contributing element to a broad, but undefined Pick-Sloan Missouri
Basin historic district, the dam was also determined to be individually
eligible for listing on the National Register. Commission staff and the
Montana SHPO concurred that the dam was individually eligible, as
discussed in a letter and Programmatic Agreement (PA) issued on May 5,
2016. Six additional sites that may or may not be eligible for listing
were identified in 2012 during a cultural resources inventory for the
proposed transmission line corridor.
    Additionally, the Commission contacted the Shoshone-Bannock,
Eastern Shoshone, Nez Perce, and Salish-Kootenai tribes inviting
comments and consultation. No comments or requests for consultation
were received from the tribes.
Traditional Cultural Properties
    The Commission consulted with the Nez Perce, Salish-Kootenai,
Eastern Shoshone, Shoshone-Bannock, and Northern Arapaho tribes
regarding the project. None of these tribes expressed concern about
potential TCPs that might be present within the project APE.
<IP_ADDRESS> Environmental Effects
    Commission staff and the Montana SHPO concurred that the Clark
Canyon Dam would be adversely affected by constructing and operating
the project, as stated in the PA and HPMP. Construction of the project,
including retrofitting project features on or adjacent to the dam, or
other alteration, would diminish the historical integrity of the
structure's location, design, setting, materials, workmanship, feeling,
or association. The applicant would consult with the SHPO and
Reclamation to develop a Memorandum of Agreement that would include
measures to address adverse effects to Clark Canyon Dam. A final PA has
been signed that requires the licensee, if a license is issued, to
revise its proposed HPMP to include a Treatment Plan to resolve effects
on the dam prior to construction.
    The SHPO concurred in 2012 that none of the six sites along the
transmission line corridor would be adversely affected by the project.
To ensure that a specific rock feature was not affected, the applicant
proposed to maintain a buffer around that area so that construction
activity would not inadvertently disturb the site.
Our Analysis
    Alterations to the Clark Canyon Dam that would result from
construction of the proposed project require specific measures to avoid
or reduce adverse effects. The HPMP was originally developed by the
applicant for the prior license before the Clark Canyon Dam was
determined to be eligible for listing on the National Register. The
HPMP filed on February 9, 2016 does not indicate what specific measures
would be developed or how or when they might be implemented. Revising
the HPMP, as required by the PA, to include these measures in a
Treatment Plan for the dam before construction begins would resolve the
adverse effects.
    The February HPMP defines consultation procedures for maintenance
activities that would and would not affect the dam and what steps would
be taken if human remains are discovered during project construction
and operation. The PA requires the applicant to revise the HPMP to
allow the SHPO and Reclamation to review and comment on maintenance
activities that the licensee may determine have no effect on the dam,
and clarifies the process to be followed in the event of an
unanticipated discovery of human remains. Revising the HPMP
accordingly, in consultation with the

SHPO and Reclamation, would ensure that cultural resources are
protected.
    The February HPMP also defines procedures, in the event that
cultural resources are inadvertently discovered during the course of
constructing or developing project works or other facilities at the
project. Those procedures include stopping all land-clearing and land-
disturbing activities in the vicinity of the discoveries and consulting
with both Reclamation and the SHPO to determine next steps.
Implementing the procedures in an approved, revised HPMP would prevent
adverse effects on any newly identified cultural resources.

3.4 No-Action Alternative

    Under the no-action alternative, the project would not be
constructed. There would be no changes to the physical, biological, or
cultural resources of the area and electrical generation from the
project would not occur. The power that would have been developed from
a renewable resource would have to be replaced with other sources, and
the anticipated benefits of reduced TDG supersaturation on aquatic
resources would not be realized.

4.0 DEVELOPMENTAL ANALYSIS

    In this section, we look at the Clark Canyon Dam Hydroelectric
Project's use of the Beaverhead River for hydropower purposes to see
what effect various environmental measures would have on the project's
costs and power generation. Consistent with the Commission's approach
to evaluating the economics of hydropower projects, as articulated in
Mead Corp.,\26\ the Commission compares the project cost to an estimate
of the cost of obtaining the same amount of power using the likely
alternative source of power for the region (cost of alternative power).
As described in Mead Corp., our economic analysis is based on current
electric power cost conditions and does not consider future escalation
of fuel prices in valuing the hydropower project's power benefits.
---------------------------------------------------------------------------

    \26\ See Mead Corporation, Publishing Paper Division, 72 FERC ]
61,027 (July 13, 1995). In most cases, electricity from hydropower
would displace some form of fossil-fueled generation, in which fuel
cost is the largest component of the cost of electricity production.
---------------------------------------------------------------------------

    For each of the licensing alternatives, our analysis includes an
estimate of: (1) The cost of individual measures considered in the EA
for the protection, mitigation and enhancement of environmental
resources affected by the project; (2) the cost of alternative power;
(3) the total project cost (i.e. for construction, operation,
maintenance, and environmental measures); and (4) the difference
between the cost of alternative power and total project cost. If the
difference between the cost of alternative power and total project cost
is positive, the project produces power for less than the cost of
alternative power. If the difference between the cost of alternative
power and total project cost is negative, the project produces power
for more than the cost of alternative power. This estimate helps to
support an informed decision concerning what is in the public interest
with respect to a proposed license. However, project economics is only
one of many public interest factors the Commission considers in
determining whether, and under what conditions, to issue a license.

4.1 Power and Developmental Benefits of the Project

    As proposed, the 4.7-MW project would generate an average of 15,400
MWh annually. We have assumed the project would have a dependable
capacity of 4.7 MW; however, because the project inflow is dependent on
releases from the Clark Canyon Dam, which is directed by Reclamation
and beyond the control of the applicant, the actual dependable capacity
of the project could be lower.
    Table 5 summarizes the assumptions and economic information we use
in our analysis. This information was provided by the applicant in its
license application and supplemental submittals, or estimated by staff.
We find that the values provided by the applicant are reasonable for
the purposes of our analysis. Cost items common to all alternatives
include; licensing costs; and normal operation and maintenance cost.

  Table 5--Parameters for the Economic Analysis of the Clark Canyon Dam
                          Hydroelectric Project
                             [Source: Staff]
------------------------------------------------------------------------
            Assumption                   Value             Source
------------------------------------------------------------------------
Period of analysis (years)........              30  Staff.
Term of financing (years).........              20  Staff.
License application cost..........        $160,000  Clark Canyon Hydro.
Construction cost.................     $32,500,000  Clark Canyon Hydro.
Annual operation and maintenance..        $365,088  Clark Canyon Hydro.
Power value \a\...................      $80.87/MWh  Clark Canyon Hydro.
Interest rate.....................       8 percent  Staff.
Discount rate.....................       8 percent  Staff.
------------------------------------------------------------------------
Note: All costs are in 2015 dollars.
\a\ Average of on- and off-peak seasonal values of project power since
  the project would be producing power during the summer representing
  55% of the project's total annual production.

4.2 Comparison of Alternatives

4.2.1 No-Action Alternative

    Under the no-action alternative, the project would not be
constructed as proposed and would not produce any electricity. No costs
for construction, operation and maintenance, or proposed environmental
protection, mitigation, or enhancement measures would be incurred by
the applicant.

4.2.2 Applicant's Proposal

    Under the applicant's proposal, the project would require
construction of a new hydroelectric facility at the existing Clark
Canyon Dam. The proposed project would have a total capacity of 4.7 MW,
an average annual generation of 15,400 MWh, and an average annual power
value of $1,245,398 ($80.87/MWh). With an annual production cost
(levelized over the 30-year period of analysis) of $3,576,910 ($232.27/
MWh), the project would produce energy at a cost which is $2,331,512,
or about $151.40/MWh, more than the cost of alternative power.

4.2.3 Staff Alternative

    Table 6 shows the staff's recommended additions, deletions, and
modifications to the applicant's proposed environmental protection and

enhancement measures and the estimated cost of each.
    Based on the same total capacity and average annual generation, the
project under the staff alternative would have an average annual power
value of $1,245,398 ($80.87/MWh). With an annual production cost
(levelized over the 30-year period of our analysis) of $3,580,760
($232.52/MWh), the project would produce energy at a cost which is
$2,335,362, or about $151.65/MWh, more than the cost of alternative
power.
    The staff alternative also included all mandatory conditions
specified by Montana DEQ section 401 certification, except for the
except for condition 11 which stipulates that the applicant meet
annually with all watershed stakeholders to discuss water quality
monitoring efforts associated with project operation.

4.3 Cost of Environmental Measures

    Table 6 gives the cost for each of the environmental enhancement
measures considered in our analysis. We convert all costs to equal
annual (levelized) costs over a 30-year period of analysis to give a
uniform basis for comparing the benefits of a measure to its cost.

  Table 6--Costs of Environmental Mitigation and Enhancement Measures Considered in Assessing the Environmental
                Effects of Constructing and Operating the Clark Canyon Dam Hydroelectric Project
                                         [Sources: Applicant and Staff]
----------------------------------------------------------------------------------------------------------------
                                                                                Levelized
       Environmental measure                Entity          Capital cost    Annual cost  (2015$)    annual cost
                                                               (2015$)                                (2015$)
----------------------------------------------------------------------------------------------------------------
1. Implement the Erosion and        Applicant, Staff.....      \a\ $5,900  $0...................            $500
 Sediment Control Plan.
2. Implement the Final Instream     Applicant, Staff.....     \a\ 424,600  0....................          31,770
 Flow Release Plan including pump
 on floating barge.
3. Implement the Construction       Applicant, Montana        \b\ 100,000  75,000 for years 1 &            4,400
 Water Quality Monitoring Plan       DEQ, FWS, Montana                      2 \b\.
 (CWQMP) including installation of   Trout Unlimited,
 monitoring equipment.               Staff.
4. Notify Montana DEQ and Montana   Staff................               0  1,000 \c\............           1,000
 DFWP within 24 hours of a
 deviation from state water
 quality criteria during
 construction and operation and
 file a report with the Commission
 within 30 days of the deviation.
5. Conduct total dissolved gas and  Staff................      \c\ 20,000  3,000 \c\............           1,530
 dissolved oxygen compliance
 monitoring for the term of the
 license.
6. Implement the Revised DOEP with  Applicant, Montana      \d\ 1,000,000  75,000 for years 1-5,          80,300
 an additional provision to send     DEQ, FWS, Montana                      $20,000 for rest of
 the annual water quality            Trout Unlimited,                       license term \b\.
 monitoring reports to FWS in        Upper Missouri
 addition to the other agencies      Waterkeeper, Staff.
 specified in the plan.
6a. Consult with Montana DFWP and   Staff................               0  1,000 in year 6 \c\..              80
 FWS in addition to Montana DEQ
 after the first five years of
 operation and, after consulting
 with the agencies, file a
 proposal for Commission approval
 regarding possible cessation of
 the temperature monitoring
 program after the first five
 years.
7. Install pressure transducer and  Staff................       \d\ 2,000  0....................             160
 water level alarm.
8. Maintain compliance monitoring   Applicant, Staff.....      \d\ 25,800  0....................           2,180
 staff on site 24 hours a day and
 7 days a week when flows are
 bypassed around the existing
 intake and outlet works during
 construction of the proposed
 penstock.
9. Notify Montana DFWP in addition  Staff................               0  0....................               0
 to Reclamation in the event of an
 unplanned shutdown.
10. Support water conservation      Interior, Upper                     0  0....................               0
 strategies.                         Missouri
                                     Waterkeeper, Montana
                                     Trout Unlimited.
11. Fund water conservation         Interior, Upper                     0  37,000 \e\...........          37,000
 measures.                           Missouri
                                     Waterkeeper, Montana
                                     Trout Unlimited.
12. Assess impacts of fish          Interior, Montana          \c\ 10,000  100,000 for years 1 &           4,540
 entrainment and impingement.        Trout Unlimited.                       2 \c\.
13. Support ongoing agency          Upper Missouri                    N/A  N/A..................         \f\ N/A
 turbidity and nutrient pollution    Waterkeeper.
 studies and participate in
 developing an adaptive management
 plan to address pollution
 concerns.
14. Evaluate the need for dam       Montana DFWP, Upper               N/A  N/A..................         \f\ N/A
 infrastructure alterations or       Missouri Waterkeeper.
 changes in operation to minimize
 downstream turbidity.
15. Consider additional upstream    Upper Missouri                    N/A  N/A..................         \f\ N/A
 and downstream water quality        Waterkeeper.
 monitoring sites to determine
 compliance with state water
 quality criteria.
16. Monitor water quality at three  Montana DFWP.........      \c\ 60,000  3,000 for years 1-3             3,500
 additional sites downstream of                                             \c\.
 the cone valve for 3 years to
 evaluate the dynamics of the
 mixing zone.

17. Hold annual meetings with       Montana DEQ..........               0  1,000 \c\............           1,000
 watershed stakeholders to discuss
 water quality monitoring efforts
 associated with project operation.
18. Survey for raptor nests prior   Applicant, Staff.....      \b\ 20,000  0....................           1,690
 to beginning construction of the
 transmission line.
18a. Maintain a record of the       Interior, Staff......               0  0....................           \c\ 0
 raptor surveys, including
 documentation of the presence of
 migratory birds, eggs, and active
 nests, along with information
 regarding the qualifications of
 the biologist(s) performing the
 surveys, and any avoidance
 measures implemented at the
 project site.
19. Coordinate (including           Interior, Staff                   N/A  N/A..................         \g\ N/A
 sequential impact avoidance,        (except compensatory
 minimization, reclamation, and      mitigation).
 compensation) with federal and
 state greater-sage grouse plans
 and provide compensatory
 mitigation to offset any
 unavoidable impacts remaining
 after application of greater sage-
 grouse impact avoidance and
 minimization measures.
20. Construct the transmission      Staff................               0  0....................           \h\ 0
 line segments that cross the
 Horse Prairie and Medicine Lodge
 drainages outside of the greater
 sage-grouse breeding season
 (March 1-April 15).
21. Construct the transmission      Applicant, Interior,                0  0....................           \i\ 0
 line in accordance with APLIC       Staff.
 guidelines, schedule construction
 to avoid nesting season for
 raptors (including bald eagles
 and ferruginous hawk) and other
 birds, establish a 0.5-mile
 construction buffer around raptor
 nests (including any bald eagle
 nest) to avoid disturbing any
 raptors during project
 construction, and include
 avoidance and mitigation measures
 for breeding migratory birds to
 the extent practicable.
22. Install avian flight diverters  Applicant, Interior,      \b\ 200,000  0....................          16,870
 and perch deterrents on the         Staff.
 transmission line.
23. Implement the Vegetation        Applicant, Staff.....      \c\ 50,000  10,000 for years 1-3           3,6800
 Management Plan.                                                           \c\.
24. Revise the HPMP to include a    Applicant, Staff.....               0  0....................           \j\ 0
 Treatment Plan and consultation
 procedures; stop work, consult
 with SHPO, and prepare action
 plan if previously unidentified
 cultural materials are found.
25. Implement the Buffalo Bridge    Staff................       \c\ 2,000  0....................             160
 Fishing Access Road Management
 Plan and other signage and
 traffic measures for local roads
 used by construction vehicles.
26. Implement signage and limit     Applicant............           \b\ 0  0....................               0
 construction times to reduce
 conflicts with recreational use.
27. Develop, install, and maintain  Applicant, Staff.....      \b\ 10,000  100 \c\..............             840
 an interpretive display.
28. Implement the Visual Resources  Applicant, Staff.....      \a\ 65,200  0....................           5,500
 Management Plan.
29. Use a single-pole design for    Applicant............           \b\ 0  0....................               0
 the transmission line, and
 materials and colors that reduce
 visibility.
----------------------------------------------------------------------------------------------------------------
\a\ Cost estimated by applicant in the original license application escalated to 2015 dollars.
\b\ Cost estimated by the applicant.
\c\ Cost estimated by staff.
\d\ Cost estimated by the applicant for its aeration basin.
\e\ Cost estimated by entity based on 4 percent of projected annual generation.
\f\ Cost cannot be determined because the measure lacks specificity.
\g\ Cost unavailable as it includes compensatory mitigation for effects after avoidance and mitigation efforts
  have been applied. Costs and measures are unknown.
\h\ Cost included with general and construction costs.
\i\ Cost for designing and constructing the transmission line in accordance with APLIC standards included in the
  construction cost. Additional costs (construction delay or implementing buffers) are unknown because it would
  depend on the nature and extent of the find.
\j\ The Treatment Plan would replace the Memorandum of Agreement approach proposed by the applicant; no
  additional cost is anticipated.

5.0 CONCLUSIONS AND RECOMMENDATIONS

5.1 Comparison of Alternatives

    In this section we compare the developmental and non-developmental
effects of the applicant's proposal, the applicant's proposal as
modified by staff, the staff alternative with all agency mandatory
conditions, and the no-action alternative. The major differences
between the applicant's proposal and our staff-recommended
modifications are that we recommend monitoring TDG and DO at all times
during project operation rather than just potentially the first five
years of project operation and the following additional measures:
Installing and maintaining a pressure transducer and water level alarm
in the Beaverhead River during construction when flows are bypassed
around Reclamation's existing intake and outlet works; notifying
Montana DFWP in addition to Reclamation in the event of an unplanned
shutdown; notifying Montana DEQ and Montana DFWP within 24 hours of any
deviation from water temperature, DO, TDG, or turbidity requirements
during construction and operation and filing a report with the
Commission within 30 days describing the deviation, any adverse effects
resulting from the deviation, the corrective actions taken, any
proposed measures to avoid future deviations; and maintaining records
of pre-construction raptor surveys that includes presence of birds,
eggs, and active nests, information regarding the qualifications of the
biologist performing the survey, and measures implemented to avoid
disturbing nesting birds. The staff alternative also includes all of
the mandatory conditions specified by Reclamation under FPA section
4(e) and all of Montana DEQ's section 401 water quality certification
conditions except for condition 11 which stipulates that the applicant
meet annually with watershed stakeholders to discuss water quality
monitoring efforts associated with project operation.
    The environmental effects of the staff alternative and applicant's
proposal are essentially the same. Both alternatives would result in
short-term changes in water quality from erosion and sedimentation and
minor impacts from vegetation removal and disturbance of wildlife
during construction. Proposed measures would minimize the adverse
effects to greatest extent practicable. Both alternatives would also
result in long-term benefits to water quality and aquatic resources
from increased oxygen through the aeration basin in the summer and
reduced potential for TDG supersaturation in the late fall. Staff's
recommended measures would improve Commission administration of the
license and ensure timely identification of any needed corrective
actions.

5.2 Comprehensive Development and Recommended Alternative

    Sections 4(e) and 10(a)(1) of the FPA require the Commission to
give equal consideration to the power development purposes and to the
purposes of energy conservation, the protection, mitigation of damage
to, and enhancement of fish and wildlife, the protection of
recreational opportunities, and the preservation of other aspects of
environmental quality. Any license issued shall be such as in the
Commission's judgment will be best adapted to a comprehensive plan for
improving or developing a waterway or waterways for all beneficial
public uses. This section contains the basis for, and a summary of, our
recommendations for licensing the Clark Canyon Dam Hydroelectric
Project. We weigh the costs and benefits of our recommended alternative
against other proposed measures.
    Based on our independent review of agency and public comments filed
on this project and our review of the environmental and economic
effects of the proposed project and its alternatives, we selected the
staff alternative as the preferred alternative. This alternative
includes elements of the applicant's proposal, all of the section 4(e)
conditions, most of the section 401 water quality certification
conditions, most of the resource agency recommendations, and some
additional measures.
    We recommend this alternative because: (1) The 4.7-MW project would
save the equivalent amount of fossil-fueled generation and capacity,
thereby helping to conserve non-renewable energy resources and reduce
atmospheric pollution; (2) the recommended environmental measures
proposed by the applicant, as modified by staff, would adequately
protect and enhance environmental resources affected by the project;
and (3) it includes all agency mandatory conditions. The overall
benefits of the staff alternative would be worth the cost of the
proposed and recommended environmental measures.
    In the following section, we make recommendations as to which
environmental measures proposed by the applicant or recommended or
required by agencies and other entities should be included in any
license issued for the project. In addition to the applicant's proposed
environmental measures, we recommend additional staff-recommended
environmental measures to be included in any license issued for the
project. We also discuss which measures we do not recommend including
in the license.

Measures Proposed by the Applicant

    Based on our environmental analysis of the applicant's proposal
discussed in section 3 and the costs discussed in section 4, we
recommend including the following environmental measures proposed by
the applicant in any license issued for the project.
    The applicant proposes the following environmental measures:
     Implement the ESCP filed with the license application to
minimize soil erosion and dust, protect water quality, and minimize
turbidity in the Beaverhead River;
     Implement the Instream Flow Release Plan filed with
license application that includes provisions to temporarily pump flows
around Reclamation's existing intake and outlet works to prevent
interrupting Reclamation's flow releases into the Beaverhead River
during installation of the proposed project's penstock;
     Maintain qualified compliance monitoring staff on site 24
hours per day and 7 days per week during construction when flows are
bypassing Reclamation's outlet works to ensure staff promptly responds
to a pumping equipment failure or malfunction and ensure Reclamation's
flow releases are maintained in the Beaverhead River downstream;
     Implement the CWQMP filed with the license application
that includes monitoring and reporting water temperature, DO, total
dissolved gas (TDG), and turbidity levels during construction;
     Implement the Revised DOEP filed with the license
application that includes installing and operating an aeration basin to
increase DO levels of water exiting the powerhouse and monitoring and
reporting water temperature, DO, and TDG levels for a minimum of the
first five years of project operation to ensure water quality does not
degrade during project operation;
     Implement the Vegetation Management Plan filed with the
license application that includes provisions for revegetating disturbed
areas, wetland protection, and invasive weed control to be implemented
before, during, and after construction;
     Conduct a pre-construction survey for raptor nests and
schedule construction activities or establish a 0.5-mile construction
buffer as appropriate to minimize disturbing nesting raptors;

     Design and construct the project transmission line in
accordance with current avian protection guidelines, including
installing flight diverters and perch deterrents;
     Implement the Visual Resources Management Plan filed with
the license application that includes measures to design and select
materials to minimize visual effects of the project;
     Post signs and public notice, limit construction hours,
days, and locations, and stage construction traffic to reduce conflicts
with recreational users and other motorists;
     Implement the Buffalo Bridge Fishing Access Road
Management Plan filed with the license application, including
provisions for flagging, traffic control devices, and public notice of
construction activities to maintain traffic safety and minimize effects
on fishing access;
     Install and maintain an interpretive sign near the dam
that describes the concept and function of the hydroelectric project
and how it affects the sport fisheries, including any measures taken to
eliminate or reduce adverse effects;
     Use a single-pole design for the transmission line, along
with materials and colors that reduce visibility and blend with the
surroundings; and
     Implement the revised Historic Properties Management Plan
(HPMP) filed February 9, 2016. Stop work if any unanticipated cultural
materials or human remains are found.

Additional Measures Proposed by Staff

    Under the staff alternative, the project would include
Reclamation's 4(e) conditions, the applicant's proposals, all of the
section 401 water quality certification conditions except for condition
11, and the following additional measures:
     Conduct TDG and DO compliance monitoring at all times
during project operation;
     Conduct water temperature monitoring for the first five
years of project operation and, after consultation with Montana DFWP,
Montana DEQ, and FWS, file a proposal for Commission approval regarding
the possible cessation of the temperature monitoring program;
     Install and maintain a pressure transducer and water level
alarm in the Beaverhead River during construction when flows are being
bypassed around Reclamation's existing intake and outlet works to alert
compliance monitoring staff if water levels downstream of the dam are
reduced;
     During project operation, notify Montana DFWP in addition
to Reclamation in the event of an unplanned shutdown;
     Notify Montana DEQ and Montana DFWP within 24 hours of any
deviation from water temperature, DO, TDG, or turbidity requirements
during construction and operation and file a report with the Commission
within 30 days describing the deviation, any adverse effects resulting
from the deviation, the corrective actions taken, any proposed measures
to avoid future deviations, and comments or correspondence, if any,
received from the agencies;
     Document the results of the pre-construction raptor survey
and the measures taken to avoid disturbing raptors by maintaining a
record that includes nesting bird survey data, including the presence
of migratory birds, eggs, and active nests, the qualifications of the
biologist performing the survey, and any avoidance measures
implemented;
     Construct the transmission line segments that cross the
Horse Prairie and Medicine Lodge drainages outside of the greater sage-
grouse breeding season (March 1-April 15); and
     Revise the Historic Properties Management Plan (HPMP) in
consultation with the Montana SHPO and Reclamation to include a
Treatment Plan to resolve project effects on the Clark Canyon Dam and
to clarify consultation procedures in the plan (see section 3.3.6).
File the HPMP with the Commission for approval prior to construction.
    The following is a discussion of the basis for the additional
staff-recommended measures that would have significant effects on
project economics or environmental resources, as well as the basis for
not recommending some measures proposed by agencies.

Construction Water Quality Monitoring and Reporting

    The applicant proposes in its CWQMP to provide Reclamation, Montana
DEQ, Montana DFWP, and FWS annual water quality monitoring reports
during construction. Because the applicant proposes to prepare
monitoring reports on an annual basis, any deviations from state water
quality criteria for turbidity, temperature, DO, and TDG that occur
during construction would not be reported to the Commission until the
annual report is submitted. The applicant's proposal does not
sufficiently protect water quality in the short term. If water quality
monitoring in the reservoir or in the Beaverhead River indicates that
deviations from water quality criteria are occurring during project
construction, the applicant should take immediate reasonable action to
remediate the deviation, and should notify Montana DEQ and Montana DFWP
within 24 hours of the deviation. This would give the agencies the
opportunity to visit the site quickly, assess the effects of the
deviation, and provide the applicant and the Commission with
recommendations for ways to prevent future deviations from occurring.
Thus, we also recommend that the applicant file a report with the
Commission within 30 days of the deviation that describes: (a) The
cause, severity, and duration of the incident; (b) any observed or
reported adverse environmental impacts resulting from the incident; (c)
operational data necessary to determine compliance; (d) a description
of any corrective measures implemented at the time of the incident and
the measures implemented or proposed to ensure that similar incidents
do not recur; and (e) comments or correspondence, if any, received from
interested parties regarding the incident.
    We estimate that these additional notification and reporting
measures would have minimal costs and conclude that the compliance
monitoring benefits as well as benefits to aquatic resources during
project construction would justify the cost.

Post-Construction Monitoring and Reporting

Temperature Compliance Monitoring
    The applicant proposes to consult with Montana DEQ on whether to
extend the water temperature monitoring program beyond the first 5
years of operation. We recommend this measure but also recommend that
the applicant consult with Montana DFWP and FWS and allow the agencies
30 days to review the report before filing a proposal to modify the
temperature monitoring requirements for Commission approval. Given
their trust responsibilities, also consulting with Montana DFWP and FWS
would allow them to weigh in on whether a sufficient record has been
established to document the project's compliance with state water
temperature criteria during project operation, and to determine if
additional temperature monitoring is needed beyond the initial five-
year monitoring period. We estimate that this additional coordination
and reporting measure would have minimal costs and conclude that the
compliance monitoring and aquatic resource protection benefits would
justify the minor costs.

Dissolved Oxygen and Total Dissolved Gas Compliance Monitoring
    We recommend that the applicant continue to monitor TDG and DO for
the term of any license issued. Our analysis in section <IP_ADDRESS>
indicates that it would be necessary to monitor these parameters for
the term of the license to ensure that adequate DO enhancement is
occurring throughout the year as needed, that DO aeration equipment is
functioning properly, and to track compliance with TDG and DO criteria.
We estimate the annualized cost of this measure would be $1,530, and
conclude that the compliance monitoring and aquatic resource protection
benefits would justify its costs.
Reporting Deviations From Water Quality Criteria
    The applicant proposes to provide annual water quality monitoring
reports for the first five years of project operation to Reclamation,
Montana DFWP, Montana DEQ, and FWS within 60 days following each
calendar year (i.e., by March 1) and includes a provision within its
Revised DOEP to report deviations from water quality criteria to
Reclamation, Montana DEQ, and Montana DFWP within 24 hours of the
deviation. We recommend the applicant implement its proposed reporting
provisions but also recommend that the applicant file a report with the
Commission within 30 days of any deviation from water quality criteria
that describes: (a) The cause, severity, and duration of the incident;
(b) any observed or reported adverse environmental impacts resulting
from the incident; (c) operational data necessary to determine
compliance; (d) a description of any corrective measures implemented at
the time of the incident and the measures implemented or proposed to
ensure that similar incidents do not recur; and (e) comments or
correspondence, if any, received from interested parties regarding the
incident. Filing a report with the Commission would facilitate the
Commission's administration of the license and ensure that corrective
actions taken to protect water quality during operation are reported to
the Commission in a timely manner.
    We estimate that these additional notification and reporting
measures would have minimal costs and conclude that the compliance
monitoring benefits as well as benefits to aquatic resources during
project operation would justify the cost.

Flow Alarm

    During construction of the project's inlet works, use of
Reclamation's intake and outlet works would not be available to release
flows to the Beaverhead River. During that construction period, the
applicant would pump flows from a barge over Reclamation's spillway to
discharge into the river. We recommend that the applicant install and
operate a minimum flow protection alarm system to alert compliance
monitoring staff in the event of a pumping system failure and
subsequent water level drop in the tailrace. Our analysis in section
<IP_ADDRESS> indicates that the alarm system would ensure that minimum flows
are maintained and backup pumps are brought on-line as rapidly as
possible in the event of a pumping system failure. We envision that the
alarm system would include: (1) Installation of a pressure transducer
at the proposed water quality monitoring station located approximately
300 feet downstream of the dam; and (2) an alarm that would sound in
the event that water levels measured by the transducer begin to drop.
We estimate the annualized costs of this measure would be $160, and
conclude the benefits of ensuring minimum instream flow releases and
protecting fish resources when flows are being bypassed during
construction would justify the cost.

Agency Notification of Unplanned Shutdowns

    We recommend that the applicant inform Montana DFWP in addition to
Reclamation in the event of an unplanned shutdown or other operating
emergency during project operation. We estimate this additional
notification would have minimal costs and therefore recommend this
measure as it would allow Montana DFWP to provide input on any
corrective measures needed to protect aquatic resources during any
unplanned shutdowns that occur during operation.

Cultural Resources

    To resolve adverse effects on the Clark Canyon Dam, we recommend
that the HPMP be revised to include a Treatment Plan for the dam, as
well as address other concerns raised by the SHPO and Reclamation
regarding consultation procedures. The Treatment Plan and revised HPMP
should be developed by the licensee in consultation with the SHPO and
Reclamation, and filed with the Commission for approval within 90 days
of license issuance and prior to construction. Because the Treatment
Plan essentially replaces the proposed MOA, no additional cost is
anticipated.

Measures Not Recommended by Staff

    Staff finds that some of the measures recommended by other
interested parties would not contribute to the best comprehensive use
of Clark Canyon reservoir and Beaverhead River water resources, do not
exhibit a sufficient relationship to project environmental effects, or
would not result in benefits to non-power resources that would be worth
their cost. The following discusses the basis for staff's conclusion
not to recommend such measures.
Water Efficiency Improvements, Conservation Planning, and Pollution
Adaptive Management Plan
    Interior, Upper Missouri Waterkeeper, and Montana Trout Unlimited
recommend that the applicant be required to: (1) Provide 4 percent of
the project's gross revenue to fund independent technical studies of
Beaverhead River Basin water efficiency improvements or water
conservation measures; and (2) support implementation of the 2006 MOU
between Reclamation and Montana DFWP for the Betterment of the
Beaverhead River and Valley. In addition, Missouri Waterkeeper
recommends the applicant be required to support ongoing agency studies
evaluating turbidity and nutrient pollution events occurring in the
watershed and participate in developing and implementing an adaptive
management plan that addresses those concerns.
    Available information indicates that trout populations in the
Beaverhead River are adversely affected by low flows that occur during
the non-irrigation season, and that fish populations in Clark Canyon
Reservoir are adversely affected by low reservoir levels during periods
of drought. Funding water conservation measures could help alleviate
some adverse conditions to fish that occur in Clark Canyon Reservoir
and the Beaverhead River, particularly during drought conditions. Our
analysis in section <IP_ADDRESS>, however, indicates that operation of the
project as proposed by the applicant would not cause any changes in the
water levels of Clark Canyon Reservoir, the quantity of water released
by Reclamation into the Beaverhead River for instream flows, or the
quality of tributaries entering the reservoir or within the reservoir.
    Although we agree that providing funds or support for water
efficiency improvements and participating in watershed management and
conservation planning activities may provide some benefits to fisheries
in

Clark Canyon Reservoir and the Beaverhead River through increased
potential for enhanced water storage, instream flows, and water
quality, we find that these measures bear no relationship to project
effects or purposes.
    For these reasons we conclude that Interior's, Montana Trout
Unlimited's, and Upper Missouri Waterkeeper's recommended measures
would be inconsistent with the comprehensive planning standard of
section 10(a)(1) of the FPA, and therefore would not be in the public
interest.
Annual Meeting With Watershed Stakeholders
    Montana DEQ's condition 11 stipulates that the applicant hold an
annual meeting with watershed stakeholders (i.e., state and federal
agencies, non-governmental organizations, and any interested members of
the public) to discuss water quality monitoring efforts associated with
project operation. Our analysis in section <IP_ADDRESS> indicates that we do
not expect project operation to result in frequent deviations from the
state water quality standards. Instead, our analysis indicates that
operating the project would improve water quality in the Beaverhead
River downstream of the project by enhancing DO levels in the summer
months and reducing the potential for TDG supersaturation in the summer
and early fall compared to existing conditions. While an annual meeting
would provide another mechanism to evaluate whether any changes are
needed to achieve water quality standards during project operation, it
is not needed because the applicants proposed annual reporting and
staff's recommended notification procedures (notifying the agencies
within 24 hours of a deviation) would be adequate to identify problems
and any need for corrective actions. Although the costs of organizing
and holding such meetings would be small ($1,000), the benefits would
not be worth the cost. For these reasons, we do not recommend the
annual meeting stipulated by Montana DEQ's condition 11.
Fish Entrainment, Impingement, and Mortality
    Interior and Montana Trout Unlimited recommend that the applicant
evaluate the effects of the project on fish entrainment and
impingement. The recommended entrainment evaluation may be useful at
assessing the entrainment, impingement, and mortality rates of fish at
the dam. However, we believe that sufficient information exists to
evaluate the effects of the project on fish entrainment and mortality.
    Our analysis in section <IP_ADDRESS> found that operation of the
proposed project would have no effect on the rate of fish entrainment
from Clark Canyon Reservoir because the project would not alter the
timing or volume of water withdrawals, and all water passing the dam
would do so via the existing intake structure (and by the spillway
during spill events), as it does under existing conditions. Further,
our analysis suggests that the mortality rates of entrained fish under
proposed project operation would be similar to existing conditions.
During project operation fish would still be subject to high mortality
levels when they are exposed to rapid depressurization as they exit the
pressure conditions of the deep reservoir and enter the relatively
shallow conditions in the tailrace of the dam; therefore, the proposed
project would not substantially add to the losses of fish currently
occurring at the existing outlet works at mortality rates approaching
100 percent of entrained fishes. The continued high mortality through
the dam would limit the potential that fish entrained from the
reservoir contribute substantially to the fishery downstream of the
reservoir, which consists of self-reproducing trout populations. For
these reasons, collecting additional information on entrainment and
mortality would have only minimal benefits to the fishery resource.
    We estimate that the annualized costs of the entrainment assessment
would be $4,540, not including the additional costs of any future
measures that could be implemented to reduce entrainment. We conclude
that the potential benefits of the entrainment assessment would not
justify the cost, and therefore would not be in the public interest.
Dam Infrastructure and Operation Evaluation
    Montana DFWP and Upper Missouri Waterkeeper recommend that the
applicant evaluate the need for alterations to dam infrastructure or
operations to minimize downstream turbidity effects resulting from
entrainment of organic material or inorganic fine sediment from the
reservoir into the project works. The recommended measure is non-
specific, and therefore, we are unable to evaluate the benefits and
costs of the measure. Because the project would be operated run-of-
release, the project would not alter the depth of the reservoir intake,
or the rate, volume, or velocity of water withdrawn from the reservoir,
nor does the Commission have the authority to require changes to
Reclamation's facilities or operations; therefore it is unclear what
specific changes in dam infrastructure or operations would be available
to the applicant to address Montana DFWP and Upper Missouri
Waterkeeper's concerns.
    For these reasons, we do not recommend requiring Montana DFWP and
Upper Missouri Waterkeeper's recommended evaluation.
Downstream Water Quality Compliance Monitoring
    The applicant proposes to continuously monitor TDG, DO and water
temperature for at least the first five years of project operation. The
applicant would monitor DO and temperature in a small chamber located
upstream of proposed turbines (Site 1), at a site located in the
proposed aeration basin (Site 2), and at a site located about 300 feet
downstream of the project in the Beaverhead River (Site 3). The
applicant would monitor TDG levels at Sites 2 and 3.
    Montana DFWP recommends that the applicant deploy probes at the
cone valve and 100, 200, and 300 feet below the project, in addition to
the sites proposed by the applicant, and to monitor water quality
parameters at these sites for a minimum of three consecutive years. The
additional probes would permit the applicant to determine the water
quality dynamics within the mixing zone and potentially the best place
to document compliance with DO and TDG levels over the long term.
    In addition, Upper Missouri Waterkeeper recommends that the
applicant evaluate the need for additional monitoring downstream of the
project during operation.
    Our analysis in section <IP_ADDRESS> indicates that although TDG and DO
may change slightly within the mixing zone, the site recommended by the
applicant is likely to be most representative of water quality
conditions downstream of the project and would be sufficient to
document compliance with water quality conditions. Given the
anticipated small changes within so short a distance, there would be
little benefit to downstream aquatic resources by conducting this
additional monitoring.
    We estimate that the annualized costs of monitoring at these
additional compliance sites would be $3,500 and conclude that the
limited benefits of the additional downstream monitoring would not
justify the cost.

Upstream Water Quality Monitoring
    Upper Missouri Waterkeeper recommends that the applicant evaluate
the need for additional monitoring upstream of Clark Canyon Dam during
project operation. The recommended measure is non-specific, and
therefore, we are unable to determine the benefits and costs of the
measure. The applicant already proposes to collect water temperature
and DO concentrations levels of source reservoir water in order to
monitor the need for DO enhancement downstream. Conducting monitoring
at additional sites upstream would provide general information on water
quality conditions within the Clark Canyon Reservoir above the intake
or in tributaries feeding the reservoir. However, the project would not
affect these upstream areas. Therefore, the recommended monitoring does
not have sufficient nexus to the project effects and we do not
recommend that additional upstream monitoring be included as a license
requirement.
Compensatory Mitigation for Greater Sage-Grouse
    We recommend adopting Interior's recommendation to coordinate with
BLM and Montana DNRC for the purposes of complying with federal and
state greater sage-grouse plans; however, we do not recommend adopting
Interior's recommendation to provide compensatory mitigation to offset
any remaining impacts after application of avoidance and mitigation
measures. We cannot evaluate the cost or benefits of compensatory
mitigation requirements because the agencies have not defined those
requirements. Regardless, compensatory mitigation would not be
warranted because the applicant's and staff proposed measures
adequately minimize potential adverse effects on greater sage grouse
for several reasons.
    First, the applicant's proposal to prevent perching of predators on
the transmission line, and the revegetation measures under the VMP,
would deter increased predation and minimize habitat loss. Second,
staff's recommended measure to construct the transmission line segments
that cross the Horse Prairie and Medicine Lodge drainages outside of
the greater sage-grouse breeding season (March 1-April 15) would reduce
the risk of project-related disturbances on breeding greater sage-
grouse.
    The avoidance and mitigation measures recommended in the staff
alternative would ensure that the project would have minimal effects on
greater sage-grouse and would not affect the population.

5.3 Unavoidable Adverse Effects

    Land-disturbing activities associated with the proposed
construction and operation of the project would require the removal of
vegetation and disturbance of soil. These activities would disrupt the
topsoil and result in some temporary erosion in the construction areas
that would be largely controlled by implementation of the applicant's
proposed ESCP and VMP.
    During the construction period there would be an unavoidable loss
of habitat along the access road and transmission line right-of way.
Bald eagles and ferruginous hawks may be displaced from foraging areas
in the stilling basin and along the access road and transmission line
ROW during the period of construction and for a short time afterward
until vegetation becomes reestablished.
    Noise and dust from land-disturbing activities, other construction
activities, and construction traffic would diminish the quality of the
recreational experience in the vicinity of Clark Canyon Dam and the
project site. Project construction traffic would conflict with
recreational traffic. The transmission line would introduce a new
structural feature within view of several nearby recreation sites and
along five miles of Montana Highway 324 where no transmission line
currently exists.
    Some long-term fish entrainment into project facilities and
subsequent injury would occur similar to existing conditions.

5.4 Summary of Section 10(j) Recommendations and 4(e) Conditions

5.4.1 Recommendations of Fish and Wildlife Agencies

    Under the provisions of section 10(j) of the FPA, each
hydroelectric license issued by the Commission shall include conditions
based on recommendations provided by federal and state fish and
wildlife agencies for the protection, mitigation, or enhancement of
fish and wildlife resources affected by the project. In response to our
Ready for Environmental Analysis notice, Interior, on behalf of FWS,
submitted 10(j) recommendations for the project on March 17, 2016.
    Section 10(j) of the FPA states that whenever the Commission
believes that any fish and wildlife agency recommendation is
inconsistent with the purposes and the requirements of the FPA or other
applicable law, the Commission and the agency shall attempt to resolve
any such inconsistency, giving due weight to the recommendations,
expertise, and statutory responsibilities of such agency. Table 7 lists
Interior's recommendations filed pursuant to section 10(j) and
indicates whether the recommendations are adopted under the staff
alternative. Environmental recommendations that we consider outside the
scope of section 10(j) have been considered under section 10(a) of the
FPA and are addressed in the specific resource sections of this
document.
    Of the 5 recommendations that we consider to be within the scope of
section 10(j), we wholly include 3, include 1 in part, and do not
include 1. We discuss the reasons for not including those
recommendations in section 5.1, Comprehensive Development and
Recommended Alternative. Table 7 indicates the basis for our
preliminary determinations concerning measures that we consider
inconsistent with section 10(j).

                                Table 7--Fish and Wildlife Agency Recommendations
                                                 [Source: Staff]
----------------------------------------------------------------------------------------------------------------
                                                            Within scope of      Levelized
         Recommendation                   Agency             section 10(j)      annual cost        Adopted?
----------------------------------------------------------------------------------------------------------------
1. Support water conservation     Interior..............  No. Not a specific              $0  Not adopted.
 strategies to improve                                     measure to                          Because the
 Beaverhead River instream flows.                          protect fish and                    measure is not
                                                           wildlife.                           related to
                                                                                project effects,
                                                                                we have no
                                                                                justification for
                                                                                recommending the
                                                                                measure.

2. Fund studies of water          Interior..............  No. A funding              $37,000  Not adopted.
 efficiency improvements or                                commitment for                      Because the
 water conservation measures.                              these purposes is                   measure is not
                                                           not a specific                      related to
                                                           measure to                          project effects,
                                                           protect fish and                    we have no
                                                           wildlife.                           justification for
                                                           Additionally,                       recommending the
                                                           there is no                         measure.
                                                           relationship
                                                           between this
                                                           measure and
                                                           project effects--
                                                           project operation
                                                           would not affect
                                                           the quantity of
                                                           Beaverhead River
                                                           instream flow
                                                           releases or
                                                           reservoir levels.
3. Submit water quality           Interior..............  No. Not a specific           \a\ 0  Adopted.
 monitoring reports during                                 measure to
 construction and operation to                             protect fish and
 FWS.                                                      wildlife.
4. Assess impacts of entrainment  Interior..............  Yes...............          $4,540  Not adopted.\b\
 and impingement.                                                                              Benefits of
                                                                                monitoring
                                                                                program would not
                                                                                justify the cost.
5. Coordinate (including          Interior..............  No. Not a specific         \c\ N/A  Adopted in part.
 sequential impact avoidance,                              fish and wildlife                   We recommend that
 minimization, reclamation, and                            mitigation                          the applicant
 compensation) with federal and                            measure.                            coordinate with
 state agencies on any                                                                         state and federal
 applicable compliance                                                                         resource agencies
 procedures and stipulations in                                                                for greater sage-
 greater-sage grouse recovery                                                                  grouse
 plans. Provide compensatory                                                                   conservation, but
 mitigation for any unavoidable                                                                we do not
 impacts.                                                                                recommend a
                                                                                requirement to
                                                                                provide
                                                                                compensatory
                                                                                funds for
                                                                                unavoidable
                                                                                effects.
6(a). Construct power lines and   Interior..............  Yes...............          \d\ $0  Adopted.
 substation in accordance with
 APLIC standards, including
 installing visual markers on
 the wires.
6(b). To the extent practicable,  Interior..............  Yes...............          \d\ $0  Adopted.
 schedule construction to avoid
 nesting season for raptors
 (including ferruginous hawk)
 and other birds, and establish
 a 0.5-mile no-construction
 buffer around raptor nests.
If field surveys are conducted    Interior..............  Yes...............          \d\ $0  Adopted.
 to avoid take during
 construction, maintain nesting
 bird survey data, including the
 presence of migratory birds,
 eggs, and active nests, as well
 as information regarding the
 qualifications of the biologist
 performing the survey, and any
 avoidance measures implemented.
7. Apply temporary seasonal       Interior..............  Yes...............              $0  Adopted.
 disturbance restrictions
 (February 1-August 15) and 0.5-
 mile buffer for any bald eagle
 nest that occur within 0.5-mile
 of the project.
----------------------------------------------------------------------------------------------------------------
\c\ Cost included in implementing the applicant's CWQMP and Revised DOEP.
\b\ Preliminary findings that recommendations found to be within the scope of section 10(j) are inconsistent
  with the comprehensive planning standard of section 10(a) of the FPA, including the equal consideration
  provision of section 4(e) of the FPA, are based on staff's determination that the costs of the measures
  outweigh the expected benefits.
\c\ Cost unavailable as it includes unidentified compensatory mitigation for effects after avoidance and
  mitigation efforts have been applied. Therefore, costs and measures are unknown.
\c\ Cost included in applicant's construction design.

5.4.2 Land Management Agency's Section 4(e) Conditions

    Of Reclamation's 9 preliminary conditions, we consider 8
(conditions 1 through 3 and conditions 5 through 9) to be
administrative or legal in nature and not specific environmental
measures. We therefore do not analyze these conditions in this EA.
Condition 4 requires the applicant to revegetate all newly disturbed
land areas with plant species indigenous to the area within 6 months of
the completion of the project's construction. All of

Reclamation's section 4(e) conditions are included in the staff
alternative.

5.5 Consistency With Comprehensive Plans

    Section 10(a)(2)(A) of the FPA, 16 U.S.C.Sec.  803(a)(2)(A),
requires the Commission to consider the extent to which a project is
consistent with federal or state comprehensive plans for improving,
developing, or conserving a waterway or waterways affected by the
project. We reviewed nine comprehensive plans that are applicable to
the Clark Canyon Dam Project, located in Montana.\27\ No
inconsistencies were found.
---------------------------------------------------------------------------

    \27\ (1) Montana DEQ. 2004. Montana water quality integrated
report for Montana (305(b)/303(d)). Helena, Montana; (2) Montana
DEQ. 2001. Montana non-point source management plan. Helena,
Montana; (3) Montana DEQ. Montana's State water plan: 1987-1999.
Part I: Background and Evaluation. Part II: Plan Sections
Agricultural Water Use Efficiency; Instream Flow Protection; Federal
Hydropower Licensing and State Water Rights; Water Information
System; Water Storage; Drought Management; Integrated Water Quality
and Quantity Management; and Montana Groundwater Plan. Helena,
Montana; (4) Montana DFWP. 2003. Montana Statewide Comprehensive
Outdoor Recreation Plan (SCORP), 2003-2007; (5) Montana DFWP. 1993.
Water rights filings under S.B.76. Helena, Montana; (6) Montana
State Legislature. 1997. House Bill Number 546. Total Maximum Daily
Load. Helena, Montana; (7) National Park Service. 1982. The
nationwide rivers inventory. Department of the Interior, Washington,
DC; (8) U.S. Fish and Wildlife Service. Canadian Wildlife Service.
1986. North American waterfowl management plan. Department of the
Interior. Environment Canada; and (9) U.S. Fish and Wildlife
Service. Undated. Fisheries USA: the recreational fisheries policy
of the U.S. Fish and Wildlife Service. Washington, DC.
---------------------------------------------------------------------------

6.0 FINDING OF NO SIGNIFICANT IMPACT

    On the basis of our independent analysis, we conclude that approval
of the proposed action, with our recommended measures, would not
constitute a major federal action significantly affecting the quality
of the human environment. Preparation of an environmental impact
statement is not required.

7.0 LITERATURE CITED

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8.0 LIST OF PREPARERS

Federal Energy Regulatory Commission

Kelly Wolcott--Project Coordinator, Terrestrial Resources and
Threatened and Endangered Species (Environmental Biologist; M.S.,
Natural Resources)
Mike Tust--Aquatic Resources (Fishery Biologist; M.A., B.A, Marine
Affairs and Policy)
Ken Wilcox--Cultural Resources, Recreation, Land Use, and Aesthetics
(Outdoor Recreation Planner; B.S., Environmental Policy and
Management)
Kim Nguyen--Geology and Soils, Developmental Analysis (Civil
Engineer; B.S., Civil Engineering)
Frank Winchell--Cultural Resources (Archaeologist; Ph.D., M.A.,
B.S., Anthropology)

[FR Doc. 2016-15343 Filed 6-28-16; 8:45 am]
 BILLING CODE 6717-01-P