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Does SSI have a position on the proposed Centennial Dam? Yes: Follow the Data.

Ms. Kara Hellige
U.S. Army Corps of Engineers
1325 J Street, Room 1350
Sacramento, CA 95814-2922

Re: Comments on the Notice of Intent to Prepare a Draft Environmental Impact Statement for the Centennial Reservoir Project

Dear Ms. Hellige:

The following comments are submitted on behalf of Sierra Streams Institute regarding the United States Army Corps of Engineers’ (Corps) Notice of Intent (NOI) to prepare a Draft Environmental Impact Statement (DEIS) for the Centennial Reservoir Project.

Sierra Streams Institute (SSI) has over 20 years on-the-ground experience in comprehensive local watershed monitoring and assessment; community-based education and citizen-science stewardship practices; and multi-faceted collaborations with government agencies, utility and water providers including Nevada Irrigation District (NID), land trusts, tribes, universities, nonprofits, farmers, and landowners. Our track record of science-based research leadership and recent completion of an updated Bear River Watershed Disturbance Inventory and Draft Bear Watershed Restoration Plan (available online at https://drive.google.com/drive/folders/0B41PFmjcAZs-VUN5LTA2RWhNZEU) in collaboration with many Bear Watershed Stakeholders, uniquely positions SSI to submit the following comments in response to the Corps’ NOI regarding NID’s proposed Centennial Dam project. SSI is currently in the process of completing additional studies in the Bear River Watershed. Preliminary results of these studies are referred to within this letter and the final data results will be made publicly available upon completion of the studies (anticipated completion date is September 2017). As part of the Environmental Review process, we urge the Corps to consider the following requests for information and further project analysis.

The Corps is tasked with determining whether or not the proposed project complies with the U.S. Environmental Protection Agency’s (EPA) 404(b)(1) guidelines,[1] including determining whether it is the least environmentally damaging practicable alternative (LEDPA) to achieve the project’s purpose. We affirm that to fully understand both the benefits and impacts of the proposed project there is a need for a thorough, scientifically rigorous review of the full scope and complexity of the proposed dam’s potential environmental impacts. These impacts may extend beyond the proposed project footprint, downstream through the Delta through issues of flows and water quality, upstream and in adjacent watersheds if other water conveyance systems would be affected by the proposed reservoir’s operations, and laterally through issues of upland habitat connectivity and movement of protected, special-status and invasive species. We request that the scale of the DEIS analysis reflect the full scale of potential project impacts, both within and far outside the proposed construction and reservoir footprints.

Further, the NOI declares that “NID’s stated purpose for the Proposed Action is to provide drought and climate change mitigation, meet projected future water supply needs, and improve water supply reliability for NID’s customers.” The DEIS should discuss all practical alternatives that would address the Proposed Action outlined by NID and investigate the environmental impacts of these alternatives in order to inform which actions will be the least environmentally damaging. Measureable project objectives should be outlined for the proposed project and each alternative in order to provide the public and decision-makers a mechanism to assess how each alternative fulfills the project purpose and compares to the proposed action. Given this proposed project’s potential for significant impacts, we also request that a scientifically rigorous, quantitative, and thorough analysis be published that describes in detail:

  1. how the region’s current water supplies are being used;
  2. a range of how those uses may change in the future under a variety of potential development or no-development scenarios and with various water use and conservation options among the current community of NID subscribers;
  3. a detailed analysis of all relevant and reasonable mitigation measures for the proposed project including cost, locations, feasibility and impacts/benefits; and
  4. a thorough evaluation of all alternatives to meet the region’s water use needs, including those proposed by the public, implemented in other model watersheds, and/or suggested by the published scientific literature. We request a full disclosure, scientific analysis, and public discourse on supply-side and demand-side alternatives that includes but is not limited to projects within NID’s purview of water storage and conveyance systems.

The following bullet points are questions about potential impacts, mitigation, and alternatives that we request be addressed within the Environmental Review process and DEIS document. This list is not exhaustive, and we request that all other questions from the potentially affected community also be addressed. We further request that the information presented and publications referenced in the above-mentioned 2016 Bear River Watershed Disturbance Inventory be considered in the DEIS as they relate to the proposed project, as well as any additional relevant science publications.

Hydrology/Water Quality

Water Storage

  1. Climate change exacerbated California’s drought conditions, with the 5-year drought creating circumstances that classified most of the state in Severe Drought (D2) to Exceptional Drought (D4) conditions[2]. With the Bear River Watershed classified as Severe Drought to Extreme Drought (D3) in 2015, it is at risk for future impacts from continued drought conditions as a result of climate change. Further, using data from the National Water Information System (NWIS), it was determined that on average, over a twelve year period, the Bear River receives approximately 60% of Upper Watershed Yuba River Water via the Drum Canal. The DEIS must include a thorough study of the latest climate change science and the impacts those changes will likely have on the Yuba and Bear watersheds, and water storage.
    1. How will water be managed and during the next drought cycle?
    2. How do high resolution climate models predict flows and what are possible changes in flows at the watershed scale?
    3. Do current climate models support the filling of current reservoirs, as well as new ones?
    4. How may “temperature drought”[3] affect water availability and watershed yield?
    5. Currently, Yuba water diversions are regulated by the FERC Drum-Spaulding Project permit. Will the Yuba River continue to be able to supply the Bear River with enough water to fully utilize the proposed reservoir? Will the proposed project demand increased water supply during the next FERC relicensing cycle to maintain utilization in the future?
    6. Are alternatives available that would be less affected by climate change impacts?
  2. The water supply needs of NID’s current customer base were adequately met with the existing storage and supply system during the recent extreme and prolonged drought. NID has also published an analysis that demonstrates that they have adequate storage and supply for anticipated human needs through 2030.
    1. The DEIS should include a Water Availability Analysis that demonstrates whether there is a need for the new storage facility based on the existing and projected future use of current NID subscribers.
    2. The Water Availability Analysis should separately delineate projected future water use associated with projected regional population growth. It should also document whether there are sufficient water resources available to support that growth, and where that water would come from.
    3. Would the proposed project induce additional population growth, and is there enough water to sustain the anticipated growth that this project may induce? Is that regional growth potential appropriate given the region’s available water and other resources?
  3. The DEIS should address fully possible new pipelines and water conveyance features (current and future) associated with the project.
    1. How would Wolf Creek and its associated watershed be affected by the pipeline from South Wolf Creek to the proposed reservoir, as mapped in the project description?

Flows

  1. How would water releases from the proposed reservoir be managed? This question applies to the timing, volume and temperature of peak, on-demand, and other releases, and to times without releases or with limited releases due to water storage.
    1. The DEIS should outline the proposed water release schedule and how this altered timing and magnitude of water flow may affect downstream hydrology and downstream water beneficial uses.
    2. How would flow and temperature requirements be met downstream to support critical fish and wildlife habitat and other beneficial uses, especially during times of limited water availability?
    3. What are the impacts of peak and on-demand flows on wildlife, fish, vegetation, habitat, and water quality?
    4. What are the impacts of potential reductions in flow on wildlife, fish, vegetation, habitat, and water quality?
    5. How would downstream flows be cumulatively affected by the addition of the proposed reservoir to the existing reservoir system on the Bear River? How would these cumulative effects impact wildlife, fish, vegetation, habitat, and water quality?
  2. How would flows in the Yuba River and Wolf Creek watersheds be affected downstream of the water diversions that would fill the proposed reservoir?
    1. How would wildlife, fish, vegetation, habitat, and water quality be affected by potential changes to flows in the Yuba River and Wolf Creek watersheds?

Sediment

  1. Have sedimentation studies been done to determine sediment transport rates and how much sediment would be stored in the reservoir?
    1. What is the anticipated longevity of the proposed reservoir, and how is storage anticipated to vary over time?
    2. In 2013, dredging operations (to remove sediment) in Combie Reservoir (owned and operated by NID) were halted because of high mercury levels found in dredge effluents, “affecting NID efforts to maintain reservoir storage capacity, and potentially affecting NID’s ability to supply drinking water to its customers.”[4] Would the proposed project have the same issues affecting its capacity?
      1. How would this problem in storage capacity reduction be addressed safely and effectively in the proposed reservoir?
    3. In addition to sediment issues on Combie Reservoir, NID has an approved Sediment Removal project on Rollins Reservoir[5]. How does NID plan to reduce sediment from entering the proposed reservoir?
      1. How could upper watershed erosion control, forest health, and riparian habitat restoration projects (in both the Bear and Yuba watersheds, since both contribute to the Bear reservoir system) potentially assist in reducing the future quantities of sediment entering the current reservoir system and/or the proposed reservoir?
      2. How could upper watershed (both Bear and Yuba) gravel and sediment containment projects in and around the historical hydraulic diggings potentially assist in reducing the future quantities of sediment entering the current reservoir system and/or the proposed reservoir?
  • If such projects could protect the capacity of the current reservoir system, could such projects affect the need for the proposed additional reservoir?
  1. The proposed reservoir would itself result in the loss of bank-stabilizing riparian and oak woodland vegetation on its steep slopes. How would erosion of these slopes affect the sedimentation rates and capacity of the proposed reservoir?
    1. How would the proposed reservoir be managed to reduce erosion from its banks and associated sedimentation?
    2. How would erosion within the proposed reservoir’s footprint affect the sedimentation rates and capacity of the existing reservoirs downstream (Combie and Camp Far West)?
    3. How would erosion within the proposed reservoir’s footprint affect the sedimentation rates, sediment composition, and benthic habitat quality of the Bear River downstream?
  2. How would the benthic composition of fine sediments and gravels be affected in downstream channels as a result of the reservoir?
    1. How does the altered availability and composition of sediment types (and/or transport capacity) affect instream habitat availability and/or suitability for aquatic organisms?

Water Quality

  1. There are multiple reaches within the Bear watershed currently that are 303(d) listed under the Clean Water Act. This includes 21 miles of the lower Bear River, below Camp Far West Reservoir, listed for mercury, copper, and pesticide use; 23 miles of Wolf Creek and 2 miles of French Ravine, listed for fecal coliform; and all three major reservoirs, Camp Far West, Rollins, and Lake Combie, listed for mercury[6]. More information on the 303(d) listing and TMDL development process, as well as pesticide use and mercury contamination in the watershed, can be found in the Bear River Watershed Disturbance Inventory and Existing Conditions Assessment. In 2016, SSI with funding from the US Bureau of Reclamation launched a Water Quality Monitoring Program in order to establish a current dataset reflective of the water quality in the Bear River Watershed. The detailed report of the 2016 results is available online at https://drive.google.com/drive/folders/0B41PFmjcAZs-VUN5LTA2RWhNZEU. How would the proposed project affect downstream water quality and aquatic beneficial uses?
    1. Does the project have potential to lead to violations of any water quality requirements, including temperature, dissolved oxygen, pH, heavy metal, fecal coliform or other contaminants?
    2. How would water quality be impacted during construction?
    3. Has potential toxicity of summer low flows been evaluated and addressed, including high pH, low dissolved oxygen, increased water temperature, and potential to increase toxic cyanobacteria and algal blooms? This has been a problem at other reservoirs such as Upper Klamath Lake and in the Klamath Watershed.
    4. How would the proposed reservoir affect downstream water quality and aquatic beneficial uses when considered cumulatively with the current water quality problems present in the Bear River Watershed?
  2. What measures are in place to ensure water quality requirements are not violated, both short and long term?
    1. How will these potentials be adequately addressed given the lack of confidence on the amount of water actually flowing through the reservoir, due to climate variation?
  3. As mentioned above, all three major reservoirs on the Bear River, Camp Far West, Rollins, and Lake Combie, are currently 303(d) listed for mercury. Additionally, downstream waterbodies, including the Sacramento San Joaquin Delta and San Francisco Bay, are 303(d) listed for mercury,[7] and tributaries like the Bear River account for 57% of the Delta’s MeHg load.[8] What are specific methods or technologies that would be employed to handle, treat and remove mercury and prevent methyl-mercury in the proposed reservoir and downstream?
    1. Bear River reservoirs are known to have some of highest levels of mercury in fish tissue in the entire watershed. In 1999, the USGS looked at mercury concentrations in fish tissues from reservoirs within the Yuba and Bear River watersheds.  The maximum mercury concentration found in fish tissue was found in reservoirs in the Bear River Watershed (2 ppm wet wt (equivalent to 1.2 mg/kg)at Lake Combie reservoir (Largemouth bass) and was 1.5 ppm wet wt (1.5 mg/kg) at Camp Far West reservoir (Spotted Bass))[9]. Additionally, Lake Combie has problems meeting downstream discharge requirements because mercury has gotten into the water column. Will the proposed project have the same issues?
    2. How would mercury methylation in the proposed reservoir be mitigated, especially with steep reservoir slopes and fill capacity variability in the reservoir, which may affect methylation rates?
    3. What are possible downstream effects of increased mercury pulses during water releases?
    4. One study suggests that water management in reservoirs can affect mercury methylation rates,[10] which are affected by pH, temperature, salinity, sediment particle size, rate of sediment deposition, and more.[11] The DEIS should outline the intended management practices for the proposed project. Management practices should be addressed for both the short and long terms, under a variety of climate scenarios and regional water use scenarios. Management practices should be reviewed and the permit should require the least environmentally damaging practices, including practices designed to minimize mercury methylation rates and mercury impacts within the proposed reservoir and downstream.
  4. How would additional heavy metals known to be present in the Bear River Watershed upstream of the proposed reservoir, including cadmium, copper, arsenic, lead, and nickel affect the water quality of the proposed reservoir?
    1. Are there additional contaminants that should be tested for?
    2. What are the current heavy metal concentrations in the soils within the proposed project footprint, and how would reservoir-associated erosion of those slopes affect future heavy metal concentrations of the water column and sediment, both within the proposed reservoir itself and downstream?
    3. How would the proposed reservoir’s management affect the transportation of heavy metals into waterways downstream?
      1. How would the timing, volume, and other aspects of water releases be managed to minimize downstream contamination?
    4. How does the proposed reservoir location compare to other regional or statewide water sources in terms of heavy metal contaminants?
      1. Is this the safest watershed from which to be supplying water for irrigation and other human uses?
      2. Is this the best watershed for locating additional future development which may be induced by the proposed reservoir?
    5. How does this project affect NID’s ability to meet Central Valley Basin Plan requirements and water quality objectives?
      1. How will this be addressed with climate variables?

Wetlands

  1. ECORP’s lidar-based map of wetlands in NID’s 404 permit application only denotes 0.9 acres as “creek” and denotes 20.4 acres as “drainage.” Their distinction between these two wetland types is inadequately addressed. During wildlife field surveys within the proposed inundation zone, we have found at least four bodies of water, including Campbell Creek, that we consider to be creeks based on the year-round presence of flowing water, the presence of hydrophytic plants, and habitat use by aquatic and riparian wildlife. Until formal wetland delineations are performed, we propose that a higher acreage of creeks be considered for purposes of the DEIS. We also propose that a higher acreage of creeks that provide wildlife habitat be considered for purposes of Streambed Alteration assessments and mitigation associated with Section 1602 of the California Fish and Game Code.
    1. We request a Jurisdictional Determination from the USACE regarding the presence and classification of Waters of the United States within the proposed project boundary, per the Corps of Engineers Wetlands Delineation Manual and the Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region.
    2. How will the presence of extended drought be taken into consideration during the formal delineation of wetlands and other waters of the U.S.?
    3. The DEIS should include the final wetland mitigation plan determined in coordination with NID and the Corps as well as include all scientific data, analysis, and reporting documents for public review.

Groundwater

  1. How will the project affect groundwater storage above and below the proposed reservoir?
  2. The lower Bear River Watershed has two groundwater subbasins (S. Yuba Basin #5-21.61 and N. American Basin #5-21.64) specified in the Sustainable Groundwater Management Act (SGMA) (one high and one medium priority). This Act requires the formation of a Groundwater Sustainability Agency (GSA) as well as the creation of a Groundwater Sustainability Plan (GSP) for each high and medium priority subbasin.
    1. The DEIS should examine the impacts on groundwater this project may have on priority subbasins.
    2. The DEIS must quantify the extent to which the proposed project will affect rates of recharge to groundwater aquifers.

General

  1. How would the water quality aspects of the proposed project affect human health, wildlife, and aquatic life?
  2. What are all possible cumulative impacts on hydrology and water quality, including downstream beneficial uses?

Terrestrial and Aquatic Biological Resources

Fish

  1. Previous Bear River Watershed studies, including those associated with the recent FERC relicensing of the Yuba Bear Drum Spaulding project, have documented a robust mixed native fishery of rainbow trout, pike minnow, Sacramento sucker, and other species within the upper and middle Bear River watersheds, while the existing reservoirs on the Bear River are dominated by non-native fish species. How much cold-water riverine habitat for native fish would be converted to warm-water reservoir habitat for non-native fish within the proposed project footprint, and how much cold-water habitat quality would be compromised downstream?
    1. What would be the impacts to native fish such as rainbow trout?
    2. Given that the most common reservoir fish such as bass are high accumulators of mercury, what would be the effects on the health of human fishermen and wildlife such as eagles and osprey in the area if their diet were to consist of a larger portion of higher-mercury reservoir bass and a lesser portion of lower-mercury river trout?
  2. What are detailed mitigation measures for the loss of this highly valuable and limited riverine habitat?
  3. The National Marine Fisheries Service (NMFS) has approved a 4(d) list monitoring project of Bear River salmon below Camp Far West reservoir, and the autumn 2016 data are available from Joel Passovoy at HDR Engineering, Inc. Additional monitoring is planned for 2017. In addition, juvenile salmon have recently been observed in Dry Creek (a tributary of the lower Bear River) at Beale Air Force Base, and future salmon recovery goals, science and habitat potential in Dry Creek and the lower Bear River are being discussed by NMFS, US Fish and Wildlife Service, and other stakeholders through FERC relicensing of the Camp Far West reservoir, which is located downstream of the proposed project. In 2016, USFWS completed a study of Dry Creek habitat suitability for salmon and proposed a project to remove small fish migration barriers in Dry Creek to increase the number of salmonids able to utilize the stream. How would downstream habitat and salmon populations be affected by the proposed reservoir?
    1. How would potential project-related changes in water temperature and flows affect the ability of adult or juvenile salmon to move upstream from the Lower Bear River into Dry Creek and/or to use the Lower Bear River itself for spawning or rearing?
    2. How would potential project-related changes in Lower Bear River flows affect the ability of juvenile salmon and steelhead kelts to migrate downstream to the ocean?
  4. Currently, NID water is diverted into Dry Creek. Would this project have any effect on these water deliveries?
    1. If so, what effects might those changes have on salmon populations and habitat in Dry Creek?
    2. What effects might those changes have on other native fish populations and biodiversity in Dry Creek?
  5. The 2016 Bear River Watershed Water Quality Monitoring Results (available online at https://drive.google.com/drive/folders/0B41PFmjcAZs-VUN5LTA2RWhNZEU) showed numerous exceedances of the California Regional Water Quality Control Board (CRWQCB) water quality objective for dissolved oxygen at one Lower Bear River site that is located downstream of the proposed project and within the area that must be traversed by salmon and other fish species in order to access Dry Creek. . Additionally, numerous instream temperature readings at this site were higher than the ideal maximum for sustaining healthy salmonid populations.
    1. Would the proposed project exacerbate these downstream water quality issues? How would flow, oxygen and temperature requirements be met downstream to support critical fish and wildlife habitat, especially during limited water availability?
    2. The DEIS should include an analysis of how the proposed project will address existing water temperature issues for salmonids in the lower watershed.
  6. What are the impacts of sediment and large woody debris-starved flows downstream on aquatic insects and fish, including salmon and native trout?
  7. What are the possible effects of increased water temperature downstream of the proposed project on non-native warm-water fish such as large-mouth bass?
    1. How could potential project-related changes to downstream non-native fish populations affect native fish, their food sources and benthic macroinvertebrates?
  8. What are possible effects of decreased water quality on native fish and their food sources and habitat?
  9. The DEIS should conduct an analysis of potential project mitigation opportunities including but not limited to Dry Creek and Auburn Ravine.
  10. What are all possible cumulative impacts on fish?

Wildlife/Plants

A full environmental analysis for all special-status species, movement corridors, and sensitive natural communities, including potential habitat suitability and cumulative impacts, must be performed. Potential downstream impacts to flows and water quality in the Bear River that may be associated with reservoir management, peak and on-demand water releases, and water holding must be fully addressed in addition to impacts to the proposed inundation zone. These downstream effects have the potential to cause additional impacts to biological resources, species and natural communities. Potential impacts to biological resources associated with the proposed reservoir’s source waters in the Yuba River Watershed and the proposed pipeline from South Wolf Creek must also be addressed if the proposed reservoir would affect the quantity and/or timing of flows from these waterways and could affect species and natural communities in the Yuba River and Wolf Creek watersheds downstream of the water diversions.

  1. Is there sufficient area, connectivity, and quality of mitigation habitat available in these watersheds and is it feasible to protect and restore additional habitat adequately to fully mitigate potential project impacts?
    1. Where are the potential mitigations sites “in the vicinity of the proposed project, including (the) large contiguous tracts of land in the American and Bear River watersheds that are situated at elevations similar to the project site and that have similar habitat attributes to the project” mentioned in NID’s Wetlands Application to the USACE?
    2. Explain the details of the “functional analysis (which) will be conducted to determine the mitigation value of lacustrine habitat of the new reservoir to compensate for the loss of riverine habitat” mentioned in NID’s Wetlands Application to the USACE?
    3. Explain how replacing a less biodiverse lacustrine water body “lacustrine” would provide similar function and value as a richly biodiverse riverine and riparian system?
  2. What is the current status of, and possible impact on, rare plants and habitats within and surrounding the project study area?
  3. 20 rare or endangered plant species have potential to be found in the project area according to the California Natural Diversity Database surrounding 9-quad search. Impacts to these species or their habitat must be analyzed during preparation of environmental documents relating to CEQA and NEPA, or those considered to be functionally equivalent to CEQA and NEPA. See plant species list is available online at https://drive.google.com/drive/folders/0B41PFmjcAZs-VUN5LTA2RWhNZEU.
  4. An additional 14 plant species are significant locally, are of limited distribution, or infrequent throughout a broader area in California. We highly recommend that California Rare Plant Rank 4 plants be evaluated for impact significance during preparation of environmental documents relating to CEQA and NEPA, in addition to Ranks 1, 2 and 3.
  5. Eighteen Natural Vegetation Types State-rRanked as rare, uncommon or threatened (GS 1-3), have high potential to be present within the proposed project area (online file at https://drive.google.com/drive/folders/0B41PFmjcAZs-VUN5LTA2RWhNZEU or access full information online at: https://www.wildlife.ca.gov/Data/VegCAMP/Natural-Communities/Background#codes). One purpose of the vegetation classification is to assist in determining the level of rarity and imperilment of vegetation types. Ranking of alliances according to their degree of imperilment (as measured by rarity, trends, and threats) follows NatureServe’s Heritage Methodology, in which all alliances are listed with a G (global) and S (state) rank. For alliances with State ranks of S1-S3, all associations within them are also considered to be highly imperiled.

1 = Critically imperiled because of extreme rarity or because it is somehow especially vulnerable to extinction or extirpation, typically with 5 or fewer occurrences.

2 = Imperiled because of rarity or because other factors demonstrably make it very vulnerable to extinction (extirpation), typically with 6-20 occurrences.

3 = Rare, uncommon or threatened, but not immediately imperiled, typically with 21-100 occurrences.

4 = Not rare and apparently secure, but with cause for long-term concern, usually with more than 100 occurrences.

5 = Demonstrably widespread, abundant, and secure

Potential impacts to these natural vegetation communities should be fully addressed in the DEIS.

  1. Thorough and timely botanical surveys on all RkD – Rescue-Rock outcrop complex soils should be completed because of the high probably of identifying rare plants species within this soil type. The DEIS should report survey methods, site conditions and species found.
  2. The rare plant list in the DEIR’s NOP was incomplete.
  3. What is the current status of, and possible impact on, rare wildlife species within and surrounding the project study area?
    1. Nearly 70 wildlife species within the Bear River Watershed are of special conservation concern. See Disturbance Inventory available online at https://drive.google.com/open?id=0B9mS0Bj1fCWKU1pBLWgtTDllVEEfor more information. The majority of these species are listed as Threatened, Endangered, or Candidate species by ESA and/or CESA, and/or listed by CDFW as Fully Protected Species and/or California Species of Special Concern. Impacts to these species and/or their habitat must be analyzed during preparation of environmental documents relating to CEQA and NEPA.
    2. For a proposed project of this size and scope, we also highly recommend that additional categories of special-status wildlife be evaluated for impact significance during preparation of environmental documents relating to CEQA and NEPA. These include species listed as Birds of Conservation Concern by USFWS; Sensitive by BLM, USFS, and/or CDF; Watch List by CDFW and/or NABCI; Priority Species by the Western Bat Working Group; and/or Red List pollinator species tracked by the Xerces Society.
  4. Among this larger list of species with potential to occur in the project study area, several special-status species have been explicitly documented within the proposed inundation zone by CNDDB, and additional documentation for these and previously undocumented special-status species has been provided by Sierra Streams Institute surveys of the Bear River Watershed in 2016-17. What measures will be taken to ensure that the Bear River populations of these species are not extirpated?
    1. Motion-triggered wildlife camera surveys conducted February-May 2017 by Sierra Streams Institute documented ringtails (Bassariscus astutus) within the oak woodlands of the proposed inundation zone. Ringtails are a Fully Protected species under the California Fish and Game Code.
    2. Bear River Watershed herpetological surveys conducted by Sierra Streams Institute in spring/summer 2016 documented foothill yellow-legged frogs (Rana boylii) within the proposed inundation zone. This species has also been documented within the proposed inundation zone by CNDDB. Foothill yellow-legged frogs are listed as Species of Special Concern by the California Department of Fish and Wildlife.
    3. Bear River Watershed avian point count surveys conducted by Sierra Streams Institute in spring/summer 2016 documented yellow-breasted chats (Icteria virens) and yellow warblers (Setophaga petechia) in riparian habitats along the Bear River within the project study area. Both of these birds are listed as Species of Special Concern by the California Department of Fish and Wildlife, and yellow warblers are additionally listed by the US Fish and Wildlife Service as a Bird of Conservation Concern.
    4. Bear River Watershed herpetological surveys conducted by Sierra Streams Institute in spring/summer 2016 documented western pond turtles (Emys marmorata) upstream of the proposed project area, the CNDDB has documented this species elsewhere within the Bear River Watershed, and this species has potential to occur within the proposed inundation zone. This species’ status is currently under review by USFWS due to its petition for listing under the federal Endangered Species Act. It is also listed as a Species of Special Concern by the state of California and Sensitive by the BLM and USFS.
    5. A botanical survey was conducted by the local Redbud chapter of the California Native Plant Society in April 2017 in a portion the Bear River Campground, which is located within the proposed inundation zone. Among the diverse plant species assemblage, abundant elderberry shrubs were documented, including many that were over 1.0 inch in diameter and which thus constitute potential habitat for the valley elderberry longhorn beetle (Desmocerus californicus dimorphus), listed as a Threatened species under the federal Endangered Species Act. The beetle itself has also been documented by CNDDB as present near the proposed project area, in a tributary to the Bear River within the middle Bear River Watershed, and has potential to occur within the 6 miles of riparian habitat and associated uplands within the proposed inundation zone.
    6. Although surveys for California black rails (Laterallus jamaicensis coturniculus) have not been performed within the project study area, several occurrences of this species have been documented elsewhere in the Bear Watershed by CNDDB, and a winter 2017 reconnaissance-level survey within the proposed inundation zone suggests that potentially suitable floodplain wetland habitat for this species may occur in at least one of the private parcels proposed for project-related seizure through eminent domain. Black rails are listed as Threatened under the California Endangered Species Act, Fully Protected under the California Fish and Game Code, and Bird of Conservation Concern by the US Fish and Wildlife Service.
  5. These species, and many other species lacking their special status, are dependent upon riparian and/or oak woodland habitats and have undergone drastic range reductions, localized extirpations, and substantial population declines in California as a direct result of riparian and/or oak woodland habitat loss. How would the proposed project’s loss of 6 miles of habitat affect these species on a region-wide or state-wide scale, when considered cumulatively with the historical loss of 90-95% of riparian habitats within California’s Central Valley and associated foothills, significant statewide loss of oak woodland habitats, and additional cumulative impacts associated with climate change?
  6. Although the afore-mentioned surveys and CNDDB have reliably documented the presence and/or potential of these species to occur within the proposed project area, these surveys are nonetheless very limited in scope and the majority of the proposed project area has not been surveyed. What level of detail and geographic extent will be included in the surveys associated with the DEIS? Will studies be designed to determine population size so that appropriate mitigation efforts can be made?
  7. Additional species such as special-status bats have not yet been surveyed for within the proposed project area. Limited past survey effort resulted in the omission of ringtails from the CNDDB list of species present within the USGS 7.5-minute quadrangles encompassing the proposed project area, although they have newly been documented (see above). What other species may have been overlooked due to the limitations of survey effort to date? Will surveys associated with the DEIS adequately cover the entire 6 miles of habitat proposed for inundation in order to ensure that no present species remain undetected and to ensure that appropriate mitigation measures are implemented for all affected species?
  8. In addition to special-status species, what is the current status of, and possible impact on, riparian and floodplain sensitive natural communities within and surrounding the project study area? Specifically, how can over 6 river miles of riparian habitat and the additional mileage of tributary creek riparian habitat be mitigated?
  9. Studies of oak woodlands indicate as many as 29 amphibian and reptile species, 57 bird species, and 10 mammal species find this mature habitat community suitable or optimum for breeding (DFG 1988), and are utilized by nearly a hundred species of birds. What is the current status of, and possible impact on, blue oak woodlands within and surrounding the project study area? How can 6 miles of oak woodland habitat loss be mitigated?
  10. What is the current status of, and possible impact, on heritage trees, which require consideration under tree preservation ordinances, within and surrounding the project study area?
  11. Downstream of the proposed reservoir, additional special-status riparian and wetland-associated species may be affected by any changes to downstream flows that may result from the proposed project. Giant garter snakes (Thamnophis gigas), listed as Threatened under the federal and state Endangered Species Acts, and tricolored blackbirds (Agelaius tricolor), listed as a Candidate for Endangered status under the California Endangered Species Act, are two examples of these that have been documented downstream by CNDDB, and additional species may occur as downstream surveys have not been exhaustive. How would the proposed reservoir be managed to minimize impacts to these and other downstream species, and how will these potential impacts be analyzed in the DEIS?
  12. Riparian zones are naturally extremely dynamic, reflecting river flows that vary seasonally across years (Trush et al. 2000). Occasional floods provide powerful agents of erosion and deposition and can immediately have dramatic impacts on aquatic and riparian zones. Floods often enable bursts of recruitment by riparian plants and some other biota and thus, the initial “destruction” may be followed by ecosystem rejuvenation, a sequence of events consistent with the flood pulse concept[12],[13] . For riparian special-status plants and wildlife, and the riparian sensitive natural community, what potential project impacts may occur downstream of the project area due to potential changes in flows and water quality?
  13. Freshwater wetlands are considered one of the habitats more sensitive to change in hydrology and climate change since change in precipitation, evaporation, and evapotranspiration are likely to affect groundwater levels. Even minor fluctuations in water availability can affect the suitability of habitat for some wetland plants[14]. For wetland-associated special-status plants and wildlife, and the wetland sensitive natural community, what potential project impacts may occur downstream of the project area due to potential changes in flows and water quality?
  14. How would invasive species potential be affected for both plants and animals, within the proposed reservoir, in disturbed soils along its banks, or elsewhere via its associated water conveyance systems?
    1. Spring 2016 sampling by Sierra Streams Institute documented chytrid fungus within the upper Bear River Watershed, and numerous invasive plant data from other sources are discussed in the Disturbance Inventory (available online at https://drive.google.com/open?id=0B9mS0Bj1fCWKU1pBLWgtTDllVEE). Invasive mollusks have also been documented in neighboring watersheds.
    2. The DEIS should evaluate a district-wide management strategy and define the quarantine and control measures that will be taken to prevent invasive species establishment such as the New Zealand mud snail, quagga and zebra mussel, Asian clam, chytrid fungus, and various invasive aquatic and terrestrial plants.
  15. Where most of the middle Bear River Watershed is developed and fragmented, the location of the proposed reservoir provides optimal habitat connectivity, wildlife migration and movement corridors, and supports regional conservation goals. The watershed-wide parcel map shown in the Bear River Watershed Disturbance Inventory (available online at https://drive.google.com/open?id=0B9mS0Bj1fCWKU1pBLWgtTDllVEE) illustrates this, as larger undeveloped parcels align the river corridor, providing upslope-downslope movement potential through riparian habitat and oak woodlands in an region otherwise much more fragmented and developed. The middle Bear River itself and its associated tributary creeks are also currently crossable by many wildlife species, at least outside of peak flow times, and this crossing would likely be less feasible across a 110,000 acre-foot reservoir. Impacts to wildlife movement in the proposed project area may also be amplified by the cumulative effects of the existing Rollins and Combie reservoirs located immediately upstream and downstream of the proposed reservoir. As proposed, this project would effectively cut off wildlife corridor potential in the middle Bear.
    1. How will this be mitigated?
    2. How does this affect regional conservation plans?
  16. What are the impacts of peak and on-demand flows on wildlife, vegetation and habitat downstream?
  17. An evaluation of the special-status species in the Yuba River Watershed downstream of the water diversions related to this project is important. Potential impacts to biological resources downstream of these diversions should be analyzed in the DEIS.
    1. How would the proposed project be managed to minimize these potential impacts, including cumulative impacts, and with consideration of climate change?
  18. Additionally, an evaluation should be performed regarding the special-status species in the Wolf Creek Watershed that may be affected by the pipeline to the proposed reservoir, as mapped in the project description. Potential impacts to biological resources downstream of this diversion should be analyzed in the DEIS.
    1. How would the proposed project be managed to minimize these potential impacts, including cumulative impacts, and with consideration of climate change?
  19. What are all possible cumulative effects on plants, wildlife, movement corridors, and sensitive natural communities?

Tribal Cultural Resources

Three Native American tribes have historically lived within the project study area. The Auburn United Indian Community has current federal recognition. Two additional Nisenan tribes, the Nevada City Rancheria and the Todd Valley/Colfax Consolidated Tribe, lost their federal recognition but continue to practice their traditions, are in the process of petitioning for their past federal recognition to be reinstated, and have received local recognition from the Nevada County Historical Society, in addition to actively living their culture in daily life.

Prehistorical cultural resources such as grinding rocks; living cultural resources such as medicinal, ceremonial and utilitarian gathering plants; and sacred sites such as burning grounds are present in the portion of the Bear River that would be inundated by the proposed project. These cultural resources continue to be used on a regular basis by members of the local Nisenan tribes and play a vital role in their livelihood.

  1. We believe strongly that all three local Native American tribes should be consulted throughout all phases of the proposed project.
  2. The preservation of tribal cultural resources and the culturally significant ecological landscape should be considered in the DEIS in relation to all three tribes with ties to the project area.

Gold Rush Historical Resources

  1. Historically significant features from the mining era, such as the old lime kiln near the camp ground, and other important cultural and historical sites noted in FERC relicensing, should be protected.

Land Use/Planning

Zoning and general plans

  1. Will there be changes in zoning designations? If so how will balance be maintained between open space, extractive use and growth, on a local and regional level?
  2. How will this project affect local plans, policies, or ordinances?
    1. How could plans policies or ordinances decrease need for water, and thus project?
  3. How many acres of low density residential, agricultural and forestry lands will be lost?
  4. What is the anticipated potential population growth resulting from this project?
  5. What are potential impacts on other watersheds, or other parts of the Bear watershed as a result of this project?
    1. As outlined in question 2, the Bear River is supplied by diverted Yuba River water. The DEIS should outline any changes in the amount or timing of water diverted from the Yuba River.
    2. The DEIS should define how the proposed project may impact the South Sutter Water District, Camp Far West Reservoir, State Water Project (SWP), Central Valley Project (CVP), and Folsom Reservoir.
    3. The DEIS should investigate how the proposed project may impact Delta inflow and outflow.
  6. With the location and large parcel sizes, the project area is an extremely important piece for land use planning and connecting open space, greenbelts, and wildlife corridors. There is very limited opportunity to protect these large tracts of conservation lands. The acquisition of land like this for conservation is supported by the community through land trusts, parks and desire for a diversity of local recreational opportunities.

Land Ownership

  1. PG&E’s Pacific Forest and Watershed Lands Stewardship Council has property within the project study area. Stewardship Council lands were set aside to permanently protect watersheds lands either as donated land or conservation easements resulting from PG&E’s 2004 court settlement in U.S Bankruptcy Court.
    1. What is the land agreement for this property? Does this project fit within allowed land use under its conservation status?
  2. How and why are public lands owned by the State of California and Bureau of Land Management being made available for this project?
    1. How many acres of PG&E, BLM and State of California land would be lost or impacted by this project?
    2. Will public land be transferred, sold, leased if this project is implemented, or will it be maintained in the public trust? How will any loss of public land be mitigated in the public’s interest?
    3. What is the notification process and opportunity for public input on land ownership changes?
    4. How would project impacts to BLM-designated Sensitive species within the proposed project area affect federal BLM objectives for these sensitive species? How would the inundation of BLM-owned land affect those objectives?
    5. How would project impacts to species designated by the State of California as Fully Protected or Species of Special Concern and present within the proposed project area affect state objectives for these sensitive species? How would the inundation of State-owned land affect those objectives?

Regional Ecological Conservation and Restoration Efforts

  1. How would the proposed project affect the substantial federal, state, county, and private investments previously made in the Bear River Watershed, including but not limited to the BLM and CDFW land holdings that would be inundated by the proposed project, the watershed-wide US Bureau of Reclamation-funded Bear Watershed Restoration Plan, the Placer County Conservation Plan, the federally and state-funded acquisition of the Garden Bar Preserve by the Bear Yuba Land Trust and other conservation holdings and easements owned by them downstream of the proposed project site, conservation holdings and easements owned by the Placer Land Trust downstream of the proposed project site, CDFW lands downstream of the project site, and the Wildlands Conservation Bank which includes mitigation for Clean Water Act and Endangered Species Act impacts from past federally permitted projects?
    1. How would the proposed project affect water quality and flows at the downstream sites, and how would these in turn affect downstream riparian and aquatic habitat, and aquatic and riparian species at these sites?
    2. How would project-related impacts to special-status species, sensitive natural communities, and wildlife movement corridors affect the species and natural communities at downstream sites?

Recreation

It is clear that public access and recreation opportunities (camping, walking trails, fly fishing, tubing, panning) will be lost with this project. Primary river access and the majority of walking trails are along the stretch of the Bear River within the proposed reservoir’s footprint. Public access to reservoirs is readily available. However, river related activities are very limited.

  1. How many miles of trails will be lost and how many will remain available for recreation?
  2. How will aesthetic impacts of the “bathtub ring” during low water levels, be mitigated to support recreation?

    Greenhouse Gas Emissions
  1. Scientific studies indicate reservoirs can be a significant source of greenhouse gas emission from methane and carbon dioxide, which may increase based on variability in filling capacity
    1. What is the expected release of greenhouse gas emissions based on predicted climate models and reservoir filling capacities
    2. How does this proposed project fit with current Carbon Reduction State mandates in AB32 and Governor Brown’s 2015 Executive Order to reduce greenhouse gas emissions?
  2. How will reduction of grassland and forest carbon sequestration potential in the project’s footprint be mitigated?
  3. How could increased groundwater storage increase carbon and other greenhouse gas sequestration.

In addition to the proposed project, we request the following alternatives to be fully considered.

  • A no building alternative, which would support sustainable growth that is commensurate with water availability, while avoiding impacts to biological communities.
    1. Analyze the feasibility and effectiveness of Best Management Practices outlined by the USEPA.
  • An alternative that allows NID to achieve the project objectives through a combination of actions focused on a complete system-wide audit of existing water losses and available water conservation efforts by NID and water users, including but not limited to the following.
    1. Implement system upgrades minimizing leaks and spillage, increasing capacity in existing facilities, and reducing evaporation and percolation loss through unsealed/uncovered canals and above ground storage in the reservoir.
    2. Work with local agencies and landowners to implement erosion control measures, forest health and riparian restoration projects, and hydraulic diggings containment projects to reduce the quantities of sediment entering the current Bear River reservoir system, to protect the current water holding capacity of the existing reservoirs while improving water quality.
    3. Continue research and development of the Combie sediment and mercury removal project, to increase water storage capacity in the existing reservoirs while improving water quality.
    4. Perform a thorough analysis of water use by all customers and real incentives and conservation requirements should be established to increase conservation. Water conservation considerations should include charging true market value for water, educating the public and/or metering water use. The current price structure that includes a high water access fee and relatively low fees for each additional miner’s inch does not provide incentives for conservation; subscribers who use less than one miner’s inch of water pay significantly higher rates per gallon than those who use larger quantities.
    5. Implement reclamation and reuse of municipal, industrial, domestic, and agricultural wastewater as well as harvest rainwater for non-potable needs.
    6. Work with local agencies to develop building ordinances and codes that require new developments to implement water conservation best management practices including but not limited to requiring instillation of water conservation technologies (water efficient fixtures, gray water reuse systems, etc.), water efficient landscapes and stormwater management to decrease runoff and increase infiltration.
    7. Work with local agencies to develop incentives to upgrade current developments with water conservation best management practices including but not limited to requiring instillation of water conservation technologies (water efficient fixtures, gray water reuse systems, etc.), water efficient landscapes and stormwater management to decrease runoff and increase infiltration.
    8. The DEIS should include a comparison of upgrade costs and potential for water conservation, as compared to a new dam.

3) Analyze all possibilities to increase potential to accumulate and store ground water within the Bear and Yuba watersheds. Scientific research shows that healthy meadows and forests can provide and support sustainable ground water storage, with multiple watershed and stakeholder benefits, including more resilient ecosystem health and function, and providing gradual releases throughout year rather than flash flows, and economic benefits such as sustainable forestry and grazing, and social benefits such as enhanced recreational opportunities.

  1. Consider meadow and wetland protection and restoration possibilities, including Bear and Van Norden Meadows and the many other smaller meadows and wetlands for water storage. The release of this banked water during dry periods can increase late season baseflows that greatly benefit species and will also be a resource for water supply projects. Currently there are studies in the meadows in the Yuba and Bear watershed to investigate how these meadows respond to restoration treatments. The nearby Feather River Watershed has numerous meadow restoration projects examples that were completed at an average cost of $1,790/acre restored,[15] which corresponds to a cost of $1,630 – $6,840/AF of groundwater storage increase.[16]
  2. Consider forest management potential to increase water infiltration, reduce evapotranspiration and potential for high intensity wildfire, and increase carbon sequestration. These are addressed in part by Podolak et al., who concludes, “There are potential water supply benefits from watershed restoration in the northern Sierra Nevada, warranting an increased research effort to quantify the costs and benefits, and consideration by downstream beneficiaries like hydropower and water utilities.”[17] Initial estimates of water yield increases from thinning projects hypothesize >10,000 AF, empirical studies to quantify this hypothesis are inconclusive on how much water yield can be expected.[18] Similarly, North et al. conclude, “Sierra Nevada mixed-conifer forests could benefit from a new management strategy that goes beyond short-term fuel treatment objectives and incorporates long-term ecological restoration and habitat improvement into forestry practices. This strategy can be implemented using a multi-age silvicultural system to meet fuel reduction, ecosystem restoration, and wildlife habitat objectives. Important facets of the strategy include: Retention of suitable structures for wildlife nest, den, and rest sites; Stand-level treatments for sensitive wildlife; Forest structure heterogeneity and use of prescribed fire.”[19] The benefit of perusing these types of projects should be evaluated for their impact on protecting existing water and habitat resources as well as furthering the understanding the potential for water yield increases.
  3. Consider Merten formations,in the eastern portion of the Sacramento Valley and low foothills, and research Upper Watershed storage opportunities for potential groundwater storage.
  4. Work with GSAs formed under the SGMA in the Lower Bear River Watershed to collaborate on the GSP to provide a buffer against drought and climate change and contribute to reliable water supplies regardless of weather patterns.
  5. Create a Groundwater Management Plan for the Upper Bear River Watershed, possibly in partnership with local water agencies and CA Dept. of Water Resources, to provide a buffer against drought and climate change and contribute to reliable water supplies regardless of weather patterns.

Thank you in advance for rigorously analyzing these important issues within the DEIS.

Respectfully,

Joanne Hild
Executive Director
Sierra Streams Institute
431 Uren St., Suite C
Nevada City, CA 95959
(530) 265-6090 x200
joanne@sierrastreams.org

 

ENDNOTES

[1] 40 C.F.R. section 230.

[2] United States Department of Agriculture and The National Drought Mitigation Center. (2017) U.S. Drought Monitor. < http://droughtmonitor.unl.edu/>

[3] Udall, B. and J. Overpeck (2017), The twenty-first century Colorado River hot drought and implications for the future, Water Resour. Res., 53, doi:10.1002/2016WR019638.

[4] Nevada Irrigation District. 2009. Combie Reservoir Sediment and Mercury Removal— A Water Supply Maintenance Project. <http://nidwater.com/wp-content/uploads/2012/04/Project_Description.pdf>

[5] Dudek prepared for Nevada Irriagation District. 2015. Environmental Impact Report for the Bear River Sediment Removal at Rollins Reservoir. <http://nidwater.com/wp-content/uploads/2015/11/FEIR-BearRiverSedimentRemovalatRollinsReservoir151123.pdf>

[6] California Water Board. 2016. Impaired Water Bodies. State Water Resources Control Board. Sacramento, CA. <http://www.waterboards.ca.gov/water_issues/programs/tmdl/integrated2010.shtml>

[7] California Water Board. 2016. Impaired Water Bodies. State Water Resources Control Board. Sacramento, CA. <http://www.waterboards.ca.gov/water_issues/programs/tmdl/integrated2010.shtml>

[8] California Environmental Protection Agency. 2010. Sacramento – San Joaquin Delta Estuary TMDL for Methylmercury Staff Report. <http://www.waterboards.ca.gov/centralvalley/water_issues/tmdl/central_valley_projects/delta_hg/april_2010_hg_tmdl_hearing/apr2010_tmdl_staffrpt_final.pdf>

[9] United States Geological Survey. (1999) Mercury Bioaccumulation in Fish in a Region Affected by Historic Gold Mining: The South Yuba River, Deer Creek, and Bear River Watersheds, California, 1999.

[10] James J. Willacker, Collin A. Eagles-Smith, Michelle A. Lutz, Michael T. Tate, Jesse M. Lepak, Joshua T. Ackerman. “Reservoirs and water management influence fish mercury concentrations in the western United States and Canada,” Science of the Total Environment 568 (Oct 2016) 739-748. <https://www.researchgate.net/publication/299574010_Reservoirs_and_water_management_influence_fish_mercury_concentrations_in_the_western_United_States_and_Canada>

[11] Jones, A.B. and D.G. Slotton. 1996. Mercury Effects, Sources and Control Measures. San Francisco Estuary Regional Monitoring Program. SF Estuary Institute, Richmond, CA <http://www.sfei.org/sites/default/files/mercury.pdf>

[12] Junk WJ, Bayley PF, Sparks RE (1989). The flood pulse concept in river-floodplain systems. Aquatic Science 106:110–127

[13] Scott ML, Auble GT, Friedman JM (1996) Fluvial process and the establishment of bottomland trees. Geomorphology 14:327–339

[14] Kutner, L. S., and L. E. Morse. 1996. Reintroduction in a changing climate. In: Falk, D.A., C. I. Millar, and M. Olwell, (eds.). Restoring Diversity: strategies for reintroduction of endangered plants.Island Press, Washington, DC.

[15] Ecosystem Economics and Stillwater Sciences 2012. An Economic Analysis of Meadow Restoration. http://www.fs.fed.us/r5/hfqlg/monitoring/resource_reports/socioeconomics/Economic%20Analysis%20of%20Meadow%20Restoration%202012.pdf

[16] American Rivers 2012. Evaluating and Prioritizing Meadow Restoration in the Sierra. http://www.americanrivers.org/assets/pdfs/meadow-restoraton/evaluating-and-prioritizing-meadow-restoration-in-the-sierra.pdf?dad3dd

[17] Podolak, K., D. Edelson, S. Kruse, B. Aylward, M. Zimring, and N. Wobbrock. 2015. Estimating the Water Supply Benefits from Forest Restoration in the Northern Sierra Nevada. An unpublished report of The Nature Conservancy prepared with Ecosystem Economics. San Francisco, CA.

[18] The Nature Conservancy 2015. Estimating Water Supply Benefits from Forest Restoration in the Northern Sierra Nevada. http://www.nature.org/ourinitiatives/regions/northamerica/unitedstates/california/forest-restoration-northern-sierras.pdf; see also Gabrielle Boisrame, Sally Thompson, Brandon Collins, and Scott Stephens. 2016. Managed Wildfire Effects on Forest Resilience and Water in the Sierra Nevada. Ecosystems. DOI: 10.1007/s10021-016-0048-1.

[19] North, Malcolm; Stine, Peter; O’Hara, Kevin; Zielinski, William; Stephens, Scott. 2009. An ecosystem management strategy for Sierran mixed-conifer forests. Gen. Tech. Rep. PSW-GTR-220. Albany, CA: U.S. Department of Agriculture, Forest Service, Pacific Southwest Research Station.49 p.

 

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