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8/4/2010 MFAR Update on FERC Relicensing
Update by Bill Carnazzo
This is meant to be a final (sort of) update, at least until the current
hiatus in the proceedings ends. Our last flow negotiation meeting was held on
July 20th. The tone was very positive, and everyone felt that the process had
been fair, open, and characterized by flexibility. The consultants did an
outstanding job overall on the studies, and explaining the metrics in the
meetings.
PCWA and its consultants are now busy preparing the Draft License
Application, with the goal of filing it in October. I believe we will see it
before it is filed, so that we can have some final input. We don't know what
PCWA will propose, but we do expect flow proposals in the DLA to be similar to
the structure that we have discussed and winnowed down. The DLA, with all of its
attachments and exhibits, will be a huge document. I have requested a hard copy,
as have others. Once it is out, we have the opportunity for further comment and
negotiation for a 90 day period.
For now, we have done all that we can and I believe that our efforts will
pay dividends for the fisheries of the MFA. If things change before the DLA is
out, I will notify everyone. For now we are in a holding pattern.
7/14/2010 MFAR Update on FERC Relicensing
Update by Bill Carnazzo
We are at the end of the negotiation phase (one remaining flow discussion
day), and PCWA is rapidly approaching its deadline for submission of the Draft
License Application ("DLA"). While the negotiations have been tedious, the
interest-based process has been generally good and has worked well for us. In
this context, it is a far better process than the traditional, somewhat
adversarial "proposal/counterproposal" (ad nauseam) procedure. Contrary to what
all of us had expected, the bypass reaches took up almost all of the time
allocated for negotiations; in fact, we tackled the peaking reach for the first
time today. Looking back I now understand why that is the case: Virtually all of
the "generation cost" to the system with the new minimum flows and
other flow-related issues, is associated with the bypass reaches. The reason for
that is that the two main powerhouses are on the bypass reaches, so when water
that would otherwise be used to generate power (especially during peak demand
periods) is taken out of the system to satisfy MIF requirements, generation
revenue is diminished. In other words, upstream water is very costly to the
system. The amount of power generated at the Oxbow powerhouse (located at the
dam), on the other hand, is miniscule compared to what the two main powerhouses
put out. While we are not at liberty to disclose the generation loss numbers (at
least at this point), suffice it to say that it will be significant under the
new bypass reach MIFs. The model that has analyzed our flow proposals, as well
as those put forth by the agencies, has assigned specific generation loss
numbers for each reach.
We do not know for sure, at this point, what specific flows PCWA will be
including in the DLA for the bypass reaches, but I believe that they will come
very close to meeting our proposals. I say this because the generation loss
associated with our flows is very close to the number that PCWA has given us as
their "comfort point."
While I have identified the "bypass reaches" for you in previous reports,
it would be well to reiterate them--so here they are:
Duncan Creek, tributary to the Middle Fork American
("MFA") below French Meadows Res. ("FM")
North Fork, South Fork, and main stem of Long Canyon
Creek (three separate reaches)
MFA below FM
MFA below Interbay powerhouse
Rubicon River
The bottom line is that we have accomplished a lot of what we set out to
do for fish flows in this relicensing proceeding. Keep in mind that flows depend
on the water year types, of which there are five: Critically Dry, Dry, Below
Normal, Above Normal, and Wet. The flow regimes differ for each water year type.
Historically, 50+% of years are either Wet or Above Normal types. Now for some
specifics--or at least as specific as I can get at this point, because the exact
numbers are both confidential at this point and still somewhat indeterminate. It
is my understanding that once the DLA is filed with FERC, it is a public
document so the flow numbers will be public information at that point and we
will be able to provide more specifics.
For Duncan Creek, and the various reaches of Long Canyon Creek, we have
achieved significant increases in spring/early summer flows and have a
committment from PCWA to stop diverting water earlier so as to provide these
flows during the critical spawning/rearing time for rainbows. The biggest
problem will be late summer/early fall flows because during that time the amount
of water available under the natural hydrograph is small and there is no storage
at the diversion facilities, which are "passive" in nature. The additional water
will help with fry survival, and with BMI production. An additional benefit for
these streams will occur with post-license modifications to the dams which will
allow downstream migration of young fish and help with the fish entrainment
problem that occurs at these facilities.
For the Middle Fork American (MFA) below French Meadows, there will be
significantly more water for fish and BMI production in this reach, which is
very difficult to access but holds some nice fish. Here we were able to get some
additional summer water because there is storage at FM to draw from. Regarding
the MFA below Interbay, we will also have more water for spring and early
summer. We were a bit constrained here because there are some Foothill Yellow
Legged Frogs ("FYLF") in the lower section of this reach. FYLFs are a "species
of concern" so the agencies are required to advocate for their protection. The
rub is that FYLF thrive on warmer water, and more water means cooler water. So,
it's one of those cases of "frogs vs. fish." The trouble here is that there is
very little science to prove that temperature is the driver on FYLF reproduction
cycles; it could be driven also by altitude and other factors unrelated to
flows. But notwithstanding this problem we did achieve significant benefits for
trout.
The Rubicon took a long time to sort out, mainly because of two factors:
boating interests (non-commercial) and the existence of a good population in the
lower 3 miles of the river above Oxbow Res. The bottom line is that we will have
more water for fish, but accomodations for both of the other interests have to
be made. PCWA is working on a flow regime that will address most of the
interests--a tough job, but their consultants are excellent and we believe we
will have won significant benefits for fish in the final analysis. More on this
following the DLA.
Regarding the "peaking reach" (the MFA below Oxbow), we are still working
on the issues. Here there are numerous competing interests and there are strong
advocates for all interests. Julie Leimbach prepared a very thorough proposal
for modeling that addresses all of the interests; when it has been put through
the model we will know where the main pinch points will be, and where
accomodations will have to be made. Yesterday's session, which was devoted to
the peaking reach, went well. Julie's proposal received a lot of discussion,
mostly about what they call the "mass balance" of the entire system, under
various flow regimes. There is still some resistance on the part of PCWA to
increase the outage period (a maintenance period of 30 days in the fall,
normally October) flows because, in their words, they would be using up a lot
of water with no generation to show for it. Aside from that, I think they may be
OK with the higher minimum flows set out in the proposal. They are also on board
with the single daily peak concept and our need to have angling flows in the
afternoon and evening. Overall, I think we are in good shape. Craig Adderly, the
science consultant, predicted that the proposal might might "break" but if that
is actually the case when the modeling results are in, they will offer some
alternatives to make the proposal more workable. They said the results should be
available for the meeting on the 20th (our last flow meeting).
Much remains to be done after the DLA is filed--more negotiations and
discussion of interests and how they are affected.
6/5/2010 MFAR Update on FERC Relicensing
Update by Bill Carnazzoo
On May 27th we had another of our series of flow discussions
(negotiations, sort of), again focusing on the bypass reaches. I believe that we
are getting quite close to consensus on the small bypass reaches (N. and S.
Forks Long Canyon Creek; Duncan Creek). On the "larger" bypass reaches we still
have a few issues. I think we are close on the Middle Fork reaches below French
Meadows and Interbay, but there remain a few tricky issues on the Rubicon. I
discuss those issues below. The intent is to wind up bypass reach negotiations
on or before June 14th. We also had our MFA working group meeting this
last Thursday (June 3), the first half of which was a very informative primer on
how the model operates; the second half was our regular working group meeting.
Our next flow meeting will be on Monday, June 7th.
Our discussions began with the consultant's report on the results of
modelling scenarios 9 and 10. Scenario 9 was a revised agency run, showing
changes to their bypass reach flow ideas. Scenario 10 was our (i.e., the
Foothill Angler Group's) proposal for all of the bypass reaches. The bottom line
was that the agencies adopted our numbers for all reaches except for the MFA
below French Meadows, and for certain times of the year in the Rubicon. On the
latter stream, we had somewhat lower flows during the spawning time frame, and
higher flows during the summer months. I will explain the reasons for our flow
numbers later. The power generation loss metric for runs 9 and 10 was
interesting. The agency scenario produces a total loss of 6.26%, taking into
account water supply issues at buildout and a "betterment" at Hell Hole Res; our
scenario resulted in a slightly higher generation loss, or 7.09%. The reason for
the difference is in the timing of the flows; i.e., the higher flows that we
included for the summer cost more to the system than the spawning time frame
water. The "betterment" mentioned above is an addition of a 6' gate structure on
the HH spillway; Andy Fecko indicated that PCWA will be including this as part
of the project description for the FERC license and for the NEPA/CEQA process.
When more details become available on this betterment, I will provide the
information to everyone. Runs 9 and 10 were modeled using the new UARP South
Rubicon flows (apparently not including pulse flows due to some uncertainty on
that issue); runs prior to 9 and 10 did not take the revised S. Fork flows into
account.
There are some adverse effects on boat ramp availability on both FM and HH
lakes in critically dry years, attributable to runs 9 and 10. However, it
appeared to me when the consultant presented this issue that the incremental
impacts attributable to runs 9 and 10 are marginal at worst because there are
problems in those years in any event. Also, we have been told repeatedly that
even if the concrete ramp is entirely out of the water, launch is still possible
from the dirt road extending beyond the bottom of the ramp.
The consultant stated that for the Rubicon, in general, run 10 (our
scenario) produced more wetted perimeter in the winter, somewhat reduced
spawning-time water (see above), and more adult habitat during the RBT
rearing/growth period. Regarding temperature effects of runs 9 and 10 (here is
where the trout/frog tension occurs), the consultant's opinions are: (i) the
revised S. Fork flows will lower Rubicon temperature for some distance
downstream of the confluence, but it is uncertain at this point as to how much
cooling will occur; (ii) in CD years, the run 10 (our) flows will push the
existing flow temperature downstream 5 or 6 miles (good for fish; possibly bad
for frogs); (iii) temperatures above 22 degrees Celsius affect trout growth and
sustainability adversely, and can be lethal; temperatures below 22 are better,
but as the temperature decreases significantly, growth will slow due to
metabolism changes and availability of food.
The main issue on the Rubicon will be "fish vs frogs;" i.e., to the extent
that more flow is provided by higher instream flow releases, in combination with
the potentially cooler water generated by S. Fork flows from the UARP, the
warmer water habitat for frog spawning and rearing will be lessened and pushed
downstream. The consultant estimated that our run 10 flows would push the frog
water line downstream about 5 miles. We are happy with our flow regime, and are
going to try to stick to it.
Regarding pulse flows in the Rubicon, the problem with the infrastructure
at Hell Hole is not yet solved, and it looks as though a fix that would remove
restrictions on the amount that can be released would, in PCWA's words, cost in
the "tens of millions." We have no way at present of judging the veracity of
that claim. What they are going to do for now is to going to do model run pulses
at 180-300 cfs, take into account downstream accretion, and then measure the
effects on the metrics (initiation of gravel motion, boating, angling, etc.).
The June 3 MFA working group afternoon meeting was devoted to issues
relating to the peaking reach. We focused mainly on some proposed measures to
increase RBT and Brown Trout spawning activity and habitat. Among those measures
are rewatering the horseshoe; re-watering the side channel at Grey Eagle;
creation of a fish enhancement facility to raise stream-bred (Middle Fork)
trout, to be located on the Horseshoe Bar property; and increasing flows in the
side section below Oxbow Dam. The group is generally in agreement with all of
these, but there is concern regarding permission from the Horseshoe Bar
ownership.
5/10/2010 MFAR Update
By Bill Carnazzo
Board member, UARF Representative to MFA
Negotiation sessions on flows were scheduled for today and tomorrow,
both all day meetings. This morning we finished up on the small bypass
streams--Duncan Creek and Long Canyon Creek (North Fork, South Fork, and main
stem). On those, it appears that we have a good shot at achieving our goal of
having higher MIFs in all reaches. The MIFs are variable by water year type
(there are 5 types) and by time of year. It's a complex set of criteria, but the
overall effect for fish and bugs is quite positive. We also worked some more on
the Middle Fork reaches: (a) From French Meadows down to Interbay; and (b) From
Interbay down to Ralston. Again, water was added by PCWA, and more under our
scenario and those propounded by the agencies, in order to increase MIFs,
thereby benefitting fish and bugs. But there remains a problem regarding
Foothill Yellow Legged frogs. See below for a discussion of that issue in the
context of the Rubicon. In short, there is some FYLF habitat on the MF above
Ralston (not a huge amount) and there is some desire on the part of the
federales to foster more frogs. That means potential trouble for trout. Read on.
The rest of the day and tomorrow were tentatively devoted to beginning work on
the Rubicon, which could prove to be a bit more difficult. However, the state
and federal agencies wanted time to caucus in order to develop their scenario(s)
for purposes of modelling. In particular, there needs to be a discussion between
CDFG and USFS as to whether their proposals will be based on managing the river
for trout (CDFG), or for Foothill Yellow Legged Frogs (USFS). The difficulty is
that frogs like higher temperature ranges for their reproductive and rearing
activities; trout, of course, thrive in lower temperatures. In the frog studies,
the river was divided up into three basic area for temperature modelling. The
upper area has lower temperatures because the water mostly comes from Hell Hole
at the base of the dam; Here there are no frogs. The middle area is where the
temperatures begin to moderate and increase; in this area the frog population
begins to grow but is still relatively small. The lower area is characterized by
much higher temperatures (at times in excess of 70 degrees F), and there are
numerous frogs in this reach. I, of course, have been advocating for more flow
and cooler water in all reaches. We'll have to wait and see how this develops in
the coming weeks. It could become complicated. The bottom line is that the
Rubicon discussion has been put off until the 19th, which is one of our
scheduled flow negotiation days. As intimated above, we will also have to tackle
the "fish vs frogs" issue on that day with respect to the MF below French
Meadows, down to Ralston. The big Q is: What species (singular and plural,
possibly) is the river to be managed for? I'm not sure how that will be resolved
(procedurally and/or substantively) if a mutually satisfactory accomodation
can't be reached. You can guess where we, the angler group, stands on the issue.
One final note: A potentially overriding factor on MIFs among the bypass reaches
is the overall water/power balance. In other words, PCWA will be able to
tolerate only so much loss of power generation capacity from the system. In
other relicensing processes, it it my understanding that the "norm" would be an
expectation on the part of the licensee that it would lose somewhere between 7
and 10%. For the smaller streams we are already at somewhere near 4.5%. Anyway,
that's where we stand for now. There is a MFA working group teleconference
tomorrow to go over PCWA's first cut at modelling a peaking reach scenario
proposed by Foothills Water Network, which is a key member of the MFA working.
We, the Foothills Angler Group, are also a member of the MFA working group; we
have proposed `a slightly different scenario that we want modelled. Within the
negotiation process, it looks like we won't get to the peaking reach until early
June. The early modelling will make those discussions go much more smoothly and
efficiently when the time comes.
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