OCRed excerpt from ENVIRONMENTAL ASSESSMENT FOR HYDROPOWER LICENSE, Kern River No. 3 Hydroelectric Project, FERC Project No. 2290, California.
Comments must be postmarked no later than November 22, 1996 to be considered. Comments should be directed to:
Forest Supervisor
Attn: Erik Ostly
Sequoia National Forest
900 West Grand Avenue
Porterville, CA 93257-2035
(This transcribed document may contain errors not found in the original document.)
b. Environmental Impacts and Recommendations
i. Whitewater boating
Chute/portage: Both the AWA (letter from Richard Bowers, American Whitewater Affiliation, Silver Spring, Maryland, February 28, 1992) and the KRO (letter from C.E. McGraw, Attorney for the Kern River Outfitters, March 1, 1992) requested that Edison undertake a feasibility analysis for a structure (chute, ramp, or bypass) that would enable boaters to float past Fairview Dam. This structure would allow boaters to continue from the Limestone run (upstream of Fairview Dam) to the Fairview run, thereby providing a continuous whitewater run of 22 miles. The KRO also requested that a feasibility analysis be conducted for a portage around the dam.
Edison conducted a conceptual design and feasibility evaluation of a boating chute and portage at Fairview Dam (Taggart, 1993). The evaluation determined that a whitewater bypass with portage is feasible, though expensive. Edison's report concludes that a bypass would require modification of the river channel at Sidewinder and Bombs Away rapids for safety and liability reasons. It is the report's opinion that any bypass plan should also include an extensive portage route around Fairview Dam, Sidewinder rapid, and Bombs Away rapid.
Edison's report also evaluates a portage plan without a whitewater bypass but does not recommend it for liability and safety reasons. The proposed design would portage past Sidewinder and Bombs Away rapids. The report contends that, once boaters portage the dam, they would be enticed to enter the river upstream of Sidewinder and Bombs Away rapids rather than undergo the longer portage around them. Because of their degree of difficulty, Edison believes that running these rapids could prove potentially hazardous to some boaters (Taggart, 1993). In the DEA, we concluded that the extensive bypass system described by Edison, including modification of the river channel, would not be appropriate or consistent with the river's wild and scenic values.
In its draft final Section 4(e) conditions, the FS recommends construction of a simplified, low-impact portage around Fairview Dam to enhance the rafting experience (letter from G. Lynn Sprague, Regional Forester, Pacific Southwest Region, U.S. Forest Service, San Francisco, California, September 21, 1994; fax from Erik T. Ostly, Sequoia National Forest, California, November 29, 1995). Boaters wanting to portage the dam would avoid a potentially hazardous walk along the roadway or the effort involved with a car shuttle. The FS recommends that the portage be designed for minimal impacts to the site, be small in scope, and blend with the surrounding landscape to be consistent with the NFKR's outstandingly remarkable wild and scenic values. The FS suggests that the portage begin at the sandbar above the dam to the west, go over/around the dam near the fish ladder, and meet the river channel at the sandbar below the dam on the west side of the river (above Sidewinder rapid).
The FS believes that a portage would provide benefits to commercial outfitters and private boaters by allowing them the flexibility to continue past Fairview Dam without having to take out above the dam, shuttle equipment by car, and put in below the dam. As long as the portage was designed to be small in scale and have minimal impact, the FS believes that a portage would provide appropriate benefits to skilled boaters seeking a more challenging experience, without the traffic hazards and effort now required to continue boating past Fairview Dam.
In the DEA, we concluded that, although both Sidewinder and Bombs Away rapids are runnable, their degree of difficulty would require boaters to be at a very advanced level to negotiate them. A number of DEA reviewers disagreed with the characterization of these two rapids as Class V difficulty, contending that they are Class IV at most water levels and, even at high flows, are within the range of overall difficulty of the rapids in the NFKR (letter from Bruce A. Ray, Attorney for the Kernville Chamber of Commerce and the Kern River Valley Community Consensus Council, May 18, 1995; letter from Richard J. Bowers, American Whitewater Affiliation, Margaret Bowman, American Rivers, Chuck Richards, Kern River Outfitters, and Dave Brown, America Outdoors, May 12, 1995; letter from Mark Thomas and Katharine Haines, Kern River Alliance, May 15, 1995). Regardless of whether these rapids are Class IV or V, we believe that most boaters entering the portage from the upstream Limestone run would be at a very advanced level since that run is also rated Class IV or V, depending on flow levels (Cassady and Calhoun, 1990).
We agree with a number of DEA reviewers who commented that inadequate parking a the take-out and put-in points causes traffic congestion and, consequently, a hazard to pedestrians. These reviewers also favor a portage because it would restore navigation along the river.
Construction of the FS-recommended portage would be feasible but could be difficult and costly due to the juxtaposition of the dam, fish ladder, and the adjoining rock ledge. However, for safety reasons and to enhance recreational opportunities on the NFKR, we are recommending a simplified, low-impact portage at Fairview Dam. We envision that the final design process would evaluate the lowest impact alternative, such as a trail around the dam on the adjacent hillside. This alternate route could prove to be less intrusive and costly than an elevated structure over or around the dam and fish ladder.
Flow releases: AWA, KRO, the FS, and the California Department of Boating and Waterways requested that Edison examine flows in the bypassed reach for their suitability for various types of whitewater recreation and the trade-offs of providing supplemental flows. Edison conducted a field evaluation to determine the minimum boatable flows in the bypassed reach, as well as flow levels that would provide higher quality whitewater opportunities. Runs in the bypassed reach were boated by various craft, including kayaks, canoes, inflatable kayaks, rafts (paddle and oar), and catarafts.
Our analysis of Edison's test results indicates that minimum boatable flows for most craft on most of the runs were 700 cfs or less. At 1,100 cfs, all of the craft experienced enjoyable runs, except for oar rigs/catarafts on Thunder run. At 1,200 cfs, most of the craft on most of the runs were experiencing near the lower end of an optimal boating experience.
To maximize future whitewater recreation, the AWA and KRO recommend the following flow management scenario for the NFKR bypassed reach (letter from Richard Bowers, American Whitewater Affiliation, Silver Spring, Maryland, October 3, 1994).
These recommended restrictions on diversion for power production would apply year-round. The upper bound of 1,400 cfs is recommended by AWA and KRO as optimum for raft passage and most suitable for creating repeat commercial customers. This proposal would maximize whitewater boating opportunities but, compared to existing conditions, would adversely affect fishing opportunities in the river because of the duration and magnitude of higher flows.
In an average year (1979), the supplemental whitewater flow releases recommended by AWA and KRO would increase the number of whitewater boating days from 55 days under current operations to 116 days (61 days of additional whitewater boating opportunities). About 18 of the additional days would occur on weekends and holidays. In addition, about 31 days of boating that would have occurred under current operations would receive noticeably elevated flow levels, with an additional 359 cfs during those days in an average year. These days would see the quality of the boating experience improve, allow a greater diversity of craft, and open up more of the bypassed reach to boating opportunities.
The AWA/KRO-recommended flow schedule provides the most benefit to boating when flows in the NFKR are higher than average. During these wet years, the AWA/KRO proposal would increase the number of whitewater boating days from 188 days under current operations to 252 days (64 additional boating days). In addition, about 71 days of boating that would have occurred under current operations would receive noticeably elevated flow levels, with an additional 250 cfs during those days. During dry years, the AWA/KRO proposal would increase the number of whitewater boating days from no days under current operations to 10 days, with no additional days experiencing elevated flows.
Under the flow schedule proposed by AWA and KRO, the bypassed reach would receive most of the river's flow, with very little water being diverted to the powerhouse. Power generation would nearly cease during most of the year because, for two- thirds of the year, flows rarely exceed 1,400 cfs. We do not consider a proposal that maximizes a single recreational use at the expense of other beneficial uses or resources to be a good balance of resources (see section VII.B.l.b).
Any provision for increasing flows for boating may adversely affect the fishery and popular fishing opportunities on the NFKR. Rapid increases in flow may move young fish downstream to less suitable habitat. The ramping constraints recommended in section V.C.3.b.iv would reduce the magnitude of this impact. Frequent high flows may adversely affect recreational fishing because wading opportunities would diminish and catch rates would likely be reduced because of the more turbulent and swifter water in the channel. However, a variety of factors limit trout production in the bypassed reach, and it is unlikely that occasional flow increases would substantially affect the fishery or recreational fishing. Nevertheless, providing whitewater boating flows would potentially cause minor adverse effects on trout recruitment and recreational fishing. The degree of these effects would depend on the frequency and magnitude at which flows are provided and on recreational fishing use patterns.
In its draft final Section 4(e) conditions, the FS recommends a supplemental whitewater flow release to the NFKR bypassed reach of 700 to 1,100 cfs to enhance whitewater boating (fax from Erik T. Ostly, Sequoia National Forest, California, November 29, 1995). The recommended flow schedule would be in effect each day from May 15 through July 15. During these months, Edison could divert all flows below 700 cfs and above 1,100 cfs, less MIF requirements, for power generation. The FS's draft final Section 4(e) conditions also recommend a 35-cfs flow allotment for the CDFG fish hatchery (25 cfs) and to allow for minimum power generation (see section V.C.3.b.iii).
The FS indicates that, during the boating season, heavy holiday and weekend recreational use on the NFKR has resulted in some overcrowding and congestion. This situation has led the FS to implement private boating use restrictions in the past, and the FS has indicated that restrictions may be reinstated in the future if warranted. The FS recommends its supplemental whitewater flow schedule on the basis that weekday supplemental flows would alleviate some of this weekend crowding and congestion on the NFKR. The FS suggests that commercial outfitters could potentially develop marketing and pricing incentives to attract users to the weekday supplemental flows. The FS also suggests that private boating use restrictions could be used to shift use patterns toward weekdays.
The FS's goal is to provide supplemental flows during the entire week in an attempt to balance boating uses with other recreational uses of the river. The FS believes that having only weekend supplemental flows would exacerbate the potential for conflicts between user groups, increase traffic and congestion, and degrade the recreational experience on weekends.
We agree with the FS's goal of shifting recreational use to weekdays, and we recognize that the FS's proposal has potential to shift some use to weekdays. However, we are not convinced that weekday supplemental flows, as proposed by the FS, would appreciably shift river use away from peak season weekends. Currently, boatable flows are just as likely to occur on a weekday as they are on a weekend; however, weekend use levels are much higher than weekday use. Weekday supplemental flows would provide some benefit to local boaters that could boat during the week, but the majority of boaters would not derive benefits from the higher weekday flows.
The FS believes that supplemental flows provided during the early season (April and early May) would not provide much benefit to boating on the NFKR because the colder weather and water temperatures would deter use. The FS gives as an example the Forks of the Kern run, which receives early season boatable flows but is most desirable to boaters in the summer months when southern Californians try to escape the heat. The FS believes this is a major motivation for recreational use of the NFKR.
Given the relatively warm daytime temperatures in southern California in April and early May and the fact that boating occurs during these months in areas where weather is much cooler (such as the Rocky Mountain States), the FS's concern with early season weather and water temperatures deterring boating use may not be valid. This conclusion is supported by comments on the DEA and by the underlying assumption of the AWA and KRO year- round flow proposal.
In an average year (1979), the supplemental whitewater flow releases recommended by the FS would increase the number of whitewater boating days from 55 days under current operations to 75 days (20 days of additional whitewater boating opportunities). About- 5 of the additional days would occur on weekends and holidays. In addition, about 3 days of boating that would have occurred under current operations would receive noticeably elevated flow levels, with an additional 250 cfs during those days in an average year. These days would see the quality of the boating experience improve, allow a greater diversity of craft, and open up more of the bypassed reach to boating opportunities. These flow enhancement days would occur from May 15 through July 15.
Because the FS proposal is for only a narrow 2-month period, valuable weekend boating opportunities are missed during both the early part of the boating season (April and early May), and the late part of the boating season (late July and August), when both weather and available water could provide high quality whitewater boating. Therefore, we developed an alternative proposal for enhancing whitewater boating opportunities. Our alternative is similar to the FS recommendation but is restricted to weekends and holidays and would be in effect for a much longer period of time.
Under our alternative, Edison would divert only 35 cfs when flows above Fairview Dam are between 735 cfs and 1,135 cfs. The 35-cfs flow would accommodate a flow allotment for the CDFG fish hatchery (25 cfs) and allow for minimum power generation (see section V.C.3.b.iii). The net result of diverting this 35 cfs would be flows of between 700 cfs and 1,100 cfs in the bypassed reach. Edison would be able to utilize any flows above the net 1,100 cfs at Fairview Dam for power generation. Flows below the net 700 cfs could be utilized by Edison for power generation, less MIF requirements.
We established 1,100 cfs as the maximum whitewater boating supplemental flow by analyzing the incremental benefits to boating opportunities that would be provided by different flow levels. Higher flows would provide enhanced boating experiences for some types of craft at some runs, but, beyond 1,100 cfs, there are diminishing returns. Therefore, we selected 1,100 cfs as the appropriate balance between using NFKR flows to enhance whitewater boating opportunities and diverting the water for power generation.
Our alternative would require Edison to provide supplemental flows in the bypassed reach only on weekends and holidays during April through August. The hydrograph of the NFKR is such that boatable flows are usually available from April through August. We conclude that taking advantage of these flows to provide early and late season boating would provide greater benefits to NFKR boating than could be gained by releasing weekday flows that for the average recreationist are more difficult to utilize. Our proposal, which would start supplementing flows with early season runoff and continue later in the season, provides some potential for a desirable shift in use patterns. Supplemental flows on weekends throughout a longer boating season could entice people to boat earlier or later in the season, thereby reducing weekend crowds during a shorter boating season and relieving some peak summer use pressures.
In an average year, this enhancement measure would increase the number of whitewater boating days from 55 days under current operations to 69 days (an additional 14 days of whitewater boating opportunities). In addition, about 6 days of boating that would have occurred under current operations would receive elevated flow levels, with an additional 240 cfs during those days in an average year. These days would see the quality of the boating experience improve, allow a greater diversity of craft, and would open up more of the bypassed reach to boating opportunities.
Even though the FS proposal would produce a greater number of additional boating days, our schedule would, in an average year, provide nearly three times as many additional weekend boating days. We consider weekend boating days to be of primary importance in providing the most benefit for whitewater boating opportunities.
The FS flow schedule provides more benefit to boating in years when flows in the NFKR are about average than in years when flows are above or below average. This is because flows in wet years typically exceed the upper bound, and flows in dry years are usually below the lower bound. During wet years, the FS proposal would provide no additional boating days compared with current operations. During dry years, the FS proposal would provide about 6 additional boating weekdays and 2 additional weekend days compared with current operations. Likewise, our flow schedule provides more benefit to boating in average flow years than in years when flows are above or below average. Our proposal would provide no additional boating days during wet years and only 2 additional days during dry years compared with current operations.
There would be potential adverse impacts to fishing opportunities with any proposal that periodically increases flows in the river. Flow levels would fluctuate from above the upper limit to below the lower limit under both the FS and our supplemental flow schedules during the spring runoff. It is difficult to determine which proposed supplemental flow schedule would have the greatest impact on the fishery and fishing opportunities.
In the DEA, we concluded that our recommended weekend supplemental flows during spring and summer provide the best overall recreation enhancement for the NFKR. Our flow schedule would substantially enhance whitewater boating opportunities with minimal impacts to other resources and power generation. However, although our independent analysis does not fully support the FS's recommendation, we are recommending the FS's supplemental whitewater flow schedule, consistent with Section 4(e) of the FPA.
Channel reconfiguration: The FS recommends that we examine the feasibility of moving some rocks within the stream in order to improve navigability (letter from G. Lynn Sprague, Regional Forester, Pacific Southwest Region, U.S. Forest Service, San Francisco, California, September 21, 1994). In the DEA, we concluded that, although it is feasible to reposition rocks within the river channel, such action would not be consistent with the wild and scenic qualities of the river. In its comments on the DEA, the FS states that moving rocks within the stream may be consistent with wild and scenic river values, depending on how the modification is done (letter from Del A. Pengilly, Acting Forest Supervisor, Sequoia National Forest, California, May 10, 1995). Nevertheless, the rapids below Fairview Dam are no more difficult than many other rapids in the NFKR, and we see no need to improve navigability in this reach any more than in the other reaches. Furthermore, moving the rocks would diminish the rapids' difficult character and, consequently, reduce the quality of the recreational experience for those advanced boaters who would choose to run them. Therefore, we do not believe that channel modification is necessary or desirable for a quality boating experience in this river reach, and we are not recommending such action.
Put-ins/take-outs: Edison is proposing to improve the existing whitewater boating take-out and put-in facilities at the Thunderbird Dispersed Camping Area. This would include installing an identifying sign, improving the parking lot grade, and applying gravel to the surface. The FS includes this measure in its draft final Section 4(e) conditions.
The FS Comprehensive Management Plan for the North and South Forks of the Kern Wild and Scenic River (CMP) identifies several management actions that will be implemented for recreation enhancement. In the CMP, there are plans to expand the Willow Point take-out, Fairview put-in, and Camp 3 put-in; improve the Ant Canyon put-in; and construct new launch and take-out sites at key locations on the Upper Kern run. According to the CNP, implementation of these improvements is expected to begin soon.
Improving the take-out and put-in facilities at the Thunderbird Dispersed Camping Area would enhance boating access in the project area and is consistent with the objectives of the CMP. We recommend that Edison implement its plans to improve the Thunderbird put-in and take-out facilities.