PACKWOOD LAKE HYDROELECTRIC PROJECT

SUMMARY OF REPORT

Lake Level Control

The Project was scheduled for completion early in 1964. Due to construction delays, the Plant was not in operation on a regular basis until August of 1964. The drop structure was completed in October of 1963 and the Lake outflow overtopped the drop structure until mid-July of 1964. In addition, the June 1964 flow was approximately 45% greater than the 50 year average. During this nine month period of overtopping, lake levels caused some flooding of shoreline trees and resulted in browning of leaves. This led to speculation by some parties that the Project would result in permanent damage to the shoreline effect.

During the first six years of Project operation since August of 1964, the Project has shown excellent capability to maintain the operating pool levels during the recreation season May 1 through September 15. The total period of days when the Lake outflow exceeded the Project release capability has amounted to a total of 38 days during the first six years and never for a period of more than 14 days.

The requirement that the licensee have a full pool elevation by May 1 of each year proves an economic hardship on the Project since during dry years it is virtually necessary to sustain complete Project shutdown in order to raise the Lake levels. On the other hand, during periods of heavy snowpack a full pool at May 1 of each year proves a hardship on recreation and shoreline since the full pool elevation on May 1 results in little or no control over sudden occurrences of heavy runoff.

Minimum Permissible Operating Level

The minimum operating level of 2850.5 is an economic hardship on the Project since it does not allow the full 8 foot of drawdown during winter critical hydro periods originally approved but later changed in the amended license. The critical hydro period in the Northwest starts August 15 to September 15 of each year and the FPC License #2244 requires a maximum pool elevation prior to September 15 of 2857.5 (operating pool limits during recreation season is 2857 plus or minus one-half foot).

Prior to Project construction, WPPSS sponsored the construction and operation of a USGS gauge in Lake Creek downstream from the outlet of Packwood Lake. As a part of project facilities, WPPSS installed a Sparling meter gauge in the fishwater bypass facility which indicates, records and totalizes at the Powerhouse, the quantity of fishwater bypass releases. With the installation of this new metering and instrumentation, the former USGS wooden gaugehouse and clock driven gauge becomes an unnecessary and duplicatory facility and should be discontinued. The first six years of operating reliability of the licensee's equipment has now been documented. The few days of drop structure overtopping each year can be recorded by adding the fishwater release meter readings to the flow over the drop structure. The discharge curves for the drop structure have now been established using this temporary USGS gauge. By letters of June 27 and July 3, 1968 the Bureau of Commercial Fisheries and the Washington Department of Game respectively, approved the licensee's request for gauge removal. In the June 12, 1969 Forest Service letter, they recommended the gauging station be continued and the USGS in their June 18, 1969 letter concurred with the Forest Service recommendation.

Memorandum of Agreement

As provided for in Article 39 of License #2244, a joint study of minimum permissible releases into Lake Creek for maintenance of resident fisheries was jointly studied by the licensee, Washington Game Commission, Washington Department of Fisheries, Bureau of Commercial Fisheries, Bureau of Sport Fisheries and Wildlife and the U. S. Forest Service. As a result of this study, a Memorandum of Agreement was developed and signed on June 19, 1968 by all parties concerned and was forwarded through the Washington, D.C. office of the Forest Service to the Federal Power Commission. The Agreement provides for a minimum release of 3 cfs from Packwood Lake into Lake Creek during the period May 15 through September 15 of each year and a maximum release of 5 cfs in order to facilitate a flow of 15 cfs at the gauging station identified as "Lake Creek at Mouth". In addition, the Memorandum of Agreement provides that the licensee shall install and annually maintain stream improvements near the mouth of Lake Creek to enhance its use as a spawning channel. Arrangements have been made for the Department of Fisheries to provide access, design and supervise construction and maintenance by the licensee of this facility.

CONCLUSIONS OF REPORT

Lake Level Control

1. Lake level is being properly maintained, and inspection of the shoreline indicates no adverse effect to trees and vegetation due to Project operation.

2. Improved control of drop structure overtopping can be obtained by use of a rule curve that equates lake level with USGS snow course measurement.

3. Recreational use is inversely proportional to snowpack measurements in April and May.

Minimum Permissible Operating Level

The minimum permissible operating level of the lake should be lowered to 2849 foot msl because current minimum operating level of 2850.5 does not allow for the full eight foot drawdown during winter critical hydro periods originally approved but later changed in the amended license.

New USGS Gauging Facility

1. The revised formula for fishery bypass established by the November 7, 1967 Memorandum of Agreement requires a new permanent gauge in Lower Lake Creek to be operated by USGS at licensee’s expense.

2. Installation of new metering and instrumentation make former USGS wooden gaugehouse and clock driven gauge unnecessary and a duplicate facility which should be discontinued.

3. Discharge curves for the drop structure have been established and the Bureau of Commercial Fisheries and the Washington Department of Game have approved licensee’s request for removal of the temporary USGS gauge.

RECOMMENDATIONS

OF WPPSS

TO THE FEDERAL POWER COMMISSION

1. Adopt the Memorandum of Agreement dated November 2, 1967, signed by the U. S. Forest Service, Bureau of Sports Fisheries and Wildlife, Bureau of Commercial Fisheries, Washington Department of Fisheries, Washington Game Commission and the Washington Public Power Supply System and incorporate into License No. 2244.

2. Adopt a rule curve such as that proposed herein to minimize the hardship on the Project in obtaining the 2857 May 1 elevation in dry years and enhance the operating pool control during peak runoff periods of years of heavy flows.

3. Establish a minimum permissible operating level of not more than 2849 during the period September 16 through April 30 to provide the eight foot of drawdown used in the feasibility study and originally licensed.

4. Discontinue the need for duplicated USGS gauging facilities below the drop structure entitled "Lake Creek Near Packwood", now that the operating reliability of licensee's fishwater bypass metering and instrumentation is a matter of record. This could include a proviso that the licensee install a mechanical stop on the fish-water bypass release valve to assure minimum releases (if the assurance of a mechanical stop is desired).

PACKWOOD LAKE HYDROELECTRIC PROJECT

LAKE LEVEL CONTROL AND FISHWATER BYPASS RELEASES

A. Lake Level Control, Maximum-Minimum Pool Levels

Article 37 of the License for FPC Project No. 2244 provides the following:

"The licensee shall operate the Project so that the maximum operating pool shall be at elevation 2858.5 and the minimum operating pool shall be 2850.5. During the period each year between May 1st and September 15th, the licensee shall maintain the pool level at elevation 2857, except for conditions which may occur which are beyond the control of the licensee."

It was later agreed, in 1964, to allow fluctuations of the recreation season level between elevation 2856.5 and elevation 2857.5.

It should be noted that the drop structure (the "dam" at the lake outlet) height of 2858.5 feet and all other heights for lake control, as specified in the license, are actually established at levels 0.51 feet below what was considered for those levels at the time of license application and issuance. This was brought about by the survey performed at the time of project construction and the establishment of a new datum due to completion of accurate construction surveys. Therefore, based on the new datum (1964) the dam weir is at 2858.5 feet msl, and based on the datum at the time of consideration for the original and amended licenses the dam crest is at 2857.99 feet.

The only period in the six years of project operation that has caused observable distress to the lake's shoreline trees was during construction in 1964, and a full explanation of that experience was made in the "1965 Appraisal". Since that time, the project has been operating with the reliability of comparable units of its type with a forced outage rate well below one percent.

In November 1964, the Supply System expressed confidence that experience in the operation of the Packwood Lake Plant, with respect to lake level effects on trees, would be the best criteria for development of a mode of operation and/or intake modifications to secure justifiable lakeshore tree damage protection. Careful observation demonstrates that the lake today (September 1970) will show the shoreline conditions of the lake are essentially unchanged from 1965.

In the past five years the recreation season levels have been well maintained within license limits, except during periods of lake inflow of more than 300 cfs - the maximum capacity of the Project's turbine and fishwater release.

During the years 1965 through June 22, 1970, the history of overtopping the drop structure (2858.5 feet) during spring runoff is as follows:

TABLE I

Year	Period of Overtopping	Days	Average Depth Overcrest (Ft.)	Peak Inflow (cfs)
1965	None	None	--	--
1966	None	None	--	--
1967	6/20-6/28	8	0.31	--
1968	6/2-6/4	2	0.06	--
1969	5/13-5/15	3	0.16	390
1969	5/19-5/27	9	0.49	400
1969	5/31-6/13	14	0.40	350
1970	6/7-6/8	2	0.10	330

Total number of days of overtopping during the first six years of operation is 38 days. Exhibits 1-5 (see Appendix) show lake elevations during the recreation seasons 1965 through 1970.

The suggested modification in the weir can not be justified on the basis of the Supply System controlled maintenance from 1965 to present. As indicated above, the extent of the overtopping has never exceeded an average of one-half foot and never for a period of more than 14 days.

The following is a chronology of events which led to the present license provisions with respect to weir structure elevations and lake level control:

(1) The order issuing License #2244 in 1960 provided for an overflow weir outlet with 2-foot flash boards and a maximum lake elevation of 2858.5 feet and with a 60-foot drop structure crest. This concept included a road to the intake for flash board maintenance and the intake structure was located in the lake.

(2) In the application for license amendment in 1960, WPPSS requested substitution of an overflow weir with an ungated spillway with a crest of 65-feet in length, and with a maximum operating lake elevation of 2857.0, and a minimum operating level of 2849.0 feet. Subsequent requests by the Forest Service (Exhibit 4eletter) resulted in the construction of the drop structure having a crest of 85 feet in length and 2858.5 feet in elevation and with a minimum operating pool elevation of 2850.5 feet with a provision that during the period each year during May 1 and September 15, the licensee shall maintain the pool elevation of 2857 feet. This

latter provision has since been modified and interpreted so as to require the licensee to maintain lake elevations during the period May 1 and September 15 within plus or minus 6 inches of elevation 2857.0 feet. It should also be noted that elevation 2850.5 - 2858.5 for the drop structure was requested by the Forest Service and consented to by the Federal Power Commission.

There has never been any disagreement as to the above facts and the Supply System has always accepted these limitations as the basis for the understanding of all parties.

The economic feasibility of the Project was originally based on a drawdown of not less than 8 feet during the winter season. In setting the operating level at 2857.0, the Project suffers an economic detriment unless a winter drawdown to 2849 or below is permitted. This would restore the original eight foot operating drawdown.

As presently required by Article 37, the Project enters the critical energy period September 1 of each year with a recreation lake level of 2857. If the recreation level is 2857 then the minimum lake level during the winter should be not more than 2849 to provide the eight feet of drawdown. Lowering of the lake level to 2849 would be infrequent since maximum drawdown need be used only during critical power situations with normal winter levels being kept near 2854.0 feet, as they have been in the past.

B. Rule Curve Proposal and Justification

In the spring of 1965, the Supply System proposed rule curve operation for the Packwood Lake Project as a permanent measure to contain flood conditions during the spring runoff periods. A review was made by the U. S. Forest Service, the Washington State Game Commission and other interested agencies, and all parties agreed that the risk of flooding trees on the perimeter of the Lake for an extended period of time could not be tolerated. As a result the Supply System was requested by Forest Service letter dated May 27, 1965, to lower the Lake's operating level to 2851.0± .5 foot and hold it there until all danger of flooding from spring runoff had passed. By letter received in April 1966 the U. S. Forest Service approved the principal of rule curve operation for the 1966 season, and by letter from the Federal Power Commission on May 31, 1966, the Supply System was directed to:

(1) "Maintain lake level between elevations of 2851 and 2854, except for conditions which may occur beyond your control, until danger from flooding has passed."

(2) "Coordinate operation on a daily basis with local U. S. Forest Service office; particularly with respect to estimating potential runoff in the remaining snowpack with the objective of determining at the earliest practicable date when danger from flooding has passed."

(3) "Retain a competent fishery biologist as appropriate during the period for the purpose of comparing fish migration conditions from Packwood Lake into its tributaries at lake levels between elevations 2851 and 2854 with those at elevation 2857. Should the lake level be such as to appear to prevent passage of fish into the tributaries, you shall permit the lake level to rise or take other appropriate action to facilitate passage of fish upon approval of the Washington State Department of Game."

As can be seen in Exhibits 1 and 2, the lake level was maintained close to, or within, the levels of 2857.5 and 2856.5 during the subject recreation seasons of 1965 and 1966 with no overtopping of the drop structure, and this was made possible by the day to day observance of runoff and snowpack conditions as the spring weather of those years progressed. Predictions of runoff proved to be conservative as the runoffs fell below predictions and the 50-year average for both years. As a result of the normal runoff conditions in both 1965 and 1966, the application of rule curve operation has yet to be proven to any significant degree but still shows excellent promise.

Based on the Pigtail Peak (21C33) snow gauging station and the Packwood Lake (21C31) snow gauging station of April 1st, the predictions for May and June monthly average flows are accomplished by the following formulae:

May Historic Flow Curve Equation

Packwood L. snowcourse 21C31 cfs = (3.33 x inches moist.) + 100 Pigtail Pk. snowcourse 21C33 cfs = (0.56 x inches moist.) + 105

May Total Average cfs = April 1 (21C31 cfs + 21C33 cfs)
2

June Historic Flow Curve Equation

Packwood L. snowcourse 21C31 cfs = (4.74 x inches moist.) + 160 Pigtail Pk. snowcourse 21C33 cfs = (3.33 x inches moist.) + 0

June Total Average cfs = April 1 (21C31 cfs + 21C33 cfs)
2

The following table gives the predicted and actual results for the past seven years based on the above formulae.

TABLE 2

Comparison of Predicted vs Actual

Results 1963 – 1970

April 1 Inches of Snow Water			Runoff Cfs
	Gauge		May		June
	21C31	21C33	Predicted	Actual	Predicted	Actual
1963	1.0	40.0	115	121	149	162
1964	18.6	91.2	159	115	276	302
1965	13.9	68.5	145	127	226	186
1966	20.3	55.2	152	170	220	167
1967	14.2	70.2	146	146	231	278
1968	0	44.7	115	115	154	178
1969	19.4	68.7	154	242	240	255
1970	1.2	51.8	119	128	169	221
Average	11.1	61.3	138	145	208	219

Previous 50 Yr. Ave. 151.9 208.7

For implementation of a rule curve it is intended to keep the basic formula as simple as possible to avoid any possible misunderstanding of its use. The orders for its use are proposed as follows:

(1) Predictions of May and June flow averages based on snowcourse measurements at Packwood Lake (21C31) and Pigtail Peak (21C33) are to be made no later than April 15.

(2) Based on the predicted flows, the following lake levels should be considered for runoff control during the period May 1 to June 18:

(a) Maintain 2854-2855 lake levels when 110 percent or more of the 50-year average are predicted for either May or June.

(b) Maintain 2855-2856 lake levels when 91-109 percent of 50-year average are predicted for either May or June.

(c) Maintain May recreation season levels as in (b) above and 2857.0 ± 0.5 foot June 1 to June 18 when 90 per-cent or less of the 50-year average are predicted for May and June.

The Supply System's Packwood operator is to implement the rule curve on a weekly basis, coordinating such operation with the local U. S. Forest Service District Ranger, particularly with respect to estimating potential runoff in the remaining snowpack with the objective of determining at the earliest practicable date when danger from flooding has passed.

The 2854.0 level as a minimum is considered important to prevent exposing lake bottom or mud flat areas in the upper lake delta and creating a potential barrier to the spawning trout during the springtime of the year. Aesthetically, Packwood Lake remains a very attractive scene at this level as can be seen in attached photographs at levels lower than 2854.0.

1969 Rule Curve Operation

Commencement of the rule curve operation in mid-April 1969, when the lake level was at 2854.03, would have been an excellent time to apply this routine as predicted runoffs, based on the Pigtail Peak (21C33) gauging station and the Packwood Lake (21C31) gauging station of April 1st, indicated above average flows to the Lake for both May and June periods. An example of how 1969 lake levels would have been controlled for the 1969 recreation season is shown by Figure 1.

Since the April 1, 1969 snowcourse moisture measurements gave a prediction of 154 cfs for May and 240 cfs for June, the operator would maintain a level of 2854.0 - 2855.0 to be maintained from May 1 to June 18. A relatively light number of visitations to the Lake area were recorded for May, probably due to the above average snowpack at the Lake. No visitations were recorded for April or the first two weeks of May. (A comparison of snowpack-vs-May visitations will be discussed later in this report.) With no recorded visitations in the first half of May, any concern for aesthetics could have been reduced accordingly.

As can be seen on the 1969 Rule Curve-vs-Actual graph on Figure 1, overtopping of the Project's weir at 2858.5 would have been delayed by 10 days and a lower crest of 2858.95-vs-2859.21 would have been the case on May 24. By May 27, the rule curve operation and the operation without a rule curve have joined each other.

A total reduction of seven (7) days of overtopping could have been accomplished with use of the rule curve, despite the fact that May 1969 average flows were 155% of predicted. This was brought about by well above average temperatures in early May and heavy rainfall in late May. The average flow for June was only 106% of predicted, but 122% of 50-year average flows.

C. Recreation Use vs. Snowpack

In support of the lower lake levels in the early part of the recreation season, Table No. 3 provides snow depths at Packwood Lake snowcourse gauge (21C31) for April 1 and depths at Pigtail Peak gauge (21C33) for April 1 and May 1 as compared to recorded visitations.

TABLE 3

Packwood Lake – April & May

Visitation-vs-Snowpack

No. of Visitors					Depth of Snow

		April		May 1-21		Packwood Lake (21C31) April 1	Pigtail Peak (21C33)
							April 1	May 1
1964	0		9		59”		201”	206”
1965	39		151		30”		151”	131”
1966	78		162		46”		133”	106”
1967	96		175		38”		187”	187”
1968	88		233		0”		106”	123”
1969	0		77		45”		152”	152”
1970	57		244		3”		124”	N.A.

Comparing this table with the following "Survey of Registered Visitors to Packwood Lake from April 1962 to 1969", Table 4, will partly explain the cause of light visitation levels in April and May of some years vs other years.

As an example - 1968 showed zero inches of snow at Packwood Lake on April 1 and less than average depth at the Pigtail Peak snowcourse with a resulting high rate of visitations in April and May to the Lake area. On the other hand, 1969 had 45 inches of snow at Packwood Lake on April 1 and more than average depth at Pigtail Peak in early April and early May. As a result, the number of registered visitors were significantly reduced with more than 70% of the registered visitors not making an appearance at the Lake until the last week of May.

TABLE 4

SURVEY OF REGISTERED VISITORS TO PACKWOOD LAKE FROM APRIL 1962 TO 1970

YEAR	WEEK OF MONTH	APRIL		MAY		JUNE		JULY		AUG		SEPT		OCT		TOTAL FOR YEAR
1962	1 2 3 4		- - - -		- - 88 85		52 64 90 159		65 108 70 94		65 65 54 137		91 - - -		- - - -
1962	TOTAL		0		173		365		337		321		91		0		1,287
1963	1 2 3 4		- - - -		- 46 54 53		53 66 52 84		87 37 59 74		96 43 30 63		21 - - -		- - - -
1963	TOTAL		0		153		255		257		232		21		0		918
1964	1 2 3 4		- - - -		- - 9 76		56 96 67 135		164 160 121 200		100 79 94 109		81 23 - -		4 - - -
1964	TOTAL		0		85		354		645		382		104		4		1,574
1965	1 2 3 4		- - - 39		45 52 54 76		140 153 102 125		175 93 127 165		74 49 63 88		82 58 21 49		41 6 - -
1965	TOTAL		39		227		520		560		274		210		47		1,877
1966	1 2 3 4		- - 51 27		43 58 61 126		255 160 197 140		192 137 136 160		69 115 83 124		198 55 3 17		17 5 8 -
1966	TOTAL		78		288		752		625		391		273		30		2,437
1967	1 2 3 4		- - 63 33		25 71 79 343		177 249 167 235		150 135 172 155		126 102 132 75		- - - -		- - 3 -
1967	TOTAL		96		518		828		612		435		0		3		2,492
1968	1 2 3 4		- - 38 50		46 98 89 185		161 79 151 108		210 113 124 204		90 98 52 130		72 25 - -		- - - -
1968	TOTAL		88		418		499		651		370		97		0		2,123
1969	1 2 3 4		- - - -		- - 77 190		42 202 101 156		99 93 113 203		83 171 87 74		-N.A. -" -" -"		- - -
1969	TOTAL		0		267		501		508		415		100est		0		1,791
1970	1 2 3 4		- - - 57		62 85 97 198		134 186 129 178		147 132 167 152		163 132 170 97		90 N.A. " "		N.A. " " "
1970	TOTAL		57		442		627		598		562		250est		20est		2,556

D. Memorandum of Agreement - Article 39

The Supply System Memorandum of Agreement signed by WPPSS, Washington Game Commission, Washington Department of Fisheries, Bureau of Commercial Fisheries, Bureau of Sports Fishersies and Wildlife and the U. S. Forest Service specifies the following:

a. "During the entire year the licensee will release a minimum of 3 cfs from Packwood Lake to Lake Creek. During the period from May 15 to September 15 each year the licensee will release up to a maximum of 5 cfs in order to facilitate a flow of 15 cfs at the gauging station identified as "Lake Creek at Mouth".

b. In addition, the Agreement signed by all parties will require stream improvement work at the mouth of Lake Creek.

E. Fishwater Bypass Release Flow Measurement

By letters of June 27 and July 3, 1968, the Bureau of Commercial Fisheries and the Washington State Department of Game, respectively, approved request by the Washington Public Power Supply System for removal of the U. S. Geological Survey gauging station at "Lake Creek near Packwood Lake". The Forest Service, however, by letter of June 21, 1968, declined to agree to the gauge removal.

The purpose of the Supply System's request was then and remains now an attempt at cost savings by eliminating a redundant device which is costing the Supply System more than $1,650 per year. Cost of gauging services have increased approximately 30% since commencement of operations.

In order to be able to evaluate the reliability of the Supply System's gauging equipment a letter was written to the U. S. Geological Survey in October 17, 1968, describing the Licensee's gauging facilities and to report the performance record of the equipment. The following is part of the text of that report:

1. Description of WPPSS Fishwater Bypass Equipment & Metering

A 24" pipe bypasses the drop structure and is equipped with a 24" butterfly valve and a 24" flowmeter. This bypass line can be supplied from either one of the two 10 foot wide bays in the intake structure. The 24" flow control valve is a Henry Pratt Company Model R1A, rubber seat butterfly valve operated by an electric motor operated PGW limitorque (Type SMA operator). This limitorque operator is controlled from the powerhouse or can be manually controlled at the intake structure. The 24" flowmeter is a Type 906 Sparling meter mounted at the discharge of the bypass line. This meter is factory calibrated and installed under the supervision

of the Sparling Company. The meter transmitter operates a Type 219 panel mounted Sparling water control instrument at the powerhouse which records and indicates cfs flow and totalizes acre/foot total use. This Sparling meter includes adjustable high and low limit switches for alarm or automatic control.

2. Operational Reliability of Fishwater Release Metering

The 24" Sparling meter is designed for maximum flow of 20 cfs whereas the valve can release as much as 45 cfs. This overvelocity condition with the meter installed caused damage to the meter in 1965 requiring an outage to procure and reinstall the necessary new calibrated meter and transmitter. Since that time, WPPSS has prepared a procedure for manually moving the meter when flows exceed 20 cfs (for purposes of discharging excess runoff) and replacing it immediately thereafter. This corrective action has remedied the problems experienced in 1964 and 1965.

3. 24" Sparling Meter Outages

The record of outages for the fishwater release recorder for the period January 1966 to the present 2-1/2 years) is as follows:

a. April 11 - April 16, 1966 - meter was inoperative because project operator found it necessary to borrow a small synchronous drive motor on the recorder to use on the total plant flow Sparling meter (72"). Spare parts are now available in the WPPSS inventory.

b. May 9 - May 12, 1966 - Sparling meter was removed from service to allow release of 40+ cfs.

c. May 19 - June 1, 1967 - meter removed to allow release of 45 cfs during a period of excess runoff.

d. June 16 - July 6, 1967 - meter removed to allow release of 45 cfs during high flow period.

e. October 24 - November 3, 1967 - meter removed to allow release of 45 cfs during project maintenance shutdown.

f. February 8, 1969 - recorder out of order for 14-1/2 hours requiring meter repair.

g. May 21 - June 17, 1969 - removed from service to prevent meter damage during high release flows of 40+ cfs.

h. May 7, 1970 - meter was out of order for 4.75 hours.

From the above record it is evident that the 24" Sparling fish release meter has been in operation 94.9% of the time since January 1, 1966. The total outage rate is therefore 5.11%. The total forced outage rate is only 0.18% with the remainder due to the removal of the meter to pass larger releases through the valve.

The USGS clock-driven stream gauge is a highly reliable device and is well maintained. However, the present location of the gauge results in exposure to falling timber, freezing, vandalism, control section changes during high water as well as lack of access during bad winter weather conditions. The resulting outage rates due to these natural hazards would make an interesting comparison.

The desirability of removing the gauge "Lake Creek Near Packwood" can be summarized as follows:

The cost of maintaining this gauge averages approximately $1,650 per year which present worthed over the remaining license, with escalation and interest amounts to a cost of $80,000 to WPPSS. In addition, WPPSS has separate costs for protecting, repairing structural damage, and supplying power by cable to the gauging structure during the winter months to prevent freeze up.

The U. S. Geological Survey in its June 18, 1970 memorandum to the "Water-data Users" proposed discontinuance of data collection at the Diversion from Toats Coulee Creek and that the open flume gauging be replaced by pipeline with Sparling meter.

In a comparison made in 1967, a tabulation of daily flow records from WPPSS and USGS gauges was made. In addition to it being evident that the WPPSS meter read several percent higher than USGS, it was apparent that manual integration was used on the USGS flow readings. While not questioning the accuracy of the USGS flow readings, it was interesting to note that during a 190 day period there were approximately 40 readings of 4.8 and 5.0 cfs and none at 4.9 cfs. The USGS records also showed no daily flows of 4.4, 5.3, 5.5 and 5.7 cfs and very few 4.7 and 5.1 cfs readings.

For the period discussed, December 1, 1966 through May 31, 1967, the average monthly comparative records are as follows:

TABLE 5

Average Monthly Flow Cfs		Average Monthly Flow Cfs
Month	WPPSS	USGS
December	4.9	4.81
January	5.3	5.3
February	5.1	4.83
March	5.1	4.86
April	4.9	4.6
May	10.4	11.0

The operating reliability of the Licensee's 24 inch fishwater bypass release mechanism is a matter of record. While it may be desirable to continue operation of the Lake Creek gauge below the drop structure "Lake Creek Near Packwood" for a year or two to establish a calibration comparison between the USGS and Licensee gauges, there should be no reason nor justification for maintaining these duplicate gauges.

The most important factor concerning this gauging is to assure that the fishwater bypass release is never shut completely off due to control malfunction, vandalism or operator error. Maintaining duplicate gauging facilities would simply record such a contingency and not prevent it. Since this gauge furnishes records that only duplicate records taken by Licensee equipment and since the gauge could not prevent accidental shutting off of the fishwater bypass release, the unnecessary expense of maintaining this gauge should be discontinued.

The only positive and fail-safe method of assuring that there is never an accidental closure of the fishwater bypass release valve would be the installation of a mechanical stop in the valve stem mechanism which could be installed by the Licensee to the satisfaction of the USGS.

Packwood Lake Project EXHIBIT 1
Article 39 FPC License No. 2244

November 2, 1967

This Memorandum of Agreement results from a meeting of parties interested in fishwater releases and improvements on Lake Creek, Packwood Lake Hydroelectric Project, Federal Power Commission Project No. 2244, held at Packwood, Washington on September 25, 1967. At this meeting the parties reviewed the conditions at Lake Creek under various flows of releases from Packwood Lake.

The parties mutually agree on certain operating standards and other measures for the maintenance of Lake Creek flows.

To accomplish the provisions of Article 39 of FPC License 2244 and to set standards for the future operation of the Project, the parties mutually agree as follows:

1. During the entire year the licensee will release a minimum of 3 cfs from Packwood Lake to Lake Creek. During the period from May 15 to September 15 each year the licensee will release up to a maximum of 5 cfs in order to facilitate a flow of 15 cfs at the gaging station identified as "Lake Creek at Mouth."

2. The licensee shall install and annually maintain stream improvement near the mouth of Lake Creak. This stream improvement is illustrated by Attachment No. 1. The location of the improvement is just above its junction with the unnamed slough that connects with the Cowlitz River.

3. In June of each year, the stream improvement will be inspected by the licensee and the Washington Department of Fisheries to determine what repair, if any, is required to maintain the improvement. If repair is required, construction will be accomplished by WPPSS. Washington Department of Fisheries will arrange with property owners for access to the work.

4. WPPSS will maintain the entrance of the unnamed slough which joins the Cowlitz River with Lake Creek so that the combined flow of the slough in Lake Creek approximates 25 cfs below the confluence of Lake Creek and the unnamed slough. In the event that the Cowlitz River floods cause a major change in the topography of the confluence, the interested agencies will meet and agree upon a modification to these construction requirements for stream improvement.

Packwood Lake Project
Article 39 FPC License No. 2244

PACKWOOD LAKE RESORT
Packwood, Washington

September 22, 1970

S. K. Billingsley, Project Manager
Washington Public Power Supply System
P.O. Box 6510
130 Vista Way,
Kennewick, Washington 99336

Dear Mr. Billingsley: EXHIBIT 2

In answer to your letter of August 31, 1970, please let me apologize first for being so long in answering. I was somewhat concerned about the effect the lower lake levels might have on my facilities at Packwood Lake Resort and consequent results to the early spring business. However, subsequent conversations with you and with Mr. Bob Sandusky have further explained your proposal and convinced me that this would not adversely affect my activities.

I realize what a tremendous problem it is to cope with the fluctuating snow loads and wide weather variance that occurs in that area. I feel you have done a magnificent job of controlling the lake level during these early spring run-off months. I am aware of the constant surveillance you give to this situation.

Our season begins with the opening of fishing season--lowland lake--which is the middle of April. Normally, the snow is very nearly gone at that time and we have a full complement of hardy fishermen for opening day, despite the fact that they may be fishing in snow flurries. In 1969 the snow load was such that we could not open at all until mid-May.

Each year shows a significant increase in the use of the facilities, both at Packwood Lake Resort and at the public campgrounds on the lake shore. There is a definite increase in public interest in hiking, camping, and fishing, and Packwood Lake is an outstandingly beautiful area, completely unique in its isolation and available facilities. However, through the increased use, it is becoming apparent that the campgrounds are not adequate. The trails are more often than not blocked for long periods, it is a fine area for horse packing and there are absolutely no facilities for horses in the camping areas. The resort is badly in need of updating, cabins and main lodge. However, in view of the fact that, so far, I have not been able to obtain more than a yearly permit type of license for operating the resort, I don't feel I can invest the money it would take to make the improvements needed.

Let me take this opportunity to thank WPPSS for the fine and ever present cooperation I have had during my four seasons of operation. Everyone has shown personal interest and thoughtfulness. I am happy to cooperate to the fullest with your proposal for an adjustment to your present lake level requirements.

                                   Sincerely,

                                   Virginia L. Hunter
                                   Owner-Operator,
                                   Packwood Lake Resort
                                   4821 Kent-DesMoines Road
                                   Kent, Washington 98031
                                   UL 2-0135

DANIEL J. EVANS, GOVERNOR

EXHIBIT 3

WASHINGTON
STATE HIGHWAY COMMISSION
DEPARTMENT OF HIGHWAYS

OFFICE OF DISTRICT ENGINEER
4200 MAIN STREET
VANCOUVER, WASHINGTON

C

O

P

Y

December 23, 1969

U.S. Dept. of the Interior
Geological Survey – Water Resources Division
1305 Tacoma Avenue, South
Tacoma, Washington 99402

Attn: Mr. L.B. Laird Permit No. 5298
District Chief

Gentlemen:

Attached is your copy of the above-numbered permit which has been prepared in accordance with your application of recent date.

Kindly read the terms and conditions under which this permit is being granted and inform anyone employed by you of the provisions under which the work is to be performed.

Please be advised we are sending one (1) copy of this permit to the Washington Public Power Supply System for their records.

Very truly yours,

RLC:ran
RJP
encl.

cc: Wash. Public Power Supply System, P.O. Box 6510, 130 Vista Way,
     Mr. C. Wieland                           Kennewick, WA. 99336
     Headquarters int. (Olympia)
     Records Control

H.F. 12.03. S.F. No. 2004—OS—(Rev. 4-65)—4-65.

WASHINGTON
STATE HIGHWAY COMMISSION
DEPARTMENT OF HIGHWAYS

District No. 4 No. 5298
PERMIT

In accordance with RCW 47.32.160-180, and/or RCW 47.44.050 and amendments thereto, and subject to all the terms, conditions and provisions written or printed below or on any part of this form

PERMISSION IS HEREBY GRANTED TO      U.S. Geological Survey
                                1305 Tacoma Avenue South
                                Tacoma, Washington 98402

to construct, operate and maintain a streamflow gaging station, consisting of a 6'X6' water stage recording structure over a stilling well with a concrete weir to stabilize the stream channel. Also an overhead cable crossing to facilitate measuring the flow at high stages. The above to be located on the southerly side of SR-12 from 50' to 75' right of the westerly end of Lake Creek Bridge No. SR 12/276 opposite HRS 1018+34 in Government Lot 7, Section 11, Township 13 North, Range 9 East, W.M. in Lewis County, Washington.

All debris and/or surplus materials resulting from this installation shall be cleared from the highway right of way and the premises left in a condition satisfactory to the Department of Highways.

All work performed shall be in full compliance with the "Manual on Uniform Traffic Control Devices for Streets and Highways, and "Manual for Emergency Traffic Control for Protection of Men and Equipment".

The entire area within the State right of way shall be used for the streamflow gaging station and its appurtenances only and placing of other structures and/or facilities within this area will not be permitted.

No work shall be started until written approval has been received from the State Water Pollution Control Commission and the State Department of Fisheries.

No work shall be done under this permit until the party or parties to whom it is granted shall

have communicated with and received instructions from                                    C. Wieland
                                                                                                   Maintenance Superintendent
                                                                                                   Chehalis, Washington

This permit shall be void unless the work herein contemplated shall have been completed before

April 1 , 1970

Dated at Vancouver, Washington this 11 day of December , 1969

Planned Limited Access
FLS

EXHIBIT 4

ROOM 115, GENERAL ADMINISTRATION BUILDING • PHONE 753-6600
OLYMPIA, WASHINGTON 98501

October 30, 1970

Washington Public Power Supply System
Post Office Box 6510
130 Vista Way
Kennewick, Washington

Attention: Mr. Sam K. Billingsley

RE: Packwood Lake Hydroelectric Project - FPC #2244 - Lake Creek.

Gentlemen:

Reference is made to the Memorandum of Agreement of November 2, 1967, relating to the Packwood Lake Project, Article 39 FPC License No. 2244.

This Department considers that the articles set forth in the above noted memorandum are still functional as stated. The Department of Fisheries intends to contact the Washington Public Power Supply System in January 1971 to develop and start the processing of activity indicated in items #2 and #3 of the agreement. Compliance with these items will be considered as satisfying the fishery resource use of the described area relating to the mouth of Lake Creek.

Recent telephone contacts with your company assure us that the activities noted will be observed.

Very truly yours,

Thor C. Tollefson
Director

TCT:RBA:ljf

cc: Department of Game
     Bureau of Sport Fisheries & Wildlife-RBS
     Bureau of Commercial Fisheries-Portland
     Management & Research-Williams
     Patrol Division

WILLIAM F. ROYCE, Ph.D.
FISHERY RESEARCH BIOLOGIST
Director, Fisheries Research Institute
University of Washington
Seattle 5, Washington

EXHIBIT 5

January 14, 1965

Mr. Owen W. Hurd, Managing Director
Washington Public Power Supply System
P. O. Box 672
Kennewick, Washington

Dear Mr. Hurd:

This letter is a commentary on certain aspects of proposed changes in lake level and the drop structure at Packwood Lake. It has been prepared at the request of Mr. S. K. Billingsley. The comments will represent my professional opinions based on approximately 30 years experience with many diverse kinds of fishery investigations. I hold B.S. and Ph.D. degrees from Cornell University where I majored in Fisheries Biology. I have been the Director of the Fisheries Research Institute at the University of Washington since 1958. Prior to that time I was employed as a Fishery Research Biologist by the U. S. Bureau of Commercial Fisheries for 16 years with headquarters successively in Cambridge, Massachusetts, New Bedford, Massachusetts, Woods Hole, Massachusetts, Honolulu, Hawaii, and Juneau, Alaska. In Juneau, Alaska, I was Assistant Regional Director in charge of research. Prior to working for the Bureau of Commercial Fisheries I was employed by the Conservation Department of the State of New York and by Cornell University in investigations of trout and warm water fishes.

Effect of Opening Drop Structure to Permit Release of up to 300 cfs
During Flood Water Periods on Escape of Fish

The species of fish of concern in Packwood Lake is rainbow trout which has been resident there for many years. Substantial populations have existed because the lake is reported to have provided good angling and records of the Washington Department of Game show that as many as 3,021,000 eggs were taken artificially from the trout in Packwood Lake. This would mean that approximately 1,500 adult females were stripped. If we assume that these were accompanied by an equal number of males it would appear that spawning grounds in the lake tributaries supported at least 3,000 adult fish at the time these spawn-taking operations were under way.

These populations persisted in the lake despite the regular annual floods down the outlet creek. Within a few hundred yards of the lake the creek bed is so precipitous that no fish can migrate up to the lake. It seems clear that this stock of fish is non-migratory and did not tend to leave the lake under natural conditions in numbers which seriously reduce the populations. In my judgment, they would be no more apt to leave the lake through an opening in the drop structure.

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EXHIBIT 5

Effect of Submerged Trees on Fish Habitat

Unquestionably the dead trees which have fallen in the lake around the shores have benefited the fish. The tangle of limbs provides important habitat for young fish where they can escape from their larger relatives and the debris encourages the growth of fish food organisms. Somewhat similar brush shelters have been artificially provided in a number of lakes in order to enhance the environment for fish.

Effect of Reduced Lake Level During Spawning Season on Access to Spawning Streams

The rainbow trout ascend the tributary streams of Packwood Lake during May and June to spawn. During the spawn-taking operations which were conducted by the Washington Department of Game from 1933 to 1940 they were captured by weirs from 10 to 100 yards above the mouths of the streams. The State records show that during most of these years eyed eggs were shipped to other hatcheries from the Packwood station between June 12 and July 27. These probably had been held in the Packwood station for about one month before they were eyed and sturdy enough to ship, and hence it appears that the spawn-taking operations occurred from early May to the latter part of June which would correspond approximately to the spawning period.

The normal level of the lake has been considered to be about 2855 feet. The maximum high water attained under natural conditions was about 2858.5. Usually the lake was near its normal level during the first month of the year and then commonly rose to maxima during May, June and July. Then usually the level decreased with only occasional high water conditions during late autumn or early winter.

Under the conditions of operation by the licensee it is expected that lake level may be reduced to a minimum of 2850.5 during the fall and winter and I understand from Mr. Billingsley that during recent months the lake occasionally has been down to this level.

With low lake levels and flood water conditions in the streams it may be expected that the streams will cut channels down to lake level which are entirely comparable to the channels they occupy immediately above the highest water mark. One need look no further than at the intertidal channels of streams which empty into the ocean to see that this is almost always the case. It should be extremely simple to observe whether this is the case at Packwood Lake and in a remote chance that a stream is spread out in a fashion which makes it difficult for fish to ascend it should be simple to start a channel cutting through the stream delta in a few hours by one man with a hand shovel.

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EXHIBIT 5

I note further from the U.S.G.S. gauge records for the years 1960-63 that the minimum levels during May and June varied between 5.70 and 5.93 and the maxima between 6.88 and 7.68. Thus it was normal for the lake to vary in level during these two months between 1 and 1.7 feet.

In summary, I believe that it is highly unlikely that changes in lake level during May and June would in any way interfere with access to the spawning streams. If by remote chance it does it could be easily observed and easily corrected.

Sincerely yours,

/s/ William F. Royce
Consultant

WFR:ac

SUPPLEMENT TO JANUARY 14, 1965 LETTER REPORT

EXHIBIT 5

William F. Royce, Ph.D.
Fishery Research Biologist
August 6, 1965

EFFECT OF CHANGES IN LAKE LEVEL ON FISHING IN PACKWOOD LAKE

"Normal" lake level fluctuation: The changes in lake level recorded by the U. S. Geological survey through the years '60 through '63 show differences between annual maxima and minima ranging from 2.3 to 3.4 feet. The summer changes in lake level between May 1 and September 15 during these same years ranged from approximately 1.2 to 2.1 feet.

The "normal" elevation of the lake is not clear to me because of minor differences in the surveys. (The USGS quadrangle shows elevation 2867; about 10 feet more then recent surveys.) However, I would judge from the shoreline development that the seasonal average in lake level must have been in the neighborhood of 2856 to 2857 feet, as measured by the most recent surveys.

Prescribed operating levels: In the order amending the license of 28 February, 1962, the maximum operating elevation is prescribed as 2858.5, the minimum elevation as 2850.5. The summer (May 1 to September 15) operating elevation was prescribed as 2857 exactly, but this order was amended subsequently to allow fluctuation between 2856.5 and 2857.5.

Elevations since commencement of plant operation: During break-in period of the plant, water level rose to a peak of 2859.8 on June 6, 1964. A peak of 2860.5 was reached during extraordinary rains on January 30, 1965. The minimum operating elevation of 2850.5 was reached occasionally during the winter period between September 16, 1964 and April 30, 1965.

Summary of changes in lake level: It appears that the summer operating levels will fluctuate not more than one foot and therefore be somewhat less than the historical fluctuation which has ranged to at least 2.1 feet for the period

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EXHIBIT 5

May 1 to September 15. Annual fluctuations on the other hand, will range up to about 8 feet as opposed to historical fluctuations which have been at least 3.4 feet.

Fish populations in the lake: The one species of concern to all those interested in the recreational use of the lake is the rainbow trout. This species has been abundant in the lake for many years. The populations have been maintained by stocking but have been abundant enough in many years, also, to permit taking substantial numbers of eggs. Records from the Department of Game spanning the years 1933 to 1941, 1946 to 1947, and 1950 to 1951, show that annual egg take ranged from 405,000 to 3,021,000. This is a race of rainbows which spawns in May and June. Spawners were collected for egg taking in a number of the tributary streams.

Possible damage caused by fluctuation in lake level: The fears expressed by various people (none of which have been documented) are that changes in lake level may block access to spawning areas during low water in May and June. They cause a loss of feeding areas due to the lowered lake levels or a loss of natural food due to lowering of lake levels. The only concern about high lake levels might be about loss of fish over the drop structure during high water (the intake to the penstock has been screened).

Comments on possible damage: No positive information on damage can be developed until the changes in lake level are actually tried, but a number of considerations indicate that damage is likely to be extremely small.

A prime consideration is the steep slope of most of the lake shores, which results in small exposure or inundation as lake level changes. No pockets occur around the lake which would trap fish and dry up as lake level is lowered and the gradient is such that fish and fish food organisms need move only a few feet to maintain a shallow water habitat. The tributary streams which attract the spawners form beds through any exposed lakeshore area which will be entirely

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EXHIBIT 5

comparable to the beds above the lakeshore area in gradient and size of bed materials.

Perhaps the best evidence of negligible damage is the good fishing being experienced in July, 1965 after the highs and the lows of the preceding year. The concessionaire at the lake reported that fish were plentiful and appeared to be well fed. Anglers contacted on the lake at this time reported large and in some cases limit catches after only a few hours fishing. Examination of vegetation along lake shore revealed that the freshwater shrimp was abundant.

ANALYSIS AND RECOMMENDATIONS CONCERNING EFFECTS ON
SHORELINE VEGETATION FROM WATER SURFACE FLUCTUATIONS
AT PACKWOOD LAKE

EXHIBIT 6

                     by: Stanley P. Gessel
                           Professor, Forest Soils
                           Associate Dean, Research
                           College of Forestry
                           University of Washington
                           January, 1965

This statement is being written as a result of discussions with Mr. S. K. Billingsley and Mr. T. R. Malone of the staff of Washington Public Power Supply System, concerning Packwood Lake level fluctuations. I have read the Federal Power Commission's license application information and various statements by interested parties. I was also furnished data on lake levels and water flow from Packwood Lake.

In order to clarify the following discussion, I will first set forth my understanding of the problem under discussion. During the period of June to August, 1965, Packwood Lake was at levels higher than it had been for a considerable number of years. The high level was due to a combination of excess water supply from the heavy 1963-1964 snow pack and construction activities resulting in periods of plant inoperation.

As a result of the higher water levels, some trees surrounding the lake began to show certain signs of distress in the autumn of 1964. As the lake is not far from a wilderness area, any change in vegetation is a cause of public concern.

My purpose in making this statement is to attempt to clarify some of the arguments which have been advanced regarding the effect of change of water level and to propose a course of action which may lead to a solution of any conflicts. I offer these statements as a professional forester who has specialized in forest research and instruction at the University of Washington for the past 18 years. Opinions and facts regarding the effect of water levels on certain forest tree species are based on certain studies at Fern Lake, Lake Whatcom, and greenhouse growth experiments, as well as general field research in the growth of forest trees.

The effect of water immersion of forest trees is largely one of reducing oxygen supply to root systems and thus suffocating trees. It is, therefore, quite obvious that flooding effect is related to physiological condition of the tree and oxygen supply in the water as well as the ability of the tree to provide oxygen through certain root system morphology. Common coniferous species can grow very well in liquid nutrient solutions if the media is properly aerated. Similarly, most forest trees could grow in well aerated water for long periods of time if nutrient supply and aeration is adequate. Others can grow well because of root adaptation. Oregon ash is one example of a tree that can survive flooding.

In relationship to general growth and well being, forest trees carry on two opposing processes -- photosynthesis and respiration. Photosynthesis is concerned with food manufacture through energy capture while respiration is the use of energy for vital life processes. Both of these processes go on in any living tree but with distinct seasonal variation in rates. At one time photosynthesis may predominate while at another respiration may. Rates of both are,

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EXHIBIT 6

of course, controlled by environmental conditions along with certain species factors. Root systems must supply water and nutrients to the photosynthesizing and respiring plant. Proper oxygen supply is a vital factor in the root functions. The roots are in turn supplied with necessary energy for respiration as well as storage.

In addition to these vital processes, a tree also expands in height, diameter, and crown volume by a process of growth. This consists essentially of cell division and may be expressed in radial growth of a tree trunk, height growth of the stem, or elongation and development of new foliage in all parts of the crown. The roots, of course, also undergo similar growth processes.

Foresters commonly speak of growth then in the sense of height or diameter. In either case there is no direct relationship between these expressions of growth and photosynthetic activity. Growth, as we commonly refer to it, occurs at well defined times of the year, but the period of elongation and radial increase do not parallel each other. Radial increase begins early and extends later in the season than height growth for most species. Both expressions of growth normally take place in the months of May, June, July, August and September in western Washington.

On the other hand, photosynthesis may occur throughout the year, and frequently the greatest net photosynthesis does not take place in the commonly accepted growing season. Local environment factors of air humidity and temperature greatly affect photosynthesis. Respiration is a constantly occurring process but also at different rates depending upon environmental conditions.

Although we do not have many major native forest trees well adapted to high water tables, saturated soils or to long periods of inundation, they do show habitat preferences. Douglas fir, and true fir found at higher altitudes, generally do not grow well in soils which are subject to flooding or long periods of high water table. Western red cedar, red alder, cottonwood, and grand fir, along with Oregon ash are species which can adapt to more water and reduced aeration. Therefore, these latter species are normally found in depressions, on flood plains, and along stream or lake margins. However, they cannot stand long periods of summer flooding, especially with water deficient in oxygen. Because species such as alder and western red cedar are normally found along lake shores and stream deltas, it is only natural to observe that these are the species which may appear to suffer as a result of flooding. This does not mean that they are more susceptible to flooding but only that they usually occupy habitats which can be easily affected by high water.

Remarks which will now be made on the effect of root water environment on tree growth should be related to the preceding discussion. Points will be made in numerical sequence for easier reference.

1. Inundation of root systems of established trees by water of low oxygen content can definitely damage the trees and if continued for periods of one to three months will result in the death of the trees. All of our common forest tree species are susceptible to such injury but there are species differences. Douglas fir is more easily damaged then western hemlock or western red cedar. As far as I can determine, the shoreline of Packwood

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EXHIBIT 6

Lake is very steep, with the exceptions of inlet delta areas. This means that small changes in water level affects very little land surface and, therefore, relatively few trees and tree root systems. Specific data could be gathered at the time of a field trip to the lake.

2. The extent and severity of the injury is related to the season of inundation and thus, in turn, to other environmental factors and physiology of the tree. It is related to season because oxygen depletion of the water may be greater at one season than another. For example, when other biological activity in the water is at high level, oxygen use is also greater and oxygen content of the water may be lower. The physiological demands of the tree also differ by seasons.

3. Past experience and observations by the author, as well as the meager literature available, indicate that damage to trees by submersion of roots is greater during the active growth, or cell division period. This is probably because the physiological demands of the tree for proper root functions is greater; and, therefore, any reduction in root function is more serious. In other words, a Douglas fir tree can stand a foot of water over its root system for a longer period of time in January than July.

4. Healthy, vigorous trees which have their root systems covered by water do not show serious damaging effect immediately. Trees so covered during cell division periods of June and July may show signs of distress by September, but the true extent of the injury does not become apparent until the following high temperature season when water stress on the tree begins. Trees can go through periods of high humidity and little physiological activity without showing effects of severe stress or injury. Water demands brought on by high temperature and low humidity of a subsequent summer season rapidly indicates the true condition of a tree. Therefore, the true extent of injury brought on by immersion during one growing season will not usually show up until the next season. It is, therefore, difficult to judge which trees may have only minor injury and will recover and which ones may actually die. This has certainly been our experience at Fern Lake where the water level has been permanently raised.

5. It is not unnatural for lake levels to be materially changed by a variety of causes. Landslides, log jams, and beaver dams are some of the common examples. In a given set of circumstances one of these factors has been responsible for several inches to several feet change in lake levels. Flooded trees are killed and a new shoreline is established. One does not have to look far in the Cascade Mountains for many examples of this. In fact, change in level is more natural and normal than a rigidly maintained level. Packwood Lake has itself probably suffered such changes in levels over the past few hundred years. The Licensee notes that they removed a large log jam from the outlet in 1963, which in itself, could have been the cause of major fluctuations in lake level in preceding years.

With these points in mind, I would make the following recommendations:

1. I would suggest that if high water during the growing season of July and August is a factor in the life of trees around the shorelines of Packwood Lake, then

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EXHIBIT 6

water levels should be reduced in the period of April, May and June. The outflow could be based on the weighted rule curve of the lake. This procedure would allow excessively high runoff such as occurring in 1964 to be stored in the Lake, and thereby reduce root system flooding. The drawdown during this period would have to be consistent with fish propagation requirements.

2. I also believe a program of selectively removing trees around the lake margin which have been killed by high water or have died from any of the many other factors causing the death of forest trees should be initiated. This could be done in a manner which would not disturb the equilibrium of the lakeshore habitat. In this connection it should be remembered that dead trees are a normal component of any lakeshore. I note that over 100 dead trees were observed around the shoreline in both 1960 and 1963. Many of our mountain lakes have large numbers of trees which have died and fallen into the water, as well as standing snags. The standing dead trees add both to the interest of the shoreline, as well as provide a necessary habitat for many birds. Some material in the water, such as trees, also provides shelter for fish, as well as surface area for growth of organisms which serve as fish food. Therefore, I do not believe in the concept which dictates that all lakeshores be managed to give a park-like affect. Certainly open shorelines are not consistent with the wilderness ideal even though some people may object on an aesthetic basis.

3. Definite conclusions regarding the extent of injury, if any, to trees around the shoreline of Packwood Lake, by the 1964 high water, cannot be made until at least June of 1965. I, therefore, propose that an inspection trip, to the lake be planned for late June or July. I would plan to make such a trip. The trip would also serve to bring all interested parties together to discuss apparent management problems and agree on the best solutions. I certainly do not feel capable of offering more definite and realistic comments on this apparent problem until I have been able to visit the lake during the summer season.

/s/ STANLEY P. GESSEL

Stanley P. Gessel, Ph.D.

May Historic Flow Curve Equation

PACKWOOD LAKE SHORELINE

PACKWOOD LAKE