federal and

state agencies, which minimizes adverse interactions between project transmission lines

and avian species. All new or rebuilt power poles would conform to guidelines in

Suggested Practices for Raptor Protection – State of the Art in 1996 (APLIC, 1996) or

updates of the guidelines when they are issued. Any pole involved in a bird fatality

would be immediately repaired/replaced to meet the guidelines.

PG&E alternative condition 26 proposed to revise the length of time allowed to

prepare a Terrestrial Biological Management Plan from within 1 year as specified by the

Forest Service’s original condition 26 to 2 years. PG&E asserted that providing 2 years

instead of 1 year to prepare the plan would allow more careful planning and adequate

schedule coordination among the various agencies and other interested parties involved in

drafting a plan. PG&E stated that 1 years would provide adequate time to achieve

consistency to the extent possible, with license conditions for McCloud-Pit and Pit 3, 4,

and 5. To support its proposal of a 2-year time frame for preparing and implementing a

Terrestrial Biological Management Plan, PG&E presented a timeline of about 9 to

16 months which would make the 1-year schedule proposed by the Forest Service

infeasible. PG&E also pointed out that there is nothing to preclude completion of the

Terrestrial Biological Management Plan prior to the 2-year schedule proposed.

PG&E alternative condition 26 proposed to exclude survey areas where access is

unsafe (steep terrain or high water flows) or private property for which PG&E does not

have specific access permission. Surveys would be conducted for disturbance/preconstruction activities and monitoring for special status species as proposed in PG&E

alternative condition 26.

Avian collision and electrocution hazards are also addressed under PG&E

alternative condition 26; PG&E proposed to upgrade segments of existing distribution

lines that do not currently meet the APLIC standards within 3 years of license issuance

and ensure that new lines would meet current APLIC standards. In addition, PG&E

alternative condition 26 proposed that any pole involved in a bird fatality would first be

assessed prior to repair or replacement; the pole involved in the collision or electrocution

could be a pole compliant with existing APLIC standards and may need further

assessment to provide additional safety modifications.

Regarding PG&E’s measure to develop a Terrestrial Biological Management Plan,

The Hearst Corporation expresses concern that Hearst lands surround the entire McCloud

reservoir and the Forest Service’s original condition 26 would require PG&E to conduct

surveys on private land. The Hearst Corporation suggests that monitoring and

management plans and surveys be limited to project-affected and national forest lands.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 26. The provisions specified in Forest Service modified condition 26 are

similar to those specified in the Forest Service’s original condition 26, except that the
200

Forest Service has removed specific details of the plan components and monitoring

schedules from the 4(e) condition and placed them in the draft Terrestrial Biological

Management Plan, included as an enclosure to the filing (Forest Service, 2010d,

Enclosure 3).

In the draft Terrestrial Biological Management Plan (Forest Service, 2010d,

Enclosure 3), the Forest Service has changed its recommendation to agree with the staff

recommendation from the draft EIS regarding the upgrade of existing powerlines that are

not currently in compliance with APLIC guidance, according to a 3-year schedule. In its

November 24, 2010, filing, PG&E accepts Forest Service modified condition 26 and

withdraws its alternative condition 26.

Our Analysis

Isolated, short-term disturbances may occur to wildlife as a result of activities

associated with project O&M activities tasks and could cause mobile wildlife species to

leave an area until tasks are completed. Less mobile species may, on occasion, incur

direct mortality as a result of actions such as trampling and those related to vegetation

management, but implementation of the Terrestrial Biological Management Plan would

mitigate possible effects on these species as a result of normal O&M activities and

mortality would not be beyond what a population could absorb.

Proposed new construction within the project would have a short-term minor

adverse effect to wildlife species as a result of disturbance from construction noise and

human activity. Short-term and long-term alterations in habitat resulting from the

construction of facilities and associated structures, including transmission lines, would

result in wildlife species at least temporarily leaving areas of activity and long-term

habitat modifications or permanent loss of habitat. Clearing along transmission corridors

would result in the loss of linear portions of existing habitat, and wildlife within the

proposed transmission line routes would leave the area during activity.

Measure 14 proposed by PG&E in the license application addressed special status

wildlife species-related issues at the project for the term of the new license and, as

outlined above, contained generalized plan elements for monitoring and protection of

special status wildlife species within the project boundary, a timeframe for development

and implementation, and a proposed schedule for completion of species-specific

monitoring elements.

In its original condition 26, the Forest Service specified that PG&E file a

Terrestrial Biological Management Plan also developed in consultation with the Forest

Service and specifically added California Fish and Game, potentially affected tribes, and

other interest parties. The plan specified by the Forest Service’s original condition 26

would be developed within 1 year of license issuance.

PG&E alternative condition 26 proposes revisions to specific elements of the

Forest Service’s original condition 26, including a 2-year schedule to develop and

implement a Terrestrial Biological Management Plan after license issuance to be
201

consistent with original measure 14 monitoring and protection measures. Because the

Forest Service and PG&E have worked collaboratively on the plan and it is substantially

complete, we expect that the development and implementation of a Terrestrial Biological

Management Plan could be completed within 1 year of license issuance.

PG&E alternative condition 26 proposed that within 3 years of license issuance,

PG&E would upgrade segments of the existing transmission lines that are not currently

compliant with APLIC guidance and construct any new transmission lines to be

compliant with current APLIC standards. PG&E asserted that a plan would not be

necessary if the appropriate upgrades were simply undertaken within 3 years of license

issuance. In the draft Terrestrial Biological Management Plan the Forest Service

recommends actions for meeting APLIC standards that are in agreement with PG&E’s

alternative condition 26 and the staff recommendation included in the draft EIS.

Special Status Wildlife Species

The potential effects on general wildlife species from project O&M activities also

apply to special status wildlife species.

In its original condition 26, the Forest Service specified that beginning the first full

calendar year after license issuance PG&E would, in consultation with the Forest Service,

annually review the current list of special status wildlife species (species that are Forest

Service Sensitive, Survey and Manage, Management Indicator Species, or on the ShastaTrinity National Forest Watch List) that might occur on Forest Service lands in the

project or project-affected area. If it is determined that newly listed special status species

may occur within the project area, PG&E would develop and implement a study plan in

consultation with the Forest Service to assess the effects of project O&M on special

status species.

When a species is added to one or more of the lists, the Forest Service, in

consultation with PG&E, would determine if the species or unsurveyed suitable habitat

for the species is likely to occur on Forest Service lands within the project or projectaffected areas. If the Forest Service determines that the species is likely to occur, PG&E

would develop and implement a study plan in consultation with the Forest Service to

reasonably assess the effects of the project on the species. PG&E would prepare a report

on the study including objectives, methods, results, recommended resource measures

where appropriate, and a schedule of implementation, and would provide a draft of the

final report to the Forest Service for review and approval. PG&E would file the final

report, including evidence of consultation, with the Commission. Upon Commission

approval, PG&E would implement the resource management measures.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 26. The provisions specified in Forest Service modified condition 26 are

similar to those specified in the Forest Service’s original condition 26, except that the

Forest Service has removed specific details of the plan components and monitoring

schedules from the 4(e) condition and placed them in the draft Terrestrial Biological
202

Management Plan, included as an enclosure to the filing (Forest Service, 2010d,

Enclosure 3). In its November 24, 2010, filing, PG&E accepts Forest Service modified

condition 26 and withdraws its alternative condition 26.

Regarding annual consultation between PG&E and the Forest Service and other

agencies, The Hearst Corporation has suggested that annual meetings also be opened to

“project-affected” private landowners.

Our Analysis

Wildlife, including special status species, has most likely adapted to the routine

activity surrounding projects and is disturbed only during non-routine actions. Isolated,

short-term disturbances may occur to special status wildlife species as a result of

activities associated with vegetation management (e.g., mowing, trimming) or

maintenance tasks and could cause mobile wildlife species to leave an area until tasks are

completed.

To ensure that continued O&M activities of the existing projects as well as O&M

of proposed facilities (if constructed) have minimal effects on special status species

potentially occurring within the project area, annual consultation with the Forest Service

and other appropriate agencies would be indispensable to PG&E’s planning and

implementation of normal O&M activities and for any necessary construction activities

that may be required. We expect that implementation of Forest Service modified

condition 26 and a Terrestrial Biological Management Plan, including annual

consultation and review of the most recent listing of special status species and

implementation of resource management measures should a species likely occur, would

continue to provide habitat and protection within the project area.

Regarding consultations, for any PG&E action that would potentially affect the

property of private landowners, PG&E would need to consult with the private landowner.

Terrestrial Mollusks

Terrestrial mollusks could be affected by changes in soil conditions, availability of

large rocks or woody debris as well as canopy cover, sources of food, and water. Nonnative invasive mollusk species also threaten native terrestrial mollusk species; several

species of invasive mollusks were identified within the project area in association with

the special status species. Project O&M activities that disturb ground or clear vegetation

can cause direct mortality as a result of crushing, injury, or desiccation through exposure.

Trampling in recreational areas could also result in mortality. Indirect mortality could be

caused by loss or modification of habitat adjacent to project facilities or recreation areas

as well as inundation or dewatering of habitat. Proposed construction could also affect

special status terrestrial mollusk species directly through various activities (ground

disturbance, vegetation removal) that are in the immediate vicinity of mollusk

populations.

PM&E measure 14 proposed the development of monitoring methodologies, preconstruction survey protocols, avoidance, and protection measures as appropriate for
203

terrestrial mollusks. Pre-construction surveys would be conducted in areas of suitable

habitat potentially affected by any planned construction, and a buffer distance around the

construction site would be defined based on existing standards and protocols for mollusk

species. Protection or relocation of species would be required when located within the

footprint of construction sites.

In its original condition 26, the Forest Service specified that PG&E develop within

the Terrestrial Biological Management Plan special status species component an element

to address terrestrial mollusks. For terrestrial mollusks, PG&E would conduct

monitoring surveys of known sites within 1 year of license issuance and every 5 years

thereafter. PG&E would survey potentially suitable habitat for new populations every 10

years for the term of the license. Species to be monitored would include the Shasta

sideband snail (Monadenia troglodytes troglodytes), Wintu sideband snail

(M. troglodytes wintu), Shasta chaparral snail (Trilobosis roperi), Tehama snail

(T. tehama), and the Shasta hesperian snail (Vespericola shasta) at known sites along the

McCloud reservoir, Lower McCloud River, Iron Canyon reservoir and Creek, and Pit 6

and 7 reservoirs. Protection or relocation of terrestrial mollusks would occur in

development sites prior to construction.

PG&E alternative condition 26 proposed that locations of monitoring sites within

the project-affected area and survey protocols would be contained in a Terrestrial

Biological Management Plan. PG&E proposed to monitor known populations of

sensitive terrestrial mollusks beginning the first year after license issuance and once

every 5 years thereafter. PG&E also proposed to survey potentially suitable habitat for

new populations every 10 years for the term of the license. Monitoring proposed in

PG&E alternative condition 26 would be conducted within project-affected areas within

200 feet of facilities and roads, a 16-foot-wide band surrounding reservoirs, and along

both sides of the Lower McCloud River and Iron Canyon Creek. Also included would be

limestone outcrops within 100 meters of riparian zones or 200 meters of project facilities.

A subset of sites surveyed would be chosen for monitoring based on documented

occurrences. Protection and relocation of any individuals detected within the footprint of

construction activities would also occur. PG&E alternative condition 26 proposed that

pre-construction surveys in areas of suitable habitat potentially affected by planned

construction would be conducted to identify and protect any previously unknown

populations in construction areas.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 26. The provisions specified in the Forest Service modified condition 26 are

similar to those specified in the Forest Service’s original condition 26, except that the

Forest Service has removed specific details of the plan components and monitoring

schedules from the 4(e) condition and placed them in the draft Terrestrial Biological

Management Plan, included as an enclosure to the filing (Forest Service, 2010d,

Enclosure 3).
204

In the draft Terrestrial Biological Management Plan, the Forest Service

recommends that a survey of known special status terrestrial mollusk populations be

conducted within 1 year of license acceptance, 6 years after license acceptance, and every

10 years thereafter. Additionally, the Forest Service recommends that PG&E conduct

surveys for special status terrestrial mollusks within other suitable habitat within the

project and project-affected areas, within 1 year of license acceptance and every 10 years

thereafter. The Forest Service also recommends that PG&E conduct pre-construction

surveys for special status terrestrial mollusk species, no more than 30 days prior to

ground disturbance. In its November 24, 2010, filing, PG&E accepts Forest Service

modified condition 26 and withdraws its alternative condition 26.

Our Analysis

Terrestrial mollusks within the project area could be adversely affected by

construction activities within habitat where they occur, especially Oregon

shoulderbanded snail, Shasta hesperian snail, and the Shasta chaparral snail. In its

original condition 26, the Forest Service specified monitoring of known special status

terrestrial mollusks every 5 years, surveys for new populations in suitable habitat every

10 years, and conducting pre-construction surveys. PG&E alternative condition 26

proposed pre-construction surveys for potential new populations of terrestrial mollusks in

suitable habitat identified within the construction footprint. Protection by establishing a

buffer around construction areas, or relocation of snails, would be implemented prior to

the initiation of construction. In the draft Terrestrial Biological Management Plan, as

compared to its original condition 26, the Forest Service recommends less frequent

surveys of known populations, which would be less protective of special status terrestrial

mollusks.

Surveys for known populations of special status terrestrial mollusk species, along

with any required pre-construction surveys, would provide information on the existing

populations of terrestrial mollusks and their overall condition, and determine if project

O&M and construction activities are affecting terrestrial mollusk populations. Surveys

for known populations conducted within 1 year of license issuance and every 5 years

thereafter would provide a baseline status assessment of existing special status terrestrial

mollusk populations and be more protective of these existing populations than the

schedule recommended by the Forest Service in the draft Terrestrial Biological

Management Plan. Surveys of suitable habitat within the first year of license issuance

and every 10 years thereafter, and adaptation of management to include new species or

populations that are detected, would ensure protection of potential future populations of

special status terrestrial mollusk species within the project area for the term of the

license.

Amphibians and Reptiles

There are no anticipated project effects on tailed frogs in tributaries to the Lower

McCloud River. No project activities are planned near Ladybug Creek or in any other

tributary to the Lower McCloud River that may harbor tailed frogs.
205

Shasta salamander and northwestern pond turtle could be adversely affected by

normal project O&M in the vicinity of the McCloud reservoir and the Pit 7 afterbay, as

well as proposed recreation construction near the Pit 6 and Pit 7 reservoirs. Grounddisturbing activities (e.g., vegetation management, LWD removal, road work, slide

removal) can alter or eliminate habitat for these species. Removing or crushing limestone

can also adversely affect the Shasta salamander through alteration or loss of preferred

habitat. Disturbance of wet areas or seeps, particularly during the reproductive season,

can also cause mortality to salamanders and turtles, their eggs, or young. Shasta

salamanders and northwestern pond turtle are the only special status amphibian or reptile

species identified as occurring within proposed construction sites.

Foothill yellow-legged frog individuals were found in the Lower McCloud River

where suitable habitat occurs. Environmental conditions that could affect the foothill

yellow-legged frog include water temperature, water depth, water velocity, substrate size,

food resources availability, and canopy cover. Predation and proximity to tributaries also

could affect the foothill yellow-legged frog; however, these factors are not related to

project O&M. Project O&M could affect water temperature, depth, and velocity, as well

as food availability. Vegetation management could potentially reduce canopy cover.

The northwestern pond turtle near the Lower McCloud River shoreline and the

Pit 6 and Pit 7 reservoirs could be adversely affected by unexpected, high volume flows

(such as those resulting from emergency shut-downs) that could inundate nest sites.

Spills that could cause these conditions are not a part of normal operations and could be

expected to occur infrequently. In addition, removal of LWD that provides underwater

shelter as well as basking areas could alter suitable nesting and overwintering sites.

In measure 14, PG&E proposed specific components addressing special status

amphibians and reptiles which would be developed in consultation with the Forest

Service and other relevant agencies and groups. Included in the Wildlife Management

Plan would be a schedule for reporting survey and monitoring results for all special status

species amphibians and reptile monitoring surveys.

In its original condition 26, the Forest Service specified conditions for special

status species regarding the development and implementation of a Terrestrial Biological

Management Plan.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 26. The provisions specified in modified condition 26 are similar to those

specified in original condition 26, except that the Forest Service has removed specific

details of the plan components and monitoring schedules from the 4(e) condition and

placed them in the draft Terrestrial Biological Management Plan, included as an

enclosure to the filing (Forest Service, 2010d, Enclosure 3).

In its original condition 26, the Forest Service specified monitoring of Shasta

salamander at known locations once every 5 years along the McCloud reservoir and

Fenders Ferry Flat afterbay as well as surveys of suitable habitat every 10 years to
206

determine any new locations of the species. Estimates of population age and distribution

would be included in reports summarizing monitoring surveys. PG&E alternative

condition 26 proposed to eliminate the Forest Service’s original condition 26 language

for monitoring Shasta salamander at known locations once every 5 years stating that there

is no project nexus for additional monitoring or surveying in areas that are not affected by

project operations. PG&E alternative condition 26 proposed to include pre-construction

surveys to protect and monitor Shasta salamanders. Pre-construction surveys following

the standard protocol for Shasta salamander would be conducted in areas of suitable

habitat within 180 meters of any proposed new development/expansion or grounddisturbing activity. Protection or relocation of individuals of Shasta salamanders would

occur prior to any construction or ground-disturbing activities.

In the draft Terrestrial Biological Management Plan (Forest Service, 2010d,

Enclosure 3), the Forest Service recommends that a survey of known Shasta salamander

populations be conducted within 1 year of license acceptance, 6 years after license

acceptance, and every 10 years thereafter. Additionally, the Forest Service recommends

that the license conduct surveys for Shasta salamander populations within other suitable

habitat within the project and project-affected areas, within 1 year of license acceptance

and every 10 years thereafter. The Forest Service also recommends that PG&E conduct

pre-construction surveys for Shasta salamander, no more than 30 days prior to ground

disturbance within 150 meters of the disturbance area.

Forest Service modified condition 27 specifies that the northwestern pond turtle

and foothill yellow-legged frog should be included in the Aquatic Biological Monitoring

Plan. The Forest Service also specifies in modified condition 26, however, that the

northwestern pond turtle be included in the Terrestrial Biological Management Plan. We

assume that the Forest Service intended for the northwestern pond turtle be removed from

the Terrestrial Biological Management Plan and placed in the Aquatic Biological

Monitoring Plan. Therefore, the northwestern pond turtle is now a part of the Aquatic

Biological Monitoring Plan; however, both the northwestern pond turtle and foothill

yellow-legged frog are discussed below because of their original inclusion within the

Terrestrial Biological Management Plan.

13

Foothill Yellow-Legged Frog — In its original condition 26, the Forest Service

specified surveys be completed once every 10 years for additional populations of foothill

yellow-legged frog along the 5.4 miles of National Forest Service lands along the Lower

McCloud River and along the Pit 6 and Pit 7 reservoirs and tributaries. Any individuals

of foothill yellow-legged frog found in areas proposed for disturbance or construction

would be protected or relocated. PG&E alternative condition 26 proposed that foothill

yellow-legged frog surveys begin the first year after plan approval and every tenth year

13 Although protection measures specific to the northwestern pond turtle and

foothill yellow-legged frog are discussed in section 3.3.3.2.2 Wildlife, these species are

included in the Aquatic Biological Monitoring Plan (Forest Service, 2010, Enclosure 3).
207

thereafter in suitable habitat, along the tributaries to Pit 6 and Pit 7 reservoirs but

excluding 5.4 miles of NFS lands and the Pit 6 and Pit 7 reservoirs. PG&E proposed that

pre-construction surveys be conducted in suitable habitat at or adjacent to construction or

maintenance activities for any proposed new developments or disturbance areas, as well

as existing sites to be expanded or redeveloped. The survey area would include

0.8 kilometer (0.5 mile) upstream and downstream of all perennial tributaries that

intersect the linear transmission line footprint.

In its comments on the draft EIS, PG&E states that it did not include surveys of

NFS lands on the Lower McCloud River because water temperatures at these locations do

not consistently reach the threshold to initiate foothill yellow-legged frog breeding until

June, which PG&E states is likely to be too late in the season for the foothill yellowlegged frog to initiate breeding with sufficient time for larvae to metamorphose by fall.

In the draft Aquatic Biological Monitoring Plan (Forest Service, 2010d,

Enclosure 3), the Forest Service recommends that surveys for new populations of foothill

yellow-legged frogs in suitable habitat be conducted within 1 year of implementation of

the required minimum instream flows in the Lower McCloud River and every 10 years

thereafter. The Forest Service recommends these surveys be conducted within the project

and project-affected areas along the Lower McCloud River and tributaries to the Pit 6 and

Pit 7 reservoirs.

The Forest Service also filed a 10(a) recommendation that, within 1 year after

licensing, PG&E should develop a Foothill Yellow-Legged Frog Monitoring Plan that

would include the following provisions: (1) population monitoring during wet and dry

seasons for an initial 5-year period; and (2) incremental population monitoring every 4

years. Under the Forest Service recommendation, PG&E would survey foothill yellowlegged frog distribution along the McCloud River from Claiborne Creek to the

confluence with Shasta Lake. Monitoring data would be used to evaluate any project

effects on the foothill yellow-legged frog, such as through the development of a

predictive tool for use in determining breeding period initiation and termination, in order

to prevent flow dynamics from adversely affecting the foothill yellow-legged frog.

PG&E submitted comments on the Forest Service 10(a) recommendation

regarding foothill yellow-legged frog population monitoring and specified alternative

approaches including the following: (1) submission of a Foothill Yellow-Legged Frog

Monitoring Plan within 2 years for license issuance; (2) annual monitoring during the

initial 5-year study period; and (3) incremental monitoring every 5 years. Foothill

yellow-legged frog surveys would be conducted at selected sites and tributaries within

and along the Lower McCloud River from Tuna Creek to the confluence with Shasta

Lake, based on locations where foothill yellow-legged frog breeding and suitable habitat

were observed during relicensing studies. Monitoring data would be used to evaluate any

changes in foothill yellow-legged frog populations over the license term. The modeling

component proposed by the Forest Service would be simplified such that monitoring data

would be used to estimate initiation of the breeding period in future years in order to
208

avoid untimely uncontrollable spills or flow fluctuations that could detrimentally affect

foothill yellow-legged frog recruitment.

In its November 29, 2010, filing, the Forest Service includes its 10(a)

recommendation as part of the draft Aquatic Biological Monitoring Plan, included as an

enclosure to the filing (Forest Service, 2010d, Enclosure 3). The Forest Service does not

include modifications to the provisions specific to its 10(a) recommendation and notes in

the draft plan that, because Forest Service authority does not extend to the entire projectaffected area, it is submitting the recommendation where there are no direct or indirect

effects to NFS resources.

Northwestern Pond Turtle — In its original condition 26, the Forest Service

specified monitoring of known northwestern pond turtle populations once every 5 years,

and surveying suitable habitat once every 10 years to identify additional populations.

Estimates of population age distribution would be included in reports summarizing

survey results. Individuals located within the area of potential disturbance or

construction activity would be protected or relocated.

PG&E alternative condition 26 proposed surveys for known northwestern pond

turtle populations within the first year after approval of the Terrestrial Biological

Management Plan and every fifth year thereafter. PG&E proposed surveys for additional

populations of northwestern pond turtle in suitable habitat within the first year after

approval of the Terrestrial Biological Management Plan and every tenth year thereafter.

PG&E would also conduct pre-construction surveys in areas of suitable habitat that could

potentially be affected by planned construction. Visual observations would estimate the

number of individuals within the age classes of adults, juveniles, and young-of-the-year.

In the draft Aquatic Biological Monitoring Plan (Forest Service, 2010d,

Enclosure 3), the Forest Service recommends that a survey of known northwestern pond

turtle populations be conducted within 1 year of license acceptance, 6 years after license

acceptance, and every 10 years thereafter. Additionally, the Forest Service recommends

that PG&E conduct surveys for northwestern pond turtle populations within other

suitable habitat within the project and project-affected areas, within 1 year of license

acceptance and every 10 years thereafter. The Forest Service also recommends that

PG&E conduct pre-construction surveys for northwestern pond turtle, no more than 30

days prior to ground disturbance.

Our Analysis

As analyzed in the draft EIS, PG&E’s proposed measure 14 to develop and

implement a Wildlife Management Plan would provide monitoring and protection

protocols as well as survey procedures to minimize any project effects that could occur to

amphibian and reptile special status species occurring in habitats (or with the potential to

occur) within the project area. The Forest Service’s original condition 26 specified

details for monitoring and surveys for listed special status amphibian and reptile species,

including pre-construction surveys for the Shasta salamander, foothill yellow-legged
209

frog, and northwestern pond turtle; surveys of known populations of the Shasta

salamander and northwestern pond turtle every 5 years; and surveys for new populations

of all three species in suitable habitat every 10 years. PG&E alternative condition 26 was

similar to the Forest Service’s original condition 26 but eliminated surveys for known

and new populations of the Shasta salamander and proposed baseline surveys for known

and new populations of the northwestern pond turtle and new populations of the foothill

yellow-legged frog within the first year after approval of the Terrestrial Biological

Management Plan. In comparison to the Forest Service’s original condition 26, in the

draft Terrestrial Biological Management Plan the Forest Service does not include preconstruction surveys for the foothill yellow-legged frog and recommends less frequent

surveys of known populations of Shasta salamander and northwestern pond turtle, which

would be less protective of these special status species than the measures specified in

original condition 26.

Surveys for known populations of the Shasta salamander and northwestern pond

turtle, along with any required pre-construction surveys, would provide information on

the existing populations of these special status species and their overall condition, and

minimize any potential effects to these species from project O&M and construction

activities. Surveys for known populations within 1 year of license issuance and every 5

years thereafter would provide a baseline status assessment of existing populations and be

more protective of these existing populations than the schedules recommended by the

Forest Service in the draft Terrestrial Biological Management Plan and draft Aquatic

Biological Monitoring Plan. Surveys of suitable habitat within the first year of license

issuance and every 10 years thereafter, and adaptation of management to include new

species or populations that are detected, would ensure protection of potential future

populations of Shasta salamander, foothill yellow-legged frog, and northwestern pond

turtle within the project area for the term of the license.

Specifically for the foothill yellow-legged frog, surveys along the Lower McCloud

River and along the Pit 6 and Pit 7 reservoirs would not be necessary as cold water

temperature in the Lower McCloud River and absence of appropriate habitat immediately

surrounding the reservoirs would preclude the presence of the foothill yellow-legged frog

in those areas. However, the presence of the foothill yellow-legged frog in the vicinity of

the Pit 6 and Pit 7 reservoirs would be more likely if this species develops a presence in

the Pit 5 reach. Pre-construction monitoring would protect foothill yellow-legged frogs

within proposed disturbance activity and would be more effective at maintaining and

potentially enhancing populations of the foothill yellow-legged frog in the project and

project-affected area. Additionally, proposed flow regimes that include ramping prior to

spill events would minimize scouring of substrates reducing the potential for scouring of

egg masses of foothill yellow-legged frog from substrates.

Birds

Normal project O&M activities could disturb breeding, causing nest failures as a

result of nest abandonment, egg exposure to predation, and premature fledging of young
210

birds, and could result in complete abandonment of the breeding territory. Noise and

human activity associated with the proposed construction activities within the project

area could result in disturbance to birds, including raptors and special status species.

Some individuals may temporarily abandon the area.

Avian transmission line structures provide perching, roosting, and nesting

opportunities for raptor species, especially those that inhabit open areas or areas where

natural nest sites are absent or limited. Avian mortality can occur directly through

electrocution or indirectly from injuries sustained by impacting with lines. Existing

project transmission lines (James B. Black, Pit 6 and Pit 7), meet or exceed the APLIC

standards for protection of birds from electrocution. A distribution line associated with

Pit 5 contains some poles that are not compliant with current APLIC standards.

PG&E’s proposed measure 14 in the license application to develop a Wildlife

Management Plan to address special status bird species that would be developed in

consultation with the Forest Service and other relevant agencies and groups. Included in

the Wildlife Management Plan would be a schedule for reporting survey and monitoring

results for all special status bird species. Few specific details were provided and would be

developed in consultation with federal and state agencies as well as other interested

stakeholders.

In its original condition 26, the Forest Service specified a list of special status bird

species and detailed monitoring and survey elements to be included in a Terrestrial

Biological Management Plan. The Forest Service’s original condition 26 specifies

species-specific elements of the Terrestrial Biological Management Plan for avian special

status species in regards to construction. Dependent on the existence of suitable habitat

required by avian special status species within proposed construction areas including

transmission lines, pre-construction surveys for listed avian species would be conducted.

As an alternative to pre-construction surveys, limited operating periods specific to the

breeding season for a species could be enforced. The limited operating periods specified

in the Forest Service’s original condition 26 for specific special status avian species were:

bald eagle, January 1 to August 1; northern goshawk and peregrine falcon, February 1 to

August 15; and willow flycatcher and neotropical breeding birds, April 1 to August 30.

PG&E alternative condition 26 proposed clarifications to the distance from

proposed construction activity for pre-construction surveys by species: northern goshawk

– within 0.5 mile; bald eagle – within 1 mile; peregrine falcon – within 1 to 3 miles; and

willow flycatcher – within 200 feet of private land where access has been granted and

within 300 feet of public land.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 26. The provisions specified in Forest Service modified condition 26 are

similar to those specified in the Forest Service’s original condition 26, except that the

Forest Service has removed specific details of the plan components and monitoring

schedules from the 4(e) condition and placed them in the draft Terrestrial Biological

Management Plan, included as an enclosure to the filing (Forest Service, 2010d,
211

Enclosure 3). Species-specific details recommended by the Forest Service in the draft

Terrestrial Biological Management Plan are discussed below. In its November 24, 2010,

filing, PG&E accepts Forest Service modified condition 26 and withdraws its alternative

condition 26.

Northern Goshawk

In its original condition 26, the Forest Service specified surveys of known

northern goshawk populations in the project or project-affected areas would occur within

0.25 mile of previously identified detection sites once per 5 years; suitable habitat would

be surveyed once per 10 years to identify any additional individuals or pairs.

PG&E alternative condition 26 proposed to eliminate monitoring within 0.25 mile

of previously identified detection sites once per 5 years stating that there are no known

active nests in the areas affected by project operations.

In the draft Terrestrial Biological Management Plan (Forest Service, 2010d,

Enclosure 3), the Forest Service recommends that the license conduct surveys for

northern goshawk within other suitable habitat within the project and project-affected

areas, within 1 year of license acceptance and every 10 years thereafter. Additionally, the

Forest Service recommends surveys of any located nests every 10 years, beginning 5

years after nest discovery. The Forest Service also recommends that PG&E conduct preconstruction surveys for northern goshawk, no more than 30 days prior to ground

disturbance within 0.5 mile of habitat, or follow a limited operating period of February 1

through August 15.

Bald Eagle

In its original condition 26, the Forest Service specified monitoring of bald eagle

individuals, pairs, and nest productivity annually at McCloud reservoir, Iron Canyon

reservoir, Pit 6 and Pit 7 reservoirs, and any additional locations identified during surveys

or monitoring as approved by the Forest Service, including surveys in suitable habitat

annually. Protective actions to minimize disturbance factors would include: buffer zones

around each known nest territory; potential zoning of water surfaces in project reservoirs

with respect to use and access of watercraft; coordination of PG&E and Forest Service

land management activities within bald eagle nest territories such as timber harvest,

mining, and woodcutting; periodic monitoring of human use patterns to discern human /

bald eagle interaction and development and placement of interpretive signage at

McCloud and Iron Canyon reservoirs addressing bald eagles.

PG&E alternative condition 26 proposed to ensure that annual monitoring for bald

eagles would be consistent with PG&E’s ongoing bald eagle monitoring program and

clarifies locations of monitoring sites within the project-affected area.

In the draft Terrestrial Biological Management Plan (Forest Service, 2010d,

Enclosure 3), the Forest Service recommends that a survey of known bald eagle

populations be conducted annually. Additionally, the Forest Service recommends that

the license conduct surveys for bald eagle populations within other suitable habitat within
212

the project and project-affected areas, within 1 year of license acceptance and every

10 years thereafter. The Forest Service also recommends that PG&E conduct preconstruction surveys for bald eagle, no more than 30 days prior to ground disturbance

within 0.5 mile of habitat, or follow a limited operating period of February 1 through

August 15. Protocol for bald eagle surveys would follow the existing protocol in the

Interagency Bald Eagle Management Plan developed for the Pit 3, 4, 5 Project (Project

No. 233). Forest Service modified condition 26 also recommends that additional

monitoring for bald eagles would be conducted along the Lower McCloud River in the

event that winter-run Chinook salmon are re-introduced to the McCloud drainage.

Furthermore, in the draft Vegetation and Invasive Weed Management Plan, the Forest

Service recommends the implementation of botanical management actions to improve

wildlife habitat, which could include nesting habitat for bald eagles (section 3.3.3.2.1,

Vegetation).

Peregrine Falcon

In its original condition 26, the Forest Service specified that annual monitoring of

peregrine falcon individuals, pairs, and nest activity occur within 0.25 mile of known

sites on Forest Service lands. In addition, the Forest Service’s original condition 26

specifies monitoring once per 5 years in potentially suitable habitat.

PG&E alternative condition 26 proposed that surveys for peregrine falcon would

begin the first year after Terrestrial Biological Management Plan approval and every fifth

year thereafter at known nesting sites and at suitable cliff nesting habitat along Pit 6 and

Pit 7 reaches of the Pit River Canyon, the McCloud River reach downstream of McCloud

dam, and Iron Canyon Creek downstream of Iron Canyon reservoir to the confluence

with the Pit River. Specifically excluded were survey areas where access is unsafe or

private property which PG&E does not have specific permission to access to perform the

survey.

In the draft Terrestrial Biological Management Plan (Forest Service, 2010d,

Enclosure 3), the Forest Service recommends that a survey of known peregrine falcon

populations be conducted annually. Additionally, the Forest Service recommends that

the license conduct surveys for peregrine falcon populations within other suitable habitat

within the project and project-affected areas, within 1 year of license acceptance and

every 10 years thereafter. The Forest Service also recommends that PG&E conduct preconstruction surveys for peregrine falcon, no more than 30 days prior to ground

disturbance, and follow a limited operating period of February 1 through August 15 if

individuals are found. Protocol for peregrine falcon surveys would follow the University

of California Santa Cruz Predatory Bird Research Group guidelines.

Willow Flycatcher and Neotropical Breeding Birds

In its original condition 26, the Forest Service specified that PG&E survey suitable

habitat for willow flycatcher habitat (including dispersed campsites) once every 5 years
213

and that habitat for willow flycatcher be restored or enhanced within the project or the

project-affected area where project activities affect willow flycatcher habitat vegetation.

PG&E alternative condition 26 proposed surveys of suitable willow flycatcher

habitat beginning the first year after plan approval and every fifth year thereafter.

Although there are no known willow flycatcher nesting sites within the project or projectaffected areas, surveys would follow standard protocols for the species and would be

conducted in contiguous suitable habitat within 300 feet (on public lands) and 200 feet

(on private land where access has been granted to PG&E) from the following features:

(1) project-affected mainstem river reaches (the Pit River from the James B. Black

powerhouse tailrace to Shasta Lake, Iron Canyon Creek downstream of Iron Canyon

dam, and the McCloud River from McCloud dam to Squaw Valley Creek; (2) project

waterbodies (McCloud, Iron Canyon, Pit 6 and Pit 7 reservoirs, and Pit 7 afterbay); and

(3) project-related recreation sites (e.g., campsites, including dispersed campsites; dayuse areas; boat launches). PG&E alternative condition 26 also proposed to restore and

enhance willow habitat where the project has affected vegetation.

Transmission lines can be a hazard to birds, especially raptors such as the bald eagle,

golden eagle, and peregrine falcon. Birds touching lines can be electrocuted or badly

injured if directly striking a line. Existing project transmission lines meet or exceed

APLIC standards to prevent electrocution of birds with the exception of the Pit 5

distribution line that contains some poles that are not in compliance. PG&E measure 16

proposed, the Forest Service’s original condition 26 specified, and Forest Service

modified condition 26 specifies avian collision and electrocution hazard prevention

measures (see section 3.3.3.2.2, Wildlife, General Wildlife).

In the draft Terrestrial Biological Management Plan (Forest Service, 2010d,

Enclosure 3), the Forest Service recommends that a survey of known willow flycatcher

and neotropical breeding bird populations be conducted within 1 year of license

acceptance, 6 years after license acceptance, and every 10 years thereafter. Additionally,

the Forest Service recommends that the license conduct surveys for willow flycatcher and

neotropical breeding bird populations within other suitable habitat within the project and

project-affected areas, within 1 year of license acceptance and every 10 years thereafter.

The Forest Service recommends that PG&E conduct pre-construction surveys for willow

flycatcher and neotropical breeding birds, no more than 30 days prior to ground

disturbance within 250 feet of habitat, or follow a limited operating period of May 1

through August 1. Additionally, in the draft Vegetation and Invasive Weed Management

Plan, the Forest Service recommends the implementation of botanical management

actions to improve wildlife habitat, including the protection of willow and alder habitat

for the willow flycatcher and riparian habitat for neotropical breeding birds (section

3.3.3.2.1, Vegetation).

Our Analysis

Project O&M and construction activities within the project area all have the

potential to adversely affect avian special status species. Primary effects would result
214

from noise and activity disturbance near roosting or nesting sites and, in the case of

breeding pairs, could lead to loss of a breeding season from nest abandonment, increased

opportunity for nest predation, and premature fledging of young. In its original condition

26, the Forest Service specified surveys for known populations of northern goshawk

every 5 years and for new populations within suitable habitat every 10 years; surveys of

known populations of bald eagle and peregrine falcon and surveys for new populations

within suitable habitat on an annual basis; and surveys for willow flycatcher within

suitable habitat every 5 years. In comparison, PG&E alternative condition 26 proposed

only pre-construction surveys for northern goshawk; surveys of known populations of

peregrine falcon, and surveys for new populations within suitable habitat, within 1 year

of approval of the Terrestrial Biological Management Plan and every 5 years thereafter;

and surveys for willow flycatcher in suitable habitat within 1 year of plan approval and

every 5 years thereafter. In the draft Terrestrial Biological Management Plan, as

compared to its original condition 26, the Forest Service recommends less frequent

surveys for known populations of willow flycatcher and for new populations of bald

eagle, peregrine falcon, northern goshawk, and willow flycatcher, which would be less

protective of these species.

Development and implementation of specific elements of the draft Terrestrial

Biological Management Plan recommended by the Forest Service for special status bird

species, including pre-construction surveys; limited operating periods; surveys for known

populations of northern goshawk, bald eagle, and peregrine falcon would provide

information on the existing populations of these species and their overall condition, and

minimize any potential effects to these species from project O&M and construction

activities. Specific to peregrine falcon and bald eagle nest sites within the project area,

buffers for active nest sites would protect them from disturbance due to project O&M

activities and could be applied to recreational activities in the vicinity of active nests.

Annual surveys for known populations of bald eagle and for new populations in suitable

habitat would provide a baseline status assessment of these populations and would be

more protective than the schedule recommended by the Forest Service in the draft

Terrestrial Biological Management Plan. Surveys for known populations of peregrine

falcon within 1 year of license issuance and every 5 years thereafter would provide a

baseline status assessment and provide adequate protection of existing populations.

Surveys for new populations of peregrine falcon within suitable habitat within 1 year of

license issuance and every 5 years thereafter would be more protective of these existing

populations than the schedule recommended by the Forest Service in the draft Terrestrial

Biological Management Plan. Pre-construction surveys for willow flycatcher combined

with surveys for new populations in suitable habitat within 1 year of license issuance and

every 5 years thereafter would provide adequate protection for this species. Additionally,

a limited operating period of April 1 through August 31 would provide more protection

for this species than the limited operating period of May 1 through August 1

recommended by the Forest Service in the draft Terrestrial Biological Management Plan.

Additionally, a re-evaluation of the geographic survey area and protocol for bald eagle if
215

salmon are re-introduced above McCloud dam would provide additional protection for

this species. Finally, we expect that specific standards for transmission lines developed

by APLIC that are employed along proposed power lines and retrofitted on existing lines

would avoid or minimize avian electrocution hazards to this species if it occurs within the

project area.

Mammals

Bats

Current project O&M activities have the potential to affect bat species and their

habitat within the project area. Special status bat species within the project area utilize

project structures and facilities for day or night roosts as well as maternity sites during

the breeding season. Individuals could be harmed if directly disturbed or excluded from

the structures. Maintenance activities are seldom conducted at night, and would be

unlikely to disturb roosting individuals. Project O&M activities that occur during the day

at these locations when individuals are present could disturb individuals and cause them

to leave the facility; extended maintenance activity could cause individuals to relocate. If

facility openings that allow access for individuals are sealed at the wrong time, or

inappropriately exclude individuals from gaining access, adverse effects to bat species

including the special status species could occur, including indirect mortality and loss of

roost habitat. Maternity roost habitat was observed at McCloud intake structure, James

B. Black powerhouse, and Willow Creek siphon. Inappropriate exclusion of female bats

from maternity sites within these facilities could result in indirect mortality. Unscreened

vent pipes at campground restrooms may provide outside access to the vault underneath

the restroom and subsequently allow access into the restroom if the toilet lid is open or

absent. Routine maintenance of these restroom structures is unlikely to disturb roosting

bats.

Roost habitat could potentially be disturbed or removed as a result of construction

activity. Also, ground-disturbing construction activities could affect the entrance and

egress points for bats, and could alter patterns of air flow and groundwater dynamics,

potentially affecting the micro climate within the cave complex and altering the

suitability of habitat for bats using the cave. Transmission line construction along the

proposed route could also alter foraging habitat, because altering the vegetation structure

could change the composition of prey species. Some bat species may benefit from

changes in vegetation structure resulting from the construction if forest edge and open

habitats are increased. Night-time construction activity in these areas could result in

short-term disturbance to foraging bats; however, disturbance to foraging bats would be

negligible since bats could relocate to other undisturbed foraging areas.

In its original condition 26, the Forest Service specified that PG&E conduct

annual monitoring for Forest Service special status bat species (Townsend’s big-eared

bat, pallid bat, and western red bat) at known locations around McCloud reservoir and

Pit 7 reservoir, and that PG&E conduct surveys once every 5 years in suitable habitat.

All bathroom vents at existing and proposed recreational sites would be screened to
216

reduce bat mortality and consultation with the Forest Service would occur prior to

implementing any bat-exclusion techniques. PG&E alternative condition 26 proposed

monitoring at known sites and other project-related suitable habitat beginning the first

year after plan approval and every fifth year thereafter. Appropriate sites for periodic

monitoring would be identified in collaboration with participating agencies and would

focus on Forest Service special status bat species. Survey methods could include a

combination of passive acoustic, active acoustic, and capture techniques such as mist

netting and harp traps. For any surveys capture methods, surveyors would have the

necessary permits to handle bats.

In its original condition 26, the Forest Service specified pre-construction surveys

to be conducted prior to disturbance or construction would be scheduled outside of the

limited operating period from March 1 through September 30. Prior to construction or

reconstruction within 1 mile of known locations, a strategy/mitigation plan for the landbased bat population at McCloud reservoir would be developed. PG&E alternative

condition 26 proposed that pre-construction surveys would be conducted to assess the

presence and roosting within areas of suitable habitat potentially affected by construction

activity, or construction would be scheduled outside of the limited operating period

during the maternity period of May 1 to August 31. PG&E would develop a strategy and

mitigation plan that would include noise disturbance distances for the land-based bat

population at McCloud reservoir.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 26. The provisions specified in Forest Service modified condition 26 are

similar to those specified in the Forest Service’s original condition 26, except that the

Forest Service has removed specific details of the plan components and monitoring

schedules from the 4(e) condition and placed them in the draft Terrestrial Biological

Management Plan, included as an enclosure to the filing (Forest Service, 2010d,

Enclosure 3).

In the draft Terrestrial Biological Management Plan (Forest Service, 2010d,

Enclosure 3), the Forest Service recommends that a survey of known special status bat

populations be conducted within 1 year of license acceptance, 6 years after license

acceptance, and every 10 years thereafter. Additionally, the Forest Service recommends

that the license conduct surveys for special status bats within other suitable habitat within

the project and project-affected areas, within 1 year of license acceptance and every

10 years thereafter. The Forest Service also recommends that PG&E conduct preconstruction surveys for special status bat species, no more than 30 days prior to ground

disturbance within 250 feet of suitable habitat, or follow a limited operating period of

May 1 through August 31. Furthermore, in the draft Vegetation and Invasive Weed

Management Plan, the Forest Service recommends the implementation of botanical

management actions to improve wildlife habitat, which could include maternity sites for

special status bats (section 3.3.3.2.1, Vegetation). In its November 24, 2010, filing,

PG&E accepts Forest Service modified condition 26 and withdraws its alternative

condition 26.
217

Our Analysis

Special status bat species can occur with other species of bats at day and night

roost sites. Surveys for known populations of special status bat species, along with preconstruction surveys or implementation of a limited operating period, would provide

information on the existing populations of special status bats (Townsend’s big-eared bat,

pallid bat, and western red bat) as well as other bat species and their overall condition,

and minimize any potential effects to these species from project O&M and construction

activities, and provide protection and conservation of roost sites Surveys for known

populations and for new populations within suitable habitat within 1 year of license

issuance and every 5 years thereafter would provide a baseline status assessment of

existing special status bat populations and be more protective of these existing

populations than the schedule recommended by the Forest Service in the draft Terrestrial

Biological Management Plan. We expect that overall, through the development and

implementation of the guidance and protocols for monitoring and surveying bat habitat

with project facilities and structures and project-related recreation sites, continued project

operations or proposed construction would not adversely affect special status bat species

within the project area.

Forest Carnivores

Forest carnivores, Sierra Nevada red fox, California wolverine, American marten,

and ringtail, could occur in the project area based on available habitat. Sierra Nevada red

fox and California wolverine are assumed to be in the project area; American martin is

likely to occur, and ringtail has been documented within 50 miles of the McCloud-Pit

project.

In its original condition 26, the Forest Service did not specify forest carnivores.

No other proposed mitigation and enhancement measures or alternative conditions were

proposed by PG&E.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 26. The provisions specified in Forest Service modified condition 26 are

similar to those specified in the Forest Service’s original condition 26, except that the

Forest Service has removed specific details of the plan components and monitoring

schedules from the 4(e) condition and placed them in the draft Terrestrial Biological

Management Plan, included as an enclosure to the filing (Forest Service, 2010d,

Enclosure 3).

In the draft Terrestrial Biological Management Plan, the Forest Service

recommends that pre-construction surveys for forest carnivores be conducted no more

than 30 days prior to construction, In its November 24, 2010, filing, PG&E accepts Forest

Service modified condition 26 and withdraws its alternative condition 26.

Our Analysis

It is unlikely that normal project O&M activities would affect any of these species.

All are mobile and would probably avoid areas of human-induced activity. This would
218

be especially true of active construction sites that would occur during construction of

proposed project facilities. We expect that, with the implementation of pre-construction

surveys for these species, there would be no adverse effects from project activities or

proposed construction. Undeveloped lands within the project area would continue to

provide potential habitat for these species and as a result could provide a long-term

benefit to individuals that are creating new territories.

3.3.4 Threatened and Endangered Species

3.3.4.1 Affected Environment

Valley Elderberry Longhorn Beetle

The VELB (Desmocerus californicus dimorphus) is listed as threatened under the

ESA. The VELB is associated with various species of elderberry (Sambucus spp.)

throughout the California Central Valley and foothills below 3,000 feet msl. Shasta

County is within the VELB range, though no critical habitat is designated for the VELB

in the county. The VELB occurs within riparian vegetation communities where it feeds

exclusively on elderberry in both adult and larval stages. Adult VELBs appear to feed

externally on the flowers and foliage of the elderberry. Adult females lay eggs in

crevices in the bark of the host elderberry plant (FERC, 2009). After hatching, larvae

spend one to 2 years feeding inside the plant. Prior to pupating, VELB larvae chew an

exit hole in the elderberry trunk for the emerging adult.

Botanical surveys documented 15 populations of elderberry containing plants with

stems greater than or equal to 1-inch diameter at ground level in areas surrounding the

McCloud reservoir, McCloud tunnel, Iron Canyon reservoir, Iron Canyon tunnel, and

Pit 7 afterbay. Most of the populations were sparse, with between one and 10

individuals. However, two populations contained between 11 and 50 individuals and one

population had more than 100. No survey of identified elderberry plant stems for exit

holes created by emerging VELB was conducted.

California Red-Legged Frog

The California red-legged frog (Rana aurora draytonii) is listed as threatened

under the ESA. This species occurs at elevations ranging from sea level to 5,000 feet msl

in wetlands; wet meadows; ponds and lakes; and pools in low-gradient, slow moving

stream reaches, with permanent sources of deep water and riparian vegetation. Eggs are

laid in ponds or backwater pools and attached to emergent vegetation. The tadpole larval

stage inhabits the same area as eggs, spending most of its time in submergent vegetation

or organic debris. Following metamorphosis, adults and juveniles are found in emergent

and riparian vegetation, undercut banks, semi-submerged root masses, open grasslands

with seeps, or springs with dense growths of woody riparian vegetation. Cattails,

bulrushes, and willows are good indicator species for potential presence of the frog.

Adults are typically associated with deep (greater than 0.7 meter), still or slow-moving

water. Juveniles prefer open, shallow aquatic habitats with dense submergents. Potential
219

habitat for adult California red-legged frog may extend 1 mile from potential aquatic

habitat.

Although the study area does not fall within the current distribution of the

California red-legged frog, the northern extent of the current range is in proximity to the

Lower Pit River. There are only six known populations of California red-legged frog in

the Sierra foothills, and their current range within that area is from Butte County to

El Dorado County. No California red-legged frog observations were made during

amphibian surveys in the project area. Although FWS has the California red-legged frog

on its species list for Shasta County, no records exist in the California Natural Heritage

Database (PG&E, 2006). Results of a survey conducted as part of a transmission line

separation project determined that the California red-legged frog has not been previously

identified at any location in the project-affected area or in the project vicinity. In

addition, PG&E determined the project area does not provide suitable habitat for the

California red-legged frog based on aerial photos, aerial video, and ground

reconnaissance. No designated critical habitat is located in the project area.

Northern Spotted Owl

The northern spotted owl, a medium-sized nocturnal raptor that inhabits mature

forest habitats, is listed as threatened under the federal ESA. Critical habitat has been

designated for the species, and a final recovery plan was released in May, 2008 (FWS,

2008).

The northern spotted owl generally inhabits older forested habitats because they

contain the structural characteristics required for nesting, roosting, and foraging.

Specifically, the northern spotted owl requires a multi-layered, multi-species canopy with

moderate to high canopy closure. Competition with the barred owl and loss, degradation,

and fragmentation of habitat due to timber harvest, fuel load management (thinning), and

natural disturbances (e.g., wildfires and wind storms) are identified as the primary threats

to this species. To a lesser extent, linear development projects (e.g., pipelines, power

lines, and roads) have been identified as potentially adversely affecting northern spotted

owl habitat because of fragmentation and destruction of habitat. The northern spotted

owl reproductive period extends from mid-February through September. The nesting

season for northern spotted owl extends from early April to mid- to late June. In the

weeks after fledging, the young are weak fliers and remain near the nest tree, and adults

continue to feed the young until late September.

The survey area included reasonably accessible suitable habitat within a 1.3-mile

distance (buffer) of project facilities and project-affected areas in which project

operations or recreational use could significantly affect the northern spotted owl or its

habitat. Areas surveyed included project water bodies (i.e., McCloud, Iron Canyon, Pit 6,

and Pit 7 reservoirs, and Pit 7 afterbay); project facilities (dams and diversion structures,

powerhouses, transmission and distribution lines, project roads included in the FERC

project boundary, the Ah-Di-Na gage (MC-1) on the McCloud River, and the McCloud

tunnel siphon at Hawkins Creek); and recreational sites (e.g., campsites, day-use areas,
220

boat launches). Habitat types in the survey area included Sierran mixed conifer,

ponderosa pine, montane hardwood-conifer, montane hardwood, montane riparian,

montane chaparral, mixed chaparral, lacustrine, and riverine. Survey elevations ranged

between about 1,070 and 4,600 feet msl with gentle to very steep topography.

No northern spotted owl individuals or active nests were detected in the project

area. A single female northern spotted owl of unknown reproductive status was detected

just outside of the project boundary buffer in the upper Mink Creek drainage, east of Van

Sicklin Butte. Three northern spotted owl activity centers were noted in the Iron Canyon

reservoir watershed in 2005, but there has been no recent documented activity at that

location (Forest Service, 2005, as cited in PG&E, 2006). A barred owl pair was found in

the Flatwoods / Pit 6 dam survey area, west of the 1.3-mile survey buffer, in an area

known as Reynolds basin (Nevares and Lindstrand, 2008c); this species is known to be

expanding its range into this area of California and is known to compete for territory with

the northern spotted owl, but these are not project-related effects.

Pacific Fisher

In December, 2000, the West Coast population of Pacific fisher was proposed for

listing under the ESA. Listing of the West Coast population segment of the Pacific fisher

was determined to be “warranted but precluded by other, higher priority listing actions,”

although the Pacific fisher is still considered a candidate species for federal listing. The

Pacific fisher is a Forest Service sensitive species and a California Fish and Game species

of special concern. Currently, only three small, isolated populations of the Pacific fisher

remain: native populations in northwestern California and the southern Sierra Nevada,

and a reintroduced population in the southern Oregon Cascades (Sierra Forest Legacy,

2008). The Pacific fisher dens in hollow trees, rotting logs, and rocky crevices of old

growth forests. Its diet consists of small mammals, fruit, truffles, and plants. This

species is primarily nocturnal, and its home range is from 50 to 150 square miles. Fishers

hunt exclusively in forested habitats and generally avoid opening areas.

The Forest Service and FWS have identified the Pacific fisher as potentially

occurring in the project vicinity based on tracks reported in the project vicinity in 1982,

and a Pacific fisher skull found on the ridge between Fisher Creek and Bald Mountain

Creek in the mid-1970s. More recently, a wildlife biologist observed a Pacific fisher

crossing FR 11 on the northeast side of Iron Canyon reservoir on April 25, 2007.

A field survey based on habitat mapping was conducted to identify potential

habitat for Pacific fisher within the project area. About 43 percent (15,607 acres) of the

study area was found to be potentially suitable Pacific fisher habitat, though the

distribution pattern and abundance of potentially suitable Pacific fisher habitat varied

throughout the study area, with changes often occurring in relation to elevation, aspect,

slope, or timber harvest history. Pacific fisher habitat types in the study area include

Sierran mixed conifer, ponderosa pine, montane hardwood-conifer, montane hardwood,

montane riparian, montane chaparral, and mixed chaparral, as classified using the CWHR
221

system. Survey elevations within the habitat ranged between 1,070 and 3,830 feet msl,

with gentle to steep topography.

Suitable habitat for Pacific fisher occurs in the vicinity of existing and proposed

project facilities, including project dams, powerhouses, and campgrounds. Connectivity

of suitable habitat is fairly high in most of the project area, with less suitability and

connectivity of habitat patches at the lower elevations around the Pit 6 and 7 reservoirs

and transmission lines, and at the upper elevations along the proposed McCloud

transmission line route (Nevares et al., 2009). PG&E’s relicensing approach regarding

Pacific fishers is to assume that the species is present, for at least part of the year, in

potentially suitable habitat within the project area.

3.3.4.2 Environmental Effects

Federally listed species could potentially be affected by project activities,

particularly construction activities that could alter habitat or disturb species.

PG&E proposes that before taking actions to construct new project features on

Forest Service lands (including but not limited to proposed recreation developments) that

may affect Forest Service special status species or their critical habitat, PG&E would

prepare a biological evaluation of the potential effect of the action on the species or its

habitat and submit it to the Forest Service for approval (measure 15). In coordination

with the Commission, the Forest Service may require mitigation measures for the

protection of the affected species. The biological evaluation would include procedures

to: (1) minimize adverse effects on special status species; (2) ensure project-related

activities meet restrictions included in site management plans for special status species;

and (3) provide implementation and effectiveness monitoring of measures taken or

employed to reduce effects on special status species. Additionally, at PG&E’s request,

the Commission appointed PG&E as the non-federal representative for informal

consultation with FWS under ESA. In this capacity, PG&E proposes to consult with FWS

and prepare biological assessment(s) as necessary to comply with section 7 of the ESA.

The Forest Service’s original and modified condition 11 is generally consistent

with PG&E’s proposed measure. In its November 29, 2010, filing, the Forest Service

does not include modifications to condition 11.

Our Analysis

Identification of potential effects related to new construction is integral to

protection of federal listed special status species and the minimization or mitigation of

unavoidable effects that could occur. The proposed measure to require the development

of a biological evaluation to be submitted to the Forest Service would provide an

important step in identification of potential effects as well as mechanisms for minimizing

effects. In addition, federal agencies, including the Forest Service and the Commission,

could require mitigative measures for protecting listed species. Both PG&E measure 15

and Forest Service condition 11 are consistent in providing the necessary guidance for
222

ensuring that the development of a biological evaluation would adequately identify,

protect, and mitigate potential effects related to new construction within the project.

Valley Elderberry Longhorn Beetle

Project O&M activities that have the potential to adversely affect VELB habitat

include vegetation trimming or clearing and herbicide applications that could damage or

kill the elderberry host plant for VELB. Recreational uses including camping have the

potential to damage elderberry plants at Deadlun Campground, Hawkins Landing

Campground, and dispersed recreation sites at Iron Canyon and McCloud reservoirs.

Measures for protection of elderberry are specified in PG&E’s programmatic

biological opinion (1-1-01-F-0114) and incidental take permit (FWS, 2003). This

consultation outlines routine operation, maintenance, and emergency activities associated

with PG&E’s gas and electric facilities that may have the potential to affect elderberry

plants. Avoidance, minimization, and conservation measures described in the

programmatic biological assessment include:

 Provide funding for the acquisition or long-term management of up to

1,000 acres of high quality habitat adjacent to existing VELB populations in

the Sacramento and San Joaquin valleys.

 Conduct elderberry surveys within a minimum of 20 feet from a project

maintenance site. Flag and avoid elderberry plants found within the project

footprint.

 Provide environmental training and education of personnel and contractors

involved with project operation, maintenance, and emergency activities.

 Avoid use of herbicides within 20 feet of elderberry plants except for stump

cut treatment of removed trees and clearing at the base of certain power poles

or towers in compliance with California Public Resources Code section 4292.

 Where possible, fell trees directionally or remove in sections so as to avoid the

20-foot zone around existing elderberry plants.

 Implement erosion control measures if ground is disturbed during maintenance

activities in the 20-foot zone around elderberry plants.

 Where feasible, trim elderberry plants rather than remove them.

PG&E proposed to apply these measures to routine O&M activities. In its original

condition 26, the Forest Service specified that suitable habitat should be monitored once

every 5 years for VELB individuals. PG&E alternative condition 26 proposes that

monitoring of known elderberry populations would occur every 5 years concurrent with

surveys conducted for the Vegetation and Invasive Weed Management Plan. In addition,

PG&E alternative condition 26 proposes to conduct pre-construction surveys for potential

VELB habitat and follow reasonable and prudent measures consistent with PG&E’s

Valley Elderberry Longhorn Beetle Conservation Program developed and approved in
223

the FWS-issued biological opinion (FWS, 2003). Periodic monitoring reports

summarizing VELB habitat locations and annual effects on elderberry at these locations

would be submitted to FWS. Avoidance, protection, or mitigation measures would

follow those outlined in the VELB conservation program, and the program specifications

including the terms and conditions of the 30-year take permit would be described.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 26. The provisions specified in Forest Service modified condition 26 are

similar to those specified in the Forest Service’s original condition 26, except that the

Forest Service has removed protective measures for the VELB from the draft Terrestrial

Biological Management Plan and has included these measures as part of the Vegetation

and Invasive Weed Management Plan.

The Forest Service recommends that surveys for known populations of elderberry

plants would occur within 1 year of plan approval and every 5 years thereafter;

comprehensive surveys for all populations, including new populations, would be

conducted within 1 year of plan acceptance and every 10 years thereafter; preconstruction surveys would be conducted no more than 30 days prior to ground

disturbance. Additionally, in the draft Vegetation and Invasive Weed Management Plan,

the Forest Service notes that the programmatic take permit for the VELB does not cover

routine construction or routine recreation O&M. The Forest Service recommends that,

after acceptance of a new license, PG&E consult with FWS regarding the potential

effects of these activities on VELB habitat. The Forest Service recommends that,

depending on the nature of the proposed new construction, a VELB protection plan

similar to the one developed for Pit 3, 4, and 5 project may provide a suitable mechanism

to protect VELB habitat during new construction and when performing recreation facility

O&M. In its November 24, 2010, filing, PG&E accepts Forest Service modified

condition 26 and withdraws its alternative condition 26.

Our Analysis

Within the project area, the VELB conservation program established and approved

by FWS in its 2003 biological opinion provides adequate protection for elderberry

populations. Avoidance, protection, or mitigation measures would follow those outlined

in the VELB conservation program.

The Forest Service’s original condition 26 specifies monitoring for VELB once

every 5 years in suitable habitat; however, PG&E alternative condition 26 proposes to

extend monitoring to include pre-construction monitoring and states that avoidance,

protection, and mitigation measures for routine O&M of the hydroelectric project would

be consistent with those outlined in the VELB conservation program already in place and

approved by FWS. Furthermore, in the draft Vegetation and Invasive Weed Management

Plan (Forest Service, 2010d, Enclosure 3), the Forest Service recommends that surveys

for VELB habitat be conducted concurrent with monitoring and protection of botanical

populations essential for wildlife habitat (3.3.3.2.1, Vegetation). Comprehensive surveys

for all populations of elderberry plants within 1 year and every 10 years thereafter, along
224

with any required pre-construction surveys and monitoring of known populations within

the first year of license issuance and every 5 years thereafter would provide information

on the existing populations elderberry and their overall condition, and minimize any

potential effects to elderberry populations within the project area from O&M activities.

Implementation of pre-construction surveys, consultation with FWS, and

avoidance, protection, or mitigation measures consistent with those outlined in the VELB

conservation program would minimize effects on the population of elderberry located

along the proposed access road corridor from the construction of the Pit 7 afterbay

powerhouse and future construction activities.

California Red-Legged Frog

No potential habitat was identified within the project area using aerial photos,

video, and ground reconnaissance. Project reservoirs have limited emergent vegetation

for breeding, limited availability of sheltered shoreline for adults, and predatory fish

species. In addition, no California red-legged frogs were observed during intensive

surveys of the project area for aquatic reptiles and amphibians, including northwestern

pond turtle and foothill yellow-legged frog.

No specific PG&E measure or Forest Service conditions have been developed for

the California red-legged frog.

Our Analysis

Because the project area does not support a California red-legged frog population

or appropriate habitat for the species, we believe that normal project O&M or proposed

construction would have no effect on California red-legged frogs.

Northern Spotted Owl

The northern spotted owl is known to be particularly sensitive to human

disturbance and habitat alterations during its reproductive period (February 15 through

September 30). Prolonged disturbance can reduce the ability of owls to detect prey,

disrupt flight responses, reduce nest attentiveness, and decrease the rate of food delivery

to the nest (FWS, 2008). These behavioral responses can lead to nest abandonment or

failure. Although no individuals or active nests were detected within the project area, and

project O&M or recreation activities are unlikely to affect this species, a majority of the

project and project-affected area occurs in both suitable and designated northern spotted

owl habitat.

Transmission lines can be hazardous to birds, especially raptors such as the

northern spotted owl. Birds touching lines can be electrocuted or badly injured if directly

striking a line. Existing project transmission lines meet or exceed APLIC standards to

prevent electrocution of birds with the exception of the Pit 5 distribution line that

contains some poles that are not in compliance. PG&E measure 16 proposed, the Forest

Service’s original condition 26 specified, and Forest Service modified condition 26

specifies avian collision and electrocution hazard prevention measures (see
225

section 3.3.3.2.2, Wildlife, General Wildlife). In its original condition 26, the Forest

Service specified monitoring for northern spotted owl within 0.25 mile of suitable habitat

in the project area once every 5 years. Surveys conducted once every 10 years in suitable

habitat would identify new individuals, pairs, or nest sites. Lastly, surveys would be

conducted prior to any disturbance activities, or PG&E could schedule construction or

disturbance activities outside of the limited operating period of February 1 through

July 9.

PG&E alternative condition 26 proposed to eliminate the requirement for northern

spotted owl surveys within 0.25 mile of suitable habitat in the project area once every

5 years, and within suitable habitat once every 10 years. Instead, PG&E proposed preconstruction surveys in suitable habitat within 1.3 miles of proposed construction.

Surveys would follow standard protocols for the species. Alternatively, PG&E could

schedule construction activity for outside of the limited operating period of February 1 to

July 9.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 26. The provisions specified in Forest Service modified condition 26 are

similar to those specified in the Forest Service’s original condition 26, except that the

Forest Service has removed specific details of the plan components and monitoring

schedules from the 4(e) condition and placed them in the draft Terrestrial Biological

Management Plan, included as an enclosure to the filing (Forest Service, 2010d,

Enclosure 3).

In the draft Terrestrial Biological Management Plan (Forest Service, 2010d,

Enclosure 3), the Forest Service recommends that surveys for northern spotted owl be

conducted as specified in the most recent FWS protocol within 0.25 mile of suitable

habitat prior to construction or habitat removal, or that PG&E follow a limited operating

period from February 15 through July 10. In its November 24, 2010, filing, PG&E

accepts Forest Service modified condition 26 and withdraws its alternative condition 26.

Our Analysis

The northern spotted owl is not known to exist within the project area, though

potential habitat does exist. We expect that pre-construction surveys as proposed by

PG&E and recommended by the Forest Service would sufficiently minimize any effects

from disturbance to northern spotted owl that project construction activity could cause.

Alternatively, avoidance of construction activity during the limited operation period

would also protect any individuals within the project area from construction activity. A

limited operating period of February 1 through July 9 as proposed by PG&E and

specified in the Forest Service’s original condition 26 would be more protective of the

northern spotted owl than the limited operating period of February 15 through July 10

recommended by the Forest Service in the draft Terrestrial Biological Management Plan.

We expect that specific standards for transmission lines developed by APLIC that are

employed along proposed power lines and retrofitted on existing lines would avoid or

minimize avian electrocution hazards to this species if it occurs within the project area.
226

We believe that relicensing the existing project, continued normal O&M activities, and

proposed construction of new facilities are not likely to adversely affect northern spotted

owl in the project area.

Pacific Fisher

The Pacific fisher’s association with late successional forest habitats and its

avoidance of human activity makes the species highly sensitive to anthropogenic habitat

loss, degradation, and fragmentation related to forest management, development, and

noise disturbance. Prolonged disturbance, forest management, and infrastructure

development can affect Pacific fishers by altering normal behavior, causing displacement

from preferred habitat, and decreasing reproductive success and individual health (Powell

and Zielinski, 1994, and 50 CFR 17 as cited in PG&E, 2009a). Potentially suitable

Pacific fisher habitat was identified throughout the project area. PG&E does not own or

manage forest lands in the project area and therefore does not have an ongoing effect on

the general quality and quantity of Pacific fisher habitat. Although hazard tree removal

around project and recreational facilities does occur as part of project O&M, it is unlikely

that fishers would roost or den in proximity to human activity, and project effects as a

result of hazard tree removal are unlikely.

In its original condition 26, the Forest Service specified that the development of a

Terrestrial Biological Management Plan should provide surveys be conducted once every

5 years in suitable habitat within the project and project-affected areas. PG&E alternative

condition 26 proposed, for the Pacific fisher, to eliminate the requirement for surveys

once every 5 years and, instead provide for pre-construction surveys in areas of suitable

habitat within 0.5 mile of any planned construction. Methods for the surveys would

involve passive detection systems, such as baited camera stations; however, survey

methods could be developed from review of scientific literature and any available

standard protocols species to fisher surveys.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 26. The provisions specified in Forest Service modified condition 26 are

similar to those specified in the Forest Service’s original condition 26, except that the

Forest Service has removed specific details of the plan components and monitoring

schedules from the 4(e) condition and placed them in the draft Terrestrial Biological

Management Plan, included as an enclosure to the filing (Forest Service, 2010d,

Enclosure 3).

In the draft Vegetation and Invasive Weed Management Plan (Forest Service,

2010d, Enclosure 3), the Forest Service has changed its recommendation to agree with

the staff recommendation from the draft EIS regarding the implementation of preconstruction surveys for the pacific fisher, which would be conducted no more than

30 days prior to ground disturbance. In its November 24, 2010, filing, PG&E accepts

Forest Service modified condition 26 and withdraws its alternative condition 26.
227

Our Analysis

It is unlikely that normal project O&M activity or proposed construction would

have an effect on the Pacific fisher. We expect that pre-construction surveys, as proposed

by PG&E and recommended by the Forest Service in the draft Terrestrial Biological

Management Plan, would provide adequate protection for Pacific fisher that may inhabit

the project area based on this species’ known behavior and the large area for potential

occurrence within the project. As a result, relicensing of the existing project, continued

normal O&M activities, and proposed construction of new facilities are not likely to

adversely affect Pacific fisher in the project area.
228

3.3.5 Recreation Resources

3.3.5.1 Affected Environment

Regional Recreation Resources

Opportunities for recreation within the region surrounding the project are plentiful.

The project partially lies within and adjacent to the Shasta National Forest which

provides a variety of formal and informal recreational facilities and opportunities. Much

of the National Forest lands are open to the public for recreation. Regional recreational

opportunities include fishing, camping, boating, hiking, scenic/wildlife viewing, hunting,

and general day-uses such as picnicking and swimming (PG&E, 2008a).

Recreational resources outside of the project but within the region surrounding the

project include areas that provide river-based fishing opportunities similar to those

available in the Lower McCloud River, or reservoir-related activities similar to those

available at McCloud and Iron Canyon reservoirs. These areas are all located in northern

California, and most are located within 100 miles of the project area (PG&E, 2008a).

Regional bank-fishing resources include the upper McCloud River, Fall River, Hat Creek,

Burney Creek, upper and lower Sacramento River, Pit River (above the project), Klamath

River, and Trinity River. Regional reservoir-based activity resources include Lake

Siskiyou, Shasta Lake, Medicine Lake, Lake Shastina, Castle Lake, Iron Gate reservoir,

Whiskeytown Lake, Lake Britton, Baum Lake, and Trinity Lake (PG&E, 2008a).

The project is geographically close to PG&E’s Pit 3, 4, and 5 Project (FERC

No. 233) with portions of the McCloud-Pit Project no more than 30 miles from the Pit 3,

4, and 5 Project (PG&E, 2008a). Thus, the regional recreational resources for the project

overlap with those of the Pit 3, 4, and 5 Project. Recreational opportunities at the Pit 3, 4,

and 5 Project generally occur in the area surrounding Lake Britton and within the

Pit River Canyon. Lake Britton provides opportunities and facilities for camping,

picnicking, boating, swimming, wildlife viewing, fishing, and hiking. Developed

facilities at Lake Britton include 155 developed campsites, two developed boat launches,

and three developed picnic areas (EDAW, 2001 as cited in PG&E, 2008a). The eastern

section of Lake Britton provides more primitive and dispersed recreational opportunities,

while the western portion of the reservoir upstream of the Pit 3 dam provides more

developed recreational opportunities, such as developed campgrounds and day-use areas

(FERC, 2004). The Pit River Canyon provides more undeveloped, dispersed recreational

opportunities, such as trout fishing, camping, hiking, whitewater boating, and sightseeing

(FERC, 2004).

Lake Siskiyou offers recreational opportunities such as boating, camping,

swimming, fishing, and windsurfing. The reservoir provides more than 300 developed

campsites, a boat launch, a marina, and two developed picnic areas (EDAW, 2001 as

cited in PG&E, 2008a).

Shasta Lake, located in the Whiskeytown Shasta-Trinity National Recreation

Area, offers recreational opportunities such as motorized (most notably houseboating)
229

and non-motorized boating, swimming, fishing, camping, picnicking, and hiking. Shasta

Lake provides seven developed boat launches, three developed picnic areas, and more

than 300 developed campsites (EDAW, 2001 as cited in PG&E, 2008a). Most of the

recreation facilities are operated by the Forest Service, except for a few private marinas

(PG&E 2008a).

Whiskeytown Lake, located in the Whiskeytown Shasta-Trinity National

Recreation Area, offers recreational opportunities such as motorized and non-motorized

boating, swimming, fishing, camping, picnicking, hiking, and sailing. Whiskeytown

Lake provides three developed boat launches and four developed picnic areas (EDAW,

2001 as cited in PG&E, 2008a). Many of the recreation sites are managed by the Park

Service, and day-use activities are encouraged rather than overnight use; however, there

are more than 100 developed campsites along the shoreline of the reservoir (PG&E,

2008a).

Baum Lake is located near the town of Cassel on Hat Creek. All motorized

boating (except electric trolling motors) is prohibited on the lake, making it open only to

non-motorized boating. The primary activity at Baum Lake is fishing, similar to the nonreservoir segments of Hat Creek. A formal fishing access with a primitive boat launch is

provided at the reservoir (PG&E, 2008a).

Trinity Lake is located entirely within the Whiskeytown Shasta-Trinity National

Recreation Area, and most of the recreation facilities are operated by the Forest Service,

except for a few private marinas (PG&E 2008a). Recreational opportunities at Trinity

Lake include motorized and non-motorized boating, swimming, fishing, camping,

picnicking, and hiking. There are nine developed boat launches, three developed picnic

areas, and more than 400 developed campsites at the lake in addition to many primitive

boat-in camping areas scattered along the shoreline (EDAW, 2001 as cited in PG&E

2008a).

Medicine Lake, located in the Modoc National Forest, provides fishing and

boating opportunities. It has one improved and two unimproved launch ramps and four

campgrounds suitable for tent, recreational vehicle (RV), or group camping. All boating

is allowed at Medicine Lake as well as water-skiing, jet-skiing, and swimming

(FishersNet, 2010). Iron Gate reservoir provides camping, boating, and fishing

opportunities with developed campgrounds suitable for tents, RVs, or trailers, and

improved boat launching facilities (FishersNet, 2010). Lake Shastina provides

opportunities for fishing, all types of boating, water-skiing, and swimming. Lake

Shastina also has a marina, tennis, golf, and a water slide (FishersNet, 2010). Fishing,

camping, and hiking are available at or near Castle Lake, located mostly within ShastaTrinity National Forest, including a trail that leads into the adjacent Castle Crags

Wilderness Area and connects to the Pacific Crest National Scenic Trail (Forest Service,

2010b and 2010c).

There are a number of river-based fishing opportunities similar to those available

in the Lower McCloud River located in the region surrounding the project. These include
230

the following: the McCloud River above McCloud reservoir which provides developed

campgrounds and dispersed camping opportunities; Fall River with limited developed

recreation facilities or dispersed camping opportunities; Hat Creek, which is partially

located in the Lassen National Forest with many nearby recreation facilities; Burney

Creek, which flows through Shasta National Forest lands and has developed recreational

facilities at the McArthur-Burney Falls State Park; the Sacramento River, which provides

angling opportunities, limited dispersed camping opportunities, and a developed

recreation facility at Castle Crags State Park; Pit River, which provides angling

opportunities with a few developed recreation facilities and dispersed camping

opportunities; and the Trinity River located nearly entirely in Shasta-Trinity National

Forest, which provides fishing opportunities and a number of developed recreational

facilities and dispersed camping opportunities (PG&E, 2008a).

There are a number of whitewater boating opportunities in the region surrounding

the project, many of which are similar to those available in the Lower McCloud River in

the region surrounding the project. The Lower McCloud River below McCloud reservoir

is classified as Class III-IV whitewater. The following stream and river reaches in the

region are classified as Class III-IV: the McCloud River above McCloud reservoir

(Fowler Camp to McCloud reservoir); Pit River (Fall River Mills to PG&E’s Pit 1

powerhouse); Antelope Creek (Hogsback Road to Cove Grove Road); Canyon Creek

(bridge 8.5 miles upstream of Junction City to Junction City); Coffee Creek (Coffee

Creek Road to Trinity River); North Fork Feather River (Caribou to East Branch North

Fork Feather River); West Branch Feather River (Whiskey Flat to Dean Road);

Grindstone Creek (Grindstone Road to Road 306); Sacramento River (Box Canyon dam

to Castle Crag); North Fork Salmon River (Idlewood Campground to Sawyers Bar);

South Fork Trinity River (East Fork/South Fork confluence to Scott Flat Campground

and Klondike Mine to Oak Flat or Hyampom Gorge); Trinity River (Tangle Blue Creek

to Clair Engle Lake); Little Cow Creek (Phillips Drive to Buzzard Roost Road)

(American Whitewater, 2010). Additionally, PG&E’s Pit 3, 4, and 5 Project provides

recreation streamflow releases, including Class III (the Pit River from Lake Britton to Pit

3 powerhouse), Class IV (the Pit River from Pit 4 dam to Pit 4 powerhouse), and Class

III+(V) (the Pit River from Pit 5 dam to Pit 5 powerhouse) whitewater opportunities.

Two Forest Service developed campgrounds, Ash Camp and Ah-Di-Na, and

The Nature Conservancy’s McCloud River Preserve, which is used by some anglers, are

located on the Lower McCloud River downstream of the project. The Lower McCloud

River extends 24 river miles from McCloud dam to Shasta Lake and is considered one of

the premiere trout streams in California, but only the upper 9 miles of this 24-mile reach

have land-based public access.

The Pacific Crest Trail, which is not part of the project, is a national scenic trail

spanning over 2,650 miles from Mexico to Canada. The trail crosses the Lower McCloud

River near Ash Camp via a wooden foot bridge. The Pacific Crest Trail crosses Ah-Di

Na Road (FR 38N53) about 0.5 mile upstream of Ah-Di Na campground.
231

Project Area Recreation Resources

There are three developed recreation areas within the project boundary: Tarantula

Gulch boat ramp at McCloud reservoir; and Deadlun Creek Campground and Hawkins

Landing Campground and boat ramp at Iron Canyon reservoir. All of these are located

within the James B. Black Development (see figures 3-2 and 3-3).

McCloud Reservoir

The Tarantula Gulch boat ramp was constructed and is operated by the Forest

Service (table 3-30 and figure 3-2). Tarantula Gulch boat ramp has a boat launch ramp

and a developed picnic area. The single-lane concrete boat launch ramp has a loading

dock with parking for 22 vehicles with trailers and a nearby overflow parking area.

PG&E states that the bottom of the boat ramp is 1 foot below the normal minimum

operating reservoir level (elevation 2,634 feet) and typically provides boater access

during the entire recreation season. The Forest Service reports that sediment and debris

accumulate on the ramp and occasionally impede boat launching.

The majority of lands surrounding McCloud reservoir are privately owned, with

NFS and PG&E-owned lands that are accessible to the public located on the southern end

of the reservoir extending along FR 38N11 from near the access road to Tarantula Gulch

(FR 38N81) and continuing across McCloud dam to Star City Creek. Most of the

publicly accessible lands are located between FR 38N11 and the reservoir shoreline.

Dispersed recreation is allowed on PG&E and NFS lands, unless otherwise designated.

PG&E identified nine user-created dispersed recreation sites at lower-gradient access

points accessible from FR 11 or Star City Road (FR 38N04Y) around McCloud reservoir

and a dispersed campsite on an island in the reservoir. The Star City Creek area is the

largest dispersed site at McCloud reservoir with space to comfortably accommodate three

to five user groups at one time. The area is typically used for camping, although the site

is not formally designated for such use. The Hearst Corporation is a private landowner

with large property holdings that surround McCloud reservoir. When the project license

was issued in 1961, the Forest Service and The Hearst Corporation were completing a

land exchange to consolidate ownership in a portion of the forest and to provide for

public access to McCloud reservoir. In a 1963 agreement, The Hearst Corporation

donated land to the Forest Service that is currently used as the Star City day-use area.

The Hearst Corporation donated about 95 acres of land around the southern shore to the

Forest Service in 1969, while the terms of the donation were laid out in the 1965 MOU

developed during the land exchange.
232

Table 3-30. Recreation Facilities at McCloud Reservoir. (Source: PG&E, 2009a and

2008b, and staff)

Site Name Facilities

Tarantula Gulch Boat

Ramp (also known as the

Lake McCloud Boat

Launch)

Single-lane concrete boat launch ramp, a loading dock,

3 picnic tables, 4 wildlife-resistant trash receptacles,

22 parking spaces for vehicles with trailers, vault

restroom with 2 unisex accessible stalls, overflow parallel

parking with unmarked spaces
233

Figure 3-2. Existing and proposed recreation facilities at McCloud reservoir. (Source:

PG&E, 2009a)
234

Iron Canyon Reservoir

There are two developed recreation areas at Iron Canyon reservoir: Hawkins

Landing Campground and boat ramp, owned and operated by PG&E, and Deadlun

Campground, which is operated by the Forest Service (table 3-31 and figure 3-3).

Hawkins Landing Campground and boat ramp have the only boat launch ramp on

Iron Canyon reservoir and provides campsites. None of the Hawkins Landing facilities

are Americans with Disabilities Act (ADA) accessible and facilities in the campground

are in poor condition. No formal parking is available at the boat launch and the number

of vehicles that the boat launch area can accommodate depends on reservoir elevation.

Normal project operations can cause the reservoir to fluctuate on a daily basis, which

affects the availability of parking at the shoreline near the launch. When the reservoir is

at full pool (2,664 feet), visitors park vehicles in the campground. As the reservoir

elevation lowers, exposing more shoreline, visitors park along the shoreline, thereby

increasing the potential number of vehicles that can park near the launch area. At the

minimum operating pool elevation (2,593 feet), the end of the boat launch (2,610 feet) is

out of water and visitors have difficulty launching or cannot launch boats. Since 1996,

PG&E has voluntarily maintained the reservoir water surface elevation above 2,615 feet

to keep the boat ramp useable during the primary recreation season from May 15 to

October 15.

The Forest Service Deadlun Campground has about twice as many campsites as

Hawkins Landing; however, the sites are positioned away from the shoreline at the back

of the Deadlun Creek Cove, making it less appealing to visitors.

Iron Canyon reservoir is easily accessible from Big Bend, California, via FR 11

and Oak Mountain Road, and is accessible via a lengthier route from the town of

McCloud (PG&E, 2008b). A section of FR 11 between McCloud reservoir and Iron

Canyon reservoir is narrow, rocky, and very rough. Hawkins Landing is the first

developed recreation area users pass when traveling north from the town of Big Bend,

California.

The majority of lands surrounding the reservoir are PG&E-owned or NFS lands.

User-created access trails (pedestrian and OHV) originate from both campgrounds and

nearby areas providing dispersed shoreline access. PG&E has identified 22 dispersed

recreation sites around Iron Canyon reservoir with heavily used dispersed recreation sites

at the areas adjacent to Deadlun Campground and Iron Canyon reservoir spillway.
235

Table 3-31. Recreation facilities at Iron Canyon reservoir. (Source: PG&E, 2009a and

2008b, and staff)

Site Name Facilities

Deadlun Campground 27 campsites with fire rings and picnic tables, 3 vault

restrooms with single, unisex, ADA-accessible stalls,

overflow parallel parking with unmarked spaces

Hawkins Landing

Campground and Boat

Ramp

Single-lane concrete launch ramp, 11 campsites with fire

rings and picnic tables, 1 working non-potable water hand

pump, trash receptacle, 2 vault toilets

Lower McCloud River and Hawkins Creek Crossing

Recreation areas downstream of McCloud reservoir include the area at Hawkins

Creek crossing (inside the project boundary) and the Lower McCloud River (outside the

project boundary). Hawkins Creek crossing is a cleared level area where the McCloud

tunnel crosses Hawkins Creek about one mile above the confluence with the Lower

McCloud River. PG&E documented two dispersed recreation sites at the project near

Ash Camp, a dispersed campsite on Hawkins Creek at Hawkins Creek tunnel that is

accessible via the PG&E project road, and a dispersed campsite on the PG&E spoil pile

area on Hawkins Creek that is just north of the Hawkins Creek tunnel (PG&E, 2008b).

The Lower McCloud River extends 24 river miles from McCloud dam to Shasta

Lake, but only the upper 9 miles of this 24-mile reach have land-based public access. No

project lands are located along the Lower McCloud River except for the area immediately

below McCloud dam,
236

Figure 3-3. Existing and proposed recreation facilities at Iron Canyon reservoir.

(Source: PG&E, 2009a)
237

Pit River (James B. Black Powerhouse, Pit 6 and Pit7 Reservoirs, and Pit 7

Afterbay)

There are no developed recreation sites in the Lower Pit River; however, dispersed

recreation is evident in a few locations.

User-created trails and dispersed camping can be found along the Lower Pit River

across from the James B. Black powerhouse.14 The powerhouse is easily accessible via

Big Bend Road to the Pit 5 Road from Big Bend, California (PG&E, 2008b).

Public vehicular traffic to Pit 6 reservoir is available by a gated road about

0.5 mile from Pit 6 dam. A dispersed recreation site is located near Pit 6 dam about

0.5 mile downstream of the dam. The Pit 6 dam is easily accessible from Big Bend,

California, via Big Bend Road to Cove Road to the Pit 6 Powerhouse Road. There is an

angler trail to the Pit 7 reservoir (Pit 6 tailwater) that originates from the Pit 6

Powerhouse Road within sight of Pit 6 dam (PG&E, 2008b).

PG&E documented a dispersed recreation site at the base of Pit 7 dam. Public

access to the Pit 7 dam is limited to foot traffic through a PG&E-maintained gate across

the access road about 1.5 miles from the dam.

User-created trails and dispersed camping can be found at Fenders Flat in the area

of the Pit 7 afterbay (figure 3-4). Fenders Flat is a 5- to 10-acre informal dispersed

recreation area located between steep topography to the south and the Pit 7 afterbay to the

north. The access road to this area is deeply rutted and only suitable for high clearance

vehicles.

Shore lands within the project at the Pit 7 afterbay are administered by the Forest

Service (PG&E, 2008a). Because the water level rapidly fluctuates in response to the

Pit 7 powerhouse operation, public access to the Pit 7 afterbay is not allowed. A Shasta

County boating ordinance prohibits swimming and boating in the afterbay due to public

safety concerns (PG&E, 2006 as cited in PG&E, 2008a). For safety reasons, the afterbay

is fenced and posted with warning signs to prohibit shoreline access and boating on the

afterbay. Flow through the Pit 7 afterbay dam creates a dangerous hydraulic condition

for fishermen accessing the site by boat from Shasta reservoir. There is a Forest Service

unimproved car-top boat launch directly below the Pit 7 afterbay dam that provides

boater access to the pit arm of Shasta Lake during late winter and early spring when high

reservoir levels allow boat launching (PG&E, 2008a).

14 According to PG&E, a developed recreation site is planned for this location as

part of PG&E's Pit 3, 4, 5 Project license implementation.
238

Figure 3-4. Existing and proposed recreation facilities at Pit 7 reservoir and Pit 7

afterbay dam. (Source: PG&E, 2009a)
239

Recreational Use

PG&E collected recreational use data using direct visual observations during the

2007 and early 2008 recreation season to develop visitation estimates. Recreation use

within the project boundary occurs at the three developed recreation areas, and dispersed

recreation use occurs in a number of areas throughout the project boundary. For purposes

of the relicensing studies, the recreation season for the project was defined to be between

April 26 (or first open access after snow melt) to November 15, with the primary

recreation season from May 15 to October 15.

Recreation uses at the project include camping, fishing, boating, swimming, water

skiing, hiking, picnicking, sightseeing, wildlife viewing, off-road driving, and hunting.

McCloud reservoir supports various recreation activities. Based on PG&E’s visitor use

surveys conducted during the relicensing studies, the primary activities at McCloud

reservoir include angling (69 percent); water-based recreation activities (swimming, jet

skiing, water skiing, wakeboarding) (18 percent ); viewing scenery, wildlife, and nature

(16 percent); camping (12 percent); and motorized and non-motorized boating

(11 percent) (PG&E, 2008d). The primary activities at Iron Canyon reservoir include

angling (80 percent); viewing scenery, wildlife, and nature (13 percent); and camping

(13 percent). Visitors to the Lower McCloud River participated in fewer recreation

activities, with fly fishing being the most common. The primary activities in the area

near the Pit 7 afterbay include angling (55 percent), camping (18 percent), and biking

(18 percent). Table 3-32 reports the primary recreation activities of visitors to the project

based on PG&E’s visitor use survey. Generally, visitors spend most of their time

participating in these recreation activities while at the project.
240

Table 3-32. Primary activity by general area within the project. (Source: PG&E, 2008d,

as modified by staff)

Percentage of Respondents

Activities McCloud

Reservoir

Iron Canyon

Reservoir

Lower

McCloud River

Pit 7

Afterbay

Angling 69 80 84 55

Camping 12 13 17 18

Picnicking 3 2 1

Wet recreation (swim,

personal watercraft, water

skiing, wakeboarding)

18 2 2

Boat (any) 11 2 0

Viewing scenery, wildlife,

nature/photography

16 13 8 9

Hiking (day and

backpacking)

3 1 3

Hunting 2 4

Scenic driving

Biking 3 1 1 18

Note: Totals more than 100 percent due to some respondents choosing more than one

primary activity.

Annual recreational use for the project was estimated at close to 33,400 visitors.15

Visitors to the project predominantly live in neighboring counties or the San Francisco

Bay area. Traffic counters recorded traffic volumes during the study period; however,

because of the configuration of the road network and dispersed use around the project,

traffic volume estimates were not the same as numbers of individual users. As such,

visitor estimates based on traffic volumes resulted in visitor use estimates that were

inconsistent with the number of vehicles-at-one-time (VAOT) or people-at-one-time

(PAOT) reported from direct visual observations. Table 3-33 presents PG&E’s estimates

of existing visitor use using the observation method.

15 Visitor estimates based on direct visual observation do not include non-project

visitors or field study staff and is based on evidence of actual visits to project recreation

areas.
241

Table 3-33. Project study area current use estimates by month using observation

method. (Source PG&E, 2008d, as modified by staff)

Month McCloud

Reservoir

Iron

Canyon

Reservoir

Lower

McCloud

Rivera

Pit 6

Reservoirb

Pit 7

Reservoirc

Pit 7

Afterbay

April 908 621 814 − 8 368

May 2,620 932 1,473 − 8 257

June 3,862 648 1,250 − 8 354

July 4,324 499 648 − 8 161

August 4,945 438 689 − 8 206

September 2,956 400 525 − 8 131

October 378 391 1,339 − 8 271

November 220 220 281 − 8 199

Total 20,212 4,148 7,019 0 64 1,947

a

PG&E’s relicensing study included areas outside the project boundary in this

study area, including the Ah-Di-Na Campground and Ash Camp Campground.

b Nobody was observed recreating within the Pit 6 reservoir during the relicensing

study.

c

Estimate based on assumption from observations of people at the sites and

conversations with PG&E operators and staff familiar with the Pit 6 dam area (within

Pit 7 reservoir) that indicated visitors rarely fish the Pit 6 dam tailwater.

McCloud Reservoir

Visitor survey results indicate that the majority of visitors to McCloud reservoir

come from Siskiyou and Shasta Counties (counties adjacent to or surrounding the

project); however, other visitors from northern Central Valley counties were also

represented in the survey results. PG&E's study results estimate that McCloud reservoir

supported about 20,133 recreation days in 2008 (PG&E, 2008d).16 Tarantula Gulch boat

ramp accounted for 92 percent of the visitation to McCloud reservoir, with overall

visitation of 55 percent occurring on weekdays and 44 percent occurring on weekends.

Tarantula Gulch boat ramp typically is the first opportunity visitors traveling from the

16 A recreation day is defined as any visit by an individual for any length of time

during a 24-hour period.
242

town of McCloud have to stop and view the reservoir. Vehicle count data was recorded

at times when project roads were covered in snow, indicating that the road to Tarantula

Gulch may have been accessible at times or there was possible snowmobile use.

In addition to launching boats, the site is popular with bank anglers and day-users.

Use levels are highest during the summer months. PG&E’s collaborative analysis of

study results with relicensing participants indicate the site is at or over capacity from

April to August.17 The study results show that the picnic area at the boat ramp is rarely

used, indicating that recreation use at the site is primarily for reservoir access and

shoreline uses. The picnic area’s location away from the water, the abundance of starthistle, and the lack of shade contribute to its undesirability for day-use. Results from

user surveys conducted at the boat ramp indicate there is growing conflict between nonboating visitors using the ramp as a swimming dock and fishing platform and visitors

launching and retrieving boats at the ramp.

Steep topography surrounding the reservoir limits the number and size of potential

recreation sites and results in concentrated uses at a few dispersed recreation sites. For

some users, these dispersed use sites provide the informal setting desired on trips to the

reservoir. Direct observation counts during the peak recreation months (May through

September) indicate that 12 vehicles are typically parked around the reservoir at

dispersed sites at any given time during daylight hours, resulting in multiple vehicles at a

number of locations. Star City Creek dispersed recreation area is the only site on

McCloud reservoir that can accommodate more than three user groups comfortably, and

the site consistently receives multiple user-groups throughout the recreation season. The

area is typically used for camping, although the site is not formally designated for such

use. Similar to Tarantula Gulch boat ramp, Star City is considered to be over capacity

from May to August and it is approaching capacity in April, September, and October.

Other popular dispersed areas include the parking area at the intersection of Tarantula

Gulch Road and FR 11, “Red Banks area,” and “Battle Creek.” The base of McCloud

dam receives modest amounts of recreation use from anglers and boaters putting into the

Lower McCloud River.

The recreational setting associated with boating on McCloud reservoir was

inventoried using the Water Recreation Opportunity Spectrum (WROS) through a

collaborative process that included interested relicensing participants. The WROS is a

tool to understand the type and location of six types of water-related recreation

opportunities, otherwise known as WROS classes. The six WROS classes range across a

spectrum of urban, suburban, rural developed, rural natural, semi-primitive, and primitive

classes. Each WROS class is defined by a particular “package” of activities, setting

attributes, experiences, and benefits. WROS classes of McCloud reservoir range from

semi-primitive (head of reservoir, Lick Creek arm, and middle of reservoir/island) to

17 Sites were determined to be over the physical capacity of the site when 35 to

40 percent of the vehicle spaces were filled on non-holiday weekends.
243

rural natural (main channel north of boat ramp, at Lick Creek, and at the bridge) to rural

developed (the boat launch arm, the area above the dam, and the main channel including

Battle Creek arm) (PG&E, 2009a and 2008c).

Iron Canyon Reservoir

Similar to McCloud reservoir, the greatest numbers of survey respondents at Iron

Canyon reservoir live in Siskiyou and Shasta Counties. PG&E estimates that the Iron

Canyon reservoir area supported about 4,163 recreation days in 2008 (PG&E, 2008d).

Developed recreation facilities (Hawkins Landing Campground and boat ramp and

Deadlun Campground) received 84 percent of the recreation use at Iron Canyon reservoir.

Traffic count data recorded at the developed recreation facilities indicate that visitors use

the campgrounds as their base while they explore and use dispersed areas throughout the

general area. Use levels of Hawkins Landing are highest in July and August when the

study results show the campground to be over capacity with slightly less use in the April

to June and September to November months. PG&E’s relicensing study results show

Deadlun Campground is below capacity during all months except for April and May

when use was approaching capacity.

The most popular water-based activities at Iron Canyon reservoir are motorized

and non-motorized boating and angling. At the dispersed recreation sites around Iron

Canyon reservoir, visitors typically participate in camping, driving OHVs, angling, or

general shoreline-based activities.

WROS classes of Iron Canyon reservoir range from semi-primitive (Gap Creek

arm, Little Gap Creek arm, Cedar Salt Log Creek arm, main body/island, Deadlun

Campground arm) to rural natural (the area above the dam and the area around Hawkins

boat ramp) (PG&E, 2009a and 2008c). These classifications capture the physical

disturbances visible from the water as well as the social setting and potential for

interaction between water and shoreline users.

Lower McCloud River

Visitor survey results indicate that visitors to the Lower McCloud River originate

from throughout California, with a lower percentage of respondents living in adjacent

counties than those visiting McCloud or Iron Canyon reservoirs, suggesting that the

Lower McCloud River has greater overall appeal. In addition, survey results indicate that

visitors to the Lower McCloud River are primarily anglers and do not visit the project

reservoirs, but rather focus activities and destinations along the Lower McCloud River

(below McCloud dam). According to survey results, these users also frequent other

regional rivers for angling (e.g., Upper Sacramento, Pit, and Trinity Rivers). Visitor

survey results indicate that although boating on the river does occur, the estimated

number of boating trips (both whitewater and access based) account for about five to ten

trips in most years depending on the water year type.

PG&E estimates that the Lower McCloud River supported about 7,050 recreation

days in 2008 (PG&E, 2008d). PG&E’s relicensing study area included Hawkins Creek
244

Crossing (inside the project) and areas outside the project boundary, including the Ah-DiNa Campground and Ash Camp Campground. Very few users were observed at the

Hawkins Creek crossing, but it is occasionally used by anglers fishing Hawkins Creek.

Pit River (James B. Black Powerhouse, Pit 6 and Pit 7 Reservoirs, and Pit 7

Afterbay)

Anglers seeking access to the Pit River comprise the majority of people using the

dispersed recreation sites near the James B. Black powerhouse, the base of Pit 6 and Pit 7

dams, and the Fenders Flat area. Recreational use of the dispersed recreation sites in

proximity to James B. Black powerhouse and Pit 6 dam is very low. During the study

period, there were no direct observations of recreational use occurring at the base of Pit 6

dam along Pit 6 Road. PG&E reports that the estimated 70 recreation days of use at this

area in 2002 is likely an accurate estimate of current use considering the lack of direct

observations during the 2007 and early 2008 study seasons. The use of the dispersed

access area across from the James B. Black powerhouse was included in the study area

for PG&E’s Pit 3, 4, 5 Project license application, whereby PG&E concluded the area

received modest use. PG&E estimates that the Pit 7 afterbay supported about

1,947 recreation days in 2008 (PG&E, 2008d).

The flat water boating WROS inventory for the Lower Pit River ranged from a

class of rural developed on Pit 6 reservoir to rural developed (put-in below Pit 6 dam,

Montgomery Creek node, and Pit 7 dam node), rural natural (private camp node and

lower Pit 7 reservoir node), and semi-primitive (Pit 7 reservoir segment, Roaring Creek

Cove node) on Pit 7 reservoir. The recreation setting within both reservoirs is

comparable and influenced by reservoir elevations (e.g., physical setting scores were

lower when shoreline was exposed within the narrow canyon). The absence of other

users resulted in primitive social setting; however, the management and physical setting

characteristics are more consistent with the rural developed setting. Pit 7 reservoir

WROS classifications tended more toward primitive due to its length and the natural slot

canyon rock formation at the confluence of Roaring Creek.

Angling

The project waters provide ample angling opportunities. Survey data collected by

PG&E indicate a high level of participation of project users in angling. The percentage

of visitors whose primary activity included angling was highest in the Lower McCloud

River (84 percent) followed by Iron Canyon reservoir (80 percent) and McCloud

reservoir (69 percent). California Fish and Game classifies the 7.3-mile-long river reach

of the Lower McCloud River immediately downstream of McCloud dam as a wild trout

area (California Fish and Game, 2004 as cited in PG&E, 2009a).

The quality of angling along the Lower McCloud River (below McCloud dam)

depends on the quantity of flow within the river. PG&E investigated flow relationships

for both angling and boating opportunities (boating opportunities are discussed below

under the section titled Whitewater Boating). Diversions from the project result in a
245

consistent base flow, and decrease the number of high-flow spill events and the number

of days of spill during various types of water years. PG&E’s study results indicate that

210 to 375 cfs as measured at the Ah-Di-Na gage (gage MC-1) is optimal for wading

anglers, with the acceptable range from 200 to 475 cfs. Anglers who were not calibrated

to the gage indicated that the existing summer base flows at Ah-Di-Na of about 160 to

200 cfs provided the best conditions for fishing.18 Study results indicate that typical base

flows of 200 cfs at Ah-Di-Na (about 330 cfs or more at Shasta Lake) provide high quality

conditions for wading anglers. Based on boater surveys the acceptable flow range for

access boating (fishing and camping) is 200-500 cfs.

Whitewater Boating

As discussed previously under the section titled Angling, PG&E investigated flow

relationships for both angling and boating opportunities on the Lower McCloud River.

Additionally, PG&E and American Whitewater assessed potential boating opportunities

on Iron Canyon Creek below the Iron Canyon dam and determined that much of this

4.3-mile reach does not appear to be boatable because it is too steep (PG&E, 2009c).

Although boats can access the downstream end of the river from Pit 6 reservoir, this

flatwater segment would be of little interest to whitewater boaters, and American

Whitewater did not recommend further investigation of the reach.

The quality of boating along the Lower McCloud River depends on the quantity of

flow within the river. Project operations affect the number of days when boatable flows

exist in the Lower McCloud River. Overall, review of hydrological data under past

project operations indicate that between 1974 and 2006, flows suitable for boating

opportunities (180 to 3,000 cfs as measured at Ah-Di-Na gage [MC-1]) were available in

about 40 percent of the years (13 of 33) with an average of 32 days with flows in the

whitewater range (500 to 3,000 cfs as measured at Ah-Di-Na gage)(16 of those days in

the standard whitewater range [700 to 1,500 cfs as measured at Ah-Di-Na gage]).

Optimal boating flows can be characterized by the type of boating experience

(e.g., access-based or whitewater), by the type of boat (e.g., kayak or raft) and the type of

experience (e.g., access-based, technical, standard, or big water). Study results indicate

that typical base flows of 200 cfs at Ah-Di-Na (about 330 cfs or more at Shasta Lake)

appear to provide improved boat-based access over the 160 cfs experienced during the

summer of 2007 (minimum flow required during a dry year). The upper segment of the

river from the base of McCloud dam to Ah-Di-Na Campground is steeper and more

constricted, requiring a different set of flow conditions for a given boating experience

than the lower segment from Ah-Di-Na to Shasta Lake.

Acceptable flow ranges for various whitewater experiences were developed from

responses to a flow-acceptability survey conducted by PG&E that was administered to

a study boater panel. The standard flow range for whitewater boating for both kayaks

18 Flow information has only been on-line since 2009.
246

and rafts on the upper segment of the McCloud River from the base of McCloud dam to

Ah-Di-Na Campground is between 700 and about 1,000 cfs depending on the boat type

(optimal 800 cfs for both boat types) and between about 600 and 1,500 cfs depending on

the boat type on the lower segment of the McCloud River from Ah-Di-Na to Shasta Lake

(optimal between 800 and 900 cfs depending on the boat type).

Compared to other rivers, study survey respondents rated the Lower McCloud

River between “excellent” and “among the very best” (the two highest ratings on the fivepoint scale used) with its length of run, up to 24 river miles, fine scenery, solitude,

excellent water clarity, remote and undeveloped character, and high quality Class III and

IV whitewater as outstanding features. On the negative side, the trip is logistically

challenging and the lack of public land for stopping to rest or camp adds additional

challenges.

There are no formal put-in sites for whitewater boating access at the project or on

the Lower McCloud River. Current whitewater boat trips on the McCloud River

generally originate at the base of McCloud dam, Ash Camp, or Ah-Di-Na Campground

and end at the McCloud Arm Bridge on Shasta Lake. The Forest Service McCloud

bridge developed campground at Shasta Lake is where boaters end their trips.

3.3.5.2 Environmental Effects

Fish Stocking

One of the primary recreational activities associated with the project includes

angling. California Fish and Game currently stocks the Pit and upper McCloud Rivers to

improve the recreational fishery. PG&E originally proposed to continue funding

California Fish and Game for the stocking of up to 38,800 pounds of trout and

500,000 kokanee per fiscal year (July 1 through June 30) in the drainages of the Pit and

McCloud Rivers below the uppermost project development thereon and in Shasta Lake.

PG&E proposed that its cost would not exceed the then-prevailing statewide average cost

to California Fish and Game for the production and distribution of catchable trout and

fingerling kokanee. Following consultation with California Fish and Game and FWS,

PG&E proposed to share the stocking costs equally with California Fish and Game,

provided that its share of costs does not exceed $5,000 during any period of three

consecutive years, and provide the Commission with an annual report containing an

evaluation of study findings on the stocking program.

California Fish and Game recommends in its 10(j) recommendation 14 that

beginning in the first calendar year after license issuance PG&E reimburse California

Fish and Game for stocking of up to 60,000 pounds of trout annually within the

McCloud-Pit Project boundary and that costs would be assessed at the standard rate for

catchable-sized hatchery grown trout in the year of stocking. California Fish and Game

recommends that PG&E, if requested by California Fish and Game, pay $5,000 annually

for monitoring and evaluation of the fish stocking program or for mitigation of sturgeon

reintroduction into Shasta Lake. California Fish and Game states that the demand for
247

angling is estimated to increase from 10,010 recreation days in 2008 to 24,403 recreation

days by 2050 on McCloud reservoir and from 2,515 recreation days in 2008 to

6,130 recreation days by 2050 on Iron Canyon reservoir.19 California Fish and Game

further states that the current fish stocking agreement would not be adequate to meet the

current and future demands. Additionally, California Fish and Game states that the

numerous proposed recreation facility upgrades and construction of new recreation

facilities would result in increased angling pressure at the project and a portion of the

stocked fish could be allocated to Pit 7 reservoir, which is not currently stocked by

California Fish and Game. California Fish and Game also comments that it does not

intend to stock kokanee since it has not stocked kokanee into Shasta Lake since 1970.

In its response to 10(j) recommendations filed by California Fish and Game,

PG&E states that it agrees with California Fish and Game’s fish stocking

10(j) recommendation, as written.

Our Analysis

Angling is one of the most popular activities associated with the project, and

stocking catchable trout would help ensure that the recreational fishery is maintained for

the term of the new license. Based on recreation studies completed during the relicensing

process, the demand for angling at the project is projected to increase over the term of a

new license and the numerous proposed recreation facility upgrades and construction of

new recreation facilities has the potential to result in increased angling pressure at the

project. Existing stocking levels may not be sufficient to meet estimated future demand

for angling for the term of a new license. The proposed kokanee stocking would not be

beneficial since California Fish and Game does not intend to stock kokanee.

In 1942, the construction of Shasta dam isolated a population of white sturgeon;

however, the population was self-sustaining in the Pit River arm of Shasta Lake, until

experiencing a decline in the 1970s and 80s. California Fish and Game began an

experimental sturgeon planting program early in 1988 to evaluate stocking as a means of

restoring the sturgeon fishery; however, the program was discontinued later that year due

to disease problems in the rearing facilities.20 California Fish and Game states that

1.8 percent of the planted sturgeon were caught or observed from 13 months to 13 years

after stocking, indicating that low natural recruitment may be the cause of the sturgeon

population decline.21 California Fish and Game further suggests that the construction of

Pit 6 and 7 dams in the early 1960’s, which eliminated access to 16 miles of stream likely

utilized by white sturgeon during spawning, likely caused the decline. There is no

19 Technical Memorandum 30: Regional Recreation Demand Assessment

(RL-S1).

20 Licensee’s Pre-Application Document.

21 California Department of Fish and Game. 10(j) Recommendations for the

McCloud-Pit Hydroelectric Project. January 28, 2010.
248

conclusive evidence, however, that the loss of riverine habitat or any project-related

effects are directly correlated to the low recruitment of white sturgeon. In December

2010, California Fish and Game provided additional documentation to the Commission

concerning the recommendation that PG&E fund fish stocking efforts of wild white

sturgeon in the Pit River arm of Shasta Lake. Although the documentation provided

information on the historical distribution and catches of white sturgeon, and additional

details on the proposed stocking program, there was no evidence that stocking white

sturgeon would be sustainable.

Increasing the number of fish stocked at the project would help meet the estimated

future demand for angling at the project. Furthermore, annual monitoring and evaluation

of the fish stocking program would provide the means for coordinated development to

allow for the flexibility to increase or decrease stocking numbers over the term of a new

license in order to meet future demand for angling.

Recreation Flows

To enhance whitewater boating opportunities downstream of the project, PG&E

proposed to provide, beginning no later than the first full calendar year after license

issuance, a recreation flow event from McCloud dam (gage MC-7) if a spill flow event of

at least 300 cfs has not occurred for seven consecutive days during the period of April 1

through October 31 at any time in the previous 3 calendar years. PG&E defined a

recreation flow event as a minimum flow release of 300 cfs from McCloud dam as

measured at MC-7 (McCloud dam), for 11 consecutive days during the period between

May 15 and June 15. The proposed flows would be equal to or greater than the flows that

are required in the current project license (section 3.3.2, Aquatic Resources).

As discussed in detail in section 3.3.2, Aquatic Resources, the Forest Service

specified PG&E release mean daily flows of at least 175 cfs year-round from the

McCloud dam such that the mean daily flow at USGS gage MC-1 at Ah-Di-Na is at least

200 cfs. These flows would be augmented during the period February 15 through June

30 according to the flow rule. The Forest Service stated that in terms of boating access,

the current flow regime allows flows to drop below 200 cfs in some months. Forest

Service further stated that its proposed flow regime would provide more days of boating

access than what currently exist, especially in drier years. Although the Forest Service’s

proposed flow regime is not significantly different than the current flow regime, it would

provide a few more whitewater boating days in wetter years.

PG&E alternative condition 19 is consistent with the Forest Service’s original

condition 19, part 1, subpart b and proposes to remove the recreation flow event from its

original proposal due to lack of support from stakeholders as expressed in the

August 27, 2009 project meeting with relicensing participants.22

22 PG&E’s submittal of alternative conditions filed on March 3, 2010.
249

American Whitewater recommends the release of elevated flows in April and May

to provide whitewater boating opportunities in addition to ecological benefits. At

McCloud dam, American Whitewater recommends peak flows of 600 cfs during April

and ramping down through May in wet and above normal years, at least 400 cfs during

the month of April in below normal water years, and flows of 300 cfs ramping down to

200 cfs base flows by the opening day of trout season in dry and critically dry years.

California Trout, Trout Unlimited, and McCloud River Club support the Forest

Service’s proposed minimum baseflow of 200 cfs at Ah-Di-Na (MC-1) but recommend

that summer base flows at Ah-Di-Na be the higher of (1) 200 cfs, or (2) the historic

average summer (i.e., July and August) base flows during normal years under the existing

license (about 210 to 220 cfs). They also recommend the number of available angling

days be increased in late April and May.

The Anglers Committee, California Salmon and Steelhead Association, California

Fisheries, and Water Unlimited support the existing daily flow requirements for the

Lower McCloud River below McCloud dam and recommend that the Commission

prohibit recreational boating in the Lower McCloud River below McCloud dam. They

state that the Lower McCloud River below McCloud dam was set aside by the State of

California as Wild Trout Waters to provide high quality trout fishing for California

licensed anglers and that recreational boating adversely affects anglers and trout fishing

on the Lower McCloud River. They recommend that whitewater boating only occur

during spilling flows in the Lower McCloud River.

The McCloud River Club states that any significant increase in flows on the

Lower McCloud River during the early fishing season could harm trout populations and

the ability of anglers to safely fish during the spring. Furthermore, California Salmon

and Steelhead Association and Anglers Committee comment that the proposed increased

flows below PG&E’s McCloud dam in the Lower McCloud River could have negative

effects to disabled California licensed anglers that fish the river with respect to increased

flows and higher velocity (effects of flows to wading anglers).

California Trout, Trout Unlimited, Northern California Council, Federation of Fly

Fishers, and McCloud RiverKeepers comments that minimum and maximum flows from

McCloud dam should be established for the protection of the habitat and fishery first and

foremost with protection of the rights of the fishing community as the second priority.

The Fly Shop also supports the protection and enhancement of rainbow and brown trout,

and the overall river system health in the Lower McCloud River and recommends flow

management that enhances and protects the extraordinary recreational fishing experience,

including the ability to wade.

California Sportfishing Protection Alliance supports putting the aquatic needs of

the McCloud River first but also seeks a balancing of measures to reasonably

accommodate recreational interests, particularly angling. California Sportfishing

Protection Alliance comments that reasonable accommodation consistent with aquatic

values also must be made for whitewater boating interests and that it does not oppose all
250

whitewater boating in the Lower McCloud River downstream of the project. Both

Friends of the River and American Whitewater comment that they advocate positions

consistent with the protection, enhancement, and restoration of aquatic species and their

habitat, and also positions consistent with protection and enhancement of recreational

opportunities in the McCloud River and its tributaries.

To support restoration of anadromous salmonids and the fish passage pilot study

(RPA of the OCAP BiOp), the Winnemem Wintu Tribe recommends that the minimum

flow increase to 300 cfs by 2013; and increase further by 2015 to 600 cfs in July and

400 cfs in August (table 3-28). During critically dry years, the Tribe also recommends

that flows during September be increased to 400 cfs beginning in 2015. These flow

recommendations are consistent with the upper range of flows proposed by NMFS for

these months when listed anadromous species are present and affected by the project, as

discussed in detail in table 3-22, section 3.3.2, Aquatic Resources.

As discussed in detail in section 3.3.2, Aquatic Resources, the Forest Service

included modifications to condition 19 in its November 29, 2010, filing with the

Commission. The provisions specified in Forest Service modified condition 19 part 1,

subpart b related to minimum streamflow requirements in the McCloud River below

McCloud dam are similar to those specified in the Forest Service’s original

condition 19 part 1, subpart b, but the differences in the modified condition make it more

consistent with the California Trout, Trout Unlimited, and McCloud River Club

recommendation which is similar to the streamflows recommended by staff in the draft

EIS. The Forest Service specifies PG&E release mean daily flows of at least 175 cfs year

round from McCloud dam such that the mean daily flow at gage USGS gage MC-1 at

Ah-Di-Na is at least 200 cfs. These flows would be augmented during the period from

February 15 through August 31 according to the specified flow rule. In its November 24,

2010, filing, PG&E objects to Forest Service modified condition 19 part 1, subpart b.

Our Analysis

As discussed in section 3.3.5.1, Affected Environment, the quality of angling

and boating along the Lower McCloud River depends on the quantity of flow within the

river. We have used available issues of DWR Bulletin 120 from 1994-2006 to determine

the runoff percentage for each semimonthly period described in the various flow

recommendations and applied the associated seasonal flow increases and decreases and

event downramping to the flows recorded at gage MC-1 (Ah-Di-Na). We then compared

the daily flows to the recreational ranges presented in the license application from TM-24

for boating and TM-58 for fishing:

 Standard, technical, and acceptable whitewater boating: 500-1,500 cfs

 Acceptable for wading anglers: 200-475 cfs

 Optimal for wading anglers: 210-374 cfs
251

Acceptable flow ranges for various whitewater experiences developed from a flowacceptability survey conducted by PG&E found that the standard flow range for

whitewater boating for both kayaks and rafts from the base of McCloud dam to Ah-Di-Na

Campground was between 700 and about 1,000 cfs depending on the boat type (optimal

800 cfs for both boat types) and between 600 and 1,500 cfs depending on the boat type

from Ah-Di-Na to Shasta Lake (optimal between 800 and 900 cfs depending on the boat

type). Technical whitewater boating conditions would exist between 500 cfs and 700 cfs

from the base of McCloud dam to Ah-Di-Na Campground. Flows greater than 1,500 cfs

are considered “big water” suitable only for expert paddlers.

The number of days gained or lost from April through October under each flow

recommendation compared to the current license (no-action alternative) is presented in

tables 3-34 (whitewater boating), 3-35 (optimal fishing), and 3-36 (acceptable fishing).
252

Table 3-34. Change in Number of Whitewater Boating Days (500-1,500 cfs) for Alternative Flow Recommendations

Compared to No-action Alternative. (Source: Staff)

Change in Number of Days Compared to Current Conditions (No-action Alternative)

Water

Year

Days

Under Noaction

Alternative

FS Cond. 19

(modified

3/1/10)/PG&E

Alt. Cond. 19

FS Cond.

19

(modified

12/29/10)

Cal

Trout/TU

California

Fish

and

Game

American

Whitewater

McCloud

RiverKeepers NMFS Wintu

1994 0 0 0 0 0 0 0 31 31

1995 13 2 2 18 2 5 0 0 31

1996 4 2 2 7 2 6 0 0 31

1997 0 0 0 0 0 0 0 0 31

1998 73 -1 -1 0 -1 0 0 0 31

1999 20 1 1 4 2 0 0 0 31

2000 10 0 0 3 0 0 0 0 31

2001 0 0 0 0 0 0 0 0 31

2002 0 0 0 0 0 0 0 0 31

2003 0 0 0 0 0 0 0 0 31

2004 0 0 0 0 0 0 0 0 31

2005 10 3 3 5 3 0 0 0 31

2006 20 0 0 0 0 0 0 0 31
253

Table 3-35. Change in Number of Optimal Fishing Days (210-375 cfs) for Alternative Flow Recommendations Compared

to No-action Alternative. (Source: Staff)

Change in Number of Days Compared to Current Conditions (No-action Alternative)

Water

Year

Days

Under Noaction

Alternative

FS Cond. 19

(modified

3/1/10)/PG&E

Alt. Cond. 19

FS Cond.

19

(modified

12/29/10)

Cal

Trout/TU

California

Fish

and

Game

American

Whitewater

McCloud

RiverKeepers NMFS Wintu

1994 31 -31 -31 -31 -31 -2 -31 -31 91

1995 153 -144 -82 -144 -144 -137 -77 -112 -22

1996 137 -135 -135 -128 -131 -103 -73 -105 7

1997 156 -156 -156 -156 -156 -127 -95 -125 -4

1998 132 -119 -64 -122 -121 -117 -55 -95 -62

1999 177 -138 -76 -140 -139 -141 -93 -127 -58

2000 190 -164 -102 -178 -164 -166 -121 -150 -51

2001 39 -39 -39 -39 -37 -10 -39 -8 83

2002 154 -154 -92 -154 -140 -149 -154 -123 -32

2003 183 -174 -112 -173 -166 -178 -167 -144 -63

2004 203 -181 -119 -178 -174 -174 -130 -167 -51

2005 174 -163 -101 -155 -143 -159 -142 -133 -68

2006 137 -132 -70 -132 -132 -132 -70 -101 -62
254

Table 3-36. Change in Number of Acceptable Fishing Days (200-475 cfs) for Flow Alternative Recommendations

Compared to No-action Alternative. (Source: Staff)

Change in Number of Days Compared to Current Conditions (No-action Alternative)

Water

Year

Days Under

No-action

Alternative

FS Cond. 19

(modified

3/1/10)/

PG&E Alt.

Cond. 19

FS Cond.

19

(modified

12/29/10)

Cal

Trout/TU

California Fish

and

Game

American

Whitewater

McCloud

RiverKeepers NMFS Wintu

1994 31 183 183 183 183 183 -31 152 152

1995 158 36 36 20 36 32 31 9 8

1996 173 32 32 27 32 28 -10 5 4

1997 178 36 36 36 36 36 -9 6 5

1998 140 0 0 -1 -1 0 0 -30 -31

1999 193 -1 -1 -4 -2 0 -12 -30 -31

2000 198 6 6 3 6 5 -19 -25 -26

2001 68 146 146 146 146 146 -68 116 115

2002 190 24 24 24 24 24 -190 -6 -7

2003 199 15 15 15 15 15 -181 -15 -16

2004 208 6 6 6 6 6 -27 -24 -25

2005 201 -1 -1 -3 -1 1 -165 -29 -30

2006 139 0 0 0 0 0 0 -30 -31
255

During the 13-year period that we analyzed (1994-2006), under the existing

license the number of whitewater boating days was 0 in 6 years and 20 or fewer in 6 of

the 7 remaining years (table 3-34). The flow scenarios proposed by California Fish and

Game and PG&E and specified by the Forest Service’s modified condition 19 would

have had no effect on the number of days available to whitewater boaters in 8 years and a

change of 1 to 3 days in the other 5 years. The California Trout, Trout Unlimited, and

McCloud River Club recommendation would have increased the number of days by 3 to

7 during 4 years with no change during 8 years. Higher flows recommended by the

Winnemem Wintu Tribe to support listed salmonids would have added 31 days each year.

Flow recommendations from American Whitewater, McCloud RiverKeepers, and NMFS

would have had no effect in most years.

As indicated in table 3-21, the actual flows at Ah-Di-Na except during the driest

years were greater than 215 cfs and would have been considered optimal. In below

normal years and normal years, flows consistently averaged in the range that is optimal

for wading anglers (i.e., 210-375 cfs) from April through October. In wet years, flows

were in the range that is optimal for wading anglers from June through October. In wet

years, flows averaged in the range that is acceptable for technical whitewater boating

(i.e., 500-700 cfs) from April through May. Since the McCloud River is closed to fishing

from November 16 to the last Saturday in April, flows during this period would have no

impact on anglers.

Because the low end of the range for optimal conditions for wading anglers is

210 cfs, whereas the minimum base flow in most recommendations is 200 cfs, all of the

recommended flow scenarios would result in a significant decrease in optimal fishing

days compared to the existing license (table 3-35). The Forest Service’s modified

condition 19 would generally have resulted in a smaller number of lost optimal days than

the recommendations by PG&E, California Trout, Trout Unlimited, and McCloud River

Club, California Fish and Game, American Whitewater, and NMFS. In contrast, the

number of acceptable days for wading anglers would generally have increased during

most of the 13-year period of analysis under all flow proposals (table 3-36), and there

were no significant differences in the number of days gained among the

recommendations from PG&E, California Trout, Trout Unlimited, and McCloud River

Club, California Fish and Game, and American Whitewater, and the Forest Service’s

modified condition. During 4 years, the number of days would have been unchanged or

decreased by 1 or 2 days; the number of days would have increased by 6 to 36 days

during 7 years. During 1994 and 2001, the number of acceptable fishing days would

have increased by more than 100.

Recreational Access to Lower McCloud River Flows

Except for the area immediately below McCloud dam, no project lands are located

along the Lower McCloud River. NFS lands along the Lower McCloud River below

McCloud dam, specifically at Ash Camp, Ah-Di-Na Campground, and the river corridor

between these facilities, currently provide the only public access to both boaters and
256

anglers on the 24-mile stretch of the Lower McCloud River from McCloud dam to Shasta

Lake. Ash Camp and Ah-Di-Na Campground are within the 4.5 miles of publicly

accessible NFS lands along the Lower McCloud River. The remainder of the land

located along the Lower McCloud River, except for The Nature Conservancy’s McCloud

River Preserve which is used by some anglers, is privately owned. In addition to the base

of McCloud dam, Ash Camp and Ah-Di-Na Campground are the origin of whitewater

boat trips on the Lower McCloud River but there is no public take-out below Ah-Di-Na

Campground for boaters until Shasta Lake.

Numerous comments filed and raised at the public meetings on the draft EIS were

related to the inability of recreationists to access the Lower McCloud River during the

early spring. The higher minimum streamflows, under the staff recommendation, that

would be appropriate for whitewater boating would occur during the early spring months

when the roads to Ah-Di-Na Campground Ash Camp are generally inaccessible due to

snow. As discussed in section 3.3.2, Aquatic Resources, and section 3.3.5.2,

Environmental Effects, Recreation Flows, the recommended flows would likely result in

flows below McCloud dam that are suitable for technical whitewater boating. Numerous

commenters state that the roads to Ash Camp and Ah-Di-Na Campground are

inaccessible due to snow during the early spring when the instream flows would be

appropriate for whitewater boating. A number of commenters recommend that PG&E be

responsible for snow plowing the road to provide access to the Lower McCloud River

flows.

In their comments on the draft EIS, the Forest Service, California Trout, Trout

Unlimited, and the Northern California Council, Federation of Fly Fishers recommend

that road access is open and available so that recreationists can access the projectreleased minimum instream flows, especially in late spring, to participate in boating or

fishing activities. In their comments on the draft EIS, American Whitewater and Friends

of the River recommend that road access be provided to Ah-Di-Nah whenever boating

flows are available and that PG&E be required to provide snow removal when flows are

above 300 cfs at the Ah-Di-Nah gage. Additionally, numerous individuals comment that

recreational access to the Lower McCloud River in the winter/spring due to snow could

be improved. PG&E disagrees with suggestions that it should be required to plow snow

to provide vehicular access to Ah-Di-Na Campground for whitewater boating access.

Our Analysis

Public access to the Lower McCloud River is challenging because except for the

area immediately below McCloud dam, no project lands are located along the Lower

McCloud River. As discussed in section 3.3.5.2, Environmental Effects, Lower McCloud

River Recreation Facilities, PG&E proposes to provide an access area at the base of

McCloud dam to increase public access to the Lower McCloud River. NFS lands along

the Lower McCloud River below McCloud dam, specifically at Ash Camp, Ah-Di-Na

Campground, and the river corridor between these facilities, currently provide the only
257

public access to both boaters and anglers on the 24-mile stretch of the Lower McCloud

River from McCloud dam to Shasta Lake.

Numerous comments filed and raised at the public meetings on the draft EIS were

related to the inability of recreationists to access the Lower McCloud River during the

early spring. The higher minimum streamflows, under the staff recommendation, that

would be appropriate for whitewater boating would occur during the early spring months

when the roads to Ah-Di-Na Campground Ash Camp are generally inaccessible due to

snow. A number of commenters recommend that PG&E be responsible for snow

plowing the road to provide access to the Lower McCloud River flows.

Ash Camp (FR U38N11Y) and Ah-Di-Na (FR 38N53) roads are non-project roads

that do not meet the Commission’s criteria for project roads used primarily for project

purposes. Therefore, these roads are not included in the list of project roads (see

table 3-41 in section 3.3.7.2, Environmental Effects, Land Use Resources, Project

Boundary) that PG&E is responsible for maintaining under the project license.

Recreation Management Plan

Development of Recreation Management Plan

In order to ensure a quality experience for recreation users over the term of the

license, PG&E proposed to develop a Recreation Development and Management Plan

(Recreation Plan) in consultation with the Forest Service, California Fish and Game,

California Water Board, and other interested parties within 2 years of license issuance.

The Recreation Plan would include the following: upgrading existing recreation facilities

and constructing new recreation facilities in accordance with Forest Service Outdoor

Recreation Accessibility Guidelines (FSORAG) and with the ADA; public use of one,

year-round campground; streamflow dissemination for the Lower McCloud River; a

Project Sign Plan; an Interpretive and Education Plan; periodic recreation monitoring and

reporting; O&M of project recreation facilities; project-wide patrol of areas including but

not limited to Hawkins Creek crossing, Iron Canyon reservoir shoreline dispersed use

sites, and McCloud reservoir shoreline access points; and annual coordination with the

Forest Service.

In its original condition 30, the Forest Service specified that PG&E develop and

implement a Recreation Plan, to be approved by the Forest Service within 2 years of

license issuance, to address recreation resource needs associated with the project in

consultation with the Forest Service, California Fish and Game, California Water Board,

and other interested parties. The plan would include annual maintenance, operation,

reconstruction, survey and monitoring, water surface management, and project patrol of

existing recreation facilities and use at the project. PG&E alternative condition 30 is

consistent with the Forest Service’s original condition 30; however, it does not include

final approval of the Recreation Plan by the Forest Service. Additionally, PG&E

alternative condition 30 proposes that all new project recreation facilities constructed

under the Recreation Plan would be included within the project boundary and that all
258

existing recreation facilities that are reconstructed under the Recreation Plan would be

included within the project boundary after reconstruction.

In its November 29, 2010, filing with the Commission, the Forest Service included

modifications to condition 30. The Forest Service has modified condition 30 to include

consultation with Native American representatives on the development of the Recreation

Plan and consultation with the conditioning agencies.23 Additionally, Forest Service

modified condition 30 specifies that new and reconstructed project facilities on NFS

lands would be included in the project boundary prior to ground disturbance (see

section 3.3.7.2, Environmental Effects, Land Use Resources, Project Boundary).

In its November 24, 2010, filing, PG&E objects to Forest Service modified

condition 30 but does not specify the components with which it disagrees.

Recreation Facility Design Standards

PG&E proposed to completely reconstruct all project recreation facilities within

25 years of license issuance so that all project recreational facilities would be

reconstructed once during the term of the license. PG&E proposed to use Forest Service

design standards and to obtain Forest Service approval on final designs and prior to

construction for any facilities located on NFS lands before submitting for Commission

approval. As part of this approval, the Forest Service may require adjustments to facility

locations and final plans to preclude or mitigate impacts and ensure that the project is

compatible with on-the-ground conditions.

In its original condition 30, part 2, the Forest Service specified that all new and

reconstructed project recreation facilities located on PG&E’s lands would be designed to

meet applicable ADA and Architectural Barriers Act (ABA) standards and FSORAG and

Forest Service Trail Accessibility Guidelines (FSTAGs) as currently written at the time

of project design. The Forest Service further specified that all project facilities would be

designed to be consistent with the recreation opportunity spectrum (ROS) class and VQO

where they are located. All existing project and project-related recreation facilities would

be reconstructed within 3 years of license issuance and new facilities would be

constructed within 3 or 5 years of license issuance, as specified. Lastly, Forest Service

specified that all project and project-related recreation facilities and infrastructure would

be reconstructed at mid-license or 25 years, whichever is greater.

California Fisheries and Water Unlimited also recommend that the Commission

enforce ADA standards and provide accommodations for disabled persons at all

associated project campgrounds and recreational public facilities, especially at McCloud

reservoir.

23 Conditioning agencies are defined in the Forest Service Draft Project

Implementation Plan as “typically Forest Service, state water resources control board,

NOAA, and occasionally others.”
259

PG&E alternative condition 30 is consistent with the Forest Service’s original

condition 30, except that it proposes to construct new and reconstruct existing recreation

facilities within 5 years of approval of the Recreation Plan. In its reply to comments on

the draft EIS, PG&E comments that its proposal to construct and reconstruct recreation

facilities within 5 years of approval of the Recreation Plan is appropriate due to the

significant design work needed for the proposed enhancements.

In its modified condition 30, the Forest Service does not specify that new and

reconstructed facilities on PG&E lands meet ADA and ABA standards nor does it specify

a schedule for construction/reconstruction of project recreation facilities, as previously

specified in condition 30.

In its November 29, 2010 filing with the Commission, the Forest Service included

a draft Recreation Development and Management Plan as an enclosure (Forest Service,

2010d, Enclosure 3) with the modified 4(e) conditions. In this draft plan the Forest

Service recommends construction of new project facilities within 3 years and the

reconstruction of existing recreation facilities within 5 years of license acceptance; all

recreation facilities be replaced in-kind or with an upgraded facility within 20 years of

construction/reconstruction; specific guidelines and standards should be followed for the

construction and reconstruction of recreation facilities on NFS lands (consistent with the

Forest Service’s original condition 30); and Forest Service approval for the development

of conceptual designs and the development of construction supporting design reports of

each project recreation facility prior to approval of the Recreation Plan.

In its November 24, 2010, filing, PG&E objects to Forest Service modified

condition 30 but does not specify the components with which it disagrees.

Our Analysis

PG&E’s proposed Recreation Plan would provide the means to develop and

implement the proposed recreation measures in a consistent and coordinated manner.

Although recreation facilities would be constructed or reconstructed shortly after license

issuance, recreation facilities and infrastructure could be become degraded over the term

of the license; however, all facilities may not need to be reconstructed near mid-license

term as proposed by PG&E in its alternative condition 30 or recommended by the Forest

Service in the draft Recreation Development and Management Plan. A reevaluation of

the facilities for degradation by PG&E at mid-license term or within 25 years of license

issuance, whichever is greater, would ensure that the recreation facilities would continue

to provide safe, reliable public access to recreational opportunities and the project and

address growing recreational demand over the term of the new license.

Consultation with the Forest Service would help to ensure that the measures being

developed and implemented would be consistent with the management goals and

objectives of the Shasta-Trinity National Forest. Consultation with Native American

representatives and conditioning agencies (which would include the Forest Service,

California Water Board, and NMFS), as specified in Forest Service modified
260

condition 30, and American Whitewater and Friends of the River, as requested in their

comments on the draft EIS, during the development of the Recreation Plan would better

inform the development and components of the Recreation Plan. Although Forest

Service modified condition 30 does not specify consultation with California Fish and

Game, consultation with California Fish and Game, as proposed by PG&E, during the

development of the Recreation Plan would also better inform the development of the

Recreation Plan. Further, improving access for the disabled at the project would be

consistent with the Commission’s policy on recreation facilities at licensed projects under

which licensees are expected to consider the needs of the disabled in the design and

construction of such facilities.24

In the draft Recreation Development and Management Plan, the Forest Service

recommends new recreation facilities be constructed within 3 years of license acceptance

and that existing facilities be reconstructed within 5 years of license acceptance. This

schedule limits the time between PG&E filing the final Recreation Plan for Commission

review and approval (within 2 years of license issuance) and constructing new recreation

facilities. Completion of construction could be difficult given the significant design work

and requirement of final Commission approval.

The Forest Service also specifies in modified condition 30 that new and

reconstructed project recreation facilities on NFS lands would be brought into the project

boundary prior to ground disturbance. As discussed in section 3.3.7.2, Environmental

Effects, Land Use Resources, Project Boundary, it would be appropriate for all existing

project recreation sites and facilities to be brought into the project boundary at license

issuance. Since construction plans for new recreation facilities could change, it would be

appropriate to bring new facilities into the project boundary once construction is

completed to ensure that each facility is included in the project boundary in its entirety.

The following sections describe the components of the Recreation Plan proposed by

PG&E and specified by the Forest Service in original condition 30 and include our

assessment of the potential effects of each component on recreational resources at the

McCloud-Pit Project.

McCloud Reservoir Recreation Facilities

 Tarantula Gulch Boat Ramp and Day-Use Area: reconstruct the Tarantula

Gulch boat ramp to California Boating standards: provide a boarding dock, and

extend the launch ramp to 3 feet (vertical) below the minimum operating pool

elevation: provide day-use facilities (restroom, paved parking, trash

receptacles/removal, tables, and pedestrian trail access) with potable water at

Tarantula Gulch boat ramp (between the ramp and the intersection with

FR 11).

24 See 18 CFR § 2.7 (2010).
261

 Red Banks: provide day-use facility that includes restroom, paved parking,

trash receptacles/removal, tables, and pedestrian trail access.

 McCloud Shoreline Access Points: provide access points (paved parking and

shoreline access trail) at Battle Creek, West dam, and East dam.

 Star City Campground and Day-Use Area: develop a campground with walkin sites (estimate six sites), paved parking, vault restroom, potable water,

tables, fire rings/grills, trash receptacles/removal, and host site; provide dayuse facilities (restroom, paved parking, trash receptacles/removal, tables, and

pedestrian trail access) including shoreline access for hand launching boats and

potable water.

 Floating Dock or Pier and Trail: conduct a feasibility study to find a suitable

location for a floating dock or pier and trail (away from Tarantula Gulch boat

launch) for day-use activities, such as fishing and swimming; design and

construct this facility if a suitable location is identified.

In its original condition 30, the Forest Service also specified that PG&E

rehabilitate existing facilities at McCloud reservoir and improve access. We summarize

the differences between the rehabilitation measures specified in the Forest Service’s

original condition 30 and those in proposed by PG&E below.

 Tarantula Gulch Boat Ramp and Day-Use Area: reconstruct existing boat

ramp to two-lane ramp with boarding dock, sidewalk, and a minimum of a

4-foot draft clearance below minimum pool to California Boating standards;

redesign existing parking lot and day-use area to include 30-40 total parking

spaces, develop paved parking area and turnaround, and designate parking

spaces for vehicles; provide lighting in the parking area that is visible from the

courtesy dock; and provide snow removal on the access road (from junction

with 38N11) and parking area between April 1 and December 1, when access

to the junction is available.

 Tarantula Gulch Inlet: provide paved parking for a minimum of five vehicles,

up to three picnic tables with pedestal grills, vault toilet, animal-resistant trash

receptacles, and a pedestrian access trail to the high water line.

 Red Banks: provide paved parking for a minimum of five vehicles, up to three

picnic tables with pedestal grills, vault toilet, animal-resistant trash receptacles,

and a pedestrian access trail to the high water line. PG&E would ensure legal

access from roadway to reservoir day-use areas.

 McCloud shoreline access points: include paved parking for three vehicles

and an access trail to the shoreline at three reservoir access points at Battle

Creek and on each side of McCloud dam; install picnic tables where space

allows; PG&E would ensure legal access from roadway to reservoir access

areas.
262

 Star City Campground and Day-Use Area: develop a campground with twovault accessible restroom facility and potable water source; up to 10 campsites

(including a host site) with a site post, picnic table, animal-resistant food

locker, and campfire ring at each campsite; day-use area near the shoreline

with a designated swim/beach area, dock, car-top boat access, single-vault

toilet, and up to five sites each with a table, pedestal grill, and animal-resistant

trash containers.

 Floating Dock or Pier and Trail: develop a fishing/swimming platform to

accommodate a fluctuating water level at one of the four proposed day-use

areas or at another designated recreation day-use location around the McCloud

reservoir.

PG&E alternative condition 30 is generally consistent with the Forest Service’s

original condition 30; however, PG&E proposes to exclude language related to the

acquisition of rights at Red Banks day-use site and the McCloud shoreline access points.

PG&E proposes to cooperate with private landowners to acquire rights of public access

by any means necessary, but not including by condemnation pursuant to section 21 of the

FPA or any other law, for the purpose of public recreational day-use. At Tarantula Gulch

boat ramp, PG&E does not propose lighting and snow plowing or a specific number of

parking spaces, as specified by the Forest Service, but does propose that the boat ramp be

extended to an elevation of at least 3 vertical feet below minimum pool and that the boat

ramp remain one lane. Additionally, PG&E comments that initial site investigations have

identified site constraints that affect the feasibility of constructing some recreation

facilities. PG&E proposes to first conduct a site evaluation within 2 years of license

issuance to determine if constructing a fishing/swimming platform at McCloud reservoir

is feasible and then constructing the facility if a suitable location is found.

The Hearst Corporation expresses concerns over the proposed expansion of

overnight camping at McCloud reservoir and unknown details that would be included in

the Recreation Plan. Further, The Hearst Corporation strongly opposes the allowance for

open campfires (including those within a fire ring) at McCloud reservoir since it is in a

very high fire risk assessment area and public use is concentrated during the dry summer

months and would pose great risk to persons and property on Hearst lands.

In its comments on the draft EIS, The Hearst Corporation continues to support a

day-use only recreation site at Star City Creek. The Hearst Corporation comments that

the 1969 grant deed to the Forest Service from The Hearst Corporation provides that the

lands would not be used for the “construction of campsites, cabins, or any overnight

accommodations.” Additionally, The Hearst Corporation recommends a campground

operating season for any campground developed that limits the operating season to

April 1 through September 30. Additionally, The Hearst Corporation disagrees that fire

rings would reduce the threat of wildfires but supports supervised cooking grills and

recommends proper signage, information, and enforcement to prevent the use of open

campfires.
263

In its reply to comments on the draft EIS, PG&E comments that it is working with

the Forest Service and The Hearst Corporation to gain the necessary approvals and rights

to develop a campground at Star City because this is the only site on McCloud reservoir

suitable for a campground and that it is not reasonable to consider developing a

campground at Tarantula Gulch boat ramp. PG&E disagrees with specifying

30-40 parking spaces for Tarantula Gulch boat ramp and comments that preliminary site

designs show that at most only about 20 vehicles with trailers and 5 single vehicles can

be accommodated at the boat ramp. Further, PG&E disagrees with a requirement to plow

snow at the Tarantula Gulch boat launch and the road leading to the ramp and because it

does not need winter access for project purposes and notes that the study results do not

demonstrate a need for this measure.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 30. The modified condition specifies if PG&E cannot acquire the rights for

overnight public recreation use at Star City, PG&E should construct a campground on

NFS lands near Tarantula Gulch boat ramp. Additionally, the Forest Service has

removed specific details from the 4(e) condition and placed them in the draft Recreation

Development and Management Plan, included as an enclosure to the filing (Forest

Service, 2010d, Enclosure 3).

In the draft Recreation Development and Management Plan the Forest Service is

now recommending, as specified in the Forest Service’s original condition 30, lighting

and the establishment of a schedule for snow plowing at Tarantula Gulch boat ramp.

Forest Service modified condition 30 does not specify, nor does the draft Recreation

Development and Management Plan recommend, a specific number of parking spaces at

Tarantula Gulch boat ramp, extension of the boat ramp to a 4-foot draft clearance below

minimum pool, or construction of a day-use site at the boat ramp. In the draft Recreation

Development and Management Plan, the Forest Service recommends specific amenities

for the individual recreation facilities that are otherwise generally consistent with the

Forest Service’s original condition 30; however, the Forest Service does recommend that

a floating dock be constructed at the Tarantula Gulch inlet day-use area. Forest Service

modified condition 30 does not specify the construction of a floating dock even though

the Forest Service’s original condition 30 specified that the dock be located at one of the

proposed day-use sites.

In its November 24, 2010, filing, PG&E objects to Forest Service modified

condition 30 but does not specify the components with which it disagrees.

Our Analysis

PG&E’s proposed rehabilitation measures for the recreation facilities at McCloud

reservoir would provide the means for future rehabilitation and replacement (as needed)

of existing recreational facilities within the project. The facility rehabilitation measures

would provide for enhanced access to project facilities and amenities and help ensure that

these access sites would continue to provide adequate facilities to meet current and future

recreational demand at the projects.
264

Constructing the proposed day-use area and reconstructing the boat ramp at

Tarantula Gulch would help relieve overcrowding and reduce user conflicts at McCloud

reservoir. However, PG&E states that initial site investigations have identified site

constraints that may affect the feasibility of constructing some recreation facilities

specified by the Forest Service. Forest Service modified condition 30 specifies that

PG&E reconstruct the Tarantula Gulch boat ramp to provide two lanes to further reduce

crowding at the ramp but does not specify a minimum of a 4-foot draft clearance below

minimal pool level or a specific number of parking spaces, as was specified in the Forest

Service’s original condition 30. PG&E states steep slopes constrain design options for

providing an additional lane at the boat ramp. Additionally, although PG&E agrees with

increasing parking capacity at the boat ramp to the extent possible, PG&E states that an

initial site assessment determined that only a few parking spaces could be added due to

site constraints. Currently, the bottom of the boat ramp is 1 foot below the normal

minimum operating reservoir level (elevation 2,634 feet) and typically provides boater

access during the entire recreation season. PG&E states reconstructing the ramp with the

toe of the ramp extending to an elevation not less than three vertical feet below minimum

pool would extend the season for launching boats.

Demand for boating access coupled with crowding issues at McCloud reservoir

demonstrates the need for improved recreational boating access at the project.

Constructing additional proposed day-use areas at Red Banks and the Tarantula Gulch

inlet and access sites at Battle Creek and both sides of McCloud dam would help relieve

overcrowding and reduce user conflicts at Tarantula Gulch boat ramp by providing

recreation users with other access areas to McCloud reservoir. Moreover, constructing a

floating fishing/swimming platform at one of the proposed day-use areas would

potentially alleviate overcrowding and user conflicts even further.

In its original condition 30, the Forest Service specified that PG&E provide

lighting and snow plowing at the Tarantula Gulch boat ramp to provide safety for anglers

fishing early or late in the day and to improve access at the ramp from April 1 through

December. In the draft Recreation Development and Management Plan, the Forest

Service recommends lighting at Tarantula Gulch boat ramp and the establishment of a

schedule for snowplowing at the boat ramp. The Forest Service pointed to the relicensing

recreation survey that indicated 10 percent of visitors use the reservoir in winter and

noted several comments requesting the need for a longer use season. PG&E states

California Boating standards do not require lighting. Lighting would improve safety at

the boat ramp and allow anglers to fish longer during the recreation season; however,

there is little evidence to support recreation use during the shoulder and winter months to

justify snow plowing at the ramp during the shoulder months when PG&E does not need

access to the boat ramp for project purposes.

Constructing additional proposed day-use areas at Red Banks and the Tarantula

Gulch inlet and access sites at Battle Creek and both sides of McCloud dam would help

relieve overcrowding and reduce user conflicts at Tarantula Gulch boat ramp by

providing recreation users with other access areas to McCloud reservoir. Moreover,
265

constructing a floating fishing/swimming platform at one of the proposed day-use areas

would potentially alleviate overcrowding and user conflicts even further.

Forest Service modified condition 30 specifies and PG&E alternative condition 30

proposes to develop an overnight campground and develop a day-use area at Star City.

However, The Hearst Corporation continues to support a day-use recreation site at Star

City Creek. Forest Service modified condition 30 specifies that if the deed for Star City

is not modified, it would support a day-use only site at Star City and require the

placement of an overnight facility at the Tarantula Gulch Boat Ramp instead. There are

no existing campgrounds at McCloud reservoir to meet existing or projected demand for

overnight use; however, regular dispersed camping is occurring at Star City. PG&E’s

suitability assessment shows the only potential site to accommodate camping at the

reservoir is at Star City. Providing a formal campground and day-use area at this location

would help manage the already existing use and reduce negative impacts on natural

resources by eliminating erosion and soil compaction from user-created trails and

vehicles and by providing for proper sanitation disposal and trash removal. However, if

PG&E is unable to secure the use of the land at the Star City Creek site, a plan for a

similar recreation area that provides camping at McCloud reservoir would be necessary to

meet existing and projected demand for overnight use at the reservoir.

The Hearst Corporation recommends a campground operating season for any

campground and expresses concerns about wildfires and the use of fire rings. The

proposed Recreation Plan, which would be developed in consultation with Forest Service

and others and approved by the Commission, would include an annual schedule and

standard protocols for opening and closing recreation facilities and the final details for

the specific amenities (such as fire rings or grills) for each recreation facility, including

the Star City campground. The development and implementation of a Fire Prevention

and Response Plan, as discussed in section 3.3.7, Land Use and Aesthetics, would

improve planning, management, and coordination of wildfire protection and prevention

measures, as well as lead to a reduction in the occurrence and suppression of wildfires in

the project area, minimizing damage to natural resources. Additionally, the proposed

Project Sign and Interpretive/Education Plan would include safety signage and additional

information to reduce the threat of wildfires. Fire rings would be included at each

developed campsite and the use of fire rings would reduce the threat of wildland fire at

Star City. Fire risk and management is further discussed in the Fire and Fuels Plan,

which we discuss in section 3.3.7, Land Use and Aesthetics.

Lower McCloud River Recreation Facilities

 Base of McCloud dam: provide a whitewater put-in base of McCloud dam,

parking, vault restroom, trash receptacle/removal, and shoreline pedestrian

access trail on river left to the pool below the spillway.

The Forest Service’s original condition 30 also specified PG&E rehabilitate

existing facilities at the Lower McCloud River and improve access. We summarize the
266

differences between rehabilitation measures specified in the Forest Service’s original

condition 30 and those proposed in PG&E’s alternative condition 30, below.

 Base of McCloud Dam: construct and maintain a day-use site that includes

access road, paved parking for a minimum of three vehicles, vault toilet,

animal-resistant trash receptacle, signing, and trail to accommodate both

fishing and boating access from the base of McCloud dam to a point past the

instream flow valve release to the splash pool below the spillway

 Lower McCloud River Trail/Ash Camp Campground Trail: upgrade, relocate

where needed, and improve tread and drainage of existing user-created

streamside river access trail along opposite side of river from Ash Camp

Campground that begins at Ash Camp bridge/PCT junction and travels

downstream to Ah-Di-Na.

 Ash Camp and Ah-Di-Na Campground: agreement with PG&E outside the

license to reconstruction, operation, and maintenance of Ash Camp and Ah-DiNa Campground.

PG&E alternative condition 30 is generally consistent with the Forest Service’s

original condition 30; however, PG&E alternative condition 30 does not propose to

upgrade and maintain the Lower McCloud river trail or to reconstruct, operate and

maintain Ash Camp and Ah-Di-Na Campground.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 30. Forest Service modified condition 30 specifies that if the site at the base of

McCloud dam is infeasible for the day-use site, then PG&E would construct facilities at

Ash Camp and include the campground in the project boundary or enter into a settlement

agreement with the Forest Service for non-project facilities. Forest Service modified

condition 30 does not, however, include specifications for PG&E to reconstruct, operate,

and maintain the Lower McCloud River Trail. Moreover, specific details of the

recreation facility enhancements for the McCloud dam day-use area were not included in

the modified 4(e) condition but incorporated into the draft Recreation Development and

Management Plan, included as an enclosure to the filing (Forest Service, 2010d,

Enclosure 3).

In its November 24, 2010, filing, PG&E objects to Forest Service modified

condition 30 but does not specify the components with which it disagrees.

On December 14, 2010, the Forest Service filed with the Commission a settlement

agreement between PG&E and the Forest Service for non-project recreation facilities

(specifically, Ash Camp, Ah-Di-Na Campground, and the Lower McCloud River Trail)

and roads in the Shasta-Trinity National Forest.

Our Analysis

Constructing a day-use site and designing an access trail to accommodate both

fishing and boating access at the base of McCloud dam for the Lower McCloud River
267

would facilitate the use of the area by anglers and boaters. Although improving the trail

along the Lower McCloud River from Ash Camp Campground at the Ash Camp

bridge/PCT junction to Ah-Di-Na Campground would improve access, the trail is outside

the existing project boundary. Moreover, both Ash Camp and Ah-Di-Na Campground

are non-project facilities outside the project boundary that are not currently being used

for project purposes. In its original condition 30, the Forest Service specified that, should

an agreement not be reached outside of the license, mitigation at Ash Camp and Ah-DiNa Campground would be included in the final 4(e) conditions. The settlement

agreement between PG&E and the Forest Service filed with the Commission on

December 14, 2010, addresses responsibilities for Ash Camp, Ah-Di-Na Campground,

and the Lower McCloud River Trail and roads that are outside of the project boundary.

As a result, the Forest Service did not include specific mitigation measures for either the

Ash Camp or the Ah-Di-Na Campgrounds in its modified 4(e) conditions.

Iron Canyon Reservoir Recreation Facilities

 Hawkins Landing Campground: reconstruct Hawkins Landing Campground

with the existing capacity (10 sites and a host site) and provide potable water;

reconstruct or resurface the access road to allow all-season use and provide a

host at the campground during the recreation season.

 Hawkins Landing Boat Ramp: retain concrete ramp surface and replace or

repair the surfacing that connects to the concrete ramp.

 Deadlun Campground: reconstruct Deadlun Campground and increase

capacity by about 10 sites to provide about 37 sites and a host site; provide

potable water and a shoreline access trail.

 Iron Canyon Dam Boat Ramp: construct a new boat launch at the east end of

Iron Canyon dam that meets California Boating standards and provide a vault

restroom, picnic tables, potable water, and trash receptacles/removal.

 Shoreline Access Areas: conduct a site evaluation to provide three paved

parking areas along FR 37N78 each with a capacity of up to three vehicle

parking spaces and a pedestrian shoreline access trail and to design and

construct these facilities.

The Forest Service’s original condition 30 also specified that PG&E rehabilitate

existing facilities at Iron Canyon reservoir and improve access. We summarize the

differences between rehabilitation measures specified in the Forest Service’s original

condition 30 and those proposed in PG&E alternative condition 30, below.

 Hawkins Landing Campground: reconstruct Hawkins Landing Campground to

provide for a minimum of 10 single and double camp sites; include entrance

gate with signing, surfaced loop road, parking spurs, site posts, picnic tables,

animal-resistant food boxes and trash receptacles, fire rings, vault restrooms,

potable water, camp host and host site, and a developed trail from the
268

campground to the adjacent boat ramp and shoreline for pedestrian fishing

access.

 Hawkins Landing Boat Ramp: reconstruct the Hawkins Landing boat ramp

surface (length and width, but not grade) to meet California Boating standard

for single lane to be operable a minimum of 155 days during the recreation

season (April 27 – November 15); provide surfaced, striped parking lot above

high water level for a minimum of 10 vehicles (minimum five with trailers),

including a single-vault toilet, animal-resistant trash receptacle, and

informational sign board.

 Deadlun Campground: re-locate the Deadlun campground to one or two Forest

Service approved location(s) along the Iron Canyon reservoir shoreline;

provide a mix of single and group campsites; provide a host, entrance gate,

surfaced loop road, parking spurs, site posts, picnic tables, animal-resistant

food lockers, fire rings, two two-vault restrooms, animal-resistant trash

receptacle, and potable water; develop a trail from the campground(s) to the

high water line of the reservoir shoreline for pedestrian-only access.

 Iron Canyon Dam Boat Ramp: construct a new single-lane boat ramp to

California Boating standards with boarding dock functional at 90 percent of

operational lake levels (ramp design and placement should include option for

two lanes if needed at mid-license facility review); provide parking for a

minimum of 15 vehicles (5 single vehicles and 10 vehicles with trailers); a

single-vault toilet at the parking area; potable water, picnic tables, and trash

receptacles; security lighting visible from the dock; and snow removal during

shoulder seasons (March/April through December) at parking area when Oak

Mountain access road and Iron Canyon boat ramp surface are passable.

 Shoreline Access Areas: provide a minimum of three day-use parking areas

around Iron Canyon reservoir with paved parking for up to three vehicles each,

and pedestrian-only access to shoreline.

PG&E alternative condition 30 for Hawkins Landing Campground is generally

consistent with the Forest Service’s original condition 30; however, it does not propose

that Hawkins Landing boat ramp be operable a minimum number of 155 days, if possible,

during the recreation season nor does it include that the Iron Canyon dam boat ramp be

operational at 90 percent of operational lake levels. Additionally, PG&E proposes to,

within 2 years of license issuance, conduct a site assessment to determine if there is one

or more suitable sites to relocate the existing Deadlun Campground along the Iron

Canyon reservoir shoreline and to determine the locations for the shoreline access areas.

If agreement can be reached on alternate location(s) to relocate the campground and

determine feasible access areas, PG&E would construct a new campground and the

access areas. If suitable location(s) do not exist for the campground, PG&E maintains

that it would reconstruct Deadlun Campground as proposed. Finally, PG&E alternative

condition 30 does not propose the lighting specification at Iron Canyon dam boat ramp,
269

and PG&E proposes to revise the snow removal specification to specify that when project

operations require snow removal from Oak Mountain Road, snow also would be removed

from the access road to the boat ramp, parking area, and boat ramp.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 30. The provisions specified in Forest Service modified condition 30 are

generally similar to those specified in the Forest Service’s original condition 30, except

Forest Service specifies that PG&E reconstruct Deadlun Campground to provide double

and triple campsites and construct a new campground for single unit sites at Gap Creek

site.

The Forest Service does not specify functionality of the Iron Canyon dam and

Hawkins Landing boat ramps or specific details related to the individual recreation

facilities in the final modified condition. The Forest Service incorporated specific details

into the draft Recreation Development and Management Plan, included as an enclosure to

the its filing (Forest Service, 2010, Enclosure 3).

In the draft Recreation Development and Management Plan, the Forest Service

recommends, lighting at all times when the Iron Canyon dam boat ramp is snow-free and

the establishment of a schedule for snow plowing at Iron Canyon dam boat ramp.

Although Forest Service modified condition 30 does not specify the new Iron Canyon

dam boat ramp be functional at 90 percent of operational lake levels, it does recommend

specific amenities for individual recreation facilities at Iron Canyon that are otherwise

generally consistent with the Forest Service’s original condition 30.

In its November 24, 2010, filing, PG&E objects to Forest Service modified

condition 30 but does not specify the components with which it disagrees.

Our Analysis

Reconstructing Hawkins Landing boat ramp and campground and providing

additional parking and restroom facilities would enhance recreational opportunities at

Iron Canyon reservoir and ensure that the project recreation facilities meet current and

future demand over the term of a new license. PG&E states the new proposed boat ramp

near Iron Canyon dam would be usable at minimum operating pool (2,593 feet) and it is

not cost effective to modify Hawkins Landing boat ramp to extend the recreation season.

PG&E further states that it has voluntarily operated Iron Canyon reservoir at or above

elevation 2,615 feet to ensure that visitors could use the only existing boat ramp,

Hawkins Landing, during the primary recreation season from May 15 to October 15.

Although providing as many usable recreation days as possible at Hawkins Landing boat

ramp would improve boating access at Iron Canyon reservoir, the Forest Service’s

specification in its original condition 30 for the Hawkins Landing boat ramp to be usable

for a certain number of days could be difficult for PG&E to accomplish as a license

condition. The Forest Service does not specify the number of days Hawkins Landing

boat ramp should be operable in its modified 4(e) condition. Constructing a second boat

ramp to be usable at minimum operating pool (2,593 feet) at Iron Canyon reservoir would
270

help to alleviate overcrowding of Hawkins Landing boat ramp by providing public

boating access to Iron Canyon reservoir during the entire recreation season.

Reconstructing or re-locating Deadlun Campground would also enhance

recreational opportunities at Iron Canyon reservoir by improving camping opportunities

at the reservoir. Because dispersed camping generally occurs along the main body of

Iron Canyon reservoir and the campground is currently located in a creek off the main

body of the reservoir, relocating Deadlun Campground to a more desirable location,

providing access to the reservoir from its current location, and improved facility

conditions would likely increase the use of this facility. Forest Service modified

condition 30 specifies that PG&E provide about the same minimum number of sites for

overnight camping at Iron Canyon as originally specified but that PG&E reconstruct

Deadlun Campground as a group camp site and construct a new campground at Gap

Creek to provide single unit sites. The Gap Creek site would be located along the main

body of the reservoir in a more desirable location. Although PG&E originally proposed

to reconstruct Deadlun Campground, its alternative condition 30 proposes to conduct a

site assessment to determine if there are one or more suitable sites to relocate the existing

Deadlun Campground along the Iron Canyon reservoir shoreline. If a suitable location

does not exist, PG&E proposes to reconstruct the campground in its current location with

access to the reservoir. Reconstruction of Deadlun Campground as a group campground

at its existing location and constructing a new campground at Gap Creek on the main

body of Iron Canyon reservoir would provide more camping opportunities at the reservoir

while improving facility conditions and increasing capacity at the campground. Further,

providing formal access to Iron Canyon reservoir shoreline from Deadlun Campground

would likely increase the use of this facility.

Constructing the proposed shoreline access areas would provide developed access

areas along the shoreline to help alleviate some of the dispersed recreation use occurring

along the reservoir shoreline. The Forest Service has not provided suggested locations or

evidence that the sites are feasible; therefore, conducting a site assessment as proposed by

PG&E would be appropriate to determine the locations for the three shoreline access

areas.

In its original condition 30, the Forest Service specified that PG&E provide

lighting and snow removal during March or April through December at Iron Canyon dam

boat ramp to provide safety for anglers fishing early or late in the day. PG&E comments

that California Boating standards do not require lighting. However, lighting would allow

anglers to fish longer during the recreation season and increase safety at the boat ramp.

Additionally, PG&E’s proposal to remove snow from Oak Mountain Road, the

access road to the boat ramp, parking area, and boat ramp when project operations require

it would also allow access to the boat ramp with minimal additional cost. The Forest

Service now recommends lighting when the boat ramp is snow-free and the establishment

of a schedule for snow plowing at Iron Canyon dam boat ramp as a part of its draft
271

Recreation Development and Management Plan enclosed with the modified 4(e)

conditions.

Pit 6 and 7 Reservoir Recreation Facilities

 Shoreline Access Trail: evaluate the feasibility (site suitability and public

safety) of providing a pedestrian shoreline access trail at the upper end of Pit 7

reservoir, downstream of Pit 6 powerhouse tailrace, to provide access for

angling and pedestrian shoreline access.

 Montgomery Creek Boat Put-in: conduct a feasibility assessment for providing

a hand-launch boat put-in where Montgomery Creek enters Pit 7 reservoir,

with paved parking, vault restroom, tables, trash receptacles/removal and

pedestrian shoreline access trail. Boating would be restricted near project

infrastructure for public safety reasons by installing buoy lines at the upper and

lower ends of the Pit 7 reservoir.

In its original condition 30, the Forest Service specified that PG&E construct new

facilities at Pit 6 and 7 reservoirs and improve access. We summarize the differences

between rehabilitation measures specified in the Forest Service’s original condition 30

and those proposed in PG&E alternative condition 30, below.

 Pit 6 Shoreline Trail: develop a shoreline trail if capacity or demand (based on

6-year recreation use monitoring) indicates increased use of the reservoir for

fishing or boating.

 Shoreline Access Trail: construct one trailhead with parking for a minimum of

three vehicles and develop a river access trail along one side of Pit 7 reservoir

for pedestrian fishing and hand-launch boating access. The Forest Service

specifies that the access point and trailheads would be located at the upper (Pit

6 dam access road) end of reservoir.

 Montgomery Creek Boat Put-in: conduct a feasibility assessment for providing

a hand-launch boat put-in where Montgomery Creek enters Pit 7 reservoir with

paved parking, vault restroom, tables, animal-resistant trash receptacles and

pedestrian access trail on public lands. Boating would be restricted from

project infrastructure for public safety reasons by installing buoy lines or other

safety devices at the upper and lower ends of the reservoir. If Montgomery

Creek is not feasible, PG&E would construct a second trailhead with parking

for a minimum of three vehicles and develop a river access trail along one side

of the reservoir for pedestrian fishing, and hand-launch boat access from the

lower end of Pit 7 reservoir.

PG&E’s alternative condition 30 does not include the Pit 6 shoreline trail specified

by the Forest Service’s original condition 30. PG&E also does not include a provision

for constructing a second trailhead and a hand-carry boat launch at the lower end of Pit 7

reservoir if Montgomery Creek is not feasible. On the other hand, PG&E does propose to
272

conduct a site evaluation within 2 years of license issuance that considers the suitability

and public safety of a pedestrian shoreline access trail at the upper end of the reservoir,

downstream of Pit 6 powerhouse tailrace. PG&E proposes to consult with the Forest

Service and, if a suitable location is determined, construct the trail and parking area at the

upper end of Pit 7 reservoir. Consistent with the Forest Service’s original condition 30,

PG&E proposes to conduct a feasibility assessment and construct, if feasible, a handlaunch boat put-in where Montgomery Creek enters Pit 7 reservoir.

In its comments on the draft EIS and its reply to comments on the draft EIS,

PG&E comments that no safe access points were identified during a field review at Pit 6

reservoir. Two potential access points were identified in the upper end of Pit 7 reservoir:

one just downstream of Pit 6 dam and the second located several miles downstream.

PG&E indicates it has thoroughly investigated all potential options and determined that it

is not feasible to provide safe and secure public access to Pit 7 reservoir near the dam. In

addition to issues associated with public vehicular access to the top of the dam, PG&E

notes that an ordinance prohibits boating within 500 feet of the dam and the reservoir

elevation can be 35 feet below the high water mark, which would require boaters to scale

the dam. PG&E comments that an old construction access road suggested by the Forest

Service has a grade that exceeds 20 percent and there are no options for lessening the

grade because of the steep topography. Moreover, the access road to the top of the dam

is only one lane wide and steep, and there is no place for the public to park along the road

or at the top of the dam.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 30. Forest Service modified condition 30 does not specify a shoreline trail or

any other recreation facility at Pit 6 reservoir. Additionally, Forest Service modified

condition 30 specifies that PG&E would develop two surfaced parking areas with

reservoir access trails at the upper end of Pit 7 reservoir, located about 1 mile apart below

Pit 6 dam, instead of one as specified in the Forest Service’s original condition 30.

Although Forest Service modified condition 30 specifies the development of a parking

area with a walkway to a put-in/take-out on lower Pit 7 reservoir or Montgomery Creek,

it does not specify that a feasibility assessment be conducted, as was specified in the

Forest Service’s original condition 30. The Forest Service also removed specific details

of the recreation facility enhancements for Pit 6 and 7 reservoirs from the 4(e) condition

and placed them into the draft Recreation Development and Management Plan, included

as an enclosure to the filing (Forest Service, 2010d, Enclosure 3).

The Forest Service recommendation for the upper end of Pit 7 reservoir in the

draft Recreation Development and Management Plan is inconsistent with modified

condition 30. The Forest Service recommends three parking areas and pedestrian trails to

the reservoir shoreline at the upper end of Pit 7 reservoir with two of these within 1 mile

of Pit 6 dam in the draft plan instead of two, as specified in the modified condition. The

other recreation facilities and amenities included in the draft Recreation Development

and Management Plan for Pit 6 and 7 reservoirs are generally consistent with the Forest

Service’s original condition 30.
273

In its November 24, 2010, filing, PG&E objects to Forest Service modified

condition 30 but does not specify the components with which it disagrees.

Our Analysis

Providing access to the river near Pit 6 & 7 reservoirs based on the results of

future recreation use monitoring would improve recreational access at the project over the

term of the license. This measure could be considered in the future if the recreation use

data collected every 6 years shows it is warranted. Alternatively, constructing the

proposed river access trail at the upper end of Pit 7 reservoir and the proposed

Montgomery Creek hand-carry boat launch near the lower end of Pit 7 reservoir would

enhance access to Pit 7 reservoir for pedestrian fishing and hand-launch boating. The

Forest Service has not provided any justification for the additional access area at the

upper end of Pit 7 reservoir specified in its modified condition 30 and this additional

access area does not seem to be warranted at this time. However, the final Recreation

Plan should be consistent with the license order.

PG&E has expressed concern for public safety if boating access is provided at the

upper and lower portions of Pit 7 reservoir due to riverine high flows from the Pit 6

powerhouse and riverine conditions at low reservoir levels (fast flowing water) that could

prevent boaters from returning upstream to exit the reservoir. PG&E further indicates it

has thoroughly investigated all potential options and determined that it is not feasible to

provide safe and secure public access to Pit 7 reservoir near the dam. The Forest

Service's specification for a boat put-in/take-out on the lower end of Pit 7 reservoir or at

Montgomery Creek would still improve access to Pit 7 reservoir for pedestrian fishing

and hand-carry boating. However, due to public safety, launching boats in the lower end

of Pit 7 reservoir still remains a concern.

Pit 7 Afterbay Recreation Facilities

 Fenders Flat Day-Use Area: provide a day-use site at Fenders Flat with a

capacity of about five; provide parking, vault restroom, tables, fire grills, and

trash receptacles/removal; and coordinate with the Forest Service to develop

and implement a plan to revegetate disturbed areas and prevent vehicle access

beyond the access road and parking area.

 Fenders Flat Boat Launch: grade and maintain FR 35N66 from its intersection

with FR 37N78 to the car-top boat launch and provide a vault restroom near

the car-top boat launch.

 Pit 7 Afterbay Public Access: continue to prohibit public access to Pit 7

afterbay water surface and shoreline by maintaining fencing, signage and

patrols.

 Pedestrian Access in Vicinity of Pit 7 Afterbay Powerhouse: if the Pit 7

afterbay powerhouse is constructed, provide a paved parking area for two to

three vehicles at the end of the powerhouse access road or along Fenders Ferry
274

Road and provide a vault restroom, trash receptacle/removal, and pedestrian

access to the shoreline between the powerhouse and Fenders Ferry Bridge.

In its original condition 30, the Forest Service specified that PG&E rehabilitate the

existing Forest Service (non-project) facility at Pit 7 afterbay and improve access. We

summarize the differences between rehabilitation measures specified in the Forest

Service’s original condition 30 and those proposed in PG&E alternative condition 30,

below.

 Fenders Flat Day-Use Area: reconstruct day-use site below the Pit 7 afterbay

at Fenders Flat with single-vault toilet, animal-resistant trash receptacles,

picnic tables, pedestal grills (not campfire rings) and designated surfaced

parking area for a minimum of five vehicles without trailers.

 Fenders Flat Boat Launch: reconstruct the car-top boat launch with improved

grooved concrete surfacing and minimum one-lane width (would not meet all

of California Boating standards) and provide revegetation, in consultation with

the Forest Service, and prevent vehicle access beyond the access road and

parking area.

 Pedestrian Access in Vicinity of Pit 7 Afterbay Powerhouse: construct a

surfaced parking area and river access trail on the opposite river bank from

Fenders Flat day-use area with a vault toilet and trash receptacles if additional

generation is developed at the Pit 7 afterbay.

PG&E alternative condition 30 for the Fenders Flat day-use area is consistent with

the Forest Service’s original condition 30, although PG&E proposes the boat launch

reconstruction near Fenders Flat be separate from the day-use area. PG&E also notes that

the Pit 7 afterbay powerhouse parking area would accommodate two to three vehicles and

be located at the end of the powerhouse access road or along Fenders Ferry Road and

subject to public safety and homeland security needs. PG&E states that it proposes to

allow public vehicular access on the proposed project access road to the powerhouse;

however, if the location of access does not ensure public safety near project infrastructure

and address homeland security needs, PG&E would locate the parking area along Fenders

Ferry Road.

In its comments on the draft EIS, the Forest Service suggests that PG&E and the

Commission consider removal of the afterbay dam and construction of an alternative

structure to attenuate the flow to improve the safety of the project and allow for waterbased access, including angling and boating at the Fenders Flat site. The Forest Service

notes that anglers regularly cut the fence to gain access to the afterbay. Additionally, in

their comments on the draft EIS, California Trout, Trout Unlimited, Northern California

Council, Federation of Fly Fishers, American Whitewater, and Friends of the River

recommend the possible removal of the Pit 7 afterbay as a way to ameliorate the safety

concerns.
275

In it reply to comments on the draft EIS, PG&E states that Pit 7 afterbay is a

necessary public safety feature of the project because it serves to attenuate the water flow

from Pit 7 dam and powerhouse before entering Shasta Lake. PG&E states that removing

the afterbay dam would increase the hazard to recreational users in the area from flow

fluctuations from Pit 7 dam, or alternatively would require reoperation of the Pit River

system as a run-of-the-river operation because Pit 7 reservoir does not provide sufficient

storage to re-regulate all of the flow from peaking operations upstream. PG&E states that

it has taken reasonable measures to address the safety issue with fencing, signage, and a

boating buoy/barrier; however, recreational users are still trespassing at the afterbay dam.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 30. The provisions specified in Forest Service modified condition 30 for Pit 7

afterbay are similar to those specified in the Forest Service’s original condition 30.

Forest Service modified condition 30 specifies PG&E investigate known safety and

public access issues at the Pit 7 afterbay dam (with or without the proposed new

hydroelectric generation facility at the Pit 7 afterbay dam), develop alternatives to

address safety, and implement a solution after consultation with the Forest Service, other

conditioning agencies, and approval by the Forest Service and the Commission. Forest

Service modified condition 30 does not specify the construction of day-use area in the

vicinity of the proposed Pit 7 afterbay powerhouse as specified in condition 30.

The Forest Service also removed specific details of the recreation facility

enhancements from the 4(e) condition and placed them in the draft Recreation

Development and Management Plan, included as an enclosure to the filing (Forest

Service, 2010d, Enclosure 3). The other recreation facilities and amenities included in

the draft Recreation Development and Management Plan for Pit 7 afterbay area are

generally consistent with the Forest Service’s original condition 30.

In its November 24, 2010, filing, PG&E objects to Forest Service modified

condition 30 but does not specify the components with which it disagrees.

Our Analysis

Reconstructing Fenders Flat day-use area and providing, if the Pit 7 afterbay

powerhouse is constructed, access near the proposed Pit 7 afterbay powerhouse with

parking at the end of the powerhouse access road or along Fenders Ferry Road, subject to

public safety and homeland security needs, would enhance recreational opportunities in

the vicinity of the afterbay by formalizing this existing dispersed recreation area.

Coordinating with the Forest Service to develop and implement a plan to revegetate

disturbed areas and prevent vehicle access beyond the access road and parking area

would further help to reduce resource damage. Moreover, reconstructing Fenders Flat

car-top boat launch would improve access to the Pit River below the afterbay and provide

boater access to the Pit arm of Shasta Lake during late winter and early spring when high

lake levels allow boat launching. Although not specified by Forest Service modified

condition 30, providing shoreline access to the Pit River near the proposed Pit 7 afterbay

powerhouse, if the powerhouse is constructed, would provide a formal shoreline access
276

area for anglers in the vicinity of the Pit 7 afterbay that could help discourage trespass at

the Pit 7 afterbay dam where safety is an issue.

PG&E originally proposed to grade and maintain FR 35N66 from its intersection

with FR 35N78 to the car-top boat launch, although this was not included in Forest

Service modified condition 30 or PG&E alternative condition 30. This measure would be

addressed, along with all project roads, in the Road and Transportation Facilities

Management Plan proposed by PG&E that is further discussed in section 3.3.7.2,

Environmental Effects, Land Use Resources, Road and Transportation Facilities

Management Plan.

Public access to the Pit 7 afterbay and dam is currently restricted by PG&E

because the water level in the afterbay rapidly fluctuates in response to the Pit 7

powerhouse operation which makes it unsafe for recreation use. Both fencing and

warning signs have been posted to prohibit shoreline access and boating access.

Additionally, a Shasta County boating ordinance prohibits swimming and boating in the

afterbay due to public safety concerns. PG&E’s proposal to continue to prohibit public

access by maintaining fencing, signage, and patrols to Pit 7 afterbay water surface would

help ensure public safety at the project. In addition, PG&E proposes to construct the Pit

7 afterbay dam powerhouse which could help address the safety issues, because the

current stream power would be attenuated by the powerhouse. Furthermore, Forest

Service modified condition 30 specifies that PG&E investigate known safety and public

access issues at the Pit 7 afterbay dam (with or without the proposed new hydroelectric

generation facility at the Pit 7 afterbay dam), develop alternatives to address safety, and

implement a solution after consultation and approval. California Trout, Trout Unlimited,

Northern California Council, Federation of Fly Fishers, American Whitewater, and

Friends of the River recommend the possible removal of the Pit 7 afterbay as a way to

ameliorate the safety concerns. Safety at Pit 7 afterbay is a dam safety issue and not a

relicensing issue analyzed in this EIS. The Commission’s Division of Dam Safety and

Inspections has been working with PG&E on ways to address this problem, and we have

forwarded the information filed by interested parties in this proceeding that are relevant

to the issue of safety at Pit 7 afterbay to the Division of Dam Safety.

Recreation Facility Operation and Maintenance

PG&E proposes to develop an O&M component of the Recreation Plan, including

fee collection, for all existing and newly constructed project recreation facilities and

existing Forest Service recreation facilities within the project area (Tarantula Gulch boat

ramp and Deadlun Campground) after they are reconstructed.

In its original condition 30, part 1, subpart a, the Forest Service specified that

PG&E develop and implement an O&M component as a part of the Recreation Plan for

all project and project-associated recreation facilities (i.e., all facilities identified in the

Forest Service’s original condition 30). The O&M component should include: annual

schedule and standard protocols for opening and closing recreation facilities; water

testing protocols for potable water sources; routine maintenance items; annual review and
277

meeting; a percentage of fee retention by Forest Service if used onsite; and maintenance

of shaded fuel breaks around project recreation facilities (addressed in the Fire and Fuels

Management Plan discussed in section 3.3.7.2, Environmental Effects). The O&M

component would include all existing project recreation facilities, existing Forest

Service-owned project-affected recreation facilities identified in the Forest Service’s

original condition 30, and new project recreation facilities. Finally, discussions of any

needed actions would be conducted at the annual consultation meeting.

PG&E alternative condition 30, part 1, subpart a is consistent with the Forest

Service’s original condition 30, part 1, subpart a; however, PG&E proposes to become

responsible for O&M of existing Forest Service-owned project-affected recreation

facilities (Deadlun Campground and Tarantula Gulch boat ramp) after they have been

reconstructed.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 30. The provisions specified in Forest Service modified condition 30 related to

O&M are similar to those specified in the Forest Service’s original condition 30, part 1,

subpart a. Forest Service modified condition 30 additionally specifies that existing health

and safety conditions at some of the project recreation facilities are the result of previous

O&M practices and that PG&E would not be held responsible for the conditions of the

existing project recreation facilities until they are reconstructed.

The Forest Service has removed specific details of the Recreation Plan

components related to O&M from the 4(e) condition and placed them in the draft

Recreation Development and Management Plan, included as an enclosure to the filing

(Forest Service, 2010d, Enclosure 3). In the draft Recreation Facilities and Management

Plan (Forest Service, 2010d, Enclosure 3), the Forest Service recommends that O&M

measures developed and appended to the Recreation Plan would be implemented within

2 years of license acceptance and include the O&M of approved dispersed recreation

sites, ROS class, protocols, and reservoir surface management.

In its November 24, 2010 filing, PG&E objects to Forest Service modified

condition 30 but does not indicate the components with which it disagrees.

Our Analysis

O&M associated with the project’s recreation facilities help to ensure that these

facilities and associated public recreational access are provided over the term of the

license. Development of an O&M component as a part of the Recreation Plan in

consultation with the Forest Service would help to address PG&E and Forest Service

responsibilities. Submittal of a final Recreation Plan to the Commission for review and

approval after consultation with the Forest Service, agencies, and other interested parties

would help to ensure that the proposed O&M measures are consistent with the terms and

conditions of a new license.

PG&E is responsible for the management, operations, and routine maintenance of

all recreation facilities within the project boundary and would be responsible for existing
278

recreation facilities upon license issuance and new recreation facilities upon construction.

We recognize that Deadlun Campground and Tarantula Gulch boat ramp are existing

Forest Service facilities located inside the project boundary that are in need of

reconstruction, but delaying PG&E’s O&M responsibility for these facilities until they

are reconstructed is inappropriate. PG&E states that both the Deadlun Campground and

Tarantula Gulch boat ramp have documented health and safety issues as a result of Forest

Service construction, operation, and maintenance and that, if PG&E were held

responsible for O&M upon license issuance, this would result in PG&E immediately

being held in non-compliance with the new license. Since both Deadlun Campground

and Tarantula Gulch boat ramp are currently serving a project purpose and located inside

the project boundary, PG&E would be responsible for these facilities upon issuance of a

new license. However, we recognize that PG&E would be assuming responsibility for

the facilities as they currently exist.

Dispersed Use and OHV Use

PG&E proposes as a part of its Recreation Plan to assess and implement closures

of existing and future user-created roads leading to the shorelines of McCloud and Iron

Canyon reservoirs, in coordination with the Forest Service. The objective would be to

prohibit vehicle access at the McCloud reservoir between the shoreline and the two roads

along the reservoir (FR 38N11 and 38N04Y) between Tarantula Gulch and Star City

Creek and at Iron Canyon reservoir between FR 37N78 and the shoreline. This would

not include closure to developed recreation facilities.

In its original condition 30, part 2, the Forest Service specified that PG&E

evaluate road closures, trail closures, and dispersed use around Iron Canyon reservoir.

The Forest Service specified that this evaluation be consistent with the Shasta-Trinity

Travel Management Plan and the HPMP.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 30. Forest Service modified condition 30 removes the evaluation of road

closures, trail closures, and dispersed use around Iron Canyon reservoir from the

4(e) condition.

In the draft Recreation Development and Management Plan, included as an

enclosure to the filing (Forest Service, 2010d, Enclosure 3); however, the Forest Service

recommends that the final plan identify current dispersed recreation sites inside the

project boundary and access routes that would be closed.

In its November 24, 2010 filing, PG&E objects to Forest Service modified

condition 30 but does not indicate the components with which it disagrees.

Our Analysis

Measures to block vehicle access and discourage OHV use at the project would

benefit environmental resources by reducing intense recreational use at degraded areas.

However, all concerns associated with dispersed use would not be eliminated by blocking

vehicle access and discouraging OHV use. Although not included in the Forest Service
279

modified condition 30, assessment and evaluation of road closures, trail closures, and

dispersed use, in coordination with the Forest Service, would provide information to

allow PG&E to determine if additional visitor management controls are needed. PG&E

identified several areas around the reservoirs and project facilities where visitors leave

trash and cause resource damage due to dispersed use. Although not included in Forest

Service modified condition 30 and PG&E alternative condition 30, McCloud reservoir

was identified as an area where resource damage from user-created roads and dispersed

use was occurring during the relicensing studies. Including McCloud reservoir in the

evaluation would address areas identified at both reservoirs where dispersed use causes

resource damage. Prohibiting vehicle access and OHV use between the roads and

reservoir shorelines would help reduce this resource damage and improve the aesthetic

quality of the area for visitors to the project.

Recreation Monitoring

PG&E proposes to conduct recreation monitoring, including visitor surveys and

use estimates, concurrent with preparing information for the FERC Recreation Form 80

reporting (every 6 years). Additionally, PG&E proposes to include Hawkins Creek

crossing in the recreation monitoring program.

The Forest Service’s original condition 30, part 1, subpart b, is generally

consistent with PG&E’s proposal for recreation monitoring but specified that PG&E also

provide a copy of the report to the Forest Service for approval before being submitted to

the Commission. The recreation monitoring should include: annual use data collection at

facilities where fees or passes are issued or required for inclusion in the 6-year report;

conduct a recreational resource survey, with prior approval by the Forest Service, and

evaluation of resource impacts from developed and dispersed use; a summary of the most

current regional and statewide recreation trends based on available surveys and reports;

and consultation with the Forest Service, appropriate agencies, and interested parties to

review and adjust project-wide recreation management objectives, if needed.

PG&E proposes in its alternative condition that recreation and survey monitoring

components be collected for project-related recreation facilities and project lands and

waters in PG&E alternative condition 30, which is generally consistent with the Forest

Service’s original condition 30. PG&E states that revisions are necessary to the Forest

Service’s original condition 30 to appropriately define the applicability to project-related

recreation.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 30. The provisions specified in Forest Service modified condition 30 related to

recreation monitoring are similar to those specified in the Forest Service’s original

condition 30, part 1, subpart b, except that the Forest Service has removed specific details

of the recreation survey and monitoring component from the 4(e) condition and placed

them in the draft Recreation Development and Management Plan, included as an

enclosure to the filing (Forest Service, 2010d, Enclosure 3).
280

In the draft Recreation Facilities and Management Plan (Forest Service, 2010d,

Enclosure 3), the Forest Service recommends that the survey and monitoring report

include the following: utilization of data collected at facilities where fees or passes are

issued or required, occupancy of project facilities and dispersed use sites over the entire

recreation season; use numbers and use patterns on water and land; recreational

opportunity satisfaction; kinds and sizes of vehicles; user preferences; evaluation of

resource impacts from developed and dispersed use; current regional and statewide

recreation trends; updated mandates; condition of facilities; and summary of any

temporary facility closures.

In its November 24, 2010, filing, PG&E objects to Forest Service modified

condition 30 but does not indicate the components with which it disagrees.

Our Analysis

Recreation use at the project is expected to exceed the rate of population growth

over the next 50 years. The level and type of recreation use and recreation user

preferences could change over the term of a new license. Based on PG&E’s visitor use

surveys conducted during the relicensing studies, angling is expected to increase at

project facilities over the next 40 years by about 107 percent, water-based recreation

activities (including swimming and boating) by about 229 percent, camping by about 182

percent, and scenery, wildlife, and nature viewing by about 168 percent. Periodic

monitoring of recreation use, surveying of user preferences, assessment of facility

capacity and recreation demand, and inventorying areas used for dispersed recreation can

help to determine if the project’s recreation facilities meet demand and provide adequate

public recreation access to the project over the term of the license. The inclusion of

visitor use fees and capacity information, including both parking and campsite capacity at

the project facilities, would help assess changes in recreational use and capacity at these

facilities. The proposed report would provide the means to summarize and assess the

survey information and monitor other recreational management provisions, such as OHV

and dispersed use and water surface elevation management. Reporting the recreation

monitoring results concurrent with the Commission’s recreation Form 80 schedule would

ensure that the Commission is updated on recreation use at the project.

Project Patrol

PG&E proposes to provide project-wide patrol of areas including but not limited

to Hawkins Creek crossing, Iron Canyon reservoir shoreline dispersed use sites, and

McCloud reservoir shoreline access points. This would include trash removal twice a

year, reporting observed resource damage to Forest Service, and emergency response at

the project. PG&E proposes to prepare a Project Patrol Plan in consultation with the

Forest Service to be filed with the Commission within 1 year after license issuance. At a

minimum, the plan would include routine and regular physical inspections of affected

lands, project facilities, and other structures, including NFS lands within the project area

or affected by project facilities, for purposes of resource protection. The plan also would

include a description of reporting responsibilities, including observed violations of law
281

and communications with law enforcement agencies, as well as required documentation

of inspections. Additionally, PG&E proposes to provide a campground host at several

project campgrounds to also serve as a point person for enforcing campground rules and

reporting vandalism.

In its original condition 30, part 1, subpart c, the Forest Service specified that

PG&E develop and implement a project patrol component as a part of the Recreation

Plan for project and project-affected NFS lands. The Forest Service specified that PG&E

coordinate annually with agencies and other interested parties to review patrol

information and plan adjustments, if needed, for the next season. Specifically, PG&E

would employ a seasonal part-time (April-November) project patrol person or,

alternatively, provide funding to an appropriate federal, state, or local agency for the

same, whose duties would include, but not be limited to: monitoring and encouraging

compliance with fire safety regulations, closures, and rules associated with camping,

parking, and trail use; installing signs; dispersing project-related information to the public

including appropriate OHV use, campfire safety, leave no trace; patrolling dispersed use

areas within one-quarter mile of all project and project-affected waterways (e.g., Hawkins

Creek crossing, Lower McCloud River); watching for and reporting looting/vandalism of

cultural sites or other resource damage and illegal activities; cooperating with law

enforcement agencies; performing minor maintenance of project recreation facilities;

other duties related to public safety and protection of project-affected resources; and

documenting activities, key resource issues, and public concerns in an annual report

provided at least 30 days prior to the annual consultation meeting. The Forest Service

also specified a campground host be provided at several project campgrounds to serve a

similar patrol purpose. The Hearst Corporation supports the concept of a host or patrol

person enforcing the conditions of recreational use and the issuance of a Forest Service

“Forest Order” allowing for enforcement action.

PG&E alternative condition 30 is generally consistent with the Forest Service’s

original condition 30; however, PG&E does not propose the patrol of dispersed public

use areas within one-quarter of a mile of the Lower McCloud River nor the distribution

of OHV use information. PG&E comments that revisions are necessary to appropriately

define the applicability to project-related recreation and to eliminate ambiguous and

open-ended terminology that could inadvertently result in non-compliance.

In their comments on the draft EIS, the Pit River Tribe and The Hearst

Corporation recommend project patrols to encourage compliance and improve safety.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 30. Forest Service modified condition 30 specifies that PG&E would develop a

separate Project Patrol Plan and that the duties of the project patrol would be

implemented on a year-round basis. The Forest Service includes specific details of these

duties as recommendations in the draft Project Patrol Plan, included as an enclosure to

the filing (Forest Service, 2010d, Enclosure 3).
282

The duties of the project patrol recommended in the draft Project Patrol Plan are

generally consistent, although more comprehensive, than those specified by the Forest

Service in its original condition 30. In the draft Project Patrol Plan (Forest Service,

2010d, Enclosure 3), the Forest Service recommends that the primary responsibilities of

the project patrol would include: providing project information to project visitors;

identifying and recording violations or project related federal, state, or local laws and fire

laws; providing trash pick-up and small repairs; recording and reporting any significant

damages to project facilities, project protection, mitigation, and enhancement measures,

project lands, and NFS lands affected by the project; identifying and reporting potential

threats to public safety; maintaining a daily patrol log; providing timely communication

with PG&E, Forest Service, law enforcement, and emergency response agencies; limited

boat patrols for monitoring recreational use areas that are not accessible by land; and

documenting activities, specific hazards or damage, repairs, and significant or repetitive

problems an annual report provided by January 15 of the following year.

In its November 24, 2010, filing, PG&E objects to Forest Service modified

condition 30 but does not indicate the components with which it disagrees.

Our Analysis

Project patrol measures would help encourage visitors, including anglers,

campground users, and boaters, to comply with regulations and project rules. A projected

increase in the number of visitors over the term of the new license would likely increase

the need for public services, including law enforcement and fire protection, which are

provided by the Shasta County Sheriff’s office. More visible law enforcement like a

project patrol person or a campground host would help reduce conflicts between

recreation users and improve visitor safety by providing an authoritative presence to

encourage compliance with navigational laws. Additional project patrol at the more

remote areas of the project would improve management of environmental resources by

increasing visitor contact with enforcement agencies and help to educate visitors about

appropriate and restricted uses.

However, within the project area, public safety and law enforcement duties are the

responsibility of the Shasta County Sheriff’s office, the California Highway Patrol, and

federal agencies on federal lands. All existing project lands are within the jurisdiction of

the Shasta County Sheriff. PG&E pays property taxes to Shasta County, which are

partially used to fund law enforcement. Further, Forest Service law enforcement

personnel from the Shasta-McCloud and National Recreation Area units of the ShastaTrinity National Forest are responsible for enforcing regulations related to the

management of Forest Service lands and resources. The Commission has no way of

ensuring that the hiring of a patrol person or campground host paid for by PG&E (in this

case staffing or funding a seasonal or year-round employee), would accomplish a project

purpose or ameliorate a project effect. However, the Commission can enforce specific

measurable actions, such as O&M measures, including maintenance of project lands and

project recreation facilities to address fire safety and vandalism, and other associated
283

potential effects of dispersed recreation use within the project boundary. Under the

Informational Sign Plan, PG&E proposes to post signs about acceptable and prohibited

recreation uses, and have proposed new measures that would increase public education to

help improve visitor compliance with project rules and regulations. While improved

implementation of Forest Service and Shasta County standards and guidelines regarding

recreational use would be beneficial, enforcement of those regulations would be outside

the jurisdiction and responsibility of PG&E.

Reservoir Water Surface and Shoreline Management

PG&E proposed to clean debris from the McCloud reservoir boat ramp annually

by April 1, weather permitting, and as needed throughout the recreation season.

Additionally, PG&E proposed to develop a surface water and shoreline management plan

for McCloud reservoir that included installing 5-mph signs on the bridge that spans the

northern end of the reservoir, LWD removal from the reservoir, points of public access to

the shoreline, and boating speeds. PG&E also proposed to remove lightweight debris

from the Iron Canyon reservoir surface annually or as needed.

In its original condition 30, part 1, subpart d, the Forest Service specified that

PG&E develop and implement a reservoir water surface management component that

addresses monitoring and management of recreation user safety, trespass on private lands

by project users, and Shasta County code compliance by project users on each reservoir

surface (i.e., McCloud, Iron Canyon, Pit 6, and Pit 7 reservoirs). The reservoir water

surface management component would include the following: developing protocols for

preventing/removing unapproved buoy courses, approved use of docks, and measures to

prevent trespass on private lands; submitting requests to the Shasta County Boating Unit

of the Sheriff’s office for establishment of a 5-mph restriction on McCloud reservoir

upstream from the McCloud Bridge, in consultation with the Forest Service;

establishment of a buoy line near Huckleberry Creek on McCloud reservoir to prevent

fishing boats from traveling upstream from November 15 to the last Saturday in April

each year (submission would be in cooperation with California Fish and Game and the

private landowner); annual surface sweeps prior to the start of the recreation season of

McCloud and Iron Canyon reservoirs and boat ramps to collect logs and debris from the

lake surface with smaller debris and trash removed from NFS lands; monitoring boat use

during the recreation season on McCloud and Iron Canyon reservoirs every 6 years

(coinciding with the Commission’s recreation Form 80); reassessing any needed water

surface management mitigations every 6 years; and evaluating the need for a speed

restriction on Iron Canyon, Pit 6, and Pit 7 reservoirs on a 6-year interval.

PG&E alternative condition 30 proposes to develop measures prevent

unauthorized access to project lands and waters where necessary to protect public safety,

instead of on private lands. PG&E also proposes to conduct the surface sweeps to collect

logs and debris from the surface of McCloud and Iron Canyon reservoirs and boat ramps

once every 5 years or as needed instead of annually. Finally, PG&E proposes to include

monitoring data on boat use on McCloud and Iron Canyon reservoirs in a report filed
284

with the Forest Service, interested agencies, and the Commission concurrent to the Form

80 schedule.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 30. The provisions specified in Forest Service modified condition 30 related to

reservoir water surface management are similar to those specified in the Forest Service’s

condition 30, part 1, subpart d; however, the Forest Service has removed the specific

details of the reservoir surface water management measures from the 4(e) condition and

has not included them in the draft Recreation Development and Management Plan,

included as an enclosure to the filing (Forest Service, 2010d, Enclosure 3).

In the draft Recreation Development and Management Plan (Forest Service,

2010d, Enclosure 3), the Forest Service recommends reservoir surface management

measures including woody debris capture on McCloud reservoir; approved use of docks

and buoys; measures to discourage trespass onto private lands; speed restrictions; buoy

lines and buoy courses; and fishing closures or seasonal limits. The Forest Service

recommendations included in the draft Recreation Plan related to reservoir water surface

management do not provide the details that were contained in the Forest Service’s

original condition 30, part 1, subpart d.

In its November 24, 2010, filing, PG&E objects to Forest Service modified

condition 30 but does not indicate the components with which it disagrees.

Our Analysis

Developing protocols for preventing/removing unapproved buoy courses and

approved use of docks would help prevent boating hazards and improve public

recreational safety at the project reservoirs. Surface sweeps of McCloud and Iron

Canyon reservoirs and boat ramps would collect and remove surface debris to reduce

boating hazards and ensure that the boat ramps are not blocked by debris. PG&E

alternative condition 30 proposes surface sweeps of McCloud and Iron Canyon reservoirs

and boat ramps once every 5 years or as needed instead of annually as originally

proposed by PG&E and specified in the Forest Service’s original condition 30. The

Forest Service commented that winter storm debris on the reservoir surfaces accumulates

at access points and boat ramps. The annual sweeps originally proposed by PG&E and in

the Forest Service’s original condition 30 would ensure that winter storm debris that

could accumulate annually is collected and removed prior to the recreation season. As

discussed in section 3.3.1.2, Environmental Effects, Large Woody Debris, Forest Service

modified condition 21 specifies the development of an LWD Plan that would provide a

procedure for the capture and removal of woody debris from the surface of McCloud

reservoir. In the draft LWD Plan, included as an enclosure to the filing (Forest Service,

2010d, Enclosure 3), the Forest Service recommends the capture of LWD on the surface

of McCloud reservoir annually in spring.

The Forest Service’s original condition 30 specified and PG&E alternative

condition 30 propose that PG&E, in cooperation with the Forest Service, would submit a
285

request to the Shasta County Boating Unit of the Sheriff’s office for the establishment of

a 5-mph restriction on McCloud reservoir upstream from the McCloud bridge and a buoy

line to be installed near Huckleberry Creek. Although speeding on the reservoirs has

been identified as an issue by project users, enforcement of speed restrictions is not the

responsibility of the Commission. The Shasta County Boating Unit of the Sheriff’s office

is responsible for boating safety enforcement on all waterways within Shasta County,

including the project reservoirs. PG&E is subject to local laws and ordinances as they

pertain to reservoir speed limits.

The Forest Service specifies measures to discourage trespass on adjacent private

lands to protect public safety. Preventing trespass on private lands outside the project

boundary is outside the Commission’s authority; it is the responsibility of private

landowners to clearly mark their property if trespassing is problematic. However,

measures to prevent unauthorized access to project lands and waters where necessary to

protect the public would ensure public safety at the project and help address the issue of

trespassing at the project, especially at Pit 7 afterbay where public access is prohibited.

Recreation use at the project is expected to exceed the rate of population growth

over the next 50 years. Monitoring boat use, as recommended in the draft Recreation

Development and Management Plan, included as an enclosure to the Forest Service

November 29, 2010 filing, and specified in the Forest Service’s original condition 30,

would help to identify excessive use and potential user conflicts on project reservoirs and

this information could be used to examine existing use and develop mitigation measures

if use is excessive or creating conflict among reservoir-based recreation users. Including

a boat monitoring and reporting protocol as a part of monitoring efforts concurrent with

the Commission’s recreation Form 80 schedule would ensure project facilities, including

reservoirs, are meeting recreation demand over the term of the license.

Project Signage and Interpretative Information

PG&E proposed to develop and implement a Project Sign Plan specific to

directional and facility signs for the project and project recreation facilities, but not to

include traffic and road signs. In addition, PG&E proposed to develop and implement an

Interpretive and Education Plan that would be specific to interpretation and education

about the project.

In its original condition 31, the Forest Service specified that PG&E develop and

implement a Sign Plan which includes directional, traffic, and road and safety signs, with

the addition of an interpretive and educational component. The plan would include the

types of informational signs to be developed, the design and content of each sign, and the

locations where the signs would be placed. The interpretive and educational component

of the Project Sign Plan would include the design, delivery methods, a schedule for

implementation as well as a website with public information to include information about

project recreation facilities such as directions, seasonal fees, streamflow information,

seasonal reservoir levels, fish stocking, and scheduled work that would change flows or

reservoir levels or affect access to recreational facilities. Informational kiosks containing
286

fee and regulation information, seasonal and safety information, and project maps would

also be placed at all developed recreation facilities.

PG&E alternative condition 31 is consistent with the Forest Service’s original

condition 31; however, PG&E proposed that the most efficient and effective means of

providing project recreation information to the public would be to post it on the Forest

Service’s website instead of posting the information on a website hosted by PG&E.

Furthermore, PG&E stated it would not provide specific information, such as real-time

reservoir levels that could be used by competitors, to the public as part of the project

recreation information. PG&E viewed this confidential business information to be

proprietary in nature.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 31. Although not specified in the Forest Service’s original condition 31, Forest

Service modified condition 31 specifies that a draft Sign and Interpretive/Education

Management Plan be developed within 2 years of license acceptance and include a sign

inventory. Additionally, Forest Service specifies that the plan would apply to all nontraffic signs.

The Forest Service removed specific details of the Sign Plan components from the

original 4(e) condition and placed them in the draft Sign and Interpretive/Education

Management Plan, included as an enclosure to the filing (Forest Service, 2010d,

Enclosure 3) within the project. The components recommended in the Forest Service’s

draft Sign and Interpretive/Education Management Plan are generally consistent,

although more comprehensive, than those specified in the Forest Service’s original

condition 31. According to the draft Sign and Interpretive/Education Management Plan

road and traffic signs associated with roads external to recreation facilities would be

included in the Road and Transportation Facility Management Plan. Interpretive and

educational panels are included in the draft Sign Plan as a means of implementing the

information and education component.

In the draft Sign and Interpretive/Education Management Plan, the Forest Service

recommends the following: updating the relicensing sign inventory conducted in 2007

and development of specific sign standards and design; specific protocols for installing,

maintaining, and monitoring project-related signs including repairing or replacing

existing signs based on the sign inventory, installing new sign and interpretive/education

displays, updating the sign inventory within six months of final sign installation; and

specific measures for the interpretive and educational component, including design,

delivery methods, a schedule for implementation as well as a website with public

information to include information about project recreation facilities such as directions,

seasonal fees, streamflow information, seasonal reservoir levels, fish stocking, and

scheduled work that would change flows or reservoir levels or affect access to

recreational facilities.
287

Our Analysis

The project currently does not have a coordinated and systematic process for the

development of signage and interpretative information associated with the project.

Development and implementation of a Project Sign Plan with associated interpretive and

educational measures for the McCloud-Pit Project would provide the means for

coordinated and systematic development of signage and interpretative information

associated with the project. The Project Sign Plan would also provide the means to

ensure that signage within the project is maintained and conforms to the Forest Service

standards on lands that are visible from NFS lands. Development of the final Sign Plan

within 2 years of license issuance, as specified in Forest Service modified condition 31

and proposed by PG&E, would be appropriate given that the final plan would include an

update to the relicensing sign inventory conducted in 2007 and development of standards

and designs for signs. Updating the relicensing sign inventory conducted in 2007 would

ensure that the final Sign Plan is based on the most recent status of signs throughout the

project. Furthermore, providing interpretive and education panels, or informational

kiosks, as recommended by the Forest Service in the draft Sign Plan, at the project would

also improve recreation access and safety by providing visitors with maps of the area and

safety information at each developed recreation site.

Developing a public website to host recreation information on the project would

provide a source for visitors to locate recreation information about the project. However,

we note that the Commission does not require that proprietary or confidential business

information be made available to the public. Although the Forest Service is the main

recreation provider in the area and the source that visitors commonly use to locate

recreation information, the Commission only has authority over its licensees and cannot

require the Forest Service to post project information on its website.

Provision of Streamflow Information

PG&E proposes to provide the following information to the public via the internet

as a part of the Recreation Plan: real-time water flow data (hourly average) for the Lower

McCloud River using gage data from gage MC-1 (gage at Ah-Di-Na), forecasts of known

events that would affect water flow (e.g., powerhouse outage) on the Lower McCloud

River, information about typical drawdown patterns for McCloud and Iron Canyon

reservoirs, and information during the recreation season on current reservoir elevations in

relation to the use of project boat launches.

In its original condition 19, part 3, the Forest Service specified that PG&E operate

and maintain existing gages for the purpose of determining the river stage and minimum

streamflow on the Lower McCloud River below McCloud dam, Pit River below the Pit 7

dam, and Iron Canyon Creek below the Iron Canyon dam, consistent with all

requirements of the Commission and under the supervision of USGS. The Forest Service

specified that PG&E measure and document all instream flow releases to be made

available to the public and post real-time flow data at MC-1 on the CDEC or its

successor’s website. Flow data collected by PG&E from the stream gages would be
288

reviewed by PG&E’s hydrographers as part of its QA/QC protocol and made available to

USGS in annual hydrology summary reports that USGS could post within its electronic

database that can be accessed via the internet. Forest Service original condition 31 also

specified that PG&E develop and implement a public website with the above information

as a part of the Project Sign Plan.

PG&E alternative condition 31 is consistent with the Forest Service’s original

condition 31; however, PG&E proposed to provide the information to the Forest Service

for posting on the Forest Service website. PG&E commented that providing public

information through the Forest Service website would be more efficient and effective

because the Forest Service is the main recreation provider in the area.

In its November 29, 2010, filing, the Forest Service includes modifications to

conditions 19 and 31. The provisions specified in Forest Service modified condition 19,

part 2 related to streamflow measurement are the same as those specified in the Forest

Service’s original condition 19, part 3, as discussed above. The Forest Service removed

the specific details related to the Project Sign Plan from the 4(e) condition, including

developing and implementing a public web site with streamflow information and

reservoir levels, and placed them in the draft Sign and Interpretive/Education

Management Plan, included as an enclosure to the filing (Forest Service, 2010d,

Enclosure 3).

With the exception of recommending that streamflow information from both

USGS gage MC-7 (gage at McCloud dam) and gage MC-1 (gage at Ah-Di-Na

Campground) be posted on the project web site, the Forest Service recommendations in

the draft Sign Plan for the information to be posted on the web site remain unchanged

from the specifications for the web site included in the Forest Service’s original

condition 31.

In its November 24, 2010, filing, PG&E accepts modified condition 31 and

withdraws its alternative condition 31.

Our Analysis

Accurate and timely streamflow information and information about the usability of

the project boat launches can assist recreationists in planning water-related visits to the

project. If this information is not easily accessible to the public, recreationists may not be

able to take full advantage of recreation opportunities and may not be appropriately

prepared for streamflow conditions which could lead to public safety issues.

PG&E’s proposal and the Forest Service’s specification in modified condition 19,

part 2 to provide accurate and timely streamflow information at gage MC-1 to the public

via the internet would provide the means for the public to gain information regarding

streamflow and reservoir levels for specified stream reaches and reservoirs at the project.

As discussed in section 3.3.2.2, Environmental Effects, Flow Monitoring and

Determination of Water Year Type, the continued O&M of gage MC-7 and gage MC-1

would help to ensure that these gages remain functional to monitor flow compliance and
289

ensure that flow data for the Lower McCloud River continues to be available to the

general public. Providing accurate and timely streamflow information at gage MC-7, in

addition to gage MC-1, to the public via the internet would provide the public with

additional streamflow information for the Lower McCloud River. This information could

then be used by the public to determine if recreation opportunities and desired flow

ranges for angling, boating, and other recreation activities would be available. This

would allow the public to take better advantage of opportunities for recreation use at the

project and in the Lower McCloud River. Although visitors commonly use the CDEC or

Forest Service’s website to locate water-based recreation information, the Commission

only has authority over its licensees and cannot require the CDEC or the Forest Service to

post project information on its website.
290

3.3.6 Cultural Resources

3.3.6.1 Affected Environment

Section 106 of the National Historic Preservation Act

Section 106 of the NHPA as amended requires the Commission to take into

account the effects of licensing a hydropower project on any historic properties and allow

the Advisory Council on Historic Preservation (Advisory Council) a reasonable

opportunity to comment if any adverse effects to historic properties are identified within

the hydropower project’s APE.

Historic properties are defined as any district, site, building, structure, or object

that is included in or eligible for inclusion in the National Register. In this document, we

also use the term “cultural resources” to include properties that have not been evaluated

for eligibility for listing in the National Register. In most cases, cultural resources less

than 50 years old are not considered eligible for the National Register. Cultural resources

need enough internal contextual integrity to be considered historic properties. For

example, dilapidated structures or heavily disturbed archaeological sites may not have

enough contextual integrity to be considered eligible. TCPs are a type of historic

property that are eligible for the National Register because of their association with

cultural practices or beliefs of a living community that: (1) are rooted in that

community’s history; or (2) are important in maintaining the continuing cultural identity

of the community (Parker and King, 1998).

Section 106 also requires that the Commission seek concurrence with California

SHPO on any finding involving effects or no effects on historic properties and allow the

Advisory Council an opportunity to comment. If TCPs have been identified, section 106

also requires that the Commission consult with interested Native American tribes that

might attach religious or cultural significance to such properties.

If existing or potential adverse effects have been identified on historic properties,

the applicant needs to develop a HPMP to seek to avoid, reduce, or mitigate the effects.

Potential effects that may be associated with a hydroelectric project include any projectrelated effects associated with the day-to-day O&M of the project after issuance of a new

license. During development of the HPMP, the applicant should consult with the

Commission, Advisory Council, California SHPO, Indian tribes, and Forest Service. In

most cases, the HPMP would be implemented by execution of a PA that would be signed

by the Commission, Advisory Council (if it chooses to participate), California SHPO, and

other consulting parties.

Area of Potential Effects

Pursuant to section 106, the Commission must take into account whether any

historic property could be affected by the issuance of a proposed new license within a

project’s APE. The APE is determined in consultation with the California SHPO and is

defined as the geographic area or areas within which an undertaking may directly or
291

indirectly cause alterations in the character or use of historic properties, if any such

properties exist. In this case, the APE for the McCloud-Pit Project includes lands within

the project boundary, as delineated in the current Commission license, plus lands outside

the project boundary where project operations may affect the character or use of historic

properties or TCPs.

The APE for the proposed project has been defined by the Commission as the land

within the proposed project boundary (project area), and encompasses the following

(PG&E, 2009d):

 100 feet from either side of the banks of the McCloud River, downstream from

McCloud dam to the confluence of Squaw Valley Creek (McCloud River

Expanded APE);25

 Public land between the perimeter road around McCloud reservoir and the

water surface from Tarantula Gulch, crossing McCloud dam, to Star City

Creek;

 The area between the perimeter road around Iron Canyon reservoir and the

water surface; and

 And the area contiguous with tunnel spoil areas having a reasonable potential

to contain archaeological materials based on topography and site conditions.

The proposed project area above project tunnels is excluded from the APE as there

are no surface activities anticipated in this area. In addition, lands on the west side of the

McCloud River, upstream from the Tarantula Gulch boat launch, and lands associated

with Fenders Flat at the Pit 7 afterbay, are also included in the APE (PG&E, 2009d).

Also encompassed within the APE are all lands affected by the construction of the

proposed powerhouse at the Pit 7 afterbay and McCloud dams. These areas include

(PG&E, 2009d):

 A 200-foot buffer around the proposed powerhouse site at the base of McCloud

dam;

 A 200-foot corridor centered on the proposed McCloud and Pit 7 afterbay

transmission line routes;

 A 200-foot buffer around the proposed Pit 7 afterbay powerhouse and

substation on the west side of the Pit 7 afterbay dam weir;

 A 200-foot corridor centered on the proposed location of the access road

between FR 34N17 and the proposed Pit 7 afterbay powerhouse site; and

25 Survey access to the APE on private lands along the McCloud River

downstream of The Nature Conservancy lands was not granted.
292

 An area on the west side of the Pit River arm of Shasta Lake extending from

the high-water mark upslope to the proposed access road corridor between the

Pit 7 afterbay dam and FR 34N17.

Preliminary study results from RL-S6, Traffic Study and Road Condition

Inventory, indicated that uses related to the proposed project are “sufficient to establish a

clear nexus with the Project or other Project-related activities,” and have the potential to

create impacts to historic properties; thus, a portion of the road near Blue Jay Creek on

NFS lands is also included in the APE. Similarly, lands located outside of the

Commission-defined project boundary that was identified in TM-16, Data Summary for

Developed and Dispersed Recreation, are included in the APE as well (PG&E, 2009d).

Cultural History Overview

The study area is located in the southern-most extension of the larger Cascade

Range, within what is described as the Cascade Range Geomorphic Province (PG&E,

2009d; Harden, 1998 as cited by PG&E, 2009d; Schoenherr, 1992 as cited by PG&E,

2009d). The majority of the Cascade range is typified by rolling, forested terrain, with

the dominant ecology in lower elevations consisting of yellow pine forest, while higher

elevations are represented by Mount Lassen and Mount Shasta, two of the regions highest

volcanic peaks. Mount Lassen measures 10,457 feet in height and sits amid an active

volcanic region that includes hot springs, cinder cones, calderas, lava tubes, and

fumaroles. Mount Shasta is a large stratovolcano, 14,162 feet in height, and is located

about 80 miles north of Mount Lassen (PG&E, 2009d; Harden, 1998 as cited by PG&E,

2009d). Although the Cascade Range has been volcanically active for about 36 million

years, most volcanoes in the range are between two and 5 million years old (PG&E,

2009d; Harden, 1998 as cited by PG&E, 2009d; Schoenherr, 1992 as cited by PG&E,

2009d).

The Pit River and the McCloud River are the two main waterways that drain the

northern California Cascade Range, both of which feed into Shasta Lake. Several creeks,

including Hat Creek, Burney Creek, and Clark Creek run into the Pit River. Several

waterfalls line the Upper McCloud River, north of McCloud reservoir, while the Lower

McCloud River flows through a deep, narrow canyon after leaving the reservoir (PG&E,

2009d). Human occupation of the area began as small, scattered sites serving a huntergatherer culture, eventually evolving into a subsistence economy as technology

progressed (PG&E, 2009d).

The cultural chronology of Shasta County proposed by Clewett and Sundahl

identified a four-part chorological sequence of human occupation stretching back

8,000 years (PG&E, 2009d; Clewett and Sundahl, 1982, 1983 as cited by PG&E, 2009d).

Evidence of human occupation in Shasta County prior to 8,000 years ago is minimal,

consisting of a few isolated fluted projectile points and crude metavolcanic tools typically

dating from circa 12,000-10,000 BP. The argument has been made that these tools

represent a late Pleistocene/early Holocene occupation, as they were found on Pleistocene

terraces; however, no stratified, undisputed Paleoindian site has been identified within
293

Shasta County (PG&E, 2009d; Brott and Dotta, 1978 as cited by PG&E, 2009d; Dillon,

1994 as cited by PG&E, 2009d).

Clewett and Sundahl termed the earliest period of occupation the Early Archaic

(6000-3000 BC) period, which is characterized by wide-stemmed projectile points and

ground stone implements, leading some scholars to assert cultural affiliation with the

Borax Lake area in southeastern California (PG&E 2009a; Moratto, 1984 as cited by

PG&E, 2009d). Early Archaic settlements appear to have been small and scattered in

foothills and along waterways, with ground stone assemblages that suggest a heavy

reliance on seeds and nuts with supplemental additions of mammals and fish. Few faunal

assemblages from the period have been analyzed, however, and it has been suggested that

the “correspondence between wide-stem points and elk distributions in other parts of

California” indicate a reliance on elk as a food source during this period (PG&E, 2009d;

Kowta, 1984 as cited by PG&E, 2009d).

The Middle Archaic, spanning 3000-500 BC, is characterized by a more

diversified tool kit, encompassing medium to large corner and side-notched projectile

points. Though the use of ground stone tools continues during this period, their use does

decrease. Settlements are believed to have been similar in type and location to those of

the Early Archaic period, with the addition of a systematic use of upland zones. A largescale, mid-Holocene, warming trend, characteristic of the western United States at this

time, may have spurred this shift in subsistence and settlement patterns (PG&E, 2009d;

Kowta, 1984 as cited by PG&E, 2009d).

During the Transitional Period (500 BC-AD500), considerable changes occurred

in assemblage structure, subsistence, and settlement patterns. A multitude of corner

notched projectile points, as well as the appearance of mortars and pestles, typify

assemblages of the period. The addition of acorns as a dietary staple during this period is

assumed due to the appearance of the mortar and pestle, and may signal a shift from a

more mobile society to a diversified subsistence economy. The labor-intensive process

required for the consumption of acorns and the eventual development of an acorn-based

economy may have prompted the creation of a sociopolitical ranking system (PG&E,

2009d; Basgall, 1987 as cited by PG&E, 2009d).

The Shasta Complex (AD 500-AD 1850) represents the final phase of Clewett and

Sundahl’s chronology. The introduction of the bow and arrow along with various small,

Gunther Barbed, Desert Side-notched, and Cottonwood Triangular projectile point types

characterized the assemblage of this phase. Settlements remained near streams and rivers

and included semi-subterranean dwellings. Subsistence activities concentrated on acorn

gathering, hunting, and fishing.

Sundahl subdivided the Shasta Complex into three temporal phases using

variations in artifact attributes (PG&E, 2009d; Sundahl, 1982 as cited by PG&E, 2009d).

All three phases, 1250-750 BP, 750-350 BP, and 450-100 BP, are characterized by

Gunther Barbed projectile points, winged drills, bi-pointed fish gorges, bone gaming

pieces, incised bone pendants, and spire-looped Olivella and glycymeris beads. The
294

assemblage of the second phase, 750-350 BP, lacks winged drills, but includes a

contracting-stem variant of the Gunther Barbed projectile point, the Desert Side-notched

projectile point, large drills manufactured of basalt or chert, sandstone arrowshaft

polishers, and Haliotis pendants. The third phase, 450-100 BP, includes Desert Sidenotched points, hafted drills, incised pebbles, biconically-drilled pebble pendants, incised

charmstones, and clam shell disc beads (PG&E, 2009d; Clewet and Sundahl, 1982 as

cited by PG&E, 2009d; Moratto, 1984 as cited by PG&E, 2009d; Sundahl, 1982 as cited

by PG&E, 2009d). Some scholars have identified the appearance of Shasta Complex

artifacts and sites as representative of a new group of peoples into the region (PG&E,

2009d; Sundahl, 1982 as cited by PG&E, 2009d). Two of the most representative sites in

Shasta County from this period are located north of Redding along the Sacramento River

(PG&E, 2009d; Moratto, 1984 as cited by PG&E, 2009d; Treganza and Heicksen, 1960,

as cited by PG&E 2009a).

At the time of European-American contact in the region, the Pit River and the

Wintu Native American groups were living in the area that is now Shasta, Siskiyou, and

adjacent counties. Along with the Shasta and Yana groups, these were the descendants of

Native American peoples who had settled in the region earlier. The Pit River group

inhabited an area south from Goose Lake along the western side of the Warner

Mountains, to just south of Eagle Lake; to the west, the Pit River territory included land

north of Mount Lassen, and north to the eastern side of Mount Shasta. Many of the main

Pit River villages were located along both the northern and southern banks of the Pit

River, as well as along Pit River tributaries. West of the Pit River territory was Wintu

territory, encompassing parts of what is now Trinity, Shasta, Siskiyou, and Tehama

Counties. Wintu territory was crossed by various waterways, including the Sacramento,

Trinity, and McCloud Rivers, as well as Cottonwood, Hayfork, and Stillwater Creeks.

Both the Pit River and the Wintu groups were hunter-gathers, relying on acorn and pine

nuts (buckeyes were also important to the Wintu), deer, waterfowl, and numerous species

of fish. Salmon were a particularly important resource, for which the Wintu constructed

salmon houses across the river from which they could spear the fish (PG&E, 2009d).

The Pit River and Wintu were both comprised of several smaller groups. The Pit

River people were also called the Achumawi, spoke a Hokan-derived language, and

included the Hewisedawi, Kosalektwi, Astariwawi, Hammawi, Atwamsini, Aporige,

Atuge, Ajumawi, Ilmawi, Itsatawi, and Madesiwi. The Wintu spoke a Penutian language

related to the Nomlaki language, included the Nomtipom, Winnemem, Dawpom, ʔelpom,

λ'abalpom, Nomsuus, Dawnom, Norelmaq, and Waymaq. Family was the dominant

social unit in Shasta, Pit River, Wintu, and Yana societies. The family was largely selfsufficient, fulfilling economic process through a gender-based division of labor, with

women gathering plant foods and men hunting, fishing, and making tools. Social

organization was based on tribelets, consisting of “one or more household groups that

included immediate family members... and any associated relatives... living together in a

village or community” (PG&E, 2009d; Krober, 1925 as cited by PG&E, 2009d).
295

The first recorded expeditions by Euro-Americans into the area are credited to

traders with the Hudson Bay Company between 1826 and 1833. At this time the Native

American population in the area was large and culturally varied. Diseases introduced by

these first explorers, however, decimated the Native populations. Nearly 40 percent of

the Pit River Tribe and almost 75 percent of the Wintu people had fallen to epidemic by

1833 (PG&E, 2009d; Loofbourow, 2009 as cited by PG&E, 2009d). The Native

American population suffered more losses during the 1840s and 1850s, with the massacre

of Wuntus and Yanas by American military under the leadership of John C. Fremont, and

the “friendship feast,” in which white settlers served Wintu guests poisoned food (PG&E,

2009d).

The discovery of gold at Sutter’s mill in 1848 brought a rush of miners and settlers

into California. Gradually, Native American lands were lost to white claims. Shasta

County, established in 1850, became the “Gateway to the Northern Gold Rush” (PG&E,

2009d; Smith, 1996 as cited by PG&E, 2009d). Star City Creek, located along the

northern banks of Grizzly Peak and flowing into McCloud reservoir, was especially

productive. As Shasta County drew more and more prospectors, streams and creeks

relied upon by Native American groups became increasingly polluted from mining

operations, causing numerous violent incidents between the miners and Native groups. In

response, the American military established Fort Cook near the Fall River in 1857

(PG&E, 2009d; Shasta Historical Society, 2003 as cited by PG&E, 2009d).

As gold mining diminished, many prospectors turned their hand to small-scale

ranching and timber operations. Nineteenth century land grants drew more settlers to the

area. Between 1899 and 1920, several families and individuals homesteaded the area that

later became the Iron Canyon reservoir. Fenders Ferry, another early American

settlement in the vicinity of the Pit 7 dam, is thought to have acquired its name from the

Fender brothers, who established a ferry near Potem Creek in 1860 (PG&E, 2009d;

Durham, 1998 as cited by PG&E, 2009d). Many settlers allowed their livestock to graze

on plants vital to the Native American diet, further fueling tension and violence between

the two groups. Despite resistance, most Native Americans in the area had been

relocated to various reservations by the late nineteenth century. Many of the Pit River

people were moved to the Round Valley Reservation east of Redding and the Nome

Lackee Reservation in Tehama County. The Wintu were taken to reservations on the

Mendocino coast. Eventually, Pit River and McCloud River Natives did return to their

traditional lands (PG&E, 2009d).

By the late 1870s, logging had become a major industry in the region. McCloud

Flats, east of the town of McCloud, was a particularly valuable timber area (PG&E,

2009d; Zanger, 1992 as cited by PG&E, 2009d). By the 1890s, copper mining had

replaced gold mining, especially along the copper-zinc belt in the west-central portion of

Shasta County. Smelting facilities were constructed in the area around Iron Mountain,

the first being at Keswick. Copper production in the area was effectively ended by a

court order in 1919 mandating the closure of smelting plants, which were producing toxic
296

fume detrimental to livestock and crops (PG&E, 2009d; Smith, 1996 as cited by PG&E,

2009d).

The McCloud River had developed a reputation for exceptional fishing as early as

the 1870s. The McCloud River Association was formed in 1900, organizing recreation

fishing on the river (PG&E, 2009d; Guilford-Kardell, 1994 as cited by PG&E, 2009d).

The association originally had 20 members, each of whom paid an annual fee of

$1,000.00 for fishing privileges. The association officially became the McCloud River

Club in 1902 or 1903 (PG&E, 2009d; Cranfield, 1984 as cited by PG&E, 2009d).

Phoebe Appleton Hearst, mother of William Randolph Hearst, began development at the

Wyntoon Castle estate in the first decade of the 1900s. The “wyntoon” name was a

derivation of the word “wintu” associated with the Winnemem Wintu. In 1929, the

Wynoon Castle was built (which later burned down). William Randolph Hearst used the

estate as a hideaway from his more well-known San Simeon estate on the coast. Today

the Hearst private estate consists of 67,000 acres containing a number of built structures

(including a village) which surrounds the McCloud reservoir and is adjacent and includes

some project lands. Presently, the Wyntoon Castle estate is managed by The Hearst

Corporation.

The topography of the area lent itself to the development of hydroelectric power

facilities beginning in the last decade of the nineteenth century. The first recorded use of

hydroelectric power in Shasta County occurred at Gladstone Mine in 1894. The Northern

California Power Company, which had originally been established as the Keswick

Electric Company to supply power to the Keswick Smelter, took over electrical

operations of the Gladstone Mine sometime around 1900 (PG&E, 2009d; Smith, 1996 as

cited by PG&E, 2009d). PG&E purchased the water rights of the Mount Shasta Power

Company in 1917, and in 1919 purchased the Northern California Power Company. The

construction of the Pit River facility spanned from 1921 to 1966, and was the single

largest construction project in PG&E’s history (PG&E, 2009d).

Previous Cultural Resource Investigations

In preparation for the pre-application document, PG&E conducted an archival

record search between June 23 and 27, 2005 at the California State University (CSU),

Chico, Northeast Information Center to identify previous investigations in the vicinity of

the project APE, as well as previously recorded cultural resources in the area. The

Northeast Information Center houses all cultural resources data for Shasta and Siskiyou

Counties. Data reviewed includes site records, base maps containing site and survey

locations, letter reports, survey reports, site testing and evaluation reports, National

Register listings, California Register listings, California Historical Landmark listings, and

California Points of Historic Interest. Additional sources of information consulted

include the Shasta-Trinity National Forest, the Shasta County Historical society in

Redding, the Shasta County Public Library in Redding, and the special collections of the

Meriam Library, CSU, Chico (PG&E, 2006).
297

In addition, PG&E consulted the California Native American Heritage

Commission concerning documented areas of tribal significance in the project APE.

Tribal groups with ties to or interest in the project area were also contacted concerning

sensitive cultural resources within the project APE. Subsequent meetings were held with

the Tribes (PG&E, 2006).

There have been 49 previous investigations conducted in and around the project

APE, ranging in date from the early 1960s to 2004. These studies were conducted to

identify cultural resources prior to the sale or transfer of timber or land, timber harvests,

or project-specific ground-disturbing activities. About 40 percent of the total APE for the

project had been investigated previously; however, many of the existing site records and

survey efforts are more than 10 years in age and are not considered to be in adherence

with current professional standards (PG&E, 2006).

Albion Environmental, Inc, was contracted to conduct archaeological fieldwork as

outlined in Study Description CR-S1. Archaeological surveys were conducted during

September, October, and November 2007, and during January, April, May, and July

2008. The surveys were designed to examine locations that had not been recently

examined, that had been surveyed but with an unknown survey strategy, or that had been

surveyed with a survey strategy that was not undertaken according to current professional

standards. In addition to the archaeological survey crew, representatives of the Pit River

Tribe and of the Winnemem Wintu Tribe were invited to participate in the field work as

official Native American monitors and observers. Only the Pit River Tribe provided

monitors (PG&E, 2009d).

In areas where it was safe to survey, crew members traversed parallel transects

spaced 15 to 20 meters apart. In areas where 75 percent or more of the ground cover was

obscured by vegetation, or the terrain exhibited a slope greater than 49 percent, transects

were expanded to 20 to 40 meters apart. Areas of the project APE that were inaccessible

because of steep terrain, extremely dense foliage, or unsafe conditions were bypassed

(PG&E, 2009d).

Surveys of both McCloud and Iron Canyon reservoirs were undertaken when the

reservoirs were at low levels so that potentially submerged resources could be identified;

however, neither reservoir was at the lowest historic levels during the 2007 field season.

Restricted access to privately owned land along the McCloud reservoir necessitated

initial survey of the reservoir by helicopter, during which potentially sensitive areas

within the project APE were identified on a topographic map. These areas were then

accessed by boat and surveyed using the methods described above. Pit 6 and Pit 7 were

also accessed by boat (PG&E, 2009d).

A preliminary inspection of the McCloud transmission line route was undertaken

on July 21, 2008. This inspection did not constitute a formal archaeological survey,

which will be undertaken after the final transmission line route and type have been

determined. An additional survey of NFS lands was undertaken on April 30, 2009. At

the request of the Pit River Tribe, a two-day field visit was hosted by PG&E to identify
298

areas of tribal concern located at the Pit 6 and Pit 7 reservoirs. Access to McCloud River

Club lands was denied, and consequently were not field surveyed (PG&E, 2009d).

Identified Resources

Archaeological and Historic Era Resources

A total of 87 archaeological and historic-era resources were identified within the

APE for the proposed project. Of these total 87 sites, 11 were identified on lands that

were inaccessible during field survey (table 3-37) and 18 were not relocated during

archaeological field survey (table 3-38). The remaining 55 resources, which include 30

archaeological sites, 22 isolated finds (artifacts unassociated with an archaeological site),

and three historic structures, were physically located during archaeological field survey

(table 3-39).

Comprising these 55 resources are 33 sites (nine newly identified, 24 previously

recorded) and 22 isolated finds. The nine newly identified sites consist of eight

prehistoric archaeological sites and one historic-era site. The 24 previously recorded

sites consist of 21 prehistoric archaeological sites and three sites containing both

prehistoric and historic components. Isolated finds include three historic structural

features and 19 prehistoric resources (PG&E, 2009d).

None of the 22 isolated finds (defined as less than five artifacts per square meter)

are considered eligible for listing on the National Register. Of the 33 archaeological and

historic-era resources, three are eligible for listing and six have been recommended

potentially eligible. The eligibility of the remaining 24 archaeological and historic-era

resources is unknown; therefore, these resources would be treated as eligible for listing

on the National Register until such time that any previous evaluation of these resources is

identified, or until these resources are formally evaluated eligible (PG&E, 2009d). The

33 archaeological and historic-era resources, along with National Register eligibility, are

identified in table 3-39.

A preliminary inspection of the proposed McCloud transmission line corridor, as

described in the supplement submitted by PG&E on October 17, 2007, was conducted as

part of archaeological field survey. The inspection consisted of viewing the proposed

route of the transmission line by vehicle from FR 11, and noting areas that may

potentially be archaeologically sensitive. Formal archaeological survey will be

conducted upon final determination of the final corridor route (PG&E, 2009d).
299

Table 3-37. Archaeological and historic-era resources located on McCloud River Club lands within the McCloud River

Expanded APE. (Source: PG&E, 2009d; Berryman, 1999)

Resource

Number Description a

National

Register

Eligibility

National

Register

Integrity

P-45-003188 Lithic scatter, fire-cracked rock, house pits, projectile

points, and historic components

Unknown Unknown

P-45-003189 Footbridge Unknown Unknown

CA-SHA3190Lithic scatter, midden deposit, fire-cracked rock, house

pits, projectile points, manos

Unknown Unknown

P-45-003191 Lithic scatter, midden deposit, house pits Unknown Unknown

P-45-003192 Lithic scatter, house pits Unknown Unknown

P-45-003193 Lithic scatter, projectile points, and historic components Unknown Unknown

P-45-003194

b

Lithic scatter, midden deposit, fire-cracked rock, and

historic components (village: “Haupom”)

Unknown Unknown

P-45-003195 Lithic scatter, midden deposit, house pits Unknown Unknown

P-45-003196 Pasture, fence, and prehistoric components Unknown Unknown

P-45-003197 Footbridge Unknown Unknown

P-45-003198 Lithic scatter, midden deposit, and historic components Unknown Unknown

P-45-003199 McCloud River Club Resort Unknown Unknown

P-45-003202 Lithic scatter, midden deposit, fire-cracked rock, house

pits (village “Sulanharas”)

Unknown Unknown

P-45-003205 Lithic scatter, midden deposit, projectile point Unknown Unknown

a Resource descriptions are taken from Berryman, 1999.

b

Partially located on Shasta-Trinity National Forest lands; Shasta-Trinity National Forest portion identified as ALB12/FS 05-04-61-601.
300

Table 3-38. Previously recorded archaeological and historic-era resources that were not relocated during Archaeological

field survey. (Source: PG&E, 2009d)

Project Location Resource

Number Description

National

Register

Status

National

Register

Integrity

Pit 7 Reservoir CA-SHA-143 e House pit, obsidian points Unknown Unknown

Pit 7 Reservoir CA-SHA-144 a House pits Unknown Unknown

Pit 7 Reservoir CA-SHA-145 dProjectile points, mano Unknown Unknown

Pit 7 Reservoir CA-SHA-147 a House pits, midden, shell Unknown Unknown

Pit 6 Reservoir CA-SHA147/247 eMidden, shell Unknown Unknown

Fenders Flat CA-SHA-150 a Obsidian flakes, shell, small

stemmed point

Unknown Unknown

Fenders Flat CA-SHA-151 a Obsidian, shell Unknown Unknown

Pit 7 Reservoir CA-SHA-152 b House pits, midden, shell Unknown Unknown

Pit 7 Reservoir CA-SHA-153 b Obsidian flakes, shell Unknown Unknown

Pit 6 Reservoir CA-SHA-248 e Obsidian flakes, shell Unknown Unknown

McCloud River CA-SHA-969 f Depressions, obsidian flakes,

scrapers, cores, projectile points,

bowl mortar, midden

Unknown Unknown

McCloud Reservoir ICI320-1

c

Percussion flake, possible house pit Unknown Unknown

McCloud Reservoir ICI320-2

c

Percussion flakes, projectile points,

midden

Unknown Unknown

McCloud Reservoir ICI230-3

c

Percussion flakes, projectile points Unknown Unknown
301

Project Location Resource

Number Description

National

Register

Status

National

Register

Integrity

McCloud Reservoir ICI230-4

c

Percussion flakes Unknown Unknown

McCloud Reservoir ICI230-5

c

Percussion flakes Unknown Unknown

McCloud Reservoir ICI230-6

c

Percussion flakes, superficial

midden

Unknown Unknown

McCloud Reservoir ICI230-7

c

Percussion flakes Unknown Unknown

a Recorded by Baumhoff et al. (1955)

b Recorded by Baumhoff and Bennyhoff (1955)

c Recorded by Clemmer (1963)

d Recorded by Flint et al. (1955)

e Recorded by Heicksen (1962)

f Recorded by Henn (1977)
302

Table 3-39. Documented archaeological and historic-era resources located within the APE. (Source: PG&E, 2009d)

Project

Location Resource Number Type a Description

National

Register

Status

National

Register

Integrity

b

Iron Canyon

Reservoir c

ALB-3

(FS-05-14-58-424)

P Native American site; lithic

scatter

Unknown Low

Iron Canyon

Reservoir c

ALB-4

(FS 05-14-58-425)

P Native American site; lithic

scatter

Unknown Moderate

McCloud

Reservoir d

ALB-5 P Native American site; lithic

scatter

Unknown Low

Pit 6

Transmission

Line c

ALB-6H H Historic trash scatter with

associated pit and milled

board feature

Unknown Low

Pit 7

Transmission

Line c

ALB-7 P Native American site; lithic

scatter

Unknown Low

McCloud

River d

ALB-8

(FS 05-14-61-598

P Native American site; lithic

scatter

Unknown High

McCloud

River d

ALB-9

(FS 05-14-61-599)

P Native American site; lithic

scatter

Unknown High

McCloud

River d

ALB-10 P Native American site;

obsidian flakes and Gunther

projectile point

Unknown High
303

Project

Location Resource Number Type a Description

National

Register

Status

National

Register

Integrity

b

McCloud

River d

ALB-11

(FS 05-14-61-597)

P Native American site; lithic

scatter

Unknown Low

McCloud

River d

ALB-12*

(FS 05-14-61-601;

P-45-003194)

P/H Prehistoric site with historic

component; lithic scatter,

ground stone fragment,

midden

Unknown Moderate

McCloud

River d

ALB-13*

(FS 05-14-61-600)

P Prehistoric site with historic

component; lithic scatter,

ground stone fragment,

midden

Unknown Moderate

Pit River c

(Pit 7

Reservoir)

CH-SHA-243 P Native American site; lithic

scatter

Unknown High

Pit River c

(Pit 7

Reservoir)

CH-SHA-244 P Native American site; lithic

scatter

Unknown High

Pit River c CA-SHA-246 P Native American site; lithic

scatter

RecommendedModerate

Pit River c

(Pit 6

Reservoir)

CA-SHA-249 P Native American site;

possible pit house features,

obsidian flakes, basalt ground

stone fragment

RecommendedModerate
304

Project

Location Resource Number Type a Description

National

Register

Status

National

Register

Integrity

b

Pit River c CA-SHA-252 P Native American site;

possible pit house features,

ground stone artifacts;

previously excavated by

M.H. Heicksen (1962)

Eligible High

Iron Canyon

Reservoir c

CA-SHA-498

(FS 05-14-58-42)

P Native American site Unknown Low

McCloud

River d

CA-SHA-622

(FS 05-14-61-185)

P Native American site; lithic

scatter, midden

Unknown High

McCloud

River d

CH-SHA-623

(FS 05-14-61-168)

P Native American site; lithic

scatter, possible pit house

features

RecommendedLow

McCloud

River d

CA-SHA-624

(FS 05-14-61-187)

P Native American site; lithic

scatter, possible pit house

features

RecommendedHigh

Iron Canyon

Reservoir c

CA-SHA-664

(FS 05-14-58-53)

P Native American site; lithic

scatter, modern fire ring

Unknown Low

Iron Canyon

Reservoir c

CA-SHA-665

(FS 05-14-58-54)

P Native American site; lithic

scatter, possible modern rock

circle feature

Unknown Moderate

Iron Canyon

Reservoir c

CA-SHA-666

(FS 05-14-58-55)

P Native American site; lithic

scatter

Unknown Low
305

Project

Location Resource Number Type a Description

National

Register

Status

National

Register

Integrity

b

Iron Canyon

Reservoir c

CA-SHA-667/H

(FS 05-14-58-56;

ALB-1)

P/H Native American site

(archaeological and historic);

obsidian scatter mixed with

historic ceramic, bottle

fragments, and metal piping;

apple tree and walnut tree

present on site

Unknown Low

Iron Canyon

Reservoir c

CA-SHA-668

(FS 05-14-58-57;

ALB-2)

P Native American site; lithic

scatter

Unknown Low

McCloud

River d

CA-SHA-686/H

(FS 05-14-61-08)

P Large Native American site;

extensive lithic scatter,

midden

Eligible Low -

Moderate

McCloud

River d

CA-SHA-687

(FS 05-14-61-32)

P Large Native American site;

lithic scatter, midden

Eligible Low

McCloud

River d

CA-SHA-688

(FS 05-14-61-33)

P Native American site; rock

shelter, obsidian lithic

debitage

RecommendedHigh

Iron Canyon

Reservoir c

CA-SHA-1623

(FS 05-14-58-228)

P Native American site; lithic

scatter

Unknown High

McCloud

River d

CA-SHA-1657

(FS 05-14-61-301)

P Native American site; lithic

scatter, basalt chopper,

midden

Unknown Moderate
306

Project

Location Resource Number Type a Description

National

Register

Status

National

Register

Integrity

b

McCloud

River d

CA-SHA-1658

(FS 05-14-61-302)

P Native American site;

possible house pit features,

obsidian lithic debitage

RecommendedHigh

McCloud

River d

CA-SHA-1659

(FS 05-14-61-303)

P Native American site; lithic

scatter

Unknown Low

Iron Canyon

Reservoir c

CA-SHA-2109

(FS 05-14-58-365)

P Native American site; lithic

scatter, ground stone

fragment

Unknown Low

* Previously recorded but no State Trinomial Number assigned

a

P = prehistoric, H = historic

b

Low = extensive impacts to resource, Moderate = limited impacts to resource, High = almost no impacts to resource

c Within FERC project boundary

d Outside of FERC project boundary, in McCloud River Expanded APE
307

Historic Buildings and Structures

Only three historic structures were identified within the APE, all three of which

are located in the McCloud River expanded APE on McCloud River Club lands (table 3-

37). These resources include two footbridges (P-45-003189, P-45-003197) and the

McCloud River Club Resort (P-45-003199). Survey access to lands owned by the

McCloud River Club located within the APE was not granted, nor is National Registereligibility for these resources known; therefore, PG&E proposes to treat these resources

as eligible until such time that any previous evaluation of these resources is identified, or

until these resources are evaluated for listing on the National Register.

Traditional Cultural and Religious Sites Inventory and Impact Study

Two Native American communities, the Pit River Tribe and the Winnemem Wintu

Tribe, have formally requested to participate in the relicensing project. The Pit River

Tribe is a federally recognized tribe. The Winnemem Wintu Tribe has petitioned for

federal recognition. Other Native American communities in the vicinity either have not

requested to participate in the project, or have only asked to be kept apprised of project

progress. The Pit River Tribe expressed interest in the Iron Canyon and Pit River areas

of the APE. The Winnemem Wintu Tribe expressed interest in the McCloud reservoir

and McCloud River areas of the APE.

The Pit River and Winnemem Wintu tribes have requested separate TCP

investigations, as is outlined in Study Description CR-S2, Traditional Cultural

Properties, (PG&E, 2009e), from which two separate reports addressing the study results

for each tribe will be produced. In addition, both tribes requested formal agreements

outlining the conduct of the TCP studies. PG&E entered into an MOU with each tribe,

recognizing the sensitivity of the resources under study, and the historical and cultural

events that have affected the tribes. The MOUs also recognize the importance of

identifying TCPs within the APE and incorporating the management of these resources

into the overall management plan for the proposed project. Full details of Study

Description CR-S2 and the MOUs for each tribe are available in the HPMP (PG&E,

2009e). So far only the Pit River Tribe TCP study has been completed (PG&E 2009f).

At this time, there continues to be an impasse between PG&E and the Winnemem Wintu

on completion of the draft TCP report due to what particular contractors have access to

review and comment on the draft TCP report.26

The Pit River TCP study resulted in the identification of a total of 158 resources,

of which 22 were considered sacred sites, 16 resource procurement locations, 14

26

See letter from Mark Franco, Winnemem Wintu Tribe, dated July 5, 2009;

letter from Steve Nevares, PG&E, dated July 30, 2009; letter from Steve Nevares, PG&E,

dated April 23, 2010, and letter from Stephen Volker, Attorney for Winnemem Wintu

Tribe, dated May 25, 2010.
308

habitation sites, two battle sites, 11 multiple use locations, and 78 place names (PG&E

2009f). Of these 158 resource sites, 31 are located within the project’s APE, consisting

of 15 place names, 4 habitation sites, 7 resource procurement locations, 2 trails, and 3

sacred sites. Of these 31 resources, four are considered as eligible for listing in the

National Register as TCPs, while 9 are considered as potentially eligible TCPs (currently

undetermined), while the remaining 18 are considered ineligible for listing in the

National Register as TCPs.

3.3.6.2 Environmental Effects

Project-Related Effects on Cultural Resources

Project-related effects to cultural resources within the project’s APE are likely to

occur from project O&M, use and maintenance of project roads (including associated

drainage ditches), recreation, vandalism, and modifications or repairs to project facilities.

Project-related adverse effects to cultural resources considered eligible for the National

Register (i.e. historic properties) would require PG&E to resolve such effects, in

consultation with the California SHPO, and with other parties depending on the nature

and location of the affected historic property.

Project Operations

The project operates both as a peaking system and a load-following system, using

the available water supply after satisfying minimum instream flow requirements that

results in regular fluctuation in reservoir levels. Regular fluctuation in reservoir levels

created by project operations can result in the erosion of archaeological sites by either

deflating or washing away cultural deposits. Thus, project-related erosion along the

shorelines of the McCloud, Iron Canyon, Pit 6, and Pit 7 reservoirs may affect

archaeological sites situated on the shoreline or presently inundated by the reservoirs.

Archaeological sites situated along the shoreline in the reaches below the reservoirs can

also be affected by erosion in a similar manner.

Road Maintenance and Use

The maintenance of project roads may affect archaeological sites located adjacent

to them or buried beneath them. Ditches excavated for roadway drainage may also affect

archaeological sites. Depending on the condition of native soil roads, season, and vehicle

type, vehicular traffic may damage archaeological sites, as well. Increased public

accessibility to archaeological sites by roads may also increase the vulnerability of those

resources.

Recreation

The project vicinity is a popular area for recreational activities including hiking,

fishing, camping, picnicking, swimming, boating, hunting, and OHV use. There are four

developed recreational areas within the project APE, the use of which has the potential to

affect archaeological sites. These recreational areas include the following:
309

 McCloud reservoir boat ramp, also called the Tarantula Gulch boat launch, at

McCloud reservoir;

 Deadlun campground;

 Hawkins Landing campground and Boat ramp at Iron Canyon reservoir; and

 Fenders Flat unimproved boat ramp at Pit 7 afterbay dam.

The Ash Camp campground and the Ah-Di-Na campground are located outside of

the project boundary, but are partially located within the McCloud River expanded APE.

Both campgrounds are Forest Service recreation developments that predate the project,

and are connected by the Pacific Crest National Scenic Trial as it parallels the McCloud

River. Dispersed recreational use also occurs in this area. Other areas where dispersed

recreational use occurs are located within the project’s APE. User-created roads leading

from improved roads to the shoreline can be found in many areas.

Vandalism

Collection of artifacts or the intentional disturbance of cultural materials by

unauthorized persons (from people accessing roads and recreational sites within the

FERC project boundary) can adversely archaeological sites and associated TCPs.

Archaeological sites that contain human remains and burials are particularly susceptible

to vandalism and looting.

Vegetation Management

Project-related vegetation management around project-related hydroelectric

features may include spraying, burning, and mechanical removal. All of these activities

have the potential to adversely affect or destroy areas currently utilized by the Pit River

Tribe and Winnemem Wintu Tribe to gather culturally significant plant spices.

Proposed Project

PG&E proposes to construct a new powerhouse at the base of McCloud dam and a

powerhouse at Pit 7 afterbay dam, along with associated transmission facilities. In

addition, PG&E proposes the creation of new recreational facilities at McCloud dam,

Battle Creek, East and West McCloud dams, Red Banks, Star City, Tarantula Gulch, at

the intersection of Tarantula Gulch access road and FR 11, a floating dock on McCloud

reservoir with an associated trail, Iron Canyon, Deadlun, Campground, Hawkins Landing

Campground, three areas along FR 37N38, Iron Canyon dam, Montgomery Creek, the

upper end of Pit & reservoir, Fenders Flat, and Pit 7 powerhouse.

Future project-related effects to cultural resources within the project’s APE that

are likely to occur under these proposed project facilities would be nearly identical to

those generated under the existing project in regard to project O&M, use and

maintenance of project roads (including associated drainage ditches), recreation,

vandalism, and repairs to project facilities. The addition of new recreational facilities

would increase and exacerbate potential effects related to inadvertent destruction of
310

archaeological sites, unauthorized collection of artifacts, and vandalism. Finally, grounddisturbing activities involving the construction phases associated with the new proposed

facilities would have the potential to directly or indirectly affect archaeological sites and

TCPs.

Archaeological Resources

PG&E identified project-related effects for 14 out of the 55 archaeological sites

located and evaluated during field survey. During archival research, 14 additional

resources were identified on McCloud River Club lands; however, these sites were not

relocated during field survey due to lack of access, and were consequently not evaluated

for project-related effects. Project effects for these resources are unknown, and therefore

PG&E has not proposed management for these resources.

Site-specific project-related effects for the identified 14 archaeological sites are

listed in table 3-40. Eight of these sites are being affected by a combination of erosion,

dispersed recreational use, and vandalism; and a ninth site is being affected by these three

effects in addition to road maintenance use. Another site is being affected by erosion

alone. Another site is being affected by dispersed recreational use and vandalism. The

three remaining sites could potentially be affected by vegetation management or new

construction activities.

PG&E-proposed management for archaeological sites that may be affected by

erosion, road maintenance and use, dispersed recreational use, or vandalism includes

blocking vehicular access to these sites, posting restrictive signage, closing of usercreated roads, and conducting annual monitoring of erosion. In addition, PG&E proposes

notifying transmission managers and educating employees about sites that may be

affected by vegetation management or new transmission line construction. PG&E

currently implements an employee environmental and sensitivity training program and

proposes to continue this program. PG&E also proposes public education of the cultural

significance of the area, as well as use restriction for the protection of resources, through

interpretive signage, brochures, or other similarly appropriate media. Appropriate

representatives from the Pit River Tribe, the Winnemem Wintu Tribe, and the Forest

Service will be asked to participate in the creation of interpretive materials.

Historic Buildings and Structures

PG&E has identified only three historic structures within the APE, all of which are

located on McCloud River Club lands. As access to these lands was not available for

field survey, National Register-eligibility, as well as project-related effects on these

resources, is unknown; therefore, no management procedures for these resources are

proposed by PG&E. The existing project facilities were constructed in 1965, and PG&E

has proposed that when the project facilities reach 50 years of age (in 2015) they will be

evaluated for National Register eligibility.
311

Traditional Cultural Properties

Upon completion of the Winnemem Wintu TCP report, and in combination with

existing the Pit River TCP report (completed in September 2009), PG&E proposes that it

would add an amendment to its HPMP that would address what management measures it

would incorporate to protect identified TCPs.

Populations of culturally significant plants were also identified in Study

Description BR-S2, Special-Status and Special-Interest Plant, Lichen, and Fungi Species

(PG&E, 2009d). The Pit River TCP report also contains names and location information

of significant plant types important to the Pit River Tribe. PG&E proposes to add an

amendment to the HPMP to manage and protect these ethnobotanical resources.

Our Analysis

Archaeological Resources and National Register-eligibility

Archaeological sites along the shorelines of the project reservoirs (as well those

presently inundated) are subject to project-related effects due to erosion from fluctuation

in the water level, as well as accidental disturbance from recreational use and vandalism.

Project-related road maintenance and use, vegetation management, and recreation all

have the potential to affect these sites through direct or indirect effects. Of the

archaeological sites identified by PG&E as being subject to project-related effects, one is

pending consultation concerning National Register-eligibility, while the eligibility of the

remaining 13 is listed as undetermined. In additional information requests, dated

May 26, 2009, and August 14, 2009, the Commission expressed the need for National

Register determinations to be presented in the HPMP. These National Register-eligibility

determinations remain outstanding, but are necessary for compliance with section 106.

Requiring PG&E to make these determinations for the 14 archaeological sites that are

being affected by the project, in consultation with the California SHPO, would ensure

that these 14 archaeological sites are protected.

Historic Buildings and Structures

No project facilities are over 50 years of age; therefore, PG&E did not evaluate

them for National Register-eligibility. Instead, PG&E proposes to evaluate the existing

project facilities when they reach 50 years of age. Waiting until existing project facilities

reach 50 years of age would allow for appropriate evaluation of the structures under the

NHPA and any project effects could them be determined based on the facilities eligibility

for the National Register.

Project-related effects on the historic structures located on McCloud River Club

lands cannot be determined until access is granted by the landowner. Until such a time,

nothing can be done to evaluate or protect these sites.

Traditional Cultural Properties

At this time, only the TCP report for the Pit River Tribe has been completed.

Upon review of the TCP report, we conclude that there is enough information to
312

determine that four resources (three sacred areas and one resource procurement gathering

site) within the project’s APE can be considered as National Register-eligible TCPs, and

that nine other resources (namely resource procurement gathering fishing sites and

several other habitation areas and a trail) are potentially eligible TCPs. Other important

gathering areas involving culturally important plants to the Native Americans have also

been identified by the Pit River Tribe and they should be recognized as significant

locations and protected by PG&E.27 PG&E proposes to include measures for the

protection of culturally-sensitive plants in the Vegetation Management Plan, which is

discussed in greater detail in section 3.3.3, Terrestrial Resources.

Providing an amendment to the HPMP, as proposed by PG&E, on the types of

management measures to incorporate for the protection of TCPs, both those important to

the Pit River Tribe and Winnemem Wintu Tribe, would allow any TCP sites to be

protected once they have been identified.

27 Although many significant plant collecting areas may not qualify as National

Register-eligible TCPs, they still need to be protected by other statutes such as NEPA and

several executive orders protecting sacred Native American areas. Along with

section 106, the Commission needs to insure that PG&E takes steps to protect such

resources under a new license.
313

Table 3-40. Site-specific potential effects for archaeological and historic-era resources. (Source: PG&E, 2010b)

Resource Number Location

Potential Effectsa

PG&E Proposed Management

1 2 3 4 5 6

ALB-5

CA-SHA-4548

McCloud Reservoir X X X

Site will be evaluated for National

Register eligibility within 1 year, and

treatment measures will be developed

and implemented within 2 years

ALB-3

(FS 05-14-58-424)

Iron Canyon

Reservoir X X X X

Site will be evaluated for National

Register eligibility within 1 year, and

treatment measures will be developed

and implemented within 2 years

ABL-4

CA-SHA-4547

(FS 05-14-58-425)

Iron Canyon

Reservoir X X X

Site will be evaluated for National

Register eligibility within 1 year, and

treatment measures will be developed

and implemented within 2 years

CA-SHA-498

(FS 05-14-58-42)

Iron Canyon

Reservoir X X X

Site will be evaluated for National

Register eligibility within 1 year, and

treatment measures will be developed

and implemented within 2 years

CA-SHA-664

(FS 05-14-58-53)

Iron Canyon

Reservoir X X X

Site will be evaluated for National

Register eligibility within 1 year, and

treatment measures will be developed

and implemented within 2 years

CA-SHA-665

(FS 05-14-58-54)

Iron Canyon

Reservoir X X

Block vehicular access (with ShastaTrinity National Forest approval);

post restrictive signage
314

Resource Number Location

Potential Effectsa

PG&E Proposed Management

1 2 3 4 5 6

CA-SHA-666

(FS 05-14-58-55)

Iron Canyon

Reservoir X X X

Site will be evaluated for National

Register eligibility within 1 year, and

treatment measures will be developed

and implemented within 2 years

CA-SHA-667/H

(ALB-1;

FS 05-14-58-56)

Iron Canyon

Reservoir X X X

Site will be evaluated for National

Register eligibility within 1 year, and

treatment measures will be developed

and implemented within 2 years

CA-SHA-668

(ALB-2;

FA 05-14-58-57)

Iron Canyon

Reservoir X X X

Site will be evaluated for National

Register eligibility within 1 year, and

treatment measures will be developed

and implemented within 2 years

CA-SHA-1623

(FS 05-14-58-228)

Iron Canyon

Reservoir X X

Post restrictive signage (with ShastaTrinity National Forest approval)

CA-SHA-2109

(FS 05-14-58-365)

Iron Canyon

Reservoir X X X

Site will be evaluated for National

Register eligibility within 1 year, and

treatment measures will be developed

and implemented within 2 years

CA-SHA-252 Pit River X

Site will be evaluated for National

Register eligibility within 1 year, and

treatment measures will be developed

and implemented within the same

period of time

ALB-6H

CA-SHA-2193H

Pit 6 Transmission

Line X X

Site will be evaluated for National

Register eligibility within 1 year, and

treatment measures will be developed

and implemented within 2 years
315

Resource Number Location

Potential Effectsa

PG&E Proposed Management

1 2 3 4 5 6

ALB-7

(CA-SHA-4549

Pit 7 Transmission

Line X X

Site will be evaluated for National

Register eligibility within 1 year, and

treatment measures will be developed

and implemented within 2 years

a. 1. Project Operations (Erosion) 4. Vandalism

2. Road Maintenance and Use 5. Vegetation Management

3. Dispersed Recreational Use 6. New Construction
316

Cultural Resource Management

PG&E prepared and filed a draft HPMP (dated July 2009) with its license

application. Preparation of the HPMP was undertaken by PG&E in anticipation of a PA

to be executed between the Commission and the California SHPO, and with other

concurring parties, for the management of historic properties that may be affected by a

new license for the project. The HPMP is designed to avoid, reduce, or mitigate (i.e.,

resolve) existing or potential project-related adverse effects to historic properties within

the project’s APE for the term of a new license.

Although the HPMP does not include site-specific measures for TCPs, some or all

of the following procedures for archaeological and historic era sites may also be

applicable to the management of TCPs. Currently included in the HPMP are procedures

for:

 Continued adherence to federal and state laws and regulations, as well regular

communication with other agencies, the Pit River Tribe, and the Winnemem

Wintu Tribe regarding the management of historic properties associated with

project APEs;

 General treatment measures for O&M (including road maintenance), and the

management of ethnobotanical resources;

 Avoidance, monitoring, stabilization, data recovery, curation, and other

treatment measures pertaining to historic properties as well as accidental

discovery of archaeological sites or human remains;

 The use of qualified Tribal Cultural Monitors during archaeological surveys,

site testing, and data recovery, non-emergency construction and maintenance

activities requiring ground disturbance that would create a reasonable effect to

historic properties, and during long-term historic properties monitoring;

 Site-specific treatment of known archaeological and historic-era properties;

 Signage, including interpretive and display signs, as well as regulatory and

warning signs;

 Closure of user-created roads to minimize or prevent artifact collection;

 Public interpretation and education of cultural resource values;

 Continuation of the cultural resource employee education program; and

 Implementation of cost-effective protection measures for historic properties in

consideration of project needs, public interests, and other resource areas.

 Other protocols and procedures are also provided in the HPMP involving

educating the public and PG&E staff on protecting cultural resources,

inadvertent discoveries, emergency situations, curation of recovered cultural

materials, activities that do not require California SHPO involvement, future
317

project studies, and project patrolling, monitoring of cultural resources, and

general consultation.

In its original condition 34, the Forest Service specified that within 1 year of

license issuance, PG&E file with the Commission an HPMP that is approved by the

Forest Service. According to the Forest Service’s original condition 34, the HPMP

should include:

Complete integration of CR-S1 and CR-S2 study results (including the currently

incomplete CR-S2 TCP study for the Winnemem Wintu Tribe), detailed site

monitoring and schedule, National Register determinations of eligibility for sites

periodically inundated by reservoir fluctuations in Iron Canyon reservoir, expected

and potential effects of current or proposed project operation effects on historic

properties including specific detailed mitigation for those effects, and a

study/evaluation of whether there is compelling evidence for a historic

archaeological and ethnographic district on the Lower McCloud River within the

project’s expanded APE.

In response to Forest Service condition 34, PG&E alternative condition 34

proposed that PG&E would file a final HPMP within 1 year of license issuance and that

the HPMP would include (italics represent PG&E’s added modifications to the Forest

Service’s original condition 34):

Complete integration of the CR-S1 and CR-S2 study results (if the CR-S2 TCP

study is not complete when the HPMP is finalized, the HPMP will be revised or

amended if necessary to reflect the results of the CR-S2 when it is completed) and

detailed site monitoring and schedule. The HPMP shall call for National Register

determinations of eligibility for sites periodically inundated by reservoir

fluctuations in Iron Canyon reservoir where erosion and/or siltation have been

found to potentially affect sites, and where consultation with the Commission,

California SHPO, Forest Service, and tribes have determined that evaluation

(which may include test excavations) is appropriate. The HPMP shall also

contain a discussion of the expected and potential effects of current or proposed

project operations on historic properties, including specific detailed mitigation

measures for effects that have been determined by the California SHPO to be

adverse. If adverse effects to sites will not be known until after the HPMP has

been approved by the Commission, the HPMP shall instead contain a process for

determining appropriate mitigation in the future in consultation with the SHPO,

Commission, Forest Service, and Tribes. Additionally the final HPMP shall

discuss whether there is compelling evidence for a historic archaeological and

ethnographic district on the Lower McCloud River within the project expanded

APE.

The Forest Service’s original condition 34 and PG&E alternative condition 34 are

very similar in regards to actions to be taken to protect cultural resources in the event of

ground-disturbing activities, or prior to such activities, or as a result of project operations:
318

Upon discovery of cultural resources on Forest Service lands that PG&E shall

immediately cease work in the affected area and shall then notify the Forest

Service and shall not resume work on ground disturbing activities unit it receives

written approval from the Forest Service. If deemed necessary the Forest Service

may require PG&E to perform recovery excavations and preservation of the

discovered cultural resource—if it is an archaeological site--and associated

artifacts at PG&E’s expense through provisions of an Archaeological Resources

Protection Act permit issued by the Forest Service. PG&E shall implement the

Plan upon approval by the Commission.

The one distinction between the Forest Service’s and PG&E’s discovery clause is

that the Forest Service specified that PG&E account for any paleontological resources

that may be discovered on Forest Service lands. PG&E alternative condition 34 disputed

this by proposing that paleontological resources are not cultural and are not subject to

section 106 compliance and, as a result, should not be addressed in the HPMP.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 34.28 The provisions specified in Forest Service modified condition 34 are

similar to those specified in the Forest Service’s original condition 34, except that the

Forest Service requests further revision of the HPMP. In its November 24, 2010, filing,

PG&E accepts Forest Service modified condition 34 and withdraws its alternative

condition 34.

Our Analysis

The Commission directed PG&E to revise and finalize its HPMP, which PG&E

filed on October 26, 2010. Overall, the final HPMP filed by PG&E contains a number of

measures to manage and protect historic properties in a timely manner. The avoidance

strategies, public and employee training proposals, signage plans, transportation plans,

monitoring, and consultation proposals are all measures that would ensure cultural

resources and historic properties within the project’s APE are protected and maintained

throughout the term of any license issued for the project.

Under our direction, PG&E’s final HPMP proposes to complete National

Register eligibility determinations on cultural resources that are determined to be

adversely affected by the project within 1 year of license issuance, and to develop and

implement treatment measures for National Register-eligible cultural resources being

adversely affected by the project within 2 years of license issuance. PG&E’s final HPMP

also provides measures for handing newly discovered paleontological resources on Forest

28 On January 28, 2011, the Forest Service filed a revised version of modified

condition 34, noting that the modified conditions filed on November 29, 2010,

inadvertently contained an earlier version of condition 34. The revised modified

condition 34 contains minor changes in the numbered paragraphs 4 and 5, and these

revisions are included in appendix E.
319

Service lands, and reporting such discoveries to the Forest Service. As PG&E recognizes

in its final HPMP, there may be other aspects or investigations identified by the Forest

Service that may need to be addressed, and a provision for adopting these additional

measures has also been provided by PG&E in its final HPMP. As stated above,

amendments to the final HPMP are expected to be made when the final results of the

associated TCP studies have been made, and other cultural resource-related investigations

warranted by the Forest Service (or with any of the other involved parties) can also be

made as amendments to the HPMP. Thus, amendments to the final HPMP can

appropriately address additional items that may need to be examined as expressed in the

Forest Service’s modified condition 34.

Prior to license issuance, the Commission would execute a final PA with the

California SHPO. The PA would require PG&E to implement the HPMP upon license

issuance. The final PA would also allow for the final HPMP to be amended and provides

a dispute resolution process. Execution of the PA and implementation of the HPMP

would ensure that adverse effects of the project on cultural resources would be

appropriately resolved. We analyze the costs of measures proposed or recommended for

cultural resources in section 4.0, Developmental Analysis, and make our final

recommendations in section 5.0, Staff’s Conclusions.
320

3.3.7 Land Use and Aesthetic Resources

3.3.7.1 Affected Environment

Land Use Resources

The existing project features are entirely located in Shasta County near the

communities of McCloud, Hillcrest, Big Bend, and Montgomery Creek. The proposed

McCloud transmission line route is partially located within Siskiyou County. The

existing project boundary, which includes portions of the McCloud River and Pit River

watersheds, encompasses 3,707.6 acres of land. Of the lands within the project boundary,

1,239.4 acres are owned by PG&E, 1,651.4 acres are federally owned lands administered

by the Forest Service, and the remaining 816.8 acres are privately owned (PG&E, 2009a).

The project boundary around McCloud reservoir is described by a metes and

bounds survey that generally follows a contour line about 200 feet above the high water

line of the reservoir. The project boundary also encompasses: (1) McCloud dam,

spillway and outlet; (2) the project road to the base of the dam; (3) the project road

between McCloud dam and Star City Creek; (4) the existing Tarantula Gulch day-use

area and boat launch; and (5) all proposed recreation developments at McCloud reservoir.

A 100-foot-wide corridor for McCloud tunnel extends southeast for about 7.2 miles

between McCloud and Iron Canyon reservoirs. Where the tunnel crosses Hawkins Creek,

there is also a 100-foot-wide corridor for the project access road that is about 0.25 mile

long (PG&E, 2009b).

The project boundary around Iron Canyon reservoir also is described by a metes

and bounds survey and generally follows a contour line about 100 to 200 feet above the

high water line of the reservoir, and in some places extends beyond this distance to

include the existing recreation facilities. The project boundary also encompasses:

(1) Iron Canyon dam, spillway, and outlet; (2) stream gage MC-10 (including the project

access road); (3) the existing Hawkins Landing day-use area and boat launch (including a

40-foot-wide corridor for the access road); (4) the existing Deadlun Campground; and

(5) areas where recreation developments at Iron Canyon reservoir are proposed. A

100-foot-wide corridor for Iron Canyon tunnel extends from near the dam to about

2.9 miles south where the tunnel joins James B. Black penstock. There is

a 300-foot-wide corridor along the 1,194-foot-long James B. Black penstock that enters

James B. Black powerhouse. At James B. Black powerhouse, the project boundary

encompasses the: (1) powerhouse; (2) switchyard; (3) 0.5-mile-long Black Tap

transmission line from James B. Black powerhouse to Pit 5 switchyard; and (4) beginning

of the 40-foot-wide corridor for the 12-kV distribution line that extends to Iron Canyon

reservoir. Oak Mountain Road (FR 37N34), a project road between Pit 5 bridge and FR

38N11, has a 100-foot-wide corridor with a few 66-foot-wide segments (PG&E, 2009b).

Downstream of James B. Black powerhouse, the project boundary encompasses

Pit 6 reservoir. The boundary is described by a metes and bounds survey that generally

follows a contour 100 to 200 feet above the high water line of the reservoir. At the
321

downstream end of the reservoir, the project boundary widens to include the Pit 6 dam,

powerhouse, and switchyard. The 100-foot-wide corridor for the Pit 6 transmission line

begins at Pit 6 switchyard and extends about 3.3 miles to the east where it terminates at a

non-project transmission line. Pit 6 Road, a project road, has a 100-foot-wide corridor

and extends from the powerhouse to Big Bend Road. Downstream of Pit 6 dam, the

project boundary encompasses Pit 7 reservoir, Pit 7 dam, Pit 7 powerhouse, Pit 7 afterbay

dam, and Pit 7 afterbay. The boundary is described by a metes and bound survey that

generally follows a contour 100 to 200 feet above the high water line of the

impoundments. At its most downstream point, the project boundary crosses the Pit River

just upstream of Fenders Ferry Bridge and widens to include the recreation area at

Fenders Flat. The 100-foot-wide corridor for the Pit 7 transmission line begins at Pit 7

switchyard and extends about 3.5 miles to the east where it terminates at a non-project

transmission line. Pit 7 Road, a project road, has a 100-foot-wide corridor and extends

from Pit 7 powerhouse to Fenders Ferry Road (PG&E, 2009b).

The proposed McCloud powerhouse would be constructed within the existing

project boundary at McCloud dam. Beginning at the proposed powerhouse at the base of

the dam, PG&E proposes to construct the McCloud transmission line within a

25-foot-wide corridor that follows the right-of-way of FR 38N11 north to State Highway

89 where it travels east then north, ending at the Pacific Power and Light switchyard in

the town of McCloud. The transmission line corridor is about 14 miles long. The

proposed Pit 7 afterbay powerhouse would be constructed within the existing project

boundary at Pit 7 afterbay dam. A new project road would be constructed just west of

Fenders Ferry Bridge within a proposed 40-foot-wide corridor. Beginning at the dam,

PG&E proposes to construct Pit 7 afterbay transmission line within a 40-foot-wide

corridor that crosses the Pit River near Fenders Flat recreation site and then generally

follows Pit 7 Road to Pit 7 switchyard. The proposed project boundary includes the area

necessary for proposed recreation development associated with the generation addition

(PG&E, 2009b).

No large-scale industrial or commercial developments are located in the project

vicinity. PG&E’s land use in the project area primarily consists of structures and

activities associated with its hydroelectric facilities. The Commission’s standard land use

article (license article 56) regulates land use activities within the project boundary. Land

management planning documents that pertain to land use activities in the area

surrounding the project include the Shasta County general plan (County of Shasta, 2005,

as cited in PG&E, 2009a); the Shasta-Trinity National Forest Land and Resource

Management Plan, as amended (Shasta-Trinity National Forest, 1995 as cited in PG&E,

2009a); and the McCloud River Coordinated Resource Management Plan (Bollibokka

Land Company et al., 2001 as cited in PG&E, 2009a). For the proposed McCloud

transmission line, land use activities would be reviewed for consistency with the Siskiyou

County general plan (County of Siskiyou, 1993, 1980 as cited in PG&E, 2009a). In

addition, Shasta County boating ordinances prohibit: (1) boating within 500 feet of

project dams, (2) operating a motorboat at a speed in excess of 5 miles per hour upstream
322

from the road bridge at the north end of the McCloud River arm of McCloud reservoir,

and (3) swimming within 200 feet of any boat launching ramp or dock open to the public.

Summaries of each of these plans are provided below.

Shasta County General Plan and Zoning Ordinance

Shasta County regulates private land uses in accordance with the Shasta County

general plan (adopted in 1984) and the Shasta County Zoning Ordinance (title 17 of the

Shasta County Code, as amended through July 2003). The Shasta County general plan is

a tool to guide long-term development planning decisions for public and privately owned

lands in Shasta County. The plan is delineated into three core subject areas: public

safety, resources, and community development. A majority of the privately owned lands

in the project vicinity are designated “Timberland.” A few small parcels designated as

“Natural Resource-Open Space” are scattered around the project area with private lands

adjacent to Iron Canyon reservoir being the most notable. Regarding the timberland

designation, the Shasta County general plan notes the following:

While the Shasta County general plan provides the overall development goals for

the County, title 17 of the Shasta County Code defines the various zoning districts within

the County, as well as identifying the primary and permitted uses within each zoning

district. The County has not yet adopted a zoning map for the areas in the project

vicinity. They are considered “Unclassified” and are part of the Special Zone District.

Shasta Trinity National Forest Land and Resource Management Plan

The project area lies within the Shasta-McCloud Management Unit of the ShastaTrinity National Forest. Land use policies and standards for this national forest are

guided by Shasta-Trinity National Forest’s Land and Resource Management Plan

(Shasta-Trinity National Forest, 1995 as cited in PG&E, 2009a). The Land and Resource

Management Plan contains details regarding Late Successional Reserves (LSRs) that are

based on the “Record of Decision on Management of Habitat for Late-Successional and

Old-Growth Forest Related Species Within the Range of the Northern Spotted Owl”

(ROD). The LSRs are intended to provide old-growth forest habitat for populations of

species that depend on late successional forests and conserve late-successional species

diversity. NFS lands near Iron Canyon reservoir are designated as LSR. NFS lands near

the Pit River are designated as “Limited Roaded Motorized Recreation.” A small area

adjacent to the northwestern portion of the upper Pit 6 reservoir is designated as

“Threatened Species – Eagles” (PG&E, 2009a).

The McCloud River Coordinated Resource Management Plan

On July 23, 1991, the Shasta-Trinity National Forest, Bollibokka Land Company,

Crane Mills, McCloud Fly Fishing Club, Sierra Pacific Industries, California Fish and

Game, The Hearst Corporation, The Nature Conservancy, California Trout, and PG&E

adopted the McCloud River Coordinated Resource Management Plan (Bollibokka Land

Company et al., 2001 as cited in PG&E, 2009a). The McCloud River Coordinated

Resource Management Plan is intended to provide the same level of protection of the
323

McCloud River’s fisheries, geology, scenery, cultural and historic values as designation

under the Wild and Scenic Rivers Act. Like the Wild and Scenic Rivers Act, the

Coordinated Resource Management Plan aims to safeguard the river’s unique resources,

while also recognizing the potential for appropriate use and development. The plan

outlines specific ecological, economic, social, and cultural considerations that must be

factored into land use and development decisions through coordinated planning efforts.

With respect to project operations, the plan states:

The operation of McCloud reservoir dam has direct influence on the McCloud

River Basin. Any changes in the operation of the dam will be a subject for study

by the Coordinated Resource Management Plan coordinating group.

Should the Coordinated Resource Management Plan fail to protect the river’s resources,

the Forest Service may seek formal designation of the river as a wild and scenic river.

Current land use activities are consistent with the existing plans and ordinances for

the project area. Issues identified by neighboring landowners were related to recreation

use effects on private lands, including public trespassing, privacy, and risks associated

with wildland fire, and natural resource protection (PG&E, 2009a).

Public Safety and Law Enforcement

The Shasta County Sheriff and the Forest Service are responsible for public safety

and law enforcement on lands in the project area. All existing project lands are within

the jurisdiction of the Shasta County Sheriff. Forest Service law enforcement personnel

from the Shasta-McCloud and National Recreation Area units of the Shasta-Trinity

National Forest are responsible for enforcing regulations related to the management of

Forest Service lands and resources. Forest Service personnel do not have jurisdiction on

the water surface of the project reservoirs.

Project Roads

Within the project vicinity, 21 road segments, about 54 miles, are used by PG&E

or recreationists to access project facilities or project recreation opportunities. Based on

the results of traffic count records, 14 of the 21 road segments are either project roads

(defined by the Commission as roads used primarily for project purposes) or roads used

to access project recreation areas (table 3-41). The majority of these segments are gravelor dirt-surfaced roads. The other six roads are paved with asphalt, concrete, or

bituminous surfaces, or they contain portions of both paved and unpaved segments. A

road condition inventory performed on these sections indicates that most of the roads are

maintained to the maintenance level definition for vehicular travel (PG&E, 2009a).29

29 In a study plan determination letter dated October 3, 2008, the Commission

determined, based on information contained in Technical Memo 22, submitted as part of

the license application, that FR 38N11 (Hawkins Creek Road segments 1 and 2) does not

meet the Commission’s criteria for project roads used primarily for project purposes.
324

In general, PG&E maintains project-related roads in accordance with easements

and use agreements between PG&E, Forest Service, or the private land owner. Road

surfaces were qualitatively characterized using good, fair, and poor ratings to describe the

overall condition for vehicular travel. These condition assessments also considered the

Forest Service management objective for the particular segment. Of the 14 segments in

table 3-41, eight were in fair condition, three were in poor condition, one was in fair/poor

condition, and two were characterized as having multiple conditions depending on the

segment. None of the roads were impassable for normal passenger vehicles; however,

fewer of these types of vehicles were observed except on the paved roads surrounding

McCloud reservoir and Iron Canyon reservoir. Road segments designated as being in

poor condition exhibited generally passable conditions; however, localized damage to the

road, such as a series of potholes or washboard conditions, warranted the poor rating.

Vehicles can access project reservoirs or features for most of the year, but road closures

due to snow periodically preclude access during the winter months. However, PG&E

maintains Oak Mountain Road so that it is free of snow to access project facilities at Iron

Canyon dam (PG&E, 2009a).
325

Table 3-41. Project roads.

Road

Number Name Start End Length(mi)

Maintenance

Responsibility

Surface

Type Comments

38N81 Brown Trout 38N11 Boat Ramp 0.3 Shared Asphalt

Concrete

Tarantula Gulch-road

access to boat ramp

recreation site

38N04Y Star City 38N11 Bridge 2.5 Shared Native Access to intake; access

for recreation on

shoreline

U38N11X McCloud

Dam Road

38N11 Base of

McCloud

Dam

0.25 PG&E Native Road to base of

McCloud dam

37N78 Iron Canyon

Loop

38N11 Iron Canyon

Dam

0.7

(estimated)

Forest Service Bituminous

Aggregate

Native

Road around Iron

Canyon reservoir-access

to Iron Canyon dam and

structures, recreational

access to shoreline areas

37N27Y Deadlun

Creek

Campground

37N78 Campground 0.34 Forest Service Native Access to campground −

project recreation feature

37N66Y Hawkins

Landing

Road

38N11 Hawkins

Boat Ramp

0.56 PG&E Native Access to campground

and boat ramp − project

recreation feature

37N78A MC-10

Gage Road

37N78 Low Level

Outlet and

Gage

0.28 PG&E Native Road to MC-10 stream

gage
326

Road

Number Name Start End Length(mi)

Maintenance

Responsibility

Surface

Type Comments

37N34 Oak

Mountain

Road

38N11 Pit 5 Bridge 7.71 PG&E Native Access to pipeline,

12-kV powerline

37N93 Ridge Iron

Canyon

Road

Junction

with

37N93A

& C

Oak

Mountain

Road

0.3 PG&E Native To pipeline off Oak

Mountain Road

37N93A Ridge Road 37N93 Pipeline 0.6 PG&E Native Off Oak Mountain Road

37N33C Willow

Siphon

37N93 Pipeline 0.5 PG&E Native Off Oak Mountain Road

Pit 6 PH Pit 6

Powerhouse

Road

Cove

Road

Pit 6

Powerhouse

6.0 PG&E Asphalt

Concrete

Road to Pit 6

Powerhouse

35N23 Pit 7

Powerhouse

Road

34N17 Pit 7 Dam

and

Powerhouse

1.79 PG&E Asphalt

Concrete

Road to Pit 7 Dam and

Powerhouse

35N66 Fenders Flat 35N23 Afterbay

Dam

0.57 PG&E Native Road to Pit 7 Afterbay
327

Recreational OHV use is an activity that occurs within the project area, and

although it is not concentrated on project roads, the activity results in road and resource

damage not typically identified as part of traditional road inventories. OHV use is

concentrated at Iron Canyon reservoir resulting in dispersed shoreline access, as well as

concentrated uses within and adjacent to the Hawkins Landing and Deadlun

campgrounds. OHV use is also popular with visitors to Fenders Flat near the Pit 7

afterbay. Multiple user-created OHV roads exist in these areas, including roads from

campsites to the Iron Canyon reservoir shoreline, roads along the shoreline, and roads

from FR 35N66 to project lands near the Pit 7 afterbay, which are not open to public use

(PG&E, 2009a).

Fire Events and Existing Wildland Fire Prevention Measures

The project is situated in a fairly remote and sparsely populated area of the state,

which has vast natural forest resources prone to dramatic fire events with the potential

(under certain conditions) for tremendous amounts of destruction. Fire suppression is a

shared responsibility between the Forest Service, state of California, and the county. Fire

stations and fire suppression equipment is generally housed near populated areas with

concentrations of fire-fighting equipment in Redding, McCloud, Burney, and Big Bend,

all located at a considerable distance from the project area with notably long travel times.

Between 1960 and 2007, four wildland fires either occurred or spread to within 1 mile of

the project area, but no fires were reported within the project boundary and these fires did

not threaten any project structures (PG&E, 2009a).

The measures taken by PG&E to reduce fire risk at project features under the

existing license include actively maintaining vegetation in proximity to project features

(e.g., transmission lines) and keeping hand tools (e.g., shovels, mattocks, McLeods)

available to suppress fires. Certain laws and regulations30 also prescribe how PG&E

must manage vegetation associated with the project transmission lines.

In addition to existing license requirements, the Forest Service-issued special use

permits for the construction of the road and campground at Hawkins Landing and

Deadlun areas require PG&E to keep tools for fire suppression onsite or readily available,

including shovels, picks, pulaskis, McLeods, and mattocks. In addition to the tools,

equipment and vehicles will have spark arrestors to prevent the unintended ignition of

fires due to sparks from work requirements (PG&E, 2009a).

Aesthetic Resources

Area around McCloud Reservoir

McCloud reservoir is located in Northern California situated within the forested

mountain terrain of the western slope of the Cascade Range just south of Mount Shasta.

30 These laws and regulations include Public Resource Code sections 4292 and

4293, General Order 95 Rule 35, and NERC standard FAC-003-1.
328

The landscape character consists of evergreen forested mountain slopes in a remote,

scenic setting. The visual character of the area around McCloud reservoir consists of a

narrow, winding reservoir surrounded by steep forested hillsides. FR 11, a paved road,

traverses the shoreline of the southern half of the reservoir, providing the public with

views dominated by the blue water of the reservoir and surrounding evergreen forest.

The northern end of the reservoir is private land with no public road access. FR 11 sits

on a bank cut out of the steep hill slopes and follows the contours around the shoreline.

Vegetation and topography often obstruct views of the reservoir. Conversely, the public

can view the project area from the reservoir surface. The natural landscape dominates the

views throughout the area, with human-made facilities limited to the earth-filled

McCloud dam, the Tarantula Gulch boat ramp recreation area, the McCloud tunnel

intake, and public and private roads. Minimum flow releases to the Lower McCloud

River are made at the base of McCloud dam from a Howell-Bunger valve that sprays

water about 100 feet away from the outlet into a pool at the base of McCloud dam, where

it enters the river. The visual resources associated with the area around McCloud

reservoir are captured in photographs from key observation points (KOPs) and presented

in volume III, TM-57, Aesthetic Resources Assessment (PG&E, 2009a).

Area around Iron Canyon Reservoir

Iron Canyon reservoir is situated at the confluence of five small creek tributaries,

creating a relatively shallow, five-fingered-shaped reservoir with waters extending into

the narrow coves created by the stream channels. Dense evergreen forests, which cover

the surrounding hill slopes, obscure most views of the reservoir from nearby roads;

however, some open views of the water occur. Below the high-water mark, slopes are

moderate and characterized by exposed (unvegetated or sparsely vegetated) soils, as

expected with a storage reservoir. Open landscape-scale views are provided at both

developed and dispersed recreation areas located around the perimeter of the reservoir,

from the dam, and from the water surface. The visual resources of the area around Iron

Canyon reservoir are captured in photographs of KOPs and presented in volume III,

TM-57, Aesthetic Resources Assessment (PG&E, 2009a).

Pit River (James B. Black Powerhouse, Pit 6 and Pit 7 Reservoirs, and Pit 7

Afterbay)

James B. Black powerhouse is located on the north bank of the Pit River less than

3 miles downstream from the town of Big Bend, California. Views of the powerhouse

are possible from points along the Pit River in proximity to the powerhouse, as well as

from a small portion of Oak Mountain Road, a Forest Service road that provides access

between Iron Canyon reservoir, the Pit River and James B. Black powerhouse.

Vegetation and topography screen views of the powerhouse from any considerable

distance. Transmission lines leaving the powerhouse and the penstock that supplies

water to the powerhouse are visible from nearby locations.

Pit 6 reservoir is long, narrow, and confined within the walls of the Pit River

Canyon, which is at most 500 feet wide. Views of the reservoir are limited to locations
329

along the top of Pit 6 dam. The reservoir can only be accessed by foot from the dam, or

potentially by boat from the Pit River, but to protect the public, PG&E discourages such

boat access. Dense tree cover and steep topography preclude views of the reservoir from

other locations, and the lack of public access limits viewing opportunities. The Pit 6 dam

and powerhouse are visible from points along the last mile or so of Pit 6 Road as it

descends into the Pit River Canyon.

Pit 7 reservoir is similar to Pit 6 reservoir in that it is long, narrow, and confined

within the walls of the Pit River Canyon with dense vegetation and steep topography

obscuring the reservoir from view. Views of Pit 7 reservoir from publicly accessible land

are very limited and only available from the Pit 6 Road and the area around Pit 6 dam or

along the section of Pit 7 Road that is open to foot travel beyond a locked gate. The Pit 7

afterbay, the most visible water feature within the Pit River portion of the project, is

visible from Fenders Ferry Road (FR 34N17) where it crosses the Pit River arm of Shasta

Lake and from the car-top boat launch area at Fenders Ferry. Uplands surrounding the

river are heavily forested with evergreen oak woodland and pine vegetation. From the

bridge, the rock-filled afterbay dam is visible in the mid-ground of the landscape. Flows

from Pit 7 reservoir are regulated with the V-notch weir in Pit 7 afterbay dam. Water

flowing out of the afterbay appears riverine as water flows through the weir when Shasta

Lake levels are low. When Shasta Lake is at full pool, the reservoir overtops the dam,

changing the character of the area to one of flat water as opposed to a flowing river.

Security fencing, signs, and safety chains that warn visitors about the danger associated

with the Pit 7 afterbay dam are visible.

Photos of visual resources associated with components of the project infrastructure

located in the Pit River drainage, including James B. Black powerhouse, Pit 6 reservoir,

Pit 7 reservoir, and Pit 7 afterbay, are captured in photographs of KOPs and presented in

volume III, TM-57 (PG&E, 2009a).

Forest Service Visual Quality Objectives

The Shasta-Trinity National Forest Land and Resource Management Plan (ShastaTrinity National Forest, 1995 as cited in PG&E, 2009a) provides preferred VQOs for

lands within the Shasta-Trinity National Forest boundary. VQOs for project lands within

the Shasta-Trinity National Forest are currently classified as either Retention or Partial

Retention. Retention VQOs promote landscapes that, when viewed by the public, have

an intact natural or natural-looking character. Human-made alterations to these

landscapes should not create changes in form, color, or texture from those naturally

occurring in the viewshed. Partial Retention VQOs allow for more alteration of the

landscape, but new forms, colors, or textures added to the landscape should be dominated

and subdued by the natural character of the area (PG&E, 2009a). Table 3-42 summarizes

the VQO designations by general project area.

Although it may be more appropriate, the Shasta-Trinity National Forest Land and

Resource Management Plan does not currently classify the area around the project

facilities as Modification. Modification refers to landscapes where the valued landscape
330

characters “appear moderately altered.” Deviations begin to dominate the valued

landscape character being viewed, but they borrow valued attributes such as size, shape,

edge effect and pattern of natural openings, vegetative type changes or architectural

styles outside the landscape being viewed. The Shasta-Trinity National Forest is

scheduled to revise the Land and Resource Management Plan, at which time the Scenery

Management System (SMS) would likely be used in scenery analysis and evaluation and

the project area may be reclassified.

Table 3-42. Summary of Shasta-Trinity National Forest VQO classifications and

guidelines for NFS lands within the project area or influenced by project

operations. (Source: PG&E, 2009a)

National Forest System Lands

Surrounding

VQO Designation

McCloud reservoir Retention

Spoil piles and tunnel crossing Partial Retention

Iron Canyon reservoir Retention

James B. Black penstock Retention and Partial Retention for the

Willow Creek siphon and surge chamber

Pit 6 and Pit 7 reservoirs Retention

Pit 7 afterbay Retention

3.3.7.2 Environmental Effects

Land Use Resources

Road and Transportation Facilities Management Plan

Some of the roads used by PG&E to access project facilities are Forest Service

roads or roads owned by The Hearst Corporation. While some of these roads are used

primarily for project purposes, others are not. Roads in the project vicinity may be used

by the Forest Service for land management or by the public for recreation unrelated to the

project.

PG&E proposed to prepare a Road and Transportation Facilities Management Plan

for the 14 road segments listed in table 3-41 within 1 year of license issuance. The plan

would include, among other things, a road inventory and condition assessment, maps, a

discussion of soil protection and erosion control measures, and a traffic safety plan. The

plan would incorporate Forest Service standards for design, construction, operation, and

maintenance and would be approved by the Forest Service. Upon Commission approval,

PG&E would implement the plan and actions specified therein.
331

In its original condition 29, the Forest Service specified that PG&E file with the

Commission, within 1 year of license issuance, a Road and Transportation Facility

Management Plan, approved by the Forest Service, for protection and maintenance of

project and project-affected roads that are on or affect NFS lands. The Forest Service

specified that two additional road segments, not covered by PG&E’s proposed measure,

be included in the plan: FR 38N11 (Hawkins Creek segment 1) and FR 37N78 (Iron

Canyon Loop Road). The Forest Service specified that the plan should address:

planning and inventory; operation, maintenance, and road-associated debris (including

road spoil piles); construction and reconstruction; monitoring; general road use; and road

use by government. PG&E should take appropriate measures to meet Forest Service

maintenance level, traffic service level, and road management objectives (RMOs).

PG&E should consult with the Forest Service and other affected parties in the

development of this plan. Upon Commission approval, PG&E should implement the plan

and actions specified therein.

In its original condition 29, the Forest Service also specified that PG&E develop

an MOU with the Forest Service and other affected parties to address shared road

management responsibilities (e.g., costs, public safety needs, resource protection, and

erosion control mitigations). Upon Commission approval, PG&E should implement the

MOU.

PG&E alternative condition 29 proposes revisions to subheadings to remove

ambiguous wording that could lead to differences of opinion as to which roads are

covered by the Forest Service’s original condition 29. PG&E alternative condition 29

proposes clarifications to which road segments would be covered by the plan and which

road segments would be included in a separate MOU with the Forest Service. PG&E

disagrees with the Forest Service’s designation of FR 38N11 (segment 1) and FR 37N78

(Iron Canyon Loop Road) as project roads for which PG&E would be responsible under

the license. PG&E’s alternative revises the extent of FR 38N11 based on an

understanding that its responsibility for shared maintenance of FR 38N11 terminates on

the west side of Kosk Creek Bridge.

PG&E alternative condition 29 clarifies the road reconstruction implementation

schedule. PG&E alternative condition 29 also removes references to bridges and tunnel

spoil piles because none of these features associated with the project are located on NFS

lands or could directly affect NFS lands.

The Hearst Corporation owns certain roads within the project area and has existing

construction and easement agreements with PG&E and the Forest Service for

maintenance and use of these roads. While The Hearst Corporation supports the idea of

an MOU, it does not support the Forest Service’s proposed expansion of the project

boundary.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 29. The provisions specified in Forest Service modified condition 29 are

similar to those specified in the Forest Service’s original condition 29, except that the
332

Forest Service has removed specific details from the 4(e) condition and placed them in

the draft Road and Transportation Facility Management Plan, included as an enclosure to

the filing (Forest Service, 2010d, Enclosure 3). Additionally, in modified condition 29,

the Forest Service continues to identify FR 38N11 (Hawkins Creek Road segment 1) and

FR 37N78 (Iron Canyon Road) as project roads. The Forest Service reiterates its concern

with the use of the PG&E traffic study, specifically, the reliance on visual observations

rather than data collected by electronic road traffic counters, to characterize the use of

these two road segments for project purposes as incidental.

In the draft Road and Transportation Facility Management Plan, (Forest Service,

2010d, Enclosure 3), the Forest Service recommends specific requirements and clarifies

the intent of modified condition 29. With the exception of the removal of a discussion of

the MOU, the minimum components of the plan remain unchanged as compared to the

Forest Service’s original condition 29.

On December 14, 2010, the Forest Service filed with the Commission a settlement

agreement between PG&E and the Forest Service for non-project recreation facilities and

roads in the Shasta-Trinity National Forest.

Our Analysis

PG&E is responsible for the maintenance of all project roads within the project

boundary (table 3-41). Consistent with the Commission’s October 3, 2008, study plan

determination letter and based on information contained in Technical Memorandum 22,

submitted as part of PG&E’s license application, FR 38N11 (Hawkins Creek Road

segments 1 and 2) do not meet the Commission’s criteria for project roads used primarily

for project purposes. Due to the unreliability of the electronic road traffic counters used

during the traffic study, the Commission previously advised PG&E to use only the direct

visual observation estimates when discussing road and recreational use at the project.

Recreation visitor questionnaire data showed that the majority of users of Hawkins Creek

Road visit non-project related locations for angling in the Lower McCloud River, with

the primary destinations including Ash Camp, Ah-Di-Na, and The McCloud River

Preserve. Questionnaire data also indicates that a majority of users (river anglers) visit

other similar regional destinations and do not fish in project reservoirs.

As shown in table 3-41, a 0.7-mile section of FR 37N78 (Iron Canyon Loop Road)

from FR 38N11 (Hawkins Creek Road) to Iron Canyon dam does meet the Commission’s

criteria for project roads and is currently within the project boundary. The entire length

of FR 37N78 (Iron Canyon Road) is not currently necessary to access project

infrastructure and study data show that there are very few visitors using Iron Canyon

Loop Road to access the dispersed sites along the shoreline.

As discussed later in this section, should PG&E construct any new recreation sites

and facilities along Iron Canyon Road, the recreation sites and facilities, to include any

roads necessary for project purposes, should also be included in the project boundary. A

Road and Transportation Facilities Management Plan would establish a forum for
333

coordination of road maintenance activities among PG&E, the Forest Service, and other

affected parties, such as The Hearst Corporation. A plan would help to clarify and

memorialize PG&E’s road management responsibilities within the project boundary.

Specifically, the plan would address planning, operations, maintenance, construction and

reconstruction, monitoring, and road use. The development and implementation of a

Road and Transportation Facilities Management Plan would improve road management

and ensure public access to project lands and waters and the adequate protection of

natural and environmental resources in the project area.

There are road spoil piles along roads on NFS lands that may be within the project

boundary. The details about who is responsible for correcting problems created by these

spoil piles (e.g., removal) should be included in the proposed Road and Transportation

Facilities Management Plan to be prepared in consultation with the Forest Service and

filed with the Commission for approval.

The settlement agreement between PG&E and the Forest Service resolves certain

issues and responsibilities for roads that are outside of the project boundary. The

settlement agreement addresses shared road (non-project) management responsibilities;

specifically, proportionate road share costs, public safety needs, resource protection, and

erosion control mitigations.

Fire Prevention and Response Plan

Steep topography, heavy vegetation, land use, and limited access make the project

area susceptible to wildfires. Continued project operations and existing facilities (e.g.,

transmission lines, generators, and construction equipment), and increased recreational

use over the term of the new license may also contribute to fire danger in the project area.

Fire fighting near the project is challenging and there exists the potential for small fires to

grow into large and very destructive fires. Additional fires in the project area may,

among other things, affect public safety, property, aesthetics, and air quality. The threat

and potential damage from wildfires in the project area would remain an issue under a

new project license.

PG&E proposed to prepare a Fire Prevention and Response Plan in consultation

with the Forest Service, California Department of Forestry and Fire Protection, and Big

Bend Volunteer Fire Department within 1 year of license issuance. At a minimum the

plan would address fuels treatment/vegetation management; fire prevention and control;

emergency response preparedness; and reporting requirements. Additionally, the plan

would ensure that fire prevention measures meet water quality BMPs. Upon Commission

approval, PG&E would implement the plan.

In its original condition 33, the Forest Service specified that PG&E develop a Fire

and Fuels Plan in consultation with the Forest Service and appropriate state and local fire

agencies and file the plan with the Commission within 1 year of license issuance. The

specified components of this plan would include fuels treatment; fire prevention and

response; emergency response preparedness; and reporting. Additionally, the Forest
334

Service specified that PG&E would cooperate fully with the Forest Service on all fire

investigations and would produce upon request all materials and witnesses not subject to

the attorney-client or attorney work product privileges, over which PG&E has control,

related to the fire and its investigation.

In its original condition 33, the Forest Service also specified that PG&E would

preserve all physical evidence, and give custody to the Forest Service of all physical

evidence requested. Similarly, the Forest Service would provide PG&E with reasonable

access to the physical evidence and documents PG&E needs to defend any and all claims,

which may arise from a fire resulting from project operations, to the extent such access is

not precluded by ongoing criminal or civil litigation.

PG&E alternative condition 33 proposed a few minor revisions intended to

improve comprehension, but no material changes to the Forest Service’s original

condition 33.

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 33. The provisions specified in Forest Service modified condition 33 are

similar to those specified in the Forest Service’s original condition 33, except the Forest

Service has removed specific details of the plan components from the 4(e) condition and

placed them in the draft Fire and Fuels Management Plan, included as an enclosure to the

filing (Forest Service, 2010d, Enclosure 3).

In the draft Fire and Fuels Management Plan (Forest Service, 2010d, Enclosure 3),

the Forest Service recommends specific requirements and clarifies the intent of modified

condition 33. With the exception of the addition of a discussion of post-fire activities, the

minimum components of the plan, as discussed above, remain unchanged as compared to

the Forest Service’s original condition 33. This additional component would require

PG&E to coordinate post-fire mitigations with the Forest Service following a fire on

project-affected NFS lands. Potential mitigations could include timber salvage or hazard

tree removal; the opening and closing of roads; slope stabilization and erosion reduction;

and construction/reconstruction plans for any project-affected facility (including

recreation sites) damaged by the fire. In its November 24, 2010, filing, PG&E accepts

modified condition 33 and withdraws its alternative condition 33.

Our Analysis

The development and implementation of a Fire Prevention and Response Plan in

consultation with the Forest Service, the California Department of Forestry and Fire

Protection, the Big Bend Volunteer Fire Department, and others, as appropriate, that

incorporates both the measures proposed by PG&E and specified by the Forest Service

would improve planning, management, and coordination of wildfire protection and

prevention measures, as well as lead to a reduction in the occurrence and suppression of

wildfires in the project area, minimizing damage to natural resources. The addition of

post-fire mitigations in the modified condition would help to further protect resources and
335

restore, if necessary, any project-affected facility damaged by the fire. The plan should

be filed with the Commission for approval within 1 year of license issuance.

Timber Removal

Project activities, such as danger tree removal; post-fire (or other natural hazard)

mitigation; construction/reconstruction of recreation facilities; and O&M activities

around project facilities and along transmission line corridors in compliance with local,

state, and federal regulations, may require PG&E to remove merchantable timber from

NFS lands within the project boundary. Depending upon the situation, timber removal

could be routine maintenance or in response to an emergency situation, and the removal

could be limited or extensive.

In modified condition 25, discussed in section 3.3.3.2.1, Vegetation, the Forest

Service specifies that PG&E develop a Vegetation and Invasive Weed Management Plan,

which would, among other things, include a timber removal process and protocols and,

more specifically, a hazard tree removal process. In its November 24, 2010, filing,

PG&E accepts Forest Service modified condition and withdraws its alternative

condition 25.

Our Analysis

The development of a Vegetation and Invasive Weed Management Plan and

established and well-defined timber removal protocols would help to avoid inadvertent

and unauthorized timber cutting on NFS lands within the project boundary, while

providing for public safety and resource protection.

PG&E has not proposed any timber removal from NFS lands within the project

boundary. However, if PG&E proposes to remove timber from NFS lands within the

project boundary, the activity must be permitted by the Forest Service in accordance with

all applicable plans and protocols. Prior notice of timber removal on NFS lands within

the project boundary must also be given to the Commission.

Hazardous Substance Management Plan

In its original condition 28, the Forest Service specified that PG&E would file, for

Commission approval, a plan approved by the Forest Service for oil and hazardous

substances storage and spill prevention and cleanup. The plan would be filed within

1 year of license issuance, and at least 60 days before the initiation of any activities that

the Forest Service determines to be of a land-disturbing nature on NFS lands. At a

minimum, the plan would require PG&E to:

 Maintain in the project area, a cache of spill cleanup equipment suitable to

contain any spill from the project;

 Periodically inform the Forest Service of the location of the spill cleanup

equipment on NFS lands and the location, type, and quantity of oil and

hazardous substances stored in the project area; and
336

 Inform the Forest Service immediately of the nature, time, date, location, and

action taken for any spill on or affecting NFS lands.

PG&E alternative condition 28 proposed to provide the Forest Service copies of

PG&E’s existing spill prevention, control, and countermeasures plans and hazardous

materials business plans for the project.

In its November 29, 2010, filing, the Forest Service removes condition 28. In its

November 24, 2010, filing, PG&E withdraws its alternative condition 28.

Our Analysis

The potential for PG&E to spill hazardous materials within the project boundary

and to impact area resources exists. PG&E is responsible for such spills and would be

required to identify acceptable prevention and mitigation measures. To meet the

regulatory requirements for handling, storage, and emergency response related to

hazardous materials, PG&E has spill prevention, control, and countermeasures plans and

hazardous materials business plans in place. The geographical scope of the plans should

include the entire project area. Although no longer required by condition 28, the

provision of the existing Spill Prevention, Control, and Countermeasures Plan and

Hazardous Materials Business Plan to the Commission (for approval), with copies to the

Forest Service and the Central Valley Regional Water Board, within 30 days of license

issuance and the continued implementation of these plans would ensure that spills of

hazardous substances are promptly contained and cleaned up to avoid/minimize the

potential extent of adverse environmental effects.

Project Boundary

While the proposed McCloud powerhouse and Pit 7 afterbay dam would be

constructed within the existing project boundary at McCloud dam and Pit 7 afterbay dam,

respectively, the proposed new transmission line corridors associated with the new

powerhouses and certain proposed new recreation facilities would be constructed outside

of the existing project boundary. PG&E proposes to include the existing access road to

Hawkins Landing Campground and boat ramp, the Fenders Flat recreation site (both are

existing project recreation facilities), and lands necessary for the proposed generation

additions within the project boundary. PG&E also proposes to include all new project

recreation facilities and any existing reconstructed facilities within the project boundary

after construction.

The Forest Service recommended under 10(a) that the following project-related

facilities, not currently included within the project boundary, be added to the project

boundary. Specific sites include:

 Segment 1 of FR 38N11 (Hawkins Creek Road);

 FR 37N78 around Iron Canyon reservoir;
337

 The area between the McCloud reservoir high waterline (elevation 2,680

feet msl) and the outside right-of-way of FR 38N11 (Hawkins Creek, segment

1), and FR 38N04Y (Star City Road); and

 All new project recreational facilities.

The Hearst Corporation does not support the proposed expansion of the project

boundary to the outside edge of the road system.

In its November 29, 2010, filing, the Forest Service continues to specify FR

38N11 (Hawkins Creek Road segment 1) and FR 37N78 (Iron Canyon Road) as project

roads. The Forest Service also recommends that project boundary adjustments be made

at the point when the Recreation Development and Management Plan is approved by the

Commission to ensure that the development of any new recreation facility is

appropriately within the Commission’s jurisdiction. As discussed in section 3.3.5.2,

Environmental Effects, Lower McCloud River Recreation Facilities, in modified

condition 30 the Forest Service specifies that new and reconstructed project recreation

facilities on NFS lands would be included in the project boundary prior to ground

disturbance.

Our Analysis

As discussed previously, the Commission has determined that FR 38N11

(Hawkins Creek Road segments 1 and 2) does not meet the Commission’s criteria for

project roads used primarily for project purposes and should not be included in the

project boundary. Although the entire length of FR 37N78 (Iron Canyon Loop Road) is

not necessary to access project infrastructure, a 0.7-mile (estimated) section of FR 37N78

from FR 38N11 (Hawkins Creek Road) to Iron Canyon dam is necessary to access

project infrastructure (i.e., the dam) and therefore meets the Commission’s criteria for

project roads and is included within the existing project boundary. Additionally, Oak

Mountain Road (FR 37N34), a designated project road, provides access to other project

infrastructure at Iron Canyon reservoir; therefore, the entire length of FR 37N78 (Iron

Canyon Loop Road) is not necessary for access to project infrastructure. As discussed

below, should PG&E construct any new recreation sites and facilities along Iron Canyon

Road, the recreation sites and facilities, to include any roads necessary for project

purposes, should also be included in the project boundary.

Since the Commission will have responsibility to ensure compliance at the

project’s existing and proposed recreation areas, these areas must be included within the

project boundary and be within the Commission’s jurisdiction. By requiring PG&E to

include all project recreation sites (existing and proposed) within the project boundary,

the Commission would have the authority to ensure that PG&E maintains adequate and

safe public access to project lands and waters for recreational purposes.

In section 2.3, Staff Alternative, we propose to modify the Forest Service’s

recommendation to require PG&E to include all existing (at license issuance) project

roads and recreation sites and facilities within the project boundary and to file a revised
338

exhibit G within 1 year of license issuance. Under any new license issued for the project,

PG&E also would be required to file a revised exhibit G with the Commission subsequent

to completing construction of new project generating and transmission facilities or

recreation sites and facilities, which would include any roads necessary for project

purposes that should also be included within the project boundary. The staff-proposed

modification would not require PG&E to include FR 38N11 (Hawkins Creek Road

segment 1) and FR 37N78 (Iron Canyon Loop Road), with the exception of a 0.7-mile

segment, already within the project boundary. Staff’s proposal to require PG&E to

include all new recreation sites and facilities within the project boundary and to file a

revised exhibit G would include the area between McCloud reservoir and FR 38N11 and

FR 38N04Y (Star City Road) to include only the outermost limits of any new recreation

site (i.e., only the area serving project purposes) if PG&E constructs new recreational

facilities in this area.

Aesthetic Resources

Visual Quality Management Plan

In its original condition 32, the Forest Service specified that PG&E develop, for

Forest Service approval and filing with the Commission, procedures or a timeline to

ensure implementation of certain mitigation measures to provide for visual quality of

project and project-related NFS lands. These mitigation measures would include, but not

be limited to, painting or reconstructing project facilities with natural looking materials

and colors, planting vegetation to screen project facilities; maintaining reservoir

elevations during the peak recreation season; developing an education plan and providing

interpretive information; and disposing of debris piles.

PG&E alternative condition 32 proposed to define the applicability of the Forest

Service’s original condition 32 to existing and proposed project facilities (i.e., generation

additions) and clarified certain terminology. PG&E alternative condition 32 also

identified an apparent inconsistency between the assigned VQO and the appearance of

the area, including existing project facilities. The Forest Service assigned VQOs to the

project area after the existing project facilities were constructed. Further, PG&E

alternative condition 32 removed text from the Forest Service’s original condition 32 that

requires modification of existing project facilities for visual quality purposes because

studies conducted during relicensing did not identify any needed modifications. PG&E

alternative condition 32 appropriately proposed provisions for visual screening, painting,

and other necessary mitigation measures for any new project facilities. PG&E alternative

condition 32 also reflected PG&E’s willingness to apply mitigation measures to attempt

to meet VQOs when existing project facilities are modified. Finally, PG&E alternative

condition 32 limited future mitigation to any new spoil or debris piles created by the

project (i.e., mitigation for existing piles would not be required).

In its November 29, 2010, filing, the Forest Service includes modifications to

condition 32. Modified condition 32 specifies the development of tasks and a timeline to

assure implementation of specific mitigation measures to improve the visual quality of
339

project and project-affected NFS lands. The provisions specified in Forest Service

modified condition 32 are similar to those specified in the Forest Service’s original

condition 32, except that the Forest Service includes a draft document as an enclosure to

the filing (Forest Service, 2010d, Enclosure 3), which identifies specific visual

mitigations to reduce project and project-related visual effects through the use of selected

materials, surface treatments, paint color, vegetative visual screening, and facility design.

Additionally, modified condition 32 also adds a monitoring component. Within the first

year of the license, PG&E and the Forest Service would develop KOPs for monitoring

any changes in visual quality as a result of project implementation during the license

term.

In the draft Visual Quality Management document (Forest Service, 2010d,

Enclosure 3), the Forest Service recommends that PG&E and the Forest Service meet, in

the field, within the first year of the license to develop a list of specific mitigations that

blend existing project facilities (VQO Modification) with the natural surroundings (VQO

Retention and Partial Retention). However, facilities in good repair would only have

mitigations applied as maintenance is needed. The draft document also discusses the

incorporation of visual quality considerations into the reconstruction of existing facilities

and construction of new facilities. In its November 24, 2010 filing, PG&E accepts

modified condition 32 and withdraws its alternative condition 32.

Our Analysis

In the draft EIS, we proposed to modify the Forest Service’s recommendation to

require PG&E to develop a Visual Quality Management Plan, in consultation with the

Forest Service and others, as appropriate, to protect the visual quality of lands in the

project area within 1 year of license issuance. The plan would address the impact of any

proposed project facilities or modifications to existing facilities, including but not limited

to generating facilities, recreation sites and facilities, and spoil piles, on the aesthetics in

the project area.

In lieu of a management plan, PG&E and the Forest Service have agreed to

specific mitigations that would be implemented within established timeframes to meet

Forest Service VQOs in the project area. Using a tasks and timeline approach is a

reasonable alternative to a management plan. The mitigations contemplated by both

PG&E and the Forest Service, such as visual screening, painting, providing interpretive

information, and maintaining reservoir water levels during the peak recreation season

would collectively reduce project visual effects and improve visual quality in the project

area. Developing a description of specific mitigation measures and an associated

timeline in consultation with the Forest Service that would be filed with the Commission,

would further ensure that appropriate measures were completed in timely manner.
340

3.4 NO-ACTION ALTERNATIVE

Under the no-action alternative, the project would continue to operate as it has in

the past. None of PG&E’s proposed measures or the resource agencies’

recommendations and mandatory conditions would be required, and the existing trout

populations would not be enhanced as a result of increased minimum flows. The

continued operation of the existing McCloud-Pit facilities would continue to be of

importance to water supply, recreation, generation of renewable energy, and

minimization of atmospheric pollutants. The continued operation of the existing facilities

under the no-action alternative would, on average, result in the annual generation of

1,542.2 GWh of clean energy.
341

4.0 DEVELOPMENTAL ANALYSIS

In this section, we estimate the economic benefits of how the McCloud-Pit

facilities now operate, the cost of various environmental measures, and the effects of

these measures on project operation under a new license. We also analyze PG&E’s

proposal to install new units at the project.

4.1 POWER AND ECONOMIC BENEFITS OF THE PROJECTS

4.1.1 Economic Assumptions

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

articulated in Mead Corporation, Publishing Paper Division (72 FERC ¶61,027, July 13,

1995) (Mead), 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.

For our economic analysis of PG&E’s proposed project and the alternatives, we

used the assumptions, values, and sources shown in table 4-1.
342

Table 4-1. Staff assumptions for economic analysis of the McCloud-Pit Project.

(Source: Staff)

Assumption Value Source

Base year for costs and benefits 2009 PG&E, 2009a

Peak/Off-peak energy value

(mills/kilowatt hour [kWh])a 87.5 PG&E, 2009a

Dependable capacity value ($/kW-year)a0 PG&E, 2009a

Period of analysis 30 years Staff

Term of financing 20 years Staff

Federal and state tax rate 40.75% PG&E, 2009a

2009 to 2010 inflation for most final

license applications costs 0% Staff

Insurance rate 1.2% PG&E, 2009a

Discount rate 8.8% PG&E, 2009a

Interest rate 8.8% PG&E, 2009a

a Based on exhibit D of the application, we assumed the energy values reflect a

capacity component.

4.1.2 Current Annual Costs and Future Capital Costs under the No-Action

Alternative

Total annualized cost for the no-action alternative for the McCloud-Pit Project

amounts to $23,102,000 as table 4-2 shows.
343

Table 4-2. Summary of current annual costs and future costs under the no-action

alternative for the McCloud-Pit Project. (Source: PG&E, 2009a, staff)

Cost

Capital and

One-Time

Cost

Annual Cost,

Including O&M

Total Annualized

Cost

Total original net

investment a $44,700,000 $7,667,000

Total relicensing cost a$26,400,000 $4,528,000

Subtotal $71,100,000 $12,195,000

O&M including insurance $4,853,000 $4,853,000

Taxes and fees $1,674,000 $1,674,000

Commission fees $880,000 $880,000

Future capital additions a$3,500,000 $3,500,000

Subtotal annual costs $10,907,000 $10,907,000

Total $71,100,000 $23,102,000

a

PG&E (2009a) exhibit D, page D-3, table D.4.3–1

4.2 COMPARISON OF ALTERNATIVES

Table 4-3 compares the power values, annual costs, and net benefits of the noaction alternative, PG&E’s proposed action, the staff alternative, and the staff alternative

with mandatory conditions. In section 5, Staff’s Conclusions, we discuss our reasons for

recommending the staff alternative, and explain why we conclude the environmental

benefits are worth the cost increases and benefit reductions.
344

Table 4-3. Summary of annual net benefits for the no-action alternative, proposed

action, staff alternative, and staff alternative with mandatory conditions for

the McCloud-Pit Project. (Source: Staff)

No Action

PG&E’s

Proposed

Action

Staff

Alternative

Staff

Alternative

With

Mandatory

Conditions

Annual power value

($)a $134,943,000 $133,376,000 $131,443,000 $131,443,000

Annual power value

($/MWh) $87.50 $87.50 $87.50 $87.50

Annualized cost of

plant and current

environmental

measures ($)

$23,102,000 $23,102,000 $23,102,000 $23,102,000

Annualized cost of

new environmental

measures (including

energy losses

contained in the

power values above)

($)

$0 $11,756,000 $14,349,000 $14,964,000

Annualized cost of

new environmental

measures (excluding

energy losses

contained in the

power values above)

($)

$0 $10,189,000 $10,849,000 $11,464,000

Annual cost ($) $23,102,000 $33,291,000 $33,951,000 $34,566,000

Annual cost ($/MWh) $14.98 $21.84 $22.60 $23.01

Annual net benefit ($) $111,841,000 $100,085,000 $97,492,000 $96,877,000

Annual net benefit

($/MWh) $72.52 $65.66 $64.90 $64.49

aDevelopmental analysis is based on an average energy value published by the California

Public Utilities Commission.
345

4.2.1 No-Action Alternative

PG&E provided an estimate of average annual output of the project under the noaction alternative (current conditions) of 1,542.2 GWh, which would provide an annual

power benefit of $134,943,000. Subtracting the current cost of $23,102,000 (see table 4-

2) yields an annual net benefit of $111,841,000.

4.2.2 PG&E’s Proposed Action

The measures that PG&E proposes, summarized in table 4-4, increase the

annualized cost from $23,102,000 to $33,291,000 relative to the no-action alternative.

PG&E proposes some operational changes which would reduce annual generation by

17.9 GWh, resulting in an annual power benefit of $133,376,000 and an annual net

benefit of $100,085,000. This equals an overall reduction in annual net benefit of

$11,756,000 relative to the no-action alternative. The decrease in net benefit from

$72.52/MWh under the no-action alternative to $65.66/MWh for the proposed action

represents a decrease of 9.5 percent.

4.2.3 Staff Alternative

The measures included in the staff alternative, summarized in table 4-4, would

increase annualized cost from $23,102,000 to $33,951,000 relative to the no-action

alternative. Operational changes would reduce annual generation from 1,542,200 MWh

to 1,502,200 MWh. The staff alternative would provide an annual power benefit of

$131,443,000 and an annual net benefit of $97,492,000. This represents an overall

reduction in annual net benefit of $14,349,000 relative to the no-action alternative. The

decrease in net benefit from $72.52/MWh under the no-action alternative to $64.90/MWh

for the staff alternative represents a decrease of 10.5 percent.

4.2.4 Staff Alternative with Mandatory Conditions

The measures included in the staff alternative with mandatory conditions,

summarized in table 4-4, would increase annualized cost from $23,102,000 to

$34,566,000 relative to the no-action alternative. Operational changes would reduce

annual generation from 1,542,200 MWh to 1,502,200 MWh. The staff alternative with

mandatory conditions would provide an annual power benefit of $131,443,000 and an

annual net benefit of $96,877,000. This represents an overall reduction in annual net

benefit of $14,964,000 relative to the no-action alternative. The decrease in net benefit

from $72.52/MWh under the no-action alternative to $64.49/MWh for the staff

alternative with mandatory conditions represents a decrease of 11.1 percent.
346

4.3 COST OF ENVIRONMENTAL MEASURES

4.3.1 Cost of Environmental Measures for the McCloud-Pit Project

PG&E provided costs for environmental measures in current dollars. Costs are

taken from the final license application filed in 2009, and the PG&E reply comments on

comments, recommendations, terms, and conditions (PG&E, 2010a). Table 4-4

summarizes the capital and O&M costs by major resource area. Proposed environmental

measures that are directly associated with the proposed powerhouses at McCloud dam

and Pit 7 afterbay are included separately in table 4-5. Changes in power benefits are

addressed in section 4.2, Comparison of Alternatives.

Appendix C includes capital and O&M costs for individual measures proposed by

PG&E and included in terms, conditions, and recommendations received from agencies

and other interested parties.
347

Table 4-4. Summary of annualized costs by resource area for measures included in the proposed action, staff alternative,

and staff alternative with mandatory conditions for the McCloud-Pit Project.a(Source: Staff)

PG&E’s Proposed Action Staff Alternative Staff Alternative with Mandatory

Conditions

Resource

Area

Annualized

Capital

Cost

Annualized

O&M Cost

Total

Annualized

Cost

(excluding

energy)

Annualized

Capital

Cost

Annualized

O&M Cost

Total

Annualized

Cost

(excluding

energy)

Annualized

Capital

Cost

Annualized

O&M Cost

Total

Annualized

Cost

(excluding

energy)

General $0 $90,000 $90,000 $0 $90,000 $90,000 $0 $90,000 $90,000

Geology

and soils $219,000 $115,000 $334,000 $223,000 $190,000 $413,000 $223,000 $190,000 $413,000

Aquatic

resources

$24,000 $70,000 $94,000 $168,000 $356,000 $524,000 $168,000 $358,000 $526,000

Terrestrial

resources

$116,000 $562,000 $678,000 $110,000 $495,000 $605,000 $110,000 $495,000 $605,000

Threatened

and

endangered

species

$0 $0 $0 $0 $0 $0 $0 $0 $0

Recreation

resources

$3,432,000 $1,060,000 $4,492,000 $3,860,000 $1,098,000 $4,958,000 $3,885,000 $1,423,000 $5,308,000

Cultural

resources

$84,000 $200,000 $284,000 $84,000 $200,000 $284,000 $84,000 $200,000 $284,000

Land use

and

aesthetic

resources

$2,952,000 $1,265,000 $4,217,000 $2,973,000 $1,002,000 $3,975,000 $2,973,000 $1,265,000 $4,238,000

Total $6,827,000 $3,362,000 $10,189,000 $7,418,000 $3,431,000 $10,849,000 $7,443,000 $4,021,000 $11,464,000

a

This summary does not include mitigation measures that are directly associated with the construction of a proposed

powerhouse.
348

Table 4-5. Summary of annualized costs by resource area for measures directly associated with construction of proposed

powerhouses under the proposed action, staff alternative, and staff alternative with mandatory conditions for

the McCloud-Pit Project. (Source: Staff)

PG&E’s Proposed Action Staff Alternative Staff Alternative with Mandatory

Conditions

Resource

Area

Annualized

Capital

Cost

Annualized

O&M Cost

Total

Annualized

Cost

(excluding

energy)

Annualized

Capital

Cost

Annualized

O&M Cost

Total

Annualized

Cost

(excluding

energy)

Annualized

Capital

Cost

Annualized

O&M Cost

Total

Annualized

Cost

(excluding

energy)

General $31,000 $17,000 $48,000 $31,000 $17,000 $48,000 $31,000 $17,000 $48,000

Geology

and soils $0 $0 $0 $0 $0 $0 $0 $0 $0

Aquatic

resources

$0 $0 $0 $0 $0 $0 $0 $0 $0

Terrestrial

resources

$59,000 $287,000 $346,000 $59,000 $287,000 $346,000 $59,000 $287,000 $346,000

Threatened

and

endangered

species

$0 $0 $0 $0 $0 $0 $0 $0 $0

Recreation

resources

$27,000 $11,000 $38,000 $27,000 $11,000 $38,000 $27,000 $11,000 $38,000

Cultural

resources

$0 $0 $0 $0 $0 $0 $0 $0 $0

Land use

and

aesthetic

resources

$0 $0 $0 $0 $0 $0 $0 $0 $0

Total $117,000 $315,000 $432,000 $117,000 $315,000 $432,000 $117,000 $315,000 $432,000
349

4.3.2 Effect of Environmental Measures on Energy Generation

Several measures proposed by PG&E or included in the terms and conditions filed

by the agencies and other parties would affect energy generation. For the McCloud-Pit

Project, increased minimum flows proposed for the McCloud River reaches are the only

measures that would have a substantive effect on energy generation. Estimates of the

power benefits under PG&E’s proposed action, the staff alternative (which includes

Forest Service condition 19 flows), and the staff alternative with mandatory conditions

are shown in table 4-6.

Table 4-6. Summary of the effect of environmental measures on energy for the noaction alternative, proposed action, staff alternative, and staff alternative

with mandatory conditions for the McCloud-Pit Project. (Source: Staff)

No Action

PG&E’s

Proposed

Action

Staff

Alternative

Staff

Alternative

With

Mandatory

Conditions

Total power (MWh) 1,542,200 1,524,300 1,502,200 1,502,200

Total power value ($) $134,943,000 $133,376,000 $131,443,000 $131,443,000

Power lost relative to no

action (MWh) 0 17,900 40,000 40,000

Reduction in power value

relative to no action ($) $0 $1,566,000 $3,500,000 $3,500,000

4.4 COMPARISON OF ALTERNATIVES FOR PG&E’S PROPOSED

POWERHOUSES

To develop the hydro potential from higher instream flows required in a new

license, PG&E proposes to install new powerhouses at both the Pit 7 afterbay and the

McCloud dam. For the Pit 7 afterbay, PG&E estimates a 5-MW powerhouse would

produce 25 GWh annually and a 10-MW powerhouse would produce 50 GWh annually.

For the McCloud dam, installing a 5-MW powerhouse would produce 30 GWh annually

and installing an 8-MW powerhouse would produce 40 GWh annually. In the license

application, PG&E says it will determine the final size of the units and their hydraulic

capacities based on instream flow requirements of the new project license. In table 4-7,

we compare our estimates of the power values, annual costs, and net benefits of the

powerhouse alternatives PG&E presents in the license application.
350

Table 4-7. Summary of annual net benefits for the proposed powerhouses of the

McCloud-Pit Project. (Source: Staff)

Pit 7 Afterbay

5 MW

Pit 7 Afterbay

10 MW

McCloud

Dam

5 MW

McCloud

Dam

8 MW

Annual power value ($) $2,188,000 $4,410,000 $2,625,000 $3,500,000

Annual power value

($/MWh) $87.50 $87.50 $87.50 $87.50

Annualized cost of

plant and environmental

measures ($)

$12,278,000 $17,671,000 $6,792,000 $8,999,000

Annual cost ($/MWh) $491.12 $350.62 $226.41 $224.96

Annual net benefit ($) ($10,090,000) ($13,261,000) ($4,167,000) ($5,499,000)

Annual net benefit

($/MWh) ($403.62) ($263.12) ($138.91) ($137.46)

As table 4-7 shows, the four alternatives that PG&E is considering would have

initial annual costs that far exceed the current power value. Although Commission staff

do not explicitly account for the effects inflation may have on the future cost of

electricity, the fact that hydropower generation is relatively insensitive to inflation

compared to fossil-fueled generators is an important economic consideration for power

producers and the consumers they serve. PG&E must also consider whether these hydro

proposals would qualify as part of its state requirement to develop renewable resources.

Based on the Commission’s policy under the Mead decision, it is the applicant who must

decide whether to accept any license and the financial risk that entails.
351

5.0 STAFF’S CONCLUSIONS

5.1 COMPARISON OF EFFECTS OF PROPOSED ACTION AND

ALTERNATIVES

In this section, we compare the developmental and non-developmental effects of

PG&E’s proposal, PG&E’s proposal as modified by staff (staff alternative), and the noaction alternative.

We estimate the annual net benefits of operating and maintaining the McCloud-Pit

Project under the three alternatives identified above. Our analysis shows that the annual

net benefit would be $100,085,000 for the proposed action; $97,492,000 for the staff

alternative; and $111,841,000 for the no-action alternative.

We summarize the environmental effects of the different alternatives in table 5-1.

Table 5-1. Comparison of alternatives for the McCloud-Pit Hydroelectric Project.

(Source: Staff)

Resource No-Action

Alternative Proposed Action Staff Alternative

Generation 1,542.2 GWh 1,524.3 GWh 1,502.2 GWh

Geology and

Soils

Continued removal of

LWD behind McCloud

dam

Prepare an LWD

Management Plan to

facilitate the placing of

LWD downstream of

McCloud dam

Same as proposed

action

Continue to maintain

roadways and

implement BMPs to

reduce sediment input

to project waters

Implement Erosion

and Sediment

Monitoring and

Control Plan to

minimize erosion

Same as proposed

action
352

Resource No-Action

Alternative Proposed Action Staff Alternative

Monitor gravel and

coarse sediment that

could benefit

downstream aquatic

habitat

The proposed action

plus implement a

Gravel and Coarse

Sediment Management

Plan to add 150 to

600 tonnes of gravel

and coarse sediment,

from Star City Creek

or other potential sites,

to the Lower McCloud

River periodically for

protection of geology

and soil resources

Aquatic

Resources

Provide existing

minimum flows in all

stream reaches

Higher minimum

instream flows below

McCloud and Iron

Canyon dams

Higher minimum

instream flows below

McCloud and Iron

Canyon dams

consistent with a more

natural spring

hydrograph
353

Resource No-Action

Alternative Proposed Action Staff Alternative

No ramping rates for

seasonal minimum

flow changes, but

upramping at 100 cfs

per hour prior to

uncontrollable spills at

McCloud dam

Upramping at 100 cfs

per hour prior to

uncontrollable spills at

McCloud dam

Downramping at

150 cfs each 48 hours

at McCloud dam

during spills

controllable by valve

Maximum upramping

during controllable

spills at 200 cfs each

24 hours at McCloud

dam

Upramping and

downramping related

to testing of the flow

valve at Iron Canyon

dam in 20-cfs

increments

Move streamflow

measurements for

McCloud dam from

gage MC-1 to MC-7

Measure streamflow

compliance at two

compliance points

(MC-7 and MC-1)

No Aquatic Biological

Monitoring Plan

Implement an Aquatic

Biological Monitoring

Plan

Implement water

quality monitoring

plan

Same as proposed

action

File annual reports on

the reintroduction and

status of listed

salmonids in the

project area.
354

Resource No-Action

Alternative Proposed Action Staff Alternative

Terrestrial

Resources

Continue to implement

vegetation

management programs

around project

facilities

Implement Vegetation

Management Plan to

guide restoration using

native plants and

manage invasive plants

Implement BMPs to

protect wetlands

during construction of

McCloud transmission

line

Use native vegetation

during restoration of

areas disturbed by

project-related

activities

Implement a

Vegetation

Management Plan as

proposed under Forest

Service condition 25

with modifications to

include provision of

information to

managers regarding

sensitive species,

protection of culturally

significant plant

populations,

provisions for the use

of herbicides and

pesticides, and

implementation of

BMPs to protect

wetlands

Monitor bald eagle

territories

Implement Wildlife

Management Plan

Implement a

Terrestrial Biological

Management Plan as

proposed under Forest

Service condition 26

with modifications to

include monitoring

schedules and limited

operating periods

Prepare biological

evaluations for special

status species and

biological assessments

for threatened and

endangered species

prior to new

construction within the

project boundary
355

Resource No-Action

Alternative Proposed Action Staff Alternative

Implement APLIC

standards for

transmission lines to

minimize avian

collision and

electrocution hazards

Same as proposed

action

Threatened

and

Endangered

Species

Implement VELB

Conservation Program

Same as no-action plus

conduct preconstruction surveys

for Pacific fisher and

to minimize effects on

northern spotted owl

Same as proposed

action

Recreation

Resources

Fund California Fish

and Game trout

stocking program

Continue funding to

California Fish and

Game for stocking

trout annually and to

evaluate fish stocking

program

Stock 60,000 pounds

of trout annually at the

project and develop

and implement a fish

stocking plan to

evaluate stocking

success at the project

Continue to operate

and maintain existing

recreational facilities

at the project

Develop and

implement Recreation

Development and

Management Plan to

include rehabilitation

and upgrades to

existing recreation

facilities, reservoir

water surface

management,

recreation monitoring,

and a Signage and

Education Plan,

providing streamflow

information to the

public via the internet

Same as proposed

action but include

posting of streamflow

data at MC-7 on the

internet in addition to

MC-1, consultation

with American

Whitewater and

Friends of the River
356

Resource No-Action

Alternative Proposed Action Staff Alternative

Construct new day-use

area, reconstruct and

extend existing boat

ramp, and add parking

at Tarantula Gulch

Same as proposed

action but add lighting

at Tarantula Gulch

boat ramp

Provide a formal dayuse area and

campground at

McCloud reservoir at

Star City

Same as proposed

action

Conduct a feasibility

study to find a suitable

location for a floating

dock or pier and trail

at McCloud reservoir

and construct if

feasible

Same as proposed

action

Construct day-use

areas at McCloud

reservoir at Red Banks

and Tarantula Gulch

inlet

Same as proposed

action

Construct three access

points to McCloud

reservoir at Battle

Creek and on each side

of McCloud dam

Same as proposed

action

At McCloud and Iron

Canyon reservoirs,

assess and implement

closures of usercreated roads leading

to the shoreline of

McCloud and Iron

Canyon reservoirs, in

coordination with the

Forest Service

Same as proposed

action with inclusion

of trails and dispersed

use sites in the

assessment and

closures; expand to

include area inside

project boundary at

both McCloud and

Iron Canyon reservoirs
357

Resource No-Action

Alternative Proposed Action Staff Alternative

Construct a day-use

site and access trail

along the Lower

McCloud River, at the

base of McCloud dam

Same as proposed

action

Reconstruct Hawkins

Landing boat ramp and

campground and

provide additional

parking, restroom

facilities

Same as proposed

action

Conduct a site

evaluation and provide

three paved parking

areas along FR37N78

with shoreline access

points to Iron Canyon

reservoir

Same as proposed

action

Construct new boat

ramp and shoreline

access at Iron Canyon

reservoir

Same as proposed

action with the

inclusion of adding

lighting at the boat

ramp

Relocate (if feasible)

or reconstruct Deadlun

Campground if a

suitable location is

found

Reconstruct Deadlun

Campground to

provide double and

triple sites and

construct new

campground at Gap

Creek for single unit

campsites

Remove snow at Iron

Canyon dam boat

ramp and access road

when project

operations require

snow removal from

Oak Mountain Road

Same as proposed

action
358

Resource No-Action

Alternative Proposed Action Staff Alternative

Evaluate the feasibility

of constructing a

pedestrian shoreline

access trail at the

upper end of Pit 7

reservoir, downstream

of Pit 6 powerhouse

tailrace, and construct

if suitable location

found

Construct the

shoreline access trail

Conduct feasibility

assessment for

providing boat put-in

or boat hand- launch at

Montgomery Creek,

near the lower end of

Pit 7 reservoir, if not

feasible construct a

fishing access trail

with boat hand-launch

Conduct a site

evaluation to

determine the location

of a pedestrian

shoreline access trail

at the lower end of Pit

7 reservoir with paved

parking and construct

this facility

Reconstruct Fenders

Flat day-use area

(above Pit 7 afterbay

dam) and boat ramp

Same as proposed

action
359

Resource No-Action

Alternative Proposed Action Staff Alternative

If the Pit 7 afterbay

powerhouse is

constructed, provide

access near the

proposed Pit 7 afterbay

powerhouse, and

provide parking at the

end of the powerhouse

access road or along

Fenders Ferry Road

Same as proposed

action

Develop and

implement Project

Patrol Plan to provide

project patrols

No requirement for

Project Patrol Plan,

patrols, or funding for

law enforcement

position

Cultural

Resources

Implement a final

HPMP

Implement the final

HPMP upon license

issuance

Continue employee

environmental training

and sensitivity

program

Continue employee

environmental training

and sensitivity

program as part of the

HPMP

Same as proposed

action

Provide program to

educate public about

cultural significance of

area (with assistance

from Pit River Tribe,

Winnemem Wintu

Tribe, and Forest

Service)

Same as proposed

action

Land Use

and

Aesthetics

Continue to maintain

all project roads and

facilities

Develop and

implement a Road and

Transportation Facility

Management Plan for

project roads

Same as proposed

action plus revise

project boundary to

include all project

roads and existing

recreational facilities
360

Resource No-Action

Alternative Proposed Action Staff Alternative

Execute a separate

MOU with the Forest

Service for areas with

shared responsibility

Outside of licensing

proceeding

Continue to implement

the Spill Prevention,

Control, and

Countermeasures Plan

and the Hazardous

Materials Business

Plan

Same as no-action Same as no-action, but

file existing Spill

Prevention, Control,

and Countermeasures

Plan and Hazardous

Materials Business

Plan with the

Commission

Identify specific visual

quality mitigation

measures and develop

an implementation

schedule

Same as proposed

action

Develop and

implement a Fire

Response Plan

Same as proposed

action

Under the no-action alternative, environmental conditions would remain the same

and no enhancement of environmental resources would occur.

5.2 COMPREHENSIVE DEVELOPMENT AND RECOMMENDED

ALTERNATIVE

Sections 4(e) and 10(a)(1) of the FPA require the Commission to give equal

consideration to the power development purposes and to the purposes of energy

conservation; the protection, mitigation of damage to, and enhancement of fish and

wildlife; the protection of recreation opportunities; and the preservation of other aspects

of environmental quality. Any license issued shall be such as in the Commission’s

judgment will be best adapted to a comprehensive plan for improving or developing a

waterway or waterways for all beneficial public uses. This section contains the basis for,

and a summary of, our recommendations for relicensing the McCloud-Pit Project. We

weigh the costs and benefits of our recommended alternative against other proposed

measures.
361

Based on our independent review of agency and public comments filed on this

project and our review of the environmental and economic effects of the proposed action,

the staff alternative, and no action, we recommend the staff alternative as the preferred

alternative for the McCloud-Pit Project.

We recommend this alternative because: (1) issuing a new license would allow

PG&E to continue operating the project as a beneficial, dependable source of water and

electric energy; (2) the project, with a total installed capacity of 368 MW may eliminate

the need for an equivalent amount of fossil fuel-produced energy, which helps conserve

these non-renewable resources and limits atmospheric pollution; (3) our recommended

environmental measures would protect water quality and quantity, enhance fish and

wildlife resources, protect cultural resources, and improve public use of the project’s

recreational facilities and resources; and (4) the public benefit of these measures would

exceed those of the other alternatives. Although we did not adopt all of the Forest

Service’s 4(e) conditions, or adopted them with modifications, we recognize that the

Commission must include these conditions in their entirety, without modification in any

license it may issue, due to their mandatory nature.

In the staff alternative, we include the following environmental measures proposed

by PG&E, based on our analyses included in sections 3.0, Environmental Analysis, and

4.0, Developmental Analysis. In some cases, we modified or supplemented PG&E’s

proposed measures and these modifications are indicated in italic text.

Geology and Soils

 Prepare an LWD Management Plan.

 Prepare an Erosion and Sediment Monitoring and Control Plan.

Aquatic Resources

 Continue to implement the current minimum flow release schedule for the Pit 7

afterbay reach.

 Implement upramping rates of no more than 100 cfs per hour prior to the start

of an uncontrolled spill event at McCloud dam.

 Develop and implement a water quality monitoring plan.

Recreation Resources

 Develop and implement a Recreation Development and Management Plan that

would include: location, conceptual designs, and schedules for upgrading

existing recreation facilities and constructing new recreation facilities,

including the reevaluation of the facilities for degradation at mid-license term

or 25 years, whichever is greater; plans using the Forest Service design

standards (including applicable standards for providing access to users with

disabilities); and details regarding O&M activities at all recreation facilities
362

including existing and new project recreation facilities. The plan also should

incorporate the following components:

o A Project Sign Plan that includes an interpretive and education component;

o Monitoring, visitor surveys, and use estimation with report concurrent with

the recreation Form 80 reporting. This measure also should include details

addressing collection of annual use data at facilities where passes/fees are

collected; consultation with the Forest Service on the survey methods for

the Recreational Resource Survey; and consultation every 6 years

(concurrent with the recreation Form 80) with the Forest Service,

appropriate agencies, and interested parties to review and adjust projectwide recreation management objective, if needed; and

o A water surface management plan to manage reservoir use at McCloud

reservoir. This plan component would include installing speed limit signs

in the northern end of the reservoir, LWD removal from the reservoir,

points of public access to the shoreline, and boating speeds. This measure

would also include details addressing monitoring and management of

recreation user safety, including developing protocols for all project

reservoirs for preventing/removing unapproved buoy courses, approved use

of docks, and measures to prevent unauthorized access to project lands and

waters; annual surface sweeps of McCloud and Iron Canyon reservoirs and

boat ramps to remove logs and other debris; monitoring boat use on

McCloud and Iron Canyon reservoirs every 6 years coinciding with the

recreation Form 80 schedule; and reassessing water surface management

mitigations every 6 years.

 Provide real-time streamflow (gages MC-1 and MC-7) and drawdown

information to the public via PG&E’s website on the internet.

 At McCloud and Iron Canyon reservoirs, assess and implement closures of

user-created roads, trails, and dispersed use sites leading to the shoreline of

McCloud and Iron Canyon reservoirs, in coordination with the Forest Service.

McCloud Reservoir

 Within 5 years of Commission approval of the Recreation Plan, reconstruct the

Tarantula Gulch boat ramp to California Boating standards with one lane ramp,

provide a boarding dock, and extend the launch ramp to 3 feet (vertical) below

the minimum operating pool elevation, including redesigning the parking lot to

maximize parking spaces and a day-use area.

 Within 5 years of Commission approval of the Recreation Plan, provide access

points (paved parking and shoreline access trail) at Battle Creek, West dam,

and East dam.
363

 Within 5 years of Commission approval of the Recreation Plan, provide dayuse areas at Red Banks and the intersection of Tarantula Gulch access road and

FR 11.

 Within 5 years of Commission approval of the Recreation Plan, develop a

formal campground and day-use area at Star City with walk-in sites (estimate

six sites), paved parking, vault restroom, potable water, tables, fire rings/grills,

trash receptacles/removal, and host site.

 Conduct a feasibility study to find a suitable location for a floating dock or pier

and trail at McCloud reservoir and construct the facilities if feasible.

Lower McCloud River

 Within 5 years of Commission approval of the Recreation Plan, provide a dayuse facility at the base of McCloud dam and provide parking, vault restroom,

trash receptacle/removal, and shoreline pedestrian access trail on river left to

the pool below the spillway. This measure is modified to recommend that the

trail accommodate fishing and boating access and to include an access road.

Iron Canyon Reservoir

 Within 5 years of Commission approval of the Recreation Plan, reconstruct

Hawkins Landing Campground to the Forest Service standards and provide

potable water and reconstruct or resurface the access road to allow all-season

use.

 Within 5 years of Commission approval of the Recreation Plan, retain concrete

ramp surface at Hawkins Landing Boat Launch and replace or repair the

surfacing that connects to the concrete ramp. This measure is modified to

include specifications for reconstruction of boat ramp surface (length and

width, but not grade) to meet California Boating standards for one lane, and

for construction of a parking area.

 Within 5 years of Commission approval of the Recreation Plan, reconstruct

Deadlun Campground to the Forest Service standards and increase capacity by

about 10 sites to provide about 37 sites and provide potable water a shoreline

access trail. This measure is modified to specify that the campground be

reconstructed to accommodate double and triple campsites.

 Within 5 years of Commission approval of the Recreation Plan, construct a

new boat launch at the east end of Iron Canyon dam that meets California

Boating standards and provide vault restroom, picnic tables, potable water, and

trash receptacles/removal. This measure is modified to recommend that the

boat ramp be operable at minimum operating pool, and that snow be removed

from the parking area and ramp when project operations require snow

removal from Oak Mountain Road.
364

 Conduct a site evaluation to determine the location of three paved parking

areas along FR 37N78, each with a capacity of up to three vehicle parking

spaces and a pedestrian shoreline access trail. This measure is modified to

specify that once three suitable locations are identified, design and construct

these project facilities.

 Allow public use of at least one campground year-round. This measure is

modified to specify that a schedule for implementation would be included in the

Recreation Plan.

Pit 7 Reservoir

 Conduct a site evaluation to determine the location of a pedestrian shoreline

access trail at the upper end of Pit 7 reservoir, downstream of Pit 6 powerhouse

tailrace. This measure is modified to include consultation with the Forest

Service, and once a suitable location is found, constructing this facility within

5 years of Commission approval of the Recreation Plan. The facility would

include a trailhead, parking for up to three vehicles, and hand-launch boating

access.

Pit 7 Afterbay

 Within 2 years of Commission approval of the Recreation Plan, grade and

maintain FR 35N66 from its intersection with FR 37N78 to the car-top boat

launch. Provide a vault restroom near the car-top boat launch.

 Continue to prohibit public access to Pit 7 afterbay water surface and shoreline

by maintaining fencing, signage, and patrols.

 If the Pit 7 afterbay powerhouse is constructed, provide a paved parking area

for two to three vehicles at the end of the powerhouse access road or along

Fenders Ferry Road and provide a vault restroom, trash receptacle/removal,

and pedestrian access to the shoreline between the powerhouse and Fenders

Ferry Bridge. This measure is modified to condition the day-use area on

public safety and homeland security needs.

 Within 5 years of Commission approval of the Recreation Plan, provide a dayuse site at Fenders Flat with a capacity of five sites, parking, vault restroom,

tables, fire grills, and trash receptacles/removal, and coordinate with the Forest

Service to develop and implement a plan to revegetate disturbed areas and

prevent vehicle access beyond the access road and parking area.

Land Use and Aesthetic Resources

 Develop, file, and implement, within 1 year of license issuance, a Road and

Transportation Facilities Management Plan for all project roads.

 Develop, file, and implement, within 1 year of license issuance, a Fire

Prevention and Response Plan.
365

 Include all existing project roads and recreation sites within the project

boundary and file a revised exhibit G with the Commission within 1 year of

license issuance.

 Develop, file, and implement, within 1 year of license issuance, visual quality

management tasks and a timeline.

Additional Measures Identified by Staff

In addition to PG&E’s proposed measures listed above (and modified as

indicated), the staff alternative also includes the following additional measures identified

by staff based on agency, tribal, and non-governmental organization specifications,

recommendations, and our analysis.

Geology and Soils

 Within 12 months of license issuance, develop and implement a Gravel and

Coarse Sediment Management Plan in consultation with agencies and

approved by the Forest Service. Employ an adaptive management approach to

monitoring with Bald Mountain Creek confluence serving as the downstream

terminus for the monitoring program, and augment gravel and coarse sediment

periodically. Evaluate Star City Creek as a primary source of gravel, and

evaluate other potential alternate local sites, such as Tarantula Gulch delta in

the development of the Coarse Sediment Management Plan.

Aquatic Resources

 Within 90 days of license issuance, release mean daily flows of at least 175 cfs

year round from the McCloud dam (as measured at MC-7) such that the mean

daily flow at Ah-Di-Na (MC-1) is at least 200 cfs. Augment flows during the

period February 15 through August 31 as follows:

Month Lower McCloud River Flows (cfs) by Water Yeara

February 15-29 0-75% ROb No flow change

76-89% ROb No flow change

90-99% RObIncrease flow by 75 cfs

100-119% RObIncrease flow by 125 cfs

≥120% RObIncrease flow by 175 cfs

March 1-15 0-75% ROb No flow change

76-89% RObIncrease flow by 50 cfs

90-99% RObIncrease flow by 50 cfs

100-119% RObIncrease flow by 100 cfs

≥120% RObIncrease flow by 150 cfs
366

Month Lower McCloud River Flows (cfs) by Water Yeara

March 16-31 0-75% ROc No flow change

76-89% ROc No flow change

90-99% ROcIncrease flow by 50 cfs

100-119% ROcIncrease flow by 50 cfs

≥120% ROcIncrease flow by 150 cfs

April 1-15 0-75% ROc No flow change

76-89% ROc No flow change

90-99% ROc No flow change

100-119% ROcIncrease flow by 50 cfs

≥120% ROcIncrease flow by 50 cfs

If the release from McCloud dam (MC-7) on April 15 is equal to or greater than 200

cfs:

On each Friday after April 15, decrease the flow by 50 cfs per week until the flow reaches

200 cfs, then maintain 200 cfs release at McCloud dam (MC-7) through June 30

July 1 through August 31: release 175 cfs at MC-7, but maintain at least 215 cfs at Ah-DiNa (MC-1)

Beginning September 1: Release 175 cfs at MC-7, but maintain at least 200 cfs at Ah-Di-Na

(MC-1)

If the release from McCloud dam (MC-7) on April 15 is less than 200 cfs:

Beginning April 16: Release 175 cfs at MC-7, but maintain at least 200 cfs at Ah-Di-Na

(MC-1).

a Using most recent California Department of Water Resources Sacramento

Valley Water Year Type Index forecast

b

February 1 runoff percentage from DWR Bulletin 120 for McCloud River

above Shasta Lake

c March 1 runoff percentage from DWR Bulletin 120 for McCloud River above

Shasta Lake.
367

 Implement a minimum flow release schedule for the Iron Canyon dam reach,

as follows:

Release from Iron Canyon Dam (cfs) by Water Year-type

Month Wet Above Normal

Below Normal, Dry,

Critically Dry

October 10 7 7

November 10 7 7

December 15 10 7

January 15 10 7

February 15 10 7

March >20a15 10

April >20a15 10

May 15 10 7

June 15 10 7

July 10 7 7

August 10 7 7

September 10 7 7

a

In March and April of wet water years, the flow control vale on Iron

Canyon dam shall be fully opened. Mean daily flow shall be at least 20 cfs

during this period.

 Downramp all spill events controllable at McCloud dam by valve operation at

a maximum rate of 150 cfs per 48 hour until the prescribed minimum instream

flow value is reached and upramp operational controllable spills at McCloud

dam at a maximum rate of 200 cfs per 24-hour period.

 Determine water year type based on the forecast of unimpaired runoff of the

McCloud River above Shasta Lake as provided by DWR Bulletin 120 or its

successor.

 Operate, maintain, and modify (if necessary) gages needed to determine river

stage and minimum streamflow; measure and document all instream flow

releases in publicly available formats.

 Develop and implement an Aquatic Biological Monitoring Plan, as specified

by Forest Service condition 27, for fish, benthic macroinvertebrates, special

status aquatic mollusks, other special status species, and invasive aquatic

species, with the inclusion of monitoring schedules specific to each component

of the plan. The special status species section of the Aquatic Biological
368

Monitoring Plan also should incorporate a monitoring plan for northwestern

pond turtles and foothill yellow-legged frogs. The number of sites, site

locations, sampling methods, and data protocols should be consistent with

relicensing studies.

 File an annual report on the reintroduction and status of listed anadromous

species in the project area. The report should detail the steps that have been

taken in the reintroduction, a status of the findings and actions of the

Interagency Fish Passage Steering Committee, and should include the

comments of NMFS.

Terrestrial Resources and Threatened and Endangered Species

 Implement a Vegetation and Invasive Weed Management Plan, as specified by

Forest Service condition 25, with modifications to include provision of

information to managers regarding sensitive species, protection of culturally

significant plant populations, provisions for the use of herbicides and

pesticides, and implementation of BMPs to minimize effects on wetlands.

 Implement a Terrestrial Biological Management Plan, as specified by Forest

Service condition 26, with the inclusion of species-specific monitoring

modifications and limited operating periods. Prepare biological evaluations for

special status species and biological assessments for threatened and

endangered species prior to construction.

Recreation Resources

 Stock 60,000 pounds of trout annually at the project, develop (for Commission

approval) and implement a fish stocking plan in consultation with California

Fish and Game within 1 year of license issuance, and evaluate and monitor the

amount of fish to be stocked every 6 years.

 Provide lighting at both the Tarantula Gulch and Iron Canyon boat launches.

 Conduct a site evaluation to determine the location of a pedestrian shoreline

access trail at the lower end of Pit 7 reservoir, with paved parking. Once a

suitable location is found, construct this facility within 5 years of Commission

approval of the Recreation Plan.

Cultural Resources

 Implement the final HPMP (PG&E, 2010b) upon license issuance.

Land Use and Aesthetic Resources

 File copies of the existing Spill Prevention, Control, and Countermeasures Plan

and Hazardous Materials Business Plan with the Commission and provide

copies to the Forest Service and the Central Valley Regional Water Board

within 30 days of license issuance and continue to implement these plans.
369

5.2.1 Discussion of Key Issues

The following paragraphs describe the basis for staff-recommended measures as

well as for not recommending measures recommended by other entities. Under each

major issue, we discuss our recommendations for the McCloud-Pit Project.

Geology and Soils

Large Woody Debris

LWD in the project streams functions primarily as: (1) aquatic habitat along the

channel margins; (2) riparian habitat where it rafts up onto surfaces above the low-flow

channel; and (3) in rare cases, as aquatic habitat where wood is retained in the active

portion of side channels. As LWD breaks apart and decays, it may also increase the

supply of organic material to the river channel, benefiting benthic macroinvertebrates and

other components of the aquatic food web.

In Iron Canyon Creek, LWD is abundant and project operations appear to have

little or no effect on LWD supply. In the Lower McCloud River, however, the large

channel width, high stream power, and normally low amount of LWD that passes the

McCloud dam limit the availability of downstream LWD. PG&E proposes to prepare an

LWD Management Plan after consultation with the Forest Service. The plan would

provide an operating procedure to facilitate the placing of woody debris downstream of

McCloud dam. The plan would specify size criteria, placement and storage sites, volume

and frequency of placement, and monitoring procedures.

Forest Service condition 21 is consistent with PG&E’s proposal except that it

specifies that monitoring procedures included in the plan should assess mobilization of

LWD from the augmentation site.

We recommend PG&E’s proposal and the Forest Service’s condition 21 to prepare

an LWD Management Plan. Monitoring procedures included in the plan would assess

mobilization of LWD from the augmentation site. This specific monitoring procedure

would provide information necessary to assess the location, timing, and quantity of LWD

appropriate to achieve the stated objectives. We estimate that the annualized cost of this

plan would be $214,000. Because LWD contributes to productive aquatic ecosystems,

is an important component in the formation of complex aquatic habitat units and channel

maintenance, and increasing the amount of LWD in downstream reaches could provide a

substantial benefit to fish habitat and aquatic habitat in general at a reasonable cost, we

recommend adopting this measure.

Erosion and Sediment Control

Fine sediment from reduction of seasonal high flow events, surface erosion,

increased overland flow, and mass wasting as a result of project operations can adversely

affect environmental resources through increased turbidity and degraded spawning

substrate. In order to manage existing erosion and reduce future erosion and sediment

delivery to stream channels, PG&E proposes to prepare an Erosion and Sediment
370

Monitoring and Control Plan within 1 year after license issuance. The plan would guide

management of erosion and sediment control during the term of the new license and

would include the following elements:

 Methods for ongoing inventory of project-related erosion and sedimentation;

 A schedule for periodic monitoring;

 An inventory of erosion sites identified by periodic monitoring;

 Criteria for treating erosion sites;

 Protocols for emergency erosion and sediment control; and

 A process and schedule for reporting monitoring results, including periodic

plan review and revision.

Initial priority would be placed on the 56 sites identified during pre-filing studies,

ranked as having high erosion potential. Sites would be monitored for 5 years to assess

erosion activity and associated causes. Annual monitoring reports would include a Forest

Service-compatible database of erosion sites and detailed site-specific erosion and

sediment control measures where necessary and appropriate.

Forest Service condition 22 supports PG&E’s proposal and specifies that the plan

should provide direction for managing erosion and controlling sediment during the term

of the new license. Furthermore, Forest Service condition 22 specifies that during

planning, and before any new construction or non-routine maintenance projects with the

potential for causing erosion or stream sedimentation on or affecting Forest Service

lands, PG&E should develop site-specific erosion control plans. The plans would include

measures to control erosion, stream sedimentation, dust, and soil mass movement.

We recommend PG&E’s proposal and Forest Service condition 22 for erosion and

sediment control. We estimate that the cost of this plan would be $120,000. Because the

plan would help determine and develop the success of effective erosion and sediment

control procedures, and would protect aquatic habitat, we consider this cost warranted.

Gravel and Coarse Sediment

As a result of project operations and the resultant trapped sediment behind

McCloud dam, the reach from about 5 to 8 kilometers downstream of McCloud dam is

the reach most likely to exhibit degraded habitat through coarsening of the bed surface

and reduction in the frequency and quantity of mobile sediment deposits. Project

operations could result in long-term adverse impacts on aquatic substrate habitat. PG&E

did not propose to augment gravel and coarse sediment in the Lower McCloud River.

Forest Service modified condition 23 specifies that PG&E should develop and

implement a Gravel and Coarse Sediment Management Plan within 1 year of license

acceptance, after consultation with the Forest Service, conditioning agencies, and other

interested parties, and with approval of the Commission and the Forest Service. The plan

would require the periodic addition of 150 to 600 tonnes of gravel and coarse sediment to
371

the Lower McCloud River, with inputs below the McCloud dam spillway. The Forest

Service specifies that PG&E consider using sorted gravel and coarse sediment from

deposits in McCloud reservoir as the source of material for the plan. The plan would also

include a monitoring component for the Lower McCloud River.

California Fish and Game’s 10(j) recommendation 2 recommends that PG&E

prepare a Gravel and Sediment Management Plan requiring the annual addition of 150

tonnes of gravel and sediment to the McCloud River, between the dam spillway and the

confluence with Hawkins Creek. California Fish and Game also recommends that PG&E

consider using the Star City Creek inlet as a material source. As part of the long-term

monitoring component of this plan, California Fish and Game’s recommendation

incorporates amphibians as an indicator species for assessing ecosystem health.

PG&E alternative condition 23 proposed to revise the time to develop the Gravel

and Coarse Sediment Management Plan to 2 years, which PG&E stated would allow for

receipt of license articles from the Commission and collaborative plan development, and

proposes that gravel and coarse sediment introductions occur periodically rather than

annually. PG&E proposed that the source of the coarse sediment be the delta deposit at

the head of the Star City Creek arm of McCloud reservoir, where the coarse sediment

could be excavated “in the dry” and not dredged. PG&E recommended that the

monitoring component of the plan cover the Lower McCloud River between McCloud

dam and Ladybug Creek rather than Bald Mountain Creek, located about 1.5 miles

downstream of Ladybug Creek, as originally specified by the Forest Service.

Given the adverse impacts with regard to gravel and coarse sediment noted above,

we recommend Forest Service modified condition 23, under which PG&E would develop

and implement a Gravel and Coarse Sediment Management Plan, and monitoring and

adaptive management of gravel and coarse sediment augmentation. Periodic gravel

augmentation would provide a more flexible mechanism for determining the volume and

frequency of coarse sediment introduction necessary to maintain aquatic habitat, given

that high spill flows capable of mobilizing sediment occur in about 4 out of 10 years. To

provide more options and greater flexibility in implementing the gravel and coarse

sediment program, we also recommend that alternative sources of material be evaluated,

to identify the volume, physical and chemical characteristics, logistics for collection and

transport of material, and range of costs. While we recommend that Star City Creek be

evaluated as a primary source of gravel, we concur with the Forest Service that PG&E

should also evaluate other potential alternate local sites, such as Tarantula Gulch delta in

the development of the Coarse Sediment Management Plan. We also concur with the

Forest Service’s withdrawal of condition 24, which required PG&E to prepare a reservoir

dredging plan. Reservoir dredging would be unnecessary under Forest Service modified

condition 23, which specifies the sources of coarse gravel would be collected in dry areas

above the waterline. Additionally, reservoir dredging is costly and poses the threat for

additional environmental risks. We find, therefore, that the costs and risks outweigh any

potential environmental benefit, and we do not recommend a dredging plan. Because the

Forest Service and PG&E have worked collaboratively on the draft Coarse Sediment
372

Management Plan and it is substantially complete, we expect that 1 year would be

adequate time to finalize the plan.

As previously indicated, we recommend PG&E employ an adaptive management

approach with monitoring for augmenting gravel and coarse sediments in the Lower

McCloud River as specified by the Forest Service. The monitoring plan would provide

data on progress of the augmentation program and improvements in the gravel substrate

through the reach downstream of the McCloud dam. These data would form the

scientific basis for judgments on the success of the program and adjustments to the source

of material, as well as its timing and placement, which may be necessary to support the

fish and invertebrate community utilizing this reach. We also recommend that Bald

Mountain Creek confluence serve as the downstream terminus for the monitoring

program. Although studies indicate the presence of suitable amounts of gravel and coarse

sediment in the reach between Ladybug Creek and Bald Mountain Creek, we note that

this reach could serve as an important comparative baseline for determining the success

of the proposed augmentation program. Finally, we note that foothill yellow-legged frog

is the only amphibian species in the project area that could benefit from the gravel

augmentation program. However, studies indicate that no foothill yellow-legged frogs

are present in the proposed augmentation reach, and furthermore, the species is excluded

from the reach due to cold water temperatures. Because amphibians are not effective for

assessments of sediment augmentation plan success in the proposed augmentation reach,

we do not recommend that PG&E include such assessments in its monitoring plan.

We consider the development of a Gravel and Coarse Sediment Management Plan

specified by Forest Service condition 23 to represent an effective approach for improving

instream aquatic habitat. We estimate that California Fish and Game’s plan would have

an annualized cost of $75,000, and the Forest Service plan would have an annualized cost

of $79,000. Given the benefits of implementing Forest Service condition 23 as described

above, we consider this cost to be warranted.

Aquatic Resources

Instream Flows

Flow regulation at McCloud and Iron Canyon dams and diversion of water to the

project powerhouses affect both habitat for aquatic biota and recreational opportunities in

downstream reaches. These reaches include Iron Canyon Creek below Iron Canyon dam

(4.6-mile bypassed reach), the Pit River below Pit 7 dam, and the Lower McCloud River

below McCloud dam (24-mile bypassed reach). As we discussed in section 3.3.2,

Aquatic Resources, many participants, including PG&E, recommend raising minimum

flows in these affected reaches, and we analyzed these recommended flow regimes in

section 3.3.2.2, Environmental Effects. In section 4.1, Power and Economic Benefits of

the Projects, we show how the proposed and recommended minimum flows decrease the

project’s power generation. Here we consider both the cost of raising instream flows and

how the recommended minimum flows affect other competing flow uses, including

aquatic habitat and recreational resources, such as angling and boating, and we then make
373

our final minimum flow recommendations for each reach, including the Lower McCloud

River.

PG&E proposed minimum flow regimes for each of its project reaches to protect

aquatic resources. For the reaches below McCloud and Iron Canyon dams, the minimum

flows would vary by month and water year type (tables 3-22 and 3-23). For the Pit River

below Pit 7 dam, the minimum flow would be the same year-round (150 cfs) whenever

the water surface elevation at Shasta Lake is below 1,055 feet msl. To determine

appropriate flows for aquatic and terrestrial biota, PG&E used both incremental flow

methods and resource studies. In all cases, PG&E’s proposed flows are equal to or

greater than the flows required in the current project license and would provide more

trout habitat in most months.

As we discuss in section 3.3.2.2, Environmental Effects, several participants

recommended alternatives to PG&E’s minimum flow regime proposals for the project’s

reaches. Forest Service modified condition 19 specifies seasonal flow regimes for each

reach (tables 3-22, 3-23, and 3-24). PG&E alternative condition 19 proposes a minimum

flow regime that differs slightly from the flow regime proposed in its license application

for the Lower McCloud River and Iron Canyon Creek (tables 3-22 and 3-23). California

Trout, Trout Unlimited, and McCloud River Club (table 3-25);31 McCloud RiverKeepers

(table 3-26); American Whitewater (table 3-27); and the Winnemem Wintu Tribe

(table 3-28) also recommend minimum flows for the Lower McCloud River that are

equal to or greater than the flows required in the current project license and would

provide more trout habitat in most months.

Iron Canyon Creek Below Iron Canyon Dam

Because of the steep canyons and private property restrictions, angling pressure on

Iron Canyon Creek is less than on the McCloud River and the project reservoirs. PG&E

now releases a year-round minimum flow of 3 cfs to the 4.6-mile Iron Canyon Creek

reach. We note that surveys of Iron Canyon Creek found a self-sustaining rainbow trout

population in good condition. However, the results of the PHABSIM model show that

increasing the minimum instream flow during all months would likely benefit resident

rainbow trout by increasing the usable habitat for juvenile and adult life stages. Except

for some small differences (two cfs) during dry water years, PG&E’s minimum flow

regime for this reach and the minimum flow regimes filed by both the Forest Service and

California Fish and Game are very similar. PG&E alternative condition 19 proposes a

minimum flow regime that is identical to the Forest Service flow regime. All proposals

would set minimum flows in the creek so that the monthly minimum flows vary

seasonally to mimic natural hydrologic conditions.

31 As Trout Unlimited and McCloud River Club filed minimum flow

recommendations identical to California Trout’s recommendation, and as recent filings

have been filed jointly, we now refer to it as the California Trout recommendation.
374

To enhance trout populations in Iron Canyon Creek, we recommend the PG&E

alternative condition and Forest Service modified condition 19 minimum flow regime.

Raising the minimum flows in this manner would reduce the project’s average annual

generation, at a cost of about $727,000 annually. While raising the minimum flow in this

reach would enhance conditions for the rainbow trout population, we acknowledge the

loss in generation due to the increased flows but conclude that the enhancement justifies

this cost. In the draft EIS, we recommended that PG&E file a plan to enhance angling

access to Iron Canyon Creek in order to provide additional public benefit as a result of

this aquatic enhancement. In its September 27, 2010, letter, PG&E indicated that access

to Iron Canyon Creek currently exists via a road that accesses the gaging station near the

upstream end of the creek. Additionally, PG&E noted that much of Iron Canyon Creek

has exceedingly difficult terrain for access. Due to these circumstances, we no longer

recommend that PG&E file a plan to enhance angling access to Iron Canyon Creek.

Pit River Below Pit 7 Dam

PG&E proposes, the Forest Service specifies, and California Fish and Game

recommends a continuation of the 150-cfs minimum flow in the Pit River below Pit 7

dam. Current project flows provide for a range of aquatic flow-habitat transitioning from

the riverine upstream conditions to broad, shallow lacustrine habitat near the afterbay

dam. This habitat supports a diverse fish assemblage, dominated by native hardhead and

Sacramento suckers. Furthermore, the fish populations in the reach have a recurrent

seasonal exchange with the fish community in the Pit River arm of Shasta Lake.

Continuation of this minimum flow will ensure adequate flow-habitat in the reach, while

also ensuring continuity with the Pit River arm of Shasta Lake even when the water

surface elevation of Shasta Lake is below 1,055 feet msl. The proposed minimum flow

of 150 cfs, consistent with current project operation, would not alter the project’s average

annual generation and would protect aquatic habitat and fish populations; therefore, we

recommend a minimum flow of 150 cfs in the Pit River below Pit 7 dam.

Lower McCloud River Below McCloud Dam

PG&E proposed a minimum flow regime for the Lower McCloud River reach that

results in a low flow season from May to November of 150 cfs, and a high flow season of

200 to 220 cfs from December to April. In condition 19, the Forest Service specified a

higher minimum baseflow (175 cfs) for the Lower McCloud River than was originally

proposed by PG&E, and a minimum flow regime that varies by month and water year

type. The Forest Service flow regime would create a spring pulse flow condition which

more closely reflects a natural hydrograph. PG&E’s alternative condition 19 baseflows

are 25 cfs higher (175 cfs) than its proposed baseflows. PG&E’s alternative also

incorporates a minimum flow regime that varies by month and water year type.

Commenters on the draft EIS indicated that under the existing license, flows at

Ah-Di-Na (MC-1) were commonly greater than the minimum 200 cfs originally specified

by the Forest Service. Therefore, in its November 29, 2010, filing, the Forest Service

modified condition 19 to specify that, during normal and above normal water years (when
375

flows at the McCloud dam greater than or equal to 200 cfs on 15 April) flows at Ah-DiNa (MC-1) should be at least 215 cfs through July and August, then decreased to 200 cfs

in September. This modification would ensure that flows in the Lower McCloud River

downstream of Ah-Di-Na are more representative of the historical summer base flows.

Similar to our draft EIS recommendation, Forest Service modified condition 19 also

would reduce the March 16 flow increase from 100 cfs to 50 cfs during normal to wet

years, thereby reducing both the rate of increase and peak magnitude in those years. In

its November 29, 2010, letter, California Trout indicated concurrence with the flows

specified by Forest Service modified condition 19. Although PG&E indicated at the

November 17, 2010 section 10(j) meeting that it was close to agreement with the Forest

Service on a flow regime, PG&E has not indicated that it concurs with the flow regime

specified in Forest Service modified condition 19.

California Fish and Game’s recommended baseflows (200 cfs), to be measured at

a single compliance point located at McCloud dam (gage MC-7), are slightly higher than

flows specified by Forest Service modified condition 19. American Whitewater’s

recommended alternative baseflows (200 cfs) also are slightly higher than the Forest

Service’s modified condition 19 flows. In addition to its recommended baseflow,

American Whitewater added seasonal peak flows for whitewater boating. Due to angler

safety concerns, McCloud RiverKeepers’ proposed alternative flows were substantially

lower (100 cfs) than the Forest Service and PG&E flows, with flows varying by month

from 160 to 210 cfs (table 3-26).

The Lower McCloud River’s trout fishery is highly regarded in terms of aesthetics

and biological productivity;32 however, this fishery can be enhanced even further. The

results of aquatic flow-habitat studies generally predicted that increasing minimum

instream base flows from the current 40-50 cfs to between 175 and 200 cfs in summer

and fall would provide the greatest abundance and highest habitat values for resident

trout species. While PG&E and the Forest Service agree on a baseflow of 175 cfs at gage

MC-7, California Fish and Game determined that PG&E should implement a baseflow of

200 cfs. Modeling results indicated a negligible difference in the amount of aquatic

habitat available with a 200-cfs baseflow, as compared to a 175-cfs baseflow. For this

reason, coupled with the loss of generation associated with a 200-cfs flow, we do not

recommend the California Fish and Game minimum flow regime.

Most flow recommendations from licensing participants are designed to create a

seasonal hydrograph that is more typical of natural patterns for the Lower McCloud River

by increasing flows from the minimum baseflow during late winter and early spring,

32 California Fish and Game designates the Lower McCloud River a “Wild Trout

Water,” defined as: “aesthetically pleasing and environmentally productive streams ...

managed exclusively for wild trout, where the trout populations are managed with

appropriate regulations to be largely unaffected by the angling process.” This

designation is similar to the “blue ribbon” designation used in other states.
376

followed by decreasing flows through late spring, and returning to the baseflow through

the summer and fall. Specifically, the Forest Service specifies and PG&E recommends

increasing flow twice a month beginning in mid-February, depending on the relative rate

of runoff in a given year, as determined by the water year (as described in DWR

Bulletin 120), reaching a peak of 500 cfs in normal water years. Studies predict that

maximal trout spawning occurs between 300 and 400 cfs. Under the current license, the

flow regime does not provide for these high late winter-spring flows that mimic the

natural hydrograph.

California Trout’s original minimum flow recommendations (table 3-25) differed

slightly from the Forest Service and PG&E flow regime, although it too attempted to

mimic the natural hydrograph in the spring. Under California Trout’s flow regime, flows

would decrease at a faster rate after April 15 during normal to wet years (table 3-25). As

compared to the flow regime specified in Forest Service modified condition 19 and

PG&E’s alternative condition 19, these slight changes in the rate decrease in spring flows

are not likely to have a significant effect on available habitat for various trout life stages,

and would still provide some benefits to spawning rainbow trout.

The McCloud RiverKeepers recommends that minimum flows at McCloud dam be

established at 100 cfs year-round and that minimum flows at Ah-Di-Na (gage MC-1)

vary by month from 160 to 210 cfs in normal years and from 160 to 180 cfs in dry years

(table 3-26). While this recommendation would increase minimum flows compared to

the current license, it would not create a more natural seasonally varying flow regime as

offered by the other recommendations. Seasonal variation in flow typical of most

streams in lower mountain and foothill landscapes helps create diverse aquatic habitat,

promotes ecological diversity, and benefits wild and native species that have adapted to

seasonally variable conditions. Because the McCloud RiverKeepers’ recommended

minimum flow regime does not include this seasonal variability, we do not recommend it.

In its license application, PG&E proposes to provide a recreation flow event from

McCloud dam if a natural spill flow event of at least 300 cfs for 7 consecutive days

during the period of April 1 through October 31 has not occurred at any time in the

previous three calendar years. PG&E defines a recreation flow event as a minimum flow

release of 300 cfs from McCloud dam for 11 consecutive days during the period between

May 15 and June 15. In its alternative condition 19, however, PG&E does not propose to

provide a recreation flow event because of lack of support from stakeholders. In contrast,

while the Forest Service does not specify flows specifically for recreational boating, it

comments that its specified flow regime would provide more boating days than currently

exist, especially in drier years, and that, in terms of whitewater boating, the flow regime

is not significantly different from the current flow regime. Further, the Forest Service

also notes that a few more whitewater boating days actually would be provided in wetter

years under its flow regime.

As noted earlier, American Whitewater recommends the release of elevated flows

in April and May to provide whitewater boating opportunities, in addition to ecological
377

benefits. In wet and above normal water years, American Whitewater recommends peak

flows of 600 cfs through April and a ramping down of flows through May. In below

normal water years, American Whitewater recommends flows of at least 400 cfs during

the month of April. In dry and critically dry years, American Whitewater recommends

flows of 300 cfs ramping down to 200 cfs baseflows by the opening day of trout season.

As discussed in section 3.3.5.2, Environmental Effects, Recreation Flows,

acceptable flow ranges for various whitewater experiences were developed from a flowacceptability survey conducted by PG&E for the relicensing proceeding. The survey

found that the standard flow range for whitewater boating for both kayaks and rafts from

the base of McCloud dam to Ah-Di-Na Campground was between 700 and about 1,000

cfs, depending on the boat type (optimal 800 cfs for both boat types). From Ah-Di-Na to

Shasta Lake, the standard flow range is between 600 and 1,500 cfs, depending on the boat

type (optimal between 800 and 900 cfs depending on the boat type). From the base of

McCloud dam to Ah-Di-Na Campground, technical whitewater boating conditions would

exist between 500 cfs and 700 cfs. Flows greater than 1,500 cfs are considered “big

water” and are suitable only for expert paddlers.

As also discussed in detail in section 3.3.5.2, Environmental Effects, Recreation

Flows, during the 13-year period we analyzed under the existing license (1994-2006), the

number of whitewater boating days was 0 in 6 years and 20 or fewer days in 6 of the 7

remaining years. The flow scenarios proposed by California Fish and Game and PG&E,

and specified by Forest Service modified condition 19, would have had no effect on the

number of days available to whitewater boaters in 8 of the years and would have

increased the available days from 1 to 3 days during the other 5 years. The California

Trout recommendation would have increased the number of days from 3 to 7 during four

years and have had no effect on the number of days during 9 years.

In comparison to existing flows at the project, PG&E’s alternative condition 19

and Forest Service modified condition 19 minimum flow regime would likely result in an

additional 100 cfs available in the reach in late March through mid-May in wet years and

an additional 200 cfs in mid-April through early June in very wet years, therefore

providing more opportunities for whitewater boating than currently exist during these

water years. Although California Trout’s recommendation would create more early

spring whitewater opportunities than currently exist, the recommended flow regime

would likely provide for fewer days with flows greater than 300 cfs in wet years and

fewer days with flows greater than 600 cfs in very wet years.

In addition to our analysis of recreational boating flows, we also analyzed the

effects of flows on recreational fishing. As noted in section 3.3.5.1, Affected

Environment, Angling Resources, in the surveys conducted for the relicensing

proceeding, anglers and guides indicated higher flows diminish fishing quality by

decreasing the angler’s ability to wade, cross the water, and cast, as well as decreasing

fishable water and safety. PG&E’s study results indicate that 210 to 375 cfs, as measured

at the Ah-Di-Na gage (MC-1), is optimal for wading anglers, with the acceptable range
378

from 200 to 475 cfs. In addition, while higher flows still allow for some fishable

locations, there are fewer of them and each has a smaller fishable area, creating the

potential for overfishing. PG&E’s controlled flow study also found that as flow

increased, use levels decreased, with fewer anglers fishing for shorter durations.33

Though all angling groups and Lower McCloud River users support enhancing aquatic

habitat in the Lower McCloud River, most do not support flow releases for whitewater

recreational boating in the Lower McCloud River. These groups oppose changes from

the existing daily flow requirements in the Lower McCloud River due to concerns for

angler safety and in order to preserve the high quality trout fishing for California licensed

anglers. Fishing is open in the Lower McCloud River from the last Saturday in April

through November 15. Under current conditions, after high spring flow conditions, the

river is usually fishable by mid-May.

As previously stated, California Trout’s spring pulse flow regime is slightly

different than the Forest Service and PG&E’s spring pulse flow regime. Under California

Trout’s flow regime, flows would increase at a slower rate at the beginning of the season

during normal to dry years and decrease at a faster rate at the end of the season during

normal to wet years. Additionally, during normal to dry years, the spring pulse flow

would peak at about 450 to 100 cfs lower than the peak flow under the Forest Service and

PG&E’s regime in similar conditions. Therefore, during normal to wet years, California

Trout’s regime would allow for optimal angling conditions, between 200 and 300 cfs, up

to 4 weeks earlier in the fishing season than in the Forest Service and PG&E’s regime.

California Trout’s recommendation would increase angling opportunities by allowing

anglers to access the river earlier in the fishing season.

Because the low end of the range for optimal conditions for wading anglers is 210

cfs, while the minimum base flow in most recommendations is 200 cfs, all of the

recommended flow scenarios would result in a decrease in optimal fishing days when

compared to the existing license. The Forest Service modified condition 19 would

generally have resulted in the least amount of optimal fishing days lost than the

recommendations made by PG&E (both in its license application and its alternative),

California Trout, California Fish and Game, and American Whitewater. In contrast,

while the number of optimal days would have decreased, the number of acceptable days

for wading anglers would generally have increased during most of the 13-year period of

analysis under all flow proposals. There were no significant differences in the number of

days gained among the recommendations from PG&E, California Trout, California Fish

and Game, and American Whitewater, and the Forest Service’s modified condition 19.

American Whitewater’s recommendation and PG&E’s original proposal to release

higher peak flows in April would create more opportunity for whitewater boating at the

project overall; however, these higher flows would decrease the number of angling days

33 Technical Memorandum 58: Lower McCloud River Report on Flows and

Fishing Conditions (RL-S3).
379

at the project in all but critically dry water-years and potentially compromise the safety of

those anglers who wade in the stream to fish. For these reasons, we do not recommend

either of these flow regimes.

In the draft EIS, we recommended the minimum flow regime proposed by

California Trout. At that time, we concluded that California Trout’s recommendation

struck the best balance between angling opportunities, aquatic resources, and recreational

boating. However, in light of comments on the draft EIS, we have reevaluated our draft

EIS minimum flow recommendation for the Lower McCloud River.

Our analysis leads us to conclude that Forest Service modified condition 19, not

unlike our draft EIS recommendation, would provide for wadeable conditions beneficial

to anglers by the trout fishing season. Although both flow regimes would provide for

favorable wading conditions, our draft EIS lower late winter-spring flow

recommendation would reduce recreational boating opportunities sooner in the spring

when compared to the Forest Service modified condition 19 flow regime. We note that

numerous draft EIS comments filed by local recreational boaters and American

Whitewater expressed the need for more whitewater flows on the Lower McCloud River

below McCloud dam.

As we stated in the draft EIS, in making a final minimum flow recommendation

for the Lower McCloud River, in addition to power generation, we must weigh the needs

of aquatic resources, anglers, and recreational boaters. Given the importance of the

existing blue ribbon fishery in the Lower McCloud River, and also recognizing the

demand for recreational boating, we now conclude that the minimum flow regime

recommended by Forest Service modified condition 19 strikes the best balance between

angling opportunities, aquatic resources, and recreational boating. This flow regime

would provide more aquatic habitat and create some early spring whitewater

opportunities while still making sure the river is accessible for angling early in the fishing

season (by mid-May). While the PG&E minimum flow regime also would provide these

opportunities and enhancements, including more aquatic habitat and recreational boating,

it would result in fewer angling opportunities early in the fishing season in a majority of

water years. While our draft EIS flow regime would provide benefits for aquatic habitat

and also angling, it would limit recreational boating opportunities in the spring as

compared to the Forest Service’s modified condition 19 flow regime. As such, and

because the costs associated with both recommendations are similar, we do not

recommend PG&E’s minimum flow regime and no longer recommend our draft EIS flow

regime. Instead, we now recommend that PG&E implement the flow regime specified in

Forest Service condition 19, as modified on November 29, 2010 (table 3-22). We

estimate this flow regime would reduce the average annual power generation at the

project by 40 GWh and would reduce the annual net benefit of the project by $3,500,000,

compared to current operations. Given the enhancements noted above, however, we

conclude that implementation of the minimum flow regime is worth the cost.
380

Flow Compliance and Monitoring

PG&E and Forest Service/California Fish and Game have proposed different

methods to measure compliance with the proposed minimum flow releases, although the

two approaches appear to accomplish essentially the same goal by requiring

compensation for under-release of minimum flows.

PG&E proposed that the minimum flow requirements be met on the basis of the

seven-day running average of mean daily flow. PG&E proposed the following:

(1) individual mean daily flows may be less than the required minimum streamflow;

(2) however, the instantaneous 15-minute streamflow should be at least 90 percent of the

required minimum streamflow; and (3) the seven-day running average of the daily mean

be equivalent to or greater than the required minimum flow. Therefore, any underrelease could be averaged out by over-releases on other days within each successive

seven-day window (averaging period).

Under Forest Service condition 19 and the California Fish and Game

recommendation, PG&E would release the equivalent under-released volume of water

within seven days following the discovery of the under-release. Credit for such

additional releases would not exceed 20 percent of the instantaneous flow amount, when

used to attain the equivalent of the under-released volume. In addition to this provision,

if PG&E finds that flow releases are non-compliant, it would be required to notify the

Commission of the potential violation, and to take immediate action to return to

compliance.

PG&E alternative condition 19, Forest Service condition 19, and the California

Fish and Game recommendation accomplish the same objective. However, PG&E’s

proposal to determine compliance via a seven-day running average provides a better

defined and more reliable accounting mechanism that can be verified by any outside

entity and is consistent with flow compliance mechanisms used at other Commissionlicensed projects. Further, we note that if PG&E were found to be in non-compliance by

the Commission, it would be required to take immediate action to return to compliance

consistent with Forest Service condition 19. Therefore, we recommend PG&E’s

proposed method.

In its license application, PG&E proposed to change the compliance point for

measuring instream flows below McCloud dam from gage MC-1 to gage MC-7, and

provide real-time flow data on the internet from gage MC-1. California Fish and Game

supported PG&E’s proposal for a single compliance point near McCloud dam and NMFS

also recommended a single compliance point at either MC-7 or MC-1. In contrast, Forest

Service condition 19 specified flows be measured at two compliance points (MC-1 and

MC-7 or near the dam) for McCloud dam. PG&E alternative condition 19 proposed the

use of two compliance points below McCloud dam.

The Ah-Di-Nah gage (MC-1) captures flow augmentation from Hawkins Creek

immediately upstream of the gage. Thus, under current conditions, the minimum flow
381

between the dam and Hawkins Creek (gage MC-7) can be as low as 40 cfs, as long as

flow from Hawkins Creek is adequate to augment flows to the required minimum at the

MC-1 gage. In order to assure that flows are augmented below Hawkins Creek, even

during dry periods and dry years when flows from Hawkins Creek could be minimal,

PG&E and the Forest Service proposed increasing the minimum flow at McCloud dam

if needed. Thus, at any time during the year, if discharge from Hawkins Creek is not

adequate enough to augment flows in the Lower McCloud River to meet the minimum

instream flow requirement at MC-1, PG&E would be required to release additional flow

from the dam. We find the Forest Service’s specification to use two compliance points

below McCloud dam to be reasonable because it would ensure minimum flows at the

dam are adequate to provide sufficient habitat for fish and other aquatic biota throughout

the entire reach between McCloud dam and Squaw Valley Creek.

The Forest Service also specified the use of existing compliance points for

Iron Canyon dam and Pit 7 dam and that PG&E must provide flow values (generally

15-minute interval recordings) to resource agencies upon request. In addition, the Forest

Service specified that PG&E operate, maintain, and, if necessary, modify under USGS

supervision, all existing gages needed to determine the river stage and minimum instream

flow in project-affected reaches, and the Forest Service specified the methodology that

PG&E must utilize to determine water year type and guide implementation of minimum

flows. In its original condition 19, the Forest Service specified the use of the DWR

Bulletin 120 of the Sacramento River near Redding to determine water year type for the

implementation of minimum flows. In concurrence with staff’s recommendation from

the draft EIS and PG&E’s proposal, Forest Service modified condition 19 specifies the

use of the DWR Bulletin 120 of the McCloud River above Shasta Lake, for implementing

minimum flows for Iron Canyon dam which is consistent with the water year type

determination specified by the Forest Service for the Lower McCloud River. We

recommend the water year index recommended by PG&E’s alternative condition and

specified by Forest Service modified condition 19 as it provides a better representation of

local hydrology and serves as a consistent methodology for implementing minimum

flows on both the McCloud River and Iron Canyon Creek.

Continued operation of the USGS gages in each of the affected reaches,

including any modifications that may be required to accurately measure minimum flows

or ramping rates that are included in the new license, would help to ensure that these

gages remain functional and can be used to effectively monitor compliance with flowrelated measures included in the new license. The gages would also help to ensure that

flow data continues to be available to other water users in the basin and to the general

public. Provision of flow data recorded at 15-minute intervals to the agencies upon

request would help to verify compliance with any instantaneous flows and ramping rates

that are included in the license. We estimate that funding the continued operation of the

USGS gages would have an annualized cost of $120,000. Because continued operation

of these gages is needed to verify license compliance and to ensure that the benefits of
382

implementing minimum flows to the project-affected reaches are realized, we conclude

that the benefits of this measure are worth its costs.

Ramping Rates

Under the existing license, there are no ramping rate requirements downstream of

any project impoundments and no ramping is required when changing between seasonal

required minimum flow rates. PG&E proposed to establish a good-faith effort to achieve

a target maximum upramping rate of 100 cfs per hour for spill flows at McCloud dam

prior to the start of an uncontrolled spill event. This upramping rate is consistent with

current practice, although the existing project license does not require it. American

Whitewater proposed alternative upramping rates at McCloud dam using stage rather

than flow as a unit of measure for ramping operational controllable spills in order to

provide flow rates that more closely mimic the natural hydrograph. Specifically,

American Whitewater proposed maximum upramping rates based on river stage, 1-foot

per 24 hours, as measured at gage MC-7.

Upramping of spill events, to the extent possible, allows aquatic organisms time to

seek refuge before high flow events and prevents excessive scour and destruction of

instream habitat structures. The relationship between flow and water depth (stagedischarge) varies along the stream channel depending on the complexity and

configuration of the channel cross-section and in particular the dimensions of the

floodplain; therefore, the gage location may not be indicative to the stage-discharge

relationship throughout much of the reach that it represents. Therefore, it is appropriate

to control ramping rates through changes in flow rather than American Whitewater’s

stage-discharge method. Because PG&E’s proposed upramping procedure would help

protect aquatic resources, we recommend it.

PG&E does not propose to downramp seasonal high flows. California Fish and

Game recommended and the Forest Service specified that PG&E ramp down all

McCloud dam spill events once the spill reaches 1,000 cfs at which point the control

valve could be used to control the discharge. Downramping would proceed at a 150-cfs

decrease every 48 hours until the prescribed minimum instream flow value is reached.

Additionally, operational controllable spills would be upramped in increments not to

exceed 200 cfs in a 24-hour period. In its alternative recommendation, PG&E

incorporated the downramping schedule outlined by California Fish and Game and the

Forest Service. American Whitewater proposed downramping rates of 0.2 foot per

48 hours until the prescribed minimum flow value is reached, as measured at MC-7.

Rapid changes in streamflow have the potential to strand and kill young fish and

macroinvertebrates, and may also cause adverse effects on amphibians including the

foothill yellow-legged frog. Our recommended ramping protocol would reduce the

potential for fish stranding at times when flows are reduced following spill flows. As

previously explained, we find that the existing gage provides an appropriate control

cross section for determining the relationship between flow and stage. It is appropriate,

therefore, to control ramping rates through changes in flow rather than stage.
383

Implementing ramping rates would have a negligible cost; therefore, we conclude the

benefits of this measure warrant the cost.

PG&E also did not propose flow ramping for annual dam safety valve testing at

Iron Canyon Creek. California Fish and Game recommends and the Forest Service’s

original condition 19 specified that valve testing for dam safety compliance at Iron

Canyon dam be conducted between March 5 and March 15 when the highest instream

flows are released, in order to minimize impacts to the reproductive success of breeding

aquatic organisms, that these flows should be kept to the minimum level allowable

(possibly in the range of 150 cfs) to minimize channel damage, and that upramping and

downramping related to testing of the flow valve at Iron Canyon dam should occur in

20-cfs increments, assuming a 200-cfs maximum. PG&E proposed an alternative valve

testing schedule of March 1 to March 31 to allow for potential winter access issues and

associated safety risks. In its modified conditions 19, the Forest Service concurs with

PG&E that valve testing could be conducted between March 1 to March 31 to avoid

potential access related safety risks during winter.

We recommend the inclusion of flow ramping procedures, as recommended by

California Fish and Game and specified by the Forest Service for spill events and valve

testing at McCloud dam and Iron Canyon dam. Implementing ramping rates would

improve on existing conditions by providing a clearly documented procedure for

reducing high flows associated with operational testing to reduce effects on aquatic

resources. Our recommended ramping protocol would reduce the potential for fish

stranding at times when flows are reduced following proposed test valve flow releases, as

well as minimize the impacts to spring breeding aquatic organisms. However, we

recommend including the expanded schedule for the Iron Canyon safety valve testing for

dam compliance, as recommended by PG&E alternative condition 19 and Forest Service

modified condition 19 in the staff alternative to ensure safety at the project. The timing,

frequency, and magnitude of natural peak spring runoff events can be highly variable

depending on storms and snowmelt; therefore, shifting the valve test one to two weeks

earlier or later to accommodate safety and access is not likely to have adverse effects on

aquatic resources.

Water Quality and Temperature Monitoring Plan

PG&E proposes to develop and implement a water quality and temperature

monitoring plan in consultation with the California Water Board, the Forest Service,

California Fish and Game, and other interested parties within 1 year of license issuance.

Under the plan, PG&E would provide monitoring for temperature, turbidity, and

contaminants in project-affected reaches and reservoirs.

Forest Service modified condition 20 specifies a water quality monitoring plan

that includes a schedule and monitoring requirements for project-affected reaches. The

Forest Service specifies that PG&E: conduct periodic monitoring of contaminants

including E. coli in all project reservoirs once every 5 years for the term of the license;

conduct periodic monitoring of DO at McCloud, Pit 6, and Pit 7 reservoirs for the term of
384

the license; conduct annual monitoring of temperature for 10 years, with additional

monitoring if temperatures exceed 20°C in reservoirs or downstream reaches; conduct

continuous monitoring of turbidity in the Lower McCloud River during the fishing season

and provide real-time turbidity information on PG&E’s public project website; conduct

turbidity monitoring for at least 5 years in Iron Canyon Creek at MC-10; and implement

BMPs to satisfy Aquatic Conservation Strategy objectives. PG&E withdrew its

alternative condition 20 and accepts Forest Service modified condition 20.

Monitoring of contaminants, including E. coli, in project reservoirs would provide

information that could be used to ensure public health and determine potential impacts of

project facilities or operations. DO data collected periodically from McCloud, Pit 6, and

Pit 7 reservoirs would ensure concentrations of DO in project reservoirs are sufficient to

support aquatic life and to determine effects, if any, of changes to project operations

resulting from the proposed operational changes under the new license. Temperature

data collected from project reaches and reservoirs would ensure project operations are

providing conditions supportive of resident fish populations. Continuous monitoring of

turbidity in the Lower McCloud River during the fishing season and providing real-time

turbidity on PG&E’s public project website would provide valuable information to

recreation users. Continuous monitoring of turbidity in Iron Canyon Creek for at least 5

years would provide information on the effectiveness of mitigation actions and ensure

levels are reduced to at or below the basin plan levels. Implementing BMPs would be

beneficial for minimizing any impacts to aquatic resources associated with O&M

activities, recreation, land use, and other practices associated with the project. We

estimate that developing the water quality and temperature monitoring plan specified by

the Forest Service would have an annualized cost of $86,000. Given the benefits of water

quality monitoring and temperature parameters, as described, we conclude that the

benefits of this measure are worth the costs.

Fish Entrainment

Entrainment of fish into hydroelectric intakes typically causes injury or mortality

to a portion of the fish that are entrained, with mortality rates tending to be lower for

smaller fish and higher for turbines that operate under higher levels of head, with higher

rotational speeds, and with smaller passageways. PG&E developed and implemented a

study in consultation with the agencies to assess the potential for entrainment losses to

affect fish populations in the project area. The results of PG&E’s entrainment studies

and literature review indicate that entrainment potential at the project intakes is

negligible. Therefore, PG&E did not propose any measures to protect fish from

entrainment.

NMFS recommends that PG&E construct effective screening facilities at project

intakes following the return of listed salmonid species. No listed anadromous salmonids

would be expected to have access to habitat in the Lower McCloud River until upstream

migration of listed species is implemented through Shasta Lake; therefore, at this time the

screening facilities recommended by NMFS would provide no benefit for listed species.
385

However, we recommend that at such time as fish passage facilities provide access to

these reaches for listed salmonid species, the need for screening facilities can be reevaluated based on fish population monitoring studies included in the new license.

Aquatic Biological Management and Monitoring Plan

Forest Service modified condition 27 specifies that PG&E develop and implement

an Aquatic Biological Monitoring Plan, in consultation with interested parties and

approved by the Forest Service, for fish, benthic macroinvertebrates, special status

aquatic mollusks, special status species, and invasive aquatic species. The number of

sites, site locations, sampling methods, and data protocols would be consistent with prefiling relicensing studies and plans. The Forest Service also specifies a reporting

requirement for providing monitoring results. In addition, the Forest Service filed a draft

Aquatic Biological Monitoring Plan as an enclosure to modified condition 27.

In its alternative condition 27, PG&E generally supported the Aquatic Biological

Management Plan specified by the Forest Service in original condition 27, but proposed

that 2 years, rather than the 1 year specified by the Forest Service, would be more

adequate to develop and finalize the Aquatic Biological Management and Monitoring

Plan. PG&E also proposed monitoring of only stream fish populations rather than

reservoir and stream fish populations recommended by the Forest Service. With the

filing of the Forest Service’s modified condition 27, however, PG&E withdrew its

alternative condition 27 and accepts Forest Service modified condition 27.

We support the development and implementation of an Aquatic Biological

Management and Monitoring Plan specified by Forest Service modified condition 27.

Because the Forest Service and PG&E have worked collaboratively on the draft Aquatic

Biological Monitoring Plan and it is substantially complete, we expect that 1 year would

be adequate time to finalize and implement the plan. Forest Service modified condition

27 also specifies that fish population surveys be conducted in Iron Canyon Creek, Lower

McCloud River, and the Pit 7 reservoir. Analysis of project reservoir fish population data

obtained during project relicensing studies indicated that fish populations do not appear

to be affected by project operations and are sustained by natural production and fish

stocking. Therefore, monitoring of fish populations in the Pit 7 reservoir would provide

little additional useful information.

Furthermore, we expect that monitoring and evaluation of fish populations in

project reservoirs would be conducted, as needed, as part of PG&E’s proposed fish

stocking plan (discussed below under Recreation), and therefore do not support

additional monitoring studies in project reservoirs specified by the Forest Service. We

estimate that developing the Aquatic Biological Management and Monitoring Plan

specified by the Forest Service and modified by PG&E would have an annualized cost of

$195,000. Because biological monitoring would assist with determining the effects of

any changes in operation or measures that are implemented in the new license to enhance

resident fish populations, and with assessing whether any modifications or additional

measures are needed, we conclude the benefits of the program are worth the costs.
386

Fish Passage

In its original condition 27, the Forest Service specified that, within 1 year of

license issuance, as a component of the Aquatic Biological Management Plan, PG&E

develop specific management actions and schedule for providing fish passage and

monitoring at road crossings for affected reservoir tributaries, in consultation with the

Forest Service, California Fish and Game, potentially affected tribes, and other interested

parties. These management actions specified by the Forest Service include:

 Constructing or correcting fish passage structures on Deadlun, McGill, Cedar

Salt Log, Little Gap, and Gap Creek on Iron Canyon reservoir and Tarantula

Gulch and Battle Creek on McCloud reservoir;

 Maintaining the fish passage structures on an annual basis, if needed,

concurrent with road condition surveys;

 Monitoring each stream reach every 3 years to determine fish passage structure

effectiveness; and

 Providing the results of fish passage monitoring concurrently with aquatic

monitoring reports.

PG&E alternative condition 27 stated that roads impeding fish passage on

tributaries to the project reservoirs are not project roads, therefore, PG&E is not

responsible for maintaining fish passage structures associated with these roads. PG&E

indicated, however, that it would provide compensation to the Forest Service for fish

passage maintenance as part of an off-license road agreement.

Forest Service modified condition 27 specifies that, as a component of the Aquatic

Biological Management Plan, PG&E conduct periodic monitoring of fish passage

conditions at Gap Creek, Deadlun Creek, and Cedar Salt Log Creek road crossings

around Iron Canyon Reservoir in consultation with the Forest Service, State Water

Resources Control Board, California Fish and Game, potentially affected tribes, and other

interested parties. In the draft Aquatic Biological Monitoring Plan filed as an enclosure

to modified condition 27, the Forest Service recommends fish monitoring beginning the

first year following license renewal, and then once every 5 years for the term of the new

license. In addition, the Forest Service specifies a reporting requirement for providing

monitoring results. PG&E filed comments withdrawing its alternative condition 27

analyzed in the draft EIS and concurring with Forest Service modified condition 27.

The roads noted by the Forest Service in modified condition 27 are not project

roads, and therefore, PG&E should not be responsible for monitoring or maintaining fish

passage road crossings. It is clear that these roads and any resulting impediments to fish

passage would be manifested with or without the project. Subsequently, we have not

included this provision in our staff alternative.
387

Listed Salmonid Technical Integration Committee

NMFS filed a recommendation that, as soon as listed salmonids are documented

within the McCloud River and affected by the project, PG&E should, in consultation with

the U.S. Bureau of Reclamation, NMFS, FWS, California Fish and Game, and the

Commission, create and implement a Listed Salmonid Technical Integration Committee.

According to the recommendation, the Listed Salmonid Technical Integration Committee

would assess and mitigate the project’s effects on listed salmonids and could be

integrated with the existing Interagency Fish Passage Steering Committee (or affiliated

Technical Advisory Committees) to begin discussions of passage logistics at Shasta dam

habitat assessments that include studies of McCloud River historic anadromous salmonid

habitats. We estimate that, upon implementation, the annualized cost of this measure

would be $20,000.

No listed anadromous salmonids would be expected to have access to the Lower

McCloud River until upstream fish passage is implemented through the Keswick and

Shasta dams, downstream of the project; however, dependent on the results of the

proposed studies to assess habitat suitability for listed salmonids conducted as part of the

RPA for the OCAP BiOp, pilot re-introduction studies could result in the presence of

listed salmonids in the Lower McCloud River and waters of the McCloud-Pit project

below McCloud dam as early as 2012. In concert with continuing consultation, the

adaptive nature of proposed and specified existing biological and habitat monitoring

programs would allow for the re-evaluation of project mitigation and enhancement

measures at such time as fish passage facilities provide access to project reaches for listed

salmonid species. We find that it would be beneficial for PG&E to maintain awareness

of the ongoing feasibility studies and the status of the potential re-introduction of listed

anadromous species in the vicinity of the project. Therefore, we recommend that PG&E

file an annual report with the Commission that details the status of listed anadromous

species in the project vicinity. When the presence of listed anadromous fish in the project

area is deemed imminent, the plan would provide an assessment of any project O&M

measures that would have the potential to contribute to the take of any listed species. We

estimate that, upon implementation, the annualized cost of this measure would be $1,000.

Because these proposed and specified biological and habitat monitoring programs and

annual listed anadromous species status reports will provide a mechanism for the

continuing evaluation of project and mitigation and enhancement measures, including the

evaluation of the potential for the presence of listed salmonids, as well as their

environmental requirements, we do not recommend requiring PG&E to implement a

Listed Salmonid Technical Integration Committee, as the measure is not worth the cost.

Reintroduction of Anadromous Fish

NMFS provided eight recommendations that included protection, mitigation, and

enhancement measures to be implemented as soon as federally listed anadromous

salmonids, including Chinook salmon and steelhead, are documented within the McCloud

River. In the draft EIS, we did not recommend these measures because they were
388

premature. We found that no listed salmonid species have been documented within the

project area due to the barrier created by the Bureau of Reclamation’s downstream Shasta

dam.

On November 17, 2010, we met in Sacramento, California with representatives of

NMFS, California Fish and Game, PG&E, and other interested parties, to discuss

NMFS’s eight recommendations. In written comments and at the meeting, NMFS noted

that in the draft EIS, Commission staff did not analyze NMFS’s OCAP BiOp (NMFS,

2009a). NMFS also noted that on October 7, 2009, the agency released a Public Draft

Recovery Plan (NMFS 2009b) that is a comprehensive plan describing the strategies and

actions necessary to recover each species sufficiently to support its removal from listing

under ESA. We agreed to analyze these documents in the final EIS and, in light of that

analysis, reevaluate NMFS’s eight recommendations.

Our review and detailed analysis of the OCAP BiOp and Public Draft Recovery

Plan can be found in section 3.3.2.3, Aquatic Resources, Cumulative Effects. Located on

the Sacramento River, downstream of the McCloud dam, the Bureau of Reclamation’s

Keswick and Shasta dams are existing barriers to upstream passage of anadromous

salmonids. None of these listed fishes would be expected to have access to habitat in the

Lower McCloud River until upstream migration is facilitated past these dams and through

Shasta Lake. While the OCAP BiOp includes an RPA that would require the Bureau of

Reclamation to begin a program to reintroduce ESA-listed salmon species in Shasta Lake

and the Upper Sacramento River and its tributaries (including the McCloud River) by

2012, the program, as outlined in the Public Draft Recovery Plan, is only in the pilot

stage and many aspects of the plan are still in flux. Furthermore, as noted in section

3.3.2.3, many factors, including budget, habitat assessment completion, future NEPA

analyses, and feasibility must be determined before the program can move forward. As

such, it does not appear that even with the pilot program’s goal of reintroducing listed

species above Shasta dam in 2012, these listed species will become present in McCloudPit Project waters in the foreseeable future; therefore, we continue to conclude that the

eight general recommendations by NMFS would provide no benefit for listed species at

this time.

Despite the uncertainty regarding the timeframe for the reestablishment of listed

anadromous salmonids in the project area, however, we recognize the potential for the

future presence of listed anadromous species in the project area. Therefore, we continue

to recommend the implementation of several adaptive monitoring plans, which include

the Gravel and Coarse Sediment Management Plan, the water quality and temperature

monitoring plan, and the Aquatic Biological Monitoring Plan. In addition, we now

recommend that PG&E file an annual report on the status of listed anadromous species in

the project area. This report would detail the steps that have been taken in the

reintroduction, require PG&E to keep abreast of the findings and actions of the

Interagency Fish Passage Steering Committee, and should include the comments of

NMFS. The filing of this report will ensure that PG&E and the Commission are kept

informed of the progress of the potential reintroduction and this information would then
389

be used to determine when it is appropriate to consider any needed changes to project

structures and or operations, in light of the presence of ESA-listed salmonids in project

waters. Jointly, these recommendations would serve as an adequate mechanism for

determining the presence of listed anadromous salmonids in project-affected areas, the

status of associated habitat variables, and the need for any future changes to project

structures or operations.

At the November 17, 2010, meeting, NMFS also indicated that the Commission

retain, by means of a specific ESA reopener provision and other appropriate reservations

of authority, sufficient discretionary involvement or control with respect to project

construction, modification, maintenance, and operation under the new license to ensure

full compliance with the requirements of the ESA during the term of the license. We

note that standard Form L, Article 15, provides such authority.34 Thus, given that

standard article and our recommendation for an annual report on the status of listed

anadromous species in the project area, we conclude that, in this instance, there is no

need to include a specific reservation of authority for ESA. As stated in the October 30,

2000, Order On Rehearing for Avista Corporation’s Clark Fork Hydroelectric Project

(Project No. 2058-015),35 while the Commission has included specific ESA reopeners in

some cases,

36 doing so does not suggest that a specific reopener was required, or that our

standard reservation of authority for fish and wildlife resources would not suffice to

permit compliance with our obligations on ESA.

Terrestrial Resources

Vegetation and Invasive Weed Management Plan

Project operations may potentially affect vegetation through the introduction and

spreading of invasive weed species. Any O&M activities that disturb soil or remove

existing vegetation could increase the spread of invasive weeds and would have a direct

effect on vegetation and associated wildlife species. Potential indirect project effects

could come from recreational users who spread invasive weed seeds or other regenerative

plant materials from colonized to non-colonized areas or whose activities disturb existing

plant communities.

PG&E proposed a Vegetation Management Plan that would minimize adverse

effects on the environment, protect special status species and culturally significant plants,

control the spread of noxious weeds, and ensure revegetation of disturbed sites.

34 This also was affirmed in the March 13, 2002, Order Approving Settlement and

Issuing New License for the City of Tacoma, Washington’s Cowlitz River Project

(Project No. 2016-044). 98 FERC ¶ 61,274 (2002).

35 93 FERC ¶ 61,116 (2000).

36 Central Nebraska Public Power and Irrigation District,

84 FERC ¶ 61,079 (1998); and The Montana Power Company, Confederated Salish and

Kootenai Tribes of Flathead Reservation, 84 FERC ¶ 61,164 (1998).
390

Development and implementation of a Vegetation Management Plan would provide

guidance, methods, and protocols for management and monitoring of botanical resources,

including special status species, within the project area.

In its original condition 25, the Forest Service specified that PG&E file a

Vegetation and Invasive Weed Management Plan within 1 year of license issuance that

would include: treatment protocols and measures for removing or trimming vegetation

within the project and project-affected area; specific conditions for the protection of

special status and culturally significant plants and populations; invasive species

management and monitoring; and pesticide or herbicide use restrictions and prohibitions.

PG&E would be required to consult with the Forest Service annually to review

procedures for special status species surveys. In its original condition 25, the Forest

Service also specified that periodic monitoring of special status and culturally significant

plants should occur every 5 years at known locations and every 10 years for the entire

project and project-affected area.

Forest Service condition 15 specifies that PG&E exclude the use of pesticides and

herbicides on NFS lands unless prior written approval is received from the Forest

Service. Materials used would be limited to those registered by U.S. EPA and consistent

with those used by the Forest Service at Shasta-Trinity National Forest.

PG&E alternative condition 25 proposed revisions to the schedule for preparation

and implementation of the Vegetation and Invasive Weed Management Plan and the

language of a few of the plan’s elements. PG&E alternative condition 25 would provide

a period of 2 years to develop the Vegetation Management Plan, which is consistent with

PG&E’s original proposal. Additionally, PG&E would limit culturally significant plant

species to those species associated with TCPs and limit invasive weed species to those on

a list of high priority species, to be developed in consultation with the Forest Service,

FWS, NMFS, and other agencies, as appropriate.

Forest Service modified condition 25 specifies provisions similar to those in the

Forest Service’s original condition 25, except that specific details of the plan components

and monitoring schedules from the 4(e) condition have been placed in the draft

Vegetation and Invasive Weed Management Plan, included as an enclosure to the filing

(Forest Service, 2010d, Enclosure 3), with some modifications. PG&E filed comments

supporting Forest Service modified condition 25 and withdrawing its alternative

condition 25.

We recommend finalization and implementation of a Vegetation and Invasive

Weed Management Plan as specified by Forest Service modified condition 25, with

modifications as described below. Because the Forest Service and PG&E have worked

collaboratively on the draft Vegetation and Invasive Weed Management Plan and it is

substantially complete, we expect that 1 year would be adequate time to finalize and

implement the plan. We recommend the inclusion of language in the plan clarifying that

for special status plant species, PG&E would inform managers of sensitive or rare species

locations. Additionally, surveys of known culturally significant plant species not
391

associated with TCPs should be conducted within the first year of plan approval and

every 5 years thereafter, to be consistent with other vegetation surveys and protect these

revegetation source populations. PG&E should also create an operations map with

revegetation source population locations, including culturally significant plant

populations not associated with TCPs. Furthermore, we recommend the inclusion of

language to address the use of BMPs to avoid/minimize effects on wetlands.

Application of pesticides and herbicides on Forest Service lands within the project

area may occur as treatment or control methods for invasive weed species, as contained

within the proposed Vegetation and Invasive Weed Management Plan. However, Forest

Service condition 15 requires PG&E to exclude the use of pesticides and herbicides on

NFS land, unless prior written approval is received first from the Forest Service. We

recommend the incorporation of parameters into the guidelines in the Vegetation and

Invasive Weed Management Plan regarding the use of pesticides and herbicides

associated with future project O&M. For example, application of herbicides for the

purpose of eliminating vegetation to meet federal safety regulations would be acceptable

in specific areas such as dam groins, under penstocks, around switchyards, and adjacent

to project hydropower facilities. Similarly, selective application of herbicides to weeds

would be a reasonable approach to prevent obstruction of project transmission or

distribution lines. BMPs should be established in the Vegetation and Invasive Weed

Management Plan, for implementation should the use of pesticides or herbicides be

employed in these limited applications. Special precautions should be implemented for

any herbicide application, particularly in any situation that may involve the use of an

herbicide to control invasive plant species near water, on vegetation in highly used

recreation sites, near riparian areas or wetlands, or near areas containing special status or

culturally significant plant species, due to the sensitivity of these systems and associated

biota. Emphasis should be placed on the use of non-herbicide techniques, and allow for

herbicide use, if any, only at specific sites. For these specific sites, the plan should

indicate why other techniques would not be effective and identify special precautions that

would be taken to protect non-target plants. Additionally, techniques and plans for the

application of pesticides and herbicides should be approved by a licensed pest control

advisor.

We consider the proposed staff alternative measure for managing vegetation,

controlling the spread of noxious weeds, monitoring and protecting culturally significant

plant species, and limiting the use of pesticides and herbicides to represent an effective

approach to minimizing and avoiding project-related effects on vegetation and the

wildlife that depend on this vegetation for habitat. We estimate that PG&E’s proposed

plan would have an annualized cost of $332,000, and that our recommended approach

would have an annualized cost of $337,000. Given the added benefits of implementing

the staff-recommended alternative as described above, we consider this cost to be

warranted.
392

Terrestrial Wildlife Management and Monitoring

Project O&M activities at existing project facilities and proposed new construction

sites may generate short-term disturbances to general wildlife species. Isolated, shortterm disturbances may occur to wildlife as a result of activities associated with project

O&M activities tasks and could cause mobile wildlife species to leave an area until tasks

are completed. Less mobile species may, on occasion, incur direct mortality as a result of

actions such as trampling and those related to vegetation management.

PG&E proposed to develop a Wildlife Management Plan that would provide

protection and monitoring of special status species, but also would protect the habitat and

general wildlife populations that co-exist with special status species. PG&E’s proposed

Wildlife Management Plan would contain monitoring methodologies, pre-construction

survey protocols, and avoidance and protection measures as appropriate for special status

species. The Wildlife Management Plan proposed by PG&E also would include a

process and schedule for reporting survey and monitoring results as well as a process for

periodic plan review and revision. PG&E also proposed an avian hazard reduction

measure to ensure transmission and distribution lines meet bird electrocution prevention

standards as recommended by APLIC.

In its original condition 26, the Forest Service specified development and

implementation of a Terrestrial Biological Management Plan37 that would include:

(1) monitoring of populations and locations occupied by special status species;

(2) periodic surveys throughout the term of the license within the project and projectaffected area to determine the location of any additional populations; and (3) reporting

every 5 years (or at species-specific frequencies identified by the Forest Service) of

terrestrial survey and monitoring results. In its original condition 26, the Forest Service

also specified pre- and post-construction surveys for Forest Service special status species

along with post-disturbance and construction monitoring to identify whether mitigation

measures are necessary. The Forest Service specified that PG&E conduct surveys for

neotropical breeding birds within suitable habitat prior to disturbance activities or

observe annual limited operating periods during April 1through August 30. Furthermore,

within 1 year of license issuance, PG&E would be required to file with the Commission

an avian collision and electrocution hazards plan approved by the Forest Service, in

consultation with appropriate federal and state agencies, which minimizes adverse

interactions between project transmission lines and avian species.

PG&E alternative condition 26 addressed the schedule for preparation and

implementation of the Terrestrial Biological Management Plan and specific elements of

37 While PG&E proposes to develop a Wildlife Management Plan and Forest

Service condition 26 refers to a Terrestrial Biological Management Plan, we note that

these two plans are meant to address the same issues and the names are generally

interchangeable.
393

the plan. PG&E alternative condition 26 would provide a period of 2 years to develop

the Terrestrial Biological Management Plan, consistent with PG&E’s original proposal.

Survey areas where access is unsafe (steep terrain or high water flows) or private

property for which PG&E does not have access would be excluded. In addition, instead

of developing a plan, avian collision and electrocution hazards would be addressed by

upgrading segments of existing distribution lines that do not currently meet the APLIC

standards within 3 years of license issuance and ensuring that new lines would meet

current APLIC standards. If existing and new poles are brought into compliance with

APLIC standards, an avian hazard and electrocution plan would be unnecessary.

Forest Service modified condition 26 specifies provisions similar to those in the

Forest Service’s original condition 26, except that specific details of the plan components

and monitoring schedules from the 4(e) condition have been placed in the draft

Terrestrial Biological Management Plan, included as an enclosure to the filing (Forest

Service, 2010d, Enclosure 3), with some modifications. PG&E filed comments

supporting Forest Service modified condition 26 and withdrawing its alternative

condition 26.

Forest Service modified condition 27 specifies that PG&E move the northwestern

pond turtle and foothill yellow-legged frog into the Aquatic Biological Monitoring Plan,

rather than including these species in the Terrestrial Biological Management Plan.

PG&E filed comments supporting Forest Service modified condition 27 and withdrawing

its alternative condition 27.

We recommend finalization and implementation of a Terrestrial Biological

Management Plan, as specified by Forest Service modified condition 26, with

modifications, as described below. Because the Forest Service and PG&E have worked

collaboratively on the draft Terrestrial Biological Management Plan and it is substantially

complete, we expect that 1 year would be adequate time to finalize and implement the

plan.

The Forest Service specifies in modified condition 27 that the northwestern pond

turtle and foothill yellow-legged frog be included in the Aquatic Biological Management

Plan. We recommend, for clarity, that both species be included in the Aquatic Biological

Management Plan. However, the northwestern pond turtle and foothill yellow-legged

frog are discussed below because of their original inclusion within the Terrestrial

Biological Management Plan.

Surveys for known populations of the Shasta salamander and northwestern pond

turtle, along with any required pre-construction surveys, would provide information on

the existing populations of these special status species and their overall condition, and

minimize any potential effects to these species from project O&M and construction

activities. Surveys for known populations within 1 year of license issuance and every 5

years thereafter would provide a baseline status assessment of existing populations and be

more protective of these existing populations than the schedules recommended by the

Forest Service in the draft Terrestrial Biological Management Plan and Aquatic
394

Biological Management Plan. Surveys of suitable habitat within the first year of license

issuance and every 10 years thereafter, and adaptation of management to include new

species or populations that are detected would ensure protection of potential future

populations of Shasta salamander, foothill yellow-legged frog, and northwestern pond

turtle within the project area for the term of the license. These survey schedules would

also be consistent with those for other special status species, as discussed below. The

Forest Service has not provided justification for the monitoring of foothill yellow-legged

frog on NFS lands along the Lower McCloud River, where habitat is not suitable for this

species. We recommend that surveys for foothill yellow-legged frog exclude the NFS

lands along the Lower McCloud River and include tributaries to the Pit 6 and Pit 7

reservoirs if the foothill yellow-legged frog becomes established in the Pit 5 reach and the

likelihood of its presence in the McCloud-Pit Project area increases. We do recommend

the Foothill Yellow-Legged Frog Monitoring Plan, as proposed by the Forest Service in

its 10(a) recommendation in the draft Aquatic Biological Management Plan.

In the draft Terrestrial Biological Management Plan, filed as an enclosure to

modified condition 26, the Forest Service recommends modifications to limited operating

periods and monitoring schedules for bird species. For the bald eagle, American

peregrine falcon, northern goshawk, and Southwestern willow flycatcher, we recommend

that the following modifications be incorporated into the Terrestrial Biological

Management Plan:

 Surveys for bald eagle populations would occur annually at known nest sites

and in suitable habitat annually. This modification would provide more

protection than surveying annually for known populations and within 1 year of

plan approval and every 10 years thereafter in suitable habitat.

 Surveys for American peregrine falcon would occur within 1 year of plan

approval and every fifth year thereafter at known nest sites and within suitable

habitat. These modifications would provide more protection than surveying

annually for known populations and within 1 year of plan approval and every

10 years thereafter in suitable habitat.

 Northern goshawk surveys would occur within 0.5 mile of proposed

construction or a limited operating period of February 1 through August 15

would be implemented, as an alternative to monitoring once per 10 years.

 The limited operating period for willow flycatcher would be April 1 through

August 31 rather than May 1 through August 1, and surveys for suitable habitat

would occur within the first year after plan approval and every fifth year. This

is an alternative to surveying for known populations within 1 year and at 6

years after plan approval and every 10 years thereafter and in suitable habitat

within 1 year of plan approval and every 10 years thereafter. These

modifications would provide adequate protection for this species.
395

 The limited operating period for neotropical breeding birds would be April 1

through August 31 rather than May 1 through August 1 and only preconstruction surveys would be required. These modifications would provide

adequate protection for these species.

Details defining precise locations for surveys to occur should be a component of

consultation with the Forest Service and other appropriate agencies and interested parties

during the development of the Terrestrial Biological Management Plan.

We recommend the inclusion of alternative language in the Terrestrial Biological

Management Plan clarifying that special status bat species surveys, for both known

populations and for new populations in suitable habitat, would begin within the first year

after plan approval and every fifth year thereafter. Additionally, the limited operating

period would be during the maternity period of May 1 to August 31, rather than between

May 1 and August 1. This clarified approach would be sufficient to assess the presence

and roosting use of project facilities within the project area, and pre-construction surveys

of implementation of the limited operating period would provide the necessary interim

prevention measure if disturbance from construction were probable. Sites would be

identified in consultation with participating agencies, and this alternative language would

provide a good mechanism for continued communication with agencies on the presence

and status of bat species within the project area.

Additionally, we recommend the inclusion of alternative language in the

Terrestrial Biological Management Plan clarifying that surveys for known populations of

special status terrestrial mollusks would begin within the first year of plan approval and

every fifth year thereafter. This clarified approach would be more protective of these

special status species than the Forest Service’s recommended schedule of known

population surveys within one and at 6 years after plan approval and every 10 years

thereafter.

We consider the proposed staff alternative measure for monitoring and mitigating

project effects on wildlife to represent an effective approach to minimize and avoid

project-related effects on wildlife, including special status species. We estimate that our

recommended approach would have an annualized cost of $198,000. Given the benefits

of implementing the staff-recommended alternative as described above and the projected

cost savings associated with the staff-recommended alternative, we consider this cost to

be warranted.

Threatened and Endangered Species

The VELB, Pacific fisher, and northern spotted owl are federally-listed threatened

and endangered species that might occur within the project area and could potentially be

affected by project O&M and any proposed construction measures. In order to protect

threatened and endangered species, which are also listed as Forest Service sensitive

species, PG&E proposed to prepare a biological evaluation of the potential effects to

Forest Service special status species prior to any action to construct project features on
396

NFS lands. In addition, specific measures for protection of elderberry are specified in the

PG&E’s programmatic biological opinion and incidental take permit (FWS, 2003);

PG&E would apply these measures to routine O&M activities, including development

and maintenance of recreational areas.

In its original condition 26, the Forest Service specified components particular to

the VELB, specifically that known suitable habitat should be monitored once every

5 years for VELB individuals, and if the species is detected, elderberry plants would be

protected from disturbance. Regarding the northern spotted owl, the Forest Service’s

original condition 26 would require monitoring for this species within 0.25 mile of

suitable habitat in the project area once every 5 years. Surveys conducted once every

10 years in suitable habitat would identify new individuals, pairs, or nest sites. Surveys

also would be conducted prior to any disturbance activities, or PG&E could schedule

construction or disturbance activities outside of the limited operating period of February

1 through July 9. Regarding the Pacific fisher, the Forest Service’s original condition 26

specifies that the Terrestrial Biological Management Plan should provide for surveys to

be conducted once every 5 years in suitable habitat within the project and project-affected

areas.

Forest Service condition 11 specifies that PG&E prepare a biological evaluation

prior to any proposed action to construct project features on NFS lands. This measure is

consistent with PG&E’s proposed measure. NMFS and FWS also recommend that

PG&E prepare a biological evaluation or biological assessment prior to construction of

new project features or non-routine maintenance activities that may affect special status

species or their habitats.

PG&E alternative condition 26 proposed alternative language that provides more

specificity to the monitoring schedule and survey area designations specified by the

Forest Service. PG&E alternative condition 26 proposed:

 Pre-construction surveys for the presence of elderberry shrubs would be

conducted for construction proposed below 3,000 feet msl in the project area,

and a 100-foot protective buffer would be provided around any identified

VELB habitat during construction consistent with the FWS biological opinion

for VELB. Monitoring surveys also would be conducted in areas of known

VELB habitat every 5 years, concurrently with noxious weed and vegetation

surveys.

 Pre-construction surveys for the presence of northern spotted owl would be

conducted in suitable habitat within 1.3 miles of proposed construction.

Surveys would follow standard protocols for the species. Alternatively, PG&E

could schedule construction activity for outside of the limited operating period

of February 1 to July 9.

 Pre-construction surveys for the presence of Pacific fisher would occur in areas

of suitable habitat within 0.5 mile of any planned construction.
397

Forest Service modified condition 26 specifies provisions for threatened and

endangered species similar to those in the Forest Service’s original condition 26, except

that specific details of the original plan components and monitoring schedules from the

4(e) condition have now been placed in the draft Terrestrial Biological Management Plan

and included with some modifications as an enclosure to the filing (Forest Service,

2010d, Enclosure 3). In particular, the Forest Service has modified its original

recommendation to reflect our staff recommendation to remove specified protective

measures for the VELB from the draft Terrestrial Biological Management Plan and

include them as part of the Vegetation and Invasive Weed Management Plan. In the

Forest Service modified condition, surveys for VELB populations are no longer required;

only habitat surveys for elderberry plants and pre-construction surveys below 3,000 feet

msl. This is consistent with our recommendation that the range of elderberry growth is

limited by elevation, so maintaining surveys below 3,000 feet msl is adequate for preconstruction surveys.

In addition, the Forest Service has specified the inclusion of a new survey for the

VELB that was not part of our original recommendation. The original staff

recommendation requires pre-construction surveys and monitoring of known populations

within the first year of license issuance and every 5 years thereafter. Forest Service

modified condition 26 agrees with this recommendation, but also specifies an additional

comprehensive survey for all populations of elderberry plants within 1 year and every

10 years thereafter. This comprehensive survey would provide more protection and

greatly minimize any potential effects to elderberry populations. PG&E filed comments

supporting Forest Service modified condition 26 and withdrawing its alternative

condition 26. We recommend Forest Service modified condition 26 and its inclusion

within the Vegetation and Invasive Weed Management Plan.

We recommend implementing Forest Service condition 11, but modify it to

include all project lands. This would require biological evaluations for Forest Service

special status species on all project lands when constructing new facilities, instead of just

NFS lands as specified by the Forest Service, as well as requiring biological assessments

for federally threatened or endangered species, and would allow for more comprehensive

protection of the species.

We recommend the inclusion of language in the Terrestrial Biological

Management Plan clarifying that, at a minimum, pre-construction surveys or a limited

operating period of February 1 through July 9 should be implemented for the northern

spotted owl, per our staff recommendation in the draft EIS. Although potential habitat

for the northern spotted owl exists, no individuals are known to be present within the

project area and we expect that pre-construction surveys would sufficiently minimize any

potential construction-related effects from disturbance. Alternatively, avoidance of

construction activity during the limited operation period also would protect any

individuals within the project area from construction activity. Additionally, we agree

with the Forest Service’s recommendation that PG&E would follow the FWS guidance

for northern spotted owl surveys.
398

Potential habitat for the Pacific fisher exists within the project boundary, and

while no individuals were located during PG&E’s relicensing surveys, the Forest Service

and FWS have identified the Pacific fisher as potentially occurring in the project vicinity

based on tracks reported in the project vicinity in 1982, and a Pacific fisher skull found

on the ridge between Fisher Creek and Bald Mountain Creek in the mid-1970s. More

recently, a wildlife biologist observed a Pacific fisher crossing FR 11 on the northeast

side of Iron Canyon reservoir on April 25, 2007. As such, we conclude that the species

most likely is present within the project area. Due to the lack of known individuals, it is

unlikely that normal project O&M activity or proposed construction would have an effect

on the Pacific fisher. The Forest Service has changed its recommendation to agree with

the staff recommendation from the draft EIS regarding pre-construction surveys for the

Pacific fisher. For the construction associated with the proposed additional generation

units, pre-construction surveys would provide adequate protection for the potential

habitat that may occur within the project area.

We consider the staff alternative measure for monitoring and mitigating project

effects on federally-listed wildlife species to represent an effective approach to

minimizing and avoiding project-related effects. Costs for the proposed plans described

above are included in the estimates for the Terrestrial Biological Management Plan, in

section 5.2.1, Discussion of Key Issues, Terrestrial Resources. Given the benefits of

implementing the staff-recommended alternative as described above, we consider this

cost to be warranted.

In the draft EIS, we concluded that relicensing of the McCloud-Pit Project, as

described under the staff alternative, was not to likely adversely affect the VELB, Pacific

fisher, and northern spotted owl. On August 6, 2010, we issued a letter seeking

concurrence from FWS on this determination.

By letter dated December 21, 2010, FWS responded to our request for

concurrence, regarding effects of the proposed action on the VELB, northern spotted owl,

and Pacific fisher. FWS states that it is not necessary to reanalyze the effects of the

proposed action on the VELB, because the FWS biological opinion (11-01-F-0114)

(FWS, 2003) addressed the potential effects of project O&M, which are anticipated to be

the same for the proposed action. FWS provides guidance for protection of the northern

spotted owl within the project area and concurs with the Commission’s determination that

the proposed issuance of a new license is not likely to adversely affect the owl or critical

habitat. FWS also concurs with the Commission’s determination that the proposed

issuance of a new license is not likely to adversely affect the Pacific fisher.

Recreation Resources

Recreational Access to Lower McCloud River Flows

Recreational access on the Lower McCloud River is limited due to the amount of

public lands located along the Lower McCloud River. The area immediately below

McCloud dam and NFS lands, specifically at Ash Camp, Ah-Di-Na Campground, and the
399

river corridor between these facilities, currently provide the only public access for both

boaters and anglers on this 24-mile stretch of the river from McCloud dam to Shasta

Lake. The remainder of the land located along the Lower McCloud River, except for

The Nature Conservancy’s McCloud River Preserve which is used by some anglers, is

privately owned. In addition to the base of McCloud dam, Ash Camp and Ah-Di-Na

Campground are the origin of whitewater boat trips on the Lower McCloud River,

however there is no public take-out for boaters below Ah-Di-Na Campground until they

reach Shasta Lake, located 24 miles below McCloud dam.

Numerous comments filed and raised at the public meetings on the draft EIS were

related to the inability of recreationists to access the Lower McCloud River during the

early spring for the purpose of whitewater boating. Most of the recommended minimum

flow regimes for this reach would provide higher flows for recreational boaters than

currently exist; however, these higher minimum streamflows would occur during the

early spring months when the roads to Ah-Di-Na Campground and Ash Camp are

generally inaccessible due to snow. For this reason, a number of commenters

recommend that PG&E be responsible for snow plowing the roads below McCloud dam

to provide recreational access to the Lower McCloud River flows.

Ash Camp and Ah-Di-Na Campground are both Forest Service recreation facilities

located about 1 mile outside the existing project boundary and are not currently used for

project purposes. Although Ash Camp and Ah-Di-Na Campground provide access to

recreational flows on the Lower McCloud River, PG&E proposes to provide access at the

base of McCloud dam by constructing a day-use area and a whitewater boater put-in.

Although the Forest Service suggests that recreation development cannot be

accommodated at the base of McCloud dam, PG&E states that it is premature to make

that determination because there is uncertainty about how and where gravel augmentation

and LWD placement would be implemented. Forest Service has modified its condition

30 to specify that if the site at the base of McCloud dam is infeasible for the day-use site,

then PG&E would construct recreational access facilities at Ash Camp and include it

within the project boundary or within a settlement agreement with the Forest Service for

non-project facilities. A separate settlement agreement, executed between PG&E and the

Forest Service, would address O&M of non-project recreation facilities (specifically, Ash

Camp, Ah-Di-Na Campground, and the Lower McCloud River Trail) and roads in the

Shasta-Trinity National Forest, including Ash Camp (FR U38N11Y) and Ah-Di-Na

(FR 38N53) roads.

By developing a boater put-in at the base of the dam, boaters would have access to

the Lower McCloud River within the project where access currently does not exist.

Because Ash Camp and Ah-Di-Na campground are Forest Service-owned and operated, it

is reasonable to assume the Forest Service will continue to operate and maintain them and

the roads to access these sites throughout a new license term. Therefore, we do not

recommend PG&E be responsible for snow plowing the roads to Ah-Di-Na Campground

and Ash Camp below McCloud dam, nor do we recommend these facilities be brought
400

into the project boundary as project recreation facilities. If the recreation needs change

during the term of the license, Standard Article 15 of a new license provides the

mechanism for the Commission to reopen the license to require additional recreation

measures.

Fish Stocking

One of the primary recreational activities associated with the project includes

angling and, based on recreation studies completed during the relicensing process, the

demand for angling at the project is projected to increase over the term of a new license.

In addition, the numerous proposed recreation facility upgrades and construction of new

recreation facilities have the potential to result in increased angling pressure at the

project. PG&E originally proposed to continue funding California Fish and Game for the

stocking of up to 38,800 pounds of trout and 500,000 kokanee per fiscal year (July 1

through June 30) in the drainages of the Pit and McCloud Rivers below the uppermost

project reservoir thereon and in Shasta Lake. In contrast, California Fish and Game, in its

10(j) recommendation, recommends that PG&E reimburse California Fish and Game for

stocking of up to 60,000 pounds of trout annually within the McCloud-Pit Project

boundary and that costs would be assessed at the standard rate for catchable-sized

hatchery grown trout in the year of stocking. In addition, California Fish and Game

recommends that PG&E, if requested by California Fish and Game, pay $5,000 annually

for monitoring and evaluation of the fish stocking program or for mitigation of sturgeon

reintroduction into Shasta Lake. In its response comments, PG&E states that it agrees

with California Fish and Game’s fish stocking 10(j) recommendation

In 1942, the construction of Shasta dam isolated a population of white sturgeon;

however, the population was self-sustaining in the Pit River arm of Shasta Lake until

experiencing a decline in the 1970s and 1980s. California Fish and Game began an

experimental sturgeon planting program early in 1988 to evaluate stocking as a means of

restoring the sturgeon fishery; however, the program was discontinued later that year due

to disease problems in the rearing facilities.38 California Fish and Game states that

1.8 percent of the planted sturgeon were caught or observed from 13 months to 13 years

after stocking, indicating that low natural recruitment may be the cause of the sturgeon

population decline.39 California Fish and Game further suggests that the construction of

Pit 6 and 7 dams in the early 1960s, which eliminated access to 16 miles of stream likely

utilized by white sturgeon during spawning, likely caused the decline. There is no

conclusive evidence, however, that the loss of riverine habitat, or any project-related

effects, is directly correlated to the low recruitment of white sturgeon.

38 Licensee’s Pre-Application Document.

39 California Fish and Game. 10(j) Recommendations for the McCloud-Pit

Hydroelectric Project. January 28, 2010.
401

Increasing the number of fish stocked at the project would help meet the estimated

future demand for angling at the project. Furthermore, annual monitoring and evaluation

of the fish stocking program would provide the means for coordinated development to

allow for the flexibility to increase or decrease stocking numbers over the term of a new

license in order to meet future demand for angling. However, consistent with

Commission policy to recommend a specific environmental measure for inclusion in a

license, we must be assured that the measure relates to project impacts or project

purposes.

40 At this time, and given low natural recruitment and the problems associated

with the previous sturgeon planting program, it is not clear how $5,000 would be used to

implement a mitigation program that would successfully maintain a white sturgeon

population in Shasta Lake. Furthermore, it also is not clear at this time how the $5,000

would be used to monitor and evaluate the fish stocking program and we have no way of

knowing if these funds would be used solely to evaluate the program at the project. Thus,

we do not recommend that PG&E provide funding for white sturgeon mitigation.

While PG&E agrees to reimburse California Fish and Game for fish stocking, we

note that PG&E is ultimately responsible for the management of all project reservoirs and

project reaches. Instead of recommending funding for California Fish and Game, we

recommend PG&E be responsible for stocking 60,000 pounds of trout annually within

the project boundary and develop a fish stocking plan to evaluate and monitor the amount

of fish to be stocked every 6 years. Accordingly, the number of pounds of fish to be

stocked could fluctuate up or down on a 6-year cycle depending on monitoring results.

We estimate that the annualized cost of developing and implementing this plan would be

$117,000, and we conclude that the benefits of this measure warrant the cost.

Recreation Management Plan

PG&E proposes to finalize the Recreation Development and Management Plan

(Recreation Plan) after consultation with the Forest Service, California Fish and Game,

California Water Board, and other interested parties, within 2 years of license issuance.

Including Native American representatives, conditioning agencies (Forest Service,

California Water Board, and NOAA), American Whitewater, and Friends of the River

during the development of the Recreation Plan would better inform the development of

the Recreation Plan. We recommend PG&E consult with all of the aforementioned

parties during the development of the Recreation Plan.

In addition, PG&E proposes to construct new recreation facilities and reconstruct

existing project recreation facilities within 5 years of Commission approval of the

Recreation Plan and to replace each facility in-kind or with an appropriate upgraded

facility within 25 years of license issuance or the mid-point of the license term.

40 For more information regarding the Commission’s policy, please see the

Commission’s Policy Statement on Hydroelectric Licensing Settlements, issued

September 21, 2006.
402

Recreation facilities and infrastructure could be become degraded over the term of the

license; however, all facilities may not need to be reconstructed near mid-license term as

proposed by PG&E or recommended by the Forest Service. To ensure that recreation

facilities and infrastructure would continue to provide safe, reliable public access to

recreational opportunities at the project and would address growing recreational demand

over the term of the new license, we recommend that PG&E reevaluate as part of the

recreation monitoring component of the Recreation Plan the facilities for degradation at

mid-license term or 25 years, whichever is greater.

PG&E’s proposal would allow the Forest Service and other stakeholders to have

input in the development of these plans and would ensure the proposed measures would

be implemented in a manner consistent with the Forest Service’s management goals and

other resource management plans at the project. Although coordination among PG&E,

governmental agencies, and interested stakeholders is encouraged in development and

implementation of the proposed recreation measures, PG&E is ultimately responsible for

the construction, operation, and maintenance of the project’s recreation facilities upon

license issuance. The specific measures are discussed in more detail below.

McCloud Reservoir

PG&E’s proposal to construct a day-use area, reconstruct and extend the existing

one-lane boat ramp to 3 feet (vertical) below the minimum operating pool elevation, and

add more parking spaces at Tarantula Gulch boat ramp would help relieve overcrowding

and reduce user conflicts at McCloud reservoir. Demand for boating access coupled with

crowding issues at McCloud reservoir demonstrates the need for improved recreational

boating access at the project. The Forest Service specifies in modified condition 30 that

PG&E reconstruct the Tarantula Gulch boat ramp to provide two lanes, instead of one,

and originally specified a minimum of a 4-foot draft clearance below minimal pool level

to further reduce crowding at the ramp and include 30-40 total parking spaces. However,

PG&E states that site constraints may affect the amount and type of improvements that

can be made to project recreation facilities. Constructing additional parking spaces as the

site will allow and the proposed day-use area would provide increased parking to

accommodate increased recreational use during the term of a new license and provide a

designated area for day-use that would help reduce user conflicts at the boat ramp.

Currently the bottom of the boat ramp is 1 foot below the normal minimum operating

reservoir level (elevation 2,634 feet msl) and typically provides boater access during

most of the recreation season. Reconstructing the boat ramp to a 3-foot draft clearance,

as proposed by PG&E, would provide even greater access and extend the current

recreation boating season. We recommend that PG&E reconstruct the Tarantula Gulch

boat ramp with the toe of the ramp extending to an elevation no less than three vertical

feet below minimum pool and that the boat ramp remain one lane. We also recommend

that PG&E construct additional parking spaces as the site will allow and the proposed

day-use area.
403

In its original condition 30, the Forest Service specified that PG&E provide

lighting and snow plowing between April 1 and December 1 at the Tarantula Gulch boat

ramp to provide safety for anglers fishing early or late in the day and to improve access at

the ramp. Forest Service modified condition 30 does not specify these measures, but they

are recommended in the draft Recreation Development Management Plan included as an

enclosure to modified condition 30. Lighting would improve safety at the boat ramp and

allow anglers to fish longer during the recreation season; however, there is little evidence

to support snow plowing the ramp in the shoulder months when PG&E does not need

access to the boat ramp for project purposes. Although 10 percent of visitors reported use

of the reservoir during the winter and expressed the need for a longer use season, there is

not enough use at McCloud reservoir during the shoulder and winter months to warrant

the Forest Service’s specified snow plowing. We recommend, however, that PG&E

provide lighting at the Tarantula Gulch boat ramp, which will allow anglers to fish longer

by providing light during longer periods of the day.

PG&E proposes and Forest Service specifies that PG&E construct day-use areas at

Red Banks and Tarantula Gulch inlet and access sites at Battle Creek and on both sides of

McCloud dam to provide additional day-use areas and shoreline access at McCloud

reservoir. Constructing additional day-use areas at Red Banks and Tarantula Gulch inlet

and access sites at Battle Creek and on both sides of McCloud dam would help relieve

overcrowding and reduce user conflicts at Tarantula Gulch boat ramp by providing

recreation users with other access areas to McCloud reservoir. Moreover, constructing a

floating fishing/swimming platform at one of the proposed day-use areas would

potentially alleviate overcrowding and user conflicts even further. We recommend that

PG&E construct day-use areas at Red Banks and Tarantula Gulch inlet, a floating

fishing/swimming platform at one of the proposed day-use areas, and access sites at

Battle Creek and on both sides of McCloud dam.

There are no existing campgrounds at McCloud reservoir to meet existing or

projected demand for overnight use; however, regular dispersed camping is occurring at

Star City. PG&E’s suitability assessment shows the only potential site to accommodate

camping at the reservoir is at Star City. Providing a formal campground and day-use area

at this location, as proposed by PG&E and specified by the Forest Service, would help

manage the already existing use and reduce negative impacts on natural resources by

eliminating erosion and soil compaction from user-created trails and vehicles from

dispersed camping and provide for proper sanitation disposal and trash removal. We

recommend that PG&E develop a campground and day-use area at Star City; however, if

PG&E is unable to secure the use of the land at the site, we recommend that PG&E at

that time file a plan with the Commission for approval for a different campground

location at McCloud reservoir.

We estimate that the annualized cost of implementing these recreation measures at

McCloud reservoir would be $1,860,000 and we conclude that the benefits associated

with maintaining existing recreation facilities and expanding recreational opportunities at

McCloud reservoir would be worth this cost.
404

Lower McCloud River

Constructing a day-use site and designing an access trail to accommodate both

fishing and boating access at the Lower McCloud River, as proposed by PG&E and

specified by Forest Service modified condition 30, would facilitate the use of the area by

both anglers and boaters.

Forest Service original condition 30 and 30a specified that PG&E upgrade the

user-created river trail from Ash Camp Campground to Ah-Di-Na Campground and, if

agreement with PG&E was not reached outside the license, reconstruct and provide

O&M over the term of the license for Ash Camp and Ah-Di-Na Campground. PG&E

does not propose to upgrade and maintain the Lower McCloud river trail nor does it

propose to reconstruct, operate, and maintain the Ash Camp and Ah-Di-Na Campground

because these are not project facilities. Although upgrading the existing trail along the

Lower McCloud River from Ash Camp Campground at the Ash Camp bridge/PCT

junction to Ah-Di-Na Campground would improve access, our review does not lead us to

conclude that the existing user-created trail or the campgrounds are project facilities. The

Forest Service trail and campgrounds are located outside the project boundary a mile or

more from the project. The trail and campgrounds are not used for project purposes and

do not provide access to the project lands or waters. A separate settlement agreement,

executed between PG&E and the Forest Service and filed with the Commission on

December 14, 2010, addresses O&M of non-project recreation facilities (specifically,

Ash Camp, Ah-Di-Na Campground, and the Lower McCloud River Trail) and roads in

the Shasta-Trinity National Forest, including Ash Camp (FR U38N11Y) and Ah-Di-Na

(FR 38N53) roads.

We recommend PG&E construct a day-use facility at the base of McCloud dam.

We estimate that the annualized cost of implementing this recreation measure at this

location would be $90,000, and we conclude that the benefits associated with expanding

recreational opportunities below McCloud dam would be worth this cost. For reasons

noted above, we are not recommending upgrading the trail from Ash Camp to Ah-Di-Na

and the reconstruction, operation, and maintenance of the Ash Camp and Ah-Di-Na

Campground.

Iron Canyon Reservoir

PG&E proposes to reconstruct Hawkins Landing boat ramp and campground, and

provide additional parking and restroom facilities, which would enhance recreational

opportunities at Iron Canyon reservoir and ensure that the project recreation facilities

meet current and future demand over the term of a new license. In addition, constructing

a new boat ramp at Iron Canyon reservoir and providing additional shoreline access

areas, also proposed by PG&E and specified by Forest Service modified condition 30,

would increase boating access at the reservoir and help alleviate dispersed recreation use

occurring along the shoreline. The Forest Service’s original and modified condition 30

further specified that PG&E provide three reservoir access sites that include surfaced

parking and trail to the reservoir. In PG&E alternative condition 30, PG&E PG&E would
405

conduct a site evaluation and construct the paved parking areas with pedestrian shoreline

access trails. Constructing the proposed shoreline access areas with the addition of the

parking areas would provide developed access areas along the shoreline to help alleviate

some of the dispersed recreation use occurring along the reservoir shoreline.

We recommend that PG&E reconstruct the existing Hawkins Landing

campground and boat ramp and construct a new boat ramp at Iron Canyon reservoir that

is usable at the reservoir's minimum operating pool (2,593 feet msl). In addition, we

recommend PG&E construct three shoreline access areas that include paved parking with

pedestrian trails to the shoreline. Because the Forest Service has not provided suggested

locations for feasible sites, we recommend that PG&E conduct a site evaluation, as

proposed, within 90 days of license issuance to determine the locations for the three

shoreline access areas.

In its original condition 30, the Forest Service specified that, if possible under

reservoir operations, the Hawkins Landing boat ramp should be operable a minimum of

155 days during the recreation season and the new Iron Canyon reservoir boat ramp

should be functional at 90 percent of operational lake levels. PG&E’s proposal to

construct the new, additional Iron Canyon dam boat ramp so that it is usable at the

reservoir’s minimum operating pool (2,593 feet msl) would result in public boating

access to Iron Canyon reservoir over the entire recreation season and should accomplish

the level of use the Forest Service is seeking, although we note that Forest Service

modified condition 30 does not include these specifications for operational use of the

boat ramps. This additional boat ramp would help to alleviate overcrowding of the

existing Hawkins Landing boat ramp. As such, we recommend that PG&E reconstruct

the Hawkins Landing boat ramp and construct a new boat ramp at Iron Canyon dam that

is functional at the reservoir’s minimum operational lake levels (2,593 feet msl) during

the recreation season.

In its original condition 30, the Forest Service specified that PG&E relocate

Deadlun campground to one or two location(s) along the Iron Canyon reservoir shoreline

and provide a mix of single and group campsites with no less than a capacity of 200

people at one time total. Forest Service modified condition 30 specifies that PG&E

provide about the same minimum number of sites for overnight camping at Iron Canyon

as originally specified but that PG&E reconstruct Deadlun Campground to provide

double and triple campsites and construct an additional new campground at Gap Creek to

provide single unit sites. Because dispersed camping generally occurs along the main

body of Iron Canyon reservoir and the campground is currently located in a creek off the

main body of the reservoir, the Forest Service states that relocating Deadlun Campground

to a more desirable location would likely increase the use of this facility. The new Gap

Creek site would be located along the main body of the reservoir in a more desirable

location. PG&E states that poor facility conditions and upkeep of the campground may

contribute to the prevalence of dispersed sites around the reservoir. As a result, PG&E

originally proposed to reconstruct Deadlun Campground. PG&E alternative condition

30, however, proposes conducting a site assessment to determine if there are one or more
406

suitable sites to relocate the existing Deadlun Campground along the Iron Canyon

reservoir shoreline. If agreement can be reached on alternate location(s), PG&E would

construct a new campground at the new location(s). If a suitable location(s) does not

exist, however, PG&E would reconstruct the campground in its current location with

access to the reservoir shoreline.

In its license application, PG&E identified 22 dispersed recreation sites around

Iron Canyon reservoir with heavily used dispersed recreation sites at the areas adjacent to

Deadlun Campground. In the draft EIS, staff recommended PG&E reconstruct Deadlun

Campground and provide access to the shoreline to improve camping opportunities at the

reservoir. At that time, no other suitable sites to relocate the campground had been

identified. Forest Service’s specification in its modified condition 30 to reconstruct

Deadlun Campground as a group campground at its existing location and construct a new,

single-site campground at Gap Creek on the main body of Iron Canyon reservoir would

not only alleviate the issue of dispersed recreation sites adjacent to Deadlun

Campground, but it also would increase camping capacity at this popular project

reservoir. Further, providing formal access to Iron Canyon reservoir shoreline from both

Deadlun Campground and Gap Creek Campground would likely increase the use of this

reservoir, thereby increasing the need for more campsites. We recommend that PG&E

reconstruct Deadlun Campground to provide double and triple campsites with access to

the shoreline and construct a new campground at the Gap Creek site for single unit

campsites.

In its original condition 30, the Forest Service specified that PG&E provide

lighting at the new Iron Canyon dam boat ramp to ensure safety for anglers fishing early

or late in the day. The Forest Service does not include this specification in modified

condition 30, but it recommends in the draft Recreation Development and Management

Plan lighting at Iron Canyon dam boat ramp when the boat ramp is snow-free. Lighting

would allow anglers to fish longer during the recreation season and increase safety at the

boat ramp. Therefore, we recommend that PG&E provide lighting at the new boat ramp.

In its original condition 30, the Forest Service also specified that PG&E provide

snow removal at the Iron Canyon boat ramp during the shoulder season (March or April

through December) and at the new boat ramp when Oak Mountain access road and the

new Iron Canyon boat ramp surfaces are passable. PG&E alternative condition 30

proposes that PG&E would remove snow from the access road to the boat ramp, the boat

ramp, and parking area when project operations require snow removal from Oak

Mountain Road. Although winter use is minimal at this site, because PG&E would

already be plowing Oak Mountain Road, plowing the short access road, boat ramp, and

small parking area would not add much additional time or cost. In addition, it would

allow access to the boat ramp during the shoulder season, therefore extending the regular

recreation use season.
407

We estimate that the annualized cost of implementing these recreation measures at

Iron Canyon reservoir would be $1,851,000, and we conclude that the benefits associated

expanding recreational opportunities at Iron Canyon reservoir would be worth this cost.

Pit 6 and 7 Reservoir

In its original condition 30, the Forest Service specified that PG&E develop a

shoreline trail at Pit 6 reservoir if capacity or demand (based on 6-year recreation use

monitoring) indicates increased use of the reservoir for fishing or boating; however,

Forest Service modified condition 30 does not specify this trail. Providing access to the

river near Pit 6 and 7 reservoirs would improve recreational access at the project if there

is an increase in recreation use at the Pit 6 reservoir. This measure could be considered in

the future if the recreation use data collected every 6 years shows it is warranted.

Additionally, constructing the proposed river access trail at the upper end of Pit 7

reservoir and conducting a feasibility assessment for providing a hand-carry boat launch

at Montgomery Creek near the lower end of Pit 7 reservoir, as proposed by PG&E, would

enhance access to Pit 7 reservoir for existing pedestrian fishing and hand-launch boating.

Although Forest Service modified condition 30 specifies two surfaced parking areas with

reservoir access trails at the upper end of Pit 7 reservoir instead of the one that was

specified in original condition 30, the Forest Service has not provided any justification

for the additional access area and this additional access area does not seem to be

warranted at this time.

The Forest Service specifies that PG&E construct a boat put-in/take-out on the

lower end of Pit 7 reservoir at Montgomery Creek or near the dam. PG&E has expressed

concern for public safety if boating access is provided at the upper and lower portions of

Pit 7 reservoir due to riverine high flows from the Pit 6 powerhouse and riverine

conditions at low reservoir levels (fast flowing water) that could increase the likelihood

of boats overtopping the dam and prevent boaters from returning upstream to exit the

reservoir. PG&E further indicates in its comments on the draft EIS that it has thoroughly

investigated all potential options and determined that it is not feasible to provide safe and

secure public access to Pit 7 reservoir near the dam. Boating is prohibited within 500 feet

of the dam and PG&E is concerned that providing shoreline access may encourage

boating use which would create a concern for public safety. Although constructing a

hand-carry boat launch where Montgomery Creek enters Pit 7 reservoir or in the lower

portion of Pit 7 reservoir would increase boating and fishing access, it would not be

appropriate to launch boats at this location because of the public safety concerns raised

by PG&E. Therefore, we do not recommend PG&E conduct a feasibility assessment for

providing a hand-launch boat put-in where Montgomery Creek enters Pit 7 reservoir or

provide the hand-launch boat put-in.

We recommend that PG&E construct one parking area with river access trail at the

upper end of Pit 7 reservoir, conduct a site evaluation to determine the location for a

pedestrian shoreline river access trail with parking at the lower end of Pit 7 reservoir, and

provide a pedestrian shoreline river access trail with parking at the lower end of Pit 7
408

reservoir. We estimate that the annualized cost of implementing this recreation measure

at Pit 7 reservoir would be $17,000, and we conclude that the benefits associated with

providing additional pedestrian access at Pit 7 reservoir would be worth this cost.

Pit 7 Afterbay

PG&E does not propose any new recreation facilities at Pit 7 afterbay. Public

access to Pit 7 afterbay is currently restricted by PG&E for public safety reasons due to

the rapidly fluctuating water level and strong water current. Both fencing and warning

signs have been posted to prohibit shoreline and boating access. However, PG&E’s

proposal to reconstruct Fenders Flat day-use area (above Pit 7 afterbay dam), and if the

Pit 7 afterbay powerhouse is constructed, to provide access near the proposed Pit 7

afterbay powerhouse, with parking at the end of the powerhouse access road or along

Fenders Ferry Road, subject to public safety, would enhance recreational opportunities in

the vicinity of the afterbay by formalizing this existing dispersed recreation area.

Moreover, reconstructing the existing Forest Service Fenders Flat car-top boat launch

would provide boater access to the Pit arm of Shasta Lake during late winter and early

spring when high lake levels allow boat launching. Although not specified by the Forest

Service in its modified condition 30, providing shoreline access to the Pit River near the

proposed Pit 7 afterbay powerhouse, if the powerhouse is constructed, would provide a

formal shoreline access area for anglers in the vicinity of the Pit 7 afterbay that could

help discourage trespass at the Pit 7 afterbay dam where safety is an issue.

PG&E’s proposal to upgrade the existing recreation facilities in the vicinity of

Pit 7 afterbay and continue prohibiting public access to Pit 7 afterbay water surface by

maintaining fencing, signage, and patrols would help to ensure public safety at the

project. We recommend that PG&E reconstruct Fenders Flat day-use area and car-top

boat launch at Pit 7 afterbay and continue to prohibit public access to Pit 7 afterbay water

surface. We estimate that the annualized cost of implementing the recreation measures at

Pit 7 afterbay would be $437,000, and we conclude that the benefits would be worth this

cost. If the Pit 7 afterbay powerhouse is constructed, we recommend PG&E provide a

formal shoreline access area for anglers in the vicinity of the Pit 7 afterbay powerhouse

with parking. We estimate that the annualized cost of implementing this additional

recreation measures at Pit 7 afterbay would be $38,000, and we conclude that the benefits

would be worth this cost.

Recreation Monitoring

Recreation use at the project is expected to double over the next 50 years. The

level and type of recreation use and recreation user preferences could change over the

term of a new license. PG&E’s proposal of periodic monitoring of recreation use, user

preference surveys, assessment of facility capacity and recreation demand, and

inventorying areas used for dispersed recreation would help to determine if the project’s

recreation facilities provide adequate public recreation access and meet user demand over

the term of the license. In addition to PG&E’s proposal, the Forest Service recommends

in the draft Recreation Development and Management Plan and originally specified in
409

condition 30 that PG&E include monitoring of boat use during the recreation season as a

part of recreation monitoring efforts every 6 years. Monitoring boat use would help to

identify excessive use and potential user conflicts on the reservoirs. FERC Form 80

Recreation Report already requires facility capacity and demand to be reported every

6 years; however, the additional recreation report would provide more specific

information such as changes in use patterns and whether or not resource damage is

occurring. We recommend that PG&E implement recreation monitoring as a part of the

Recreation Plan for all project recreation facilities and file a monitoring report

concurrently with the FERC Form 80 schedule every 6 years after license issuance. We

estimate that the annualized cost of this measure would be $300,000 and conclude that

the benefits of this measure are worth the cost.

Reservoir Water Surface and Shoreline Management

PG&E originally proposed to clean debris from the McCloud reservoir boat ramp

and Iron Canyon reservoir water surface annually, weather permitting, and as needed

throughout the recreation season. In its original condition 30, the Forest Service

specified that PG&E conduct annual surface sweeps prior to the start of the recreation

season on both McCloud and Iron Canyon reservoirs and boat ramps to collect logs and

debris from the lake surface with smaller debris and trash removed from NFS lands, but

the Forest Service does not specify a frequency or the reservoirs where surface debris

would be captured in its modified condition 30. PG&E alternative condition 30 proposes

to conduct surface sweeps to collect logs and other debris from the surface of McCloud

and Iron Canyon reservoirs once every 5 years or as needed, prior to the start of the

recreation season. Surface sweeps of McCloud and Iron Canyon reservoirs and boat

ramps would remove surface debris to reduce boating hazards and ensure that the boat

ramps are not blocked by debris. Annual sweeps would ensure that winter storm debris

that could accumulate seasonally is removed prior to the beginning of each recreation

season.

Additionally, PG&E originally proposed to develop a surface water and shoreline

management plan for McCloud reservoir that includes installing 5-mph signs on the

bridge that spans the northern end of the reservoir, points of public access to the

shoreline, and boating speeds. Developing protocols for preventing/removing

unapproved buoy courses and approved use of docks, as specified by the Forest Service

in its original condition 30 and proposed by PG&E in alternative condition 30, would

help prevent boating hazards and improve public recreational safety at the project

reservoirs.

In its original condition 30, the Forest Service specified, and in alternative

condition 30, PG&E modified its original proposal for the surface water and shoreline

management plan for McCloud reservoir to propose that PG&E would submit requests to

the Shasta County Boating Unit of the Sheriff’s office for the establishment of a 5-mph

restriction on a portion of McCloud reservoir and for a buoy line near Huckleberry Creek

on McCloud reservoir. Although speeding on the reservoirs has been identified as an
410

issue by project users, enforcement of speed restrictions is not the responsibility of the

Commission. The Shasta County Boating Unit of the Sheriff’s office is responsible for

boating safety enforcement on all waterways within Shasta County, including the project

reservoirs. PG&E is subject to local laws and ordinances as they pertain to reservoir

speed limits.

Additionally, the Forest Service specifies that PG&E implement measures to

discourage trespass on private lands to protect public safety. The Commission does not

have authority on private lands outside the project boundary; it is the responsibility of

private landowners to clearly mark their property if trespassing is problematic. However,

measures to prevent unauthorized access to project lands and waters where necessary to

protect the public would ensure public safety at the project and help address the issue of

trespassing at the project, especially at Pit 7 afterbay where public access is prohibited.

We recommend that PG&E implement a water surface management component of

the Recreation Plan to include protocols for preventing/removing unapproved buoy

courses and approved use of docks; surface sweeps of McCloud and Iron Canyon

reservoirs and boat ramps, annually or as needed; and measures to prevent unauthorized

access to project lands and waters, where necessary, to protect public safety. We

estimate the annualized cost of the overall surface water management component would

be $50,000 and conclude that the benefits of this measure are worth the cost.

Project Signage and Interpretative Information

The project currently does not have a coordinated and systematic process for the

development of signage and interpretative information associated with the project.

Development and implementation of a Project Sign Plan with an updated sign inventory

and associated interpretive and educational measures for the project would provide the

means for coordinated and systematic development of signage and interpretative

information to ensure public safety and help the public receive the most out of visits to

the project. Furthermore, providing informational kiosks or interpretive and education

materials at developed project facilities and a public website to host recreation

information would provide a source for visitors to locate recreation information about the

project both on the internet and onsite. Therefore, we recommend the development of the

Project Sign and Interpretive Education Plan in consultation with the Forest Service and

that PG&E be responsible for ensuring that public information required under the Project

Sign and Education Plan is available through the internet, via PG&E’s website. We

estimate that the annualized cost of the Project Sign Plan would be $42,000 and the

annualized cost of the interpretive and educational component would be $30,000, and we

conclude that the benefits of these measures are worth the cost.

Dispersed Use and OHV Use

PG&E’s proposal to work with the Forest Service to discourage littering and OHV

use through the assessment and evaluation of road closures, trail closures, and dispersed

use would improve visitors’ recreational experience at the project and enhance public
411

safety. Further, by implementing measures to block vehicle access and discourage OHV

use at the project, environmental resources would be further protected although these

measures are no longer specified by the Forest Service in modified condition 30. The

Forest Service originally specified in condition 30 that PG&E implement measures to

evaluate road closures, trail closures and dispersed use closure around Iron Canyon

reservoir. Although not specified by the Forest Service or proposed by PG&E in

alternative condition 30, including McCloud reservoir in the evaluation would address

areas identified at both reservoirs where dispersed use occurs. Prohibiting vehicle access

and OHV use between the roads and reservoir shorelines would help reduce this resource

damage and improve the aesthetic quality of the area for visitors to the project. To help

reduce resource damage from dispersed-use recreation, we recommend that PG&E

evaluate and implement appropriate road closures and trail closures, in coordination with

the Forest Service, for the area inside the project boundary around both McCloud and

Iron Canyon reservoirs. We estimate the annualized cost of this measure would be

$114,000 and conclude that the benefits of this measure would be worth the cost.

Project Patrol

PG&E proposes to prepare a Project Patrol Plan in consultation with the Forest

Service that would address patrol at the project, including NFS land within the project

area. Similarly, Forest Service modified condition 30 specifies that PG&E develop and

implement a Project Patrol Plan and coordinate annually with appropriate agencies and

other interested parties to review information from the prior season and plan any

adjustments for the next high-use season. Forest Service modified condition 30 also

specifies that PG&E would employ a year-round project patrol person or, alternately,

provide funding to an appropriate federal, state, or local agency to provide that same.

The Hearst Corporation filed comments supporting the concept of a host or project patrol

person.

Although more visible patrol or law enforcement may help reduce conflicts

between recreation users and improve visitor safety, the state and county are responsible

for law enforcement activities at public recreation sites, including within the project area.

Further, the Commission has no way of ensuring that the hiring of a patrol person or

campground host paid for by PG&E would actually accomplish a project purpose or

ameliorate a project effect. There would be no indication that existing recreation

conflicts would be reduced through the proposed measure; therefore, we do not

recommend that PG&E provide patrol (i.e., seasonal or year-round employee,

campground host) or funding for a law enforcement position.

Provision of Streamflow Information

Accurate and timely streamflow information and information about the usability of

the project boat launches can assist recreationists in planning water-related visits to the

project. PG&E proposes and Forest Service modified condition 19, part 2 specifies that

accurate and timely streamflow information be provided to the public. This would

provide the means for the public to gain information regarding streamflow and reservoir
412

levels for specified stream reaches and reservoirs at the project. Providing accurate and

timely streamflow information at gage MC-7, in addition to gage MC-1, to the public via

the internet would also provide the public with additional streamflow information for the

Lower McCloud River. Therefore, we recommend PG&E provide streamflow data from

gage MC-1 and gage MC-7 and reservoir drawdown information to the public via its

website on the internet. We estimate the annualized cost of this measure to be $4,000,

and conclude that the benefits outweigh the costs.

Cultural Resources

National Register of Historic Places Eligibility

As part of the required cultural resource surveys, PG&E surveyed all accessible

project lands within the APE. Although PG&E has not yet conducted all evaluations to

determine which, if any, of the identified sites are eligible for inclusion in the National

Register, we conclude than one archaeological site (CA-SHA-252) that is currently being

adversely affected by the project is eligible for the National Register. In the draft EIS, we

also recommended that PG&E set up a schedule to determine National Register eligibility

on all remaining sites that either currently or have the potential to be adversely affected

by the project. On October 26, 2010, PG&E filed a revised HPMP that lists site

CA-SHA-252 as a National Register-eligible site being adversely affected by the project

and states that site specific measures for its protection will be developed within 1 year of

license issuance. PG&E also provided a schedule indicating that National Register

eligibility for the remaining sites would be determined within 1 year of license issuance,

and any necessary protection measures would be developed within 2 years of license

issuance. These revisions are consistent with our recommendations in the draft EIS and

we recommend that they be implemented.

Cultural Resource Management

Continued operation of the project, along with construction of the proposed

generation and recreation facilities, could adversely affect properties eligible for listing in

the National Register. To protect and manage historic properties within the project APE,

PG&E prepared and filed a draft HPMP (dated, July 2009) and proposed to continue

consultation to develop a final HPMP. In the HPMP, PG&E proposes to conduct

monitoring of sites within the project area that are eligible for listing on the National

Register. In addition, the HPMP includes additional mitigation and management

measures for historic properties affected by the project, as well as proposals for

continuous cultural resource consultation with the Forest Service, the Pit River Tribe, and

the Winnemem Wintu Tribe. The Forest Service’s original condition 34 also specified

finalization and implementation of the HPMP and that the HPMP should: (1) fully

integrate all cultural resource studies completed for the project relicensing, including

each tribe’s TCP studies; (2) take into account project effects on National Registereligible properties that are being periodically inundated by Iron Canyon reservoir and

elsewhere on NFS lands; (3) provide measures to mitigate effects on historic properties;

(4) evaluate whether an archaeological or ethnographic historic district should be
413

established on the Lower McCloud River within the project’s expanded APE; and

(5) provide for a monitoring program and management protocols on NFS lands.

PG&E alternative condition 34 proposed slight modifications to Forest Service

condition 34. PG&E proposed that: (1) if a TCP report from the Winnemem Wintu is

completed after a final HPMP is filed, then the final HPMP would need to be amended;

(2) National Register eligibilities would be applied to sites periodically inundated that are

being affected by project-related effects; (3) mitigation measures would be applied after

the California SHPO determined that those project-related affects are adverse, and such

measures are necessary; and (4) determining a historic district involving archaeological

and ethnographic sites would be done only if there is compelling evidence that supports

such a historic district. Forest Service modified condition 34 is similar to its original

condition 34, except that in the modified condition, the Forest Service requests further

revision of the HPMP. PG&E filed a letter on December 14, 2010, stating that it accepts

the Forest Service modified condition 34, and withdrew its alternative condition 34.

In our draft EIS, we recommended that PG&E include the following additional

measures in the HPMP:

 Treatment measures, to be conducted within 1 year of license

Issuance, that resolve project-related adverse effects on National

Register-eligible archaeological site CA-SHA-252;

 National Register evaluations, to be completed within 1 year of license

issuance, on all cultural resources that are currently, or in the future will be,

adversely affected by the project;

 Site-specific protection measures, to be completed within 2 years of license

issuance, to resolve project-related erosion effects on all National Register

eligible archaeological sites; and

 Measures for handling of newly discovered paleontological resources, due to

the recent paleontological law enacted by Congress in March 2009 that

requires all federal land managers to manage and protect paleontological

resources discovered on their lands.

On October 26, 2010, PG&E filed a revised HPMP with the Commission that

included these draft EIS recommended measures. With the addition of these measures,

we find that the October 2010 final HPMP is revised adequately.

In addition to these measures, PG&E has also stated in the October 2010 final

HPMP that it will pursue investigations on any additional cultural resource sites

identified by the Forest Service that have not already been addressed in the final HPMP,

and that such related documentation will be completed within 1 year of license issuance.

We agree that addressing any sites identified by the Forest Service would ensure that all
414

cultural resource sites being adversely affected by the project are adequately protected

and recommend that this measure be implemented, as well.

PG&E has not yet filed the results of its Winnemem Wintu TCP study. On

April 23, 2010, and May 25, 2010, PG&E and the Winnemem Wintu Tribe (Tribe),

respectively, filed letters with the Commission explaining the parties’ disagreement about

who can gain access to Tribe’s TCP study.41 The Commission is not the appropriate

venue for resolving this issue.42 However, PG&E’s final HPMP provides a process to

incorporate the Winnemem Wintu TCP study and to protect or resolve project-related

adverse effects to any TCP that is located within the project’s APE. Amendments to the

final HPMP can also be used to incorporate additional information and treatment

measures for TCPs resulting from such studies when they are completed. Furthermore,

any other measures recommended by the Forest Service can be added as an amendment

to the final HPMP, as may be required by the Forests Service’s modified condition 34.

Implementation of PG&E’s October 2010 final HPMP would ensure that adverse

effects on historic properties, as a result of project operation, maintenance, recreation,

vandalism, or other existing and future project-related activities, would be addressed over

the term of any new license issued for the project. In order to implement the terms of the

final HPMP, Commission staff would execute a PA with the California SHPO.43 PG&E,

the Forest Service, Pit River Tribe, and Winnemem Wintu Tribe would be invited to sign

the PA as concurring parties. With the execution of the PA and implementation of a final

HPMP, all anticipated effects on any historic properties within the project APE would be

resolved. Therefore, we recommend implementation of the final HPMP upon license

issuance. We estimate that implementation of the protective measures proposed in

PG&E’s final HPMP would have an annualized cost of $284,000. These costs would

include any additional modifications to the HPMP as specified by Forest Service

condition 34, and we conclude that the expected benefits of implementing the HPMP

with any recommended modifications are worth the cost.

41 Letter from Steve Nevares, PG&E, dated April 23, 2010, and letter from

Stephen Volker, Attorney for Winnemem Wintu Tribe, dated May 25, 2010.

42 As the MOU is a legal document between PG&E and the Tribe, the

Commission cannot enforce any of the clauses contained within the document. While the

Commission itself is not the appropriate venue for resolving these issues, we can refer the

parties to the Commission’s Dispute Resolution Service. If both parties feel facilitation

could assist in resolving their dispute, please contact Commission staff.

43 We issued a draft PA on August 27, 2010, and invited the Council to participate

in the PA. Since then, we have not received a response back from the Council, and as

with other draft PAs we issued and ask whether the Council chooses to participate, we

conclude that the Council has chosen not to participate in this particular PA.
415

Land Use and Aesthetic Resources

Road and Transportation Facilities Management Plan

A Road and Transportation Facilities Management Plan, as proposed by PG&E

and specified by Forest Service condition 29 and modified condition 29, would establish

a forum for coordination of road maintenance activities among PG&E, the Forest Service,

and other affected parties. Specifically, the plan would address operations, maintenance,

construction and reconstruction, monitoring, and road use within the project boundary

(project roads are listed in table 3-41). A plan would help to clarify and memorialize

PG&E’s road management responsibilities within the project boundary, ensure safe

public access to project lands and waters, and ensure the adequate protection of natural

and environmental resources in the project area. A separate settlement agreement,

between PG&E and the Forest Service, would address O&M of non-project recreation

facilities and roads in the Shasta-Trinity National Forest. We estimate that the annualized

cost of developing and implementing this plan would be $3,950,000 and conclude that

the benefits of this measure warrant the costs. We recommend the implementation of this

measure.

Fire Prevention and Response Plan

The development and implementation of a Fire Prevention and Response Plan in

consultation with the Forest Service, the California Department of Forestry and Fire

Protection, the Big Bend Volunteer Fire Department, and others, as appropriate, that

addresses fuels treatment, prevention and response, access and safety, emergency

response preparedness, investigation and reporting, and post-fire activities, as proposed

by PG&E and specified by Forest Service condition 33, would improve planning,

management, and coordination of wildfire protection and prevention measures.

Implementation of the plan would also lead to a reduction in the occurrence and

suppression of wildfires in the project area. We estimate that the annualized cost of

developing and implementing this plan would be $4,000. Given the benefits of improved

public safety and reduced potential damage to property and natural resources, we

conclude that the benefits of this measure are worth the cost and recommend the

implementation of this measure.

Hazardous Substance Management Plan

To meet the regulatory requirements for handling, storage, and emergency

response related to hazardous materials, PG&E has developed a Spill Prevention,

Control, and Countermeasures Plan and Hazardous Materials Business Plan. The

continued implementation of these plans would ensure that spills of hazardous substances

within the project boundary are promptly contained and cleaned up to avoid/minimize the

potential extent of adverse environmental effects. Although the Forest Service did not

specify a Hazardous Substance Management Plan in its modified 4(e) conditions, the

California Water Board and the Center for Water Advocacy supported the original

proposal. We recommend that PG&E provide copies of the existing plans to the
416

Commission, the Forest Service, and the Central Valley Regional Water Board within

30 days of license issuance. We estimate that the annualized cost of filing the existing

Spill Prevention, Control, and Countermeasures Plan and Hazardous Materials Business

Plan with the Commission and providing copies to the Forest Service would be minimal,

and we recommend implementation of this measure.

Project Boundary

We have concluded that certain roads and dispersed areas recommended by the

Forest Service to be included in the project boundary do not meet the Commission’s

criteria for roads used primarily for project purposes and should not be included in the

project boundary.44 In modified condition 30, the Forest Service also specifies that all

new, proposed recreation sites and facilities be included within the project boundary prior

to ground disturbance. We conclude that it would be premature to alter the project

boundary before new recreational facilities are actually constructed, as the location of the

facilities or design plans may change, possibly requiring multiple, unnecessary, changes

to exhibit maps. By requiring PG&E to include all existing project recreation sites, to

include any roads necessary for project purposes within the project boundary within

1 year of license issuance, the Commission would have the authority to ensure that

PG&E maintains adequate and safe public access to project lands and waters for

recreational purposes. If new recreation sites are included in a new project license,

PG&E would be required to file a revised exhibit G that would include the new facilities

and roads, as appropriate, once construction of the facilities is complete. We estimate

that the annualized cost of filing revised exhibit maps with the Commission would be

$10,000 and conclude the benefits of this measure warrant the costs. We recommend the

implementation of this measure.

Visual Quality Management Plan

Aesthetic resources can be affected by project facilities and operations. Project

facilities, such as project powerhouses, transmission lines, and recreation facilities can

dominate views, creating contrast with the natural landscape. Forest Service condition 32

specified that PG&E develop, for Forest Service approval and filing with the

Commission, an implementation schedule of visual quality mitigation measures. Forest

Service modified condition 32 specifies and PG&E agrees to develop tasks and a timeline

to ensure implementation of certain mitigation measures to blend project and projectrelated facilities on project and project-affected NFS lands with the natural surroundings.

These measures apply to existing, modified, and constructed and reconstructed project

facilities. However, existing facilities in good repair would only have mitigations applied

as maintenance is needed.

44 For more information regarding the Commission’s roads policy, please see the

Commission’s Policy Statement on Hydroelectric Licensing Settlements, issued

September 21, 2006.
417

The implementation of visual quality mitigation measures would help to ensure

that project facilities blend with the natural environment and are consistent with the

Forest Service’s VQOs for the project area. The measures proposed by PG&E and

specified by the Forest Service, such as visual screening, painting, providing interpretive

information, and maintaining reservoir levels during the peak recreation season would

collectively reduce the impacts on aesthetic resources in the project area. We agree that a

tasks and timeline approach is a reasonable alternative to a management plan. We

recommend PG&E identify specific mitigation measures and develop an implementation

schedule, in consultation with the Forest Service and stakeholders, as appropriate, to

protect the visual quality of lands in the project area within 1 year of license issuance. At

a minimum the proposed measures should address the effect of project facilities on the

aesthetics in the project area, including but not limited to generating facilities, recreation

sites and facilities, and spoil piles. We estimate an annualized cost of $11,000 and

recommend implementation of this measure.

Proposed Additional Generation Units

To develop the hydro potential from higher instream flows that may be required in

a new license, PG&E studied the feasibility of installing new generation units at both the

McCloud and Pit 7 afterbay dams. For McCloud dam, PG&E studied the feasibility of

both a 5-MW powerhouse and an 8-MW powerhouse. For the Pit 7 afterbay

development, PG&E analyzed both a 5-MW powerhouse and a 10-MW powerhouse. In

the final license application, PG&E says it will determine the final size of the units and

their hydraulic capacity based on instream flow requirements of the new project license.

In table 4-7 of section 4.4, Comparison of Alternatives for PG&E’s Proposed

Powerhouses, we compare our estimate of the power value, annual costs, and net benefits

of the powerhouse alternatives presented by PG&E in the license application. As table 4-

7 shows, the four alternatives that PG&E is considering would have initial annual costs

that far exceed the current power value.

PG&E needs to decide whether to propose the new units at McCloud dam and the

Pit 7 afterbay dam, and how to appropriately size them. Though our analysis shows that

the cost of these new units could exceed the potential power benefits, PG&E might

consider whether these hydro proposals would qualify as part of its state requirement to

develop renewable resources and whether to accept the financial risk that entails from

developing these units. Therefore, until PG&E decides on the final capacity of these

minimum flow units, we make no recommendation at this time regarding the proposed

additional generation units.

5.3 UNAVOIDABLE ADVERSE EFFECTS

The continued operation of the project would result in some minor unavoidable

adverse effects on geologic, soil, and terrestrial resources. The geologic and soil

resources effects could include some minor continued erosion associated with project

operation and renovation of recreational facilities and interruption of sediment transport
418

at project reservoirs. Most of these effects would be reduced by the proposed resources

enhancement measures, including: (1) development and implementation of an Erosion

and Sediment Control Plan; and (2) development and implementation of an LWD Plan.

For terrestrial resources, these effects could include short-term loss of vegetation

communities along the proposed transmission line. Most of these effects would be

reduced by proposed resource enhancement measures, including the development and

implementation of a Vegetation and Invasive Weed Management Plan and vegetation

management BMPs. Vegetation within the permanent corridor would re-establish;

however, the vegetation within the corridor would be managed and maintained as

necessary and in the long-term would be permanently altered from the original plant

communities that existed prior to the construction of the new transmission lines.

We have identified no other unavoidable adverse effects on resources influenced

by project operation.
419

5.4 SUMMARY OF SECTION 10(j) RECOMMENDATIONS AND 4(e)

CONDITIONS

5.4.1 Fish and Wildlife Agency Recommendations

Under the provisions of section 10(j) of the FPA, each hydroelectric license issued

by the Commission shall include conditions based on recommendations provided by state

and federal fish and wildlife agencies for the protection, mitigation, or enhancement of

fish and wildlife resources affected by the project.

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 the agency. If the Commission still does not

adopt a recommendation, it must explain how the recommendation is inconsistent with

Part I of the FPA, or other applicable law and how the conditions imposed by the

Commission adequately and equitably protect, mitigate damages to, and enhance fish and

wildlife resources.

In response to the Commission’s Ready for Environmental Analysis notice, issued

December 1, 2009, California Fish and Game (February 2, 2010) and NMFS

(January 29, 2010) filed letters providing comments and terms and conditions for the

McCloud-Pit Project, pursuant to section 10(j). In response to the Commission’s draft

EIS, NMFS also filed a letter on September 28, 2010, providing comments on the draft

EIS and requesting a meeting with Commission staff to discuss our preliminary

determinations on inconsistency regarding NMFS’s 10j recommendations. Commission

staff held a 10(j) meeting with NMFS in Sacramento, California, on November 17, 2010,

in an attempt to resolve these preliminary inconsistencies. California Fish and Game did

not request a 10(j) meeting. Table 5-2 summarizes the agency recommendations made

under section 10(j), as well as whether the recommendations are adopted 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 and in section 5.2, Comprehensive

Development and Recommended Alternative.

Of the 15 recommendations, we make a preliminary determination that two of the

recommendations made by NMFS and two recommendations made by California Fish

and Game are within the scope of section 10(j). Of those four recommendations filed by

NMFS or California Fish and Game, we adopt two and partially adopt one.

NMFS provided 12 section 10(j) recommendations, and we make the preliminary

determination that two of those recommendations are within the scope of section 10(j)

and we recommend both of those measures. In the staff alternative, we recommend that

PG&E submit draft biological evaluation or assessment for special status species

protection and mitigation. We also recommend that PG&E measure instream flows at
420

gage MC-7. We make a preliminary determination that the remaining 10 measures,

however, are outside the scope of section 10(j) and we analyze these recommendation

under section 10(a) of the FPA. Of these 10 measures, we recommend one (that PG&E

consult annually on newly added special status species), but we do not recommend that

PG&E create the Listed Salmonid Technical Integration Committee. Instead, we

recommend that PG&E file an annual report on the status of listed anadromous fish

reintroduction in the project area.

The remaining eight section 10(j) recommendations from NMFS include

protection, mitigation, and enhancement measures to be implemented as soon as listed

salmonids are documented within the McCloud River. As discussed previously,

however, no listed salmonids are present in the project area. Although NMFS has issued

a final biological opinion on long-term operations of Reclamation’s Central Valley

Project and State Water Project in the Central Valley, California, as well as a Public Draft

Recovery Plan for ESA-listed salmon species, a review of documented scientific, legal,

regulatory, and economic resources indicates that the reestablishment of listed salmonids

both above Shasta dam and in the project area is not assured. Furthermore, NMFS states

that the eight recommendations that provide for the protection, mitigation, and

enhancement of listed salmonids would be implemented as soon as the species were

documented in the McCloud River. In the draft EIS, we analyzed the recommendations

and made a preliminary determination that they were within the scope of section 10(j),

but we did not recommend these eight measures because they were premature since listed

salmonids were not currently present in project waters. After further review of the eight

NMFS section 10(j) recommendations and the NMFS OCAP BiOp and Public Draft

Recovery Plan, we have now revised our preliminary determination with regard to scope.

As these are measures that would be instituted at an indeterminate future time, it is our

preliminary determination that these eight measures do not fall within the scope of

section 10(j). Instead, we consider these measures under section 10(a) of the FPA and

they are addressed in the specific resource sections of this document and in section 5.2,

Comprehensive Development and Recommended Alternative, Reintroduction of

Anadromous Fish.

California Fish and Game provided three 10(j) recommendations, and we

recommend one of the recommendations, partially recommend another recommendation,

and do not recommend the third recommendation, which also is outside the scope of

10(j). While we recommend adopting California Fish and Game’s recommended

minimum instream flow regime for Iron Canyon Creek and Pit 7 dam, we do not

recommend adopting California Fish and Game’s recommended minimum flow regimes

for below McCloud dam. Our analysis in sections 3.3.2.2, Environmental Effects, and

5.2, Comprehensive Development and Recommended Alternative, indicates that the staffrecommended Lower McCloud River flow regime, as specified in Forest Service

modified condition 19, would provide a similar level of increased trout habitat with less

loss to generation. We estimate that the annualized cost of implementing the minimum

flow regime recommended by California Fish and Game would be $15,910,000 per year,
421

which is $1,459,000 more than the cost of the staff-recommended flow regime and the

added benefit is not worth the cost. Therefore, we find that California Fish and Game’s

recommended minimum flow regime for the Lower McCloud River is inconsistent with

the comprehensive planning standard of section 10(a) of the FPA, as well as the equal

consideration provision of section 4(e) of the FPA.

Table 5-2. Analysis of fish and wildlife agency section 10(j) recommendations for the

McCloud-Pit Hydroelectric Project. (Source: Staff)

Recommendations Agency

Within Scope

of 10(j)?

Annualized

Cost Adopted?

1. Submit draft

biological evaluation or

assessment for special

status species protection

and mitigation

NMFS Yes $0 Yes

2. Consult annually on

newly added special

status species

NMFS No. Not a

specific

measure to

protect,

mitigate, or

enhance fish

and wildlife

resources.

$11,000 Yes

3. Provide access to

suitable habitat for

anadromous fish and

restore fully functioning

habitat conditions for

spawning, rearing,

migration, and adjoining

habitats

NMFS No. This is a

measure that

would be

instituted at an

indeterminate

future time.

NA Not adopted;

premature given

lack of

anadromous fish

on the McCloud

River

4. Implement scheduled

instream flows for

McCloud River to the

benefit of native

anadromous fishes

NMFS No. This is a

measure that

would be

instituted at an

indeterminate

future time.

NA Not adopted;

premature given

lack of

anadromous fish

on the McCloud

River
422

Recommendations Agency

Within Scope

of 10(j)?

Annualized

Cost Adopted?

5. Move instream flow

compliance point from

gage MC-1 to gage MC7 or at McCloud dam

NMFS Yes $60,000 Yes

6. Implement instream

flow range estimates

that meet the thermal

summer spawning

requirements for winterrun Chinook salmon

NMFS No. This is a

measure that

would be

instituted at an

indeterminate

future time.

NA Not adopted;

premature given

lack of

anadromous fish

on the McCloud

River

7. Implement ramping

to minimize impacts of

flows on listed

salmonids

NMFS No. This is a

measure that

would be

instituted at an

indeterminate

future time.

NA Not adopted;

premature given

lack of

anadromous fish

on the McCloud

River

8. Augment gravel

substrates for listed

salmonids

NMFS No. This is a

measure that

would be

instituted at an

indeterminate

future time.

NA Not adopted;

premature given

lack of

anadromous fish

on the McCloud

River

9. Maintain channel to

minimize impacts of

project operations on

habitat for listed

salmonids

NMFS No. This is a

measure that

would be

instituted at an

indeterminate

future time.

NA Not adopted;

premature given

lack of

anadromous fish

on the McCloud

River

10. Protect and enhance

riparian habitat and

habitat function for

listed salmonids

NMFS No. This is a

measure that

would be

instituted at an

indeterminate

future time.

NA Not adopted;

premature given

lack of

anadromous fish

on the McCloud

River
423

Recommendations Agency

Within Scope

of 10(j)?

Annualized

Cost Adopted?

11. Maintain water

quality, including

temperature, for the

benefit of listed

salmonids

NMFS No. This is a

measure that

would be

instituted at an

indeterminate

future time.

NA Not adopted;

premature given

lack of

anadromous fish

on the McCloud

River

12. Create the Listed

Salmonid Technical

Integration Committee

NMFS No. Not a

specific

measure to

protect,

mitigate, or

enhance fish

and wildlife

resources.

$20,000 Not adopted.

Recommended

annual reports on

the status of listed

anadromous fish

in the project

area.

13. Implement

minimum instream

flows for Lower

McCloud River, Iron

Canyon Creek, and Pit

River below Pit 7 dam

California

Fish and

Game

Yes $15,910,000 Partially adopted:

recommend

implementation of

Iron Canyon

Creek and Pit 7

dam flow, but

find Lower

McCloud River

flow

recommendation

inconsistent with

the

comprehensive

planning standard

of sections 4(e)

and 10(a) of the

FPA, because the

loss of generation

associated with

the higher

instream flows do

outweigh the

negligible

benefits.
424

Recommendations Agency

Within Scope

of 10(j)?

Annualized

Cost Adopted?

14. Prepare a

Gravel/Sediment

Management Plan,

which includes

requirement to add a

minimum of 150 tonnes

of gravel and associated

sediment to the

McCloud River

annually

California

Fish and

Game

Yes $75,000 Not adopted

15. Reimburse

California Fish and

Game for increased

stocking of trout

annually, at levels above

current levels in order to

meet recreational needs.

PG&E shall also pay

California Fish and

Game $5,000 annually

for mitigation for white

sturgeon.

California

Fish and

Game

No. Not a

specific

measure to

protect,

mitigate, or

enhance fish

and wildlife

resources.

$117,000 Partially adopted;

recommend

PG&E be

responsible for

stocking trout

annually within

the project

boundary and

developing a fish

stocking plan.

Payment for white

sturgeon

mitigation not

adopted

5.4.2 Forest Service 4(e) Conditions

In section 2.2.4.1, Section 4(e) Federal Land Management Conditions, we 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 condition that

meets the requirements of the law may be included in a license issued by the

Commission, regardless of whether we include the condition in our staff alternative.

In section 2.2.4.1, Section 4(e) Federal Land Management Conditions, we identify

that we consider 15 of the Forest Service conditions to be administrative or legal in

nature and not specific environmental measures. We therefore do not analyze these 15

conditions in our draft EIS. Table 5-3 summarizes our staff conclusions with respect to
425

the conditions that we consider to be environmental measures. In its November 29, 2010,

filing, the Forest Service withdrew original conditions 24 and 28. Of the remaining 18

Forest Service conditions that we do not consider administrative or legal in nature, we

fully recommend 8 in the staff alternative and partially recommend 10. Our reasons for

not including measures in the staff alternative are summarized in table 5-3 and are

discussed in more detail in section 5.2.1, Discussion of Key Issues.

Table 5-3. Forest Service 4(e) conditions for the McCloud-Pit Hydroelectric Project.

(Source: Forest Service, 2010a)

Condition Annualized

Cost Recommended?

Condition 1: Consult with the Forest Service

annually on project O&M activities. Shall include

status reports on license condition implementation,

results of monitoring studies, routine and nonroutine maintenance, review of any necessary

revisions or modifications of plans included in

license, discussion of any measures that are needed

to protect special status species or changes to

existing management plans, and any planned

pesticide use.

$30,000 Yes

Condition 11: Submit a biological evaluation to

the Forest Service before taking actions to

construct new project features that may affect

Forest Service special status species or their critical

habitat. This shall include procedures to minimize

impacts to special status species, adhere to

restrictions in site management plans for special

status species, and develop monitoring to reduce

effects to special status species.

$0 Yes

Condition 15: Obtain prior written approval from

the Forest Service for use of pesticides on NFS

lands or in areas affecting NFS lands. Pesticide

use would be excluded from NFS lands within 500

feet of known locations of Shasta salamanders,

northwestern pond turtles, foothill yellow-legged

frogs, or known locations of Forest Service special

status or culturally significant plant populations.

$0 Yes
426

Condition Annualized

Cost Recommended?

Condition 19: Maintain specified minimum

streamflows in project reaches in accordance with

the provisions described in the Forest Service

filing. The minimum instantaneous 15-minute

streamflow shall be at least 80 percent of the

prescribed mean daily flow for those minimum

streamflows less than or equal to 10 cfs, and at

least 90 percent of the streamflows required to be

greater than 10 cfs. Should the mean daily flow as

measured be less than the required mean daily flow

but more than the instantaneous flow, PG&E shall

begin releasing the equivalent under-released

volume of water within 7 days of discovery of the

under-release.

$14,451,000 Yes

Condition 19: Determine the water year type for

minimum flow compliance based on the DWR

Bulletin 120 water year forecast of unimpaired

runoff for the McCloud River above Shasta Lake.

$5,000 Yes

Condition 19: Operate, maintain, and modify (if

necessary) gages needed to determine river stage

and minimum streamflow and measure and

document all instream flow releases in publicly

available formats.

$120,000 Yes
427

Condition Annualized

Cost Recommended?

Condition 20: Prepare a water quality and

temperature monitoring plan in consultation with

agencies and approved by the Forest Service. The

plan shall include monitoring of all project

reservoirs every 5 years for contaminants including

E. coli; periodic monitoring of DO at McCloud, Pit

6, and Pit 7 reservoirs; annual temperature

monitoring for 10 years from May 1 through

September 30, ; continuous monitoring of turbidity

for the term of the license in the Lower McCloud

River during the fishing season, and periodically

during construction or other soil disturbing

activities; continuous monitoring of turbidity for 5

years after license issuance at Iron Canyon Creek

to ensure that repairs have reduced sedimentation

into the creek below the dam; implementation of

best management practices (BMPs) to satisfy the

Aquatic Conservation Strategy objectives from the

Northwest Forest Planning area; and mitigation of

impacts from project O&M, recreation, road use

and maintenance, vegetation management, fire

management, and watershed practices.

$86,000 Yes

Condition 21: Prepare an LWD Management Plan

in consultation with agencies and approved by the

Forest Service. The plan will specify size criteria,

placement and storage sites, volume and frequency

of placement, and monitoring procedures to assess

mobilization of LWD from the augmentation site.

$214,000 Yes
428

Condition Annualized

Cost Recommended?

Condition 22: Prepare an Erosion and Sediment

Control Management and Monitoring Plan

developed in consultation with agencies, and

approved by the Forest Service. The plan shall

include methods for inventorying and monitoring

project-related erosion and sedimentation,

inspection schedule, inventory of erosion sites,

criteria for treating erosion sites, schedule for

repair of erosion sites, protocols for emergency

erosion and sediment control, a process and

schedule for reporting monitoring results including

plan review and revision, and BMPs for erosion

control measures.

$120,000 Yes

Condition 23: Develop a Gravel and Coarse

Sediment Management Plan in consultation with

agencies and approved by the Forest Service. The

plan shall require the periodic addition of 150-600

tonnes of gravel and coarse sediment, ranging in

size between 8 and 128 mm, to the Lower

McCloud River directly below the McCloud dam

spillway splash pool. The plan shall identify the

source of materials, identify the locations for

gravel introduction in the Lower McCloud River

below McCloud dam, identify any facilities or

improvements necessary for accessing the sites for

gravel and coarse sediment placement, identify

coarse sediment storage sites, develop a schedule

for placement, and include an adaptive

management component to allow higher or lower

quantities of gravel and coarse sediment to be

delivered based upon spill and monitoring results.

$79,000 Yes, with staff

modifications

Note: Condition 24 was withdrawn on

November 29, 2010.
429

Condition Annualized

Cost Recommended?

Condition 25: Develop a Vegetation and Invasive

Weed Management Plan in consultation with

agencies and approved by the Forest Service. The

plan will address special status species, aquatic and

terrestrial invasive species, and revegetation source

plant populations, including culturally significant

plants, within the project boundary and adjacent to

project features directly affecting NFS lands

including roads and distribution and transmission

lines. The plan shall address treatment protocols

for removing vegetation; protection of special

status plants, revegetation source plants, and

critical wildlife habitat; invasive species

management and monitoring; and pesticide use

restrictions.

$337,000 Yes, with staff

modifications

Condition 26: Develop a Terrestrial Biological

Management Plan, including Forest Service special

status species potentially affected by the project on

NFS lands. This plan should be consistent with the

recent plans for the relicensing of the Pit 3, 4, 5

Project. The plan should include monitoring for

the species listed in the Forest Service filing,

periodic surveys of the project area to determine if

additional populations develop, and reporting of

survey results including suitable habitat,

populations, individuals, pairs, and nest locations

every 5 years or as determined for individual

species. Mitigation measures include conducting

pre-construction surveys for special status species,

observing limited operating periods where

required, and using surveys to determine if

additional mitigation measures are necessary to

protect Forest Service special status species.

PG&E shall ensure that all power poles conform to

APLIC guidelines.

$198,000 Yes, with staff

modifications
430

Condition Annualized

Cost Recommended?

Condition 27: Develop an Aquatic Biological

Monitoring Plan in consultation with agencies and

approved by the Forest Service. The plan will

include monitoring of fish, benthic

macroinvertebrates, special status aquatic

mollusks, special status species, and invasive

aquatic species. PG&E would conduct monitoring

of fish passage structures at stream crossings at

listed streams.

$195,000 Yes, with staff

modifications

Note: Condition 28 was withdrawn on

November 29, 2010.

Condition 29: File a Road and Transportation

Facility Management Plan, approved by the Forest

Service, for protection and maintenance of project

and project-affected roads on or affecting NFS

lands. The plan shall include the following

components: planning and inventory; operation,

maintenance, and road-associated debris;

construction and reconstruction; monitoring;

PG&E road MOU; road use by government; and

road use. The Forest Service filing lists project and

project-affected roads, and roads with high erosion

potential requiring repair.

$3,950,000 Yes, with

incorporation of

some of PG&E

alternative

condition 29

Condition 30: Prepare a Recreation Development

and Management Plan in consultation with

agencies and approved by the Forest Service to

address recreation resource needs associated with

the project. New and reconstructed project

recreation facilities on NFS lands would meet all

Forest Service laws, standards and policy and meet

Forest Service recreation design guidelines. The

plan will address the following components

(included below) and specify location, design,

structures, and schedules for completion as

appropriate: O&M; recreation survey and

monitoring; project patrol; reservoir surface water

management; and construction and reconstruction

of project facilities.

$29,000 Yes, with staff

modifications

and

incorporation of

some of PG&E

alternative

condition 30
431

Condition Annualized

Cost Recommended?

Condition 30: Develop and implement recreation

survey and monitoring component of Recreation

Plan.

$300,000 Yes

Condition 30: Develop and implement Project

Patrol Plan.

$263,000 No

Condition 30: Develop and implement reservoir

water surface management component of

Recreation Plan.

$50,000 Yes, with staff

modifications

Condition 30: Reconstruct Tarantula Gulch boat

launch.

$936,000 Yes, with staff

modifications

and

incorporation of

some of PG&E

alternative

condition 30

Condition 30: Develop Star City day-use area and

campground.

$571,000 Yes

Condition 30: If land at Star City cannot be

acquired for overnight use, construct overnight

camping facilities on NFS lands near Tarantula

Gulch.

NA No

Condition 30: Construct Red Banks day-use area. $170,000 Yes

Condition 30: Construct Tarantula Gulch inlet

day-use area.

$40,000 Yes

Condition 30: Provide West McCloud dam

reservoir access site.

$49,000 Yes

Condition 30: Provide East McCloud dam

reservoir access site.

$47,000 Yes

Condition 30: Provide Battle Creek reservoir

access site.

$47,000 Yes

Condition 30: Provide day-use area at base of

McCloud dam.

$90,000 Yes

Condition 30: Construct three reservoir access

sites with parking and trail to Iron Canyon

reservoir.

$177,000 Yes, with staff

modification
432

Condition Annualized

Cost Recommended?

Condition 30: Design and construct Iron Canyon

dam boat launch.

$471,000 Yes, with staff

modification and

incorporation of

some of PG&E

alternative

condition 30

Condition 30: Reconstruct Hawkins Landing

Campground and boat launch.

$317,000 Yes

Condition 30: Reconstruct Deadlun Campground. $443,000 Yes

Condition 30: Construct new Gap Creek

Campground.

$443,000 Yes

Condition 30: Develop two surfaced parking areas

with reservoir access trails below Pit 6 dam to

provide fishing access and boating put-in onto the

upper Pit 7 reservoir.

$35,000 Yes, with staff

modifications

Condition 30: Develop road access to a surfaced

parking area and short walkway to put-in/take-out

onto the lower Pit 7 reservoir, either at

Montgomery Creek or near the Pit 7 dam.

$109,000 No

Condition 30: Construct day-use site at Fenders

Flat in vicinity of boat launch.

$423,000 Yes

Condition 30: Reconstruct the car-top boat launch

near Fenders Flat.

$14,000 Yes

Condition 30: Investigate known safety and public

access issues at Pit 7 afterbay dam.

NA No, will be

addressed under

current license

Condition 31: Develop and implement a Project

Sign and Interpretive/Education Plan for all nontraffic signs within the project, and an interpretive

and educational component. Sign locations and

design elements will be collaboratively developed.

$72,000 Yes, with staff

modifications
433

Condition Annualized

Cost Recommended?

Condition 32: Develop procedures and a timeline

for mitigation measures to provide for visual

quality of project and project-affected NFS lands.

Specific measures are listed in the Forest Service

filing.

$11,000 Yes

Condition 33: Develop a Fire and Fuels

Management Plan in consultation with agencies

and approved by the Forest Service. The plan shall

set forth PG&E’s responsibility for prevention,

reporting, and emergency response to fires in the

vicinity of the project resulting from project

operations. The plan shall address fuels treatment,

prevention and response, and investigation of

project-related fires.

$4,000 Yes

Condition 34: File a Historic Properties

Management Plan with the Commission, approved

by the Forest Service. The plan is tiered to a PA to

which the Forest Service will be a signatory, as

defined by 36 CFR 800, and implements

regulations of the NHPA. PG&E shall consult

with the SHPO, tribes, Forest Service, and other

applicable agencies during preparation of the plan.

The plan shall include the CR-S1 and CR-S2 study

results, detailed site monitoring and schedule,

National Register determinations of eligibility for

sites periodically inundated by reservoir

fluctuations in Iron Canyon reservoir, and potential

effects of current or proposed project operations on

historic properties including detailed mitigations.

If items of potential cultural, historical,

archaeological, or paleontological value are

reported or discovered during ground disturbing

activities or as a result of project operations, PG&E

shall cease work immediately and notify the Forest

Service.

$284,000 Yes, with staff

modifications
434

5.5 CONSISTENCY WITH COMPREHENSIVE PLANS

Section 10(a)(2) of the FPA requires the Commission to consider the extent to

which a project is consistent with federal and state comprehensive plans for improving,

developing, and conserving waterways affected by a project. Under this section, federal

and state agencies filed numerous qualifying comprehensive plans, of which we

identified 13 California and five federal plans that are applicable to the project. The

continued operation of the McCloud-Pit project, as recommended in this draft EIS, is

consistent with the 18 state and federal plans listed below.

California Advisory Committee on Salmon and Steelhead Trout. 1988. Restoring the

balance: 1988 annual report. Sausalito, CA. 84 pp.

California Department of Fish and Game. U.S. Fish and Wildlife Service. National

Marine Fisheries Service. Bureau of Reclamation. 1988. Cooperative agreement

to implement actions to benefit winter-run Chinook salmon in the Sacramento

River basin. Sacramento, CA. May 20. 10 pp. and exhibit.

California Department of Fish and Game. 1996. Steelhead restoration and management

plan for California. February. 234 pp.

California Department of Fish and Game. 2004. Lower McCloud River wild trout area

fishery management plan, 2004–2009. Redding, CA.

California Department of Parks and Recreation. 1998. Public opinions and attitudes on

outdoor recreation in California. Sacramento, CA. March 1998.

California Department of Parks and Recreation. 2009. California outdoor recreation

plan-2008. Sacramento, CA. 150 pp. and appendices.

California Department of Water Resources. 1983. The California water plan: projected

use and available water supplies to 2010. Bulletin 160-83. Sacramento, CA.

December. 268 pp. and attachments.

California Department of Water Resources. 1994. California water plan update. Bulletin

160-93. Sacramento, CA. October. Two volumes and executive summary.

California Department of Water Resources. 2000. Final programmatic environmental

impact statement/environmental impact report for the CALFED Bay-Delta

Program. Sacramento, CA. July. Three volumes and CD Rom.

California—The Resources Agency. Department of Parks and Recreation. 1983.

Recreation needs in California. Sacramento, CA. March 1983. 39 pp. and

appendices.

California State Water Resources Control Board. 1995. Water Quality control plan

report. Sacramento, CA. Nine volumes.

California—The Resources Agency. 1989. Upper Sacramento River Fisheries and

Riparian Habitat Management Plan. Sacramento, CA. January. 158 pp.
435

U.S. Forest Service, Land and Resource Management Plan. 1995. Shasta Trinity

National Forest, Redding, CA.

State Water Resources Control Board. 1999. Water Quality Control Plans and Policies

Adopted as Part of the State Comprehensive Plan. April. Three enclosures.

National Park Service. 2010. The nationwide rivers inventory. Department of the

Interior, Washington, D.C. http://www.ncrc.nps.gov/rtca/nri.

U.S. Fish and Wildlife Service. 1986. Canadian Wildlife Service. 1986. North

American waterfowl management plan. Department of the Interior. Environment

Canada. May.

U.S. Fish and Wildlife Service. Undated. Fisheries USA: The recreational fisheries

policy of the U.S. Fish and Wildlife Service. Washington, DC. 11 pp.
436

This page intentionally left blank.
437

6.0 LITERATURE CITED

APLIC (Avian Power Line Interaction Committee). 2006. Suggested practices for avian

protection on power lines: the state of the art in 2006. Edison Electric Institute,

APLIC, and the California Energy Commission. Washington, D.C. and

Sacramento, CA.

American Whitewater. 2010. National River Database. Available [online]:

http://www.americanwhitewater.org/content/River/view/. Accessed on November

12, 2010.

Barrett et al. (Barrett, J.C., G.D. Grossman, and J. Rosenfield). 1992. Turbidity induced

changes in reactive distance in rainbow trout. Transactions of the American

Fisheries Society 121:437–443.

Berryman, R. 1999. Confidential archaeology addendum for timber operations on nonfederal lands in California. Shasta-Trinity National Forest, Redding, California.

Bradford, M.J., G.C. Taylor, J.A. Allan, and P.S. Higgins. 1995. An experimental study

of the stranding of juvenile coho salmon and rainbow trout during rapid flow

decreases under winter conditions. North American Journal of Fisheries

Management. American Fisheries Society 15:473-479.

Bollibokka Land Company, Crane Mills, U.S. Forest Service, McCloud River CoTenants, Pacific Gas and Electric Company, Sierra Pacific Industries, State of

California, The Hearst Corporation, and The Nature Conservancy. 2001.

McCloud River coordinated resource management plan. Adopted July 23. 29 pp.

Calflora. 2010. Information on wild California plants for conservation, education and

appreciation. Available [online] at: http://www.calflora.org/. Accessed on

January 6, 2010.

California Fish and Game (California Department of Fish and Game). 1990. Bull trout,

Salvelinus confluentus Suckley. In: The McCloud River: Status and recovery

recommendations. Inland Fisheries Administrative Report No. 90-15.

————. 1994. McCloud River wild trout migrations and angler harvest from weir

counts and tagging, 1984–1987. Inland Fisheries Administrative Report No. 94-1.

————. 2001. Pit 6 Reservoir fish survey data. Unpublished data. Redding,

California.

————. 2003. Species accounts–birds. Threatened and endangered species of

California. Available [online]:

http://www.dfg.ca.gov/wildlif..._e_spp/docs/2004/t_ebirds.pdf. Accessed on

December 8, 2009.

————. 2010. State & federally listed endangered & threatened animals of

California. State of California Natural Resources Agency, Biogeographic Data

Branch, California Natural Diversity Database. October. Available [online]:
438

http://www.dfg.ca.gov/biogeodata/cnddb/pdfs/TEAnimals.pdf. Accessed on

April 8, 2010.

California Water Board (California State Water Resources Control Board). 2006. List of

water quality segments requiring TMDLs. Sacramento, California.

Central Valley Regional Water Board (Central Valley Regional Water Quality Control

Board. 2002. Resolution No. R5-2002-0150. Amending the water quality control

plan for the Sacramento River and San Joaquin River basins to update the water

quality objectives for bacteria. Sacramento, California.

———. 2007. Water quality control plan (basin plan) for the Sacramento and San

Joaquin River Basins. Fourth Edition. Revised October 2007 (with approved

amendments). Sacramento, California.

Cook, T.C., G.E. Hecker, H.B. Faulkner, and W. Jansen. 1997. Development of a more

fish-tolerant turbine runner advanced hydropower turbine project. Prepared for

U.S. Department of Energy, DOE Idaho Operations Office, and Hydropower

Research Foundation, Inc. DOE/ID-10571. ARL Report No. 13-97/M63F.

CWHR (California Wildlife Habitat Relationships). 2010. Life history accounts and

range maps. California Department of Fish and Game and California Interagency

Wildlife Task Group. Available [online]:

http://www.dfg.ca.gov/biogeodata/cwhr/cawildlife.aspx. Accessed on

January 7, 2010.

EPA (U.S. Environmental Protection Agency). 2003. Bacterial water quality standards

for recreational waters (freshwater and marine waters). Office of Water Report

No. EPA-823-R-03-008. Office of Water. Washington, DC.

FERC. 2004. Final Environmental Impact Statement Pit 3, 4, 5 Hydroelectric Project

(FERC No. 233-081). California. June 2004.

————. 2009. South Feather Power Project FERC Project No. 2088-068, California.

Final Environmental Impact Statement. FERC/EIS-0225F. Office of Energy

Projects. Washington, D.C. June.

FishersNet. 2010. California Lake Maps and Info web page.

www.fishersnet.com/fishmap.html, accessed on January 15, 2010. FishersNet.

Forest Service (U.S. Department of Agriculture, Forest Service). 1995. Shasta-Trinity

National Forest land and resource management plan and environmental impact

statement.

————. 2005. Shasta-Trinity CWE 2005 - cumulative watershed effects analysis.

Quantitative models for surface erosion, mass-wasting and ERA/TOC. Analysis

by D. Elder and M. Reichert, ACT2 Enterprise Team. U.S. Forest Service, ShastaTrinity National Forest, Redding, California.
439

————. 2010a. Section 4(e) Terms and Conditions and Section 10(a)

Recommendations: McCloud-Pit Hydroelectric Project, FERC No. 2106 Pacific

Gas and Electric Company. January 29, 2010.

————. 2010b. Pacific Southwest Region, Forest Visitor Maps, Shasta-Trinity

National Forest web page. http://www.fs.fed.us/r5/forestvisitormaps/shastatrinity,

accessed on April 14, 2010.

————. 2010c. Shasta-Trinity National Forest Service web page.

http://fs.usda.gov/wps/portal/fsinternet/!ut/p/c4/04_SB8K8xLLM9MSSzPy8xBz9

CP0os3gDfxMDT8MwRydLA1cj72BTJw8jAwjQL8h2VAQAzHJMsQ!!/?ss=110

514&navtype=BROWSEBYSUBJECT&cid=FSE_003705&navid=110130000000

000&pnavid=110000000000000&position=BROWSEBYSUBJECT&recid=6571

&actid=29&ttype=recarea&pname=Shasta-Trinity%20National%20Forest%20-

%20Castle%20Lake%20Campground, accessed on April 14, 2010.

————. 2010d. McCloud-Pit Hydroelectric Project FERC Project No. 2106, final

section 4(e) conditions, section 10(a) recommendation and comments.

November 29, 2010.

Franke, G.F., D.R. Webb, R.K. Fisher, D. Mathur, P.N. Hopping, P.A. March, M.R.

Headrick, I.T. Laczo, Y. Ventikos and F. Sotiropoulos. 1997. Development of

environmentally advanced hydro turbine design concepts. Prepared for the U. S.

Department of Energy, DOE Idaho Operations Office, Idaho Falls, ID. 456 pp.

FWS (Fish and Wildlife Service (FWS). 2003. PG&E biological assessment for valley

elderberry longhorn beetle.

————. 2008. Northern spotted owl recovery plan. Available [online]:

http://www.fws.gov/oregonfwo/Species/Data/NorthernSpottedOwl/Recovery/Plan/

#NoHeader. Accessed on January 13, 2010.

Heicksen, M.H. 1962. Site record for CA-SHA-252, Archaeological site survey record.

University of California Archaeological Survey.

Hunter, M.A. 1992. Hydropower flow fluctuations and salmonids: A review of the

biological effects, mechanical causes, and options for mitigation. Technical

Report No 119. State of Washington Department of Fisheries.

Huntington, C.W. 2004. Klamath River flows within the JC Boyle bypass and below the

JC Boyle powerhouse. Technical Memorandum to Larry Dunsmoor, Aquatic

Biologist, Klamath Tribes. April 15, 2004.

Moyle, P.B. 2002. Inland Fishes of California. University of California Press,

Berkeley, California. Revised Edition. 502 pp.

————. Unpublished. McCloud River Preserve: Biology and management.

Davis, California.
440

NatureServe. 2009. NatureServe Explorer: An online encyclopedia of life [web

application]. Version 7.1. NatureServe, Arlington, Virginia. Available

http://www.natureserve.org/explorer. Accessed: December 14, 2009.

Nevares and Lindstrand (Nevares, S., and L. Lindstrand, III). 2008a. Northern goshawk

surveys in the project area (WL-S1). Technical Memorandum 59, Pacific Gas &

Electric and North State Resources, Inc. December 2.

Nevares and Lindstrand (Nevares, S., and L. Lindstrand, III). 2008b. Willow flycatcher

habitat and presence survey in the project area (WL-S2). Technical

Memorandum 20, Pacific Gas & Electric and North State Resources, Inc.

November 12.

Nevares and Lindstrand (Nevares, S., and L. Lindstrand, III). 2008c. Northern spotted

owl surveys in the project area (WL-S1). Technical Memorandum 53, Pacific Gas

& Electric and North State Resources, Inc. October 31.

Nevares et al. (Nevares, S., T. Cosio, and C. Champe). 2008a. Bald eagle habitat use

near project reservoirs and project- affected stream reaches. Technical

Memorandum 61, Pacific Gas & Electric and Stillwater Sciences. December 10.

Nevares et al. (Nevares, S., T. Cosio, and C. Champe). 2008b. Summary of peregrine

falcon habitat use near project reservoirs and project-affected stream reaches.

Technical Memorandum 60. Pacific Gas & Electric and Stillwater Sciences.

December 9.

Nevares et al. (Nevares, S., D. Trawick, and C. Champe). 2009. Pacific fisher habitat in

the project area (WL-S4). Technical Memorandum 62, Pacific Gas & Electric and

Stillwater Sciences. February 3.

NERC (North American Electric Reliability Corporation). 2009. 2009 Long-term

reliability assessment, 2009-2018. October. Princeton, New Jersey. 448 pp.

NMFS (U.S. Department of Commerce, National Oceanic and Atmospheric

Administration, National Marine Fisheries Service). 2009a. Biological and

conference opinion on the long-term operations of the Central Valley Project and

State Water Project. June 4.

NMFS. (U.S. Department of Commerce, National Oceanic and Atmospheric

Administration, National Marine Fisheries Service). 2009b. Public Draft

Recovery Plan for the Evolutionarily Significant Units of Sacramento River

Winter-run Chinook Salmon and Central Valley Spring-run Chinook Salmon and

the Distinct Population Segment of Central Valley Steelhead. Sacreamento

Protected Resources Division. October 2009.

NMFS (U.S. Department of Commerce, National Oceanic and Atmospheric

Administration, National Marine Fisheries Service). 2010. Federal Power Act

Preliminary Prescriptions, Terms, Conditions, Recommendations, and Comments;

Motion to Intervene; and Management Goals and Objectives for the McCloud-Pit
441

Hydroelectric Project, Federal Energy Regulatory Commission Project No. 2106,

McCloud and Pit Rivers, California. January 28, 2010.

Osterkamp et al. (Osterkamp, W.R., C.R. Hupp, and J.C. Blodgett). 1986. Magnitude

and frequency of debris flows, and areas of hazard on Mount Shasta, Northern

California. U.S. Geological Survey Professional Paper 1396-C.

Parker, P. and T.F. King. 1998. National Register Bulletin 38, Guidelines for evaluating

and documenting Traditional Cultural Properties. U.S. Department of the

Interior, National Park Service, Washington, D.C.

PG&E (Pacific Gas and Electric). 1999. Environmental assessment for hydropower

license: Pit 1 Hydroelectric Project, FERC Project No. 2687-014. California.

————. 2001. Exhibit E. Pit 3, 4, 5 Relicensing. FERC 233.

————. 2006. McCloud-Pit Hydroelectric Project, FERC Project No. 2106,

Relicensing pre-application document (PAD). Volume I. Pacific Gas and Electric

Company.

————. 2008a. Regional Recreation Supply Assessment (RL-S2) Technical

Memorandum 45 (TM-45). October 6, 2008.

————. 2008b. Data Summary for Developed and Dispersed Recreation Inventory

(RL-S2) Updated October 2008 Technical Memorandum 16 (TM-16).

October 27, 2008.

————. 2008c. Flatwater Boating Assessment (RL-S2) Technical Memorandum 23

(TM-23). April 4, 2008.

————. 2008d. Regional Recreation Demand Assessment (RL-S1) Technical

Memorandum 37 (TM-37). November 11, 2008.

————. 2009a. McCloud-Pit Hydroelectric Project application for new major

license. FERC Project No. 2106. July 2009.

————. 2009b. McCloud-Pit Hydroelectric Project FERC Project No. 2106 response

to FERC’s August 14, 2009 Additional Information Request (AIR Response).

September 10, 2009.

————. 2009c. Lower McCloud River 1-D

————. 2009d. McCloud-Pit Hydroelectric Project, FERC Project No. 2106, Study

report CR-S1, Archaeological and historic-era properties (privileged). Pacific

Gas and Electric Company, relicensing application.

————. 2009e. McCloud-Pit Hydroelectric Project, FERC Project No. 2106,

Historic properties management plan (privileged). Pacific Gas and Electric

Company, relicensing application, Volume IV.
442

————. 2010a. Pacific Gas and Electric Company’s reply comments to comments,

recommendations, terms, and conditions. Pacific Gas and Electric Company.

March 16, 2010.

————. 2010b. McCloud-Pit Hydroelectric Project, FERC Project No. 2106,

Historic properties management plan (privileged). Pacific Gas and Electric

Company. October 26, 2011.

Rehn et al. (Rehn, A,. C.N. Ellenrieder, and P.R. Ode). 2007. Assessment of ecological

impacts of hydropower projects on benthic macroinvertebrate assemblages: A

review of existing data collected for FERC relicensing studies. California Energy

Commission, PIER - Energy Related Environmental Research Program.

CEC-500-2007-040.

Sawyer and Keeler-Wolf (Sawyer, John O., and Todd Keeler-Wolf). 1995. A manual of

California vegetation. California Native Plant Society.

Sierra Forest Legacy. 2008. Pacific fisher (Martes pennanti). Available [online]:

http://www.sierraforestlegacy.org/FC_SierraNevadaWildlifeRisk/PacificFisher.ph

p. Accessed on December 8, 2009.

Stebbins, R.C. 2003. Western reptiles and amphibians. Peterson Field Guides. Third

Edition. Houghton Mifflin Company, New York.

Tippets and Moyle (Tippets, W.E., and P.B. Moyle). 1978. Epibenthic feeding by

rainbow trout (Salmo gairdneri) in the McCloud River, California. Journal of

Animal Ecology 47:549–559.

Tu, M., C. Hurd and J.M. Randall. 2001. Weed Control Methods Handbook. The

Nature Conservancy. Available [online]:

http://www.invasive.org/gist/handbook.html. Accessed on November 17, 2010.

Winchell, F.C., S. Amaral, and D. Dixon. 2000. Hydroelectric turbine entrainment and

survival database: An alternative to field studies. Presented at Hydrovision 2000,

August 8-11, 2000. Charlotte, North Carolina.

Yoshiyama et al. (Yoshiyama, R., E. Gerstung, F. Fisher, and P. Moyle). 2001.

Historical and present distribution of Chinook salmon in the Central Valley

drainage of California. Contributions to the Biology of Central Valley Salmonids.

California Department of Fish and Game, Fish Bulletin 179.
443

7.0 LIST OF PREPARERS

G. Matt Buhyoff—Geology and Soils and Aquatic Resources (Fisheries Biologist; M.S.

Fisheries Science)

Emily Carter— EIS Coordinator, Terrestrial Resources, Threatened and Endangered

Species, and Editorial Review (Environmental Biologist; B.A. Environmental

Studies)

Jim Fargo—Engineering and Developmental Analysis (Civil Engineer; M.S. Civil

Engineering)

Mary Greene—Terrestrial Resources and Threatened and Endangered Species

(Environmental Biologist; B.S. Biology)

Shana Murray—Recreation, Land Use, and Aesthetic Resources (Outdoor Recreation

Planner; M.S. Recreation, Park, and Tourism Management)

Frank Winchell—Cultural Resources (Archeologist; B.A., M.A., Ph.D., Anthropology)

Jeffrey M. Boltz—Program Manager (Senior Scientist/Project Manager; Ph.D.,

Ecology/Ichthyology; B.S., Biology/Aquatic Sciences)

Thomas C. Cook—Engineering and Development Analysis (Senior Engineer; B.S., Civil

Engineering)

Janet L. Earickson—Editorial Review (Technical Writer/Editor; M.S., Professional

Writing; B.A., Geography and English; Certificate in Environmental Studies)

H. Jeffrey Elseroad—Project Manager, Water Quantity & Quality, Geology & Soils

(Senior Environmental Scientist; M.S.E., Environmental Engineering; B.A.,

Chemistry)

Jeffrey W. Hills—Program Management (Program Manager, Federal

Programs/Contracts; M.S., Civil Engineering (MSCE); M.S., Management

(MSM/MBA); B.S., U.S. Military Academy, West Point)

Mary Alice Koeneke—Terrestrial Resources (Senior Environmental Scientist; M.S.,

Biology/Environmental Science; B.S., Biology)

Charles W. Leasure—Terrestrial Resources (Senior Environmental Scientist; B.S.,

Horticulture)

Allegra M. Marcell—Terrestrial Resources (Environmental Scientist; M.S., Marine,

Estuarine and Environmental Sciences; B.S., Biology)

John G. Matkowski—Aquatic Resources (Environmental Scientist; M.S., Environmental

Science and Policy; B.S., Marine Science)

Paul H. Muessig—Aquatic Resources; Water Quantity and Quality; Geology and Soils

(Senior Environmental Scientist; M.S., Biological Oceanography; B.A., Biology)
444

Wendy Bley— Recreation/Land Use/Aesthetics (Senior Consultant; M.S., Natural

Resources Management)

Joyce Brooks—Recreation/Land Use/Aesthetics (Consultant; B.S., Biology –

Environmental Science Emphasis)

Jody Johns—Land Use/Aesthetics (Senior Consultant; Master of Urban and Regional

Planning; B.A., Political Science)

Mary Beth Reed—Cultural Resources (Project Manager; M.A., American Civilization;

B.A., Anthropology)
445

8.0 LIST OF RECIPIENTS

David Wright

1573 49th Street

Sacramento, California 95819

California Coastal Commission

45 Fremont Street, Suite 2000

San Francisco, California 94105-2219

William E. Foster, M.S.

Fishery Biologist

650 Capital Mall, Suite 8-300

Sacramento, California 95814-4706

Joshua Horowitz

Attorney

Bartkiewicz, Kronick & Shanahan

1011 22nd Street

Sacramento, California 95816-4907

Steve Rothert

Director, California Field Office

American Rivers

432 Broad Street

Nevada City, California 95959

Julie Gantenbein

Staff Attorney

Natural Heritage Institute

18255 Robin Avenue

Sonoma, California 95475-4043

Gerrit Jobsis

American Rivers

2231 Devine Street,

Columbia, South Carolina 29205-2419

Kevin Richard Colburn

National Stewardship Director

American Whitewater

1035 Van Buren Street

Missoula, Montana 59802

Dave Steindorf

California Stewardship Director

American Whitewater

4 Baroni Drive

Chico, California 95928-4314

Kelly L. Catlett

Policy Advocate

Friends of the River

915 20th Street

Sacramento, California 95814

Robert Baiocchi

President

Anglers Committee

P.O. Box 1035

Blairsden-Graeagle, California 96103

Dan Smith

Director of Regulatory Affairs

Association of California Water

Agencies

910 K Street, Suite 100

Sacramento, California 95814

Philip M. Battaglia

Attorney

P.O. Box 209

Los Olivos, California 93441-0209

Stephan Volker

Law Offices of Stephan C. Volker

436 14th Street

Oakland, California 94612
446

Jim Crenshaw

California Sportfishing Protection

Alliance

1248 E. Oak Avenue, Suite D

Woodland, California 95776-4104

California Department of Fish and Game

Regional FERC Coordinator

Northern California North Coast Region

601 Locust Street

Redding, California 96001-2711

California Department of Fish and Game

Office of the General Counsel

1416 9th Street, Floor 12

Sacramento, California 95814-5511

Annie Manji

Statewide FERC Coordinator

California Department of Fish and Game

Water Branch

830 S Street

Sacramento, California 95814

Matt Myers

California Department of Fish and Game

601 Locust Street

Redding, California 96002

Stephen G. Puccini

California Department of Fish and Game

1416 9th Street, Floor 12

Sacramento, California 95814-5510

Sidney Manheim

Senior Staff Counsel

California Electricity Oversight Board

770 L Street, Suite 1250

Sacramento, California 95814

FERC Contact

California Fish and Game Commission

Attn: Environmental Services Division

1416 9th Street

Sacramento, California 95814-5511

Orlando Foote

Attorney

Horton, Knox, Carter & Foote

895 Broadway

El Centro, California 92243

Richard Roos-Collins

Director, Legal Services

Natural Heritage Institute

100 Pine Street, Suite 1550

San Francisco, California 94111

Charlton Bonham

Trout Unlimited

1808B 5th Street

Berkeley, California 94710

Samuel D. Hough, ESQ

Directing Attorney

California Indian Legal Services

324 F Street

Eureka, California 95501

Governor of California

RE: FERC Projects

Office of the Governor of California

State Capitol Building

Sacramento, California 95814

Nate Rangel

President

California Outdoors

PO Box 401

Coloma, California 95613-0401
447

California Public Utilities Commission

505 Van Ness Avenue

San Francisco, California 94102-3214

Traci Bone

California Public Utilities Commission

505 Van Ness Avenue, 5

th Floor

San Francisco, California 94102

Margaret J. Kim

California Resources Agency

1416 9th Street, Suite 1311

Sacramento, California 95814-5509

Bob Baiocchi

Private Consultant

California Salmon and Steelhead

Association

P.O. Box 1035

Blairsden-Graeagle, California 96103

Percival Banks

Board Member

California Salmon and Steelhead

Association

1301 Quarry Court, Suite 204

Richmond, California 94801

Christopher Shutes

FERC Projects Director

Individual

1608 Francisco Street

Berkeley, California 94703

Curtis Knight

Conservation Manager

California Trout, Inc.

P.O. Box 650

Mt. Shasta, California 96067-0650

Brian J. Johnson

Staff Attorney

Trout Unlimited

B1808B 5th Street

Berkeley, California 94710

Harold Shepherd

Center for Tribal Water Advocacy

P.O. Box 331

Moab, Utah 84532-0331

Eric R. Klinkner

Assistant General Manager

City of Pasadena Dept. of Water &

Power

150 S. Los Robles, Suite 200

Pasadena, California 91101

Julie Gantenbein

Staff Attorney

Natural Heritage Institute

18255 Robin Avenue

Sonoma, California 95475-4043

Monty Crump

City Manager

City of Rockingham, North Carolina

514 Rockingham Road

Rockingham, North Carolina 28379

Mark Perlis

Partner

Dickstein Shapiro LLP

1825 Eye Street, NW

Washington, DC 20006-5403

R. Winston Bell, Jr

Vice President

Foothill Conservancy

P.O. Box 1255

Pine Grove, California 95665
448

Jennifer Carville

P. ADVOCATE

Friends of the River

1418 20th Street, Suite A

Sacramento, California 95811-5206

Steven G. Lins

Assistant City Attorney

Glendale, City of

613 E. Broadway. Suite 220

Glendale, California 91206-4308

Lloyd T. Bradshaw

Manager

Hearst Corporation

P.O. Box 670

McCloud, California 96057-0670

Tamara C. Falor

Esquire

Humboldt, County of

825 5th Street

Eureka, California 95501-1153

John Steffan

Imperial Irrigation District

P.O. Box 937

Imperial, California 92251-0937

Kathy Turner

FERC Coordinator

Lassen & Shasta-Trinity National Forests

P.O. Box 220

Fall River Mills, California 96028-0220

Norman Pedersen

Attorney

Hanna and Morton LLP

444 South Flower Street, Suite 1500

Los Angeles, California 90071-2916

Perl Perlmutter

Shute, Mihaly & Weinberger

396 Hayes Street

San Francisco, California 94102

Kristin Burford

Shute, Mihaly & Weinberger

396 Hayes Street

San Francisco, California 494102

Robert Perlmutter

Shute, Mihaly & Weinberger

396 Hayes Street

San Francisco, California 94102

Brian Momsen

Partner

Carter & Momsen LLP

P.O. Box 1709

Ukiah, California 95482

Dennis A. Amato

McCloud RiverKeepers

4723 Tee View Court

Santa Rosa, California 95405

John Whittaker

Winston & Strawn LLP

1700 K Street, NW

Washington, DC 20006-3817

Water Users Association

P.O. Box 31

El Nido, California 95317

Gregory Pohl

Modesto Irrigation District

P.O. Box 4060

Modesto, California 95352-4060
449

Ronald S. Nelson

General Manager

Nevada Irrigation District

P.O. Box 1019

Grass Valley, California 95945-1019

Jeffrey Meith

Partner

Meith, Soares & Sexton, LLP

1681 Bird Street

Oroville, California 95965

Les Nicholson

Hydro Manager

Nevada Irrigation District

28311 Secret Town Road

Colfax, California 95713-9473

Eric Theiss

Fisheries Biologist

NOAA, General Counsel Southwest

1655 Heindon Road

Arcata, California 95521

Karl W. Meyer

Northern California Power Agency

180 Cirby Way

Roseville, California 95678-6420

Joshua Rider

United States Department of Agriculture

33 New Montgomery, 17th Floor

San Francisco, California 94105

Michael Glaze

General Manager

Oroville-Wyandotte Irrigation District

2310 Oro-Quincy Highway

Oroville, California 95966

Annette Faraglia

Attorney

Pacific Gas and Electric Company

P.O. Box 7442

San Francisco, California 94120-7442

Randal S. Livingston

Lead Director

Pacific Gas and Electric Company

P.O. Box 770000

San Francisco, California 94177-0001

PG&E Law Dept FERC Cases

Pacific Gas and Electric Company

77 Beale Street, Room 3120 B30A

San Francisco, California 94120-7442

Michael W. Neville

Deputy Attorney General

People of the State of California

455 Golden Gate Avenue, Suite 11000

San Francisco, California 94102-7004

FERC Contact

Pit River Tribe

36970 Park Avenue

Burney, California 96013

Tribal Council

Pit River Tribe

36970 Park Avenue

Burney, California 96013

Michelle Berditschevsky

Director

Environmental Coordinator

Pit River Tribe

37014 Main Street Burney, California

96013
450

David Arthur

Redding Electric Utility

P.O. Box 496071

Redding, California 96049-6071

Lon W. House

Regional Council or Rural Counties

4901 Flying C Road

Cameron Park, California 95682

Kirby Bosley

Manager

Reliant Energy Wholesale Group

P.O. Box 148

Houston, Texas 77001-0148

Kathy A. Valenzuela

Shasta-Trinity National Forest

3644 Avtech Parkway

Redding, California 96002

Michael Pretto

Silicon Valley Power

1500 Warburton Avenue

Santa Clara, California 95050-3713

Raymond C. Camacho

Assistant Director of Electric

Silicon Valley Power

1500 Warburton Avenue

Santa Clara, California 95050

County Clerk

Siskiyou, County of

510 N. Main Street

Yreka, California 96097-2525

Robert Isaac

General Manager

Solano Irrigation District

508 Elmira Road

Vacaville, California 95687-4931

Michael D. Mackness

Southern California Edison Company

P.O. Box 800

Rosemead, California 91770-0800

Michael Caranci

The Fly Shop

4140 Churn Creek Road

Redding, California 96002

Mike Michalak

Chief Executive Officer

The Fly Shop

4140 Churn Creek Road

Redding, California 96002

Steve Felte

General Manager

Tri-Dam Project

P.O. Box 1158

Pinecrest, California 95364-0158

Michael T. Brommer

Turlock Irrigation District

P.O. Box 949

Turlock, California 953810949-0949

Regional Environmental Officer

U.S. Department of Interior

1111 Jackson Street, Suite 700

Oakland, California 94607-4807

Dennis O’Halloran

FERC Coordinator

Department of Interior

6000 J. Street, Placer Hall

Sacramento, California 95819
451

Stephen M. Bowes

Planner

U.S. Department of the Interior

1111 Jackson Street

Oakland, California 94607

Kerry O’Hara

Office of the Regional Solicitor

Department of the Interior

2800 Cottage Way, Suite E-1712

Sacramento, California 95825-1863

Field Supervisor

Sacramento Office

Department of the Interior

2800 Cottage Way, Room W-2605

Sacramento, California 95825

Randall R. Thoreson

National Park Service RTCA/H

National Park Service

111East Kellogg Blvd. Suite 105

St. Paul, Minnesota 55101

Commander

U.S. Army Corps of Engineers

San Francisco District Office

1455 Market Street, #1760

San Francisco, California 94103

Robert Hawkins

Natural Resource Planner

USDA Forest Service Pacific SW

Region

650 Capital Mall Rm 8-200

Sacramento, California 95603

Julie Tupper

USDA Forest Service Pacific SW

Region

650 Capital Mall Rm 8-200

Sacramento, California 95603

Jim Canaday

Senior Environmental Scientist

Water Resources Control Board

1001 I Street

Sacramento, California 95814

Mark Franco

Headman

Winnemem Wintu Tribe

14840 Bear Mountain Road

Redding, California 96003

Curt Aikens

General Manager

Yuba County Water Agency

1220 F Street

Marysville, California 95901
452

This page intentionally left blank
Appendix A

Staff Responses to Comments on the Draft Environmental

Impact Statement

A-1

APPENDIX A

STAFF RESPONSES TO COMMENTS ON THE DRAFT ENVIRONMENTAL

IMPACT STATEMENT

The U.S. Environmental Protection Agency (EPA) notice of availability of the

draft environmental impact statement (EIS) for the McCloud Pit Hydroelectric Project

(project) was issued on July 30, 2010, and comments on the draft EIS were due on

September 28, 2010. In addition, Federal Energy Regulatory Commission (Commission)

staff conducted two public meetings to receive oral comments on the draft EIS in

Redding, California, on September 9, 2010. Twenty-one out of 33 members of the public

that attended the meetings spoke. Speakers commented on instream flows for the project,

including support for boating and angling/fishery flows; designation of project roads;

delineation of the project boundary; snow removal; recreation facilities and access; dam

safety; and the potential for anadromous fish reintroductions in the project area.

Additionally, there were 428 filings by individuals during the comment period, which

included comments regarding the hydrograph and fishery in the project area, as well as

boating and angling flows. These topics were also addressed in 26 additional filings by

individuals, organizations, or agencies, after the conclusion of the formal comment

period.

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. We do not summarize comments that point out minor edits to the draft EIS;

however, we have made these edits in the final EIS. The following entities filed

comments on the draft EIS.

Commenting Entity Filing Date

California Fisheries and Water Unlimited August 5, 2010

Pacific Gas and Electric (PG&E) August 5, 2010

California Salmon and Steelhead Association August 6, 2010

California Fisheries and Water Unlimited August 19, 2010

California Fisheries and Water Unlimited August 20, 2010

McCloud RiverKeepers August 23, 2010

California Coastkeeper Alliance September 17, 2010
A-2

Commenting Entity Filing Date

California Sportfishing Protection Alliance September 22, 2010

California Fisheries and Water Unlimited September 23, 2010

U.S. Department of Agriculture – Forest

Service (Forest Service)

September 24, 2010

Forest Service September 24, 2010

Forest Service September 27, 2010

PG&E September 27, 2010

The Hearst Corporation September 27, 2010

California State Water Resources Control

Board (California Water Board)

September 28, 2010

National Park Service September 28, 2010

U.S. Department of Commerce, National

Oceanic and Atmospheric Administration,

National Marine Fisheries Service (NMFS)

September 28, 2010

California Trout, Trout Unlimited, Northern

California Council, Federation of Fly Fishers

September 28, 2010

Center for Water Advocacy September 28, 2010

EPA, Region 9 September 28, 2010

McCloud River Club September 28, 2010

American Whitewater and Friends of the

River

September 28, 2010

Winnemem Wintu Tribe September 28, 2010

Winnemem Wintu Tribe September 29, 2010

McCloud RiverKeepers September 29, 2010

Pit River Tribe September 29, 2010
A-3

Commenting Entity Filing Date

California Fisheries and Water Unlimited November 12, 2010

McCloud RiverKeepers November 30, 2010

California Department of Fish and Game

(California Fish and Game)

December 22, 2010

McCloud RiverKeepers December 23, 2010

McCloud RiverKeepers December 29, 2010

California Fisheries and Water Unlimited January 3, 2011

Individual

Commenter

Filing Date Individual

Commenter

Filing Date

Eing Ong August 25, 2010 Michael McWhirter September 8, 2010

Eric Juday August 25, 2010 Michael Brocchini September 9, 2010

Mark R Zakutansky August 25, 2010 Noel Alfague September 9, 2010

Chris G. Uhtoff September 1, 2010 Robert Dougherty September 9, 2010

David E Schwartz September 1, 2010 Ron Rogers September 9, 2010

Jeffrey Sanchez September 2, 2010 Bruce Jones September 9, 2010

Mary Elliott September 2, 2010 Dave Steindorf September 9, 2010

Urs Schhuler September 2, 2010 Eric White September 9, 2010

David Greenleaf September 3, 2010 Ilona Karow September 9, 2010

Matt Jordan September 3, 2010 Michael Caranci September 9, 2010

Mira Boyda September 3, 2010 Mike Martini September 9, 2010

Robert Warren September 3, 2010 Paul Gamache September 9, 2010

Justin September 7, 2010 Peter Gerodette September 9, 2010

Todd Reasor September 7, 2010 Steve Andrews September 10, 2010
A-4

Individual

Commenter

Filing Date Individual

Commenter

Filing Date

Daniel Brasuell September 8, 2010 Tim Hadsell September 10, 2010

Jerome Brisson September 8, 2010 Chuck Seidler September 13, 2010

Douglas Pease September 13, 2010 Judith Austin Brown September 14, 2010

Frank Atter September 13, 2010 Judy Decker-Inouye September 14, 2010

John Colton September 13, 2010 Kenneth Nakano September 14, 2010

Joyce and David

Quinn September 13, 2010 Lee Jester September 14, 2010

Paul Schraeder September 13, 2010 Louis Fry September 14, 2010

Philip Foti September 13, 2010 M. Kim Fondrk September 14, 2010

Alex Flagg September 14, 2010 Michael Bland September 14, 2010

Andrew Weiner September 14, 2010 Michelle Hladik September 14, 2010

Bill McDonald September 14, 2010 Mike Guerin September 14, 2010

Carole Newman September 14, 2010 Milton Granton September 14, 2010

Charles Gunther September 14, 2010 Paul Vais September 14, 2010

Don Meehan September 14, 2010 Paula Zerzan September 14, 2010

Ed Heneveld September 14, 2010 Peter Haddad September 14, 2010

Ed Phelan September 14, 2010 Ralph Cutter September 14, 2010

Guy Hendersen September 14, 2010 Robert Ferroggiaro September 14, 2010

Ilona Karow September 14, 2010 Ross Capdeville September 14, 2010

James Pepin September 14, 2010 S. Brainerd September 14, 2010

Jan Whitacre September 14, 2010 Steven Johnson September 14, 2010

Jason Clark September 14, 2010 Terry Sternberg September 14, 2010
A-5

Individual

Commenter

Filing Date Individual

Commenter

Filing Date

Jerry Tone September 14, 2010 Tim Little September 14, 2010

Joseph Nowak September 14, 2010 Tim Metz September 14, 2010

William Henry September 14, 2010 Jim and Diana Prola September 15, 2010

Amanda PetrackZunich September 15, 2010 Jim Breyer September 15, 2010

Bjorn Stromsness September 15, 2010 Jim Parks September 15, 2010

Bryan Vais September 15, 2010 Jim Parrinello September 15, 2010

Charles Sambol September 15, 2010 John O'Hern September 15, 2010

Charles Ward September 15, 2010 Joyce Quinn September 15, 2010

Chris Welch September 15, 2010 Judy Decker-Inouye September 15, 2010

Daniel Eckhard September 15, 2010 Kate Karriker-Jaffe September 15, 2010

Daniel Maher September 15, 2010 Laura Heron September 15, 2010

Dean September 15, 2010 Michael Pike September 15, 2010

Dennis Leski September 15, 2010 Mike Caltagirone September 15, 2010

Dennis Parker September 15, 2010 Neil Nikirk September 15, 2010

Duane September 15, 2010 Nick Sinderson September 15, 2010

Gary Slade September 15, 2010 Noel Alfague September 15, 2010

Gerald MacIntosh September 15, 2010 Norman Christensen September 15, 2010

Greg Foy September 15, 2010 Peter Walker September 15, 2010

Jack Obedzinski September 15, 2010 Peter Williamson September 15, 2010

Jeff Trafican September 15, 2010 Phillip Erickson September 15, 2010

Jeff Wasielewski September 15, 2010 Richard Melbostad September 15, 2010
A-6

Individual

Commenter

Filing Date Individual

Commenter

Filing Date

Jeremy Clark September 15, 2010 Ron Mastalski September 15, 2010

Jerome Marek September 15, 2010 Rosealea Bond September 15, 2010

RP September 15, 2010 Mark Mills September 16, 2010

Sarah Hugdahl September 15, 2010 Marsh Chamberlain September 16, 2010

Scott September 15, 2010 Matt Zidar September 16, 2010

Susan Clymer September 15, 2010 Michael Holstrom September 16, 2010

Suzanne Remien September 15, 2010 Mike Kempf September 16, 2010

Teresa Fantasia September 15, 2010 Paul Cress September 16, 2010

Terry and Sue Hall September 15, 2010 Paul Sumner September 16, 2010

Thomas Bates September 15, 2010 Richard Schieffer September 16, 2010

Tim Hunt September 15, 2010 Roger Finke September 16, 2010

Timothy Devine September 15, 2010 Steve Schramm September 16, 2010

Tom Venus September 15, 2010 Steven Schlegel September 16, 2010

Tom Williams September 15, 2010 Steven Tichenor September 16, 2010

Chris Noyes September 16, 2010 Tom Chandler September 16, 2010

Colin Drake September 16, 2010 Brian Ginsberg September 17, 2010

Don Iverson September 16, 2010 Charles Belsom, Jr. September 17, 2010

Don McEnhill September 16, 2010 Dave Wilkinson September 17, 2010

Greg Gotham September 16, 2010 Gabriel Lopez September 17, 2010

James Kirwan September 16, 2010 Justin Cordonnier September 17, 2010

John Barry September 16, 2010 Linda Pepin September 17, 2010

John Donati September 16, 2010 Michael Russell September 17, 2010
A-7

Individual

Commenter

Filing Date Individual

Commenter

Filing Date

John Wylie September 16, 2010 Peter Przybylinski September 17, 2010

Keith Anderson September 16, 2010 Roger Watson September 17, 2010

Tom Rafalovich September 17, 2010 Ron Szymanski September 21, 2010

Bill Street September 20, 2010 Dan Barber September 23, 2010

Dennis Johnson September 20, 2010 Terrance Carr September 23, 2010

Don Mittelstaedt September 20, 2010 Randy Brown September 24, 2010

Doug Walker September 20, 2010 Beth Gaydos September 27, 2010

Esther Mecking September 20, 2010 Cyrus Merrill September 27, 2010

Gary Sanda September 20, 2010 Dick Harris September 27, 2010

Lewis Leichter September 20, 2010 Eric Arons September 27, 2010

Mark York September 20, 2010 Frank Babbitt September 27, 2010

Mike and Jude Lee September 20, 2010 Ida Crawford September 27, 2010

Peter Klosterman September 20, 2010 J. Larry Carroll September 27, 2010

Raffi Boloyan September 20, 2010 Jesse Johnson September 27, 2010

Saskia Baur September 20, 2010 Kathy Gray September 27, 2010

Thomas Lane September 20, 2010 Leila Lanctot September 27, 2010

Will Gardner September 20, 2010 Marilyn Freedberg September 27, 2010

Bruce Forsythe September 21, 2010 Robin Stocum September 27, 2010

Gregory Reis September 21, 2010 Rudy Ramp September 27, 2010

Harald Ekman September 21, 2010 Todd Walsh September 27, 2010

Jennie Goldberg September 21, 2010 Urs Schhuler September 27, 2010

Kevin Mather September 21, 2010 Victor Simend September 27, 2010
A-8

Individual

Commenter

Filing Date Individual

Commenter

Filing Date

Lowel Sims September 21, 2010 Victoria Smith September 27, 2010

Luke Kornbluh September 21, 2010 William H Bunstock September 27, 2010

Adam Dwinells September 28, 2010 Craig Nielsen September 28, 2010

Alan Chaplin September 28, 2010 Dan Sadowski September 28, 2010

Alex Cichy September 28, 2010 Darrell Boyle September 28, 2010

Alex Gutt September 28, 2010 Dave Kellogg September 28, 2010

Allen Hallock September 28, 2010 David Balducci September 28, 2010

Amit Kapoor September 28, 2010 David Figur September 28, 2010

Andy Coradeschi September 28, 2010 David Garfin September 28, 2010

Barry Urbach September 28, 2010 David Hale September 28, 2010

Bill Lattin September 28, 2010 David Hobbs September 28, 2010

Bill Wharton September 28, 2010 David Hohler September 28, 2010

Bob September 28, 2010 David Knapp September 28, 2010

Bob Shoberg September 28, 2010 David Lipscomb September 28, 2010

Brian Wright September 28, 2010 David Morris September 28, 2010

Bruce Antell September 28, 2010 David Peterson September 28, 2010

Bruce Pederson September 28, 2010 David Sesline September 28, 2010

Caleb Garling September 28, 2010 David Varney September 28, 2010

Carl Searway September 28, 2010 David Wood September 28, 2010

Chris September 28, 2010 Derald Lahti September 28, 2010

Christopher Fox September 28, 2010 Don Meehan September 28, 2010

Christopher Hest September 28, 2010 Donald Pierce September 28, 2010
A-9

Individual

Commenter

Filing Date Individual

Commenter

Filing Date

Cliff Butcher September 28, 2010 Doug Durham September 28, 2010

Clint Kelley September 28, 2010 Edgar Fincher September 28, 2010

Edward Bruno September 28, 2010 James Mathis September 28, 2010

Ellwood Jones September 28, 2010 James Scanlon September 28, 2010

Eric Miller September 28, 2010 Jamie Lyle September 28, 2010

Evan Elliott September 28, 2010 Jeff McLoughlin September 28, 2010

Gary Bard September 28, 2010 Jeff Ramsdell September 28, 2010

Gene Gantt September 28, 2010 Jeffrey Henigan September 28, 2010

George Hayford September 28, 2010 Jeremy Cadagan September 28, 2010

George Williams, Sr. September 28, 2010 Jim Collins September 28, 2010

George Yandell September 28, 2010 Jim DeSwarte September 28, 2010

Gerald Weisbach September 28, 2010 Jim Gaumer September 28, 2010

Greg Dinger September 28, 2010 Jim Kuehne September 28, 2010

Hal Watts September 28, 2010 Jim Miller September 28, 2010

Heather Carrico September 28, 2010 Jim Milligan September 28, 2010

Hobson Brown September 28, 2010 Joe Euphrat September 28, 2010

Hugh Barron September 28, 2010 John Curran September 28, 2010

Hugh Beattie September 28, 2010 John Davey September 28, 2010

Hugh Kuhn September 28, 2010 John DeMartino September 28, 2010

Jack Campbell September 28, 2010 John H. Davis September 28, 2010

Jack Street September 28, 2010 John Kagel September 28, 2010

James Feller September 28, 2010 John McGuire September 28, 2010
A-10

Individual

Commenter

Filing Date Individual

Commenter

Filing Date

James Ferguson September 28, 2010 John Newhoff September 28, 2010

James Hann September 28, 2010 John Reed September 28, 2010

John Rickard September 28, 2010 Melvin September 28, 2010

John Street September 28, 2010 Michael Balog September 28, 2010

Jon Goerke September 28, 2010 Michael Carey September 28, 2010

Jon Goulden September 28, 2010 Michael Jordan September 28, 2010

Jon Steele September 28, 2010 Michael Kalinowski September 28, 2010

Joseph Bunning September 28, 2010 Michael Tomlinson September 28, 2010

Joseph Sturla September 28, 2010 Mike Bobbitt September 28, 2010

Joy Chesna September 28, 2010 Mike Miller September 28, 2010

Karen Henderson September 28, 2010 Mike Milliorn September 28, 2010

Katherien Brandt September 28, 2010 Mike O'Dell September 28, 2010

Kelly Barlow September 28, 2010 Mike Pingree September 28, 2010

Ken Kerley September 28, 2010 Mike Rogers September 28, 2010

Kirk Clague September 28, 2010 Nathan Hall September 28, 2010

Laura Loper September 28, 2010 Nick Di Croce September 28, 2010

Laurie Urbach September 28, 2010 Nick Salle September 28, 2010

Lawrence Miller September 28, 2010 Pat Carroll September 28, 2010

Leland Wilson September 28, 2010 Paul McKee September 28, 2010

Lisa Hogan September 28, 2010 Paul Siple September 28, 2010

Marc Ericksen September 28, 2010 Peter Michaelides September 28, 2010

Mark Adams September 28, 2010 Peter Towle September 28, 2010
A-11

Individual

Commenter

Filing Date Individual

Commenter

Filing Date

Mark Kanai September 28, 2010 R. Burke September 28, 2010

Mark Spieler September 28, 2010 Randall Boyd September 28, 2010

Randy Renick September 28, 2010 Steve Kopp September 28, 2010

Rex Murphy September 28, 2010 Ted Shapas September 28, 2010

Richard Hanavan September 28, 2010 Terence Grant September 28, 2010

Richard Scott Nelson September 28, 2010 Terry Fernandez September 28, 2010

Rika Nelson September 28, 2010 Thomas Bertetta September 28, 2010

Rober Pauli September 28, 2010 Tim Burwell September 28, 2010

Robert September 28, 2010 Tim Hanagan September 28, 2010

Robert Alex Corum September 28, 2010 Tim McCrone September 28, 2010

Robert Miller September 28, 2010 Tim Polishook September 28, 2010

Robert Minor September 28, 2010 Tim Stutz September 28, 2010

Robert Oliver September 28, 2010 Tim Sullivan September 28, 2010

Ryan Popple September 28, 2010 Tim Swihart September 28, 2010

Sage Donnelly September 28, 2010 Tom Higgins September 28, 2010

Sam Bishop September 28, 2010 Tom Street September 28, 2010

Seymour Singer September 28, 2010 Tony Alex September 28, 2010

Sheree Kajiwara September 28, 2010 Tony Brookfield September 28, 2010

Stanley Bricker September 28, 2010 Trevor Rhodes September 28, 2010

Stanley O'Hara September 28, 2010 Tricia September 28, 2010

Stephen Haggard September 28, 2010 Walter Bird September 28, 2010

Stephen Neff September 28, 2010 Will Lyon September 28, 2010
A-12

Individual

Commenter

Filing Date Individual

Commenter

Filing Date

Stephen Ordway September 28, 2010 William O'Brien September 28, 2010

Stephen Zakur September 28, 2010 William O'Kelly September 28, 2010

William Werner September 28, 2010 Kevin Eastman September 29, 2010

Alan Chun September 29, 2010 Libby McLaren September 29, 2010

Alex Cichy September 29, 2010 Lyle Timmerman September 29, 2010

Andy Benkert September 29, 2010 Mark Rockwell September 29, 2010

Barbara Korb September 29, 2010 Martin M. Seldon September 29, 2010

Barry Vorpahl September 29, 2010 Matthew P. Walters September 29, 2010

Brett Henderson September 29, 2010 Michael McGibben September 29, 2010

Brian Stewart September 29, 2010 Michael Rettie September 29, 2010

Chris Crofford September 29, 2010 Nancy R. Ihara September 29, 2010

Chris Little September 29, 2010 Nathan September 29, 2010

Chris Moore September 29, 2010 Pamela Gach September 29, 2010

Craig Jaffurs September 29, 2010 Patrick McKee September 29, 2010

Curtis Kroeker September 29, 2010 Patrick Ryan September 29, 2010

David Bender September 29, 2010 Paul Crafts September 29, 2010

David Carter September 29, 2010 Paul Martzen September 29, 2010

Derrell Bridgman September 29, 2010 Paul Stiff September 29, 2010

Diane Lowe September 29, 2010 Piasente September 29, 2010

Domi Fellers September 29, 2010 Robert Bonfilio September 29, 2010

Erik White September 29, 2010 Robert Williams September 29, 2010

Jeff Spurr September 29, 2010 Ron Azevedo September 29, 2010
A-13

Individual

Commenter

Filing Date Individual

Commenter

Filing Date

John Phair September 29, 2010 Sean Solway September 29, 2010

Ken Del Monte September 29, 2010 Sonia Dinger September 29, 2010

Steven Gwozdz September 29, 2010 Bob McConachie October 4, 2010

Tom Waters September 29, 2010 David Hale October 4, 2010

Woody Lowe September 29, 2010 Loren Crow October 4, 2010

Brian Sugrue September 30, 2010 Luis Motes October 4, 2010

Donald Wayne September 30, 2010 S.Sax October 4, 2010

Gary Rich September 30, 2010 Bart Hughes October 8, 2010

Henry Bramhall September 30, 2010 Bill Lang October 12, 2010

John McCosker September 30, 2010 Charles Hammerstad October 12, 2010

Roger Bevers September 30, 2010 Michael Culcasi October 12, 2010

Stephanie Bates September 30, 2010 Wade Goertz October 12, 2010

David Fiore October 1, 2010 John Hamilton October 19, 2010

Trevor Fagerskog October 1, 2010

GENERAL

Comment: The Forest Service and PG&E note that, as a result of a recent land

interchange between the Forest Service and the Bureau of Land Management (BLM), the

current project boundary now encompasses 1,651.4 acres of National Forest System

(NFS) lands, and 0 acres of BLM lands. PG&E also clarifies that except for the area

immediately below McCloud dam, no project lands are located along the Lower

McCloud River.

Response: We have updated the EIS text to reflect these changes to the project acreage.

Comment: PG&E notes that figure 1-1 is missing several project powerlines and should

show the: (1) 12-kV distribution line between James B. Black Powerhouse and Iron

Canyon dam; (2) transmission line between the James B. Black and Pit 5 switchyards;

and (3) Pit 6 and Pit 7 transmission lines.
A-14

Response: We have updated figures 1-1 and 2-1 to provide this additional detail

regarding project powerlines.

Comment: The California Water Board states that the scope in the final EIS should

include the McCloud River to Shasta reservoir (not just to the mouth of Squaw Valley

Creek), because studies were conducted throughout these areas. EPA, Region 9 notes

that the draft EIS limits the project scope on the McCloud River to the mouth of Squaw

Valley Creek, but that the project controls water flow down to Shasta reservoir. EPA,

Region 9 recommends that the scope of analysis in the final EIS be modified to reflect

this.

California Trout, Trout Unlimited, and the Northern California Council, Federation of Fly

Fishers also disagree with the assertion that the effect of project operations is not

measurable below Squaw Valley Creek, and that this is the extent of project nexus. They

state that there is a direct and quantifiable relationship between instream flow

requirements for the McCloud River and streamflows all the way to Shasta reservoir, and

that license requirements for instream flow releases from McCloud reservoir have a direct

relationship to streamflow quantity and timing all the way to Shasta reservoir. They

agree, however, that the increased flow is no longer a project nexus once it reaches

Shasta Lake, and that any differences that might exist in timing are inconsequential.

Response: The project scope was defined through the scoping process and comments

received on geographical and temporal scope at that time. After scoping, we determined

that generally, the magnitude of project effects decrease going downstream as other

tributaries enter the river, and therefore, the project has minimal additional impacts below

Squaw Valley Creek. We acknowledge, however, that several studies proposed by

PG&E included study sites on the Lower McCloud River, below the confluence of Squaw

Valley Creek, as requested by the parties involved in this Integrated Licensing Process.

Commission staff did not require studies at these sites because they found these sites to

be outside of the geographic scope and have no project nexus; however, PG&E decided

to continue to include them within its proposed studies. We note that with these study

sites on the Lower McCloud River, below the confluence of Squaw Valley Creek, the

scope of analyses in the environmental document was not necessarily limited to areas

upstream of Squaw Valley Creek. In evaluating project impacts during preparation of the

draft EIS, we again determined that project effects decrease going downstream as other

tributaries enter the river, the project has minimal additional impacts below Squaw

Valley Creek, and the project geographic scope did not need to be modified for the

environmental analysis.

Comment: The Center for Water Advocacy recommends that plans should provide a

means of funding local Indian tribes to cover monitoring and assist with mitigation

activities.

Response: The Commission cannot require applicants to make funding provisions to

third parties. PG&E may agree to pay a third party to perform mitigation and monitoring

activities; however, the Commission has jurisdiction only over its licensee and thus
A-15

cannot ensure that a measure will be carried out if only funding is required. The

Commission will leave it to PG&E to determine how to best fulfill the requirements of

any license issued.

Comment: The Forest Service notes that it discussed and agreed with PG&E that all

final 4(e) conditions would consistently refer to “license acceptance” and not “license

issuance” as the trigger date for implementation of the 4(e) condition requirements. This

distinction would provide a minimum of one additional month for PG&E to comply with

the measures.

Response: It is general Commission practice to use the more certain date of license

issuance rather than license acceptance as a trigger point for development and

implementation of environmental actions. If deadlines for compliance with the

requirements of license articles become an issue, the appropriate remedy is for PG&E to

seek extensions of those deadlines.

Comment: PG&E states that because the Forest Service recently completed a land

exchange that transferred management of the 29.5 acres of project lands administered by

BLM to the Forest Service and all federal lands occupied by the project are now managed

by the Forest Service, the BLM resource management plan is no longer applicable to the

project.

Response: We agree that the BLM resource management plan is no longer applicable to

the project because of the recent land exchange and have removed references to this

resource management plan from the EIS text.

Comment: The California Salmon and Steelhead Association feels that the draft EIS

does not disclose and evaluate cumulative effects on the human environment resulting

from Forest Service 4(e) conditions.

Response: The EIS includes a comprehensive analysis of the measures specified in the

Forest Service 4(e) conditions. Furthermore, as stated in the EIS, based on information in

the license application, agency comments, other filings related to the project, and

preliminary staff analysis, we identified the following resources that have the potential to

be cumulatively affected by the continued operation of the McCloud-Pit Project, in

combination with other activities: water resource, fisheries resources, and recreation.

Accordingly, we included a discussion of cumulative effects on applicable resources in

sections 3.3.2.3, Cumulative Effects, of the draft and final EIS.

Comment: The California Water Board comments that the section on cumulative effects

does not address the impact of this project incrementally with other past, present, and

reasonably foreseeable future actions. The California Water Board recommends that, at a

minimum, this project should be evaluated with the operation of the Pit 3, 4, 5 Project.

Response: The cumulative effects analysis has been expanded to include a summary of

the potential effects of project operations in conjunction with operation of the

Pit 3, 4, 5 Project and other reasonably foreseeable future actions.
A-16

Comment: The California Water Board states that for projects with less than significant

impacts, a negative declaration or mitigated negative declaration can be issued. The

California Water Board states that the California Environmental Quality Act (CEQA)

also provides categorical and statutory exemptions for certain projects. The California

Water Board states that the draft EIS incorrectly implies that an environmental impact

report (EIR) will be required for this project (section 1.3.6, page 19). The California

Water Board states that under CEQA, a project may be analyzed for its incremental

effects over existing baseline conditions. Typically the reauthorizing of an existing

hydroelectric project will not yield many environmental impacts, because most of the

impacts have already occurred and, when compared to the existing condition, do not

register as significant. The California Water Board notes that often, significant impacts

occur from construction of new facilities necessary to obtain all necessary permits and

approvals and/or bring the project into compliance with existing law. Further, because

National Environmental Policy Act (NEPA) documents do not specifically identify

significant impacts, the California Water Board notes that additional analysis may be

required to identify the impacts and comply with CEQA. California Water Board states

that staff may rely on sections of this draft EIS or final EIS.

Response: We understand the comments from the California Water Board concerning

the relationship of the NEPA and CEQA process and documents, and we have updated

the final EIS, section 1.3.6., California Environmental Quality Act, to reflect the

California Water Board’s comments.

Comment: The California Water Board notes that, unless PG&E is moving forward with

plans for the proposed new powerhouses at McCloud dam and Pit 7 afterbay dam, it will

be difficult to analyze the impacts resulting from construction and operation. The

California Water Board notes that construction of new facilities could result in impacts

that must be analyzed in CEQA.

Response: Although PG&E studied the feasibility of installing new generation units at

the base of McCloud dam and at the Pit 7 afterbay dam, the final license application for

the McCloud-Pit Project did not include the final size of these units because PG&E stated

that it would determine the size and hydraulic capacity based on instream flow

requirements of the new project license. Furthermore, our economic analysis of the

proposed units found that the cost could exceed the potential power benefits; however,

we could not make a final recommendation until PG&E decided on the exact capacity of

the units. If PG&E decided to move forward with either of the proposals, further analysis

would be required at that time.

Comment: The California Water Board states that allowing a project to operate

indefinitely without making progress to obtain a new license is inconsistent with the

Federal Power Act (FPA) and the California Water Board requests a more realistic

evaluation of the no-action alternative in the final EIS.

Response: The purpose of the no-action alternative, as described in section 2.1,

No-Action Alternative, is to establish baseline environmental conditions for comparison
A-17

with other alternatives. We intend to issue a new project license prior to the expiration of

the current license on July 31, 2011, so that the project will not be operated indefinitely

under the existing license.

However, the Commission cannot issue a new license for the project without water

quality certification from the California Water Board under section 401 of the Clean

Water Act. Therefore, for the Commission to timely act on PG&E’s relicense application

by this date, the California Water Board will need to do its part by timely acting on

PG&E’s application for water quality certification.

To help expedite the CEQA process that the California Water Board must undertake

before acting on PG&E’s water quality certification, we have expanded the final EIS to

include several elements needed in an environmental report prepared under CEQA

(please see final EIS section 1.3.6, California Environmental Quality Act). Though not a

joint environmental document between the Commission and the California Water Board,

we hope that including these CEQA-required elements will reduce the time the California

Water Board needs to act on the pending water quality certification application.

Comment: California Fisheries and Water believes that the draft EIS does not

comprehensively disclose and evaluate the effects to the human environment resulting

from section 4(e) requirements of the Forest Service and also section 401 of the Clean

Water Act, water quality certification requirements of the California Water Board. For

example, California Fisheries and Water believes that the draft EIS fails to consider the

effects to federally protected Shasta crayfish of the Pit River below Fall River. California

Fisheries and Water feels that the draft EIS is in violation of NEPA and must be

amended. California Fisheries and Water also believes that the draft EIS does not

disclose and evaluate the effects to the safety of California licensed anglers (including

disabled anglers) resulting from specific daily flow section 401 requirements of the Clean

Water Act.

California Fisheries and Water feels that the draft EIS does not disclose and evaluate the

direct and cumulative effects to wild trout fisheries of the Lower McCloud (including the

potential stranding of juvenile and adult trout), macroinvertebrate species and their

habitat, water quality, the State of California Wild Trout Policy, the environment, the

California Wild and Scenic River Act for the McCloud River, and boating requirements,

resulting from the effects to power production, as related to section 401 requirements of

the Clean Water Act.

Response: We have addressed both resource-specific and cumulative effects of the

project alternatives, including flow recommendations, in the sections of the EIS on

aquatic resources, special status species, water quality, and recreation. We considered all

relevant federal or state comprehensive plans for waterways affected by the project in our

comprehensive analysis. We have not addressed impacts of Clean Water Act section 401

requirements because those requirements are not known at this time. Neither PG&E nor

the consulting agencies identified the Shasta crayfish as a special status species occurring

within the project boundary or as being affected by the project; however, in the EIS we
A-18

recommend that prior to any project-related construction within the project boundary,

PG&E conduct biological evaluations in order to adequately identify and mitigate

potential effects to affected species. If the Shasta crayfish is present and affected by the

project-related construction, these evaluations would help identify and mitigate those

effects.

Comment: The California Salmon and Steelhead Association feels that the draft EIS is

premature because the Commission must disclose and evaluate the direct, indirect, and

cumulative effects to the human environment as related to section 401 Clean Water Act

conditions of the California Water Board.

Response: We disagree with the California Salmon and Steelhead Association’s

assessment of the draft EIS. We cannot issue a new license until the state issues the

401 certification; however, the state’s 401 certification is not required prior issuance of a

NEPA document. The California Water Board will address issues specifically pertinent

to its review under CEQA when it prepares its EIR.

Comment: The Center for Water Advocacy states that the draft EIS lacks any analysis

of the impacts of climate change both on the operation of the project and other water

issues. The Center for Water Advocacy is concerned that the draft EIS does not mention

the effects of climate change of the project’s hydrological management.

EPA, Region 9 notes that the draft EIS does not discuss the impacts of climate change on

the project, and that changes in the timing and quantity of precipitation may impact dam

stability, hydropower operation, water releases, and erosion of project roads. EPA,

Region 9 recommends that the final EIS describe any reasonably anticipated impacts of

climate change on the proposed project and any measures that could be incorporated to

address these impacts.

Response: Few resources are available for the evaluation of future climate change

impacts, 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 issued for

the project and would be the vehicle for making changes to the license should a material

change in conditions occur that results in unanticipated environmental effects.

Comment: PG&E is concerned about broad general statements on project effects that

are contained in the draft EIS Executive Summary. There is no question that there have

been project effects, but general statements either overstate these effects or are not

supported by extensive data presented in PG&E’s license application and FERC’s draft

EIS.

Response: We disagree. The summary of project effects provided in the Executive

Summary of the draft EIS identifies the resources that are affected by the continued

operation and maintenance (O&M) of the project based on the best available information.

These may appear general, but these statements serve as an overall summary of the

project’s issues and impacts.
A-19

Comment: The California Water Board notes that without details of the contents of the

various monitoring/management plans that PG&E plans to develop and/or implement, it

is impossible to determine the environmental impacts of implementation. The California

Water Board recommends that one way to help avoid impacts from implementation plans

is to require approval from the agency(ies) with authority over the subject resource area.

Response: The EIS evaluates the anticipated impacts of the proposed project, including

considerations of various mitigation options intended for inclusion in the draft plans as

proposed by the applicant, state and federal agencies, etc. As such, we consider most of

the proposed management and monitoring plans to contain enough detail to be able to

implement the plan at the time of license issuance and recommend that these plans be

considered final. We also note that the Commission and appropriate state agencies,

including the California Water Board, will have an opportunity to review and comment

on whether any of the remaining draft management and monitoring plans achieve the

purposes of the mitigation described in the EIS during finalization of those plans.

DEVELOPMENTAL ANALYSIS

Comment: PG&E states that it is unclear in the draft EIS how or if the Commission

analyzed costs for any of the alternative conditions that were filed. PG&E states that it

appears that the PG&E-proposed action does not include the flow scenario for the Lower

McCloud River that was filed on March 3, 2010, in PG&E’s alternative condition but if it

does, this should be clarified in the final EIS.

Response: PG&E’s March 3, 2010, flow recommendations are the same as the

alternative Forest Service 4(e) proposal filed on March 1, 2010; see table 3-21 of the draft

EIS. Consequently, our analysis of flows treated these conditions as a single

recommendation. The costs associated with the various alternatives/recommendations

were analyzed in section 4.0, Developmental Analysis, of the draft EIS.

Comment: The California Water Board states that the annual cost for developing and

implementing the fish stocking plan should include an inflation factor.

Response: As discussed in draft EIS section 4.1.1, Economic Assumptions, 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. Instead, 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, as articulated in

Mead Corporation, Publishing Paper Division (72 FERC ¶ 61,027, July 13, 1995).

Comment: PG&E comments that implementing Forest Service 4(e) flows below

McCloud dam and California Trout, Trout Unlimited, and McCloud River Club

alternative 4(e) flows below McCloud dam will require replacement of the HowellBunger valve at McCloud dam. PG&E notes that this capital cost is not reflected in the

cost table for either of these alternatives. PG&E is developing a cost estimate and will

provide this information to FERC as soon as it is available.
A-20

Response: We acknowledge that the Howell-Bunger valve at McCloud dam would

require replacement to implement modified instream flows below McCloud dam.

Minimum flow at McCloud dam under the no-action alternative is 40-50 cubic feet per

second (cfs) depending on the time of year (table 3-26). PG&E’s proposed minimum

flow is 150-220 cfs (table 3-22). The minimum flow specified by the Forest Service is

175 cfs or greater (table 3-22). Therefore, the Howell-Bunger valve discharge capacity

would have to be at least three times the normal discharge capacity of the existing valve.

PG&E would have to complete a detailed engineering study to properly size the

replacement valve and determine installation costs at McCloud dam. Because PG&E has

not completed this study and has not provided costs for replacement of this valve, we

have updated EIS section 4.0, Developmental Analysis, to include a $300,000 capital cost

for replacement of the valve (see also appendix C). This cost would include installation

of a larger bifurcation in the 84-inch outlet pipe and a valve twice the size of the existing

valve. The new valve would have a flow capacity about four times the existing 24-inch

valve.

Comment: California Fisheries and Water feels that the draft EIS does not disclose and

evaluate the direct and cumulative effects to California power consumers related to Forest

Service 4(e) conditions effects on power production.

Response: Draft EIS section 3.2, Scope of Cumulative Effects Analysis, describes the

scope of our cumulative effects analysis for the McCloud-Pit project and identifies water

quality, fisheries, and recreation as the resources having a potential for cumulative effects

in this proceeding.

In section 4.0, Developmental Analysis, we give our estimate of the direct annual cost of

proposed measures, including the Forest Service’s 4(e) conditions that would reduce the

current power production of the project. In section 5.0, Staff’s Conclusions, of the draft

and final EIS, we compare the cost of Forest Service 4(e) conditions to the effects of

these environmental measures in making recommendation to the Commission. Because

the Commission makes decisions on individual proceedings, we do not believe that an

estimate of the total cost of 4(e) conditions of other projects now being relicensed in

California would help the Commission make a license decision for the McCloud-Pit

Project.

Comment: McCloud RiverKeepers is concerned that the draft EIS does not include

details on relicensing costs that are passed on to electric ratepayers. Specifically,

McCloud RiverKeepers is referring to all the costs including the costs of flow used under

“Other Uses of the Resource” policy, specifically whitewater boating and the intended

use versus any habitat need for water quality flows. McCloud RiverKeepers requests

information on how the Commission calculates its Power Production Analysis, because

the relicensing costs presented in the draft EIS appear to be lower than expected based

upon the McCloud RiverKeepers’ understanding of relicensing costs that are not paid for

by licensees.
A-21

Response: In our economic analysis, we do not attempt to predict what costs would be

passed onto the electric ratepayers. Table 4-2 in section 4.1.2, Current Annual Costs and

Future Capital Costs Under the No-Action Alternative, presents the relicensing costs,

including original net investment, license application preparation, and annual O&M that

are the basis of section 4.0, Developmental Analysis, for the no-action alternative.

Table C-1 in appendix C presents capital and annual costs for mitigation measures. Costs

resulting from minimum flow releases, including the whitewater boating releases, are

referenced in section 4.3.2, Effect of Environmental Measures on Energy Generation, and

reflected in the annual power generation summarized in table 4-6. We have calculated

lost power using differences between existing minimum flow releases and proposed

releases and the normal heads at the powerhouses. All of these costs are included in the

Developmental Analysis of PG&E’s proposed action, the staff alternative, and the staff

alternative with mandatory conditions (table 4-3). As shown in table 4-3, the

Developmental Analysis is based on an average energy value published by the California

Public Utilities Commission.

GEOLOGY AND SOILS

Comment: Due to past incidents in portions of the McCloud penstock and identified

soils and geologic stability conditions, the Forest Service stated in its comments on the

draft EIS that it will request, in the final 4(e) conditions, copies of the project safety

reports prepared by the independent consultant on dam safety. The Forest Service also

stated it will require real-time monitoring of soil and ground movement at high risk sites

along the penstock alignment to detect movement prior to total failure.

Response: It does not appear that the modified Forest Service conditions or

recommended management plans provide guidance related to submission of project

safety reports for penstock areas. However, in final EIS section 3.3.1.2, Environmental

Effects, Erosion and Sediment Control, we note that monitoring implemented as part of

routine safety inspections at penstocks and project water conveyance structures would

minimize the risk of erosion-associated leakage or potential failure.

In the final EIS, section 3.3.1.2, Environmental Effects, Erosion and Sediment Control,

we have noted the Forest Service’s recommendation in the draft Erosion and Sediment

Control Management Plan (provided as an enclosure to the Forest Service final 4(e)

condition 22 filed on November 29, 2010) for PG&E to provide real-time seismic

monitoring along the James B. Black penstock at the McCloud-Pit project.

Comment: The Forest Service concurs with the TM-67 results that erosion is occurring

at Tarantula Gulch recreation area, Ash Camp and Ah-Di-Na Campgrounds, and Star

City Creek, and agrees that treatment by PG&E is needed. The Forest Service also notes

that, in addition to erosion at road-related sites along Forest Road (FR) 38N11, erosion is

also occurring along the access road to three day-use sites (Red Banks, Battle Creek, and

West dam), McCloud dam and spillway, and the minimum instream flow intake gate

access.
A-22

Response: Mitigation of erosion sites would be implemented as part of the Erosion and

Sediment Monitoring and Control Plan we recommend PG&E prepare within 1 year of

license issuance, in consultation with the Forest Service and other appropriate agencies.

Project-related erosion sites such as those identified in the Forest Service comment would

be prioritized for restoration.

Comment: The Forest Service notes that a total of 22 erosion sites were identified along

the shoreline of Iron Canyon Reservoir within the high water zone, and not only “few

erosion sites,” as the draft EIS states.

Response: We have revised the text in final EIS to specify the number of erosion sites

identified along the shoreline of Iron Canyon reservoir.

Comment: The Forest Service notes that additional erosion control and treatment

measures will be required at sites used for borrow material during construction of Iron

Canyon dam, and this treatment of the borrow sites will need to be included in the draft

Erosion and Sediment Control Management Plan, to be submitted to the Commission

with the final 4(e) conditions.

The California Water Board agrees with the Forest Service’s above statement.

Response: The Erosion and Sediment Monitoring and Control Plan would be prepared

by PG&E in consultation with the Forest Service to ensure that Forest Service concerns

are adequately addressed.

Comment: The Forest Service clarifies that updates to the Forest Service -compatible

database of erosion sites and detailed site-specific erosion and sediment control measures

will be required annually when treatment measures have been completed.

Response: The requirements of this erosion and sediment control measure have been

clarified in the final EIS.

Comment: The California Water Board requests that the Commission provide more

details on PG&E’s Erosion and Sedimentation Plan addressing fine sediment delivery to

Iron Canyon reservoir as a result of unrestricted off-highway vehicle (OHV) use and

future expanded OHV use. The California Water Board requests additional details on the

scope of the plan to ensure it will prevent impacts to water quality. The California Water

Board states that increases in OHV use over the life of the license could result in water

quality impacts and recommends that these be evaluated and notes that the shallow slope

of the Iron Canyon reservoir shoreline makes it more vulnerable to OHV use.

The California Water Board also suggests that the final EIS evaluate the impacts to water

quality if the dispersed recreation use increases at McCloud reservoir or at other project

locations. Uncontrolled dispersed camping can result in increases in shoreline erosion

and in human waste entering waterways. The California Water Board notes that

construction of campgrounds and addition of restrooms will prevent or reduce impacts

from dispersed camping.
A-23

Response: In section 3.3.1.1, Affected Environment, we discuss the results of the PG&E

pre-licensing surveys within the project area to determine the distribution of erosion sites,

which identifies several sites caused by recreation use. In order to manage existing

erosion and minimize future erosion and sediment delivery to stream channels, PG&E

proposes to prepare an Erosion and Sediment Monitoring and Control Plan, which among

other measures, would provide an inventory of project-related erosion and sedimentation,

including recreational use areas and criteria for treating erosion sites.

In section 3.3.5.2, Environmental Effects, Dispersed Use and OHV Use, we recommend

measures proposed by PG&E and specified by the Forest Service to block vehicle access

and discourage dispersed use and OHV use at the project that would benefit

environmental resources by closing degraded areas to intense recreational use. Projectrelated roads that are a direct source of erosion and fine sediment loading have been

identified in the erosion site inventory and would be remediated as prioritized under the

Erosion and Sediment Monitoring and Control Plan. In addition, we support the

construction of designated camping areas to prevent dispersed use in sensitive or

overused areas.

In section 3.3.2.1.2, Water Quality, of the draft EIS, we indicate that coliform analyses

collected during a heavy recreational use period (2008 Labor Day weekend) in Iron

Canyon reservoir and its tributaries did not appear to show significantly altered

concentrations. Samples collected from both historical and recent sampling efforts in

recreational areas in McCloud and Iron Canyon reservoirs resulted in generally low

concentrations of total coliform, fecal coliform, and E. coli. In our analysis of the water

quality and temperature monitoring plan we recommended the measure for PG&E to

conduct periodic monitoring of all project reservoirs once every 5 years for E. coli and

contaminants to ensure proper water quality conditions for recreational users at the

project.

Comment: PG&E notes that Study GS-S2, Assessment of Channel Morphology and

Fluvial Geomorphic Process in the Lower McCloud River, did not find armoring to be a

significant problem in the Lower McCloud River, and that the statement by NMFS that

armoring is “a significant problem” is unsupported by the results of the relicensing

studies.

Response: We have revised the text in the final EIS to reflect the findings reported in

GS-S2, TM-68.

Comment: The Forest Service supports closure of the user-created roads and trails

around McCloud and Iron Canyon reservoirs to prevent further erosion.

Response: In the final EIS, we have recommended the license application proposal by

PG&E to implement closure of existing and future user-created roads around McCloud

and Iron Canyon reservoirs as discussed in section 3.3.5.2, Environmental Effects,

Dispersed Use and OHV Use.
A-24

Comment: The Forest Service states that the draft EIS contains several inaccuracies

regarding the current status of roads and spoil piles on the project. The Forest Service

will remove references to bridges; however, contrary to PG&E statements, road spoil

piles do occur on Forest Service lands along road alignments noted in the Commission’s

listing of roads, and on Forest Service lands near project infrastructure.

Response: We have revised the final EIS to clarify that there are road spoil piles along

roads on NFS lands that may be within the project boundary. The details about who is

responsible for correcting problems created by these spoil piles (e.g., removal) should be

included in the proposed Road and Transportation Facilities Management Plan, which we

recommend and would be filed with the Commission for approval within 1 year of

license issuance.

Comment: The Forest Service states that the Large Woody Debris (LWD) Plan for

McCloud reservoir shows an annualized cost of $452,506 (section 5.2.1, Discussion of

Key Issues, Geology and Soils, Large Woody Debris), but notes that, in appendix B of the

draft EIS, a one-time capital cost of $1,500,000 and an annual O&M cost of $167,000 are

shown for this plan. The Forest Service states that it is baffled by these costs. The Forest

Service states that the LWD Plan is no more than a plan to have PG&E place woody

debris they already collect into the river rather than burn it—those costs are already

incurred by PG&E under the existing license and should be shown in the current

environmental measures in table 4-3. The Forest Service acknowledges that the

deployment of additional boom line may be an additional capital cost but that it should

not cost $1.5 million. The Forest Service envisions monitoring as no more than ensuring

that the material does not create log jams near the toe of the dam or pile up on property

below the dam. The Forest Service reviewed the costs associated with the Coarse

Sediment Plan and note that the annualized costs for that activity are only $78,000. The

Forest Service feels that the Coarse Sediment Plan and LWD Plan are similar activities

and that the activities associated with the Coarse Sediment Plan would be the more

expensive since it requires more handling of material. The Forest Service states that the

main point is that the cost of environmental measures needs to be more clearly

documented and include discussion of how PG&E and the Commission determined the

capital and O&M costs.

Response: We reviewed the cost estimate for the LWD program and agree that it seems

too high. In its response to comments, PG&E (October 2010) concurred that the costs in

the license application assumed a LWD program that was significantly greater than that

now being considered; however, they did not provide a revised estimate of cost for the

LWD program. No commenting party has made other estimates of these costs and the

cost of this measure has a small effect on the overall economic benefits of the project;

however, we have re-analyzed the costs and presented these updated costs in the final

EIS.

Comment: PG&E states that surveying for LWD effectiveness would likely result in

unreliable data, and considering the high cost of this measure, PG&E disagrees that it is
A-25

appropriate to conduct this monitoring. PG&E goes on to state that cost-effective

implementation of a gravel augmentation plan depends on the use of a gravel source near

McCloud dam. PG&E anticipates that sediment stored in the Star City Creek delta

deposit will likely be suitable material and provide adequate quantity. If this is not the

case, PG&E states that it and the Forest Service will re-evaluate the cost effectiveness of

this measure.

Response: In the final EIS, we concur with the Forest Service modified condition for

monitoring of LWD dispersal from the placement to adaptively manage the amount and

timing of placement of LWD below McCloud dam. Additionally in the final EIS, we

recommend the use of Star City delta for collection of coarse sediment and to evaluate

other potential sites that could provide suitable coarse sediment for augmentation.

Comment: In its comment on the draft EIS, the Forest Service states that monitoring for

LWD dispersal could be integrated into the Aquatic Biological Monitoring Plan to ensure

that large accumulations of LWD do not form along the Lower McCloud River margins.

PG&E states that its management plan does not propose long-term monitoring of the

volume and distribution of LWD that is mobilized from the placement site and distributed

in the downstream channel. PG&E states that long-term monitoring of the dispersal of

LWD would not be effective for many reasons (e.g., LWD is unlikely to be retained in

the river and distinguishing between LWD moved from McCloud reservoir and LWD

from the forest below McCloud dam would be problematic).

Response: In its modified condition 21, the Forest Service specifies monitoring of LWD

as a component of the LWD Plan rather than the Aquatic Biological Monitoring Plan, so

its comment above is no longer applicable. In modified condition 21, the Forest Service

also recommends monitoring LWD only to assess mobilization from the placement site

and not downstream dispersal. PG&E has accepted the Forest Service’s modified

condition 21.

In the draft EIS, we incorrectly indicated that PG&E’s proposal for a LWD Management

Plan included monitoring of mobilization and dispersal of LWD. In the final EIS, we

have corrected PG&E’s proposal for the LWD Management Plan to not include specific

monitoring procedures. In the final EIS, we recommend Forest Service modified

condition 21 and its monitoring component, because it allows the volume and frequency

of LWD placement to be adaptively managed and only specifies monitoring of LWD

mobilization from the placement site. We find monitoring of LWD mobilization from the

placement site would be adequate to minimize issues associated with downstream

dispersal and therefore do not recommend any additional long-term monitoring of

downstream dispersal and distribution.

Comment: PG&E agrees with the Forest Service that monitoring of gravel augmentation

should be focused on assessing spawning gravel characteristics between McCloud dam

and Hawkins Creek, because below Hawkins Creek, augmented gravel will not be

distinct from naturally recruited gravel. PG&E clarifies that the gravel augmentation
A-26

plan addresses the interruption of sediment transport, not the LWD Plan as stated in the

draft EIS.

McCloud RiverKeepers believes that gravel augmentation should be implemented on an

experimental basis with moderate amounts being added over a number of years while

monitoring and verified results determine additional need based upon confirmed

additional spawning activity and a benefit to fish population. McCloud RiverKeepers

states that, if positive results do not materialize within a reasonable number of years, the

augmenting should be terminated due to the additional expense to ratepayers.

Response: As stated in section 5.2.1, Discussion of Key Issues, we recommend

modification of Forest Service condition 23 according to PG&E alternative condition 23,

to specify that gravel augmentation should occur based on monitoring results, rather than

a fixed time period, in order to provide a more flexible mechanism for determining the

volume and frequency of sediment introduction necessary to maintain aquatic habitat.

We also indicated that monitoring results would aid in determining the success of gravel

augmentation and the need for adjustments to source material, timing, and placement.

Consultation will allow PG&E and the agencies to adaptively manage the resources to

ensure the measures contained within the plans are appropriate and beneficial.

Comment: The California Water Board suggests that monitoring of large bivalves

(California floater and shell mussels) should occur throughout the life of the license since

these are long-lived species. In addition, the California Water Board notes that the

reintroduction of anadromous salmonids may result in reintroduction of mollusks in

McCloud River and that future monitoring may be appropriate.

Response: In the draft EIS, we recommend PG&E monitor aquatic mollusks consistent

with Forest Service condition 27. This Forest Service condition specifies that PG&E

monitor suitable habitat of California floater and other special status aquatic mollusks for

the term of the license. In addition, the proposed monitoring plan allows for new species

to be added to the list of monitored species if necessary.

Comment: The Forest Service agrees to drop the requirement for a reservoir dredging

plan. The Forest Service states that if dredging is required that will be on or affect NFS

lands, a suitable plan, approved by the Forest Service and recommended to the

Commission can be developed at that time.

Response: In the final EIS, we have updated our analysis to reflect this change to Forest

Service condition 24.

Comment: The Forest Service supports an adaptive approach to the introduction of

coarse sediment to ensure that placed sediments are mobilized. However, the Forest

Service clarifies that Aquatic Conservation Strategy benefits of augmentation include

geomorphic as well as aquatic outcomes. The Forest Service notes that monitoring is

intended to track mobilization and dispersal of course sediments, with emphasis on the

sediment-deficient portion of the river between McCloud dam and Hawkins Creek as

well as any unintended consequences of augmentation (e.g. large accumulations or
A-27

scouring). The Forest Service agrees that 1 year after license acceptance is adequate to

complete the Coarse Sediment Management and Monitoring Plan.

Response: We appreciate the clarification on the benefits of gravel augmentation, and

have modified the text in the final EIS to reflect the intent of monitoring from an aquatic

habitat and geomorphic standpoint.

Comment: The California Water Board states that the draft EIS does not quantify the

current sediment delivery, or describe how this impact will change over the life of the

license. The draft EIS should contain additional details on the scope of the plan to ensure

it will prevent impacts to water quality.

Response: Section 3.3.1, Geology and Soils, in the draft EIS we summarized the results

of PG&E’s prelicensing studies on erosion and sediment delivery to the project

[Technical Memorandum; Erosion and Sediment Inventory (TM-67)] and provided

rankings corresponding to the potential of project sites to cause future effects to project

infrastructure or water resources. On page 69 of the draft EIS, we stated that cumulative

sediment supply to the Lower McCloud River under regulated conditions ranges from

1,450 tonnes per year at the Hawkins Creek confluence to 7,050 tonnes per year at the

Squaw Valley Creek confluence. In section 5.2.1., Discussion of Key Issues, we

recommended Forest Service condition 23, which specifies that PG&E develop and

implement a Gravel and Coarse Sediment Management Plan which provides an adaptive

management component for augmentation of gravel and coarse sediment. We further

recommend modification of Forest Service condition 23 according to PG&E alternative

condition 23, to specify that gravel augmentation should occur based on monitoring

results, rather than annually. We believe this approach would allow PG&E to minimize

any new impacts of sediment delivery and water quality resulting from the project

throughout the term of the license.

In the final EIS, we provide details of the draft Coarse Sediment Management Plan, filed

as an enclosure to Forest Service modified condition 23.

Comment: The Forest Service agrees that baseline monitoring of erosion and sediment

over the term of the new license will help identify new sites and those where treatment

has been unsuccessful. The Forest Service also supports a new baseline survey within 1

year of license issuance, because study results will be out of date by that point. The

Forest Service’s proposal prioritizes treatment for all 56 sites identified as high risk and

includes 6-year schedule for treatment or repair of all sites.

Response: We appreciate the clarification to your recommendation for the Erosion and

Sediment Monitoring and Control Plan.

Comment: EPA notes that the draft EIS does not state whether the rivers and reservoirs

of the project are considered waters of the United States. EPA encourages FERC and

PG&E to discuss this issue with the U.S. Army Corps of Engineers (USACE), because if

waters of the United States are present, a Clean Water Act section 404 permit may be

required for activities described in the draft EIS, such as the excavation of gravel and
A-28

coarse material from Star City Creek and other potential sites; the placement of gravel

and coarse material in the McCloud River; construction of additional power generating

facilities at the base of McCloud dam and the Pit 7 afterbay dam; shoreline boat ramps;

and other recreational improvements. EPA recommends that the final EIS should discuss

the applicability of Clean Water Act section 404 permitting to the project and quantify

the direct and indirect impacts to waters of the United States.

Response: The project contains waters of the United States; however, as stated on

page 80-81 of the draft EIS, PG&E acknowledges that implementation of the gravel

augmentation plan, which would include removal and placement of fill into the stream,

would be contingent on receipt of a section 404 permit from USACE, and other permits.

We note that PG&E is responsible for obtaining necessary permits from the appropriate

agencies for all other project activities.

AQUATIC RESOURCES/RECREATIONAL BOATING

Comment: The Forest Service observes that it is unclear what “suitable” boating might

be in terms of cfs, and recommends that this term be clarified.

Response: In the final EIS, text has been revised to note flows, in cfs, for acceptable and

optimal conditions for boating and angling.

Comment: Eighty-six individuals stated their support for a hydrograph that would

support whitewater boating on the Lower McCloud River.

PG&E states that whitewater boating and angling opportunities exist over a wide range of

flows. Consequently, the effects of the flow regime in terms of opportunities are more

accurately described as providing more whitewater boating opportunities and fewer

angling opportunities within the preferred ranges of flows for these activities. PG&E

notes that analyses presented to relicensing participants showed that for the period of

record (1974-2006), the revised preliminary 4(e)/PG&E alternative condition would have

provided an average of 11 days per year with flows in the optimal range (601-1,000 cfs)

for whitewater boating as compared to 7 days per year under the present license

requirement.

The California Water Board states that the quantification of boating days does not

adequately describe the actual number of days for boating that were available. The actual

number of boating days in each of the years in the period of record (past operation)

should be provided so that it can be compared to the number of days available under

unimpaired hydrology. The California Water Board states that the final EIS should

quantify the number of boating days for each of the agency/non-governmental

organization proposals provided, compare these numbers to the baseline conditions, and

describe the impact of each of the flows. The California Water Board notes that under

the unimpaired flow regime, whitewater boating flows would have been available

365 days per year.

American Whitewater and Friends of the River state that using average number of

boatable days mischaracterizes the amount of boating opportunity that currently exists on
A-29

the Lower McCloud River (p. 217 of the draft EIS) and recommends that the current draft

EIS language be changed to reflect the content of TM-24 (p. 25), specifically the median

number of boatable days. American Whitewater and Friends of the River note that under

the PG&E/Forest Service flow schedule, the median number of boatable days in the

optimal boating timeframe should be 4, which American Whitewater and Friends of the

River states is an improvement over the existing condition of zero boatable days.

American Whitewater and Friends of the River note that under the PG&E/Forest Service

flow schedule, the median number of optimal angling days is 191 and 200 days under

existing conditions.

Response: The analysis of boating opportunities has been expanded in the final EIS with

an analysis of the potential affect of each alternative/recommendation on opportunities

for boating and angling at various flow levels. The number of available days that could

have been available with each flow scenario during historic water year conditions has

been estimated and is presented to show the increase or decrease in days for each

scenario relative to the current license conditions (no-action alternative).

The baseline condition for this environmental analysis is the existing condition, not the

pre-project condition. Therefore, the analysis of effects of various flow scenarios is

based on comparison to the no-action alternative as opposed to unimpaired flows.

Comment: PG&E notes that the staff recommendation referring to California Trout,

Trout Unlimited, and McCloud River Club does not recognize conflicts with the Forest

Service preliminary 4(e) condition, for some periods and under some types of runoff. To

avoid the potential for a license with conflicting terms, PG&E recommends the

Commission delete reference to the California Trout, Trout Unlimited, and McCloud

River Club flow regime because any 4(e) conditions must be included in their entirety,

without modification.

Response: For preparation of the EIS under the NEPA process, we are required to

independently analyze a range of alternatives/proposals and balance the effects of the

project on various beneficial uses when making recommendations. Thus, our

recommendations in the final EIS may differ from the 4(e) conditions, but, as stated in

the draft and final EIS, the Forest Service 4(e) conditions will become part of any license

issued by FERC.

Comment: The Center for Water Advocacy believes that the McCloud RiverKeepers’

recommended flows would further reduce the amount of water that is released by PG&E

into the McCloud River from McCloud reservoir. The Center for Water Advocacy states

that the condition 19 flows already incorporated a reduction in springtime flows by the

Forest Service, compared to its first set of preliminary flow conditions. The Center for

Water Advocacy believes that the Commission’s adoption of the alternative flow

recommendations will further weaken prescriptions designed to protect the aquatic

ecosystem in the McCloud River.
A-30

The Center for Water Advocacy and California Sportfishing Protection Alliance believe

that the incremental potential benefits to recreational angling and to power generation

represented by the staff alternative do not outweigh the superior aquatic benefits of the

4(e) flows. The Center for Water Advocacy also states that the Commission revised

article 421 of the current license to require a minimum flow of at least 1,000 cfs or

inflow, if less, through May and June.

Response: In the draft EIS, we did not recommend the minimum instream flows for the

Lower McCloud River proposed by McCloud RiverKeepers but instead recommended

the minimum instream flows recommended by California Trout, Trout Unlimited, and

McCloud River Club. The benefits of this flow regime were supported by the instream

flow and aquatic habitat studies designed in collaboration with resource agencies and

other interested parties and conducted by PG&E during the development of its final

license application. In the final EIS, we recommend the minimum instream flows for the

Lower McCloud River specified by Forest Service modified condition 19 and supported

by California Trout, Trout Unlimited, and McCloud River Club. Again, the relicensing

studies conducted by PG&E support this recommendation and the recommended timing

and magnitude of seasonal flow augmentation would help maintain channel morphology

and aquatic habitat and create a more natural hydrograph. We find that the flow regime

specified by Forest Service modified condition 19 strikes the best balance between

angling opportunities, aquatic resources, and recreational boating, as compared to the

alternatives.

Comment: California Fisheries and Water states that the draft EIS did not disclose and

evaluate the effects resulting from 4(e) flow boating requirements by the Forest Service.

Response: The Forest Service did not specify recreation flow events in its 4(e)

conditions; however, boatable days would occur under the flow scenarios specified by

Forest Service 4(e) conditions. In the final EIS, we have expanded the analysis of

boating opportunities and the potential effects of each alternative/recommendation on

opportunities for boating and angling at various flow levels.

Comment: The California Water Board recommends that additional studies are needed

to determine if the flows in the 175-200 cfs range, as recommended in the draft EIS, are

supported by the corrected flow models.

The Center for Water Advocacy believes that there is substantial risk of scientific error in

the flow measurements upon which the draft EIS is based resulting from an insufficient

number of flow gages and/or poor quality data from existing gages. The Center for

Water Advocacy states that the use of these unreliable data gathered by PG&E will affect

existing and future aquatic species in the McCloud River and requests additional instream

flow modeling due to situations that can occur that result in unusual gage height

recordings (e.g., the incident at MC-10 on June 7, 2008).

Response: The models and field sampling methodologies PG&E used to assess

appropriate flows, and the number and location of flow gages from which historical flow
A-31

data were derived, were developed and implemented in coordination with resource

agencies and other interested parties. Although some data errors were identified in the

historical flow data from some gages and during estimation of flows, PG&E applied

several quality assurance methods to ensure reasonable results of the flow analysis. We

also recognize that although each of these study approaches looked differently at the

aquatic community and habitat, and some erroneous data were identified by PG&E, the

model results collectively provide consistent, weight-of-evidence information to support

the recommended flow scenario. The methods and results of these studies are consistent

with scientific standards of precision and accuracy. We believe that additional data

collection to support these models would not be likely to significantly improve the

characterization of the appropriate flows.

Comment: American Whitewater and Friends of the River state that the flow proposals

from the Forest Service, California Fish and Game, and PG&E evaluated in the draft EIS

provide a peak release of 250 cfs in 76-89 percent water years, which is just under the

minimum boatable flow. American Whitewater and Friends of the River state that an

additional release of 50 cfs in these water years would provide boating opportunity,

would not interfere with wading based angling, and would more closely mimic the

natural hydrograph.

Response: During below-normal runoff water years (76-89 percent) when water

resources and aquatic resources may be stressed and water storage capacity may be

reduced, we must balance the requirements of power generation, aquatic resources, and

other users. The recommended 250-cfs peak flow during dry years, falls within the

acceptable range for access boating, but below requirements for whitewater boating.

During dry conditions, we have emphasized conservation of water during the period of

spring seasonal high flows in order to help maintain and prolong adequate flows into the

summer period of minimum precipitation and runoff.

Comment: McCloud RiverKeepers feels that it is inappropriate for agencies to

“balance” the interests of anglers and the fishery itself against those of kayakers or some

other interest. McCloud RiverKeepers states that the creation of boating flows for the

purpose of whitewater recreation is unsubstantiated and that the focus should be on

habitat needs and the objectives of the Forest Service’s Aquatic Conservation Strategy.

McCloud RiverKeepers opposes the Forest Service’s flow rule because McCloud

RiverKeepers feels the flow rule is not based on ecosystem need and is apparently

designed to create the opportunity for whitewater boating at the expense of habitat

damage. McCloud RiverKeepers states that according to the California Wild and Scenic

Rivers Act, the California legislature guarantees management of the Lower McCloud

river in its “existing natural condition” to “protect the unique fishery in its free-flowing

condition,” which is the “highest and most beneficial use of the waters of the McCloud,”

and that the code also states that PG&E’s existing and future facilities “cannot alter the

existing flow regime below the dam.”
A-32

The California Fisheries and Water states that the draft EIS does not evaluate effects

related to the California Wild and Scenic River Act for the McCloud River.

American Whitewater and Friends of the River state that the Commission should

demonstrate how various beneficial use interests are being met by project operations,

rather than giving more deference for safe wading opportunities than to whitewater

boating.

Response: The Forest Service 4(e) flow conditions and staffs’ flow recommendation in

the draft EIS are measures intended to enhance aquatic habitat conditions compared to

current license conditions, but they are measures to enhance recreational opportunities. A

key feature of several of the recommended flow scenarios is the management of high

flows during late winter and spring to more effectively mimic the seasonal variation

typical of the natural hydrograph of an unregulated river. These peak flows are a

necessary condition for natural maintenance of channel morphology and substrate

conditions associated with quality aquatic habitat. Peak flows associated with seasonal

weather patterns and significant runoff events can also provide white water boating

opportunities that may, however, be excessive for comfortable or safe angler wading

depending on when they occur. Our analysis and recommendations are made based on

review of the available scientific data and our charge to determine the best

comprehensive use of the waterway as mandated by the FPA. Each relevant beneficial

use interest is discussed in more detail in its respective resource analysis section of the

final EIS.

Comment: McCloud RiverKeepers recommends that the Commission identify costs

related to whitewater boating flows. In particular, McCloud RiverKeepers requests

identification of: (1) the project’s actual market value dollar costs of the lost power

production paid by electric ratepayers for an additional 75 cfs in minimum dam releases

for four months (Jan-April); and (2) the Forest Service’s flow rule, over the duration of

the expected 50-year license. McCloud RiverKeepers states that it received an estimate

of the cost of whitewater boating flows from PG&E for a recreational flow event below

McCloud dam (11 days at 150 cfs between May and June), and that the estimate was

$200,000 to $300,000.

Response: Because the recommended flows provide a balance of benefits between

multiple uses, including power generation, aquatic habitat, aquatic resources, and

recreational users, costs cannot be segregated by “user.” In reality, high seasonal flows

that may benefit whitewater boaters, are also an integral part of natural ecosystem

dynamics necessary for habitat maintenance for aquatic and terrestrial resources.

Comment: American Whitewater and Friends of the River state it is unclear whether

certain areas of discussion (e.g., p. 217 of the draft EIS) refer to boating or angling and

recommend clarification.

Response: We have revised text in the final EIS to better clarify analysis of differing

flow recommendations relative to boating and angling.
A-33

Comment: California Fisheries and Water states that the draft EIS does not disclose and

evaluate the effects to the wild trout fisheries (including the effects to juvenile and adult

trout that may be stranded resulting from ramping rate) or the California Wild Trout

Policy of the Lower McCloud River resulting from daily 4(e) flow requirements specified

by the Forest Service.

Response: The effects of rapid changes in flow and ramping proposals are discussed in

section 3.3.2.2, Environmental Effects, Ramping, and section 5.2.1, Discussion of Key

Issues, Ramping. In the draft EIS, we indicate that PG&E did not conduct any analyses

of the potential for fish stranding to occur in the project reaches; however, we believe

there is some potential for fish to be stranded at times when flows are reduced following

spill events or valve test flow releases. In these cases, we recommended implementing

the ramping rates specified by the Forest Service and recommended by California Fish

and Game to help to limit the potential for stranding of fish and macroinvertebrates.

In section 5.2.1, Discussion of Key Issues, of the draft EIS we acknowledge that

California Fish and Game designates the Lower McCloud River a “Wild Trout Water”

and indicate the results of aquatic flow-habitat studies generally predicted that increasing

minimum instream base flows from the current 40-50 cfs to between 175 and 200 cfs in

summer and fall would provide the greatest abundance and highest habitat values for

resident trout species. Forest Service modified condition 19 specifies a minimum

baseflow of 175 cfs for the Lower McCloud River and a flow regime that varies by

month and water year type. During above normal years the base flow would increase in

July and August to 215 cfs. Our analysis of stranding indicates that the proposed rate for

down ramping flows at the time of high spring releases would minimize the potential for

stranding. We find that the flow regime specified by the Forest Service would create a

spring pulse flow condition which more closely reflects a natural hydrograph and would

benefit the resident trout population.

Comment: McCloud RiverKeepers expresses concerns about increased costs to

taxpayers as a result of the proposed flows. McCloud RiverKeepers states that

whitewater boating is a declining recreational activity while fishing is enjoyed by a much

larger percentage of the population, and that increasing flows for whitewater boating at

the detriment of harming the fishing industry, hurting the ecosystem, and increasing costs

is not justified. McCloud RiverKeepers goes on to request a boating ban on the Lower

McCloud River during the fishing season in order to emphasize year-round high-quality

fishing on the river, claiming that there are many other local whitewater boating

opportunities, and the Lower McCloud River’s narrow structure makes whitewater

boating a conflicting recreational activity during the fishing season.

Response: High flow spill events typical of a natural hydrograph benefit the Lower

McCloud River as a mechanism for enhancement and maintenance of channel

morphology and aquatic habitat as well as provide whitewater boating opportunities. The

various alternative recommendations to provide such late winter early spring events

under a managed flow regime are generally designed to return flows to the range
A-34

considered acceptable to wading anglers by fishing season. Furthermore, we do not

consider a ban on boating to be necessary as there is not significant overlap between the

flows preferred by whitewater boaters and wading anglers. In addition, boat-based

angling, which prefers flows in the range of wading anglers, provides access for anglers

to reaches of the Lower McCloud River that would otherwise not be available.

Comment: PG&E believes the statement of “No flow change” for row 3 of the table on

p. 53 of the draft EIS (March 16-31, 90-99 percent runoff) is incorrect. PG&E states that

the March 3, 2010 alternative condition from the California Trout, Trout Unlimited and

McCloud River Club flow proposal specifies a 50 cfs increase for this runoff category.

PG&E notes that p. 136 of the draft EIS, paragraph 1 should state that “...during the first

half of April if runoff is less than 120 percent...,” and not “...less than 102 percent.”

Response: In the final EIS, appropriate edits have been made to this table. Under March

16-31, the flows after 09-99 percent and 100-119 percent should be 100 cfs, not 50 cfs as

shown in draft EIS. The text in the final EIS also has corrected the typographic error for

percent runoff, which should have read 120 percent, as opposed to 102 percent.

Comment: The Forest Service agrees with the Commission’s conclusions that flow

regulation at McCloud and Iron Canyon dams and diversion of water to the project

powerhouses affect recreational opportunities, including in the Lower McCloud River

reach below McCloud dam (24-mile bypassed reach) but states that it does not

understand conflicting language elsewhere in the draft EIS which does not recognize the

project nexus for recreation in the Lower McCloud River between McCloud dam and

Squaw Valley Creek tributary inflow.

Response: In the draft EIS, we incorrectly stated that some recreational facilities (e.g.,

campgrounds at Ah-Di-Na and Ash Camp) were located below Squaw Valley Creek and

therefore did not have project nexus. In final EIS section 3.3.5.2, Environmental Effects,

Lower McCloud River Recreation Facilities, we have clarified that these facilities are

above Squaw Valley and that although they provide access to the Lower McCloud, they

are not project facilities. Although we agree that flow regulation at McCloud dam affects

recreational opportunities, this does not change our conclusion that these facilities do not

have a project nexus because they do not serve a project purpose or provide direct access

to the project.

Comment: The Forest Service notes that PG&E studies indicate that 210-375 cfs are

optimal flows for angling, but the that these numbers are inconsistent between each

section of the draft EIS and should be corrected.

Response: In the final EIS, we have revised the text to assure consistency between

sections and the findings and cfs ranges reported in Technical Memoranda 24 and 58.

Comment: The California Water Board acknowledges that the McCloud River is closed

to fishing from November 16 to the last Saturday in April so flows during this period

would have no impact on fishermen. The California Water Board notes that, according to

Technical Memorandum 58, the optimal range of flows for fishing at Ah-Di-Na is
A-35

210-375 cfs, which does not agree with the draft EIS statement that, “...flows higher than

300 were too stressful for all but the youngest and most aggressive waders.”

American Whitewater and Friends of the River agree with the Commission that

210-375 cfs at Ah-Di-Na gage (gage MC-1) is optimal for angling and note that other

sections of the draft EIS are contradictory to this and state 200-300 cfs as the optimal

flow range for angling; American Whitewater and Friends of the River assert that the

latter flow values are incorrect and should be changed. American Whitewater and

Friends of the River note that at the Ah-Di-Nah gage, summer flows have typically been

220 cfs or higher, rarely below 200 cfs, and never as low as 160 cfs, although some

anglers indicated baseflows at this location most suitable for angling were 160-200 cfs

and flow information has only been posted online since 2009. American Whitewater and

Friends of the River state that using the median number of optimal angling days results in

a median of 191 days under the PG&E/Forest Service flow schedule and a median of

200 days under the base case.

Response: The statements relative to the optimal and acceptable flow ranges for fishing

have been revised in the final EIS to be consistent with Technical Memorandum 58;

however, we would like to note that the reference to 300 cfs being too strong for all but

the youngest and strongest anglers came from the personal interviews and focus groups

conducted for the McCloud River Recreational Flow Assessment and associated

Technical Memorandum 24.

We have provided an expanded analysis in the final EIS of number of boating and fishing

days available under various flow scenarios. As part of the analysis, we have

summarized the change in the number of boating and fishing days for each of the flow

scenarios compared to the no-action alternative. We find this analysis adequately

estimates the differences between the number of angling and boating days under the

various flow scenarios and relative to existing flows.

Comment: California Trout, Trout Unlimited, and the Northern California Council,

Federation of Fly Fishers state that the minimum flow issue is important for anglers

because Ah-Di-Na flows have only recently (2009) been available to the public real time

via the internet. In previous years, the public could only assume that 200 cfs was flowing

by Ah-Di-Na during the summer months during normal years because that was the FERC

mandated minimum flow.

Response: Real-time flow data will continue to be available for the gage at Ah-Di-Na

(MC-1) and flow data at the McCloud dam (MC-7) will also become available under

staff’s recommendations to assist anglers in knowing the flow conditions.

Comment: Several individuals who filed comments expressed concern regarding

increased flows and mud events in fall 2009 and spring 2010 and related these effects to

the increased flow regimes, as proposed.

PG&E states that whitewater boating and angling opportunities exist over a wide range of

flows and that consequently, the effects of the flow regime in terms of opportunities are
A-36

more accurately described as providing more whitewater boating opportunities and fewer

angling opportunities within the preferred ranges of flows for these activities. Analyses

presented to relicensing participants showed that for the period of record (1974-2006),

the revised preliminary 4(e)/PG&E alternative condition would have provided an average

of 11 days per year with flows in the optimal range (601-1,000 cfs) for whitewater

boating as compared to 7 days per year under the present license requirement.

McCloud RiverKeepers defines fishable flows at MC-1 as the existing flow regime and

states that flows at MC-1 begin to be wadeable for angling at about 250 cfs and become

marginally fishable at 275 cfs (between late April and early May). McCloud

RiverKeepers expresses concern that the Forest Service flow rule does not result in a flow

reduction to 250 cfs until June/July. McCloud RiverKeepers states that the Forest

Service’s flow rule will result in a threat to the fishery due to increasing flows in March

and April and extending those increased flows into May, June, and July, and is in

opposition to the rainbow trout pre-spawn, spawn, and post-spawn flows recommended

in Technical Memo 54. McCloud RiverKeepers states that changing the flow above the

current 190 cfs for rainbow trout upstream of Squaw Valley Creek and 358 cfs

downstream of Squaw Valley Creak is not justified and would threaten the fishery.

McCloud RiverKeepers also believes the flow changes will negatively affect the

macroinvertebrate and fish community that is beginning to emerge in March, April, and

May.

Response: The instream flow and aquatic habitat studies designed in collaboration with

resource agencies and other interested parties and conducted by PG&E support the staffrecommended flow regime for enhancement of aquatic habitat in the Lower McCloud

River in general and for rainbow trout in particular. The recommended timing and

magnitude of seasonal flow augmentation would help maintain channel morphology and

aquatic habitat and create a more natural hydrograph. These are consistent with FERC’s

responsibility to consider both developmental and non-developmental resources. The

magnitude and duration of turbidity in the Lower McCloud River and Iron Canyon

reservoir associated with natural flow events from Mud Creek is affected by project

operations at McCloud dam; however, the recommended flow regimes would not be

expected to change conditions compared to the no-action alternative. Our analysis of

other water quality conditions indicates that the recommended alternative and Forest

Service 4(e) conditions would not adversely affect existing conditions. The monitoring

plan proposed would document the affect of the new flow regime on water quality and

provide a tool for adaptive management to assure maintenance of adequate water quality

conditions.

Comment: Several individual commenters request that timelines for observation and

study be established for water flow releases into the Lower McCloud River

California Trout, Trout Unlimited, and the Northern California Council, Federation of Fly

Fishers note that the flow study (Technical Memo 58) found optimal angling flows to be
A-37

210-375 cfs, and acceptable angling flows from 200-475 cfs. They feel that the final EIS

should reflect this in its interpretation of the Recreation Flow Assessment Study.

The California Water Board states that problems with the collection and processing of

hydrology data for the flow models renders the results of the models inadequate for

making flow decisions.

Response: The license will provide a schedule for preparation, approval and

implementation of aquatic monitoring plans and the frequency of periodic surveys of

aquatic and terrestrial resources.

The analysis has been expanded in final EIS section 3.3.5.2, Environmental Effects,

Recreation Flows, to evaluate the effect of proposed flow scenarios on acceptable and

optimal fishing and various levels of boating experience.

PG&E used several models to assess appropriate flows for protection and enhancement of

selected species and life stages important to the aquatic community and recreational

fishery in the Lower McCloud River. The models and field sampling methodologies

were developed and implemented in coordination with resource agencies and other

interested parties. The models selected utilized different approaches to assess the affect

of flow on fish populations and habitat. At the request of a resource agency, Physical

Habitat Simulation Modeling (PHABSIM), which has been refined and routinely used to

evaluate flow requirement for licensing and relicensing of hydroelectric projects, was

added to the study design after the field data collection had been completed. Following

the initial PHABSIM model runs, several agencies identified several issues with the

method by which cross section flow data were collected as those data were later applied

to the PHABSIM model. PG&E performed a more refined analysis of the data and

revised the PHABSIM input files as requested by the agencies. These models have been

used as tools to aid in evaluating the relative relationship of various flows, aquatic

habitat, and the potential of habitat to support, maintain, and enhance aquatic populations.

Ultimately, while each of these study approaches looked differently at the community

and aquatic habitat, they collectively provide consistent, weight-of-evidence information

to support the recommended flow scenario. The methods and results of these studies are

consistent with scientific standards of precision and accuracy. We find that additional

data collection to support these models would not significantly improve the

characterization of the habitat provided by the models or change the findings relative to

recommendations of appropriate flows.

Comment: Three hundred fifty-nine organizations and individuals stated their support

for a hydrograph that would support angling and/or fish habitat in the Lower McCloud

River. Individuals expressed concern regarding economic impact of perceived future

angler absence on the Town of McCloud.

McCloud RiverKeepers feels that it is inappropriate for agencies to “balance” the

interests of anglers and the fishery itself against those of kayakers or some other interest.

McCloud RiverKeepers believes state agencies should not support flows that have an
A-38

adverse affect on the trout fishery. McCloud RiverKeepers claims that PG&E’s use of

McCloud dam is regulated such that the existing flow regime below the dam may not be

altered from the “1989 flow regime,” as these flows are beneficial to the trout fishery.

McCloud RiverKeepers suggests that the Commission should support the preservation of

the trout fishery, under the California Wild and Scenic Rivers Act. McCloud

RiverKeepers is “opposed to any speculative changes in the existing normative flow

regime that represent decisions of policy not based on substantiated needs of the nearperfect ecological condition of the aquatic habitat and fishery of the Lower McCloud

River.” McCloud RiverKeepers states there is no specific habitat need identified to

warrant the magnitude of flows specified under Forest Service condition 19 and feels

there are ecologically adverse effects that could occur if these flows are implemented.

The California Water Board states that 58 percent of anglers surveyed support balancing

both fish habitat and fishing conditions, and about 33 percent thought that fish habitat

was more important than good fishing conditions. The California Water Board states that,

based on this information (Technical Memo 58), establishing flows to meet the needs of

less capable waders may not provide the correct balance.

Response: We continue to conclude that the weight-of-evidence from analysis of the

licensing studies conducted by PG&E and comments on those studies, support the flow

regime we recommended in the draft EIS; however, we have revised our staff alternative

in the final EIS to recommend flows specified by the Forest Service modified 4(e)

conditions. The Forest Service modified 4(e) flows were developed to more closely

match flows recommended by California Trout, Trout Unlimited, and McCloud River

Club, which we originally recommended in the staff alternative of the draft EIS. Further,

California Trout, Trout Unlimited, and McCloud River Club concurred with the flow

conditions specified by the Forest Service in the modified 4(e) conditions. Overall,

changes in the flow regime specified by the Forest Service in its modified 4(e) condition

and the flow regime recommended by staff in the draft EIS are relatively small and

temporally limited and not likely to result in measurable differences in aquatic habitat

conditions; differences in number of days predicted from the hydrograph available for

fishing and whitewater boating are small enough that they would be difficult to

distinguish against the typical inter and intra-annual variability of flow associated with

weather conditions and runoff.

Comment: Seven individuals stated their support for increased late winter/early spring

flows in general or a more “natural” hydrograph on the Lower McCloud River.

The California Coastkeeper Alliance states its support for increased later winter and early

spring flows in the Lower McCloud River.

The Center for Water Advocacy and California Sportfishing Protection Alliance

recommend that the Commission replicate the snowmelt hydrograph in river reaches

affected by the project as reflected in the Forest Service’s flow regime, which it believes

will benefit fisheries, aquatic insects, amphibians, and other biota
A-39

EPA states that while the dam-controlled Lower McCloud River no longer experiences a

natural flow regime, the river can still benefit from an attempt to mimic natural flow,

which can benefit native vegetation, scour and redeposit fine sediment, benefit aquatic

biota, and foster greater ecological integrity. EPA recommends that the final EIS

consider the long-term value of seasonally higher flow, mimicking natural flows, to

aquatic resources of the Lower McCloud River

American Whitewater and Friends of the River recommend flows with the goal of

restoring a more natural hydrograph in the Lower McCloud River, especially in the

spring, and would like an analysis of their proposed flows included in the draft EIS.

Their proposal would provide an elevated flow, coinciding with the spring snowmelt,

would gradually taper off in April or May depending on water year, and would not have

elevated flows during the fishing season in dry and critically dry years. They believe that

the spring flow schedule proposed by the Forest Service and California Fish and Game

would be an improvement to the current flow regime and superior to any of the other

flow regimes that have been proposed thus far. American Whitewater and Friends of the

River support the minimum instream flows proposed by California Fish and Game.

American Whitewater and Friends of the River recommend a flow increase from the

Forest Service/California Fish and Game/PG&E proposal of 50 cfs on March 15 in years

when the expected runoff is 76-89%. Mr. Dave Steindorf, representing American

Whitewater, made a public comment at the morning draft EIS meeting on September 9,

2010, that addressed many of the aforementioned comments given by American

Whitewater.

Response: We acknowledge and agree with the support expressed for a more natural

hydrograph on the Lower McCloud River. Several of the recommended flow regimes

would better manage peak seasonal flows and the ramping of flows associated with

significant runoff events than the current license conditions. In the draft and final EIS,

we analyze the flow recommendations and recommend a flow scenario that would

augment flows in later winter through early spring and mimic natural flow conditions.

Comment: California Trout, Trout Unlimited, and the Northern California Council,

Federation of Fly Fishers states that the minimum flow release schedule does not take

into account California Trout, Trout Unlimited, and McCloud River Club alternative 4(e)

minimum flow schedule for the summer months. In this proposal, it is recommended that

summer base flows at Ah-Di-Na to be higher of (1) 200 cfs or (2) the historic average

summer (i.e., July and August) base flows during normal years under the existing

license—which historically appears typically in the range of 210 to 220 cfs during normal

year designations. California Trout, Trout Unlimited, and the Northern California

Council, Federation of Fly Fishers wants to avoid a situation where the new license flows

create lower summer base flows than what currently exists.

Response: In final EIS section 3.3.2.2, Environmental Effects, Minimum Flows, we have

expanded the analysis of the hydrograph to characterize historic average base flows

during the summer and incorporated this analysis into our recommended flow regime in
A-40

section 5.2.1, Discussion of Key Issues, Aquatic Resources. This is also consistent with

the Forest Service modified condition 19, which specifies flows of 215 cfs at Ah-Di-Na

(MC-1), if the flow at MC-7 is equal to or greater than 200 cfs on April 15 and, therefore,

avoids a situation where the new license flows create lower summer base flows than what

currently exists.

Comment: The Forest Service comments that the Commission’s analysis provides some

erroneous information when comparing the California Trout, Trout Unlimited, and

McCloud River Club flow proposal with the Forest Service revised flow proposal. The

Forest Service comments that the draft EIS incorrectly states the magnitude and duration

of the difference between the Forest Service and Cal Trout/Trout Unlimited/McCloud

River Club flow proposals for the spring ramping rate. The Forest Service flow rule

requires higher flow releases in mid-March through May, but the difference between the

two flow regimes is generally no more than 125 to 175 cfs in additional flow as measured

at Ah-Di-Na, not the 450 cfs reported in the draft EIS. The Forest Service notes that the

greatest difference observed was 225 cfs for one week in May 1978.

Additionally, the Forest Service provides details showing the minimum required flow

release from McCloud dam for the two flow rules for Water Years 1974 through 2009

(36 years) and notes that in many years there is no difference between the two proposals

but that, rather, based on the results from PG&E’s flow modeling, only 6 of these

14 years would have actually resulted in differing flow regimes. The Forest Service

states that the California Trout, Trout Unlimited, and McCloud River Club flow

proposal’s objective is to generate flows that mimic the natural hydrograph but to return

flows to under 300 cfs at Ah-Di-Na by May 1 which is the approximate beginning of

stream fishing season. The Forest Service notes that in all but the 6 years noted above,

the Forest Service and California Trout, Trout Unlimited, and McCloud River Club flow

proposals produce identical results. The Forest Service comments that in wet years, spill

overshadows the rules and natural flow events cause flow at Ah-Di-Na to be above

300 cfs, and in normal to dry years, both rules generate flows that are at or under 300 cfs

by May 1 at Ah-Di-Na. The Forest Service comments that the flow generated by the

California Trout, Trout Unlimited, and McCloud River Club flow rule on April 29, 1978

(opening day of fishing season that year) was 349 cfs, and the flow generated by the

Forest Service flow rule is 574 cfs. The California Trout, Trout Unlimited, and McCloud

River Club flow at Ah-Di-Na drops to about 300 cfs on May 5. The Forest Service flow

reaches 300 cfs on May 26 about 3 weeks later. By June 1, as in most water years, the

required flows are identical and much below 300 cfs. The Forest Service notes that 1978

shows the greatest difference in flow between the two regimes, and the greatest time span

between the dates when the California Trout, Trout Unlimited, and McCloud River Club

flow reaches 300 cfs and the Forest Service flow reaches 300 cfs, which is in contrast to

the statement in the draft EIS that the California Trout, Trout Unlimited, and McCloud

River Club flow regime provides four more weeks of flows less than 300 cfs than the

Forest Service regime.
A-41

American Whitewater and Friends of the River believe the summer flows proposed by

California Fish and Game are equivalent to the alternative proposed by California Trout,

Trout Unlimited, and McCloud River Club (about 210 to 220 cfs). American Whitewater

and Friends of the River believes that the summer minimum flows proposed by the Forest

Service in the original preliminary 4(e) conditions were consistent with California Fish

and Game and the California Trout, Trout Unlimited, and McCloud River Club proposal.

Response: For the final EIS, we updated our analysis by water year of flow proposals

and determined that for most years there is little or no difference in flow between the

Forest Service condition and California Trout, Trout Unlimited, and McCloud River Club

recommendation, and the differences are slight and short in duration.

We have evaluated the historic record for the Ah-Di-Na gage to determine the average

flows for different water year types. The discussion has been expanded in the final EIS.

Comment: The Forest Service notes that while the Commission states that it chose the

California Trout, Trout Unlimited, and McCloud River Club flow proposal because it

provided more fishing days, the Forest Service’s rationale for its flow regime was not

based on favoring fishing or boating. The Forest Service flow proposal was developed to

meet the requirements of the Aquatic Conservation Strategy in the Northwest Forest Plan

which guides management for Shasta-Trinity National Forest.

California Trout, Trout Unlimited, and the Northern California Council, Federation of Fly

Fishers agree with our conclusion in the draft EIS that the “flow regime” recommended

by California Trout, Trout Unlimited, and McCloud River Club strikes the best balance

between angling opportunities, aquatic resources, and recreational boating, because this

regime would provide more aquatic and create some early spring whitewater

opportunities while still making sure the river is accessible for fishing. The McCloud

River Club strongly supports the Commission’s decision to recommend the California

Trout, Trout Unlimited, and McCloud River Club alternative flow proposal over the

Forest Service’s proposed flow regime. They agree with the draft EIS that the California

Trout, Trout Unlimited, and McCloud River Club proposal strikes the best balance and

agree that it is appropriate to give more weight to safe angling opportunities than

recreational boating.

McCloud RiverKeepers feels that the increased minimum dam release of 175 cfs in the

Forest Service’s Flow Rule is not rational because there is no demonstrated need of the

ecosystem in the McCloud River Basin for these changes. McCloud RiverKeepers states

that from an economic standpoint, lost power production and impact on ratepayers, the

Forest Service’s proposed Flow Rule and increase to a 175 cfs minimum dam release is

considered an inefficient use of flow based on the needs of the ecosystem. McCloud

RiverKeepers requests that the Forest Service provide an explanation of the McCloud

ecosystem’s need of: (a) the proposed increased magnitude and duration of flows

resulting from the flow rule; and (b) the magnitude of the increases and decreases (Sept

and Oct) to the existing flow regime measured at MC-1 that result from a 175 cfs yearround minimum dam release.
A-42

The California Sportfishing Protection Alliance and the Center for Water Advocacy

believe that it is important to support the Forest Service flows. These groups believe the

Forest Service flow regime does a better job of replicating the snowmelt hydrograph,

both in terms of flow quantity and in terms of timing, than does the staff alternative. The

California Sportfishing Protection Alliance believes that the staff alternative (which

incorporates a position taken by California Trout, Trout Unlimited, and McCloud River

Club) seeks to reduce even further still the amount of water that is released by PG&E into

the McCloud River from McCloud reservoir.

Response: We recognize the difference in opinion among the Forest Service and the

various user groups regarding our recommend flow regime and we have addressed those

differences in both the draft and final EIS.

Based on relicensing studies conducted by PG&E, in the draft EIS, we concluded that

flow regime alternatives submitted by the Forest Service (revised)/PG&E, California Fish

and Game, California Trout, Trout Unlimited, and the Northern California Council,

Federation of Fly Fishers would improve aquatic habitat and benefit aquatic resources;

differences between these flow regimes would be relatively small and vary depending on

the water year type. In addition, the proposed flow regimes would provide a few

additional days during most years (except dry or extremely dry conditions) with

improved conditions for recreational boaters (whitewater and access) while maintaining

safe and acceptable conditions for wading anglers. On November 29, 2010, Forest

Service filed its modified 4(e) minimum flow conditions for the McCloud-Pit project.

Modifications to the 4(e) proposal included changing the March 16 to 31 incremental

flow increase to 50 cfs rather than 100 cfs when McCloud River runoff on March 1 is

100 to 119 percent and requiring the flow at Ah-Di-Na gage to at least 215 cfs (instead of

200 cfs) in July and August in wetter water years. Following consultation with Forest

Service relative to final 4(e) conditions, California Trout, Trout Unlimited, and McCloud

River Club indicated concurrence with the modified 4(e) condition 19 flows proposed by

the Forest Service. We have modified our staff alternative in the final EIS to reflect our

recommendation of this flow proposal because it provides appropriate flows to support

aquatic resources, recreational uses, and power generation and closely mimics the natural

hydrograph of the McCloud River.

Comment: California Trout, Trout Unlimited, and the Northern California Council,

Federation of Fly Fishers states that the line item for March 16-31 for water years in the

90-99% range should read “50 cfs,” and not “no change.” The McCloud River Club

agrees with this observation.

Response: Flow changes, as noted by California Trout, Trout Unlimited, and the

Northern California Council, Federation of Fly Fishers, have been corrected in table 3-25

of the final EIS.

Comment: The California Coastkeeper Alliance states that the comments by “McCloud

RiverKeepers” should not be viewed as in any way representing the California

Coastkeeper Alliance, the international Waterkeeper Alliance, or any licensed
A-43

Waterkeeper alliance. The California Coastkeeper Alliance supports the adoption of a

science-based flow regime that achieves these objectives such as the flow regimes

proposed by the Forest Service or by California Trout, Trout Unlimited, and the Northern

California Council, Federation of Fly Fishers. The California Coastkeeper Alliance states

that such alternative flow regimes call for increased flows in late winter and early spring,

during the critical time that rainbow trout are spawning and fry are rearing, and that these

types of proposals would decrease the risk of fry stranding and reduce fish mortality and

would help minimize the amount of uncontrolled spills from the dam.

Response: We appreciate the information on the Waterkeeper Alliance, and we

recognize the difference between McCloud RiverKeepers and the other Waterkeeper

alliances.

As stated in our draft EIS, we concur with California Trout, Trout Unlimited, and the

Northern California Council, Federation of Fly Fishers that alternative flow regimes

which call for increased flows in late winter and early spring would be beneficial to

resident fish species.

Comment: The Forest Service comments that the proposals from the McCloud

RiverKeepers and American Whitewater/Friends of the River should not be classified as

alternative condition filings to the Forest Service’s Preliminary Section 4(e) Conditions

under the provisions of the Energy Policy Act of 2005, because they were not filed within

the regulatory timeframe. The Forest Service suggests that these proposals can instead be

included and analyzed as part of the NEPA analysis.

Response: As alternative 4(e) conditions are covered under Forest Service regulations

under the Energy Policy Act of 2005, staff defer to the Forest Service comments filed

with the Commission on September 27, 2010, and have removed references to the filings

by the McCloud RiverKeeper and American Whitewater and Friends of the River from

the “alternative conditions” sections and analyze them as recommendations in the NEPA

analysis. In the final EIS, we also add a footnote to section 1.3.1.3, Alternative 4(e)

Conditions Pursuant to the Energy Policy Act of 2005, clarifying that the filings occurred

after the March 18, 2010, filing deadline.

Comment: McCloud RiverKeepers has also has submitted supporting documents for

inclusion in the final EIS and license approval process, including: California Public

Resource Code section 5093.50-5093-70; McCloud RiverKeepers’ recommended flows;

and McCloud RiverKeepers’ response to the Forest Service original 4(e) conditions.

McCloud RiverKeepers also requests Commission assistance in procuring flow and

power generation comparisons from PG&E. McCloud RiverKeepers also requests that its

proposed flows are included as supporting documentation and that its relicensing

positions and proposed flows are included when discussing environmental effects of

minimum flows.

Response: McCloud RiverKeepers’ comments were filed on the public record and have

been considered in preparation of the final EIS. PG&E is required to conform to all local
A-44

and state laws including California Public Resource Code, as applicable. Issuance of a

new license for the McCloud-Pit Project by FERC would not affect PG&E’s

responsibility to comply with applicable state and local regulations. We have included

the McCloud RiverKeepers’ comments and recommendations on the license application

and draft EIS in our analysis for the final EIS.

Comment: American Whitewater and Friends of the River agree with the Commission

that the potential for stranding fish and other aquatic organisms during rapid changes in

flow is a function of changes in water depth rather than flow rate and feels that the

Commission presents contradictory information by rejecting American Whitewater and

Friends of the River’s recommendation to use stage rather than flow as the unit of

measure for ramping rates. American Whitewater and Friends of the River state that the

Commission claimed that American Whitewater and Friends of the River did not provide

evidence that using stage measurements at the Ah-Di-Na gage as a guide for ramping

would be any more appropriate for protection of aquatic resources than the use of flow

measurements, but American Whitewater and Friends of the River disagree, stating that

in their alternative condition submitted to the Forest Service they did articulate that using

stage rather than flow would more closely mimic natural recession rates. American

Whitewater and Friends of the River also feel that the Commission staff fail to explain

how using flow as the unit of measure for ramping is more protective of the resource. In

addition, American Whitewater and Friends of the River believe that the stage at the AhDi-Nah gauge is, in fact, an appropriate representation of other cross-sections within the

reach, and they request that information is provided to substantiate the Commission’s

position. American Whitewater and Friends of the River also state that the Commission

provides no information to demonstrate that the Ah-Di-Nah cross section is not

representative of the Lower McCloud River.

Response: Stranding can occur along the water edge during rapid decrease in water level

primarily for lifestages with limited mobility (such as recently emerged salmonid fry), or

by entrapment in side channels and backwater areas. The probability of stranding is a

function of channel configuration and slope as well as the rate of fall in the water surface.

The rate of fall or change in stage (water depth) is affected by the channel cross section.

U.S. Geological Survey gage are placed at locations with uniform cross sections along

straight reaches of a stream to ensure consistent, reproducible measurement of stage. The

gage typically measures stage and the relationship between stage and flow (cfs) (stagedischarge) is calibrated for the gage through a series of surveys of cross section and

velocity performed over a range of flows. The stage-discharge relationship is applicable

only to the cross section at the gage, but provides a dependable method for estimating

flow based on a simple depth measurement. The characteristics of channel configuration

which are desirable for establishing a gaging station are characteristics that are likely to

minimize the probability of stranding. As concluded in the draft EIS, while stage is an

important factor in stranding, stage at the Ah-Di-Na gage would not necessarily provide

an appropriate indication of the potential for stranding throughout the Lower McCloud
A-45

River. For the purpose of compliance with ramping rates we find that, change in flow is

more functional than change in stage and has generally been used for license compliance.

Comment: The California Sportfishing Protection Alliance states that a small part of the

calculus is also recreational, in that the broader angling constituency does not have the

luxury of joining or using the facilities of the elite McCloud River Club or the equally

elite, neighboring Bollibokka Club, and the only opportunity that many anglers will have

to fish the bottom end of the Lower McCloud River is to gain access by boat. The

California Sportfishing Protection Alliance states that the 4(e) condition flows may

provide marginally more opportunities to access the bottom end of the Lower McCloud

River by boat than would the staff alternative.

Response: In the final EIS, we have revised our recommendation to support the flows

specified by the Forest Service modified 4(e) conditions; however, we continue to

conclude that the licensing studies conducted by PG&E provide adequate evidence to

support the flow regime recommendation for the project in the draft EIS. We believe our

recommended flows provide a suitable balance between the different user groups, aquatic

habitat, and power generation. We also note that in the final EIS, we recommend that

PG&E provide an access site at the base of McCloud dam that would accommodate

fishing and boating access at the Lower McCloud River and allows anglers greater access

to the recommended flows.

Comment: The California Sportfishing Protection Alliance states that until measures in

support of reintroducing salmonids to the McCloud have practical effect, the Commission

should adopt the flow measures proposed by the Forest Service in its proposed

section 4(e) conditions.

Response: We concur that until listed-salmonids are present in project waters, the flows

developed for the new license should be supportive of the existing aquatic community.

In addition, the specific habitat conditions including flows, water temperature and

substrate have not been adequately defined for the listed salmonids at this time. In final

EIS section 5.2.1, Discussion of Key Issues, Aquatic Resources, we have revised our

recommendation to support the flows specified by the Forest Service modified

4(e) conditions.

Comment: California Fish and Game notes that its understanding is that its

10(j) recommendation for instream flows was determined to be inconsistent with the

FPA, specifically related to the additional cost of its proposed alternative in comparison

to the staff-recommended flows. California Fish and Game commented that the process

for determining these costs were not detailed in the draft EIS and requested additional

information about how the Commission determines project costs.

Response: We provided a cost analysis of proposed flow alternatives in appendix B of

the draft EIS. In section 4.1.1, Economic Assumptions, we state that our economic

analysis provides a general estimate of the potential power benefits and costs of a project

and reasonable alternatives to project-generated power. We provide the assumptions,
A-46

values, and sources in table 4-1 of the draft EIS used to calculate our estimate of the

project alternatives, including proposed flow regimes.

Comment: The Forest Service and PG&E note that the aquatic resources flow release

tables for McCloud and Iron Canyon dams need definitions provided for indicated

footnotes a, b, & c.

Response: The footnotes for this flow release table were lost during production of the

draft EIS have been inserted back into the table in the text of the final EIS.

Comment: The Forest Service recommends that the sentence stating that the Lower

McCloud River is used for fishing below McCloud reservoir be deleted since it is

misleading, because the Lower McCloud River has a much broader use. The Forest

Service also suggests that the term project “reservoirs” be used instead of project

“waters.”

Response: All designated uses are identified in the final EIS. We use project reservoirs

to discern the project impoundments from project streams, whereas, project waters refer

to all waters within the project boundary.

Comment: The Forest Service recommends that Kokanee Salmon (Oncorhynchus

nerka) in Shasta Lake be added to the historical species list, as it spawned in the Lower

McCloud River prior to dam construction, as stated in the 1963 Multiple Use Impact

Report.

Response: The historic occurrence of Kokanee in Shasta Lake and the McCloud River

immediately upstream of Shasta Lake during 1984-1987 studies is identified in

section 3.3.2.1.3, Aquatic Biota, Stream Fish Populations, in the draft and final EIS.

Comment: PG&E comments that the sentence addressing forecast of unimpaired runoff

of the Sacramento River near Redding is incorrect; it should instead reference the

unimpaired runoff forecast for the McCloud River above Shasta Lake.

Response: Text and table footnotes in the final EIS have been corrected to reference the

unimpaired runoff forecast for the McCloud River above Shasta Lake.

Comment: The Forest Service has met with PG&E to discuss flow compliance and the

conversation has focused on using compliance measures that are compatible with

PG&E’s upstream Pit 3, 4, 5 Project because they are operated together, and the Forest

Service has no objection to using weekly means with daily compliance if that provides

the best means to assure basin-wide compliance.

The California Water Board states that most of the Commission’s proposed methods of

measuring minimum flow compliance are complex and allow for some under release and

averaging over time. The California Water Board recommends that Commission staff

explain why the current method of compliance is not adequate. The California Water

Board states that from an enforcement perspective, it is easier to assure compliance with

an instantaneous minimum flow requirement. The California Water Board states that, in

this case, PG&E has the ability to accurately release flows at the two flow compliance
A-47

locations. The California Water Board recommends that the Commission explain why an

averaging period is necessary for flow compliance.

American Whitewater and Friends of the River state that PG&E’s proposed flow

compliance measure is far too complex and that flows should be a minimum flow based

upon a 15-minute instantaneous reading. American Whitewater and Friends of the River

state that this would allow PG&E’s operators, and the general public, to understand the

condition and know if PG&E is in compliance.

Response: We have updated the final EIS to recommend, in section 5.2.1, Discussion of

Key Issues, Aquatic Resources, Flow Compliance and Monitoring, the modified Forest

Service condition which requires that individual 15-minute instantaneous flow

measurements be within 80 percent of the minimum flow prescription for flows less

than10 cfs or at least 90 percent for flows greater than 10 cfs. If the daily average flow is

less than the required minimum flow, PG&E would be required to begin releasing the

equivalent under-released volume within 7 days following discovery of the under-release.

This method for determining instream flow compliance should be less complex than the

method recommended in the draft EIS.

Comment: California Trout, Trout Unlimited, and the Northern California Council,

Federation of Fly Fishers agree with the Commission and the Forest Service that there is

a need for two compliance points at both MC-1 (Ah-Di-Na) and MC-7 (McCloud dam)

and state that it is essential for the implementation of the proposed flow schedule.

McCloud RiverKeepers is in agreement with this too. California Trout, Trout Unlimited,

and the Northern California Council, Federation of Fly Fishers believe real-time flow

data should be made available at MC-7 at McCloud dam and state that MC-1 at Ah-DiNa is already available real-time on the internet. California Trout, Trout Unlimited, and

the Northern California Council, Federation of Fly Fishers states that under existing

conditions and as proposed for a new license, MC-7 is a compliance point and should be

made available real-time on the internet.

Response: We recommend two flow compliance points in section 5.2.1, Discussion of

Key Issues, of the draft EIS and continue to recommend two compliance points in the

final EIS. Under the staff’s recommendations, real-time flow data will continue to be

available for the gage at Ah-Di-Na (MC-1) and flow data at the McCloud dam (MC-7)

will also become available to assist anglers in knowing the flow conditions.

Comment: The Forest Service notes that the water year type determination is only

relevant to the flow regime proposed for Iron Canyon Creek, since the flow in the Lower

McCloud River is set by monthly McCloud runoff (Bulletin 120).

McCloud RiverKeepers states that the Forest Service’s run-off percentages and the five

water-type year categories are inadequate and do not adequately provide for a “normal or

average” water-type year. McCloud RiverKeepers states that the flow rule also changes

the existing flow regime in that it does not include decreases in minimum required flows

during dry years.
A-48

American Whitewater and Friends of the River state that the hydrologic record shows

that there is a clear snowmelt pulse that occurs in all but the most extreme dry years.

They also note that with the potential for the reintroduction of anadromous fish, flows

that allow fish to migrate throughout the Lower McCloud River will be required in all

water year types. They believe that the flow proposal from the Forest Service/California

Fish and Game/PG&E will help meet that requirement.

Response: Water year types listed for Iron Canyon dam releases (wet, above normal,

below normal, dry, and critically dry) correspond to the five runoff percent ranges

(> 120 percent, 100-119 percent, 90-99 percent, 76-89 percent, and 0-75 percent) listed

for McCloud River dam releases. We find that these ranges adequately capture the range

of flow conditions and provide an appropriate mechanism and protocol to mimic a more

natural hydrograph, capturing the late winter/spring snowmelt event(s).

Comment: PG&E comments that the water year types contained in the March 3, 2010,

alternative condition from the California Trout, Trout Unlimited, and McCloud River

Club flow proposal differs from the March 1, 2010, Forest Service revised 4(e)

condition 19 that specifies forecasts for the McCloud River above Shasta Lake.

Response: The text has been appropriately revised in the final EIS section, 3.3.2.2,

Environmental Effects, Flow Monitoring and Determination of Water Year Type, to

indicate that water year type would be determined based on the forecast of unimpaired

runoff for the McCloud River above Shasta Lake.

Comment: McCloud RiverKeepers states that the hydrology of the lower-upper

McCloud River measured at gauge MC-3 has no intrinsic relevance in the Lower

McCloud River’s ecosystem and therefore should not be used to determine a change to

the existing flow regime measured at either MC-1 or MC-7.

Response: Gage MC-3 on the upper McCloud River was used by PG&E as a measure of

unregulated flow conditions in order to estimate unimpaired flow in the Lower McCloud

River. Flows at MC-3 were augmented by estimates of direct runoff to the McCloud

reservoir. We consider this method described in TM-46 to be appropriate and adequate

for the analysis.

Comment: The Forest Service states that the final 4(e) conditions should reflect the

PG&E proposed extension of the valve safety testing window from March 5-15 to

March 1-31.

PG&E states that, although the Commission analyzed the valve testing window specified

by California Fish and Game and the Forest Service (between March 5 and 15), the draft

EIS does not include an analysis of the valve testing window of March 1 through 31

submitted in PG&E’s alternative condition (March 3, 2010). PG&E states that its

alternative condition allows a slightly wider scheduling window for adjusting flows and

testing the Iron Canyon dam valve based on weather conditions because snow, ice, and

winter storms can restrict access to the site and create unsafe working conditions from

December through March. PG&E states that monthly adjustments to minimum flow
A-49

requirements and annual valve testing would be conducted as early in these periods as

practical, based on conditions on the ground.

Response: We note that in section 3.3.2.2, Environmental Effects (page 138 of the draft

EIS), we analyzed and recommended implementation of the March 1-31 window for

valve testing. We have updated the final EIS, to reflect Forest Service’s modified

condition 19, which specifies the valve safety testing window from March 1-31.

Comment: The Forest Service would support the installation of the turbidity monitor on

PG&E lands within the boundary near the minimum instream flow outlet of McCloud

dam if needed; the Forest Service would also support the opportunity to combine the

turbidity monitor with the flow monitoring gage at MC-7 if this is desirable.

Response: Our analysis in the final EIS does not preclude the option of placing turbidity

monitoring at either of these locations; the final decision on placement can be determined

during preparation of the monitoring plan.

Comment: The Forest Service completed an Environmental Assessment in 2005 that

evaluated fish passage concerns at road culverts in Shasta-Trinity National Forest. The

Environmental Assessment identified three tributaries to Iron Canyon reservoir (Cedar

Salt Log, Deadlun and Gap Creeks) above Iron Canyon Loop Road with substantial fish

spawning habitat (>1 mile) where improved culvert passage would provide support and

reproductive opportunity to fish populations in the reservoir. The Forest Service notes

that these culverts were installed by PG&E during project construction and, in addition to

blocking fish passage for spawning, have created erosional concerns.

The Forest Service acknowledges that fish stocking may be provided in Pit 7 reservoir in

the future, if recreation access increases fishing pressure. In addition, the Forest Service

reiterates that fish passage issues associated with the Iron Canyon Loop Road (FR

37N78) are the responsibility of PG&E, not the Forest Service as implied in the draft EIS.

Correcting this fish passage would provide access to substantial spawning habitat for fish,

and the Forest Service suggests that addressing the fish passage impediments, in lieu of

stocking the river reaches, would be an alternate and beneficial means to mitigate for the

fish entrainment losses.

Response: We determined that only a 0.7-mile portion of the Iron Canyon Loop road

needs to be within the project boundary. PG&E would be responsible for maintenance of

that road section. Any culverts in those sections of road within the project boundary

would be the responsibility of PG&E to improve/repair in order to enhance fish passage

at those locations. PG&E is not responsible for providing fish passage and maintenance

of culverts on the remaining non-project segments of this road. Plans for culvert

improvements would be part of the road maintenance plan.

Comment: PG&E notes that, with regard to fish surveys, it conducted fish surveys at

nine sites on the mainstem Lower McCloud River in fall 2009, including one additional

site added between Hawkins Creek and McCloud dam, and that results were similar to

those of 2007 and were presented in Technical Memo 18, updated November 2009.
A-50

Response: We have modified section 3.3.2.1.3, Aquatic Biota, Stream Fish Populations,

to recognize the additional year of sampling and similarity of results.

Comment: The Forest Service states that a draft Aquatic Biological Monitoring Plan

will be submitted in the Forest Service’s final 4(e) conditions, allowing PG&E to

complete the plan within the first year of its acceptance of the license.

PG&E states the timeframe presented in the draft EIS for the development of the Aquatic

Resources Management Plan appears inconsistent. PG&E believes the 18-months

timeframe is the most appropriate.

Response: We have revised the text in the final EIS to indicate that because the Forest

Service has provided a first draft as a working document for further consultation and

finalization, we find that 1 year following license issuance would be a reasonable time to

complete the final Aquatic Biological Monitoring Plan.

Comment: The Forest Service recommends that aquatic monitoring should occur at sites

sampled for relicensing studies, and that the benthic macroinvertebrate monitoring should

follow the State of California’s Surface Water Ambient Monitoring Program protocols.

PG&E comments that the number of sites for monitoring of fish, benthic

macroinvertebrates, and special status mollusks may not need to be as large as for

relicensing studies, particularly because some resource inventories for relicensing were

conducted in areas downstream of the Squaw Valley Creek confluence with the McCloud

River, an area FERC’s scoping document determined were beyond the limit of project

effects.

Response: We have updated the analysis of the Aquatic Biological Monitoring Plan

requirements in section 3.3.2.2, Environmental Effects, Fish Population Monitoring, to

reflect Forest Service modified condition 27, which includes the use of Surface Water

Ambient Monitoring Program protocols for the benthic macroinvertebrate monitoring

component.

In the final EIS, we recommend that the number and location of sites to be surveyed

should be consistent, to the extent possible, with the relicensing surveys in order to

determine effects, if any, to aquatic resources resulting from O&M of the project under

the new license. The specific details of the plan, including the number of survey sites and

their location will be determined by PG&E in consultation with conditioning agencies

and must be approved by the Commission prior to implementation.

Comment: The Center for Water Advocacy states that the draft EIS lacks sufficient

water quality monitoring, and this will impact aquatic species and the fishery habitat.

California Fisheries and Water states that the draft EIS does not disclose and evaluate

effects to water quality in the Lower McCloud River and Pit River resulting from the 4(e)

requirements by the Forest Service.

Response: We consider the water quality monitoring data provided by PG&E

relicensing studies to be adequate to determine potential impacts on aquatic species and
A-51

fishery habitat. In the draft EIS, we recommend PG&E develop and implement a water

quality monitoring plan that would assess potential impacts of the project on aquatic

species and habitat over the term of the license.

Our analysis of water quality conditions indicates that the recommended alternative and

Forest Service 4(e) conditions would not adversely affect existing conditions. The

proposed water quality and temperature monitoring plan would document the affects of

O&M from the project on water quality and provide a tool for adaptive management to

assure maintenance of adequate water quality conditions.

Comment: PG&E comments that Iron Canyon reservoir has never spilled and that

McCloud reservoir water levels are managed to prevent spill from Iron Canyon

Reservoir. PG&E notes that this is not stated correctly in the draft EIS.

Response: Final EIS, section 2.1.3, Existing Project Operation, has been modified to

reflect spill conditions at McCloud and Iron Canyon reservoirs as described by PG&E.

Comment: PG&E feels that the draft license article detailing minimum flow releases

within 90 days of license issuance below McCloud dam, Iron Canyon dam, and Pit 7 dam

needs to be clarified to differentiate between implementation of minimum flow

requirements below McCloud dam and those below Iron Canyon and Pit 7 dams. PG&E

states that the minimum flow requirements specified below Iron Canyon and Pit 7 dams

could be implemented within 90 days of license issuance; however, implementing the

springtime minimum flow requirements specified below McCloud dam would require

installing a new valve, which could not be accomplished within 90 days of license

issuance—the process would likely take 2 to 3 years. PG&E states that until the valve is

replaced, the only way to meet the specified flow requirement at McCloud dam would be

to operate at full pool and pass water over the spill gates, which would significantly

constrain project operations and could increase downstream water temperatures.

Response: The text in the license articles is clarified to differentiate the minimum flow

requirements below McCloud dam and those below Iron Canyon and Pit 7 dams. Spring

minimum flows which require design and installation of a new valve at Iron Canyon dam

would be required within 3 years of license issuance.

Comment: The Center for Water Advocacy recommends that PG&E gather the

following information: (1) hydrograph of mean daily flow for the gauge on the McCloud

River above Shasta Lake; and (2) daily maximum mean and minimum water temperature

at the McCloud River. The Center for Water Advocacy also recommends that PG&E

refer to models produced by The Nature Conservancy for McCloud reservoir in

developing the Operations Model (in addition to the USACE-Hydrologic Engineering

Center Reservoir Simulation Version 3.0).

Response: As part of the relicensing studies, PG&E conducted water quality

temperature modeling and flow modeling, using flow data from gages in the projectaffected stream reaches. The models and field sampling methodologies were developed

and implemented in coordination with resource agencies and other interested parties. We
A-52

continue to consider these models appropriate to assess flows necessary to protect and

enhance the aquatic community and recreation in the Lower McCloud River.

Comment: The California Water Board believes that the three models developed by

PG&E to evaluate flow habitat relationships for the Lower McCloud River (e.g.,

Individual Base Modeling [IBM], Habitat Criteria Mapping [HCM], and PHABSIM) all

have limitations and will not yield accurate results, and thus cannot be used in the final

EIS. The California Water Board believes that the IBM is particularly flawed and its

conclusions are unreliable. In addition, the California Water Board states there are

problems with the use of depth and velocity data collected by the Acoustic Doppler

Current Profiler and its unreliable results should not be used in the final EIS. The

California Water Board states that, because the Acoustic Doppler Current Profiler data

were used for both the HCM and PHABSIM models, it likely generated errors in data

collection and processing that provided velocity data that over-estimates the actual

velocities of the river. The California Water Board advises that another study be required

to determine the amount of error; additional data should be collected in the field; new

transects should be selected in consultation with agencies; and depth and velocity data

should be collected using a flow meter. The California Water Board states that additional

studies are needed to determine if the flows in the 175-200 cfs range, as recommended in

the draft EIS, are supported by the correction flow models. Based on information from

Technical Memorandum 58, the California Water Board states that establishing flows to

meet the needs of less capable waders may not provide the correct balance.

Response: We acknowledge that all models have limitations in their ability to predict

possible scenarios or conditions. We also agree that the IBM in particular had problems

in accurately predicting flow relationships, as was pointed out by PG&E in Technical

Memorandum 58 (TM-58); however, the IBM was requested by the resource agencies

and aided in confirming the precision of all three models in evaluating the optimum flowhabitat relationships. In our analysis of minimum flows in section 3.3.2.2, Environmental

Effects, we indicate that the results of the IBM and HCM were generally similar and

indicated flows at the lower end of the range studied (175-200 cfs) provide greatest

abundance or highest habitat values. Similarly, the PHABSIM modeling runs provided

nearly identical estimates of flows for peak habitat for each life stage evaluated, which

demonstrates the robustness of the model.

Comment: The California Water Board also states that the Commission staff does not

consider the benefits of high spring flows, since construction of the project has resulted in

riparian encroachment. The California Water Board notes that alder and dogwood can

now become established in the flatter areas next to the channel, but under pre-project

flow conditions, these species were forced out of the relatively broad channel and onto

the steeper slope. The California Water Board states that this information was not

considered in Commission staff’s flow recommendations.

American Whitewater and Friends of the River state that higher flows are required in the

spring to keep the river channel clear of vegetation. American Whitewater and Friends of
A-53

the River believe that the proposed Forest Service/California Fish and Game spring flow

schedule will help to meet this objective.

Response: In section 3.3.3.2, Environmental Effects, Riparian and Wetland Vegetation,

we peak flows and a decrease in duration of inundation from flooding, leading to

increased riparian vegetation along the lower reaches of the river. In our analysis, we

indicate that PG&E proposed a minimum instream flow that would provide additional

flow volumes over an annual and seasonally distributed schedule and that the upward

ramping of flows prior to uncontrolled spill events would return scouring flows to the

stream channel, which would reduce the ability of riparian vegetation to become

established along the channel.

Comment: The Center for Water Advocacy feels that the relicensing of the project will

interfere with other existing and future uses of water since the project is currently the

only regulation of the McCloud River and Iron Canyon Creek and the only hydroelectric

project on the McCloud River. The Center for Water Advocacy notes that existing and

future uses of water in the project-affected area include recreation use (boating, fishing,

camping) and instream flow use to protect aquatic resources.

EPA is concerned that the draft EIS does not give full consideration to meeting all

beneficial uses of the McCloud River in the context of the minimum flow determination.

EPA recommends seasonal variation of water release from McCloud dam to create a

more natural flow regime that better supports beneficial downstream uses of the river.

EPA states that beneficial uses include municipal and domestic supply, hydropower

generation, water contact recreation, non-contact water recreation, canoeing and rafting,

cold freshwater habitat, coldwater spawning, and wildlife habitat.

Response: In section 3.3.2.2, Environmental Effects, we analyzed the recommended

alternatives to PG&E’s minimum flow regime proposals for the project’s reaches. Most

of these participants, including PG&E, recommended minimum flows that vary by month

and water year type in order to more closely reflect a natural hydrograph for the system

and support aquatic resources and other users. In section 4.1, Power and Economic

Benefits of the Projects, we analyzed how the proposed and recommended minimum

flows decrease the project’s power generation. In section 5.2.1, Discussion of Key Issues,

we considered both the cost of raising instream flows and how the recommended

minimum flows affect other competing flow uses, including aquatic habitat and

recreational resources, such as angling and boating. Based upon these analyses, we made

a minimum flow recommendation that provides the best balance of developmental and

non-developmental resources.

Comment: The California Water Board notes that the draft EIS states that the primary

consumptive uses of water in the Lower McCloud and Pit Rivers within the project area

are recreation and wildlife/aquatic habitat. The California Water Board states that

recreation and wildlife/aquatic habitat are not usually considered consumptive uses but

are beneficial uses identified in the basin plan. The California Water Board states that the
A-54

list of beneficial uses for the McCloud River is incomplete and should include canoeing

and rafting.

Response: We removed wildlife and aquatic habitat from the discussion of consumptive

uses in section 3.2.2.1, Affected Environment, Water Quantity, of the final EIS and we

modified the description of beneficial uses in the final EIS to include non-contact

recreation uses such as fishing, canoeing, and kayaking.

Comment: The Center for Water Advocacy feels that the current draft EIS lacks

measures to address potential channel maintenance problems typically associated with

hydro-power operations. The Center for Water Advocacy feels that it is likely, therefore,

that PG&E would be unprepared for a major event that would devastate the cultural and

fishery resources in the McCloud River.

Response: Section 3.3.1.2, Environmental Effects, of both the draft and final EIS notes

that continued operation of the project could affect geomorphic characteristics of the

stream channel. In the Sediment and Erosion Control section, our analysis indicates that

PG&E’s proposal for management and control of erosion and sedimentation would

provide development of emergency response protocols to manage erosion and

sedimentation. The measures in this proposal would also provide mitigation for existing

erosion sites and prevention of erosion and sedimentation associated with project

infrastructure and future project actions. In the Large Woody Debris section, we note that

the addition of LWD is an important component of channel maintenance, and we

recommend the incorporation of an LWD Plan in the license.

ANADROMOUS FISH

Comment: The California Water Board states that changes in project operations to

support the reintroduction of anadromous fish to the McCloud River must be included as

an alternative in the final EIS. This is because a required plan to re-introduce winter-run

and spring-run Chinook salmon to habitats upstream of Shasta dam will be in place by

January 2011, with reintroductions beginning January 2012. The California Water Board

notes that winter-run and spring-run Chinook salmon will thus be present in watersheds

upstream of Shasta dam by January 2012.

The Winnemem Wintu Tribe states that Chinook salmon require different flow regimes

than those considered in the preliminary 4(e) proposals submitted, and that none of the

proposed 4(e) flow conditions submitted maintain sufficient summer flows to preserve

the cooler temperatures required by the winter-run Chinook. The Winnemem Wintu

Tribe proposes that flows below McCloud reservoir be increased to 600 cfs in July,

400 cfs in August, and 400 cfs in dry and critically dry Septembers to support the

reintroduction of anadromous fish populations.

Response: After reviewing the NMFS Operations Criteria and Plan Biological Opinion

(OCAP BiOp) and other documents associated with NMFS Reasonable and Prudent

Alternative (RPA), we continue to find a lack of specific detail regarding the

reintroduction of Endangered Species Act (ESA) listed salmonids into project-effected
A-55

stream reaches. As this reintroduction program continues to be in flux, with research,

budget, and feasibility still undetermined, and no solid timeline for the salmonids to be

fully present in project waters, we continue to find that this is not the appropriate time to

consider project operational conditions for the benefit these listed species. At such a

time that the species are present in the watershed, then measures for their protection can

and should be considered. As such, in final EIS section 5.2.1, Discussion of Key Issues,

Listed Salmonid Technical Integration Committee, we have revised the text to

recommend that PG&E keep abreast of the findings and actions of the Interagency Fish

Passage Steering Committee and file an annual report with the Commission detailing the

steps that have been taken in the reintroduction and the status of the reintroduction. The

filing of this report will ensure that PG&E and the Commission are kept informed of the

progress of the potential reintroduction and this information would then be used to

determine when it is appropriate to consider any needed changes to project structures and

or operations in light of the presence of ESA-listed salmonids in project waters.

The RPA determined by NMFS in the OCAP BiOp for reintroduction of listed salmonids

in the Lower McCloud River proposes only a pilot study to determine the suitability for

potential introductions in the future. If, and, when NMFS decides that such

reintroductions are necessary, they may decide to conduct a NEPA analysis.

We also note that we have not been provided a basis or supporting evidence that flows

proposed by NMFS would support reintroduced listed salmonids; the flows we

recommend in the final EIS have been supported by modeling studies and input from

license participants and are aimed at providing habitat conditions suitable for the existing

fish community.

Comment: California Trout, Trout Unlimited, and the Northern California Council,

Federation of Fly Fishers state they are willing to participate in a process to attempt to

develop commonly agreed upon measures for streamflow requirements that will take

effect upon reintroduction of salmon and steelhead.

Response: We appreciate the interest in participating in a process to develop streamflow

requirements for the proposed salmon and steelhead reintroductions; however, we cannot

specify which interested parties or agencies are required to attend such proceedings

because the Commission only has jurisdiction over its licensees.

Comment: The Center for Water Advocacy believes this project blocks all upstream

movement of anadromous fishes from the Pacific Ocean at McCloud reservoir and

interferes with anadromous fish passage at each facility within the project. In the Center

for Water Advocacy’s opinion, PG&E’s facilities impair or preclude upstream fish

movements for spawning fishes such as Chinook salmon, redband trout, lamprey, and

various sucker species.

NMFS states that a RPA to proposed operations at the Bureau of Reclamations Central

Valley Project includes a program to reintroduce salmonid species in the McCloud and/or
A-56

upper Sacramento Rivers by providing fish passage upstream and downstream of the

Shasta dam.

Response: We note that the Shasta and Keswick projects downstream on the

Sacramento River prevent access for anadromous species to even access the upper

Sacramento River and its tributaries, including the McCloud and Pit Rivers and their

tributaries.

As part of NMFS’s restoration plan (RPA for the OCAP Bi-Op) for listed salmonid

species, we understand that studies are ongoing to assess the feasibility of alternatives to

facilitate fish passage at Keswick and Shasta dams and the quality and availability of

appropriate habitat in tributaries to Shasta Lake including the Lower McCloud River.

None of the listed anadromous salmonids would be expected to have access to habitat in

the Lower McCloud River until reintroduction of listed species is implemented through

Shasta Lake.

With regard to anadromous fish, if these fish are successfully reintroduced into project

waters, the license could be reopened to address the potential effects of project operations

and the need for fish passage. NMFS has reserved the authority to prescribe fish passage

at such time as it becomes necessary. In the final EIS, we recommend that PG&E file

annual reports listing the progress and status of the reintroduction program. The

information contained in these reports can then be used to determine when it is

appropriate to revisit the license conditions and consult on project-related effects as they

relate to the ESA-listed species now present in project waters.

Comment: The Winnemem Wintu Tribe feels that FERC should address potential

fishway modifications to the McCloud dam in conjunction with PG&E’s proposed

McCloud powerhouse. The Winnemem Wintu Tribe states PG&E must install a new

release valve and make other modifications to the McCloud dam in order to install its

new powerhouse. The Tribe states that if the McCloud powerhouse is

approved/constructed without any consideration of potential fishway needs, its operation

may further impede NMFS’s planned restoration of the listed species and PG&E may

have to make expensive modifications later.

Response: Due to a lack of more specific information, we do not make any

recommendations with regard to PG&E’s proposed new powerhouse. Regardless, we fail

to see the link between construction of that powerhouse and fish passage.

Comment: NMFS states that its June 2009 Biological Opinion mandates reintroduction

of anadromous fish species, protected under the ESA, into the project watershed in the

foreseeable future. The species at issue are Sacramento winter-run Chinook salmon

(Oncorhynchus tshawytscha), Central Valley spring-run Chinook salmon

(O. tshawytscha), and Central Valley Steelhead (O. mykiss). NMFS notes that its

October 2009 Public Draft Recovery Plan for Central Valley ESA-listed salmonids

describes strategies/actions required to recover these species and includes recovery

scenarios that involve the reintroduction into the upper Sacramento-McCloud River
A-57

watersheds upstream of Shasta dam. As stipulated by the RPA of the OCAP BiOp, a plan

for the reintroduction of these salmonid species is scheduled to be in place by January

2011. NMFS states that this pilot reintroduction program for the three ESA-protected

anadromous fish species is a mandatory condition on Bureau of Reclamation’s Central

Valley Project and State Water Project operations and is not optional.

NMFS notes that the purpose of NMFS’s recommended 10(j) conditions is to have

conditions in the license in advance so that such terms would benefit listed salmonids as

soon as they arrive within the McCloud-Pit Project watershed. NMFS states that by

ignoring the imminent nature of anadromous fish reintroduction into the project area, the

Commission fails in its responsibility to balance resource values under the FPA, as well

as in responsibilities under ESA section 7(a)(1) and (2).

NMFS disagrees with the Commission’s preliminary determination of inconsistency with

six of NMFS’s wildlife protection, mitigation, and enhancement recommendations under

FPA 10(j), and seeks to correct the misperception that the remaining two

recommendations are not within the scope of 10(j). The Commission’s alternative

recommendations in the draft EIS are unacceptable to NMFS, and NMFS requests the

Commission revise its preliminary determination of inconsistency under the FPA

proceedings and commence preliminary consultation with NMFS under provisions of the

ESA.

California Trout, Trout Unlimited, and the Northern California Council, Federation of Fly

Fishers do not agree with the Commission’s rejection of NMFS 10(j) recommendations to

conduct an environmental analysis for the purpose of evaluating and developing PM&E

measures related to the reintroduction of anadromous fish into the Lower McCloud River.

California Trout, Trout Unlimited, and the Northern California Council, Federation of Fly

Fishers feel this is in violation of NEPA and is contrary to the FPA’s comprehensive

planning mandate, and that it is legally required because NMFS mandates the

reintroduction of salmon and steelhead upstream of Shasta Reservoir.

California Trout, Trout Unlimited, and the Northern California Council, Federation of Fly

Fishers feel that it is critical that the Commission recognizes that its draft NEPA

document is not sufficient and takes action to address that shortcoming. Mr. Curtis

Knight, representing California Trout and Trout Unlimited, made a public comment at the

morning draft EIS meeting on September 9, 2010, that addressed many of the

aforementioned comments made by California Trout and Trout Unlimited concerning

bull trout and reintroductions of steelhead and salmon into the McCloud River.

The California Sportfishing Protection Alliance states that the final EIS should evaluate

under NEPA the reasonably foreseeable actions and effects that may come to pass

through the future reintroduction of salmon and steelhead to the McCloud River.

The Winnemem Wintu Tribe states that the Commission’s failure to use the integrated

relicensing procedure as designed to efficiently incorporate the restoration of anadromous

species is a violation of its duties under NEPA and the ESA.
A-58

Response: We acknowledge the stated goals of the OCAP BiOp and the Public Draft

Recovery Plan and progress of the programs to-date; however, based upon documented

scientific, legal, regulatory, and economic uncertainties, the reestablishment of listed

salmonids both above Shasta dam and in the project area is not assured. We note that in

October, 2010, the Interagency Fish Passage Steering Committee’s Annual Report of

Activities indicated that the Bureau of Reclamation requested, but has not received

funding for fiscal year 2012 and does not have dedicated fiscal year 2011 funding for the

Fish Passage Program. The program is currently subsisting by requesting that partner

agencies “...provide what support they are able to provide within existing budgets and

staffing.” Therefore, we continue to conclude that eight of NMFS’s recommendations

are inconsistent with the comprehensive planning standard of section 10(a) of the FPA, as

well as the equal consideration provision of section 4(e) of the FPA. However, despite

the uncertainty regarding the reestablishment of listed anadromous salmonids in the

project area, we continue to recognize the potential for the future presence of listed

anadromous species in the project area.

Final EIS section 3.3.2.2, Environmental Effects, incorporates discussion of the RPA of

the OCAP BiOp. As a result of additional analysis, we recommend that PG&E file

annual reports listing the progress and status of the reintroduction program. The

information contained in these reports can then be used to determine when it is

appropriate to revisit the license conditions and consult on project-related effects as they

relate to the ESA-listed species now present in project waters. We understand that an

assessment of the Lower McCloud River for habitat suitable for the listed salmonids is

being undertaken by Bureau of Reclamation and that a pilot reintroduction study is

scheduled to occur sometime during 2012-2015. The annual reports filed by PG&E will

provide for ongoing information regarding the restoration process and facilitate

evaluation of appropriate flow conditions to assure adequate flows and temperatures to

support the listed salmonids, when the time is appropriate. As the appropriate conditions

for these species are more clearly identified through ongoing studies and stakeholder

consultations, changes to the license can be implemented through the standard license

reopener.

Comment: PG&E concurs with the Commission’s analysis indicating that

recommendations by NMFS would provide no benefit for listed species at this time

because listed anadromous salmonids would not have access to habitat in the Lower

McCloud River until upstream migration of listed species is implemented through Shasta

Lake.

NMFS suggests that the Commission adopt their 10(j) conditions during this relicensing

action, with an active “trigger mechanism” that will put the conditions into effect as soon

as listed species are present and impacted by project operations, rather than suddenly

having to deal with the presence of listed species.

California Trout, Trout Unlimited, and the Northern California Council, Federation of Fly

Fishers state that the comprehensive planning mandate of the FPA argues strongly for
A-59

consideration of project effects on these fish, not against it (as was suggested in the draft

EIS). Mr. Curtis Knight, representing California Trout and Trout Unlimited, made a

public comment at the morning draft EIS meeting on September 9, 2010, that addressed

many of the aforementioned comments made by California Trout and Trout Unlimited

concerning bull trout and reintroductions of steelhead and salmon into the McCloud

River.

The California Water Board, EPA, California Trout, Trout Unlimited, and the Northern

California Council, Federation of Fly Fishers, Center for Water Advocacy, and California

Sportfishing Protection Alliance indicate that the draft EIS fails to sufficiently address the

plan for salmon reintroduction in Shasta Lake and the McCloud River.

EPA is concerned that the draft EIS does not adequately evaluate the reasonably

foreseeable introduction of ESA-listed species, anadromous salmonids, into the McCloud

River over the term of the license. EPA recommends this scenario be fully evaluated in

the cumulative impact assessment for this project and that, furthermore, the final EIS and

FERC license should include mitigation and license conditions that require PG&E to

evaluate, and, if appropriate, implement restoration activities for anadromous salmonids.

Response: In the final EIS, we have updated the text in section 3.3.2, Aquatic Resources,

to acknowledge the potential for the reintroduction of listed salmonids into Shasta Lake

and the McCloud and Pit Rivers that coincides with the RPA of the OCAP BiOp;

however, as discussed in section 3.3.2.3, Cumulative Effects, we continue to maintain that

there are uncertainties regarding the viability and implementation of the reintroduction

program set forth by the OCAP BiOp. We also maintain that recommendations provided

by NMFS present no benefit to listed salmonids until they are present within project

waters and that the requested flows have not been based on results of the minimum flow

studies conducted by PG&E, nor have they been consulted on among the McCloud-Pit

Project stakeholders. We note that PG&E will be required to implement a Coarse

Sediment Management Plan under the Forest Service modified 4(e) conditions, which

may provide adequate spawning habitat the listed salmonids. Furthermore, the proposed

aquatic resources monitoring plan should provide information to assess the quality of

substrate and water temperatures under the new minimum flow regime to support listed

salmonids. In addition, we recommend in the final EIS that PG&E file annual reports

detailing the progress and status of the potential reintroduction efforts and these reports

would provide a mechanism for evaluating the need for altering project operations based

upon the presence or imminent presence of listed salmonids.

Comment: The Center for Water Advocacy, California Sportfishing Protection Alliance,

Winnemem Wintu Tribe and EPA comment that the EIS and project license should

include mitigation and license conditions that require PG&E to evaluate and, if

appropriate, implement restoration activities for anadromous salmonids in the McCloud

River as recommended in the OCAP BiOp.

Response: We have revised the text in the final EIS, section 3.3.2, Aquatic Resources, to

acknowledge the OCAP BiOp, and the plans by NMFS to conduct a listed salmonid
A-60

reintroduction pilot study in the project area during 2012-2015. We have also

recommended that PG&E file annual reports detailing the progress and status of the

potential reintroduction efforts and these reports would provide a mechanism for

evaluating the need for altering project operations based upon the presence or imminent

presence of listed salmonids.

Comment: The Center for Water Advocacy believes that the project produces serious

impacts to fish because it has permanently blocked access to historical salmon habitat in

the Upper McCloud-Pit Basin since 1968, and the draft EIS mostly fails to address this

impact; the Center for Water Advocacy states that the draft EIS does not address changes

to mitigate the project impacts.

Response: It is not within the temporal scope of the EIS to evaluate the pre-project

conditions. The baseline for the draft EIS includes the existing conditions under the

current license which is the no-action alternative.

Comment: The Center for Water Advocacy believes that allowing access above

McCloud reservoir to salmonid populations would provide an impetus for applying

ecosystem restoration measures over the course of a new PG&E license and that

salmonids would be able to migrate from the upper McCloud and Pit River basins to the

ocean if modifications were made, such as the building of a screen structure and yearly

opening of the gates for the winter-run of the species. The Center for Water Advocacy

states that freeing of the Red Band and other trout species so they can migrate to the

Pacific Ocean—through modifications of the Red Bluff diversion dam and the project—

would mean the return of the anadromous Steelhead. They note that modeling results

indicate that the volitional fish passage options rank higher than trap-and-haul options

and that under restored conditions, tributaries above Upper McCloud-Pit Lake provide

significant spawning and rearing capacity in the model.

NMFS states that the McCloud River in particular is a primary Candidate Area for

reintroductions of the listed species and that during the pilot program from January 2012

through 2015, the winter-run, spring-run, and steelhead will be reintroduced into suitable

habitats upstream of Shasta dam in the Sacramento River Watershed. The specific places

and methods of reintroductions will be determined by the Interagency Fish Passage

Steering Committee.

Response: We have recommended in EIS section 5.2.1, Discussion of Key Issues,

Aquatic Resources, Listed Salmonid Technical Integration Committee, that PG&E file

annual reports detailing the progress and status of the potential reintroduction efforts and

these reports would provide a mechanism for evaluating the need for altering project

operations based upon the presence or imminent presence of listed salmonids. NMFS has

reserved its authority to prescribe fish passage at such time as it is appropriate in the

restoration process; at that time NMFS will be able to prescribe the most appropriate

method to provide fish passage up and downstream at the McCloud dam.
A-61

Comment: The Center for Water Advocacy states that modeling shows that the project

increases in water temperatures in late summer and fall will reduce the survival of adult

Chinook salmon (because they return to spawn during this period) and cause poor egg

quality, ultimately leading to decreased production. Furthermore, the Center for Water

Advocacy states that the project causes lower water temperatures during winter, spring,

and early summer, which will reduce the growth and maturation rates of salmon and

steelhead during incubation, emergence, and juvenile stages. The Center for Water

Advocacy states that this will impact the ability of fish to survive their migrations

through the McCloud River.

Response: In the final EIS, our analysis of the proposed minimum flows in section 3.3.2,

Aquatic Resources, Water Quality Monitoring, indicates some uncertainty of the effects

that the new flow regime will have on water temperatures in the project reaches or on the

cold water pool available below the thermocline in McCloud reservoir; however, in order

to minimize effects, we recommend implementation of water quality and temperature

monitoring program capable of providing data to evaluate water temperatures under the

new flow regime and assess the compatibility with requirements of anadromous salmonid

life stages.

Comment: The Center for Water Advocacy states that because PG&E relies heavily on

monthly mean, minimum and maximum inflow into the project reservoirs from the

McCloud, Iron Creek and Pit Rivers for its hydrological record data base as reported by

water gages and that the draft EIS ignores data that could be collected from potential

stream reaches in which salmonid species could be re-established and the impacts of

flows on other significant existing and future water uses.

The Center for Water Advocacy states that the approach to analyzing affected river flows

and water uses other than the project ignores the fact that watersheds, and aquatic

ecological systems in particular, do not recognize subbasin divisions, which makes it

impossible to analyze the role of unimpaired hydrological development in the potential

return of salmonid species to the upper basin of the project-affected area.

American Whitewater and Friends of the River believe that the proposed flows should be

reviewed and revised to allow for the reintroduction of anadromous fish into the Lower

McCloud before that reintroduction occurs.

The Winnemem Wintu Tribe states that Chinook salmon require different flow regimes

than those considered in the preliminary 4(e) proposals submitted. The Tribe feels that

none of the proposed 4(e) flow conditions submitted maintain sufficient summer flows to

preserve the cooler temperatures required by the winter-run Chinook. The Tribe feels

that necessary instream flows, gravel augmentation, and LWD placement should all be

implemented so that these restored fish have a chance for survival. The Winnemem

Wintu Tribe proposes a flow regime for the Lower McCloud River to support salmonids,

including the endangered Sacramento River winter-run Chinook salmon and the

threatened Central Valley spring-run Chinook salmon. The Tribe also supports gradual
A-62

down-ramping after McCloud dam spill events in order to decrease risks to aquatic

resources.

Response: It is our understanding that NMFS is planning habitat evaluation and pilot

reintroduction studies for listed salmonids in the upper Sacramento River watershed

above Shasta dam during the next 5 years. In final EIS section 5.2.1, Discussion of Key

Issues, Aquatic Resources, Listed Salmonid Technical Integration Committee, we

recommend that PG&E file annual reports detailing the progress and status of the

potential reintroduction efforts and these reports would provide a mechanism for

evaluating the need for altering project operations based upon the presence or imminent

presence of listed salmonids.

In the final EIS, our analysis of the proposed minimum flows in section 3.3.2, Aquatic

Resources, Water Quality Monitoring, indicates some uncertainty of the effects that the

new flow regime will have on water temperatures in the project reaches or on the cold

water pool available below the thermocline in McCloud reservoir; however, in order to

minimize effects, we recommend implementation of water quality and temperature

monitoring program capable of providing data to evaluate water temperatures under the

new flow regime and assess the compatibility with requirements of anadromous salmonid

life stages. Water temperature recorded as part of the water quality monitoring plan and

at other gages in the McCloud River basin can be used in this evaluation.

Comment: The Center for Water Advocacy does not agree with conclusions in the

supplemental plan that discount the potential salmon and other fishery habitat in the

Upper McCloud River and tributaries. The Center for Water Advocacy is also concerned

that the list of agencies provided for the supplemental plan do not include tribal

consultations or tribal studies regarding fishery resources and feels that further, PG&E

should commit to continue to consult with the Winnemem Wintu and other federally

recognized Indian Tribes in relation to fishery resources portion of the draft EIS.

The Winnemem Wintu Tribe disagrees with the Commission’s preliminary determination

of inconsistency as to the restoration of anadromous fish to the McCloud River under

18 Code of Federal Regulations (CFR) section 5.27.

Response: Please see our previous comments regarding NMFS restoration plans and the

potential for reintroduction of anadromous salmonids in project waters.

Comment: NMFS notes that no costs would be incurred under the recommended 10(j)

conditions until fish are present. NMFS states that inadequate information exists in the

preliminary determination of inconsistency to support any analysis of costs the

Commission used in any balancing exercise it conducted in reaching its preliminary

finding.

Response: We concur that no costs would be incurred associated with the 10(j)

recommendations until fish are present; however, we also find that habitat conditions

including flows, water temperature and substrate have not been adequately defined for
A-63

the listed salmonids at this time. Therefore, given the absence of listed salmonids at this

time, no costs would be justified.

Comment: California Trout, Trout Unlimited, and the Northern California Council,

Federation of Fly Fishers ask that the Commission investigate the issue of bull trout

reintroductions more thoroughly and require PG&E to fund a bull trout reintroduction

effort. California Trout, Trout Unlimited, and the Northern California Council,

Federation of Fly Fishers recommend this be done in close cooperation with California

Fish and Game and other stakeholders. California Trout, Trout Unlimited, and the

Northern California Council, Federation of Fly Fishers believe it is necessary to review

the reasons for decline of the bull trout, current and potential future habitat conditions,

and life history requirements to determine feasibility of a reintroduction plan or if

alternative mitigation measures should be pursued. This proposed assessment would

form the basis for making informed management decisions for bull trout in the McCloud

River. California Trout, Trout Unlimited, and the Northern California Council,

Federation of Fly Fishers state that there is evidence to indicate a clear project nexus and

requirement to more thoroughly address the extirpation of bull trout in the McCloud

River final EIS. Mr. Curtis Knight, representing California Trout and Trout Unlimited,

made a public comment at the morning draft EIS meeting on September 9, 2010, that

addressed many of the aforementioned comments made by California Trout and Trout

Unlimited concerning bull trout and reintroductions of steelhead and salmon into the

McCloud River.

The Winnemem Wintu Tribe is also concerned that the current configuration of the dam

at the McCloud River prevents any fish passage, making successful restoration of the bull

trout population unlikely.

Response: In sections 3.3.2.1.3, Aquatic Resources, Aquatic Biota and 3.3.2.3,

Cumulative Effects, of the draft EIS, we discuss that the extirpation of bull trout from the

watershed is thought to be the results of a number of factors including, but not limited to,

loss of the forage base, excessive fishing pressure, competition from other managed game

species, and reduction of habitat associated with construction of McCloud dam. We also

indicate that past efforts by California Fish and Game to restore the species through

stocking were unsuccessful and the restoration is not currently a primary management

goal of the agency. In addition, no recommendations by other agencies have been

proposed specifically to support restoration of this species at this time.

Comment: The Winnemem Wintu Tribe believes the Commission has failed to examine

the impacts of the McCloud powerhouse on the McCloud River’s native fish species,

such as riffle sculpin, McCloud redband trout, and Sacramento suckers. The Tribe states

that the addition of a powerhouse at the base of the McCloud Reservoir has the potential

to alter the temperature, turbidity, and dissolved oxygen (DO) levels of the McCloud

River, and could increase fish entrainment. The Tribe feels that, in order for the

McCloud River to present a hospitable environment for these salmonids, upon

reintroduction the McCloud River flows must provide adequate temperatures, depths, and
A-64

velocities to support these fish, which will require different flow regimes than those

contained in the various proposed 4(e) flow conditions in the draft EIS. The Winnemem

Wintu Tribe proposes that flows below the McCloud Reservoir be increased to 600 cubic

feet per second (cfs) in July, 400 cfs in August, and 400 cfs in dry and critically dry

Septembers to assure the survival of these restored salmonids.

Response: The draft EIS evaluates the anticipated impacts of the additional generation

unit at the base of McCloud dam, as currently proposed, including considerations of

various mitigation options proposed by the applicant, state and federal agencies, etc. The

management plans to be finalized post-licensing will provide specific details of how

PG&E would implement the final mitigation options. The recommended monitoring

plans will determine if the mitigation required in the license is achieving its purpose of

avoiding or minimizing impacts. FERC and appropriate agencies will have an

opportunity to review and comment on whether draft management and monitoring plans

achieve the purposes of the mitigation described in the EIS. We also note that PG&E has

only studied the feasibility of installing the generation unit at the base of McCloud dam,

but has not yet determined the hydraulic capacity of the unit. We currently find that the

cost of the unit would outweigh any potential power benefits; however, we state in the

final EIS that we cannot make any recommendation until PG&E determines the final size

of the unit. If PG&E decides to move forward with the proposal, further analysis would

be required at that time.

Comment: NMFS states that the OCAP BiOp, which it considers a regulatory certainty,

contains a RPA for the Bureau of Reclamation to develop a fish passage program. NMFS

is concerned that the draft EIS does not consider the impending implementation of the

RPA.

NMFS noted that the current legal challenge to the BiOp would likely not affect the

schedule for implementation of the pilot program and the longer term reintroduction

program, and that the BiOp is current and valid at this point. NMFS noted that court’s

ruling resulting from the legal challenge indicated that the implementation of the BiOp

and its RPA on the project operations, without any NEPA documentation, violated

NEPA; NMFS further noted that the legal challenge was to portions of the RPA, which

are unrelated to the fish restoration measures that were part of NMFS’s 10(j)

recommendations.

Response: We acknowledge the future implementation of the RPA of the OCAP BiOp

in the final EIS and appreciate NMFS clarification on the legal proceedings concerning

the OCAP BiOp. This, together with the OCAP BiOp that was filed on the record have

allowed Commission staff to further review and analyze the potential reintroduction

activities and the final EIS text has been updated to include greater discussion and

analysis of the reintroduction.
A-65

WATER RESOURCES

Comment: PG&E states that because only bacterial contamination was identified as a

specific issue during relicensing and no other contaminants of concern were identified in

pre-licensing surveys, the license provision identifying “specific contaminant monitoring

locations” should be changed to “bacterial monitoring locations.” PG&E notes that this

is consist with both PG&E’s draft water quality monitoring plan and Forest Service

condition 20, which discuss the potential for bacterial contamination within McCloud and

Iron Canyon reservoirs near recreation sites.

Response: Although only bacterial contamination has been identified as a specific issue,

we consider that monitoring project reservoirs once every 5 years for other contaminants

would be useful for ensuring public health and determining the potential impacts of

project operations. We recognize that the term “contaminants” has not been defined, but

specific monitoring parameters would be identified in the water quality and temperature

monitoring plan that would require Commission approval, and therefore, would not

contain unreasonable monitoring requirements. In the final EIS, we recommend Forest

Service modified condition 20, which specifies that the plan include monitoring for

contaminants, including E. coli, in project reservoirs every 5 years.

Comment: The Center for Water Advocacy suggests that PG&E conduct temperature

modeling for the following: (1) the annual pattern of daily mean water temperature,

seasonal means, maximum temperatures; (2) daily water and air temperature during the

summer and fall at the McCloud River Preserve; (3) specific conductance (the Center for

Water Advocacy feels that other models in the McCloud river indicate “very noisy”

specific conductance data); (4) daily maximum, mean and minimum specific

conductance; (5) DO; (6) daily maximum, mean, and minimum DO; (7) correlation

between daily mean DO and mean water temperature; and (8) daily mean turbidity.

Response: In 2007, PG&E conducted temperature monitoring (Technical Memorandum

28: 2007 Water Temperature Monitoring) to evaluate the influence of the various

tributary inflows on water temperatures in the main stem of the McCloud River. In

addition, PG&E used the StreamTemp Version 1.0.4 (Technical Memorandum 38: Lower

McCloud Water Temperature Modeling) to model temperatures in the Lower McCloud

River from McCloud dam to Gage MC-5 upstream of Shasta Lake from June to October.

This model was used to predict mean and maximum daily water temperatures and aid in

analyzing the thermal consequences of releasing alternative flows below McCloud dam.

In 2007 and 2008, PG&E conducted monthly and seasonal water quality sampling

(Technical Memorandum 26: Water Quality Data Summary) to determine baseline water

quality conditions in the project area; sampling components included DO, specific

conductance, and turbidity. In 2007 and 2008, PG&E also conducted turbidity

monitoring (Technical Memorandum 30: Results of Suspended Sediment Monitoring) to

determine the potential effects of project operations on turbidity in McCloud reservoir

and the Lower McCloud River. We continue to consider the data provided by PG&E to

be sufficient to address the environmental effects upon water quality associated with the
A-66

continued operation of the project, including the alternatives recommended by the license

participants.

Comment: Center for Water Advocacy states that the recommendations in the final EIS

should minimize thermal impacts to listed salmonids by passing water through the

reservoir bypass; require installation of adequate temperature monitoring devices and

develop a monitoring plan to track compliance; and require PG&E to develop a water

quality management plan to insure water quality standards are met and to safeguard

ecological resources in the McCloud River.

Response: Because habitat feasibility studies are ongoing and the reintroduction of listed

salmonids above Shasta Lake are not imminent, we do not recommend a continuous flow

bypass to maintain flow releases beneficial to listed salmonids at this time. In the EIS,

we recommend the development and implementation of a water quality and temperature

monitoring plan, which would provide guidance for monitoring potential effects of

project operations on water quality and temperature for the term of the license and ensure

proper conditions for aquatic biota. We find these monitoring activities adequate to

detect and minimize any adverse impacts to the aquatic community resulting from O&M

of the project.

Comment: The Center for Water Advocacy states that the draft EIS fails to provide any

information about what chemical water purification agents will be used, and if they are

part of an EPA-approved system. In addition, the Center for Water Advocacy states that

the draft EIS lacks any analysis of the pH, DO, and turbidity in the system.

Response: PG&E has not identified any chemical water purification agents that it is

planning to use at the project. If operation and/or maintenance of the project require use

of chemical agents, PG&E would be required to report these chemicals in its application

for 401 water quality certification.

Comment: The Center for Water Advocacy states that a National Pollutant Discharge

Elimination System (NPDES) permit may be needed if an entity who owns/operates

facilities discharge pollutants into surface waters.

Response: In lieu of an NPDES permit, under the Clean Water Act the license applicant

is required to obtain 401 water quality certification from the appropriate state pollution

control agency, in this case the California Water Board. The Water Board will specify

any measures necessary to comply with the Clean Water Act and protect beneficial uses

in its water quality certification. By letter dated January 5, 2011, PG&E resubmitted its

application for water quality certification to the California Water Board.

Comment: The Center for Water Advocacy advises the Commission to provide a list of

tribal agencies and studies/data that PG&E consulted with regarding fishery resources.

The Center for Water Advocacy states that the current lack of deferring to tribal data and

information regarding fishery resources eliminates important information related to the

impacts of the development on water resources and fish and wildlife habitat and is in

violation of other legal requirements. The Center for Water Advocacy states that Indian
A-67

Tribes should be consulted with regarding the impacts of any hydropower re-licensing on

tribal land, water, and fish and wildlife resources. The Center for Water Advocacy states

state that PG&E has not committed to continuing to consult with the Winnemem Wintu

and other federally recognized Indian Tribes in relation to the fishery resources portion of

the draft EIS.

Response: In section 1.4, Public Review and Comment, we provide a list of comments

or additional information received by the tribal agencies in response to the scoping

document and the final license application (FLA). We describe and evaluate

recommendations of tribal agencies in the EIS.

Comment: The Center for Water Advocacy is concerned that the draft EIS fails to

incorporate the results of the California Stream Bioassessment Protocol, which is

designed to assess the biological integrity of wadeable streams in California. The Center

for Water Advocacy states that if the California Stream Bioassessment Protocol cannot be

incorporated into the draft EIS, then similar studies with similar methodologies should be

included.

Response: The results of the benthic macroinvertebrate sampling conducted by PG&E

during prelicensing studies were discussed in the draft EIS, section 3.3.2.1.3, Aquatic

Biota. PG&E conducted sampling following the California Stream Bioassessment

Protocol and assessed the results using a multimetric index (MMI) that is sensitive to the

cumulative effects of hydropower operations on streams. In addition, PG&E acquired

historical (1999-2008) benthic macroinvertebrate data from The Nature Conservancy’s

McCloud River Preserve for comparison purposes.

The benthic monitoring component of the draft Aquatic Biological Monitoring Plan

specified by Forest Service modified condition 27 recommends the use of the California

Water Board’s Surface Water Ambient Monitoring Program protocol, which replaces the

widely used California Stream Bioassessment Procedure developed by California Fish

and Game.

Comment: The Center for Water Advocacy is concerned that the draft EIS does not

provide conclusions regarding the health or population dynamics of invertebrates or

habitat in the analysis of benthic invertebrates in the habitat assessment. The Center for

Water Advocacy recommends that the information provided in the McCloud River

Preserve Research and Monitoring Report 2007 by the Nature Conservancy be

incorporated into the final EIS.

California Fisheries and Water states that the draft EIS does not disclose and evaluate the

effects to the macroinvertebrate species of the Lower McCloud River resulting from

Forest Service 4(e) conditions.

Response: In section 3.3.2.1.3, Aquatic Biota, of the draft and final EIS, we summarize

the conclusions of the benthic macroinvertebrate assessment conducted by PG&E during

the pre-licensing studies. As stated previously, PG&E used an MMI, which assesses the

ecological impacts of hydropower projects on benthic macroinvertebrate communities.
A-68

On page 115 of the draft EIS we indicated that MMI values from the McCloud River sites

were lower when compared to MMI values of reference sites and at Iron Canyon Creek

the values were within or slightly below the range of MMI values of reference sites.

We also indicate that that PG&E compared the MMI values to historical data collected

over a 10-year period (1999–2008) on the Nature Conservancy’s McCloud River

Preserve and that these MMI values were consistently closer to those of the reference

sites and higher than those collected from the other Lower McCloud River sites. We also

stated that the physical habitat data and benthic macroinvertebrate samples collected over

10 years within the project area generally indicated good aquatic habitat conditions and

water quality.

Comment: The Center for Water Advocacy states that the only way to completely

eliminate adverse impacts to aquatic habitat and cultural resources is to provide

substantial flows down the bypass reaches to assure waters in those reaches are neither

seasonally warmer nor cooler than adjacent river reaches. The Center for Water

Advocacy suggests that the final EIS include an analysis of operating the project with a

run-of-river flow pattern such that the amount of water entering an impoundment is equal

to the sum of water passed over the dam, through fish passage facilities, and through

turbines at any given point in time at every relevant facility structure.

EPA expresses concern that the flow regime selected by FERC, as proposed by California

Trout, Trout Unlimited, and McCloud River Club, may not be the best alternative for the

long-term health of the river ecosystem.

Response: Analysis of alternative flow scenarios evaluated the benefits of water releases

that mimic a more natural hydrograph to enhance, channel morphology, aquatic habitat,

and water quality. The project is not proposed as a run-of-river operation. Instead, the

recommended flow regime in the final EIS attempts to match a more natural hydrograph

while still providing aquatic habitat benefits and recreational opportunities.

Comment: California Fisheries and Water states that the draft EIS does not disclose and

evaluate the specific Forest Service 4(e) condition daily flow requirements.

Response: The effects of alternative flow recommendations (including the Forest

Service 4(e) condition) on aquatic habitat are evaluated in section 3.3.2.2, Environmental

Effects, and the staff’s recommendation is expected to enhance water quality and aquatic

habitat.

Comment: We revised the draft license article, Reservation of Authority to Prescribe

Fishways, in the final EIS to match the language provided by NMFS in its request.

Response: We modified the text of the draft license article “Reservation of Authority to

Prescribe Fishways” to our standard license text because only the Commission has the

authority to reopen a FERC-issued license. The Commission is still the only entity that

can reopen a license; however, if necessary, another agency can request the Commission

to reopen the license. In this case, construction, operation, and maintenance of

mandatory fishways prescribed by the Secretaries of Interior and Commerce under
A-69

section 18 of the FPA are a cause for reopening the license. Furthermore, the standard

language used by the Commission matches in spirit the language requested by NMFS in

its reservation of authority.

Comment: NMFS emphasizes that its “reopener” term for the project, 10(j)

recommendation #1, is tailored to address the specific concerns necessary to address

recovery of the particular listed species at issue, and is thus superior to a general term,

such as the generic Commission term. NMFS states that its 10(j) recommendation #1 and

Forest Service 4(e) conditions 1, 11, and 27, including biological monitoring, special

status species review, and consultations, will serve to detect, document, study the

project’s impacts, and recommend mitigations so as to benefit listed salmonids.

American Whitewater and Friends of the River consider the use of the standard re-opener

clause to be an inadequate substitute for the NMFS proposed 10(j) recommendations.

California Trout, Trout Unlimited, and the Northern California Council, Federation of Fly

Fishers do not agree that the standard reopener provisions in a license include sufficient

detail to deal with the probable reintroduction of salmon and steelhead into the McCloud

River and recommend that the Commission insist that PG&E develops environmental

information sufficient to adopt a legal NEPA document on project effects on reintroduced

salmon and steelhead.

Response: Forest Service conditions 1, 11, and 27, require PG&E to provide specific

information related to the presence of listed species and habitat conditions supporting

listed species. Annual reports required for the monitoring plans will support a

scientifically based request for reopening the license, as necessary, to further enhance

habitat for listed species. Furthermore, as discussed previously, we recommend that

PG&E file annual reports on the progress and status of the potential reintroduction and

these reports will form the basis of any decision regarding the need to reopen the license

to address the presence or imminent presence of listed salmonids in project waters.

The Commission's standard reservation of authority to reopen the license for the

conservation and development of fish and wildlife resources can be used to address

impacts to listed salmonids once they are present in project waters and are found to be

affected by O&M of the project. We recognize that NMFS could invoke this article to

recommend that the Commission reopen a license to permit compliance with the ESA;

however, because listed salmonids are not present in project waters and are not affected

by the project at this time, and studies to determine feasibility of reintroduction are

ongoing, we continue to find that, if and when, listed salmonids are present in project

waters in the future, reopening the license at such a time to address additional project

impacts is adequate and reasonable.

Comment: NMFS states that its recommendations are crafted as complete terms and that

subsections were used only to make the text more readable. NMFS states that the

Commission renumbered its recommendations so as to consider the subsections as

individual recommendations, which is incorrect. For example, NMFS states that 10(j)
A-70

recommendations #3CD (Instream Flow Estimates...) should be #3C; and #3DF (Flow

Ramping) should be #3D. Further, NMFS states that 10(j) recommendation #1B is

actually part of 10(j) recommendation #1 (and/or #1A), which the Commission agrees is

within the scope of the FPA. NMFS states that 10(j) recommendation #1B must be

considered within the context of NMFS 10(j) recommendation #1 because the annual

consultation process affords an opportunity for FERC and PG&E to exchange

information, and coordinate management actions and schedules.

Response: We understand that the NMFS recommendations were provided as complete

terms; however, sections or subsections were discussed and analyzed separately in the

appropriate resource section. In some cases, we have incorporated portions of

recommendations into the development of our staff alternative. Our 10(j) numbering

system in the draft and final EIS was intended to help the reader track these portions of

NMFS’s 10(j) recommendations throughout the document.

TERRESTRIAL RESOURCES

Comment: The Forest Service states that the foothill yellow-legged frog was found in

the Lower McCloud River at one time, although it is unlikely that this population would

be affected by gravel and coarse sediment augmentation near McCloud dam. The Forest

Service notes that, to the contrary, the draft EIS states that the foothill yellow-legged frog

is not found in the Lower McCloud River.

Response: We modified the EIS text in section 3.3.1.2, Environmental Effects, Gravel

and Coarse Sediment, to specify that the foothill yellow-legged frog is not found in the

reach of the Lower McCloud River targeted for gravel and coarse sediment

augmentation, because water temperatures are generally too cold to support the species.

Comment: The Forest Service states that the Commission fails to note that many

pioneering species that have established themselves in the maintenance areas,

transmission corridors, and roadways are invasive species. Therefore, the Forest Service

disagrees with the blanket proposal to allow areas disturbed by project activities to revegetate naturally by pioneering species. In addition, the Forest Service states that

erosion and sedimentation to the disturbed areas are also of concern. The Forest Service

suggests that larger sites, especially those near invasive populations, be re-vegetated to

prevent soil erosion and encourage native vegetation. The Center for Water Advocacy is

also concerned that measures will not be in place to prevent reestablishment of invasive

species.

Response: We acknowledge the Forest Service’s concern regarding a “blanket proposal”

for revegetation of disturbed areas. We have clarified the text to indicate that over time,

vegetation would be expected to reestablish as a result of pioneering of plant species in

adjacent areas (with measures to control invasive species, erosion, and sedimentation),

and growth of plants from the existing seed bank, and restoration of native vegetation by

PG&E. Specifically, in section 3.3.3.2.1, Vegetation, we state that implementation of the

Vegetation and Invasive Weed Management Plan specified in Forest Service condition 25
A-71

would provide potential enhancement of existing populations and habitat by managing

and minimizing encroachment of invasive noxious weeds, and we expect that these

monitoring and management measures would be implemented in conjunction with natural

and planned revegetation efforts in disturbed areas. Treatment protocols that will be

implemented as part of the Vegetation and Invasive Weed Management Plan specified in

Forest Service condition 25 include soil protection and erosion control to minimize the

risk of introducing non-native invasive plant species.

Comment: The Center for Water Advocacy is concerned that the draft EIS fails to

specifically state which species of native plants will be used for restoration in order to

reduce the potential for spread of invasive plants. The Center for Water Advocacy

suggests the frequency of reporting on revegetation monitoring should be within 10

working days after surveys are conducted. The Center for Water Advocacy also

recommends that the draft EIS provide that interpretive signs be posted at revegetation

sites in areas of wildlife habitat. Finally, the Center for Water Advocacy recommends

that the local Indian tribes should be added to the parties receiving such reports and as

entities to receive a specific revegetation plan and to be consulted during preparation of

the review draft that will be submitted to the Commission and other agencies.

Response: As noted in section 3.3.3.2.1, Vegetation, Upland Vegetation, the Vegetation

and Invasive Weed Management Plan developed in consultation with the Forest Service,

would provide guidance regarding revegetation efforts using native plant species and

associated reporting requirements and public communication. Furthermore, in this

section of the EIS, we note that Forest Service condition 25 specifies that PG&E develop

a Vegetation and Invasive Weed Management Plan also in consultation with the County

Agricultural Commissioner, California Department of Food and Agriculture, potentially

affected tribes and other interest parties. Additionally, as noted in section 3.3.3.1.1,

Vegetation, Special Interest Plants, native plants that are suitable for revegetation source

material include culturally significant plant species that have been identified in a

confidential list that was created in consultation with the Tribes.

Comment: The Forest Service states that additional time should not be needed to

incorporate already approved protocols from the vegetation plan for the Pit 3, 4, 5 Project

into the draft Vegetation and Invasive Weed Management and Monitoring Plan. The

Forest Service will submit collaboratively developed draft plans, in addition to the final

4(e) conditions; therefore plan preparation should be substantially complete.

Response: Because the Forest Service and PG&E have worked collaboratively on the

draft Vegetation and Invasive Weed Management Plan and it is substantially complete,

we have modified our recommendation for completion of the plan to be within 1 year of

license issuance, rather than the 2-year timeframe we recommended in the draft EIS.

Comment: The Forest Service agrees with the Commission and suggests that PG&E

collect seeds and cuttings from culturally significant populations that are not associated

with Traditional Cultural Properties (TCPs) (as identified in the Historic Properties

Management Plan [HPMP]), in order to support the use of culturally significant
A-72

populations in revegetation and erosion control efforts. The Forest Service suggests that

the locations of culturally significant populations, or other sites requiring protection, be

displayed on an Operations Map to avoid impact during management activities such as

dumping, herbicide application, materials staging, etc. This would be an alternative to

annual monitoring of these sites.

The Forest Service states that culturally significant population monitoring will be

included in the botanical monitoring survey scheduled at 5-year intervals and that

selection of final populations will be from those located in Study CR-S2 for the Pit River

Tribe but not identified in association with TCPs. The Forest Service states that a similar

protocol will be suggested for the Winnemem Wintu Tribe if it requests that culturally

important plant species be included in revegetation efforts. The Forest Service feels that

botanical surveys need to be completed within the expanded area of potential effects

(APE) for the Winnemem Wintu Tribe along the Lower McCloud River, because this

information will be necessary to identify the culturally significant plants associated with

TCPs.

PG&E notes in its reply comments filed on October 27, 2010, that it completed botanical

surveys for the entire APE on the Lower McCloud River between McCloud dam and

Squaw Valley Creek. PG&E notes that mapped locations of culturally significant

populations of importance to the Pit River Tribe in this area were presented in appendix

D of the CR-S2 report, Traditional Cultural Properties, prepared in consultation with the

Pit River Tribe. PG&E states that mapped locations for culturally significant plants of

importance to the Winnemem Wintu Tribe will be similarly included in an appendix to

the TCP report prepared for the Winnemem Wintu Tribe after the study is complete.

Response: We have revised EIS sections 3.3.3.2.1, Vegetation, and 5.2.1, Discussion of

Key Issues, Terrestrial Resources, to support the Forest Service recommendation that

PG&E utilize native plants including culturally significant plants that are not associated

with TCPs for revegetation and erosion control efforts. Additionally, we clarify in the

EIS that the component for special status plant species (including culturally significant

plant species) of the Vegetation and Invasive Weed Management Plan would include

surveys to determine the presence of any new populations of special status species

including culturally significant plant species or newly listed special status species;

alternatively, these sites requiring protection could be displayed on an operations map as

areas to avoid, in order to prevent impact during management activities. In the EIS we

also clarify that the component for special status plant species of the Vegetation and

Invasive Weed Management Plan would also include populations of culturally significant

species not identified in association with TCPs for periodic monitoring. This comment is

addressed further under section 3.3.6, Cultural Resources.

Comment: PG&E states that the scope of its alternative condition 25 is not properly

characterized in the draft EIS (draft EIS p. 170). PG&E states that its alternative

condition 25 proposed limitations to the scope of Forest Service condition 25 so that it

would only apply to culturally significant species associated with TCPs; that is, areas
A-73

“that are currently utilized by tribal members to gather plants for traditional purposes and

that qualify for inclusion on the National Register of Historic Places as Historic

Properties.”

Additionally, PG&E states that text in the draft EIS does not accurately state PG&E’s

alternative condition regarding culturally significant populations and TCPs. The text

should read, “and limit invasive weed species to those on a list of high priority species,”

not special status species.

Response: In section 3.3.3.2.1, Vegetation, we clarify the text to accurately reflect the

scope of PG&E’s alternative condition 25 to “only apply to culturally significant species

associated with TCPs.” We have updated the EIS text in section 5.2.1, Discussion of Key

Issues, Terrestrial Resources, Vegetation and Invasive Weed Management Plan, to reflect

PG&E’s clarification regarding culturally significant plants and TCPs.

Comment: The Forest Service notes that there is pertinent language that is not included

in the Commission’s analysis. Specifically, the Forest Service recommends that the

Commission’s analysis state that there is a potential nexus between project operations

that have restricted flow and the creation of additional favorable riparian habitat along the

Lower McCloud River margins for black locust establishment downstream from Ah-DiNa, as documented in Technical Memorandum 65, which describes the colonization of

black locust in the riparian areas created by the project flow regime.

Response: We have updated our discussion in section 3.3.3.2.1, Vegetation, Noxious

Weeds, to indicate that there is a potential project nexus between decreases in base flow

and annual peak flow and increased black locust habitat, particularly in areas with high

percent cover of coarse material downstream of Ah-Di-Na.

Comment: The Forest Service clarifies that the 3-year annual monitoring schedule

following license acceptance does not apply to all high priority weeds but is meant to

create situational awareness of weed encroachment into Forest Service Sensitive and

culturally significant populations so that treatment can be scheduled promptly. In

addition, the Forest Service states that monitoring is required for 3 years following

ground-disturbing activities and a 5-year monitoring protocol is required to update the

original survey work (which includes the expanded APE from Ash Camp to Squaw

Valley Creek). The Forest Service agrees that annual monitoring of noxious weeds at

undisturbed sites is not necessary.

Response: We have updated our analysis in section 3.3.3.2.1, Vegetation, Noxious

Weeds, to specify that monitoring of known invasive plant species populations would

create situational awareness of weed encroachment into locations of existing special

status or culturally significant plant populations, determine if other adverse impacts are

occurring to these plant populations, and facilitate prompt scheduling of treatment as

necessary. Additionally, we have clarified that monitoring, inventory, and mapping of

areas of “high priority” noxious weed populations that remain undisturbed would
A-74

facilitate updates to original survey work, including in the area of the Commissionapproved APE (see section 3.3.6, Cultural Resources, for a description of the APE).

Comment: The Forest Service states that it is more accurate to say that there may be

some adverse effects to wildlife but they will be mitigated through implementation of the

Terrestrial Biological Management and Monitoring Plan, as opposed to stating that there

will be no adverse effects. This is because adverse effects depend on the species, and

timing and/or duration of the O&M activities. The Forest Service states that specific

O&M activities that may affect species must observe the limited operating periods and

have been defined in table B2-1 in the draft Road and Transportation Facility

Management Plan. Special status species that occur in the project should be protected

from further damage, especially specific endemic species (e.g., Shasta Salamander).

Thus, the Forest Service states that if relocation is possible for these species then it is

preferable so they will not incur direct mortality due to disturbance from project

activities.

Response: We have modified EIS section 3.3.3.2.2, Wildlife, General Wildlife, to clarify

that project O&M activities that may negatively affects terrestrial wildlife species that

occupy habitats within the project area as resident, transient, or migratory species would

be mitigated through the implementation of limited operating periods and other

monitoring and mitigation measures such as relocation. Furthermore, we add additional

clarification that implementation of the Terrestrial Biological Management Plan would

mitigate project-related effects on less mobile species that may not leave areas of

disturbance.

Comment: The Center for Water Advocacy recommends that the draft EIS address

potential impacts to terrestrial resources, including the need for roosting trees and open

corridors for wildlife regardless of the presence of critical migration routes. The Center

for Water Advocacy is concerned that the entire preventative measures provided

(monitoring plans) in the draft EIS are based on little more than inadequate preconstruction and non-existent future monitoring efforts. The Center for Water Advocacy

also believes that the due dates for the reports are untimely and do not allow for any

adaptive management or prevention or mitigation should there be disturbances to these

sites and species.

Response: Potential impacts as well as mitigation measures to address potential projectrelated impacts to wildlife, including special status species, are addressed in EIS

sections 3.3.3.2.2, Wildlife, 3.3.4, Threatened and Endangered Species, and 5.2,

Comprehensive Development and Recommended Alternative. These analyses are based

on extensive scientific assessments conducted by PG&E of terrestrial resources in the

project area. Requirements for monitoring and mitigation actions for wildlife and

associated reporting requirements will be included in the management plans that PG&E

will develop in consultation with the Forest Service, including the Aquatic Biological

Management Plan, Terrestrial Biological Management Plan, and Vegetation and Invasive

Weed Management Plan. As discussed in EIS section 3.3.3.2.1, Vegetation, revegetation
A-75

in disturbed areas as well as invasive weed control will help re-establish and maintain

habitat for wildlife species within the project area.

Comment: The Forest Service recommends that the Terrestrial Biological Management

Plan should be finalized within 1 year of license acceptance. The Forest Service is

currently working with PG&E on the draft Terrestrial Biological Management Plan and it

is substantially complete.

Response: We have modified our recommendation in section 5.2.1, Discussion of Key

Issues, Terrestrial Resources, regarding the development of the Terrestrial Biological

Management Plan such that the plan would be completed within 1 year of license

issuance, rather than the 2-year timeframe we recommended in the draft EIS.

Comment: The Forest Service agrees with the modification that PG&E should upgrade

segments of the existing transmission lines within 3 years of license issuance that are not

currently in compliance with APLIC guidance. If within 3 years, all lines are upgraded

and all new construction is compliant, an additional plan will not be required.

Response: We have updated EIS section 3.3.3.2.2, Wildlife, to reflect the requirements

of Forest Service modified condition 26. Modified condition 26 specifies that PG&E

should upgrade segments of the existing transmission lines that are not currently in

compliance with Avian Power Line Interaction Committee (APLIC) guidance within

3 years of license issuance; if, within 3 years, all lines are upgraded and all new

construction is compliant, an additional plan will not be required.

Comment: The Forest Service agrees with our recommendation in the draft EIS that preconstruction surveys in suitable habitat for the Shasta hesperian, Shasta chaparral, and

Shasta salamander would adequately identify the presence of these species before any

construction activities. The Forest Service clarifies that it also requires monitoring of the

known sites where these sensitive species are found 1 year after license acceptance and

every 5 years thereafter to determine population changes resulting from project activities

such as O&M. Additionally, new population surveys every 10 years would assist in

locating potential future populations of these species.

PG&E clarifies that, in regards to terrestrial mollusks, the draft EIS does not accurately

describe its alternative condition 26. The draft EIS states that PG&E proposes

monitoring of known populations every 5 years and pre-construction surveys in lieu of

monitoring for new populations in suitable habitat every 10 years, but PG&E states that

its alternative condition includes: (1) surveys of known populations every 5 years;

(2) surveys of other suitable habitat every 10 years; and (3) pre-construction surveys.

Response: We have clarified our analyses of terrestrial mollusk and amphibian

monitoring. Because of the presence and sensitivity of the Shasta hesperian and Shasta

chaparral and Shasta salamander, we have updated EIS section 3.3.3.2.2, Wildlife, Special

Status Wildlife Species, and our recommendations in EIS section 5.2.1, Discussion of Key

Issues, Terrestrial Resources, to state that surveys for known individuals of these species

should be conducted within 1 year of license acceptance and every 5 years thereafter, in
A-76

order to monitor any population changes that may result from project activities. We also

recommend surveys for new populations in suitable habitat within the first year of license

issuance and every 10 years thereafter.

We have also clarified our analysis of amphibian and reptile species monitoring to

specify implementation of surveys for known populations within 1 year of license

issuance and every 5 years thereafter, and surveys of suitable habitat within the first year

of license issuance and every 10 years thereafter, with adaptation of management to

include new species or populations that are detected. This monitoring plan would be

more protective of the Shasta salamander than the particular measures included in the

draft Terrestrial Biological Monitoring Plan.

Comment: PG&E notes that tailed frogs are associated with cold, rocky streams, not

freshwater emergent wetlands or reservoirs. PG&E notes that the Commission states that

the Forest Service commented on November 18, 2006, that the tailed frog is known to be

present in the McCloud reservoir based on unpublished data from a Forest Service

employee. PG&E states that it assumes this comment is referring to a tributary of the

McCloud reservoir or the watershed as a whole because tailed frogs are associated with

cold rocky streams, not reservoirs.

Response: We acknowledge that the tailed frog is typically associated with cold, rocky

streams and have noted the sighting of the tailed frog in McCloud reservoir, as observed

and reported by the Forest Service. We have not identified that this species has

established a presence in McCloud reservoir, which represents a habitat typically not

associated with the tailed frog, and we are not requiring mitigation for this species.

Comment: The Forest Service notes, and PG&E agrees, that in addition to the Shasta

salamander, the northwestern pond turtle is also a Forest Service sensitive species that

occurs within potentially proposed recreation construction sites near Pit 6 and Pit 7

reservoirs. In addition, the Forest Service states that pre-construction surveys and

relocation of individuals, in combination with monitoring known locations every 5 years,

and surveys every 10 years for potential future species locations should be specified for

the northwestern pond turtle.

PG&E states that, in respect to the northwestern pond turtle, its alternative condition

proposed monitoring: (1) unknown populations at Pit 6 and 7 reservoirs beginning the

first year after plan approval, and every fifth year thereafter; and (2) potential habitat in

McCloud and Iron Canyon reservoirs every 10 years. In addition to monitoring of the

northwestern pond turtle, PG&E will also conduct pre-construction surveys in areas of

suitable habitat that could potentially be affected by planned construction.

Response: We have included the northwestern pond turtle in our discussion in EIS

section 3.3.3.2.2, Special Status Wildlife Species, of potential effects to special status

amphibian and reptile species in proposed construction areas. In addition, we have

clarified in EIS section 5.2.1, Discussion of Key Issues, Terrestrial Resources, that preconstruction surveys should also be conducted for this species and that monitoring and
A-77

mitigation actions for these species would be included in the Aquatic Biological

Management Plan.

Comment: The Forest Service will move the surveys for the foothill yellow-legged frog

into the draft Aquatic Biological Monitoring Plan associated with its modified 4(e)

condition 27. These surveys will reveal any expansion of the habitat upstream on the

Lower McCloud River or the Pit River downstream from the known populations in the

Pit 4 reach.

The Forest Service states that the monitoring needs described for the foothill yellowlegged frog are unclear. The Forest Service notes that, with the increase in late spring

flows under the new flow regime, it is possible that other channel side margin habitat will

become more suitable for foothill yellow-legged frog. Thus, the Forest Service believes

it is important to periodically survey for foothill yellow-legged frog through the life of

the license in the Lower McCloud River. The Forest Service states that surveying every

5 years would be sufficient to determine if the species is expanding its habitat. The

Forest Service states that known populations should also be monitored to document the

effects of the flow regime on this species, and that pre-construction surveys and

relocation of individuals should be performed to provide additional protection. If the

population expands into the Pit 5 reach, it will likely continue to expand down to the Pit 6

reach. Thus, the Forest Service recommends the monitoring plan includes surveys

conducted into the upper Pit 6 reservoir reach if this occurs.

PG&E clarifies that its alternative condition 26 actually proposed that foothill yellowlegged frog surveys be conducted along the tributaries to Pit 6 and Pit 7 reservoirs but not

along the reservoirs themselves because these reservoirs do not provide suitable foothill

yellow-legged frog habitat; PG&E makes typographical corrections related to foothill

yellow-legged frog surveys (draft EIS p. 187). PG&E did not include surveys of NFS

lands on the Lower McCloud River because water temperatures at this location do not

consistently reach the threshold to initiate foothill yellow-legged frog breeding until

June—which is likely to be too late in the season for foothill yellow-legged frogs to

initiate breeding and then have sufficient time for larvae to successfully complete

metamorphosis by fall. PG&E notes that the Forest Service suggested that edgewater

temperatures need exceed 17°C to be potentially suitable for the foothill yellow-legged

frog, while edgewater temperatures in locations closest to Forest Service land never

exceeded 15°C.

American Whitewater and Friends of the River recommend that the Commission review

Technical Memorandum 9, which documented that the water temperature within side

channel sites where tadpoles were found were significantly warmer than the main

channel. American Whitewater and Friends of the River note that Technical

Memorandum 9 reports that temperatures were above 20°C at these sites while the main

river was 13.5 to 16°C, and that the foothill yellow-legged frog has historically been

found as far upstream as The Nature Conservancy lands.
A-78

Response: We have updated EIS section 3.3.3.2.2, Wildlife, Special Status Wildlife

Species, to note the inclusion of foothill yellow-legged frog monitoring, as part of Forest

Service modified condition 27, in the draft Aquatic Biological Management Plan. We

have clarified the EIS text to specify that PG&E alternative condition 26 proposed that

foothill yellow-legged frog surveys occur along the tributaries to Pit 6 and Pit 7 reservoirs

but excludes 5.4 miles of National Forest Service lands and the Pit 6 and Pit 7 reservoirs

themselves. We have also clarified our analysis of foothill yellow-legged frog

monitoring requirements to state that surveys along the NFS lands of the Lower McCloud

River would not be necessary because cold water temperature in the Lower McCloud

River and absence of appropriate habitat immediately surrounding the reservoirs would

preclude the presence of the foothill yellow-legged frog in those areas. In our

recommendations in section 5.2.1, Discussion of Key Issues, Terrestrial Resources, we

suggest that specific suitable habitat for the foothill yellow-legged frog in the project area

be surveyed the first year after plan approval and every 10 years thereafter, for the term

of the license.

Comment: The Forest Service states that the survey area for bald eagle should be

expanded to include additional monitoring along the Lower McCloud River in the event

that winter-run Chinook salmon are re-introduced to the McCloud drainage via the

NMFS plan to place salmon into Shasta Lake.

Response: We have revised our analysis in section 3.3.3.2.2, Wildlife, to note that a reevaluation of the geographic survey area and protocol for bald eagle, if salmon are reintroduced above McCloud dam would provide additional protection for this species.

Comment: PG&E clarifies that the bald eagle is a California-listed endangered species,

not a state-listed threatened species.

Response: We have updated EIS section 3.3.3.1.2, Wildlife, Special Status Wildlife

Species, Birds, to reflect this correction for the bald eagle’s state-protected status.

Comment: The Forest Service specifies that PG&E should annually survey known

peregrine falcon nest sites within the project APE to quantify the level of recovery of the

population in California and renew baseline studies on an annual, statewide basis—as is

recommended by the University of California Santa Cruz Predatory Bird Research

Group. The Forest Service will require PG&E to meet this standard to determine how

project O&M activities affect the recovery and population stability of the peregrine

falcon.

Response: We have revised our analysis in section 3.3.3.2.2, Wildlife, taking into

consideration the Forest Service’s revised condition 26 and draft Terrestrial Biological

Management Plan. In our recommendation, we recommend that surveys for peregrine

falcon would occur within 1 year of plan approval and every fifth year thereafter at

known nest sites and within suitable habitat, per our recommendation in the draft EIS,

rather than annually for known populations and within 1 year of plan approval and every

10 years thereafter in suitable habitat. We also note in our analysis that protocol for
A-79

peregrine falcon surveys would follow the University of California Santa Cruz Predatory

Bird Research Group guidelines.

Comment: The Forest Service will require that annual monitoring be implemented at

known locations for Forest Service sensitive bat species (pallid bat, Townsend’s big

eared bat, and western red bat). This will include monitoring of roost sites for 3 years

after disturbing activities to determine the project effects on population stability. The

Forest Service agrees with the change in the bat limited operating period to occur from

May 1 to August 31. The Forest Service states that pre-construction surveys will be

required in order to track the long-term occupancy of these species within projectaffected areas. The Forest Service has modified the 4(e) condition to reflect this.

Response: We have revised our analysis in section 3.3.3.2.2, Wildlife, taking into

consideration the Forest Service’s revised condition 26 and draft Terrestrial Biological

Management Plan. In our recommendation in EIS section 5.2.1, Discussion of Key

Issues, Terrestrial Resources, we recommend the inclusion of alternative language in the

Terrestrial Biological Management Plan clarifying that special status bat species surveys,

for both known populations and for new populations in suitable habitat, would begin

within the first year after plan approval and every fifth year thereafter. Additionally, the

limited operating period would be during the maternity period of May 1 to August 31,

rather than between May 1 and August 1.

Comment: PG&E notes that the staff alternative requirement to monitor bats “annually

for 5 years after plan approval, then once every 5 years” appears to be inconsistent with

the recommendation on p. 340, paragraph 2 to “begin within the first year after plan

approval and every fifth year thereafter,” which is PG&E’s preferred approach. PG&E

recommends the inclusion of alternative language in the Terrestrial Biological

Management Plan clarifying that special status bat species surveys would begin with the

first year after plan approval and every fifth year thereafter.

Response: We have made table 5-1 and section 5.2.1, Discussion of Key Issues,

Terrestrial Resources, Terrestrial Wildlife Management and Monitoring, consistent with

the staff recommendation that PG&E conduct surveys for special status bat species within

the first year after plan approval and then once every 5 years.

Comment: PG&E states that winter hibernacula were not observed at the locations listed

in the draft EIS (McCloud reservoir intake, McCloud dam diversion/outlet tunnel, Ah-DiNa campground old cellar building, and Iron Canyon reservoir overflow spillway), but

that rather, these locations represent sites at which winter hibernacula surveys were

conducted. Survey results did not indicate that bats use these sites as winter hibernacula.

PG&E notes that, although acoustic records indicated the presence of bats in the study

area during the winter, no project structures were identified as winter hibernacula.

Response: We have updated EIS section 3.3.3.1.2, Wildlife, General Wildlife, to clarify

that winter hibernacula surveys were conducted at McCloud reservoir intake, McCloud
A-80

dam diversion/outlet tunnel, Ah-Di-Na campground old cellar building, and Iron Canyon

reservoir overflow spillway, but no evidence of hibernacula was observed.

Comment: The Forest Service agrees that in addition to pre-construction surveys,

monitoring of known valley elderberry plant populations should occur concurrently with

the 5-year monitoring conducted as part of the Vegetation and Invasive Weed

Management Plan. The Forest Service has moved the monitoring component to the draft

Vegetation and Invasive Weed Management Plan and associated 4(e) condition 26.

Response: We have updated EIS section 3.3.4.2, Environmental Effects, Valley

Elderberry Longhorn Beetle, to state that Forest Service modified condition 26 specifies

that valley elderberry longhorn beetle (VELB) monitoring should also include preconstruction surveys and that monitoring for known valley elderberry plant populations

should occur concurrently with the 5-year monitoring conducted as part of the Vegetation

and Invasive Weed Management Plan.

Comment: PG&E states that two of the 15 populations of valley elderberry plants

documented were found along Oak Mountain Road, which is not included in the list of

locations described in the draft EIS.

Response: We have updated EIS section 3.3.3.1.1, Vegetation, Special Interest Plants,

to include Oak Mountain Road as one of the locations at which valley elderberry plants

were documented.

Comment: PG&E also provides a revised version of the VELB section of the draft EIS;

the largest change is the following added text: “After acceptance of a new license, PG&E

will consult with the U.S. Department of the Interior – Fish and Wildlife Service (FWS)

regarding the potential impacts of these activities on VELB habitat. Depending on the

nature of the proposed new construction, a VELB protection plan similar to the one

developed for Pit 3, 4, and 5 project may provide a suitable mechanism to protect VELB

habitat during new construction and when performing recreation facility O&M.”

Response: We have modified EIS section 3.3.4.2, Environmental Effects, Valley

Elderberry Longhorn Beetle, to be more consistent with the programmatic biological

opinion for the VELB and PG&E’s VELB Conservation Program, including the

recommendation that PG&E consult with FWS regarding the potential impacts of new

construction and routine O&M activity on VELB habitat.

Comment: American Whitewater and Friends of the River state that the conclusions of

the analysis of impacts to riparian vegetation misleads the reader into thinking that

operations have not changed riparian communities on the Lower McCloud River.

American Whitewater and Friends of the River state that there were many limitations to

the study and significant changes in the longitudinal and cross-sectional extent of riparian

vegetation due to project-related flow alterations are not discernable using the available

historical aerial photography.

PG&E notes in its reply comments filed on October 27, 2010, that the baseline for the

EIS is the existing conditions, and that consequently, FERC’s analysis of PG&E’s
A-81

riparian study (Technical Memorandum 65, Assess Potential Ongoing Project Effects on

Riparian Vegetation Community Types in the Project Area) presented at pages 152–153

in the draft EIS is correct and appropriate.

Response: We analyze the proposed project flows in relation to riparian vegetation and

related environmental effects in section 3.3.3.2.1, Vegetation, Riparian and Wetland

Vegetation. Our analysis reflects a consideration of the proposed actions as compared to

the no-action alternative, which represents the background conditions under the existing

project license.

Comment: PG&E notes that the decreased magnitude of annual peak flows affects white

alders at both higher and lower elevations, as per TM 65.

Response: We have made this clarification regarding the effect of annual peak flows on

white alders in EIS section 3.3.3.2.1, Vegetation, Riparian and Wetland Vegetation.

Comment: American Whitewater and Friends of the River express concerns about

potential project effects on the foothill yellow-legged frog, particularly at IBM transect-8

(near gage MC-5 at Shasta Lake), because this is a known foothill yellow-legged frog

breeding site. American Whitewater and Friends of the River state that a Forest Service

amphibian specialist has indicated that the appropriate ramping rate for the protection of

the foothill yellow-legged frog is 1 foot in 3 weeks on the descending limb of the

hydrograph. American Whitewater and Friends of the River believe that ramping rates

that exceed 1 foot in 3 weeks limit the success of the foothill yellow-legged frog on the

McCloud River and that ramping conditions off of spill events will only be marginally

protective of the foothill yellow-legged frog and other species.

In response to this comment from American Whitewater and Friends of the River, PG&E

notes in its reply comments filed on October 27, 2010, that the foothill yellow-legged

frog occurs about 18 miles downstream of McCloud dam, in a reach with accretion from

more than 12 unregulated major tributaries, and that the project influence on flow

recession in foothill yellow-legged frog habitat is significantly attenuated by natural

accretion in this area. Additionally, PG&E notes that, as discussed with relicensing

participants on May 20, 2009, the pattern of flow recession below McCloud dam during

spills approximates the recession rate seen above McCloud reservoir.

Response: As detailed in Technical Memorandum 9 and Technical Memorandum 29,

surveys of the foothill yellow-legged frog determined that this species is not present

within the geographical scope of the project, which includes the Lower McCloud River

downstream to the confluence of Squaw Valley Creek. The foothill yellow-legged frog

was not found upstream of RM 5.7, which is downstream of Squaw Valley Creek and

about 18 miles downstream of McCloud dam. As noted in the draft EIS, we have

recommended adoption of the Forest Service’s modified condition 27 which contains a

monitoring plan specific to the foothill yellow-legged frog and will facilitate

identification of any future expansion of the foothill yellow-legged frog into the

geographic scope of the project.
A-82

Additionally, as noted in the draft EIS, our recommended downramping rates at McCloud

dam during spills controllable by valve as well as the water quality and temperature

monitoring plan proposed in the staff alternative would limit the potential for stranding of

fish and macroinvertebrates. This also would provide an increased level of protection for

the foothill yellow-legged frog and balance the developmental values and additional

environmental values, including waterway development for beneficial public purposes.

Furthermore, we agree with PG&E’s analysis of the downramping suggested by

American Whitewater and Friends of the River (PG&E 2009a). Faster recession to base

flows during egg-laying is less likely to cause stranding or desiccation of egg masses than

slower recession. Implementation of the downramping suggested by American

Whitewater and Friends of the River, with gradual flow reduction from spring into

summer, would result in a period of unnaturally-prolonged higher flows during recession

from spills, and contrary to the expectation of such flows improving foothill yellowlegged frog habitat, they are actually expected to lead to less suitable conditions for the

foothill yellow-legged frog.

Comment: The Forest Service feels that the draft EIS discussion pertaining to pesticide

and herbicide use lacks analysis and specificity. The Forest Service suggests that, at a

minimum, the draft EIS should contain a general characterization of where

herbicide/pesticide use is minimally allowed. In addition, the Forest Service

recommends that the final EIS address the following additional topics: (1) locations

where the Commission considers the use of pesticides for complete removal of vegetation

as reasonable; (2) discussion of pesticide use, application techniques, and affected

vegetation guilds for right-of-way areas where selective vegetation removal is applied;

(3) discussion of the applicability of pesticides in the treatment of terrestrial and aquatic

invasive weeds, including a discussion on the appropriateness of aquatic pesticides for

use against specific aquatic invasive species; (4) discussion of areas where pesticide use

would not be appropriate (e.g., culturally significant plants, recreation sites, threatened

and endangered plant locations, adjacent to water); (5) discussion that identifies

mitigation measures, including BMPs and a toxicological/environmental or risk

assessment requirement for PG&E before any application. The Forest Service expects

some of this detail to be contained in the Vegetation and Invasive Weed Management

Plan and site-specific proposals to the Forest Service, as well as in the draft EIS.

Response: In its license application, PG&E notes that while herbicide use is a part of

project O&M for road and facility maintenance, applications are prescribed by a licensed

pest control advisor, and no pesticides are used as a part of project O&M. We

recommend additional parameters for incorporation into the guidelines in the Vegetation

and Invasive Weed Management Plan regarding the use of pesticides and herbicides

associated with future project O&M. Emphasis should be placed on the use of nonherbicide techniques, and allow for herbicide use, if any, only at specific sites; for these

sites, the plan should indicate why other techniques would not be effective. We

recommend in EIS section 5.2.1, Discussion of Key Issues, Terrestrial Resources, that the

Vegetation and Invasive Weed Management Plan include restrictions and prohibitions
A-83

regarding the use of pesticides and herbicides particularly near riparian areas, wetlands,

and areas containing special status or culturally significant plant species, due to the

sensitivity of these sites.

Although the EIS establishes a framework for development of the Vegetation and

Invasive Weed Management Plan, the plan would need to reflect goals and objectives that

have not yet been determined. Detailed weed management measures would depend on

site-specific conditions that are best addressed by local expertise during consultation for

plan development.

The EIS discusses parameters for use of herbicides near elderberry plants in

section 3.3.4.2, Environmental Effects, Valley Elderberry Longhorn Beetle.

THREATENED AND ENDANGERED SPECIES

Comment: The Forest Service notes that, although no individuals or active nests of

northern spotted owls were detected within the project area, a majority of the project and

project-affected area occurs in both suitable and designated northern spotted owl habitat.

In its comments on the draft EIS, the Forest Service states that formal consultation with

the FWS would provide the effects determination to the northern spotted owl and critical

habitat. Thus, the Forest Service defers to FWS for guidance and survey requirements.

Response: In our recommendation in section 5.2.1, Discussion of Key Issues, we note

that although no northern spotted owl individuals or active nests were detected within the

project area and project O&M or recreation activities are unlikely to affect this species, a

majority of the project and project-affected area occurs in both suitable and designated

northern spotted owl habitat. We recommend the inclusion of language in the Terrestrial

Biological Management Plan clarifying that, at a minimum, pre-construction surveys or a

limited operating period of February 1 through July 9 should be implemented for the

northern spotted owl, per our staff recommendation in the draft EIS. Additionally,

although the Forest Service commented that it would defer to formal consultation with

the FWS, in its draft Terrestrial Biological Management Plan submitted as an enclosure

to its modified 4(e) conditions, the Forest Service recommends only that PG&E follow

the FWS guidance for northern spotted owl surveys; we agree with this recommendation.

Comment: The Forest Service clarifies that a biological evaluation is prepared for

Forest Service sensitive species and a biological assessment is prepared for federally

threatened and endangered species.

Response: We have clarified this distinction between biological evaluations for Forest

Service sensitive species and biological assessments for federally threatened and

endangered species in EIS sections 3.3.4.2, Environmental Effects, 5.2.1, Discussion of

Key Issues, Threatened and Endangered Species, and table 5-1.

Comment: PG&E notes that it is appropriate for PG&E to provide plans and reports,

such as those prepared for special status wildlife species, to agencies for review and

comment, and that PG&E will address comments on plans and reports prior to submittal
A-84

to FERC. PG&E states that FERC should be the agency that approves any plans or

reports associated with the project license.

Response: The Commission will issue final approval of project-related reports on

special status species, specifically those that are Forest Service Sensitive, Survey and

Manage, Management Indicator Species, or on the Shasta-Trinity National Forest Watch

List. Prior to submission of plans and reports to the Commission, review and approval of

such reports by the Forest Service will help ensure that all concerns related to potential

impacts from project O&M activities are addressed.

RECREATION RESOURCES

Comment: American Whitewater and Friends of the River state that all of the flow

proposals that have been suggested will limit boating opportunity to the winter and early

spring.

Response: The Forest Service 4(e) flow conditions and staff recommendation in the EIS

are intended to enhance aquatic habitat conditions compared to current license conditions,

as well as, recreational opportunities. A key feature of several of the recommended flow

scenarios is the management of high flows during late winter and spring to more

effectively mimic the seasonal variation typical of the natural hydrograph of an

unregulated river. These peak flows are a necessary condition for natural maintenance of

channel morphology and substrate conditions associated with quality aquatic habitat.

Peak flows associated with seasonal weather patterns and significant runoff event can

also provide whitewater boating opportunities that may, however, be excessive for

comfortable or safe angler wading depending on when they occur. Our analysis and

recommendations are made based on review of the available scientific data and our

charge to balance the needs of occasionally conflicting users and resources, however,

under the staff recommendation there would be a few more whitewater boating flows

than what currently exist.

Comment: PG&E states that only the upper 9 miles of the 24-mile Lower McCloud

River reach between McCloud dam and Shasta Lake have land-based public access.

Response: The EIS has been revised, under section 3.3.5.1, Affected Environment,

Regional Recreation Resources, and section 3.3.5.1, Affected Environment, Project Area

Recreation Resources, Lower McCloud River and Hawkins Creek Crossing, to clarify

that only the upper 9 miles of the 24-mile Lower McCloud River reach between McCloud

dam and Shasta Lake have land-based public access.

Comment: The Forest Service notes that the Pit 3, 4, 5 Project addresses the recreation

development in the area where water from the James B. Black powerhouse tailrace passes

by the Pit 5 powerhouse. Thus, it is not included in the recreation 4(e) conditions for the

McCloud-Pit Project.

Response: We acknowledge that the area where water from the James B. Black

powerhouse tailrace passes by the Pit 5 powerhouse is not included in the Forest Service

recreation 4(e) conditions for the McCloud-Pit Project.
A-85

Comment: California Fisheries and Water states there are sufficient boating flows in the

regional areas such as above McCloud dam in the Upper McCloud River, in the upper Pit

River, and elsewhere.

American Whitewater and Friends of the River request that the Commission describe

other whitewater recreation opportunities, specifically any that are comparable to the 25

mile class III/IV wilderness run of the Lower McCloud River.

Response: Section 3.3.5.1, Affected Environment, Regional Recreation Resources, of the

EIS has been revised to describe other whitewater recreation opportunities in the region.

Comment: The Hearst Corporation states that there is a factual error in the draft EIS that

states, "The 1963 agreement between The Hearst Corporation and the Forest Service

allows the Forest Service to use and manage the Star City area located on Hearst

Corporation lands for public recreation use." The Hearst Corporation states that this is

incorrect in that no current lands belonging to The Hearst Corporation are available for

public use. The Hearst Corporation clarifies that the area addressed in the 1963

agreement is the area that was donated to the Forest Service and is currently the "day use

area" and recommends that this language be revised in the final EIS.

Response: The EIS has been revised, under section 3.3.5.1, Affected Environment,

Project Area Recreation Resources, McCloud Reservoir, section 3.3.5.1, Affected

Environment, Recreational Use, McCloud Reservoir, and section 3.3.5.2, Environmental

Effects, Recreation Management Plan, McCloud Reservoir Recreation Facilities, to

clarify the 1963 agreement, the use of the lands at Star City, and the relationship between

the Forest Service and The Hearst Corporation.

Comment: The Hearst Corporation states that the data supports implementing a

campground operating season. The Hearst Corporation believes that the operating season

of any campgrounds should be limited to April 1 through September 30.

Response: The proposed Recreation Management Plan would include O&M of all

project recreation areas, including annual schedules and standard protocols for opening

and closing recreation facilities, including primary season and shoulder seasons.

Section 3.3.5.2, Environmental Effects, Recreation Management Plan, McCloud

Reservoir Recreation Facilities, of the EIS has been revised to reflect this discussion.

Comment: The Hearst Corporation is concerned that the Forest Service proposal for the

addition of parking and a trail for access to the Red Banks area will endanger The Hearst

Corporation’s property rights and subject it to potential liability. The Hearst Corporation

states that its historical understanding regarding the Red Banks site was that public access

would be provided solely from the surface of the water.

Response: PG&E would be responsible for providing any recreation facilities included

in any license issued for the project and acquiring the rights necessary to operate those

facilities from any private landowners. PG&E proposes to cooperate with private

landowners to acquire rights of public access for the purpose of public recreational dayuse.
A-86

Comment: The Forest Service notes that, in addition to the base of McCloud dam, Ash

Camp and Ah-Di-Na Campground are the origin of whitewater boat trips on the McCloud

River. These sites are within the 4.5 miles of publically accessible Forest Service lands

along the Lower McCloud River below the dam and have been managed by the Forest

Service for the life of the current license to provide support facilities for these flowdependent uses. The Forest Service wants to emphasize that it is key that road access is

open and available so recreationists can access the project-released minimum instream

flows, especially in late spring, to participate in boating or fishing activities. The Forest

Service states that the Commission should recognize this necessity in the final EIS. The

Forest Service will be working with PG&E in the Settlement Agreement for Ah-Di-Na

Road to try to optimize this accessibility, since this road is not currently proposed as a

project road.

California Trout, Trout Unlimited, and the Northern California Council, Federation of Fly

Fishers agree with the Forest Service’s statements above regarding the sites within the

4.5 miles of publicly accessible Forest Service lands along the Lower McCloud River

below the dam. They recommend that the Commission, PG&E, and the Forest Service

determine how to optimize recreation opportunities for the road to Ah-Di-Na and Ash

Camp. California Trout, Trout Unlimited, and the Northern California Council,

Federation of Fly Fishers note that this could particularly help in relieving some of the

perceived differences between boater and angler flows by allowing access to boaters to

optimum boating flows that occur outside of the fishing season but are otherwise not

accessible due to road conditions.

Response: A discussion of recreational access to the Lower McCloud River has been

added to the final EIS in section 3.3.5.2, Environmental Effects, Recreational Access to

Lower McCloud River Flows, and section 5.2.1, Discussion of Key Issues, Recreation

Resources, Recreational Access to Lower McCloud River Flows, to address comments on

the draft EIS. We recommend that PG&E provide an access site at the base of McCloud

dam that would accommodate fishing and boating access at the Lower McCloud River.

Because PG&E would be providing access to the Lower McCloud River from the project,

it is not necessary for PG&E to also provide access to the Lower McCloud River outside

the project boundary at Ash Camp or Ah-Di-Na Campground. Ash Camp

(FR U38N11Y) and Ah-Di-Na (FR 38N53) roads provide access to these campgrounds

located outside the project boundary that are not used for project purposes; therefore, they

do not meet the Commission’s criteria for project roads. Accordingly, PG&E would not

be responsible for maintaining these roads, including snow plowing, under the project

license.

Comment: PG&E clarifies that its objective would be to prohibit vehicle access at

McCloud reservoir between the shoreline and the two roads along the reservoir

(FR 38N11 and 38N04Y) between Tarantula Gulch and Star City Creek, not to “prohibit

vehicle access at the McCloud reservoir between roads FR 38N11 and 38N04Y and the

shoreline, at Iron Canyon reservoir between FR 37N78 and the shoreline, and to prohibit
A-87

dispersed camping and OHV use between the roads and the shorelines” (draft EIS

p. 236).

Response: Section 3.3.5.2, Environmental Effects, Dispersed Use and OHV Use, and

section 5.2.1, Discussion of Key Issues, Dispersed Use and OHV Use, of the EIS has been

revised to clarify the objectives of PG&E’s proposal.

Comment: The Forest Service notes that camping use numbers would likely be higher at

McCloud reservoir and Pit 7 afterbay if developed camping facilities were available. The

Forest Service does not agree with PG&E’s characterization of the “roaming nature” of

visitors to areas around McCloud reservoir.

Response: Section 3.3.5.1, Affected Environment, Recreational Use, of the EIS has been

revised to discuss dispersed used at McCloud reservoir and Pit 7 afterbay instead of the

“roaming nature” of visitors.

Comment: The Forest Service clarifies that California Fish and Game currently stocks

the Upper McCloud River and that fish stocking is not proposed in the Lower McCloud

River below the uppermost project development.

Response: The EIS has been revised, under section 3.3.5.2, Environmental Effects, Fish

Stocking, and section 5.2.1, Discussion of Key Issues, Recreation Resources, Fish

Stocking, to clarify the fish stocking proposal and California Fish and Game 10(j)

recommendation.

Comment: The Forest Service clarifies that existing recreation development should be

reconstructed within 3 years of license acceptance and again at mid-license or 25 years,

whichever is greater. This requirement is because the Forest Service has concerns that

future rehabilitation and replacement “as needed” of existing recreational facilities may

have different interpretations.

Response: We have revised the EIS under section 3.3.5.2, Environmental Effects,

Recreation Management Plan, Recreation Facility Design Standard, section 5.2,

Comprehensive Development and Recommended Alternative, Recreation Resources,

section 5.2.1, Recreation Resources, Recreation Management Plan, to clarify the Forest

Service recommendation for reconstruction. Instead of requiring PG&E to reconstruct all

recreation facilities, regardless of their condition, at mid-license term or 25 years, we

have included a recommendation in section 5.2.1, Discussion of Key Issues, Recreation

Resources, Recreation Management Plan, of the EIS for PG&E to reevaluate the

facilities for degradation at mid-license term or within 25 years of license issuance,

whichever is greater, to ensure that facilities do not become degraded during the license

term.

Comment: The Forest Service will require a two-lane boat ramp with a 4-foot vertical

draft clearance consistent with the California Department of Boating and Waterways at

the Tarantula Gulch Boat Ramp to alleviate congestion during summer months.
A-88

Response: In the draft EIS, we recommended that PG&E reconstruct the Tarantula

Gulch boat ramp with the toe of the ramp extending to an elevation no less than 3 vertical

feet below minimum pool and that the boat ramp remain one lane. No new information

has been provided to change our recommendation in the final EIS for the Tarantula Gulch

Boat Ramp. As discussed in EIS section 3.3.5.2, Environmental Effects, PG&E has

indicated steep slopes constrain design options for providing an additional lane at the

boat ramp. The bottom of the boat ramp is currently 1 foot below the normal minimum

operating reservoir level and typically provides boater access during the entire recreation

season. Reconstructing the ramp, as proposed by PG&E, with the toe of the ramp to an

elevation not less than 3 vertical feet below minimum pool would extend the season for

launching boats.

Comment: The Forest Service clarifies that it has specified 30-40 total parking spaces,

not additional spaces, at Tarantula Gulch Boat Ramp.

PG&E comments that the Forest Service overestimates the parking capacity that can be

accommodated at Tarantula Gulch Boat Launch because there are extremely steep slopes

that prevent expanding the parking area without significant site modification (e.g.,

including, but not limited to, blasting and constructing retaining walls). PG&E’s states

that its preliminary site designs using a site survey with 1-foot contour intervals shows

that at most only about 20 vehicles with trailers and 5 single vehicles can be

accommodated at the site. PG&E reiterates its commitment to develop the site to its

maximum potential; however, it disagrees with specifying 30-40 spaces in any license

article because it does not believe this capacity can be possibly be achieved at the site.

Response: In the draft EIS, we recommended that PG&E construct additional parking

spaces at Tarantula Gulch boat ramp. The final EIS has been revised, under

section 3.3.5.2, Environmental Effects, McCloud Reservoir Recreation Facilities, and

section 5.2.1, Discussion of Key Issues, Recreation Resources, Recreation Management

Plan, McCloud Reservoir, to clarify the Forest Service’s original specification for the

number of parking spaces at the Tarantula Gulch Boat Ramp and to include additional

information from PG&E’s preliminary site designs regarding the number of vehicles that

can be accommodated; however, the Forest Service’s modified condition does not specify

a specific number of parking spaces. We have clarified our recommendation in the final

EIS to recommend that PG&E construct additional parking spaces at Tarantula Gulch

boat ramp as the site will allow.

Comment: The Forest Service notes that the final design and development of the

Tarantula Gulch boat ramp will depend on the need to accommodate an overnight

camping area in lieu of the preferred location at Star City Creek.

PG&E comments that PG&E and the Forest Service visited the Tarantula Gulch site on

May 12, 2010, to discuss a redesign of the Tarantula Boat Ramp area. At that time, the

Forest Service suggested the potential for a campground in the adjacent area. Because of

its small size and lack of developable area, PG&E believes that it is not reasonable to

consider a campground at Tarantula Gulch.
A-89

Response: The EIS has been revised, under section 3.3.5.2, Environmental Effects,

McCloud Reservoir Recreation Facilities, and section 5.2.1, Discussion of Key Issues,

Recreation Resources, Recreation Management Plan, McCloud Reservoir, to

acknowledge that if PG&E is unable to secure the use of the land at the Star City Creek

site, we would require a proposal for a similar recreation area that provides camping at

McCloud reservoir. Although we recommend a campground at McCloud reservoir, we

have not recommended a specific location for a campground. PG&E can file a plan with

the Commission for approval for a different campground location at McCloud reservoir at

that time.

Comment: PG&E states that in addressing specifications for reconstruction of Hawkins

Landing boat ramp surface (length and width) that the text should actually read: length

and width, but not grade. PG&E states that this should be consistent with the Forest

Service preliminary 4(e) condition to avoid misinterpretations.

Response: The EIS has been revised in section 5.2, Comprehensive Development and

Recommended Alternative, Discussion of Key Issues, Recreation Resources, Iron Canyon

Reservoir, to clarify the specifications for reconstruction of Hawkins Landing boat ramp

surface.

Comment: Multiple individuals noted that recreational access to McCloud River is

difficult in the winter due to snow.

California Trout, Trout Unlimited, and the Northern California Council, Federation of Fly

Fishers note that access to Ash Camp and Ah-Di-Na is not possible in some years due to

snow on the road. These groups state that public road access to Ash Camp and Ah-Di-Na

(weather permitting) for anglers, boaters, and other recreationists along the Lower

McCloud River is important so that project-released minimum instream flows are

accessible and state that the Commission should recognize this necessity in the final EIS.

California Trout, Trout Unlimited, and the Northern California Council, Federation of Fly

Fishers feel that this will help in relieving differences between boater and angler flows by

allowing access to boaters during optimum boating flows that occur outside of the fishing

season but are not accessible due to road conditions.

American Whitewater and Friends of the River recommend that PG&E be required to

provide snow removal when flows are above 300 cfs at the Ah-Di-Nah gage to allow for

boating access.

PG&E disagrees that it should be required to plow snow to provide vehicular access to

Ah-Di-Na Campground for whitewater boating access because of public safety concerns,

cost-effectiveness, and inconsistency with FERC’s project road determination. PG&E

states that, unlike Iron Canyon reservoir, it does not need to plow any roads at McCloud

reservoir for operational purposes. PG&E states it has no need to plow snow at McCloud

Reservoir. PG&E states that in the early spring, snow storms could suddenly make a

plowed road impassable and entrap visitors or prevent their access to parked vehicles.

Similarly, uncertain weather during the early spring creates a concern for responding to
A-90

boating-related emergencies that may occur. PG&E estimates plowing snow on the road

to Ah-Di-Na Campground would cost $62,000 per year. PG&E states that its study

results documented circumstances that present logistical challenges to boaters that would

likely affect demand.

Response: A discussion of recreational access to the Lower McCloud River has been

added to the final EIS in section 3.3.5.2, Environmental Effects, Recreational Access to

Lower McCloud River Flows, and section 5.2.1, Discussion of Key Issues, Recreation

Resources, Recreational Access to Lower McCloud River Flows, to address comments on

the draft EIS. We agree with PG&E’s comments regarding plowing and continue to

maintain the PG&E should not be required to plow the access roads to Ash Camp and

Ah-Di-Na Campground. As noted previously, Ash Camp (FR U38N11Y) and Ah-Di-Na

(FR 38N53) roads provide access to these campgrounds, which located outside the

project boundary and are not used for project purposes; therefore, they do not meet the

Commission’s criteria for project roads. Accordingly, PG&E would not be responsible

for maintaining these roads, including snow plowing, under the project license.

Comment: The Forest Service clarifies that its preliminary 4(e) condition reads that

provision of snow removal on the access road (from junction with 38N11) and parking

area will occur between April 1 and December 1—all seasons except winter. The Forest

Service will match the snow removal language for both McCloud reservoir and Iron

Canyon reservoir boat ramps. The Forest Service clarifies that PG&E proposes to

remove snow from portions of the Iron Canyon Loop road in addition to the Oak

Mountain Road in order to access the Iron Canyon dam, valve house, boat ramp and dayuse area—since these areas cannot be accessed solely by use of Oak Mountain Road.

PG&E comments that it proposes to continue plowing snow at Iron Canyon dam to

provide access for operational purposes. However, PG&E disagrees with the Forest

Service requirement to plow snow on roads leading to Tarantula Gulch Boat Launch at

McCloud Reservoir because it does not need winter access for project purposes and the

study results do not demonstrate a need for this measure.

Response: The EIS has been revised, under section 3.3.5.2, Environmental Effects,

McCloud Reservoir Recreation Facilities, section 3.3.5.2, Environmental Effects, Iron

Canyon Reservoir Recreation Facilities, section 5.2.1, Discussion of Key Issues,

Recreation Management Plan, McCloud Reservoir, and section 5.2.1, Discussion of Key

Issues, Recreation Management Plan, Iron Canyon Reservoir, to clarify the Forest

Service and PG&E proposals for snow removal at McCloud and Iron Canyon reservoirs.

Comment: The Forest Service acknowledges the option to move the development of a

day-use area with boating put-in and fishing access from the base of McCloud dam to the

Ash Camp Campground (1 mile below the dam at the Hawkins Creek confluence). The

Forest Service notes that the need to provide for LWD and coarse sediment augmentation

may make recreation use at the base of the dam infeasible due to safety concerns. The

Forest Service feels that Ash Camp site could be an improved location. The Forest

Service feels that further evaluation does not appear to support developments of a day-
A-91

use site at the Lower McCloud River due to safety and space considerations. Ash Camp

Campground appears to be a more suitable site and field review by Forest Service, and

the Forest Service notes that PG&E has confirmed this. Relocation of the McCloud Dam

day-use developments to Ash Camp places these facilities at an existing public recreation

site. The Forest Service notes that PG&E has agreed to take over management of Ash

Camp and Ah-Di-Na under a Settlement Agreement, as long as the facilities remain

outside of the license Boundary. The Forest Service has agreed to this arrangement only

if a signed Settlement Agreement or other binding agreement is in place prior to filing of

the final 4(e) conditions.

PG&E comments that it is premature to determine recreation development cannot be

accommodated at the base of McCloud dam because there is not enough certainty about

how and where gravel augmentation and LWD placement will be implemented. PG&E

comments that although there may be constraints, it would be preferable to locate

development at the base of the dam because it currently receives recreational use and it

would not diminish space that could be used for overnight camping when Ash Camp is

reconstructed. PG&E comments that it is still proposing to construct a powerhouse at the

base of the dam and it would prefer to retain an option to construct the development at

the base of the dam until the details of the various plans are known.

Response: It is still unclear as to whether the LWD and coarse sediment augmentation

may make recreation use at the base of McCloud dam infeasible due to safety concerns.

We continue to analyze access at the base of McCloud dam in the EIS as PG&E’s

proposal. However, if it is determined that this location is not feasible, PG&E can file a

plan with the Commission for approval of an alternative facility.

Ash Camp and Ah-Di-Na Campground are both Forest Service recreation facilities

located about 1 mile outside the project boundary and are not currently being used for

project purposes, nor do they provide access to the project lands or waters. Since we are

recommending that PG&E provide, at the project, an access site at the base of McCloud

dam that would accommodate fishing and boating access at the Lower McCloud River, it

is not necessary for PG&E to also provide access to the Lower McCloud River outside

the project boundary at Ash Camp or Ah-Di-Na Campground. We acknowledge that a

Settlement Agreement has been executed between PG&E and the Forest Service to

address Ash Camp and Ah-Di-Na campgrounds; however, facilities located outside of the

project boundary are not subject to Commission jurisdiction or the terms and conditions

of the project license.

Comment: PG&E states that the McCloud River Preserve is not used as a launch site by

boaters. Further, PG&E states that there is text in the draft EIS that implies that the

Pacific Crest Trail follows the river upstream of Ash Camp when it actually follows the

river to a point upstream of Ah-Di-Na Campground (draft EIS p. 203).

Response: Section 3.3.5.1, Affected Environment, Regional Recreation Resources, of the

EIS has been revised to clarify that the McCloud River Preserve is not used as a launch

site by boaters and the location of the Pacific Crest Trail.
A-92

Comment: Multiple individuals noted that access for disabled persons could be

improved.

Response: In section 3.3.5.2, Environmental Effects, Recreation Management Plan,

PG&E proposes to upgrade existing recreation facilities and construct new recreation

facilities in accordance with Forest Service Outdoor Recreation Accessibility Guidelines

(FSORAG) and the Americans with Disabilities Act. Improving access for the disabled

at the project would be consistent with the Commission’s policy on recreation facilities at

licensed projects under which licensees are expected to consider the needs of the disabled

in the design and construction of such facilities.

45 It also would help address growing

recreational demand at this project.

Comment: The Forest Service notes that it is difficult to distinguish the project nexus

with recreational fishing from recreational fishing access. The Forest Service also notes

that safe angling opportunities for the public occur on Forest Service lands along the

shoreline of the Lower McCloud River, specifically at Ash Camp, Ah-Di-Na, and the

river corridor between these facilities. The Forest Service notes that, although these sites

lack a project nexus, all three of these sites are directly related to, were created for, and

are strongly impacted by, project flow-based use as described in the draft EIS. These

sites currently provide the only public access to both boaters and anglers who have

commented extensively on the desire for suitable project flows that support their

recreational needs. The Forest Service notes that providing for “optimal” or “acceptable”

fishing and boating are project-controlled and the only means available to the

Commission to provide for this use is on public or project lands.

The Forest Service disagrees with PG&E’s stance that recreational improvements in areas

of access to the Lower McCloud River have no project nexus. The Forest Service states

that this opinion by PG&E is in direct conflict with the debate between anglers and

whitewater boaters, whose focus is recreational use and access to the Lower McCloud

River (specifically between Ash Camp and Ah-Di-Na Campground). The Forest Service

feels that it is a necessity to provide a legitimate trail that meets this need while

minimizing resource impacts.

Response: A discussion of recreational access to the Lower McCloud River has been

added to the final EIS in section 3.3.5.2, Environmental Effects, Recreational Access to

Lower McCloud River Flows, and section 5.2.1, Discussion of Key Issues, Recreation

Resources, Recreational Access to Lower McCloud River Flows, to address comments on

the draft EIS because this issue was not analyzed in the draft EIS. Except for the area

immediately below McCloud dam, no project lands are located along the Lower

McCloud River. Although we agree that flow regulation at McCloud dam affects

recreational opportunities, Ash Camp and Ah-Di-Na Campground and the trail that

connects them are not project facilities. We are recommending that PG&E provide, at the

45 See 18 CFR § 2.7 (2010).
A-93

project, an access site at the base of McCloud dam that would accommodate fishing and

boating access at the Lower McCloud River. Because PG&E would be providing access

to the Lower McCloud River from the project, it is not necessary for PG&E to also

provide access to the Lower McCloud River outside the project boundary at Ash Camp or

Ah-Di-Na Campground.

Comment: PG&E states that it will provide information on a public website about the

general range of McCloud and Iron Canyon reservoir elevations and whether the boat

launches are usable. PG&E notes that currently, real-time flow information at MC-1

(Ah-Di-Na) and MC-7 (above Shasta Lake) is (and will continue to be) provided to the

public via the California Data Exchange Center (CDEC) website.

California Trout, Trout Unlimited, and the Northern California Council, Federation of Fly

Fishers state that real-time flow data should be made available (on the internet) at MC-7

at McCloud dam.

American Whitewater and Friends of the River also support the inclusion of a

requirement in the new license conditions to post real time flow information for the AhDi-Nah gauge online.

Response: In the draft EIS, we recommended that PG&E provide real-time from MC-1

via PG&E’s website. Since MC-7 is a compliance point for the flows from McCloud

dam, the final EIS has been revised, under section 3.3.2.2, Environmental Effects, Flow

Monitoring and Determination of Water Year Type, section 3.3.5.2, Environmental

Effects, Provision of Streamflow Information, and section 5.2.1, Discussion of Key Issues,

Provision of Streamflow Information, to recommend that PG&E provide real-time flow

data at MC-7 in addition to MC-1 via PG&E’s website. Although visitors commonly use

the CDEC website to locate water-based recreation information, the Commission only

has authority over its licensees and cannot require the CDEC to post project information

on its website.

Comment: California Fisheries and Water state that the draft EIS does not disclose and

evaluate the effects to California licensed anglers and also California licensed disabled

anglers resulting from the specific daily 4(e) requirements by the Forest Service during

the angling season.

Response: As discussed in section 3.3.5.2, Environmental Effects, Recreation

Management Plan, Recreation Facility Design Standards, of the EIS, licensees are

expected to consider the needs of all recreation users, including the disabled, in the

design and construction of recreation facilities consistent with the Commission’s policy

on recreation facilities at licensed projects. Additionally, a discussion of recreational

access is included in the EIS in section 3.3.5.2, Environmental Effects, Recreational

Access to Lower McCloud River Flows, and section 5.2.1, Discussion of Key Issues,

Recreation Resources, Recreational Access to Lower McCloud River Flows.

Comment: PG&E states that neither it nor the Forest Service identified the need to

provide angling access to Iron Canyon Creek. PG&E states that additional angling access
A-94

is not necessary because there is already a road to the gauging station near the upstream

end of Iron Canyon Creek, which is where the public land is located. Additionally,

PG&E states that Iron Canyon Creek flows through private lands and all roads leading to

the land adjacent to the creek are gated by the private landowner to restrict public access.

The Forest Service notes that although the Commission recommends that PG&E file a

plan to enhance angling access to Iron Canyon Creek, field reviews do not indicate any

current use for angling, and the steep narrow nature of the canyon and private property do

not appear to invite use.

Response: In the draft EIS, we recommended that PG&E file a plan to enhance angling

access to Iron Canyon Creek in order to provide additional public benefit as a result of

the aquatic enhancement. In its September 27, 2010, letter, PG&E indicated that access

to Iron Canyon Creek currently exists via a road that accesses the gaging station near the

upstream end of the creek. Additionally, PG&E noted that much of Iron Canyon Creek

has exceedingly difficult terrain for access. Due to these circumstances, we no longer

recommend that PG&E file a plan to enhance angling access to Iron Canyon Creek. The

EIS has been revised in section 5.2.1, Discussion of Key Issues, Aquatic Resources, Iron

Canyon Creek Below Iron Canyon Dam, to reflect this staff recommendation.

Comment: The Forest Service agrees with the proposal to keep the Deadlun

Campground in the current location, and additionally proposes (and states that PG&E

agrees) that this facility would be redeveloped to provide for multi-family sites that can

accommodate larger groups. Development of the new Gap Creek Campground and

redevelopment of the Hawkins Landing Campground will focus on single-unit camping.

The Forest Service also proposed that at least one campground be available (without

water) year-round when the reservoir is accessible, to accommodate the off-season use.

Furthermore, the Forest Service states that one day-use site (paved parking, picnic tables,

restroom, and trash receptacle) and three shoreline access sites (paved parking and access

trail to the water surface) are also proposed around the perimeter of the Iron Canyon

reservoir.

Response: Subsequent to receipt of this comment dated September 24, 2010, the Forest

Service filed its modified conditions by letter dated November 29, 2010, which clarified

its modified 4(e) conditions. In the draft EIS, we recommended that PG&E reconstruct

Deadlun Campground in its existing location and provide access to the shoreline at this

site. The final EIS has been revised, under section 3.3.5.2, Environmental Effects, Iron

Canyon Reservoir Recreation Facilities, and section 5.2.1, Discussion of Key Issues,

Recreation Resources, Recreation Management Plan, Iron Canyon Reservoir, to analyze

the modified condition related to recreation at Iron Canyon reservoir. Reconstruction of

Deadlun Campground as a group campground at its existing location and the construction

of a new, single-site campground at Gap Creek on the main body of Iron Canyon

reservoir would provide more camping opportunities at the reservoir, improve facility

conditions, and increase capacity at the campground. In the final EIS, we recommend

PG&E reconstruct Deadlun Campground to provide double and triple campsites with
A-95

access to the shoreline and construct a new campground at the Gap Creek site for single

unit campsites.

Comment: The Forest Service suggests that development of an emergency egress route

from the surface of the Pit 6 reservoir at the dam would meet the current need for

providing public recreation access within safety constraints. The Forest Service notes

that boaters that may put into the Pit 5 reach on the overlapping Pit 3, 4, and 5 Project

would need a way out of the Pit 6 reservoir if they fail to take-out appropriately upstream.

The Forest Service states that development of a larger put-in/take-out above the Pit 7

dam, with access road and parking, should be possible and would direct use away from

the dam and intake facility. The Forest Service will provide additional specifics for this

in the final 4(e) conditions. The Forest Service states that an alternate egress point should

be located a few hundred yards downstream of both the Pit 6 dam put-in and a bedrock

constriction point, with slower flows that should allow egress even if Pit 6 powerhouse is

at full load. The Forest Service notes that development at Montgomery Creek does not

seem feasible due to access constraints. The Forest Service states that recreational

development on Pit 7 reservoir would be included in the schedules for survey and

monitoring under the Recreation Management and Monitoring Plan, and would include

fish stocking and survey data.

PG&E disagrees with providing proposed enhancements at the lower end of Pit 7

reservoir if Montgomery Creek is not feasible based on public safety, feasibility, and lack

of suitability.

PG&E states that, after review of public access options for Pit 6 and 7 reservoirs, it is

PG&E’s opinion that no safe access point was identified at Pit 6 reservoir. PG&E notes

that, at the Pit 7 Reservoir, an access point was identified just downstream of Pit 6 dam,

as well as at another potential location several miles downstream. However, in PG&E’s

opinion, no acceptable public access point was identified at the downstream end of the Pit

7 reservoir near the dam. In addition to the problems associated with public vehicular

access to the top of the dam, PG&E notes two additional complications: (1) an ordinance

prohibits boating within 500 feet of the dam; and (2) the reservoir elevation can be

35 feet below the high water mark, which would require boaters to scale the dam. PG&E

located and investigated potential road access on an abandoned construction access road

on September 19, 2010. Based on the suitability study results and subsequent

investigations, PG&E believes it has thoroughly investigated all potential options and

determined that it is not feasible to provide safe and secure public access to Pit 7

reservoir near the dam. Consequently, it is not appropriate to designate an access route to

the feature labeled “Pit 7 Lake Access” located near Pit 7 dam area shown in

attachment 2, figure 3, Pit 7 afterbay of the Forest Service comments on the draft EIS.

PG&E states that the Commission should disregard this feature.

PG&E comments that the Forest Service implies that an old construction access road can

be used to gain access to Pit 7 reservoir. PG&E conducted a site investigation with a civil

engineer and found that the grade on the section of the road up and over the ridge
A-96

extending about 0.25 mile exceeds 20 percent and there are no options for lessening the

grade because of the steep topography. In addition, PG&E states that the access road to

the top of the dam is only one lane wide and steep, and there is no place for the public to

park along the road or at the top of the dam.

American Whitewater and Friends of the River support the Commission’s

recommendation for the development of hand launch boating access at the Pit 7 reservoir

and request that they be consulted on any plans to provide access for non-motorized

boating.

Response: Subsequent to receipt of this comment dated September 24, 2010, the Forest

Service filed its modified conditions by letter dated November 29, 2010, which clarified

its modified 4(e) conditions. In the draft EIS, we analyzed but did not recommend

PG&E’s proposal and the Forest Service original 4(e) condition for a feasibility

assessment for a hand-launch boat put-in where Montgomery Creek enters Pit 7 reservoir

due to public safety concerns raised by PG&E about boating near the Pit 7 dam; however,

we did recommend a river access trail and parking at the upper end of Pit 7 reservoir and

a river access trail and parking at the lower end of Pit 7 reservoir. The final EIS has been

revised, under section 3.3.5.2, Environmental Effects, Pit 6 and 7 Reservoir Recreation

Facilities, and section 5.2.1, Discussion of Key Issues, Recreation Resources, Recreation

Management Plan, Pit 6 and 7 Reservoir Recreation Facilities, to analyze the modified

condition related to recreation at Pit 6 and Pit 7 reservoirs. In the final EIS, we continue

to recommend PG&E construct one river access trail with a parking area at the upper end

of Pit 7 reservoir but have revised our recommendation to recommend PG&E conduct a

site evaluation to determine a location, and provide a shoreline river access trail with

parking at the lower end of Pit 7 reservoir.

Comment: PG&E comments that in regards to Forest Service condition 30 calling for

PG&E to rehabilitate existing facilities, PG&E states that there are no existing facilities at

Pit 6 and 7 reservoirs; however, there is an existing Forest Service (non-project) car top

boat launch downstream of Pit 7 afterbay.

Response: The EIS has been revised, under section 3.3.5.2, Environmental Effects, Pit 6

and 7 Reservoir Recreation Facilities, section 3.3.5.2, Pit 7 Afterbay Recreation

Facilities, and section 5.2.1, Discussion of Key Issues, Recreation Management Plan, Pit

7 Afterbay Recreation Facilities, to clarify that there are no existing facilities at Pit 6 and

7 reservoirs; but there is an existing Forest Service (non-project) car top boat launch

downstream of Pit 7 afterbay.

Comment: PG&E clarifies that public vehicular traffic to the Pit 6 reservoir is available

by a gated road about 0.5 mi from Pit 6 dam. PG&E also clarifies that the dispersed

recreation site near Pit 6 dam is located about 0.5 mi downstream of the dam (draft EIS

p. 207).
A-97

Response: Section 3.3.5.1, Affected Environment, Project Area Recreation Resources,

Pit River, has been revised to clarify that public vehicular access to Pit 6 reservoir is

available by a gated road and the location of the dispersed recreation area near Pit 6 dam.

Comment: American Whitewater and Friends of the River support the Commission’s

recommendation for the development of hand launch boating access at the Pit 7 reservoir

and request that they be consulted on any plans to provide access for non-motorized

boating.

Response: We agree that consulting with American Whitewater and Friends of the River

on plans on related to boating access would better inform the development of public

access and the Recreation Plan. We have revised the EIS, under section 3.3.5.2,

Environmental Effects, Recreation Management Plan, and section 5.2.1, Discussion of

Key Issues, Recreation Management Plan, to include American Whitewater and Friends

of the River as parties to be consulted during the development of the Recreation

Management Plan.

Comment: The Forest Service proposes that PG&E and the Commission consider

removal of the afterbay dam and construction of an alternative structure to attenuate the

flows. The Forest Service states that altering this structure would improve the safety of

the project and allow for water-based access, including angling and boating at the

Fenders Flat site. The two day-use developments within the Fenders Flat area could be

combined if the afterbay dam and barbed wire were removed. The Forest Service states

that Fenders Flat site is one of the largest flat areas within the project, and the only likely

site for overnight camping on the Pit River portion of the project. By consolidating the

two proposed day-use developments within the Fenders Flat area, a day-use area,

campground, boat launch, and waterplay, whitewater boating and angling access could all

be provided with parking and support facilities.

Response: Please see our response regarding the safety issues at Pit 7 afterbay dam.

Comment: The Forest Service clarifies that, according to the Recreation Demand

Assessment RL-S1 (TM-37), angling is projected to increase by 243 percent, camping by

350 percent, boating by 438 percent, and viewing scenery/wildlife by 350 percent. The

Forest Service states that this illustrates the need for camping, angling, and boating

facilities on this project.

Response: The EIS has been revised in section 3.3.5.2, Environmental Effects,

Recreation Monitoring, section 3.3.5.2, Environmental Effects, Reservoir Water Surface

and Shoreline Management, and section 5.2.1, Discussion of Key Issues, Recreation

Management Plan, Recreation Monitoring, to reflect the results of the Recreation

Demand Assessment RL-S1 (Technical Memorandum 37). Our recommended recreation

facility enhancements would be adequate to support the need described in the Recreation

Demand Assessment RL-S1 and the final EIS.

Comment: The Forest Service clarifies that the Forest Service Law Enforcement

personnel from the Shasta-McCloud and National Recreation Area units of the Shasta-
A-98

Trinity National Forest are responsible for enforcing regulations related to the

management of Forest Service lands and resources as provided for in the CFR. The

Forest Service notes that these personnel do not have jurisdiction on the water surface of

the four reservoirs within the project. The Forest Service also notes that McCloud

reservoir serves mostly Siskiyou County users and is rarely, if ever, patrolled by Shasta

County.

The Hearst Corporation states that the pervasiveness of disbursed use and camping noted

in the draft EIS demonstrates the need for enforcement.

Response: The EIS has been revised, under section 3.3.5.2, Environmental Effects,

Project Patrol, and section 3.3.7.1, Affected Environment, Public Safety and Law

Enforcement, to clarify that the Forest Service is only responsible for enforcing

regulations on Forest Service lands and does not have jurisdiction on the water surface of

the project reservoirs. All existing project lands are within the jurisdiction of the Shasta

County Sheriff. The Shasta County Sheriff is responsible for public safety and law

enforcement on lands in the project area. The Shasta County Sheriff’s Boating Safety

Unit is responsible for boating safety enforcement on all waterways within Shasta

County, including McCloud reservoir.

Comment: The Forest Service states that it has nearly missed an opportunity to resolve

the known safety issues associated with the Pit 7 afterbay dam and V-notch weir. The

Forest Service states that flow changes can cause the V-notch weir portion of the afterbay

dam facility to go from exposed wing walls with flows confined to the V-notch, to the

entire V-notch weir and adjacent afterbay dam completely inundated and not visible to

boaters. In both cases, flows through and just downstream of the V-notch weir are

dangerous and create hydraulics, which have capsized boats and caused at least three

known drownings. The Forest Service notes that anglers regularly cut the fence to gain

access to this area, and states that PG&E has noted that maintenance at this site takes

place weekly, with no clear improvement of compliance. The Forest Service

recommends that the final EIS explore other alternatives to resolve this safety issue. One

alternative should include the removal of the existing afterbay dam facility and

reconstruction of the river channel between the Pit 7 dam and Fenders Flat, with an

alternate energy attenuator. The Forest Service notes that the removal of the Pit 7

afterbay facility would have the added benefit of allowing public use of the 1.5 mile

section of the Pit River from the Pit 7 dam to Fenders Flat, which has been fenced and

signed since project construction. Ms. Stacy Smith, representing the Forest Service, made

a public comment at the morning draft EIS meeting on September 9, 2010, that addressed

many of the aforementioned comments.

The California Water Board states that the draft EIS does not disclose the safety issues at

the Pit 7 afterbay dam, which creates a dangerous hydraulic condition that has caused the

death of fishermen accessing the site by boat from Shasta reservoir. The California

Water Board states that low/leakage through the dam results in pools below the dam that

hold fish, which creates an attractive but dangerous condition for fisherman and
A-99

recommends that this information be included in the final EIS and considered during the

development of recreational improvements.

California Trout, Trout Unlimited, and the Northern California Council, Federation of Fly

Fishers suggests that the Commission explore the removal of Pit 7 afterbay as an

alternative way to ameliorate the safety concerns. California Trout, Trout Unlimited, and

the Northern California Council, Federation of Fly Fishers states that this alternative

would also require the reconstruction of the river channel in this area.

American Whitewater and Friends of the River also recommends that FERC require

PG&E to remove the Pit 7 afterbay dam and reconstruct the river channel between the

Pit 7 dam and Shasta Lake due to the aforementioned safety concerns.

PG&E states that Pit 7 afterbay is a necessary public safety feature of the project—it

serves to attenuate the water flow from Pit 7 dam and powerhouse before entering Shasta

Lake. PG&E believes the suggestion by the Forest Service that Pit 7 afterbay dam should

be removed is ill-advised. PG&E states that removing the afterbay dam would increase

the hazard to recreational users in the area from flow fluctuations from Pit 7 dam, or

alternatively would require reoperation of the Pit River system as a run-of-the-river

operation, because Pit 7 reservoir does not provide sufficient storage to re-regulate all of

the flow from peaking operations upstream. PG&E states that this, in turn, would have a

significant adverse effect on the ability of PG&E to meet peak consumer power demand.

Mr. Steve Nevares, representing PG&E, also made a public comment at the morning draft

EIS meeting on September 9, 2010, that addressed many of the aforementioned

comments.

Response: As several commenters describe, the dangerous hydraulic conditions at the

Pit 7 afterbay dam create a public safety concern. As such, our Division of Dam Safety

and Inspections (D2SI) has been working with PG&E on ways to address this problem.

Given the need for immediate attention, D2SI will continue to work with PG&E and

others to resolve this serious concern. We have forwarded the information filed by

interested parties in this proceeding that are relevant to this issue to D2SI and revised the

EIS in section 3.3.5.2, Environmental Effects, Pit 7 Afterbay Recreation Facilities, to

reflect this.

Comment: The Forest Service supports stocking (with management responsibilities and

hatchery infrastructure to provide fish) by California Fish and Game with funds from

PG&E to stock the 60,000 pounds of fish. The Forest Service notes that this is contrary

to the Commission’s conclusion that PG&E will stock the fish themselves and develop a

plan to evaluate fish stocking every 6 years.

Response: To clarify, PG&E is ultimately responsible for the management of all project

reservoirs and project reaches and would be responsible for stocking trout annually

within the project boundary. PG&E could meet its responsibility by providing funding to

California Fish and Game if it chose to do so.
A-100

Comment: The Forest Service supports the Commission’s concurrence with the

California Fish and Game 10(j) recommendation that PG&E provide funding to increase

stocking levels of trout to meet recreational demands, and to provide funding for white

sturgeon mitigation.

Response: To further clarify, PG&E is ultimately responsible for the management of all

project reservoirs and project reaches and would be responsible for stocking trout

annually within the project boundary. PG&E could meet its responsibility by providing

funding to California Fish and Game if it chose to do so.

To clarify, we are not recommending funding for white sturgeon mitigation. As

discussed in section 5.2.1, Discussion of Key Issues, Recreation Resources, Fish

Stocking, given low natural recruitment and the problems associated with the previous

sturgeon planting program, it is not clear at this time how $5,000 would be used to

implement a mitigation program that would successfully maintain a white sturgeon

population in Shasta Lake. Furthermore, it also is not clear at this time how the $5,000

would be used to monitor and evaluate the fish stocking program and we have no way of

knowing if these funds would be used solely to evaluate the program at the project.

Comment: The Forest Service final 4(e) conditions will modify the following recreation

items discussed in the January 2010 preliminary 4(e) conditions: (1) the Forest Service

believes it will have an agreement with PG&E that three shoreline access areas are

appropriate, with specific locations to be defined later; (2) the Forest Service will drop

the wording that requires 155-day operability at the Hawkins landing boat ramp and

90 percent operable at the new Iron Canyon dam boat launch/day facility because these

requirements are addressed by the elevational requirements of the ramps; (3) although the

distance of the existing Deadlun Campground to the water is still a concern, there is an

agreement on a reasonable alternative that will include reconstruction of the existing

Deadlun Campground to provide for larger group use; and (4) construction of a new

campground at Gap Creek will provide for the identified need of individual family use

adjacent to project waters (i.e. Iron Canyon Reservoir)—this campground would include

standard Forest Service level 3 facilities (i.e., camping road spurs, vault toilets, campfire

rings, picnic tables, trash collection, host, etc.).

Response: Subsequent to receipt of this comment dated September 24, 2010, the Forest

Service filed its modified conditions by letter dated November 29, 2010 which clarified

its modified 4(e) conditions. The EIS has been revised, under section 3.3.5.2,

Environmental Effects, Iron Canyon Reservoir Recreation Facilities, and section 5.2.1,

Discussion of Key Issues, Recreation Resources, Recreation Management Plan, Iron

Canyon Reservoir, to analyze the modified conditions related to recreation at Iron

Canyon reservoir.

Comment: The Forest Service disagrees with the Commission that the duties of the

project patrol should be addressed by state and county agencies, and does not ask that

PG&E provide a law enforcement person. The Forest Service states that project patrol

contacts law enforcement if project patrol comes across a situation that requires legal
A-101

enforcement; the duties of the project patrol are to assure compliance with various

aspects of the license including protection of cultural resource and project facilities, and

public contact management.

The Pit River Tribe agrees with the above statement by the Forest Service.

The Hearst Corporation states that disbursed camping has been identified in relicensing

studies as creating resource damages. The Hearst Corporation feels that project patrols

and campground hosts would provide a step towards internalizing the externalities

resulting from the project; project patrols would encourage compliance and improve

safety.

Response: Although more visible patrol or law enforcement may help reduce conflicts

between recreation users and improve visitor safety, the state and county are responsible

for law enforcement activities at public recreation sites, including those within the project

area. Further, the Commission has no way of ensuring that the hiring of a patrol person

would actually accomplish a project purpose or ameliorate a project effect. There would

be no indication that existing recreation conflicts would be reduced through the proposed

measure; therefore, we continue to not recommend that PG&E provide a project patrol or

funding for a law enforcement position.

Comment: PG&E clarifies that the phrase “temporary bridges” refers to the fishing

bridges that the McCloud River Club installs for access to its privately owned fishing

trails along the river. PG&E notes that these bridges are located on private land and are

not project features.

Response: The EIS has been revised in section 2.2.3, Proposed Environmental

Measures, Aquatic Resources, to clarify that “temporary bridges” are located on private

lands and are not project facilities.

Comment: The Center for Water Advocacy suggests that analyses of McCloud River

Preserve, Iron Canyon Creek and Pit 6 and Pit 7 reservoirs should include the following

specifications: (1) all visitors should be asked to register when they arrive at the McCloud

River Preserve; and (2) each angler who fishes the preserve should record fishing data

(i.e., number of hours fished, size, species, and number of trout caught). In addition, the

Center for Water Advocacy recommends that angler and visitor use surveys under the

draft EIS should include: (1) total number of visitors who use the river for fishing;

(2) number of anglers reporting fishing results and what percentage of fisherman this

represents; (3) variations in reporting rate monthly, including which seasons contain the

lowest points; (4) monthly number of anglers, hikers, number of angler surveys

completed (with reporting rate), hours fished, and hours fished per angler; (5) total

number of anglers, hours fished, and hours fished per angler; (6) monthly numbers of

rainbow and brown trout caught; (7) total number and percentage of rainbow and brown

trout caught; (8) variations in susceptibility to capture of each species; (9) number and

species of fish caught by size class; (10) number of brown trout caught by size class; and

(11) catch rate (fish/hr) by month of rainbow, brown and all trout caught.
A-102

Response: The McCloud River Preserve is not located inside the project boundary and

not part of the McCloud-Pit Project. This preserve is located on private property

downstream of the project and does not serve a project purpose nor does it provide direct

access to the project.

Although the relicensing studies have been completed, recreation monitoring would be

conducted at the project concurrent with preparing information for the recreation Form 80

reporting (every 6 years). The recreation monitoring would include consultation with the

Forest Service, appropriate agencies, and interested parties to review and adjust projectwide recreation management objectives, if needed. Additionally, the annual Recreation

Management Plan meetings would be an appropriate venue to discuss additional

information needs at the project.

Comment: The Forest Service feels it should be clarified in the final EIS that blocking

of non-NFS routes will not eliminate all concerns associated with dispersed camping.

Response: The EIS has been modified, under section 3.3.5.2, Environmental Effects,

Dispersed Use and OHV Use, to clarify that closing non-NFS routes would not eliminate

all concerns associated with dispersed camping.

Comment: The Forest Service states that if agreement cannot be reached at the Star City

Creek site within 1 year of license acceptance, the Forest Service will specify that

overnight camping be accommodated along the Tarantula Gulch inlet. Due to the small

size of a limited area for recreational vehicle and/or tent camping at the area, the Forest

Service would not support a host occupying one of the limited spaces, should this

alternative be implemented.

Response: The EIS has been revised, under section 3.3.5.2, Environmental Effects,

McCloud Reservoir Recreation Facilities, and section 5.2.1, Discussion of Key Issues,

Recreation Resources, Recreation Management Plan, McCloud Reservoir, to

acknowledge that if PG&E is unable to secure the use of the land at the Star City Creek

site, we would require a proposal for a similar recreation area that provides camping at

McCloud reservoir. PG&E can file a plan with the Commission for approval for a

different campground location at McCloud reservoir at that time.

Comment: The Forest Service comments that if developed overnight camping is

provided at Star City Creek or Tarantula Gulch, the Forest Service will complete a Civil

Rights Impact Analysis and Forest Order to accompany the Commission’s final EIS

analysis and close the NFS lands around McCloud reservoir to dispersed camping. If

overnight facilities are not developed, the Forest Service will continue to allow dispersed

camping to accommodate the demand, with additional mitigations by PG&E that should

assist in addressing the current concerns at Star City Creek. The Forest Service

recommends that the final EIS provide additional analysis related to the closure of NFS

lands around Iron Canyon and McCloud reservoirs to dispersed camping.

The Hearst Corporation is concerned that the EIS does not make a recommendation

regarding The Hearst Corporation’s request that a “Forest Order” be issued to allow for
A-103

enforcement action and states that this is an important and basic measure which should be

dealt with during the licensing process.

Response: The EIS includes the analysis to meet the Commission’s purposes and to

allow us to recommend a formal campground at McCloud reservoir. If additional

analysis is needed for the Forest Service to issue a Forest Order, it is the responsibility of

the Forest Service to perform that analysis.

The Commission does not have authority over the Forest Service or NFS lands.

Comment: California Trout, Trout Unlimited, and the Northern California Council,

Federation of Fly Fishers comments that, given that the Forest Service lands provide the

only public access for anglers, boaters, and other recreationists along the Lower McCloud

River, it is important that road access is open and available so recreationists can access

the project released minimum instream flows, especially in late spring.

The Forest Service supports the development of an angling access route along the Lower

McCloud River between Ash Camp and Ah-Di-Na instead of access at Iron Canyon

Creek, where a user-created trail and angling pressure currently exists, and the Land and

Resource Management Plan supports development of a trail.

The Forest Service supports access for both angling and boating opportunities (and the

associated day-use and camping support facilities for these uses) and would support

Commission language specifying that road access (including snow plowing) and facilities

for both uses should be provided by PG&E such that each activity can occur when flows

are “optimal” for the use.

American Whitewater and Friends of the River comment that it is imperative that access

be provided to Ah-Di-Nah whenever boating flows are available. American Whitewater

and Friends of the River state that the Commission’s recommendation to only provide

put-in access for boating below McCloud dam will limit boating opportunity to only the

most skilled boaters; the upper segment is not suitable for the intermediate level boaters

and far less suitable for rafts. American Whitewater and Friends of the River state that,

in contrast, the run from Ah-Di-Nah provides an intermediate level trip suitable for

kayakers, rafters, and rafting based anglers, as well as disabled persons that have no other

way to see this river in its entirety. American Whitewater and Friends of the River state

that currently, the road to Ah-Di-Nah campground is often impassable due to snow

during this period and that it is unacceptable to relegate boating opportunity to this

particular season and not provide access.

Response: A discussion of recreational access to the Lower McCloud River has been

added to the final EIS in section 3.3.5.2, Environmental Effects, Recreational Access to

Lower McCloud River Flows, and section 5.2.1, Discussion of Key Issues, Recreation

Resources, Recreational Access to Lower McCloud River Flows, to address comments on

the draft EIS because this issue was not analyzed in the draft EIS. Except for the area

immediately below McCloud dam, no project lands are located along the Lower

McCloud River. Although we agree that flow regulation at McCloud dam affects
A-104

recreational opportunities, Ash Camp and Ah-Di-Na Campground and the trail that

connects them are not project facilities. We are recommending that PG&E provide, at the

project, an access site at the base of McCloud dam that would accommodate fishing and

boating access at the Lower McCloud River. Because PG&E would be providing access

to the Lower McCloud River from the project, it is not necessary for PG&E to also

provide access to the Lower McCloud River outside the project boundary at Ash Camp or

Ah-Di-Na Campgrounds.

Ash Camp (FR U38N11Y) and Ah-Di-Na (FR 38N53) roads provide access to these

campgrounds located outside the project boundary that are not used for project purposes,

therefore, they do not meet the Commission’s criteria for project roads. Therefore,

PG&E would not be responsible for maintaining these roads, including snow plowing,

under the project license.

Comment: The Hearst Corporation strongly disagrees with the conclusion that fire rings

would reduce the threat of wildland fire at Star City. Instead, The Hearst Corporation

recommends proper signage, information, and enforcement to prevent the use of open

campfires. The Hearst Corporation would also support the use of supervised cooking

grills as an alternative to fire rings.

Response: Fire rings in addition to the development of a Fire Prevention and Response

Plan that would increase preparedness of fire responders and minimize damage to natural

resources in the area, could greatly reduce the threat of wildfires. Cooking grills could

also meet the needs of overnight users at the proposed developed campground. Although

we have revised the EIS, under section 3.3.5.2, Environmental Effects, McCloud

Reservoir Recreation Facilities, and section 5.2.1, Discussion of Key Issues, Recreation

Resources, Recreation Management Plan, McCloud Reservoir, to not specifically

recommend fire rings at Star City, we acknowledge that including fire rings at Star City

could help reduce the threat of wildfires at Star City. The specific details of the Star City

campground facilities would be included in the proposed Recreation Management Plan

that would be developed in consultation with the Forest Service, California Fish and

Game, California Water Board, and other interested parties. We agree that proper

signage and information would also help reduce the threat of wildfire.

Comment: The Forest Service suggests that within 2 years of plan approval seems more

appropriate timeframe to construct recreation improvements (i.e., facilities), rather than

the 5 years that that Commission suggests.

PG&E comments that the time estimates to construct new facilities also include

significant design work and that the 5-year window cited in the draft EIS more accurately

captures these constraints.

Response: We maintain in section 3.3.5.2, Environmental Effects, Recreation

Management Plan, Recreation Facility Design Standards, that PG&E’s estimates for

construction of these facilities within 5 years of Commission approval of the plan are

reasonable due to the significant design work that is anticipated.
A-105

Comment: The Forest Service states that it and PG&E have collaboratively developed a

draft Recreation Development and Management Plan which will be filed with the final

4(e) conditions and that this draft plan should be finalized within 1 year after license

acceptance.

PG&E comments that after license application submittal, the Forest Service created its

own version of a Recreation Plan and invited PG&E to attend meetings and discuss the

content of its plan, but FERC should not interpret this interaction to mean that PG&E

agrees with the content of any plan submitted by the Forest Service. PG&E indicates that

it has not reviewed what the Forest Service has written in the plan that it is submitting

with its final 4(e) conditions.

Response: Subsequent to these comments, the Forest Service filed modified 4(e)

conditions on November 29, 2010, that included a draft Recreation Management Plan.

This plan and PG&E’s recreation proposals are analyzed in this final EIS and we note

that the draft Recreation Plan submitted with the modified 4(e) condition was considered

in the final EIS to be part of the Forest Service’s 4(e) conditions and not a joint Forest

Service-PG&E document.

CULTURAL RESOURCES

Comment: The Pit River Tribe supports the Forest Service’s comment that botanical

surveys have not yet been completed within the expanded APE for the Winnemem Wintu

Tribe along the Lower McCloud River. The Pit River Tribe notes that this information

will be necessary in order to identify culturally significant plants associated with TCPs

along this alignment and complete Study Plan CR-S2.

Response: PG&E has informed the Commission that a botanical survey was completed

within the APE. Data are still forthcoming from the Winnemem Wintu TCP study that

will identify culturally significant plants to the tribal members.46 These data will be

incorporated into the final HPMP with an amendment. Botanical surveys related to

culturally significant plants are addressed further under Terrestrial Resources.

Comment: The Forest Service clarifies that “Native American properties” should be

more appropriately referred to as “traditional cultural properties.”

The Pit River Tribe also notes that “Native American Properties” (as defined in the draft

EIS) should be identified as “Traditional Cultural Properties.”

Response: The Commission agrees, and where appropriate, will substitute the term

“traditional cultural properties” for “Native American Properties.”

46 On January 3, 2010, PG&E filed a revised appendix D associated with Study

Report CR-S2: Traditional Cultural Properties: Pit River Tribe.
A-106

Comment: The Forest Service clarifies that a limited site survey was conducted on NFS

lands, where a site (Site #10 – Old Bridge Site –F.S. 05-14-61-601) (P-45-003194) was

recorded.

Response: The EIS (table 3-32) recognizes this as a newly recorded site.

Comment: The Center for Water Advocacy states that the draft EIS fails to correctly

apply the National Historic Preservation Act (NHPA). For example, the Winnemem

Wintu Tribe representative could not participate in fieldwork because the crew allegedly

did not check with him to ensure that he did not have conflicts prior to scheduling the

fieldwork. The Center for Water Advocacy suggests that the APE be revised to address

impacts on cultural resources as identified by the Tribes including the Winnemem Wintu

Tribe. The Center for Water Advocacy feels that the license should not be granted until

the APE is changed as requested by the Winnemem Wintu Tribe.

Response: The APE was developed in consultation with the California State Historic

Preservation Office and was approved by the Commission in 2008. At this time, we find

no compelling reasons to expand the APE. However, as stated in the draft EIS,

section 3.3.6.2, Environmental Effects, Cultural Resource Management, Our Analysis, if

there is a future need expand the APE, the APE can be expanded according to the

mechanism provided in the Historical Properties Management Plan (section 5.15). The

final Programmatic Agreement (PA) would also allow for the final HPMP to be amended

and provides a dispute resolution process. Additionally, although the NHPA does not

specifically require the presence of tribal representatives during fieldwork, we find that

there remains ample opportunity for Winnemem Wintu Tribe representatives to continue

to participate in the identification and protection of cultural resources, as detailed in

section 5.71 of the HPMP.

Comment: Additionally, the Winnemem Wintu Tribe states that the Commission has

limited the scope of the APE without determining whether the project may impact

cultural sites outside of its proposed APE. The Tribe feels that the Commission has

improperly put off its duty to examine the potential impacts of its actions on the Tribe’s

cultural resources before they are approved, by allowing any management measures

related to the Tribe’s cultural resources be deferred to an amendment to the HPMP. For

example, the Tribe states that the draft EIS fails to examine any impacts posed by the

proposed McCloud reservoir powerhouse, increased recreational facilities and access, and

operations undertaken to mitigate other project impacts along the McCloud River, on the

Tribe’s TCPs and other cultural resources. In addition, without an adequate

understanding of the planned transmission route, powerhouse location and size, and

extent of additional ground-disturbing activities associated with its installation, the

Commission lacks the ability to determine that the powerhouse will have no unavoidable

impacts on cultural resources. The Tribe states that PG&E’s current route for the

transmission line has the potential to impact significant tribal resources, but that such

impacts are ignored in the draft EIS. The Tribe notes that ground disturbing activities

involving the construction phases associated with the new proposed facilities would have
A-107

the potential to directly affect archaeological sites and TCPs. The Tribe is not assured

that the Commission has made an informed decision regarding the project’s potential

impacts to cultural resources, and whether appropriate alternatives exist to mitigate or

avoid such impacts.

Response: The Commission approved the APE for the project in 2008, after considering

the scale and nature of the project and its potential for direct and indirect effects on

cultural resources. The APE was developed in consultation with the California State

Historic Preservation Office. No change is anticipated in its scope as we find that

consideration of these effects on identified resources has been adequately addressed in

the HPMP. We agree that the effects of the project on TCPs associated with the

Winnemem Wintu Tribe have yet to be so treated; however, section 5.2 of the HPMP

provides a mechanism for conducting additional field studies related future construction

activities such as the proposed transmission line and powerhouse, and appropriate

treatment measures can be amended to the final HPMP, that would in the future assure

that such resources are adequately protected. The APE may be modified as a result of

ongoing or future studies if we determine in the future that a historic property outside of

the current APE may be affected by the project. We also note, as previously stated, that

PG&E’s proposed McCloud powerhouse remains just a proposal. At this time the

Commission does not have enough information from PG&E to make a recommendation

regarding whether the proposed powerhouse should be included in any license issued for

the project.

Comment: The Forest Service notes that in the third paragraph, “Hoken” should be

spelled “Hokan.” In addition, the Forest Service does not support the description which

states the Winnemem Wintu and Pit River groups migrated from Asia.

The Pit River Tribe agrees with the aforementioned statement. They claim ties to the

100 square mile boundary since time immemorial, and request this to be noted in the draft

EIS.

Response: The spelling for “Hokan” and the text concerning the Tribes’ origins have

been amended in the EIS, in section 3.3.6.1, Affected Environment, Cultural History

Overview.

Comment: The Forest Service disagrees that 14 sites are located on lands that were

inaccessible during surveys. It states that access was provided to a site on NFS lands

(Site #10 – Old Bridge Site [F.S. 05-14-61-601] [P-45-003194]) and was subsequently

recorded. In addition, the Forest Service provided PG&E with a November, 2008

California State University Chico Foundation site record for the portion of this site on the

adjacent private lands.

The Pit River Tribe agrees with the Forest Service’s statement above.

Response: The HPMP lists 14 sites located on McCloud River Club land that were

inaccessible for study purposes. It also notes that a portion of the referenced site on

Shasta-Trinity National Forest lands was recorded as ALB-12 [FS 05-04-61-601]. The
A-108

portion on the McCloud River Club remained inaccessible. We have revised the number

of sites that were identified on lands that were inaccessible during field surveys, in EIS

section 3.3.6.1, Affected Environment, Identified Resources. The site located by Chico

State personnel in 2008 is included in the HPMP as ALB-12 [P-45-003194; FS05-04-61-

601].

Comment: The Forest Service recognizes 11 newly identified/recorded sites in the

project—in combination with 23 previously recorded sites, this brings the total to 34

sites.

Response: The Commission finds that there are nine newly identified sites within the

project APE and 24 previously recorded sites. However, two of the 24 were treated as

newly recorded (ALB-12[FS 05-04-61-601] and ALB-1[FS 05-04-61-600]) as they did

not receive state trinomial numbers when they were first identified. There is a total of 33

sites and 22 isolated finds. Thus, the cultural resource inventory as described in the EIS is

correct.

Comment: The Forest Service states that the Commission fails to note that the Forest

Service located a new site near the confluence of the Lower McCloud River and Squirrel

Creek.

Response: The cultural resources information in the EIS is based on the final HPMP

data. A site recorded after its publication may not be reflected in the cultural resources

inventory. The Forest Service would need to provide site data and report citations for

new sites located after 2009. The final HPMP also provides a provision where such new

data could be incorporated and addressed if necessary.

Comment: The Forest Service disagrees that there is only one potentially eligible site

currently affected by project operations, and concludes that there are as many as four

eligible or potentially eligible sites that are currently being adversely affected by project

operations (this number does not include the Iron Canyon Reservoir sites which are

project-affected, and may also be eligible). The Pit River Tribe also agrees with the

Forest Service’s above statements that there are as many as four eligible or potentially

eligible sites that are currently being adversely affected by project operations. This

number does not include the Iron Canyon Reservoir sites which are project-affected.

Response: The HPMP identified types of project-related effects for project area

archaeological and historic-era resources and provided analysis of potential effects on the

cultural resources within the APE. Fourteen sites were identified as having projectrelated effects. One of these is an eligible site and the remainder are undetermined in

terms of their National Register of Historic Places (National Register) eligibility. As

stated in the final HPMP, all sites that are being adversely affected by the project will be

evaluated for National Register eligibility within a year after license issuance.

Comment: Of the 34 archaeological sites, the Forest Service considers 2 eligible for the

National Register, and one potentially eligible (F.S. 05-14-61-33 [CA-SHA-33]) within
A-109

the Lower McCloud River area. Additional sites are also potentially eligible within the

Iron Canyon Reservoir area.

Response: The EIS identifies 2 sites as eligible in the McCloud River Area and noted

CA-SHA-688 (F.S. 05-14-61-33) as undetermined in its eligibility. The final EIS has

been revised to state this site is recommended as potentially eligible by the Forest

Service. No Iron Canyon sites were identified as eligible or potentially eligible in the

HPMP. Nevertheless, and as stated in the final HPMP, all sites that are being adversely

affected by the project will be evaluated for National Register eligibility with a year after

license issuance.

Comment: The Forest Service identified 17 (not 14) of the 34 sites that have projectrelated effects. The Pit River Tribe is very concerned that 17 (not 14) of the 34 sites have

project-related effects. The additional three sites that the Forest Service and Pit River

Tribe consider to have project-related effects are CA-SHA-246, CA-SHA-686, and

CA-SHA-687.

Response: We acknowledge the Forest Service and Pit River Tribe’s comments

regarding sites they identified as having project-related effects; however, we do not find

that those three sites are being affected by the project. In the October 2010 final HPMP,

PG&E identifies erosion at site CA-SHA-246 which it considers not to be project-related

due to the location of this site. PG&E also addresses recreation-related effects at sites

CA-SHA-686 and CA-SHA-687 that it considers not to be project-related due to a lack of

project nexus for these effects. Additionally, PG&E notes that it would address potential

management and mitigation actions for sites CA-SHA-686 and CA-SHA-687 under a

Settlement Agreement with the Forest Service, if PG&E were to assume responsibility

for management of Ah-Di-Na and Ash Camp Campgrounds. Finally, if additional sites

are identified or become adversely affected by the project, section 5.15 of the final HPMP

includes provisions to address such sites. As stated in EIS section 5.2, Comprehensive

Development and Recommended Alternative, we consider the October 2010 HPMP filed

by PG&E to be a final document and we agree with the findings contained in that

document regarding these three sites.

Comment: The Pit River tribe also agrees with the Forest Service that PG&E should not

wait to add a later amendment to the HPMP for Pit River Tribe TCPs.

Response: The HPMP has been finalized with the provision that an amendment(s) may

be made to treat new information that needs to be considered in project development.

Comment: The Winnemem Wintu Tribe states that the draft EIS fails to adequately

study the ongoing and future impacts of the project, including its impacts to the Tribe’s

cultural resources and the McCloud River’s aquatic resources. Since the Tribe’s historical

and traditional cultural sites may be eligible for inclusion in the National Register, the

Tribe states that the Commission must consider the impacts of the project on these sites.

Response: The HPMP, which is a management tool, has been finalized to move the

project forward with the recognition that new data will come forward that needs to be
A-110

considered in project development. The HPMP will be amended in those circumstances

and the receipt of the Winnemem Wintu Tribe TCP study is an important example of

such a circumstance.

Comment: The Forest Service clarifies that it considers the HPMP a draft document at

this time and feels there are further edits that need to be incorporated. For example, the

draft HPMP does not contain complete study results, fails to incorporate previous input

from the Forest Service, has not yet included formal consultation with Tribal

Governments, and does not include collaborative development of project-specific

mitigations based on study results and other necessary components. The Forest Service

notes that PG&E has not attended a meeting to discuss the HPMP in over a year, and that

when meetings were held, there were no collaborative discussions of development of sitespecific treatment measures as proposed in PG&E’s draft HPMP (table 6.1.0-1). The

Forest Service has requested PG&E to participate in meetings and provide

comments/feedback to the Forest Service and the Tribe, to discuss specific treatment

measures that can be taken to protect identified sites. PG&E has declined to attend (it has

not attended a meeting since July 2009).

The Forest Service further clarifies that the HPMP should be finalized and implemented

after license acceptance, and that the plan should be labeled as a draft document until

approved by the Forest Service, Tribes, and the Commission. The Forest Service original

condition 34 specifies that the final HPMP shall be completed within 1 year after license

issuance. This will be modified in the modified 4(e) conditions to license acceptance (not

issuance). This would give PG&E more time to have discussions regarding the proposed

treatment measures.

Response: The Commission directed PG&E to revise and finalize the HPMP by October

26, 2010, and PG&E complied with that directive. We consider the HPMP filed with the

Commission in October 2010 a final document. The final document addresses: the final

results of Study Report CR-S1, Archaeological and Historic-Era Properties; the final

results of Study Report CR-S2, Traditional Cultural Properties, undertaken in

consultation with the Pit River Tribe; USFS preliminary 4(e) conditions filed January 29,

2009, including comments on the July 2009 HPMP; comments on the July 2009 HPMP

received from the Pit River Tribe; Commission requirements for HPMP revision

provided in its July 30, 2010, draft EIS; and comments submitted to the Commission on

its draft EIS that relate to the HPMP. Additionally, PG&E recognizes that there may be

additional items raised by the Forest Service that may need to be addressed after license

issuance, and as a result, PG&E has added a provision in its final HPMP that such

investigations would be completed with 1 year of license issuance.

Finally, the final HPMP provides a process for additional amendments to be added to the

document, and any such new information provided by the Forest Service, Pit River Tribe,

or Winnemem Wintu Tribe can be accommodated in such a manner.

Comment: The Forest Service states that the Pit River Tribe portion of CR-S2 is

currently complete and should be integrated into the HPMP, regardless of the current
A-111

status of the Winnemem Wintu portion of the CR-S2. Otherwise the Commission reaches

conclusions that are based on an incorrect interpretation of the Forest Service’s 4(e) and

PG&E alternative license condition documents.

Response: It is our understanding that the final results of study report CR-S2,

Traditional Cultural Properties, undertaken in consultation with the Pit River Tribe, were

addressed in the final HPMP. PG&E has recently revised appendix D of study report

CR-S2, Traditional Cultural Properties, to correct information about culturally significant

plants and has submitted the revised appendix to the Pit River Tribe, State Historic

Preservation Officer (SHPO), Forest Service, and Commission. Data that stem from the

TCP study of the Winnemem Wintu Tribe, which was not completed in time for

incorporation into the final HPMP, would be handled in an amendment to that document.

Comment: The Forest Service provides the following measures that should be included

in the final HPMP (in addition to the four proposed by the Commission):

(1) Specific Forest Service comments on the draft HPMP as provided on page 92

of Enclosure 2 of the Forest Service’s original 4(e) conditions;

(2) A study/evaluation of whether there is compelling evidence for a historic

archaeological and ethnographic district on the Lower McCloud River within the

expanded project APE;

(3) Both studies (CR-S1 and CR-S2) for the Pit River Tribe ;

(4) Winnemem Wintu Tribe studies (CR-S2 and also CR-S1);

(5) Botanical surveys to identify culturally significant plants in the Lower

McCloud River; and

(6) A monitoring program with protection measures and/or management protocols

for project-affected sites on Forest Service lands.

The Pit River tribe supports the comments of the Forest Service, as noted above.

Response: While the HPMP has been finalized, the Commission recognizes that

additions may need to be made as more information becomes available. Such changes

can be handled via amendments and through the addition of appendices if needed.

Below, we discuss the six measures the Forest Service requested be included in the

HPMP

(1) The final HPMP has addressed Forest Service original 4(e) conditions filed

January 29, 2009, including comments on the July 2009 HPMP.

(2) The Commission considers the evaluation of cultural resources to be complete,

including district analysis.

(3) PG&E has integrated the final results of both study reports (CR-S1 and CR-S2)

into the final HPMP.
A-112

(4) The final results of the Winnemem Wintu Tribe study report on TCPs would

also be incorporated into the final HPMP as an amendment.

(5) PG&E has completed a botanical survey within the project APE and has

mapped out locations of culturally significant plants of importance to the Pit River

Tribe (appendix D, Traditional Cultural Properties, CR-S2). A revised appendix D

has recently been resubmitted to the Commission. An identical approach would

be taken for culturally significant plants of importance to the Winnemem Wintu

Tribe. When that study is complete, a similar appendix would be developed, and

along with the study’s final results, would be incorporated into the HPMP as an

amendment.

(6) Section 3.3.6.2, Environmental Effects, Cultural Resource Management, of the

final EIS provides a description of the proposed monitoring effort contained in

section 5.7 of the HPMP for project-affected sites on Forest Service lands as well

as other areas within the APE.

Comment: The Center for Water Advocacy recommends that the draft EIS should list

the specific tribes, such as the Winnemem Wintu, Pit River, and other tribes that will be

consulted in reference to cultural sites. The Center for Water Advocacy also feels that

PG&E should plan consultations with other requirements beyond section 106 of the

NHPA, such as the American Indian Religious Freedom Act.

Response: The EIS lists two tribes that were consulted in reference to cultural sites: the

Pit River Tribe and the Winnemem Wintu Tribe. Section 106 of the NHPA is the

relevant legislation as it requires federal agencies to consider the effects of their

undertakings on historic properties. The application of the section 106 process for

identifying TCPs of tribal significance effectively covers other sacred phenomena that are

cited in other relevant statutes protecting native cultural resources.

Comment: PG&E clarifies that that if erosion is found to be project-related on National

Register-eligible archaeological sites (instead of from natural high water flows), then

appropriate protection measures would be developed in consultation with the Pit River

Tribe and SHPO.

Response: The Commission agrees that appropriate protection measures would be

developed in consultation with the California SHPO and the Tribes to treat any project–

related effects on historic properties. This includes eligible TCPs associated with the

Winnemem Wintu Tribe once the study is completed and the results of the study are

incorporated as an amendment to the final HPMP.

Comment: The Winnemem Wintu Tribe is concerned regarding inappropriate disclosure

of the sensitive and confidential information contained within the TCP report and states

that PG&E does not respect this concern.

PG&E states that it has made numerous attempts to resolve the TCP confidentiality issue

with the Winnemem Wintu Tribe with no success, and that is why the Commission was

requested to help resolve the impasse.
A-113

Response: The Commission recognizes the Winnemem Tribe’s concerns on the

sensitivity of its tribal TCP information; however, in order to treat any effects from the

proposed undertaking on the TCPs, certain information is needed. When the final results

of the TCP study are provided to the Commission, the effects of the undertaking can be

fully understood. This would be handled in an amendment to the final HPMP.

As discussed in final EIS section 5.2.1, Discussion of Key Issues, Cultural Resources,

while the Commission itself is not the appropriate venue for resolving these issues, if

both parties feel facilitation could assist in resolving their dispute, we can refer the parties

to the Commission’s Dispute Resolution Service.

Comment: The Winnemem Wintu Tribe maintains that the Commission must have

access to an accurate and complete TCP report and must not make a final decision

regarding the appropriate alternatives and mitigation measures associated with this

project until the Tribe’s TCP report is complete and submitted to the Commission. The

Tribe states that the existing Project has already caused significant impacts to the Tribe’s

cultural resources. The Tribe states that by altering the natural flow of the McCloud

River, the Project has flooded lands traditionally used by the Tribe, and has altered the

nature of the McCloud River below the dam.

Response: As we state in final EIS section 5.2.1, Discussion of Key Issues, Cultural

Resources, PG&E’s final HPMP provides a process to incorporate the Winnemem Wintu

TCP study and to protect or resolve project-related adverse effects to any TCP that is

located within the project’s APE. Amendments to the final HPMP can also be used to

incorporate additional information and treatment measures for TCPs resulting from

additional studies when they are completed. This course of action allows for project

planning to move forward while providing a mechanism for the HPMP to be revised to

fully treat the resource inventory within the project area.

Comment: The Forest Service asserts that it must be a signatory to the PA along with

Commission and SHPO. The Forest Service states that it must be a signatory because:

(1) only land managing agencies, such as the Forest Service, have jurisdiction to

implement and enforce the Native American Graves Protection and Repatriation Act and

Archaeological Resources Protection Act; (2) the Forest Service has sole authority to

issue Archaeological Resources Protection Act permits to PG&E to conduct surveys or

excavation of archaeological properties located on NFS land; (3) the PA will cover

actions into the future that may include activities outside of the current project boundary

on NFS lands, where the Forest Service would require a special use permit; and

(4) decisions made by other parties on NFS lands may be counter to decisions the Forest

Service would have made in fulfilling responsibilities under various legal mandates.

In addition, the Forest Service requests that it be identified as a signatory on PAs

pertaining to projects that will be implemented on NFS lands for the following reasons:

(1) failure to identify the Forest Service as a signatory on PAs may jeopardize the

agency’s ability to comply with the NHPA and other statutory requirements pertaining to

NFS lands; (2) it is critical that the Forest Service makes decisions for actions that affect
A-114

NFS lands; (3) it would ensure the agency is involved with these decisions; (4) the Forest

Service has no authority to abdicate all its responsibilities to another federal agency; and

(5) assigning the Forest Service as a signatory member would not interfere with the

Commission’s ability to issue a license in a timely manner. The Forest Service also

requests the addition of a stipulation to the PA to cite Forest Service responsibilities for

issuing permits.

The Pit River Tribe requests that the Tribe be identified as a Signatory party rather than a

concurring party in the PA.

Response: While the Commission appreciates the Forest Service and the Pit River

Tribe’s desire to be signatories for the PA, the Commission has elected to proceed with

the PA as a two-party agreement between FERC and the California SHPO. The

Commission notes that section 106 does not require the lead federal agency (i.e., agency

official) to assign signatory status to any other involved parties to a PA, other than the

SHPO or Advisory Council on Historic Preservation (see 36 CFR Part 800.6[c][1][i-iii]).

Pursuant to the FPA, and in order for the Commission to issue hydropower licenses in a

timely manner, the Commission, as the agency official, chooses to execute all

hydropower PAs with either the SHPO, or with the SHPO and Council, when the Council

chooses to participate in a particular PA. Furthermore, the PA stipulates that Forest

Service has responsibilities for issuing permits under the Archaeological Resources

Protection Act, and that the final HPMP provides the requisite protocols for PG&E to

follow procedures involving the Archaeological Resources Protection Act and the Native

American Graves Protection and Repatriation Act, that, in turn, are governed by the

Forest Service on lands under its jurisdiction. Finally, executing the final PA between the

Commission and California SHPO in no way jeopardizes the Forest Service’s ability to

carry-out its obligations under the Archaeological Resources Protection Act, Native

American Graves Protection and Repatriation Act, or any other law that applies to its

land management responsibilities.

Comment: The Winnemem Wintu Tribe notes that its traditional cultural resources at

Star City Creek may be impacted by gravel excavation.

Response: On completion of the Traditional Cultural Properties Study, the possible

effect of gravel extraction on resources at Star City Creek can be assessed and a treatment

plan can be defined for inclusion in the HPMP.

LAND USE AND AESTHETIC RESOURCES

Comment: The Forest Service specifies that its concerns with road access relate to the

Hawkins Creek, Star City (FR 38N04Y) and Tarantula Gulch Boat Launch Roads near

McCloud reservoir and Iron Canyon Loop Road (FR 37N78) around Iron Canyon

reservoir.

The Forest Service clarifies that two (not three) additional road segments are proposed in

the plan: Hawkins Creek Road Segment 1 (FR 38N11) and Iron Canyon Loop Road

(FR 37N78). The Forest Service requests that the Commission review the project
A-115

infrastructure (existing and proposed) with the Technical Memorandum 22 results and the

Commission’s 2006 Policy Statement guidance. The Forest Service believes that these

two roads meet the Commissions policy criteria as “primarily” for project use. The

Forest Service clarifies that Hawkins Creek Road Segment 2 (FR 38N11) and the Ah-DiNa Road (FR 38N53) were not proposed as project roads. The Forest Service clarifies

that Oak Mountain Road does not provide access to Iron Canyon dam. The Forest

Service notes that there is no table 3-40 in the draft EIS (see draft EIS p. 355).

The Forest Service notes that five additional segments are proposed for inclusion within a

Memorandum of Understanding (MOU) that would be addressed outside of the project

license: Ash Camp (U38N11Y), Ah-Di-Na (FR 38N53), Hawkins Creek Segment 2

(FR38N11), Fenders Ferry (34N17), and the Reynolds Basin road to the Hogback lookout

turnoff (35N46).

Response: We have revised section 3.3.7.2, Environmental Effects, of the final EIS to

clarify that the Forest Service proposes to include two additional road segments in the

Road and Transportation Facilities Management Plan as project roads: Hawkins Creek

Road Segment 1 (FR 38N11) and Iron Canyon Loop Road (FR 37N78).

FR 38N11 (segment 1) provides access to private lands, including The McCloud River

Preserve, as well as National Forest destinations such as the Lower McCloud River, Bald

Mountain, Cabin Creek Trail, Pacific Crest Trail, 4WD trails, and interconnections with

other points south (e.g., Big Bend and Highway 299). Additionally, studies conducted

during relicensing conclude that 35 percent of the traffic on FR 38N11 is not related to

the project. Consistent with the Commission’s October 3, 2008, study plan determination

letter and based on information contained in Technical Memorandum 22, submitted as

part of PG&E’s license application, FR 38N11 does not meet the Commission’s criteria

for project roads used primarily for project purposes. Therefore, FR 38N11 is not

included in the list of project roads (table 3-34 in the draft EIS) that PG&E is responsible

for maintaining under the project license.

While the entire length of FR 37N78 is not necessary to access project infrastructure, a

0.7-mile section of FR 37N78 from FR 38N11 to Iron Canyon dam does meet the

Commission’s criteria for project roads (i.e. it is necessary for project purposes / access to

the dam). In section 5.2, Comprehensive Development and Recommended Alternative,

we propose to include this segment of FR37N78 within the project boundary.

We have also revised section 3.3.7.2, Environmental Effects, of the final EIS to clarify

that the Forest Service is not proposing Hawkins Creek Road Segment 2 (FR38N11) and

Ah-Di-Na Road (FR 38N53) as project roads.

We have revised section 3.3.7.2, Environmental Effects, of the final EIS to clarify that FR

37N34 (Oak Mountain Road) does not provide access to Iron Canyon dam. However, as

discussed above, a 0.7-mile section of FR 37N78 (Iron Canyon Loop) provides access to

Iron Canyon dam and should be included within the project boundary.
A-116

We have revised section 5.2.1, Discussion of Key Issues, of the final EIS to correct an

incorrect table reference. The reference to table 3-40 in this section should be table 3-41,

Project Roads.

We acknowledge that a MOU among PG&E, the Forest Service, and other interested

parties would address shared road (non-project) management responsibilities. However,

roads located outside of the project boundary are not subject to Commission jurisdiction

or the terms and conditions of the project license.

Comment: The Forest Service states that the final EIS needs to address roads that are

not currently in the NFS road system, but will be needed for project-associated

recreational or public use as a result of license implementation. Specifically, these

include: (1) Iron Canyon reservoir – road designation/development will be needed to

access 3 new shoreline access sites, one new day-use area, and one new campground;

(2) McCloud reservoir – road designation/development will be needed to access various

sites for proposed recreational facilities; (3) Pit 7 reservoir and afterbay – road

designation/development will be needed to access proposed recreational facilities.

Response: At this time, it is unclear what new recreation sites will be a requirement of

the new license and where these sites will be located. In the final EIS, we recommend

PG&E include all existing (at license issuance) project roads and recreation sites and

facilities within the project boundary and to file a revised exhibit G. We also recommend

PG&E file a revised exhibit G with the Commission subsequent to completing

construction of new project generation and transmission facilities or recreation sites and

facilities, to include any roads necessary for project purposes, which shall also be

included in the project boundary.

Comment: The Forest Service states that no further evaluation of closing of the access

roads at Iron Canyon Reservoir is needed. The Forest Service recommends that the

following direction be ordered in the license and included in the Road and Transportation

Facility Management Plan: “Following license acceptance, site-specific construction

designs and plans will be developed. At that time location shifts in specific road

development may be necessitated by topographic or other resource constraints. If so, all

applicable resource mitigations (i.e., implementation plan requirements) will be

employed for these locations and consultation with the Forest Service must occur for all

roads on or affecting NFS lands.”

The Forest Service recommends that the project-action of blocking roads be addressed in

the project-specific final EIS analysis in order to be implemented. The Forest Service

states that the best means to ensure these closure actions occur is for the Commission to

require the closure of these roads in the license order, and included as an activity in the

Road and Transportation Facility Management Plan.

The Forest Service specifies that actions to close roads include: (1) removing/pulling

culverts; (2) physically blocking the route with natural or man-made materials;

(3) ripping roads with mechanized equipment to encourage natural establishment of
A-117

native species vegetation; (4) restoration of drainage channels to normal topography to

allow for natural water drainage and prevent ponding; (5) re-contouring to conceal usercreated route; (6) out sloping to allow water to run off the entire surface and not

accumulate; (7) water bars, if necessary, to reduce erosion; (8) mulching of route surface;

(9) seeding or revegetation if needed; and (10) other similar measures.

Response: We agree that no further analysis of the closing of the access roads at Iron

Canyon reservoir is necessary. In the draft EIS, we analyzed the proposed Road and

Transportation Facilities Management Plan, but specific details about the siting and

design of roads, and actions to close roads were not included. We agree that these details

should be included in the plan filed with the Commission for approval.

Comment: PG&E disagrees with designating the following roads as project roads:

(1) Hawkins Creek Road (FR 38N11) extending from the Shasta-Trinity National Forest

boundary to Hawkins Crossing spoil pile; and (2) Iron Canyon Loop Road (FR 37N78)

extending from its northernmost intersection with FR 38N11 and proceeding west to Iron

Canyon dam. PG&E believes that the Forest Service misinterprets FERC’s project road

policy to request that several general NFS roads be designated project roads because they

are also the routes used to access project reservoirs and recreation areas.

PG&E notes that the Commission already determined that Segment 1 of Hawkins Creek

Road is not a project road.

PG&E notes that the segment of Iron Canyon Loop Road between Deadlun Campground

and the dam does not provide direct access to any existing or proposed project facilities.

PG&E also notes that Iron Canyon Loop Road is clearly a component of the larger NFS

road network that is used for multiple purposes, including timber harvest, access to

private property fire prevention and suppression, and public recreational use beyond the

project vicinity. PG&E agrees that Iron Canyon Loop Road extending from its

southernmost intersection with FR 38N11 and proceeding west to Iron Canyon dam

should be designated a project road.

PG&E agrees to consider the following non-project roads in an off-license agreement:

(1) FR38N53 (Ah-Di-Na Road) extending between FR 38Naa and end of the road (T37N,

R2W, Sec 5, NE 1⁄4, MDM); (2) FR U38N11Y extending between FR38N11 and end of

the road at Ash Camp; (3) FR 38N11 extending from the Hawkins Crossing spoil pile to

the west abutment of the Kosk Creek bridge; (4) FR 34N17 (Fenders Ferry Road)

extending from end of county road 6L005 (T34N, R1W, Sec 9, W 1⁄2, MDM) to 35N46

(Hogback Road); and (5) FR 35N46 (Reynolds Basin Road) extending from 34N17

(Fenders Ferry Road) to 35N93 (Hogback Mountain).

PG&E also reminds the Commission of comments on the Forest Service original 4(e)

conditions from The Hearst Corporation, owner of most of the road segments, filed a

letter with the Commission on March 16, 2010, which states:

[The USFS] proposes to reclassify our road system around the south end of the lake as

“project roads” that would be included into the project area. All reconstruction and
A-118

replacement of facilities would be to a very high USFS recreational standard that is not

needed for our land management use. The issue of concern is that we own the roads and

currently have existing construction and easement agreements with PG&E and USFS for

maintenance and use on these roads. We support the concept presented by the USFS of

working with PG&E and USFS, outside of the licensing process, to develop a

comprehensive road use agreement – if needed. We do not support the proposed

expansion of the project boundary to the outside edge of the road system.

Response: We have revised section 3.3.7.2, Environmental Effects, of the final EIS to

clarify that no portions of FR 38N11 (Hawkins Creek Road) meet the Commission’s

criteria for project roads, and that a 0.7-mile portion of FR 37N78 from Hawkins Creek

Road to Iron Canyon dam is necessary for project purposes and, therefore, is considered a

project road.

We acknowledge that a MOU among PG&E, the Forest Service, and other interested

parties would address shared road (non-project) management responsibilities.

Comment: The Forest Service provided the Record of Decision and final EIS for

“Motorized Travel Management” and requested that FERC add this document to the list

of comprehensive plans for the McCloud-Pit Project in the final EIS.

Response: The review of the Forest Service’s September 24, 2010, request that the

Record of Decision and final EIS for “Motorized Travel Management” to be considered a

comprehensive plan under section 10(a)(2)(A) of the FPA is pending at the Commission.

Comment: The Forest Service clarifies that Tarantula Gulch Boat Ramp is currently

within the project boundary and a small boundary adjustment at Deadlun Campground

would place the entirety of that facility within the project boundary. The Forest Service

notes that the project boundary crosses over the Star City Creek Road (38N04Y) in

several locations and that only portions of the road currently fall within the project

boundary, not the entire road between McCloud dam and Star City Creek as was

indicated. In addition, the access road to the proposed Red Banks day-use area is not

currently included in the project boundary.

The Forest Service supports the Commission’s inclusion of new recreation sites in the

FERC project boundary; however the Commission’s language does not specify when a

revised Exhibit G would include these new facilities. The Forest Service feels that the

draft EIS inadvertently omits some proposed and existing facilities from the project

boundary, or does not require they be included in the project boundary prior to ground

disturbing activities.

The Forest Service states it is best to have all proposed project-related actions authorized

by the license order and included within the project boundary. In the cases where the

exact location of a facility is unknown, the Forest Service states that Commission cannot

include the proposed facility within the project boundary, and that once the location is

known, the best action is for PG&E to request a license amendment to include the

proposed facility within the boundary prior to any commencement of ground disturbance.
A-119

The amended license order will thus be the authorizing instrument, and there will be no

need for the Forest Service to issue a Special Use Permit and complete a separate NEPA

analysis. The Forest Service supports amending the project boundary closer to the time

of activities that would expand the boundary, as long as that amendment(s) occurred prior

to ground-disturbing activity.

The Forest Service states that because the license can only be used to authorize facilities

and areas designated by the license and included within the project boundary, if an area

or facility is not included within the project boundary and/or is not designated as a project

facility, the Forest Service must issue a Special Use Permit to authorize the remaining

occupancy.

The Hearst Corporation does not agree with the recommendation of expanding the project

boundary between the reservoir and the outside right-of-way of FR 38N11 and FRN047

to ensure all new project recreation facilities are included within the project boundary.

Hearst states that this expansion is broader than necessary to achieve its goals.

PG&E clarifies that Tarantula Gulch boat launch at McCloud reservoir is owned and

operated by the Forest Service. PG&E restates its preference to include the facilities (i.e.,

Deadlun Campground and Tarantula Gulch boat ramp) in the project boundary when they

are reconstructed. However, if the Commission requires PG&E to include these facilities

in the project boundary as part of a new license, PG&E requests that FERC incorporate

language about a grace period into any license article stating that until the facilities are

reconstructed, PG&E will not be held in non-compliance because of the condition of the

project recreation facilities.

PG&E will provide a revised Exhibit G (not E as stated in the draft EIS) to include the

footprint of any new recreation site and facility within the project boundary, as well as

any land necessary for access.

Response: The Forest Serviced filed modified 4(e) conditions with the Commission on

November 29, 2010. In modified condition 30, the Forest Service specifies that project

recreation facilities will be included inside the project boundary, prior to ground

disturbing activities. The Forest Service specifies that project boundary adjustments are

made at the point when the Recreation Development and Management Plan is approved

by the Commission, in order that development of the facility is appropriately within the

Commission’s jurisdiction, and a separate Forest Service Special Use Permit is not

required in order to proceed with development within the timeframes approved in the

Recreation Development Management Plan.

In the final EIS, we recommend PG&E include all existing (at license issuance) project

roads and recreation sites and facilities within the project boundary and to file a revised

exhibit G. We also recommend PG&E file a revised exhibit G with the Commission

subsequent to completing construction of new project generating and transmission

facilities or recreation sites and facilities, to include any roads necessary for project

purposes, which shall also be included in the project boundary.
A-120

The project boundary description in section 3.3.7.1, Affected Environment, Land Use

Resources, Project Boundary, includes the existing Tarantula Gulch day-use area and

boat launch and the existing Deadlun as currently within the project boundary. It is

unclear if only portions of these sites are included in the existing project boundary. In

section 3.3.5.2, Environmental Effects, Recreation Facility Operation and Maintenance,

we propose including both of these sites in their entirety within the project boundary at

license issuance, if they are not already.

We revised section 3.3.7.2, Environmental Effects, Land Use Resources, Project

Boundary, Our Analysis, of the final EIS to clarify that the project boundary would be

expanded between McCloud reservoir and the outside right-of-way of FR 38N11

(Hawkins Creek Road) and FR 38N047 (Star City Road) to include only the outermost

limits of any new recreation site (i.e., only the area serving project purposes).

We have revised section 3.3.7.2, Environmental Effects, Land Use Resources, Project

Boundary, Our Analysis, of the final EIS to correct an inaccurate reference to exhibit E.

The correct reference is to exhibit G.

Comment: The Forest Service supports FERC in the clarification that only those private

lands within the project boundary would be subject to access as a result of this license.

The Forest Service notes that access to private lands outside of the project boundary is

subject to the discretion of the landowner.

Response: Lands and facilities outside the project boundary are not subject to

Commission jurisdiction or the terms and conditions of the project license.

Comment: The Forest Service notes that the Commission’s assumption that its facilities

predated the Forest Service’s establishment of Forest Service Visual Quality Objectives

(VQOs) for this area is incorrect. The Forest Service states that the Shasta-Trinity Land

and Resources Management Plan does not address power generation and associated

facilities and also that the PG&E facilities are inconsistent with the Retention VQO as per

the definition of Retention within the Visual Management System. The Forest Service

recognizes that on a project-specific scale these facilities are more appropriately

classified as Modification VQO (i.e., man’s activity may dominate the characteristic

landscape but must at the same time utilize natural established form, line, color and

texture). It is the opinion of the Forest Service that this better meets the needs of the

existing and proposed hydroelectric and other project-related facilities. The Forest

Service states that any future management activities within sight distance of the

McCloud-Pit Project-related facilities would need to be in compliance with this

Modification VQO. In addition, the Forest Service states that the Aesthetic Resources

Assessment (AR-S1) did not focus on opportunities to help facilities meet scenic

objectives, and this would be the focus of the proposed Visual Quality Management

Objectives. Finally, the Forest Service states that its final 4(e) conditions will apply

mitigation measures to all project-related facilities (not just the new facilities as

suggested by the Commission).
A-121

The Forest Service states that there is an inaccurate assumption for project level NEPA

analysis. The Aesthetic Resources Assessment (AR-S1) did not focus on opportunities to

help facilities meet scenic objectives; this would be the focus of the proposed Visual

Quality Management Objectives, to be filed with the Forest Service’s 4(e) conditions.

Response: Studies conducted during relicensing did not identify any needed

modifications to existing project facilities for visual quality purposes. Further, PG&E is

not proposing any changes to the visual character of the existing Iron Canyon, Pit 6 and 7

dams, roads, intakes, penstocks, recreational facilities and transmission lines, so these

facilities would continue as they appear today. PG&E does propose to construct a new

powerhouse at the base of McCloud dam, a switchyard, transmission line, and office. We

agree that the development and construction of these new project facilities should meet

any applicable Forest Service VQOs.

The Forest Service filed modified 4(e) conditions with the Commission on November 29,

2010. Modified condition 32 specifies the development of tasks and a timeline to assure

implementation of specific mitigation measures to improve the visual quality of project

and project-affected NFS lands. Modified condition 32 is similar to condition 32, except

that the Forest Service includes a draft document as an enclosure to the filing, which

identifies specific mitigation actions.

In the November 29, 2010, filing, the Forest Service also clarifies that the current ShastaTrinity Land and Resources Management Plan (1995) identifies two VQOs for lands

within the project area. The final EIS summarizes (table 3-42) the VQO designations by

general project area as either Retention or Partial Retention. The Forest Service discusses

project facilities as most appropriately meeting the definition of Modification. The

Forest Service plans to make this change to the Land and Resource Management Plan

during a future scenery analysis and evaluation and subsequently revise the Land and

Resource Management Plan. We have revised section 3.3.7.1, Affected Environment, and

section 3.3.7.2, Environmental Effects, of the final EIS to clarify the applicable VQO

designations in the project area and the Forest Service’s intent to revise the Land and

Resource Management Plan.

In the November 29, 2010, filing, the Forest Service also clarifies that existing facilities

in good repair would only have mitigations applied as maintenance is needed.

We agree that this approach for mitigating impacts to aesthetic resources in the project

area is reasonable. In the final EIS, we recommend that PG&E file visual quality

management tasks and a timeline within 1 year of license issuance for Commission

approval.

Comment: The Forest Service states that draft EIS p. 284, paragraph four, contains

several inaccuracies regarding the current status of roads and spoil piles on the project.

Contrary to PG&E statements, road spoil piles do occur on Forest Service lands along

road alignments noted in the Commission’s listing of roads, and on Forest Service lands

near project infrastructure.
A-122

The Forest Service misunderstands PG&E’s statements that there are no tunnel spoil piles

on or affecting NFS lands to mean there are no road spoil piles. PG&E acknowledges

the Forest Service has created road spoil piles along roads as part of its road maintenance

practices. PG&E disagrees that it should be responsible to correct problems created by

inadequate Forest Service maintenance practices.

Response: We have revised section 3.3.7.2, Environmental Effects, Land Use Resources,

Road and Transportation Facilities Management Plan, Our Analysis, of the final EIS to

clarify that there are road spoil piles along roads on NFS lands that may be within the

project boundary. PG&E is responsible for any spoil piles created by PG&E within the

project boundary and on NFS lands. The details about correcting problems created by

these spoil piles (e.g., removal) should be included in the proposed Road and

Transportation Facilities Management Plan, which would be filed with the Commission

for approval.

Comment: The Forest Service agrees that the current Spill Prevention, Control, and

Countermeasures Plan and Hazardous Materials Business Plan, in addition to existing law

and regulation, are sufficient detail regarding hazardous substances and hazardous waste

handling treatment.

The California Water Board states that the Hazardous Materials Business Plan needs to

extend to the entire project and include Regional Water Quality Control Board approval.

The Center for Water Advocacy states that the draft EIS lacks even rudimentary

containment capacity analysis of the facility in the event of a spill of oil or other toxic

substances. The Center for Water Advocacy states that, in result, any spill would

devastate the cultural resources and salmon fishery in the McCloud River since storm

water drainage from upland areas of the facility would likely flow across the ground

surface as sheet flow and eventually reach the river either overland or through ground

water. The Center for Water Advocacy states that the Comprehensive Environmental

Response, Compensation, and Liability Act provides that a “potentially responsible

party” may be liable for damages to natural resources in addition to response costs. The

Center for Water Advocacy states that a superfund action may also seek damages for

injury to, destruction of, or loss of natural resources, including the reasonable costs of

assessing such injury, destruction or loss resulting from an actual or threatened release of

hazardous substances (42 USC §9601(16)). The Center for Water Advocacy states that

the draft EIS fails to discuss the impacts of potential spills to natural resources and what

efforts would be made to limit such impacts and the resulting cultural and economic

impacts to the Tribe, and that this omission is contrary to 42 USC § 9651(c)(2).

Response: Section 3.3.7.2, Environmental Effects, of the final EIS has been revised to

clarify that the geographic scope of the Spill Prevention, Control, and Countermeasures

Plan and Hazardous Materials Business Plan should encompass all the lands within the

project boundary. The EIS has also been revised to recommend PG&E provide copies of

the plan to not only the Commission and the Forest Service, but also the appropriate

Regional Water Quality Control Board.
A-123

Section 3.3.7.2, Environmental Effects, of the final EIS has been revised to discuss the

potential impacts of a PG&E spill on resources in the project area, to include an

acknowledgement of PG&E’s responsibility for such spills within the project boundary,

and to identify acceptable prevention and mitigation measures (i.e., the plans). Under a

new project license, PG&E would be required to file the existing Spill Prevention,

Control, and Countermeasures Plan and Hazardous Materials Business Plan within

30 days of license issuance. Because the plans have not yet been filed with the

Commission and the Commission is unaware of the details of the plans, it is premature to

conduct any detailed analysis of the plans. The Commission will fully analyze the plans

when they are filed with the Commission for approval.

Comment: The California Water Board states that the draft EIS does not adequately

represent the authority and goals of the McCloud River Coordinated Resource

Management Plan, an alternative to the Wild and Scenic River Act designation of the

McCloud River. The California Water Board states that the Coordinated Resource

Management Plan is intended to provide the same level of protection as designation

under the Wild and Scenic Rivers Act. The California Water Boards states that the Forest

Service reserves the authority to seek designation should the Coordinated Resource

Management Plan fail to protect the values which render the river suitable for such

designation.

American Whitewater and Friends of the River agree that the draft EIS fails to adequately

characterize the purpose and goals of the Coordinated Resource Management Plan.

American Whitewater and Friends of the River state that the description of the

Coordinated Resource Management Plan should be adjusted accordingly and the

proposed action should either include a statement on how the Wild & Scenic River

protection standard is met or to be modified to ensure that this standard is met. American

Whitewater and Friends of the River state that Forest Service 4(e) conditions must also

meet this protection standard.

McCloud RiverKeepers comments that the Forest Service, as a signatory to the

Coordinated Resource Management Plan, is obligated to follow the conditions of the

Coordinated Resource Management Plan. McCloud RiverKeepers also expresses

concern regarding the proposed project’s potential effects on the McCloud River as a

valued historic river and world-renowned trout fishery.

Response: We recognize the unique character of the McCloud River and acknowledge

the Coordinated Resource Management Plan. We revised the EIS to further describe the

purpose and goals of the Coordinated Resource Management Plan, in section 3.3.7, Land

Use and Aesthetic Resources. Additionally, we note that the Coordinated Resource

Management Plan is only one component we use to balance developmental values and

environmental values, including waterway development for beneficial public purposes.

Comment: The McCloud River Club states that the draft EIS’ analysis of fire hazard

and other public safety hazards fails to serve NEPA’s core purpose and is inadequate

because it does not contain any analysis of what the project’s impacts will be on fire
A-124

hazards, and does not specifically identify risk or contain the required analysis,

disclosure, or discussion of potential mitigation measures. The McCloud River Club also

states that a Fire Prevention and Response Plan should be required for NEPA analysis of

impacts in an EIS and states that a future plan is not acceptable. In addition, the

McCloud River Club finds it inconceivable that a budget of $3,903 would be adequate to

develop a comprehensive Fire Plan that could lead to a reduction in the occurrence and

suppression of wildfires in the project area. The McCloud River Club recommends that

the final EIS provide a detailed analysis of the project’s potential impacts on fire hazards,

public safety, and trespass. Based on that analysis, the McCloud River Club recommends

that the final EIS also propose and discuss potentially feasible mitigation measures to

address these impacts.

Response: We have revised section 3.3.7.1, Affected Environment, Land Use Resources,

and 3.3.7.2, Environmental Effects, Land Use Resources, of the final EIS to further

analyze the potential impacts of the project on the number and frequency of fire events in

the area. We have also revised the EIS to include a discussion about how continued

project operations and existing facilities (e.g., transmission lines, generators, construction

equipment etc.), and increased recreational use over the term of the new license may

contribute to fire danger in the project area. The EIS acknowledges that additional fires

in the project area may, among other things, affect public safety, property, aesthetics, and

air quality. To mitigate these potential affects, PG&E proposes and we recommend the

development of a Fire Prevention and Response Plan, which would increase preparedness

of fire responders and minimize damage to natural resources in the area. The plan would

be filed with the Commission within 1 year of license issuance for approval.

In its FLA, PG&E estimates the one-time capital cost of developing a Fire Prevention and

Response Plan to be $10,000 (2009 $) and assumes an annual expense of $2,000 (2009

$). We reviewed these cost estimates and find that they give a reasonable estimate of the

cost of the measure. No commenting party has provided other estimates of these costs

and the cost of the measure has a small effect on the overall economic benefits of the

project. Therefore, we did not find it necessary to ask PG&E for a detailed breakdown of

the cost. In the final EIS, (table C-1) we show the equivalent annual cost to develop and

implement this plan $3,903 (2009 $).

Comment: The Forest Service suggests that the final EIS contain an analysis of the

activity of timber removal from the NFS lands; this analysis will expedite approvals

when needed. The Forest Service suggests that some topics that could be addressed in

the final EIS are the following: (1) the need to remove timber; (2) agency requirements;

(3) public safety/resource protection (i.e., compliance with/changes to clearance

standards, natural hazards, and similar situations when removal of merchantable timber

has a nexus to the project); (4) compensation (for the value of timber removed); and

(5) timber removal process/protocols. In particular, the Forest Service recommends that

the final EIS include a brief discussion stating that PG&E would be expected to comply

with the land agency timber removal protocols (i.e., the draft protocol to be included in

the Vegetation and Invasive Weed Management Plan). The Forest Service notes that
A-125

Forest Service regulations require Forest Service permission for cutting or removal of

timber, including occupancy of a right of way or other authorized use of NFS land.

Additionally, the Forest Service notes that the Commission requires Forest Service

permission and sale of merchantable timber.

Response: The Commission is not aware of any PG&E proposal to remove timber from

NFS lands inside the project boundary and therefore, there is no need to analyze this

further. However, if PG&E proposes to remove timber from NFS lands within the

project boundary, the activity must be permitted by the Forest Service, prior notice must

be given to the Commission, and PG&E must comply with all applicable Forest Service

plans and protocols. We have revised section 3.3.7.2, Environmental Effects, of the final

EIS to include a discussion about timber removal on NFS lands within the project

boundary.
This page intentionally left blank.
Appendix B

McCloud-Pit Project

Mitigation and Monitoring Summary

B-1

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

General –

Potential

projectrelated

impacts on

Forest Service

lands

Consult with the Forest

Service to present project

O&M activities planned for

the next calendar year

[Measure 1 and Forest

Service condition 1]

Ongoing:

Annually; the date

of the consultation

meeting will be

mutually agreed to

by PG&E and the

Forest Service.

Ongoing: Meeting would

include review of all

monitoring activities as

well as any additional

information that has been

compiled for the project

area, including progress

reports on other resource

measures

PG&E PG&E
B-2

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

General –

Potential

effect of

project O&M

on sensitive

resources

Conduct annual employee

awareness training [Measure

2 and Forest Service

condition 1]

Ongoing: Annual

employee

awareness

training to

familiarize

staff with local

resource issues,

special status

species, noxious

weeds, procedures

for reporting to the

Forest Service, and

applicable Forest

Service orders, to

allow avoidance/

minimization of

impacts

PG&E
B-3

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

General –

Potential

projectrelated

impacts on

Forest Service

lands

Obtain Forest Service

approval for all final design

plans [Measure 3]

Ongoing: Prior to

construction of any

new project

facilities on NFS

lands, obtain prior

written approval of

the Forest Service

for all final design

plans

PG&E
B-4

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

General –

Potential

effect of

project O&M

on sensitive

resources

Prepare and file a biological

evaluation or assessment for

newly added special status

species [NMFS 10(j)

recommendation 1B]

Ongoing: In

consultation with

the resource

agencies, annually

review the current

list(s) of special

status species that

might occur in the

project area

directly affected by

project operations.

Prepare biological

evaluation prior to

construction of

new project

features or nonroutine

maintenance

activities that may

affect special

status species or

their habitats

Ongoing: Develop and

implement a study plan in

consultation with the

resource agencies to assess

the effects of the project

on newly added special

status species

PG&E PG&E
B-5

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

General –

Potential

effect of

project O&M

on sensitive

resources

Prepare and submit a

biological evaluation for

Forest Service special status

species or their critical

habitat [Measure 15 and

Forest Service condition 11]

Ongoing: Before

taking actions to

construct new

project features on

NFS lands that

may affect Forest

Service special

status species or

their critical

habitat, prepare

and submit a

biological

evaluation for

Forest Service

approval

PG&E

General –

Altered

seasonal

geohydrology

Determine water year type

annually and apply to

appropriate minimum flow

release schedule and other

measures dependent on water

year type [Forest Service

condition 19]

Ongoing: Annual

determination of

water year type

and application of

appropriate

minimum flow

release schedule

PG&E
B-6

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Geo/Soils –

Blockage of

downstream

transport of

LWD

Develop and implement an

LWD Management Plan to

facilitate placement of woody

debris in Lower McCloud

River downstream of

McCloud dam [Measure 11

and Forest Service condition

21]

One-time: Within

1 year of license

issuance, prepare

LWD Management

Plan

Ongoing:

Implement the

approved plan

through the term of

the license

Ongoing: Monitor

mobilization of LWD from

augmentation site

according to the frequency

specified in the

management plan

PG&E PG&E
B-7

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Geo/Soils –

Potential

effects of

project

operations on

erosion

sites/other

sediment

sources and

related effects

on project

infrastructure

and sediment

delivery to

project

streams

Develop and implement an

Erosion and Sediment

Control Management and

Monitoring Plan [Measure 12

and Forest Service condition

22]

One-time: Within

1 year of license

issuance, develop

and file Erosion

and Sediment

Control

Management and

Monitoring Plan

Ongoing:

Implement the

approved plan

through the term of

the license

Ongoing: Monitor project

and project-related erosion

and

sedimentation sites at least

once every 10 years during

the term of the license and

for 3 years after treatment

at high priority sites

PG&E PG&E
B-8

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Geo/Soils –

Obstruction

of

downstream

gravel and

coarse

sediment

transport by

project dam

Develop and implement a

Gravel and Coarse Sediment

Management Plan [Forest

Service condition 23]

One-time: Within

1 year of license

issuance, develop

and file a Gravel

and Coarse

Sediment

Management Plan

Ongoing:

Implement the

approved plan

through the term of

the license

Ongoing: Monitor

mobilization and dispersal

of coarse sediment

PG&E PG&E
B-9

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Water –

Potential

effects of

project

operations

and

maintenance

on water

quality

Develop and implement a

water quality and temperature

monitoring [Forest Service

condition 20]

One-time: Within

1 year of license

issuance, develop

and file water

quality and

temperature

monitoring plan

Ongoing:

Implement the

approved plan

through the term of

the license

Ongoing: Periodic

monitoring of

contaminants once every 5

years at all project

reservoirs, periodic

monitoring of DO at

McCloud, Pit 6, and Pit 7

reservoirs, annual

temperature monitoring for

10 years, continuous

turbidity monitoring in the

Lower McCloud River

during fishing season,

turbidity monitoring

during construction,

reconstruction, or other

soil disturbing activities,

continuous monitoring of

turbidity for a minimum of

5 years in Iron Canyon

Creek, and for an

additional 5 years

thereafter, if turbidity

issues persist.

PG&E PG&E
B-10

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Aquatic –

Potential

impact on fish

and aquatic

invertebrate

populations in

projectaffected

reaches

Develop and implement an

Aquatic Biological

Management and Monitoring

Plan in consultation with

Forest Service and other

interested parties and

approved by the Forest

[Forest Service condition

27]aThis measure is modified

to remove the specification to

monitor fish passage

conditions and to remove

specification to monitor fish

populations in Pit 7

reservoir.

One-time: Within

1 year of license

issuance, develop

and file an Aquatic

Biological

Management and

Monitoring Plan,

to the extent

possible, consistent

with standardized

sampling and data

protocols in

relicensing studies

Ongoing:

Implement the

approved plan

through the term of

the license

Ongoing: Monitor

fish, benthic

macroinvertebrates,

and special status

mollusks, and other

special status species,

and invasive aquatic

species once every 3

years for the first 9

years and every 5 years

thereafter. Annually

review list of special

status aquatic species.

Assess threat of

invasive mussels and

implement prevention

plan. Report all

aquatic biological

monitoring results

within 1 year following

completion of

monitoring efforts.

PG&E PG&E
B-11

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Aquatic –

Minimum

flows

downstream

of McCloud

dam

Implement minimum flows at

McCloud dam[Forest Service

condition 19]

Ongoing:

Implement

minimum flows at

McCloud dam

PG&E

Aquatic –

Minimum

flows

downstream

of Iron

Canyon dam

Implement minimum flows at

Iron Canyon dam [Forest

Service 19]

Ongoing:

Implement

minimum flows at

Iron Canyon dam

PG&E

Aquatic –

Minimum

flows

downstream

of Pit 7 dam

Implement minimum flows at

Pit 7 dam [Measure 8 and

Forest Service condition 19]

Ongoing:

Implement

minimum flows

downstream of Pit

7 dam

PG&E
B-12

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Aquatic –

Potential

effects of

downramping

operations

during spill

events

Downramp spill events

controllable by valve

operation at McCloud dam at

a maximum rate of 150 cfs

per 48 hours until the

prescribed minimum

instream flow is reached

[Forest Service condition 19

and California Fish and

Game 10(j) recommendation

1]

Ongoing:

Implement

downramping rates

during spill events

controllable by

valve operation

PG&E

Aquatic –

Potential

effects of

upramping

during

operational

controllable

spills

Upramp operational

controllable spills at a

maximum rate of 200 cfs per

24 hours [Forest Service

condition 19 and California

Fish and Game 10(j)

recommendation 1]

Ongoing:

Implement

upramping rates

during operational

controllable spills

PG&E
B-13

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Aquatic –

Potential

effects of

uncontrollable

spill events

To extent possible, upramp

water flows released at

McCloud dam prior to the

start of an uncontrolled spill

event at a maximum target

rate of 100 cfs per hour

[Measure 9]

Ongoing:

Implement

upramping rate, if

possible, prior to

start of

uncontrollable spill

event

PG&E

Aquatic –

Confirmation

of compliance

with

minimum

streamflows

Operate, maintain, and

modify (if necessary) gages

needed to determine river

stage and minimum

streamflows [Forest Service

condition 19]

Ongoing: Maintain and

operate gages for term of

license

PG&E

Aquatic –

Confirmation

of compliance

with

minimum

streamflows

Measure streamflow

compliance at two points

below McCloud dam [Forest

Service condition 19]

Ongoing: Use two

compliance points

below McCloud

dam (MC-1 and

MC-7) to ensure

streamflows meet

minimum flow

requirements

Ongoing: Monitor flow

compliance below

McCloud dam at two

compliance points for term

of license

PG&E PG&E
B-14

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Aquatic –

Confirmation

of compliance

with

minimum

streamflows

Measure and document all

instream flow releases below

McCloud dam, Pit 7 dam,

and Iron Canyon dam in

publicly available and

accessible formats [Forest

Service condition 19]

Ongoing: Measure

instream flows below

project-affected reaches

and provide data in

publically available and

readily accessible format.

Post real-time flow data

for MC-1 online.

PG&E

Aquatic –

Potential

effect of

project dams

on fish

passage

Reserve NMFS authority to

prescribe fishways [NMFS

10(j)]

PG&E
B-15

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Terrestrial –

Potential

project

constructionrelated effects

on upland

vegetation,

riparian areas,

and wetlands

Develop and implement a

Vegetation and Invasive

Weed Management Plan

[Forest Service condition

25]aThis measure is modified

to specify that PG&E would

inform managers of sensitive

or rare species locations and

to include monitoring of

culturally significant plant

species not associated with

traditional cultural

properties and

implementation of BMPs to

minimize effects on wetlands.

One-time: Within

1 year of license

issuance, file a

Vegetation and

Invasive Weed

Management Plan

Ongoing:

Implement the

approved plan

through the term of

the license

Ongoing: Monitor known

populations of special

status plant species,

culturally significant plant

species not associated with

traditional cultural

properties, other

revegetation source

populations, and essential

wildlife habitat 1 year after

plan approval and every 5

years thereafter; survey for

new populations and new

listings in project area

beginning in first year

after plan approval and

every 10 years thereafter;

implement preconstruction surveys;

utilize operations map of

special status and

culturally significant

species; implement BMPs

for O&M in riparian and

wetland areas.

PG&E PG&E
B-16

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Terrestrial –

Potential

project related

alteration

of invasive

plant

populations

Develop and implement a

Vegetation and Invasive

Weed Management Plan

[Forest Service condition 25]

One-time: Within

1 year of license

issuance, file a

Vegetation

Management Plan

Ongoing:

Implement the

approved plan

through the term of

the license

Ongoing: Monitor areas

with ground disturbing

activities annually for 3

years after disturbance;

monitor selected known

populations beginning in

the first year after plan

approval and annually

thereafter; comprehensive

surveys of selected weed

species within 1 year of

plan approval and every 5

years thereafter; control

infestations of highpriority invasive species

within 1 year of detection

or as soon as practicable;

adaptive management to

prevent aquatic invasive

weeds

PG&E PG&E
B-17

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Terrestrial –

Potential

project related

effects on

disturbed

areas

Develop and implement a

Vegetation and Invasive

Weed Management Plan

[Forest Service condition 25]

One-time: Within

1 year of license

issuance, file a

Vegetation and

Invasive Weed

Management Plan

Ongoing:

Implement the

approved plan

through the term of

the license

Ongoing: Monitor for 3

to 5 years after disturbance

based on vegetative cover

and implement standards

of success and remediation

measures

PG&E PG&E

Terrestrial –

pesticide and

herbicide use

Restrict pesticide use on NFS

lands and develop and

implement a Vegetation and

Invasive Weed Management

Plan [Forest Service

conditions 15 and 25]aThis

measure is modified to

include additional

restrictions and guidelines

for the use of pesticides and

herbicides

One-time: Within

1 year of license

issuance, file a

Vegetation and

Invasive Weed

Management Plan

Ongoing:

Implement the

approved plan

through the term of

the license

Ongoing: Submit a

request for approval of

planned uses during annual

consultation with the

Forest Service

PG&E PG&E
B-18

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Terrestrial –

Potential

project

impacts on

northwestern

pond turtle

and foothill

yellow-legged

frog

Develop and implement an

Aquatic Biological

Monitoring Plan which

includes a Foothill YellowLegged Frog Monitoring Plan

[Forest Service

10(a) recommendation 1 and

condition 27]aThis measure

is modified to include

monitoring periods as

specified.

One-time: Within

1 year of license

issuance, submit an

Aquatic Biological

Monitoring Plan

which includes a

Foothill YellowLegged Frog

Monitoring Plan

Ongoing:

Implement the

approved plan

through the term of

the license

Ongoing: Monitor known

populations of

northwestern pond turtle

within 1 year of plan

approval and every 5 years

thereafter. Conduct

surveys for new

populations of

northwestern pond turtle

and foothill yellow-legged

frog in suitable habitat in

the project area within 1

year of plan approval and

every 10 years thereafter.

Conduct pre-construction

surveys for northwestern

pond turtle. Implement

Foothill Yellow-Legged

Frog Monitoring Plan.

PG&E PG&E
B-19

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Terrestrial -

Potential

project related

impacts

on wildlife

and avian

species

Develop and implement a

Terrestrial Biological

Management Plan and ensure

new and rebuilt power poles

conform to APLIC standards

for avian collision and

electrocution hazards

reduction

[Forest Service condition

26]aThis measure is modified

to remove monitoring of the

northwestern pond turtle,

which is specified in Forest

Service condition 27, and to

include monitoring periods

as specified.

One-time: Within

1 year of license

issuance, develop a

Terrestrial

Biological

Management Plan

Ongoing:

Implement the

approved plan

through the term of

the license

Ongoing: Monitor known

populations within 1 year

of plan approval and every

5 years thereafter for

terrestrial mollusks, Shasta

salamander, peregrine

falcon, and special status

bats, and annually for bald

eagle; survey for new

populations within 1 year

then every 10 years for

terrestrial mollusks, Shasta

salamander, annually for

bald eagle, and within 1

year and then every 5

years for peregrine falcon,

willow flycatcher, and

special status bats; conduct

pre-construction surveys

for terrestrial species or

follow limited operating

periods.

PG&E PG&E
B-20

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Land use –

potential

degradation of

access roads

needed to

safely

maintain

project

facilities

Road and Transportation

Facilities Management Plan

[Measure 18 and Forest

Service condition 29]

One-time:

Develop and file a

Road and

Transportation

Facilities

Management Plan

with the

Commission

within 1 year of

license issuance

Ongoing:

Implement the

approved plan

through the term of

the license

PG&E
B-21

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Land use –

project O&Mrelated effects

on land

management

Develop and implement a

Fire Prevention and Response

Plan [Forest Service

condition 33]

One-time:

Develop and file a

Fire Prevention

and Response Plan

with the

Commission

within 1 year of

license issuance

Ongoing:

Implement the

approved plan

through the term of

the license

PG&E
B-22

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Land use – oil

and hazardous

substances

spill

Implement existing Spill

Prevention, Control, and

Countermeasures Plan and

Hazardous Substance

Management Plana

One-time: File

with the

Commission the

existing Spill

Prevention,

Control, and

Countermeasures

Plan and

Hazardous

Substance

Management Plan

and provide copies

to the Forest

Service and the

Regional Water

Quality Control

Board within 30

days of license

issuance

Ongoing:

Implement the

plans through the

term of the license

PG&E
B-23

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Land use –

maintenance

of roads and

recreational

facilities

providing

access to

project lands

and waters

Revise project boundary and

file a revised exhibit Ga

One-time:

Incorporate all

existing project

roads and

recreation sites

within the project

boundary and file a

revised exhibit G

with the

Commission

within 1 year of

license issuance

Ongoing: As new

project facilities

are constructed,

including

recreation sites,

file revised exhibit

maps with the

Commission

PG&E
B-24

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Aesthetic

resources –

project

facilities and

operation may

impact

aesthetic

resources in

the project

area

Develop and implement

visual quality mitigation

measures [Forest Service

condition 32]

One-time:

Develop and file a

description of

specific visual

quality mitigation

measures and an

associated timeline

with the

Commission

within 1 year of

license issuance

Ongoing:

Implement the

measures through

the term of the

license

PG&E
B-25

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

RecreationPotential

effects

of streamflow

on

recreation

opportunities

Provide recreation flow

information for Lower

McCloud River [Measure 19,

Forest Service condition 19,

PG&E alternative condition

19]aThis measure is modified

to also include providing

real-time flow data for gage

MC-7 via PG&E’s webpage

on the internet.

Ongoing:

Implement by

providing real-time

flow data for gages

MC-1 and MC-7

and drawdown

information to the

public via PG&E’s

webpage on the

internet through

the term of the

license

PG&E
B-26

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Recreationpotential

increases in

projectrelated

recreation use

Recreation Development and

Management Plan [Measure

19, Forest Service condition

30, PG&E alternative

condition 30]aThis measure

is modified to specify

consultation with American

Whitewater, Friends of the

River, Native American

representatives and

conditioning agencies,

submittal of final plan to

Forest Service for review,

PG&E O&M responsibility

for all recreation facilities

upon license issuance

including Forest Service

facilities, and removal of

project patrol component.

One-time:

Develop and file

Recreation Plan

with the

Commission

within 2 years of

license issuance

Ongoing:

Implement the

approved plan

through the term of

the license

PG&E
B-27

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

RecreationPotential

safety issues,

provide

public

information

Develop and implement a

Project Sign Plan [Forest

Service condition 31]

One-time:

Develop and file

Project Sign Plan

with the

Commission

within 2 years of

license issuance

Ongoing:

Implement the

approved plan

through the term of

the license

PG&E
B-28

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Recreationpotential

increases in

projectrelated

recreation use

Recreation Monitoring

Plan/Component [Measure

19, Forest Service condition

30, and PG&E alternative

condition 30]aThis measure

is modified to include Forest

Service review of report and

boat use monitoring at the

reservoirs..

One-time:

Develop and file

with Recreation

Plan with the

Commission

within 2 years of

license issuance

Ongoing:

Implement the

approved plan

through the term of

the license

Ongoing: Conduct boat

use monitoring every 6

years

PG&E PG&E
B-29

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Recreation--

potential

increases in

projectrelated

recreation

use, potential

public safety

issues

Surface water management

plan/component [Measure 19,

Forest Service condition 30,

and PG&E alternative

condition 30]aThis measure

is modified to include

protocols, e.g., to prevent

unapproved buoy courses,

unauthorized access to

project areas; approved use

of docks; annual, or as

needed, surface sweeps of

McCloud and Iron Canyon

reservoirs.

One-time:

Develop and file

with Recreation

Plan with the

Commission

within 2 years of

license issuance

Ongoing:

Implement the

approved plan

through the term of

the license

PG&E
B-30

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Recreation--

potential

increases in

projectrelated

recreation

use, potential

public safety

issues

Annually stock up to 60,000

pounds of trout at the project

and develop and implement a

fish stocking plan [California

Fish and Game 10(j)]aThis

measure is modified to

include responsibility of

PG&E for fish stocking and

developing a fish stocking

plan to evaluate and monitor

the amount of fish to be

stocked every 6 years.

Ongoing:

Annually stock

60,000 pounds of

trout at the project

and implement fish

stocking plan

One-time:

Develop (for

Commission

approval) a fish

stocking plan in

consultation with

California Fish and

Game within 1

year of license

issuance.

Ongoing: Evaluate and

monitor the amount of fish

to be stocked every 6 years

through the term of the

license

PG&E PG&E
B-31

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Recreation--

potential

public safety

issues and

resource

damage

At McCloud and Iron

Canyon reservoirs, assess and

implement closures of usercreated roads leading to the

shoreline of McCloud and

Iron Canyon reservoirs

[Measure 19 and PG&E

alternative condition 30]a

This measure is modified to

also include trail and

dispersed use closure.

Ongoing:

Implement through

the term of the

license

PG&E
B-32

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Recreationpotential

increases in

projectrelated

recreation use

Provide or reconstruct dayuse facilities at Red Banks,

Star City, Tarantula Gulch,

Tarantula Gulch Inlet, base of

McCloud dam, and Fenders

Flat; and access areas at

Battle Creek, East McCloud

dam, West McCloud dam,

Iron Canyon reservoir (three

access points), and near the

proposed Pit 7 afterbay

powerhouse if the Pit 7

afterbay powerhouse is

constructed [Measure 19,

Forest Service condition 30,

and PG&E alternative

condition 30]

One-time:

Construct facilities

Ongoing: O&M

of facilities

PG&E
B-33

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Recreationpotential

increases in

projectrelated

recreation use

Conduct a site evaluation to

determine feasibility of

constructing a

fishing/swimming platform at

McCloud reservoir and

construct this facility if a

suitable location is found

[Measure 19 and PG&E

alternative condition 30]a

This measure is modified for

the site evaluation and report

to be filed with the

Commission within 2 years of

license issuance for approval

and construction of the

platform.

One-time: Site

evaluation and

filing report of

results with the

Commission

within 2 years of

license issuance

and construction of

the facility

Ongoing: O&M

of facility

PG&E
B-34

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Recreationpotential

increases in

projectrelated

recreation use

Provide or reconstruct boat

ramps: Tarantula Gulch,

Hawkins Landing, Iron

Canyon dam (new boat

ramp), and Fenders Flat

[Measure 19, Forest Service

condition 30, and PG&E

alternative condition 30]a

This measure is modified to

include lighting at Tarantula

Gulch boat ramp and the new

Iron Canyon dam boat ramp.

One-time:

Construct facilities

Ongoing: O&M

of facilities

PG&E
B-35

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Recreationpotential

increases in

projectrelated

recreation use

Provide snow removal at Iron

Canyon dam boat ramp and

access road when project

operations require snow

removal from Oak Mountain

Road [PG&E alternative

condition 30]

Ongoing: Snow

removal at Iron

Canyon dam boat

ramp and access

road when project

operations require

snow removal

from Oak

Mountain Road

PG&E
B-36

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Recreationpotential

increases in

projectrelated

recreation use

potential

public safety

issues and

resource

damage

Provide or reconstruct a

campground at Star City, Gap

Creek, Deadlun, and

Hawkins Landing [Measure

19, Forest Service condition

30, and PG&E alternative

condition 30]aThis measure

is modified to include a

campground at Gap Creek

for single unit campsites,

reconstruction of Deadlun

Campground for double and

triple campsites, and to

remove the requirement for

campground hosts.

One-time:

Construct facilities

Ongoing: O&M

of facilities

PG&E
B-37

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Recreationpotential

increases in

projectrelated

recreation use

Conduct site evaluation and

construct a pedestrian

shoreline access trail at the

upper end of Pit 7 reservoir

[Measure 19, Forest Service

condition 30, and PG&E

alternative condition 30]a

This measure is modified to

include construction of

facilities and only one access

trail and parking area.

One-time:

Construct facilities

Ongoing: O&M

of facilities

PG&E

Recreationpotential

increases in

projectrelated

recreation use

Conduct site evaluation and

construct a pedestrian

shoreline access trail at the

lower end of Pit 7 reservoir

[Forest Service condition

30]aThis measure is

modified to include the site

evaluation and to not include

a put-in or take-out for boats.

One-time:

Conduct site

evaluation within 2

years of license

issuance and

construct facilities

within 5 years of

license issuance

Ongoing: O&M

of facilities

PG&E
B-38

Mitigation

Implementation

Duration Monitoring Duration

Mitigation

Responsibility

Impact Mitigation

One-time or

Ongoing One-time or Ongoing

ImplementationMonitoring

Cultural

Resources –

projectrelated

impacts to

archaeologica

l and historic

era resources

Finalize and implement

HPMP [Measure 22 and

Forest Service condition 34]a

This measure has been

modified such that the final

HPMP filed with the

Commission in October 2010

would be implemented.

Ongoing:

Implement general

and site specific

treatment measures

identified in the

HPMP, to begin

upon new license

issue

Ongoing: Conduct longterm historic properties

monitoring; baseline

monitoring within 1 year

following new license

issuance, and annual

monitoring thereafter

PG&E PG&E

a

Staff alternative: includes additional measures identified by staff based on agency and non-governmental organization recommendations 
Appendix C

Capital and Annual Costs of Measures for the

McCloud-Pit Project

C-1

Table C-1. Estimated capital and O&M costs of measures proposed by PG&E and recommended by staff and agencies

for the McCloud-Pit Hydroelectric Project. (Source: Staff)

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M

Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Consult with Forest

Service annually

regarding planned

operation and

maintenance activities

on NFS lands

FS (4e #1),

PG&E (#1) Adopt $0 $0 $30,000 $0 $30,000

Provide annual

employee training in

coordination with the

Forest Service

FS (4e #1,

25), PG&E

(#2)

Adopt $0 $0 $60,000 $0 $60,000

Obtain Forest Service

approval for all final

design plans

PG&E (#3) Adopt $0 $0 $0 $0 $0

Consult annually on

newly added special

status species

NMFS (10(j)

#1B) Adopt $0 $0 $11,000 $0

The cost for

this measure

is reflected

in the cost

($30,000)

for FS

condition 1.

Develop and

implement gravel

augmentation and

amphibian indicator

species monitoring

CF&G

(10(a))

Do not

adopt $0 $0 $75,000 $0 $75,000
C-2

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M

Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Develop and

implement gravel

augmentation plan for

listed salmonids

NMFS (10(j)

#4A and B)

Do not

adopt $0 $0 $100,000 $0 $100,000

The cost of

developing and

implementing

gravel

augmentation

plans that may

be prescribed

in the future

cannot be

estimated at

this time.

Develop a plan for

gravel and coarse

sediment management

FS (4e #23) Adopt $20,000 $4,000 $75,000 $0 $79,000

Maintain stream

channel in McCloud

River to minimize

impacts on listed

salmonid habitat

NMFS (10(j)

#5)

Do not

adopt $0 $0 $10,000 $0 $10,000

The cost of

mitigation

plans that may

be prescribed

in the future

cannot be

estimated at

this time.
C-3

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M

Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Protect and enhance

riparian habitat

function for listed

salmonids

NMFS (10(j)

#6)

Do not

adopt $0 $0 $0 $0 $0

The cost of

riparian

protection and

enhancement

measures that

may be

prescribed in

the future

cannot be

estimated at

this time.

Move flow compliance

gage from MC-1 to

MC-7

CF&G (10(j)

#1),

NMFS(10(j)

#3)

Do not

adopt $0 $0 $60,000 $0 $60,000

Monitor instream flow

at two compliance

points below McCloud

dam

FS (4e #19) Adopt $0 $0 $60,000 $0 $60,000

Operate and maintain,

and modify (if

necessary) existing

gages for determining

streamflow and river

stage

FS (4e #19) Adopt $0 $0 $120,000 $0 $120,000
C-4

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M

Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Provide real-time flow

data for gage MC-1 on

the California Data

Exchange Center

website or its

successor.

FS (4e #19) Do not

adopt $0 $0 $2,000 $0 $2,000

Determine water year

type FS (4e #19) Adopt $0 $0 $5,000 $0 $5,000

Implement ramping

rates during

controllable spill

events and valve

testing

FS (4e 19)

CF&G (10(j)

#1)

Adopt $0 $0 $0 $0 $0

Implement American

Whitewater and

Friends of the River

alternative 4(e)

ramping rates during

controllable spill

events and valve

testing

American

Whitewater

and Friends

of the River

(Alternative

to FS 4e#19)

Do not

adopt $0 $0 $0 $0 $0

Implement minimum

flows proposed in FLA

PG&E (#5, 7,

8)

Do not

adopt $0 $0 $0

$10,703,00

0

$10,703,000
C-5

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M

Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Implement California

Fish and Game’s

recommended

minimum flows

CF&G (10(j)

#1)

Do not

adopt

$300,000

for valve

replacement

at McCloud

dam

$57,000 $0 $15,852,00

0

$15,910,000

Implement Forest

Service’s 4(e)

minimum flows

FS (4e #19) Adopt

$300,000

for valve

replacement

at McCloud

dam

$57,000 $0 $14,393,00

0

$14,451,000

Implement PG&E’s

alternative 4(e) flows

below McCloud dama

PG&E

(Alternative

to FS 4e #19)

Do not

adopt $0 $0 $0 $10,703,000

$10,703,000

Implement NMFS

minimum flows below

McCloud dam to meet

requirements for listed

salmonids

NMFS (10(j)

#3)

Do not

adopt $0 $0 $0 $0 $0

The cost of

minimum

instream flows

that may be

prescribed in

the future

cannot be

estimated at

this time

Implement McCloud

RiverKeepers flows

below McCloud dam

McCloud

RiverKeepers

(Alternative

to FS 4e #19)

Do not

adopt $0 $0 $0 $0 $4,255,000
C

-6

Measure Entity and

Measure No.

Staff

Recom-

mend?

Capital

Cost

(2009 $)

Annual-

ized

Capital

Cost

(2009 $)

Annual

O&M

Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Implement Winnemem

Wintu Tribe minimum

flows below McCloud

dam to meet

requirements for listed

salmonids

Winnemem

Wintu Tribe

(Alternative

to FS 4e #19)

Do not

adopt $0 $0 $0 $0 $0

The cost of

minimum

instream flows

that may be

prescribed in

the future

cannot be

estimated at

this time

Implement minimum

flows below Iron

Canyon dam

a

FS (4e#19)

CF&G(10(j)

1)

Adopt $0 $0 $0 $0 $727,000

Implement McCloud

dam up-ramping flows

prior to uncontrolled

spill events

a

PG&E (#9) Adopt $0 $0 $0 $0 $0

Provide a recreation

flow event from

McCloud dam

PG&E (#6) Do not

adopt $0 $0 $0 $0 $0

Upgrade gage MC-10 PG&E (#7) Do not

adopt $41,000 $8,000 $0 $0 $8,000

Develop and

implement a water

quality monitoring

plan in consultation

with applicable federal

and state agencies

FS (4e #20),

PG&E (#10) Adopt $85,000 $16,000 $70,000 $0 $86,000
C-7

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M

Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Modify project

structure and

operations necessary

to mitigate impacts of

water quality and

temperature to listed

salmonids

NMFS(10(j)

#7)

Do not

adopt $0 $0 $0 $0 $0

The cost of

project

mitigation

plans that may

be prescribed

in the future

cannot be

estimated at

this time.

Develop and

implement a Large

Woody Debris

Management Plan

FS (4e #21),

PG&E (#11) Adopt $600,000 $114,000 $100,000 $0 $214,000

Reserve authority to

prescribe fishways

NMFS/FWS

(Section 18) Adopt $0 $0 $0 $0 $0

The cost of any

fishways that

may be

prescribed in

the future

cannot be

estimated at

this time.
C-8

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M

Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Provide access to

suitable habitat for

anadromous fish and

restore habitat

conditions

NMFS(10(j)

#2)

Do not

adopt $0 $0 $0 $0 $0

The cost of any

fishways that

may be

prescribed in

the future

cannot be

estimated at

this time.

Develop and

implement an Erosion

and Sediment

Monitoring and

Control Plan

FS (4e #22),

PG&E (#12) Adopt $550,000 $105,000 $15,000 $0 $120,000

Develop and

implement a

Vegetation

Management Plan

PG&E (#13) Do not

adopt $300,000 $57,000 $275,000 $0 $332,000

Develop and

implement a

Vegetation and

Invasive Weed

Management Plan

FS (4e #25)

Adopt with

staff

modifications

$325,000 $62,000 $275,000 $0 $337,000

Prepare a biological

evaluation to protect

Forest Service special

status species

FS (4e #11),

PG&E (#15) Adopt $0 $0 $0 $0 $0
C-9

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M

Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Prepare and file a

biological or

assessment evaluation

for newly added

special status species

NMFS(10(j)

#1B) Adopt $0 $0 $0 $0 $0

Develop and

implement a Foothill

Yellow-Legged Frog

Monitoring Plan

FS (10(a)) Adopt $0 $0 $70,000 $0 $70,000

Develop and

implement a Wildlife

Management Plan

PG&E (#14,

16)

Do not

adopt $310,000 $59,000 $287,000 $0 $346,000

Develop and

implement a

Terrestrial Biological

Management Plan

FS (4e #26)

Adopt with

staff

modifications

$250,000 $48,000 $150,000 $0 $198,000

Develop and

implement an Aquatic

Biological

Management and

Monitoring Plan

FS (4e #27)

Adopt with

staff

modifications

$500,000 $95,000 $100,000 $0 $195,000
C-10

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M

Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Submit biological

evaluation or

assessment for special

status species

protection or

mitigation

NMFS(10(j)

#1)

Do not

adopt $20,000 $4,000 $2,000 $0 $6,000

Biological

evaluation

would be

conducted

under

Terrestrial and

Aquatic

Biological

Management

Plans.

Create a Listed

Salmonid Technical

Integration Committee

NMFS (10(j)

#8)

Do not

adopt $0 $0 $20,000 $0 $20,000

File reports with

Commission regarding

activities of existing

Interagency Fish

Passage Steering

Committee

Staff Adopt $0 $0 $1,000 $0 $1,000

Develop and

implement avian

hazard reduction

measures

PG&E (#16) Adopt $123,000 $23,000 $0 $0

The cost of

this measure

is reflected

in the

Terrestrial

Biological

Managemen

t Plan.
C-11

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M

Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Stock trout in

McCloud and Iron

Canyon reservoirs and

Shasta Lake, as

proposed in FLA

PG&E (#17) Do not

adopt

$0 $0 $117,000 $0 $117,000

Stock up to 60,000

pounds of trout within

project boundary

annually

CF&G

(10(j) #3)

Adopted

with staff

modifications

$0 $0 $117,000 $0 $117,000

Provide at least $5,000

annually for the

monitoring and

evaluation of fish

stocking program or

stocking of white

sturgeon within Shasta

Lake

CF&G

(10(j) #3)

Do not

adopt $5,000 $1,000 $0 $0 $1,000

Develop and

implement a Road and

Transportation Facility

Management Plan

FS (4e #29 &

30a), PG&E

(#18,

Alternative to

FS 4e #29)

Adopt with

incorporation of

PG&E’s

alternative

$15,500,000 $2,950,000 $1,000,000 $0 $3,950,000
C-12

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M

Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Develop and

implement a

Recreation

Development and

Management Plan in

consultation with

Forest Service,

conditioning agencies,

Native American

representatives, and

other interested parties

FS (4e #30 &

30a), PG&E

(Alternative

to FS 4e #30)

Adopt with

staff

modifications and

incorporation of

PG&E’s

alternative

$150,000 $29,000 $0 $0 $29,000

Develop and

implement a

Recreation

Development and

Management Plan in

consultation with

Forest Service,

California Fish and

Game, and California

Water Board

PG&E (#19) Do not

adopt $150,000 $29,000 $0 $0 $29,000

Provide recreation

flow information for

Lower McCloud River

on website

FS (4e #19,

Part 2 and

31), PG&E

(#19,

Alternative to

FS 4e #30)

Adopt with

staff

modifications

$0 $0 $4,000 $0 $4,000
C-13

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M

Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Develop and

implement a Project

Sign Plan as proposed

in FLA

PG&E (#19) Do not

adopt $200,000 $38,000 $0 $0 $38,000

Develop and

implement a project

Sign and

Interpretive/Education

Management Plan

FS (4e #31)

Adopt with

staff

modification

$314,000 $60,000 $12,000 $0 $72,000

The cost of the

Project Sign

Plan is $42,000

and the cost of

the Interpretive

and Education

Component is

$30,000

Develop and

implement an

Interpretive and

Education Sign plan as

proposed in

FLA/component of

Sign Plan

PG&E (#19) Do not

adopt $94,000 $18,000 $2,000 $0 $20,000

Develop and

implement a recreation

monitoring component

FS (4e #30),

PG&E (#19,

Alternative to

FS 4e #30) Adopt

$0 $0 $300,000 $0 $300,000

Develop a surface

water and shoreline

management plan

PG&E (#19,

Alternative to

FS 4e #30)

Do not

adopt $0 $0 $10,000 $0 $10,000
C-14

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M

Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Develop and

implement surface

water management

component

FS (4e #30)

Adopt with

staff

modifications

$0 $0 $50,000 $0 $50,000

Provide McCloud dam

recreation access

FS (4e #30),

PG&E (#19,

Alternative to

FS 4e #30)

Adopt

$413,000 $79,000 $11,000 $0 $90,000

Provide Battle Creek

day-use area

FS (4e #30),

PG&E (#19,

Alternative to

FS 4e #30) Adopt

$216,000 $41,000 $6,000 $0 $47,000

Provide East McCloud

dam day-use area

FS (4e #30),

PG&E (#19,

Alternative to

FS 4e #30) Adopt

$216,000 $41,000 $6,000 $0 $47,000

Provide Red Banks

day-use area

FS (4e #30),

PG&E (#19,

Alternative to

FS 4e #30) Adopt

$783,000 $149,000 $21,000 $0 $170,000

Develop Star City dayuse area and

campground

FS (4e #30),

PG&E (#19,

Alternative to

FS 4e #30)

Adopt $2,646,000 $504,000 $67,000 $0 $571,000
C-15

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M

Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Reconstruct Tarantula

Gulch boat launch and

provide day-use area

PG&E (#19,

Alternative to

FS 4e #30)

Adopt

PG&E’s

alternative

with staff

modification

$4,456,000 $848,000 $88,000 $0 $936,000

Reconstruct Tarantula

Gulch boat launch and

provide day-use area

FS (4e #30) Do not

adopt $4,456,000 $848,000 $228,000 $0 $1,076,000

Provide Tarantula

Gulch inlet day-use

area

FS (4e #30),

PG&E (#19,

Alternative to

FS 4e #30)

Adopt $188,000 $36,000 $4,000 $0 $40,000

Provide West

McCloud dam day-use

area

FS (4e #30),

PG&E (#19,

Alternative to

FS 4e #30) Adopt

$225,000 $43,000 $6,000 $0 $49,000

Conduct site

evaluation and provide

three day-use parking

areas at Iron Canyon

reservoir

FS (4e #30),

PG&E (#19,

Alternative to

FS 4e #30)

Adopt with

staff

modification

$816,000 $155,000 $22,000 $0 $177,000

Construct new

campground at Gap

Creek site for single

unit campsites

FS (4e #30) Adopt $2,016,000 $384,000 $59,000 $0 $443,000
C-16

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M

Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Reconstruct Deadlun

Campground to

provide double and

triple campsites

FS (4e #30) Adopt $2,016,000 $384,000 $59,000 $0 $443,000

Reconstruct/relocate

Deadlun Campground

PG&E (#19,

Alternative to

FS 4e #30)

Do not

adopt

$2,016,000 $384,000 $59,000 $0 $443,000

Reconstruct Hawkins

Landing Campground

and boat launch

FS (4e #30),

PG&E (#19,

Alternative to

FS 4e #30)

Adopt $1,450,000 $276,000 $41,000 $0 $317,000

Design and construct

Iron Canyon dam boat

launch

PG&E (#19,

Alternative to

FS 4e #30)

Adopt

PG&E

alternative

with staff

modifications

$1,962,000 $373,000 $98,000 $0 $471,000

Design and construct

Iron Canyon dam boat

launch

FS (4e #30) Do not

adopt $1,962,000 $373,000 $198,000 $0 $571,000

Evaluate feasibility

and construct shoreline

access trail (upper end

of Pit 7), if suitable

location found

PG&E (#19,

Alternative to

FS 4e #30)

Adopt with

staff

modifications

$70,000 $13,000 $4,000 $0 $17,000
C-17

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M

Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Develop two surfaced

parking areas with

reservoir access trails

below Pit 6 dam to

provide fishing access

and boating put-in

onto the upper Pit 7

reservoir

FS 4e #30 Do not

adopt $140,000 $27,000 $8,000 $0 $35,000

Recommend

only one trail -

adopt staffmodified

measure

“Evaluate

feasibility and

construct

shoreline

access trail

(upper end of

Pit 7),” in lieu

of this measure

Develop road access to

a surfaced parking area

and short walkway to

put-in/take-out onto

the lower Pit 7

reservoir, either at

Montgomery Creek or

near the Pit 7 dam

FS (4e #30) Do not

adopt $125,000 $24,000 $85,000 $0 $109,000
C-18

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M

Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Conduct a site

evaluation to

determine the location

of a pedestrian

shoreline access trail at

the lower end of Pit 7

reservoir, with paved

parking. Once a

suitable location is

found, construct this

facility within 5 years

of Commission

approval of the

Recreation Plan.

Staff

Staff

recommended

alternative

$70,000 $13,000 $4,000 $0 $17,000

Evaluate feasibility

and construct a boat

put-in at Montgomery

Creek (Pit 7 reservoir)

PG&E (#19,

Alternative to

FS 4e #30)

Do not

adopt $125,000 $24,000 $85,000 $0 $109,000

Provide day-use site at

Fenders Flat; maintain

access to car-top boat

launch; and provide

restroom near Pit 7

afterbay car-top boat

launch

PG&E (#19) Do not

adopt $1,404,000 $267,000 $109,000 $0 $376,000
C-19

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M

Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Reconstruct day-use

site at Fenders Flat

FS (4e #30),

PG&E

(Alternative

to FS 4e #30) Adopt

$1,620,000 $308,000 $115,000 $0 $423,000

Close/rehabilitate/eval

uate off-highway

vehicle trails

PG&E (#19,

Alternative to

FS 4e #30)

Adopt with

staff

modifications

$600,000 $114,000 $0 $0 $114,000

Develop and

implement plan to

provide project-wide

patrol

FS (4e #30),

PG&E (#20) Do not

adopt

$0 $0 $263,000 $0 $263,000

Provide project-wide

patrol for project and

project-affected NFS

land

PG&E

(Alternative

to FS 4e #30)

Do not

adopt $0 $0 $263,000 $0 $263,000

Prepare a Fire

Response Plan in

consultation with the

Forest Service,

California Department

of Forestry and

Protection, and Big

Bend Volunteer Fire

Department

FS (4e #33),

PG&E (#21) Adopt $10,000 $2,000 $2,000 $0 $4,000

Implement the HPMP

included in the FLA PG&E (#22) Do notadopt $440,000 $84,000 $200,000 $0 $284,000
C-20

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M

Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Additional measures

likely to be required in

an HPMP approved by

the Forest Service

FS (4e #34) Do not

adopt $440,000 $84,000 $200,000 $0 $284,000

Implement the final

HPMP, filed with the

Commission in

October 2010

NA

Staff

recommended

alternative

$440,000 $84,000 $200,000 $0 $284,000

Develop and

implement a plan to

protect visual quality

of project lands

FS (4e #32) Adopt $60,000 $11,000 $0 $0 $11,000

File a plan approved

by the Forest Service

for oil and hazardous

substances storage and

spill prevention and

cleanup.

NA

Staff

recommended

alternative

$0 $0 $0 $0 $0

Investigate known

safety and public

access issues at the Pit

7 afterbay dam (with

or without the

proposed new

powerhouse at the Pit

7 afterbay dam

FS (4e #30) Do not

adopt $0 $0

Not relicensing

issue - referred

to dam safety
C-21

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M

Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Reconstruct the cartop boat launch near

Fenders Flat

FS (4e #30),

PG&E

(Alternative

to FS 4e #30)

Adopt $50,000 $10,000 $4,000 $0 $14,000

Revise project

boundary and file a

revised exhibit G

NA

Staff recommended

alternative

$50,000 $10,000 $0 $0 $10,000

Total Applicant’s

Proposal $35,866,000 $6,827,000 $3,362,000 $1,566,000 $10,189,000

Staff Alternative $38,967,000 $7,418,000 $3,431,000 $3,500,000 $10,849,000

Staff Alternative with

4(e) Mandatory

Conditions

$39,092,000 $7,443,000 $4,021,000 $3,500,000 $11,464,000

a This measure would be implemented even if there is no new powerhouse constructed. Annual energy cost would differ, however, if the

new powerhouses are constructed.
C-22

Table C-2. Estimated capital and O&M costs of measures proposed by PG&E and recommended by staff and agencies

for construction of new powerhouses and transmission lines at the McCloud-Pit Hydroelectric Project.

(Source: Staff)

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Obtain Forest Service

approval for all final

design plans

PG&E (#3) Adopt $163,000 $31,000 $17,000 $0 $48,000

Move flow compliance

gage from MC-1 to

MC-7

CF&G (10(j)

#1), NMFS

(10(j) #3)

Do not

adopt $0 $0 $0 $0 $0

Monitor instream flow

at two compliance

points below McCloud

dam

FS(4e #19) Adopt $0 $0 $0 $0 $0

Implement minimum

flows proposed in FLA

PG&E (#5, 7,

8)

Do not

adopt $0 $0 $0

$2,793,000

to

$5,890,000a

$2,793,000

to

$5,890,000a

Implement California

Fish and Game’s

recommended

minimum flows

CF&G (10(j)

#1)

Do not

adopt $0 $0 $0

$7,942,000

to

$11,040,00

0

a

$7,942,000

to

$11,040,00

0

a

Implement Forest

Service’s 4(e) minimum

flows

FS (4e #19) Adopt $0 $0 $0

$6,483,000

to

$9,581,000a

$6,483,000

to

$9,581,000a

Implement PG&E’s

alternative 4(e) flows

below McCloud damb

PG&E

(Alternative

to FS 4e #19)

Do not

adopt $0 $0 $0

$2,793,000

to

$5,890,000a

$2,793,000

to

$5,890,000a
C-23

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Implement NMFS

minimum flows below

McCloud dam to meet

requirements for listed

salmonids

NMFS (10(j)

#3)

Do not

adopt $0 $0 $0 $0 $0

The cost of

minimum

instream flows

that may be

prescribed in

the future

cannot be

estimated at

this time

Implement Winnemem

Wintu Tribe minimum

flows below McCloud

dam to meet

requirements for listed

salmonids

Winnemem

Wintu Tribe

(Alternative

to FS 4e #19)

Do not

adopt $0 $0 $0 $0 $0

The cost of

minimum

instream flows

that may be

prescribed in

the future

cannot be

estimated at

this time

Implement McCloud

RiverKeepers flows

below McCloud damb

McCloud

RiverKeepers

(Alternative

to FS 4e #19)

Do not

adopt $0 $0 $0 $0 $0

Implement minimum

flows below Iron

Canyon damb

FS (4e#19)

CF&G(10(j)

1) Adopt $0 $0 $0 $0 $0
C-24

Measure Entity and

Measure No.

Staff

Recommend?

Capital

Cost

(2009 $)

Annualized

Capital

Cost

(2009 $)

Annual

O&M Cost

(2009 $)

Annual

Energy

Costs

(2009 $)

Total

Annualized

Cost

(2009 $)

Comments

Implement ramping

rates during

controllable spill events

and valve testing

FS (4e 19)

CF&G (10(j)

#1)

Adopt $0 $0 $0 $0 $0

Implement American

Whitewater and Friends

of the River alternative

4(e) ramping rates

during controllable spill

events and valve testing

American

Whitewater

and Friends

of the River

(Alternative

to FS 4e#19)

Do not

adopt $0 $0 $0 $0 $0

Implement McCloud

dam up-ramping flows

prior to uncontrolled

spill eventsb

PG&E (#9) Adopt $0 $0 $0 $0 $0

Prepare a biological

evaluation before

taking actions that

may affect Forest

Service special status

species

on NFS lands

FS (4e #11),

PG&E (#15) Adopt $310,000 $59,000 $287,000 $0 $346,000

Provide Pit 7 afterbay

powerhouse day-use

area and parking area

PG&E (#19,

Alternative to

FS 4e #30)

Adopt $141,000 $27,000 $11,000 $0 $38,000

a Costs based on estimated generation capacity of proposed McCloud and Pit 7 afterbay powerhouses.

b This measure would be implemented even if there is no new powerhouse constructed; capital and annual costs are included only in

table C-1. Annual energy cost would differ, however, if the new powerhouses are constructed.
Appendix D

Commission Staff Recommended

License Conditions

D-1

I. MANDATORY CONDITIONS

On November 29, 2010, the United States Department of Agriculture - Forest

Service (Forest Service) filed 32 section 4(e) conditions, 17 of which we consider

pertinent to environmental resources (described in section 2.2.4.1 of the EIS and included

in appendix E). In the staff alternative, we recommend 10 of the 17 conditions specified

by the Forest Service. In addition, we recommend 7 of the specified conditions with

modifications.1 We recognize, however, that the Federal Energy Regulatory Commission

(Commission) is required to include valid 4(e) conditions in any license issued for the

project. As such, each of the measures that staff recommend be modified in the staff

alternative (as discussed in section 5.0, Comprehensive Development and Recommended

Alternative) would not be included in any license issued by the Commission. Instead,

those conditions would be replaced with the Forest Service’s corresponding conditions,

as filed with the Commission.

II. ADDITIONAL LICENSE ARTICLES RECOMMENDED BY

COMMISSION STAFF

We recommend including the following license articles in any license issued for

the project, in addition to the mandatory conditions.

Draft Article 4XX. Reservation of Authority to Prescribe Fishways. Authority is

reserved for the Secretary of Commerce, through the National Marine Fisheries Service,

to prescribe the construction, operation, and maintenance of fishways at the project,

including measures to determine, ensure, or improve the effectiveness of such prescribed

fishways, pursuant to section 18 of the Federal Power Act, as amended, during the term

of the project license.

Draft Article 4XX. Reservation of Authority to Prescribe Fishways. Authority is

reserved for the Department of Interior to prescribe the construction, operation, and

maintenance of fishways at the project, including measures to determine, ensure, or

improve the effectiveness of such prescribed fishways, pursuant to section 18 of the

Federal Power Act, as amended, during the term of the project license.

Draft Article 4XX. Aquatic Biological Management and Monitoring Plan.

Within 1 year of license issuance, the licensee shall file with the Federal Energy

Regulatory Commission (Commission), for approval, an Aquatic Biological Management

and Monitoring Plan consistent with United States Department of Agriculture – Forest

1 As explained in section 5 of the draft Environmental Impact Statement, of the 17 conditions, we recommend

modifying the following 7 conditions: (1) vegetation and invasive weed management and monitoring

(condition 25); (2) terrestrial biological management and monitoring (condition 26); (3) aquatic biological

management and monitoring (condition 27); (4) road and transportation facility management (condition 29);

(5) recreation development, management, and monitoring (condition 30); (6) project sign plan (condition 31); and

(7) heritage resources management and monitoring (condition 34).
D-2

Service (Forest Service) 4(e) condition 27 (appendix E), except as noted herein. The

Aquatic Biological Management and Monitoring Plan shall be modified to: (1) exclude

fish population monitoring in Pit 7 reservoir; (2) exclude periodic monitoring of fish

passage conditions at non-project road crossings at Iron Canyon reservoir; (3) require

monitoring known populations of northwestern pond turtle within 1 year of plan approval

and every 5 years thereafter, conducting surveys for new populations of northwestern

pond turtle and foothill yellow-legged frog in suitable habitat in the project area within 1

year of plan approval and every 10 years thereafter, and conducting pre-construction

surveys for northwestern pond turtle; and (4) exclude surveys for foothill yellow-legged

frog from the Forest Service lands along the Lower McCloud River and include surveys

for foothill yellow-legged frog in tributaries to the Pit 6 and Pit 7 reservoirs if the foothill

yellow-legged frog becomes established in the Pit 5 reach.

The documentation and reporting component of Forest Service condition 27 shall

also be modified to include a provision that a draft technical report of all aquatic

biological monitoring components be prepared within 1 year following the completion of

each sampling effort.

The licensee shall prepare the plan and all components after consultation with the

Forest Service, California State Water Resources Control Board, United States

Department of Interior – Fish and Wildlife Service, and California Department of Fish

and Game. The licensee shall include with the plan documentation of consultation,

copies of comments and recommendations on the completed plan after it has been

prepared and provided to the agencies, and specific descriptions of how the agencies'

comments are accommodated by the plan. The licensee shall allow a minimum of

30 days for the agencies to comment and to make recommendations before filing the plan

with the Commission. If the licensee does not adopt a recommendation, the filing shall

include the licensee's reasons, based on project-specific information.

The Commission reserves the right to require changes to the plan. The plan shall

not be implemented until the licensee is notified that the plan is approved by the

Commission. Upon Commission approval, the licensee shall implement the plan.

Draft Article 4XX. Annual Report on Status of Reintroduction of ESA-listed

Species. By December 31 of each year following license issuance, the licensee shall file

with the Commission a report on the status of reintroduction into the McCloud River of

Endangered Species Act-listed species. The report shall include a discussion of the steps

that have been taken to assist in the reintroduction process, provide a summary of the

results of any studies that have been undertaken to benefit the reintroduction effort, and

discuss the status of any reintroduction programs.

The licensee shall prepare the report and all components after consultation with

the National Marine Fisheries Service, Bureau of Reclamation, United States Department

of Interior – Fish and Wildlife Service, and California Department of Fish and Game.
D-3

The licensee shall include with the plan documentation of consultation, copies of

comments on the completed report after it has been prepared and provided to the agencies

and specific descriptions of how the agencies' comments are accommodated by the plan.

The licensee shall allow a minimum of 30 days for the agencies to comment and to make

recommendations before filing the report with the Commission. If the licensee does not

adopt a recommendation, the filing shall include the licensee's reasons, based on projectspecific information.

The Commission reserves the right to require changes to the reporting

requirements.

Draft Article 4XX. Vegetation Management Plan. Within 1 year of license

issuance, the licensee shall file with the Federal Energy Regulatory Commission

(Commission), for approval, a Vegetation Management Plan consistent with the United

States Department of Agriculture - Forest Service (Forest Service) section 4(e)

condition 25 (appendix E), except as noted herein. The Vegetation Management Plan

shall be modified to include: (1) informing managers of sensitive or rare species

locations to protect these species during project operation and maintenance;

(2) monitoring of culturally significant plant species not associated with traditional

cultural properties; (3) additional restrictions and guidelines for the use of pesticides and

herbicides; and (4) implementation of best management practices to minimize effects on

wetlands.

The licensee shall develop the plan in consultation with the Forest Service, the

United States Department of Interior – Fish and Wildlife Service, and the California

Department of Fish and Game. The licensee shall include with the plan copies of

comments and recommendations made on the completed plan after it has been prepared

and provided to the agencies, and specific descriptions of how the agencies’ comments

are accommodated by the plan. The licensee shall allow a minimum of 30 days for the

consulted agencies to comment and make recommendations before filing the plan with

the Commission. If the licensee does not adopt a recommendation, the filing shall

include the licensee’s reasons, based on project-specific information.

The Commission reserves the right to require changes to the plan. The plan shall

not be implemented until the licensee is notified that it has been approved by the

Commission. Upon Commission approval, the licensee shall implement the plan,

including any changes required by the Commission.

Draft Article 4XX. Terrestrial Biological Management Plan. Within 1 year of

license issuance, the licensee shall file with the Federal Energy Regulatory Commission

(Commission) for approval, a Terrestrial Biological Management Plan consistent with the

United States Department of Agriculture - Forest Service (Forest Service) section 4(e)

condition 26 (appendix E), except as noted herein. The Terrestrial Biological

Management Plan shall be modified to include: (1) removal removal of the northwestern
D-4

pond turtle from the plan; (2) monitoring of known populations of terrestrial mollusks,

Shasta salamander, peregrine falcon, and special status bats within 1 year of plan

approval and every 5 years thereafter; (3) monitoring of known populations of bald eagle

annually; (4) conducting surveys for new populations of bald eagle annually, and within 1

year and then every 5 years for peregrine falcon, willow flycatcher, and special status

bats; (5) conducting only pre-construction surveys for northern goshawk or observe a

limited operating period of February 1 through August 15; (6) conducting only preconstruction surveys for neotropical breeding birds or observe a limited operating period

of April 1 through August 31; (7) conducting pre-construction surveys for willow

flycatcher or observing a limited operating period of April 1 through August 31; and (8)

conducting pre-construction surveys for northern spotted owl or observing a limited

operating period of February 1 through July 9.

The licensee shall develop the plan in consultation with the Forest Service, United

States Department of Interior – Fish and Wildlife Service, and the California Department

of Fish and Game. The licensee shall include with the plan copies of comments and

recommendations made on the completed plan after it has been prepared and provided to

the agencies, and specific descriptions of how the agencies’ comments are accommodated

by the plan. The licensee shall allow a minimum of 30 days for the consulted agencies to

comment and make recommendations before filing the plan with the Commission. If the

licensee does not adopt a recommendation, the filing shall include the licensee’s reasons,

based on project-specific information.

The Commission reserves the right to require changes to the plan. The plan shall

not be implemented until the licensee is notified that it has been approved by the

Commission. Upon Commission approval, the licensee shall implement the plan,

including any changes required by the Commission.

Draft Article 4XX. Special Status Species Review and Protection. The special

status species review and protection measures required by United States Department of

Agriculture - Forest Service section 4(e) conditions 25, 26, and 27 (appendix E) shall

apply to all accessible project lands and shall also include federal and state rare,

candidate, threatened, and endangered species. The Federal Energy Regulatory

Commission reserves the right to require additional measures to protect special status

species.

Draft Article 4XX. Streamflow Information. Within 90 days of license issuance,

the licensee shall provide the public access via its webpage on the internet, to reservoir

drawdown information for McCloud and Iron Canyon reservoirs and real-time flow data

for U.S. Geological Survey (USGS) Gage 11367760 (MC-7) and USGS Gage 11367800

(MC-1).

Draft Article 4XX. Fish Stocking Plan. Within 1 year of license issuance, the

licensee shall file with the Federal Energy Regulatory Commission (FERC, the
D-5

Commission) for approval, a plan to evaluate and monitor the amount of fish to be

stocked every 6 years in the reservoirs and affected stream reaches at the project. The

licensee shall develop the plan after consultation with California Department of Fish and

Game and include a description of the number, location, and species of fish to be stocked

in McCloud, Iron Canyon, Pit 6 and Pit 7 reservoirs, and other affected stream reaches at

the project and an implementation schedule. This stocking plan shall be included as a

part of the recreation monitoring effort that shall occur concurrently with the FERC Form

80 schedule every 6 years after license issuance.

The licensee shall include with the plan documentation of consultation, copies of

comments and recommendations on the completed plan after it has been prepared and

provided to the California Department of Fish and Game, and specific descriptions of

how the agency’s comments are accommodated by the plan. The licensee shall allow a

minimum of 30 days for the California Department of Fish and Game to comment and to

make recommendations before filing the plan with the Commission. If the licensee does

not adopt a recommendation, the filing shall include the licensee’s reasons, based on

project-specific information.

The Commission reserves the right to require changes to the plan. The plan shall

not be implemented until the licensee is notified that it has been approved by the

Commission. Upon Commission approval the licensee shall implement the plan,

including any changes required by the Commission.

Draft Article 4XX. Recreation Development and Management Plan. Within 2

years of license issuance, the licensee shall file with the Federal Energy Regulatory

Commission (Commission) a Department of Agriculture – Forest Service (Forest

Service)-approved Recreation Development and Management Plan consistent with Forest

Service section 4(e) condition 30 (appendix E). The plan shall include provisions for

operation and maintenance of project recreation facilities, recreation survey and

monitoring, reservoir water surface management, and the specific recreation facilities to

be reconstructed or constructed under the plan. The Recreation Development and

Management Plan required by Forest Service condition 30 shall be modified to include:

(1) monitoring of boat use during the recreation season as a part of recreation monitoring

efforts every 6 years; (2) a reservoir water surface management component that includes

protocols for preventing/removing unapproved buoy courses and approved use of docks,

surface sweeps of McCloud and Iron Canyon reservoirs and boat ramps annually or as

needed, and measures to prevent unauthorized access to project lands and waters, where

necessary, to protect public safety; and (3) an evaluation and implementation schedule for

road and trail closures, in coordination with the Forest Service, for the area inside the

project boundary around both McCloud and Iron Canyon reservoirs.

During the development of the plan, the licensee shall also consult with the

California Department of Fish and Game, American Whitewater, and Friends of the

River. The licensee shall include with the plan copies of comments and
D-6

recommendations made on the completed plan after it has been prepared and provided to

the entities above, and specific descriptions of how the entities’ comments are

accommodated by the plan. The licensee shall allow a minimum of 30 days for the

consulted entities to comment and make recommendations before filing the plan with the

Commission. If the licensee does not adopt a recommendation, the filing shall include

the licensee’s reasons, based on project-specific information.

The Commission reserves the right to require changes to the plan. The plan shall

not be implemented until the licensee is notified that the plan has been approved by the

Commission. Upon Commission approval, the licensee shall implement the plan,

including any changes required by the Commission.

Draft Article 4XX. Recreation Facilities. The following existing facilities shall

be operated and maintained for the term of the license: Tarantula Gulch Boat Launch,

Star City dispersed area, Deadlun Campground, Hawkins Landing Campground and boat

launch, and Fenders Flat Car-top boat launch.

Draft Article 4XX. Tarantula Gulch Boat Ramp. Upon reconstruction of

Tarantula Gulch boat ramp in accordance with a Department of Agriculture – Forest

Service (Forest Service)-approved Recreation Development and Management Plan

prepared consistent with Forest Service section 4(e) condition 30 (appendix E) and any

modifications to the plan made by the Federal Energy Regulatory Commission, the

licensee shall extend the boat ramp with the toe of the ramp to an elevation no less than

three vertical feet below minimum pool. The licensee shall also provide lighting,

additional parking, and a day-use area at the reconstructed Tarantula Gulch boat ramp.

Draft Article 4XX. McCloud Reservoir Swimming/Fishing Platform. Within 2

years of license issuance, the licensee shall conduct a site evaluation to determine the

location of a fishing/swimming platform on McCloud reservoir, and file a report

containing the results of the evaluation and recommendations for the placement and

construction of the platform with the Federal Energy Regulatory Commission

(Commission), for approval. After Commission approval, the licensee shall construct the

platform within 3 years of license issuance.

The licensee shall provide the report to the U. S. Department of Agriculture –

Forest Service (Forest Service) for comment. The licensee shall include with the report

copies of comments and recommendations made on the completed report after it has been

prepared and provided to the Forest Service, and specific descriptions of how the

agency’s comments are accommodated by the plan. The licensee shall allow a minimum

of 30 days for the Forest Service to comment and make recommendations before filing

the report with the Commission. If the licensee does not adopt a recommendation, the

filing shall include the licensee’s reasons, based on project-specific information.

The Commission reserves the right to require changes to the report. The report

shall not be implemented until the licensee is notified that it has been approved by the
D-7

Commission. Upon Commission approval, the licensee shall construct the platform with

any modifications required by the Commission.

Draft Article 4XX. Iron Canyon Dam Boat Ramp. Upon construction of Iron

Canyon dam boat ramp in accordance with a Department of Agriculture – Forest Service

(Forest Service)-approved Recreation Development and Management Plan prepared

consistent with Forest Service section 4(e) condition 30 (appendix E) and any

modifications to the plan made by the Federal Energy Regulatory Commission, the

licensee shall provide lighting at the Iron Canyon dam boat ramp. Upon construction of

the Iron Canyon dam boat ramp, the licensee shall remove snow from the boat ramp, the

access road to the boat ramp, and the parking area when project operations require snow

removal from Oak Mountain Road.

Draft Article 4XX. Pit 7 Reservoir Fishing Access Trail. Within 2 years of license

issuance, the licensee shall conduct a site evaluation to determine the location of a

pedestrian shoreline fishing access trail at the lower end of Pit 7 reservoir, and file a

report containing the results of the evaluation and recommendations for the location and

construction of the trail with the Federal Energy Regulatory Commission (Commission),

for approval. After Commission approval, the licensee shall construct the trail within 3

years of license issuance.

The licensee shall provide the report to the U. S. Department of Agriculture –

Forest Service (Forest Service) for comment. The licensee shall include with the report

copies of comments and recommendations made on the completed report after it has been

prepared and provided to the Forest Service, and specific descriptions of how the

agency’s comments are accommodated by the report. The licensee shall allow a

minimum of 30 days for the Forest Service to comment and make recommendations

before filing the report with the Commission. If the licensee does not adopt a

recommendation, the filing shall include the licensee’s reasons, based on project-specific

information.

The Commission reserves the right to require changes to the report. The report

shall not be implemented until the licensee is notified that it has been approved by the

Commission. Upon Commission approval, the licensee shall construct the trail with any

modifications required by the Commission.

Draft Article 4XX. Pit 7 Afterbay Powerhouse Access Area. Upon notifying the

Federal Energy Regulatory Commission (Commission) of its plans to construct the Pit 7

afterbay powerhouse, the licensee shall file for approval by the Commission, a report

containing the results of a site evaluation and recommendations for the placement and

construction of a shoreline access area with parking for anglers in the vicinity of the Pit 7

afterbay powerhouse that is consistent with homeland security needs. After Commission

approval, the licensee shall construct the access area with parking in accordance with the

schedule identified in the report.
D-8

The licensee shall provide the report to the U. S. Department of Agriculture –

Forest Service (Forest Service) for comment. The licensee shall include with the report

copies of comments and recommendations made on the completed report after it has been

prepared and provided to the Forest Service, and specific descriptions of how the

agency’s comments are accommodated by the report. The licensee shall allow a

minimum of 30 days for the Forest Service to comment and make recommendations

before filing the report with the Commission. If the licensee does not adopt a

recommendation, the filing shall include the licensee’s reasons, based on project-specific

information.

The Commission reserves the right to require changes to the report. The report

shall not be implemented until the licensee is notified that it has been approved by the

Commission. Upon Commission approval, the licensee shall construct the access area

with any modifications required by the Commission.

Draft Article 4XX. Fire Prevention and Response Plan. Within 1 year of license

issuance, the licensee shall file with the Federal Energy Regulatory Commission

(Commission) a Department of Agriculture – Forest Service (Forest Service)-approved

Fire Prevention and Response Plan consistent with Forest Service section 4(e) condition

33 (appendix E). During the development of the plan, the licensee shall also consult with

the California Department of Forestry and Fire Protection and the Big Bend Volunteer

Fire Department. The plan shall include provisions for fuels treatment/vegetation

management, fire prevention, emergency response, preparedness, reporting, post-fire

mitigations, and identifying fire control extinguishing locations within the project

boundary.

The Commission reserves the right to require changes to the plan. The plan shall

not be implemented until the licensee is notified that the plan has been approved by the

Commission. Upon Commission approval, the licensee shall implement the plan,

including any changes required by the Commission.

Draft Article 4XX. Road and Transportation Facilities Management Plan.

Within 1 year of license issuance, the licensee shall file with the Federal Energy

Regulatory Commission (Commission) a Road and Transportation Facilities Management

Plan, as specified by United States Department of Agriculture – Forest Service section

4(e) condition 29 (appendix E), for all roads and transportation facilities within the

project boundary. The plan shall address planning, operations, maintenance, construction

and reconstruction, monitoring, and road use.

The Commission reserves the right to require changes to the plan. The plan shall

not be implemented until the licensee is notified that the plan has been approved by the

Commission. Upon Commission approval, the licensee shall implement the plan,

including any changes required by the Commission.
D-9

Draft Article 4XX. Hazardous Substance Management Plan. Within 30 days of

license issuance, the licensee shall file with the Federal Energy Regulatory Commission

(Commission) copies of the existing Spill Prevention, Control, and Countermeasures Plan

and Hazardous Materials Business Plan. The licensee shall also provide copies of the

Spill Prevention, Control, and Countermeasures Plan and Hazardous Materials Business

Plan to the U. S. Department of Agriculture – Forest Service and the Regional Water

Quality Control Board.

The Commission reserves the right to require changes to the plans. The licensee

shall continue to implement the plans throughout the term of the license, including any

changes required by the Commission.

Draft Article 4XX. Visual Quality Mitigation Measures. Within 1 year of license

issuance, the licensee shall file with the Federal Energy Regulatory Commission

(Commission) a description of specific visual quality management measures and an

associated timeline, prepared consistent with the Department of Agriculture – Forest

Service (Forest Service) section 4(e) condition 32 (appendix E) and approved by the

Forest Service. The management measures shall address the impact of any proposed

project facilities or modifications to existing facilities, including but not limited to

generating facilities, recreation sites and facilities, and spoil piles, on the aesthetics in the

project area.

The Commission reserves the right to require changes to the management

measures and timeline. The mitigation measures shall not be implemented until the

licensee is notified that the measures have been approved by the Commission. Upon

Commission approval, the licensee shall implement the measures, including any changes

required by the Commission.

Draft Article 4XX. Programmatic Agreement and Historic Properties. The

licensee shall implement the “Programmatic Agreement among the Federal Energy

Regulatory Commission and the California State Historic Preservation Officer on

Historic Preservation for Managing Historic Properties that may be Affected by Issuing a

License to Pacific Gas & Electric for the Continued Operation and Maintenance of the

McCloud-Pit Hydroelectric Project in Shasta County, California, (FERC No. 2106-059)”

executed on (future date). Upon license issuance, and pursuant to the requirements of the

(future date) Programmatic Agreement, the licensee shall implement the October 2010

Historic Properties Management Plan. In the event that the Programmatic Agreement is

terminated, the licensee shall continue to implement the provisions of its approved

Historic Properties Management Plan. The Commission reserves the authority to require

changes to the Historic Properties Management Plan at any time during the term of the

license.

Draft Article 4XX. Use and Occupancy. (a) In accordance with the provisions of

this article, the licensee shall have the authority to grant permission for certain types of
D-10

use and occupancy of project lands and waters and to convey certain interests in project

lands and waters for certain types of use and occupancy, without prior Federal Energy

Regulatory Commission (Commission) approval. The licensee may exercise the

authority only if the proposed use and occupancy is consistent with the purposes of

protecting and enhancing the scenic, recreational, and other environmental values of the

project. For those purposes, the licensee also shall have continuing responsibility to

supervise and control the use and occupancies for which it grants permission, and to

monitor the use of, and ensure compliance with the covenants of the instrument of

conveyance for any interests that it has conveyed under this article. If a permitted use

and occupancy violates any condition of this article or any other condition imposed by

the licensee for protection and enhancement of the project’s scenic, recreational, or other

environmental values, or if a covenant or a conveyance made under the authority of this

article is violated, the licensee shall take any lawful action necessary to correct the

violation. For a permitted use or occupancy, that action includes, if necessary, canceling

the permission to use and occupy the project lands and waters and requiring the removal

of any non-complying structures and facilities.

(b) The types of use and occupancy of project lands and waters for which the

licensee may grant permission without prior Commission approval are: (1) landscape

plantings; (2) non-commercial piers, landings, boat docks, or similar structures and

facilities that can accommodate no more than 10 watercraft at a time and where said

facility is intended to serve single-family type dwellings; (3) embankments, bulkheads,

retaining walls, or similar structures for erosion control to protect the existing shoreline;

and (4) food plots and other wildlife enhancement. To the extent feasible and desirable to

protect and enhance the project’s scenic, recreational, and other environmental values, the

licensee shall require multiple use and occupancy of facilities for access to project lands

or waters. The licensee shall also ensure to the satisfaction of the Commission’s

authorized representative that the use and occupancies for which it grants permission are

maintained in good repair and comply with applicable state and local health and safety

requirements. Before granting permission for construction of bulkheads or retaining

walls, the licensee shall: (1) inspect the site of the proposed construction, (2) consider

whether the planting of vegetation or the use of riprap would be adequate to control

erosion at the site, and (3) determine if the proposed construction is needed and would

not change the basic contour of the impoundment shoreline. To implement this

paragraph (b), the licensee may, among other things, establish a program for issuing

permits for the specified types of use and occupancy of project lands and waters, which

may be subject to the payment of a reasonable fee to cover the licensee’s costs of

administering the permit program. The Commission reserves the right to require the

licensee to file a description of its standards, guidelines, and procedures for implementing

this paragraph (b) and to require modification of those standards, guidelines, or

procedures.
D-11

(c) The licensee may convey easements or rights-of-way across, or leases of

project lands for: (1) replacement, expansion, realignment, or maintenance of bridges or

roads where all necessary state and federal approvals have been obtained; (2) storm

drains and water mains; (3) sewers that do not discharge into project waters; (4) minor

access roads; (5) telephone, gas, and electric utility distribution lines; (6) non-project

overhead electric transmission lines that do not require erection of support structures

within the project boundary; (7) submarine, overhead, or underground major telephone

distribution cables or major electric distribution lines (69 kV or less); and (8) water intake

or pumping facilities that do not extract more than one million gallons per day from a

project impoundment. No later than January 31 of each year, the licensee shall file three

copies of a report briefly describing for each conveyance made under this paragraph (c)

during the prior calendar year, the type of interest conveyed, the location of the lands

subject to the conveyance, and the nature of the use for which the interest was conveyed.

If no conveyance was made during the prior calendar year, the licensee shall so inform

the Commission in writing no later than January 31 of each year.

(d) The licensee may convey fee title to, easements or rights-of-way across, or

leases of project lands for: (1) construction of new bridges or roads for which all

necessary state and federal approvals have been obtained; (2) sewer or effluent lines that

discharge into project waters for which all necessary federal and state water quality

certification or permits have been obtained; (3) other pipelines that cross project lands or

waters but do not discharge into project waters; (4) non-project overhead electric

transmission lines that require erection of support structures within the project boundary

for which all necessary federal and state approvals have been obtained; (5) private or

public marinas that can accommodate no more than 10 watercraft at a time and are

located at least one-half mile (measured over project waters) from any other private or

public marina; (6) recreational development consistent with an approved report on

recreational resources of an Exhibit E; and (7) other uses, if: (i) the amount of land

conveyed for a particular use is 5 acres or less; (ii) all of the land conveyed is located at

least 75 feet, measured horizontally, from project waters at normal surface elevation; and

(iii) no more than 50 total acres of project lands for each project development are

conveyed under this clause (d)(7) in any calendar year. At least 60 days before

conveying any interest in project lands under this paragraph (d), the licensee must submit

a letter to the Director, Office of Energy Projects, stating its intent to convey the interest

and briefly describing the type of interest and location of the lands to be conveyed (a

marked exhibit G map may be used), the nature of the proposed use, the identity of any

federal or state agency official consulted, and any federal or state approvals required for

the proposed use. Unless the Director, within 45 days from the filing date, requires the

licensee to file an application for prior approval, the licensee may convey the intended

interest at the end of that period.
D-12

(e) The following additional conditions apply to any intended conveyance under

paragraph (c) or (d) of this article:

(1) Before conveying the interest, the licensee shall consult with federal and state

fish and wildlife or recreation agencies, as appropriate, and the State Historic

Preservation Officer.

(2) Before conveying the interest, the licensee shall determine that the proposed

use of the lands to be conveyed is not inconsistent with any approved report on

recreational resources of an exhibit E; or if the project does not have an

approved report on recreational resources, that the lands to be conveyed do not

have recreational value.

(3) The instrument of conveyance must include the following covenants running

with the land: (i) the use of the lands conveyed shall not endanger health,

create a nuisance, or otherwise be incompatible with overall project

recreational use; and (ii) the grantee shall take all reasonable precautions to

ensure that the construction, operation, and maintenance of structures or

facilities on the conveyed lands will occur in a manner that will protect the

scenic, recreational, and environmental values of the project.

(4) The Commission reserves the right to require the licensee to take reasonable

remedial action to correct any violation of the terms and conditions of this

article, for the protection and enhancement of the project’s scenic, recreational,

and other environmental values.

(f) The conveyance of an interest in project lands under this article does not in

itself change the project boundaries. The project boundaries may be changed to exclude

land conveyed under this article only upon approval of revised exhibit G drawings

(project boundary maps) reflecting exclusion of that land. Lands conveyed under this

article will be excluded from the project only upon a determination that the lands are not

necessary for project purposes, such as operation and maintenance, flowage, recreation,

public access, protection of environmental resources, and shoreline control, including

shoreline aesthetic values. Absent extraordinary circumstances, proposals to exclude

lands conveyed under this article from the project shall be consolidated for consideration

when revised exhibit G drawings would be filed for approval for other purposes.

(g) The authority granted to the licensee under this article shall not apply to any

part of the public lands and reservations of the United States included within the project

boundary.
Appendix E

Forest Service 4(e) Conditions

E-1

Conditions filed by the Forest Service on November 29, 2010, pursuant to section

4(e) of the Federal Power Act, for the new license for Project No. 2106

I. STANDARD PROVISIONS APPLICABLE TO ALL PROJECTS

OCCUPYING NATIONAL FOREST SYSTEM LANDS

Condition No. 1 - Consultation

The Licensee shall, beginning the first full calendar year after license acceptance,

participate in annual meetings with the Forest Service to present Project operation and

maintenance activities planned for the next calendar year. In addition, Licensee shall

present results from current year monitoring of noxious weeds and special status species

as well as any additional information that has been compiled for the Project area,

including progress reports on other resource measures. The goals of this meeting are to

share information, mutually agree upon planned maintenance activities, identify concerns

that the Forest Service may have regarding activities and their potential effects on

sensitive resources, and any measures required to avoid or mitigate potential effects.

The date of the consultation meeting will be between January 10 and March 15 of

each year, as mutually agreed to by the Licensee and the Forest Service. Representatives

from the U.S. Fish and Wildlife Service (USFWS), California Department of Fish and

Game (CDF&G), State Water Resources Control Board (SWRCB), other interested

agency representatives, and other interested parties concerned with operation of the

Project may attend the meeting.

Consultation shall include, but not be limited to:

 A status report regarding implementation of license conditions;

 Results of any monitoring studies performed over the previous year in formats

agreed to by the Forest Service and the Licensee during development of

implementation plans;

 Review of any non-routine maintenance;

 Discussion of any foreseeable changes to Project facilities or features;

 Discussion of any necessary revisions or modifications to implementation

plans approved as part of this license;

 Discussion of needed protection measures for species newly listed as

threatened, endangered, or sensitive, or changes to existing management plans

that may no longer be warranted due to delisting of species or, to incorporate

new knowledge about a species requiring protection;

 Discussion of elements of current year maintenance plans, e.g. road

maintenance; and

 Discussion of any planned pesticide use.
E-2

A record of the meeting shall be kept by the Licensee and shall include any

recommendations made by the Forest Service for the protection of NFS lands and

resources. The Licensee shall file the meeting record, if requested, with the Commission

no later than 60 days following the meeting.

Copies of other reports related to Project safety and non-compliance shall be

submitted to the Forest Service concurrently with submittal to the FERC. These include,

but are not limited to: any non-compliance report filed by the Licensee, geologic or

seismic reports, and structural safety reports for facilities located on or affecting NFS

lands.

The Forest Service reserves the right, after notice and opportunity for comment, to

require changes in the Project and its operation through revision of the Section 4(e)

conditions to accomplish protection and utilization of NFS lands and resources.

Condition No. 2 – Approval of Changes

Notwithstanding any license authorization to make changes to the Project, when

such changes directly affect NFS lands the Licensee shall obtain written approval from

the Forest Service prior to making any changes in any constructed Project features or

facilities, or in the uses of Project lands and waters or any departure from the

requirements of any approved exhibits filed with the Commission. Following receipt of

such approval from the Forest Service, and a minimum of 60- days prior to initiating any

such changes, the Licensee shall file a report with the Commission describing the

changes, the reasons for the changes, and showing the approval of the Forest Service for

such changes. The Licensee shall file an exact copy of this report with the Forest Service

at the same time it is filed with the Commission. This condition does not relieve the

Licensee from the amendment or other requirements of Article 2 or Article 3 of this

license.

Condition No. 3 – Maintenance of Improvements on or Affecting National Forest

System Lands

The Licensee shall maintain all its improvements and premises on NFS lands to

standards of repair, orderliness, neatness, sanitation, and safety acceptable to the Forest

Service. Disposal of all materials will be at an approved existing location, except as

otherwise agreed by the Forest Service.

Condition No. 4 – Existing Claims

The license shall be subject to all valid claims and existing rights of third parties.

The United States is not liable to the Licensee for the exercise of any such right or claim.

Condition No. 5 – Compliance with Regulations

The Licensee shall comply with the regulations of the Department of Agriculture

for activities on NFS lands, and all applicable Federal, State, county, and municipal laws,

ordinances, or regulations in regards to the area or operations on or directly affecting
E-3

NFS lands, to the extent those laws, ordinances or regulations are not preempted by

federal law.

Condition No. 6 – Surrender of License or Transfer of Ownership

Prior to any surrender of this license, the Licensee shall provide assurance

acceptable to the Forest Service that Licensee shall restore any Project area directly

affecting NFS lands to a condition satisfactory to the Forest Service upon or after

surrender of the license, as appropriate. To the extent restoration is required, Licensee

shall prepare a restoration plan which shall identify the measures to be taken to restore

such NFS lands and shall include or identify adequate financial mechanisms to ensure

performance of the restoration measures.

In the event of any transfer of the license or sale of the Project, the Licensee shall

assure that, in a manner satisfactory to the Forest Service, the Licensee or transferee will

provide for the costs of surrender and restoration. If deemed necessary by the Forest

Service to assist it in evaluating the Licensee's proposal, the Licensee shall conduct an

analysis, using experts approved by the Forest Service, to estimate the potential costs

associated with surrender and restoration of any Project area directly affecting NFS lands

to Forest Service specifications. In addition, the Forest Service may require the Licensee

to pay for an independent audit of the transferee to assist the Forest Service in

determining whether the transferee has the financial ability to fund the surrender and

restoration work specified in the analysis.

Condition No. 7 – Protection of United States Property

The Licensee, including any agents or employees of the Licensee acting within the

scope of their employment, shall exercise diligence in protecting from damage the land

and property of the United States covered by and used in connection with this license.

Condition No. 8 – Indemnification

The Licensee shall indemnify, defend, and hold the United States harmless for:

 any violations incurred under any laws and regulations applicable to, or

 judgments, claims, penalties, fees, or demands assessed against the United

States caused by, or

 costs, damages, and expenses incurred by the United States caused by, or

 the releases or threatened release of any solid waste, hazardous substances,

pollutant, contaminant, or oil in any form in the environment related to the

construction, maintenance, or operation of the Project works or of the works

appurtenant or accessory thereto under the license.

The Licensee’s indemnification of the United States shall include any loss by

personal injury, loss of life or damage to property caused by the construction,

maintenance, or operation of the Project works or of the works appurtenant or accessory

thereto under the license. Indemnification shall include, but is not limited to, the value of
E-4

resources damaged or destroyed; the costs of restoration, cleanup, or other mitigation; fire

suppression or other types of abatement costs; third party claims and judgments; and all

administrative, interest, and other legal costs. Upon surrender, transfer, or termination of

the license, the Licensee’s obligation to indemnify and hold harmless the United States

shall survive for all valid claims for actions that occurred prior to such surrender, transfer

or termination.

Condition No. 9 – Damage to Land, Property, and Interests of the United States

The Licensee has an affirmative duty to protect the land, property, and interests of

the United States from damage arising from the Licensee's construction, maintenance, or

operation of the Project works or the works appurtenant or accessory thereto under the

license. The Licensee's liability for fire and other damages to NFS lands shall be

determined in accordance with the Federal Power Act and standard Form L-1 Articles 22

and 24.

Condition No. 10 – Risks and Hazards on National Forest System Lands

As part of the occupancy and use of the Project area, the Licensee has a continuing

responsibility to reasonably identify and report all known or observed hazardous

conditions on or directly affecting NFS lands within the Project boundary that would

affect the improvements, resources, or pose a risk of injury to individuals. Licensee will

abate those conditions, except those caused by third parties or not related to the

occupancy and use authorized by the License. Any nonemergency actions to abate such

hazards on NFS lands shall be performed after consultation with the Forest Service. In

emergency situations, the Licensee shall notify the Forest Service of its actions as soon as

possible, but not more than 48 hours, after such actions have been taken. Whether or not

the Forest Service is notified or provides consultation, the Licensee shall remain solely

responsible for all abatement measures performed. Other hazards should be reported to

the appropriate agency as soon as possible.

Condition No. 11 – Protection of Forest Service Special Status Species

Before taking actions to construct new project features on NFS lands that may

affect Forest Service special status species or their critical habitat, the Licensee shall

prepare and submit a biological evaluation (BE) for Forest Service approval. The BE

shall evaluate the potential impact of the action on the species or its habitat. In

coordination with the Commission, the Forest Service may require mitigation measures

for the protection of the affected species.

The biological evaluation shall:

 Include procedures to minimize adverse effects to special status species.

 Ensure project-related activities shall meet restrictions included in site

management plans for special status species.

 Develop implementation and effectiveness monitoring of measures taken or

employed to reduce effects to special status species.
E-5

Condition No. 12 – Access

Subject to the limitations set forth under the heading of “Road Use by

Government” in Condition No. 29 hereof, the Forest Service reserves the right to use or

permit others to use any part of the licensed area on NFS lands for any purpose, provided

such use does not interfere with the rights and privileges authorized by this license or the

Federal Power Act.

Condition No. 13 – Crossings

The Licensee shall maintain suitable crossings as required by the Forest Service

for all roads and trails that intersect the right-of-way occupied by linear Project facilities

(powerline, penstock, ditch, and pipeline).

Condition No. 14 – Surveys, Land Corners

The Licensee shall avoid disturbance to all public land survey monuments, private

property corners, and forest boundary markers. In the event that any such land markers or

monuments on NFS lands are destroyed by an act or omission of the Licensee, in

connection with the use and/or occupancy authorized by this license, depending on the

type of monument destroyed, the Licensee shall reestablish or reference same in

accordance with (1) the procedures outlined in the "Manual of Instructions for the Survey

of the Public Land of the United States," (2) the specifications of the County Surveyor, or

(3) the specifications of the Forest Service. Further, the Licensee shall ensure that any

such official survey records affected are amended as provided by law.

Condition No. 15 – Pesticide-Use Restrictions on National Forest System Lands

Pesticides may not be used on NFS lands or in areas affecting NFS lands to

control undesirable woody and herbaceous vegetation, aquatic plants, insects, rodents,

non-native fish, etc., without the prior written approval of the Forest Service. During the

Annual Consultation Meeting described in Condition 1, the Licensee shall submit a

request for approval of planned uses of pesticides for the upcoming year. The Licensee

shall provide at a minimum the following information essential for review:

 whether pesticide applications are essential for use on NFS lands;

 specific locations of use;

 specific herbicides proposed for use;

 application rates;

 dose and exposure rates; and

 safety risk and timeframes for application.

Exceptions to this schedule may be allowed only when unexpected outbreaks of

pests require control measures that were not anticipated at the time the report was

submitted. In such an instance, an emergency request and approval may be made.
E-6

Pesticide use will be excluded from NFS lands within 500 feet of known locations

of Shasta Salamanders, Northern Pond Turtles, Foothill Yellow Legged Frog, or known

locations of Forest Service Special Status or culturally significant plant populations.

Application of pesticides must be consistent with Forest Service riparian conservation

objectives.

On NFS lands, the Licensee shall only use those materials registered by the U.S.

Environmental Protection Agency and consistent with those applied by the Shasta-Trinity

National Forest and approved through Forest Service review for the specific purpose

planned. The Licensee must strictly follow label instructions in the preparation and

application of pesticides and disposal of excess materials and containers. The Licensee

may also submit Pesticide Use Proposal(s) with accompanying risk assessment and other

Forest Service required documents to use pesticides on a regular basis for the term of the

license as addressed further in Condition 25: Vegetation and Invasive Weed

Management. Submission of this plan will not relieve the Licensee of the responsibility

of annual notification and review.

Condition No. 16 – Modifications of 4(e) Conditions after Biological Opinion or

Water Quality Certification

The Forest Service reserves the right to modify these conditions, if necessary, to

respond to any Final Biological Opinion issued for this Project by the National Marine

Fisheries Service, United States Fish and Wildlife Service; or any Certification issued for

this Project by the State Water Resources Control Board.

Condition No. 17 – Signs

The Licensee shall consult with the Forest Service prior to erecting signs related to

safety issues on NFS lands covered by the license. Prior to the Licensee erecting any

other signs or advertising devices on NFS lands covered by the license, the Licensee must

obtain the approval of the Forest Service as to location, design, size, color, and message.

The Licensee shall be responsible for maintaining all Licensee-erected signs to neat and

presentable standards.

Condition No. 18 – Ground Disturbing Activities

If the Licensee proposes ground-disturbing activities on or directly affecting NFS

lands that were not specifically addressed in the Commission’s NEPA processes, the

Licensee, in consultation with the Forest Service, shall determine the scope of work and

potential for Project-related effects, and whether additional information is required to

proceed with the planned activity. Upon Forest Service request, the Licensee shall enter

into an agreement with the Forest Service under which the Licensee shall fund a

reasonable portion of Forest Service’s staff time and expenses for staff activities related

to the proposed activities.
E-7

II. ADDITIONAL PROVISIONS

Condition No. 19 – Streamflow

Part 1. Minimum Streamflow Requirements and Measurement

Licensee shall maintain specified minimum streamflows in project reaches in

accordance with provisions described below. Minimum streamflows shall commence

within 90 days of license issuance, unless facility modifications are required. License

Condition 16 (Modification of 4(e) Conditions After Biological Opinion or Water Quality

Certification) provides the opportunity to adjust these minimum streamflow requirements

to comply with the NOAA Biological Opinion and the SWRCB 401 Water Quality

Certificate, if needed.

Minimum streamflows for the Lower McCloud River and Iron Canyon Creek shall

be measured in two ways: as the 24-hour average of the flow (mean daily flow), and as an

instantaneous flow. Minimum streamflow measurement at Pit 7 shall be instantaneous

flow. There is no minimum flow requirement for the Pit River below Pit 6 dam. The

instantaneous flow is the flow value used to construct the average daily flow value and

shall be measured in time increments of at least 15-minutes. The 24-hour average flow is

the average of the incremental readings from midnight of one day, to midnight of the

following day, or an alternate 24-hour period as agreed. Licensee shall record

instantaneous 15-minute streamflow as required by US Geological Survey (USGS)

standards at all gages. The minimum instantaneous 15-minute streamflow shall be at least

80% of the prescribed mean daily flow for those minimum streamflows less than or equal

to 10 cubic feet per second (cfs), and at least 90% of the prescribed mean daily flow for

those minimum streamflows required to be greater than 10 cfs.

Should the mean daily flow, as measured, be less than the required mean daily

flow but more than the instantaneous flow, Licensee shall begin releasing the equivalent

under-released volume of water within 7 days of discovery of the under-release. Credit

for such additional releases will not exceed 20% of the instantaneous flow amount, when

used to attain the equivalent of the under-released volume.

The Licensee shall schedule the timing of maintenance or other planned outages to

avoid negative ecological effects from the resultant spills. The Licensee shall provide

written notification to the USFS at least 90 days prior to any planned or scheduled

maintenance outages that would affect streamflows in the Pit River, Lower McCloud

River or Iron Canyon Creek reaches. Notification shall include a description of the

project and coordinated measures the Licensee plans to take to minimize the magnitude

and duration of spills into the Project reach. The Licensee shall not proceed with the

planned maintenance outage without the formal written approval of the USFS and

notification on Licensee’s public Project website. The USFS will respond in a timely

manner.
E-8

The Minimum Streamflow requirements are subject to temporary modification if

required by equipment malfunction, as directed by law enforcement authorities, or in

emergencies. An emergency is defined as an event that is reasonably out of the control of

the Licensee and requires Licensee to take immediate action, either unilaterally or under

instruction by law enforcement or other regulatory agency staff, to prevent imminent loss

of human life or substantial property damage. An emergency may include, but is not

limited to, natural events such as landslides, storms or wildfires, malfunction or failure of

Project works, and recreation accidents.

If the Licensee temporarily modifies the requirements of these conditions, then the

Licensee shall make all reasonable efforts to promptly resume performance of such

requirements and shall notify the USFS and other interested or affected governmental

agencies within 48 hours of the modification.

Where facility modification is required to implement the efficient release of

Minimum Streamflows, the Licensee shall submit applications for permits within one

year after license issuance, and complete such modifications and initiate minimum

streamflows as soon as reasonably practicable but no later than two years after receipt of

all required permits and approvals. Prior to completion of such required facility

modifications, the Licensee shall make a good faith effort to provide the specified

Minimum Streamflows within the capabilities of the existing facilities.

a) Pit River below Pit 7 Dam

The Licensee shall release instantaneous flow of 150 cfs in the Pit River below Pit

7 Dam as measured at USGS Gage 11365000 year round. Instantaneous flow is defined

as the flow value used to construct the average daily flow value and shall be measured in

time increments of at most 15-minutes.

b) McCloud River below McCloud Dam

The Licensee shall release mean daily flows of at least 175 cfs year round from the

McCloud Dam such that the mean daily flow at USGS Gage 11367800 (MC-1) at Ah-DiNa is at least 200 cfs. These flows shall be augmented during the period February 15

through August 31 according to the prescription shown below. Flows shall be measured

for compliance at both USGS Gage 11367800 (MC-1) and either at Gage MC-7 or

directly at McCloud Dam.

Beginning February 1, the Licensee shall consult Bulletin 120 published by the

California Department of Water Resources (or its successor) and determine the “Percent

of Average, April through July Forecast” for the McCloud River above Shasta Lake. That

value shall be compared to values in Table 1-1 and the flow shall be modified as

indicated. No ramping is required between semi-monthly increments.

Licensee shall downramp all spill events once controllable by valve operation

(assumed to be at 1000 cfs). Down ramping shall proceed at an increment of 150 cfs

decrease each 48 hour period until the prescribed minimum instream flow value is
E-9

reached. Operational controllable spills (e.g. valve testing for dam safety compliance)

also shall be up ramped in increments not to exceed 200 cfs each 24 hour period.

Table 1-1. Flow Rule for McCloud River Instream Flow

If the February 1

McCloud Runoff % is:

then for the period:

February 15-29

and for the period: March

1-15

0-75 No Change No Change

76-89 No Change Increase flow by 50 cfs

90-99 Increase flow by 75 cfs Increase flow by 50 cfs

100-119 Increase flow by 125 cfs Increase flow by 100 cfs

120+ Increase flow by 175 cfs Increase flow by 150 cfs

If the March 1 McCloud

Runoff percentage is:

then for the period:

March 16-31

and for the period: April

1-15

0-75 No Change No Change

76-89 No Change No Change

90-99 Increase flow by 50 cfs No Change

100-119 Increase flow by 50 cfs Increase flow by 50 cfs

120+ Increase flow by 150 cfs Increase flow by 50 cfs

If the release from McCloud Dam (MC-7) on April 15 is equal to or greater

than 200 cfs:

On each Friday after April 15, decrease the flow 50 cfs per week until the

flow reaches 200 cfs, then maintain 200 cfs release at McCloud Dam (MC7) through June 30

July 1 through August 31: release 175 cfs at MC-7 but maintain at least 215

cfs at Ah-Di-Na (MC-1)

Beginning September 1: Release 175 cfs at MC-7; but maintain at least 200

cfs at Ah-Di-Na (MC-1)

If the release from McCloud Dam (MC-7) on April 15 is less than 200 cfs:

Beginning April 16: Release 175 cfs at MC-7; but maintain at least 200 cfs

at Ah-Di-Na (MC-1)

c) Iron Canyon Creek below Iron Canyon Dam

The Licensee shall release mean daily flows in Iron Canyon Creek below Iron

Canyon Dam in accordance with the schedule shown below in Table 1-2 as measured at

Gage MC-10.
E-10

Table 1-2. Iron Canyon Creek

Month Mean Daily Flow (cfs) by Water Year

Below Normal, Dry,

Critically Dry Above Normal Wet

Oct 7 7 10

Nov 7 7 10

Dec 7 10 15

Jan 7 10 15

Feb 7 10 15

Mar 10 15 >20**

Apr 10 15 >20**

May 7 10 15

Jun 7 10 15

Jul 7 7 10

Aug 7 7 10

Sep 7 7 10

**In March and April of Wet Water Year Types, the Flow Control Valve on Iron

Canyon Dam shall be fully opened. Mean Daily flow shall be at least 20 cfs during this

period.

No ramping is required between monthly increments. Valve testing for dam safety

compliance shall only occur between March 1 and 31. Up ramping to test flow valve

(assumed 200 cfs maximum) shall occur in 20 cfs increments spaced at least 15-minutes

apart. Down ramping shall occur in 20 cfs increments spaced at least 30-minutes apart.

The Licensee shall determine the water year type based on the forecast of

unimpaired runoff as provided by the California Department of Water Resources (DWR)

Bulletin 120 report of water conditions in California for the “Percent of Average, April

through July Forecast” for the McCloud River above Shasta Lake. Critically Dry, Dry

and Below Normal shall be defined as less than 100% of the average April-July

forecasted runoff in Bulletin 120 for McCloud River at Shasta Lake for each respective

month. Above Normal shall be defined as 100-119% of the average April-July forecasted

runoff in Bulletin 120 for McCloud River at Shasta Lake for each respective month. Wet
E-11

shall be defined as 120% and greater of the average April-July forecasted runoff in

Bulletin 120 for McCloud River at Shasta Lake for each respective month.

In January, February, March, and April the Licensee shall determine the water

year type based on the DWR Bulletin 120 forecast and shall operate for that month based

on that forecast. The May forecast shall be used to establish the water year type for the

remaining months until the next January, when forecasting shall begin again.

Minimum Instream Flows (MIFs) triggered by water year type shall be

implemented within 3 business days of the actual publication date of that month’s DWR

Bulletin 120, or as soon as permitted by weather and site accessibility. The previous

month’s flows may continue through the first several days of these months where

forecasts are used to determine flows, until the new flow has been determined and the

flow change made.

Part 2. Streamflow Measurement.

For the purpose of determining the river stage and minimum streamflow on the

Lower McCloud River below McCloud Dam, Pit River below the Pit 7 Dam, and Iron

Canyon Creek below the Iron Canyon Dam, the Licensee shall operate and maintain the

existing gages, consistent with all requirements of FERC and under the supervision of the

USGS. Any modification of the gage facilities at any of these gages that may be

necessary to measure the new Minimum Streamflow releases shall be completed within

three years of issuance of the new Project license. Licensee shall install an instream

measuring device either within or adjacent to the McCloud Dam to directly measure

instream flow releases from McCloud dam.

The Licensee shall measure and document all instream flow releases in publicly

available and readily accessible formats. Flow data at USGS Gage 11367800 (MC-1)

shall be real-time data and posted on the California Data Exchange Center (CDEC) or its

successor website. Flow data collected by Licensee from the stream gages will be

reviewed by the Licensee’s hydrographers as part of its quality assurance/quality control

(QA/QC) protocol. Upon completion of the QA/QC process, the data will be catalogued

and made available to USGS in annual hydrology summary reports. Licensee understands

that the USGS will then complete their QA/QC review of the data and subsequently

publish the data and post it within their electronic database that can be accessed via the

internet. The flow values (generally 15-minute recordings) used to construct the 24-hour

average flows will be available to the resource agencies from the Licensee upon request.

Condition No. 20 – Water Quality and Temperature Monitoring

Within one year of license acceptance, and in consultation with applicable Federal

and State agencies, the Licensee shall file with the Commission a Water Quality and

Temperature Monitoring Plan (WQTMP) that is approved by the Forest Service, as it

relates to aquatic habitats and water-based recreation on NFS lands. Upon Commission

approval, Licensee shall implement the Plan. This plan shall include:
E-12

 Monitoring all project reservoirs every five years for contaminants at

appropriate key recreation locations, e.g. boat ramps, day use areas, near

campgrounds (including e. coli, to measure possible sanitation concerns);

 Periodic monitoring of dissolved oxygen at McCloud, Pit 6 and Pit 7

Reservoirs; and

 Temperature monitoring from May 1 through September 30 at a minimum, for

a period of ten years following implementation of instream flow schedule.

Monitoring to be conducted by Project segment (i.e. reservoirs and Projectaffected rivers) subject to the following:

o Permission to enter private lands during sensor installation/maintenance, as

applicable;

o Routine sensor maintenance or deployment in the spring may be delayed

due to late snows or high flows and will be initiated as early in May as

possible, subject to safety and access constraints; and

o If monitoring indicates that temperatures above 20o C are occurring within

the project reservoirs or downstream reaches, additional monitoring may be

required;

 Continuous monitoring of turbidity for the term of the license in the Lower

McCloud River (at MC-7 or MC-1) during fishing season (approximately April

25 to November 15) to record elevated turbidity for recreational use.

o Routine sensor maintenance or deployment in the spring may be delayed

due to late snows or high flows and will be completed prior to or as early in

the fishing season as possible, subject to safety and access constraints.

o Turbidity levels shall be available real-time during the fishing season on the

Licensee’s public Project website.

 Turbidity monitoring during construction, re-construction, or other soil

disturbing activities to identify point source erosion that may require repair or

stabilization;

 Continuous monitoring of turbidity for a minimum of five years after license

acceptance in Iron Canyon Creek (at MC-10) to ensure that Licensee’s repairs

have reduced sedimentation into the creek below the dam. If elevated turbidity

(above Basin Plan level) is still occurring after five years, continue monitoring

for an additional five years until additional mitigations reduce turbidity to or

below Basin Plan level. If, before the end of five years, the Licensee proposes

and the USFS and other applicable conditioning agencies agree and approve

that Licensee’s erosion control repairs have effectively reduced sedimentation

and turbidity below the dam, then turbidity monitoring at this location can

cease.
E-13

 Implement “Best Management Practices” (BMP’s), or the most current USFS

regulations, within the Project and Project-affected area that will satisfy the

Aquatic Conservation Strategy Objectives within the Northwest Forest

Planning area, and mitigate impacts from:

o Project operation and maintenance activities;

o Project construction, reconstruction and repair of Project sites;

o Developed and dispersed recreation use;

o Road use, routine maintenance, reconstruction and repair;

o Vegetation manipulation;

o Prescribed fire and wildland fire planning, and fire suppression; and

o Watershed practices.

Condition No. 21 – Large Woody Debris

Within one year of license acceptance, Licensee shall, in consultation with the

USFS, CDF&G, SWRCB, potentially affected tribes, and other interested parties, prepare

a Large Woody Debris Plan approved by the USFS. The Plan shall include at a minimum

the components included in Exhibit LWDP, Draft Large Woody Debris Plan, referenced

by this condition, unless otherwise agreed to by the USFS during Plan finalization. The

Plan shall provide an operating procedure to facilitate the capture and removal of woody

debris from the surface of McCloud Reservoir, and the placement into the Lower

McCloud River downstream of McCloud Dam. The Plan will specify: (1) size criteria, (2)

storage and placement sites, (3) volume and frequency of placement, including

monitoring procedures that assess the mobilization of Large Woody Debris (LWD) from

the augmentation site. Upon Commission approval, Licensee shall implement the Plan.

Condition No. 22 – Erosion and Sediment Control and Management

Within one year of license acceptance, the Licensee shall file with the

Commission an Erosion and Sediment Control Management Plan developed in

consultation with Conditioning Agencies, and other interested parties, and approved by

the USFS that will provide direction for treating erosion and controlling sedimentation

within the Project and Project-affected NFS lands during the term of the new license.

Upon Commission approval, Licensee shall implement the Plan.

The Plan shall include at a minimum the components included in Exhibit ESCMP,

Draft Erosion and Sediment Control Management Plan, referenced by this condition,

unless otherwise agreed to by the USFS during Plan finalization. Minimum components

include, but may not be limited to:

Erosion Control Guidelines for Existing Project-Affected Areas

 Methods for initial and periodic inventory and monitoring of the entire

Project area and Project-affected NFS lands to identify erosion sites and
E-14

assess site condition for each, using protocols established in relicensing

study GS-S1 (Inventory and assessment of erosion and sediment from

Project Construction, Operation, and Maintenance, Technical Memo-67).

Periodic monitoring and inventory will include recording effectiveness of

erosion treatment measures, and identification of new erosion sites for the

term of the new license;

 Criteria for ranking and treating erosion sites including a risk rating and

hazard assessment for scheduling erosion treatment measures and

monitoring at each site using protocols developed in relicensing study GSS1;

 Erosion control measures that incorporate current standards, follow Forest

Service (USFS) regulations and guidance (e.g. LRMP, RMO’s, BMP’s ),

are customized to site-specific conditions, and approved by the USFS;

 Develop and implement a schedule for treatment (e.g. repair, mitigate,

monitor) of erosion sites, including a list of sites requiring immediate

mitigation and schedule for their implementation. Priority will be placed on

the 56 sites ranked as having high erosion potential in study results from

Inventory and Assessment of Erosion and Sediment from Project

Construction, Operation, and Maintenance (TM-67). All sites (high,

moderate and low priority, and any new sites added as a result of periodic

monitoring) will be scheduled as described in the Implementation Plan

(Exhibit ESCMP).

 Effectiveness monitoring of completed erosion control treatment measures

for a period of up to three years after treatment in order to determine if

further erosion control measures are needed;

 Protocols for emergency erosion and sediment control; and

 Process for documenting and reporting inventory and monitoring results

including periodic plan review and revision. Documentation shall include a

USFS compatible GIS database for maps keyed to a narrative description of

detailed, site-specific, erosion treatment measures and sediment monitoring

results.

Erosion Control Guidelines for New Construction or Non-Routine

Maintenance

Licensee shall develop site-specific temporary erosion control measures for each

project to be approved by the USFS. These temporary measures will prevent erosion,

stream sedimentation, dust, and soil mass movement during the period of ground

disturbance until replaced by permanent measures.
E-15

Condition No. 23 – Coarse Sediment Management Plan

Within one year of license acceptance, the Licensee shall develop, in consultation

with the USFS, Conditioning Agencies, and other interested parties, and file with the

Commission a Course Sediment Management Plan that is approved by the USFS. Upon

Commission approval, Licensee shall implement the Plan.

The Plan shall include at a minimum the components included in Exhibit CSMP,

Draft Coarse Sediment Management Plan, referenced by this condition, unless otherwise

agreed to by the USFS during Plan finalization.

This Plan shall require the periodic addition of between of 150 to 600 tonnes of

clean, rounded gravel, and associated coarse sediment ranging in size between 8-128 mm

to the Lower McCloud River directly below the McCloud Dam spillway splash pool. The

source of the coarse sediment will be coarse sediment deposits within McCloud

Reservoir. At a minimum, the Coarse Sediment Management Plan shall:

 Identify the source(s) of coarse sediment;

 Identify the location(s) for coarse sediment introduction, and the facilities or

improvements necessary for accessing the Lower McCloud River below

McCloud Dam;

 Identify coarse sediment storage sites;

 Develop a schedule for coarse sediment placement; and

 Include an adaptive management component to allow non-delivery of coarse

sediment in non-spill years or in years when spring flows are insufficient to

mobilize the sediment from the placement site(s) or increased delivery above

the minimum 150 tonnes if mobilization and dispersal monitoring results

indicate capacity for greater quantities of coarse sediment.

During the Annual Consultation Meeting required by USFS License Condition

No. 1, the USFS will review monitoring results and discuss any needed changes to the

Coarse Sediment Management Plan. Any proposed changes shall require USFS approval.

Condition No. 25 – Coarse Sediment Management Plan

Within one year of license acceptance, the Licensee shall complete, in consultation

with the USFS, appropriate County Agricultural Commissioner, California Department of

Food and Agriculture, potentially affected tribes, and other interested parties, and

approved by the USFS, a Vegetation and Invasive Weed Management Plan for all NFS

lands potentially affected by the Project. Targeted invasive species will be those species

defined by the California Department of Food and Agriculture (CDFA) code, the

California Invasive Plant Council (Cal-IPC) rating system, or as USFS species of

concern. The plan will address Special Status species, both aquatic and terrestrial

invasive species, and Revegetation Source populations within the Project boundary and
E-16

adjacent to Project features directly affecting NFS lands including roads, distribution and

transmission lines. Upon Commission approval, Licensee shall implement the plan.

The Plan shall include at a minimum the components included in Exhibit VIWMP

Draft Vegetation and Invasive Weed Management Plan (referenced by this condition),

unless otherwise agreed to by the USFS during Plan finalization. Minimum components

include, but may not be limited to:

 Protection of Special Status and Revegetation Source populations.

 Invasive Species Management and Monitoring, including an adaptive

management element to implement methods for prevention of aquatic invasive

weeds, as necessary.

 Revegetation Implementation and Monitoring.

 Treatment protocols for vegetation management and hazard reduction for

protection of Project facilities and Project-affected resources within the

project-affected area.

 Pesticide/herbicide use approval and restrictions.

 Botanical enhancements for specific special-status wildlife species.

Condition No. 26 – Terrestrial Biological Management and Monitoring

Within one year of license acceptance the Licensee shall develop, in consultation

with conditioning agencies, and other interested parties, and approved by the USFS, a

Terrestrial Biological Management and Monitoring Plan, including USFS special status

species (i.e. Forest Service Sensitive, survey and manage, and management indicator

species) and specific California special status (i.e. endangered or fully protected)

potentially affected by the Project on NFS lands. Upon Commission approval, Licensee

shall implement the plan.

To the extent possible, this plan should be developed consistent with the survey

protocol’s developed and included in the biological implementation plan’s from the

recently relicensed Pit 3, 4 & 5 Project (FERC No. 233) to provide similar data collection

protocol’s for species that span both hydroelectric Project area’s on adjacent NFS lands.

The Plan shall include at a minimum the component’s included in Exhibit TBMP

Draft Terrestrial Biological Management Plan (referenced by this condition), unless

otherwise agreed to by the USFS during Plan finalization. Minimum component’s shall

include, but may not be limited to:

 periodic survey’s (including pre-disturbance/pre-construction);

 occupation and population monitoring;

 species specific mitigation measures (including avian collision and

electrocution hazard prevention measures); and

 GIS mapping and reporting.
E-17

Surveys shall follow the most current standard protocols as reviewed and

approved by the USFS, or protocols collaboratively developed and approved by the

USFS if no standard protocols exist at the time. Licensee shall observe Limited Operating

Periods (LOP’s) where required (LOP’s do not apply to emergency situations). In the

event emergency response is necessary to address an unanticipated, Project-related event

(e.g. wildfire, dam breach, toxic spill) and with the potential to impact federally-listed

species and/or critical habitat, PG&E will work with FERC to initiate emergency

consultation with the USFWS as described in the Endangered Species Consultation

Handbook: Procedures for Conducting Consultation and Conference Activities Under

Section 7 of the Endangered Species Act (Handbook) (USFWS and NMFS 1998) or the

most current consultation protocol.

Species to be monitored include: terrestrial mollusks, shasta salamander, northwestern pond turtles, northern goshawk, bald eagles, peregrine falcon, northern spotted

owl, willow flycatcher, special status bats, neotropical birds, and forest carnivores.

Additional species may be added in the future if required by law or regulation, and

suitable habitat occurs within the Project or Project-affected area. Surveys for valley

elderberry longhorn beetle occur under the Vegetation and Invasive Weed Management

Plan and are habitat-only surveys.

Condition No. 27 – Aquatic Biologic Monitoring

Within one year of license acceptance, the Licensee shall develop, in consultation

with the USFS, State Water Resource Control Board, CDF&G, potentially affected tribes,

and other interested parties, and approved by the USFS, an Aquatic Biological

Monitoring Plan, including USFS special status species (i.e. Forest Service Sensitive,

survey and manage, and management indicator species) potentially affected by the

Project on NFS lands. Upon Commission approval, Licensee shall implement the Plan.

The Plan shall include at a minimum the components included in Exhibit ABMP,

Draft Aquatic Biological Monitoring Plan (referenced by this condition), unless

otherwise agreed to by the USFS during Plan finalization. Minimum components include,

but may not be limited to:

Fish population trend assessments in Iron Canyon Creek and the Lower McCloud

River with monitoring at specific intervals;

Standardized sampling and data protocols consistent with relicensing studies, to

the extent possible, to ensure comparability of survey results with existing data;

For Lower McCloud River and Iron Canyon Creek, periodic survey once every

three years for the first nine years following the first full year of the new License

required minimum instream flow, and then once every five years for the term of

the license. For

Pit 7 Reservoir, periodic survey once every five years following License

acceptance;
E-18

Benthic Macroinvertebrate (BMI) monitoring component using the SWAMP, or

current protocol, including population heterogeneity, composition and trends;

Aquatic special status species (northwestern pond turtles, Foothill yellow-legged

frog) protocol and schedule for monitoring within the Project waters and rivers;

Protocols to monitor for and prevent introduction of invasive aquatic species,

consistent with SWRCB and CDF&G regulations;

Report of all aquatic survey and monitoring results within one year of data

collection, with a Forest Service GIS compatible map that includes base data from

all post-licensing surveys; and

Periodic monitoring of fish passage conditions at Gap Creek, Deadlun Creek and

Cedar Salt Log Creek Road crossings around Iron Canyon Reservoir.

Condition No. 29 – Road and Transportation Facility Management Plan

Within one year of License acceptance, Licensee shall complete the Road and

Transportation Facility Management Plan for protection and maintenance of Project

Roads that are on or affect NFS lands. The Licensee shall consult with the USFS in the

finalization of this Plan, and the final Plan shall be approved by the USFS. Upon

Commission approval, Licensee shall implement the Plan.

The Plan shall include at a minimum the components included in Exhibit RTFMP,

Draft Road and Transportation Facility Management Plan (referenced by this condition),

unless otherwise agreed to by the USFS during Plan finalization. Minimum components

include, but may not be limited to:

Planning & Inventory: A map(s) compatible with USFS Travel Management

Routes and GIS database showing all Project Roads (shown in Table 1) and associated

road signs within, adjacent, or specific to the Project Boundary.

Operation, Maintenance, and Road-Associated Debris: An annual road

operation and maintenance (O&M) schedule for Project Roads that complies with USFS

standards, Road Management Objectives (RMO’s), Best Management Practices (BMP’s),

Limited Operating Periods (LOP’s), and USFS Travel Management Rule.

Construction and Reconstruction:

Construction and reconstruction implementation schedule to bring existing roads

and associated facilities into compliance with USFS standards (including RMO’s and the

USFS Travel Management Rule).

Monitoring: Conduct periodic traffic use surveys and periodic road capacity

reviews. If the Forest Service determines roads no longer meet the RMO’s, define actions

and timelines to correct deficiencies.

Road Use by Government: The United States shall have unrestricted use of any

road over which the Licensee has control within the Project area for all purposes deemed

necessary and desirable in connection with the protection, administration, management,
E-19

and utilization of NFS lands or resources. When needed for the protection,

administration, and management of NFS lands or resources the United States shall have

the right to extend rights and privileges for use of the right-of-way and road thereon, to

States and local subdivisions thereof, as well as to other users. The United States shall

control such use so as not to unreasonably interfere with the safety or security uses, or

cause the Licensee to bear a share of the costs disproportionate to the Licensee's use in

comparison to the use of the road by others.

Road Use by Licensee: The Licensee shall confine all vehicles being used for

Project purposes, including but not limited to administrative and transportation vehicles

and construction and inspection equipment, to roads or specifically designated access

routes. The Forest Service reserves the right to close any and all such routes where

damage is occurring to the soil or vegetation, or, if requested by Licensee, to require

reconstruction/construction by the Licensee to the extent needed to accommodate the

Licensee's use. The USFS agrees to provide notice to the Licensee and the Commission

prior to road closures, except in an emergency, in which case notice will be provided as

soon as practicable.

Table 1: Project Roads.

Road # Name Start End Miles USFS

RMO

38N11 Hawkins Creek Road

FA11 (Segment 1)

Siskiyou

MC1N01

Hawkins Creek Tunnel

Spoil Pile

14.25 4/3

38N81 Tarantula Gulch Boat

Launch Road

38N11 Ramp/parking 0.3 4

38N04Y Star City Road 38N11 Bridge 2.5 3

U38N11X McCloud Dam Road 38N11 Base of McCloud Dam 0.25 N/A

37N78 Iron Canyon Loop

Road

38N11 (Oak Mtn Rd) 37N34 8.54 3

37N27Y Deadlun CG 37N78 Campground 0.34 3

37N66Y Hawkins Landing

Road

38N11 Hawkins Boat Ramp 0.56 3

37N78A MC-10 gage Road 37N78 Low Level outlet and

gage

0.28 2

37N34 Oak Mountain Road 38N11 Pit 5 Bridge 7.71 3

37N93 Ridge Iron Canyon

Road

37N93A

37N93C

Oak Mountain Road 0.3 2

37N93A Ridge Road 37N93 pipeline 0.6 2

37N93C Willow Siphon 37N93 pipeline 0.5 2

Pit 6 PH Pit 6 Powerhouse Road Cove Rd. Pit 6 PH N/A

35N23 Pit 7 Powerhouse Road 34N17 Pit 7 Dam & PH 1.79 3

35N66 Fenders Flat Road 35N23 Afterbay Dam 0.57 3

Condition No. 30 – Road and Transportation Facility Management Plan

Within two years of license acceptance, Licensee shall complete the Recreation

Development and Management Plan in consultation with the USFS, conditioning
E-20

agencies, Native American representatives, and other interested parties, and approved by

the USFS, to address recreation resource needs associated with the Project. New and

reconstructed Project recreation facilities on NFS lands will be included in the Project

Boundary prior to ground disturbance, approved by the USFS and meet all USFS laws,

standards and policy, such as protecting sensitive resources (e.g. cultural, wildlife, etc.)

and meet USFS recreation design guidelines. Where design or site analysis constraints

preclude specific developments stipulated in this License Condition, the USFS will

review and approve modifications that meet the intent of this Condition. Upon

Commission approval, Licensee shall implement the Plan.

The Plan shall include at a minimum the components included in Exhibit RDMP,

Draft Recreation Development and Management Plan (referenced by this condition),

unless otherwise agreed to by the USFS during Plan finalization. Minimum components

include, but may not be limited to:

Operation and Maintenance: Develop and implement an Operation and

Maintenance (O&M) component (including fee collection and retention) for all Project

recreation facilities. Recognizing that the existing health and safety conditions at some of

the Project recreation facilities are the result of previous operation and maintenance

practices, Licensee will not be held responsible for the conditions of the Project

recreation facilities until they are reconstructed.

Recreation Survey and Monitoring: Develop and implement a periodic

Recreation Survey and Monitoring component with Report that is filed with the

Commission after USFS approval.

Project Patrol: Develop and implement a Project Patrol Plan for Project and

Project-affected NFS lands. Annually, the Licensee shall coordinate with the agencies

and interested parties to review information from the prior season and plan any

adjustments for the next high use season (April through November). This position may be

either a Licensee employee, or equivalent funding provided to an appropriate Federal,

State, or local agency. This component shall outline duties to implement on a year-round

basis. The Plan shall include at a minimum the components included in Exhibit PPP Draft

Project Patrol Plan (referenced by this condition), unless otherwise agreed to by the

USFS during Plan finalization.

Reservoir Water Surface Management: Develop and implement a Reservoir

Water Surface Management component that addresses recreation user safety (including

surface debris capture), discourages travel onto adjacent private lands, and displays

County code and contact information to Project users on each Reservoir surface

(McCloud, Iron Canyon, Pit 6 and Pit 7).

McCloud Reservoir Facilities: Construct day use areas at Tarantula Gulch inlet,

Red Banks and Star City Creek (including surfaced parking, and vault toilets), and lake

access sites at Battle Creek and both sides of McCloud Dam (including surfaced parking

and trail). Reconstruct Tarantula Gulch Boat Ramp to Cal Boating standards for a 2-lane
E-21

ramp with boarding dock and sidewalk. Licensee shall acquire rights, by any means

necessary, but not including by condemnation pursuant to Section 21 of the Federal

Power Act or any other law, for the purpose of overnight public recreational use, a

portion of the Star City Creek parcel located in the SE 1⁄4 of Section 15, Township 38

North, Range 2 West, M.D.B.M. (included as a portion of APN’s 015-040-035, 015-190-

002). After acquisition, Licensee will construct overnight camping facility (including

parking, vault toilet, and a minimum 50 PAOT capacity) at Star City. If Star City cannot

be acquired as described above, Licensee shall instead construct overnight camping

facilities on NFS lands near Tarantula Gulch within the Project boundary.

Lower McCloud River: Construct a Day Use Area with trail at the base of

McCloud Dam. Trail shall be designed to accommodate both fishing and boating access.

Trail access could be by road, if developed for other needs. If McCloud Dam site is

infeasible due to operational constraints, develop facilities at Ash Camp Campground and

include in Project boundary or Settlement Agreement.

Iron Canyon Reservoir: Construct a single lane boat ramp with boarding dock to

Cal Boating standards at Iron Canyon Dam. Provide a minimum of total 200 PAOT’s for

overnight camping around Reservoir. Reconstruct Hawkins Campground to existing

capacity. Reconstruct Hawkins Landing Boat Launch and construct parking area.

Reconstruct Deadlun Campground to provide for double and triple campsites. Construct

new campground at Gap Creek site for single unit sites. Construct three additional lake

access sites (including surfaced parking and trail to Reservoir) around the shoreline of

Iron Canyon Reservoir.

Pit 6 and Pit 7 Reservoirs and Afterbay: Develop two surfaced parking areas

with Reservoir access trails (approx. 1 mile apart) below Pit 6 Dam to provide fishing

access and boating put-in onto the upper Pit 7 Reservoir. Develop road access to a

surfaced parking area and short walkway to put-in/take-out onto the lower Pit 7

Reservoir, either at Montgomery Creek or near the Pit 7 Dam.

Licensee shall investigate known safety and public access issues at the Pit 7

Afterbay Dam (with or without the proposed new hydroelectric generation facility at the

Pit 7 Afterbay Dam). This analysis will develop alternatives to address safety while

considering current and needed public access in this flat and easily accessible location

adjacent to the Pit River. Alternatives may include safety items collaboratively developed

and implemented (e.g. reinforced fencing, patrols, signs, physical barriers, information on

safety hazards, including website information) by the Licensee under the existing license

between the time of Final 4(e) Condition filing and license acceptance. Alternatives will

include hydrologic analysis that may result in structural modification or relocation, public

use data, and other pertinent existing literature. Each alternative will include a cost

estimate for comparison purposes. Implement a solution after consultation with the Forest

Service, other Conditioning Agencies, and approved by the Forest Service and FERC.
E-22

Re-construct the car-top boat launch at the current Pit 7 Afterbay Dam location,

and construct a day use area near the reservoir high-water line in the vicinity of the boat

launch.

Condition No. 31 – Sign and Interpretive/Education Management Plan

Within two years of license acceptance, the Licensee shall complete, in

consultation with and approved by the USFS, a Sign and Interpretive/Education (S&I/E)

Plan for all non-traffic signs within the Project. This includes existing signs potentially

affected by the Project, and new signs at Project locations on NFS lands where

interpretation or information would support or enhance visitor experiences. Upon

Commission approval, Licensee shall implement the plan.

The Plan shall include at a minimum the components included in Exhibit SIEMP,

Draft Sign and Interpretive/Education Management Plan (referenced by this condition),

unless otherwise agreed to by the USFS during Plan finalization. Minimum components

include, but may not be limited to:

 Inventory of all existing informational, FERC, safety, directional, recreation,

interpretive and education (all non-road or traffic) signs within the Project

Area or associated with Project facilities

 Collaborative development of standards, designs, and locations for all ProjectRelated Signs (existing and new), including web media.

 Protocols for installing, maintaining, and monitoring Project-Related Signs for

the life of the license.

Condition No. 32 – Visual Quality Management

Within one year of License acceptance, Licensee shall develop, for USFS approval

and filing with the Commission, tasks and timeline, to assure implementation of specific

mitigation measures to provide for improved visual quality of Project and Projectaffected NFS lands. Upon Commission approval, Licensee shall implement the

mitigations.

The mitigations shall include, at a minimum, the components included in Exhibit

VQM, Draft Visual Quality Management (referenced by this condition), unless otherwise

agreed to by the USFS during Plan finalization. Minimum components include, but may

not be limited to:

 Operation and Maintenance activities at existing facilities

 Reconstruction or repair of existing facilities

 Construction of new facilities

 Key Observation Point (KOP) Monitoring
E-23

Condition No. 33 – Fire and Fuels Management Plan

Within one year of license acceptance, the Licensee shall complete, in consultation

with the USFS, Cal Fire, potentially affected Tribes, and other interested parties, and

approved by the USFS, a Fire and Fuels Management Plan (FFMP). The plan shall set

forth in detail the Licensee’s responsibility for the prevention (including fuels treatment),

reporting, emergency response, and investigation of fires related to Project operations.

Upon Commission approval, Licensee shall implement the Plan.

The Plan shall include at a minimum the components included in Exhibit FFMP,

Draft Fire and Fuels Management Plan (referenced by this condition), unless otherwise

agreed to by the USFS during Plan finalization. Minimum components include, but may

not be limited to:

 Fuels Treatment

 Prevention and Response

 Access and Safety

 Emergency Response Preparedness

 Reporting and Response

 Investigation of Project Related Fires

 Post-Fire activities

Condition No. 34 – Historic Properties Management and Monitoring

Within one year of license acceptance, Licensee shall file with the Commission a

Historic Properties Management Plan (HPMP) that has been amended from the October

26, 2010 version, incorporates collaborative input from the Forest Service, Licensee, and

potentially affected Tribes, and is approved by the Forest Service. The Forest Service will

consider this filing of the HPMP as the final. The HPMP will be tiered to an anticipated

Programmatic Agreement (PA), to which the Forest Service has requested to be a

signatory, as defined by 36 CFR 800, and implements regulations of the National Historic

Preservation Act. The Licensee shall consult with the State Historic Preservation Officer

(SHPO), applicable Native American Tribes, Forest Service, and other applicable

agencies during the finalization of the HPMP. Consultation for the finalization of the

HPMP shall consist of field (as appropriate) and office meetings.

The final HPMP shall include, but is not limited to:

1. Integrate CR-S1 and CR-S2 study results into individual reports (in

confidential appendices to the HPMP) for the Pit River and Winnemem

Wintu Tribes. CR-S2 results are available for the Pit River Tribe, but are at

an impasse for the Winnemem Wintu Tribe. If the current CR-S2

ethnographic Winnemem Wintu study is not completed prior to HPMP

finalization (i.e. within one year of license acceptance) the Final HPMP

will instead incorporate currently available data. Sources of these data
E-24

should include, but are not limited to: the Harrington notes, research by:

McTavish, Kardell/Dotta, Thoedoratus, Bauman, Curtin, and Merriam, and

historic maps. If the Winnemem Wintu CR-S2 study component is

completed after HPMP finalization, the HPMP will be revised or amended

at that time.

2. A detailed table and description defining the schedule for site monitoring

and HPMP implementation, including: reports, revisions, consultation, sitespecific treatment measures, and others.

3. For Iron Canyon Reservoir, complete National Register evaluations, in

accordance with the Commission’s August 27, 2010 directive, within one

year of license acceptance, on all cultural resources on NFS lands that are

currently, or in the future will be, adversely affected by Project-related

erosion (including frequent and large magnitude reservoir fluctuations),

siltation, and site exposure that could induce looting. Where sites have been

affected, consultation with the Commission, SHPO, Forest Service, and

Tribes shall occur to determine if any evaluations may require

archaeological test excavation. In addition for sites determined eligible,

perform monitoring, on a frequency to be developed during collaborative

discussion.

4. The Forest Service has determined current Project affects to historic

properties have not been entirely acknowledged in the HPMP. To correct

this, collaboratively develop site-specific detailed mitigation measures for

adverse effects from Project operations on historic properties.

5. The Forest Service believes there is merit for consideration of a historic

district along the APE for the Lower McCloud River. The HPMP shall

complete an in-depth analysis to determine if there is compelling evidence

for a historic archaeological and ethnographic district. This analysis shall

cross-walk ethnographic sources (Item 1, above) with archaeological site

data.

If, prior to, or during ground-disturbing activities, or as a result of Project

operations, items of a potential cultural, historical, archeological, or paleontological

character are reported or discovered, or a known deposit of such items is disturbed on

NFS lands or on Licensee’s adjoining fee title property when such properties extend onto

NFS lands, the Licensee shall immediately cease work in the area so affected. The

Licensee shall then notify the Forest Service and shall not resume work on grounddisturbing activity until it receives written approval from the Forest Service. If it deems it

necessary, the Forest Service may require the Licensee to perform recovery, excavation,

and preservation of the site and its artifacts at the Licensee's expense through provisions

of an Archaeological Resources Protection Act permit issued by the Forest Service. The

Licensee shall implement the Plan upon approval by the Commission.