November 27, 1964

F. Stewart Brown, Chief
Bureau of Power
Federal Power Commission
Washington 25, D. C.

Subject: PACKWOOD LAKE PROJECT – 2244
Supplement to our letter - 11/9/64

Dear Mr. Brown:

This letter is intended to supplement our letter of November 9, 1964 on the above referenced subject. Specifically, its purpose is two-fold; to correct certain inaccuracies and misimpressions contained in the Forest Service letter of August 16, 1964; and to present to you certain additional information which should be considered before a final conclusion is reached concerning the necessity of a by pass facility at Packwood. I appreciate very much the time you took in discussing these matters over the phone last Wednesday. During our conversation you stated that it was very probable the staff would meet soon to discuss Packwood matters and we therefore feel that this letter offering additional clarification of the facts is timely and appropriate.

The Forest Service letter of August 26, 1964, undoubtedly plays a large part in the whole problem, and accordingly, deserves thorough discussion. the Forest Service letter makes two general contentions; first, that the design of the project was changed without Forest Service knowledge, to the detriment of Forest Service interests, and secondly, that the Licensee will be unable to comply with Article 37 of the amended License, pertaining to operating pool elevations. We submit that both of these contentions are wrong.

After describing - correctly - the original design of the Packwood Spillway Structure, the Forest Service states:

"When the Amended License was issued and after work on the project was started, the permanent spillway crest was raised from 2857.0 to 2858.5 and the flashboards eliminated. The Department of Agriculture was not consulted on this change, nor given opportunity to comment on the compatibility of the change with National Forest purposes."

The Forest Service clearly implies that WPPSS somehow "slipped by" the Forest Service the present design of the Packwood spillway, and that WPPSS should therefore make amends by redesigning the spillway, or installing a diversion structure.

The facts are these: Exhibit H of the WPPSS application for license dated March 20, 1959 requested lake level limits of 2858.5 (maximum) and 2850.5 (minimum), this request was granted. This application also proposed a weir at the outlet of Packwood Lake which would include hinged flash boards supported on struts which would fail at a predetermined water height. The proposed weir had a crest width of 60¢. After continued study of the hydraulic and geological characteristics of the Labs and Intake area, and the impact this construction would require, the licensee revised the design of the Intake Works by deleting the weir and flashbboards at the outlet of Packwood Lake and requested approval of a combined over-flow and Intake Structure in the Lake Creek channel downstream from the outlet of the Packwood Lake. In the application for amendment No. 1 dated December, 1960, the overflow structure was described as "Ungated spillway with a crest width of 65 feet.........." (Underlining added.) The exhibits and drawings submitted as part of the Application for Amendment deleted all mention of flash boards and requested approval for lowering the maximum operating level to 2857.0 and the minimum operating level to 2849.0.

The Forest Service was completely aware of the proposed elimination of the flash boards and the change in pool elevation. This is perfectly clear from the Forest Service's "4(e)" letter to the Commission dated February 12, 1961. This letter shows that the Forest Service received the application for amendment and related exhibits.

In this letter, the Forest Service made no criticism whatsoever, of the basic change in design. It did however, object strenuously to the lowering of the pool elevation limits by exactly 1.5 feet. In accordance with these objections, pool elevation limits were sot as requested by the Forest Service, as found in Article 37 of the Amended License. In short, the forest Service itself set the present elevations, against the wishes of the Supply System. At the same time, the Forest Service made no intimation whatsoever that it objected to the change in design.

Moreover, by letter of October 16, 1961, WPPSS transmitted to the FPC new drawings which again showed that the flash boards had been eliminated. The drawings changed the dam with the ungated spillway, proposed in the amended license application and having a width of 65 feet, for the present drop structure design, with a width of 85 feet and consequent improvement in water overflow characteristics.

This letter of October 16 states:

"These drawings are being submitted at this time for information purposes only, with the request that they be submitted to the various state sad federal agencies for comment."

Also, as indicated in that letter, copies of these drawings were sent directly by WPPSS to the Forest Supervisor of the Gifford Pinchot National Forest in Vancouver, Washington, in order to expedite review at the local level.

These drawings showed the top of the drop structure at 2857 feet. By letter of February 26, 1963, WPPSS was instructed by the Commission Staff to put the top of the drop structure at 2858.5, in accordance with Article 37 of the amended license. This was done.

Another major change in the application for amendment was the deletion of permanent access by road to the Project head works. This change requited substantial modification to the design of both Intake and Overflow Structures as that they could be operated and maintained by personnel on foot without any vehicular access whatsoever. (see Exhibit L. drawings dated March 20, 1959) The new requirement that the Project headworks be isolated except by foot, (or "totegoat") and almost inaccessible, particularly during periods of heavy winter snowfall, required the use of an overflow structure requiring minimum maintenance and devoid of usual screens and gates in order to fulfill the reliability requirements at a remote location without vehicular access. It must be emphasized that it was Forest Service requirements which led to this deletion of the permanent access road, in order to preserve the semi-wilderness state of the area.

In summary, the Forest Service was kept fully informed at all stages concerning the change in design which resulted in the elimination of the flash boards.

For further detail on those matters, we invite your attention to a letter from WPPSS to Mr. Ross Williams, Forest Supervisor of the Gifford Pinchott National Forest dated November 17, 1964 and enclosed herewith.

We turn now to matters discussed in the second paragraph of page 2 of the Forest Service letter, relating to lake levels since May 1, 1964.

We are enclosing a graph which shows the flows for the period discussed in the Forest Service letter. It will be noted from this chart that the 1964 spring runoff flows were unusually heavy. The duration during which water overtopped the drop structure ant to approximately 36 days, as compared to approximately 11 days for the 44 year average flow in Lake Creek. The average flow is June and July of 1964 amounted to 153.2 per cent of the 44 year average flow for June and July.

It must be emphasized that the design of the drop structure, as approved by the FPC, clearly contemplated that during period of excess or unusual flows such as have occurred this year, there would be spillage over the drop structure. The basic concept was simply to replace the natural stream-bed of Lake Creek with a structure having essentially the same characteristics. This is exactly what has been done.

The Forest Service letter states on page 2, in the last paragraph:

"The Licensee is unable to operate at one hundred percent capacity for sustained periods because transmission line facilities are inadequate."

The letter then goes on to state that this results in inability to control the lake level.

The fact is that WPPSS can operate and has operated the plant for sustained periods at a point between 95 and 100 percent of the rated machine capacity. If you desire, we will send records which will confirm this fact. Actually, for short periods we have operated the plan in excess of the full rating.

It is true that a transmission line has not been constructed by WPPSS. We will discuss this matter with you shortly in a separate letter. However, here we wish to note that the transmission line being used presently for the plant is owned by Lewis County P.U.D., and under agreement with the PUD, WPPSS can use the capacity of this line from the Packwood Substation to the BPA Morton Substation. This line is sufficient to allow operation at full rated plant capacity for sustained periods. Existing transmission facilities are not a limitation to the maximum utilization of the plant for lake level regulation.

One other statement in the Forest Service letter should not go unchallenged in the fourth paragraph of page 2, it is stated:

"The Licensee appears unconcerned with the outstanding aesthetic resource Article 37 was designed to protect. At the meeting (of July 9, 1964, referred to in this paragraph) the Licensee suggested that removal of all trees around the perimeter of the Lake would not hurt or impair the beauty of the area."

We have in fact never made any such suggestion. At the meeting of July 9, we asked Forest Service officials whether or not they had considered the possibility of selective removal and disposal of any water-killed trees around the shoreline. Mr. Austin of your San Francisco office was present at this meeting, and can confirm our statements in this matter. At no time have we ever suggested the possibility of simply denuding the area on the margin of Packwood Lake.

In this regard, we note that Article 10 of the License provides that the Licenses will "prior to impounding water clear all lands in the bottoms and margins of reservoirs up to the high-water level." Further, at a conference with Forest Service representatives on November 13, 1961, these representatives stated that the natural high water level for Packwood Lake had been established by Forest Service studies to be 2859.01 feet.

Precisely because of our interest in cooperating with the Forest Service in preserving the aesthetics values of Packwood Lake, we have done no clearing on the shoreline, but have suggested, as at the conference of July 9, the possibility of selective removal of trees killed naturally or by project operation.

We now come to the key question raised by the Forest Service letter. Is the Packwood Plant, as presently designed, able to be operated in compliance with Article 37? We submit that it is. Admittedly, the possibility exists that there will be flood conditions, including flash floods, during which water will over-top the drop structure. If this possibility is to be completely eliminated, the drop structure would have to be completely redesigned to provide for by-passing 1400 cfs record flow. We submit that such a result was not intended by the FPC in approving the present design of the plant and in issuing Article 37.

Design and operating requirements were intended which would provide a reasonable assurance that the aesthetic interests of the Forest Service would be preserved, i.e., that there would be no appreciable kill or removal of trees above the level of 2857 feet, due to project operation.

In order to demonstrate to you that such an assurance does exist, and to provide you with the basis of coming to a proper final decision, we feel that answers should be obtained to the following questions:

1. What are the flood frequency characteristics of Packwood Lake and Lake Creek?

2. What is the probability of plant shutdown of varying durations, especially during the "photo" period in the summer?

3. On the basis of the answers to questions 1 and 2 above, what is the probability of appreciable tree damage (a) without the by-pass facility proposed, and (b) with the by-pass facility proposed?

4. In the light of the answer to question 3, above, what would be the aesthetic impact upon the perimeter of the lake of selective removal of trees which may in the future die because of either natural causes or project operations?

5. What is the cost of the proposed by-pass facility, and when would be a reasonable schedule for installation?

6. What impact would a by-pass for emergency lake level control have on the escapement of resident lake fish?

7. What improvement in overflow characteristics could be obtained by operating in the Spring in accordance with a rule curve agreed upon by the Forest Service and/or FPC to absorb anticipated runoff?

8. What would be the advisability of reverting back to the originally proposed operating levels of 2849 minimum and 2857 maximum?

We would be most happy to furnish you with answers to the above questions, and with whatever studies by WPPSS staff or by independent consultants you may wish in order to provide the basis for these answers.

Very truly yours,

OWEN W. HURD
Managing Director

OWH:ph

Enclosures as stated

cc: Boyd Austin + encl.