On November 18th, the Federal Energy Regulatory Commission (FERC) published their Draft Environmental Assessment for PacifiCorp's Prospect 1, 2, and 4 Hydroelectric Project (P-2630). This project is located in Oregon on the North Fork of the Rogue River and contains unique whitewater resources serving the southern Oregon boating community. We encourage members of the Oregon paddling community who have an interest in this project to review this document and taken advantage of the 45 day public comment period. AW will schedule a conference call or facilitate email conversation to discuss this project. Our goal is to represent the needs and interest of the paddling community with an interest in this project so your thoughts are important. Following this input AW will prepare comments responding to this EA by January 1st, 2006 and assist local paddlers and clubs who have an interest in filing their own individual comments. Issues of interest to paddlers include access to the river, provisions for public accessbility to flow information, and restored flows to the bypass reach.

In the document FERC staff recommend an alternative whereby PacifiCorp would release a range of flows up to 500 cfs into the Rogue River bypassed reach for a 6-hour duration on one weekend (6 hours on Saturday followed by 6 hours on Sunday) each in the months of July, August, and September plus the Fourth of July and Labor Day (a total of 3 weekends plus 2 holidays). The release events would occur for the first three summers after license issuance, during which PacifiCorp would evaluate the quality of flow for whitewater boating. At the end of the 3-year period, PacifiCorp would file a report of the results with the Commission along with a proposed final schedule for whitewater boating releases up to 500 cfs for the duration of the license.

Whitewater reaches on the Rogue River in the Prospect Project area

• River bridge to North Fork Park, 6 miles, class III, Forest Service Road 6210 bridge (RM 178) to North Fork Park (RM 172)
• Avenue of the Boulders, 0.5 mile, class V, Between North Fork diversion and Mill Creek Falls (about RM 171.4) to Mill Creek Falls (RM 170.9)
• Mill Creek Falls, 1.5 miles, class IV, Mill Creek Falls (RM 170.9) to Prospect powerhouses (RM 169.4)a
• Powerhouse run, 2 miles, class III, Prospect powerhouses (RM 169.4) to Lost Creek Lake (RM 167.4)

Note that most boaters do not take out or put in boats at the project powerhouses due to the lack of public access. Instead, boaters put in at Mill Creek Falls and paddle 3.5 miles to the takeout point at Lost Creek Lake.

FERC Staff Analysis of Whitewater Recreation from the EA:
(link to full document)

Whitewater Boating

Given the increasing popularity of whitewater recreation during mid- to late-summer in southern Oregon and widespread interest from American Whitewater and individual boaters in the southern Oregon region for increasing whitewater boating opportunities within the Rogue River bypassed reach, we find that whitewater boating is an important use of the Rogue River in the project area.

PacifiCorp and American Whitewater have discussed an approach where flows for whitewater boating could be determined post-license through a whitewater boating study conducted in consultation with whitewater boating interests. However, because of the current interest in whitewater boating in the reach and the potential effects whitewater boating flows would have on project economics and aquatic resources, we will not defer analysis of this issue solely to a post-license study.

We find that based on the best available information we have for the project, a flow of about 500 cfs could provide adequate whitewater boating flows in the bypassed reach. We, therefore, recommend that for the first three summers after issuance of any license for the project, PacifiCorp release, in consultation with American Whitewater, Oregon PRD, Oregon DEQ, Oregon DFW, and FWS, flows up to and including 500 cfs into the Rogue River bypassed reach, to the extent an equivalent amount of Rogue River inflow to the North Fork reservoir would be available, for a six-hour duration on: (1) one weekend (2 days) each in the months of July, August, and September; and (2) the Fourth of July and Labor Day. Flows would come solely from Rogue River inflow to the North Fork reservoir and not reservoir storage or inflow to the reservoir from Red Blanket Creek or the Middle Fork Rogue River.

In concert with the releases, we recommend that PacifiCorp conduct a 3-year whitewater boating study, in consultation with American Whitewater, FWS, Oregon DFW, Oregon DEQ, and Oregon PRD, to evaluate various releases up to and including a maximum of 500 cfs to determine a more precise flow amount and schedule. We recommend that the study: (a) be designed to differentiate between flow-dependent and flow-enhanced recreation opportunities as recommended by American Whitewater; (b) be designed to evaluate the effects of the whitewater flow releases on: (i) any loss of project generation; (ii) fishery and aquatic resources; and (iii) other conditions required by any license issued for the project; (c) include a schedule of the whitewater release dates; (d) assess relevant costs associated with the study; (e) include a provision for a discussion of the study results and the filing of recommendation(s); and (f) include documentation of consultation with American Whitewater, FWS, Oregon DFW, Oregon DEQ, and Oregon PRD. Our environmental analysis in this EA assumes a maximum release of 500 cfs and a maximum of 8 release events in July, August, and September. A proposal or recommendation for higher releases, more events, or releases in different months upon completion of the 3-year study may require additional environmental analysis by the Commission.

Because the release of whitewater boating flows would occur at a time of year when generation is at its lowest, a whitewater boating flow of 500 cfs, or Rogue River inflow to North Fork reservoir if less, would result in an annual generation loss of only 900 MWh, costing about $37,000 annually. We estimate that a whitewater boating study would cost $4,400 annually. Because whitewater boating is an important use of the Rogue River bypassed reach and because there is interest for increased whitewater boating at the project, we find that the benefits of providing up to 500 cfs on up to 8 occasions in the months of July through September would justify the cost.

Recreational Access

American Whitewater and Boaters recommend that PacifiCorp improve three public access points to the Rogue River: (1) Avenue of the Boulders and Mill Creek Falls Trailhead--provide materials to improve an approximate 100-foot-long section of the Mill Creek Falls Trailhead (American Whitewater states that they would provide in-kind services); (2) Prospect No. 1 powerhouse--construct a turn-around where the powerhouse road reaches the Rogue River and construct a footpath to the river; and (3) Lost Creek Lake/Skookum Creek--the north shore of Lost Creek Lake via an existing gated road to Skookum Creek for boaters to get vehicles to the shore of Lost Creek Lake at Skookum Creek; the site could serve as a day-use area.

A benefit of providing a public whitewater access site at the powerhouses would be that boaters skilled up to Class III rapids could utilize the Class III whitewater reach downstream of the project powerhouses. We note that boaters skilled up to Class III rapids would not be able to access this reach from Mill Creek Falls (upstream of the powerhouses) by paddling downstream, because paddling downstream of Mill Creek Falls would require traversing a more difficult reach (Class IV).

An additional benefit of a public whitewater access site at the powerhouses would be that Class IV boaters using the reach upstream of the powerhouses would be able to exit the river at the powerhouses instead of boating an additional 2 miles downstream to the Lost Creek Lake access site.

Providing a formal public whitewater access site at the project powerhouses on the Rogue River would put the public at risk when accessing the site to either drop off or pick up boats and associated equipment. The access road to the powerhouses is very steep and narrow and is bordered on one side by nearly sheer terrain leading down toward the river valley (the road is cut into the surrounding terrain). In addition, parking along the road, however temporary, may interfere with the ability of PacifiCorp or emergency responders to access the powerhouses.

We note that the project already provides and would continue to provide public access (a takeout point at North Fork Park) to a Class III whitewater boating reach, which is located upstream of North Fork reservoir (table 9). We note also that the absence of a formal access point at the powerhouses has not deterred use of the Class IV reach immediately upstream of the powerhouses. Boaters paddle/run an additional 2 miles downstream through less difficult Class III water to the takeout point at Lost Creek Lake. Therefore, given our finding that there are public safety concerns associated with providing a formal public whitewater access point at the project powerhouses and that the project and other recreation sites already provide access to the river for skill levels ranging from Class III through Class V+, we have no justification for recommending a public whitewater access site at the project powerhouses.

We find that our recommendations for (1) whitewater boating flow releases from the North Fork diversion, (2) a whitewater boating study for the Rogue River bypassed reach, and (3) a recreation enhancement plan for North Fork Park adequately address recreation needs at the project, and therefore, we are not recommending the off-site enhancements at the Mill Creek Falls Trailhead or Lost Creek Lake.