FEDERAL ENERGY REGULATORY COMMISSION
`Washington, D. C. 20426
`
`OFFICE OF ENERGY PROJECTS
`
`To the Parties Addressed:
`
`MAY 0 5 2003
`
`In July 2002, we issued a report entitled, "Mitigation Effectiveness Studiesat the
`Federal Energy Regulatory Commission: draft water quality." This draft report presented
`the results of our evaluation of the effectiveness of water quality mitigation measures
`implementedat projects that were licensed or re-licensed since 1986. We asked for your
`comments, concerns, and/or recommendations. A water quality workshop was conducted
`in September 2002 to discuss these results and any comments wereceive on the report.
`
`I am enclosing a copy of ourfinal report on water quality entitled, "Mitigative
`Effectiveness Studies at the Federal Energy Regulatory Commission: Water Quality.”
`This report incorporates comments and recommendations wereceivedin letters and in
`person at the workshop. We wantto thank those that took the time to read the draft report
`and commentonit and thank those that attended the workshop.
`
`Ournext endeavor will involve fish passage and a draft report should be out later
`this year. If you are not interested in receiving copies of future reports, please let us
`know, otherwise, we will continue to send you the information relevant to your project as
`it becomesavailable.
`
`Thank you for your cooperation in this matter. If you have any questions
`concerningthis report, please contact Bob Fletcher at (202) 502-8901 or via emailat
`robert. fletcher@:ferc.gov -
`
`Sincerely,
`
`ttsna
`
`
`irector, Division’of Hydropower
`Administration and Compliance
`
`enclosure
`
`

`

`Darwin Pugmire
`Box 70
`1220 Idaho Street
`Boise, ID 83707
`
`Ron Settje
`Ketchikan Public Utilities
`2930 Tongass Avenue
`Ketchikan, AK 99901
`
`p-18
`
`p-420
`
`Larry L. Yarger
`Carolina Power & Light
`P.O. Box 1551
`Raleigh, NC 27602
`
`Steven J. Klein
`Light Superintendent
`P.O. Box 11007
`Tacoma, WA 98411
`
`p-432
`
`p-460, 1862
`
`Nelson P. Turcotte
`Wolf River Hydro LP
`36 Kimberly Drive
`Kapuskasing, ON P5N
`
`E.D. Bruce
`Duke Power Company
`P.O. Box 1006 (ECO8P)
`Charlotte, NC 28201
`
`p-710
`
`p-1267
`
`Randal 8. Livingston
`Mail Code Ni1E
`P.O. Box 770000
`San Francisco, CA 94177
`
`Jay Maher
`P.O. Box 740
`415 Lincoln Street
`Holdredge, NE 68949
`
`p-1333
`
`p-1417
`
`Gary Gwyn
`Brazos River Authority
`4400 Cobbs Dr. P.O. Box 7555
`Waco, TX 76714
`
`Bob Sullivan
`Grand River Dam Authority
`P.O. Box 409, Drawer G
`Vinita, OK 74301
`
`p-1490
`
`p-1494
`
`

`

`Rita L. Hayen
`Wisconsin Electric Power Co.
`231 West Michigan St.
`P.O. Box 2046
`Milwaukee, WI 53201
`
`Wesley Moody
`General Manager
`2244 Walnut Grove, Rm. 285
`Rosemead,CA 91770
`
`p-1759, 1980, 2072, 2073, 2074, 2131, 11830,
`11831
`
`p-298, 1930
`
`Thomas G. Schaff
`Consolidate Water Power Co.
`P.O. Box 8050
`Wisconsin Rapid, WI 54495
`
`William Nadeau
`Northeast Utilities Service Co
`P.O. Box 270
`Hartford, CT 06141
`
`p-1953
`
`p-2004, 2287, 2288, 2456
`
`James Weldon
`Denver Water Department
`1600 West 12th Avenue
`Denver, CO 80254
`
`Steven Fry
`Hydro Safety Manager-Avista Corp
`E.1411 Mission Avenue
`Spokane, WA 99220
`
`p-2035
`
`p-2058
`
`Robert W. Gall
`2301 North Third Street
`Wausau, WI 54403
`
`John Van Daveer
`PP&L Montana, LLC
`45 Basin Creek Road
`Butte, MT 59701
`
`p-2113
`
`p-2188
`
`David Gibson
`Empire District Electric Co.
`602 Joplin Street, P.O. Box 127
`Joplin, MO 64802
`
`Gary Dudley
`P.O. Box 800
`2244 Walnut Grove Avenue
`Rosemead, CA 91770
`
`p-2221
`
`p-2290
`
`

`

`Donald Mercier
`650 Main Street
`Berlin, NH 03570
`
`Mike Kline
`U.S. Gen New EnglandInc.
`One Bowdoin Square, Suite 600
`Boston, MA 02114
`
`p-2300, 2311, 2326, 2327, 2422, 2423
`
`p-2323
`
`Robert L. Boyer
`Vice President, Bin # 10170
`241 Ralph McGill Blvd.
`Atlanta, GA 30308
`
`David C. Benson
`c/o AES Rural Route 12, Box 1000
`Roseytown Road
`Greensburg, PA 15601
`
`p-2336
`
`p-2343, 2459
`
`Bill Rauscher
`800 Industrial Park Drive
`Iron Mountain, WI 49801
`
`Joe Niemela
`30 West Superior Street
`Duluth, MN 55802
`
`p-2357, 2394, 2431, 2486
`
`p-2360, 2663
`
`Brent Frost
`International Paper Co.
`Riley Road
`Jay, ME 04239
`
`Lloyd Everhart
`1414 West Hamilton Avenue
`P.O. Box 8
`Eau Claire, WI 54702
`
`p-2375, 8277
`
`p-2390, 2475, 2587
`
`Donald Hallee
`P.O. Box 129
`Riverside Avenue
`Gilman, VT 05904
`
`ThomasSteiner
`200 North First Avenue
`P.O. Box 340
`Park Falls, WI 54552
`
`p-2392
`
`p-2395, 2421, 2473, 2640
`
`

`

`David W. Harpole
`Wisconsin Public Service Co.
`600 N. Adams Street
`Green Bay, WI 54307
`
`p-2402, 2433, 2506, 2522, 2525, 2546, 2560, 2581
`
`p-2404
`
`R.M. Akridge
`P.O. Box 2641
`Birmingham, AL 35291
`
`Andy Blystra
`15 West Six Street
`Holland, MI 49423
`
`Paul C.Hittle
`Consumers Power Co.
`330 Chestnut Street
`Cadillac, MI 49601
`
`p-2407
`
`p-2436, 2447, 2448, 2449, 2450, 2451, 2452, 2453,
`2468, 2580, 2599
`
`Scott D. Goodwin
`Seneca Falls Power Corp.
`1233 Alpine Road, Suite #202
`Walnut Creek, CA 94596
`
`Norman Liu
`Room 305, Municipal Bldg.
`245 Washington Street
`Watertown, NY 13601
`
`p-2438
`
`p-2442
`
`MarkE. Sundquist, P.E.
`300 W. Washington Street, Suite 801
`Chicago, IL 60606
`
`Charles Alsberg
`P.O. Box 167
`116 State Street
`Neshkoro, WI 54307
`
`p-2446, 9840
`
`p-2523, 2689
`
`Chris Shaw
`General Manager-Hydro Operations
`150 Main Street
`Lewiston, ME 04240
`
`Rich Fennelly
`Penobscot Hydro, LLC
`Milford Station, PO Box 276
`Milford, ME 04461
`
`p-2325, 2519, 2527, 2528, 2529, 2531, 2552
`2556, 2557, 2559
`
`p-2403, 2534, 2666, 2712, 2727
`
`

`

`Neville Lorrick
`South Carolina Electric and Gas Co.
`111 Research Drive
`Columbia, SC 29203
`
`Mark E. Anderson
`STORA ENSO North America
`P.O. Box 8050
`Wisconsin Rapids, WI 54495
`
`p-2535
`
`p-2536
`
`Bill Vineyard
`American Electric Power Service
`1 Riverside Plaza
`Columbus, OH 43215
`
`Jeffrey Lacasse
`P.O. Box 356
`Waterville, ME 04240
`
`p-255]
`
`p-2555
`
`G. Smithberger
`American Electric Power Service
`138 40 E. Jefferson Road
`Mishawaka, IN 46545
`
`HughJ. Ives
`89 East Avenue
`Rochester, NY 14649
`
`p-2583, 2584
`
`Peter D. Prast
`Electric and Water Department
`777 Island Street
`Kaukauna, WI 54130
`
`John L. Warshow
`26 State Street
`Montpelier, VT 05602
`
`Thomas K. O'Connor
`Metro Water Recl Dist. Gr. Chgo.
`100 East Erie Street
`Chicago, IL 60611
`
`p-2756
`
`p-3574
`
`Ted S. Sorenson
`Tiber Montana, L.L.C.
`5203 South 11th Street
`IdahoFalls, ID 83404
`
`p-2579
`
`p-2588
`
`p-2866
`
`

`

`Cheryl Krueger
`19515 North Creek Parkway
`Suite 310
`Bothell, WA 98011
`
`Robert S. Grimm
`President
`P.O. Box 222
`Port Townsend, WA 98368
`
`p-8864, 9025
`
`p-10440
`
`Gregg Blanche
`13561 West Bay Shore
`Suite 3000
`Traverse City, MI 49684
`
`Frank Christie
`Manager, P.O. Box 147
`6000 South M-30
`Edenville, MI 48620
`
`p-10805
`
`p-10522, 10808
`
`Sam Nott, Gen'l Manager
`P.O. Box 147
`6000 South M-30
`Edenville, MI 48620
`
`Ralph Mellin
`Idaho Water Resource Board
`P.O. Box 83720
`Boise, ID 83720
`
`p-10809, 10810
`
`p-10819
`
`Charles Schrock
`Wisconsin Public Service Co.
`600 N. AdamsStreet
`Green Bay, WI 54307
`
`Kevin Webb
`Chi EnergyInc.
`200 Bulfinch Drive
`Andover, MA 01810
`
`p-10854
`
`p-11482, 11163
`
`Tim Henderson
`H&H Properties
`1240 Springwood Church Rd.
`Gibsonville, NC 27249
`
`Thomas Griffin
`Crown Hydro Company
`5436 Columbus Ave. South
`Minneapolis, MN 55417
`
`p-11169
`
`p-11175
`
`

`

`Charles C. Wood
`Mayo Hydro
`1240 Springwood Church Rd.
`Gibsonville, NC 27249
`
`Kenneth J. Gates
`CordovaElectric Coop. Inc.
`P.O. Box 20
`Cordova, AK 99574
`
`p-11219
`
`p-11243
`
`Duncan S. Broatch
`Summit Hydropower
`67 May Brook Road
`Woodstock, CT 06281
`
`David Krumwiede
`City Manager
`P.O. Box 40
`Abbeville, SC 29620
`
`p-11282, 11547
`
`p-11286
`
`Richard K Muntz
`109 South Detroit Street
`Lagrange, IN 46761
`
`Edward M.Clark
`P.O, Box 715
`Lincoln, NH 03251
`
`p-11291
`
`p-11313
`
`William S. Woods
`505 Riverside Drive
`Columbia, TN 38401
`
`p-11351
`
`p-11402
`
`Samuel S. Hirschey
`c/o Orion Power, New York
`225 Greenfield Parkway, Suite 201
`Liverpool, NY 13088
`
`p-2538, 2569, 11408
`
`p-11433
`
`C. Nordeman
`City of Crystal Falls
`401 Superior Avenue
`Crystal Falls, MI 49920
`
`Philip Curts
`Town of Madison
`Department of Public Works
`P.O. Box 190
`Madison, ME 04950
`
`

`

`Floyd Collins
`City of Albany
`333 Broadalbin SW, P.O. Box 490
`Albany, OR 97321
`
`Milton Owen
`415 Lime Kiln Road
`R.R. #2
`Osage, [A 50461
`
`p-11509
`
`p-11530
`
`Arlo L. Rude
`P.O. Box 528
`Thief River Falls, MN 57601
`
`David Brown Kinlock
`Soft Energy Associates
`414 South Wenzel Street
`Louisville, KY 40204
`
`p-11546
`
`p-11685
`
`Roger Braden
`P.O. Box 1231
`327 North Wenatchee Ave
`Wenatchee, WA 98801
`
`John MacDonald
`VP-Operations, PSNH
`P.O. Box 330
`Manchester, NH 03105
`
`p-943
`
`p-2288, 2456, 2457
`
`Mark Noyes
`Con Edison Development
`111 Broadway, 16th Floor
`New York, NY 10006
`
`R.A. Landolt
`Hydro Resources Dept.
`825 N.E Multinomah Suite 1500
`Portland, OR 97232
`
`p-2334
`
`p-2337, 2381
`
`David Holabird
`PDI New England,Inc.
`142 Lower LyndonStreet
`Caribou, ME 04736
`
`B. Frank Moon
`WPS New England Generation
`1088 Springhurst Dr.
`Green Bay, WI 54304
`
`p-2367
`
`p-2368
`
`

`

`M. Scarzello
`Central Vermont Public Service
`77 Grove Street
`Rutland, VT 05701
`
`Roy Bourgue
`City of Norwich-Public Utilities
`16 South Golden Street
`Norwich, CT 06360
`
`p-2396, 2397, 2399, 2400, 2489
`
`p-2441, 11574
`
`Steven F. Bliss
`Vermont Marble Company
`61 Main Street
`Proctor, VT 05765
`
`Jeffrey Martin
`One Katahdin Ave
`Millinocket, ME 04462
`
`p-2445
`
`p-2458, 2520
`
`John Skorupski
`3205 State Route 7
`Johnsonville, NY 12094
`
`Cary Feldmann
`Puget Sound Energy,Inc.
`OBC-14N,P.O. Box 97034
`Bellevue, WA 97034
`
`p-2487
`
`p-2494
`
`Everett Jordan
`Eugene Water & Electric BD
`500 East 4th Avenue
`Eugene, OR 97440
`
`David Barnhart
`Elkem Metals Company -Alloy, LP
`P.O. Box 613, Route 60
`Alloy, WV 25002
`
`p-2496
`
`p-2512
`
`Jon A. Soter
`163 Acorn Lane
`Colchester, VT 05446
`
`Frank C. Brown
`REXAM Inc
`4201 Congress Street Suite 340
`Charlotte, NC 28209
`
`p-2513
`
`p-2608
`
`

`

`Michael Chapman
`International PlaceII
`6400 Poplar Avenue
`Memphis, TN 38197
`
`WesHallowell
`Kennebec Water Power Co.
`37 Childs Road
`Norridgewock, ME 04957
`
`p-2622
`
`p-2671
`
`Gary Parker
`Seattle City Light
`700 5th Avenue, Suite 3300
`Seattle, WA 98104
`
`Walter L. Bok
`204 Commane Road West
`P.O. Box 170
`Baldwinsville, NY 13027
`
`p-2705
`
`p-4715
`
`William Wasnak
`Adirondack Hydro Dev. Corp.
`39 Hudson Falls Road
`South Glen Falls, NY 12803
`
`C.D.L. Perkins
`c/o Bryon Brothers,Inc.
`The Arlington Building
`1802 Bayberry Court, Suite 301
`Richmond, VA 23226-3767
`
`p-5276
`
`p-8535, 8657
`
`Frank Christie
`359 River Street
`Suite 202
`Manistee, MI 49660
`
`Daniel N. Evans
`212 Range Road
`Kings Mountain, NC 28086
`
`p-10522
`
`p-10881
`
`Jay Boeri
`257 Weed Road
`Hartland, VT 05048
`
`Michael V. Stimac
`HDREngineering,Incl.
`500 108th Ave, NE, Suite 1200
`Bellevue, WA 98004
`
`p-11090
`
`p-11480
`
`

`

`Robert G. Parker
`1209 University of Oregon
`Hendrick Hall
`Eugene, OR 97403
`
`p-11512
`
`Al Solonsky
`Seattle City Light
`700 Fifth Ave, Suite 3300
`Seattle, WA 98104-5031
`
`Andrew Fauland
`American Rivers National Office
`1025 Vermont Ave. N.W.
`Suite 720
`Washington, D.C. 20005
`
`Karen Hester Abrams
`Office of Habitat Conservation
`NMFS
`1315 East-West Highway
`Silver Spring, MD 20910
`
`Fred Springer
`HydropowerPolicy Advisor, C.E.
`Troutman Sanders LLP
`401 Ninth Street, NW Suite 1000
`Washington, DC 20004-2134
`
`George H. Schneider,P.E.
`Water Management Section
`Seattle Public Utilities
`710 Second Avenue, Room 570
`Seattle, WA 98104
`
`Kenneth Kimball
`Appalachian Mountain Club
`Route 16, Box 298
`Gorham, NH 03581-0298
`
`Mark R. Stover
`Director of Government Affairs
`National Hydropower Association
`1 Massachusetts Avenue, NW Ste. 850
`Washington, DC 20001
`
`Mr.Jeffrey Cueto
`Vermont Agency of Natural Resources
`103 South Main Street
`Building 10 North
`Waterbury, VT 05671-3287
`
`Mr. Leroy Young
`Pennsylvania Fish and Boat Commission
`Division of Environmental Services
`450 Robinson Lane
`Bellefonte, PA 16823-9616
`
`

`

`Mr. Curtis I. Taylor
`Chief, Wildlife Resources Section
`WV Dept. of Natural Resources
`Capitol Complex, Building 3, Room 812
`Charleston, WV 25305
`
`Mr. David Bryson
`U.S. Fish and Wildlife Service
`3817 Luker Road
`Cortland, NY 13045
`
`Mr. Kenneth Carr
`U.S. Fish and Wildlife Service
`70 Commercial Street, Suite 300
`Concord, NH 03301-5087
`
`Dana Paul Murch
`Bureau of Land and Water Quality
`Maine Dept. of Environmental Protection
`17 State HouseStation
`Augusta, ME 04333-0017
`
`John Morris, Director
`N.C. Dept. of Environmental and Natural
`Resources
`Archdale Building, 11th floor
`512 North Salisbury Street
`Raleigh, NC 27604-1148
`
`Alfred Vang, Deputy Director
`Land, Water, and Conservation Division
`South Carolina Dept. of Natura] Resources
`2221 Devine Street, Suite 222
`Columbia, SC 29205
`
`Thomas Meronek
`Wisconsin Dept. of Natural Resources
`Peshtigo River Center
`P.O. Box 208, 101 N. Ogden Rd.
`Peshtigo, WI 54157
`
`Mr. John Biagi
`Georgia Dept. of Natural Resources
`2070 U.S. Highway 278, S.E.
`Social Circle, GA 30025
`
`Mr.Jim Burroughs
`Fisheries Division, ODWC
`1801 North Lincoln
`OklahomaCity, OK 73105
`
`Mr. Fred Harders
`Alabama Dept. of Conservation and
`Natural Resources
`64 North Union Street, Suite 567
`P.O. Box 301456
`Montgomery, AL 36130-1456
`
`

`

`Dr. Kurt Newman
`FERC Unit Coordinator
`Fisheries Division, MDNR
`P.O. Box 30446
`Lansing, MI 48909
`
`Chuck Zimmerman
`Framtome ANP DE&S
`1394 Ragley Hall Road
`Atlanta, Ga 30319
`
`Mr. Jim Fossum
`U.S. Fish and Wildlife Service
`1015 Challenger Court
`Green Bay, WI 54311
`
`David M. Diamond
`Office of Policy Analysis
`Departmentof the Interior
`1849 C Street, NW MS4426
`Washington, DC 20240
`
`Rebecca Sherman
`Coordinator, Hydropower Reform Coalition
`1025 Vermont Ave. NW;Suite 720
`Washington, DC 20005
`
`

`

`EVALUATION OF MITIGATION EFFECTIVENESS
`
`AT HYDROPOWERPROJECTS: WATER QUALITY
`
`Division of Hydropower Administration and Compliance
`
`Office of Energy Projects
`
`Federal Energy Regulatory Commission
`
`May 2003
`
`

`

`CONTENTS
`
`List Of Figures ........:c-ccsecssssseccoesseseeceesencesescessseeesssecesseonacesenensoessssneatsneeseneacastacsseasateaesessraeseaes
`
`List Of Tables .........cscssscsscsserssssscssenssessenensusensesennsensessesseessauscaseeseeoeensscescenerensacenateasnasaceossensees
`
`Acknowledgment6.............::scsssssscsssscsssssssecssosseenesesesceessessessatsesnenseaseuseseeseatarsanasararestecsesscasoneee
`
`Executive SUMIMALY .........ccccccecssesseseesecessesesssaesncnscenssveevscsoserssassansassseessseussessecsssnesecesteaseenteates
`
`1.0 Tintroduction.............ccccecseeccceescssesnecassusecsacnscevsceenacssceessseneessensedsnssssasserscnssccessesesseustesseesvesss
`1.1 Background ........csccsssesrssssseveesessosnsesssassesscensansesssessssatsssacssssenresngecenateasatseatsesees
`1.1.1 Review of Previous Hydropower Mitigation Studies.................00
`1.1.2 Overview of Licensing Process ........ssssssassssssssseesssnscescscnesesceevenees
`1.2 Purpose Of Study... cscsscccsssonsensssnsessnsesseenssansessaseesersssessssseesesseseereresersrecesees
`1.2.1 Measures of Effectiveness........ssscssccscsscsssssecscreerssscsrscsessscesseassarserees
`1.2.2 Description of RIMS Database..............:scsssssecessesssensescsssseseeateesrnsees
`
`2.0 Data Amalysis .0.....:ccccccsssssesscsessessssessenessesanercasenseassuaseneseeseacsessseensssenesensenseeensasseteassasenas
`2.1.1
`Summary of Monitoring Requirements...............0c0ccessssesessesseessensens
`2.1.2 Compliance with Criteria...cccccstecssssesseerecsesesseteesetessassssssasssses
`2.1.3 Assessment of Mitigation Measures.................::sssersserssssrsesssuscenseee
`
`3.0 Summary and Conclusion.........ccccccccccsseccecesesseecsesccessensessessateseeceeseersoesssnenessersesseatseaees
`3.1 Value of Monitoring to Identify Problem...................ccsssessesseserresneseessessesseaers
`3.2 Mitigation Effectiveness ..............scescsscsesscessecseeeseesresceseeeesesceseenevenessesesseseasssseeees
`3.3 Recommendations. .............ccccccssceesecsescesseenesessveesenessntsetenseseesesestusneseraseesessnevaeenees
`
`4.0 References ..........:ccccssscecsssseeeseeseeseseseasassncersesasscseeseesseesceaseaneeceseescacensseeesenanacassaveaneenenesees
`
`5.0 List of Preparers.......csscssssssssssssesssssesscessscsssersseesssnesserseasersenssteenessasseeseseorereessserevereresars
`
`ili
`
`Page
`
`iv
`
`iv
`
`Vv
`
`vi
`
`1
`1
`2
`3
`4
`5
`6
`
`10
`11
`16
`19
`
`27
`27
`30
`31
`
`34
`
`35
`
`

`

`Figure
`
`1-1
`
`Table
`
`1-1
`
`1-2
`
`LIST OF FIGURES
`
`Histogram ofthe licensing years for 81 hydropower projects that comprise the
`database used in the analysis of mitigation effectiveness..............:scceeseeereereeres
`
`LIST OF TABLES
`
`Numbers of hydropower projects with DO requirements for each of five
`capacity categories included in an earlier DOE mitigation study and the
`present FERC study .......ccssscsesscessessenscessssscesseeseeseseeseseaesseaceansesersensensoreareenanee?
`
`Regional summary of the modeof operation and water quality monitoring
`parameters at 81 projects for which monitoring data were available in the
`RIMS database.........scccscsssscesesseresseecessassgeeessessecseesaceeseeeceescessssesaeeneeseeeeeeseneaseeseetens
`
`Summary ofthe status and type of water quality monitoring plans required for
`53 projects for which no monitoring data were available in the RIMS database.
`
`Regional summary of the water quality monitoring programs and monitoring
`results for 81 projects for which monitoring data were available in the RIMS
`Catabase ........cssccccssesscscsssseccessescerssenscescessesscssansenseeseecsstoassesetscesstcessesconseosessasaneeses
`
`2-3
`
`Location, capacity, operational mode, and license/relicense date of nine
`hydroelectric projects where mitigative measures were implemented to increase
`downstream concentrations of dissolved oxygen or enhance temperatures..........
`
`Description of water quality monitoring plans and mitigation at nine
`' hydroelectric projects where mitigative measures were implemented to increase
`downstream concentrations of dissolved oxygen or enhance temperatures..........
`
`1Vv
`
`
`
`ipe fo)
`
`10
`
`12
`
`13
`
`19
`
`20
`
`

`

`ACKNOWLEDGMENTS
`
`The draft report was discussed at a workshop held in September 2002 in Atlanta, and
`
`written comments were received from Georgia Power Company and American Rivers. The
`
`authors thank those individuals and organizations who attended the workshop and/or submitted
`
`comments.
`
`

`

`EXECUTIVE SUMMARY
`
`vi
`
`The effectiveness of water quality monitoring and mitigation plans at hydropower
`
`projects was assessed to determine whetherthe license requirements of the Federal Energy
`
`Regulatory Commission (FERC or Commission) are achieving the desired result of resource
`
`protection. Water quality is the first of several mitigation areas (others include fish passage and
`
`recreation) that will be evaluated in the next few years. This activity is part of a FERCstrategic
`
`plan that describes the goals and the corresponding measures of performance for meeting the
`
`intent of the Government Performance and Results Act of 1993. The assessment is based on
`
`information, such as letters, monitoring plans and annual reports, and orders, contained in the
`
`Commission’s public Records of Information Management System (RIMS) database of all FERC
`
`projects that were licensed since 1986. The RIMS database was replaced in 2002 by the Federal
`
`Energy Regulatory Records Information System (FERRIS).
`
`Important water quality parameters that can be adversely affected by hydropower projects
`
`include dissolved oxygen (DO), water temperature, and total dissolved gases, but sufficient data
`
`were only available for DO and temperature. Of the 81 projects evaluated in this study, 79%
`
`were licensed or relicensed during a five-year period from 1994-1998. Of these, 75% had a
`
`capacity of <10 MW and 64% were operated in a run-of-river mode. Most were located in the
`
`North Central (59%) or Northeast (19%) United States.
`
`The assessment focused on DO monitoring and mitigation, becauseit is the water quality
`
`parameter that is most frequently monitored at hydropowersites, andit is a significant
`
`determinant of ecosystem health. In addition, states have established numeric criteria for DO to
`
`protect aquatic ecosystems, so an unambiguous measure of mitigation effectiveness is a
`
`comparison of measured DOwith thestate criterion. The results of this assessment indicated
`
`

`

`Vil
`
`that low DO in the tailwaters was not a commonoccurrence. Only 11 of the 81 projects (14%)
`
`had DO or temperature problems requiring mitigation. Levels of DO were successfully
`
`increased byaeration of (1) intake waters or tailwaters, using diffusers, agitators, or weirs; or
`
`(2) turbines. Although several options were usually tested and some may have beenineffective,
`
`the final mitigation measure waseffective (i.e., DO levels were increased enough to meetstate
`
`water quality criteria).
`
`The assessment also found that the DO monitoring plans of the 81 projects were well
`
`designed for their intended purpose:
`
`to assess compliance with state criteria and to identify DO
`
`problems. More than 50% ofthe projects monitored DO and temperature continuously during
`
`the period when DO can be mostlimiting to biota (e.g., May-October), thus ensuring that any
`
`low DO problems would be detected. The majority of the projects never encountered DO
`
`problems, and many discontinued monitoring.
`
`Several recommendations were made to enhance the effectiveness of both monitoring
`
`plans and mitigation planning. License articles that address water quality monitoring should
`
`specify the duration of the monitoring and the conditionsthat could result in the discontinuation
`
`and resumption of monitoring. Water quality monitoring data should be includedin a central
`
`database with public access (e.g., STORET). A process for mitigation planning that includes
`
`guidance to developers on identifying and evaluating alternatives should be includedin the
`
`appropriate license article. Additional information is needed on the most effective mitigation
`
`measures for various project and environmental conditions, as obtained from rigorousfield tests
`
`that employ monitoring programsspecifically designed to measure the successofthe test.
`
`Finally, all parties must ensure that the best technical information is used in developing
`
`mitigation alternatives and in selecting and designing the preferred alternative.
`
`

`

`1.6 Introduction
`
`To minimize the adverse effects of energy production facilities on the environment,
`
`mitigative measures can be implemented that reduce and/or compensate for the impacts of
`
`facility construction and operation. Licenses issued by the Federal Energy Regulatory
`
`Commission (FERC or Commission), which regulates nonfederal hydropower facilities, usually
`
`contain articles that condition project design or operation to protect, mitigate, and/or enhance
`
`environmental resources and to achieve nonpowerbenefits. The Government Performance and
`
`Results Act (GPRA)of 1993 defines how federal agencies managetheir performance and
`
`requires the developmentofstrategic plans that describe the goals and measures ofprogress and
`
`performancein achieving those goals. In response to GPRA, FERC implemented an initiative in
`
`2000 to evaluate the effectiveness of the environmental mitigation requirements incorporated in
`
`the licenses.
`
`This report presents the results of an evaluation of the effectiveness of water quality
`
`mitigation measures implemented at nonfederal hydropower projects that were recently licensed
`
`or relicensed by FERC, Shoreline management was addressed previously (FERC 2001a), and
`
`other mitigation measures, including fish passage andrecreation, will be evaluated over the next
`
`few years. Finally, the report should not be considered a comprehensive review of the
`
`alternatives for mitigating water quality impacts at hydropower projects. Such reviews are
`
`provided by Sale et al. (1991) and more recently by EPRI (2002).
`
`1.1 Background
`
`In the 1980’s, environmental protection conditions in FERC licenses were implemented
`
`based on relatively limited information that was typically collected early in the licensing process.
`
`

`

`Theeffects of these measures were rarely evaluated, so little was known about whether the
`
`measures provided the level ofprotection intended at license issuance. Bythe early 1990's, but
`
`especially after 1993, most FERClicenses included requirements to develop monitoring plans
`
`for assessing significant environmental resources, such as water quality andfisheries. These
`
`plans and monitoring data have been includedin reports submitted to FERC bythelicensees.
`
`The reports and other compliancefilings required under the variouslicense articles and
`
`Commission orders were reviewed in this study.
`
`1.1.1 Review of Previous Hydropower Mitigation Studies
`
`Hydropower mitigation that provided for the maintenance ofinstream flows, dissolved
`
`oxygen (DO), and upstream and downstream fish passage was examinedin a U.S. Departmentof
`
`Energy (DOE)study by Sale et al. (1991). The study used public information from Commission
`
`records and additional information obtained from a written survey of developers andstate/federal
`
`resource and regulatory agencies, focusing on nonfederal hydropower projects that were licensed
`
`or exempted between January 1980 and July 1990.
`
`From a target population of 707 projects that were identified in the FERC Hydropower
`
`Licensing Compliance Tracking System as having mitigation requirements for instream flow,
`
`DO,and/orfish passage, information was obtained on 280 projects. This sample, according to
`
`FERCrecords, included 56 projects (26%) that had implemented DO mitigation measures, of
`
`which 13 had no water quality mitigation requirements stipulated in their licenses. The 1991
`
`study also found that compliance with state water quality criteria was the most common purpose
`
`of the DO mitigation, andspill flows andturbine aeration were the most frequently implemented
`
`mitigation measures. Thirty-five ofthe 53 projects (66%) that provided information on
`
`

`

`mitigation methods employed spill (either alone or with other methods) to mitigate DO
`
`problems. At the time of this 1991 study, FERC commonly required continuousspill to mitigate
`
`DO problemsat low-head hydropowerprojects duringcritical periods of the year (Taylor 1988).
`
`Moreover, spill was employed twiceas often as other mitigation methodsat projects with design
`
`headsofless than 15 m, and maybethe mitigation of choice at smaller hydropower sites, where
`
`feweralternatives are available when the constraints of cost and design are considered (Cada and
`
`Francfort 1995). For such projects, capital investments would be inappropriate when the
`
`frequency andseverity of DO problemsare relatively low or uncertain (Sale et al. 1991). In
`
`somecases, nonstructural approaches, such as negotiation for site-specific water quality criteria,
`
`including biocriteria, and the use ofwatershed-based strategies for managing water quality may
`
`provide a more flexible andless costly alternative to structural or operational modifications
`
`(Petersonet al. 2003).
`
`The 1991 study concluded that the proportion ofprojects with environmental mitigation
`
`requirements had increased significantly during the 1980s,but little information was available on
`
`the effectiveness ofthat mitigation. This earlier study had to rely primarily on surveys of
`
`licensees to obtain information on the implementation ofmitigation because the availability of
`
`data to directly assess its success was limited. The present study used the data from the FERC-
`
`required water quality monitoring programs to identify DO problemsandassess the effectiveness
`
`of the measures implemented to mitigate those problems.
`
`1.1.2 Overview of Licensing Process
`
`Whena licenseis issued for a project, the articles contain provisionsthat the licensee file a
`
`monitoring plan. After consulting with the resource agencies, the licensee prepares a plan for
`
`

`

`Commission approval. In the case of water quality issues, the state water quality permitting
`
`agency or the U.S. Environmental Protection Agency (EPA)is consulted as well as other state
`
`and federal resource agencies. The state water quality agency’s requirements are incorporated
`
`into the Clean Water Act (CWA)Section 401 Certification, a mandatory componentof the
`
`FERClicense, unless waived. Commission staff review the plan and issue orders approving the
`
`monitoring. Provisions are usually incorporated into the monitoring plan to determine the goal
`
`of the monitoring and measures that need to be taken to ensure compliance with the license
`
`requirements. Authority is usually reserved by the Commission to require changesto the plan,
`
`project operation, and/or facilities during the term ofthe license in order to ensure compliance
`
`and environmental protection.
`
`Oncethe plan is approved, the licensee begins monitoring. The type and frequency of
`
`monitoring is project-specific. Annual reports and any recommendations developed in
`
`consultation with the resource agencies usually will be filed by the licensee with the resource
`
`agencies and the Commission. These reports can identify deviations from the license
`
`requirements, problems encountered during the monitoring period, and measures taken to
`
`address any problems. Evaluating the effectiveness of these measuresis the goal of the present
`
`study.
`
`1.2 Purpose of Study
`
`The purposeofthis study is to evaluate the water quality monitoring programs required
`
`by FERClicenses and assess the effectiveness of mitigation measures implemented to improve
`
`water quality downstream of the projects. From this evaluation, the Commission will be able to
`
`

`

`determine whether the license requirements are achieving the desired result of resource
`
`protection. Studies such as this and future studies offish passage and recreation mitigation will
`
`help guide Commission decisions regarding the need for environmental mitigation. The findings
`
`of this study are intended to improve internal practices of the Commission, thus making
`
`regulatory procedures more cost effective and efficient. For example, the lessons learned from
`
`evaluating and improving mitigation effectiveness will enable Commissionstaff to design better
`
`license articles. This approach providesall stakeholders with additional flexibility to
`
`cooperatively decide the best and most cost-effective method of meeting license objectives. The
`
`goal of this and the other studies that will follow is to ensure that mitigation measures
`
`implemented at nonfederal hydropowerprojects are both necessary and effective.
`
`1.2.1 Measures of Effectiveness
`
`The effectiveness of water quality mittgation at hydropower projects will be measured by
`
`a comparison with state water quality criteria. If frequent exceedances of the numeric criterion
`
`characterized the project prior to the implementation of mitigation measures and no exceedances
`
`occurred afterward, the mitigation was successful. Another measure can be the frequency and
`
`duration of exceeding state criteria before and after mitigation. However, if exceedances
`
`continue to occur, the present mitigation may be necessary but not sufficient to always meet
`
`water quality criteria.
`
`The effectiveness of water quality monitoring plans was also evaluated to assess their
`
`ability to detect potential problems. Such factors as the frequency and duration of sampling and
`
`the effectiveness of the monitoring program in capturing worst-case conditions(i.e., low
`
`streamflow and high temperatures) were considered. A poorly designed monitoring plan that
`
`

`

`fails to adequately capture these conditions can result in undetected water quality problems. On
`
`the other hand, a well-designed monitoring program that has detected no exceedancesofstate
`
`water quality criteria for several years, yet has no provision for reviewing and/or downsizing the
`
`monitoring effort, is inefficient and may even be unnecessary.
`
`Because the effectiveness of mitigation is linked to the monitoring plan that was
`
`developed to measure that effectiveness, both mitigation measures and monitoring plans are
`
`included in the study. Mitigation refers to those structural and nonstructural approachesthat are
`
`implemented at hydropower projects specifically to increase DO. Monitoring plansare not
`
`Mitigative measures. Rather, they are needed to evaluate compliance with water quality criteria;
`
`determine the need for mitigation if those criteria are not met; and assess the effectiveness of that
`
`mitigation.
`
`1.2.2. Description of RIMS Database
`
`The review ofthe effectiveness of water quality mitigation measuresutilized information
`
`contained in the public record for hydropowerprojects that were licensed orrelicensed since
`
`passage of the Electric Consumers Protection Act in 1986. Letters, monitoring plans, and reports
`
`filed with the Commission by licensees, as well as the orders issued by the Commission based on
`
`these documents, constitute the key elements of the Records of Information Management System
`
`(RIMS) database usedin this study. The database contains an index to all documents issued or
`
`received by the Commission since November 16, 1981; images of documents submitted to and
`
`issued by the Commission since November13, 1994; and documents submitted electronically
`
`through the Commission’s web-enabled filing mechanism since N