January 29, 2014

Mr. Rob Wood SCO Planning & Engineering, Inc. 140 Litton Drive, Suite 240 Grass Valley, California 95945

Re: Waters of the United States Field Inventory Letter Report Truckee Springs Project JBR Project Number B.A13403.00

Dear Mr. Wood,

JBR Environmental Consultants, Inc. (JBR) performed field investigations of the Truckee Springs Project Site (survey area) in order to inventory all potential Waters of the United States (WOUS) that may exist within the project boundaries. An initial field investigation was performed on November 7, 2013, and a follow-up field visit was performed on January 23, 2014 to document the presence of surface waters within the survey area and document whether or not those waters have a connection to an already established jurisdictional waterway, such as the Truckee River.

WOUS are defined by 33 Code of Federal Regulations (CFR) 328.3 as:

1. All waters which are currently used, or were used in the past, or may be susceptible to use in interstate or foreign commerce, including all waters which are subject to the ebb and flow of the tide;

2. All interstate waters including interstate wetlands;

3. All other waters such as intrastate lakes, rivers, streams (including intermittent streams), mudflats, sandflats, wetlands, sloughs, prairie potholes, wet meadows, playa lakes, or natural ponds, the use, degradation or destruction of which could affect interstate or foreign commerce including any such waters:

i. Which are or could be used by interstate or foreign travelers for recreational or other purposes; or ii. From which fish or shellfish are or could be taken and sold in interstate or foreign commerce; or iii. Which are used or could be used for industrial purpose by industries in interstate commerce.

Mr. Rob Wood January 29, 2014 Page 2

4. All impoundments of waters otherwise defined as waters of the United States under the definition;

5. Tributaries of waters identified in paragraphs (a)(1)-(4) of this section;

6. The territorial seas; and

7. Wetlands adjacent to waters (other than waters that are themselves wetlands) identified in paragraphs (1)-(6) of this section.

The following terms are defined by 33 CFR 328.3 as:

The term “adjacent” means bordering, contiguous, or neighboring. Wetlands separated from other waters of the United States by man-made dikes or barriers, natural river berms, beach dunes and the like are "adjacent wetlands."

Wetlands are defined by the United States Army Corps of Engineers (USACE) and the Environmental Protection Agency in 40 CFR 230.3 and 33 CFR 328.3 as:

Those areas that are inundated or saturated by surface or ground water at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, and similar areas.

JBR reviewed the following databases for additional water resources information: National Wetland Inventory data, the United States Geological Survey (USGS) National Hydrographic Dataset, the Nevada Division of Water Resources data, USGS topographic maps, National Resources Conservation Service soils data, the National Gap Analysis Program vegetation data, aerial photographs, and previously performed surveys within and around the survey area.

Findings Field investigations discovered the presence of three wetland areas within the survey area (Wetlands 1 though 3). All water resources that exist within the survey area and their corresponding acreages have been mapped and are provided on Figure 1. However, the acreages provided are only estimates and may change if formal wetland delineations are conducted. A list of the hydrophytic vegetation that was identified within each wetland area is provided as Figure 2. Wetlands 1 through 3 are described in detail below.

Wetland 1 Wetland 1 is the historical ice skating pond that was constructed as a feature of the Ice Palace in the early twentieth century. Even though Wetland 1 is a man-made feature, it supports a highly functional wetland ecosystem and shares a surface connection with the Truckee River. Wetland 1 is supported by a spring-fed stream that begins approximately 200 feet up-gradient from the pond. A small diversion forces some of the water being conveyed in the stream into Wetland 1, while the rest of the water continues traveling north, down the drainage towards the Truckee River. The stream crosses the dirt access road into the survey area and continues to support a

Mr. Rob Wood January 29, 2014 Page 3 variety of grass, sedge, rush, and willow species until it leaves the survey area. JBR mapped what are likely to be the extents of this wetland and found that Wetland 1 encompasses approximately 0.78 acres within the survey area. Since water leaving Wetland 1 has the potential to enter the Truckee River, Wetland 1 would be considered to be a jurisdictional feature and would be subject to regulation under Section 401 of the Clean Water Act.

Wetland 2 Wetland 2 is an isolated spring site that supports a small wetland community near the center of the survey area. The spring is located in a thicket of aspen, Geyer’s willow, and a variety of berry bushes. Water being discharged from this spring flows north for approximately 50 feet until it infiltrates into the soil, where it supports a small community of hydrophytic grasses. JBR estimated the size of this wetland area to be approximately 0.062 acres. Since the water being discharged from the spring does not connect with the Truckee River, it is JBR’s opinion that Wetland 2 would be considered an isolated feature and would not subject to regulation under Section 401 of the Clean Water Act.

Wetland 3 Wetland 3 is the riparian buffer that exists along the edge of the Truckee River throughout the survey area. A number of hydrophytic species are supported by the shallow groundwater that exists in this area, including black cottonwood, Lemmon’s willow, shinning willow, as well as a variety of shrub and grass species. This area is seasonally inundated when the Truckee River is experiencing elevated flows, typically in the spring months when snowmelt runoff contributes flows to the river. JBR estimated the size of this wetland to be approximately 2.29 acres. Since Wetland 3 is directly adjacent to an established jurisdictional waterway, the Truckee River, it too would be considered to be a jurisdictional feature and would be subject to regulation under Section 401 of the Clean Water Act.

Discussion The field investigations in the survey area are considered preliminary until a formal WOUS delineation is completed, a delineation report is submitted to the USACE, and a Jurisdictional Determination is received from the USACE.

The field investigations documented the presence of three wetland areas, two of which (in our opinion) would be considered jurisdictional features under the USACE. If SCO Planning & Engineering, Inc. (SCO) plans on impacting Wetlands 1 and 3, federal permits will be required for disturbance activities and mitigation measures may be required for SCO to be released of permit obligations.

Similarly, state permits, issued by the California Regional Water Quality Control Board, Lahontan Region, will be required for activities that impact any of the wetland areas identified by JBR. Should it be required, JBR can assist SCO with this process; however, it is recommended that impacts to Wetlands 1 through 3 be avoided wherever possible. By avoiding these features, SCO will not need to be issued a permit from state or federal agencies, as long as Best Management Practices are utilized during ground disturbing activities to prevent any illicit discharges of construction site runoff from entering nearby waters.

Mr. Rob Wood January 29, 2014 Page 4

Should you have any questions, please do not hesitate to contact me at (775) 747-5777, or email me at [email protected].

Sincerely,

JBR ENVIRONMENTAL CONSULTANTS, INC.

Matthew McKissick Hydrologist

Attachments Figure 1 – Estimated Wetland Boundaries Figure 2 – Vegetation Species List per Wetland Area

FIGURES

¨¦§80

er Wetland 1 iv R 0.78 acres ee ck ru T Wetland 2 0.062 acres

Wetland 3 2.29 acres d x m . s e i r a d n u o B _ d n a l t e W _ d e t a m i t s E _ 1 _ e r u g i F \ s D X M g n i k r o W \ s D X M \ 0 0 0 4 8 9 0 A P _ s g n i r Feet p S

_ 200 100 0 200 e e k

c $ Basemap: Source: Esri, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community u r T \ g n i r e e

n SCO PLANNING AND ENGINEERING i

g Project Boundary n

E TRUCKEE SPRINGS PROJECT _ g n i n n a l Estimated Wetland Boundary P

_ FIGURE 1 O C

S ESTMATED WETLAND BOUNDARIES \ s t n e i DRAWN DATE l BY DRAWN C

\ CHJ 1/28/2014 A

C SCALE \ : 1 in = 200 feet X

:

h PROJECT t a B.A13403.00 P This document is for reference purposes only and should not be used as a legal document. JBR makes no guarantees to the accuracy of the data contained herein or any loss resulting therefrom. Figure 2. Vegetation Species List per Wetland Area

Wetland Estimated Area Lifeform Family Genus Species subspecies/variety Common name Invasive/Noxious Indicator % cover Status WMVC* Invasive (moderate) Wetland 1 Forb Asteraceae Cirsium vulgare bull thistle FACU T Noxious list C Wetland 1 Forb Rosaceae Geum macrophyllum large leaf avens FAC T Wetland 1 Graminoid Juncaceae Juncus balticus Baltic rush FACW 15 Wetland 1 Graminoid Typhaceae Typha latifolia broad leaf cattail OBL 25 Wetland 1 Shrub Salicaceae Salix lemmonii Lemmon's willow FACW 20 Wetland 1 Tree Salicaceae Populus tremuloides aspen FACU 10 Wetland 2 Forb Rosaceae Achillea millefolium common yarrow N/L 5 Wetland 2 Graminoid Juncaceae Juncus balticus Baltic rush FACW 25 Wetland 2 Graminoid Poaceae Elymus glaucus blue wildrye FACU 10 Wetland 2 Graminoid Poaceae Leymus triticoides creeping wildrye FAC 20 Wetland 2 Shrub Asteraceae Artemesia tridentata var. vaseyana mountain sagebrush N/L 3 Wetland 2 Shrub Rosaceae Amalanchier alnifolia serviceberry N/L 7 Wetland 2 Shrub Rosaceae Prunus emarginata bittercherry FACU 7 Wetland 2 Shrub Rosaceae Symphoricarpos rotundifolius mountain snowberry N/L 5 Wetland 2 Tree Salicaceae Populus tremuloides aspen FACU 20 Wetland 2 Tree Salicaceae Salix geyeriana Geyer's willow FACW 20 Wetland 3 Forb Apiaceae Conium maculatum poison hemlock Invasive (moderate) FAC T Wetland 3 Forb Asteraceae Centaurea stoebe ssp. micranthos spotted knapweed Invasive (high) N/L T Wetland 3 Forb Brassicaceae Thlapsi arvense field pennycress N/L T Wetland 3 Forb Fabaceae Melilotus sp. sweetclover N/L T Wetland 3 Forb Hypericaceae Hypericum ? Klamathweed? Noxious list C ? T Wetland 3 Forb Labiaceae Mentha arvense field mint FACW T Wetland 3 Forb Plantaginaceae Plantego lanceolata English plantain Invasive (limited) FACU T Wetland 3 Graminoid Cyperaceae Carex pellita woolly sedge FACW 10 Wetland 3 Graminoid Poaceae Agrostis stolonifera creeping bentgrass FAC 5 Wetland 3 Graminoid Poaceae Bromus inermis smooth brome FAC 7 Wetland 3 Graminoid Poaceae Elymus glaucus blue wildrye FACU 10 Wetland 3 Graminoid Poaceae Hordeum brachyantherum meadow bareley FACW T Wetland 3 Graminoid Poaceae Leymus triticoides creeping wildrye FAC 10 Wetland 3 Shrub Asteraceae Artemesia tridentata var. vaseyana mountain sagebrush N/L T Wetland 3 Shrub Asteraceae Ericameria nauseosus rubber rabbitbrush N/L T Wetland 3 Shrub Betulaceae Alnus incana ssp. tenuifolia mountain alder FACW 10 Wetland 3 Shrub Cornaceae Cornus sericea red osier dogwood FACW T Wetland 3 Shrub Rosaceae Purshia tridentata bitterbrush N/L T Wetland 3 Shrub Rosaceae Rosa woodsii Wood's rose FACU T Wetland 3 Tree Salicaceae Populus balsimafera ssp. trichocarpa black cottonwood FAC 7 Wetland 3 Tree Salicaceae Salix lemmonii Lemmon's willow FACW 10 Wetland 3 Tree Salicaceae Salix lucida ssp. lasiandra shinning willow FACW 10 * Lichvar, R.W. 2013. The National Wetland Plant List: 2013 wetland ratings. Phytoneuron 2013-49: 1-241.