Type of day                                              Number   day
----------------------------------------------------------------------------------------------------------------
Peak days\a\.....................................................................................       540  14
Weekend days.....................................................................................       190   6
Weekdays.........................................................................................       648   6
                                                                                --------------
  Total..........................................................................................     1,378
----------------------------------------------------------------------------------------------------------------
\a\ Days coinciding with holidays or recreational events, including Fourth of July (4 days), Northwest Miner's
  Rally (3 days), Labor Day/Blues Festival (3 days), and first weekend of deer hunting season (2 days).

    Although thirty-three respondents (60 percent) reported staying
longer than one day at the project area, only two of the parties
surveyed actually camped within the Enloe Project area due to the
absence of developed facilities.

Land Use

    The proposed Enloe Project boundary is generally defined by the
1,055-foot elevation contour. The boundary extends 0.25 mile downstream
from Enloe dam, following the 1,055-foot elevation contour to include
the falls and the site of the proposed powerhouse, tailrace, and
associated facilities. The Enloe Project boundary deviates from the
1,055-foot elevation contour to accommodate rehabilitation of the OTID
Ditch Road. In that area, the Enloe Project boundary has been set 100
feet landward of the OTID Ditch Road's upper leg; it does not maintain
a specific elevation.
    Agriculture, grazing, and recreation are the primary land uses in
the Enloe Project vicinity. A number of orchards, vineyards, and a
public golf course are located along the Loomis-Oroville Road. The
Enloe Project area is unfenced open range, and the BLM lands in the
immediate vicinity of the Enloe Project are generally leased for
grazing (figure 6). The bulk of the private land in the Enloe Project
area is owned by a livestock company. There are a few residences in the
Enloe Project vicinity, mainly along the Loomis-Oroville Road. Most
active land uses are some distance from the Enloe Project area, with
the nearest located about 1 mile downstream. There are no lands
designated as prime or unique farmlands within the FERC boundary.
BILLING CODE 6717-01-P

[GRAPHIC] [TIFF OMITTED] TN17MY11.005

BILLING CODE 6717-01-C

    Mining was once a dominant land use in the region; however,
commercial mining activity in the Similkameen Valley in Washington has
been very limited during the past 25 to 35 years. Several small
individual mining claims exist on BLM lands in vicinity of the Enloe
Project. Recreational gold prospecting (small-scale placer mining;
conducted primarily with motorized suction dredges) is popular within
the river corridor.
    One of the largest commercial mines in the area was the Kaaba-Texas
Mine, located several miles upstream of the project area, near the
community of Nighthawk. The mine operated from the late 1890s until
1951, and discharged tailings directly into the Similkameen River until
1946. In 1999, the EPA removed and disposed of approximately 81,000
cubic yards of contaminated mine tailings from the mine site.

Land Ownership

    The Enloe Project boundary encompasses approximately 136.4 acres,
including the proposed raised Enloe reservoir, river corridor extending
downstream from the dam 0.25 mile, and shoreline generally to the
1,055-foot elevation contour. The project boundary deviates from the
1,055-foot elevation contour to accommodate work that the Okanogan PUD
proposes to build a new access road.
    Table 17 shows land ownership within the Enloe Project boundary.
Public agencies own and manage the majority of the land, with the
exception of a portion of a single parcel (comprising about 0.15
percent of the area) held privately.

   Table 17--Land Ownership Within the Proposed Enloe Project Boundary
                      [Source: Okanogan PUD, 2008a]
------------------------------------------------------------------------
                     Land owner                         Acres    Percent
------------------------------------------------------------------------
BLM.................................................     35.47     26.00
Washington DNR......................................    100.76     73.85
Private.............................................      0.20      0.15
                                                     -------------------
  Total.............................................    136.43    100.00
------------------------------------------------------------------------

    Hydropower generation was the primary land use in the Enloe Project
area from 1906 until 1958. A hydropower facility was first constructed
in 1906 at the falls on the east bank of the Similkameen River, across
from the present powerhouse. That facility was replaced by the existing
dam and power plant, which began construction in 1916 and was completed
in 1923. The facility ceased operations in 1958 for economic reasons.
Most of the project structures, including the dam, the powerhouse, one
of two penstocks, and the power line, still exist. Portions of the
foundation of the original power house are still extant, as well.
    At one time, the OTID transported irrigation water through the
Enloe Project area via a system of canals and flumes, and some of the
structures remain in place. That system has been replaced by a
pressurized distribution system, and the point of withdrawal has been
transferred from the Similkameen River, 7 river miles upstream of the
dam, to Lake Osoyoos, 3.5 miles southeast of the Enloe Project. The
Oroville Golf Club maintains a pumping station and pipeline within the
project area to provide irrigation water for its course. With the
exception of the golf course facilities, no irrigation facilities in
the Enloe Project area are currently in use, and there are no other
water rights on the Similkameen River.
    In accordance with the Washington's Shoreline Management Act of
1971 (WSMA), Washington State has designated the Similkameen River and
associated shoreline areas as shorelines of the state, which are
subject to the provisions of Okanogan County's Shoreline Master Program
(Okanogan Shoreline Program). In Okanogan County, shorelines of the
state include water areas and shorelands extending 200 feet landward,
on a horizontal plane, from the ordinary high water mark, or the 100-
year floodplain, whichever is greater. The WSMA and the Okanogan
Shoreline Program provide for protection of shoreline functions and
values, including physical and visual access to the shoreline.
    The Okanogan Shoreline Program designates all of the shoreline area
within the proposed Enloe Project boundary as ``Conservancy.''
According to the Okanogan Shoreline Program, the Conservancy areas
contain a resource capable of sustained yield. Forest products,
hunting, fishing, agriculture, and many types of recreation are
examples of uses compatible with this environment. The intent of this
environment is to maintain the existing character of the shoreline.

Access

    Highway access to the Enloe dam area is via the Loomis-Oroville
Road. Located in a remote rural area, the road carries little traffic.
Traffic counts for Loomis-Oroville Road range between 112 and 166
average daily trips according to 2005 traffic counts by Okanogan
County.\36\ Two access roads (the Enloe Dam Road and the OTID Road),
connect the Loomis-Oroville Road to the dam site.
---------------------------------------------------------------------------

    \36\ An average daily trip is the average number of vehicles
that cross a given surface during a specified 24-hour period.
---------------------------------------------------------------------------

<IP_ADDRESS> Environmental Effects

Recreation

Recreation Management Plan (REC-13)

    Okanogan PUD proposes to implement a Recreation Management Plan to
address recreational issues associated with the project. The plan
includes 12 measures for recreation and three measures for safety and
access to the project areas. This Recreation Management Plan was
developed in coordination with the BLM, NPS, Washington DNR, the
Washington RCO, and tribal agencies that use lands within the project
area. Lessees that use project lands for grazing were also invited to
participate in the preparation of the RMP. The various measures within
the plan are discussed below.
    BLM recommends that Okanogan PUD complete a final Enloe Recreation
Management Plan after consultation with BLM and the Park Service.

Abandon Portion of Existing Road Along the Shoreline and Restore
Existing OTID Road To Provide Access (BOTA-03)

    Okanogan PUD proposes to restore the OTID Road by smoothing out
bumps, filling potholes, and adding vehicle turnouts to allow vehicles
traveling in opposite directions to safely pass one another. A 2,000-
foot-long segment of the existing access road (Shoreline Road) located
along the east bank of the impoundment would be abandoned and closed to
vehicle traffic (figure 7). The roadway would be relocated
approximately 200 feet to the east (up slope) to protect wetlands,
reduce effects on cultural resources (for effects of project proposals
on cultural resources see section <IP_ADDRESS>, Cultural Resources,
Environmental Effects), and make the road more accessible during
spring, summer and fall months for all users. The new roadway segment
would follow the alignment of an old irrigation canal road.
    Large rocks would be placed at both ends of the abandoned roadway
segment to prevent vehicle access. Pedestrian use of the abandoned road
would be discouraged until riparian vegetation planted in that area has
become established. Other existing unimproved spur roads in the project
area would also be closed to vehicles by blocking entry points with
large rocks. All parties have agreed that additional design details on
the access road and any proposed crossing structures would require
consultation.

[GRAPHIC] [TIFF OMITTED] TN17MY11.006

    Although the access road would not be plowed on a regular basis
during the winter, Okanogan PUD may clear the road periodically to
access project facilities for maintenance and operations purposes.

    Consistent with Okanogan PUD's proposal, BLM recommends improving
an existing access road for public access into the Enloe dam area and
abandoning and relocating a segment of the existing road that would be
subjected to seasonal flooding under the proposed project operations.
BLM also comments that the Commission should develop and analyze an
alternative access road configuration that does not affect the OTID
right-of-way.

Our Analysis

    The realignment of a 2,000-foot-long segment of the existing access
road located along the east bank of the impoundment would improve
recreation at the project by providing enhanced access to project lands
and waters. However, it is unclear in Okanogan PUD's application
whether the entire public access road (OTID Road) between the Loomis-
Oroville Road and the proposed project boundary (approximately 4,000
feet) would also be maintained to the same standard. Although, Okanogan
PUD proposes to make improvements to the entire access road from the
Loomis-Oroville Road to the dam, it does not intend to bring the entire
access road into the proposed project boundary. Brining the entire
length of the access road from the Loomis-Oroville Road to the dam
would ensure that the entire access road is maintained by the licensee
for project operation as well as recreational access. Incorporating the
4,000-foot stretch of this road including a 50-foot-wide corridor and
turnouts would add approximately 5.0 acres of land to the proposed
project boundary.
    Okanogan PUD's proposal to construct an access road is in a portion
of the OTID right-of-way. Okanogan PUD has consulted with OTID, and
OTID has agreed that the proposed access road would not conflict with
the OTID's interest or affect any facilities in current use. The two
parties have come to an agreement that would allow Okanogan PUD to
construct an acceptable access road to the project dam. A final
agreement would be negotiated after the licensing decision. Therefore,
we do not see a demonstrated need for Commission staff to develop and
analyze an alternative access road configuration at this time.
    During the winter season, Okanogan PUD would not regularly plow or
maintain the access road for visitors but states it may clear the road
periodically to access project facilities for maintenance and
operations purposes. Access to project waters was evident during the
site visit in January 2009, when Commission staff noted that there was
a fisherman downstream of the dam. Therefore, there is a need for more
periodic maintenance of the roadway in the winter to allow visitors to
project lands and water. Development of an established plowing schedule
with signs posted at the beginning of the access road would have a
direct beneficial effect on winter recreation users by providing
enhanced access to project lands and waters.

Fence Plan (REC-01)

    Safety/Security Fence--Okanogan PUD proposes to remove the existing
chest-high chain-link fence, approximately 100-foot-long, that
separates visitors on the east bank of the river from the dam and the
lower reaches of the impoundment and install a new fence (at least 6
feet high) along the upland perimeter of the power generating
facilities and tailrace (figure 8). The fence would be constructed of
small mesh chain-link material finished in traditional galvanized zinc
or coated in brown vinyl. A top rail would be installed to keep the
fence from sagging. Authorized personnel would have keys to access
selected locked gates. Signs warning the public about high voltage and
other hazards would be posted on appropriate fence locations.
    Cattle Fencing--Okanogan PUD proposes to install an 8,000-foot-long
cattle fence along the eastern boundary of the project boundary from
Shanker's Bend to Enloe dam. At its northern end, the cattle fence
would tie in to a rock outcrop just south of the apex of Shanker's Bend
and an access point through the fence would be provided for
pedestrians. Cattle would have access to the river just upstream from
the rock outcrop. At its southern end, the fence would tie in to
another rock outcrop just east of the proposed powerhouse. The
configuration of the cattle fence would be consistent with BLM
guidelines for livestock fencing installed in areas inhabited by common
ungulate species. The fence would consist of no more than four, well-
stretched horizontal wires with the top wire no more than 42 inches
above the ground. The other wires would be spaced evenly no less than
8-, 16-, and 24-inches below the top wire.
    The grazing lessee has an existing water right to withdraw water
from the river for stock watering purposes. Okanogan PUD proposes to
install a stock watering tank approximately 300 upslope from the river,
just inside the project boundary and north of the proposed recreation
site, as an alternative source of drinking water for all grazing cattle
with rights to this area. The tank would be supplied with water from an
existing pump and waterline located on the east bank of the river. The
pump and waterline are owned by one of the grazing lessee Okanogan PUD
would monitor the need to install a security fence around the pump and
electrical power system to discourage vandalism and theft if they
become problems.
    A cattle guard would also be installed where the cattle fence
crosses the main access road to the dam. The cattle guard grid would be
designed to bear the maximum expected vehicle load (which may include
construction equipment). A gate (accessible only by authorized
personnel) would be installed where the cattle fence crosses Enloe Dam
Road.
BILLING CODE 6717-01-P

[GRAPHIC] [TIFF OMITTED] TN17MY11.007

BILLING CODE 6717-01-C

    BLM recommends non-barbed wire be used near the recreation area or
the addition of crossings as needed for safe access to project lands
and waters. In addition, BLM recommends prior to building the proposed
Enloe Project fence, Okanogan PUD develop and implement a plan to
provide water outside the fenced area for the use of livestock that are
authorized to graze on BLM-administered public lands within and
adjacent to the Enloe Project.

Our Analysis

    Three ranchers have rights to graze cattle on BLM land within the
proposed project boundary. Because there are no fences to limit or
control livestock access, cattle freely roam the entire site. The
grazing lessee has an existing water right to withdraw water from the
river for stock watering purposes. Cattle access the river for drinking
water wherever the topography allows. Okanogan PUD's Fence Plan
implemented in coordination with its vegetation resources management
plan would be consistent with BLM's recommendations. The proposed fence
configuration would protect wildlife and vegetation within the project
area while still allowing access to recreation users. Injury to fawns
and yearling deer who often try to move between lower fence wires would
be reduced and adult deer could easily jump a fence with a top wire 42
inches above the ground. However, continued consultation with BLM and
lessees who have the water rights would ensure the fence meets BLM
standards and cattle are still able to access water within the project
area. In addition, Okanogan PUD's proposal to install a stock watering
tank north of the proposed recreation area would provide an alternative
source of drinking water for all grazing cattle with rights to this
area. A written agreement to provide water for all three lessees'
cattle at this proposed watering site would also ensure all three
ranchers' cattle would have an alternative source of water.
    Barriers to Restricted Areas--Okanogan PUD proposes to install
locked gates and rock barricades to limit vehicle access by
recreational users. The proposed barriers and access restrictions are
described below:
     Locked metal gates would be installed at the upper end of
Enloe Dam Road to prevent unauthorized vehicles from using the road.
The road is very steep and is not maintained for passenger vehicles.
Visitor access to the project area would be via OTID Road. Because
Enloe Dam Road is a county road, Okanogan PUD would work closely with
Okanogan County on plans to close the road to public vehicle access.
Pedestrians would be able to walk along the road; however, they would
need to use the pedestrian access at the north end of the recreation
area to access the new recreation site and areas below the dam.
     Okanogan PUD staff and other authorized personnel would
have keys to the locked gates. Okanogan PUD does not propose to install
a gate at the entrance to the main access road off Loomis-Oroville
Road.
     A locked metal gate would also be installed at the
intersection of the one-way loop road within the proposed recreation
site and the new access road to the area below the dam. Only Okanogan
PUD staff and authorized personnel would have keys to open the gate.
Large rocks spaced approximately 3 feet apart would be used to prevent
visitors from attempting to drive around the gate. Visitors (including
those portaging rafts, canoes, kayaks and mining equipment) would be
able to access the area below the dam by using a trail to be located
near the west end of the gate.
    Consistent with Okanogan PUD's proposal, BLM also recommends
installing barricades and fencing to prevent unauthorized access to
closed areas.

Our Analysis

    Finalizing and implementing the Fence Plan after consultation with
BLM and stakeholders as part of the proposed Recreation Management Plan
would improve prevent damage to wetlands and proposed riparian/wetland
mitigation sites by preventing cattle from entering the proposed
recreation site and keeping recreation users out of sensitive
vegetative areas. A key schedule developed by Okanogan PUD in
consultation with stakeholders would also ensure the appropriate
entities had keys to access project facilities.

Recreation Access Below Enloe Dam (REC-02)

    The construction of the new power generation facilities would
require upgrading or replacing portions of the abandoned road, which
currently provides foot access to areas below Enloe dam, including the
rocky area above the falls and the lower reaches of the Similkameen
River.
    The area downstream of the dam contains dispersed trails made by
visitors who access different areas below the dam depending on the
activity they are taking part in (fishing, hiking, photography, mining,
and kayaking/rafting/canoeing). Okanogan PUD proposes to designate and
improve a single trail for public recreation access to the river below
Enloe dam. Okanogan PUD would allow hikers and visitors portaging
watercraft or recreational mining equipment (on foot) to use the
improved access road between the recreation site and the powerhouse.
Okanogan PUD also proposes to improve approximately 350 feet of the
existing trail located between the access road to the powerhouse and
the southernmost interpretive display. The trail would be widened to
approximately 6 feet, leveled, smoothed, and surfaced with gravel to
provide barrier-free access to all users.
    In addition, Okanogan PUD proposes to make limited improvements to
an existing footpath that extends between the trail described above and
the edge of the river. Large obstacles would be moved or avoided, and
the path would be widened and smoothed where possible. The path would
also be marked to increase its visibility and enhance public safety.
Other existing footpaths leading from the upper trail to the river's
edge would be closed by placing rocks at the existing entry points to
discourage use.
    BLM recommends providing recreation access below Enloe dam and
rebuilding the footbridge.

Our Analysis

    Options for providing access to the river corridor below Enloe dam
(including portage options) are limited by site factors (including
steep, rocky terrain on both sides of the access corridor and the
confined river channel). Generation facility design and security
requirements also limit options for improving access to areas below the
dam. Okanogan PUD proposes to designate and improve a single trail
within the proposed project boundary for public recreation access to
the river below Enloe dam. The improved path would provide easier
access to those carrying kayaks or prospecting equipment and provide
overall enhanced access. Anglers would also be able to access the
popular fishing areas below the falls using the improved footpath. The
proposed improvements would enhance access to lands and waters
downstream of the dam and provide for the effective launching of boats
below the falls.
    At this time, Okanogan PUD does not propose to provide public
access to the west bank of the river as a part of the Recreation
Management Plan. Okanogan PUD states it would be receptive to proposals
to restore the footbridge across the river if a proponent and source of
funding were to come forward. Okanogan PUD would continue to

coordinate with federal and state agencies and local historical
societies to explore funding sources for restoring the footbridge (see
Land Use ``Non-motorized Trails and West Side River Access'' for a full
analysis).

Transfer Ownership of Trestle Bridge (REC-03)

    Okanogan PUD proposes to continue collaboration with the County
towards development of the County's proposed 12.5-mile non-motorized
public access trail on the railroad bed along the west side of the
Similkameen River between Oroville and Nighthawk. This trail is
currently under construction with the first 3.5 miles having been
completed, running from the City of Oroville to a scenic view of
Similkameen Falls at around RM 8.5, which lies just outside of the
lower end of the proposed project boundary. Okanogan PUD has provided
easements through its property to the County with the following
conditions: (1) The first phase of the trail would terminate prior to
reaching the downstream end of the project boundary--that is, the first
phase of the trail would not run adjacent to the project boundary; and
(2) Okanogan PUD retains the right to use the bridge and the railroad
bed to reach the dam site for project maintenance and operations.
    Okanogan PUD also plans to coordinate with the Department of Public
Works regarding road approaches and signage.

Our Analysis

    Okanogan PUD transferred ownership of the trestle bridge to
Okanogan County for the development of a future public, non-motorized,
recreational use trail. The rail would provide a beneficial effect to
users who would be able access to the west side of the Similkameen
River and Enloe Project area for possible informal, dispersed
recreational activities.

Improvements to Existing Informal Boat Ramp (REC-04)

    Okanogan PUD proposes to install a new formal boat launch in
approximately the same location as the primitive put-in/take-out area
now used by recreational boaters on the reservoir. The boat launch
access road would be accessed from the loop road at the new recreation
site. The road to the boat ramp would be approximately 14 feet wide and
surfaced with gravel. The road would be accessible to both vehicles
with trailers and people carrying watercraft on foot. The boat ramp
would be constructed of gravel geoweb materials or concrete planks.
Changing water levels would be accounted for in the design of the ramp.
If necessary, a trash deflector would be installed to protect the boat
ramp from floating debris. A vehicle and trailer parking area would
also be located in the new recreation site.
    Rock barricades would be installed along both sides of the access
road to the boat ramp to prevent vehicles from entering the adjacent
woodland area. The rock barricade would consist of three-man rocks \37\
placed approximately 3 feet apart.
---------------------------------------------------------------------------

    \37\ A three-man rock is defined as a rock weighing 750-3,500
pounds and measuring approximately 24 to 36 inches on each side.
---------------------------------------------------------------------------

    BLM recommends improving the existing informal boat ramp at Enloe
dam, consistent with Okanogan PUD's proposal.

Our Analysis

    These improvements would facilitate access for current and future
recreation use at the project. By implementing the proposed
enhancements in areas where recreational use is most concentrated,
within 1.5 miles of the dam, recreation access at the project would be
increased and areas for the effective launching and retrieving of boats
would be improved.

Clean Up and Restore Wooded Area on East Bank (REC-05) and Remove
Existing Trash and Conduct Annual Cleanup (REC-07)

    Okanogan PUD proposes to remove existing trash from the following
areas: (1) the wooded area on the east bank of the reservoir, just
above Enloe dam; (2) the OTID Road access leading from the Loomis-
Oroville Road to the dam site; and (3) unimproved beaches within the
project area, including Shanker's Bend and area below the dam.
    Okanogan PUD proposes to clean up and restore the wooded area on
the east bank of the impoundment, just upstream of the dam on BLM land,
to enhance visitor experience. Clean up would include removing trash,
auto bodies, and other debris from within the wooded area. Restoration
would include planting native vegetation appropriate to the site in
areas that have been degraded by vehicle use and informal camping.
    Okanogan PUD proposes to coordinate with user groups and area civic
organizations to arrange an annual clean-up to remove trash and dumped
materials that accumulate within the project boundary. Signs stating
Okanogan PUD's ``Pack it In/Pack it Out'' policy would be installed at
the entrance to the OTID Road off Loomis-Oroville Road and at a
conspicuous location within the new recreation site upstream of the
dam.
    Okanogan PUD personnel would visit the site several times each
month, and if trash or illegal dumping exist, they would be removed as
soon as practical.
    BLM recommends cleaning up and restoring the wooded area on the
east bank as well as removing existing trash and conducting annual
cleanup events consistent with Okanogan PUD's proposal.

Our Analysis

    The proposed clean-up plan for the wooded area on the east bank of
the river and removal of existing trash and an annual clean up plan
would address the litter and sanitation concerns expressed by the
visitors in response to Okanogan PUD's recreational surveys. The
proposed plan would have a direct beneficial effect on the recreational
experiences of visitors by providing annual litter pickups, site checks
on a regular basis, and signage to encourage users to carry-in/carry-
out.

Develop an Interpretive Publication (REC-06)

    Okanogan PUD proposes to develop an interpretive publication that
would include a map of the project area in consultation with Okanogan
County, the Greater Columbia Water Trail Steering Committee, and other
interested parties. The interpretive publication would identify the
locations of developed recreational facilities and inform visitors of
appropriate locations to park, load and unload recreational equipment,
portage, and camping areas. The map would include recreation sites and
access areas and be suitable for printing as a stand-alone piece that
could be posted on an information board.
    The design of the publication would follow the style guidelines
that would be developed in the Aesthetic Resources Plan (see section
3.3.7 Aesthetic Resources) and be consistent with other interpretive
signs (REC-11) and information boards (REC-12) at the project.
    Okanogan PUD's proposal is consistent with BLM's recommendation to
develop an interpretive publication.

Our Analysis

    Finalizing and distributing an interpretive publication after
consultation with stakeholders as part of the proposed Recreation
Management Plan would establish a consistent method to provide visitors
with information about the project and recreation sites within the
project area. Development of such a publication

would increase public safety and awareness at the project.

Develop Parking Area, Including Vault Toilet and Access Road (REC-08),
Install Picnic Tables (REC-09), and Develop Primitive Campsites (REC-
10)

    Okanogan PUD proposes to develop a one-acre recreation site located
in a relatively flat area next to the riparian woodland just upstream
from the dam. Okanogan PUD chose this site because it is heavily
disturbed and would not affect known cultural resources in the area.
The design concept for the recreation site is a one-way access road
that would circulate traffic in a counter clock-wise direction. The
access road would be approximately 14 feet wide and would be surfaced
with gravel. A gravel surfaced parking area able to accommodate up to
five standard vehicles and two vehicles with trailers would be located
on the southern half of the site. Large rocks would be used as needed
to direct traffic, protect facilities, and designate the parking areas.
Due to space and topographical limitations, vehicles with boat trailers
would be required to pull in and back out of the parking area. One
vault toilet would be constructed for recreational users at the south
end of the parking area.
    Okanogan PUD also proposes to install picnic tables in two areas on
the east side of the new recreation site near the parking area. The
areas would be designated for day-use picnicking, although overnight
campers would be able to use the picnic facilities as well.
    The first site (Picnic Area I) would be located in the southeast
corner of the recreation site outside of the loop road (figure 9). This
area is slightly wooded providing natural shade and views toward the
dam. Two tables would be spaced approximately 25 to 50 feet from each
other to provide privacy. The second picnic area (Picnic Area II) would
be located in the northeast corner on the outside of the loop road.
This site provides overlooking views of the placid water of the
reservoir. Two picnic tables would be clustered together to accommodate
larger groups. Parking for both picnic areas would be provided in the
parking area located at the south end of the recreation site inside the
loop road (Figure 9).
    Okanogan PUD would develop four primitive campsites near the
parking and picnic areas described above. Each campsite would be
approximately 25 feet wide and 50 feet long. The campsites would
provide for pull-in parking and include ample space to accommodate a
tent site. Rock barriers would be installed to serve as curbstops and
define the boundaries of individual campsites. A picnic table and steel
fire ring would be provided at each campsite and be surrounded by 3
feet of gravel in all directions to reduce fire danger. Campsites would
be available on a first-come, first-served basis and overnight stays
would be limited to a maximum number of 14 consecutive stays. Okanogan
PUD's overnight stay policy would be clearly posted on an information
board at the recreation site and at each campsite. Campsites would be
designed to provide barrier free access to all users.

[GRAPHIC] [TIFF OMITTED] TN17MY11.008

    Okanogan PUD proposes it would, either directly or indirectly
through a formal partnership, be responsible for maintaining
recreational assets in an acceptable condition through routine
maintenance, repair and replacement.
    Recreation features would be inspected during normal maintenance
visits and any recreation features that are identified as broken or in
need of repair would be repaired or replaced. The repair of recreation
features, which could include the replacement of certain items, would
be conducted on an as-needed basis as soon as practical after being
identified through regular facility inspections.
    BLM recommends developing a parking area, installing a vault
toilet, installing picnic tables, and developing primitive camp sites
at the recreation site consistent with Okanogan PUD's proposal. BLM
also recommends that Okanogan PUD provide recreation site grounds
maintenance and consult with BLM to develop a schedule for site
maintenance, facility replacement, modifications, or upgrades to the
administered recreation sites at Enloe dam and Miner's Flat. In
addition, BLM recommends Okanogan PUD clear and keep clear to an
adequate width all lands along roads and trails and dispose of all
temporary structures, unused timber, brush, refuse, or other material
unnecessary for the purposes of the Enloe Project that result from
maintenance, operations, or alteration of the Enloe Project facilities.
Trees that have died or had portions die should be removed or pruned to
minimize hazards to the public. Prior to removal, trees would be
evaluated for wildlife value and a determination made of the
appropriate action. Trees that have been removed should be replaced by
planted seedlings of species native to the area.

Our Analysis

    The development of this small recreation area is consistent with
the low level of current and anticipated use. Survey results indicate
that use of the Enloe Project Area is estimated at 1,378 user days
during the June 1 to October 15 survey period.
    Okanogan PUD developed a Recreation Needs Assessment, dated April
2009. The Recreation Needs Assessment projected the needs and capacity
data for the project area through the year 2050 using peak use
estimates.
    The peak day-use projection for campers visiting the survey area in
2030 under Okanogan PUD's high growth scenario is 15, which would be in
balance with the capacity available at the project site once the
campsites are developed. The 2050 peak day demand is anticipated to be
38 percent of the total survey area capacity, including the primitive
campsites available 3 miles upriver at Miner's Flat. This suggests that
peak day demand for camping facilities at the project would be exceeded
in 20 to 30 years. Thus, it appears there would be sufficient capacity
to accommodate anticipated future demand for camping in the area of the
project.
    The proposed sites would be appropriate given current recreational
use at the project. Recreation access would be improved at the project
by providing formal campsites and picnic areas in the areas where
recreational use is concentrated. The addition of a vault toilet would
ensure that human waste is handled in a manner that would protect
environmental and aesthetic resources. The addition of picnic tables
and primitive campsites would assist in defining areas for recreational
activity and would concentrate recreational use in these intended
areas. This would reduce the current adverse effects on surrounding
natural and cultural resources from recreational activities that could
cause ground compaction, vegetation loss, and erosion. Similarly, the
designation of parking spaces for recreational users would reduce
impacts on natural and cultural resources. Although grounds maintenance
is already included in Okanogan PUD's day-to-day operation and
maintenance activities finalizing the Recreation Management Plan after
consultation with stakeholders and filing the plan with the Commission
for approval would establish a maintenance protocol to provide visitors
with clean and safe recreation facilities.

Interpretive Signs and Information Board (REC-11 and REC-12)

    Okanogan PUD proposes to place at least three interpretive signs
(display panels) in areas accessible to visitors at the project. The
purpose of these panels would be to develop visitor understanding of
the cultural, historical, and biological resources in the project area
and enhance visitor experience. Sign designs and locations would be
consistent with those specified in the HPMP and would be finalized in
consultation with BLM and the CRWG during the design phase.
    The preliminary list of proposed sign locations and topics are as
follows: (1) One display panel at or near the old bridge tower, below
the falls, the focus of which would be the history of power generation
at the site; (2) one display panel at or near the 1906 powerhouse
foundation at the end of the new access road, the focus of which would
be native legend about the falls and fish; and (3) one display panel
near the parking and picnic area, which would have smaller versions of
the two other panels and interpretive information about the environment
(e.g., wetland, riparian, and shrub-steppe functions and values) around
the project area.
    The exact locations of the signs may change slightly to ensure that
they do not obstruct views of other project features and are placed in
appropriate locations relative to the features being interpreted.
    Okanogan PUD also proposes to develop an information board in
addition to the interpretive signs. At a minimum, the information board
would include a map showing recreational features in the project area,
visitor rules, and safety information.
    BLM recommends the development of the interpretive signs and an
information boards consistent with Okanogan PUD's proposal.

Our Analysis

    Finalizing and implementing the plan for interpretive signage and
information board after consultation with BLM and the CRWG, as part of
the proposed Recreation Management Plan, would enhance the recreational
experience by providing visitors with information about the project as
well as important safety messages. In its proposed Recreation
Management Plan, Okanogan PUD identified likely locations, themes,
stories, objectives, and options for structures and sign displays
within the project boundary. Because Okanogan PUD states that specific
displays would be subject to alteration based on the outcome of
consultation, a final Recreation Management Plan filed with the
Commission for approval would ensure that the proper consultation has
occurred and that the final site-specific information could be assessed
properly.

Additional Measures To Improve Public Safety

    In the interest of promoting public safety for all those who
participate in recreational activities within the project area,
Okanogan PUD proposes following additional safety measures.

Maintain Warning Signs, Safety Cable and Grab Ropes (SAFETY-01)

    In consultation with BLM, Park Service, FWS, Washington RCO,
Washington PC, Washington DNR, CRWG, Washington DFW, Washington DOE,
Okanogan County Planning and Development Office, the Colville, Greater
Columbia Water Trail Coalition, Pacific Northwest Trail Association,

Washington Water Trails Association, Wenatchee Valley Museum and
Cultural Center, and grazing lessees, Okanogan PUD proposes to install
a 1,500-foot long canoe/kayak portage trail. Paddlers would be able to
identify the portage trail by signs informing boaters and paddlers
where take-outs are located. Portage signs would be large enough to
direct canoeists and kayakers to safe take-out locations.
    Okanogan PUD also proposes to continue to maintain the existing
signs and system of safety cables and grab ropes above the dam. The
existing system of safety cables and grab ropes is located more than
300 feet upstream of Enloe dam and the proposed intake channel at a
narrow point in the reservoir. The cables and grab ropes serve as a
means of restraint and escape for people who are approaching the
spillway and are not able to exit the water at the boat launch as
directed by instructional signs and warnings.
    Finally, a log boom would be placed at the entrance to the intake
channel to serve as a restraining barrier for any boaters or swimmers
approaching the intake channel.

Allow Limited Public Access to the Project Area During Construction
(SAFETY-02)

    Okanogan PUD proposes to allow limited public access to the project
area during the 2.5-year construction period. Public access would be
limited to areas upstream of the dam, outside of the construction and
staging areas. Access to the primitive put-in/take-out area in the
riparian wooded area would be available during most of the construction
period. During periods when the put-in/take-out area would not be
available for use, a sign would be placed upstream to alert boaters to
use an alternate take-out location.
    Because of safety and liability concerns, the area along the east
bank of the river (extending approximately 250 feet above the dam and
550 feet below the dam), including all areas of active construction and
materials stockpiling, would be off-limits to the public until major
construction activities are completed. The off-limits area would be
completely enclosed by a temporary chain link security fence. Signs
would be erected at the entrance to main access road, alerting visitors
that construction activities are taking place and that portions of the
site may be closed to public use. Okanogan PUD would continue regular
site inspections during periods of active construction.

Identify Options for Preventing Public Access to the Old Powerhouse
(SAFETY-03)

    Okanogan PUD proposes to coordinate with BLM, the state of
Washington, and private land owners, as appropriate, to identify
options for preventing public access to the old powerhouse. Options
include installing fencing and/or gates at key access locations on the
west bank of the river between the powerhouse and the old railroad.
Warning signs with the words ``Danger'' and ``No Entry'' could also be
installed at key locations. The fencing and signage could remain in
place until another party has assumed ownership and management of the
powerhouse or until the powerhouse and penstock are demolished and
removed. Okanogan PUD would allow 5 years before the powerhouse is
demolished to identify potential partners to restore the old powerhouse
for interpretive opportunities (see section 3.3.8, Cultural Resources,
for more discussion of this issue).
    BLM recommends improving public safety by maintaining warning
signs, safety cables, and grab ropes, allowing limited or controlled
public access to the Enloe Project area during construction, and
preventing or appropriately managing public access to the old
powerhouse.

Our Analysis

    Okanogan PUD has a responsibility for public safety and ensuring
public access under parts 12 and 2.7 of the Commission's regulations.
The proposed measures listed above to improve public safety are
reasonable and appropriate to ensure public safety at the project.
Public safety at the proposed new recreation site and other areas
within the project area is also under the jurisdiction of law
enforcement agencies, including the Okanogan County Sheriff's Office.
It would be appropriate for Okanogan PUD to also coordinate with the
local county sheriff's office and other emergency response entities to
ensure that an appropriate level of public safety exists within the
project area.

Recreation Management Plan (REC-13) and Monitoring

    Okanogan PUD proposes to review, update, and/or revise the RMP if
the FERC Form 80 monitoring indicates significant changes in recreation
use and or conditions or substantial differences in uses versus
capacity of recreation facilities. Changes would also be implemented if
monitoring results indicate resource objectives are not being met. Any
updates to the RMP would be made after consultation with BLM and filed
for final Commission approval.
    BLM recommends that Okanogan PUD conduct annual and periodic
recreation plan monitoring. Within 90 days of license issuance, BLM
recommends Okanogan PUD develop an Annual Visitor Use and Monitoring
Form, in consultation with BLM. This form would be used to record
visitor use; maintenance, both performed and needed; and report on the
recreation facilities and recreation use within the Enloe Project area.
The report would be submitted to BLM by December 1 each year for review
and approval.
    Every 6 years, starting with the issuance of an Enloe Project
license, Okanogan PUD should review and evaluate information regarding
recreation needs and report recreation use levels. Use levels would be
documented by means of site visits and staff observations. Okanogan PUD
would also conduct monitoring, using the Commission's FERC Form 80.
    BLM recommends that every 5 years, Okanogan PUD review, and if
necessary, update the final Recreation Management Plan. If the Form 80
monitoring, the Annual Visitor Use and Monitoring Form, or other
sources identify issues, problems, or significant changes to
recreational use levels, types, or other issues, Okanogan PUD would
update or revise the final Recreation Management Plan to contain
information on managing and providing adequate facilities to meet the
needs of the current and projected recreation use. Significant change
would include exceeding the project's recreation facility capacity as
defined by the Commission's FERC Form 80 updates.

Our Analysis

    Okanogan PUD's proposed recreational use monitoring and assessment
of recreation-related effects on lands within the project boundary as a
component of the proposed Recreation Management Plan would allow
Okanogan PUD and stakeholders to consider measures to address
recreational use, including dispersed use, over the term of a license.
It would be beneficial for Okanogan PUD, in coordination with filing of
the FERC Form 80, to file every 6 years a Recreation Monitoring Report
summarizing the recreation monitoring results and any recommendations
for future recreation management at the project. The monitoring would
provide a mechanism for which recreation facilities could be maintained
and improved over the term of a license.

Although monitoring recreation on an annual basis, as proposed by BLM,
would also be beneficial, this amount of monitoring seems excessive due
to the low amount of current recreational use at the project.
    Coordination with other stakeholders, such as the Washington SHPO,
BLM, NPS, Washington DNR, and Washington ROC would ensure that other
environmental resources are appropriately considered when implementing
any changes or new recreation measures into the Recreation Management
Plan.

River Access Point at Miner's Flat

    BLM recommends that Okanogan PUD place the Miner's Flat area within
the Enloe Project boundary. Currently some visitors use Shanker's Bend
as a boat take out to avoid paddling the flat water above the dam. BLM
states that river visitors who take out at Shanker's Bend to avoid the
flat water would now take out at Miner's Flat due to the increase in
reservoir area as proposed. BLM recommends Okanogan PUD make recreation
improvements to the Miners Flat area to accommodate future increases in
recreation needs at this location. BLM proposes that recreational
development at Miner's Flat incorporate the following: (1) Improve the
existing entrance road, road through the site, and parking areas; (2)
improve water access for launching and landing boats; (3) install an
information kiosk with a map; (4) establish primitive campsites,
including picnic tables and steel fire rings; (5) install a vault
toilet; and (6) develop drawings showing the location of site
improvements and consult with them on this plan.

Our Analysis

    Currently, there is no suitable area for the development of a take-
out within Okanogan PUD's proposed project boundary. It is likely that
the raised reservoir level would result in more paddlers taking out at
Miner's Flat to pass up the increased flatwater area.
    Since an informal access already exists at Miner's Flat and the
area is flat enough to accommodate a take-out area, it would be
reasonable to develop a take-out within this location with minor
upgrades made to the access road to the take-out. However, because
Okanogan PUD has proposed to develop formalized campsites within the
project boundary and two campgrounds already exists within two to five
miles of the project, developing campsites at Miner's Flat would not be
justified.

Land Use

Project Boundary

    The Enloe Project boundary encompasses approximately 136.4 acres
and includes Enloe reservoir, the corridor for the new access road
proposed by Okanogan PUD, the location identified for the placement of
boulder clusters in the riverbed (about 2.5 miles upstream of the dam)
and the river corridor extending downstream from the dam 0.25 mile.
Okanogan PUD does not propose to place additional lands associated with
the proposed side-channel enhancement site, the restoration of the
existing OITD road, and Miner's Flat within the project boundary.

Our Analysis

    Okanogan PUD's proposal to enhance existing side channel to improve
spawning, rearing, and summer thermal refugia would be a mitigation
measure for the protection of environmental resources. This proposed
facility would add approximately 0.75 acres of project lands
approximately 5 miles downstream of the dam necessary for project
operation. These enhancements would need to be maintained over the
license term and, therefore, it would be appropriate to include these
lands within the project boundary for the purpose of operation and
maintenance of the proposed Enloe Project.
    In addition, all but about 4,000 feet of the existing access road
is currently proposed to be located within the project boundary.
Because of the proposed modifications of the existing access road and
the fact that the road is the only access route to the project, it is
appropriate to include the entire access road within the project
boundary. This would add approximately 5 acres of land to the project
area.
    Finally, the provision of an upgraded take-out area at Miner's Flat
is justified due to the potential increase in recreational use as a
result of the raising of the impoundment from current levels and
anticipated increases in recreational use of the area over time. The
inclusion of the recommended Miner's Flat take-out area, would be
necessary for project purposes, such as recreation, shoreline control,
or protection of environmental resources. This would add approximately
one acre of land into the project boundary.

Law Enforcement, Emergency Services, and Fire Prevention

    BLM recommends Okanogan PUD develop and implement, after
consultation with BLM, a Law Enforcement, Fire, and Emergency Services
Plan. The plan would include provisions for: (1) Coordination of and
funds for law enforcement, fire, and emergency services personnel; (2)
law enforcement presence, enhanced emergency communication and response
procedures, public safety and security, protection measures for natural
resources, recreation resources, and heritage resources; (3) an
emergency telephone at the site; (4) an assessment of the need for
additional law enforcement, including funds for additional personnel,
to patrol BLM-administered lands; (5) a description of fire prevention
and protection on BLM-administered lands to include: (a) An
identification of hazard abatement procedures, (b) a notification
process, (c) an identification of agencies to respond to fire reports,
and (d) a process for reclaiming and/or rehabilitating burned lands;
(6) coordination with BLM to evaluate the need for fire protection on
BLM-administered lands, including monitoring and evaluating of man-made
fires that affect BLM-administered lands; and (7) all costs provided by
Okanogan PUD, if monitoring demonstrates an increased need for fire
prevention, detection, and suppression.

Our Analysis

    BLM indicated that increased recreational use in the Enloe Project
area can lead to adverse effects on environmental and cultural
resources, an increased risk of fire, and an increase in vandalism that
will require law enforcement and emergency or fire response. As
previously discussed, Okanogan PUD proposes to remove existing trash
from defined areas on BLM land, conduct annual clean up events, and
conduct project facility site reviews. Further, Okanogan PUD proposes
to implement its Recreation Management Plan that contains measures to
minimize conflicts between recreational use and associated effects on
environmental resources. Overall, these measures, along with additional
staff-recommended measures, would protect the environmental,
recreational, and cultural values at the Enloe Project.
    Providing funds for law enforcement, fire, and emergency services
personnel is not a specific measure to protect and enhance fish and
wildlife resources. The Commission has made clear that it is concerned
with protecting resources and uses at the project rather than funding
personnel.\38\ However, a fire suppression program to rehabilitate

lands subject to wildfire and to reduce fuel loads to prevent wildfire
on project lands and adjoining wildlife areas could protect and enhance
terrestrial resources affected by the construction, operation, and
maintenance of the Enloe Project. A fire suppression program could
include signage at recreation sites describing the hazards and costs of
wildfire and undertaking habitat rehabilitation efforts, such as
replanting with perennial grasses to reduce fuel loads.
---------------------------------------------------------------------------

    \38\ See Settlements in Hydropower Licensing Proceedings Under
Part I of the Federal Power Act, 116 FERC Sec.  61,270 (2006).
---------------------------------------------------------------------------

Building Removal

    BLM recommends that Okanogan PUD remove two small, deteriorating
buildings at the north end of the proposed Enloe Dam Recreation Area.
BLM states these buildings are deteriorating, unsafe to enter, marked
with graffiti, and pose an unattractive nuisance to visitors to the
site. In response to BLM, Okanogan PUD states that one of two small
structures on the north end of the proposed Enloe dam recreation area
is owned by a private landowner that maintains a lease with BLM.
Okanogan PUD states it is not in a position to remove this structure,
however, it will take reasonable measures to secure existing structures
from unauthorized entry.

Our Analysis

    Licensees are required to ensure that all reasonable precautions
are taken to ensure that the construction, operation, and maintenance
of structures or facilities on project lands occur in a manner that
protects the scenic, recreational, and environmental values of the
project.
    If the deteriorating pump house structure is unsafe and does not
serve project purposes, it would be appropriate for Okanogan PUD to
maintain the building to a point where it is safe or remove it from the
project boundary. Currently, it does not appear that these two
buildings are being used for project purposes.

Non-Motorized Trails

    BLM recommends Okanogan PUD support the development of the
Similkameen Rail Trail, a cooperative, non-motorized public access
trail along the old railroad grade from Oroville to Nighthawk, as a
segment of the Pacific Northwest National Scenic Trail. BLM also
recommends that Okanogan PUD support the development of the Similkameen
portion of the Greater Columbia Water Trail. BLM recommends that
Okanogan PUD consult with BLM, FWS, Park Service, Water Trail
Committee, Pacific Northwest Trail Association, and Okanogan County to
identify water and trail access points that are likely to become
popular as the trails are developed in this area. BLM also recommends
that Okanogan PUD rebuild the footbridge across the Similkameen River.
The footbridge would provide the only foot access from the east side of
the river (between the trestle bridge two miles downstream of the dam
and Nighthawk six miles upstream) to the trail opportunities on the
west side of the river.
    Okanogan PUD states its recreation development proposal was crafted
in consultation with local stakeholders, and local stakeholders did not
identify that the footbridge providing public access to the west bank
of the river was needed. Okanogan PUD states this is a request for an
enhancement that goes beyond the need to mitigate project impacts.
However, Okanogan PUD has indicated that it is receptive to proposals
to restore the footbridge across the river if a proponent and source of
funding were to come forward. Okanogan PUD would continue to coordinate
with federal and state agencies and local historical societies to
explore funding sources for restoring the footbridge.
    Okanogan PUD states it supports the development of the Greater
Columbia Water Trail as evidenced by the measures in the Recreation
Management Plan that are supportive of and complementary to the goals
and objectives of Greater Columbia Water Trail. Okanogan PUD states
that it has demonstrated support for the Similkameen Rail Trail by
transferring ownership of the trestle bridge to Okanogan County for use
in developing the Similkameen Connector Trail, which has become part of
the Similkameen Rail Trail and the Scenic Trail.

Our Analysis

    Consultation with Okanogan PUD in the development of the
Similkameen Rail Trail and the Similkameen portion of the Greater
Columbia Water Trail within the project vicinity would ensure both
planned trails are implemented in a manner consistent with the project.
Rebuilding the footbridge across the Similkameen River downstream of
the dam would provide access to the west side of the river, no project
recreational facilities are being proposed for that area at this time.
Recreational access to the west side of the Similkameen River could be
improved in the future, once the plans for the Similkameen Rail Trail
are finalized.
3.3.7 Aesthetic Resources
<IP_ADDRESS> Affected Environment
Project Setting
    Situated in north-central Washington (near the Canadian border) on
the east side of the Cascade Mountains near the rural community of
Oroville, the Enloe Project area is characterized by its remote,
relatively undeveloped landscape. Accessed via the narrow Loomis-
Oroville Road, the Enloe Project area features moderately steep
mountainous terrain incised by eroded canyons. Created by the
Similkameen River, the Enloe Project area's topography is distinguished
by gradual to steep sloping canyon walls. These walls rise to
elevations between 700-800 feet with Kruger Mountain rising 878 feet to
the north and a series of smaller un-named 750- to 800-foot peaks line
the southwest side. A small intermittent stream, the Ellemeham Draw, is
situated between Enloe dam and the falls, and visually cleaves the
southeast canyon wall. Most of the project area is undeveloped with a
cluster of industrial structures and abandoned buildings assembled
immediately around and just below Enloe dam.
    The land surrounding the Enloe Project area is greatly influenced
by its climate and geologic history. The eroded canyons that
characterize the Enloe Project area are generally the result of
retreating glaciers that last covered the area about 15,000 years ago.
The eroded canyon slopes feature both gradual slopes, as well as steep,
rocky inclines that rise to 800 feet (about 500 feet above the mean
Enloe Project area elevation). Upstream, the Similkameen River follows
a horseshoe-shaped turn enclosed between steeply sloped canyon walls,
known as Shanker's Bend. The river within the Enloe Project area flows
placidly through a shallow reservoir before spilling over Enloe dam and
plunging down steep falls immediately downstream.
    The hills on either side of the river are a combination of rocky
outcrops and large areas of shrub steppe vegetation spotted with
evergreen trees. Riparian forest, dominated by black cottonwood in
stands, is found along the reservoir shoreline. In the spring, summer,
and fall, colors in the landscape are primarily brown hues dotted with
dark green vegetation. Snow is common in the winter. Textures in the
landscape include rocks, sagebrush, trees, and water.
    The overall landscape is a combination of natural and human-made
elements. The natural elements

are characterized by unnamed mountains, sparse low level vegetation,
and the Similkameen River snaking through the canyon. Several human-
made elements are included in the landscape of this region. These
include a vineyard, golf course, and residences approximately 2 miles
north of Oroville. Linear elements include the Loomis-Oroville Road,
which is located on the canyon rim above the Similkameen River and
roughly follows the river's twists and turns, the abandoned Great
Northern Railroad grade that lines much of the south or east shoreline
of the river at the canyon floor, power distribution lines that run
along the canyon walls and rim, and two dirt tracks that extend south
from Loomis-Oroville Road and lead to the dam. The access roads proceed
along the river's eastern perimeter to the dam, which is located at a
point where the canyon narrows. While minimally visible from upstream,
Enloe dam rises quite prominently when viewed from downstream. The
historic powerhouse is similarly sheltered from view, perched against a
sharp slope on the west side of the river, nestled within a rocky eddy.
It is accompanied by horizontal penstocks, and prominently positioned
cylindrical surge tanks that rest on raised concrete foundations.
Human-made elements on the east side of the river include: A bridge
remnant (which once connected the east side of the river to the
powerhouse); two small outbuildings; and an abandoned concrete
irrigation ditch. The town of Nighthawk, approximately 6 miles west of
Enloe dam, is a historic mining community comprised of wood-frame
buildings (residences and associated agricultural buildings) along a
two-track dirt road.
    Visitation to the Enloe Project area is largely confined to those
persons traveling along the Loomis-Oroville Road or pursuing outdoor
recreation activities in the canyon, as well as Native Americans and
Canadian First Nations who attach cultural value to the natural setting
and associated fishing areas.
Visual Resource Management
    BLM manages its lands in accordance with its Visual Resource
Management (VRM) System. The system designates landscape units in four
classes that indicate the overall significance of the visual
environment and establishes objectives for the management of each class
in order to define the level of change from a proposed project that is
acceptable in that class. By comparing the effects from a project to
the established visual objective for that area, the visual
acceptability of that project and mitigation measures needed to
decrease the visual contrast are determined. The four visual management
classes and their objectives are described below:
     Class I--The objective of this class is to preserve the
existing character of the landscape. This class provides for natural
ecological changes; however, it does not preclude very limited
management activity. The level of change to the characteristic
(background) landscape should be very low and must not attract
attention.
     Class II--The objective of this class is to retain the
existing character of the landscape. The level of change to the
characteristic landscape should be low. Management activities may be
seen, but should not attract the attention of the casual observer. Any
changes must repeat the basic elements of form, line, color, and
texture found in the predominant natural features of the characteristic
landscape.
     Class III--The objective of this class is to partially
retain the existing character of the landscape. The level of change to
the characteristic landscape should be moderate. Management activities
may attract attention but should not dominate the view of the casual
observer. Changes should repeat the basic elements found in the
predominant natural features of the characteristic landscape.
     Class IV--The objective of this class is to provide for
management activities that require major modification of the existing
character of the landscape. The level of change to the characteristic
landscape can be high. These management activities may dominate the
view and be the major focus of viewer attention. However, every attempt
should be made to minimize the impact of these activities through
careful location, minimal disturbance, and repeating the basic
elements.
    In consultation with the BLM, Okanogan PUD conducted visual
resources analysis of the Enloe Project area using the VRM methodology
outlined above and determined that the characteristics of the area fell
within the Class IV management class. Four key observation points
(KOPs) in the project area were identified for analysis of the most
critically-traveled routes or observation points in the Enloe project
boundary (figure 10): (1) Loomis-Oroville Road; (2) overlook from
Loomis-Oroville Road approximately 3 miles north of Oroville; (3) rocks
below Enloe dam on the Similkameen River; and (4) overlook near Enloe
dam (figures 11 through 14).
BILLING CODE 6717-01-P

[GRAPHIC] [TIFF OMITTED] TN17MY11.009

    On May 29, 2009, additional information was submitted by Okanogan
PUD regarding the visual resources study. Three additional KOPs were
evaluated to include views associated with the proposed locations for
interpretive displays (figure 10): The overlook east of Enloe dam and
the areas where the two interpretive panels would be placed (figures 15
through 17). The dates that the photos were taken and the approximate
river flows at that time were not included in the study.
[GRAPHIC] [TIFF OMITTED] TN17MY11.010

    Travelers on Loomis-Oroville Road view the Enloe Project area for a
relatively short time in the foreground-middleground. Visibility of the
Enloe Project area is generally unobstructed to travelers on Loomis-
Oroville Road; however, the canyon topography makes it difficult for
the travelers to view.

[GRAPHIC] [TIFF OMITTED] TN17MY11.011

    People stopping at the overlook on Loomis-Oroville Road have
opportunities for extended views of the Enloe Project area. From this
viewpoint, the dam is visible as are the abandoned penstock, surge
tank, and the roof of the abandoned powerhouse.

[GRAPHIC] [TIFF OMITTED] TN17MY11.012

    Recreators on the river have extended views of the project area.
From this viewpoint visitors see the existing human-made features to
include the abandoned powerhouse, former footbridge tower, and Enloe
dam.

[GRAPHIC] [TIFF OMITTED] TN17MY11.013

    From this viewpoint, the dam and abandoned penstock are clearly
visible.

[GRAPHIC] [TIFF OMITTED] TN17MY11.014

    From this viewpoint looking downstream, the abandoned penstock and
powerhouse are visible.

[GRAPHIC] [TIFF OMITTED] TN17MY11.015

    Visitors stopping at this proposed interpretive panel location
along a proposed pedestrian trail would have opportunities for extended
views of the project area. From this viewpoint, the dam is clearly
visible.

[GRAPHIC] [TIFF OMITTED] TN17MY11.016

BILLING CODE 6717-01-C
    Visitors stopping at this proposed interpretive panel along a
proposed pedestrian trail, located approximately 300 feet south of KOP
6 would also have opportunities for extended views of the
project area. From this viewpoint, the dam, the abandoned penstocks,
and Similkameen Falls are clearly visible.
Noise
    Noise is generally defined as unwanted sound. It is emitted from
various sources including airplanes, factories, railroads, and highway
vehicles. The magnitude of noise is described by its sound pressure.
Because the range of sound pressure varies greatly, a logarithmic scale
is used to relate sound pressures to some common reference level, the
decibel. Therefore, a sound pressure level is equivalent to a certain
number of decibels.
    Because sound pressure levels expressed in decibels are based on a
logarithmic scale, they cannot be added or subtracted in the usual
arithmetical manner. If a sound of 70 dB is added to another sound of
70 dB, the increase is only 3 dB to 73 dB, not a doubling to 140 dB. If
two sounds are of different levels, the lower level adds less to the
higher level as their difference increases. For example, if the
difference is as much as 10 dB, the lower level adds nearly nothing to
the higher level. Adding 60 dB to a 70 dB sound increases the total
sound pressure level less than 0.5 dB. Additionally, a decrease of 3 dB
in sound pressure level means that the noise has been reduced to half
of its original level.
    In 1974, EPA identified indoor and outdoor noise levels to protect
public health and welfare against hearing loss, annoyance, and activity
interference (EPA, 1974). A 24-hour exposure level of 70 dB was
identified as the limit of environmental noise which will protect
against hearing damage. Levels of 55 dB outdoors and 45 dB indoors are
identified as desirable limits to protect from activity interference
and annoyance. These levels of noise are considered those which will
permit spoken conversation and other activities such as sleeping,
working, and recreation. The levels are not single event or peak
levels, but are 24-hour averages. Further, these levels are not
regulatory goals or requirements; they represent levels of
environmental noise required to protect the public health and welfare
with an adequate margin of safety (EPA, 2007).
    The Enloe Project area is characterized by its remote, relatively
undeveloped landscape. Accessed via the narrow Loomis-Oroville Road,
the Enloe Project area features moderately steep mountainous terrain
incised by eroded canyons. Natural noises which are associated with
this site would include wildlife sounds such as animal calls and the
sounds of wildlife moving through the environment and interacting with
one another. Other natural sounds would include sounds of the physical
environment such as wind, rain, thunder and the river rushing over

the dam or falls when flows are occurring. Human background noise would
include the passing cars on the Loomis-Oroville Road, the sound of
recreating visitors, and the activities Okanogan PUD employees
occasionally checking the area of the dam.
<IP_ADDRESS> Environmental Effects
Aesthetics Management Plan
    Okanogan PUD proposes to implement its Aesthetics Management Plan
to manage project effects on aesthetic resources associated with the
proposed project. Okanogan PUD proposes the following measures within
its Aesthetics Management Plan.

Use Visually-Compatible Colors and Building Materials and Non-
Reflective Surfaces (AES-01 and AES-03)

    Okanogan PUD proposes to use visually-compatible colors and
building material textures that harmonize with the existing landscape
for the new east-bank construction. A range of compatible colors and
building material textures would be used to reduce the visual presence
of new project facilities within the larger landscape.
    The proposed east bank construction of project facilities consists
of the (1) new crest gates at the top of the dam, (2) headworks that
include an approach channel, river intake, and intake canal, (3)
penstock intake, (4) two penstocks, (5) powerhouse, (6) tailrace, (7)
recreational facilities north of the dam (picnic tables, vault toilet,
boat launch), and (8) an improved access road.
    It would be expected that the powerhouse, penstocks, and tailrace
would be visible from KOPs 3 through 7 with the
powerhouse representing the most visible new feature. To further reduce
the visual presence of the new powerhouse and have the new structure
harmonize with its surroundings, Okanogan PUD proposes colors
consistent with suggested guidelines within the HPMP regarding new
construction within the Enloe Project. These guidelines state that
``muted, natural tone materials would be used. Okanogan PUD also
proposes matte finishes, as opposed to glossy finishes. Consistent with
guidance within the HPMP, new building materials, such as concrete,
steel, and galvanized metal roofing would have minimal, but some
discernable textures. Concrete, for instance, would in general be left
exposed, trowelled smooth so that board forms are not visible, or
coated with natural gray-colored stucco coatings to blend with the
original features. While galvanized materials, such as steel or iron
roofing, are by nature smooth, they would be primed with a matte finish
and be nonreflective.

Consultation with Colville Confederated Tribes on Traditional Cultural
Properties (AES-02)

    The Colville attach cultural significance to the visual aesthetics
of several natural features and their components (i.e., Traditional
Cultural Properties) within the project area. Okanogan PUD proposes to
consult with the Colville concerning these traditional cultural
properties utilizing the existing Cultural Resources Working Group.

Dewatering and Construction of a New Facility That Could Block Existing
Views (AES-04)

    Okanogan PUD proposes to make trail improvements that would create
closer and more intimate views of the falls. This would be from
viewpoints that are not currently easily accessible to the public. The
trail would be linked to the recreational improvements made above the
dam and provide visitors with a trail with closer views of the falls
and greater accessibility to the area below the dam. Interpretive
signage, in concert with HIST-03, would also be placed along the trail
to highlight historical flows over the dam. This new trail would help
to replace views partially blocked by the construction of new project
facilities and provide closer access to the falls for recreators during
periods of high flows and high visitation.
    The existing buildings would be removed unless a qualified third
party entity assumes ownership and management of the old west bank
powerhouse to maintain it for historic and recreation purposes. If a
qualified third party entity is not identified within five years of
licensing, then the historic Enloe powerhouse, located on the west side
of the Similkameen River and below Enloe dam, would be demolished after
completing mitigation measures undertaken in consultation with the
Washington SHPO and Park Service. Such measures may include detailed
Historic American Engineering Record (HAER) documentation.
    Okanogan PUD states that the foundation of the powerhouse and surge
tanks, which accounts for about 50 percent of the visible portions of
the building, would be retained, but that the powerhouse and surge tank
superstructures would be demolished to remove any deteriorated and
unstable structures from the site. Okanogan PUD would also ensure that
these actions are consistent with Measures HIST-01, HIST-02, and ARCH-
01.
    BLM recommends that Okanogan PUD revise and implement the
Aesthetics Resource Management Plan to include the following: (1)
Blending the existing and proposed Enloe Project into the existing
landscape character; (2) revegetate, stabilize, and landscape new
construction areas and areas immediately adjacent; (3) grading,
planting native vegetation, repairing slopes damaged by erosion,
preventing future erosion; (4) monitoring and maintenance; (5)
implementation schedule; (6) periodic review and revision; and (7)
providing river flows over Enloe dam.
    BLM also noted in its 10(a) recommendations that Okanogan PUD's
aesthetic analysis identified the Similkameen Area as having a Scenic
Quality of B, but then based its analysis as having a Scenic Quality of
C. Therefore, BLM recommends that the aesthetic analysis that Okanogan
PUD conducted be revised to reflect a Scenic Quality of B and to
similarly adjust the sensitivity rating given the current and projected
recreation use, the identification of sightseeing as a use in the final
license application, the designation of a National Scenic Trail which
passes by the Enloe Project, and the proximity of a highway.

Our Analysis

    Okanogan PUD's proposal to use visually-compatible colors and
building material textures that harmonize with the existing landscape
for the new east-bank construction and implement its Aesthetics
Management Plan would reduce potential adverse visual effects at the
proposed project. BLM's recommendation that Okanogan PUD include
specific approaches concerning the blending of the existing and
proposed Enloe Project facilities into the existing landscape
character, revegetating and stabilizing and landscaping new
construction areas and areas immediately adjacent, grading, planting
native vegetation, repairing slopes damaged by erosion, preventing
future erosion, monitoring and maintenance, implementation schedule,
and periodic review and revisions would help ensure that project
facilities would ensure protection of the visual resources at the
proposed project. In addition, because the project is located on BLM
lands, it would be beneficial if BLM were added to this consultation
process in addition to consultation with the Colville. Revising the
Aesthetics Management Plan to contain these elements could have a
direct beneficial effect on aesthetic resources at the project by
keeping BLM and the Colville informed on lay down or construction
material storage areas that are yet to be determined. Consultation with
BLM on

the revision of the aesthetic analysis to reflect a Scenic Quality of
B, with an appropriate sensitivity rating reflecting the site
conditions identified in BLM's 10(a) recommendation, would ensure that
the project area has been appropriately evaluated and that appropriate
measures are undertaken to preserve the aesthetic character of the
area.

Aesthetic River Flows

    As we've said, Okanogan PUD proposes a year-round minimum flows of
10 cfs in the bypassed reach. The flows would be seasonally adjusted to
30 cfs for the period of mid-July through mid-September. This proposal
would provide minimum flows when spillage is not occurring--about 9.5
months of the year in low water years and 8 months in high water years.
BLM, the Colville, Washington SHPO, and American Whitewater recommend
an investigation into options for providing river flows over Enloe dam
and the subsequent Similkameen Falls for aesthetic purposes, the
incorporation of aesthetic flows into the Aesthetic Management Plan,
and a survey of recreational users regarding aesthetic flow releases.
Specifically, the parties request a study to assess the effects of
dewatering the spillway and rocky area below the dam, including
alternatives that would spill water over the dam all year long.
    Okanogan PUD states that Similkameen River fisheries managers have
expressed serious concern that aesthetic flows could increase
temperature below the falls. For this reason, the minimum flows would
be monitored for both DO and temperatures. Additionally, Okanogan PUD
proposes to address issues with the minimum flow through an adaptive
management plan.

Our Analysis

    In consultation with BLM, Okanogan PUD conducted visual resources
analysis of the Enloe Project area using the VRM methodology outlined
above and determined that the characteristics of the area fell within
the Class IV management class. In addition, Okanogan PUD provided
aesthetic simulations showing the views of project area from various
KOPs.
    The lowest minimum monthly average flow of 191 cfs occurred on
September 2003. The proposed minimum flow of 10 cfs (for the last 15
days of the month) is only 5 percent of the 79 year record (see table
2) and is less aesthetically desirable. However, any minimum flow must
meet the water quality standards. The 10-cfs flow (with seasonal
adjustment to 30 cfs) would meet water quality standards based on
Okanogan PUD's best estimate of the bypassed reach dimensions and
modeling of the temperature gained in the bypassed reach (see section
<IP_ADDRESS>, Minimum Flow Proposal).
    While several assumptions were made in the modeling and size
estimate of the bypass section, this is a proposed minimum flow and is
subject to change based on real-world results. Additionally, the method
of delivery of the minimum flow is undetermined at this time. As such,
it is difficult to ascertain the full effects of the minimum flow on
water quality and the aesthetic resources, namely the falls. However,
the measure, along with an evaluation to determine effectiveness,
should adequately provide a means for testing the proposals' effect on
aesthetics and water quality while still providing a framework for
making improvements, if needed. Observing recreation use at the falls
as a part of the recreation monitoring plan would provide more
information on if visitors to the project are visiting the falls as
well.

Noise

    Proposed construction activities at the Enloe project would cause
unnatural noises. Okanogan PUD has taken steps to reduce the impacts of
such noise, particularly with its Blasting Plan. It also proposes to
concentrate construction activities with the loudest noise to occur in
summer and early fall to minimize effects on overwintering birds and
bald eagles as much as possible.
    Once the project is complete, minor noise would be associated with
the operation and maintenance of the hydroelectric facility (typically
54-68 decibels ten to sixty feet from the powerhouse, depending upon
the design structure and topography), but it is not anticipated that
routine project operations and maintenance would disturb wildlife or
visitors in the project area.

Our Analysis

    Although proposed construction activities would cause unnatural
noises at the project, construction-related noise is considered a
temporary and short-term effect. Constructing the project in the summer
and early fall would reduce the effect on overwintering birds and bald
eagles and other wildlife. Moreover, visitors would only be allowed
limited public access to the project during construction as proposed in
the Safety during Construction Plan. This would increase the distance
between the public and construction activities at the project and
further minimize the amount of construction-related noise visitors may
hear when visiting the project.
3.3.8 Cultural Resources

<IP_ADDRESS> Affected Environment

Section 106 of the National Historic Preservation Act

    Section 106 of NHPA, as amended, requires the Commission to take
into account the effects of licensing a hydropower project on any
historic properties and allow the Advisory Council on Historic
Preservation a reasonable opportunity to comment if any adverse effects
on historic properties are identified within the hydropower project's
APE.
    Historic properties are defined as any district, site, building,
structure, or object that is included in or eligible for inclusion in
the National Register. In this EA, we also use the term ``cultural
resources'' to include properties that have not been evaluated for
eligibility for listing in the National Register. In most cases,
cultural resources less than 50 years old are not considered eligible
for the National Register.
    Section 106 also requires that the Commission seek concurrence with
the Washington SHPO on any finding involving effects or no effects on
historic properties. If Native American (i.e., aboriginal) properties
have been identified, section 106 also requires that the Commission
consult with interested Native American tribes that might attach
religious or cultural significance to such properties.

Area of Potential Effect (APE)

    Pursuant to section 106, the Commission must take into account
whether any historic property could be affected by the issuance of a
license within a project's APE. The APE is determined in consultation
with the Washington SHPO and is defined as the geographic area or areas
within which an undertaking may directly or indirectly cause
alterations in the character or use of historic properties, if any such
properties exist. In its license application, Okanogan PUD (2008a)
defined an APE as consisting of all lands within the Enloe Project
boundary, described as the 1,055-foot above mean sea level elevation
line that extends from the upstream end of Shanker's Bend, to
approximately 1,000 feet downstream from Enloe dam. The APE includes
the dam, penstocks, powerhouse, recreational sites, access roads, and
appurtenant facilities. The APE for historic resources (buildings and
structures) extends beyond the

project boundary to include an additional 100 feet (horizontally) where
project operations may affect the character or use of historical
resources and/or TCPs. Okanogan PUD included in its license application
a letter dated July 24, 2009, from the Washington SHPO office which
concurred with the APE.
    In November 2008, Okanogan PUD requested Washington SHPO
concurrence on an amended APE that consisted of the APE as described
above, and also included an additional access road. Okanogan PUD's May
2009 HPMP identifies the APE as such, but also includes a limited
number of power transmission lines that connect to a single utility
pole.
    On October 14, 2009, the Commission requested clarification of
Okanogan PUD's response to additional information Item 11, side channel
enhancement development. The Commission requested a map to clearly
identify the proposed side channel's location in relationship to the
project's defined APE and requested that the Okanogan PUD consult with
the Washington SHPO regarding the side-channel enhancement site.
Okanogan PUD filed its response on December 14, 2009. In its
clarification response, PUD provided a copy of meeting minutes from a
November 30, 2009, CRWG meeting. At the meeting, the possibility of two
separate APEs was discussed: one consisting of the proposed project APE
and another APE encompassing lands to be affected by the proposed side-
channel enhancement site (side-channel APE). The CRWG agreed that two
separate APEs for the Enloe Project would be appropriate and should be
identified in the PA and associated HPMP. On September 23, 2010,
Okanogan PUD requested Washington SHPO's concurrence on the side-
channel APE. On September 28, 2010, the Washington SHPO concurred.

Prehistoric and Historic Background

    The following text is a summary of the cultural overview provided
in the May 2009 HPMP (Okanogan PUD, 2009e).
    The Northern Columbia Plateau lies primarily within the Fraser
Watershed, with a portion in the south draining into the Columbia River
Watershed. It is an area that was occupied primarily by Interior Salish
speakers who are now represented by the Colville. Colonizing groups
were likely coastal people with a generalized Paleolithic foraging
economy that spanned a much larger geographic area. Middle Holocene and
later peoples followed a generally riverine subsistence economy typical
of the large western river systems, including a collector strategy that
was centered on ungulates and salmon and the gathering and storage of
root crops. As a result of resource pressures, Plateau peoples tended
to follow an annual round that led them to move to locations of stable,
predictable resources on somewhat the same schedule every year. Changes
to that schedule, such as moving from winter villages earlier in spring
than usual, or leaving a common fishing location earlier, were
generally due to variations in the productivity of the resource that
existed that year. Several different regional cultural chronologies
commonly employed for the region reflect prehistoric occupation to
approximately 12,500 years before present.
    At the time of contact, the Okanogan people occupied the portion of
the Central Plateau region that includes the study area. The political
structure of the people of the Central Plateau region consisted of
small autonomous bands or villages. Bands were organized in small
groups according to language, customs, and friendly relations, with
group leaders generally inheriting their position. The seasonal round
that groups made was based on the availability of salmon, berries,
roots, and large game. Winter villages typically consisted of a long
house covered with a tule-mat roof, one or more subterranean houses,
and a sweat lodge. Villages were located near water and firewood. Near
the project area, the falls, the location of Enloe dam, was a likely
fishing site throughout the Holocene. If necessary, individuals would
hunt deer, bear, or other game to supplement their winter food
supplies.
    In April, the members of the winter village moved to streams where
they would catch trout and suckers, which were dried and eaten until
the salmon runs began in June. Women gathered bitterroot and camas.
From June to October, salmon fishing was a primary focus of subsistence
activities with the continuation of gathering of berries and roots near
rivers. The salmon were caught with spears, weirs, fish traps, large
nets, and dipnets. They were dried on racks erected near the fishing
camps.
    Early Euroamerican presence in the Okanogan Valley was driven by
economic interest in locating fur trading posts and establishing
relations with local tribes. In 1811, the Canadian Northwest Company
fur trader David Thompson was the first Euroamerican to travel to the
Okanogan County seeking new trading opportunities. In fall 1811, the
Pacific Fur Company established Fort Okanogan 1 mile north of the
confluence of the Okanogan and Columbia rivers. By the late 1820s,
nearby Fort Colville became the center for inland trading. By 1860,
plagues caused a decline in the Native American population and the
depletion of fur resources, which led to the decline of the fur
industry in the Okanogan region.
    Christian missionaries arrived in to the Northwest in the 1840s and
contributed to the permanent Euroamerican settlement of the Northwest.
The Whitman mission was established in 1841 south of the Okanogan
region in Walla Walla, while Father Pierre Jean de Smet, who traveled
widely, came to the Okanogan Valley in 1842. It was not until 1885 that
missionary Etienne de Rouge established a mission for the Okanogan
Indians at Ellisforde. Two years later, the mission was moved south to
Lake Omak.
    On May 3, 1853, Washington Territory was created out of the Oregon
Territory. During this period, Territorial Governor Isaac Stevens
negotiated treaties with local tribes. The treaties defined boundaries
of ceded territories and removed Indian tribes to reservations, thereby
opening lands for American settlement. Between 1855 and 1856
hostilities broke out between tribes and Euroamericans erupting into
the Yakima War.
    Another point of conflict for local tribes was the growing mining
activity that had an impact on salmon spawning streams, brought an
influx of Euroamericans to the Okanogan Valley, and further altered the
local economy and development patterns. Miners formed temporary
settlements in places with convenient access to supplies and the gold
fields. One such encampment near the mouth of the Similkameen River
following a gold strike at Shanker's Bend in 1859 was called ``Okanagan
City'' and in 1860 had a population of 3,000.
    Transportation in the area advanced from stage coaches following
the Okanogan Trail to steamboats along the Columbia and Okanogan rivers
during high water season. By the early 1900s, the Marcus Division
Molson-Chopaka branch of the Great Northern Railway line was
constructed along the Similkameen River offering improved access to the
mineral of the area. The lead and zinc mining town of Nighthawk, just
west of the project, was founded in the 1890s. The community once
occupied 160 acres. Today, it is privately owned by a rancher, and
several historical buildings remain standing, including the old post
office and hotel dating to the mining era.
    A USGS map from 1906 and county atlas from 1934 show additional
roads

and trails in the vicinity of the APE (Metzger, 1934, as cited by
Okanogan PUD, 2009e). The 1934 map also shows an irrigation canal
between the Similkameen River and the Oroville-Tonasket Road to the
east.
    In 1955, the U.S. Bureau of Reclamation (Reclamation) began
investigating the feasibility of establishing irrigation facilities for
an Okanogan-Similkameen Division, using water from the nearby Chief
Joseph Dam. The Oroville-Tonasket Unit of the Okanogan-Similkameen
Division was authorized by the Act of October 9, 1962 (76 Stat. 761,
Public Law 87-762), placed under construction in 1965, and completed in
1969 (Reclamation, 2007, as cited by Okanogan PUD, 2009e). Remnants of
this later partially concrete-lined canal are within the project
boundary APE.
    The power potential of the falls site attracted the interest of
Eugene Enloe, the owner of a store in Medicine Lake, who began buying
small power companies in eastern Washington. In 1913, he incorporated
the Okanogan Valley Power Company. By 1916, Okanogan Valley Power had
also acquired the falls site including all the power generating
equipment used at the original power plant. Use of the Great Northern
Railway allowed for the delivery of construction materials for the
powerhouse and dam. Designs for the new powerhouse were developed in
1916, and construction of the concrete arch-gravity Enloe dam began in
1919 and was completed in the summer of 1920.
    Reflective of the move toward small utilities becoming part of a
unified system, the Washington Water Power Company bought Okanogan
Valley Power in 1923. Washington Water Power Company added a second
unit of 1,600 kilowatts to the Enloe plant in 1924. Washington Water
Power Company operated the complex until 1942 when it was acquired by
Okanogan PUD. It became economically inefficient to operate the small
complex after 1958, when the Bonneville Power Administration brought
its high voltage line to the Okanogan Valley. Okanogan PUD ceased
operation of the plant's generators on July 29, 1958.
    According to a record search undertaken by Okanogan PUD, several
cultural resources studies have been undertaken in the vicinity of the
project boundary APE (Okanogan PUD, 2009e). The Corps conducted a
cultural resources study between 1985 and 1987 (Salo, 1987, as cited by
Okanogan PUD, 2009e). Within the APE in the vicinity of the project
boundary, the Corps study identified five archaeological sites:
45OK367, 45OK532, 45OK533, 45OK565, and 45OK566.
    Another study within the APE was conducted for a previous Enloe
Project licensing effort (Galm, 1991, as cited by Okanogan PUD, 2009e).
This previous effort identified the potential of adverse effects on the
National Register-eligible Enloe dam and archaeological sites 45OK532,
45OK533, 45OK565, and 45OK566 (Okanogan PUD, 2009e). It was noted that
licensing the project could result in adverse effects on unidentified
TCPs.
    A later study conducted by Archaeological and Historical Services
(AHS) included test excavations at 45OK367, 45OK532, and 45OK566
(Boreson, 1992, as cited by Okanogan PUD, 2009e). AHS determined that
both 45OK532 and 45OK566 were National Register-eligible under
Criterion D.\39\ AHS did not conduct archaeological investigations of
sites 45OK533 and 45OK565.
---------------------------------------------------------------------------

    \39\ Criterion D is as follows, ``that have yielded, or may be
likely to yield, information important in prehistory or history.''
36 CFR 60.4.
---------------------------------------------------------------------------

    A record search undertaken of the side channel APE identified six
archaeological sites documented within one mile of the side channel
APE: 45OK355, 45OK357, 45OK358, 45OK359, 45OK369, and 45OK370 (Okanogan
PUD, 2009f). All of the sites were recorded in 1976 by the Corps. No
archaeological, historic, or architectural resources had been
previously identified within the boundary of the side channel APE. A
dike constructed in the early 1970s is located in this APE, but
according to Okanogan PUD, this feature does not meet the 50-year age
requirement for National Register eligibility (Okanogan PUD, 2009f).

Archaeological and Historic-Era Properties and Structures

    Between 2006 and 2007, Okanogan PUD conducted cultural resources
inventories of lands within the project boundary APE. These results of
these studies were presented in Enloe Dam Licensing Project, Okanogan
County, Washington, FINAL Cultural Resources Section 106 Technical
Report (Okanogan PUD, 2008b). These studies resulted in the
documentation of eight archaeological sites and six historical features
or structures within the APE. Two additional sites were identified
directly adjacent to the project boundary APE. Table 18 provides a
summary of all prehistoric and historic resources identified within or
adjacent to the project boundary APE to date. A cultural resources
study of the side channel APE conducted in October 2009 did not result
in the documentation of any archeological or historic-era properties
within this area.
---------------------------------------------------------------------------

    \40\ Criterion A is as follows, ``that are associated with
events that have made a significant contribution to the broad
patterns of our history.'' 36 CFR 60.4.

   Table 18--Archaeological and Historic Resources Within or Directly
               Adjacent to the Enloe Project Boundary APE
           [Source: Okanogan PUD, 2009e, as modified by Staff]
------------------------------------------------------------------------
                                                National
                                                Register
       Primary No.           Description     eligibility and  Within APE
                                                rationale
------------------------------------------------------------------------
45OK367.................  Prehistoric       Not eligible due          Y
                           occupation        to lack of
                           debris.           integrity.
45OK368.................  Enloe dam.......  Listed on the             Y
                                             National
                                             Register;
                                             eligible under
                                             Criterion A.
                                             \40\.
45OK368.................  Enloe powerhouse  Listed on the             Y
                                             National
                                             Register;
                                             eligible under
                                             Criterion A.
45OK532.................  Lithic debris...  Eligible under            Y
                                             Criterion D.
45OK533H................  Historic          Not eligible;             Y
                           homestead.        does not meet
                                             National
                                             Register
                                             criteria.
45OK565.................  Prehistoric site  Unknown;                  Y
                                             consultant
                                             could not
                                             relocate site.
45OK566.................  Lithic scatter..  Eligible under            Y
                                             Criterion D.
45OK1238 (AR-1).........  Gensey homestead  Unevaluated               N
                           site.             (outside of
                                             APE).
45OK1239 (AR-4).........  Similkameen       Not eligible due          Y
                           Falls             to lack of
                           powerhouse.       integrity.
45OK1240 (AR-5).........  Railroad camp...  Unevaluated               N
                                             (outside of
                                             APE).
45OK1241 (AR-6).........  Historic roads..  Not eligible;             Y
                                             does not meet
                                             National
                                             Register
                                             criteria.
45OK1265 (AR-4).........  Historic can      Not eligible;             Y
                           dump.             does not meet
                                             National
                                             Register
                                             criteria.

HR-1....................  Great Northern    Eligible under            Y
                           Railroad Grade.   Criterion A
                                             (June 19, 2007).
HR-2....................  Access road to    Not eligible;             Y
                           operator's        does not meet
                           house.            National
                                             Register
                                             criteria.
HR-3....................  Pump house and    Not eligible;             Y
                           water tank.       does not meet
                                             National
                                             Register
                                             criteria;
                                             integrity
                                             compromised.
HR-4....................  Oroville-         Portion within            Y
                           Tonasket          the APE not
                           Irrigation        eligible; does
                           Canal.            not meet
                                             National
                                             Register
                                             criteria,
                                             integrity
                                             compromised.
------------------------------------------------------------------------

    In June 2007, the Washington SHPO concurred that resources 45OK368
(Enloe dam, Enloe powerhouse and penstock), and HR-1 (Great Northern
Railroad Grade) are eligible for or listed in the National Register and
that resources HR-2 (access road to operator's house at Enloe dam) and
HR-3 (pump house and water tank) are not eligible (letter from G.
Griffith, Deputy State Historic Preservation Officer, Washington
Department of Archaeology and Historic Preservation, Olympia,
Washington, to K. Demuth, ENTRIX, Inc., Seattle, Washington, June 19,
2007). In its letter, the Washington SHPO also concurred that the
portion of HR-4 (Oroville-Tonasket Irrigation Canal) located within the
APE does not contribute to the potential significance of other portions
of the canal that were previously determined to be eligible. However,
the Washington SHPO recommends that the system be re-evaluated for
National Register eligibility 5 to 10 hence. The HPMP notes that both
the historic Enloe dam and powerhouse have been documented according to
HAER standards (Holstine and Eminger 1990, as cited by Entrix 2009).
    In September 2008, the Washington SHPO concurred that sites 45OK532
and 45OK566 are eligible for the National Register and that sites
45OK367, 45OK533H, 45OK1239, 45OK1241, and 45OK1265 are not eligible
(letter from R. Whitlam, State Archaeologist, Washington Department of
Archaeology and Historic Preservation, Olympia, Washington, to R.
Bailey, District Archaeologist, Spokane District Office, BLM, Spokane
Valley, Washington, September 23, 2008).
Traditional Cultural Properties
    In 2006, Okanogan PUD consulted with the Colville to identify
potential TCPs that could be present within the project APE. A final
TCP report was included as an appendix to the Enloe Dam Licensing
Project, Okanogan County, Washington, Final Cultural Resources Section
106 Technical Report (Okanogan PUD, 2008b). Within the APE, two
potential TCPs were identified.
<IP_ADDRESS> Environmental Effects
    In a letter filed August 6, 2009, the Washington SHPO concurred
that the proposed Enloe Project would have an adverse effect on
significant cultural resources listed in, or determined eligible for
listing in, the National Register. In view of the adverse effect
determination, the Washington SHPO recommended development of a
Memorandum of Agreement or PA.
    In this section, we evaluate the effects of Okanogan PUD's proposed
project construction, operation, and maintenance on the following
cultural resources: (1) Archaeological resources; (2) TCPs; and (3)
historic buildings and structures.

Project Construction

    In its HPMP and section 106 Technical Report, Okanogan PUD states
that construction activities would adversely affect one archaeological
site located within the project boundary APE: Archaeological site
45OK532, which is eligible for the National Register under Criterion D
(Okanogan PUD, 2009e, 2008b). The access road needed for project
construction site would use the existing OTID Ditch Road that crosses
site 45OK532. During construction, Okanogan PUD proposes to improve
this road to a one-lane gravel road with turnouts. As discussed below,
changes in chemical characteristics (including pH) of soils and
increases in soil moisture content due to ground-disturbing activities
can affect the preservation of site 45OK532.
    Proposed ground-disturbing construction (parking area, trails,
fencing) would occur in the vicinity of site 45OK367. However, this
site has been determined ineligible for the National Register due to
disturbance of the prehistoric archaeological deposits during the
historic period. The remaining sites are either ineligible for the
National Register, eligible (45OK566), or unevaluated (45OK565);
however, they are not located where ground disturbance may occur.
Okanogan PUD also concluded that any demolition of the historic Enloe
powerhouse is unlikely to affect historically significant
archaeological resources (Okanogan PUD, 2009e).
    In its Section 106 Technical Report, Okanogan PUD (2008b) states
that short-term effects on TCPs identified in the project boundary APE,
such as noise, dust, vibrations, and access restrictions, would not be
adverse. However, construction of the new powerhouse would have an
adverse visual effect on one of the two TCPs identified within the
project APE.
    National Register-eligible Great Northern Railroad Grade (HR-1) and
National Register-listed Enloe dam (45OK368) and historic Enloe
powerhouse (45OK368) are historically significant resources. The Enloe
powerhouse and Great Northern Railroad Grade, both of which are
abandoned, are located across the river from the proposed construction
site; therefore, Okanogan PUD states that project construction would
not result in long-term effects on the Great Northern Railroad Grade
(Okanogan PUD, 2009e, 2008b). Long-term effects on the historic Enloe
powerhouse are discussed under Operation and Maintenance Effects below.
    The historic Enloe dam would need to be refurbished to meet current
dam safety requirements and to extend its service life. Okanogan PUD
states that activities associated with refurbishment would not
contribute to the extended life of the structure. These effects would
therefore not be considered adverse if they are completed according to
the Secretary of the Interior's Standards for Rehabilitation (Okanogan
PUD, 2009e, 2008b).
    Other project-related construction would entail an approximate 2.3-
acre staging area near the proposed new powerhouse site and areas
potentially affected by spoil disposal. At this time, effects on
cultural resources that may be

associated with these areas are unknown. The HPMP, however, includes a
provision for the discovery of previously unidentified cultural
resources, which would ensure that the resource is addressed in
accordance with section 106.

Project Operation and Maintenance

    In its HPMP, Okanogan PUD states that operation of the proposed
Enloe Project would not adversely affect National Register-eligible
archaeological site 45OK566 and that effects on site 45OK565 have not
been assessed because the site could not be relocated during project
surveys (Okanogan PUD, 2009e). However, because prehistoric site
45OK532 is buried within an alluvial terrace adjacent to the
reservoir's edge, Okanogan PUD explains that fluctuating water levels
in the reservoir could potentially disturb archaeological deposits at
this site. Additionally, the access road passing through this site may
result in disturbance of archaeological deposits as a result of
maintenance activities and increased traffic. Okanogan PUD therefore
concludes that effects on this site are adverse.
    Prehistoric site 45OK566 is situated on a terrace outcrop above the
river, limiting the potential of project-related erosion effects at
this historically significant site. Okanogan PUD therefore states that
there would be no operational adverse effects to this site (Okanogan
PUD, 2009e).
    Okanogan PUD states that proposed recreation improvements could
increase public use of the project area resulting in the potential of
increased site disturbance by recreationalists (Okanogan PUD, 2009e,
2008b). However, revegetating disturbed areas with native vegetation,
as discussed in section 3.3.6, Recreation and Land Use, could minimize
project-related erosion effects at the sites. Additionally,
consultation with the CRWG, including the Washington SHPO and the
tribe, regarding project-related recreation improvements, would protect
the sites through placement of the facilities.
    In its HPMP, Okanogan PUD states that operational effects on the
historic Enloe dam would not be adverse (Okanogan PUD, 2009e). Also,
Okanogan PUD states that proposed construction of a new powerhouse on
the east side of the river would not adversely affect the historic
Enloe powerhouse. However, per the HPMP, the powerhouse would either
assume new ownership with portions demolished, or it would be entirely
demolished. In either case, any demolition of the historic Enloe
powerhouse would result in an adverse effect on a historic property.
Additionally, because of the powerhouse's proximity to a known TCP,
there is a possibility intact archaeological resources could be
uncovered during demolition activities. In its HPMP, Okanogan PUD
proposes to monitor this area during ground disturbance.
    Further, demolition of part or all of the historic powerhouse would
require the transportation of equipment and supplies along the existing
National Register-eligible Great Northern Railroad Grade, which serves
as an access road to the Enloe powerhouse. However, Okanogan PUD states
that the use of heavy equipment and hauling of refuse along the
railroad grade would not damage the grade, including elements to its
existing railroad grade surface or tunnel, which are located outside
the APE (Okanogan PUD, 2009e, 2008b). Okanogan PUD therefore concludes
that there would be no adverse effect to the railroad grade as a result
of the project.

Historic Properties Management Plan

    The HPMP was prepared after consultation with the CRWG, consisting
of representatives from Okanogan PUD; BLM; Forest Service; Washington
SHPO; the Colville; and the Commission staff. In its HPMP, Okanogan PUD
proposes to appoint an HPMP Coordinator and implement review procedures
that would apply to non-routine maintenance activities, structural
modifications or additions that may be necessary in the future.
Additionally, the HPMP includes measures and procedures for: (1)
Monitoring during construction activities and over the license term;
(2) addressing unanticipated discoveries and evaluating cultural
resources for National Register-eligibility; (3) discovery of human
remains; (4) emergency undertakings; (5) annual reporting and agency
coordination; (6) periodic review and revision to the HPMP every 5
years; (7) employee training; (8) records management and curation of
any recovered archaeological materials; and (9) activities exempt from
section 106 consultation. The HPMP includes a process for identifying
resource-specific measures for historic properties within the APE after
consultation with the CRWG.
    The HPMP describes standards to be applied during project
activities that have the potential to affect the historic integrity of
the historic Enloe dam. Okanogan PUD would apply specific standards
adapted from the Secretary of the Interior's Standards for Historic
Preservation Projects to ensure preservation of the dam. Additionally,
the HPMP includes historic resource maintenance guidelines that would
guide future dam maintenance.
    In its license application, Okanogan PUD proposes to implement four
measures to address project effects on significant historic structures
(HIST-01, HIST-02, HIST-03, and HIST-04). Additionally, Okanogan PUD
proposes five measures for archaeological resources (ARCH-01, ARCH-02,
ARCH-03, ARCH-04, and ARCH-05). Of the nine measures, all but two of
these measures were subsequently incorporated into the May 2009 HPMP.
HIST-04 would entail a review of appropriate measures, and although the
HPMP does not specifically identify measure ARCH-05 (Determine
Potential Recreational Impacts to Archaeological Sites) by name, the
HPMP discusses measures to address potential recreational effects on
cultural resources. The HPMP discusses the other measures and describes
how Okanogan PUD is seeking an outside entity to assume ownership of
the historic Enloe powerhouse (HIST-01). If a new owner is not
identified within 4 years, Okanogan PUD would consult with the CRWG,
which includes the Commission, to identify appropriate mitigation
options prior to demolishing the structure (HIST-02), which may include
updated HAER photography, stabilization of a portion of the powerhouse
as a ``ruin,'' development of interpretive materials for display in the
project boundary (HIST-03), offering bricks, windows and other
materials for salvage, providing turbines and other equipment from the
powerhouse for use in local museums, and developing an interpretive
facility that houses artifacts from the powerhouse and Enloe dam. If
demolition is determined necessary, a Memorandum of Agreement between
the Commission and the Washington SHPO would be developed that could
identify agreed-upon mitigation measures. The powerhouse penstocks and
surge tanks would be demolished regardless of whether a new owner would
be identified. To mitigate adverse effects on these features, Okanogan
PUD would photograph the powerhouse, penstocks, and surge tanks to HAER
standards prior to their demolition.
    In its HPMP, Okanogan PUD proposes to monitor shoreline areas for
erosion as a result of reservoir fluctuation (ARCH-01), avoid known
historic properties during construction (ARCH-02), and monitor sites
45OK532 and 45OK367 during construction activities (ARCH-03). If
removal of the historic Enloe powerhouse becomes necessary,

Okanogan PUD proposes to mitigate potential effects on an identified
TCP by monitoring any ground-disturbing activity in the vicinity of the
site during demolition. Other treatment options for site 45OK532
include capping the portions of site that would be crossed by the
improved access road with gravel and/or dirt rather than re-grading the
existing road and placing road turnouts and shoulders outside of the
site boundary. However, in Appendix E of the HPMP, Okanogan PUD states
that data recovery of site 45OK532 prior to construction may be
necessary. Although site 45OK367 is not eligible for the National
Register, Okanogan PUD would monitor it during construction in the
event that intact deposits might be identified. To protect both of
these sites from recreational use, Okanogan PUD proposes to implement a
long-term monitoring program. If any changes to site conditions are
identified, Okanogan PUD would implement a review procedure with the
CRWG to determine appropriate next steps. Additionally, Okanogan PUD's
annual report would summarize monitoring efforts and CRWG consultation.
Other measures include implementing an inadvertent discovery program
and training staff about protocols for such discoveries (ARCH-04) and
determining if there would be effects on archaeological sites in the
vicinity of recreational facilities (ARCH-05).
    Interior recommends revising the May 2009 HPMP, after consultation
with BLM, the Washington SHPO, and the Colville, to include the
following:
     Revise the APE to accommodate modifications to the Enloe
Project boundary, if any, and any project-related actions that may
affect historic properties on BLM-administered lands;
     A process for evaluating any previously unidentified
cultural resources identified on BLM-administered lands;
     Provision for annual reports describing activities
involving BLM-administered cultural resources;
     Periodic review of the HPMP;
     Site monitoring program for long-term cultural resource
monitoring on BLM-administered lands;
     A process for developing site-specific treatment or
stabilization measures for previously unidentified historic properties
on BLM-administered lands;
     A plan for updated cultural resources inventory to be
conducted if the project boundary is modified to include additional
land or project operations result in newly exposed, previously un-
surveyed lands;
     Provision for consultation with regard to cultural
interpretative and educational plans (including signage);
     Provision for making records of cultural resource data
gathered by Okanogan PUD on BLM-administered lands available to the
BLM; and
     Provision for inadvertent discoveries.
    In its response, Okanogan PUD states that the May 2009 HPMP
provides procedures for the majority of the issues raised by Interior
and that, as provided for in the HPMP, Okanogan PUD would review the
HPMP within 1 year of license issuance to address any concerns raised
by the CRWG, including by Interior.
    As previously mentioned, the Washington SHPO concurred that a
portion of the Oroville-Tonasket Irrigation Canal within the project's
defined APE is considered ``non-contributing'' to other portions of the
system that have previously been determined National Register eligible.
However, the Washington SHPO recommends that the system be re-evaluated
for National Register eligibility 5 to 10 years hence.

Our Analysis

    Okanogan PUD's May 2009 HPMP addresses many of Interior's
recommendations and contains measures for the protection of historic
properties within the defined Enloe Project APE. However, we discuss
particular measures contained within the HPMP, and where appropriate,
Interior's recommendations.
    The two APEs defined for the Enloe Project encompass all areas
related to, or necessary for, the construction, operation, and
maintenance of the entire proposed project. However, the May 2009 HPMP
does not identify or discuss the side-channel enhancement site,
including its defined APE. While no historic properties have been
identified in this area, we find that inclusion of the side-channel
enhancement site and a definition of its APE in the HPMP would ensure
that measures applied to lands within the project boundary would also
apply to lands within the side-channel enhancement site APE.
Additionally, as recommended by Interior, the HPMP should include a
process for reviewing and revising the APE, particularly where project-
related ground-disturbing activities may occur in the future. In
particular, this provision would ensure that any design modification to
the proposed side-channel enhancement site would be taken into account.
    Okanogan PUD's proposal to appoint an HPMP Coordinator would ensure
that the requirements of the HPMP are followed. Annual reporting to
agencies and the Colville on the status of cultural resources
management over the course of the year would provide a regularly
scheduled forum for parties to discuss the HPMP and provide comments. A
periodic review process for the HPMP undertaken every 5 years would
provide a basis for continued implementation of the HPMP. Interior
recommended that the May 2009 HPMP be revised within 1 year of license
issuance to address its recommendations. Interior's recommended
timeframe should allow Okanogan PUD sufficient time to consult with
Interior and the CRWG in order to revise the HPMP accordingly.
    Okanogan PUD's proposal to conduct training sessions as needed for
staff involved with the public or involved in planning and
implementation of actions potentially affecting cultural resources at
the project would ensure that employees are regularly informed about
issues, procedures, and protocols regarding cultural resource.
Consulting with the Colville with regard to Okanogan PUD employee
training would contribute toward staff understanding properties of
traditional religious and cultural importance to the tribe.
    Okanogan PUD's implementation of review procedures during the
planning of potential ground-disturbing activities, as well as
protocols for inadvertent discovery of previously unknown cultural
resources (as recommended by Interior), human remains, and emergency
procedures as specified in its HPMP, would ensure that cultural
resources are not inadvertently affected by project-related actions;
and, therefore cultural resources and human remains would be
appropriately addressed.
    While the May 2009 HPMP does not specifically contain a detailed
discussion of public interpretation and education, HIST-03 includes a
provision for installing public interpretive panels. Okanogan PUD's
proposed measures REC-11 and REC-12 also provide for installing
interpretive signs and an information board that would focus on the
history of hydroelectric power, the falls, and the fishery resources.
Including a provision in the HPMP to coordinate public information on
archaeological and historic resources at the project with REC-11 and
REC-12 interpretive signage could lead to an enhanced visitor
experience and encourage protection of environmental and cultural
resources.
    Okanogan PUD proposes to: (1) Maintain records relating to cultural
resources located within the APE; (2)

ensure confidentiality of these records; (3) provide any recovered
cultural materials to BLM for inclusion in its repository; and (4)
consider donating historic materials recovered from the historic Enloe
powerhouse to the Okanogan Historical Society or another group. This
proposal would address Interior's recommendation regarding the
collection of cultural resource materials and would ensure that such
materials are properly conserved and also accessible, under properly
controlled conditions, to those with appropriate research or cultural
interests.
    Okanogan PUD's proposal to implement a long-term monitoring program
at all sites within the project boundary APE would help determine if
any observed effects are project-related. This would enable Okanogan
PUD to determine the need for and frequency of future monitoring. It
would also assist in the development of appropriate treatment measures
if disturbances are identified as being related to project-related
activities. As recommended by Interior, including a provision in the
HPMP to develop a more detailed monitoring plan would ensure that
monitoring is undertaken and in a way that documents and quantifies
resulting data for consideration. This measure could also apply to the
side channel enhancement site.
    Okanogan PUD determined that erosion has the potential to adversely
affect site 45OK532 and that the site would also be adversely affected
by road construction. In its HPMP, Okanogan PUD discusses the
possibility of capping the site to protect it from road construction
activities and use. A 1992 study by the Corps (Mathewson et al., 1992)
found that burial of archaeological resources increases the vertical
load on sites, causes changes in chemical characteristics (including
pH) of soils, and increases the moisture content. These changes can
affect the preservation of site components, particularly organic
materials such as botanical and faunal remains. The Corps concluded
that site burial ``* * * should be used only when preservation of the