Shoreline and recreation management obligations present multiple challenges, ranging from interpretation issues to use/user and resource management conflicts. Public Utility District No. 2 of Grant County has navigated through these issues, using both shoreline management and recreation development standards and procedures.
By Kelly Larimer
Kelly Larimer, formerly the Lands & Recreation Manager with Grant County Public Utility District, is now senior licensing and regulatory consultant at Kleinschmidt Associates.
Shoreline and recreation management have, for the most part, been an ancillary management obligation for owners of hydroelectric projects operated under a Federal Energy Regulatory Commission license. Past practices under original FERC licenses were likely insufficient to manage recreation as these elements of a project license were not a priority and land use at projects, and consistent management for those uses, was absent. This past laissez-faire approach has resulted in significant management and compliance issues for licensees, especially as they enter into the stages of relicensing and new license implementation.
Over the years of original project licenses, many private landowners have assumed a claim on shoreline properties owned by licensees, which has resulted in cumulative effects including unauthorized development — such as homes, docks, outbuildings, grading, fill and landscape encroachments — and uncontrolled social gatherings and/or recreational uses. Many of these encroachments and uses, if left unaddressed, can pose risks to both the private parties and licensees.
Past management policies and procedures have been inconsistent, leaving private landowners, the public and agencies confused or upset about licensee business practices. Under licenses issued since the Electric Consumers Protection Act of 1986, hydro project owners are held to higher standards such as giving equal consideration to recreation, fish and wildlife resources, etc. to maintain control and management of shorelines for public recreation, habitat and cultural resources.
Shoreline and recreation management can be politically charged and controversial if standards and procedures are not in place. Flexibility and reasonableness must play a factor, and transparency and consistency are key attributes of success. Licensees must determine what is reasonable and how this should be defined. While tackling these issues is a difficult and sometimes costly task, licensees are stepping up to face private and public criticism and achieve better regulatory oversight. This article shares how Public Utility District No. 2 of Grant County, Washington (Grant PUD) has begun to address these issues.
Grant PUD owns and operates the 1,800-MW Priest Rapids Hydroelectric Project on the Columbia River in central Washington along the borders of six counties (Chelan, Douglas, Grant, Kittitas, Yakima and Benton). This project serves the electrical needs of the Grant County service area and the broader Pacific Northwest region (see Figure 1 on page 41).
The project consists of the 900-MW Wanapum and 855-MW Priest Rapids developments (both subject to turbine upgrades increasing the installed capacity). Both developments consist of reservoirs, power generating facilities, primary transmission lines, and other facilities and resources necessary to support and maintain project operations. The project boundary encompasses about 34,380 acres and is 58 miles long. The acreage of land contained within the project boundary outside the reservoirs is 12,909 acres and is owned by various entities. Grant PUD owns 4,619 acres.
Neither reservoir provides seasonal storage. Instead, hourly and daily flow modifications accommodate changing flows entering the project. Daily generation load cycles augment the flood control capacity of upstream reservoirs and balance power and non-power uses of the river, such as flows for salmon.
During the original 50-year license issued in November 1955, shoreline management and recreation development obligations were absent and/or limited in scope. Early efforts related to recreation and shoreline management were primarily focused on developing a man-made island called Crescent Bar, which was envisioned to be a destination public recreation site and potential point of commerce along the Columbia River. This area is owned by Grant PUD and was leased in 1962 to a port district, which developed the island by installing a boat launch, marina, campground, swim beach, utilities and golf course. The port later subleased the area to a developer who converted and expanded the public campground into private RV parks and constructed condominiums that were sold to private parties.
Other shoreline communities began to evolve beginning in the mid-1960s and have since developed into dense recreational areas with high-end homes and condominiums. Primary developments include the communities of Crescent Bar (off-island in addition to the island development), Sunland, Vantage and Desert Aire. At each of these locations, Grant PUD owns the shoreline in fee.
From a recreation management standpoint, Grant PUD never built or actively managed recreation facilities over the term of the original license. Grant PUD did however allow for the development of recreation facilities by local and state agencies and homeowner associations and provided some cost share on select upgrades. Grant PUD also provided seasonal labor to help clean undeveloped recreational properties, which are informal public access areas/no built facilities.
The Growth Management Act (Washington State land use planning act, intended to ensure comprehensive long-range planning) was adopted by Washington State in 1990, and in 1992 Grant PUD developed and adopted the Priest Rapids/Wanapum Land Use Plan (LUP) as a comprehensive management plan. The LUP performed as a document for managing project lands and was used largely to permit existing structures and landscaping after-the-fact. In 2000, Grant PUD determined that conditions and land management needs at the project had changed enough to warrant an update to the LUP and also began studies and public outreach to identify potential recreational needs under the term of a new operating license, which the PUD planned to file for.
Beginning in September 2000, Grant PUD reviewed the LUP to see where changes needed to be made and/or what components needed to be updated. Grant PUD stopped issuing permits for shoreline uses in 2001. The result of that review was a draft shoreline management plan (SMP) that was submitted to FERC in 2003 as part of Grant PUD’s relicensing application.
Over the term of the original license, very limited staffing (usually one person) was available for shoreline and recreation monitoring and management. Few corrective actions were conducted during the term of the license, and permits were issued without consistent standards.
In anticipation of a new license being issued, the Lands and Recreation Department staffed up beginning in 2007 and began preparing for finalization of the SMP and recreation resource management plan (RRMP).
|The 1,800-MW Priest Rapids Hydroelectric Project consists of two powerhouses on the Columbia River in central Washington.|
On April 17, 2008, FERC issued Grant PUD a 44-year license to operate the Priest Rapids Project. Articles within the license require specific and general resource management directives and identify the key stakeholders with whom Grant PUD is required to consult. License Article 419 required finalization of an SMP for the project. The SMP applies to lands and waters within the project boundary and assists Grant PUD in day-to-day management activities, as well as ensuring activities occurring on project lands are compliant with all applicable laws and regulations. The SMP was developed to guide and accomplish the following:
— Development and implementation of the resource management and recreation development plans required by the license;
— Decisions regarding requests for non-project use of Grant PUD-owned project lands and waters, as well as decisions that may be required by the terms of flowage easements on project lands and waters not owned by Grant PUD;
— Coordination efforts with other public entities to cooperatively manage publicly owned lands within and adjacent to the project consistent with common goals, objectives and license requirements; and
— Efforts to preserve, protect and enhance the environmental, scenic and recreational values of the project.
Availability of public access and use of project lands is a key component of this plan. Therefore, the SMP was developed in coordination with Grant PUD’s RRMP and other license requirements, including protection and enhancement of wildlife habitat, fisheries and cultural resources. The goals and policies in this SMP are intended to provide purpose, clarity and consistency related to these management objectives.
In its SMP, Grant PUD took a stronger policy stance regarding public benefit by not allowing non-exclusive use of project lands owned by Grant PUD. Grant PUD will review all authorizations, permits or use agreements issued prior to the license issuance date. If an existing use or activity is determined to be compliant and consistent with license provisions, a new land use authorization may be issued. Individual permits, authorizations and agreements may also be incorporated into a public recreation development plan (PRDP) within the public recreation development land use classification. This process is a collaborative planning effort that will result in a comprehensive plan within shoreline areas adjacent to denser residential developments. The goal is to balance private interests and enhance public access and use of these areas.
In the event Grant PUD determines an existing authorization is no longer consistent with the license provisions, management policies or PRDP, the authorization may be terminated. Grant PUD may also require the use be brought into compliance. Existing or past uses and/or activities occurring on Grant PUD-owned and managed lands do not carry forward any “grandfathering” rights beyond the term of the specific conveyance or authorization. Existing uses and/or activities that did not receive written authorization from Grant PUD will also be addressed during this process.
FERC approved Grant PUD’s SMP on April 18, 2013. Grant PUD is now preparing to implement the policies and procedures within and recognizes that building and maintaining positive relationships with private landowners, public agencies and tribes is essential to the success of shoreline management. Dedicated staff time to conduct outreach, education, monitoring and management is a core business objective.
When it issued the new operating license, FERC approved the Priest Rapids RRMP, filed in October 2003, as to the 23 recreation sites that would be located within the existing project boundary. In addition, six recreation monitoring sites are included in the requirements for periodic inspection and clean-up.
Implementation of the recreation requirements has been challenging, given tight deadlines and significant complexities in environmental and cultural resource management and project permitting on the Columbia River. Grant PUD has sought several license amendments modifying project scopes and deadlines and is challenged to accomplish all recreation capital projects by 2015, which is also the year the update to the RRMP is due.
To best develop a long-term vision and set standards, even under an intense capital development period, Grant PUD developed the following recreation programs to design, implement and manage numerous existing and new public recreation facilities.
Signage and visual guidelines program
In 2009, Grant PUD’s Lands and Recreation Department undertook the development of district-wide signage and visual guidelines. Past practices for signage consisted of random design and placement of signs to serve a variety of management, safety and educational functions. The result was inconsistent, confusing and in some areas dense signage pollution.
Under the new program, Grant PUD has inventoried, replaced and monitors all signs on project lands. The result has been extremely positive, and as new facilities come on-line, continuity and clarity regarding Grant PUD’s image and management objectives will continue to improve. Moreover, the design standards have translated to print materials, web design and other public outreach tools that promote consistent messaging.
Recreation site development program
Recreation site development guidelines serve as a reference document for developing standardized recreation sites at the Priest Rapids Project. These guidelines provide policy on design criteria and examples of recreation facility design details for use in the development of recreational sites. They are used in the planning and budgeting process and in reducing design costs, establishing standards, and providing consistent and compliant designs across the project.
When implementing required measures, Grant PUD uses the following design and siting criteria and other standards necessary to fulfill the recreation site development guidelines:
— Comply with public health and safety codes and regulations;
— Provide design continuity and consistency with the SMP goals;
— Provide high-quality experiences for visitors;
— Minimize facility and site deterioration and operation and maintenance costs associated with public use and exposure to environmental conditions; and
— Protect the natural and cultural environment.
Grant PUD uses these guidelines in the design and development of new recreation sites and the rehabilitation of existing facilities. These guidelines will be updated as designs, technology and materials are developed.
The following recreation site development objectives will guide recreational development planning to consistently support Grant PUD goals and policies:
— The PUD will meet the public recreation development requirements of its FERC license and RRMP, while ensuring natural and cultural resource protection measures are identified and considered.
— Recreation site development shall improve the user experience and/or enhance visitor convenience by increasing the availability (number) and accessibility of recreation sites in the project.
— Development shall be compatible with the environmental character in design and appearance while providing for reasonable public access and use.
— Recreation user expectations will be recognized. Recreation site development will give consideration to the understanding that people choose a setting for an activity in order to realize a desired set of experiences. Natural open space and the distinctive outdoor experience found on the project will blend with awareness that those seeking isolation, self-reliance and closeness to nature will desire a much lower level of development than those seeking a social experience, who desires the comforts of built facilities.
The recreation opportunity spectrum is a planning tool used to establish site planning and management objectives by understanding the environment and social experience desired for each setting. The site can then be designed with facilities consistent with those goals. Table 1on page 42 shows the characteristics that define the spectrum.
Without thoughtful consideration to recreation site planning, history has shown that incremental improvements to site access will lead to more intensive use and the demand for more developed services. Grant PUD will meet its recreation requirements in a cost-effective fashion, both in upfront capital costs and in realizing lower long-term operations and maintenance costs. Ultimately, Grant PUD will seek the greatest facility life cycle for the investment cost.
Recreation O&M program
The operations and maintenance (O&M) program and guidelines serve as a reference document for providing managed and maintained recreation facilities on the project. This document provides guidance on facility management, policy and procedures, maintenance, operations, and staffing.
The O&M program sets guidelines and frequencies for recreation facility management by detailing the conditions that constitute the minimum acceptable maintenance and full-service maintenance. These guidelines provide the necessary information to develop a fundamental maintenance and operational program that will maximize service life, minimize life-cycle expenditures and establish operational budgeting
The O&M program also addresses the necessary agreement that will allow Grant PUD to provide reasonable and safe public access to the project lands and waters. The PUD, its managing partners, and concessionaires will use these guidelines and agreements to help ensure consistent facility management and maintenance on the project as well as consistency with the license, SMP, RRMP and other plans as applicable.
Recreation monitoring program
In 2009, Grant PUD elected to develop a more robust recreation monitoring program to assist with license implementation efforts. The program purpose is to monitor and evaluate recreational use on the project in order to assist with site evaluations and management decisions regarding capital development and O&M needs. The program consists of the use of monitoring indicators and standards, defines monitoring needs, and identifies periodic monitoring and reporting responsibilities with GPS and GIS technologies as primary tools.
Use of visitor count forms to account for land-based recreation, boat density surveys, traffic counters, visitor contact surveys, and recreation impact monitoring studies are conducted every year. Most monitoring focuses on the recreation season (May to September), however expansion to year-round monitoring has been recently deployed in anticipation of the next FERC Form 80 report.
Interpretation and education program
Grant PUD has interpretive signage and outreach requirements, ranging from information on the history of Ice Age floods to hydro history to fisheries. Grant PUD has elected to make this an important aspect of recreation management and participates in numerous outreach events including Archeology Days, the county fair, public meetings, shoreline clean-ups, presentations to local service clubs, field trips and many other functions.
These outreach and interpretive signage/material opportunities are gaining momentum and popularity, thus advancing several management goals for Grant PUD related to natural and cultural history, protection of resources, and safe recreation on project lands and waters.
Grant PUD has faced and will continue to face challenging opportunities in shoreline and recreation management. Lessons learned from past experiences are being addressed in thoughtful ways, and these aspects of license implementation are becoming more standardized and consistent.
Key elements of program success include, but are not limited to:
— Addressing past deficiencies or shortfalls in a fair and consistent manner;
— Development and implementation of clear, reasonable policies and standards to address current and new development and activities;
— Development of clear communication and education materials;
— Dedication of time and resources to proactively perform public outreach;
— Development and implementation of a good shoreline and recreation monitoring program; and
— Concerted business dedication to ensure the appropriate amount of staff and technical resources are available to accomplish these tasks.
Grant PUD has made great strides toward improving its shoreline and recreation management goals and has gone above and beyond to set a vision. Implementation of key goals and objectives will ultimately improve public relations, protect and enhance important environmental resources, maximize capital investments, reduce long-term O&M, and provide a safe and high-quality experience for the recreating public while respecting private property rights.