January 10, 20011:4 The PDEA has been revised to include a discussion of the adequacy of the...

Response to First Draft PDEA/LA Comments Lake Chelan Project No. 637July 6, 2001 Page 3 SS/5775

Table 1List of Comment Letters related to first drafts of the PDEA and LA

July 6, 2001

Agency/Organization Signature Date

Save Chelan Alliance Phyllis Murra May 24, 2001

US Army Corps of Engineers Michael White May 11, 2001

US Fish & Wildlife Service Steven Lewis May 10, 2001

Federal Energy Regulatory Commission Vince Yearick May 4, 2001

WA Department of Fish & Wildlife Tony Eldred May 4, 2001

WA Department of Ecology Pat Irle May 4, 2001

US National Marine Fisheries Service Brian Nordlund May 4, 2001

US Forest Service Sonny O'Neal May 4, 2001

Lake Chelan Recreation Association Board Members May 3, 2001

WA Department of Fish & Wildlife Rod Woodin May 3, 2001

Manson Park and Recreation District Board Members May 2, 2001

Local Resident A. Donald Jamtaas May 1, 2001

American Whitewater John Gangemi May 1, 2001

US National Park Service William Paleck April 30, 2001

US Department of the InteriorOffice of Environmental Policy & Compliance

Willie Taylor April 30, 2001

Caravel Resort Stella Walcker April 30, 2001

People for Lake Chelan Board Members April 27, 2001

Lake Chelan Chamber of Commerce Jan McAlvey April 26, 2001

City of Chelan David Sypher April 23, 2001

Local Businesses: April 10, 2001Chamber of Commerce Colleen Crawford -DavisCity of Chelan Mitch AtkinsonChelan Business Association Frantz Holm-NielsonTourism Promotion Group Clint CampbellLake Level Committee Board Members


Table 2Lake Chelan Project

Response to Comments Regarding First Drafts of the Preliminary Draft Environmental Assessment and License Application

Source Comments Page Nos.:Paragraph Nos. Chelan PUD’s Response

Save Chelan AllianceMay 24, 2001

PDEAStrongly agree with 350-650 cfs flow proposal forColumbia River augmentation for salmon

1:2 Evaluation of minimum flow alternatives will continue to be addressedthrough the relicensing process.

Ensure that habitat be provided and maintained forfish in the Chelan River. Agrees with creating enoughwater flow to maintain salmon redds and keep watertemperatures low enough for bull trout and cutthroat.

1:3 Evaluation of alternatives for bypassed reach minimum flow and Reach 4enhancement for anadromous fish will continue to be addressed throughthe relicensing process.

In favor of managing the lake level to support theabove issues – water flow and fish habitat

1:4 The flows required to provide aquatic habitat in the Chelan River andsupport salmon spawning in Reach 4 of the Chelan River, or the 350 to650 cfs flows proposed by WDFW and others, could, in most years, beprovided while following any of the recently proposed lake leveloperating regimes.

Chelan PUD and other stakeholders will continue to seek a balancedsolution that considers both natural and social resources.

U.S. Army Corps of EngineersMay 21, 2001

Based on information provided in the relicensedocuments, it appears that a Department of the Armypermit, under Section 404 of the Clean Water Act,may be required for this Project.

2:1 All necessary permits for the proposed PME measures will be applied forand approved prior to Project construction. Chelan PUD anticipates thatimplementation of the proposed PMEs will not begin until two yearsafter the new license is issued or an agreement can be reached with moststakeholders.

Please be advised that the Seattle District, RegulatoryBranch must become an active participant in theforthcoming 3-stage consultation process.

2:2 Chelan PUD received a similar comment in letter from the Corps ofEngineers on October 27, 1998. Three individuals from the Corps ofEngineers have been included on our mailing list since that time.

U.S. Fish & Wildlife ServiceMay 10, 2001

Letter indicated comment would be forthcoming, but no comment wasever received.

Lake Chelan Project No. 637 Response to First Draft PDEA/LA CommentsSS/5775 Page 6 July 6, 2001

Federal Energy Regulatory CommissionMay 4, 2001

Comments and changes recommended by FERC have been incorporatedinto the PDEA. In some instances, the section was rewritten and therecommended change was not applicable.

Washington Department of Fish & WildlifeMay 4, 2001

PDEAPage 99, Table 13: Include key of symbols 1:2 Comment incorporated.Page 101, fourth paragraph, second sentence: Do notconcur with statement that “…impacts of Projectoperation on big-game habitat, rare plants, andnoxious weeds were determined to be negligible…”Need discussion in NSWG; preparing material forWG.

1:3 Comment noted. Will provide time during future Natural SciencesWorking Group meetings for presentation and discussion.

Page 104, third paragraph, first sentence: One-timeplanting of native vegetation in Stehekin area may notbe sufficient.

2:1 The revegetation and other work in the Stehekin Flats area will bedescribed in terms of funding rather than by the number of plantings.

Page 104, third paragraph, sixth sentence: Supportearlier lake draft in fall for tributary access. Table 1does not appear to be much difference.

2:2 Evaluation of lake level management alternative will continue to beaddressed during the relicensing process.

Page 106, second paragraph, last sentence: Change“…because to their…” to “…because of their…”

2:3 Comment incorporated.

Page 107, second paragraph: Concerned about impactsof increased recreation on listed terrestrial species.Not sure that proposed enhancements would not likelyadversely affect threatened and endangered species.


Page 107, second paragraph: “Blue collar” specieswould bear brunt of increased “camping crave.”


Two broods of common loon known to have beenproduced on Lake Chelan in 2000. First occurrence.



Washington Department of EcologyMay 4, 2001

PDEARefraining from detailed comments at this time. 1:2 Chelan PUD encourages all stakeholders to provide comments as soon as

possible.Subsequent to publication of the PDEA, Chelan PUDand federal and state environmental agencies havecontinued discussions regarding instream flowreleases. We anticipate that the next version of thePDEA will include a discussion of this information,including feedback you have received from otherparties regarding the viability of your initial proposals

1:3 The PDEA has been extensively revised regarding the issue of instreamflow releases and the results of the Natural Sciences Working Groupdevelopment of an agreed-to PME for establishment of a functionalaquatic ecosystem in the bypassed reach.

Aesthetics and flow in the bypass reach should beaddressed. The document contains norecommendation or analysis as to which instream flowvolume constitutes an appropriate instream flow valueto protect aesthetic values. The next version of thePDEA should discuss these issues and provide anevaluation of relative ranking of flow for aestheticvalue.

1:4 The PDEA has been revised to include a discussion of the adequacy ofthe proposed instream flows for aesthetic value.

The PDEA states the initial instream flow proposed bythe fishery agencies would be expected to increase thewater temperature by greater than 0.3°C. The nextversion of the PDEA should address temperatures offlows ranging up to natural levels. The PDEA shouldalso evaluate the impacts of different magnitudes ofcontinuous flows on the size of the hyporheic zoneand the magnitude of the effect of hyporheic flow ontemperature.

1:5 The PDEA includes the initial results of temperature modeling studies (inprogress) that are addressing these issues.


The PUD claims that its proposed artificial channelwould address the limiting factor of temperature inReach 4 of the Chelan River. The proposed use ofriparian vegetation might help cool the alreadywarmed water, but it is unclear whether and howquickly it could compensate for the high temperatureof the water at the head of the spawning channel.

2:1 The first draft of the PDEA did not intend to imply that the enhancedstream channel and riparian vegetation would reduce water temperaturesbelow the temperature at entry to Reach 4. The riparian vegetation thatcould be established in the enhanced stream channel, with protectionfrom high flow events, would be the most effective way to minimizethermal loading of the stream as it passes through Reach 4.

U.S. National Marine Fisheries ServiceMay 4, 2001

PDEAEffects of Project on anadromous fish concerns NMFSunder FPA and FWCA.

1:1 Evaluation of alternatives for bypassed reach minimum flow and Reach 4enhancement for anadromous fish will continue to be addressed throughthe relicensing process.

Chelan River up to first impassible barrier designatedas critical habitat for ESA listed fish (spring chinook,steelhead)

1:2 See comment 1:1.

Current operations...significantly limit potentialspawning/rearing habitat in Chelan River and reducedsystem species health.


Not advocating introduction of anadromous fish, atthis time.

2:1 Introduction of anadromous fish into Lake Chelan is an issue that hasbeen considered, but will not be pursued in the subsequent drafts of thePDEA.

Support developing streamflows that will supportwide variety of species in Chelan River; do notsupport flow augmentation from Lake Chelan storage.

2:2 See comment 1:1. Using Lake Chelan storage for Columbia River flowaugmentation is an issue that has been considered, but will not bepursued in the subsequent drafts of the PDEA.

PUD proposed flows too low, channel too small, willnot establish properly functioning ecosystem inChelan River.


Do not agree with water temperature assessment;natural conditions? No mitigation? Prohibit westslopecutthroat trout?

2:4 Temperature data collection, modeling, and analysis will be conducted in2001 and 2002 to determine Project effects on bypassed reach watertemperature.


Support caucus flow proposal. Are interested inevaluation of more cost-effective options to achieveobjectives (Stillwater Sciences).

2:5-3:1 See comment 1:1.

PDEA developed prematurely due to lack ofconsensus on potential alternatives. Therefore,comments limited at this time. Need more quantitativeinformation in future drafts.

3:2 The first draft PDEA was written in November 2000 based on the bestavailable information at that time. Chelan PUD is committed tocontinued discussions/negotiations regarding PMEs related to ongoingProject-related impacts and rewriting future PDEA drafts accordingly.Due to the relicensing schedule, Chelan PUD believes that producing afirst draft PDEA in February 2001 was a prudent step in completing therelicensing process in the required time frame.

U.S. Forest ServiceMay 4, 2001

Before determining final PMEs for recommendationto the regional forester, will need complete, finalstudy results consistent with the study plans and afinal determination of the lake level requirements,water release rates, and timing that will regulateoperation of the Project.

Cover 1:3 The final study results consistent with the study plans are issued as draftsfor review by the stakeholders, and final reports are issued as theybecome available. At this time, final reports for most of the study planshave been completed. The final determination of lake levelrequirements, water release rates for minimum flows and timing of lakelevels and minimum flow releases will continue to be addressed throughthe relicensing process.

Enclosed preliminary PMEs so that they may beaddressed in detail in the next draft of the PDEA

Cover 1:4 It is appropriate that the PDEA address all USFS issues in the context ofthe proposed license articles resolved through the collaborative workinggroup process. If specific USFS recommended PMEs are not addressedin the license articles, then the PDEA will include the recommendationsin the discussion of environmental impacts and recommendationssections.

Issues identified in the USFS Existing InformationAnalysis (EIA) should be addressed

Cover 1:5 The intent of the working groups, which have had substantialinvolvement by USFS personnel, has been to address all stakeholderissues through the studies and negotiations on PME measures. It isChelan PUD’s understanding that all USFS issues have been addressedor are being addressed with the ongoing working group efforts. Thus, itis our belief that the issues in the Existing Information Analysis that hadbeen mostly settled by February were adequately addressed in the firstdraft of the PDEA.

General Comments: Increased use of cross-referencing would improve PDEA

1:1 A detailed table of contents (with direct links in the electronic version)and lists of figures and tables are provided. In the electronic pdf format,the document is also searchable for key words or phrases. This should besufficient to enable readers to locate sections of interest to them.

Page 4, Item 2: One-time plantings can occasionallyfail and not meet “full stocking” levels. May want toallow for this

1:1 The PME (Article 2) has been revised to provide $160,000 (2001$) toassist with efforts to enhance wildlife and riparian vegetation, with partof this funding anticipated to be used to control dust in the Stehekin area.





The funds can be used for replacement planting, if necessary.Page 5, Item 10: The term “bypassed reach” needs tobe defined or use Chelan River or Chelan River Gorgeconsistently throughout document

1:2 The term “bypassed reach” will be defined and used consistentlythroughout the document.

Page 5, Item 13: Clarify that the Endowment Fund isnot open-ended, with the intent to cover only agreedupon social and natural resource items

1:3 The PME (Article 10) has been revised to state that the primary purposeof the Endowment Fund is to fund the costs of enhancement measuresoutlined in License Articles 1, 2, 3 and 9 (erosion control plans, Stehekinarea issues, survey monuments and recreation resources managementplan). The financial returns generated by the Endowment Fund will beused as defined by the criteria established with the fund. Local, non-federal enhancement measures will be developed by the various resourcemanagement groups and forwarded to the Endowment Fund AdvisoryGroup every third year for application for available funds.

Page 13, next to last sentence: One-time plantings(same comment as 1:1)

1:5 See response 1:1

Page 19, second paragraph: The description needs tostate that a portion of the income gained from theendowment would be used to fund additional USFSand NPS recreation projects or O&M that is separatefrom dock repairs and erosion

1:6 The PME (Article 10) has been revised to state that the financial returnsgenerated by the Endowment Fund will be used as defined by the criteriaestablished with the fund. These criteria will include use of EndowmentFund income to fund additional USFS and NPS projects separate fromdock repairs and erosion control. Article 9 also includes the followinglanguage: “Additional projects to address needs at other docks orcampsite improvements managed by these agencies (USFS and NPS)may be provided through funds generated by the Lake ChelanEndowment Fund." The description in the PDEA will be revised toreflect the above language.


Page 19, second paragraph: USFS will providepreliminary conditions that reflect their 1/99 EIA, asmodified by new or more complete information. Theconditions are derived from a number of laws, policiesand guidelines defining and regulating agencyactivities including the Wenatchee National ForestLand and Resource Management Plan, as amended.

1:7 The paragraph in the PDEA has been revised.

Page 20, second, third and fourth paragraphs: Define“bypassed reach”

1:8 See response 1:2.

Page 23, third paragraph: The upper end of LakeChelan is bordered by …

1:9 The PDEA has been revised.

Page 23, last paragraph: Replace “softwood forest”with “mixed conifer” forest


Page 25, second paragraph: Suggested revisions 1:11 The PDEA has been revised.Page 27, third paragraph: Revision regarding tributarystream mouths


Page 28, second paragraph: There is no SnoqualmiePass wilderness area


Page 30: Settlement range for erosion repair andmonitoring, $1.5 to $2.0 million, is an estimate


Page 30: Damage waiver discussion 2:4 Chelan PUD maintains that the damage waivers cover all impacts causedby the Project including recreation.

Page 31, first paragraph: Revise language 2:5 The PDEA has been revised.Page 31 and 32: Survey monuments discussionappears to be adequate

2:6 Adequacy noted.

Page 32, fourth paragraph: It should be noted here thatsediment deposition at the mouth of the StehekinRiver is a natural and ongoing process


Page 33, second to last paragraph: Document needs tobe consistent with PME implementation timing; needfor follow-up planting at Stehekin


Page 43, second paragraph: Largemouth bass may notbe present – not in table 4

2:9 PDEA revised.

Page 60, third paragraph: Update with results of 2000studies

2:10 This section has been updated with the results of the 2000 studies.

Page 61, first paragraph: Update with results of 2000studies


Page 61, third paragraph: Include list of speciesrecovered from stilling basin






Page 77, upper paragraph: Same comment as for Page5, Item 13, regarding Endowment Fund.

3:1 This paragraph in the PDEA has been replaced.

Page 85, second paragraph: Editorial comments 3:2 The paragraph in the PDEA has been replaced.Page 85, fifth paragraph: List other benefits of changein lake level operation or refer reader to other sectionsfor these benefits.

3:3 The paragraph has been replaced.

Page 85, last statement: Editorial changerecommended

3:4 The paragraph in the PDEA has been revised.

Pages 87-89: Large Woody Debris (LWD) discussionneeds more detail, how much, how often, how much isProject related, what percent is Project share.

3:5 As a result of recent discussions, the Natural Sciences Working Grouphas concluded that neither the input nor retention of large woody debrisis affected by the Project. Future actions regarding LWD and LWDmanagement plans will be a shared responsibility, eligible for matchingfunds under PME 7 (CFMP).

Page 92, third paragraph: Editorial change – lodgepolepine is fire-dependent, not fire-tolerant.


Pages 92-96: Riparian discussion is a good start. Thehistorical perspective can be enhanced by includinginformation such as historical photographs and the1917 railroad maps. The information should alsoinclude discussion on glacial history, historic riparianlands at Stehekin and tributary alluvial fans andpockets near Manson. The foregoing will aid indefining present day capability of the land.


Page 96: Need to include discussion of Projectimpacts on winter mule deer range and Project effects.

3:8, 9 A new paragraph has been added to the PDEA.


Page 96: Mule deer mortality study, place-holder 4(e)condition to address Project and broader cumulativeimpacts to habitat

3:10 – 4:1, 2 Over 2,950 acres of mule deer winter range were improved with ChelanPUD funding and participation during the existing license ascompensation for 70 acres of inundated habitat on federal lands. Theinformation on migration routes, habitat use and abundance of winteringmule deer along the lakeshore during the nearly 20 years of wildlifesurveys has quantified the use of shoreline habitat by mule deer. Theshoreline acreage that was inundated (70 acres) was a very smallcomponent of the thousands of acres of federal and private lands that areused by the Chelan deer herd for wintering areas. The greatest habitatloss over the past 20 years has been the loss of deer range on privatelands that have been converted to residential development. This sourceof habitat loss is now regulated through the Growth Management Act.The mule deer mortality study is intended to provide information thatwill better define migration routes, winter range use by mule deermigrating from various parts of the Wenatchee National Forest, and themost prominent causes of winter mortality. Chelan PUD fundedpurchase by WDFW of 20,397 acres of prime winter range for these muledeer populations as compensation for Rocky Reach HydroelectricProject, and the WDFW has management authority of 10,106 contiguousacres, for a total of 30,503 acres of winter range. The habitat value ofthese lands has degraded over time from fire damage, invasive noxiousweeds and sharecropping practices that were WDFW's funding source forlimited management efforts over the past 35 years. The philosophy ofChelan PUD is that winter range improvement and restoration to theselands would give greater benefit to the mule deer population from boththe Chelan Ranger District and other parts of the Wenatchee NationalForest than additional habitat improvements to the USFS lands borderingLake Chelan. Chelan PUD believes that compensation for originalProject inundation has been fulfilled under the existing license, ongoingProject impacts are negligible, and restoration of habitat areas alongChelan Butte and the Columbia River breaks will provide much greaterbenefits to mule deer populations that migrate to and from USFS andother federal lands.

Page 98, 6th paragraph: Canada lynx inhabit area 4:3 The word “potentially” has been deleted.Page 102: Add paragraph to analysis 4:4 Paragraph has been added.Page 100, last paragraph: No discussion of inundatedlands supporting the state threatened, endangered andsensitive (TE&S) Sierra cliffbrake, western ladies-tresses and common bluecup.

4:5 A paragraph has been added to the PDEA addressing the issue.

Page 101, last paragraph: USFS disagrees with 4:6 To date the USFS has not presented any evidence that the Project’s





conclusion that impact of Project operations on big-game habitat (mule deer) and rare plant species isnegligible (per their comments on pages 96 and 100).

ongoing operations have any effect on these species. The USFS raisesthe issue of initial inundation and loss of potential habitat from thataction. Chelan PUD maintains that the baseline for relicensing is currentconditions, not speculation about the loss of potential benefits from landsflooded over 70 years ago. As pointed out earlier regarding mule deerhabitat, Chelan PUD funded substantial efforts to improve and managewintering habitat for this species, covering acreage far exceeding theacreage inundated. The report by the botanists (well recognized expertsin their field), Chelan PUD, 2000d, concluded that populations of rareplant species are not affected by Project operations, and the major issuesaffecting the continued viability of rare plant populations are not Projectrelated.


Page 106: Biggest impact for the last 100 years hasbeen due to Project construction; the second paragraphmay belong in the next section.

4:7 Since current conditions are the baseline condition for relicensing ofhydroelectric projects, the current factors affecting riparian zones, notoriginal Project inundation effects, are discussed in detail in this PDEA.The studies have shown that most riparian vegetation within the Projectboundary is found in the tributary mouths, which are also the areas wheremost recreation sites managed by the USFS are located. Therefore,recreational use has major, continuing effects on riparian vegetation andis appropriately discussed in this section. The second paragraphdescribes the connection between relicensing of the Lake Chelan Projectwith continuing and future use of riparian areas for recreation purposes.Dedication of Project funding for dock maintenance and other recreationfacility improvements funded through the Endowment Fund willmaintain the attractiveness of the recreation sites, thus contributing torecreational use and continuing effects on riparian vegetation into thefuture.

Page 106, third paragraph: Bypassed reach is notsuitable habitat for spotted owls and none of the otherfederally listed terrestrial species are known orexpected to use this area other than the bald eagle

4:8 – 5:1 The PDEA is being revised.

Page 106: Recreation enhancement…, not alldeveloped campgrounds are listed. “Our analysis”section on page 107 needs to be rewritten so thatissues may be tracked

5:2 This section is discussing potential adverse effects of recreationenhancements, funded or affected by the Project, to threatened andendangered species. These potential effects appear to be limited todegradation of riparian vegetation. More complete discussion of therecreation proposals and maintenance to recreation sites appears in therecreation resources section of the PDEA.

Page 107, second paragraph: There are no “previouslyundisturbed lands”

5:3 Undisturbed is a relative term, but pertinent to this discussion any sitethat is suitable for developed recreation access that has not previouslysustained significant recreation use is considered “undisturbed” inreference to the riparian vegetation at the site.


Page 107, second full paragraph: The enhancementmeasures are in response to current demand, notintended to foster increased use. Suggested additionallanguage regarding objectives of proposedenhancements

5:4 The suggested language has been incorporated into the PDEA.

Page 107, last long paragraph: Demographics apt tohave more of an impact to increased use

5:5 See response 5:4

Section 5.3.4, Cultural Resources: Should beexpanded to include an Introduction as well asdiscussions on Federal Trust Responsibility andReserved Indian Rights.

5:6 USFS comments and the example from the I-90 Land Exchange werehelpful. Chelan PUD tried to incorporate several of the comments in therevised PDEA, however many of them do not fit into the required FERCformat.

Page 109, paragraph 3: Unless there is a state sitenumber, delete references to burials.

5:7 Chelan PUD agrees with comments regarding reference to burials.

Page 109, paragraph 3: "Potentially eligible" isredundant in fourth line. Fifth line should be 12 sitesrather than 14.

5:7 Changes will be made to the revised PDEA.

Page 109, paragraph 4: First line, change 62 to 69.Third line, change cultural resource scatter to trashscatter. Delete Chelan PUD Dam sentence(redundant).


Page 109, fifth paragraph: Move paragraph to end ofparagraph 4.


Page 109 (b. Environmental…): Change first sentenceto read "Within the APE, effects to cultural resourcescould result from…"


Page 110, paragraph 2: HRMP and CRMP are notused consistently between the PDEA and the DLA.Use "historic properties" in reference to eligible sites.


Page 110, paragraph 3, line 1: Change to "CulturalResources Working Group".


Page 111, third paragraph: Define “close” proximity.If the 2,788 miles of trail … are a 3 hour drive fromChelan.

6:6 The PDEA has been revised as follows: There are 2,788 miles of trails,including 2,608 and 640 miles available for ORV/motorcycle use withinapproximately 100 miles of Lake Chelan.

Page 113, Figure 4: Suggest changing figure title to“Lake Chelan Basin, Three Major Zones”

6:7 This section has been revised to refer to Figure 1. Project Location mapin Section 1.

Page 116, Table 15: Need clarification on how ADACompliance was assessed and why all these sites willnot meet ADA accessibility standards

6:8 The ADA Compliance section of the referenced report (Howe and DES,2000b) has a discussion of how the assessment of ADA compliance wasconducted. It is unnecessary to repeat that discussion in the PDEA.

Page 125, first paragraph: Same comment as Page 5,Item 10

6:9 The term “bypassed reach” will be used consistently in subsequent draftsof the PDEA.





Page 126, fourth paragraph: Add language that thestudy is a narrow snapshot in time and may notadequately portray future trends

6:10 Sentences have been added at the end of paragraph 4 in the PDEA.

Page 126, last paragraph: Requested clarification 6:11 The PDEA has been revised.Page 128, fourth paragraph: Requests for additionaldetail in the discussion, discussion of solutions toovercapacity, and not clear on page 138 how issuesare being addressed.

7:1 The additional information is contained in the study reports referenced inthis section. The scope of the PDEA is to summarize the results of thebaseline studies, as has been done in the first. The resolution of allrecreation overcapacity issues is not within the scope of the PDEA andthe License Application because these are not Project effects. The “OurAnalysis” section adequately discusses how those issues that do have arelated Project effect are being addressed.

Page 128, last paragraph: May want to comment onwhat is being done to resolve overcapacity


Page 129, second paragraph: In addition, the USFSwilderness and Holden Village are also majorattractions


Page 135, second paragraph: Which docks would havethe reduced access with loss of boat space? Need tocomment on the significance of “reduced access”


Page 138, first and second paragraph: (2) Shore accesssite – delete “and managed by the USFS” – therestroom is maintained by the city

7:5 The PDEA has been revised to show that the city manages the site.


Page 138, second and third paragraphs: As part of theRecreation Plan will there be a ComprehensiveInterpretive Plan? Will people be hired to do theinterpretive work?

7:6 Chelan PUD has no plans to develop an interpretive plan nor to directlyfund interpretive work other than proposed for the trail in Reach 1 of thebypassed reach. Proceeds from the proposed Lake Chelan EndowmentFund could be used for this purpose, subject to approval by theEndowment Fund Advisory Group.

Page 138, 139 and 141: Clarify what kinds of trails arebeing discussed, standardizing terminology (non-motorized as opposed to varying references as hiking,mountain biking, etc.)

7:7 The term “non-motorized trail” has been incorporated where appropriatein the PDEA.

Page 142, third paragraph, last sentence: Clarify thaterosion is the only natural science working groupPME to be funded from the Endowment Fund

7:8 The PDEA has been revised to make this clear.

Page 143, second paragraph: We are not in agreementthat the PUD is completely free of all liability witheasement sites, as tied to recreation resource use

7:9 Reaching agreement on PME measures makes this point of disagreementmoot.

Page 143, third paragraph: Rewording suggested 7:10 The suggested changes are incorporated in the PDEA.Page 145: Affected environment – add SawtoothWilderness, consistency of term Bypassed Reach

7:11 The changes are incorporated in the PDEA.

Page 149, second to last line 7:12 The PDEA has been changed accordingly.Page 150, first and second paragraphs: Add “andenvironmental health” to sentences

8:1, 2 The PDEA has been changed accordingly.

Page 151, second paragraph: Clarification regardingeffect of change in lake level on riparian vegetation

8:3 Clarification has been added

Page 153: The last sentence is incorrect 8:4 The PDEA has been revised.Page 155, last paragraph: Revisions to paragraph 8:5 The PDEA has been changed accordingly.Page 155, last sentence: Is there a plan to control thereed canary grass?

8:6 Chelan PUD has not proposed any control measures because it is not aneffect of the Project.

Page 159: Define “double-declining balance method" 8:7 The PDEA has been revised to clarify the term.Page 161: Change title of table 8:8 The title has been changed.Page 162: Correct typo on table 8:9 The typo has been corrected.Page 166: Use the acronym PME in place ofenhancements

8:10 The change has been made.

Page 166, bullet 8: CRMP or HPMP – use one or theother consistently throughout the PDEA and LA

8:11 The change has been made, using CRMP.

Page 170: Replace USFS, Land and ResourceManagement Plan discussion

8:12 – 9:1 The PDEA has been modified as requested.

Page 1-2, Table 1 (comments on DLA): Change toapproval of Cultural Resources

9:2 The DLA has been changed accordingly.

Page 1-2, change Historic Property Management Plan 9:3 The DLA has been changed accordingly.





to Cultural Resources Management PlanPage 1-4: Change title 9:4 The DLA has been changed accordingly.Page 1-16: Change title 9:5 The DLA has been changed accordingly.Page 2-5, second paragraph: Change Tribes to lowercase


Page B-16, Proposed Development: Please list datesof studies


Page B-16: Discuss whether Project expansion hasbeen recently considered in view of the energy crisis

9:8 The possibility was recently examined, and expansion is still infeasible atthis time. This information was added to the DLA.

Page H-4, H2.2: Is there an error regarding the 48MW Lake Chelan Project constituting 25% of ChelanPUD’s current total resource portfolio

9:9 There is no error. Chelan PUD’s resource portfolio contains onlyproportions of the power generated at the Rocky Reach and Rock IslandProjects, with the remainder owned by power purchasers under long-termpower sales contracts.

Lake Chelan Recreation AssociationMay 3, 2001

General CommentsSupport LL04 as minimum; lake up earlier, heldlonger.

1:3 The most recent proposal (PME07) is closer to LL04 than the scenarioshown in the first draft PDEA. It is intended to mimic the historicalaverage levels from the first license from July 1 through October 15. Italso raises the lake slightly earlier, as did LL04. After mid-September itwould begin to lower the lake level slightly faster than LL04. Evaluationof lake level management alternatives will continue to be addressedduring the relicensing process.


Change definition of full pool to 1,100 ft. 1:4 The reason for defining full pool as some level below 1,100 feet, e.g.1,098 feet, is to allow a reasonable amount of leeway for controlling thelake level while avoiding flooding (going above 1,100 feet). It is notfeasible to maintain the lake at a constant elevation. Trying to keep thelake level too near 1,100 feet would be dangerous because of increasedflood risk. It would also waste water that could be used for generationbecause it would require spilling water any time flow into the lakeexceeded the capacity of the power plant.

Oppose reduction of power generation from currentlevel.

1:5 Some water will need to be released into the bypassed reach for theminimum flow. Evaluation of minimum flow alternatives will continue tobe addressed through the relicensing process.

Support PUD proposal for minimum flow as long aslake elevation unaffected.

1:6 Evaluation of minimum flow alternatives will continue to be addressedthrough the relicensing process.

Support PUD proposal for Reach 4 enhancement, aslong as cost less than $750,000.

2:1 Evaluation of Reach 4 enhancement alternatives for anadromous fish willcontinue to be addressed through the relicensing process.

Oppose anadromous fish biological test in bypassedreach.


Oppose using lake storage for Columbia River flowaugmentation.

2:3 Using Lake Chelan storage for Columbia River flow augmentation is anissue that has been considered, but will not be pursued in subsequentdrafts of the PDEA.

Oppose reintroduction of bull trout and anadromoussalmonids.

2:4 The US Fish & Wildlife Service is required, by law, to investigaterestoration of bull trout in the Chelan Basin. Bull trout restoration iscurrently in the feasibility stage, and is included in the ComprehensiveFishery Management Plan (CFMP) for Lake Chelan. Introduction ofanadromous fish into Lake Chelan is an issue that has been consideredbut will not be pursued in subsequent drafts of the PDEA.


Support PUD cost-sharing for additional facilities,which improve public access to lower lake.

2:5 The Endowment Fund could be a source of funding for projects related topublic access to the lower lake.

Chelan PUD has met its requirement for providing access to the lowerlake through the development of three parks. Certain streets and alleys inChelan vacated in the past are below 1,100 feet and were conveyed byoperation of law to the abutting landowners. When the streets werevacated, the city of Chelan retained “walking” easements for publicaccess to the lake. Properties above 1,100 feet were not impacted by thevacation or easements described above. All but two of the vacated streetsowned by Chelan PUD are now included within its park system. Otherlands owned by the PUD are under water when the lake is at 1,100 feet.

Oppose using large woody debris (LWD) for erosionwhere it conflicts with public access, safety, etc.

2:6 The parties planning to use LWD as part of various repairs andenhancements (USFS, NPS and Chelan PUD), and the agencies requiringits use as a condition of permitting erosion repair (mainly WDFW),recognize the risk to boaters if LWD is misplaced. As a result, all theparties involved have agreed it is important to place LWD in areas thatare not near docks or other areas heavily used for recreation.

Support erosion control on public lands whichenhances, but does not preclude, public access.

2:7 The erosion control plans being developed with the USFS and NPS areintended to maintain or enhance public access. The USFS and NPSmanage the only sites for which Chelan PUD does not hold easements.The proceeds (interest) from the Endowment Fund can be used forerosion repairs on other sites.

Oppose lake level proposal for improving tributaryaccess. Use mechanical removal.

2:8 Lake level operation proposals are continuing to be analyzed anddiscussed by the Natural Sciences Working Group. Mechanical removalof barriers is being recommended as the initial course of action to removetributary mouth barriers.

Support whitewater boating if generation not impactedand minimum number of boaters is 24 per day.

2:9 Chelan PUD is working with American Whitewater (AW) to determine areasonable minimum number of whitewater boaters per release. Lakelevels and power generation losses will be a primary consideration innegotiations.


Support PUD public access to the Gorge and amanaged access system.

2:10 Chelan PUD proposes to provide a trail for public access to Reach 1 inthe Chelan River Gorge. The local sheriff’s office and fire district havestrongly recommended against allowing access to the gorge area becauseof the difficult and unsafe rescue situation in this area.

Encourage funding for Lower Lake Chelan ShorelineTrail System.

2:11 The Endowment Fund could be a source of funding for trail projects.Chelan PUD disagrees with some local stakeholders that lower lake trailsare a responsibility of the PUD and its customer/owners. To meet FERCrequirements for recreational access to the lake, Chelan PUD provided$10 million in its existing license to purchase shoreline properties anddevelop three parks in the lower lake area. These parks continue to be anongoing responsibility of Chelan PUD.

Support establishing Endowment Fund specificallydesignated to address downlake/nonfederal public andrecreational needs.

2:12 Chelan PUD proposes to create an Endowment Fund to help generateseed money for recreation and erosion projects in the Lake Chelan Basinthat are outside PUD responsibility. The principal for the fund will comefrom recreation and erosion PME measures (federal and nonfederal) thathave a demonstrated ongoing impact from Lake Chelan Hydro Projectoperations.

PDEA CommentsOppose lake level proposal for improving tributaryaccess. Use mechanical removal.


$100,000 for trails is an unreasonable approach to trailenhancement. Prefer managed access program.

3:3 Chelan PUD proposes to provide $100,000 for planning and developmentof a 2.2-mile multi-use, non-paved trail in Reach 1 of the Chelan Riverbypassed reach. The trail will connect to the PUD’s Riverwalk Loop trail.Chelan PUD maintains that Reach 2 and 3 are unsafe for public access.Chelan PUD believes proposals for canyoneering and adventure hikes inReach 2 or 3 create considerable liability exposure to the PUD and itscustomer/owners.

Support recreation plan development andimplementation through PUD cost-sharing.

3:4 Chelan PUD will develop a Recreation Resources Management Plan forits recreation facilities and lands. The plan will include provisions forPUD funding of recreation measures outlined in the final drafts of thePDEA and License Articles.


Support establishing a separate, nonfederalEndowment Fund to address downlake recreationalneeds.

3:5 Chelan PUD proposes to create an Endowment Fund to help generateseed money for recreation and erosion projects in the Lake Chelan Basinthat are outside PUD responsibility. The principal for the fund will comefrom recreation and erosion PME measures (federal and nonfederal) thathave a demonstrated ongoing impact from Lake Chelan Hydro Projectoperations.

Page 19, paragraph 4.7, Section 4(e) conditioning 3:6 Chelan PUD is unclear on the change requested in this section.Page 20, paragraph 2: Bull trout are extinct, not“thought to be.” No citation to bull trout observationsin tailrace.

3:7 Chelan PUD does not agree. Additional investigation in historic bulltrout habitat must be conducted to determine whether a remnantpopulation exists somewhere before reaching the conclusion that bulltrout are extinct.

Page 29, Table 1: Do not support PME04. Concernedwith the use of “average lake levels.” What isaverage?

3:8 As mentioned above, the plan currently being considered (PME07)should be an improvement over PME04. To avoid further confusion, useof monthly averages in Table 1 will be changed in subsequent drafts ofthe PDEA to average elevations on the first day of each month. Averagelake levels are used to illustrate the results of running the operationsmodel using a certain set of minimum target elevations. The averageelevations and dates would be included in the license application, butthey don't necessarily reflect the lake level that would result in a typicalyear. Subsequent drafts will clarify this.

Page 30, paragraph 1: Include in the draft that thePUD has agreed to complete an erosion control planthat includes identifying erosion sites with specificissues and a set of potential erosion control designs;and that this plan is made available to the public.

4:1 Chelan PUD and the Erosion Working Ggroup completed a notebook oferosion control methods on May 4, 2001. The designs in that report werediscussed with the permitting agencies, but should not be considered tobe pre-approved for any site. The report is available to the public andcan be obtained from the relicensing Web site. It is hoped that it will behelpful to the public.

The PUD is also working with the NPS and USFS on more specificerosion control plans for sites for which Chelan PUD does not holdeasements.

Page 45: Add that bull trout have been extinct for 50years.



Page 62, RTE species: Even though bull trout arenative, there is no reason to believe they exist in thedrainage today.


Page 77: Oppose reintroduction of bull trout. 4:4 See comment 2:4.Page 79: Oppose introduction of anadromous fish toLake Chelan.

4:5 Introduction of anadromous fish into Lake Chelan is an issue that hasbeen considered, but will not be pursued in subsequent drafts of thePDEA.

Page 85: Oppose lake level proposal for improvingtributary access. Use mechanical removal.


Page 87: Questions why PUD responsible solely forLWD.

4:7 At the May 2, 2001, Natural Sciences Working Group meeting, U.S.Forest Service representatives stated that they do not believe that LWDmanagement in Lake Chelan is solely a PUD responsibility. LWDmanagement is a joint responsibility of all relicensing participants.

Page 89: Oppose use of LWD in riprap walls due torotting and compromise of wall integrity.

4:8 Inclusion of LWD as part of erosion control structures is an idea shownin sample designs from WDFW and others, but the working group hasrecognized that this is not appropriate around Lake Chelan. As a result,the erosion control methods notebook and the plans developed to date donot include LWD as an integral part of riprap or other structures. Insteadthe LWD is used as a separate item, likely to be required to mitigate forerosion mitigation work.

Pages 111-112: Focus on Lake Chelan recreationalopportunities before discussing regional opportunities.

4:9 Chelan PUD followed a format consistent with FERC requirements.

Pages 111-112: Lake Chelan Valley Public TrailsComprehensive Plan should be mentioned as resourceguide.

5:1 The Lake Chelan Valley Public Trails Comprehensive Plan is referencedin the trails section on page 139 of the first draft PDEA. This has beenadded to the references.

Page 112: Disagree with presumption that recreationalopportunities at Lake Chelan are predominantlywater-based. Off-lake activities draw a large numberof participants.

5:2 Numerous studies established the clear connection between recreation,tourism and water-related activities associated with the lake. Thesentence does not mean to imply that off-water opportunities don’t exist.The sentence will be changed for clarity.


Page 130: Questions 100,000 people on peakweekends. 25,000-35,000 is better number.

5:3 The Lake Chelan Valley Public Trails Comprehensive Plan (1996) statesthat seasonal influx of summer visitors brings the average dailypopulation of the Chelan area up to 30,000. Chelan PUD believes acurrent estimate of 100,000 for a peak weekend (two days) over theentire Lake Chelan Basin is an accurate statement.

Page 134: Full pool should read 1,100 ft. 5:4 See response 1:4.Page 138: Take exception to 2,788 miles of trailsavailable near Lake Chelan. Social Sciences WorkingGroup has not discussed trail in Reach 1.

5:5 Chelan PUD will break down the number of trails using the lower,middle and upper zone categories.

The proposal to develop a trail in Reach 1 for biking and hikingoriginated with Rich Uhlhorn (Lake Chelan Recreation Association) inthe Social Sciences Working Group meeting May 24, 2000. At thatmeeting, Pat Irle (DOE) also proposed that Chelan PUD consider accessfor viewing the Chelan River bypassed reach. At subsequent workinggroup meetings, the concept of a trail in Reach 1 was discussed further.At the Aug. 30, 2000, Social Sciences Working Group meeting, Uhlhornstated that he liked the idea of not spending much money and making thetrail simple and natural and felt most of the trail could be built byvolunteers. A subsequent field trip occurred with PUD staff and Uhlhornto look at options for the Reach 1 trail. The outcome of these meetingsresulted in Chelan PUD’s proposal for the Reach 1 trail.

Page 138: Direct any trail development to public’shighest priority wish for a Lower Lake ChelanShoreline Trail System.

5:6 Chelan PUD has been requested by Department of Ecology (DOE),Interagency Committee for Outdoor Recreation (IAC) and localstakeholders to provide a trail in the bypassed reach. Chelan PUDdisagrees with some local stakeholders that other trails are aresponsibility of the PUD and its customer/owners.

Page 139: Does not see how Reach 1 trail connectswith city of Chelan or Riverwalk Loop Trail.

5:7 Planning and design for the Reach 1 trail may include a connection to theRiverwalk Loop Trail (if feasible).

Page 141: LCTA has not agreed to partner in Reach 1trail.

5:8 This will be removed. Per Social Sciences Working Group meeting onMay 17, 2001, this statement has been changed to reflect that the locationand design standards for the Reach 1 trail will be discussed with localstakeholders.


Trail opportunities need to be developed/implementedin Chelan Valley, primarily Manson to Lakeside.

6:2 Chelan PUD will work with agencies and local entities on trail projectsthat enter or pass through Chelan PUD-owned parks or lands.

Support whitewater boating if generation not impactedand minimum number of 24 boaters attend.

See response 2:9.

Fully supports establishing Endowment Fund. Wouldlike a separate Endowment Fund for nonfederalstakeholders to address recreational andsocioeconomic issues facing the Lake Chelan Valley.


Washington Department of Fish & WildlifeMay 3, 2001

PDEAContrasting preliminary draft proposals is premature. 1:2 Available proposals had to be described at the time the draft PDEA was

written.Page 43, paragraph 1: Not aware of largemouth bass(LMB). Whitefish specified as pygmy and mountain.Other centrarchids (Table 4).


Page 44, paragraph 1: Add “…significantly removedfrom the wetted perimeter most of the year” at end ofsentence 3.


Page 44, paragraph 4: Change “…large and smallrocks, cobbles…” to “…large and small boulders,cobbles…”


Page 55, paragraph 2, after sentence 6: Add, “Allhatchery-reared chinook releases are marked by finclipping, and catches indicate hatchery chinook arenot contributing significantly to the sport catch.”


Page 55, paragraph 4, second sentence: Insert “andkokanee” after “shrimp.”


Page 57:4-5: Clarify if number fish captured wasactual number or expanded from survey sample.


Page 59, Table 6: Trout composition results should beshown by species.

2:7 Will investigate feasibility of reanalyzing data to address comment.


Page 60, paragraph 2: Last sentence suggests highstream discharge prevented spring spawner entranceto lake tribs. Recent data show alluvial barriers asprimary cause.


Page 61, paragraph 2: Move paragraph to page 62after paragraph 1


Page 62, paragraph 1: Species discussed arethreatened or endangered, but not rare.


Page 69, Table 8, Footnote 2: Insert “Natural” before“habitat area”


Page 70, paragraph 1: Discuss observed temperaturemoderation at 100, 250, and 500 cfs, and where inbypassed reach cooling occurs.

3:5 The PDEA will be revised.

Page 70, paragraph 2, second sentence: Add “withouthabitat enhancement” after “Reach 4.”


Page 71, paragraph 3, first sentence: Change to“Establishing a significant cutthroat population…”


Page 72, Table 9: Brown’s 1984 temperature profilesat Lakeside remarkably similar to lake outlet data.


Page 76, paragraph 2, third sentence: Insert “(CFMP)”after “plan.”


Page 76, paragraph 1, first sentence: Residentsalmonids emerge first half of April; WSCT beginspawning in April; SMB begin spawning in earlyMay.


Page 76, paragraph 3, next to last sentence: WDFW’sobjective for the Chelan River is to establish a viableaquatic and terrestrial ecosystem.


Page 77, paragraph 1, third and fourth sentences: Notaware of proposed funding or Endowment Fund fromNSWG.



Page 78, Bypassed Reach and Tailrace: Change“native cool-water species” to “a functional aquaticand terrestrial ecosystem.”


Page 80, paragraph 1, third sentence: Change “wildfish management policy” to “Wild Salmonid Policy.”


Page 80, paragraph 2: After “...implemented byWDFW” add “As part of the native cutthroatrestoration effort, rainbow trout stocking will bephased out over four years.”


Page 80, paragraph 2, last sentence: Change“…WDFW promotes enhancement of habitat forSMB,…” to “…WDFW promotes enhancement ofhabitat for fish, with incidental benefits for SMB,…”


Page 82, paragraph 1: Reference to flowaugmentation, significant departure from present lakeoperating regime could degrade Stehekin area,probably the lake’s largest rearing area for juvenilesalmonids.

5:2 Using Lake Chelan storage for Columbia River flow augmentation is anissue that has been considered, but will not be pursued in subsequentdrafts of the PDEA.

Page 85, paragraph 3, last sentence: End sentenceafter “inaccessible;” join third and fourth paragraphs;insert “cobble and” between “through” and“sediment.”


Mechanical removal of alluvial deposits necessary tonaturally maintain stream channels.


Page 87, paragraph 1, first sentence: Reservecomment on entrainment issue until review of 2001study results.

5:4 Chelan PUD appreciates your comment.


Manson Park and Recreation DistrictMay 2, 2001

PDEASupport LL04 as a minimum; lake up earlier, heldlonger.

1:1 Evaluation of lake level management alternatives will continue to beaddressed during the relicensing process.

Change definition of full pool to 1,100 ft. 1:2 The reason for defining full pool as some level below 1,100 feet, e.g.1,098 feet, is to allow a reasonable amount of leeway for controlling thelake level while avoiding flooding (going above 1,100 feet). It is notfeasible to maintain the lake at a constant elevation. Trying to keep thelake level too near 1,100 feet would be dangerous because of increasedflood risk. It would also waste water that could be used for generationbecause it would require spilling water any time flow into the lakeexceeded the capacity of the power plant.

Oppose reduction of power generation from currentlevel.

1:3 Some water will need to be released into the bypassed reach forminimum flow. Evaluation of minimum flow alternatives will continue tobe addressed through the relicensing process.

Support PUD proposal for minimum flow and Reach4 enhancement, as long as lake elevation unaffected.

1:4 Evaluation of Reach 4 enhancement alternatives for anadromous fish willcontinue to be addressed through the relicensing process.

Oppose anadromous fish biological test in bypassedreach and using lake storage for Columbia River flowaugmentation.

1:5 Evaluation of minimum flow alternatives will continue to be addressedthrough the relicensing process. Using Lake Chelan storage for ColumbiaRiver flow augmentation is an issue that has been considered, but willnot be pursued in subsequent drafts of the PDEA.

Oppose reintroduction of bull trout. 1:6 The U.S. Fish & Wildlife Service is required, by law, to investigaterestoration of bull trout in the Chelan Basin. Bull trout restoration iscurrently in the feasibility stage, and is included in the ComprehensiveFishery Management Plan (CFMP) for Lake Chelan.

Oppose using LWD for erosion where conflicts withpublic access, safety, etc.

1:7 The parties planning to use LWD as part of various repairs andenhancements (USFS, NPS and Chelan PUD), and the agencies requiringits use as a condition of permitting erosion repair (mainly WDFW),recognize the risk to boaters if LWD is misplaced. As a result, all theparties involved have agreed it is important to place LWD in areas thatare not near docks or other areas heavily used for recreation.


Support erosion control on public lands whichenhances, but does not preclude, public access.

1:8 The erosion control plans being developed with the USFS and NPS areintended to maintain or enhance public access. We believe the USFS andNPS manage the only sites for which Chelan PUD does not holdeasements.

Oppose lake level proposal for improving tributaryaccess. Use mechanical removal.


Support whitewater boating if generation not impactedand minimum number (24 vs. 12) attend.

1:10 Chelan PUD is working with AW to determine a reasonable minimumnumber of whitewater boaters per release. Lake levels and powergeneration losses will be a primary consideration in negotiations.

Support Endowment Fund 2:1 Chelan PUD proposes to create an Endowment Fund to help generateseed money for recreation and erosion projects in the Lake Chelan Basinthat are outside PUD responsibility. The principal for the fund will comefrom recreation and erosion PME measures that have a demonstratedongoing impact from Lake Chelan Hydro Project operations.

A. Donald JamtaasMay 1, 2001

PDEASupport PUD proposal as balanced approach. 1:2 Evaluation of alternatives for lake level management, bypassed reach

minimum flow and Reach 4 enhancement for anadromous fish willcontinue to be addressed through the relicensing process.

Opposes caucus proposal as unbalanced approach;does not include details regarding the local andregional economic impact.


The Socioeconomic Report was published withoutaddressing the WDFW recommendations.

1:3 The final Socioeconomic Study Report was completed Jan. 27, 2000. TheWDFW recommendation was first discussed in a Natural SciencesWorking Group meeting on Sept. 25, 2000.

Unable to find reference to the Lake ChelanReclamation District letter to the PUD citing impactsto irrigation needs due to WDFW alternative.

1:3 Letter dated Dec. 19, 2000. A reference to this letter will be included insubsequent drafts of the PDEA.


American Whitewater (AW)May 1, 2001

PDEASupports the implementation of a three-year study incollaboration with AW and the FERC to monitorwhitewater boating use and craft a license conditionfor the remainder of the license term that addressesdemand/carrying capacity, access, safety andscheduled flows.

1:2 Chelan PUD agrees and will work with AW and FERC to plan for andimplement the study.

A report should be issued annually with a final reportand recommendations at the conclusion of the three-year study.

1:2 Chelan PUD agrees.

An adaptive management plan should be implementedand contain a clause allowing up to eight weekendsannually based on analysis of demand and carryingcapacity.

1:3 Chelan PUD agrees that an adaptive management plan should beimplemented following the three-year study. The number and timing ofreleases will need to consider lake level and power issues.

Recommend instituting a reservation system wherescheduled releases are contingent on three or moreboaters up until 3 p.m. Friday, on the week of thescheduled release.

2:1 For the three-year study, Chelan PUD proposes 12 boaters per releasewith signed liability waivers “received” by the PUD no later than 3 p.m.Friday on the week of the scheduled release.

Chelan PUD should work closely with AWannouncing the reservation system. AW will assistwith dissemination of the release schedule andreservation requirements.

2:3 Chelan PUD will work with AW to disseminate information regardingliability waivers and scheduled releases. Chelan PUD will provideinformation on its Web site regarding the reservation system. ChelanPUD will not be responsible for advertising or promoting whitewaterboating events.

The flows currently proposed in the PDEA do notreflect the results from the study report. That reportrecommended offering a standard trip with flowsbetween 300-375 cfs on Saturday and a high challengetrip with flows 400-450 cfs on Sunday.

2:4 These changes have been made in the PDEA and License Articles.


U.S. National Park ServiceApril 30, 2001

The proposed action plan makes no mention ofsedimentation at the head of the lake. This issueneeds to be addressed in the PDEA.

1:1 PME 2 will be modified to address this issue.

Planting of vegetation in the drawdown zone failedwhen last attempted. In fact, it introduced the exoticcanary grass. We do not need to repeat this error. Wecan develop a better implementation plan and at leastreduce (perhaps not eliminate) the dust problem. Weoffer some possibilities below.

1:2 See responses 3:2 and 3:3 below.

It would be helpful if the document included a figureto illustrate the new lake level operating plan.

1:3 We agree that a graph of average lake levels anticipated as a result of thenew operating scenario would be helpful.

It would be helpful if the list of studies included insection 10 were referred to in the discussions of allimpact topics (e.g. it is not in the erosion section).

1:4 The list of studies will be referenced as appropriate.

It would be helpful if an index were included. 1:5 A detailed table of contents (with direct links in the electronic version)and lists of figures and tables are provided. In the electronic pdf format,the document is also searchable for key words or phrases. This should besufficient to enable readers to locate sections of interest to them.

Figure 1, page 7: Glacier Peak Wilderness Area ismislabeled as the "North Cascades Wilderness," andthe Lake Chelan National Recreation Area ismislabeled as "North Cascades National Park."

1:6 This will be corrected in the revised PDEA.

Greenhouse gases, page 9: It is unlikely that continuedoperation of the Project will "reduce annual carbondioxide emissions in the region." In fact, it is clearthat the region faces a power shortage, and that newfossil-fuel powered generators will be built. It wouldbe more accurate to say that the Lake Chelan Projectdoes not release greenhouse gases.

2:1 The reasoning behind this part of the PDEA is implicit in the comment.There is an energy shortage in the region. If the Lake Chelan Project isnot operated, the power it generates will have to be replaced. It will mostlikely be replaced by a fossil-fueled power plant that produces carbondioxide, etc. Continued operation of the Project will, therefore, reducecarbon dioxide emissions below what would occur without the Project.This is explained in more detail in the PDEA.


3.1 Project Description, page 10: Note that theprevious dams were unstable, that they had only beenin place for a few decades, and that they were notoperated in a manner that manipulated lake level likethe current dam.

2:2 As pointed out, the previous dams were in place for a total of a fewdecades, but each ultimately proved unstable. They manipulated the lakelevel, but not in the same way as the current dam. Also, the previousdams were not at exactly the same location. This sentence will berevised.

Bullet items, page 14: Monitoring Project impacts onthe mouth of the Stehekin River should be added tosection 3.3.

2:3 Monitoring the Stehekin River channel near its mouth has been proposedand accepted subsequent to preparation of the PDEA. No means ofmonitoring Project impacts on the river mouth has been proposed to date.The choice of words is intended to clarify that monitoring the mouth ofthe Stehekin River channel is not the same as monitoring Project impactson the river mouth.

Page 20: Restoring native fish populations such asbull trout, cutthroat trout, and whitefish would benefitbald eagles and osprey. Whitefish will accumulatepersistent organic pollutants and heavy metals morethan many fish species and are good indicators formonitoring water quality status and trends, and thebio-magnification in the food chain. As top predators,both bald eagle and osprey are again showingincreasing levels of these contaminants at the regionallevel (Columbia and Fraser Rivers.)

2:4 Chelan PUD appreciates the comment.

Beginning here and in several other instances, baldeagles and northern spotted owls are discussed as ifthey mutually benefit from riparian restoration andhave the same prey base. They are very different, andwe doubt if there are northern spotted owls in thebypass reach.

2:5 The reference to riparian vegetation enhancement in the bypassed reachfor spotted owls will be deleted.

It should also be noted that any project work would bescheduled to avoid disturbing any nesting birdslocated.



Page 20: Delete last sentence on page, “We do notpropose any additional recreational enhancementsalong the northwest shore of Lake Chelan.” Thisstatement may not be true.

2:7 The statement will be deleted.

Page 21: The common reference to grizzly bears in theNorth Cascades Ecosystem is that there are fewer than20 individuals, not 50.


General Description of the Lake Chelan Basin, page23: The Glacier Peak Wilderness Area, not “GlacierPeak Complex,” borders the Project to the south.

2:9 "Glacier Peak complex" refers to a part of the Project's geologic settingrather than to a man-made entity.

Page 23: The Project is bordered by more than twomillion acres of public lands, including NationalParks, Forests, and Recreation Areas–not NationalForest Lands alone, as stated.


Page 23: It would help to provide a better generaldescription of the vegetation at the north end of thelake than “softwood.” How about Douglas fir, grandfir, and ponderosa pine on upland areas, andcottonwood, cedar and alder in riparian zones?Further, some note about the lack of a littoralzone/riparian vegetation along the lakeshore wouldbetter describe the environment.

2:11 Those subjects are covered in more detail in Section 5.3.3.2.

5.2.2 Temporal Scope, page 25: While appreciatingthe fact that Chelan PUD desires a 50-year license, the“temporal scope” of this document does not “look 50years into the future.” None of us can do this, which isthe very reason for an adaptive management approach.This management concept needs further developmentin the environmental assessment.

2:12 Chelan PUD has agreed to provide funding over the term of the newlicense and is willing to make changes to proposed measures. ChelanPUD will meet at least annually with agencies to discuss possiblechanges.

Page 26, first paragraph: The moraine at the end of thelake retains some water in the lake, but most water isretained because the lake is over-deepened (i.e. thedam is bedrock).

3:1 The paragraph will be revised to make that point clear.

Page 27, Stehekin Flats: Please double check theacreage. We believe that a USFS Forest Supervisor’sletter in the 1920s referred to 310 acres beinginundated by the reservoir. The 175 acres may indeedbe that portion exposed to wind and dust events in thespring of each year. This discussion of air qualitymonitoring and findings is grossly biased, primarily

3:2 The 175-acre figure is the potential source area for dust exposed in atypical year. The total inundated area of the flats is about 310 acres.This will be clarified.

The statements in the PDEA are not intended to be biased. We willprovide additional details in the next draft. Also, some clarification maybe useful, as follows:





by omission. Your statement refers to PM2.5 andPM10; however, the bulk of the dust was largerparticles not detected by these samplers, but detectedby the Total Particulate Sampler. Furthermore, thereare no standards for these larger particles. While itwas determined that this dust does not contain anypollutants, it is inhaled by people, it is an eye irritant,and it can cause other physical discomfort. The dustalso penetrates buildings and engine air filters anddamages computers and other electronic equipment.For the visiting public, residents, and NPS employees,this dust plume is also a visual intrusion to anotherwise pristine scenic view. The air qualitymonitoring data should be summarized like the waterquality data sets.

• The PDEA does not refer only to PM2.5 or PM10. All the dustmeets all the standards of which we are aware.

• Text in the final study report (ARS, 2001), supplied by NPS airquality staff, states that "...regardless of the area classification,resources in these areas are protected from significant air pollutionimpacts." On this basis we assume that whatever protectivestandards are considered necessary are in place.

• The PM2.5 and PM10 sizes are known as "respirable" particleswhile the larger particles are known as "non-respirable" particles.Thus it may be misleading or confusing to say that people inhale thelarger particles.

• As stated, the bulk of the dust measured was larger than the PM10size. These larger particles are no longer subject to a specific limitbecause that limit was dropped from the standards.

• The existing standards are intended to cover all the types ofproblems mentioned, including public health and "effects on soils,water, crops, vegetation, buildings, property, animals, wildlife,visibility, transportation, and other economic values, as well aspersonal comfort and well-being."

• The dust does not violate any of the above standards.• Chelan PUD recognizes that the dust is still considered a problem,

which is why it has agreed to assist in finding a way to improve thesituation.


Chelan PUD has an opportunity here to show that theywere responsive to public and agency concerns byfunding an air quality study. Little reference is madeabout this fact. This study provides baselineinformation, and it could be repeated in the future todetermine how effective our mitigation measures hadbeen.

3:3 The comment is appreciated. The study should be mentioned.

Page 27: The Stehekin River deposits sediment in theflats area when the lake level is between 1,100 ft and1,080 ft — particularly in spring and summer. Below1,080 ft lake level, this material is moved to deeperwater.

3:4 The PDEA will note that the area of deposition varies with lake level.

Page 27: The comparison of cross sections waslimited because the FEMA sections could not beexactly located with modern survey.

3:5 That is correct. Only two cross sections could be matched in ameaningful way, and the match is approximate.

Page 28, first paragraph: The statement that the opticalair quality at Stehekin is better than the two otherareas listed is misleading because it only applies toPM2.5 and PM10. Again, most of the dust consists oflarger particles. While it may be true during full lakeor non-dust event periods, during dust events theoptical quality of the air at Stehekin is very bad and is,in fact, probably worse than the other sites.

3:6 The statement in the PDEA is accurate, based on the final study report(ARS, 2001). Some clarifications may help, as follows:• The instrument used to measure light scattering by particles does not

distinguish between scattering caused by small versus large particles;it simply measures scattering of light. Therefore, the measurementsdo not apply only to PM2.5 and PM10 particle sizes.

• Chelan PUD understands that smaller particles can have adisproportionately greater influence on light scattering but wouldexpect that influence to be reflected in the appearance of the site topeople, not just the instrument readings.

• The last sentence in the comment appears subjective and speculativeand is in opposition to the study report which providesmeasurements and states, "During Spring 2000, Stehekin showed thelowest average particle scattering, and likely the best average visualrange of all sites."

• The dust which creates the visual impact that is of concern occurs onStehekin Flats, on land not under NPS management.

• Also, as the report states, "the source of the visibility impairment …is primarily due to wind blown soil and is not subject to PSDreview" under the Clean Air Act (ARS, 2001).

• The same conclusion is reached. The dust does not violate airquality standards, including those intended to regulate impairment ofvisibility.

As mentioned in response 3:2, Chelan PUD recognizes that the dust is





still considered a problem and has agreed to assist in finding a way toimprove the situation.

Page 29: It appears from the data in Table 1 that inMay and June the lake levels under the working groupproposal would be higher than under the existinglicense. Since the 1,098 to 1,100 level is critical forerosion, it seems that the impacts of a new lake levelregime are mixed–not entirely positive as suggested.The negative impact stems largely from the fact thatlake levels held near the 1,098-1,100 ft level couldundermine many existing erosion control structures.

3:7 It is correct that the benefits of lowering the lake level more quickly inthe fall are partially offset by raising it sooner in the spring. The netresult is expected to be beneficial. This will be clarified.

Page 30: Do the 42 “high priority” sites referred to inthe first paragraph include all 17 NPS sites? Again,the NPS listed 17 sites where erosion control wasneeded, and prioritized these relative to each other ashigh, medium, and low. Under no circumstanceshould the PUD limit work to a subset of the 17 sitesoriginally listed.

3:8 The number shown will be corrected. The comment points out theimportance of including all 17 of the NPS sites in the PDEA to avoidseparate EAs for individual erosion repair sites beyond those for whichthe PUD is responsible. A similar correction will be made in the linearfeet to be treated stated in the first paragraph of page 31.


Page 30: This section reads as though the PUD willfund no work at sites with easements. We understandthe sensitivity of this issue for the PUD, but want tomake sure that the Endowment Fund would providefunds for work at these sites — even if we agree that itwon’t be detailed in this document. The NPS agreeswith the PUD position on easements with respect todamage prevention/mitigation but not with respect torecreational enhancements.

3:9 - 4:1 The PUD understands the importance of this issue and the need forrepairs at the 17 sites selected by the NPS. The intent of the EndowmentFund is to give the NPS flexibility in spending the proceeds (interest)from the fund. The NPS' portion of the proceeds from the EndowmentFund could be used to perform work on erosion sites with easements,should the NPS choose to do that. On the other hand, the wording andeffect of the easements is clear. The PUD cannot be held responsible fordamage to easement sites resulting from Project operations. Theeasements are not contingent upon either land ownership or use of thesite.

Page 31, second paragraph: The permitting agencieswill also be involved in the selection of erosioncontrol methods.

4:2 That point will be noted in the next draft.

Page 31: Sites where shoreline erosion is mitigatedwill be revegetated with native plants to help stabilizethe soils, make the site more productive biologicallyand to assist in controlling exotic plants. This shouldbe mentioned.

4:3 The PDEA will be revised to note that revegetation, and also such itemsas aquatic habitat improvements to mitigate for the erosion mitigation,will be included in the erosion repair work.

Page 31: The “Our Analysis” section should mentionthe potential negative impacts from the lake levelchange to existing structures (see comment for page29).

4:4 Chelan PUD agrees that there is some potential for a change in the lakelevel cycle to negatively impact some structures. The next draft of thePDEA will mention this potential. No stakeholder has objected to anyproposed change in the lake level cycle on this basis.

Page 32, Sedimentation and localized flooding: Thework group did not analyze backwater effects onflooding of properties without easements. Further, wehave not seen a final Sedimentation Study Report thataddresses the issues the NPS raised on the draft report.

4:5 The last input on the Sedimentation Summary Report was receivedApril 18, and the final report was sent out May 4, 2001.

As the draft and final reports state, the backwater effect of the Project islimited to areas for which the PUD has easements. This remains truewhen the lateral spreading of the river during flood flows is taken intoaccount. For this reason, no analysis of effects on property withouteasements was considered necessary.


Page 32, last paragraph: It is not accurate to say thatchannel changes have been positive. The error in theanalyses was large. In fact, the error is probably largerthan the “positive change.” It is not accurate to portraythis and other statements as being from the workinggroups. This is PUD’s interpretation. To date, we havenot received a response to NPS comments on the draftSedimentation Study Report.

4:6 The response to the NPS comments was sent on April 24, 2001. This didnot allow enough time for the response to be taken into account in thesecomments.

It is assumed that the statement "the error in the analyses was large" isrelated to comparisons of older and newer cross sections in an effort toevaluate changes. It is correct to state that the results include someuncertainty, but to state that "the error…is large" is speculation. Thestudy report notes the degree and sources of uncertainty in thecomparison. This will be clarified in the PDEA.

The items attributed to the working group were accurate as stated at thetime the PDEA was prepared. Since that time, the PUD has agreed toassist with monitoring of the channel at the Stehekin River mouth. Thisproposal has been accepted by the working group.

Page 32, last paragraph: We understood that thebackwater effect was 9 inches and not the 6 inchesnoted on this page. Further, while the backwater effectmay not extend upstream past easements from thelake, adding 6-9 inches of water to the floodelevations has the potential to affect areas from valleywall to valley wall. Finally, while other impacts haveeffects on flood elevations, this cannot be used todismiss PUD impacts. The discussion in this sectionshould include a cumulative impact analysis.

4:7 Per the draft and final reports on the computer model results, themaximum backwater effect from the lake is 0.51 feet, which was roundedto 6 inches. The 6-inch backwater depth occurs beyond the river mouthat section 2 of the model and tapers to zero at its upstream end. Whenlateral spreading of the river related to this backwater effect is taken intoaccount, the effect of the lake is still contained within the Project'seasements.

The existence of other factors that create backwater effects larger thanthose from the lake has not been used in an effort to "dismiss PUDimpacts" but has been explained to provide a complete context forevaluation of those impacts. Conversely, the presence of those otherfactors and the existence and significance of the Project easements mustbe borne in mind in evaluating this issue.

The Erosion Working Group did not conclude that a cumulative impactanalysis was needed for this issue, however, a more detailed explanationof the various factors which influence the river mouth will be providedby expanding the relevant paragraphs, by a reference to the study reportson this subject or by both means.

Page 33-34, Dust from Stehekin Flats: We are stillexploring potential, practical methods for reducingand mitigating dust. The strategic placement ofconstructed logjams or a log boom coupled withriparian revegetation and higher reservoir water levels

4:8 As mentioned in the comment, this is an area of ongoing investigation.In the absence of an objectively measurable goal, it is difficult to knowwhat reduction in dust concentration will be considered adequate.

Chelan PUD agrees that spraying with a binder or dust suppressant





in the spring may be effective. Strategically placedwater sprinklers in a relatively small area with a hoseand operator for two to three months may reduce thedust by 50% and be cost-effective. Spraying thesilt/dust in the draw down zone with soil bindingchemicals is not a viable option for the NPS, and itshould be deleted from the EA. We are not interestedin $250,000 for a one-time revegetation effort. Anyfunding should be spread out over several years. Thisis to our mutual advantage. We desire a long-termpartnership with Chelan PUD to explore the practicaloptions and resolve as much of the problem aspossible.

chemical is not worthy of further consideration. It was included for thesake of completeness since it was examined extensively. The otherpotential methods mentioned in the comment (logs, riparian vegetationand raising the lake earlier) hold some promise, though each has its owndrawbacks and limitations. Placement of logs and revegetation shouldcomplement the planned erosion repair work, since it includes work withLWD and revegetation.

The total source area for dust is not small, but it is thought that a largeportion of the dust may originate from a small fraction of the area. If thatis the case, the use of sprinklers could be a viable option.

As mentioned above, the PUD has agreed to assist in finding a way toaddress this problem.

Page 36-42, Water Quality: The water qualitymonitoring data is synoptic at best, an

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