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HomeMy WebLinkAboutG11b-encl_1_pad_comments_07_15 CROOKED CREEK AND JIM’S LAKE HYDROELECTRIC PROJECT FERC No. P-14514 USDA FOREST SERVICE COMMENTS AND STUDY REQUESTS On the PRE-APPLICATION DOCUMENT For FERC TRADITIONAL LICENSING PROCESS July 2015 Forest Service PAD Comments & Study Requests Page 2 of 14 Crooked Creek and Jim’s Lake Hydroelectric Project FERC No. P-14514 07/06/2015 Part 1 – Related Plans and Forest Service Involvement I Applicable Comprehensive Plans, Laws and Orders 2008 Tongass Land and Resource Management Plan (Forest Plan) The entire project, except a portion of the transmission line, lies within the boundaries of the Tongass National Forest. Crooked Creek, Jim’s Lake and most of the transmission line routes are under the jurisdiction of the Tongass National Forest. The Forest Plan guides all natural resource management activities and establishes management standards and guidelines according to the Land Use Designation. It describes resource management practices, levels of resource protection and management, and the availability and suitability of lands for different kinds of resource management. According to the Forest Plan the Crooked Creek and Jim’s Lake Hydroelectric Project is within the Semi-Remote Recreation land use designation (LUD). This is described in greater detail in Part 2, Comments to the PAD, of this document. You can find the Forest Plan and associated appendices online at: http://www.fs.usda.gov/detail/tongass/landmanagement/planning/?cid=stelprdb5402695 References to Resource Goals and Objectives and Standards and Guidelines can be found in this document. The Forest Plan and Final Environmental Impact Statement (FEIS) provide the basis and essential clarification for Forest Service study requests. Applicable Laws and Executive Orders Shown below is a partial list of federal laws and executive orders pertaining to project-specific planning and environmental analysis on federal lands. While most pertain to all federal lands, some of the laws are specific to Alaska. • Multiple-Use Sustained-Yield Act of 1960 • National Historic Preservation Act of 1966 (as amended) • Wild and Scenic Rivers Act of 1968, amended 1986 • National Environmental Policy Act (NEPA) of 1969 (as amended) • Clean Air Act of 1970 (as amended) • Alaska Native Claims Settlement Act (ANCSA) of 1971 • Marine Mammal Protection Act of 1972 • Endangered Species Act (ESA) of 1973 (as amended) • Forest and Rangeland Renewable Resources Planning Act (RPA) of 1974 (as amended) • National Forest Management Act (NFMA) of 1976 (as amended) • Clean Water Act of 1977 (as amended) • American Indian Religious Freedom Act of 1978 • Alaska Native Interest Lands Conservation Act (ANILCA) of 1980 • Archeological Resource Protection Act of 1980 Forest Service PAD Comments & Study Requests Page 3 of 14 Crooked Creek and Jim’s Lake Hydroelectric Project FERC No. P-14514 07/06/2015 • Cave Resource Protection Act of 1988 • Tongass Timber Reform Act (TTRA) of 1990 • Native American Graves Protection and Repatriation Act (NAGPRA) of 1990 • Magnuson-Stevens Fishery Conservation and Management Act of 1996 (Essential Fish Habitat) • Executive Order 11593 (cultural resources) • Executive Order 11988 (floodplains) • Executive Order 11990 (wetlands) • Executive Order 12898 (environmental justice) • Executive Order 12962 (aquatic systems and recreational fisheries) • Executive Order 13007 (Indian sacred sites) • Executive Order 13112 (invasive species) • Executive Order 13175 (consultation and coordination with Indian Tribal Governments) • Executive Order 13287 (migratory birds) Forest Service PAD Comments & Study Requests Page 4 of 14 Crooked Creek and Jim’s Lake Hydroelectric Project FERC No. P-14514 07/06/2015 Part 2 – Comments to the Preliminary Application Document In our review of the Preliminary Application Document (PAD), we looked for the information listed in 18 CFR §16.8(b)(2): (i) Detailed maps showing existing project boundaries, if any, proper land descriptions of the entire project area by township, range, and section, as well as by state, county, river, river mile, and closest town, and also showing the specific location of all existing and proposed project facilities, including roads, transmission lines, and any other appurtenant facilities; (ii) A general engineering design of the existing project and any proposed changes, with a description of any existing or proposed diversion of a stream through a canal or a penstock; (iii) A summary of the existing operational mode of the project and any proposed changes; (iv) Identification of the environment affected or to be affected, the significant resources present and the applicant’s existing and proposed environmental protection, mitigation, and enhancement plans, to the extent known at that time; (v) Streamflow and water regime information, both existing and proposed, including drainage area, natural flow periodicity, monthly flow rates and durations, mean flow figures illustrating the mean daily streamflow curve for each month of the year at the point of diversion or impoundment, with location of the stream gauging station, the method used to generate the streamflow data provided, and copies of all records used to derive the flow data used in the applicant’s engineering calculations; (vi) Detailed description of any proposed studies and the proposed methodologies to be employed. (vii) Any statement required by 4.301(a) of this chapter. Forest Service comments to the PAD were provided to the applicant along with a signed cover letter on April 14, 2015. The same comments, and a few additional comments and requests, are included in Part 2. Project Timeline The timeline is ambitious. We are concerned that the applicant cannot complete any required studies between July 14, 2015, and October 12, 2015.   Project Description Only the siphon intake configuration is described and no process is identified on how to decide on a final configuration based upon technical, economic, environmental, and other pertinent factors. Table 2.3-1: depicts a total available storage volume of 43 acre feet based on a siphon intake. The table does not make clear that the siphon configuration would have a net storage capacity of 43 acre feet (67 ac ft. gross storage capacity) contrasted to the dam configuration having a net storage capacity of 67 acre feet (133 ac ft. gross capacity). Each of these is based on drawing down only the top eight feet of storage capacity. Because only one configuration is depicted, Table 2.3-2 displays excess production (kWh) during the Forest Service PAD Comments & Study Requests Page 5 of 14 Crooked Creek and Jim’s Lake Hydroelectric Project FERC No. P-14514 07/06/2015 economically crucial months of June through August as only 12,000, 6,100, and 10,500 kWh respectively. Most important, Figure 2.3-1 based on current utility demand, indicates that about every other year the community would need to meet demand with energy supplied from diesel. Clear depiction of the dam configuration is needed to evaluate the economic impact of the project. Likewise without going into additional detail, the technical, environmental, and other pertinent factors cannot be part of the consultation process without both configurations being part of the detailed project description. If the two configurations are viable action alternatives they would need to both be fully scoped and analyzed in the planning and consultation process. The PAD states that the transmission line would be underground where feasible but no detail is provided about the standard for feasibility. No alternatives to underground installation are described. Under or above ground transmission line installation makes a difference to effects on resources. Please provide plans for installation of transmission line. Existing environment and resource impacts Geology, topography, and soils Geology The geology of the project area suggests it is subject to geologically regular and recent mass wasting events. A geologist should analyze for potential adverse impacts and issues related to such an event on project improvements and operations. What proposed resource measures could protect or mitigate against adverse impacts? Topography The applicant should provide a complete topographic survey of the Jim’s lake shoreline and upland area as a basis for evaluating the retention of water in the basin, given the estimated eight feet rise of the lake for a dam and gravity intake system. Soils Any studies to design access trails should address the ‘feasibility’ of underground transmission lines. Stability of the lake bed and shore is expected to be a factor in the decision to regulate the lake with a siphon or dam and gravity intake. These impacts need to be analyzed and proposed avoidance, minimization, or mitigation measures identified. The applicant states that bathymetric data suggests that if draw down of the lake in a siphon intake system were used at Jim’s Lake, the lake bed may exhibit instability or be susceptible to erosion. Since the applicant is considering this system and also a dam intake system at Jim’s Lake, the applicant should further study the potential effects of drawing down the lake on stability and erosion of the lake bed and shoreline. What would be the effects of a dam intake system on the lake bed and existing shoreline and uplands? Water Resources (quality and quantity) Is there a recognized municipal water shed for Elfin Cove? The lower system describes both a siphon intake configuration in which the lake’s surface elevation would be the maximum pool elevation and a dam and gravity intake that would raise the lake eight feet. The siphon intake configuration would have a total volume of 67 acre-feet whereas the dam and gravity intake configuration would have a total volume of 133 acre-feet. In figure 2.3-1 (based on the siphon intake configuration) the projection is that demand supplied from diesel would be expected to occur about every other year during the high demand summer season. It would be useful to project the same data for the dam Forest Service PAD Comments & Study Requests Page 6 of 14 Crooked Creek and Jim’s Lake Hydroelectric Project FERC No. P-14514 07/06/2015 and gravity intake configuration. The project description calls for diversion of water from Crooked Creek, diverted to Jim’s Lake at a maximum 5cfs. Applicant should provide hydrology report data to demonstrate the amount of excess flow + accretion of water to support existing fish habitat at bottom of Crooked Creek. All plans must be consistent with National Best Management Practices for Water Quality Management on National Forest System Lands, USDA Forest Service, FS-990a, April 2012. This document is available online at: http://www.fs.fed.us/biology/resources/pubs/watershed/FS_National_Core_BMPs_April2012.pdf Wildlife Forest Service direction for management indicator species (MIS), threatened and endangered species (TES), and other wildlife and fish species on the Tongass National Forest require Biological Evaluations (BE) be completed. The BE must be approved by a Forest Service Journey Level Biologist. In addition, Forest Plan requirements, goals and objectives for these species will be met at the project level (Forest Service Manual 2621.3, 2621.4 and 2672.4). The resource reports will need to be evaluated by a Forest Service Journey Level Biologist and if necessary additional study requirements and comments may be provided during stage 2 consultations. Reference documents for fish and wildlife are Endangered, Threatened, Proposed, Candidate, and Delisted Species in Alaska (updated February 18, 2014), available at http://www.fws.gov/alaska/fisheries/endangered/species.htm Endangered, Threatened, and Candidate Species under NMFS’ Authority in Alaska (updated April, 2014), available at http://www.alaskafisheries.noaa.gov/protectedresources/esa/ak_nmfs_species.pdf Botany - Sensitive, Rare and Invasive Plants A pre-field review and field surveys will be required to determine the presence of sensitive, rare, or invasive plants within the project area. Chapter 4 of the Forest Plan provides direction of analysis of sensitive, rare and invasive plants. Consult pages 4-22, 4-41, and 4-42. Specific direction for pre-field review, field surveys and NEPA analysis may be found in Guidance for Preparing a Botany Resource Report, Tongass National Forest (Dillman and Krosse 2009) and Guidance for Preparing a Biological Evaluation for Sensitive Plants. Both of these documents can be provided upon request. Invasive Species Forest Plan standards and guidelines require all proposed projects determine the risk of invasive species introduction or spread and any need to implement mitigation measures. The project design must contain appropriate provisions concerning the prevention and/or spread of invasive species. The analysis should be reviewed by a Forest Service Journey Level Botanist or Ecologist. Floodplains, wetlands, riparian, and littoral habitat We encourage the applicant to consult with the U.S. Army Corps of Engineers regarding wetlands delineation, effects, and mitigations.  Land Management Plan Direction How does the proposal align or conflict with Forest Plan Land Use Designations (LUDs) in the project area? Forest Service PAD Comments & Study Requests Page 7 of 14 Crooked Creek and Jim’s Lake Hydroelectric Project FERC No. P-14514 07/06/2015 The proposed project is in an area designated as Semi-Remote Recreation. The goals for this LUD are: • To provide predominantly natural or natural appearing settings for semi-primitive types of recreation and tourism and for occasional enclaves of concentrated recreation and tourism facilities. • To provide opportunities for a moderate degree of independence, closeness to nature, and self- reliance in environments requiring challenging motorized or non-motorized forms of transportation. The desired condition for the Semi-Remote Recreation LUD is • Areas in the Semi-Remote Recreation LUD are characterized by generally unmodified natural environments. Ecological processes and natural conditions are only minimally affected by past or current human uses or activities. Users have the opportunity to experience a moderate degree of independence, closeness to nature, solitude, and remoteness, with some areas offering motorized opportunities and others non-motorized opportunities (except for the traditional uses of boats, aircraft, and snow machines). Interactions between users are infrequent. Facilities and structures may be minimal or occasionally may be larger in scale, but will be rustic in appearance, or in harmony with the natural setting. This LUD represents a Transportation and Utility System (TUS) “window” and provides an opportunity for the designation and location of Transportation and Utility sites. However, project improvements and structures should remain visually subordinate to the characteristic landscape and blend, to the extent feasible, with the natural setting. Refer to the Forest Plan for all the Standards and Guidelines that are applicable to the Semi-Remote Recreation LUD. Recreation and Special Uses Objectives of the Semi-Remote LUD include managing recreation and tourism use and activities to meet the Recreation Opportunity Spectrum (ROS) classes, to determine on a case-by-case basis whether roads, trails, and other areas should be closed to motorized recreation activities, and to apply the Moderate Scenic Integrity Objective (SIO) to any developments, facilities, or structures. The project will require a determination on whether or not the access trails should be open or closed to motorized recreation activities. Designation of motorized routes for OHVs must be planned in accordance with regulations at Title 36 CFR part 212, Travel Management. The ROS class for the project area is semi-primitive recreation. How will the proposal change the existing Recreation Opportunity Spectrum class? How will the proposal affect the dispersed recreation in this area? Recreationists may include: deer, waterfowl, bear, hunters; sport fishers; backcountry hikers, photographers, kayakers, campers and sightseers. A recreation resource report will be needed to support the analysis. The applicant should consult with the Hoonah Ranger District to determine if there is any outfitter and guide use within and adjacent to the project area, what non-commercial recreational uses occur in the project area, and any non-recreational land uses. Scenery The Scenic Integrity Objective (SIO) for the project area is Moderate (Forest Plan page 3-67). Scenery prescriptions for the Semi-Remote Recreation LUD are to design activities, project improvements and Forest Service PAD Comments & Study Requests Page 8 of 14 Crooked Creek and Jim’s Lake Hydroelectric Project FERC No. P-14514 07/06/2015 structures, to remain visually subordinate to the characteristic landscape. Activities may repeat form, line, color, or texture common to the landscape. Rehabilitation techniques may be used to restore disturbed landscapes to be compatible with the Semi-Primitive setting. Table 3-9-1 provides a good starting point but is incomplete regarding the VPRs and Use Areas near the project area. For example, Port Althorp is a small boat and mid-size tour boat route. Port Althorp head, Georges Island, and Elfin Cove are dispersed recreation areas in the area of effect. Port Althorp head and Granite Cove are additional boat anchorages in the project area. A more comprehensive list of VPRs and Use Areas can be found in Appendix F of the Forest Plan on pages F-14 and F-15. There is no discussion of the impacts on aesthetic resources if above ground transmission lines are installed. Cultural Resources To comply with Section 106 of the National Historic Preservation Act, the applicant must consider a project’s potential to affect historic properties. There has been little archaeological survey in the project area to identify sites. The Alaska Region Programmatic Agreement Appendix C identifies the high sensitivity areas for the presence of cultural resources to include • all land between lower low water and 100 feet in elevation above mean high water, with no consideration of slope, • areas of former lode and placer mining activity, • lakes and stream systems containing anadromous fish runs, including a focus on barrier falls location in such systems. Portions of the project area fall within the high sensitivity zone for the presence of cultural resources. And will need to be inventoried with site evaluations and determinations of eligibility and effect completed for any sites discovered. In addition to archaeological inventories, the applicant must consult with culturally affiliated Tribes, Corporations and Certified Local Governments regarding the presence and significance of sites or traditional cultural properties. The State Historic Preservation Officer has oversight responsibilities to ensure that federal agencies comply with the National Historic Preservation Act and we are required to consult with them regarding the agency’s determinations of eligibility and effect to all historic properties. Tribal Resources Native consultation with Central Council of the Tlingit and Haida Indian Tribes of Alaska, Hoonah Indian Association, Sealaska Corporation, and Huna Totem Corporation is necessary. Executive Order 13007 directs federal agencies to accommodate access to and ceremonial use of American Indian sacred sites by Indian religious practitioners and to avoid adversely affecting the physical integrity of such sacred sites. Executives Orders 13084 and 13175 direct federal agencies to work with tribal governments in policy development and project implementation where significant tribal interests are affected by federal policies or undertakings. Climate Change There are places throughout the environmental effects portion of the PAD where the applicant mentions the positive effects of reducing dependence on diesel generated energy. Suggest it would be better to address climate change and clean air as important resources and state the case for clear positive impacts on the Forest Service PAD Comments & Study Requests Page 9 of 14 Crooked Creek and Jim’s Lake Hydroelectric Project FERC No. P-14514 07/06/2015 human environment. Lands Any on-the-ground site investigations/studies (including non-ground-disturbing activities) that take place on National Forest System lands or roads will require authorization by a special use permit from the Forest Service prior to beginning work. Minerals A thorough investigation will be needed as to the occurrence of existing mining claims in the project area. The identification of existing claims and claimant ownership will aid in the avoidance of conflicts regarding access to mineral rights. A Mineral Potential Report may be necessary to identify mineral resources that may be affected by the hydropower withdrawal. The format and content of a Mineral Potential Report may vary, but the report is generally prepared by Certified Geologist/Mineral Examiner, Professional Mining Engineers, or Mining Geologists. The report should emphasize locatable mining claimants, historical prospects, and mineral potential. An example Mineral Potential Report can be made available upon request. Roadless Area Conservation The project area is located in Inventoried Roadless Area #311, Chichagof, as identified in the set of maps contained in the November 2000 EIS for the Roadless Area Conservation Rule. On May 30, 2012, the Chief of the Forest Service implemented the process for review of certain activities in Roadless Areas. The Chief will review all projects involving road construction or reconstruction and the cutting, sale, or removal of timber in Inventoried Roadless Areas as defined above. Based on current direction, the Tongass National Forest will need to request approval from the Chief before preparing the 4(e) terms and conditions for inclusion in the license and/or approving any project plans that involve roads or timber within the project area. Applicant will need to provide a Roadless Resource Report. An example report can be made available upon request. Subsistence Section 810 (a) of the Alaska National Interest Lands Conservation Act of 1980, (ANILCA), reads in part In determining whether to withdraw, reserve, lease, or otherwise permit the use, occupancy, or disposition of public lands under any provision of law authorizing such actions, the head of the Federal agency having primary jurisdiction over such lands or his designee shall evaluate the effect of such use, occupancy, or disposition on subsistence uses and needs, the availability of other lands for the purposes sought to be achieved, and other alternatives which would reduce or eliminate the use, occupancy, or disposition of public lands needed for subsistence purposes. The subsistence resource existing environment and resource impacts based on existing, relevant, and reasonably available information must be evaluated. Subsistence Access ANILCA, section 811(a) reads in part, The Secretary [of Agriculture] shall ensure that rural residents engaged in subsistence uses shall have reasonable access to subsistence resources on the public lands. Subsistence access resources existing environment and resource impacts based on existing, relevant, and reasonably available information must be evaluated. Forest Service PAD Comments & Study Requests Page 10 of 14 Crooked Creek and Jim’s Lake Hydroelectric Project FERC No. P-14514 07/06/2015 Part 3 – Forest Service Study Requests This section of the report provides the Forest Service’s study requests for the Crooked Creek and Jim’s Lake Hydroelectric Project. The Forest Service study requests are written following the protocols required under 18 CFR § 5.9 (b) as follows: (i) Identifying its determination of necessary studies to be performed or information to be provided by the potential applicant, “Study” (ii) Identifying the basis for its determination, “Basis for Study” (iii) Discussing its understanding of the resource issues and its goals and objectives for these resources, “Resource Goals & Objectives” (iv) Explaining why each study methodology recommended by it is more appropriate than other available methodology alternatives, including those identified by the potential applicant pursuant to paragraph (b)(1)(vi) of this section, “Study Methodology” (v) Documenting that the use of each study methodology recommended by it is a generally accepted practice, “Accepted Practice” (vi) Explaining how the studies and information requested will be useful to the agency or Indian tribe in furthering its resource goals and objectives, “Usefulness of Information” TERRESTRIAL RESOURCE STUDIES A. Terrestrial Wildlife STUDY: Conduct a biological evaluation (BE) to assess the effects of the project on threatened, endangered, proposed and sensitive species (animal and fish) and their habitat. Complete a wildlife analysis report that addresses the effects of the proposed project on management indicator species (MIS) and other mammal and migratory bird species that occur within the project area. 1) Basis For Study: To evaluate the effects of the project on National Forest System lands on terrestrial wildlife populations surrounding the Crooked Creek and Jim’s Lake project area. 2) Study Methodology: Elfin Cove Utility Commission (ECUC) should conduct wildlife surveys and develop these surveys in association with state and federal resource agencies. More specifically, the Forest Service requests that ECUC provide the following information. a) Describe habitat relationships of the mammals listed on page 47 of the PAD in habitats affected by proposed future project operations. Specifically, describe brown bear use (denning and foraging) and identify important deer winter range affected by proposed future project operations. b) Document observations of Tongass National Forest sensitive species and management indicator species inhabiting the project area. Outcome of observations may lead to additional monitoring and study requests in stage 2 of consultation. c) Describe neo-tropical migrant bird use within the project area. Forest Service PAD Comments & Study Requests Page 11 of 14 Crooked Creek and Jim’s Lake Hydroelectric Project FERC No. P-14514 07/06/2015 3) Resource Goals & Objectives: Recognize as wildlife habitat, areas of land and water which can contribute to achieving wildlife objectives for consumptive and non-consumptive uses. Provide for the abundance and distribution of habitat necessary to maintain viable populations of existing native and desirable introduced species well distributed in the planning area.(Forest Plan: Wildlife Habitat Planning, WILD1, subparts II, VII, VIII, IX, XII, XIII, XVI, XVIII, XIX; Threatened, Endangered and Sensitive Wildlife Species, WILD4, subpart II). 4) Accepted Practice: Wildlife Inventory and analysis methods often have to take site-specific conditions into account. Discussion with Forest Service and other biologists (ADFG and USFWS) would ensure that the methods are appropriate to the area. 5) Usefulness of Information: Surveys will identify wildlife species currently inhabiting the area and habitat relationships. This information is useful to evaluate the extent of project effects to wildlife species. B. Migratory Waterfowl and Sea Birds STUDY: Identify migratory waterfowl species and sea birds that currently use Crooked Creek and Jim’s Lake project area for nesting, rearing, and resting areas. 1) Basis for Study. Knowledge of waterfowl and sea bird species using the project area will help determine the impacts of future project operations on these species. 2) Study Methodology. Identify location, species, and numbers present, nest locations and occupancy, nest elevation, habitat description and nesting success. 3) Resource Goals and objectives. Provide for the protection and manintenance of seabird (marine bird) rookeries. Maintain or enhance wetland habitats which receive significant use by waterfowl and shorebirds. “Significant” is relative, but generally relates to use of a specific area by tens to hundreds of individuals of one or more species (Forest Plan: WILD1, subpart XII; WILD1, subpart IX). 4) Accepted Practice. Surveys conducted by air, foot and/or boat are techniques used widely by natural resource management agencies for enumerating water birds, locating nest sites and determining nesting success. 5) Usefulness of Information. Waterbird surveys will help identify project effects on water bird populations associated with the project area. SUBSISTENCE STUDIES STUDY: Identify traditional and existing subsistence uses of fish, wildlife and plants within the Crooked Creek and Jim’s Lake project area. 1) Basis for Study. The community of Elfin Cove, is designated as a rural community by the Federal Subsistence Board. This designation allows residents of this community and other near by rural communities to harvest fish, wildlife and plant resources under federal subsistence rules. All of the Forest Service PAD Comments & Study Requests Page 12 of 14 Crooked Creek and Jim’s Lake Hydroelectric Project FERC No. P-14514 07/06/2015 project components (reservoir at Jim’s Lake, diversion at Crooked Creek, upper and lower powerhouses, access routes, and power transmission line) lie within close proximity to the community of Elfin Cove. Knowledge of existing subsistence uses is needed to evaluate the effects of future project operations on the ability of subsistence users to access resources. 2) Study Methodology. State and federal agencies and local tribal governments maintain harvest records of fish and wildlife that can be used to assess subsistence uses within the project area. Conducting surveys within the community of Elfin Cove and conducting personal interviews with long time residents of the area who may be familiar with subsistence uses within the project area would augment harvest data. 3) Resource Goals and Objectives. Consistent with the purposes for which National Forest System lands in Alaska were established, sound management principles, and the conservation of healthy populations of fish and wildlife, the use of the National Forest System lands in Alaska is to cause the least adverse impact possible on rural residents who depend upon subsistence (Forest Plan: Subsistence, SUB, subpart I). 4) Accepted Practice. Review of harvest records and use surveys are common practices used by natural resource agencies to determine which species are harvested, numbers harvested, and locations of harvest. 5) Usefulness of Information. Knowledge of subsistence uses in the project area will help determine mitigation measures necessary to ensure that these uses will continue to be viable in the future. PLANT STUDIES A. Sensitive and Rare Plants. STUDY: Conduct a biological evaluation (BE) using data from surveys of the project area for the presence of sensitive and rare plants. 1) Basis for Study: The proposed Project has not been surveyed for sensitive and rare plants. Determining presence is needed to evaluate whether the project will affect such species on National Forest System lands. 2) Study Methodology: The Tongass National Forest – Guidance for Biological Evaluations: Sensitive Plants, November 2007 describes a methodology for plant biological evaluations. A list of rare plants known or suspected on the Tongass National Forest is found in the attached Guidance for Preparing a Botany Resource Report.. In order to meet professional standards, BEs must be conducted or reviewed by journey or higher level botanists (FSM 2672.42). We recommend ECUC seek Forest Service concurrence on the contractor for this study. 3) Resource Goals and Objectives: The objectives of a BE as specified in Forest Service Manual 2673.41 are: 1) to ensure that actions do not contribute to loss of viability of any native or desired non-native plant or animal species; 2) to incorporate concerns for sensitive species throughout the planning process; 3) to ensure that activities will not cause a species to move toward federal listing. The Forest Plan directs that management will maintain habitat to support well distributed viable populations of sensitive species throughout the recent range of the species by avoiding or minimizing impacts to those species (Forest Plan, Threatened, Endangered, Sensitive and Rare Plants, PLA1, Forest Service PAD Comments & Study Requests Page 13 of 14 Crooked Creek and Jim’s Lake Hydroelectric Project FERC No. P-14514 07/06/2015 subparts II, III). 4) Accepted Practice: Tongass National Forest rare and sensitive plant surveys were developed over many years by experienced botanists. Field surveys are conducted during a time of the year when plants are likely to be found in a condition they can be identified. 5) Usefulness of Information: The biological evaluation and companion surveys will identify the extent and magnitude of any plant concerns relating to the project. HISTORICAL AND ARCHAEOLOGICAL RESOURCE STUDIES STUDY: Identify and record historical and archeological resources within the Project’s Area of Potential Effect (APE) 1) Basis for Study: Heritage Resources must be inventoried and protected as specified by law. The principal goal of the evaluation will be the identification of historical and archeological resources in the APE that could be affected by the proposed action. “Identification” includes identifying properties and determining whether or not they are listed on, or eligible for inclusion in, the National Register of Historical Places (NRHP). Surveys must be accomplished and approval by the State Historic Preservation Office (SHPO) prior to any ground disturbance. In accordance with Section 101(d)(6)(B) of the National Historical Preservation Act, consultation should take place with any Indian Tribe or Alaska Native corporation that attaches religious and cultural significance to properties in the APE. Consultation with Indian tribes must recognize the government-to-government relationship between the Federal government and the governments of Indian Tribes. This should take place with representatives designated or identified by the tribal government(s). 2) Study Methodology: A specific APE for the project should be defined. This would help in defining the area that needs to be investigated for direct and indirect effects on potential cultural resources. ECUC shall coordinate with SHPO, the Forest Service, and any potentially affected Indian Tribe to determine the approach to consultation, to define the APE, to determine the extent of field surveys, and seek concurrence on the use of a contractor. 3) Resource Goals and Objectives: The Forest Plan states “Any project, activity, or program that can result in changes in the character or use of historic properties and is under the direct or indirect jurisdiction of Forest, licensed or assisted by the Forest, including new or continuing projects, activities, or programs and any of their elements not previously considered under Sections 106 and 110 of the National Historic Preservation Act of 1966, as amended, shall be considered an undertaking and will require evaluation through inventory and survey. 4) Accepted Practice: Inventory and protection of Heritage Resources is a routine practice in any land- disturbing activities on National Forests. The study plan should be reviewed by a Forest Service archeologist. 5) Usefulness of Info: Inventory information will be used to protect the heritage resources as mandated by law. Forest Service PAD Comments & Study Requests Page 14 of 14 Crooked Creek and Jim’s Lake Hydroelectric Project FERC No. P-14514 07/06/2015 SCENIC RESOURCE STUDIES STUDY: Determination of ongoing and proposed Project effects on existing scenery. 1) Basis for Study. To evaluate the effects of the project on scenic resources on National Forest System lands. 2) Study Methodology. Conduct a visual resources inventory and assessment to determine Project area visual characteristics in context with the surrounding landscape and a baseline photographic inventory of Project elements from Visual Priority Routes and Use Areas where the project effects are visible. Visual Priority Routes and Use Areas in the project area to be considered are listed in Appendix F (pages F-14 and F-15) of the Forest Plan Use of visualization software and techniques are highly effective in communicating expected visual effects. 3) Resource Goals and Objectives. Recognize the scenic values of forest lands viewed from popular roads, marine routes, trails, recreation sites and minimize the visibility of developments as seen from Visual Priority Travel Routes and Use area. (Forest Plan: SCENE1,2 and 3). 4) Accepted Practice. The study approach proposed for visual resources will comply with methodologies described in USFS Agricultural Handbook Number 701, “Landscape Aesthetics, A Handbook for Scenery Management” (USFS 1995). This handbook has been developed for standard use in all projects on National Forests. User surveys are standard techniques employed by the Forest Service for evaluating visual effects. 5) Usefulness of Information. The information is needed to assess what measures may be needed to ensure that the Project complies with the scenic integrity objectives of the Forest Plan. A visual resource inventory and assessment study helps better develop site location alternatives, aesthetic design alternatives, and inform and/or disclose effects to the public more thoroughly.